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Q&As for Safety-Sensitive Employees

Thursday, September 26, 2024

As a pilot who flies internationally for a U.S. air carrier, am I subject to drug and alcohol testing when I fly outside of the United States?
Although you are not subject to your employer's FAA-mandated testing program (required under 14 CFR part 120), you and your entire flight crew may be subject to the testing laws and associated penalties in foreign countries that you fly in and out of. Some of these penalties may include monetary fines and/or imprisonment.

In addition, you remain subject to the Federal Aviation Administration's regulation under 14 CFR § 91.17. Under § 91.17, you may not act as a crewmember of a civil aircraft within 8 hours after the consumption of any alcoholic beverage, while under the influence of alcohol, while using any drug that affects your faculties in any way contrary to safety, or while having an alcohol concentration of 0.04 or greater in a blood or breath specimen. Violations of § 91.17 may result in the revocation of your FAA certificate.

Q&As for Safety-Sensitive Employees

Thursday, September 26, 2024

What will happen if I return to work after a violation and I don't complete the return-to-duty process?
If you return to a safety-sensitive position after a violation and do not complete the return-to-duty process, you may be subject to legal enforcement action. The regulation prohibits you from performing any safety-sensitive functions after a violation until you have completed the return to duty requirements described in 49 CFR part 40, subpart O.

Q&As for Safety-Sensitive Employees

Thursday, September 26, 2024

Do I need to complete the return-to-duty process after my violation if I leave aviation for a long period and return later?
Yes. Regardless of the time that you allow to elapse between your drug or alcohol violation and your return-to-work date, you must complete the return-to-duty process described in 49 CFR part 40, subpart O before you may return to the performance of any safety-sensitive functions.

Q&As for Safety-Sensitive Employees

Thursday, September 26, 2024

If I cannot provide sufficient urine during a drug test, is it a refusal?

If you fail to provide a sufficient specimen when directed by the collector, and it has been determined, through a required medical evaluation, that there was no adequate medical explanation for the failure, it may be considered a refusal to test. According to 49 CFR part 40, the collector must begin the “shy bladder” or “dry mouth” procedures if you cannot provide a sufficient sample. You will have three hours to provide a sufficient amount of urine (45mL sample from a single void), or one hour to provide a sufficient amount of oral fluids (2mL single sample). If you cannot, the collector notifies your employer who will direct you to obtain a medical evaluation. If it is determined that a medical condition precluded you from providing a sufficient specimen, the test may be canceled and would not be considered a refusal. However, if there is not a medical condition that caused the insufficient sample, the collection will be considered a refusal.

Q&As for Safety-Sensitive Employees

Thursday, September 26, 2024

What steps must I take to return to the performance of safety-sensitive functions after I violated the FAA's drug and alcohol testing regulation?

You cannot return to the performance of safety-sensitive functions after violating the FAA’s drug and alcohol testing regulation [14 CFR part 120] until you complete the steps described in 49 CFR part 40, subpart O. The first step in the return-to-duty process is for your employer to provide you with a list of qualified Substance Abuse Professionals (SAP). The subsequent steps are as follows:

  • Step 1:  You must meet with the SAP for an evaluation either face-to-face in-person or remotely.  The SAP must recommend education and/or treatment and document the evaluation in a written report that is provided to your current or future employer.  
  • Step 2: The SAP must re-evaluate you in a follow-up face-to-face meeting to determine if you successfully completed the education and/or treatment recommendations.  If the SAP is satisfied, he or she must issue a written report to your current or future employer indicating whether your education and/or treatment was or was not successful.
  • Step 3: Before an employer can return you to safety-sensitive work, you must take a return-to-duty test under direct observation and receive a verified negative drug test result and/or an alcohol test with an alcohol concentration of less than 0.02.
  • Step 4: After you return to work, you will be subject to follow-up drug and/or alcohol testing under direct observation, as directed by the SAP.  Follow-up testing follows you through any breaks in service or from one employer to another. 

If you hold a medical certificate issued under 14 CFR part 67 and wish to return to the performance of duties requiring such a certificate, you must comply with any requirements imposed by your Aviation Medical Examiner or Regional Flight Surgeon and obtain an airman medical certificate issued by the Federal Air Surgeon dated after the date of your violation. The steps you must take to obtain your medical certificate are independent from the requirements your employer must follow to return you to duty (as described above), and both are required.

NOTE: If you have an on-duty drug or alcohol use violation, you are permanently disqualified from performing the safety-sensitive function you performed prior to the violation.

Q&As for Safety-Sensitive Employees

I received a letter of investigation from the FAA because of my drug or alcohol violation. Who do I contact to discuss my case?
If you received a letter of investigation from the Drug Abatement Division and have any additional questions, please contact the assigned Investigator at the number provided in your letter.

Physiology & Survival Training

Wednesday, February 18, 2026

Airman Education Programs offer aviation physiology and post crash survival courses for general aviation pilots, aircrew, and passengers at our facility in Oklahoma City, Oklahoma.

Please check out our newest publications:

Aircrew Health and Safety

Venous Thromboembolic Disease: Risk for Passengers and Aircrew?
By Nicholas Lomangino, MD

Although venous thromboembolic disease during air travel is the focus of recent attention, lack of activity such as a long car, bus, train ride, sitting in the theatre or long hours at a desk are all causes of prolonged immobilization. However, review of the literature indicates that most cases of VTE seem to be associated with an underlying disorder. Clinicians and the public at large should focus on existing medical conditions in addition to immobilization and be aware of measures to reduce the risk of VTE.

Recent concerns in the global news have again raised an issue about the association of thromboembolic disease and air travel. The association of venous thromboembolic disease (VTE) and inactivity was first described in persons sleeping on deck chairs in bomb shelters during the London blitz of WWII. In 1954, John Homans (1) reported several cases of venous thrombosis involving restricted activity.

