depend on your company drug and alcohol policy whether they are able to return to their current employment. You may want to send a certified leter to the employee with all the information for the SAP, stating he/she must comply with the SAP’s recommendations before returning to any safety-sensitive functions. Once you receive the signed, certified postcard from the postal department as verification that the leter was received by the worker, file it with your documentation. Federal agency inspectors will want to see documentation that you have complied with SAP information. You can give the information verbally or fax it to the employee, and as a follow-up, the best practice is to send a certified leter with all the information. If your policy allows for the employee


to return to work, then you must follow the return-to-duty process that is outlined by the SAP. A Federal DOT return-to- duty test is performed, and negative results must be reported before the employee can return to duty. If you are lucky, and you have someone


who manages this part of your program, that is awesome; however, as the DER, it is your responsibility to know for certain that the result is negative before leting the employee return to work. Some facilities have a protected site where you can look to see if results are posted and actually pull up the results to verify yourself. Last but not least, what do you do and


how do you document for reasonable suspicion? You should document thoroughly and carefully all information surrounding a reasonable suspicion. Remember, it takes two trained supervisors with 90 minutes of drug and alcohol training to verify “reasonable cause.” You only need one supervisor for alcohol; however, at our facility, we use two. It is also a very good idea that anyone who is a DER complete the same required supervisor 90 minute drug and alcohol course that the


www.datia.org


FAA requires for supervisors. It is not required by the FAA, but as a best practice, all DERs should be required to participate in the training and complete a refresher course every 18 months. Oſten aſter hours, holidays, and weekends, there may be only one supervisor on duty, and you may be called at home to come in to determine and verify reasonable suspicion. Te federal regulations state you must have two trained people. At right is a sample “Reasonable Cause/ Reasonable Suspicion” form from the FAA’s website. I utilize most of the forms


the FAA has posted, and you may always apply them to your company’s leterhead. Using the government’s form will ensure that you are compliant.


Post-Accident Testing Injury to self or damage to company property does not constitute a federal post-accident test. Te only definition of a federal post-accident test is: Federal Post Accident—an occurrence


associated with the operations of an aircraſt which takes place between the time any persons board the aircraſt with the intention of flight and the time all such persons have disembarked, and in which any person suffers death or serious injury or in which the aircraſt receives substantial damage. Any other type of post-accident test is a


non-DOT test. Te above federal definition is prety clear and concise, however some people get excited when there is any type of injury or accident. Just because someone is working in a safety-sensitive job doesn’t mean that when they injure themselves or damage an aircraſt a federal test is required. It is a good idea to post the definition


of a federal post-accident test in your facility and make sure your supervisors understand. Tey are oſten the first ones to come and tell you they need a DOT post- accident test on an employee. Just remind them of the definition and explain why the test is a non-DOT post-accident test. ❚


Karen Lehman has been a registered nurse since 1966 and is employed by Bom- bardier Aerospace/Learjet in Wichita, KS. She has been with Bombardier for 29


years. She is the administrator compliance coordinator for the federal drug and alcohol program. She was instrumental in setting up the local Drug Council in her area, which meets annually to discuss recent audits, new regulations, and any other problem areas. Karen enjoys classical music and dance, church choir, and cross-stitching.


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