Jenkins Academy of Applied Technology · DOT-102 · v1.0.0

FMCSA Supervisor Reasonable-Suspicion Training — learner reference

Course developed by Todd Jerome Jenkins, MS, CSP.

Course overview and registered classroom

Public learner reference. Reading or printing this file does not record course time or award completion. Use the registered classroom for separate alcohol/drug instruction, exercises, checks and assessment. Use fictional facts only.

Two distinct instruction blocks: at least 60 minutes on alcohol misuse and 60 minutes on controlled-substances use, addressing physical, behavioral, speech and performance indicators and reasonable-suspicion decisions under 49 CFR 382.603/382.307. Free registered course with recorded participation, case exercises and assessment.

1. Alcohol: physical indicators and immediate safety

Describe observed physical signs without diagnosing or delaying urgent care.

Alcohol misuse · 10-minute instruction activity. Start the study session below before reading. Suggested allocation: 4 minutes reading/listening,4 minutes case analysis,1 minute debrief/correction and 1 minute practice. Take longer if needed; breaks and final testing are additional.

Supervisors designated to supervise covered CDL drivers need instruction in recognizing probable alcohol misuse and controlled-substances use. This course separates those subjects into two 60-minute blocks. DOT-101 is useful background, but is not a substitute for either block. The employer must verify the actual driver/vehicle/operation coverage, designate supervisors and explain its own testing and emergency arrangements. Recurrent training is not mandated by 382.603, although an employer may require additional instruction.

Alcohol can disrupt judgment, attention, coordination and movement. Physical observations may include unsteady walking, fumbling an ordinary object, difficulty maintaining balance or a noticeable odor associated with the person. Record the actual behavior, location, time, distance and context. “Dropped keys twice while unlocking the cab” tells a reviewer more than “looked drunk.” Do not ask the driver to perform a balance test, estimate an alcohol concentration from appearance or treat an odor as a measurement.

These observations are not exclusive to alcohol. Illness, an injury, fatigue, medication effects, a mobility limitation, a slippery surface or environmental conditions may explain a sign. Acknowledge plausible alternatives and ask factual, limited questions while addressing immediate safety. You need not diagnose a cause to stop an unsafe vehicle movement and seek assistance. You also must not use a known disability, appearance or medical history as a substitute for current articulable observations.

Inability to wake, serious breathing difficulty, seizures or another acute emergency calls for the emergency response route. Arrange emergency medical assistance promptly and follow dispatcher instructions and your actual training. Do not leave an acutely ill person alone or tell them to drive for help. Coffee, a cold shower and a walk do not make an impaired person ready to drive. Medical care takes priority over obtaining a test.

Fictional supervisor case

At 06:45, before dispatch, you see Morgan drop a key ring twice, hold the cab rail while standing, and sway on level pavement. You notice an alcohol-like odor near Morgan, but a spilled cleaning product is also nearby. Morgan’s speech is understandable and Morgan says, “I feel dizzy.”

Work through the decision

Write an objective note identifying three direct observations, the odor’s uncertainty, immediate vehicle/movement protection, a medical-help decision and the employer contact. Identify what you cannot conclude.

Compare your reasoning: case debrief

A strong response preserves the key drops, use of the rail, swaying, time and location; it does not convert an uncertain environmental odor into a confirmed breath odor. Hold unsafe movement, assess urgent medical needs and notify the actual designated route. Dizziness merits attention. Do not assign a BAC, diagnose intoxication, require a field sobriety performance or wait for a crash.

Deeper study: DOT-101 — Recognizing and escalating possible impairment. For timing arithmetic, MAT-101 — units and technical problem solving is optional study support; formal MAT enrollment remains closed. This lesson supplies the required clock explanations locally.

Basis: 49 CFR 382.603,382.307; NIAAA alcohol effects and overdose guidance

2. Alcohol: behavior, speech and contextual observations

Distinguish specific behavioral and speech indicators from labels, rumor and bias.

