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Alcohol Testing (DOT) Procedures
 
Open/Close text What is the overall purpose of the Department of Transportation (DOT) alcohol testing program?

The alcohol testing program is designed for the deterrence and detection of alcohol misuse. The overall goal is stated as ensuring transportation safety.

 

Open/Close text Which employees in the aviation industry are covered under the rule?

Flight crewmembers, flight attendants, flight instructors, aircraft dispatchers, aircraft maintenance employees, screening and ground-security coordinator personnel and air traffic controllers.

 

Open/Close text What alcohol use is prohibited under the rule?

Alcohol use is defined, under the rule, as "the consumption of any beverage, mixture or preparation, including any medication, containing alcohol."  Alcohol related conduct prohibited under the rule includes acting or attempting to act as a crew member of a civil aircraft within eight hours of using alcohol, while having an alcohol concentration of 0.04 or greater as indicated by an alcohol breath test, using alcohol within eight hours after an accident or until tested, and refusing to submit to an alcohol test.
Open/Close text I am concerned with testing "positive" after only having used a mouth alcohol such as mouth wash. Should I be?

The rule clearly defines "consumption" as the violation. The testing procedure which requires a confirmatory test, given at least 15 minutes, after the initial screening test protects you from testing positive to mouth alcohol, if not consumed.
Open/Close text When will I be subject to alcohol testing?

The new rule requires alcohol testing in five categories. The first four of these categories require a "triggering event".
Open/Close text Triggering Events:

Pre-employment - Before or after an applicant is hired, but before actually performing safety-sensitive functions for the first time.

Post-accident - Conducted after accidents on employees whose performance could have contributed to the accident.

Reasonable suspicion - Conducted when a trained supervisor observes behavior or appearance that is characteristic of alcohol misuse.

Return -to-duty and Follow-up - Conducted when an individual who has violated the prohibited alcohol conduct returns to performing safety-sensitive duties.

Open/Close text The Fifth Category - Random Testing

Random - Conducted on a random, unannounced basis just before, during or just after performance of safety-sensitive function.

As with random testing, three of the other four categories (the exception is pre-employment testing) must be conducted just before, during or just after performance of a safety-sensitive function.

Open/Close text Is the rule more specific in defining the "time surrounding" the performance of the safety sensitive function?

DOT did not define the concept "time surrounding... in terms of a specific time, but it is intended to be close enough to the actual performance of the safety-sensitive function that the test results will clearly indicate that the employee would be or was at 0.04 (or 0.02 or greater but less than 0.04) at the time when performing those functions."
Open/Close text Who determines when a "reasonable suspicion" test will be given?

A single "trained" supervisor can require testing when he or she believes an employee has violated the rules.  The determination "must be based on specific, contemporaneous, articuable observations... concerning the appearance, behavior, speech or body odors.." of the individual.   Again, reasonable suspicion testing is authorized to take place only if the "required observations are made, during, just preceding or just after the period of the work day that the covered employee is performing the safety-sensitive function."   Testing should not be performed based on long-term factors such as, patterns of absenteeism, lateness, abuse of sick leave, decline in work performance, etc.. Testing cannot not be based on " reports by a third person". The observation must be by the "trained"supervisor.  Training for supervisors is defined as "at least 60 minutes of training on the physical, behavioral, speech and performance indicators of probable alcohol misuse, particularly those associated with lower concentrations of alcohol."
Open/Close text How will random testing take place?

"The employer must select employees for testing through a scientifically valid method, such as a random number table or a computer-based random number generator that is matched with employees' Social Security numbers, payroll identification numbers, or comparable identifying numbers... Each covered employee must have an equal chance of being tested under the random selection process used.... The dates for administering random tests must be spread reasonably throughout the year." Each year the number of random test must be at least 10% of the covered employees. The rules provide for an adjustment to annual testing rate in the future based on industry violations.  From 1996 to 1997, the testing rate was at least 25%, but was lowered because the industry average for those two years remained low.
Open/Close text How long do I have to arrive at the test site for random testing once notified?

The rule indicates you must proceed "immediately". The time between notification and testing should be the absolute minimum necessary. FAA goes on to say "with limited exceptions, the time between notification and testing will be no more than the requisite travel time to the testing site. If notification and testing occur at an airport, this time should be a matter of minutes".
Open/Close text How will the alcohol testing be performed?

