What are the drug testing program training requirements for my employees and supervisors?
The Federal Aviation Administration's (FAA's) drug and alcohol testing regulation establishes the requirements for training both safety-sensitive employees and supervisors who will make reasonable cause/suspicion testing determinations.
The training requirements for a drug testing program requires that each employer must implement initial training for employees that includes the effects and consequences of drug use on personal health, safety, and work environment; the manifestations and behavioral cues that may indicate drug use and abuse; and requires the employer to document that the training was given to employees and employer's supervisory personnel.
In addition to the employee training, each employer must implement initial and recurrent supervisory training for personnel who will determine when an employee is subject to testing based on reasonable cause. The training must include the specific, contemporaneous physical, behavioral, and performance indicators of probable drug use. Employers must ensure that supervisors who will make reasonable cause determinations receive at least 60 minutes of initial training and receive recurrent training at reasonable intervals. Although a timeframe for reasonable recurrent training is not defined, we believe that it is a best practice to conduct the recurrent training on a 12-18 month schedule.
The training requirements for an alcohol testing program are slightly different than those for a drug testing program. Specifically, each employer must provide educational materials that explain the alcohol misuse requirements and the employer's policies and procedures with respect to meeting those requirements. Please refer to the regulation for further requirements for the distribution and content of the educational materials.
Supervisors who make reasonable suspicion determinations for alcohol testing must receive at least 60 minutes of training on the physical, behavioral, speech, and performance indicators of probable alcohol misuse. Although the regulation does not require recurrent training for supervisors making reasonable suspicion alcohol determinations, we believe the best practice is to include a review of the alcohol testing requirements while conducting recurrent reasonable cause drug testing training.
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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