Gregory C. Krueger, M. Div., MSW, LCSW
DOT Qualified Substance Abuse Professional

DOT Regulated Employer

The Department of Transportation's rules regarding substance use are very specific.  According to the procedures outlined in the DOT's Federal Drug and Alcohol Testing Rules (49 CFR Part 40), a DOT regulated employee who      refuses or has tested positive on any DOT drug or alcohol test is required to be evaluated by a DOT Qualified Substance Abuse Professional (SAP).  Applicants who refuse or fail a pre-employment drug test must also be evaluated by a DOT Qualified SAP if they every want to become eligible for a DOT regulated position in the future.

 In my role as a DOT Qualified SAP, I provide the core services employers need for DOT-regulated or other safety-sensitive employees who test positive and desire to return to safety-sensitive responsibilities.  My services include conducting an initial evaluation, setting rehabilitation recommendations, identifying available resources the employee needs in order to meet the recommendations, monitoring the employee’s progress and, finally, completing the DOT required Follow-Up evaluation.  I keep in close communication with the Designated Employer Representative, and make certain that the Designated Employer Representative (DER) has all essential documentation in a timely manner.  As part of my service, I also set the follow-up drug/alcohol testing schedule the employer is required to maintain on returning employees.   In addition, I can also provide the DOT required compliance checks for an extended period of time, depending on the nature of the case.  While this can be done by the DER or the SAP, many employers want this responsibility handled by the SAP for the sake of continuity.  All of this required under DOT 49 CFR Part 40.  

Many employers ask about the cost of the Return-to-Duty process.  Who used drugs or abused alcohol?  Unless you have a policy stating otherwise, I encourage employers to require the person testing positive to pay the cost of the evaluation and related tasks.  After all, it was the employee’s decision to use the prohibited substances, not yours.   While it is your responsibility as an employer to make sure that Return-to-Duty process is followed correctly, the DOT Rules do not dictate that employers pay for the process.  Since the Return-to-Duty process is occurring because of your employee’s behavior, please insist that the employee pay the cost.  Many employers initially pay the cost of evaluation and Follow-Up testing and seek reimbursement from the employee via payroll deduction.  

My goal is to provide you with a consistent level of competence and professionalism.  I have received my qualifying and re-qualifying training from the highly acclaimed trainer Lee Mauk of Blair Consulting and  I am committed to keeping employers in compliance with DOT regulations and making sure that an individual is drug/alcohol free before returning to DOT safety sensitive duties.  I am experienced with DOT audits, and have a clear sense of the Investigator’s areas of concern.

If your policy needs a review or an extensive overhaul, please feel free to contact me.  I will be happy to meet with you, free of charge, at your location to consult with you about your program.  For additional information, please feel free to contact me at (314) 275-8114 or click here.

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