Return To Duty (RTD) Drug Testing

The Return-to-Duty (RTD) test is often given after an employee has violated a company’s drug and alcohol policy. If the violation occurs in a safety-sensitive position (for example oil and gas, construction, or transportation) the employee must be removed from duty immediately. If the employee is not in a safety-sensitive position, actions can vary.

For companies that follow Department of Transportation (DOT) regulations, federally-mandated workforces are governed by specific regulations. Under federally-mandated testing guidelines, Return-to-Duty drug tests are performed after one of three incidents: a positive drug test result, the violation of a specific drug rule, or the violation of a specific alcohol rule.

An employee must first be evaluated by a Substance Abuse Professional (SAP) and complete any treatment deemed necessary by the SAP prior to taking the Return-to-Duty test. Once the SAP has determined the employee is eligible to return to work, the RTD test will be administered. RTD tests must be administered under direct supervision to assure that the test results are not manipulated in any way.

In addition, unannounced follow-up tests may also be administered to the employee at later dates to make sure that drug use does not continue at any time after treatment. For employees in safety-sensitive positions, the SAP must direct at least 6 follow-up tests in the first 12 months after the person returns to work. However, the SAP can direct more tests if deemed necessary, and may extend them for up to five years. DISA has a team of Certified Substance Abuse Program Administrators (C-SAPA) certified. The C-SAPA exam certification verifies that the person administering drug tests is reliable and has successfully demonstrated his/her capability in this industry with proper credentials.

My employee is returning after being on leave. Shouldn’t he/she take a Return-to-Duty test? 

Considering the term “return to duty” it’s reasonable to assume that returning employees, such as re-hires, those returning from a seasonal layoff, or medical leave would need to complete an RTD test, but instead, these employees would need to take a pre-employment drug test.

What’s the difference between an RTD and a Pre-Employment test? 

Return-to-Duty tests are only administered to an employee once they have violated the drug and alcohol program by receiving a positive or non-negative test result. Employees must also have completed the initial steps of the return-to-duty process, including the completion of the recommended counseling program. RTD’s differ from pre-employment drug tests as they are directly observed, which means an individual of the same sex will accompany the employee throughout the entire process to ensure the integrity of the test.

What is the Return-to-Duty process? 

The process varies by company and industry specifics, but the following are specific steps that need to be taken following a positive test required by the DOT:

• The immediate removal of an employee from safety-sensitive functions, (i.e. driving) - Even if on the road in another state, the employee must be notified to cease driving as soon as it’s safe to do so.
• Initial evaluation with a DOT-qualified Substance Abuse Professional (SAP) - The SAP will perform a face-to-face interview to evaluate the employee’s particular situation and history in order to determine a treatment program or plan that the employee must complete.
• Education and Treatment Program - The SAP will establish a treatment program for the employee during the initial interview.
• Follow-Up Evaluation with the SAP - Once the employee has completed their designated program, they must meet with their assigned SAP, who will then determine if the employee can take an RTD test and resume work again.
• Follow-Up Test Schedule - The Designated Employer Representative (DER) will receive a follow-up test schedule from the SAP.
• Drug Test - This is when the RTD will be scheduled. If the employee has successfully completed the SAP recommended treatment program or plan, their assigned SAP can recommend to the DER that an employee is eligible for a RTD test. Once a negative test result is received, the employee may resume work again.

How many follow-up tests have to be taken? 

Depending on the company, policies may differ; however, the DOT requires the SAP to schedule at least six tests over a 12-month period of time. This process can continue for up to five years, and each follow-up test must be under direct observation.

Do follow-up tests replace random testing? 

No, because random tests are not taken under direct observation and a follow-up test requires direct observation, therefore, they cannot replace one another. The employee must be included in the regular random testing pool like all other drivers and complete any selections in addition to their follow-up schedule.