Behavioral indicators may include a marked change in restraint, unusual argumentativeness, inappropriate joking during a serious task, difficulty following a familiar discussion or repeating the same question without retaining the answer. Speech may be slurred, unusually slow, difficult to understand or inconsistent with the person’s normal communication in the situation. Describe the actual words, delivery and behavior. A broad label such as “bad attitude” does not identify what another reviewer needs to know.

Language, accent, anxiety, a speech difference or disagreement with a supervisor is not evidence of alcohol misuse. Compare like circumstances and document uncertainty. A new supervisor may not know the person’s baseline; say that rather than inventing one. Do not rely on stereotypes, protected reporting activity, dislike or the idea that a quiet person must be hiding something. A specific current observation can support action; a label about identity cannot replace it.

A coworker’s report is useful information to receive and document with its source. It does not become your direct observation merely because you believe the coworker. For the DOT reasonable-suspicion decision, the required observations must be made by a supervisor or company official who has the required training. Arrange prompt appropriate observation without sending an unsafe driver onto a route to obtain more evidence. One appropriately trained observer can meet the federal observation requirement; a company may seek a second if available without delaying protection or testing.

Use respectful factual questions: “I heard you repeat the dispatch instruction three times and your words were difficult for me to understand. Are you having a medical emergency?” Keep the encounter private where safe. Explain immediate steps without demanding a confession, arguing over a diagnosis or promising that no one will ever see the record.

Fictional supervisor case

A coworker reports that Sam “was drinking at lunch.” You did not see lunch. At 12:55 you hear Sam repeat “Which gate?” three times after clear directions and hear several words run together. Sam becomes loud when told the truck will remain parked. Another employee suggests that Sam’s accent explains everything.

Work through the decision

Separate direct observation, reported information and interpretation. Draft a neutral opening statement and explain why neither the rumor nor the accent should decide the test referral.

Compare your reasoning: case debrief

Keep the lunch allegation attributed to its source. Record the repeated question, actual speech difficulty and loud response without treating the accent or disagreement as the basis. Have the trained official evaluate current facts and medical needs. A private, direct explanation and a safe hold are stronger than a confrontation or a vote by coworkers.

Basis: 49 CFR 382.307(a),(c); FMCSA supervisor guidance

3. Alcohol: performance, risk and observation quality

Connect performance observations to immediate risk without manufacturing a test trigger.

Alcohol may affect divided attention, judgment and reaction before a person appears dramatically intoxicated. A supervisor might observe missed steps in a familiar inspection, repeated difficulty using ordinary controls, delayed responses to a clear instruction or an unsafe backing movement. Describe the task, instruction, response and surrounding conditions. The event needs protection and review even when the cause is uncertain.

Performance errors also arise from poor instructions, unfamiliar equipment, fatigue, inadequate lighting, conflicting signals and other work conditions. A failed task does not automatically become a drug or alcohol event. Look for specific contemporaneous observations supporting the actual reasonable-suspicion standard. Do not dispatch someone into traffic, ask for a hazardous demonstration or stage a surprise equipment test to see whether a concern is real.

Keep different processes distinct. A preventable backing contact can require an operational investigation; that does not by itself meet the federal post-accident testing rule or the reasonable-suspicion observation rule. Post-accident testing has its own crash/citation conditions. Actual knowledge of prohibited use has a specific definition and separate employer obligations. Do not select a testing label merely because it is easier to arrange.

A fair observation record includes time, place, task, conditions, what you personally saw or heard, relevant statements, medical/safety actions and the responsible decisionmaker. Do not revise an original note later to make it sound more certain after a result arrives. Preserve an identified correction or supplement. If a second trained official observes something different, retain both accounts and explain the decision on the available facts rather than erasing the disagreement.

Fictional supervisor case

At 14:10 a driver misses a stop signal while backing. The spotter’s radio battery was dead and the rear work light was out. During the safe stop, you observe the driver struggle repeatedly with a familiar buckle and hear slowed, slurred replies. A manager wants the error alone labeled “DOT post-accident.”

