FROM THE EDITOR DRUG AND
EDITORIAL DIRECTOR JOE ESCOBAR
jescobar@DOMmagazine.com | 920.747.0195
its Advanced Notice of Proposed Rulemaking (ANPRM) titled “Drug and Alcohol Testing of Certain Maintenance Provider Employees Located Outside the United States” in the Federal Register on March 17. The FAA wanted to get feedback from the industry on the ramifi cations of expanding drug and alcohol testing requirements to foreign repair stations. The deadline for comments was originally May 16, but on May 1, the FAA announced that the deadline for comments had been extended to July 17. You still have time to comment on this ANPRM! Visit http://www.
regulations.gov/#!docketDetail;D=F AA-2012-1058 to read the ANPRM and submit your comments. We have included a special section discussing drug and alcohol testing in this issue beginning on page 34. First, the Aeronautical Repair Station
T
he topic of drug and alcohol testing has been at the forefront of discussions since the FAA published
Association (ARSA) shares its thoughts on the subject. Next, Shelley Hedrick, president of JetSeat, LLC shares the comments she has submitted in response to the ANPRM including her research on drug and alcohol use and the current regulatory testing requirements in various parts of the world. I have shared my opinion on this subject with many people in the past. I believe an eff ective drug and alcohol testing policy is important to the safety of aviation. What has always bugged me is how all foreign Part 145 repair stations are not required to implement the same testing programs that U.S.- based repair stations are. If drug and alcohol testing is so important that the FAA requires random testing for U.S.- based repair stations, why are foreign repair stations held to a diff erent standard? I asked an FAA Inspector quite a few years ago, “Why aren’t all foreign FAA-certifi cated repair stations required to have a drug and alcohol testing program in place?” His answer was, “We tried to force the issue a few years back, but were told by the State Department to back off .” Needless to say, I was shocked by his response. Granting drug and alcohol testing
exemptions to foreign repair stations discriminates against the repair stations that do have to comply with the mandate. Repair stations end up having to compete on a playing fi eld that is not level. I know there may be many State
Department offi cials, FAA higher- ups and all kinds of lawyer-types that
ALCOHOL TESTING
will disagree with what I am going to say next. I have a simple solution to the problem – the FAA should not certify any Part 145 repair station that doesn’t have a drug and alcohol testing program in place. That’s not too hard, is it? If you
want to be certifi ed as a Part 145 repair station, you need to have a drug and alcohol testing program in place. If you don’t, you don’t get your certifi cate (or you don’t get it renewed if you already have it). If it is against the law in your country to randomly test employees, then guess what – you won’t have to test them because you won’t be performing maintenance under an FAA certifi cate. If your labor union contract states you cannot test employees, then you won’t need to test them, and they won’t be working under an FAA certifi cate. Normally, at the end of my editorial column, I encourage you to send your feedback! I strongly urge you to submit your feedback on this topic as well. I’m not asking you to send me your thoughts on the subject (although you are welcome to if you like). Instead, I urge you to send them to the FAA by commenting on the FAA ANPRM by the deadline of July 17. Your voice matters! Now is the time to have it heard by submitting your comments. If you don’t, you have no reason to complain if the resulting rulemaking is not to your liking.
Thanks for reading! – Joe Escobar
06 2014 4
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