Reasonable suspicion testing — also known as for-cause testing — is one of the most sensitive and consequential forms of workplace drug and alcohol testing. Unlike random testing, which is triggered by a statistical selection, reasonable suspicion testing is initiated because a supervisor or manager has observed behaviour that indicates an employee may be impaired by drugs or alcohol while at work.

The effectiveness and legal defensibility of reasonable suspicion testing depends almost entirely on the quality of the documentation. A well-documented observation protects the organisation, supports the testing decision, and ensures procedural fairness for the employee. A poorly documented one can expose the organisation to claims of discrimination, bullying, or unfair dismissal.

What Is Reasonable Suspicion?

Reasonable suspicion is not a hunch, a rumour, or a personal dislike of an employee. It is an objective, articulable belief, based on specific observations, that an employee may be impaired by drugs or alcohol. The observations must be current — relating to the employee’s behaviour, appearance, or conduct during the current shift or work period.

The threshold is not certainty. A supervisor does not need to be certain that an employee is impaired. They need to be able to articulate specific, observable facts that a reasonable person would interpret as consistent with possible impairment.

Observable Indicators

Supervisors should be trained to recognise the following categories of observable indicators. No single indicator is conclusive on its own — the assessment should be based on the totality of what is observed.

Physical Indicators

• Bloodshot or glazed eyes.
• Dilated or constricted pupils.
• Unsteady gait or poor coordination.
• Slurred speech.
• Trembling hands.
• Unusual sweating or flushing.
• Odour of alcohol on breath or person.
• Dishevelled or unusually untidy appearance.

Behavioural Indicators

• Unusual agitation, aggression, or emotional outbursts.
• Significant change in mood or demeanour compared to normal.
• Inappropriate laughter, crying, or emotional responses.
• Disorientation or confusion about tasks, location, or time.
• Slow reaction times or difficulty following instructions.
• Falling asleep or excessive drowsiness during work hours.

Performance Indicators

• Sudden decline in work quality or output.
• Inability to perform tasks that are normally routine.
• Errors in judgement or unsafe work practices.
• Failure to follow standard procedures.
• Near-miss incidents or minor accidents.

It is important to note that many of these indicators can have explanations other than substance impairment — fatigue, illness, medication side effects, emotional distress, or medical conditions can all present similarly. This is why documentation must focus on what was observed, not on conclusions about the cause.

How to Document: Factual, Not Interpretive

The single most important principle of reasonable suspicion documentation is this: document what you observed, not what you concluded.

Consider the difference:

• Interpretive (wrong): “John was drunk at work today.”
• Factual (correct): “At approximately 10:15 am on 14 March 2026, I observed that John Smith had bloodshot eyes, was speaking with slurred speech, and was unsteady on his feet when walking from the lunch room to the workshop. I could smell what appeared to be alcohol on his breath when I spoke to him from approximately one metre away. John was unable to follow a routine instruction to prepare the materials for the afternoon pour, which he has performed without difficulty on numerous previous occasions.”

The factual account is specific, timestamped, and describes observable behaviour without drawing conclusions about the cause. This is the standard that will withstand scrutiny in a Fair Work Commission hearing or workplace investigation.

Key Elements of Good Documentation

• Date and time — when the observations were made.
• Location — where the observations occurred.
• Duration — how long the behaviour was observed.
• Specific descriptions — what exactly was seen, heard, or smelled.
• Context — what the employee was doing at the time and how their behaviour compared to their normal conduct.
• Observer’s name and position — who made the observations.
• Actions taken — what steps were taken in response to the observations.

Witness Requirements

Best practice — and many organisational policies — require that reasonable suspicion observations be corroborated by a second observer before testing is initiated. This provides an additional layer of objectivity and protects against claims of personal bias or vendetta.

The second observer should:

• Be a supervisor, manager, or other trained person — not a peer of the employee being observed.
• Make their own independent observations and document them separately.
• Not be briefed on what the first observer saw before making their own assessment. The goal is independent corroboration, not confirmation.

If a second observer is not available — for example, on a remote site with only one supervisor — the policy should specify the process for proceeding with a single observer. In these cases, the documentation must be particularly thorough.

Chain of Reporting

Once observations have been documented, the supervisor must follow the organisation’s reporting chain. This typically involves:

• Notifying HR or the designated manager — the supervisor should contact the person authorised to make the decision to proceed with testing. This is usually not the supervisor themselves.
• Providing the documentation — the written observations should be shared with the decision-maker, who will assess whether they meet the threshold for reasonable suspicion.
• Decision to test — the decision to proceed with testing should be made by the authorised person, based on the documented observations. If the observations do not meet the threshold, the decision-maker may recommend monitoring rather than testing.
• Notification to the employee — the employee should be informed that they are required to submit to a drug and alcohol test based on observed behaviour. They should be told what was observed (in general terms), that testing is being conducted in accordance with the policy, and that they have the right to a support person.

When to Test Versus When to Stand Down

Not every observation of potential impairment needs to result in immediate testing. In some cases, the appropriate response is to stand the employee down from safety-sensitive duties, ensure their safety, and arrange testing as soon as practicable.

Immediate stand-down (with or without testing) is appropriate when:

• The employee appears significantly impaired and poses an immediate safety risk.
• The employee is aggressive, disoriented, or unable to follow basic instructions.
• The employee is in a role where any impairment could result in serious injury or death (e.g., operating heavy machinery, driving, working at heights).

If testing cannot be conducted immediately — for example, because a collector is not available on site — the stand-down should be documented separately, and testing should be arranged at the earliest opportunity. The passage of time between the observation and the test is a factor that may affect the result, so promptness is important.

Using a Documentation Template

Many organisations provide supervisors with a reasonable suspicion observation form or template. This standardises the documentation and ensures that all required information is captured. A good template includes:

• Fields for date, time, location, and observer details.
• A checklist of physical, behavioural, and performance indicators with space for specific descriptions.
• Space for a narrative account of what was observed.
• Fields for witness details and their independent observations.
• A record of the reporting chain and the decision made.
• The employee’s response when notified of the requirement to test.

Having a template ensures that in the stress of the moment, the supervisor does not forget to capture critical information.

Training Is Everything

Reasonable suspicion documentation is only as good as the training behind it. Supervisors must be trained not only in what to observe, but in how to document it, who to report to, and how to manage the situation with professionalism and respect for the employee’s dignity.

If you need a platform that supports your reasonable suspicion testing process — from documentation through to result management and compliance reporting — start your free trial with FairTest and give your supervisors the tools they need to get it right.