Upon the occurrence of any of the triggering events, employers must promptly initiate the RTD process. This multi-step journey involves several critical components:
1. Immediate Removal from Safety-Sensitive Functions
The first step in the Return to Duty process is the immediate removal of the employee from all safety-sensitive duties, such as operating commercial vehicles, aircraft, or heavy machinery. We take care of our people – employees, colleagues, and the public – by following this procedure until the issue is completely resolved.
2. Referral to a Substance Abuse Professional (SAP)
Employers are required to provide the employee with a list of qualified Substance Abuse Professionals (SAPs) approved by the Department of Transportation (DOT). Before getting started, the employee meets with a SAP, a seasoned expert who evaluates their past struggles with substance abuse and outlines a personalized recovery roadmap.
3. Completion of a Treatment Program
Based on the SAP’s recommendations, the employee must enroll in and successfully complete a prescribed treatment program. A personalized plan that addresses each person’s distinct needs might involve a mix of educational programs, counseling sessions, and rehabilitative care – either on an outpatient or inpatient basis.
4. Follow-up Evaluation with the SAP
After completing the treatment program, the employee must undergo a follow-up evaluation with the same SAP. The SAP takes a close look at how the employee is doing during this assessment, and based on that, decides what they need to get back to their normal duties – and that might involve some extra counseling or treatment to get them back on track.
5. Return-to-Duty Drug or Alcohol Test
If the SAP deems the employee fit to resume safety-sensitive functions, they will authorize the employer to administer a return-to-duty (RTD) drug or alcohol test. Reliable results hinge on this test being conducted in full view, where every step can be monitored and verified.
6. Reporting to the FMCSA Clearinghouse
Employers are mandated to report successful treatment completion and negative RTD test results to the Federal Motor Carrier Safety Administration (FMCSA) Clearinghouse. With a reputation for being thoroughly up-to-date, a sophisticated database catalogs every drug and alcohol program infraction, keeping transportation professionals in the know and on the right side of the rules.
7. Follow-up Testing Schedule
The SAP will provide the employer with a follow-up testing schedule, which typically includes a minimum of six unannounced drug or alcohol tests during the first 12 months following the employee’s return to duty. These tests must be conducted under direct observation and are in addition to any random or reasonable suspicion testing required by the employer’s policies.
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