SAPs are allowed, if they voluntarily choose to do so, to conduct a remote “face-to-face” evaluation and assessment while this policy is in effect through December 31, 2022.
At the beginning of the COVID pandemic, the Department of Transportation (DOT) Office of Drug and Alcohol Policy and Compliance (ODAPC) provided guidance about the impact of the COVID-19 public health emergency on DOT drug and alcohol testing requirements for employers, employees, and service agents (collectors, MROs, SAPs).
On April 4, 2020, ODAPC provided supplemental information specific to performing remote evaluations by Substance Abuse Professionals (SAP).
On June 15, 2022, the ODAPC updated its Statement of Enforcement Discretion for Substance Abuse Professionals and Service Agents guidance document to extend the guidance for SAPs to conduct remote assessments and evaluations until December 31, 2022
Virtual SAP Assessments and Evaluations Allowed During Pandemic
Under federal regulations, the SAP must conduct a face-to-face, or in-person, assessment and evaluation of an employee who has violated DOT drug and alcohol regulations.
ODAPC recognizes that conducting face-to-face assessments and evaluations during the pandemic may not be possible for certain individuals.
SAPs are allowed, if they voluntarily choose to do so, to conduct a remote “face-to-face” evaluation and assessment while this policy is in effect during the pandemic.
ODAPC recommends that, when a SAP conducts assessments and evaluations remotely, the format of the assessment be documented in the final report for reference.
ODAPC realizes that performing evaluations remotely may not provide as much information to the SAP as a face-to-face evaluation would, but believes remote evaluations are preferable to not performing the evaluations at all.
SAPs who choose to conduct initial assessments and evaluations and follow up evaluations remotely should consider the following parameters:
- The technology used should permit a real-time two-way audio and visual communication and interaction between you and the employee.
- You should determine if the quality of the technology (e.g., speed of the internet connection, clarity of the display, application being used, etc.) is sufficient for you to gather all the visual (e.g., non-verbal physical cues) and audible information you would normally observe in an in-person face-to-face interaction.
- You may only utilize the technology if your State-issued license authorizes you to do so and within the parameters of that authority.
All fleets need to conduct proper and thorough pre and post trip inspections, which consists of implementing quality:
- driver training that is ongoing and consistent
- driver education, and
- driver awareness of current and changing traffic laws
All of this will help prevent being targeted by the DOT at roadside inspections and is a valuable resource to ensure a healthy fleet, and compliant safety practices.