Return-to-Duty Testing: What It Is, What It Isn’t, and What SAPs Need to Know

If you’re a Substance Abuse Professional (SAP), employer, or safety-sensitive employee, understanding the return-to-duty (RTD) test is essential. It’s not just another drug test—it’s a second chance. But there’s a lot of confusion about what it is, who’s responsible, and when it should happen.

Let’s clear it up.

What Is a Return-to-Duty Test?

A return-to-duty test is a DOT-required drug and/or alcohol test that must be conducted after an employee has violated DOT drug and alcohol regulations and has completed the SAP process. It is:

1. Observed (no exceptions)
2. Triggered by the employer after receiving the SAP’s follow-up report
3. Required to be negative before the employee can return to safety-sensitive duties

This test is not for employees returning from long-term leave, vacation, or medical absence. That’s a pre-employment or pre-duty test—not a return-to-duty test.

What’s the SAP’s Role?

As a SAP, your job is to:

1. Conduct the initial and follow-up evaluations
2. Recommend treatment or education
3. Determine compliance
4. Create a follow-up testing plan
5. Indicate whether the RTD test should be for alcohol, drugs, or both (always check both if applicable)

You do not:

1. Schedule the RTD test
2. Monitor the test
3. Keep custody and control forms
4. Track follow-up testing

That is the employer’s responsibility.

What If the Employee Was Terminated?

Here’s where it gets tricky. If an employee was terminated after a violation:

1. Their previous employer will not conduct the RTD test
2. They remain ineligible for safety-sensitive work
3. A new employer must initiate the RTD test process after hiring, or a C/TPA may be used to complete it without an employer

Until that negative RTD test is completed, the employee’s Clearinghouse record will show “Not Eligible for Safety-Sensitive Functions.”

What If the Test Is Cancelled?

If the RTD test is cancelled for any reason—lab error, collection issue, etc.—it must be repeated. A valid, negative result is required before the employee can return to duty.

Final Thought: Know Your Role, Protect the Process

The return-to-duty test is a critical checkpoint in the DOT process. As a SAP, your role is to guide the employee to the threshold—but it’s the employer who opens the door.

So remember:

1. RTD tests are only for DOT violations
2. They must be observed and negative
3. SAPs don’t manage the test—they design the plan