[Federal Register: January 10, 2006 (Volume 71, Number 6)]
[Rules and Regulations]
[Page 1665-1677]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr10ja06-10]
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Part IV
Department of Transportation
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Federal Aviation Administration
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14 CFR Part 121
Antidrug and Alcohol Misuse Prevention Programs for Personnel Engaged
in Specified Aviation Activities; Final Rule
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DEPARTMENT OF TRANSPORTATION
Federal Aviation Administration
14 CFR Part 121
[Docket No.: FAA-2002-11301; Amendment No. 121-315]
RIN 2120-AH14
Antidrug and Alcohol Misuse Prevention Programs for Personnel
Engaged in Specified Aviation Activities
AGENCY: Federal Aviation Administration (FAA), DOT.
ACTION: Final rule.
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SUMMARY: This final rule amends the FAA regulations governing drug and
alcohol testing to clarify that each person who performs a safety-
sensitive function for a regulated employer by contract, including by
subcontract at any tier, is subject to testing. These amendments are
necessary because in the 1990s, the FAA issued conflicting guidance
about which contractors were subject to drug and alcohol testing. This
action also rescinds all prior guidance on the subject of testing
contractors.
DATES: These amendments become effective April 10, 2006. Affected
parties, however, do not have to comply with the information collection
requirements in part 121, Appendix I, Section IX, and Appendix J,
Section VII, until the FAA publishes in the Federal Register the
control numbers assigned by the Office of Management and Budget (OMB)
for these information collection requirements. We will publish the
control number to notify the public that OMB has approved these
information collection requirements under the Paperwork Reduction Act
of 1995.
FOR FURTHER INFORMATION CONTACT: For technical information, Diane J.
Wood, Manager, Drug Abatement Division, AAM-800, Office of Aerospace
Medicine, Federal Aviation Administration, 800 Independence Avenue SW.,
Washington, DC 20591, telephone number (202) 267-8442. For legal
information, Patrice M. Kelly, Senior Attorney, Regulations Division,
AGC-200, Federal Aviation Administration, 800 Independence Avenue, SW.,
Washington, DC 20591, telephone number (202) 267-8442.
SUPPLEMENTARY INFORMATION:
Availability of Rulemaking Documents
You can get an electronic copy of this rule using the Internet by:
(1) Searching the Department of Transportation's electronic Docket
Management System (DMS) web page (http://dms.dot.gov/search); (2) Visiting the Office of Rulemaking's web page at http://
http://www.faa.gov/regulations_policies/; or
(3) Accessing the Government Printing Office's web page at http://www.access.gpo.gov/su_docs/aces/aces140.html
.
You can also get a copy by submitting a request to the Federal
Aviation Administration, Office of Rulemaking, ARM-1, 800 Independence
Avenue SW., Washington, DC 20591, or by calling (202) 267-9680. Make
sure to identify the docket number of this rulemaking.
Anyone is able to search the electronic form of all comments
received into any of our dockets by the name of the individual
submitting the comment (or signing the comment, if submitted on behalf
of an association, business, labor union, etc.). You may review DOT's
complete Privacy Act statement in the Federal Register published on
April 11, 2000 (Volume 65, Number 70; Pages 19477-78) or you may visit
http://dms.dot.gov.
Small Business Regulatory Enforcement Fairness Act
The Small Business Regulatory Enforcement Fairness Act (SBREFA) of
1996 requires FAA to comply with small entity requests for information
or advice about compliance with statutes and regulations within its
jurisdiction. If you are a small entity and you have a question
regarding this document, you may contact its local FAA official, or the
person listed under FOR FURTHER INFORMATION CONTACT. You can find out
more about SBREFA on the Internet at http://www.faa.gov/regulations_policies/rulemaking/sbre_act/
.
Authority for This Rulemaking
The FAA's authority to issue rules regarding aviation safety is
found in Title 49 of the United States Code. Subtitle I, Section 106
describes the authority of the FAA Administrator. Subtitle VII,
Aviation Programs, describes in more detail the scope of the agency's
authority.
This rulemaking is promulgated under the authority described in
Subtitle VII, Part A, Chapter 451, section 45102, Alcohol and
Controlled Substances Testing Programs. Under section 45102, the FAA is
charged with prescribing regulations to establish programs for drug and
alcohol testing of employees performing safety-sensitive functions for
air carriers and to take certificate or other action when an employee
violates the testing regulations. This regulation is within the scope
of the FAA's authority because it clarifies the existing regulations
regarding individuals who perform a safety-sensitive function for a
regulated employer by contract. This rulemaking is a current example of
FAA's continuing effort to ensure that only drug- and alcohol-free
individuals perform safety-sensitive functions for regulated employers.
Background
History
Since the inception of the FAA drug and alcohol testing
regulations, the FAA has not directly regulated contractors or
subcontractors of regulated parties. The FAA defines who is a regulated
``employer,'' for drug and alcohol testing purposes as a part 121
certificate holder, a part 135 certificate holder, an operator as
defined in 14 CFR 135.1(c), or an air traffic control facility not
operated by the FAA or by or under contract to the U.S. military. (14
CFR part 121, appendix I, section II, and appendix J, section I.D.)
On February 28, 2002, the FAA published in the Federal Register a
notice of proposed rulemaking (NPRM) (67 FR 9366). The NPRM proposed
changing several provisions in 14 CFR part 121, appendices I and J.
Among other proposals in the NPRM, the FAA proposed to clarify that
each person who performs a safety-sensitive function directly or by
contract (including by subcontract at any tier) for a regulated
employer is subject to testing. Currently, both 14 CFR part 121,
appendix I, section III and appendix J, section II specify employees
performing a safety-sensitive function must be subject to testing if
they are performing the function ``directly or by contract for an
employer.'' We proposed to add the parenthetical phrase ``including by
subcontract at any tier'' after the word ``contract.''
Several commenters to the NPRM, including trade associations,
repair stations certificated under 14 CFR part 145 (certificated repair
stations), and non-certificated entities, indicated the proposed
clarification on subcontractors would impose an economic burden on the
aviation industry. We did not include any costs or benefits for the
subcontractor issue in the preliminary regulatory evaluation
accompanying the NPRM because we considered the proposed language to be
merely clarifying. On January 12, 2004, we published a final rule
addressing all issues proposed in the NPRM, except for the
subcontractor issue (69 FR 1840).
[[Page 1667]]
Employees affect aviation safety whenever they perform a safety-
sensitive function listed in appendices I and J. Thus, it is important
that individuals who perform any safety-sensitive function be subject
to drug and alcohol testing under the FAA regulations. We recognize the
aviation industry frequently uses subcontractors to perform safety-
sensitive functions.
For more than a decade, we have required each regulated employer to
ensure any individual performing a safety-sensitive function by
contract be subject to drug and alcohol testing under the FAA
regulations. If the regulated employer wants to use the individual
under a contract, there are two options for drug and alcohol testing.
One option is for the contractor company to obtain and implement its
own FAA drug and alcohol testing programs. Under this option, the
contractor company must subject the individual to testing. The other
option is for the regulated employer to maintain its own testing
programs and subject the individual to testing under these programs.
Our experience indicates that many regulated employers and
contractor companies have recognized contractors and subcontractors are
subject to testing under the regulations. The FAA believes it would be
inconsistent with aviation safety to change the regulations so that
regulated employers are no longer required to ensure individuals
performing safety-sensitive functions ``by contract'' are subject to
testing.
Many commenters to the NPRM were concerned the proposed language
would cause considerable costs by requiring subcontractors to conduct
drug and alcohol testing for the first time. However, these commenters
did not substantiate their cost concerns with specific data. In
response to the economic comments regarding the subcontractor issue in
the NPRM, we published a supplemental notice of proposed rulemaking
(SNPRM), in the Federal Register on May 17, 2004 (69 FR 27980). In the
SNPRM, we proposed the same language we proposed in the NPRM. We asked
commenters to provide economic information to help us address the
concerns they raised in the NPRM.
We prepared a regulatory evaluation for the SNPRM regarding the
possible costs associated with explicitly including the words ``by
subcontract at any tier.'' We evaluated the costs that could be
generated by additional subcontractors who might be subject to testing
under the proposal.
