ARSA calls for its foreign members (except those located in Canada) to utilize the association’s new Foreign Repair Station Drug & Alcohol (D&A) Compliance Toolkit by following these steps:

(1) Gather an internal D&A compliance team that includes HR, legal, quality, and executive representation.

(2) Request the D&A Compliance Toolkit from arsa.org/publications.

(3) Use the D&A Compliance Toolkit and provide feedback to the association.

The Compliance Toolkit provides basic information regarding the FAA’s expansion of D&A testing outside the United States (except for Canada); the toolkit includes:

• A matrix for cross-referencing the testing requirements of 14 CFR part 120 with the laws of the country in which the repair station is located.
• A matrix for cross-reference of the testing procedures and requirements of 49 CFR part 40 with the laws of the country in which the repair station is located.
• Draft documents and guidance for repair stations and/or governments to seek exemptions/waivers.

ARSA has pushed back against the rule’s expansion since Congress’ 2012 mandate, which demanded the rulemaking but stipulated that overseas testing requirements be “consistent with the laws” of the sovereign nation in which the repair station is located. The association’s D&A Compliance Toolkit uses “sovereignty” to blunt unnecessary requirements. The association is testing its guidance with Australian regulators.

“[ARSA] has done substantial work, which was vastly underestimated by the FAA,” Executive Director Sarah MacLeod said. “We need the industry to pick up the ball as it bears the compliance burden.”

For background on the issue and ARSA’s advocacy and compliance efforts, visit arsa.org/drugandalcohol and arsa.org/regulatory/faa/operations/drug-and-alcohol-testing.

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