AOPA supports a cost-cutting regulatory amendment would allow air carrier (Part 121) and charter (Part 135) operators that also conduct sightseeing tours under Part 91 to combine their drug and alcohol testing programs.
In comments submitted Aug. 31, AOPA Vice President of Regulatory Affairs Rob Hackman noted the proposed language could be further clarified when it comes to consequences of violations. It appears that the FAA seeks to impose specific sanctions, comprising removal of the offending employee from safety-sensitive tasks, following a single on-duty violation, or two off-duty violations. That intent is not entirely clear in the proposed rule, and Hackman recommended a minor revision.
Overall, the proposed rule would cut costs for operators by eliminating the need to maintain separate drug and alcohol testing programs for Part 91 operations conducted by air carrier or charter companies.
“AOPA supports the overall concepts of this (notice of proposed rulemaking) and appreciates the FAA’s efforts to streamline drug and alcohol testing requirements while providing cost-effective changes to applicable regulations, but requests the FAA reconsider its intended policy regarding enforcement of this regulation,” Hackman wrote.