Conflicting Guidance
In both the NPRM and the SNPRM, we discussed conflicting FAA
guidance about the testing of subcontractors. In the initial
implementation phase of the drug testing rule in 1989, the FAA issued
informal guidance stating maintenance subcontractors would not be
required to be subject to testing unless they took airworthiness
responsibility. This guidance was provided to persons and companies as
late as the mid-1990s, on an ad hoc basis. However, this guidance
constricted the potential reach of the regulation, which offered no
exceptions for subcontractors who did not take airworthiness
responsibility but performed safety-sensitive activities. Accordingly,
this guidance was in conflict with the objective of the regulations,
i.e., ensuring that each person who performs a safety-sensitive
function is subject to testing. Today's final rule clarifies that the
level of contractual relationship with a regulated employer does not
limit the requirement that all persons performing safety-sensitive work
must be subject to drug and alcohol testing.
As noted in the SNPRM, we are hereby rescinding all prior guidance
regarding subcontractors (69 FR at 27981).
Discussion of Comments
General Overview
The comment period for the SNPRM closed on August 16, 2004. The FAA
received approximately 35 comments in response to the SNPRM. To ensure
we meaningfully considered all comments on the issue, the FAA reviewed
both the comments filed to the SNPRM and any comments filed to the NPRM
not addressed in the preamble to the SNPRM. We note that none of the
commenters opposing the proposal provided specific data challenging the
FAA's fundamental economic assumptions. The regulatory evaluation
accompanying this final rule specifically addresses the comments about
costs and benefits.
Commenters included the Air Transportation Association of America
(ATA); Regional Airline Association (RAA); Drug and Alcohol Testing
Industry Association (DATIA); International Brotherhood of Teamsters
(Teamsters); Aircraft Mechanics Fraternal Association (AMFA); Aviation
Suppliers Association; and Aeronautical Repair Station Association
(ARSA), which filed joint comments on behalf of itself and 12 other
associations.
Approximately 10 of the commenters, including United Technologies
Corporation (UTC), the Teamsters, AMFA National, AMFA Local 33, and
several individuals, stated they generally support the FAA's Antidrug
and Alcohol Misuse Prevention Program regulations. Specifically, UTC
said they believe the ``regulations are a valuable tool to the aviation
industry in ensuring workplace and public safety.'' One individual
stated the proposal makes it clear the duties the individual performs
define whether or not the individual will be subject to drug and
alcohol testing. Several commenters, including three union commenters,
supported the proposal because they believed it would improve aviation
safety. One commenter, an individual, stated the regulations will make
flying safer.
The remaining 25 commenters opposed the proposal, with many of them
citing the comments filed by ARSA. The commenters questioned the FAA's
estimates of the cost of the proposal and the benefits to aviation
safety. Additionally, ARSA, the Aircraft Electronics Association, and a
certificated repair station stated the proposal would substantially
expand the scope of the FAA-regulated drug and alcohol testing programs
without any evidence it would enhance safety. The Aircraft Electronics
Association believes the proposal is based more on a moral preference
than on science. ARSA also raised invasion of privacy issues associated
with drug and alcohol testing. The Aircraft Electronics Association
commented the drug and alcohol testing regulations should not apply to
outsourced maintenance.
Commenters also suggested the rule is vague, may add additional
regulatory requirements to existing duties, and may exceed the FAA's
regulatory mandate. Specifically, ARSA cited the FAA's general
regulatory mandate in 49 U.S.C. 44701(d)(1)(A) as a limitation on the
FAA's authority to impose requirements on non-certificated entities
that supply services to directly regulated parties. The Aviation
Suppliers Association was concerned distributors could be
recharacterized as performing safety-sensitive functions and opposed
the proposal, believing it was not supported by a reasonable government
purpose. They requested we publish a statement in the final rule
recognizing that the distribution of an aircraft part is not considered
to be a safety-sensitive function for the purposes of this rule.
One commenter, who filed comments on behalf of the National
Association of Metal Finishers, the American Electroplaters and Surface
Finishers Society, and the Metal Finishing Suppliers' Association,
requested the
[[Page 1668]]
FAA not add regulatory requirements to their members' existing duties.
This commenter noted existing regulatory requirements represent a large
percentage of their operating expenses.
This final rule does not expand the scope of the FAA-regulated drug
and alcohol testing programs. Rather, it clarifies that any individual
who performs a safety-sensitive function by contract must be subject to
the FAA-regulated drug and alcohol testing requirements, regardless of
the tier of the contract under which the individual performs. This
rulemaking is not questioning or expanding the current outsourcing
process. Instead, the final rule eliminates any confusion that might
have existed regarding drug and alcohol testing of subcontractors who
are connected to the regulated employer through the outsourcing
process. In addition, the issues regarding invasion of privacy were
resolved more than 15 years ago when the drug testing regulation
carefully balanced the interests of individual privacy with the Federal
government's duty to ensure aviation safety. The purpose of this
rulemaking is not to reopen the long-settled issue of invasion of
privacy.
Further, we do not agree that this rule results in vague standards.
We have adopted the proposal as a final rule to create a clear standard
for regulated employers to follow for drug and alcohol testing of
subcontractors. Contractor companies often choose to conduct their own
drug and alcohol testing under the FAA regulations because it improves
their marketability. However, the requirement to ensure individuals
performing safety sensitive functions are subject to testing ultimately
rests with the regulated employer.
In addition, we want to emphasize the proposal does not in any way
change the scope of safety-sensitive functions currently covered by the
drug and alcohol testing regulations. Drug and alcohol testing applies
to any individual who performs a safety-sensitive function, including
maintenance or preventive maintenance functions for a regulated
employer. The FAA defines ``maintenance'' and ``preventive
maintenance'' in 14 CFR 1.1 and 14 CFR part 43. The distribution of an
aircraft part is not ``maintenance'' or ``preventive maintenance'' and
is not considered a safety-sensitive activity.
While ARSA cited the FAA's general authority for regulating air
carriers, 49 U.S.C. 44701(d)(1)(A), as a limitation on testing
authority, the Omnibus Transportation Employees Testing Act of 1991
(Omnibus Act), 49 U.S.C. 45101-45106, gave the FAA specific authority
to regulate drug and alcohol testing in aviation. In the Omnibus Act,
Congress acknowledged the FAA's existing regulations requiring the
testing of air carrier employees performing safety-sensitive functions
directly or by contract. Specifically, the Omnibus Act ``does not
prevent the Administrator from continuing in effect, amending, or
further supplementing a regulation prescribed before October 28, 1991,
governing the use of alcohol or a controlled substance * * *.'' 49
U.S.C. 45106 (c). When Congress gave the FAA authority to ``continue''
regulations prescribed before October 28, 1991, they were acknowledging
the drug testing regulation that was already in existence.
The drug and alcohol testing regulations have always required any
individual performing safety-sensitive functions directly or by
contract for a regulated employer to be subject to testing. As this
final rule is not adding more regulatory requirements, the ``reasonable
government purpose'' of aviation safety that has been the foundation of
the drug and alcohol testing regulations since their inception remains
valid.
Do Safety Concerns Support Continuing To Subject Subcontractors to Drug
and Alcohol Testing?
AOPA, ARSA, and other commenters including certificated repair
stations and non-certificated entities, stated the FAA did not show any
accident data attributable to drug and alcohol abuse by maintenance
personnel to support this rulemaking. In addition, AOPA argued ``it is
unreasonable for the FAA to require maintenance contractors performing
non-safety critical maintenance functions to incur the added expense of
developing and implementing a drug and alcohol testing program.'' Two
certificated repair stations and an individual said the redundancies
built into the maintenance system already ensure maintenance errors are
likely to be caught by someone else through the high level of scrutiny
and evaluation in the supervision and inspection process. Also, one
certificated repair station noted the largest number of positive test
results for maintenance employees exist in pre-employment testing,
which indicates individuals who pose a potential threat to aviation
safety are being screened out before they enter the performance of
safety-sensitive functions.
In addition, the Aircraft Electronics Association commented that it
is not correct for the FAA to assume increasing air carrier maintenance
outsourcing decreases aviation safety because ``part 135 on-demand air
carriers have been outsourcing maintenance for years without a decline
in aviation safety.'' This commenter said the proposal would expand the
drug and alcohol testing regulations to include all certificated repair
stations and their subcontractors. The commenter stated the majority of
individuals who would be included in testing programs have not been
shown to be substance abusers.
We believe the safety data showing the number of current positive
test results offer strong support for this rulemaking. We do not
believe we should wait until there is an actual loss of human life
before we take action to ensure the remaining subcontractors who are
not already subjected to testing are brought into compliance with the
regulations. Only one link in the safety chain would have to fail for
an accident to occur.
