DRUG & ALCOHOL TESTING
• Where to get started and how to prevent employees use? Voluntarily implement a drug and alcohol testing program by a 145 operator which may make them a preferred 145 vendor.
• Are employees using THC in the workplace? Deter usage by random testing and arrest usage by reasonable suspicion/reasonable cause testing.
• Can an employer terminate an employee for testing positive or using THC? Yes – under a drug and alcohol testing program. Employees should (in some cases must) be informed of the consequences of using psychoactive substances.
• What if in the event a disgruntled employee wants to take action against a supervisor or a co-worker and gives him/her a consumable product with THC without his/her knowledge? Allow voluntary testing without disciplinary action.
• What if an employee in the course and scope of his/her employment causes an incident or accident while under the influence? The employer remains liable in many countries.
145 operators should not wait for a problem to arise causing an incident or accident or for the FAA to amend Part 120. By implementing and administering a voluntary Drug and Alcohol Program, employers can greatly reduce incidents or accidents in the workplace and greatly reducing their liability or the possible seizure and sale of assets. It may possibly reduce insurance rates as well.
TIME RESTRICTIONS FROM CONSUMPTION OF ALCOHOL TO REPORTING FOR DUTY
It is JetSeat’s belief that in the interest of safety and the preven- tion of the loss of public trust the FAA should amend Part 120 to include all international Part 145 operators performing maintenance on any aircraft registered in the United States be subject to a drug and alcohol testing program. The FAA should also expand the time frame from consuming alcohol to performing safety-sensitive maintenance functions from four hours to a minimum of eight hours for all safety-sensitive employees domestically and internationally. Currently, under the Part 120, only crewmembers and flight attendants have an eight hour restriction from “bottle to throttle” while all other safety- sensitive employees are restricted from consuming alcohol only four hours prior to performing safety-sensitive duties (i.e. “bottle to wrench”). International Civil Aviation Organization (ICAO)
recommends an eight hour restriction for consumption of alcohol to duty for safety-sensitive employees. The United Arab Emirates’ General Civil Aviation Authority (GCAA) regulations require a twelve hour restriction from consumption of alcohol to duty for all employees. Many air carriers require a 24 hour restriction from consumption of alcohol to duty for crewmembers. The Manual of Civil
Aviation Medicine recommends all alcohol and drugs have a restriction of twelve hours from consumption prior to duty.
DRUG AND ALCOHOL TESTING PROGRAMS (MANDATORY AND VOLUNTARY)
JetSeat, LLC offers aviation companies worldwide Guideline Manuals and Drug and Alcohol Testing Programs (manda- tory and voluntary) based on Department of Transportation (DOT), FAA, ICAO and GCAA regulations, recommenda- tion and standards. The Guideline Manuals consist of the guideline for implementing and administrating a drug and alcohol program for safety-sensitive and non-safety-sensitive employees, safety signs, educational materials and non- Federal forms. The Program includes an employee assistance program and educational materials. JetSeat also offers initial and recurrent training for
supervisors and employees. Training courses for supervisors and employees include syllabuses, tests with answer keys (based on the guideline, program and educational materials) and certifications of completion of training. The guideline manuals, programs and training courses
can be customized by JetSeat to comply with any country’s civil aviation regulations. Currently, it offers programs for the following: • Mandated Part 120 programs for safety-sensitive employees • Company Authority programs allowed by the DOT for civil aviation companies (which has been reviewed by the FAA’s Drug Abatement Division in Washington, D.C. which comments have been incorporated) for Part 120 non-covered employees • Company Authority for non-aviation companies • Mandatory UAE CAAP 51 for all employees including safety-sensitive
• Company Authority for all employees for aviation organizations governed by the Civil Aviation Authority of the Republic of the Philippines While researching and writing these programs, Shelley
Hedrick has corresponded with the following civil aviation authorities: • Head of Administration & Examination, Licensing Department of the UAE General Civil Aviation Authority (GCAA)
• Officer in Charge, Republic of the Philippines Civil Aviation Authority (Authority)
• Chief Medical Examiner, European Aviation Safety Agency (EASA)
• Regional Aviation Medical Officer, Transport Canada (TCAA)
• Chief Medical Officer, Civil Aviation Authority Germany (CAA Germany)
Only the GCAA has a mandatory drug and alcohol testing program requirement for aviation companies with safety-
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