When is a Return to Duty Test Required? Understanding the Key Steps

When is a Return to Duty Test Required? Understanding the Key Steps

Return to Duty

For individuals working in safety-sensitive positions within the transportation industry, understanding when a return-to-duty test is required is crucial. This test is a pivotal part of the DOT return-to-duty process, designed to ensure that employees who have violated DOT drug and alcohol regulations are fit to resume work responsibilities safely. Here’s a detailed look at when this test becomes necessary and what it entails.

Overview of the Return to Duty Process

Ensuring Safety and Compliance

The Return to Duty Test is required for employees who have previously failed or refused a drug or alcohol test. The test confirms that these individuals have successfully met the treatment requirements set by a Substance Abuse Professional (SAP) and are no longer under the influence of substances that could impair their ability to perform safety-sensitive duties.

Circumstances Leading to a Return to Duty Test

Criteria for Testing

A Return to Duty Test is required in the following situations:

  1. Following a Violation: Any employee who fails a drug or alcohol test or refuses to submit to one is immediately removed from performing safety-sensitive functions and can only return once all the Return to Duty Program steps are completed.
  2. After Completing SAP Recommendations: Once an employee undergoes an evaluation by a qualified SAP and completes the recommended treatment or education program, a Return to Duty Test is the next step. This test is crucial to ensure that the employee has addressed the issues related to their substance use.

What to Expect During the Return to Duty Test

Procedures and Protocols

The DOT Return to Duty Test must be conducted under direct observation, meaning a same-gender observer must be present during the urine sample collection to ensure the test’s integrity. The test must check for alcohol and drugs, depending on the nature of the original failure or refusal. A negative test result is mandatory for the employee to be considered for returning to safety-sensitive functions.

The Role of the SAP in the Return to Duty Test

Guidance and Follow-Up

The SAP plays a continuous role throughout the return-to-duty process. After the initial assessment and recommendation for treatment, the SAP also determines when the employee is ready to undergo the return-to-duty test. The SAP will also set up a follow-up testing plan involving a series of unannounced tests to ensure ongoing compliance and prevent future violations.

Frequently Asked Questions

Failure to complete the Return to Duty Test requires the employee to complete another return to duty process. This could mean the employee must undergo additional treatment or education as the SAP recommends, after which another test can be attempted.

The SAP determines the frequency and duration of follow-up testing, and only the employer who returns the employee to duty after a negative return-to-duty test will know the specifics of the follow-up testing schedule.

Understanding when a return-to-duty test is required is essential for any transportation industry employee who handles safety-sensitive tasks. AACS Counseling is dedicated to guiding such individuals through the return-to-duty program and ensuring they meet all necessary criteria to return to work safely.

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About the Author

Jacques Khorozian

Jacques Khorozian,

Ph.D., LPC, NBCC, MAC, SAP, CCS

Jacques Khorozian, Ph.D., LPC, MAC, SAP, CCS, is an experienced behavioral health professional with over 30 years of work in the criminal justice system, specializing in mental health and substance use disorder treatment. He serves as Chief Executive Officer of American Alternative Court Services (AACS) in Atlanta, where he conducts diagnostic and biopsychosocial assessments and develops treatment and diversion programs.

He collaborates with justice system stakeholders to improve access to behavioral health services and alternative sentencing solutions. Dr. Khorozian previously worked as a Behavioral Health Social Worker with the Fulton County Public Defender's Office, where he assessed client needs and coordinated services.

He also held a leadership role as Division Chief with the San Francisco Superior Court, managing operations and contributing to strategic initiatives. He holds a Ph.D. in Positive Psychology, a Master's in Clinical Mental Health Counseling, and a Bachelor's degree in Psychology.

His professional memberships include the American Counseling Association (ACA), the American Positive Psychology Association (AMPPA), the Licensed Professional Counselors Association of Georgia (LPCA), the National Board for Certified Counselors (NBCC), and the Alcohol and Drug Abuse Certification Board of Georgia (ADACBGA).

Dr. Khorozian has advanced certifications as a Certified Clinical Supervisor, Substance Abuse Professional (SAP), Family Violence Intervention Specialist, and DUI Evaluator. He is recognized for his expertise in counseling techniques, assessment, diagnosis, and culturally responsive care. His work focuses on improving population health outcomes through evidence-based behavioral health programs.


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