The Aircraft Electronics Association takes issue with the
discussion in the SNPRM preamble regarding increased maintenance
outsourcing. In the SNPRM preamble, we merely discussed the Department
of Transportation Inspector General's reports regarding maintenance
outsourcing and offered no independent conclusions (69 FR 27982). We
included this information to further explain why it is important for
the FAA to clarify its existing drug and alcohol testing regulations
regarding outsourced maintenance.
This final rule does not expand the drug and alcohol testing
regulations to include all certificated repair stations and their
subcontractors. As we said earlier, we have not changed the scope of
who is required to conduct testing. We are merely clarifying that a
contractor includes a subcontractor. In addition, many certificated
repair stations already have drug and alcohol testing programs.
According to the FAA's Operations Specifications Subsystem (OPSS), over
3,000 certificated repair stations currently have drug and alcohol
testing programs under the existing regulations. This represents more
than 60 percent of all certificated repair stations in the FAA's OPSS.
In addition, the Aircraft Electronics association stated the
majority of individuals affected by the proposal have not been shown to
be substance abusers. While this may be true, a substantial number of
maintenance workers have had positive test results on FAA-required
tests. As we noted in the SNPRM preamble, in the first 11 years of drug
testing, almost half of the 30,192 positive drug test results were
attributable to maintenance workers.
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Also, in the first 6 years of alcohol testing, almost half of the 876
alcohol violations were attributable to maintenance workers. (69 FR
27984) Thus, there is data showing substance abuse in the maintenance
population causing sufficient safety concern to justify this final
rule.
As one commenter noted, the largest number of positive test results
for maintenance employees was in the pre-employment testing context.
This data demonstrates the existing regulations were successful in
screening out many maintenance personnel who use illegal drugs. The
individuals who were prevented from entering the aviation maintenance
field were pre-employment tested by many types of entities including
regulated employers, contractors, and subcontractors. However, as
evidenced by the continuing number of positive random drug test results
each year, pre-employment testing is not a complete barrier to
individuals who use illegal drugs, and random testing is a necessary
form of detection and deterrence. Thus, the large number of positive
test results for maintenance personnel further demonstrates why it is
important for regulated employers to ensure all subcontractors are
subject to testing.
Safety-sensitive functions include all maintenance or preventive
maintenance performed for a regulated employer. The drug and alcohol
testing regulations do not differentiate between safety critical and
non-safety critical forms of maintenance. This final rule does not
expand the types of maintenance functions that are considered to be
``safety-sensitive.'' While there might be redundancies built into the
maintenance system, the supervisory and other quality assurance
processes involved in aviation maintenance do not constitute a
substitute for the protections afforded by drug and alcohol testing.
Therefore, we will continue to require subcontractors be subject to
drug and alcohol testing.
RAA commented the rate of positive test results for maintenance
personnel was not significantly higher than the rate of positive test
results for all safety-sensitive employees. To illustrate its point,
RAA used the rates for calendar year 1999 when ``the rate for
maintenance personnel who test positive for alcohol was 0.02% compared
to a 0.18% rate for all employees who tested positive. The rate for
maintenance personnel who test positive for drugs was 1.5% compared to
a 1.2% rate for all employees who tested positive.'' The Aircraft
Electronics Association also commented about the positive test result
data, saying the data failed to distinguish between the positive test
results of large businesses versus small businesses.
RAA's analysis, while flawed,\1\ simply argues that maintenance
personnel should be subjected to the same requirements as other
personnel performing safety-sensitive functions. The purpose of today's
rule is not to apply more stringent requirements on maintenance
personnel, but rather to clarify which maintenance personnel are
subject to testing, i.e., all personnel performing a safety sensitive
function regardless of who their direct employer is.
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\1\ We disagree with RAA's analysis of the testing data. When
RAA analyzed the calendar year 1999 data, they compared the rate for
maintenance with the rate for all personnel (including maintenance).
For a true comparison of the data, one should compare the positive
rate for maintenance against the positive rate for all personnel,
excluding maintenance. For a full discussion of the data, see the
Regulatory Evaluation for this final rule.
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The Aircraft Electronic Association is correct in noting the
positive test result rates have been declining. We believe this annual
decline shows the effectiveness of the FAA drug and alcohol testing
regulations in deterring illegal drug use and alcohol misuse. Because
the data prove the effectiveness of our regulations, we do not see the
declining positive rate as grounds for eliminating any safety-sensitive
personnel who are subject to testing, including maintenance
subcontractors.
Should Airworthiness Responsibility Be the Determining Factor for Drug
and Alcohol Testing?
ARSA stated the FAA regulations do not currently regulate non-
certificated maintenance subcontractors or require them to take
airworthiness responsibility for the work they perform, so the non-
certificated maintenance subcontractors should not be subject to drug
and alcohol testing. Several commenters, including certificated repair
stations and non-certificated entities, expressed similar concerns. In
addition, AOPA referred to ``non-aviation contractors that perform non-
safety maintenance functions for certificated repair stations,'' saying
they should not be required to comply with the FAA drug and alcohol
testing regulations.
Several commenters, including ARSA, UTC, RAA, and several
certificated repair stations, believe the current regulatory system for
maintenance provides sufficient oversight to ensure certificated repair
stations adequately monitor the work performed by non-certificated
maintenance facilities. ARSA noted a certificated repair station has
the responsibility to sign off on the airworthiness of any repair
performed by its non-certificated contractors. ARSA said the proposal
would require a certificated repair station to oversee its non-
certificated contractors' participation in drug and alcohol testing
programs, and this would be beyond the scope of a repair station's
competencies. ARSA added that a repair station would need to make
investments in procedures and personnel in order to fulfill this new
regulatory burden.
ARSA and UTC suggested that because non-certificated maintenance
entities ensure quality control when they perform repairs, each
subcontractor in the chain of maintenance is responsible for its work
and that of its noncertificated subcontractors. Thus, each
subcontractor in the chain of maintenance relies on the certificated
work that is performed. In addition, ARSA noted certificated mechanics
who sign off on airworthiness are subject to drug and alcohol testing.
ARSA believes these safeguards protect against even the negligent
maintenance that results from drug or alcohol abuse. ARSA asserted that
an article repaired under the influence of drugs is no less conspicuous
in its inability to conform to airworthiness standards than an article
improperly repaired due to a failure to follow prescribed procedures.
For these reasons, ARSA and UTC supported testing only for those with
airworthiness responsibility.
ARSA and the Aircraft Electronics Association suggested that
because the FAA regulations do not allow non-certificated maintenance
subcontractors to take airworthiness responsibility for the work they
perform, they cannot perform safety-sensitive work. Also, the Aviation
Suppliers Association commented the FAA regulations do not regulate
non-certificated maintenance subcontractors or require them to take
airworthiness responsibility for their work. RAA said the current FAA
guidance rightfully limits the group of subcontractors only to those
technicians who actually work on the airplane or have airworthiness
responsibility for the component before it is installed on the
airplane. RAA did not believe all maintenance and preventive
maintenance should be considered safety-sensitive, rather the
airworthiness of a product or actual work on the airplane itself should
be the defining line in describing a safety sensitive position.
There is no ``non-safety maintenance'' recognized in our
regulations. Within certificated repair stations, there are non-
certificated individuals such as mechanic's helpers, who have been
[[Page 1670]]
subject to testing for more than 15 years. Thus, not only are non-
certificated individuals allowed to perform safety-sensitive
maintenance but the regulations contemplate the performance of
maintenance by non-certificated individuals and entities.
The FAA drug and alcohol testing regulations have never articulated
a difference between safety-sensitive functions performed by a
certificated versus a non-certificated maintenance facility. Our
regulations identify all maintenance and preventive maintenance duties
as safety-sensitive functions. Anyone performing maintenance or
preventive maintenance duties for a regulated employer must be subject
to testing, regardless of who signs off on the airworthiness of the
maintenance.
As we acknowledged in the NPRM and SNPRM preambles, some of our
early guidance only required subcontractors who took airworthiness
responsibility to be subject to drug and alcohol testing. By the mid
1990s, the guidance we developed eliminated the airworthiness
responsibility component and followed the rule language explicitly. The
point of this rulemaking is to clarify that any individual who performs
safety-sensitive functions for a regulated employer must be subject to
drug and alcohol testing.
