DRUG AND ALCOHOL TESTING - SUPERVISOR GUIDANCE

Supervisors are to have their employees tested using a DOT drug kit if any of the two following incidents occur.

Supervisors should escort the individual to the drug and alcohol testing collection site.  If they are unable to do so, they may designate an employee to escort the individual to the testing collection site. 

Pipeline Hazard Materials (PHMSA) Incident*:

If there is a release of gas, hazardous liquid or CO2 AND one of the statements below is true, then you must test using a Post-Accident DOT kit: 

  • A human fatality occurred
  • Explosion or non-intentional fire
  • Personal injury requiring in-patient hospitalization
  • Accidental release of at least 5 gal. of hazardous liquid or CO2
  • Estimated property damage including clean-up, recovery, lost production and damage to property exceeds 
    • $50,000 due to a release hazardous liquid or CO2 OR
    • $145,400 due to a release of gas 
  • Unintentional estimated gas loss of three million cubic feet or more 
  • Event was deemed significant by a Pipeline Operator

Federal Motor Carrier (FMCSA) Driving Incident*:

If there is an accident involving a KM Commercial Motor Vehicle AND one of the following:

  • A human fatality occurred
  • Bodily injury requiring medical treatment away from the scene AND a citation for a moving violation was issued to the CMV driver
  • Disabling damage to any motor vehicle requiring tow away AND a citation for a moving violation was issued to the CMV driver

All other incidents that do not meet the above requirements should have employees drug and alcohol tested using non-DOT drug kits.

However, if you are in doubt regarding the type of incident that occurs, utilize a DOT drug kit as it is easier for the drug test to be downgraded to a non-DOT incident.

*Note that management has the discretion not to test an individual if it is determined they had no role in the cause of the incident.

Supervisors are to utilize the specific documents listed below when the following occurs.


1. Use the PHMSA-FMCSA Incident Accident Drug and Alcohol Testing Record document if an accident occurs that qualifies as DOT.  Once completed, upload the document into IMPACT. 

2. Use the Post-Accident Supervisor Written Record document if an accident occurs where an individual isn’t drug tested within 32 hours of incident AND/OR alcohol tested within 8 hours and then 2 hours of an incident.  Once completed, upload the document into IMPACT. 

3. Use both documents below if an accident occurs that qualifies as DOT AND an individual isn’t drug tested within 32 hours of incident AND/OR alcohol tested within 8 hours and then 2 hours of an incident.  Once completed, upload both documents into IMPACT.

Reasonable Cause/Suspicion Guidance

Supervisors are to conduct reasonable cause/suspicion testing on employees based on the observation of “signs and symptoms” displayed by an employee. This document must be provided to your HR Representative upon completion.  

Documentation must be prepared:

  • Within 24 hours of the observed behavior OR
  • Before the results of the tests are released, whichever is earlier.

Supervisors or a member of management/employee designee are required to escort the employee to and from the collection site for testing. Employees are not allowed to return to work until a negative test result is received.

Drug Testing Collection Sites

If you have any questions, please contact your HR Representative or the following HR Services team members: