Direct Answer — Supervisor Reasonable-Suspicion Training Under Part 120
A Part 135 supervisor who may decide that reasonable suspicion exists to send a covered employee for testing must be trained first. Under 14 CFR §120.115(c), a supervisor who will make reasonable-cause drug testing determinations must receive at least 60 minutes of initial training on the specific physical, behavioral, and performance indicators of probable drug use, and the employer must run a reasonable recurrent training program in subsequent years. Under 14 CFR §120.223(b), a person designated to make reasonable-suspicion alcohol determinations under §120.217(d) must receive at least 60 minutes of training on the physical, behavioral, speech, and performance indicators of probable alcohol misuse. Documentation of all this training must be included in the training program (§120.115(c)), and the FAA Drug Abatement Division — separate from your FSDO — inspects it.
A trained supervisor is a precondition for a defensible reasonable-suspicion test
The reasonable-suspicion process only works if the person making the call was trained to recognize the indicators. If a supervisor who has never been documented as trained pulls a pilot off a leg and orders a test, the operator has two problems at once: a possible challenge to the test itself and a Part 120 training-record gap. This post is the companion to the main Part 135 drug & alcohol program records checklist — that piece covers the whole program; this one zeroes in on the supervisor training requirement and its records.
The Two 60-Minute Rules — and Why They Come From Different Sections
The single most common mistake operators make with supervisor training is treating it as one requirement. It is two, and they live in two different subparts of 14 CFR Part 120: the drug-side requirement in Subpart E and the alcohol-side requirement in Subpart F. A supervisor who could order either kind of test generally needs to have covered both.
Drug indicators — 14 CFR §120.115(c)
At least 60 min initial + recurrentSection §120.115 is the Employee Assistance Program (EAP) section. Its training program paragraph requires that supervisory personnel who will determine when an employee is subject to reasonable-cause testing receive specific training on contemporaneous physical, behavioral, and performance indicators of probable drug use, in addition to the general employee EAP education. The rule sets a minimum of at least 60 minutes of initial training for supervisors who will make reasonable-cause determinations, and directs the employer to implement a reasonable recurrent training program for those supervisors in subsequent years. It also requires that documentation of all training given to employees and supervisory personnel be included in the training program.
Alcohol indicators — 14 CFR §120.223(b)
At least 60 minSection §120.223(b) requires each employer to ensure that persons designated to determine whether reasonable suspicion exists to require a covered employee to undergo alcohol testing under §120.217(d) receive at least 60 minutes of training on the physical, behavioral, speech, and performance indicators of probable alcohol misuse. Note the indicator list here adds speech to the drug-side trio — the alcohol determination under §120.217(d) is built on specific, contemporaneous, articulable observations concerning the employee's appearance, behavior, speech, or body odors.
In practice: one combined course, two documented competencies
Most operators and C/TPAs deliver a single reasonable-suspicion course of roughly two hours that satisfies both the §120.115(c) drug minimum and the §120.223(b) alcohol minimum. That is fine — but your record has to make clear that both the drug indicators and the alcohol indicators were covered, and that each met its 60-minute floor. A certificate that only says "reasonable suspicion training — 1 hour" without distinguishing drug and alcohol content invites a question you would rather not answer on inspection day.
Not sure which of your records would survive a Part 120 inspection?
A two-minute readiness check shows where supervisor training and other aviation records stand.
Who Actually Needs the Training
The trigger is functional, not titular: anyone who could make the determination needs the training. To understand who that is, you have to read the training rules together with the determination rules.
The drug determination: two supervisors, one trained (or one if you are small)
Under 14 CFR §120.109(d), a reasonable-cause drug test rests on a reasonable and articulable belief, grounded in specific contemporaneous physical, behavioral, or performance indicators of probable drug use. The decision to test must be substantiated and concurred in by at least two of the employee supervisors, one of whom is trained in detecting the symptoms of possible drug use — except that an employer with 50 or fewer employees performing safety-sensitive functions may rely on one supervisor trained in detecting those symptoms. For most small Part 135 operators, that exception applies, but the trained-supervisor requirement does not go away — you still need at least one trained person to make the call, and your record has to prove that person was trained.
The alcohol determination: a trained person making articulable observations
For alcohol, §120.217(d) frames the test around a determination based on specific, contemporaneous, articulable observations of the employee's appearance, behavior, speech, or body odors — and the person designated to make that determination is exactly the person §120.223(b) requires to be trained. The same section is also clear that the person who makes the determination must not conduct the breath alcohol test on that employee; the test is administered by a qualified BAT or STT under 49 CFR Part 40.
