Join ARSA Ask ARSA Pay ARSA

ARSA Seeks Drug/Alcohol Rule Applicability Interpretation

ARSA has requested a legal interpretation from the FAA related to the new DOT/FAA drug and alcohol (D&A) testing rule. In a July 18 letter to the agency, 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.

While many repair station personnel perform both maintenance and alterations, some do only alterations. Clarifying whether alterations specialists 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 said in the letter.

ARSA also asked the agency to clarify a conflict on how IFE 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 FAR Part 1 includes repair and replacement but excludes removal.

ARSA’s request comes one week after the FAA and industry representatives, including ARSA, met to discuss pending guidance slated to be released by the FAA on complying with the rule.

For more on the new rule, click here.

For a news release on ARSA’s request, click here.



More from ARSA

2025 Annual Conference – Get Ready

March 18-21, 2025 Event Information | Registration | Sponsors Arlington, Virginia and Washington, D.C. with Livestream Options ARSA will make use of its well-honed tools for providing an engaging Conference; participants…Read More

U.S. Bilateral Update Requires SMS Compliance

On Feb. 10, the Bilateral Oversight Board (BOB) for the U.S.-European Union (EU) bilateral aviation safety agreement (BASA) issued Decision No. 13. It amends BASA Annex 2 to require U.S.-based…Read More

ARSA Survey Invite Sent

On Feb. 21, an invitation to complete ARSA’s member survey was sent to the email address of every primary contact. The message was subjected “Invitation to Complete ARSA’s Annual Member…Read More

ARSA Helps CNBC Illustrate Career Development “Challenge”

On Feb. 14, CNBC published a 12 minute special addressing the workforce and career development challenges facing the maintenance industry. ARSA Executive Director Sarah MacLeod participated, lending a voice to…Read More

ARSA Joins Workforce Grant Application

On Feb. 5, the aviation non-profit Choose Aerospace, which administers ARSA’s annual scholarship in addition to providing a maintenance-focused curriculum for student and employee development programs, included the association on…Read More
ARSA