FAA DOT Follow-Up Testing: Only Happens When You're Doing Safety-Sensitive Work

If you’ve gone through the SAP process after a DOT drug or alcohol violation, you’ve probably heard about follow-up testing. It’s a critical part of ensuring safety and accountability once someone returns to a safety-sensitive role.

But here’s something that often gets misunderstood: Follow-up testing only happens when the employee is actively performing safety-sensitive work.

Let’s break that down.

No Safety-Sensitive Work = No Follow-Up Testing

If an employee is not currently working in a safety-sensitive position, follow-up testing is not conducted. That includes:

1. Seasonal workers (like those in agriculture) who are off for the season
2. Employees on extended leave
3. Anyone who hasn’t yet returned to a safety-sensitive role after completing the SAP process

This is a DOT rule—not a loophole. Follow-up tests are designed to monitor employees while they’re in roles that impact public safety. If they’re not in that role, there’s nothing to monitor.

Common Question: “Who’s Doing the Follow-Up Testing?”

OFTEN ASKED QUESTION: “Who’s responsible for the follow-up tests if the employee isn’t working yet?”

The answer: no one is, because the testing doesn’t start until the employee is back in a safety-sensitive position. The clock on the follow-up testing plan begins only when the employee resumes those duties.

So if someone is off for the winter, or between jobs, or hasn’t yet returned to a safety-sensitive role—their follow-up testing plan is simply on pause.

What Happens When They Return?

Once the employee is hired back into a safety-sensitive role:

1. The employer resumes the follow-up testing plan
2. The schedule picks up where it left off
3. All tests must be conducted under direct observation
4. Time away from safety-sensitive work does not count toward plan completion

Final Thought

Follow-up testing is a powerful tool for maintaining safety—but it only applies when someone is actively in a safety-sensitive role. If they’re not working in that capacity, the testing waits. That’s not a gap in the system—it’s how the system is designed.

If you’re a SAP, DER, or employer navigating this process, make sure you’re clear on when the clock starts—and when it doesn’t.

Would you like help turning this into a seasonal guidance sheet for agricultural employers or a FAQ for SAP networks? I’d be happy to help you build that next.