Director of Operations (DO)
Routinely positioned to observe and pull a crewmember off duty
Chief Pilot
First-line supervision of pilots performing safety-sensitive functions
Director of Maintenance (DOM)
Supervises mechanics performing maintenance / preventive maintenance — a covered function
Any line supervisor / lead
If they can decide to send a covered employee for testing, they need the training
Designated Employer Representative (DER), where they also supervise
Train if they may make determinations; the DER role itself is administrative
Who is in your covered population is set by 14 CFR §120.105 — flight crewmember, flight attendant, flight instruction, aircraft dispatcher, aircraft maintenance and preventive maintenance, ground security coordinator, aviation screening, air traffic control, and operations control specialist duties. The supervisors of those people are the ones who may need to be trained. For how supervisor and management qualifications fit the broader Part 135 picture, see Part 135 required management personnel qualifications.
What the Training Record Has to Show
The recordkeeping anchor is plain in the rule: 14 CFR §120.115(c) requires that documentation of all training given to employees and supervisory personnel be included in the training program, and that the employer identify the employee and supervisor EAP training in its drug testing program. The rule does not prescribe a particular certificate format, so the burden is on you to keep records detailed enough to answer an inspector's questions without ambiguity. A defensible per-supervisor record establishes each of the following:
Supervisor name and role
Tie the record to a specific person who may make determinations
Training date(s)
Undated certificates are a recurring DAD finding
Drug indicators covered — at least 60 minutes
Satisfies the §120.115(c) initial-training minimum
Alcohol indicators covered — at least 60 minutes
Satisfies the §120.223(b) minimum; note speech is an alcohol indicator
Topics / curriculum reference
Physical, behavioral, performance (drug) and physical, behavioral, speech, performance (alcohol)
Provider / instructor or platform
C/TPA, training vendor, or documented in-house program
Recurrent training history (drug program)
§120.115(c) directs a reasonable recurrent program in subsequent years
Link to the written DATP and program identification
§120.115(c) requires the program to identify the supervisor EAP training
The most common gap: a new manager who never got documented
Supervisor training records go stale through turnover, not neglect. An operator trains its leadership team once, then promotes a new chief pilot or hires a new DOM two years later — and that person quietly becomes someone who can make a reasonable-suspicion determination without a training record on file. The fix is procedural: tie reasonable-suspicion training to onboarding for any role that supervises covered employees, and re-verify the roster whenever the org chart changes. A document-tracking layer that flags "current supervisor, no training record" turns this from an inspection surprise into a routine alert.
Reasonable-suspicion training records sit alongside the rest of your Part 135 training program records and your required pilot records. The difference is that this record proves the supervisor was qualified to trigger a test — a category inspectors specifically ask about and operators routinely overlook. For the full program context, the drug & alcohol program records checklist covers test results, random documentation, MIS, MRO, and SAP chains.
Can you prove every reasonable-suspicion supervisor is trained?
FileFlo is a compliance document intelligence platform that classifies and tracks over 600 document types against the governing CFR requirement — including supervisor reasonable-suspicion training certificates, your written DATP, and your random testing logs. Upload them and FileFlo organizes them into an inspector-ready binder and flags gaps like a current supervisor with no training record on file. It does not deliver the training or run your program — it proves the records are there. Starter $89/mo · Professional $299/mo · 5-day free trial, no credit card required.
How Long to Keep Supervisor Training Records — and the §40.333 Confusion
Here is where a lot of operators tie themselves in knots. The DOT retention schedule at 49 CFR §40.333 is the canonical retention rule for the drug and alcohol program — and it is precise about test-related records: verified positive drug results, refusals, and SAP-related records for 5 years; previous-employer inquiry information for 3 years; EBT calibration and maintenance records for 2 years; and negative and cancelled results for 1 year. What §40.333 does not do is set a specific retention period for supervisor reasonable-suspicion training records. Those are governed by the program-documentation requirement of §120.115(c), not by a numeric line in §40.333.
| Record | Retention | Source |
|---|---|---|
| Verified positive drug results, refusals, SAP records | 5 years | 49 CFR §40.333(a)(1) |
| Previous-employer test-result inquiries | 3 years | 49 CFR §40.333(a)(2) |
| EBT calibration / maintenance records | 2 years | 49 CFR §40.333(a)(3) |
| Negative and cancelled results | 1 year | 49 CFR §40.333(a)(4) |
| Supervisor reasonable-suspicion training records | Program documentation — no fixed §40.333 number | 14 CFR §120.115(c) |
The practical rule of thumb: keep each supervisor's training record for as long as that supervisor can make reasonable-suspicion determinations, plus a reasonable margin afterward, so you can always demonstrate the person was qualified at the time of any determination they made. Because the longest result-retention periods in the program run five years, many operators standardize on retaining supervisor training records for at least five years and keeping records for current supervisors on file for as long as they hold the role. The goal is simple: never be in a position where a supervisor made a call and you cannot show they were trained to make it. For the broader picture of which aviation records run on which clocks, see the aviation records retention schedule.
