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Department of Transportation Training Requirements
Reasonable Suspicion Training for Supervisors Overview

You may be out of compliance with Federal Regulations if your company has not provided the required training to your supervisors that oversee your safety-sensitive employees.  Most operating agencies of the Department of Transportation (DOT) require at least two hours of training to supervisors in recognizing the signs and symptoms of drug and alcohol use.  You may have heard this type of training called “60/60 training” or “60-60 training for supervisors”.  This “60/60” term came about because most modal agencies require 1-hour of training on recognizing the signs and symptoms of alcohol use/abuse and 1-hour of training in recognizing the signs and symptoms of drug use.

Below is a breakdown of the various Operating Agency requirements:

Federal Motor Carrier Safety Administration (FMCSA) – This agency oversees the motor carrier industry — most trucking companies with CDL drivers and the FMCSA also covers school bus companies. This is the largest of the DOT’s operating agencies.
Reasonable Suspicion (Signs & Symptoms) Training Requirements:  The FMCSA requires one-hour of training on the specific, contemporaneous physical, behavioral, and performance indicators of probable drug use, and also one-hour of training on the specific, contemporaneous physical, behavioral, and performance indicators of probable alcohol use.   If you are covered by the FMCSA, A TOTAL OF 2 HOURS OF TRAINING IS REQUIRED FOR YOUR SUPERVISORS.

Federal Aviation Administration (FAA) – This agency oversees the airline industry (air carriers or operators and certain contract air traffic control towers).
Reasonable Suspicion (Signs & Symptoms) Training Requirements:  The FAA requires one-hour of training on the specific, contemporaneous physical, behavioral, and performance indicators of probable drug use.  Reasonable recurrent training is also required. In addition, one-hour of training is required on the physical, behavioral, speech, and performance indicators of probable alcohol misuse.  If you are covered by the FAA, A TOTAL OF 2 HOURS OF TRAINING IS REQUIRED FOR YOUR SUPERVISORS.

Federal Railroad Administration (FRA) – This modal agency oversees the railway industry (locomotives/trains).
Reasonable Suspicion (Signs & Symptoms) Training Requirements:  The FRA requires that those persons supervising “regulated workers” receive training on the specific, contemporaneous physical, behavioral, and performance indicators of probable drug use; and training on probable indicators of alcohol use.
Prior to June 12, 2017, the FRA Rules required this training to be a minimum of two hours.  However, the Rules were changed and now simply require the training, but also added coverage for maintenance-of-way workers (MOW employees).  Therefore, those in supervisory positions over FRA-covered MOW employees must now also receive the training.

Special note:  The FRA also requires that all supervisors receive post-accident determination training.   Failure to ensure that your supervisors receive the required training may subject you to severe penalties.

See Certified Training Solutions “Combo Course” for FRA, which includes both the Reasonable Suspicion Training for DOT-covered Supervisors and the FRA Post-accident Determination Training Course.

Certified Training Solutions’ Reasonable Suspicion course and FRA Post-accident course are APPROVED by the FRA as Model Courses.

Federal Transit Administration (FTA) – This operating agency of the DOT oversees the public transportation industry, such as those involved in the revenue vehicle industry. The FTA also covers those in the armed security sector.
Reasonable Suspicion (Signs & Symptoms) Training Requirements:  The FTA requires one-hour of training on the specific, contemporaneous physical, behavioral, and performance indicators of probable drug use, and one-hour of training required on the specific, contemporaneous physical, behavioral, and performance indicators of probable alcohol use.  If you are covered by the FTA, A TOTAL OF 2 HOURS OF TRAINING IS REQUIRED FOR YOUR SUPERVISORS.

Pipeline and Hazardous Materials Safety Administration (PHMSA) – This operating agency of the DOT oversees those working in the pipeline industry and also liquefied natural gas (LNG) facilities.

Reasonable Suspicion (Signs & Symptoms) Training Requirements:  The PHMSA requires one-hour of training on the specific, contemporaneous physical, behavioral, and performance indicators of probable drug use. One-hour of training is also required on the specific, contemporaneous physical, behavioral, and performance indicators of probable alcohol use.
United States Coast Guard (USCG) – The USCG oversees the maritime industry.  Although the Coast Guard is now under the Department of Homeland Security, their drug and alcohol testing rules are closely related to the Department of Transportation testing requirements.
Reasonable Suspicion (Signs & Symptoms) Training Requirements:  USCG supervisors must have at least 60 minutes’ training on the effects of drug and alcohol use on personal, health, safety, and the work environment; and the behavioral indications of drug use/abuse.
Certified Training Solutions offers convenient, online courses to help you meet the various DOT Operating Agency requirements for supervisor training.  Our online training is self-paced, and your learners may start the course at any time, 24 hours a day (instant access is granted once payment is made)!

Our online training course is easy-to-use and consists of three training modules and three quizzes.  After completing our online Reasonable Suspicion Training course, the supervisor is immediately presented with his or her Certificate to print (no waiting!).

Click here for more details on our Reasonable Suspicion (Signs and Symptoms) Training Course for DOT-covered Supervisors, or call us at 307-640-5859.

If you would like more details on the various DOT Operating Agency requirements for both supervisor and employee training, along with “need to know” information relating to your specific operating agency, please click here for the publication “DOT Agency / USCG Drug and Alcohol Program Facts”, or you may copy and paste the following link into your browser address bar: https://www.dot.gov/sites/dot.dev/files/docs/ODAPC%20EmployeeHandbook%20En.pdf
Other suggested reading for all DOT-covered employers is the publication:  “What Employers Need To Know About DOT Drug and Alcohol Testing [Guidance and Best Practices]”

The information presented here is meant to provide general information and guidance. Information is deemed reliable but not guaranteed.  Legal advice must be provided in the course of an attorney-client relationship specifically with reference to all the facts of the particular situation under consideration. Such is not the case here, and accordingly, the information presented here must not be relied on as a substitute for obtaining legal advice from a licensed attorney and/or the U.S. Department of Transportation Office of the General Counsel.  When in doubt, check with your corporate legal counsel and/or the U.S. Department of Transportation Office of the General Counsel or an agent of the operating agency that covers your industry.  Certified Training Solutions is not responsible or liable for any loss or damage relating to the use of the information in this article. Before relying on the material in any important matter, users should carefully evaluate its accuracy, currency, completeness and relevance for their purposes, and should obtain any appropriate professional advice relevant to their particular circumstances.

© Certified Training Solutions – Original Copyright May 2015.  Updated August 2018

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