New SAP Guidelines Announced by the DOT’s Office of Drug and Alcohol Policy and Compliance

By: ASAP

On June 1, 2023, the Office of Drug and Alcohol Policy and Compliance (ODAPC) published the updated Substance Abuse Professional (SAP) guidelines, recognizing certain provisions to the Department of Transportation’s (DOT) final rule from May 2, 2023.

The updated SAP guidelines expand on SAP’s geographical limitations regarding remote evaluations, providing additional details about the steps in the return-to-duty process being “unique” to each employee, and includes a new section about remote assessments and evaluations. Additionally, the SAP guidelines have developed updated written report requirements and formatting, along with documentation requirements for remote evaluation practices.

A Substance Abuse Professional (SAP) is a credentialed individual who assesses employees who have violated a DOT drug and alcohol regulation, making recommendations to the employee regarding educational opportunities, treatment, follow-up testing and aftercare programs. The function of the SAP is to protect public interest and safety, adhering to the 49 CFR Part 40 compliance regulations.

“As a SAP you represent the major decision point (and in some cases the only decision point) an employer may have in choosing whether or not to place an employee behind the steering wheel of a school bus, in the cockpit of a plane, at the helm of an oil tanker, at the throttle of a train, in the engineer compartment of a subway car, or at the emergency control valves of a natural gas pipeline,” as stated by the DOT’s SAP Guidelines Overview. “Your responsibility to the public is enormous!”

The SAPs role is imperative to the DOT’s initiative to make the transportation industry as safe as possible and plays a vital part in protecting public safety. As the “Gatekeepers” to the return-to-duty process, SAPs duties directly affect employees, employers, and the traveling public. With a previous face-to-face approach that has now opened the door to a federally-approved remote process, SAPs are key in addressing the needs of employees needing to return to safety-sensitive duties.

To review the updated SAP guidelines, please go to the DOT’s ODAPC document.