SAP, MRO and DER
SAP, Substance Abuse Professional: A professional who meets the qualification requirements in 49 CFR § 40.281 and evaluates an employee who has violated a DOT drug or alcohol regulation. The SAP recommends appropriate education and/or treatment, conducts a follow-up evaluation and, when applicable, establishes a follow-up testing plan. A SAP is not simply any counselor or treatment provider.
MRO, Medical Review Officer: A qualified physician who performs the medical review functions required by DOT drug-testing rules, including reviewing laboratory-reported drug test results before verified results are reported as required by Part 40.
DER, Designated Employer Representative: An employee authorized by the employer to receive communications and take immediate actions required by the employer's DOT drug and alcohol testing program.
C/TPA and the FMCSA Clearinghouse
C/TPA, Consortium/Third-Party Administrator: A service agent that performs specified drug and alcohol program functions for an employer. The functions it can perform depend on the applicable DOT rules. A C/TPA does not replace the SAP's clinical and regulatory responsibilities.
Drug and Alcohol Clearinghouse: FMCSA's database containing records related to drug and alcohol program violations by drivers subject to the Clearinghouse rules and information about their return-to-duty process. See the FMCSA Clearinghouse Learning Center.
Prohibited status: For a driver subject to the FMCSA Clearinghouse, a status that prevents the driver from performing safety-sensitive functions requiring a commercial driver's license or commercial learner's permit while the applicable prohibition remains. See Clearinghouse prohibited status.
RTD, successful compliance and follow-up testing
RTD, return-to-duty: The regulatory process required before an employee who has committed a DOT drug or alcohol violation can return to DOT safety-sensitive duties. It includes the SAP process and the applicable return-to-duty test requirements. See DOT return-to-duty process.
Successful compliance: A determination made by the SAP after the follow-up evaluation that the employee has demonstrated successful compliance with the SAP's education and/or treatment recommendations. It is not the same thing as a negative RTD test or an employer's decision to return someone to work. See 49 CFR § 40.301.
Follow-up testing: Unannounced testing prescribed by the SAP after successful compliance for an employee seeking to resume safety-sensitive duties. At least six tests are required during the first 12 months after return to safety-sensitive duty, with testing potentially extending to 60 months. Follow-up testing is separate from random testing. See 49 CFR § 40.307.
Evaluation, treatment and DOT-qualified SAP
Initial SAP evaluation: The assessment used by the SAP to determine what assistance, education and/or treatment is appropriate following a DOT violation. See SAP evaluation.
Follow-up SAP evaluation: The later evaluation in which the SAP determines whether the employee has demonstrated successful compliance with the earlier recommendations.
DOT-qualified SAP: A SAP who meets Part 40's professional credential, training, examination and continuing-education requirements. The term does not mean that DOT has personally approved or endorsed a particular provider. See what DOT-qualified SAP means.
