Return To Duty (RTD) Drug Testing

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.

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.

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:

1. 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.
2. 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.
3. Education and Treatment Program - The SAP will establish a treatment program for the employee during the initial interview.
4. 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.
5. Follow-Up Test Schedule - The Designated Employer Representative (DER) will receive a follow-up test schedule from the SAP.
6. 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 the employee is eligible for an RTD test. Once a negative test result is received, the employee may resume work.

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

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.