Forgot your password?    

Home > Information for SAPs >

DOT's Continuing Education
Requirement for SAPs

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 DOT's requirement.


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” a test.

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.


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 Training.)

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 2011.
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 U 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 payments.


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.


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 to DOT.

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.


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.