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DOT Reasonable Suspicion Training for Supervisors

If you supervise CDL drivers, FMCSA requires you to be trained to spot drug and alcohol use before you can order a reasonable suspicion test. The training is at least 60 minutes on alcohol and 60 more minutes on drugs. This guide covers the training rule and the basic steps for a reasonable suspicion test.

Updated September 28, 2026 · Checked against the federal regulations

The training rule: 60 + 60 minutes

Under 49 CFR 382.603, every person designated to supervise drivers must get at least 60 minutes of training on alcohol misuse and at least another 60 minutes on controlled substances use.

The training must cover the physical, behavioral, speech, and performance signs of probable alcohol misuse and drug use. Supervisors use it to decide whether reasonable suspicion exists.

• At least 60 minutes on alcohol misuse
• At least 60 minutes on controlled substances use
• Covers physical, behavioral, speech, and performance indicators
• One-time requirement: recurrent training is not required

What reasonable suspicion means

You must order a test when you have reasonable suspicion that a driver broke the drug or alcohol rules. That decision must be based on specific, contemporaneous, articulable observations of the driver's appearance, behavior, speech, or body odors.

In plain terms: what you saw, heard, or smelled, at that time, that you can describe clearly. Rumors or a hunch are not enough. For drugs, observations can also include signs of chronic use or withdrawal.

Who can make the call

The observations must be made by a supervisor or company official trained under 382.603. An untrained manager cannot be the one who decides.

The person who decides a reasonable suspicion alcohol test is needed cannot also conduct that alcohol test.

Alcohol test timing: 2 hours and 8 hours

Reasonable suspicion alcohol testing is only allowed if the observations are made during, just before, or just after the period the driver must be in compliance. Timing after that matters too.

• If the alcohol test is not done within 2 hours, write down why it was delayed and keep that record.
• If it is not done within 8 hours, stop trying and write down why the test was not given.
• If no test is done, the driver cannot do safety-sensitive work until a test shows less than 0.02 or 24 hours have passed since the decision.

Document it within 24 hours

Write down what you observed that led to the test. The supervisor or official who made the observations must sign it. It must be done within 24 hours of the observed behavior, or before the test results are released, whichever comes first.

Keep these documents. Under 382.401, records of reasonable suspicion decisions and supervisor training are part of your required program records.

Pact Compliance keeps each driver's testing records on file for small fleets and owner-operators nationwide.

Common questions

Sources

• 49 CFR 382.603 Training for supervisors
• 49 CFR 382.307 Reasonable suspicion testing
• 49 CFR 382.401 Retention of records