The airworthiness signoff process is not designed to address the
safety risk arising from safety-sensitive functions performed by
individuals who use illegal drugs or misuse alcohol. ARSA spoke of
quality control procedures and review by certificated mechanics as the
safeguards to ensure ``negligent maintenance'' will be discovered and
corrected. However, the maintenance quality control procedures do not
remove individuals who use illegal drugs or misuse alcohol. The FAA
drug and alcohol regulations are designed to address exactly this
safety risk by deterring drug and alcohol use, and through removing
from safety-sensitive functions, individuals who engage in such
prohibited practices.
Should the Level of Contractual Relationship Limit Who Is Subject to
Drug and Alcohol Testing?
ATA stated it ``does not take issue with the premise that
individuals actually performing safety sensitive functions for airlines
should be subjected to the highest standards for performance, including
appropriate drug and alcohol testing.'' ATA noted ``we agree with the
statement in the SNPRM that `[t]he level of contractual relationship
with an employer should not be read as a limitation on the requirement
that all safety-sensitive work be performed by drug- and alcohol-free
employees.' '' Furthermore, ATA commented ``it is the nature of the
function being performed by an individual, and not the employment
relationship of that individual to the airline, that is relevant.''
The FAA agrees with ATA. As we stated in the preamble to the SNPRM,
the level of contractual relationship should not limit the requirement
for all safety-sensitive work to be performed by drug-free and alcohol-
free employees. If individuals are performing safety-sensitive
functions for a regulated employer, the individuals must be subject to
testing, regardless of the tier of contract under which they are
performing.
It would be inconsistent with aviation safety for individuals
performing maintenance work within the certificated repair station to
be subject to drug and alcohol testing, while individuals performing
the same maintenance work under a subcontract would not be subject to
drug and alcohol testing. In addition, if drug and alcohol testing
could be avoided by simply sending the maintenance work to a
subcontractor, a company could form separate subsidiaries within its
organization in order to create an internal subcontracting system that
avoids drug and alcohol testing.
Should Subcontractors Be Distinguished From Contractors Based on
Differing Contractual Relationships?
ARSA said the language to include subcontractors at any tier is a
change in the reach of the regulation, rather than a clarification. In
making this assertion, ARSA asserted that a contract is binding only
between the parties to the contract, based on the doctrine of privity.
In ARSA's opinion, privity does not extend to subcontractors. Thus,
ARSA concluded the law does not consider the subcontractor bound by
contract to an entity with which it has no direct relationship, in this
case the air carrier. UTC echoed this statement, emphasizing the legal
concept of privity of contract as being between signatory parties,
giving each responsibilities and rights in pursuit of a common goal.
Accordingly, UTC asserted that a contractual relationship and all that
it incorporates cannot extend to any unnamed party.
In addition, ARSA discussed the Drug-Free Workplace Act (DFWA)
requirements that apply to Department of Defense (DoD) contracts.\2\
ARSA stated the DoD applies the DFWA to its contractors through
specific contract clauses required by regulation. ARSA said DoD does
not require the DFWA requirements to extend beyond direct contractors
to subcontractors. Based on DoD's practice, ARSA argued it is
inconsistent with safety and economics to extend drug and alcohol
testing to any tier of the maintenance process, including
subcontractors that are not part of a certificated repair station or
the aviation industry. DoD's decision to exclude subcontractors from
its contracts is not relevant to this rulemaking, and we offer no
opinion to the contract practices of other Federal agencies. We note
that the DFWA does not apply to the FAA and we are not compelled to
follow DoD's lead in this regard.
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\2\ DFWA requires Federal contractors to maintain programs for
achieving a drug-free workplace, but does not require drug and
alcohol testing.
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The issue of subcontractor privity is irrelevant to this
regulation, because the FAA will take enforcement action against those
employers directly covered by the drug and alcohol regulations by
virtue of their part 121 or part 135 operations, as well as those
contractors who have voluntarily submitted to our jurisdiction by
obtaining their own drug and alcohol programs. This final rule
clarifies that these two groups of regulated entities must ensure all
individuals performing a safety sensitive function are subject to
testing. If the regulated employer or contractor is concerned that
there is insufficient privity between itself and a subcontractor to
assure that employees of a subcontractor are subject to testing, it can
require a testing provision be placed in each contract between its
contractors and their subcontractors. Such provisions are common in
other contexts and are likely already used by some carriers in this
context.
The FAA guidance has always indicated subcontractors were covered
by the drug and alcohol testing regulations. The conflict in the
guidance was whether all subcontractors or only those subcontractors
with airworthiness responsibility were required to be subject to drug
and alcohol testing. The guidance requiring all contractors to be
subject to testing is consistent with the fact all individuals
performing safety-sensitive functions directly or by contract are
required to be subject to testing.
[[Page 1671]]
How Will This Rule Affect Contractual Relationships, Including Auditing
Contractor's and Subcontractor's Drug and Alcohol Testing Programs?
ATA and ChevronTexaco requested guidance on how air carriers can
ensure their contractors and subcontractors are complying with the drug
and alcohol testing regulations. In addition, the commenters requested
guidance on satisfying the audit requirement for both domestic and
overseas contractors and subcontractors.\3\ Specifically, ATA asked if
air carriers should continue to retain a copy of the contractor's
OpSpec or registration. ATA also stated air carriers currently do not
independently verify the status of subcontractors' compliance with drug
and alcohol testing requirements. ChevronTexaco noted that it currently
requests information from its contractors to verify ``they have drug
and alcohol prevention plans in place and they audit their contractors
for the same.'' ChevronTexaco stated it uses a questionnaire for many
of its contractors but not for all subcontractors. Similarly, a
certificated repair station said air carriers have used questionnaires
as an alternative to performing on-site audits.
---------------------------------------------------------------------------
\3\ FAA drug and alcohol testing regulations prohibit testing
outside the United States and its territories. Today's rule does not
add an extra territorial testing requirement.
---------------------------------------------------------------------------
ARSA suggested the proposed rule would require certificated repair
stations and the air carriers with whom they contract to look beyond
the airworthiness of a particular article to the person who performed
maintenance, no matter how insignificant the job or how far removed
from the aircraft. ARSA also expressed concern that direct contractors
would need to ensure their subcontractors actually implemented drug and
alcohol testing programs. ARSA stated the proposal would require direct
contractors ``to take on the role of human resource auditor'' for all
non-certificated subcontractors. Thus, ARSA asserted the proposal would
alter contractual relationships and expectations for non-certificated
entities performing contracted maintenance functions on the industry's
behalf.
The FAA regulations require a regulated employer to ensure any
individuals performing safety-sensitive functions for it by contract
are included in the FAA-regulated drug and alcohol testing programs of
either the regulated employer or the contractor. While it is advisable
for the regulated employer to retain a copy of the contractor's OpSpec
or registration, merely retaining this copy does not ensure all
individuals performing safety-sensitive functions by contract for the
regulated employer are subject to drug and alcohol testing under the
regulations. While OpSpec or registration documentation may indicate
that a contractor has agreed to implement a drug and alcohol program,
it does not provide a regulated employer with specific information to
determine if the contractor has actually implemented its programs.
Accordingly, more oversight is needed. A regulated employer could ask
its contractor specific questions and request documentation to ensure
the contractor has fully implemented its testing programs and to ensure
the individuals who will perform safety-sensitive functions for the
regulated employer are subject to testing. It is also a good business
practice for an employer to verify and document that specific
individuals performing safety-sensitive functions by contract are
currently subject to testing under the contractor's drug and alcohol
testing program.
Direct contractors must both determine the airworthiness of an
article and ensure subcontractors have actually implemented drug and
alcohol testing programs because both have safety implications.
Regulated employers and contractors at any tier should not disregard
the requirements of either safety responsibility. Accordingly, it is
not necessary for companies to become auditors because the FAA's
regulations do not specifically require audits to ensure the testing
requirements are met.
Finally, we note the commenters have not provided any data or
information to support an assumption the proposal would alter
expectations and contractual relationships with non-certificated
entities. As stated previously, the FAA believes the majority of
regulated employers are already ensuring individuals who are performing
safety-sensitive functions for them under a contract at any tier are
subject to drug and alcohol testing.
Who Is Responsible for Subcontractor Compliance?
