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Navigating the Maze: When is Return to Duty Testing Required?

When is return to duty testing required? A RTD test is part of the return-to-work process for employees in safety-sensitive industries who have tested positive for drug and/or alcohol use or have violated workplace drug and alcohol policy.

In this blog, we explain the RTD process, who must take the test, and the importance of treatment and follow-up testing.

Understanding the Return-to-Duty Process

Workplace incident leading to when is return to duty testing required

Statistics show that more than 70% of Americans dealing with drug or alcohol addiction are employed. These employees pose significant health and safety risks to their employers, co-workers, and the public. If they violate workplace drug and alcohol policy or work in a safety-sensitive job, they may find themselves removed from duty.

Fortunately, RTD testing gives employees a second chance.

Incidents Leading to RTD Testing

There are three circumstances that can trigger an RTD test in safety-sensitive industries.

  1. Positive drug/alcohol test: U.S. Department of Transportation (DOT) regulation requires that any employee in a safety-sensitive position who tests positive for drug or alcohol on a random drug test or based or a reasonable suspicion test must be removed from duty. The individual must then complete a drug and alcohol treatment program under the supervision of a Substance Abuse Professional (SAP). A negative RTD test result must be recorded before they can return to work.
  2. Violation of a drug or alcohol rule or policy: Violations may include possession of drugs or alcohol at work or transporting drugs or alcohol while operating a commercial vehicle. In these circumstances, the employee must be removed from duty, complete a drug and alcohol treatment program, and undergo an RTD test.
  3. Refusal: If an employee refuses to take a random drug test or reasonable suspicion test, they may be removed from duty. To return to duty, they must complete a drug and alcohol treatment program and undergo an RTD drug test.

Steps in the RTD Process

The RTD process encompasses the following steps:

Step 1: Removal from duty

An employee must be immediately removed from duty following a workplace drug or alcohol violation or positive drug/alcohol test as confirmed by a Medical Review Officer (MRO). The MRO must also report the violation to the Federal Motor Carrier Safety Administration (FMCSA) Drug and Alcohol Clearinghouse.

Step 2: SAP evaluation

If the employee wishes to return to work, they must submit to an evaluation by a Substance Abuse Professional (SAP). The employer must provide the employee with a list of DOT-approved SAPs.

Following the face-to-face assessment of the employee, the SAP will establish a drug and alcohol treatment program.

Step 3: Completion of treatment

Once the treatment is complete, the assigned SAP will review the employee’s progress and determine if they are ready to take an RTD test and return to work upon a negative result. The SAP may also recommend continued counseling as part of any follow-up care.

If the employee fails to complete treatment or requires additional evaluation or treatment, the SAP will not clear them for return to work.

Step 4: Reporting

The SAP will communicate their findings to the employer, providing details on the employee’s progress in treatment and the number of follow-up drug tests required.

Step 5: RTD test

After examining the report, the employer is required to arrange an RTD drug test for the employee. The test should be performed under direct supervision to ensure an untampered result. To pass the RTD test, the employee must exhibit the following results:

  • Alcohol concentration of less than 0.02; and/or
  • Controlled substances with a result indicating a verified negative result for drug use.

Employers must notify the FMCSA Clearinghouse of successful treatment completion and negative test results. Follow-up test results must also be reported to the FMCSA.

Role of the Substance Abuse Professional

Substance Abuse Professional's role in determining when return to duty testing is required

A Substance Abuse Professional or SAP is a medical professional who evaluates employees who have violated a DOT drug and alcohol program regulation.

To become an SAP, the individual must pass the Certified Substance Abuse Program Administrator (C-SAPA) exam. Once certified, an SAP can make recommendations concerning employee treatment, follow-up testing, and aftercare.

Importantly, an SAP doesn’t advocate for the employee or the employer. Their main task is to protect the public. After all, the decisions they make determine whether to place an employee behind the wheel of a truck, in an aircraft cockpit, or at the throttle of a train.

As part of their duties, SAPs must be knowledgeable of DOT procedures for transportation workplace drug and alcohol testing programs (49 CFR Part 40), including substance abuse return to duty processes, employee confidentiality laws, and more.

Finding a Qualified SAP

As part of the RTD process, employers are required to provide employees with a list of SAPs qualified in accordance with DOT Rule 49 CFR Part 40 Section 40.281.

If the employer does not provide a list, employees can search the internet using terms such as “DOT qualified SAP.”

Post-Treatment and Return-to-Work

Employee's return to work after passing the required return to duty testing

Following treatment and return-to-work the employee must submit to a series of follow-up RTD tests as recommended by the SAP.

Types of Drug and Alcohol Tests Post-Treatment

In addition to the initial RTD test, the SAP will establish the number of tests required after treatment and return to work based on regulatory requirements or company policy. DOT law requires a minimum of six unannounced, random tests during the first 12 months following resumption of work.

These tests must be conducted under direct observation. All results must be reported to the FMCSA Clearinghouse.

Common Questions About RTD Testing

What are the steps for RTD?

The RTD process includes:

• Evaluation by a Substance Abuse Professional (SAP)
• Completion of a treatment program
• RTD drug and/or alcohol testing
• Follow-up testing (as required by law or company policy)

What do you need an SAP for?

An SAP or Substance Abuse Professional is a certified medical professional who evaluates employees and recommends substance abuse treatment programs and follow-up RTD testing.  

Employers in DOT-regulated industries are required to refer employees to an SAP following removal from duty due to a drug or alcohol violation. However, SAPs can assist any employer in managing and administering their return-to-work drug programs.

What does returned to duty mean?

An employee is returned to duty after completing treatment for a workplace drug and alcohol policy violation and passing a drug and/or alcohol test. Follow-up random testing may also be required.

Unraveling the Mystery: Why “When is Return to Duty Testing Required” Matters

RTD testing is vital to ensuring a safe and compliant workplace. When is RTD testing required? Employees in safety-sensitive and regulated industries must undergo RTD testing following a positive drug/alcohol test, violation of a workplace drug or alcohol rule or policy, or refusal to submit to a random drug/alcohol test.

At Acuity, we offer a wide range of workplace drug and alcohol testing services, both for regulated and non-regulated industries, including pre-employment, random, reasonable suspicion, DOT drug and alcohol tests, RTD, and follow-up tests.

These services are backed by advanced technology and a widespread provider network to give employers 24/7 access to scheduling, testing status notifications, case management reporting, and more.

Learn more about Acuity’s comprehensive portfolio of Occupational Health Services.

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