Over the past few weeks, I have received a number of questions from motor carriers on a diagnosis of alcoholism as it relates to a driver’s medical qualifications.
After going for a physical, the drivers were told they had to go to a substance abuse professional (SAP) before becoming medically certified. The employers were confused since the driver did not test positive on a DOT alcohol test. In some instances, the drivers did not hold a commercial driver’s license (CDL) to even qualify for testing under Part 382.
Section 391.41(b)(13): Current clinical diagnosis of alcoholism
Alcoholism is listed as a medical disqualification in §391.41(b)(13). It is not to be confused with a positive alcohol test performed under Part 382 for CDL drivers. During a driver’s physical exam, the medical examiner (ME) is instructed in the Federal Motor Carrier Safety Regulations and guidance materials to look for signs of alcoholism, such as tremors or an enlarged liver.
Furthermore, the ME must address any “yes” answers that the driver provided under the health history portion of the physical exam form that indicate a potential alcohol problem. Question 30 on the form asks, “Do you currently drink alcohol?” As you can imagine, a lot of individuals answer yes since alcohol is a legal, recreational substance. The driver is then asked to explain any yes responses in a box provided on the form.
The ME will follow up on the response by asking the driver about his or her frequency of alcohol consumption. The ME is looking for a consumption pattern (quantity per occasion or per day/week) that indicates additional evaluation may be needed.
The ME may also inquire into the driver and/or family’s alcohol-related medical and behavioral problems. Standardized screening questions on alcohol use (e.g., Alcohol Use Disorders Identification Test (AUDIT), CAGE, and T-ACE) are at the ME’s disposal.
Drivers with suspected alcoholism
If the medical examiner has reason to believe the driver has a current clinical diagnosis of alcoholism, he or she can request a course of treatment and counseling before certifying the driver. That’s where the SAP referral comes into play.
The driver is not following the return-to-duty procedures, or commonly called a SAP program, after a DOT alcohol violation. Instead, it is an evaluation and treatment for recovery. It does not involve DOT return-to-duty and follow-up tests.
The driver may obtain medical certification once there is no longer a current clinical diagnosis of alcoholism.
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