DOT Return-to-Duty Process Explained
The return-to-duty process has a fixed order. Knowing it helps you see where you are and what's actually holding things up.
Steps one to three: the SAP's side
You're evaluated face to face. You receive an individualized recommendation for education, treatment or both. You complete it, and the SAP verifies your participation with the provider.
Step four: the compliance determination
At the follow-up evaluation, the SAP decides whether you've successfully complied. If you have, a report goes to your employer's designated employer representative along with a written follow-up testing plan.
Step five: the employer's side
Your employer decides whether to return you to duty — nothing in Part 40 requires them to — and arranges a directly observed return-to-duty test. A negative result is required before any safety-sensitive work.
Step six: follow-up testing
Once back at work, you're subject to unannounced, directly observed follow-up tests: at least six within the first 12 months, under a plan that can run up to 60 months. The SAP writes the plan; the employer administers it.
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