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Connecticut, the Federal Court system, and the District of Columbia. Prior to working with Gama, Miller practiced business and aviation law while concurrently working as a Learjet pilot. He has been employed as a pilot by Gama Charters since 1985. He was promoted to chief pilot in 1992, and to director of operations in 1996. Mr. Miller was instrumental in the ISO 9001-2008, ACSF,


FAA SMS pilot program, and the International Standard for Business Aircraft Operations (IS-BAO) registrations for the company. He is both a fi xed- and rotor-wing qualifi ed pilot, and has more than 11,000 hours as pilot-in-command in Learjet, Westwind, Citation, Gulfstream, BAC 111 and DC-9 aircraft, and numerous turbine-powered helicopters. “I am honored to be appointed to the ACSF Board of


Governors,” says Miller. “Gama Charters is proud to be one of the high-quality operators that strive to enhance our level of safety through the accomplishment of the ACSF audit process, the most comprehensive in our industry.” “Tom’s knowledge, experience and leadership in


the aviation industry will help support and sustain the foundation’s ongoing and future safety activities,” says ACSF President Bryan Burns.


FAA SEEKS COMMENTS FOR DRUG AND ALCOHOL TESTING ANPRM


On March 19, the Federal Aviation Administration announced it is seeking comments on an Advance Notice of


Teledyne_3rdAd_140311 copy.pdf 1 3/11/14 4:09 PM


Proposed Rulemaking (ANPRM) that would require drug and alcohol testing of maintenance personnel who work on aircraft operated by U.S. air carriers (Part 121) in facilities outside the United States. In the Federal Register notice, the FAA noted that it is considering developing a rulemaking that would require employees of FAA-certifi ed foreign repair stations and certain other maintenance providers who perform safety- sensitive work on U.S. air carrier aircraft to be subject to a drug and alcohol testing program. Consistent with the Congressional mandate for the rulemaking, the testing program would have to meet FAA standards and be consistent with the applicable laws of the country where the repair station is located. Currently, the FAA’s drug and alcohol testing regulations do not extend to companies or individuals who perform safety-sensitive functions, including aircraft and preventive maintenance, outside the United States. The public comment period will help the FAA develop


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a proposed rule and to assess its likely economic impact. The notice invites comments on a variety of issues related to proposing drug and alcohol testing requirements for the relevant employees of covered maintenance providers. These issues include: • Which drugs are most misused in a particular country? If testing programs exist, are they administered by a national regulatory authority? Are industry participants required to establish such programs under the country’s laws and regulations, or does industry do that voluntarily • Should the program require testing for the same drugs the FAA requires tests for in the United States? At what concentrations should alcohol and drug tests be considered “positive?”


• Does a particular country allow or require random drug and/or alcohol testing? If so, what is the process?


• If a country does not allow or require random drug and/or alcohol testing, are there laws that prohibit random testing? What other methods might successfully deter employees from misusing drugs or alcohol while performing safety-sensitive duties, or within a certain period of time before performing such duties? How would such misuse be detected?


• What are the standards that employees who have violated drug and alcohol regulations should meet before they are allowed to return to performing safety-sensitive maintenance work?


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