Reasonable Suspicion Training: Preparing Your Supervisors for a Tough Situation

Reasonable suspicion determinations are one of the hardest calls a supervisor has to make. You're essentially looking at a driver and deciding, based on observable behavior, that there's enough evidence to warrant a drug or alcohol test. Get it right and you've potentially saved lives. Handle it poorly and you're exposed to grievances, lawsuits, and your own liability.

That's exactly why training isn't optional — it's federally mandated for any company with CDL drivers.

Training Requirements

Every person who may make a reasonable suspicion determination about a CDL driver must complete:

• 60 minutes of drug awareness training
• 60 minutes of alcohol awareness training

Training must cover the physical, behavioral, speech, and performance indicators of probable drug use and alcohol misuse. Keep certificates of completion in your files — indefinitely.

What to Watch For

The observations must be specific, contemporaneous, and articulable — meaning you saw it happen, you can describe exactly what you saw, and you documented it right away:

• Slurred speech, unsteady gait, abnormal coordination
• Bloodshot or glassy eyes
• Smell of alcohol on breath
• Unusual behavior — agitation, paranoia, excessive drowsiness
• Sudden decline in job performance or attendance
• Physical evidence — paraphernalia, substances in vehicle

It's not about having a bad day. It's about observable, documented signs that would lead a reasonable person to suspect impairment.

The Process

1. Observe and document — Write down exactly what you see, hear, and smell. Be specific: "driver had glassy eyes and slurred speech at 7:15 AM on March 2" — not "driver seemed off."
2. Consult if possible — If another trained supervisor is available, get their observation too. Two sets of eyes are better than one for documentation purposes.
3. Remove the driver from safety-sensitive duty immediately — Safety-sensitive functions include driving, loading/unloading, vehicle inspection, and any time spent waiting to drive. Do not let the driver perform any of these.
4. Arrange testing — Alcohol testing should happen within 2 hours (must happen within 8 hours or document why it didn't). Drug testing should happen within 32 hours. These are different windows — don't mix them up.
5. Arrange transportation — The driver cannot drive themselves to the collection site or home.

After the Test

If negative: the driver returns to duty. Document everything and retain the file.

If positive: follow your return-to-duty procedures — SAP (Substance Abuse Professional) referral, removal from safety-sensitive functions, reporting to the Clearinghouse (the FMCSA's online database that tracks CDL driver drug and alcohol violations).

If you didn't test (because the window expired): document why testing didn't occur. This documentation is critical if the situation is ever questioned.