on January 25, 2026

By the Current Consulting Group

Drug Testing Training Requirements: What Employers and Supervisors Need to Know  

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When employers think about workplace drug testing compliance, policies and testing methods usually get the most attention. However, training, specifically training for supervisors, employers, and employees, is just as critical and, in many cases, legally required.

Both federal regulations and some state laws impose training obligations that employers must understand and implement correctly. Failing to do so can expose organizations to compliance violations, liability risks, and breakdowns in workplace safety.

Federal Drug Testing Training Requirements (DOT-Regulated Employers) 

For employers regulated by the U.S. Department of Transportation (DOT) drug and alcohol testing regulations and training requirements are clearly defined and mandatory.

Under 49 CFR Part 40, DOT-regulated employers must ensure that supervisors who oversee transportation-related safety-sensitive employees receive reasonable suspicion training. This training must cover:

  • The physical, behavioral, speech, and performance indicators of drug use
  • The physical, behavioral, speech, and performance indicators of alcohol misuse

For example, the Federal Motor Carrier Safety Administration (FMCSA) requires supervisors to complete at least 60 minutes of drug training and 60 minutes of alcohol training under 49 CFR §382.603. Similar requirements exist under other DOT agencies, including the Federal Aviation Administration (FAA), Federal Railroad Administration (FRA), Federal Transit Administration (FTA), and Pipeline and Hazardous Materials Safety Administration (PHMSA), as well as the U.S. Coast Guard (USCG).

In addition to supervisor training, DOT programs often require or strongly encourage training for:

Importantly, while service agents play a key role in administering testing programs, a service agent may not act as a DER. Employers remain legally responsible for ensuring DERs understand their obligations under 49 CFR Part 40.

Employer and Supervisor Training Outside of DOT Programs

For non-DOT employers, training requirements are driven primarily by state law, and this is where compliance can become complicated.

Some states incentivize or require supervisor training as a condition of qualifying for workers’ compensation discounts and/or legal protections. These requirements often include training on:

  • Recognizing the signs of substance misuse
  • Proper documentation and response procedures
  • Company drug testing policies
  • Employee rights and responsibilities

Even when not explicitly required, supervisor training is widely recognized as a best practice. Properly trained supervisors are better equipped to handle reasonable suspicion situations consistently and defensibly, reducing the risk of improper testing decisions or discrimination claims.

Employee Drug Testing Education: What Do States Require?

Unlike supervisor training, employee education requirements vary widely by state, and many states do not regulate employee training at all. However, several states do impose specific requirements related to content, duration, and renewal.

Some examples include:

  • Tennessee: Requires detailed employee education content, including the effects of drugs and alcohol, the disease model of addiction, and company policies
  • Alabama, Kentucky, Mississippi, Ohio, and Wyoming: Require at least one hour of employee education, with varying renewal schedules
  • Kentucky: Allows renewal training to be reduced to 30 minutes after the initial session

Even in states without explicit education mandates, employee training is a best practice that can deliver beneficial results. Education programs, for instance, help employees understand expectations, testing procedures, consequences of violations, and available resources for assistance, contributing to safer and more transparent workplaces. They can also help employers to be supportive of the company’s drug testing program in general.

The Role of Training in Program Integrity 

Training is not just a regulatory checkbox; it directly impacts the effectiveness of a drug testing program.

Well-trained supervisors are more confident in recognizing and addressing potential impairment. Educated employees are more likely to understand program expectations and less likely to challenge testing decisions. DERs who receive proper training are better prepared to manage results, communicate with service agents, and respond to complex testing scenarios.

According to DOT guidance and industry best practices, ongoing training—rather than one-time instruction—helps ensure compliance as laws, testing methods, and company priorities evolve.

Best Practices for Employers

To stay compliant and reduce risk, employers should:

  • Identify which federal agency or state laws govern their program
  • Confirm required training topics, duration, and renewal cycles
  • Provide documented training for supervisors, DERs, and employees
  • Refresh training regularly, even when not explicitly required
  • Work with qualified experts who understand both federal and state requirements

Conclusion

Training requirements for supervisors, employers, and employees are a foundational element of compliant drug testing programs. While DOT-regulated employers face clearly defined federal mandates, non-DOT employers must navigate a patchwork of state laws and best practices.

Understanding and implementing the right training not only helps meet legal obligations but also strengthens workplace safety, consistency, and program credibility.

Current Consulting Group offers training for supervisors, employees, and DERs under both federally regulated and non-federally regulated requirements. For additional guidance on employer and employee drug testing training, visit www.currentconsultinggroup.com or explore DOT regulations directly at www.ecfr.gov.

 

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