What's Your Drug Testing Tier?

Federal regs say that certificated and sightseeing tour operators must ensure that all work "at any tier" on their aircraft is performed by individuals covered under a registered FAA-mandated drug and alcohol testing program. In practical terms, this means that if a company hires a repair station or general maintenance contractor to perform regulated repair work and that work is then outsourced to another vendor, the initial hiring company is still responsible for ensuring that the work is performed by an individual covered under a registered FAA-mandated drug and alcohol program.

"Obviously, this requires more diligence on the part of everyone concerned and it may therefore be prudent for operators to specifically put clearly defined instructions in writing, signed by the repair station or general maintenance contractor," says Kimberly LeClaire of Western Aeromedical Consortium.

Copies of plan registration documents (that is, an A449 or anti-drug and alcohol plan registration format) should be obtained from all repair entities -- at any tier -- and retained in the company's file.

According to LeClaire, it's also a good idea to periodically query the repair stations or general contractors to ensure that the programs are still current.

A little time spent checking in the beginning will reduce hours of headache when FAA inspectors audit your program -- not to mention the financial burden if a fine is imposed for non-compliance.