Trained But Not Ready: Why Reasonable Suspicion Falls Apart When It Matters Most

Supervisor having a serious conversation with an employee on a warehouse floor

Most safety managers I talk to have been through some form of reasonable suspicion training. A session, a seminar, maybe an online course. They can tell you what bloodshot eyes look like. They know slurred speech is a red flag. They've seen the list of observable indicators.

And then a coworker pulls them aside and says they're worried about Johnny. And everything they learned goes right out the window.

I get calls like this more than you'd think. A safety manager calls me, sometimes frantic, sometimes trying to sound casual, and somewhere in the conversation they say it: "Hey, we need to do a random pull. Can you make sure Johnny is in it?"

I understand exactly what's happening in that moment. Someone tipped them off. Or they saw something. Or a coworker came to them quietly and said they were worried. And now this safety manager is holding information they don't know what to do with, and they're reaching for the closest tool available, a random drug test, because it feels like action without confrontation.

I get it. But I have to be straight with you: what they're describing isn't a random test anymore. The moment you target a specific employee for a "random" pull, you've left random territory entirely. And that distinction, between a legitimate random program and a targeted test dressed up as one, is exactly the kind of thing that creates serious legal exposure for your organization.

This is the conversation I'll be having at ASSP Safety '26 in June. And I want to start having it here first.

The Real Problem Isn't Knowledge. It's Panic.

Here's what I've learned after two decades in this industry: the biggest gap in most reasonable suspicion programs isn't that managers don't know what impairment looks like. Some do, some don't. The bigger gap is that even trained managers freeze when the moment actually arrives.

They get a tip and panic. They see something unusual and second-guess themselves. They don't want to be wrong. They don't want to cause a scene. They don't want to damage a relationship with someone they've worked alongside for years. So they either do nothing and hope it goes away, or they overcorrect and reach for a tool that wasn't designed for the situation they're in.

Neither response protects anyone. Not the employee, not the organization, and not the safety manager standing in the middle of it.

The panic is completely understandable. The problem is that panic is not a process. And in a safety-sensitive environment, process is the only thing that protects you.

Why a Positive Test Isn't the Whole Story

Let me address something that adds another layer of confusion to all of this, especially in 2026.

When a reasonable suspicion test is conducted correctly and returns a positive result, many managers assume the case is closed. The test confirmed it. End of story.

Not quite.

A positive drug test tells you that a substance was detected in that employee's system. What it does not tell you, and what no standard urine drug test can tell you, is whether that employee was impaired at the time they were working.

This matters most with cannabis, and here's why. THC, the active compound in cannabis, can remain detectable in urine for days or even weeks after use depending on the individual's metabolism and frequency of use. An employee who used cannabis legally on a Saturday night in one of the 24 states where that's permitted could return a positive test on a Wednesday morning while being completely unimpaired and fully fit for duty. It's worth noting that the type of test used matters too; urine, saliva, and other methodologies each have different detection windows, and that distinction is increasingly relevant as testing science evolves.

Many states have already moved to reflect this reality, prohibiting employers from taking adverse action based solely on a positive THC test unless actual impairment on the job can be demonstrated. That's not a technicality. That's a meaningful legal and operational distinction that safety managers across the country need to understand before they're standing in front of HR trying to explain a termination decision.

What the Right Response Actually Looks Like

So if the random test isn't the right tool when you get a tip, and a positive result alone isn't proof of impairment, what are you supposed to do?

The answer starts before the moment of panic. It starts with having a process in place so that when a manager sees something concerning, they aren't improvising under pressure.

At a high level, reasonable suspicion in a safety-sensitive environment requires three things to happen in sequence before a test is ever initiated.

First, a trained supervisor must directly observe specific, articulable signs and symptoms of impairment. Not a tip, not a rumor, not a gut feeling. Direct, contemporaneous observation.

Second, those observations need to be documented in real time, in objective language, before any conversation with the employee takes place. What was seen. When. Where. Who else was present.

Third, the process your organization has defined for initiating a reasonable suspicion test, who gets called, who accompanies the employee, what happens if they refuse, needs to be followed exactly as written.

A tip from a coworker can be a starting point. It can prompt a supervisor to pay closer attention. But it cannot be the sole basis for sending someone to testing. That distinction is not just a legal protection. It's a fairness principle that holds up under scrutiny when decisions get challenged.

Training Isn't Enough Without Confidence

I want to push back on something the industry often assumes: that training solves the problem.

Training is necessary. It is not sufficient.

A manager who has been through a two-hour reasonable suspicion training session but has never practiced the conversation, never worked through a realistic scenario, and never been given a clear decision-making framework for the moment of panic, that manager is still going to freeze. Or overcorrect. Or call me and ask me to make sure Johnny is in the random pool.

What changes behavior isn't information. It's preparation. It's having done the uncomfortable thing in a safe environment before you have to do it for real.

That's the gap most organizations haven't closed. And it's exactly what I'll be addressing in my session at ASSP Safety '26 on June 17th in Anaheim.

The Question Worth Asking Now

Before the next tip comes in, before the next moment of panic, ask yourself honestly: do your supervisors know not just what to look for, but what to do with what they see?

If the answer is anything other than a confident yes, that's the gap worth closing before it closes itself in the worst possible way.

Reach out. This is exactly the kind of program we build with organizations that want to get it right before something goes wrong.