Several commenters questioned who would be responsible for ensuring
subcontractor compliance with drug and alcohol testing. Specifically,
they asked if certificated repair stations or regulated employers (air
carriers) would be held responsible for any and all subcontractors at
any tier. Prime Turbines commented to both the NPRM and the SNPRM,
expressing concern that it will be held liable for all tiers of
contract work. Another commenter, ChevronTexaco, stated its current
practice is to audit its contractors' drug and alcohol prevention
programs. ChevronTexaco also specifies in its contractual agreements
that contractors must audit subcontractors' programs because it is
common for them to have several tiers of subcontractors. ChevronTexaco
was concerned the proposal ``would cascade employer responsibility for
auditing drug and alcohol programs to ALL these subcontractors with
which we have no direct business or contractual relationship.''
Similarly, UTC questioned whether a third tier subcontractor's non-
compliance has any affect on the fourth tier subcontractor or on the
second tier subcontractor.
We applaud ChevronTexaco for creating a contract provision to
require its contractors to audit subcontractors and ensure individuals
performing safety-sensitive functions by contract are subject to drug
and alcohol testing. While the contract provision ChevronTexaco
describes is an excellent business practice, the FAA's regulations have
not required ``auditing,'' and this final rule does not require it. As
we discussed in the preamble to the SNPRM, although auditing is a
business decision, we believe it is a good way to determine if an
entity has FAA drug and alcohol testing programs and is testing its
employees (69 FR 27982).
As we said in the preamble to the SNPRM, the safety of the air
carrier's maintenance and operations ultimately rests with the air
carrier (69 FR 27983). Similarly, in 14 CFR 121.363(a) and 135.413(a),
we recognize that air carriers are primarily responsible for the
airworthiness of its aircraft. A regulated employer must ensure any
individual performing safety-sensitive functions for it is subject to
the required drug and alcohol testing. Thus, the regulated employer has
the ultimate responsibility to ensure individuals performing safety-
sensitive functions for it by contract are subject to FAA-regulated
testing.
A contractor company can test individuals performing safety-
sensitive functions for a regulated employer under the contractor
company's own FAA-regulated testing programs. Once a contractor company
obtains its FAA-regulated testing programs, the FAA will hold the
contractor company responsible for its compliance with the regulations.
There may be circumstances where the regulated employer may also share
responsibility for a contractor company's non-compliance.
If a contractor company has FAA-regulated testing programs, it must
ensure any individual performing a safety-sensitive function by
contract (including by subcontract at any tier) below it is subject to
testing. The FAA
[[Page 1672]]
recognizes there may be multiple tiers of subcontractors in the
aviation industry. Any lower tier contractor company with FAA-regulated
testing programs will be held responsible for its own compliance with
the FAA drug and alcohol testing regulations. Also, there may be
circumstances where the regulated employer and higher tier contractor
companies share responsibility for the lower tier contractor company's
noncompliance.
The FAA provides information to assist regulated employers and
their contractors to implement drug and alcohol testing programs.
Entities can obtain this information by:
--Contacting the Drug Abatement Division at the address in the FOR
FURTHER INFORMATION CONTACT paragraph listed earlier; or
--Referencing the Drug Abatement Division's Web site: http://www.faa.gov/about/office_org/headquarters_offices/avs/offices/aam/drug_alcohol/
.
What Are the Consequences for Subcontractor Noncompliance?
Several commenters, including UTC and ARSA, expressed concern about
oversight responsibilities for subcontractors and contended that air
carriers would be required to oversee drug and alcohol programs for
every subcontractor at any lower tier in the maintenance process. UTC
noted the FAA had not proposed to require audits or other specific
means of ensuring contractors and subcontractors were properly
conducting drug and alcohol testing. UTC believed the lack of an audit
requirement would create a wide diversity of compliance standards and a
potential variability in enforcement. In addition, UTC was concerned
certificated repair stations would audit other certificated repair
stations that are subcontractors. This was problematic for UTC because
it views certificate oversight as an FAA responsibility.
Since the inception of the FAA drug and alcohol testing
regulations, we have had a requirement that any individual who performs
a safety-sensitive function directly or by contract must be subject to
drug and alcohol testing. The FAA deliberately chose not to specify how
regulated employers would ensure subcontractor compliance with the drug
and alcohol testing regulations. Similarly, the FAA deliberately chose
not to specify how contractors that opt to obtain drug and alcohol
testing programs would comply with the regulations.\4\ The means for
achieving the requirement are somewhat flexible--the regulated employer
may conduct the testing or the contractor company may conduct the
testing, but the regulated employer must ensure individuals performing
safety-sensitive functions for it are subject to testing.
---------------------------------------------------------------------------
\4\ There is no difference between the FAA's method for
inspecting certificated versus non-certificated maintenance
contractors that have opted to obtain drug and alcohol testing
programs. Also, we do not vary our inspection method based on the
difficulty or criticality of the maintenance performed. While our
inspection methodology does not vary by type of company, the
sanctions the FAA imposes vary depending on the specific
circumstances surrounding the actual violation. We note the FAA has
always handled interpretations and enforcement matters on a case-by-
case basis. We are not aware that this has caused difficulties in
maintenance productivity in the past.
---------------------------------------------------------------------------
Regulated employers and entities opting to obtain testing programs
must include individuals performing safety-sensitive functions by
contract in their own programs. Alternatively, they can allow an
individual to perform a safety-sensitive function by contract for them
if the individual is subject to testing under the contractor company's
drug and alcohol testing programs. One way to determine if the
individual is subject to testing in accordance with the FAA regulations
is to inquire further about the specifics of the contractor company's
programs and request supporting documentation from the contractor
company. Merely obtaining a program registration or an OpSpec does not
indicate a company has implemented compliant drug and alcohol testing
programs.
Because each regulated employer currently has a duty to ensure any
individual performing a safety-sensitive function by contract for it is
subject to testing, several regulated employers might conduct inquiries
to ensure the same individual is subject to testing. For example, a
contractor company might have personnel with skills that put them in
high demand with many regulated employers. Before each of these
regulated employers can allow the contractor company's personnel to
perform safety-sensitive functions by contract, each regulated employer
must ensure the individuals performing safety-sensitive functions by
contract for it are subject to drug and alcohol testing in accordance
with the FAA regulations. We do not view this as a duplication of
effort or as an administrative burden because each regulated employer
has a separate duty to ensure drug and alcohol testing occurs.
Furthermore, we acknowledge there will be times when a higher tier
contractor company and its lower tier contractors are certificated
repair stations. To ensure specific individuals performing safety-
sensitive functions by contract are subject to testing, the higher tier
contractor company may choose to audit or otherwise inquire into its
lower tier contractors' drug and alcohol testing programs. It is
possible one certificated repair station might audit the drug and
alcohol testing programs of another certificated repair station. We do
not see this as a difficulty or a conflict because certificated repair
stations can audit their contractors under the current regulations, and
the FAA already has and will continue to have oversight
responsibilities for certificated repair station certificates.
Should Certificated Repair Stations Disclose Their Subcontractors?
One certificated repair station commented that most air carriers
allow repair stations to subcontract, but the identity of these
subcontractors normally is not disclosed. Therefore, the FAA should not
be allowed to force a repair station to disclose all of its contractors
both by name and by contacts. In addition, RAA asserted its members are
not able to continuously ensure that subcontractors are being tested.
RAA stated that many individuals working for a subcontractor may be an
employee only for a short period of time or the contractor may want to
quickly replace subcontractors. RAA also said airlines will have
difficulty identifying who to include in drug and alcohol testing
programs.
We do not agree certificated repair stations should not provide
information about subcontractors to regulated employers. The FAA
regulations have always required regulated employers to ensure they
tested or their contractors tested all contractor and subcontractor
employees performing safety-sensitive functions for the regulated
employer. This is not a new requirement. At issue in this rulemaking is
the confusion resulting from conflicting guidance about which
contractors were required to be subject to drug and alcohol testing.
The regulated employer must continue to receive information about the
drug and alcohol testing programs of contractor companies whose
employees are performing safety-sensitive work for the regulated
employer under a contract. Regulated employers need this information to
continue to ensure individuals performing safety-sensitive functions
for them are subject to testing in accordance with the FAA regulations.
We agree regulated employers will have problems identifying who
should be subject to drug and alcohol testing if certificated repair
stations or other contractors do not provide the regulated employers
with current information about which contractors and
[[Page 1673]]
subcontractors are performing safety-sensitive functions. Providing
this information is already necessary under the FAA's drug and alcohol
testing requirements and is not added by this rulemaking. It is
imperative to safety that certificated repair stations and other
contractors share current identifying information about subcontractors
with the regulated employers to ensure individuals performing safety-
sensitive functions for the regulated employers are subject to testing
in accordance with the FAA regulations.
