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There is considerable confusion and misinformation about DOT's
requirements for SAPs’ continuing education hours, documentation,
and related matters. The purpose of this section is to clarify
49 CFR Part 40.281(d)(1) says “This continuing education
must include material concerning new technologies, interpretations,
recent guidance, rule changes, and other information about developments
in SAP practice, pertaining to the DOT program, since the time
you met the qualification training requirements of this section.”
DOT published specific information about this in an ODAPC Dispatch,
issued on May 27, 2005.
Click here to go to ODAPC’s clarification “Nuts and Bolts of Continuing Education for SAPs”.
Among the courses that do not meet this requirement would be a
course on ethics, or a course on violence, or a course on how
to handle the resistant client. Attending a conference will also
not meet the requirement.
Must I take another exam?
The purpose of this regulation is to update you on new information
related to the law. There is no formal "exam". However,
DOT expects some assurance that a SAP has studied and learned
information. 49 CFR Part 40.281(d)(2) says “Your continuing
education activities must include documentable assessment tools
to assist you in determining whether you have adequately learned
the material.” Notice that it says “to assist YOU”…
not to assist DOT, or the provider of the continuing education
session. The quiz, or an exam, is for your own use, as a measurement
tool. Nothing in the regulation says you must “pass”
If you take a class, the class must include some version of a
quiz or test. If you take your continuing education online, the
provider must offer a quiz or a test that helps you determine
what you learned (or didn’t learn). But this is not the
formal exam that DOT required after your Qualification Training.
SAVE YOUR DOCUMENTATION ! !
When you complete any continuing education hours, you should
receive a document that indicates that those hours of continuing
education meet the requirements of 49 CFR Part 40.281(d). 40.281(e)
says “You must maintain documentation showing that you currently
meet all requirements of this section. You must provide this documentation
on request to DOT agency representatives [auditors] and to employers
and C/TPAs who are using or contemplating using your services.”
At any time in the future, an employer, an EAP, a DOT auditor,
or any other service agent working under this rule, can request
you to show them or send them your documentation. You must then
provide documentation of 1) Qualification Training; 2) SAP exam;
3) 12 hours of continuing education in every 3 year period since
your SAP exam. If you cannot provide all of this documentation,
you will be in violation of the rule. Never, never destroy any
of your previous documentation, regardless of how old it may be.
It is never outdated or obsolete. Having documentation of 12 hours
of continuing education does NOT mean you can now throw away your
Qualification Training documentation!!! You must ALWAYS have ALL
documentation. (This is not like your Drivers License, which you
can throw away when you get a new one).
Why rush? My target date is still a year away…
You can obtain these 12 hours of continuing education at
any time during the 3 years following your SAP Exam. You
can choose to obtain your continuing education hours early in
those three years, or in the middle of those three years, or you
can go right up to the end of that 3-year period. You can also
accomplish this requirement in pieces, a few hours at a time,
or you can do it all at once. The target date is three years following
your SAP exam. (It is not related at all to the date of your Qualification
Example: Say you completed your SAP Exam in August
2005. You could take a 3-hour course in January 2006, another
3-hour course in March 2006, and a 6-hour course in September
2006. You would then have fulfilled your requirement through August
2008. The target date won’t change if you complete the continuing
education hours early. You then must complete another 12 hours
of continuing education anytime between August 2008 and August
SAPs have asked if there is a “grace period”. There
is no grace period. Plan carefully, and plan accordingly. If you
plan to take a class, don’t assume that a class will be
conveniently located in your city a month before your 3 years
run out. You would be wise to pick up that class a year or even
two years ahead of your target date.
SAPlist.com has created an online version of continuing education
that meets DOT's requirement.
Download your study materials, purchase the accompanying (required)
quiz of 50 questions, print the quiz, take your time finding answers,
transfer the answers to your online version, and you'll immediately
have a certificate that you can print, mail, save to your hard
drive, and e-mail to employers and EAPs. You'll also get a printout
of your incorrect answers, and a reference to the appropriate
site so you can find the correct answer. Work at your own pace,
comfortably at home.
To read more about this, click on SAPlist U Continuing Education,
the tab on the left side of this page. The cost is $175. ($100
if you've had a Profile on SAPlist for at least 2 subscription
MISSING THE DEADLINE
These dates are carefully examined by auditors. If an employer
doesn’t have copies of your documentation, a DOT auditor
could ask you directly to provide those copies. If an auditor
determines that you provided SAP services during a time when you
were not in compliance with this part of the regulation, the employer
that used your SAP services could be fined, and DOT could require
the employee to be removed from safety-sensitive functions and
repeat the SAP return-to-duty with a different SAP who is in compliance
with this part of the regulation.
CONTINUING EDUCATION PROVIDERS
Must I obtain my continuing education hours from the same entity
or organization that gave me my Qualification Training?
No. You can fulfill your continuing education requirement from
any provider that you choose. Your Qualification Training may
have been with one group or one association, your SAP Exam was
through another entity, and your continuing education hours were
provided by yet an entirely different group (or several groups).
Each provider must give you a certificate of completion.
It is up to employers to look at your documentation and decide
to use your services, based on whether you have met the requirements
and whether you are currently up-to-date with your continuing
education. Certificates that assign "certification numbers"
to a SAP mean nothing under this regulation, and they mean nothing
The following statement appears in DOT's SAP Guidelines: “DOT
does not certify, license, or approve individual SAPs.”
Some SAPs are being told that their “certification”
will run out. Your status as a SAP is in no way affected, as long
as you obtain your continuing education hours from a bona fide
provider, group, trainer, educator.
CONTINUING EDUCATION CONTENT
What should I be looking for in continuing education?
DOT's objective is for SAPs to be informed about changes and
new information. If DOT hadn't written this requirement into the
law, there would be no incentive for SAPs to keep up with changes.