Implementation Guidelines - Federal Transit Administration - U.S. ...

Exhibit 5-4
REASONABLE SUSPICION TRAINING
POINTS OF EMPHASIS
Remember that the Primary Issue is Safety. Employees who are believed to be under the
influence of a prohibited substance are an immediate hazard to themselves and others.
Management’s inability to substantiate the objective facts associated with the reasonable
suspicion determination or concern for a grievance or other employee action should be secondary
to assuring safety.
Inquire and Observe. Ask the employee to explain the suspected behavior and to describe
the events that took place from his or her perspective. A persuasive explanation should not deter
or prevent you from requiring a test if you have a reasonable belief that prohibited drug use or
alcohol misuse is a factor.
Denial should be an expected reaction. If an employee knows he/she will test positive,
he/she may give several explanations and protests in an attempt to avoid testing. As a result, a
reasonable suspicion decision must be based on objective observations. Remember, a request for
a urine specimen or a breath test is not an accusation; it is merely a request for additional
objective data.
To the employee, a request for a specimen may feel like an accusation; so it is important to
stress that this is merely a request for additional data. Explain also that the incident and the test
results will be handled with strict confidentiality. Sometimes, it may be necessary to calm the
situation by telling the employee, “I’m glad to hear your explanation, and in light of the
circumstances, I want to verify what you have just told me.”
Isolate and Inform the Employee. Remove the employee from the vehicle or public
locations. Explain that you believe he/she may not be fit for duty and you are requesting him or
her to accompany you to the collection site. Inform the employee of the consequences of refusal
and that he or she is being relieved from duty.
It is important to respect the dignity and confidentiality of the employee during the interview.
Review Findings. During the conversation, observe physical and mental symptoms. Be sure
to document any characteristics that either support or contradict the initial information. The FTA
regulation only requires that one supervisor make the reasonable suspicion referral. If possible, a
second supervisor should be consulted. The confirmation by a second supervisor creates greater
objectivity, provides additional observation, and generally strengthens the reliability of the
reasonable suspicion determination.
Make the Reasonable Suspicion Decision. Anonymous tips must be taken seriously, but
should not be the sole reason to initiate a request for a reasonable suspicion test. Hearsay is not
an acceptable basis for a reasonable suspicion referral. If witnesses saw a specific event or
behavior, the supervisor should ask them to describe what they saw. Questions a supervisor
might ask an employee are: How far away were they? How long did they observe the person?
Chapter 5. Training 5-21 August 2002