Should Subcontractors That Are Not Primarily Aviation-Related
Businesses Be Subject to Testing?
Some certificated repair stations and businesses that are not
primarily aviation-related commented that the rule, if amended, could
place economic pressure on subcontractors that provide service to more
than the aviation industry. In addition, several commenters, including
ARSA, opposed requiring non-certificated subcontractors be subject to
testing. Furthermore, some commenters expressed concern that if non-
certificated subcontractors are subject to testing, those entities
might stop providing services to the aviation industry.
The FAA disagrees with these commenters' distinction between
certificated and non-certificated subcontractors when it comes to the
issue of safety-sensitive work. When subcontractors choose to perform
safety-sensitive functions for regulated employers, they are choosing
to comply with the FAA drug and alcohol testing regulations. The impact
these subcontractors have on aviation safety is not related to whether
they hold a repair station certificate. Instead, they have an impact
because they actually perform safety-sensitive functions.
The commenters did not provide data to support the premise that
non-certificated subcontractors would cease providing service to the
aviation industry. Furthermore, as discussed in detail in the
accompanying regulatory evaluation, the data provided by commenters
showed the majority of such contractors would continue doing business
with the aviation industry after the final rule becomes effective.
What Is Safety-Sensitive Maintenance or Preventive Maintenance?
ATA believes ``individuals actually performing safety-sensitive
functions for airlines should be subjected to the highest standards for
performance, including appropriate drug and alcohol testing.'' However,
ATA questioned whether many subcontractors doing work for airlines are
actually performing safety-sensitive functions.
While ATA recognized the FAA regulations define the terms
``maintenance'' and ``preventive maintenance'' (see 14 CFR 1.1 and 14
CFR part 43), they requested additional guidance. Specifically, ATA
requested the FAA provide guidance clearly describing ``maintenance and
preventive maintenance for flight-critical systems, and those
components whose failure could have a direct adverse effect on the
continued airworthiness of the aircraft.'' In addition, ATA requested
the guidance distinguish safety-sensitive maintenance from other types
of ``maintenance'' that do not have the potential to directly impact
airworthiness.
In a related comment, one commenter holding multiple air carrier
certificates and a repair station certificate said the proposed rule
would cause difficulty whenever an entertainment system component needs
repair. This commenter provided cost data on how much revenue air
carriers would lose if they had to modify the aircraft to accept a new
unit every time an entertainment unit system broke and could not be
repaired by a drug and alcohol tested technician. Also, a non-
certificated subcontractor company that does interior plating
decoration on non-essential components said the proposed rule would
have a large impact on the way it does business. This commenter asked
the FAA to exclude it from drug and alcohol testing.
The ATA correctly notes the FAA defines maintenance and preventive
maintenance in 14 CFR 1.1 and 14 CFR part 43. In the drug and alcohol
testing regulations, any maintenance or preventive maintenance (as
defined in 14 CFR 1.1 or part 43) an individual performs for a
regulated employer is a safety-sensitive function, and therefore
subject to drug and alcohol testing.
The FAA Drug Abatement Division defers to the Flight Standards
Service for decisions on whether a task is maintenance or preventive
maintenance. If we were to attempt to further define maintenance and
preventive maintenance functions through a guidance document, it would
likely be quickly outdated and would not be helpful. Since job titles
and functions vary from company to company, the title of a task
performed at one company may not be the title of a similar task at
another company. Determining whether a particular task fits under the
definitions of ``maintenance'' or ``preventive maintenance'' is the
responsibility of the regulated employer, working in conjunction with
the regulated employer's assigned FAA principal inspector. Once the
principal inspector determines a task is maintenance or preventive
maintenance, the individual performing the task for the regulated
employer must be subject to drug and alcohol testing.
With respect to the specific assertion that repairing an
entertainment system could subject an entity to drug testing, we note
that repairing entertainment system components usually is not
considered ``maintenance.'' Consequently, drug and alcohol testing
usually is not required for individuals who repair these components. On
the other hand, removing the entertainment system component from the
aircraft and reinstalling the repaired component on the aircraft is
maintenance and subject to testing. Similarly, interior plating
decoration to nonessential components is ``preventive maintenance''
under 14 CFR part 43, appendix A. Consequently, drug and alcohol
testing is required for individuals who perform this type of plating.
Does the Regulatory Flexibility Act Apply to This Rulemaking?
ARSA, several certificated repair stations, and some non-
certificated entities stated the FAA failed to conduct a required
Regulatory Flexibility Act (RFA) analysis. In ARSA's opinion, the FAA
understated ``the impact of this regulation on the aviation industry
and on those industries providing maintenance support services.'' ARSA
believes an Initial Regulatory Flexibility Act analysis (IRFA) would
help the FAA and the public evaluate the costs and benefits of the
proposed rule. Also, ARSA argued the FAA failed to meet the RFA
requirement to consider significant alternatives to minimize the
SNPRM's economic impact on small entities.
The FAA disagrees with ARSA and other commenters who raised RFA
issues. In 14 CFR part 121, appendix I, section II, and appendix J,
section I.D, the FAA defines which employers are directly regulated by
the drug and alcohol testing regulations. Specifically, the directly
regulated employers are: Air carriers operating under 14 CFR parts 121
and 135; Sec. 135.1(c) operators; and air traffic control facilities
not operated by the FAA or by or under contract to the U.S. military.
These directly regulated employers must conduct drug and alcohol
testing under the FAA regulations. For drug and alcohol testing
purposes, certificated repair stations are contractors, and contractors
are not regulated employers. Contractors can
[[Page 1674]]
choose to obtain drug and alcohol testing programs. Once a contractor
chooses to obtain such programs, it must follow the FAA drug and
alcohol testing regulations.
Twenty years ago, the U.S. Court of Appeals for the DC Circuit held
the RFA only applies to small entities directly regulated by a proposed
rule. ``Congress did not intend to require that every agency consider
every indirect effect that any regulation might have on small
businesses in any stratus of the national economy.'' Mid-Tex Electric
Cooperative v. FERC, 773 F.2d 327, 343 (DC Cir. 1985). The DC Circuit
held the Small Business Regulatory Enforcement Fairness Act (SBREFA) of
1996 did not change the fact the RFA only applies to directly regulated
entities. American Trucking Associations v. EPA, 175 F.3d 1027, 1044
(DC Cir. 1999). The DC Circuit ``has consistently rejected the
contention that the RFA applies to small businesses indirectly affected
by the regulation of other entities.'' Cement Kiln Recycling Coalition
v. EPA, 225 F.3d 855, 869 (DC Cir. 2001) (citing Mid-Tex Electric
Cooperative v. FERC, and its progeny). In Cement Kiln, the
Environmental Protection Agency (EPA) had done a regulatory evaluation
to cost out the impact on small businesses indirectly affected by the
proposed regulation. While the EPA's cost evaluation was based on small
businesses indirectly impacted, it was ``in the spirit of the RFA
because some portion of the burden of compliance might pass through to
[these small businesses].'' Cement Kiln, 255 F.3d at 868. Similarly in
the SNPRM, the FAA followed the spirit of the RFA by evaluating the
costs of the proposal on indirectly affected small businesses
(contractors). However, the DC Circuit said conducting an economic cost
evaluation for small businesses indirectly affected does not trigger
the requirements of a full RFA analysis. Cement Kiln, 255 F.3d at 868-
869.
The DC Circuit specifically explained ``* * * application of the
RFA does turn on whether particular entities are the `targets' of a
given rule. The statute requires that the agency conduct the relevant
analysis or certify `no impact' for those small businesses that are
`subject to' the regulation, that is, those to which the regulation
`will apply.' '' Cement Kiln, 255 F.3d at 869 (citations omitted). In
addition, the DC Circuit went on to say ``The rule will doubtless have
economic impacts in many sectors of the economy. But to require an
agency to assess the impact on all of the nation's small businesses
possibly affected by a rule would be to convert every rulemaking
process into a massive exercise in economic modeling, an approach we
have already rejected.'' Cement Kiln, 255 F.3d at 869.