Work through the decision

Describe the work-system problems separately from personal indicators, name the immediate controls, and explain which testing determinations still require their own factual review.

Compare your reasoning: case debrief

Stop the movement and restore safe arrangements; preserve the radio/light problems as real system issues. Describe the buckle difficulty and specific speech observations for the trained official’s 382.307 review. Check any crash rule independently. Do not treat an error, lack of injury or later test result as proof that the other conditions are irrelevant.

Basis: 49 CFR 382.107,382.307; NHTSA drunk-driving information

4. Alcohol: referral rules, clocks and duty restrictions

Apply the alcohol-specific decision and timing rules using the correct starting event.

The reasonable-suspicion alcohol observation and direction to test must have the required relationship to safety-sensitive work: during, just before or just after that period. Base the determination on specific current observations made by the appropriately trained supervisor or official. The official who makes the alcohol reasonable-suspicion determination must not conduct that driver’s alcohol test. A separate qualified technician performs the test under Part 40.

Arrange testing promptly. If a required alcohol test is not administered within two hours after the reasonable-suspicion determination, make and retain the reasons. At eight hours after the determination, cease alcohol testing attempts and record why the test was not administered. These are not the post-accident clock starting points, and the deadlines are not permission to wait. Keep contacting the authorized route while meeting medical and protective needs.

If the relevant behavioral, speech and performance indicators show alcohol influence or impairment without an alcohol test, do not permit safety-sensitive work until an alcohol test is below 0.02 or 24 hours have elapsed after the reasonable-suspicion determination, as specified in 382.307(e)(2). This is a distinct rule from a measured 0.02-to-below 0.04 result: that result requires the next regularly scheduled duty period and at least 24 hours after the test. A 0.04-or-greater result and other violations trigger the separate removal/referral process. No automatic return is appropriate if another medical, license or lawful employer restriction remains.

Sign the observations within 24 hours of the observed behavior or before results are released, whichever is earlier. Except for the specified no-test duty restriction, behavior/appearance alone does not authorize other action under Part 382 against a driver for alcohol use without an alcohol test. Independent employer authority must be separately identified and lawfully applied.

Fictional supervisor case

You make a qualifying alcohol determination at 09:20. At 11:20 no test has been administered because the available site could not supply a technician. At 17:20 there is still no test. A dispatcher suggests the driver can work now because the shift is nearly over.

Work through the decision

Build the two-hour and eight-hour record, identify the continuing no-test restriction, and distinguish its clock from the 0.03-result and post-accident clocks.

Compare your reasoning: case debrief

Document the delay at 11:20 and cease alcohol test attempts with reasons at 17:20. Do not treat the end of a shift as the required no-test restriction ending. The no-test rule runs from the 09:20 determination; a 0.03 test would have a separate test-based next-duty-period/24-hour rule. Check other restrictions before any return.

Deeper study: DOT-101 — Prohibitions and result distinctions. For timing arithmetic, MAT-101 — units and technical problem solving is optional study support; formal MAT enrollment remains closed. This lesson supplies the required clock explanations locally.

Basis: 49 CFR 382.307(d)–(f),382.505,382.201–382.209

5. Alcohol: respectful conversation and collection handoff

Explain a factual referral, protect the person and preserve distinct testing roles.

Prepare the actual employer contact route before an event. Know who can authorize and coordinate testing, which qualified collection service is available after hours, how transport is arranged and how immediate duty restrictions are communicated without exposing confidential detail. A general phone number that nobody answers is not a verified response arrangement.

Use a calm, direct statement grounded in observations: identify what you saw or heard, explain that covered work will stop, describe the required test and the next step. “I am referring you under the company’s DOT procedure because of these observations” is clearer than demanding an admission. Invite information about immediate medical needs without asking the supervisor to interpret an entire medical history. An admission may raise a separate actual-knowledge issue for the designated representative; preserve it accurately rather than bargaining away the process.

