Motor carriers with employees who supervise CDL drivers are required to provide reasonable suspicion training under 49 CFR § 382.603. The training prepares supervisors to recognize signs of possible drug use or alcohol misuse and determine when a driver may need to be referred for DOT reasonable suspicion testing.
The requirement is straightforward: designated supervisors must receive at least 120 minutes of training, including:
For most supervisors, this is a one-time training requirement. FMCSA does not require recurrent supervisor training under § 382.603.
Who Needs DOT Supervisor Training?
If your company employs CDL drivers subject to FMCSA drug and alcohol testing regulations, anyone you designate to supervise those drivers and make reasonable suspicion determinations must receive the required training.
An owner-operator who is both the employer and the only employee is not required to complete reasonable suspicion supervisor training. An owner-operator who hires or supervises other CDL drivers may no longer fall under that exception.
The key question is whether you supervise CDL drivers covered by the DOT drug and alcohol testing program. If you do, you should complete the required training before making reasonable suspicion determinations.
DOT Reasonable Suspicion Training
You do not need to purchase a private training course to meet the FMCSA supervisor training requirement. FMCSA’s own supervisor training guidance identifies the Federal Transit Administration’s Reasonable Suspicion Training as a resource motor carriers can use to train supervisors. FMCSA requires at least 60 minutes on alcohol misuse and 60 minutes on controlled substances use under 49 CFR § 382.603.
The U.S. Department of Transportation’s Federal Transit Administration (FTA) provides a free, two-hour Reasonable Suspicion Testing for Supervisors course covering those same drug and alcohol training areas. The current FTA course provides the full two hours of training content and is an official U.S. DOT resource.
After completing the full two-hour course, the supervisor can enter their name and download a PDF certificate of completion for the company’s compliance records.
Free U.S. DOT Reasonable Suspicion Training Course
What Does Reasonable Suspicion Training Cover?
The purpose of the training is not to teach supervisors to diagnose drug or alcohol use. Instead, supervisors learn to recognize specific, contemporaneous observations involving a driver's appearance, behavior, speech and performance that may establish reasonable suspicion.
When reasonable suspicion exists, the trained supervisor can refer the driver for the appropriate DOT drug and/or alcohol test. FMCSA requires employers to ensure that supervisors making these determinations have received the training required by § 382.603.
What Happens When Reasonable Suspicion Exists?
A trained supervisor must base the determination on observations of the driver rather than a third-party report or guess. Once the employer determines that reasonable suspicion exists, the driver should be removed from safety-sensitive functions as appropriate and sent for the required DOT test in accordance with FMCSA procedures.
DOTConsortium.com customers can order reasonable suspicion, pre-employment, random, post-accident, return-to-duty and follow-up testing through the same platform used to manage their DOT drug and alcohol compliance program.
Keep Your Supervisor Training Records
After completing supervisor training:
FMCSA may review supervisor training and supporting reasonable suspicion documentation during a compliance investigation.
Frequently Asked Questions
Do owner-operators have to complete supervisor training?
An owner-operator who is the employer and only employee and does not supervise other CDL drivers is not subject to the requirement.
Is Reasonable Suspicion Training Required Every Year?
No. FMCSA describes the § 382.603 requirement as a one-time two-hour training requirement. There is no federal requirement to repeat the course annually.
How many hours of reasonable suspicion training are required?
FMCSA requires at least 120 minutes total: 60 minutes on alcohol misuse and 60 minutes on controlled substances use.
Can I take DOT reasonable suspicion training for free?
Yes. The U.S. DOT's Federal Transit Administration provides a free two-hour supervisor training course and allows participants who complete the full course to download a PDF certificate.
Does reasonable suspicion training expire?
FMCSA does not require recurrent training under § 382.603. The supervisor training requirement is generally one-time.
Who should keep the training certificate?
The motor carrier should retain documentation establishing that supervisors responsible for reasonable suspicion determinations received the required training.