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DRUG & ALCOHOL TESTING


DRUG AND ALCOHOL TESTING PROGRAMS


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helly Hedrick, President of JetSeat, LLC (www.jet- seatllc.com) shared the information she submitted to the FAA ANPRM on Drug and Alcohol testing. Here are her comments on the issue. Safety should be the number one priority for all aviation


professionals and it should be the cornerstone for any aviation operations. Therefore, in the interest of safety, the Federal Aviation Administration (FAA) should require any 145 Repair Station inside or outside the United States performing any maintenance to any Part(s) 121, 135 and 91 operators to implement and administer a drug and alcohol testing program. Safety-sensitive maintenance personnel performing any form of maintenance services should be subject to a drug and alcohol testing program. The ANPRM should be expanded to include Part 135 and 91 operators as well as Part 121 air carriers, as unsafe operations of any air carrier may cause catastrophic consequences.


In amending the FAA’s drug and alcohol testing


regulations, the FAA should focus on the issue of safety versus the legality, moral, cultural or religious views surrounding the use of psychoactive substances (illegal drugs, controlled substances and alcohol). According to the Manual of Civil Aviation Medicine, the use of psychoactive substances varies world-wide as follows: • Alcohol in the West • Opium in the Far East • Hashish (marijuana) in the Middle East


The year 2014 saw the legalization of recreational


tetrahydrocannabino (THC), the psychoactive ingredient in marijuana/cannabinoids (“THC use”) in Colorado. In June 2014, recreational THC use will become legal in Washington State. Seventeen states and Washington, D.C. have legalized medical THC use. Twenty other U.S. states and Washington, D.C. are considering initiatives to legalized recreational THC use.


THC concentration is similar to alcohol concentration.


Marijuana in the 1960’s and 1970’s had a very low concentration of 2-4% THC similar to 4-5% alcohol content in beer. Today, it is common for THC product to be at a concentration of 25-35% similar to the 40% alcohol concentration in a glass of hard liquor such as bourbon or


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scotch. The higher the percentage of THC, the more acute influence and the longer the effects last. Colorado has no limitation of percentage of THC under the new recreational law. Therefore, it can be sold in concentrations of 100%. When inhaled, the effects of THC are immediate and can last up to four hours. When ingested, the effects of THC begin within 30 minutes and can last up to four hours. With the legalization of THC, usage is no longer limited to inhalation. Marijuana and cannabinoids may now be consumed and/or ingested in products including, but not limited to soda pop, candy, cookies, cakes, cooking oil, butter, etc. Driving under the influence of THC remains illegal and law enforcement may obtain a search warrant for a person’s breath or blood. The DOT and FAA remain adamant that use of any


form of THC by individuals performing safety-sensitive functions is illegal and prohibited. The Drug Enforcement Agency (DEA) remains adamant that use of any form of THC is illegal under the federal Controlled Substances Act, which supersedes any state law. The DOT allows operators governed by the agencies it governs to implement and administer voluntary drug and alcohol testing programs known as “Company Authority”. Companies should recognize that psychoactive substance


abuse (especially alcohol) is a worldwide problem and marijuana is one of the most underestimated drugs of abuse. Employers are in unchartered territory with the legalization of THC for medical and recreational use. Prevention and education of using psychoactive substances is the best offense to a great defense. Identification of problematic use and removal from company functions increases the safety of employers, employees, property, machinery, assets and the public. Companies should determine worst-case scenarios for employees’ use of problematic substances. International 145 Repair Station employers need to examine the issues prevalent with employees’ use of psychoactive substance, especially THC, inside and outside the workplace. If employers are not concerned about the use of psychoactive substances, they should be. Employers should focus their attention regarding usage of THC (whether legal or illegal) and psychoactive substances and where to focus their attention:


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