ARSA RSS Feed ARSA LinkedIn
Contact Us Online Portal

ARSA Seeks Drug/Alcohol Rule Applicability Interpretation From FAA

Alexandria, Va., July 19, 2006: The Aeronautical Repair Station Association has requested a legal interpretation from the Federal Aviation Administration (FAA) related to the DOT/FAA drug and alcohol (D&A) testing rule released January 10, 2006.

In a letter dated July 18, ARSA inquired whether persons performing rebuilding and alteration activities are required to be covered by a D&A testing program, and whether persons doing off-aircraft maintenance of in-flight entertainment (IFE) system components must be covered by a program.

“It is our understanding that neither rebuilding nor alterations [as defined in Federal Aviation Regulations Part 43 and FAA Order 8300.10, respectively] is subject to the drug and alcohol testing rules,” ARSA said in its request to the FAA. “Please advise if this is correct.”

ARSA noted that while many repair station personnel perform both maintenance and alterations, some do only alterations. Clarifying who must be covered by a D&A program is critical. The only persons that can be part of an FAA-regulated D&A program are those that perform safety-sensitive functions, including maintenance. “If these [alteration-only] activities are not maintenance, no federal testing would be authorized and the company would be subject to sanctions if it ‘erred on the side of caution’ and tested such employees,” ARSA explained.

ARSA also asked the agency to clarify a conflict on how IFE-related maintenance is defined. In the D&A rule’s preamble, the agency said that repairing IFE components “usually is not considered maintenance,” while removing and reinstalling the repaired component is maintenance. However, the definition of maintenance in Federal Aviation Regulations Part 1 includes repair and replacement but excludes removal, ARSA noted.



More from ARSA

DC Circuit Issues Opinion in Falsification Case

On July 12, the U.S. Court of Appeals for the District of Columbia Circuit issued its opinion in Kornitzky Group v. Daniel Elwell regarding the appeal of a National Transportation…Read More

Take Part in the FAA’s Engine Safety Review

On Oct. 24, the FAA will host a one-day Engine & Airframe-Engine Integration Safety Summit. Industry participation is encouraged. The purpose of the summit is to review and analyze engine-related…Read More

Hotline Highlight – Conference Glimpse

The hotline – ARSA’s premier member newsletter – contains news, editorial content, analysis and resources for the aviation maintenance community. All members should ensure they receive their edition the first week of…Read More

Upcoming SBA Roundtables in Alaska, Maine, New Hampshire & Vermont

The U.S. Small Business Administration (SBA) Office of Advocacy recently announced four new dates for its ongoing “regulatory roundtable” series: Anchorage, Alaska Wednesday, July 10, 2019 Alaska Small Business Development…Read More

Quick Question: Event Selection

Why do you go to an industry meeting or event? The association asked previously about what events aviation professionals attend (click here to see the list and share your itinerary),…Read More
ARSA