Do not promise that a test will be negative, that the person will be fired or that every record will remain secret under all circumstances. Explain that authorized program personnel will handle results and applicable duties. A supervisor’s observation supports a referral, not a medical diagnosis or a verified laboratory result. Keep public dispatch communications limited to the operational restriction and replacement arrangement.

Plan safe escorted transport using the employer’s procedure; do not allow a possibly impaired driver to drive to the collection site or home. If the person becomes threatening or leaves, protect others, use emergency/security resources when necessary, record facts and notify the authorized employer representative. Refusal decisions depend on the applicable rule and actual circumstances. Physical detention, intimidation or an improvised search is not the supervisor’s training role.

Fictional supervisor case

A driver says, “If I take the test you have to promise nobody will know, and I can drive myself there.” The observer is also a qualified alcohol technician and the only technician presently in the yard.

Work through the decision

Draft a short factual referral statement, a truthful confidentiality explanation and safe transport/technician arrangements. Identify the conflict that prevents this observer from performing this alcohol test.

Compare your reasoning: case debrief

Explain the observations and authorized process without a secrecy or result promise. Arrange safe transport and another qualified technician. The observer’s separate technician credential does not override 382.307(c), which prohibits that person from conducting this driver’s reasonable-suspicion alcohol test. Document delay reasons if the clock requires it.

Deeper study: DOT-101 — Testing integrity and employee rights. For timing arithmetic, MAT-101 — units and technical problem solving is optional study support; formal MAT enrollment remains closed. This lesson supplies the required clock explanations locally.

Basis: 49 CFR 382.307;49 CFR 40 testing roles; employer response exercise

6. Alcohol: integrated decision and observation exercise

Produce a complete alcohol decision, signed observation note and handoff plan.

This final alcohol activity combines indicator recognition with an actual decision sequence. Begin with the immediate risk and any emergency. Identify covered functions and whether the observation is during, just preceding or just after safety-sensitive work. State the trained observer’s direct physical, behavioral, speech and performance observations, with times and sources. Separate uncertain reports or environmental facts from direct evidence.

Decide whether the facts support the reasonable-suspicion alcohol referral under the actual employer procedure. The threshold is not certainty about a diagnosis or a guessed BAC. It also is not any mistake plus an arbitrary score. Use a reasoned explanation of the observations. A checklist helps organize evidence but does not create a numerical federal threshold, replace the trained observer or require every possible indicator to appear.

Record the determination time, prompt testing arrangements, safe transport, separate qualified tester, duty restriction, communications and actual collection outcome. Track the two-hour documentation point, eight-hour stop-attempt point and signed-observation deadline. Protect confidentiality and preserve the original record. Apply any measured result or no-test outcome under its own rule and refer release decisions to the responsible authorized employer role.

Compare your written response against the debrief and correct omissions before attesting to the exercise. The self-review and multiple-choice checks supplement recorded participation time; they are not an independent instructor evaluation of your judgment in an actual workplace. The employer remains responsible for reviewing the person’s training evidence and making the designation, contacts and procedures operational.

Fictional supervisor case

At 07:50, just before dispatch, trained supervisor Lee observes Casey stagger twice on dry level ground, fumble a familiar latch repeatedly, speak with slurred words and shout at a routine route question. Lee notices a strong alcohol-like odor on Casey’s breath during a close conversation. Casey is awake and denies a medical emergency. Lee determines reasonable suspicion at 08:00. A different qualified technician administers the test at 09:35.

Work through the decision

Write the factual observation, source distinctions, decision basis, immediate protections, tester/transport handoff and timing record. State what changes if no test occurs by 10:00 or 16:00 and when Lee must sign. Do not guess a test result.

