How many supervisors have to be involved to make a reasonable suspicion test determination for FAA?

The answer depends on how many employees your company employs that perform safety-sensitive functions and whether or not you fall under 14CFR part 121 regulations. Buried within the 14 CFR part 120.109 “Types of drug testing required – Drug testing based on reasonable cause” you’ll find the following: 

“At least two of the employee’s supervisors, one of whom is trained in detection of the symptoms of possible drug use, must substantiate and concur in the decision to test an employee who is reasonably suspected of drug use.”

(view the eCFR regulations for drug testing here)

There is an exception to the two-supervisor rule which is if the employer is not an air carrier operating under 14 CFR part 121 and has 50 or fewer employees, a single trained supervisor can make the determination.

So the answer can be either two…or one, depending on how many safety-sensitive employees are employed. Either way, the requirement is clear that a supervisor must be trained on “the symptoms of possible drug use” in order to make a reasonable suspicion drug test determination.

It would make sense then to ensure that any new supervisor, or employee promoted to a supervisor position are immediately enrolled into a 2-hour supervisor reasonable suspicion training course.  DOT requirements for the FAA regulated industry also require “recurring” training on a 12-18 month cycle. At Hand Training’s online courses meet the DOT’s requirements and represent the quickest way to ensure supervisors meet their training requirements.

Access At Hand Training’s courses below:

Download the FAA reasonable suspicion check list and documentation form here.