Are people who repair or maintain cargo containers loaded on the aircraft in cargo operations included in the requirement for a drug and alcohol testing program? (Note: Cargo containers are considered part of the aircraft.)
Yes. The definition of maintenance in 14 CFR Part 43 includes these types of repairs/maintenance. Therefore, an employer must ensure that these individuals are included in a Federal Aviation Administration (FAA) mandated drug and alcohol testing program.
Employers who need more information about the definition of maintenance or preventive maintenance should review our Safety-Sensitive Job Categories Alert or consult directly with their FAA Principal Maintenance Inspector or local Flight Standards District Office. The Flight Standards Service is the expert in clarifying maintenance or preventive maintenance duties. Please visit the FAA's website to find the Flight Standards District Office closest to you.
If you have any further questions or need additional guidance that is more specific to your situation, please contact the FAA Drug Abatement Division at (202) 267-8442 or drugabatement@faa.gov.
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