DOT Return-to-Duty Process: Why Step 6 Does Not Stop You From Getting Back to Work

If you are a commercial driver working through the DOT drug and alcohol return-to-duty (RTD) process, you have likely heard about the six required steps. What many drivers do not realize is that you do not need to complete all six steps before returning to safety-sensitive work.

Here is how the process works and where confusion often happens.

The Six Steps of the RTD Process

According to the Federal Motor Carrier Safety Administration (FMCSA), the return-to-duty process includes the following steps:

1. SAP request sent - The driver initiates the process by requesting a Substance Abuse Professional (SAP).
2. SAP designated - The driver selects and designates a SAP in the Clearinghouse.
3. Initial assessment completed - The SAP evaluates the driver and recommends treatment or education.
4. SAP determines eligibility for RTD testing - After the driver completes the recommendations, the SAP re-evaluates them and clears them for testing.
5. Return-to-duty test completed with a negative result - The driver completes a DOT-observed drug or alcohol test and receives a negative result.
6. Follow-up testing plan completed - The driver completes the SAP-prescribed follow-up testing plan over time.

When a Driver Is Eligible to Work Again

A driver is eligible to return to safety-sensitive work at the end of Step 5.

Once the driver receives a negative return-to-duty test result, they are no longer prohibited from performing safety-sensitive functions. They may legally return to driving or other DOT-regulated duties.

Common Misunderstanding About Step 6

Some employers or law enforcement officers mistakenly believe a driver must complete the entire follow-up testing plan before returning to work. This is incorrect.

1. Step 6 can take months or even years to complete
2. Drivers are not required to finish Step 6 before resuming safety-sensitive duties
3. FMCSA guidance confirms this interpretation

What to Do If Employers or Law Enforcement Push Back

If a driver is stopped or denied employment because Step 6 is not complete:

1. Contact the state FMCSA office
2. The state office can clarify the regulations to employers or law enforcement
3. While officers may not rely on the driver or SAP alone, they will follow guidance from FMCSA

Final Takeaway

Drivers are eligible to return to safety-sensitive work after Step 5, once they have completed treatment, been cleared by a SAP, and passed a return-to-duty test. Step 6 remains important, but it is completed while the driver is already back at work.

If someone claims otherwise, refer them to FMCSA guidance and continue forward.