A group of aviation organizations and businesses are asking the U.S. FAA to clarify the applicability of drug and alcohol testing requirements to workers who are involved in receiving items for stock. Sixteen organizations wrote the FAA on February 15 for a legal interpretation after reports surfaced that some FAA auditors viewed receiving responsibilities as safety-sensitive functions and thus covered under drug and alcohol testing requirements.
“A receiving process simply verifies that incoming parts or materials are what they purport to be and that there are no obvious reasons to question a previous determination of airworthiness,” said the letter, which was signed by organizations such as the Aeronautical Repair Station Association, National Air Transportation Association and General Aviation Manufacturers Association, as well as companies such as Honeywell and Gulfstream.
The letter adds that receiving activities do not require the creation of a maintenance record. “Therefore, they are not safety-sensitive functions under [the drug and alcohol testing requirements of 14 CFR] Part 120.” Historically, agency guidance has not included either distributing or receiving parts in maintenance or preventive maintenance duties, the organizations agreed.
But the letter noted auditors who “have informally opined that personnel conducting tasks associated solely with receiving items for stock are performing maintenance and are therefore engaged in safety-sensitive functions,” and added, “This expansive interpretation would result in the misclassification of employees, thereby diluting random testing pools with non-safety-sensitive personnel.”