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

Industry Input on Youth Engagement

Last July, ARSA Vice President of Operations Brett Levanto was appointed to the Department of Transportation’s Youth Access to American Jobs in Aviation Task Force. Since the task force began…Read More

The Sponsors

Registration Form | Event Information | Hotel Reservations March 9-12, 2021 Washington, D.C., Arlington, Virginia & Online Annual Conference sponsors represent the best of ARSA’s membership. The 2021 list will…Read More

FAA Opens Grant Program Applications

On Jan. 19, the FAA announced it was officially accepting applications for both of the new aviation workforce development grant programs mandated by the FAA Reauthorization Act of 2018. The…Read More

[Updated] FAA-EASA BASA Amended, MAG Change 8 Published

Update: On Jan. 14, 2021, ARSA distributed a member alert providing general guidance for U.S.-based repair stations with existing EASA supplements reviewing MAG 8. The alert provided access to a…Read More

Make ARSA Training Work for 2021

ARSA’s online training program represents its most-valuable benefit to the aviation industry: knowledge gained through training and experience. The association’s team has turned its decades of work on behalf of…Read More
ARSA