Does a person who cleans an aircraft have to be covered under a drug and alcohol testing program?

No, unless preparing the aircraft for cleaning requires the removal of components or the protection of components, which may fall under the definition of maintenance or preventive maintenance under 14 CFR § 1.1 or Part 43. For example, before cleaning an aircraft, it may be necessary to close and secure the upper and lower fan cowl doors on a transport category aircraft. The FAA considers the closing and securing of the engine fan cowl doors maintenance.

Additionally, after the cleaning process, it may be necessary to reapply lubrication compounds and preservatives to aircraft components, both of which could be considered maintenance or preventive maintenance. If the aircraft is operated by a part 119 certificate holder authorized to conduct Part 121 or 135 operations, or is used to conduct sightseeing operations as defined in 14 CFR § 91.147, the individual performing the aircraft maintenance or preventive maintenance must be subject to drug and alcohol testing in accordance with 14 CFR Part 120.

Conversely, the FAA does not consider cleaning seat cushions/covers maintenance or preventive maintenance.

The FAA's Flight Standards Service are the experts in determining whether work is considered maintenance or preventive maintenance, in accordance with the definitions in 14 CFR § 1.1 and Part 43. If you have additional questions about these definitions, please contact your local Flight Standards District Office (FSDO) or your Principal Maintenance Inspector.

If you have any other questions or need additional guidance regarding the FAA's drug and alcohol testing requirements in 14 CFR Part 120, contact the Drug Abatement Division at 202-267-8442 or drugabatement@faa.gov.

Please visit our website to learn more about our program.

Applicable Regulations:

14 CFR § 1.1
14 CFR Part 43
14 CFR § 91.147
14 CFR § 120.1
14 CFR § 120.105(e)
14 CFR § 120.215(a)(5)