1. Complete the initial SAP evaluation
The process begins with a Substance Abuse Professional who meets DOT qualification requirements. Under 49 CFR 40.291, the SAP evaluates the employee and determines what education and/or treatment is needed. The SAP's role is independent and focused on public safety rather than advocating for either the employee or employer.
An evaluation can be in person or remote when the SAP's credential permits it and the remote session meets DOT requirements for real-time audio and video, adequate interaction and confidentiality.
2. Complete the SAP recommendation and follow-up evaluation
The individual must complete the education and/or treatment prescribed by the SAP. The SAP then conducts a follow-up evaluation to determine whether the person actively participated and demonstrated successful compliance. The requirement is individualized. It is not valid to substitute a generic class simply because it is quicker or less expensive.
If the SAP determines successful compliance, the SAP provides the required report and establishes a follow-up testing plan for a person seeking to resume safety-sensitive functions. See SAP follow-up evaluation for this stage in more detail.
3. Complete the return-to-duty test
Successful SAP compliance allows the RTD testing stage to occur. It is not itself a negative test. Under 49 CFR 40.305, an employer that decides to permit the person to resume safety-sensitive duties must ensure the RTD test is completed. A drug RTD result must be negative. An alcohol RTD result must be below 0.02.
DOT return-to-duty and follow-up drug tests require direct observation under 49 CFR 40.67. Drivers should not treat an ordinary personal drug screen as a substitute for a properly ordered DOT RTD test. FMCSA drivers without a current or prospective employer have a specific C/TPA procedure described in our no-employer guide.
4. Employer return and follow-up testing
Passing the RTD test satisfies an important regulatory condition, but DOT does not require an employer to reinstate or hire someone simply because the process has reached that point. The employer makes the personnel decision.
If the individual returns to safety-sensitive duty, the SAP's follow-up testing plan applies. 49 CFR 40.307 requires at least six unannounced follow-up tests during the first 12 months of safety-sensitive duty, with the SAP able to require additional testing for as long as 60 months of safety-sensitive duty. Follow-up testing is separate from ordinary random testing. See DOT follow-up drug testing procedures for the rules that apply after return.