Maintaining a safe workplace requires supervisors and employers to recognize when an employee may be impaired by drugs or alcohol. This is especially important in safety-sensitive environments where one impaired decision can put the employee, coworkers, customers, or the public at risk.
Reasonable suspicion does not mean guessing, assuming, or relying on rumors. It means there are specific, observable signs that give an employer a reasonable basis to believe an employee may be under the influence while at work.
For DOT-regulated employees, the Federal Motor Carrier Safety Administration states that reasonable suspicion must be based on “specific, contemporaneous, articulable observations” related to the employee’s appearance, behavior, speech, or body odors. (eCFR)
What Is Reasonable Suspicion?
Reasonable suspicion occurs when a trained supervisor observes physical, behavioral, or performance-related signs that may indicate drug or alcohol use. These signs should be documented clearly and objectively.
The goal is not to diagnose the employee or accuse them of substance use. The goal is to determine whether the employee can safely continue working and whether testing is appropriate under the employer’s policy.
Common Signs an Employee May Be Under the Influence
1. Changes in Appearance
Supervisors should look for visible signs that are unusual for the employee, such as:
- Bloodshot, glassy, or watery eyes
- Dilated or constricted pupils
- Flushed, pale, or sweaty appearance
- Poor coordination or balance
- Stumbling, swaying, or unsteady walking
- Tremors, shaking, or unusual fatigue
- Disheveled appearance that is out of character
One sign alone may not prove impairment, but multiple signs observed together may support reasonable suspicion.
2. Unusual Behavior
Behavioral changes are often one of the clearest indicators that something may be wrong. Warning signs may include:
- Confusion or disorientation
- Difficulty concentrating
- Mood swings or sudden irritability
- Unusual aggression, anxiety, paranoia, or euphoria
- Inappropriate laughing, crying, or emotional reactions
- Trouble following instructions
- Unsafe work practices
- Poor judgment or risk-taking behavior
- Repeatedly leaving the work area without explanation
Supervisors should focus on behavior they can describe, not personal opinions about the employee.
3. Speech Changes
Drug or alcohol impairment may affect how an employee speaks. Signs may include:
- Slurred speech
- Slow or delayed responses
- Rapid, pressured, or rambling speech
- Incoherent answers
- Repeating the same statements
- Difficulty answering simple questions
- Losing their train of thought
Documenting these observations is important because speech-related signs can be clearly described and time-sensitive.
4. Odor or Physical Clues
Odors and other physical clues may support reasonable suspicion when combined with other observations. These may include:
- Smell of alcohol
- Smell of marijuana
- Chemical odors
- Excessive use of mouthwash, breath spray, cologne, or perfume
- Vomiting or nausea
- Evidence of drug paraphernalia
An odor alone should be documented carefully. For example, instead of writing “employee was drunk,” a supervisor should write, “Supervisor detected a strong odor of alcohol on the employee’s breath.”
5. Work Performance or Safety Concerns
Substance use may also show up through sudden changes in job performance, such as:
- Mistakes on routine tasks
- Missed steps in safety procedures
- Accidents or near misses
- Unsafe operation of vehicles, tools, or equipment
- Sudden decline in productivity
- Excessive tardiness or unexplained absences
- Complaints from coworkers, customers, or supervisors
Performance issues should be considered alongside direct observations of appearance, behavior, speech, or odor.
What Supervisors Should Do
When reasonable suspicion is suspected, employers should act promptly and consistently.
Step 1: Observe directly
A supervisor should personally observe the employee whenever possible. Coworker reports may alert management to a concern, but the decision to test should be based on direct, documented observations.
Step 2: Use a second supervisor if available
Having a second trained supervisor observe the employee can strengthen the decision-making process and reduce the risk of bias.
Step 3: Document objective facts
Documentation should include:
- Date and time of the observation
- Location
- Specific signs observed
- Employee behavior and statements
- Names of supervisors or witnesses
- Action taken
Avoid vague statements such as “employee seemed high” or “employee acted weird.” Instead, write what was actually seen, heard, or smelled.
Step 4: Remove the employee from safety-sensitive duties
If impairment is suspected, the employee should not continue performing safety-sensitive work, driving, operating machinery, treating patients, or performing tasks that could place others at risk.
Step 5: Follow the company policy
Employers should follow their written drug and alcohol policy, including procedures for reasonable suspicion testing, transportation, confidentiality, and return-to-work requirements.
SAMHSA recommends that supervisors be trained to recognize and respond to workplace problems that may be related to alcohol or drug use, and that training should be tailored to the workplace and the employer’s policy. (SAMHSA)
Step 6: Arrange safe transportation
If an employee is suspected of being impaired, they should not be allowed to drive themselves home or to a testing location. Arrange transportation according to company policy.
DOT-Regulated Employees
For DOT-covered employees, reasonable suspicion rules are stricter. Under 49 CFR § 382.307, reasonable suspicion for alcohol or controlled substances testing must be based on specific observations of the driver’s appearance, behavior, speech, or body odors. The regulation also notes that controlled substance observations may include signs of chronic use or withdrawal. (eCFR)
DOT supervisors should receive proper reasonable suspicion training. FMCSA guidance explains that requests for reasonable suspicion testing must be based on observable, articulable facts, not assumptions. (FMCSA)
The Bottom Line
Reasonable suspicion is about workplace safety, not punishment. Employers should train supervisors to recognize warning signs, document observations objectively, and follow a consistent process.
A good rule for supervisors is this:
Can I clearly explain, in writing, what I personally observed that made me believe this employee may be impaired?
If the answer is yes, and the observations involve appearance, behavior, speech, odor, performance, or safety concerns, reasonable suspicion testing may be appropriate under the employer’s policy.
Need Help With Drug and Alcohol Testing?
Integrated Care provides occupational health services, including drug and alcohol testing support for employers. Our team can help businesses maintain a safer workplace with timely testing, clear documentation, and professional service.
Contact Integrated Care today to learn more about reasonable suspicion testing and occupational health services.