Short Answer

A DOT Substance Abuse Professional must hold one of several specific professional credentials, complete qualification training on the DOT testing and Return to Duty process, pass an exam administered by a nationally recognized professional or training organization, and complete continuing education every three years. 49 CFR § 40.281 These are minimum federal requirements. Individual states or credentialing bodies may impose additional licensing rules that are separate from Part 40.

Detailed Explanation

Required Professional Credential

To act as a DOT SAP, a person must be one of the following: a licensed physician (MD or DO), a licensed or certified social worker, a licensed or certified psychologist, a licensed or certified employee assistance professional, or a drug and alcohol counselor certified by an organization listed by the DOT's Office of Drug and Alcohol Policy and Compliance. 49 CFR § 40.281 The underlying license or certification must be current and in good standing under whatever state or board rules govern that credential.

Required Qualification Training

Beyond the base credential, a DOT SAP must complete training that covers specific subject matter, including:

• The background and rationale for the DOT drug and alcohol testing program
• 49 CFR Part 40 and the applicable DOT agency's own drug and alcohol rules
• Drug testing requirements, including collection, laboratory testing, Medical Review Officer review, and problems that can arise in testing
• Alcohol testing requirements, including the testing process and the roles of the Breath Alcohol Technician and Screening Test Technician
• The SAP's specific role in the Return to Duty process: initial evaluation, referral, follow up evaluation, continuing treatment recommendations, and the follow up testing plan
• How to consult and communicate with employers, Medical Review Officers, and treatment providers

49 CFR § 40.281

Examination and Continuing Education

After completing qualification training, the individual must pass an examination administered by a nationally recognized professional or training organization. Once qualified, a SAP must complete at least 12 professional development hours of continuing education every three years, measured from the date of the qualifying exam. 49 CFR § 40.281

Applicable Regulations

• 49 CFR § 40.281, listing the eligible professional credentials, required training content, exam requirement, and continuing education requirement

Professional Observation

In my experience, drivers and employers sometimes assume any addiction counselor or therapist automatically qualifies to conduct a DOT SAP evaluation. That's not accurate. A professional needs the underlying license or certification listed above, plus the specific DOT qualification training and exam. It's reasonable, and often necessary, for an employee or employer to ask a prospective SAP to confirm their qualification status directly rather than assume it. You can view my credentials by clicking here.

Common Misconceptions

Misconception

Any licensed counselor or social worker can perform a DOT SAP evaluation.

Reality

The underlying license or certification is necessary but not sufficient. The individual must also complete DOT specific qualification training, pass the required exam, and maintain continuing education. 49 CFR § 40.281

Why the Confusion Occurs

Many licensed behavioral health professionals do excellent clinical work with substance use disorders generally, so it seems reasonable to assume they can also perform the specific DOT function. The DOT credential is a separate, additional layer on top of the base license.

Frequently Asked Questions

How can I confirm someone is a qualified DOT SAP?

Ask the individual directly for confirmation of their underlying license or certification, their completion of DOT qualification training, and their exam status. If you need help verifying a SAP's credentials, your DER or the applicable DOT agency can also be a resource.

Does the required continuing education ever change?

Specifics of accepted continuing education providers can vary and are set by the training and credentialing organizations recognized for this purpose. Confirm current requirements with your SAP training organization or the applicable DOT agency rather than relying on outdated information.

Related Articles

• What Is a DOT Substance Abuse Professional?
• How Do I Choose a DOT SAP?
• What Are the SAP's Responsibilities?
• What Ethical Responsibilities Does a DOT SAP Have?

Primary Authorities/Sources

• 49 CFR § 40.281, who is qualified to act as a SAP

Working With a Qualified SAP

Confirming a SAP's qualifications before your evaluation begins can prevent delays later in the Return to Duty process.

Schedule an Initial SAP Assessment