Why Outdated Safety-Sensitive Employee Policies Put Your Business at Risk — and How to Fix Them

What to Review, What to Change, and Why Partnering With CNS Matters

As a new year begins, businesses with safety-sensitive employees—including trucking companies, construction firms, manufacturers, warehouses, and logistics providers—have a critical opportunity to review and strengthen their company policies.

Regulations change, enforcement priorities shift, and operational risks evolve. Policies that were “good enough” last year can quickly become liabilities if they aren’t updated.

Below is a clear, practical framework for updating policies in the new year and why many companies formally include Compliance Navigation Specialists, CNS Driver Training Center, and CNS Occupational Medicine directly into their written programs.

The Core Best Practice: Name Partners the Right Way

Company policies should designate preferred or primary partners for specific services while allowing flexibility for emergencies or geographic limitations. This approach:

• Avoids legal and regulatory pushback
• Maintains DOT and OSHA neutrality
• Drives real-world utilization
• Holds up during audits and insurance reviews

For example, the most effective way to integrate services like drug testing, work-injury care, SAP coordination, CDL training, and compliance support is to name CNS companies as designated partners, using smart, defensible language.

Avoid: “All testing and treatment must be done at [CNS Occupational Medicine].”

Use instead: “[CNS Occupational Medicine] is the Company’s designated occupational health provider for applicable services when available.”

Let’s take a closer look at this.

How to Properly Add CNS Occupational Medicine to Policies

It Is important to break policy language by service category.

1. Drug & Alcohol Testing: The Company utilizes CNS Occupational Medicine as its designated collection site and occupational health partner for DOT and non-DOT drug and alcohol testing, including pre-employment, random, post-accident (non-emergency), reasonable suspicion, return-to-duty, and follow-up testing, when geographically available.
2. Drug & Alcohol Consortium / TPA: The Company participates in a DOT-compliant drug and alcohol testing program administered in coordination with CNS Occupational Medicine and its approved consortium/TPA partners.
3. DOT SAP Process: In the event of a DOT drug or alcohol violation, the Company will refer affected employees to a DOT-qualified Substance Abuse Professional (SAP). CNS Occupational Medicine coordinates SAP referrals, return-to-duty testing, and follow-up testing in accordance with 49 CFR Part 40.
4. DOT Physicals & Medical Certification: The Company utilizes CNS Occupational Medicine for DOT physical examinations and medical certification services when available. Employees are responsible for maintaining valid medical certification as a condition of employment.
5. Non-Emergency Work Injuries: For non-emergency workplace injuries, employees should report to CNS Occupational Medicine for evaluation and treatment when feasible. Emergency medical situations should be directed to the nearest emergency facility.

How to Name CNS Driver Training Center

• CDL Training & ELDT: The Company utilizes CNS Driver Training Center as its designated CDL training and testing partner for company-sponsored driver training, Entry-Level Driver Training (ELDT), and CDL skills testing when available and permitted by state and federal regulations.
• Company-Contract CDL Programs: Drivers enrolled in Company-sponsored or contract CDL training programs may receive instruction and testing through CNS Driver Training Center in accordance with Company agreements and applicable regulations.
• CDL Testing (Where Permitted): Where permitted by state law, the Company may utilize third-party CDL testing services provided by CNS Driver Training Center.

How to Name Compliance Navigation Specialists

• Driver Qualification Files (DQFs): The Company utilizes Compliance Navigation Specialists to support Driver Qualification File management, compliance review, and recordkeeping in accordance with FMCSA regulations.
• Crash & Post-Accident Compliance: Following a DOT-reportable crash or safety incident, the Company may engage Compliance Navigation Specialists to assist with compliance response, documentation, and regulatory support.
• DOT Audits & Investigations: In the event of a DOT audit or enforcement action, the Company may utilize Compliance Navigation Specialists for audit preparation, corrective action support, and regulatory guidance.

Policies to Prioritize Updating in 2026

1. Hiring & Qualification Policies
   • Review: screening standards, DQFs, MVRs, safety-sensitive definitions
   • Why it matters: hiring gaps often trigger audits and insurance issues
   • Why include CNS: creates a consistent, defensible qualification process
2. Drug & Alcohol Testing Policies
   • Review: testing types, consortiums, supervisor training, recordkeeping
   • Why it matters: one of the top DOT enforcement triggers
   • Why include CNS: ensures proper escalation, SAP coordination, and RTD flow
3. DOT SAP Policies:
   • Review: failed test handling, SAP steps, RTD conditions
   • Why it matters: termination-only policies increase risk and turnover
   • Why include CNS: faster RTD, consistent treatment, DOT-compliant handling
4. CDL Training & Ongoing Education:
   • Review: ELDT compliance, onboarding, retraining triggers
   • Why it matters: training gaps show up in crashes and litigation
   • Why include CNS Driver Training Center: documented, ELDT-compliant training
5. DOT Physicals & Occupational Medicine
   • Review: exam timelines, provider selection, med-card tracking
   • Why it matters: expired or downgraded cards sideline drivers
   • Why include CNS Occupational Medicine: faster scheduling, integrated services

Start the Year Strong With Policy Updates That Protect Your Business

The new year is the ideal time to move beyond generic templates and build real-world, enforceable programs for safety-sensitive employees. Updating hiring, drug and alcohol, SAP, training, and medical policies, while formally integrating trusted partners, helps protect your people, your fleet, and your business.

If your policies haven’t been reviewed recently, now is the time before an audit, accident, or insurance renewal forces the issue.

CNS can help you align compliance, training, and occupational health under one coordinated framework. Have questions, call us at 888.260.9448 or email at info@cnsprotects.com.