Compare your reasoning: case debrief

The direct physical, speech, behavioral and performance observations support an explained trained determination. Prevent driving and arrange safe transport and a different tester; record the actual 09:35 test without inventing its result. If no test occurs by 10:00, document reasons; at 16:00 cease alcohol attempts and record why. Lee signs within 24 hours of the 07:50 behavior or before results are released, whichever is earlier. Keep restrictions and result/referral decisions separate from a diagnosis.

Basis: 49 CFR 382.307,382.401; integrated alcohol application

7. Controlled substances: physical indicators and drug groups

Recognize potential physical indicators across drug groups without identifying a drug by sight.

Controlled-substances use · 10-minute instruction activity. Start the study session below before reading. Suggested allocation: 4 minutes reading/listening,4 minutes case analysis,1 minute debrief/correction and 1 minute practice. Take longer if needed; breaks and final testing are additional.

The controlled-substances block addresses probable use and the physical, behavioral, speech and performance signs a supervisor might encounter. Drug effects vary by substance, dose, timing, combinations and the person. The same sign may have several causes; absence of a dramatic sign does not guarantee safety. The task is to recognize and describe current observations, protect people and make the appropriate referral, not to determine a drug from appearance.

Cannabis may affect coordination, attention, memory and time perception. Red or watery eyes and an odor can be contextual observations, but lighting, irritation, environmental smoke or other explanations matter. Cocaine and amphetamine-type stimulants may be associated with unusual agitation, rapid movements, sweating or an eventual fatigue/crash pattern. Opioids can cause drowsiness and slowed breathing. PCP and other substances may produce unusual perception, disorientation or behavior. These examples are not a diagnostic chart, an exhaustive list or proof that a particular DOT test detects every impairing substance.

Record ordinary visible facts without conducting pupil, balance or neurological tests. “Eyes repeatedly closed during conversation and head dropped forward twice” is more useful than “opioid user.” A medical emergency can look like impairment, and dangerous breathing or unresponsiveness requires urgent medical assistance. Follow emergency directions and your actual first-aid/naloxone training and available product instructions; this course is not hands-on medical-response qualification.

Prescription and over-the-counter products can impair driving too. The relevant DOT controlled-substance rules and any lawful fitness-for-duty or employer process must be distinguished. Do not tell someone to stop prescribed treatment or make a medical clearance decision as the observing supervisor.

Fictional supervisor case

At 15:05 Rowan’s eyes close repeatedly during a conversation and Rowan’s head drops twice while seated. Rowan then becomes difficult to wake and breathing appears slow. A coworker points to a prescription container and says, “That makes this legal, so we can dispatch.”

Work through the decision

Document observable facts, prioritize the emergency response, and explain why the container neither proves the cause nor authorizes driving. Identify the trained supervisor and clinical decision roles.

Compare your reasoning: case debrief

Treat difficult waking and abnormal breathing as urgent; prevent driving, call emergency help and follow actual training/dispatcher instructions. Retain the time and direct observations. The prescription container does not diagnose the event or establish safe duty. The supervisor neither clears medical fitness nor tells the person to stop treatment.

Basis: 49 CFR 382.603,382.307(b); NHTSA drug-impaired driving; FMCSA indicators

8. Controlled substances: behavior, speech and uncertainty

Describe relevant speech and behavior while separating current facts, background and assumptions.

Possible behavioral observations include unusual agitation, confusion, suspiciousness, a marked difficulty organizing a familiar task or inappropriate reactions in context. Speech can be unusually rapid, rambling, slowed, difficult to understand or repeatedly lose the thread of the discussion. These are potential indicators, not diagnostic findings. State the actual words and actions, timing and circumstances rather than labeling the person “high,” “paranoid” or “an addict.”

A rapid conversation may be ordinary for that person or reflect anxiety, caffeine, time pressure or a medical condition. Quiet speech may reflect language or communication differences. The supervisor should not use race, age, disability, appearance, a past treatment history or a protected complaint as evidence. Consistency means using the same factual decision process, not pretending every worker has identical behavior in every setting.