Testing will be performed using evidential breath testing (EBT) devices which have been approved by the National Highway Traffic Safety Administration (NHTSA).  NHTSA  issues Conforming Products Lists of such approved devices. Only devices on these lists may be used for DOT alcohol testing.   Blood or urine testing is NOT allowed under the current rule.
Open/Close text Where will the testing be performed?

Testing will be conducted in a location which allows "visual and aural privacy to the individual being tested". In addition, the area should be such that it "prevents unauthorized persons from seeing or hearing the test results". The BAT will supervise only one individual's use of the EBT at a time. The BAT will not leave the testing area while a test is in progress.
Open/Close text Who will be performing the alcohol testing?

Implementation and conduction of the testing is the responsibility of the employer.  Individuals actually performing the breath testing must be trained to proficiency on the EBT they will be using as breath alcohol technicians (BAT).  Courses of instruction must be equivalent to the DOT model course as determined by NHTSA.
Open/Close text What are the specific testing procedures?

When you arrive at the testing location the BAT will require you to provide positive identification.  The BAT also has to provide positive identification if you so request.  The BAT must then explain the testing procedure to you.

The screening test will then proceed. The BAT will complete Step 1 on the Breath Alcohol Testing Form which involves completing administrative information. You will then complete Step 2 of the form, signing the certification.  Refusal to sign this certification shall be considered a refusal to take the test. An individually sealed mouthpiece will then be opened in your view by the BAT and attached to the EBT. You will then be instructed to blow forcefully into the mouthpiece for at least 6 seconds or until the EBT indicates an adequate breath amount. If the EBT can not print out the results, the BAT will show you the results displayed on the EBT. The BAT will then record this number (result) along with the test number, testing device name, testing device serial number and time of test in Step 3 of the form. The BAT will then record the same information in a log book which you will initial. If the EBT prints this information the BAT will affix it to the form using tamper-evident tape. The BAT will also show you the test result displayed on the machine to be assured they are the same. If the result is less than 0.02 the BAT shall date and sign the certification in Step 3. You will then date and sign the form in Step 4. If you do not sign the form in Step 4 or fail to initial the log book entry for a test, "it shall not be considered a refusal to be tested". The BAT will note the failure to sign or initial in the remarks section. If the EBT prints the results and they do not match what is displayed, this should be noted in the remarks section and initialed by both. This test is considered invalid and the company and employee should be so advised. No further testing is authorized if the result is less than 0.02. Copies of the form will be distributed to employer, employee and a copy is retained by the BAT. If the screening test is 0.02 or greater a confirmation test will be performed.

For confirmation testing. The confirmation test may be performed on the same machine, as long as, the machine has the capability of printing each test result and air blank, and to consecutively number each test. The BAT will instruct you "not to eat, drink, put any object or substance in your mouth, and, to the extent possible, not belch during a waiting period before the confirmation test." The waiting period between test must be at least 15 minutes and begins at the end of the screening test. The confirmation test is suppose to be completed within 20 minutes of the completion of the screening test, however. The BAT should explain to you the reason for this waiting period. "If a BAT other than the one who conducted the screening test is conducting the confirmation test, the new BAT shall initiate a new Breath Alcohol Testing form." The procedure will continue as outlined above for the screening test. There are several differences, however. Prior to the confirmation test the BAT will ensure the EBT reads 0.00 on an air blank test. If the reading is greater than 0.00 then another air blank will be run. If the reading is still greater than 0.00 then the test can not be performed on this machine. The testing may proceed on another EBT, however. If the screening and confirmation test are not identical, the confirmation test will be the result on which action will be taken. The BAT will "transmit all results to the employer in a confidential manner." There will be specific employer designated individuals who will receive and handle the alcohol testing results. Again, this will be done in a confidential manner, but can be transmitted "in writing, in person or by telephone or electronic means". This will be done immediately. There must be a mechanism in place so the employer has a way of verifying the identity of the BAT. If the initial transmission is not in writing then the BAT must follow with a copy of the breath testing form. "The employer shall store the information so as to ensure that confidentiality is maintained..."

 

Open/Close text What occurs if a test cannot be completed?

"If a screening or confirmation test cannot be completed, or if an event occurs that would invalidate the test, the BAT shall, if practicable, begin a new screening or confirmation test, as applicable , using a new breath alcohol testing form with a new sequential test number.."
Open/Close text What occurs if I refuse to take the test?

