If you manage DOT-regulated employees or work at a collection site supporting regulated testing, understanding reasonable suspicion is not just a compliance box to check, it’s a critical part of overall workplace safety.
In this blog, we’ll break down what reasonable suspicion is (and what it isn’t), the role supervisors and collection sites play, and common misconceptions that can lead to costly mistakes. Whether you’re a safety manager, HR professional, or service agent, this information is for you.
What Exactly is “Reasonable Suspicion”?
Reasonable suspicion is a legal term used in the DOT drug and alcohol testing program to describe a supervisor’s belief that an employee may be under the influence of drugs or alcohol while performing, or about to perform, safety-sensitive duties.
But here’s the catch: it’s not about hunches, gut feeling, rumors, or what happened last week.
Under DOT rules, a supervisor must observe specific behaviors or signs that are:
- Specific – Clear, identifiable, and not vague. (Example: the strong odor of alcohol on breath, not just “acting weird”.)
- Contemporaneous – Happening in real time. You’re making the decision to test based on what’s happening now, not what someone told you happened yesterday.
- Articulable – You can describe what you observed in a way that makes sense and holds up in documentation or even court. “I smelled alcohol and noticed slurred speech,” is articulable. “I think they’re drunk,” is not.
If those three criteria are met, the supervisor has a duty to remove the employee from duty and send them for a reasonable suspicion drug and/or alcohol test.
What it’s Designed to do — and What it isn’t
The goal of reasonable suspicion testing is prevention and safety. It’s about identifying possible impairment before it leads to a serious mistake, injury, or accidents. But many people misuse or misunderstand it — and that can cause real problems.
What It Is Not:
- Not a random test.
- Not based on hearsay or gossip.
- Not used for retaliation or discipline.
- Not the same as a return-to-duty or follow-up test.
- Not a collection that automatically requires observation.
A reasonable suspicion test is conducted the same way as a standard test — unless a directly observed collection is otherwise required (e.g., temperature out of range, etc.). This is one of the most common misconceptions, especially at collection sites. – as many collectors (and some employers) think that a reasonable suspicion test must be an observed collection when it should not be.
Why Employers Need to Pay Attention
If you’re an employer with DOT-regulated workers (FMCSA, PHMSA, FRA, FAA, or FTA), you are responsible for ensuring supervisors are trained to make these calls. In fact, DOT requires that supervisors receive training on the signs and symptoms of drug and alcohol use before they are allowed to make a reasonable suspicion determination.
Failure to follow proper protocol could result in:
- Noncompliance with DOT regulations
- Employees continuing to perform safety-sensitive functions while impaired
- Legal liability in the event of an accident
- Fines or enforcement actions
Having a clear process and properly trained supervisors protects your team — and your company.
Why Collection Sites Should Understand the Difference
If you’re a collector or run a collection site, you might receive a donor for a “reasonable suspicion test” and think it’s just like a return-to-duty or follow-up test — which must be directly observed. But this is not the case for reasonable suspicion testing.
Reasonable suspicion collections are:
- Standard collections, unless there’s a separate trigger for observation
- Based on timing and urgency — they should happen ASAP after the observed behavior
- Not an opportunity for collection staff to assess the person or question the employer’s decision
Your role is to follow collection protocols, not to judge whether the person should be tested. That decision is made by the trained employer representative before the donor arrives.
Common Misconceptions
Let’s clear up a few myths we hear all the time:
“If it’s reasonable suspicion, it has to be observed.”
False. Only return-to-duty and follow-up tests require directly observed collections.
“The employee seems fine now — maybe we don’t need to test.”
Wrong. If the supervisor observed concerning behavior, the test should be done promptly.
“The collector can decide if someone looks impaired or not.”
Not true. That decision lies entirely with the trained supervisor or DER (Designated Employer Representative).
Training Makes All the Difference
Making accurate, compliant reasonable suspicion determinations starts with training. Supervisors need to know what to look for, how to document it, and when and how to act. And collection site staff need to understand how these tests differ from other testing reasons.
That’s why we offer a full suite of online, DOT-compliant training courses:
- Online DOT Reasonable Suspicion Training for Supervisors
Covers FMCSA, PHMSA regulations, how to observe, document, and respond appropriately. - Online DOT Drug and Alcohol Awareness Training for Employees
Helps employees understand the importance of compliance and staying fit for duty. - DOT Reasonable Suspicion Training for Supervisors – FRA, FTA, FAA
Tailored versions for specific DOT agencies and requirements.
…and more coming soon – like our new Non-DOT Reasonable Suspicion and DOT DER Training!
Ready to Train Your Team?
Whether you’re just getting started or need a refresher course, we’ve got flexible, self-paced online options for both employers and collectors.
Learn more and register for a course today. Protect your workplace. Stay compliant. Get confident with reasonable suspicion.