DOT SAP RTD Changes
- Mar 4
- 1 min read
Today, the Department of Transportation (DOT) published a Federal Register Notification regarding “The Do’s and Don’ts for the Substance Abuse Professional and the Return-to-Duty Process in the U.S. DOT Drug and Alcohol Testing Program.” This notification addresses several Substance Abuse Professional (SAP)/Return-to-Duty (RTD) issues the DOT has become aware of, to remind DOT-qualified SAPs to follow all RTD process procedures in Part 40, and to remind DOT-regulated employers of the SAP responsibilities and the RTD process.
Common problems noticed:
Employers having a hard time getting the follow-up testing plans
SAPs referring employees solely to online programs as opposed to in-person programs
SAPs prescribing the minimum number of follow-up tests in response to pressure from consortium/third-party administrators (C/TPA)
SAPs administering follow-up tests
SAPs not holding appropriate credentials to act as a DOT-qualified SAP
SAPs performing the RTD process in a very short timeframe to get the employee back to work quicker
SAPs going outside their credentials' geographical limit to perform remote evaluations
SAPs performing remote evaluations without real-time two-way audio and visual communication with the employee.
