Agenda 03/12/2024 Item #16F10 (Settlement of a clain filed by the FAA)03/12/2024
EXECUTIVE SUMMARY
Recommendation to approve and authorize the Chairman to execute a Settlement Agreement with the
Federal Aviation Administration (FAA) in the amount of $5,000 based on the Notice of Proposed Civil
Penalty issued to Collier County Helicopter Operations regarding an alleged violation of FAA regulations.
OBJECTIVE: Recommendation to approve settlement of a claim filed by the FAA.
CONSIDERATIONS: The FAA conducts an annual audit of Collier County Helicopter Operations (Helicopter
Operations) which includes reviews of all employee files, including review for required background screening
information. Based on the audit conducted in May 23, 2023, the FAA issued a Notice of Proposed Civil Penalty to
Helicopter Operations on November 29, 2023. The violation alleges that Collier County did not obtain the required
drug and alcohol information before a new hire was allowed to perform safety-sensitive functions in violation of 49
C.F.R. Sec. 40.25(d). The new hire was a helicopter maintenance employee. Collier County successfully
performed required drug and alcohol screenings; however, Collier County did not timely collect the FAA required
background documentation from the employee’s former employer. The proposed fine was $6,750.
Based on the FAA audit, Risk Management worked with Human Resources and Helicopter Operations to develop
Standard Operating Procedures to ensure that the County is timely requesting and receiving all FAA required
documentation for new hire employees at Helicopter Operations.
The Notice of Proposed Civil Penalty provided the County with the opportunity for an informal hearing to discuss
the proposed penalty. On January 29, 2024, the County participated in the informal hearing, and Risk Management
presented the Standard Operating Procedures to the FAA together with the Human Resources Department,
Helicopter Operations, and County Attorney’s Office. The County requested that the FAA consider removing the
fine based on the new processes implemented, that the FAA reduce the fine , or that if a fine was imposed, that the
County be authorized to use the funds for training or for another public purpose. Following the hearing, the FAA
responded that after taking into consideration the statements and evidence presented the hearing, the FAA is willing
to reduce the amount of the civil penalty in this matter from $6,750 to $5,000.
The County Attorney and the Risk Management Director recommend that the Board approve this proposed
settlement as reasonable. In the alternative, with Board direction, the County may file a formal appeal of the Notice
of Proposed Civil Penalty in accordance with 14 C.F.R. Section 13.16 resulting in a formal administrative
proceeding with the FAA, but this course of action is not recommended by the County Attorney.
FISCAL IMPACT: Funds are budgeted and available in Fund MF Operating Fund #144505 EMS/Helicopter
Operations Fund and the total impact will be $5,000.
GROWTH MANAGEMENT IMPACT: There is no Growth Management Impact related to this request.
LEGAL CONSIDERATIONS: This item is approved as to form and legality and requires a majority vote for
approval. - CMG
RECOMMENDATION: To approve and authorize the Chairman to execute a Settlement Agreement with the
Federal Aviation Administration (FAA) in the amount of $5,000 based on the Notice of Proposed Civil Penalty
issued to Collier County Helicopter Operations regarding an alleged violation of FAA regulations.
PREPARED BY: Bruce Gastineau, Interim Chief, Collier County EMS/President Helicopter Operations
ATTACHMENT(S)
1. FAA Collier County Drug & Alcohol Testing Protocol (PDF)
16.F.10
Packet Pg. 1695
03/12/2024
COLLIER COUNTY
Board of County Commissioners
Item Number: 16.F.10
Doc ID: 28221
Item Summary: Recommendation to approve and authorize the Chairman to execute a Settlement Agreement with
the Federal Aviation Administration (FAA) in the amount of $5,000 based on the Notice of Proposed Civil Penalty
issued to Collier County Helicopter Operations regarding an alleged violation of FAA regulations.