Accordingly, we have determined we are not required to conduct an
RFA analysis, including considering significant alternatives, because
contractors (including subcontractors at any tier) are not the
``targets'' of the proposed regulation, and are instead indirectly
regulated entities. For the purpose of the RFA, we have evaluated the
impact on the regulated employers to reach our decision to certify that
this action will not have a significant economic impact on a
substantial number of small entities.
While an IRFA can be a tool for evaluating costs and benefits of a
proposal, the main tool is the regulatory evaluation. Accordingly, we
used the regulatory evaluation to determine the impact on the number of
indirectly regulated entities that might be affected by the proposal.
This provided a better idea of what the costs to the regulated
employers would ultimately be. Evaluating the costs the indirectly
regulated entities might bear complied with the spirit of the RFA and
provided us with a realistic total cost that could be distributed among
regulated employers. We are now explicitly distributing the total cost
among regulated employers.
Should FAA Provide More Time for Pre-Employment Testing of
Subcontractors?
DATIA (an association of service agents in the drug and alcohol
testing industry) and AMFA Local 33 supported the proposed pre-
employment provision. The proposal contemplated providing an employer
with a 90-day window after the effective date of the rule in which to
conduct pre-employment testing of existing subcontractors who have not
previously been tested. Both commenters stated the proposed 90-day
window would assist air carriers, contractors, and subcontractors to
implement any necessary pre-employment testing.
The FAA notes that today's rule merely clarifies an existing
requirement that we have estimated at least 60 percent of the industry
already follows. Additionally, the regulated parties are not required
to establish new testing programs. Accordingly, a 90-day window for
pre-employment testing subcontractors appears excessive. In order to
provide some additional time to complete testing we have decided to
make today's rule effective 90 days after publication rather than our
usual 30.
Miscellaneous Comments
One certificated repair station questioned why the FAA requires
drug and alcohol testing for a non-certificated entity performing
maintenance on a business jet operated under part 135 but not if the
same business jet is operated under part 91. This commenter also said
it can contract with non-certificated entities ``to perform maintenance
on a part 91 aircraft and the FAA has no issue with airworthiness or
safety.''
The commenter is not correct in saying the FAA has ``no issue with
airworthiness or safety'' for part 91 aircraft. We are very much
concerned that maintenance on part 91 aircraft is performed in
accordance with airworthiness requirements. Aviation safety is not
limited to maintenance on air carriers.
However, commercial operators carrying passengers for compensation
or hire are required to meet a higher level of safety than general
aviation, which operates under part 91. Included in the higher level of
safety is the requirement for regulated employers to conduct drug and
alcohol testing.
Issues Outside the Scope of This Rulemaking
The FAA received a number of comments concerning: The repeal of the
moonlighting exception to drug and alcohol testing; the Antidrug and
Alcohol Misuse Prevention Program OpSpec requirement; revising the
definitions of certain safety-sensitive functions to tie them to safety
risk; drug and alcohol testing outside the United States and its
Territories; drug and alcohol testing for manufacturers; and drug and
alcohol testing for general aviation. These issues are outside the
scope of the SNPRM. Therefore, we have not addressed them in this final
rule.
Paperwork Reduction Act
This final rule contains information collection activities subject
to the Paperwork Reduction Act (44 U.S.C. 3507(d)). No agency may
conduct or sponsor and no person is required to respond to a collection
of information unless it displays a currently valid OMB control number.
In accordance with the Paperwork Reduction Act, documentation
describing the information collection activities was submitted to the
Office of Management and Budget (OMB) for review and approval. The FAA
will publish the OMB control number for this information collection in
the Federal Register after the Office of Management and Budget approves
it.
[[Page 1675]]
This rule imposes additional reporting and recordkeeping
requirements on regulated employers (part 121 and 135 certificate
holders, and operators as defined in Sec. 135.1(c)). This rulemaking
indirectly affects contractors and subcontractors, including non-
certificated maintenance contractors, performing maintenance and
preventive maintenance for these regulated employers at any tier if
they elect to obtain antidrug and alcohol misuse prevention programs.
International Compatibility
In keeping with U.S. obligations under the Convention on
International Civil Aviation, it is the FAA policy to comply with
International Civil Aviation Organization (ICAO) Standards and
Recommended Practices to the maximum extent practicable. The FAA has
reviewed the corresponding ICAO Standards and Recommended Practices and
has identified no differences with these regulations.
Executive Order 12866 and DOT Regulatory Policies and Procedures
Executive Order 12866 directs that each Federal agency shall
propose or adopt a regulation only upon a reasoned determination that
the benefits of the intended regulation justify its costs. The FAA has
determined this rule has benefits that justify its costs, is not a
``significant regulatory action'' as defined in section 3(f) of
Executive Order 12866, and is not ``significant'' as defined in DOT's
Regulatory Policies and Procedures.
This rulemaking directly affects regulated employers (part 121 and
135 certificate holders, and operators as defined in Sec. 135.1(c)).
This rulemaking indirectly affects contractors and subcontractors,
including non-certificated maintenance contractors, performing
maintenance and preventive maintenance for these regulated employers at
any tier. Approximately 300 non-certificated maintenance contractors
will have to develop anti-drug and alcohol misuse prevention programs,
affecting about 5,000 employees in 2006, rising to approximately 5,700
employees by 2015.
The FAA is not changing the current regulations, but is simply
clarifying them. As such, there should be no additional costs. However,
the FAA recognizes that, due to conflicting guidance, some companies
may have to modify their current anti-drug and alcohol misuse
prevention programs or implement such programs. The FAA does not know
how many additional employees or contractor companies will be subject
to anti-drug and alcohol misuse prevention programs, but has
conservatively estimated that over 10 years, costs sum to $3.08 million
and cost savings sum to $790,300, for net total costs of $2.29 million
($1.76 million, discounted).
The major benefit from this rulemaking will be the prevention of
potential injuries and fatalities and property losses resulting from
accidents attributed to neglect or error on the part of individuals
whose judgment or motor skills may be impaired by the presence of drugs
and/or alcohol. The FAA estimates 10-year benefits sum to $15.07
million ($10.59 million, discounted).
A full evaluation of the estimated costs and benefits associated
with today's rule is provided in the final regulatory evaluation
located in the docket.
Regulatory Flexibility Assessment
The Regulatory Flexibility Act of 1980 (RFA) establishes ``as a
principle of regulatory issuance that agencies shall endeavor,
consistent with the objective of the rule and of applicable statutes,
to fit regulatory and informational requirements to the scale of the
business, organizations, and governmental jurisdictions subject to
regulation.'' To achieve that principle, the RFA requires agencies to
solicit and consider flexible regulatory proposals and to explain the
rationale for their actions. The RFA covers a wide-range of small
entities, including small businesses, not-for-profit organizations and
small governmental jurisdictions.
Agencies must perform a review to determine whether a proposed or
final rule will have a significant economic impact on a substantial
number of small entities. If the agency determines that it will, the
agency must prepare a regulatory flexibility analysis as described in
the Act.
However, if an agency determines that a proposed or final rule is
not expected to have a significant economic impact on a substantial
number of small entities, section 605(b) of the 1980 RFA provides that
the head of the agency may so certify and a regulatory flexibility
analysis is not required. The certification must include a statement
providing the factual basis for this determination, and the reasoning
should be clear.
For this rule, the small entity group is considered to be small
part 121 and 135 certificate holders and operators under Sec. 135.1(c)
(North American Industry Classification System [NAICS] 481111). The FAA
examined the annual revenues of all the certificated air carriers under
part 121, 121/135, 135, as well as operators under Sec. 135.1(c).
For the certificated air carriers under part 121, 121/135, and 135,
annual revenue data is not available by 14 CFR part number, so the FAA
used Forms 41 and 298C, available from the Bureau of Transportation
Statistics (BTS), for this data. In these forms, BTS breaks down the
different airplane operators that file Form 41, by revenue. Large
certificated carriers (which includes Majors through Medium Regionals),
which file Form 41, must fly aircraft with 60 seats or more or have a
payload of at least 18,000 lbs.
Carriers reporting on Form 298C are classified as either ``Small
Certificated'' (also known as Small Regionals) or ``Commuter'' air
carriers. While neither of these types of carriers are defined by
annual revenues, some small certificated carriers have more than $100
million in annual revenues.
Carriers that file Form 41 that have annual revenue over $20
million (Majors, Nationals, and Large Regionals) report revenue data
quarterly, while carriers that File 41 that have annual revenue less
than $20 million (Medium Regionals) report revenue data twice a year.
