Random testing runs on a schedule. Reasonable-suspicion testing runs on a supervisor’s judgment — and FMCSA only trusts that judgment if the supervisor has been trained for it.
The requirement: 60 + 60 minutes, once
49 CFR §382.603 requires everyone designated to supervise CDL drivers to receive at least 60 minutes of training on alcohol misuse and 60 minutes on controlled substances use. The training covers the physical, behavioral, speech, and performance indicators of probable use.
It’s a one-time requirement — no recurrent training mandated. But a supervisor with a 15-year-old certificate and no refresher makes a shaky witness, so many fleets re-run it periodically anyway.
Who actually needs it
Anyone designated to supervise drivers. For a fleet with dispatchers or operations managers who direct drivers, that’s them.
A true solo owner-operator with no one to supervise has no one to train — this is one of the few Part 382 pieces that doesn’t apply to a one-person operation. The moment you hire a second driver and supervise them, the requirement is live.
What the training enables
A reasonable-suspicion test can only be ordered by a trained supervisor, based on specific, contemporaneous, articulable observations of the driver — appearance, behavior, speech, or body odors. A hunch doesn’t qualify. A tip from another driver doesn’t qualify. The trained supervisor has to witness the behavior firsthand, and document what they saw.
That’s the point of the training: it turns “something seemed off” into documented observations that hold up — in the test decision, in the driver file, and in front of an auditor or a lawyer.
What auditors ask for
Proof the training happened: who was trained, when, and the curriculum it covered. Keep the certificates in the same audit file as your testing records. A compliant program has six test types, and reasonable-suspicion is the one that fails silently — not because tests were done wrong, but because nobody who could order one was ever trained.
Not sure who in your operation counts as “designated to supervise,” or where to get the training? We’ll point you in the right direction — (651) 482-1124.