Records access, not just retention
Retention is half the obligation; access is the other half. Under 14 CFR §120.111 (Administrative and other matters), the employer must permit the Administrator or the Administrator's representative to examine records required to be kept under the subpart. A training record that exists but cannot be produced promptly during an inspection is functionally a gap. This is the operational case for keeping these documents indexed and retrievable rather than buried in a binder or a former C/TPA's archive.
On a DAD Inspection: How Supervisor Training Gets Examined
The FAA Drug Abatement Division (DAD) inspects aviation employer drug and alcohol programs under 14 CFR Part 120, separately from your local FSDO, and inspections may be unannounced. Supervisor training is one of the discrete categories an inspector can ask for by name. Based on FAA inspection practice, expect the supervisor-training portion to look something like this:
Show me who can make a determination
The inspector wants to understand who in the organization may decide that reasonable suspicion or reasonable cause exists. That is a list of roles and people — and it needs to match your written program. If your DATP names roles that no longer exist, or omits a manager who in fact supervises covered employees, that mismatch is itself a finding.
Show me each of those people was trained
For each person on that list, the inspector expects a training record establishing the date, the duration, and that both drug indicators (§120.115(c)) and alcohol indicators (§120.223(b)) were covered. A roster with names but no dates, or certificates that do not distinguish drug from alcohol content, draws follow-up questions.
Show me your recurrent training
For the drug program, §120.115(c) directs a reasonable recurrent training program in subsequent years. The inspector may ask how your recurrent training is scheduled and whether supervisors who were trained years ago have been refreshed. Be ready to show the recurrent history, not just the initial certificate.
Walk me through a determination you made
If your program has actually conducted a reasonable-suspicion test, the inspector may trace it: who observed the indicators, were they trained, were the observations specific and contemporaneous, and did the person who made the determination avoid also administering the test (per §120.217(d) for alcohol). The training record is the foundation that makes the rest of that chain defensible.
Enforcement is independent of your FSDO relationship
A DAD finding can be handled through a Warning Notice or Letter of Correction, or referred for civil penalty action under 49 U.S.C. §46301 — independent of any FSDO enforcement. As adjusted at 14 CFR §13.301, for violations occurring on or after December 30, 2024, the general maximum civil penalty is $75,000 per violation, with a lower cap of $1,875 for an individual or small business concern. A clean operational record under Part 135 operational control does not insulate you from a Part 120 supervisor-training gap — they are tracked by different FAA offices.
For how the supervisor-training records fit into a full inspection walkthrough, pair this with how to prepare for a Part 135 FAA surveillance audit and the master list of records a Part 135 operator must keep. If you also run a TPA-style consortium or compare program structures, the consortium vs. C/TPA comparison is a useful companion, and the Part 135 SMS 2027 deadline covers the adjacent safety-program records wave.
Frequently Asked Questions
How much reasonable-suspicion training do Part 135 supervisors need under 14 CFR Part 120?
There are two separate minimums, and a supervisor who may order both drug and alcohol testing generally needs both. Under 14 CFR §120.115(c), a supervisor who will make reasonable-cause determinations for drug testing must receive at least 60 minutes of initial training on the specific, contemporaneous physical, behavioral, and performance indicators of probable drug use. Under 14 CFR §120.223(b), a person designated to determine whether reasonable suspicion exists for alcohol testing under §120.217(d) must receive at least 60 minutes of training on the physical, behavioral, speech, and performance indicators of probable alcohol misuse. Operators commonly deliver these as a combined 120-minute reasonable-suspicion course, but the two 60-minute minimums come from two different sections of Part 120, so the training content must cover both drug and alcohol indicators.
Is supervisor reasonable-suspicion training one-time or recurrent?
They differ. The drug-side rule, 14 CFR §120.115(c), requires at least 60 minutes of initial training and also directs the employer to implement a reasonable recurrent training program for supervisory personnel making reasonable-cause determinations in subsequent years — so the drug program contemplates ongoing recurrent training, though the rule states the obligation in general terms rather than fixing a rigid interval. The alcohol-side rule, 14 CFR §120.223(b), states the 60-minute requirement without separately spelling out a recurrent obligation in that subsection. Because of this asymmetry and because many C/TPAs and FAA guidance treat reasonable-suspicion training as a periodically refreshed competency, operators frequently schedule combined recurrent refreshers on a fixed cycle. Verify your specific cycle against your written program, your C/TPA, and current FAA Drug Abatement guidance rather than assuming a single number.
Which supervisors actually need this training?
