Quote Originally Posted by Burnt Toast
The only revision DOT made concerning observed testing is that observed testing is now mandatory on return-to-duty/follow up specimen collections.

Before the revisions, only the employer decided whether the return-to-duty collection should be observed.

Observed testing without cause is still prohibited under the revised regs.
I do want to add that the revised regs were to go into effect back on 8/25/08, but was suspended by the DOT until 11/01/08 to allow public comments on the new ruling.