Training: An employer must implement a reasonable program of initial training for employees that includes the effects and consequences of drug use on personal health, safety, and work environment; the manifestations and behavioral cues that may include drug use and abuse; and documentation of training given to employees and employer's supervisory personnel. Supervisory personnel who will determine when an employee is subject to drug testing (based on reasonable cause) must receive initial and recurrent training on specific, contemporaneous physical, behavioral, and performance indicators of probable drug use. In addition, an employer must ensure that persons designated to determine whether reasonable suspicion exists receive training on the physical, behavioral, speech, and performance indicators of probable alcohol misuse.
Records maintenance and retention
Federal regulations require certain drug and alcohol records be kept for a specific period of time. For detailed information on the records that must be kept and required length of time for these records, refer to 49 CFR Part 40; and 14 CFR Part 121, Appendix I, VI. and Appendix J, IV., A.
More information on federal requirements of drug and alcohol programs can be found at www.faa/gov/avr/aam/
Everyone has heard "Just Say No to Drugs." Take time to review your program. A drug and alcohol program is another way to "Keep em' Flying."
A special thanks to Eric Wells, Inspector, Drug Abatement Division, Aerospace Medicine, ANM-304, Renton, Washington.
Fred Workley, the president of Workley Aircraft and Maintenance Inc. in Alexandria, VA, Benton City, WA, and Indianapolis, IN, holds an A&P certificate with an Inspection Authorization.
Consequences under FAA programs
- Removal from safety-sensitive duties until return-to-duty process is completed.
- Suspension or revocation by the Federal Air Surgeon of certificate of flight crewmembers and air traffic controllers that allows them to work.
The following procedures must be followed before allowing an employee to resume working in a safety-sensitive position.
- Initial evaluation by a substance abuse professional (SAP).
- A SAP must evaluate employees who have violated DOT drug and alcohol regulations and make recommendations concerning education, treatment, follow-up testing, and after care.
- Employee must participate in the treatment programs recommended by the SAP. If you want to see if your programs are meeting the latest requirements this may help you.
- Follow-up evaluation by a substance abuse professional to determine if the employee has successfully carried out the education and/or treatment recommendations.
- Employee must pass a return-to-duty test.
Prohibited conduct and consequences
- Alcohol concentration of 0.04 and greater.
- Use of alcohol prior to performing safety-sensitive duties (flight crewmembers, flight attendants, and air traffic controllers may not work within eight hours after consuming alcohol; mechanics, screening personnel, and ground security coordinators may not work within four hours after consuming alcohol).
- Use of alcohol while on duty.
- Use of alcohol after an accident.
- Use of prohibited drugs.
- Refusal to submit to testing (drugs and/or alcohol).
Drug and/or alcohol program documents
Note: An asterisk indicates documents that are required only if those events have occurred or if that practice is followed. Some may not be required but, if available, will greatly assist the review of your program.
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