Separate direct observations from reports, admissions and historical patterns. A coworker’s allegation is attributed information; an appropriately trained observer must make the required reasonable-suspicion observations. A statement about use may raise a distinct actual-knowledge issue requiring the employer’s authorized review. Do not promise immunity for an admission or assume that an employee-assistance request cancels an already required test.

Ask limited questions needed for safety, understanding and the next step. Avoid a public interrogation or demands for unrelated diagnoses and medications. If someone is confused, help them understand the procedure and arrange safe assistance. Preserve the evidence that supported the decision at the time, including meaningful uncertainty. Testing personnel and the medical review officer have their own functions; the supervisor should not pre-judge their determinations.

Fictional supervisor case

At 10:15, Taylor speaks unusually rapidly, interrupts repeated instructions and repeatedly moves between three tasks without completing the first. Taylor says a delivery deadline is causing anxiety. A coworker reports a past treatment episode and urges you to “use that as proof.”

Work through the decision

Write direct observations and the stated alternative explanation. Exclude the treatment history as a shortcut. Explain how the trained official should assess the concern without demanding medical disclosures or a confession.

Compare your reasoning: case debrief

Retain the current speech/task facts and the deadline/anxiety context. Do not transform past treatment into current use or diagnose a stimulant from rapid speech. Protect any immediate risk and use the actual trained-observer/DER procedure with a reasoned factual basis, keeping distinct reports and possible admissions identified.

Basis: 49 CFR 382.307(b),(c); NHTSA drug-impaired driving

9. Controlled substances: performance, chronic and withdrawal effects

Assess contemporaneous performance indicators and possible chronic/withdrawal effects without inferring use from trends alone.

A drug concern may arise through performance: delayed responses, loss of place during a familiar sequence, poor coordination, unusual errors, difficulty dividing attention or unsafe judgment. A trained supervisor should describe what task was underway, what instruction or condition applied, what occurred and when. Identify the immediate hazard and protect against it while the cause is assessed.

Section 382.307 permits drug observations to include indications of chronic and withdrawal effects. This does not make absenteeism, declining output or a past rumor an automatic DOT test trigger. Those patterns may prompt appropriate management attention, but the testing determination still needs the required specific contemporaneous articulable observations. A person can have an emerging medical condition, exhaustion, a poorly designed task or inadequate support; preserve these possibilities and the work conditions.

Someone coming down from a stimulant may appear fatigued; tremor, sweating, nausea, agitation or other changes can accompany some withdrawal states or illnesses. A supervisor cannot safely diagnose withdrawal, predict its course or instruct the person to self-treat. Acute confusion, collapse, serious breathing problems, chest pain, seizures or another emergency requires the medical route, not a prolonged observation exercise. Medical care does not erase the need to preserve lawful program facts, and obtaining facts must not delay care.

Do not convert a productivity review into a substance accusation. Separate performance management, medical/fitness review, work-system investigation and the DOT testing decision. They may share factual observations but have different purposes and authorities. A general company policy may address additional concerns, but its testing basis must be labeled separately rather than falsely represented as DOT.

Fictional supervisor case

Over several weeks Devin has missed deadlines. Today at 13:40 Devin is sweating heavily in a cool office, hands shake while handling routine papers, and instructions must be repeated. Devin says, “I feel sick,” and complains of chest pain. Management asks you to prove withdrawal from the performance history.

Work through the decision

Separate the trend from today’s observations, state the immediate medical response, and describe what you can and cannot conclude about withdrawal or the DOT referral.

Compare your reasoning: case debrief

Chest pain requires prompt emergency assessment through the actual route. Preserve today’s timed physical/performance facts and the reported illness; do not diagnose withdrawal or use missed deadlines alone as a DOT trigger. Trained employer personnel review testing authority and medical priorities without delaying care.

Basis: 49 CFR 382.307(b); FMCSA and NHTSA drug-effect guidance

10. Controlled substances: referral, testing integrity and refusal boundaries

Use the drug reasonable-suspicion basis without importing unrelated alcohol or crash deadlines.

