DRUG & ALCOHOL TESTING
(This data along with other pertinent information must be compiled for inclusion in the Company’s annual report to the GCAA LIC (MED) Form 21. This data shall also be provided to the Aeromedical section semi-annually to assist in overall program evaluation and to determine whether changes to the mandatory guidelines may be required by the GCAA. Annual percentage rate includes all random positive, random, negative and refusal results.) For EASA, TCAA, CAA Germany and CAA Philippines are all voluntary programs and would be self regulated.
COMPANY ADMINISTRATORS Designated Employer Representatives serve as the administra- tors and maintain the required documents. Companies may utilize MROs or Consortium/Third Party Administrators to assist in implementing programs. Mandatory programs would be fi led with the appropriate governing agency. MROs or C/ TPA should not be allowed to serve as DERS.
INTERNATIONAL COMPATIBILITY International compatibility can be established for Drug and Alcohol Testing Program world-wide. ICAO based much of its manual on Part 40 and Part 120. ICAO expanded drugs to include all psychoactive substances (whether legalized or not in any country) and the way civil aviation authorities and aviation companies may test. The GCAA based its regulations on DOT, FAA and ICAO regulations and recommendations.
CONCLUSION In the interest of safety, the FAA should amend Part 120 to require international 145 operators to implement and enforce Drug and Alcohol Testing Programs to prevent accidents and injuries resulting from the use of psychoactive substances by all aviation personnel, contractors and volunteers. It is the goal of JetSeat, LLC’s Guideline Manual for Drug
and Alcohol Testing Program is to educate operators they are entitled to implement and enforce the programs and to provide guidance in administrating the programs. As discussed above, ICAO encourages its member states to implement and administer drug and alcohol testing programs. Of all of Authority representatives that were contacted by JetSeat, all agreed programs based on ICAO’s standards and recommendations would be a great idea. The use of psychoactive substance should not be
viewed as religious, moral or legal beliefs. It should be based on safety. Safety should be the number one priority of all aviation operators and personnel with it being the cornerstone of any operation. Lastly, drug and alcohol programs should be required by
any international 145 repair station providing maintenance to any 121 air carrier. It should be expanded by the FAA to include Part 135 and Part 91 operators, as well as Part 121 operators. All operators have responsibility for the safety of their operations to themselves, employees and the public.
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Regulatory Counsel • Regulatory Integration/Rulemaking Proceedings • Management of Certification Projects • Ensuring a Professional Relationship with the FAA • Legal Opinions • Enforcement Defense • Private Company Training • Independent Regulatory Compliance Audits • Internal Company Investigations • Aircraft Accidents and Incidents • Drafting of Company Manuals and Related Procedures
• Review of Contracts 06 2014 48
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