Anyone in your organization who may make the decision that reasonable suspicion or reasonable cause exists to send a covered employee for testing. Under 14 CFR §120.109(d), the determination to conduct reasonable-cause drug testing must be substantiated and concurred in by at least two of the employee supervisors, one of whom is trained in detecting the symptoms of possible drug use — with an exception for employers with 50 or fewer safety-sensitive employees, where one trained supervisor may make the determination. For alcohol, §120.217(d) frames the determination around a trained person making specific, contemporaneous, articulable observations. In a small Part 135 operation that often means the Director of Operations, the Chief Pilot, the Director of Maintenance, and any line manager who supervises safety-sensitive employees. If a manager could plausibly be the one to pull a pilot or mechanic off duty, that manager should be trained and the training documented.
What does the FAA Drug Abatement Division look for in supervisor training records?
On a Part 120 program inspection, the FAA Drug Abatement Division (DAD) typically asks the operator to show which supervisors received reasonable-suspicion training, when they received it, how long it ran, and what content it covered. Per 14 CFR §120.115(c), documentation of all training given to employees and supervisory personnel must be included in the training program. In practice that means a roster or per-supervisor certificate showing the supervisor name, training date, the topics covered (drug indicators and alcohol indicators), the duration (at least 60 minutes each), and the provider. Undated certificates, a course that covered only drug or only alcohol indicators, or a current supervisor with no record on file are common findings. The DAD is a separate inspectorate from your local FSDO, and these training records are squarely within its scope.
How long must supervisor training records be retained?
This is a frequent point of confusion. The DOT retention schedule at 49 CFR §40.333 sets explicit retention periods for test results, refusals, EBT calibration, and previous-employer inquiries — but it does not list a specific retention period for supervisor reasonable-suspicion training records. Instead, 14 CFR §120.115(c) requires that documentation of all training be included in the training program, and the program records must be available to the Administrator. The practical compliance posture is to keep supervisor training records for the entire time the supervisor performs that role plus a reasonable margin afterward, so you can always demonstrate that every person who made a reasonable-suspicion determination was qualified to do so at the time. Many operators simply retain training records for at least five years (aligning with the longest result-retention periods) and keep current supervisors documented indefinitely while they hold the role.
Does the supervisor who makes the reasonable-suspicion determination conduct the test?
No. Under 14 CFR §120.217(d), the supervisor who makes the alcohol reasonable-suspicion determination must not be the same person who conducts the breath alcohol test on that employee. The supervisor role is to observe specific, contemporaneous, articulable indicators and trigger the testing process; the test itself is administered by a qualified Breath Alcohol Technician (BAT) or Screening Test Technician (STT) under 49 CFR Part 40. Keeping these roles separate, and documenting that separation in your written program, is part of a defensible reasonable-suspicion record.
How is reasonable-suspicion training different from the general employee EAP education?
They are related but distinct requirements in the same section. Under 14 CFR §120.115, every covered employee must receive EAP education on the effects and consequences of drug use and the behavioral cues that may indicate drug use and abuse, plus display and distribution of the employer policy and a community hotline. Supervisors who will determine when an employee is subject to reasonable-cause testing must receive that employee-level content plus the additional specific training on contemporaneous physical, behavioral, and performance indicators of probable drug use, with a minimum of 60 minutes of initial training. So the supervisor requirement is layered on top of, not instead of, the general employee education — and your records should show both the employee education and the additional supervisor training.
Does FileFlo administer my drug and alcohol program or deliver the training?
No. FileFlo is a compliance document intelligence platform — the proof layer, not the program. It does not run your drug and alcohol testing program, deliver supervisor training, act as your C/TPA, or replace your Drug and Alcohol Program Manager. What FileFlo does is classify, index, and expiration-track the documents that prove your program is compliant — including supervisor reasonable-suspicion training certificates, your written DATP, and your random testing logs — and surface gaps (for example, a current supervisor with no training record on file) before an inspection. Program design, training delivery, and enforcement response stay with you, your C/TPA, and qualified counsel.
Chad Griffith
Founder, FileFlo — compliance document intelligence
This article is a compliance document management perspective, not legal, HR, or airworthiness advice. Regulatory citations were checked against the Cornell Legal Information Institute text of the Code of Federal Regulations; training intervals, random testing rates, and enforcement practice can change. Confirm requirements with your Drug and Alcohol Program Manager, your C/TPA, current FAA Drug Abatement Division guidance, and qualified counsel before making program decisions.
Make "every supervisor is trained" something you can prove in seconds
FileFlo classifies your Part 120 records — supervisor reasonable-suspicion training certificates, your written DATP, random testing logs, MRO and SAP files — against the governing CFR and surfaces gaps like an untrained current supervisor before an inspection. The proof layer that keeps 600+ document types organized, expiration-tracked, and inspector-ready. It does not run your program or deliver training. Starter $89/mo · Professional $299/mo · 5-day free trial, no credit card required.
5-day free trial · No credit card required · Cancel anytime