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@daniel @Tim The exemptions aren't explicitly written in the regulations. They are "common sense" practices based on our experience working with DOT auditors.

Here's an FMCSA guide that mentions the supervisor training exemption for Owner/Ops: https://www.fmcsa.dot.gov/sites/fmcsa.dot.gov/files/docs/regulations/drug-alcohol-testing/54256/dot-drug-alcohol-supervisor-training-guidance-082715_0.pdf