Reasonable Suspicion Checklist and Observation Form (Free PDF)

Free download: the observation checklist and report form

Two pages, built for a clipboard or a phone. Page one is the checklist by category with the deadlines printed on it. Page two is the written observation record required by §382.307(f): observations line by line, the determination, who drove the driver to the collection site, test times, and the signature block.

Built from the current text of 49 CFR 382.307 and 382.603.
No company name on it, so it works inside your own policy.
Free. Enter an email to get a copy sent to you, or open the PDF without one.

What the rule lets you act on

Section 382.307 names four kinds of observation: appearance, behavior, speech, and body odors. For controlled substances the observations may also include indications of chronic and withdrawal effects. 49 CFR 382.307(a)–(b) The examples below are the kind of thing a trained supervisor notices and writes down. They are observations, not a diagnosis. You are not deciding what the driver took; you are recording what you saw, heard, and smelled, and letting the test answer the rest.

Appearance · what you see

Bloodshot, glassy, or watery eyes
Pupils noticeably dilated or pinpoint
Flushed or unusually pale face
Unsteady stance, swaying, leaning on something for support
Sweating not explained by heat or work
Tremors or shaking hands
Disheveled, or a clear change from the driver’s normal appearance

Behavior and performance · what you watch

Unsafe act or near miss
Wide turns, abrupt corrections, drifting
Skipped or botched required steps: pre-trip, securement, paperwork
Slow reactions, drowsiness, nodding off
Agitation, aggression, or sudden mood swings
Confusion, poor coordination, fumbling simple tasks
Laughing, crying, or anger that does not fit the situation

Speech · what you hear

Slurred or thick speech
Unusually slow, or rapid and pressured
Rambling, incoherent, or losing the thread
Difficulty finding ordinary words
Much louder or much quieter than normal

Body odors · what you smell

Alcohol on the breath at normal conversation distance
Odor of marijuana on breath, clothing, or in the cab
Another chemical odor you can name
Strong mint, cologne, or mouthwash covering another odor (note both)

What does not count

The same paragraph that tells you what to observe rules out everything else. Leave these out of the determination and out of the record:

Conclusions. “He is drunk” and “she is high” are opinions. Write the slurred words and the odor instead.
Hearsay. A dispatcher’s call, a customer complaint, or a coworker’s story can send you to go look. It cannot be the observation.
History. Last month’s incident, attendance, and attitude are not contemporaneous.
Guesses about cause. Hangover, medication, personal problems. The test, the medical review officer, and the driver sort that out.
Alcohol observations outside the window. An alcohol test is authorized only when the observations are made during, just before, or just after the driver’s safety-sensitive work. 49 CFR 382.307(d)

Before you order the test

Four questions, in order. Each one maps to a paragraph of the rule.

Have you completed the 60 minutes on alcohol misuse and 60 minutes on controlled substances required by §382.603?
Yes: Continue to question 2.
No: You are not the person who can make this determination. Get a trained supervisor or company official to observe the driver now, and complete the training before you are put in this position again.
Are your observations specific, contemporaneous, and articulable, and limited to appearance, behavior, speech, or body odors?
Yes: Continue to question 3.
No: Go observe the driver yourself. A report from someone else, a hunch, or history is not a basis for the test.
For an alcohol test: were the observations made during, just before, or just after the driver’s safety-sensitive functions?
Yes: Continue to question 4.
No: An alcohol test is not authorized under §382.307(d). Company policy may still require action; the DOT alcohol test is not the tool.
Can someone other than you conduct the alcohol test, and is transportation to the collection site arranged?
Yes: Make the determination, remove the driver from safety-sensitive functions, and start the clock. Fill in page two of the form as you go.
No: The person who determines reasonable suspicion for an alcohol test may not conduct it (§382.307(c)). Line up a collection site or technician and a ride before you tell the driver.

The clock after the determination

Every deadline in §382.307 runs from the moment you decide, not from the moment the driver arrives at the clinic. Note the time of your determination on the form.

