ARSA in a Sept. 22, 2006 letter (.pdf) has asked the Federal Aviation Administration (FAA) to grant industry a nine-month extension, to July 10, 2007, for complying with the new drug & alcohol (D&A) program testing requirement. The current compliance deadline is October 10.

The extension is necessary because, despite the agency’s efforts to explain the rule through written guidance and presentations to industry, several key issues remain unresolved.

Among the issues awaiting clarity is an understanding of what activities are considered maintenance–and therefore are covered by the new rule.

For instance, activities such as rebuilding and alterations are similar to maintenance from a technical standpoint, but they are not within the regulatory definition of maintenance and preventive maintenance set forth in Federal Aviation Regulation (FAR) section 1.1. The agency’s guidance is not clear on whether rebuilding or alteration is covered by the new rule.

Also, guidance issued by the FAA says that cleaning of seat covers–which requires following specific instructions in manufacturer maintenance manuals to ensure flammability standards are met–during an overhaul is not maintenance, but cleaning engine parts during an overhaul is maintenance.

Another challenge: industry is still awaiting guidance on how companies with multiple repair station locations can register each of their facilities as part of one common program. ARSA understands that the agency is drafting guidance on this, but currently, each location must be registered individually and there are pending enforcement issues on this particular matter.

ARSA has been working with the FAA to get these issues resolved. Most recently, the Association submitted letters on July 18 and August 30, 2006 in which it posed several questions and requested the FAA to issue a legal interpretation. The agency is still working on its responses.

ARSA will keep its members informed regarding any developments.

Click here for more information on the new D&A rule.

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