Is Recurrent Reasonable Suspicion Training Required for DOT Supervisors?

It depends on the DOT agency. FMCSA rule 49 CFR 382.603 states that recurrent training for supervisory personnel is not required. FAA rule 14 CFR 120.115(c)(4) requires a reasonable recurrent training program for supervisory personnel making reasonable cause drug testing determinations during subsequent years.

The supervisor training sections for these agencies set training requirements without mentioning recurrent training:

• FTA, 49 CFR 655.14(b)(2), at least 60 minutes on probable drug use and at least 60 minutes on probable alcohol misuse
• PHMSA, 49 CFR 199.113(c) and 199.241, one 60-minute period on probable drug use and at least 60 minutes on probable alcohol misuse
• FRA, 49 CFR 219.11(g), training in the signs and symptoms of alcohol and drug influence, intoxication and misuse
• FAA alcohol testing, 14 CFR 120.223(b), at least 60 minutes on the indicators of probable alcohol misuse

The FAA recurrent requirement appears in the drug testing EAP section, 120.115, and the FAA rules are covered in What Reasonable Cause Training Must FAA Supervisors Complete?. The FMCSA rule for supervisors of CDL drivers is covered in What Is Reasonable Suspicion Testing for CDL Drivers?.

Collectors follow a different pattern. Under 49 CFR 40.33(e) and 40.35(e), urine and oral fluid collectors complete refresher training no less frequently than every five years. Under 49 CFR 40.213(e), breath alcohol technicians and screening test technicians also complete refresher training no less frequently than every five years.

Learn Laws® offers FAA Annual Recurrent Training for Supervisors, a recurrent course of about 1 hour for FAA supervisors who make reasonable cause drug testing decisions.

In the location details of some trainer profiles in the MyDrugTesting.com directory, a Call to Schedule button appears beside Show Phone.