The drug determination requires specific contemporaneous articulable observations concerning appearance, behavior, speech or body odors made by an appropriately trained supervisor or official. Follow the actual employer testing route promptly and record its reason accurately. The alcohol rule’s safety-sensitive timing restriction and two/eight-hour testing provisions are not a universal 32-hour drug reasonable-suspicion window. The 32-hour outer limit belongs to specified post-accident drug testing. Do not wait for an invented deadline.

Make and sign the drug observations within 24 hours of the behavior or before the test results are released, whichever is earlier. Record who observed what, when the determination occurred, why the referral was made, collection/transport arrangements and any delay or change in facts. A person who did not make an observation should not sign as though they personally observed it.

Part 40 governs collection and test-result review. DOT and non-DOT testing stay separate; an instant workplace or home screen does not replace the required federal collection, laboratory and MRO process. A laboratory nonnegative is not the observing supervisor’s verified positive diagnosis. The MRO handles assigned medical explanations and result verification; the employer handles its assigned restrictions and duties.

Failure to appear, leaving before completion or failure to cooperate can be refusal conduct under the applicable rule, but test type, timing, facts and assigned decisionmaker matter. An insufficient specimen is not automatically refusal; the prescribed medical-evaluation pathway applies. Document and promptly contact the DER/authorized process rather than making a medical judgment or reporting a refusal to punish a disagreement. Do not forcibly collect a specimen or detain the driver.

Fictional supervisor case

A trained official makes a drug reasonable-suspicion determination at 11:10. The dispatcher suggests waiting until tomorrow because “all drug tests have 32 hours.” At the site, the driver cannot initially provide a sufficient specimen. The dispatcher wants an immediate refusal report.

Work through the decision

Correct both proposed shortcuts. Identify the actual testing process, observation signing deadline, delay record and appropriate insufficient-specimen decision route.

Compare your reasoning: case debrief

Arrange the required test promptly; do not import the post-accident 32-hour outer limit. Sign the observations within 24 hours of behavior or before result release, whichever is earlier. An insufficient specimen follows the actual Part 40 medical/collection process and responsible decision roles; it is not automatically a refusal. Preserve facts and communicate promptly.

Basis: 49 CFR 382.307(b),(f);49 CFR 40.13,40.191,40.193

11. Controlled substances: fair response, privacy and result handoff

Maintain a fair confidential process and act on results through the correct roles.

Communicate the referral calmly and specifically. Explain the observed facts, covered-work restriction, authorized test reason, safe transport and next contact. Do not demand an admission or tell the driver which drug you have decided they used. An employee may disagree or provide relevant context; record the actual statement and follow the required process rather than arguing until the employee agrees.

State marijuana authorization or a CBD product explanation does not excuse a DOT marijuana positive under the current DOT rules. That principle does not make odor, possession or a product label a verified result, nor does it permit the supervisor to diagnose impairment. Prescriptions and over-the-counter medicines need appropriate medical/fitness review, and confidential medical explanations belong with the authorized clinical/testing role. Avoid unnecessary disclosure of treatment or medication details to dispatch coworkers.

When the employer receives a verified positive, qualifying refusal or other violation, the designated employer role must promptly apply required removal and referral obligations. A negative result does not prove every performance concern or medical problem is resolved. Do not use this course to decide that a person is automatically medically cleared, licensed or authorized for every assignment. Return-to-duty and follow-up duties after a violation require their own SAP/testing process; a later ordinary negative or this course pass cannot replace them.

Keep observation and test records secure with controlled access. The employer’s driver/supervisor training records remain while the person performs the requiring functions and for two years after, with distinct retention categories for other testing/program records. Employer policies, legal holds and governing duties may require more. Preserve original notes and a correction trail; do not circulate results in a public chat or upload real driver data into this course.