Deadlines that start with a reasonable suspicion determination
Deadline	What the rule requires	Citation
2 hours (alcohol)	If the alcohol test is not administered within two hours of your determination, prepare a record stating why and keep trying.	49 CFR 382.307(e)(1)
8 hours (alcohol)	Stop attempts to administer an alcohol test and state in the record why no test was given.	49 CFR 382.307(e)(1)
24 hours, or a result under 0.02	The driver may not perform safety-sensitive functions until an alcohol test reads below 0.02 or 24 hours have passed since the determination, even if no test was ever given.	49 CFR 382.307(e)(2)
24 hours (the written record)	Sign a written record of the observations within 24 hours of the observed behavior or before the test results are released, whichever is earlier.	49 CFR 382.307(f)
Drug test	Section 382.307 sets no fixed clock for the controlled substances collection. Test promptly and record the reason for any delay.	49 CFR 382.307(b)

How to write the observation record

The rule does not prescribe a form. It requires a written record of the observations that led to the test, signed by the person who made them, within 24 hours or before the results come back. 49 CFR 382.307(f) A record that would satisfy an auditor or an arbitrator has five things: who observed, what exactly, when, where, and a signature with the date and time.

The same incident, written two ways

Write this: “6:05 p.m., yard gate. Smelled alcohol on his breath from about two feet away while he answered my question. Words were slurred: said ‘I’m fine’ twice. Steadied himself on the mirror arm when he stepped down.”
Not this: “Driver was obviously drunk. Dana said he was out drinking last night. He has been late twice this month and has an attitude.”
Why the difference matters: The first version is what the rule asks for: specific, contemporaneous, articulable, and limited to appearance, behavior, speech, and odor. The second is a conclusion, hearsay, and history. If the test is challenged, the record is what gets read.

One observation per line, each with a time.
Quote the driver’s own words rather than summarizing them.
Record what you did next: the time you told the driver, the time you removed them from safety-sensitive functions, who drove them to the collection site, and when the test was given.
If the two-hour or eight-hour alcohol deadline passes, write the reason on the same record.
Keep the record with your Part 382 files and give a copy to your designated employer representative.

Related guides

Reasonable suspicion vs. post-accident testing: different triggers, different clocks, and when both apply.
When a driver refuses a reasonable suspicion test: what counts as a refusal and what the employer must do next.
Who needs reasonable suspicion training: by DOT mode, with the edge cases.

Frequently asked questions

Can I order a reasonable suspicion test based on what a coworker told me?

No. The observations behind the test must be made by a supervisor or company official trained under 49 CFR 382.603, and they must be specific, contemporaneous, and articulable. A coworker’s report is a reason to go observe the driver yourself; it is not a substitute for your own observations.

Is there an official DOT reasonable suspicion form?

No. 49 CFR 382.307(f) requires a written record of the observations, signed by the person who made them, within 24 hours of the observed behavior or before the test results are released, whichever is earlier. Any format that captures who observed what, when, and where, with a signature, satisfies the rule. The free form on this page is built to that requirement.

How long do we keep the observation record?

At least two years. Documents generated in connection with a decision to administer a reasonable suspicion test are records related to the collection process under 49 CFR 382.401(c)(1)(v), which carry a two-year minimum under 382.401(b)(2). If the driver refuses the test, keep the refusal documentation for at least five years under 382.401(b)(1)(iii). Store the records in a secure location with controlled access.

Can the supervisor who made the determination conduct the alcohol test?

No. 49 CFR 382.307(c) says the person who determines that reasonable suspicion exists for an alcohol test shall not conduct that alcohol test. Use a breath alcohol technician or screening test technician at a collection site, or another qualified person.

What happens if the alcohol result is between 0.02 and 0.039?

The driver may not perform safety-sensitive functions until the start of the next regularly scheduled duty period, and not less than 24 hours after the test. Under 49 CFR 382.505, the employer may not take other Part 382 action based solely on a result under 0.04, although company policy with independent authority may still apply.

Does marijuana legalization change what I document?

No. Marijuana remains a Schedule I substance under 21 CFR 1308.11, and 49 CFR 382.213(a) prohibits a driver from reporting for or remaining on duty requiring safety-sensitive functions while using any Schedule I substance. Record the odor and the indicators you observe the same way you would for alcohol.

What if the driver refuses the test?

A refusal carries the same consequences as a violation: the driver is removed from safety-sensitive functions and cannot return until completing the substance abuse professional process in 49 CFR part 40, subpart O. The employer must report the refusal to the FMCSA Clearinghouse by the close of the third business day. Your written observation record is still required.

Sources

Every citation on this page was checked against the eCFR text in effect on October 30, 2026.