What counts as reasonable suspicion under DOT rules?
The four words that carry the weight
Specific: a particular sign you can name, such as odor of alcohol on the breath. Contemporaneous: happening now or just now, not last week. Articulable: you can put it into words another person would understand and that would hold up if challenged. Observations: what you saw, heard or smelled yourself, not what you were told.
What qualifies
Observed indicators in the four categories the training covers. Physical: odor, bloodshot eyes, unsteady balance, tremors, pinpoint or dilated pupils. Behavioral: mood out of character, aggression, unusual calm, avoidance. Speech: slurred, rapid, rambling, incoherent. Performance: errors in routine tasks, slow reactions, poor vehicle handling. For drugs, 382.307 adds that observations may include indications of chronic and withdrawal effects. One indicator alone is rarely enough; a cluster is what builds reasonable suspicion.
What does not qualify
An anonymous tip. A coworker saying the driver smelled like beer, unless you go and observe it yourself. The driver's history. A feeling. The fact that a driver was out late. A random guess. These may be reasons to go and look; they are not grounds to test. Testing without proper grounds exposes the employer to a grievance and the program to challenge.
Who can make the call, and when
Only a supervisor or company official who has completed the training required by 382.603. And only while the driver is performing a safety-sensitive function, just before, or just after. A driver seen at a bar on Saturday night is not a reasonable suspicion case. A driver walking to the truck Monday at 6 a.m. is.
The clocks
Alcohol: test as soon as possible; if not within two hours, record why; after eight hours, stop trying and record why. A driver identified for reasonable suspicion cannot return to safety-sensitive duty until an alcohol test shows below 0.02 or 24 hours have passed. Drugs: no two-hour or eight-hour window, because drugs remain detectable for days, but the driver stays off duty pending the result. Both: the supervisor signs a written record of the observations within 24 hours or before results are released, whichever is earlier.
Questions drivers ask
Can the supervisor who made the observation run the breath test?
No. The supervisor who determines reasonable suspicion may not conduct the alcohol test. A Breath Alcohol Technician or Screening Test Technician does.
Can the driver drive themselves to the collection site?
No. If there was reasonable suspicion of impairment, the driver cannot drive anywhere. Someone else transports them.
What if the driver refuses to test?
A refusal is treated exactly like a positive result: removal from safety-sensitive functions and the full return-to-duty process.
Can an employer act on appearance alone without a test?
For alcohol, 382.307 says no: an employer may not take action based solely on behavior and appearance with respect to alcohol in the absence of a test. The observation gets the test; the result is what the company acts on.