Fictional supervisor case

A driver says a CBD label proves the pending test will be negative. A manager wants the driver’s prescription list posted in the dispatch chat so everyone understands the delay. After collection, a coworker says a negative screen means dispatch must resume immediately.

Work through the decision

Draft a response that distinguishes a product claim, an authorized verified result and actual duty eligibility. Identify who receives confidential explanations and what should be communicated to dispatch.

Compare your reasoning: case debrief

Neither the CBD label nor the coworker’s statement determines the MRO result or medical eligibility. Keep actual medications and results in authorized private channels. Dispatch needs the operational hold/replacement information. Apply the actual result and any continuing medical, license or employer restrictions through the responsible roles; do not promise automatic release.

Deeper study: DOT-101 — Removal and return-to-duty responsibilities. For timing arithmetic, MAT-101 — units and technical problem solving is optional study support; formal MAT enrollment remains closed. This lesson supplies the required clock explanations locally.

Basis: 49 CFR 382.405,382.501,382.505,40 subpartsG andO; DOT marijuana/CBD notices

12. Controlled substances: integrated referral and employer readiness

Complete a defensible drug-referral exercise and identify the employer’s remaining responsibilities.

Bring the controlled-substances observations together without turning the exercise into a diagnostic quiz. Identify physical, behavioral, speech and performance indicators in the facts; identify missing information and possible alternative explanations. Immediate protection and emergency medical needs come first. State which observations are personal, which are reported and which inferences remain uncertain.

An appropriately trained official makes the DOT reasonable-suspicion determination and uses the employer’s actual procedure. A second opinion can be useful if available, but a blanket federal two-observer requirement should not be invented. Do not delay a necessary protective action or required testing merely to gather more opinions. A supervisor should neither mechanically order a test after every mistake nor require certainty about a particular drug before acting on qualifying observations.

Prepare a written observation record, decision rationale, safe transport and collection handoff, delay record and signed-observation deadline. Explain the boundaries of the observer, DER, collector, MRO and SAP. Preserve medical confidentiality. If the driver leaves or disputes the referral, record the facts and promptly notify the responsible employer role; apply the appropriate refusal and other duties on their actual facts, without physical detention or automatic assumptions.

This course requires both recorded 60-minute subject blocks, the twelve fictional exercises and self-reviews, every practice check, a final score of at least 80 percent with every critical item correct, and the course rating. Time alone does not establish learning. Periodic online participation confirmations do not independently prove identity or attention, and self-reviewed responses are not individually instructor-graded. The employer must review identity and evidence, provide its procedures and designate the supervisor. No DOT/FMCSA endorsement, medical credential or general work authorization is awarded.

Fictional supervisor case

At 16:25, trained supervisor Alex sees Jordan repeatedly nod off during a routine pre-trip discussion, hears unusually slowed replies and watches repeated inability to complete a familiar inspection step. Jordan reports no emergency symptoms and says a prescribed sleep medicine may be involved. The truck remains parked. Another trained supervisor is 20 minutes away, a qualified collection site is available now, and dispatch wants a confession before acting.

Work through the decision

Write a factual drug-referral analysis and respectful conversation, include the medication explanation without diagnosing, protect driving, arrange the DER/collection handoff and sign the observation record on time. Identify employer adoption gaps and explain why a confession or a second observer is not a federal prerequisite.

Compare your reasoning: case debrief

Describe the current physical, speech and performance facts, assess medical needs and preserve Jordan’s statement for the authorized review. Explain the reasoned trained determination without claiming a drug-specific diagnosis. Keep the truck parked and arrange safe transport/DER coordination promptly. No confession or universal second observer is required. Sign within 24 hours of behavior or before results, whichever is earlier. The employer still needs actual procedures, designated roles, available services, private records and identity/training review.

Basis: 49 CFR 382.603,382.307,382.401; integrated controlled-substances application

Primary sources

Source review: October 25, 2026. Historical FMCSA instructional guidance supplies context; current regulations control. Independent technical review and learner/device duration pilots are not claimed.