Breath Alcohol Technician (BAT) Training & Qualification — 49 CFR §40.213

BAT vs. STT

The Two Screening Methods

• EBT — Evidential Breath Testing device (used by BATs and STTs)
• ASD (Alcohol Screening Device) — saliva-based, STTs only (and some BATs)

Confirmation is always an EBT, performed by a BAT.

Result Thresholds

• 0.00 to 0.019 — Negative (no further test needed)
• 0.020 to 0.039 — Confirmation required; if confirmed, removal from safety-sensitive duty for ≥ 8 hours
• 0.040+ — DOT violation; mandatory referral to SAP

§40.213 Qualification

• Basic information on DOT alcohol testing rules
• Qualification training on the specific EBT model
• 7 (BAT) or 5 (STT) error-free mock tests
• Refresher every 5 years

Who CANNOT Be a BAT

• 1The donor's immediate supervisor (limited exception)
• 2A safety-sensitive co-worker in the same pool
• 3The donor themselves

DER Contact

Required at every collection. Without DER contact info on hand, you cannot handle refusals, invalid tests, or other escalation events properly.

Site Requirements

• 1Privacy adequate to prevent the test being overseen or overheard
• 2A clean work surface for the EBT and the ATF
• 3Stable temperature (per EBT specs)
• 4Power for the EBT (if not battery-only)
• 5No food, drink, smoke, or vape items within reach of the donor

What's NOT Required (vs. Urine)

• — No toilet
• — No bluing
• — No restroom security checklist

Security During Test

• Donor under your continuous observation during deprivation and testing
• EBT and supplies under your physical control
• ATF visible to donor at signing

Evidential Breath Testing Device (EBT)

• Listed on the NHTSA Conforming Products List
• Calibration verified per manufacturer interval (typically monthly or after specific event counts)
• Quality Assurance Plan (QAP) on file
• External air blank capability for confirmation

Supplies

• EBT — calibrated and ready
• Disposable mouthpieces — individually wrapped, fresh for every test
• ATF — federal alcohol testing form
• ASD (if used for screening only) — within expiration date

Calibration

Verify EBT calibration per manufacturer schedule. Document every check.

The 3 Copies of the ATF

ATF Sections

Required Information from Employer

• Donor name, SSN/ID
• Employer name, address, phone
• DER name + telephone
• DOT Agency
• Reason for test (pre-employment, random, RS, post-accident, RTD, follow-up)

Acceptable ID

Same as urine — government photo ID, employer photo badge, or in-person ID by an employer representative.

⏱️ The 15-Minute Wait

For screening, observe the donor for at least 15 minutes. The donor MUST NOT:

• ! Eat or drink
• ! Smoke or vape
• ! Regurgitate or belch into the mouth
• ! Place anything in the mouth (gum, mints, dental product)

⏱️ 15—30 Minute Wait for Confirmation

Between the screening (positive) and confirmation, wait at least 15 minutes but no more than 30. Continue observation throughout. Same eat/drink/smoke restrictions.

Screening Procedure

Confirmation Procedure

Mouth Alcohol — §40.253(d)

Mouth alcohol is residual alcohol in the mouth (from belching, mouthwash, regurgitation, dental fixatives) that briefly elevates the breath result. The 15-minute wait and the 15—30 minute pre-confirmation pause are the primary defenses.

If screening ≥ 0.02 but confirmation comes back lower, the confirmation governs.

Refusal Triggers

• ! Refuses to take the test
• ! Leaves the site before complete
• ! Refuses to sign the ATF (vs. simple declining the certification — note in Remarks)
• ! Refuses to provide an adequate breath sample without medical reason
• ! Engages in conduct that obstructs the test

Fatal Flaws (ATF)

• ! Numeric BAC on screening or confirmation missing
• ! BAT signature missing
• ! Donor ID on ATF doesn't match the test result
• ! No air blank performed before confirmation (when required)

Insufficient Breath / Inability to Provide

If donor cannot provide an adequate sample (claimed medical reason or otherwise):

§40.213 BAT Training Requirements

• aBasic information on the DOT alcohol testing program
• bQualification training on the specific EBT
• cProficiency demonstration:
  • BATs: 7 error-free mock tests (mix of screening / confirmation / problem)
  • STTs: 5 error-free mock tests (screening only)
• dRefresher every 5 years
• eError correction — 3 error-free mocks within 30 days
• fDocumentation — retain qualification records, mock test logs, EBT QAP, calibration records

Quality Assurance Plan (QAP)

The EBT manufacturer supplies a QAP. You're responsible for:

• Calibration verification at the manufacturer's interval
• Recording every QAP event
• Taking out-of-service EBTs offline immediately
• Documenting service and repair

Retention

Top 10 BAT Mistakes

• 1Short-cutting the 15-minute deprivation
• 2Not using a fresh mouthpiece for confirmation
• 3Skipping the air blank between screening and confirmation
• 4Recording the screening result as the test of record (it's the confirmation)
• 5Letting the donor handle the mouthpiece out of view
• 6Missing EBT calibration verification
• 7Forgetting to notify the DER on ≥ 0.04
• 8Treating "I can't blow" as automatic refusal — start the protocol first
• 9Filling in ATF Step 4 even though screening was < 0.02
• 10Not documenting Remarks when the donor declines to sign

Best Practices Checklist

• Calibrate & verify before each shift
• Eyes on donor through the 15-minute wait
• Fresh mouthpiece every blow, in donor's view
• Air blank for confirmation
• Confirmation is the test of record
• DER notified for ≥ 0.04 results