According to the U.S. Department of Transportation, a Substance Abuse Professional, aka an SAP, is a person who evaluates employees who have violated DOT drug and alcohol program regulation and makes recommendations concerning education, treatment, follow-up testing, and aftercare. But I think an SAP is more than that.
Certainly the SAP is often responsible for making the primary decision regarding placing an employee back behind the steering wheel of a school bus, or captaining a tour boat, or placing a hazardous materials driver back in charge of a tanker truck. And this responsibility is immense as a mistake can cause the loss of innocent lives and significant damages to property. But I think the SAP also has a responsibility to significantly influence the employee’s attitudes and behaviors when it comes to using drugs and alcohol in their lives.
The U.S. Department of Transportation is concerned with only one thing: making sure the employee is fit for duty so property and people are not threatened. As a result, the Code of Federal Regulations Title 49: Transportation, Part 40 – Procedures for Transportation Workplace Drug and Alcohol Testing Programs has been written to provide clear guidance and policy for the SAP.
Certain section of 49 CFR Part 40 which require particular attention include:
Subpart O – Substance Abuse Professional and
Subpart P – Confidentiality and Release of
Subpart Q – Roles and Responsibilities of Service
Subpart R – Public Interest Exclusions
Appendix E – SAP equivalency Requirements for
In order to officially act as an SAP, one must comply with the following:
(a) Credentials. You must have one of the following credentials:
(1) You are a licensed physician (Doctor of Medicine or Osteopathy);
(2) You are a licensed or certified social worker;
(3) You are a licensed or certified psychologist;
(4) You are a licensed or certified employee assistance professional;
(5) You are a state-licensed or certified marriage and family therapist; or
(6) You are a drug and alcohol counselor certified by the National Association of Alcoholism and Drug Abuse Counselors Certification Commission (NAADAC); or by the International Certification Reciprocity Consortium/Alcohol and Other Drug Abuse (ICRC); or by the National Board for Certified Counselors, Inc. and Affiliates/Master Addictions Counselor (NBCC).
(b) Basic knowledge. You must be knowledgeable in the following areas:
(1) You must be knowledgeable about and have clinical experience in the diagnosis and treatment of alcohol and controlled substances-related disorders.
(2) You must be knowledgeable about the SAP function as it relates to employer interests in safety-sensitive duties.
(3) You must be knowledgeable about this part, the DOT agency regulations applicable to the employers for whom you evaluate employees, and the DOT SAP Guidelines, and you keep current on any changes to these materials. These documents are available from ODAPC (Department of Transportation, 1200 New Jersey Avenue, SE, Washington, DC 20590 (202–366–3784), or on the ODAPC web site (http://www.dot.gov/ost/dapc).
(c) Qualification training. You must receive qualification training meeting the requirements of this paragraph (c).
(1) Qualification training must provide instruction on the following subjects:
(i) Background, rationale, and coverage of the Department’s drug and alcohol testing program;
(ii) 49 CFR Part 40 and DOT agency drug and alcohol testing rules;
(iii) Key DOT drug testing requirements, including collections, laboratory testing, MRO review, and problems in drug testing;
(iv) Key DOT alcohol testing requirements, including the testing process, the role of BATs and STTs, and problems in alcohol tests;
(v) SAP qualifications and prohibitions;
(vi) The role of the SAP in the return-to-duty process, including the initial employee evaluation, referrals for education and/or treatment, the follow-up evaluation, continuing treatment recommendations, and the follow-up testing plan;
(vii) SAP consultation and communication with employers, MROs, and treatment providers;
(viii) Reporting and recordkeeping requirements;
(ix) Issues that SAPs confront in carrying out their duties under the program.
(2) Following your completion of qualification training under paragraph (c)(1) of this section, you must satisfactorily complete an examination administered by a nationally-recognized professional or training organization. The examination must comprehensively cover all the elements of qualification training listed in paragraph (c)(1) of this section.
(3) The following is the schedule for qualification training you must meet:
(i) If you became a SAP before August 1, 2001, you must meet the qualification training requirement no later than December 31, 2003.
(ii) If you become a SAP between August 1, 2001, and December 31, 2003, you must meet the qualification training requirement no later than December 31, 2003.
(iii) If you become a SAP on or after January 1, 2004, you must meet the qualification training requirement before you begin to perform SAP functions.
(d) Continuing education. During each three-year period from the date on which you satisfactorily complete the examination under paragraph (c)(2) of this section, you must complete continuing education consisting of at least 12 professional development hours (e.g., CEUs) relevant to performing SAP functions.
(1) This continuing education must include material concerning new technologies, interpretations, recent guidance, rule changes, and other information about developments in SAP practice, pertaining to the DOT program, since the time you met the qualification training requirements of this section.
(2) Your continuing education activities must include documentable assessment tools to assist you in determining whether you have adequately learned the material.
(e) Documentation. You must maintain documentation showing that you currently meet all requirements of this section. You must provide this documentation on request to DOT agency representatives and to employers and C/TPAs who are using or contemplating using your services.
It is clear that being an SAP is a significant effort, and an ongoing effort as well. The U.S. Department of Transportation clearly wants educated professionals making appropriate determinations about an employee’s ability to perform safety-sensitive job duties.
The regulations are thorough regarding policies and procedures that must be followed in order to allow an employee to return to duty. There must be, at a minimum, a face-to-face clinical assessment, a referral fo appropriate education and/or treatment, a face-to-face follow up evaluation, a follow-up drug and/or alcohol testing plan for the employee, and employee/employer recommendations for continuing education and/or treatment.
But there is something that may be missing in all of this process and procedure. The individualization of the interventions provided for the employee may be lost to normalized approaches to SAP interventions.
There is tremendous opportunity for the SAP to intervene earlier, rather than later, with an individual who is dangerously approaching addiction and alcoholism. Perhaps they are not quite exhibiting the criteria of addiction yet, but the negative consequences of violating the DOT drug and alcohol program regulation can be a genuine revelation for the employee that may not realize the longer-term effects of their behaviors.
An SAP can offer great insight into how drinking and drugging can cause irreparable damage to one’s life. The use of generalized storytelling and the citation of facts and statistics may be enough to cause the employee to engage in the recommendations of the SAP at a higher level of attention and meaning.
Without motivation, the employee may go through all the necessary steps to return to duty, but they may not learn much in the process. The SAP has an opportunity to help set-up the mindset of the employee prior to their engagement in education and/or treatment. Additionally, the SAP can check-in on the employee throughout the course of the recommendations.
Checking in with the employee while they are participating in the recommended education and/or treatment is an excellent way to assess the progress being made by the employee and intervening on negative attitudes if necessary. It is my opinion this should not be left to the referred agencies, as the employee is also the responsibility of the SAP.
In my experience, SAPs are usually engaged in the work because they want to help people overcome their problems with substance abuse and addiction; however the burden of paperwork and the necessity of large caseloads can quickly create a repetitive process in which most employees are viewed as cases instead of individuals. This is not to fault the SAP, it is simply a natural phenomenon that occurs when so many regulations are in place.
I encourage SAPs to work into their procedural model a reminder to connect with the employee on a human level. To speak with them about their motivations and needs, and to intervene when the employee’s thinking begins to drift away from the important work of living life without substance abuse or addiction.