Under the rules this is considered a violation, equal to a result of 0.04 or greater.
Open/Close text Can my company hold higher standards or take specific actions?

Yes, the rule deals with consequences of testing at 0.04 or greater and actions taken. The requirement of the rules for testing 0.02 - 0.039 is only removal from the safety sensitive position duties for 8 hours or until retested below 0.02.  Company policies may differ significantly.
Open/Close text How will I know what the company policies are?

The rules require the company to provide each employee with their policies and procedures with respect to meeting the requirements of the rules, in addition to materials which explain the alcohol misuse prevention requirements. You should also be given the identity of a contact person knowledgeable on the company's alcohol misuse program and its specifics.
Open/Close text If I have just completed a flight, and test at 0.017 can the company assume that I was greater than 0.02 during the flight?

Calculating alcohol concentrations over time based on an average rate of alcohol metabolism, better known as "back extrapolation" is not allowed under the rule. Action is based on the actual reading only.
Open/Close text What procedures of the testing process must I be aware of?

There are seven circumstances in which a breath alcohol test will be considered invalid

(1) The 15 minute waiting period prior to a confirmation test is not observed.

(2) An air blank is not performed on the EBT before a confirmation test or the air blank doesn't result in a reading of 0.00

(3) The BAT does not sign the form as required by the regulations

(4) The BAT fails to note in the remarks section on the form that the employee failed the test or refused to sign.

(5) An EBT fails to print a confirmation test result

(6) The sequential test number or the alcohol concentration printed out is not the same as displayed on the EBT

(7)  If an EBT fails an external calibration check, then every test result of 0.02 or above obtained on this particular device since the last valid external calibration check will be invalid.

Open/Close text What are the consequences of alcohol misuse?

Individuals who engage in prohibited conduct (see question 3) must be immediately removed from their safety sensitive function. They must be evaluated by a company selected Substance Abuse Professional (SAP) and comply with treatment recommendations if any. In addition those testing between 0.02 and 0.039 must be removed from safety sensitive function for at least 8 hours or until another breath test indicates a result less than 0.02. As noted above most companies' policies will differ from that within the rules. Further more, aviation covered employees may face a "permanent bar" from performing the safety sensitive function they performed prior to the violation. This bar applies to the individual who misuses alcohol while on duty; or a second time violation, after previous misuse for which rehabilitation was undertaken or completed; or if they then refuse to undertake required rehabilitation; or if they fail to complete required rehabilitation.
Open/Close text I would like to be able to self-test. What is available to do so?

DOT is currently considering allowing several individual, self contained testing apparatus to be used. This includes a saliva tester and several tube/crystal breath testers. These devices will be obtainable by individuals at reasonable cost. Final approval is pending. If these pass NHTSA standards, they would be considered appropriate for personal screening use.  Further information on these devices will be published at a later date.
Open/Close text Must a rule violation be reported to the FAA, or just DOT?

Yes, violations will be reported to the Federal Air Surgeon within 2 working days on all individuals holding a medical certificate issued under Part 67 of the regulations.  SAP evaluations must also be reported to the Federal Air Surgeon on all Part 67 medical certificate holders within 2 working days of the reports receipt.  If you test between 0.02 and 0.039 and the company requires a SAP evaluation, this will likely be reported by the company to the Federal Air Surgeon. Once FAA has received the medical reports, they will then determine further action if any. This may include additional evaluation, treatment, medical certificate action, etc.
Open/Close text Will FAA deny my medical certificate for a violation?

"No covered employee who holds a Part 67 airman medical certificate shall perform safety-sensitive duties for an employer following a violation until and unless the Federal Air Surgeon has recommended that the employee be permitted to perform such duties."
Open/Close text If I am concerned I may have an alcohol use problem, who should I contact?

Contact VFS for assistance. See our article on Drug and Alcohol Treatment and Abatement Programs for corporate aviation flight departments and professional pilots.  Also see Aviation International News article Feb 04 on VFS Substance Abuse Prevention Program.
Open/Close text VFS Aeromedical Assistance

For a more specific personal explanation to your questions or those concerning aeromedical certification, contact VFS for a private consultation.    If you are a VFS Corporate Member, these services are FREE to you.
 
 
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