All carriers that file Form 298C, report revenue data quarterly.
Unfortunately, the data is not consistent as it is not available for
some carriers for every reporting period. The FAA examined data from
the last 3 years to identify the most recent consecutive four quarters
or two half-year periods, whichever was applicable, for each carrier to
be used as the relevant operating revenue for that carrier. Using this
air carrier operator information, the FAA separated the carriers into
part 121, part 121/135, and part 135 certificated carriers, and
operators under Sec. 135.1(c). The average annual revenue for these
three categories is $1,686.60, $58.74, and $59.10, respectively, in
millions of dollars.
The FAA used a different method to calculate the annual revenue for
the operators under Sec. 135.1(c), as this information is not
collected by BTS. As shown in an earlier (2002) analysis, the FAA
collected information on both part 135 and part 91 aircraft engaged in
air tours. The FAA determined that the group that was most similar to
the operators under Sec. 135.1(c), in this analysis, was the core part
91 operators with the annual revenue per operator of $62,600.
This rule will cost $2.29 million over 10 years ($1.76 million,
discounted). The annualized cost is about $800 for each of the
approximately 300 contractors to put together an antidrug and alcohol
misuse prevention program and then implement it. These
[[Page 1676]]
contractors will absorb some of these costs, while the rest will be
passed on to both the companies at the other tiers that they are
contracting for or with as well as to the regulated employers. Given
such low annualized costs, the FAA does not believe that most of the
costs will be passed on to companies at other tiers. However, the FAA
assumes that all of the additional NCMS cost is passed along to the
regulated employers in order to estimate the maximum impact of this
regulation on regulated employers.
For this analysis, the FAA considers each part 135 certificate
holder and operator under Sec. 135.1(c) to be a small entity, and some
of the part 121 and 121/135 certificate holders to also be small
entities. The FAA examined the costs of this rule two different ways:
a. The costs are shared equally by all regulated employers; and
b. In order to determine the maximum impact of this rule, the
entire cost is borne by one regulated employer.
a. Given 2,562 air carrier certificate holders and 250 operators
under Sec. 135.1(c), the cost borne by each regulated employer would
equal about $800 ($600, discounted). Using the same capital recovery
rate yields an annualized cost of about $100. The costs to each air
carrier certificate holder would be less than 0.0002% of their annual
revenues, while the costs to each operator under Sec. 135.1(c) would
be less than 0.15% of their annual revenues. Given that the majority of
Sec. 135.1(c) operators usually has one or two aircraft, and operates
in and out of one airport, it is unlikely that they would interact with
multiple subcontractors in the regular course of business operations.
Therefore, it is unlikely that their annualized costs as a percentage
of annual revenues would be much higher than 0.15%.
b. Under this scenario, with the entire cost being borne by one
regulated employer that is not a small entity, the costs sum to $2.29
million over 10 years ($1.76 million, discounted). It is highly
unlikely that one or a small number of regulated employers would bear
the costs of this rule exclusively because the regulated employers vary
in size, number of aircraft, and geographic location. The smaller the
operator, the fewer aircraft that operator would use, hence the smaller
the number of subcontractors that operator would use for safety-
sensitive maintenance. Therefore, this scenario would not be applicable
to many small entities, including many part 135 operators or any
operator under Sec. 135.1(c).
Using the same capital recovery rate yields an annualized cost of
about $251,200. Even if one regulated employer absorbed all the costs,
these costs would be less than 0.5% of annual median revenue. Clearly,
no regulated employer is going to absorb all, or even most, of the
costs to the exclusion of the other regulated employers, so the impact
on their revenues will be much less than 0.5% of annual median revenue.
In addition, it is highly unlikely that all of the additional costs to
the NCMS will be passed along to these regulated employers.
Under both scenarios, the economic impact is minimal. Therefore,
the Administrator certifies that this action will not have a
significant economic impact on a substantial number of small entities.
International Trade Impact Assessment
The Trade Agreements Act of 1979 prohibits Federal agencies from
establishing any standards or engaging in related activities that
create unnecessary obstacles to the foreign commerce of the United
States. Legitimate domestic objectives, such as safety, are not
considered unnecessary obstacles. The statute also requires
consideration of international standards and, where appropriate, that
they be the basis for U.S. standards. The FAA has assessed the
potential effect of this NPRM and has determined that it would have
only a domestic impact and therefore no affect on any trade-sensitive
activity.
Unfunded Mandates Assessment
The Unfunded Mandates Reform Act of 1995 (the Act) is intended,
among other things, to curb the practice of imposing unfunded Federal
mandates on State, local, and tribal governments. Title II of the Act
requires each Federal agency to prepare a written statement assessing
the effects of any Federal mandate in a proposed or final agency rule
that may result in an expenditure of $100 million or more (adjusted
annually for inflation) in any one year by State, local, and tribal
governments, in the aggregate, or by the private sector; such a mandate
is deemed to be a ``significant regulatory action.'' The FAA currently
uses an inflation-adjusted value of $120.7 million in lieu of $100
million.
This final rule does not contain such a mandate. The requirements
of Title II do not apply.
Executive Order 13132, Federalism
The FAA has analyzed this final rule under the principles and
criteria of Executive Order 13132, Federalism. We determined that this
action will not have a substantial direct effect on the States, or the
relationship between the national Government and the States, or on the
distribution of power and responsibilities among the various levels of
government, and therefore does not have federalism implications.
Environmental Analysis
FAA Order 1050.1E identifies FAA actions that are categorically
excluded from preparation of an environmental assessment or
environmental impact statement under the National Environmental Policy
Act in the absence of extraordinary circumstances. The FAA has
determined this rulemaking action qualifies for the categorical
exclusion identified in paragraph 312f and involves no extraordinary
circumstances.
Regulations That Significantly Affect Energy Supply, Distribution, or
Use
The FAA has analyzed this final rule under Executive Order 13211,
Actions Concerning Regulations that Significantly Affect Energy Supply,
Distribution, or Use (May 18, 2001). We have determined it is not a
``significant energy action'' under Executive Order 13211 because it is
not a ``significant regulatory action'' under Executive Order 12866,
and it is not likely to have a significant adverse effect on the
supply, distribution, or use of energy.
List of Subjects in 14 CFR Part 121
Air carriers, Aircraft, Airmen, Alcohol abuse, Alcoholism, Aviation
Safety, Charter flights, Drug abuse, Drug Testing, Safety,
Transportation.
The Amendment
0
In consideration of the foregoing, the Federal Aviation Administration
amends part 121 of Title 14, Code of Federal Regulations as follows:
PART 121--OPERATING REQUIREMENTS: DOMESTIC, FLAG AND SUPPLEMENTAL
OPERATIONS
0
1. The authority citation for part 121 continues to read as follows:
Authority: 49 U.S.C. 106(g), 40113, 40119, 41706, 44101, 44701-
44702, 44705, 44709-44711, 44713, 44716-44717, 44722, 44901, 44903-
44904, 44912, 45101-45105, 46105, 46301.
0
2. Amend appendix I to part 121 by revising the introductory text to
section III.
Appendix I to Part 121--Drug Testing Program
* * * * *
III. Employees Who Must be Tested. Each employee, including any
assistant, helper, or individual in a training status, who performs
[[Page 1677]]
a safety-sensitive function listed in this section directly or by
contract (including by subcontract at any tier) for an employer as
defined in this appendix must be subject to drug testing under an
antidrug program implemented in accordance with this appendix. This
includes full-time, part-time, temporary, and intermittent employees
regardless of the degree of supervision. The safety-sensitive
functions are:
* * * * *
0
3. Amend appendix J to part 121 by revising paragraph A introductory
text of section II.
Appendix J To Part 121--Alcohol Misuse Prevention Program
* * * * *
II. Covered Employees
A. Each employee, including any assistant, helper, or individual
in a training status, who performs a safety-sensitive function
listed in this section directly or by contract (including by
subcontract at any tier) for an employer as defined in this appendix
must be subject to alcohol testing under an alcohol misuse
prevention program implemented in accordance with this appendix.
This includes full-time, part-time, temporary, and intermittent
employees regardless of the degree of supervision. The safety-
sensitive functions are:
* * * * *
Issued in Washington, DC, on December 22, 2005.
Marion C. Blakey,
Administrator.
[FR Doc. 06-205 Filed 1-9-06; 8:45 am]
BILLING CODE 4910-13-P