ARSA Highlights Petition to Amend FAA’s D&A Testing Rules

On Aug. 22, 2025, a coalition of eight aviation trade associations joined the Aeronautical Repair Station Association petition to amend the FAA’s recently issued rules expanding drug and alcohol (D&A) testing obligations outside the United States for the first time.

The FAA’s December final rule imposes D&A requirements on foreign repair stations performing work on U.S. registered air carrier aircraft.

The petition proposed 10 changes to simplify compliance, oversight and enforcement, including:

Clarifying testing applies only to foreign repair stations performing heavy maintenance on air carrier aircraft.

Simplifying and expanding waiver opportunities by allowing the FAA to grant waivers without a petition.

Allowing the use of laboratories, medical review officers and substance abuse professionals in the national jurisdiction of the repair station

The petition explained the public’s interest in facilitating compliance for more than 1,000 certificated repair stations supporting American global operations.

It stated, “The proposed amendments will reduce the regulatory burden associated with…compliance and make it more likely that these facilities will continue to provide maintenance services for U.S. registered aircraft. This, in turn, benefits every American who depends on international air transportation for travel, cargo shipments, and mail.”

The petition is ARSA’s most-recent engagement in the decades-old effort to limit burdens resulting from Congress’ 2012 legislation requiring international expansion of testing rules “consistent with the applicable laws” of the country where the repair station is located.

The FAA’s final rule makes certificate holders responsible for determining the consistency U.S. D&A obligations with foreign nations’ laws, abdicating the FAA’s responsibility to set clear standards.

In addition to ARSA, the petition was signed by:

• Aviation Suppliers Association
• General Aviation Manufacturers Association
• Modification and Replacement Parts Association
• National Air Carrier Association
• National Air Transportation Association
• National Business Aviation Association
• United Aerial Firefighters Association

To support the petition:

1. Access the petition’s docket.
2. Click “Comment” and submit a supportive statement. Demonstrate your interest by explaining the rule’s impact on your business, even if it is indirect. 

Ensure submissions meet the standards of effective rulemaking comments.