Signs and symptoms of VTE may include paresthesias, swelling, chest pain, discoloration or pain in the dependent extremity, dyspnea, and cardiac arrhythmias. The clinical presentation is dependent upon the simple development of thrombosis or the addition of embolic activity. Although the lower extremity is involved in the preponderance of cases, upper extremity involvement has also been described.

The annual incidence of venous thromboembolic (VTE) disease has been reported to be 1 in 1000. Kesteven (2) refined the median estimate to from 1.6 to 1.8 per 1000. However, age adjusted data demonstrate a wide range from 1 per 10,000 in young adults to 3-5 per 1000 in persons greater than 60 years of age.

Although there are numerous studies in the literature examining VTE disease, variability of population demographics resists combined analysis. There are no published prospective clinical studies in asymptomatic travelers identifying VTE or activation of the thrombotic system (2). Close examination of the literature clearly demonstrates that VTE is multi-causal in nature, resulting from differing etiologic and predisposing factors across different age groups. A dynamic model dependent upon age and co-morbid factors is necessary to understand the relative risk for each set of clinical criteria (3).

Risk factors for VTE include prior personal or family history of VTE, pregnancy, postpartum period, obesity, malignancy, hormone replacement therapy, recent trauma (surgical or injury), dehydration, alcohol consumption, lower limb paralysis, low cardiac output syndromes, chronic disease, autoimmune disease, genetic factors such as coagulopathies (blood clotting disorders) and other blood disorders, and finally, immobilization.

Genetic predisposition to excessive clotting is reported to affect 3 to 5% of the general population. When the acquired forms of coagulopathies are considered, the prevalence is even higher. Most prominent amongst this category of disorders are anti-thrombin III deficiency, Protein S and Protein C deficiencies, Factor V Leiden mutation, lupus anti-coagulant (anti-phospholipids), high Factor VIII concentration, hyperhomocysteinaemia, and prothrombin 20210A (3).

Although venous thromboembolic disease during air travel is the focus of recent attention, lack of activity such as a long car, bus, train ride, sitting in the theatre or long hours at a desk are all causes of prolonged immobilization. However, review of the literature indicates that most cases of VTE seem to be associated with an underlying disorder. Clinicians and the public at large should focus on existing medical conditions in addition to immobilization and be aware of measures to reduce the risk of VTE.

Berndt and associates (4) reported that none of the comprehensive studies report crew members suffering from thromboembolism. Although the activity of the cabin crew minimizes the immobilization effect, the same cannot be said for the cockpit crew. Eklof and associates (5) studied cases of VTE originating from Honolulu International Airport for the 6-year period from 1988 to 1993. It was estimated that 6 million passengers annually traveled through the airport. Forty-four cases of VTE were identified. All but 7 cases had one or more risk factor in addition to immobilization.

There is one report suggesting an association between increased activity of coagulation system and the hypobaric hypoxic (low pressure and low oxygen) environment experienced in flight. This study lacked a control group and screening for predisposing genetic factors. There was no association between increased activity of the coagulation system and VTE. Although the study is not conclusive, it is certainly suggests that further study is justified (6).

The wisdom of John Homas, written in 1954 (1), is still true today. He wrote, "As is so often true of venous thrombosis, this group of cases reveals a tendency rather than a proved relation of cause and effect." He continued, saying "Such matters are important enough to suggest the advisability of making movements of the toes, feet and lower legs when one is sitting for long periods and of getting up and exercising when opportunity offers." Some have suggested a 5-minute period of activity every hour. This may be problematic in modern aircraft and additionally may pose a separate safety risk, as well as increased opportunity for injury if the aircraft encounters turbulence.

The House of Lords' Committee on Science and Technology has published recommendations.

The Aerospace Medical Association likewise has published recommendations to reduce the risk of deep vein thrombosis (7).

Avoidance of alcohol and sedating medications, hydration before and during flight, use of compression stockings, and having adequate legroom and leg exercises are all measures that will lower the risk of VTE. Use of aspirin and or low molecular weight heparin clearly needs consultation with a physician to assess the risk and benefits of such pharmacologic intervention.

References

  1. Homans, John. Thrombosis of the deep leg veins due to prolonged sitting. NEJM;1954;V.250:148-9.
  2. Kesteven, PLJ. Traveller's thrombosis. Thorax; Aug 2000;55:532-6.
  3. Rosendaal, FR. Venous thrombosis: A multicausal disease. Lancet; April 3, 1999; 353:1167-73.
  4. Berndt, A. et al. Risk Factors for venous thromboembolism following prolonged air travel. Hematology/Oncology Clinics of North America; 14/2; April 2000: 391-7.
  5. Eklof B et al. Venous thromboembolism in association with prolonged air travel. Dermatol Surg; Jul 1996;22:637-41.
  6. Bendz, B et al. Association between acute hypobaric hypoxic and activation of coagulation in human beings. Lancet; Nov 11, 2000; 356:1657-58.
  7. Aerospace Medical Association, Medical Guidelines for Airline Travel, 1997

Dr. Lomangino is the Deputy Manager of Medical Specialties Division at FAA headquarters.

This article originally appeared in the Federal Air Surgeon's Medical Bulletin, Spring 2001.

Q&As for Safety-Sensitive Employees

Thursday, September 26, 2024

Who pays for my meeting with a Substance Abuse Professional (SAP) and my treatment program?
The testing regulations do not specify who must pay for an employee's SAP evaluation and treatment program. The employer is required to provide a listing of qualified SAPs to individuals who violate the drug and alcohol testing regulations. Who pays for this evaluation and treatment program is at the discretion of the employer.