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Code of Federal Regulations (CFR) Title 49 pertains to the set of rules and regulations regarding transportation and transportation-related security. These regulations are issued by the Department of Transportation, the Department of Homeland Security and other federal_agencies of the United States.

In order to qualify as a Breath Alcohol Technician (BAT) or Screening Test Technician (STT), one must understand PART40 of 49 CFR and stay updated on current changes to these regulations which apply to employers for whom BATs and STTs will conduct alcohol tests.1

Under 49 CFR Part 40.213b and 40.213c, any individual seeking qualification as a BAT or STT must:

  1. Complete a qualification training program
  2. Pass a monitored proficiency demonstration

BAT or STT qualifications are valid regardless of location or collection site.

Law enforcement officers who are already certified by local or state governments to perform breath alcohol tests are considered qualified to be BATs and are no longer required to complete the DOT training requirements. Alcohol tests they conduct will be acceptable under DOT alcohol test requirements if said officers are certified to use the ASD or EBT device used for the test.

DOT does not “certify” anyone to become a BAT or STT. DOT also does NOT REQUIRE anyone to be “certified”. Qualified BATs and STTs do not even have to register or become members of any federal list. One only has to be “qualified” to perform the DOT drug tests.

No collection sites can become “qualified”. Only individuals may become qualified BATs or STTs.

BAT vs. STT: What’s the Difference?

STTs may only conduct alcohol screening tests using approved ASDs. BATs may perform both alcohol screening tests using either an ASD or EBT and alcohol confirmation tests using an approved EBT device.

If an STT gets a 0.02% BAC or higher, a BAT should be prepared to conduct a confirmatory test using an approved EBT device within 30 minutes of the screening test.

 

DrugConfirm 80 Hour EtG Alcohol Test Kit

 

BAT STT Qualification Training Program

The DOT published two model training courses, 1 each for BATs and STTs. These are available for trainers to use or they may opt to use a DOT-equivalent course. Basically, trainers must ensure that the course they are using contain these elements Part 40.213(b):

  1. Instruction using either the DOT-model or DOT-equivalent course for BAT or STT;
  2. Knowledge about Alcohol Testing Procedures under Part 40;
  3. Knowledge about the operation of alcohol testing device to be used;
  4. The responsibility of the BAT or STT over: a) maintaining the integrity and credibility of the testing process; b) ensuring the privacy of the employees; and c) avoiding offensive or inappropriate behavior or statements.

The trainer/instructor must himself be a qualified BAT or STT who has demonstrated the necessary skills, knowledge, and abilities by:

  1. Having conducted DOT alcohol tests as a BAT or STT for at least 1 year;
  2. Having conducted BAT or STT training for 1 year; or
  3. Having successfully completed a “train the trainer” course.

The training course may be conducted in person, via video, via video conference, via CBTs (computer-based training), online, or any equivalent media. For training media other than in-person training, the proficiency demo must happen within 30 days from the date of training. The candidate will only be qualified as a BAT or STT after both the qualification and proficiency training have been completed.

Alcohol Testing Proficiency Demonstration

Under Part 40.213(c), the BAT candidate must complete seven (7) consecutive mock tests, all error-free and the STT candidate must complete five (5) consecutive mock tests, all error-free.

The scenarios for the tests will be up to the monitor. The trainees must successfully demonstrate the following:

  1. Ability to respond to the messages and commands displayed by the device;
  2. Respond with the appropriate actions to take when the device malfunctions or gives an error message;
  3. Ability to conduct an air blank or ability to recognize that an air blank has been conducted;
  4. Identify and explain the appropriate actions the technician will take when a malfunction occurs;
  5. Explain when it becomes necessary to check external calibration (if applicable) and identify the proper procedures.

The mock tests are supposed to mimic real-life events. The instructor may act as the donor who will also observe the tests in real time. The proficiency monitor must state in writing that the mock tests were error-free as per Part 40.213 (c)(2).

Note: The proficiency monitor must have the same qualifications as an instructor for the qualification training, but may or may not be the same person who actually taught the course.

Proof of Qualification

Course certificates are typically awarded to successful trainees by the organizations who provided their training, but the ultimate proof of qualification is the ability to demonstrate one’s skills in front of DOT Agency inspectors, employers and/or their designated service agents who will eventually require their services. A Federal Inspector may request that a candidate provide details of the training and the proficiency demo, and the candidate must be prepared to do so. They may be asked for graduation certificates and/or certificates/letters of course completion signed by the trainer.

Refresher Training

Every five (5) years, BATs or STTs must undergo refresher training in order to keep their eligibility to conduct DOT alcohol tests (Part 40.213(e)), but they are expected to remain updated for any or all current changes without needing to learn them in a refresher course.

Note: DOT does not offer BAT or STT training, nor do they maintain lists of qualified trainers and/or training programs. Needless to say, the DOT does not certify, approve or recommend any training programs being offered by any organization. It is up to aspiring BATs or STTs to find a suitable training service thru industry associations, the internet or the yellow pages.

Approved Alcohol Testing Devices

The NHTSA published a CPL (conforming products list) containing all EBTs authorized to be used for alcohol confirmatory testing and approved-screening devices (ASD) under 49 CFR Part 40 Subpart M.

Getting Hired as a BAT or STT

After getting the necessary qualification and after having successfully demonstrating your proficiency, the only thing left to do is to get the word out that your services are available. At the end of the day, you are a business offering specialized services. Explore all available means to let the public know.  Attend transportation trade shows, advertise online, get listed in the local yellow pages or send out flyers to DOT-regulated companies.