Repair Station Drug and Alcohol Testing

On December 7, 2023 the FAA published an NPRM titled, “Drug and Alcohol Testing of Certificated Repair Station Employees Located Outside of the United States.” The original deadline for comments was February 5, 2024, but it has been extended to April 5. The NPRM addresses repair stations that work on Part 121 aircraft. You can read it at:

The topic of drug and alcohol testing has been a controversial topic for quite a while. One argument is business-related. Some say the current situation creates an unlevel playing field. They argue that FAA-certified repair stations in foreign countries have an unfair advantage because they don’t have the costs associated with implementing and maintaining an approved drug and alcohol testing program.

Others cite safety as a concern. After all, nobody wants drug- or alcohol-influenced workers working on aircraft? It’s a safety issue, right?

In the NPRM, under IV. Discussion of the Proposal, subhead C. Exemptions and Waivers to Drug and Alcohol Program Requirements, it discusses scenarios where waivers can be granted.

Is it just me, or does the fact that there will be paths to waivers for some foreign-based repair stations negate both business and safety concerns? If drug and alcohol testing is so important, why offer opportunities for waivers? In my opinion, if you would like to operate an FAA-certificated repair station in a foreign country, then you either follow drug and alcohol testing or you don’t get your FAA repair station certificate. It seems to be common sense.

But then again, common sense doesn’t seem to be too common in the federal government these days.

Whatever your opinion is on the subject, be sure to share your comments on the NPRM before the deadline!

Thanks for reading, 

Joe Escobar

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