Return-To-Duty (RTD) Workflow

A driver who tested positive or refused cannot return to safety-sensitive work until completing the full RTD sequence under § 40.305 + § 382.605.

The sequence

1. Removal from safety-sensitive functions (immediate, day-of test result)
2. SAP evaluation completed (initial)
3. Treatment/education completed per SAP plan
4. SAP follow-up evaluation — SAP issues "may return" report
5. Return-to-duty test — controlled substance test (alcohol if SAP prescribed)
   • Must be observed collection per § 40.67 (one of three triggers)
   • Result must be negative
6. Driver returns to safety-sensitive work
7. Follow-up testing schedule begins (per § 382.605)

Observed collection requirement

Per § 40.67, the RTD test (and follow-up tests) must be observed:

• Same-gender observer
• Observer watches the urine leave the body
• Observer not the same person who collects the test (typically)

Clearinghouse updates

• Day of positive test: report to Clearinghouse within 3 business days
• Day of SAP report: update Clearinghouse with SAP info + follow-up schedule
• Day of negative RTD test: update Clearinghouse — status moves from "prohibited" to "not prohibited"
• Each follow-up test result: report within 3 business days

Common timeline

• Removal to SAP eval: 1-2 weeks
• SAP eval to treatment completion: 4-12 weeks (varies)
• Treatment to follow-up SAP eval: 1-2 weeks
• SAP report to RTD test: 1 week (often same day)
• RTD test to return-to-duty: same day if negative
• Total typical: 6-16 weeks

What carriers commonly get wrong

• Returning driver before SAP follow-up evaluation (must be the second SAP visit, not the first)
• Conducting RTD test as a regular pre-employment test (must be observed)
• Forgetting to update Clearinghouse on the negative RTD test → driver shows "prohibited" forever
• Allowing a driver to drive for personal/yard purposes before negative RTD test

CFR citations

• 49 CFR § 40.305
• 49 CFR § 40.67
• 49 CFR § 382.605
• 49 CFR § 382.701

How Compass surfaces this

This skill is searchable in the Compass Ask interface and runs against the carrier's actual fleet data when invoked from within the relevant tracker. It is read-only — no actions are taken without explicit user approval.

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