Meeting Date: 03/12/2024
Prepared by:
Title: – Emergency Medical Services
Name: Cherie DuBock
03/04/2024 3:39 PM
Submitted by:
Title: – Emergency Medical Services
Name: Bruce Gastineau
03/04/2024 3:39 PM
Approved By:
Review:
Emergency Medical Services Bruce Gastineau EMS Chief Review Completed 03/04/2024 3:51 PM
Emergency Management Michael Choate Executive Director Review Completed 03/05/2024 10:49 AM
Risk Management Michael Quigley Other Reviewer Completed 03/05/2024 10:50 AM
Office of Management and Budget Debra Windsor Level 3 OMB Gatekeeper Review Completed 03/05/2024 11:06 AM
County Attorney's Office Jeffrey A. Klatzkow Level 3 County Attorney's Office Review Completed 03/05/2024 11:21 AM
Corporate Business Operations Jennifer Reynolds OMB Reviewer Completed 03/05/2024 11:27 AM
Office of Management and Budget Agnieszka Chudy OMB Reviewer Completed 03/05/2024 12:30 PM
County Manager's Office Amy Patterson Level 4 County Manager Review Completed 03/06/2024 9:50 AM
Board of County Commissioners Geoffrey Willig Meeting Pending 03/12/2024 9:00 AM
16.F.10
Packet Pg. 1696
RISK MANAGEMENT DIVISION
STANDARD OPERATING PROCEDURE
_
SUBJECT: COLLIER COUNTY DRUG AND ALCOHOL TESTING PROTOCOL (FAA)
REFERENCE: CMA #5312 DRUG FREE WORKPLACE; U. S. Department of Transportation
49 CFR Part 40; Federal Aviation Administration FAA) (14 CFR part 120); Drug-Free Workplace
Act of 1988, and § 112.0455, Fla. Stat. Drug Free Workplace.
EFFECTIVE DATE: May 2023 REVISION DATE: 1/5/2024
PURPOSE
The purpose of this Instruction is to provide for procedures and implementation of the Drug-Free
Workplace policy for positions that fall under the Federal Aviation Administration (FAA) as
authorized by the County Manager. It is the SOP to meet the requirements of CMA #5312 DRUG
FREE WORKPLACE. Additionally, the purpose of this policy is to establish guidelines to maintain
a drug and alcohol-free workplace in compliance with the Drug-Free Workplace Act of 1988, and
the Omnibus Transportation Employee Testing Act of 1991. This policy is intended to comply with
all applicable Federal regulations governing workplace anti-drug and alcohol programs in the
aviation industry. The U. S. Department of Transportation (USDOT) has also published 49 CFR
Part 40, as amended, that sets standards for the collection and testing of urine, breath or saliva
specimens. Specifically, the Federal Aviation Administration (FAA) 14 CFR part 120 which
mandates urine drug testing and breath alcohol testing for FAA covered employees in safety-
sensitive positions, and prohibits performance of safety-sensitive functions when there is a positive
test result.
CONCEPT
The Board of County Commissioners has a vital interest in maintaining a safe, healthy, and
efficient working environment. Being under the influence of a drug or alcohol on the job or the use,
sale, purchase, transfer, or possession of an illegal drug or alcohol in the workplace poses
unacceptable risks for safe, healthy, and efficient operations to the user and to all those who work
with the user. Collier County is obligated to the public and its FAA covered employees to provide
services that are free of the influence of illegal drugs and alcohol and will endeavor through this
policy to provide drug-and alcohol-free services.
1. FAA covered employees will be informed of the dangers of alcohol and/or drug use in the
workplace during New Hire Orientation within the first month of employment.
2. The County intends, through this policy, to comply with federal and state rules, regulations or
laws that relate to the maintenance of a workplace free from illegal drugs and alcohol.
POLICY
This policy applies ONLY to BCC FAA covered employees and complies with 14 CFR part 120, as
amended and 49 CFR Part 40, as amended.
16.F.10.b
Packet Pg. 1697 Attachment: FAA Collier County Drug & Alcohol Testing Protocol (28221 : FAA SETTLEMENT AGREEMENT)
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All FAA covered employees are required to submit to drug and alcohol tests as a condition of
employment in accordance with 14 CFR part 120.
In addition, DOT has published 49 CFR Part 32, implementing the Drug-Free Workplace Act of
1988, which requires the establishment of drug-free workplace policies and the reporting of certain
drug-related offenses to the FAA.
All Board of Collier County Commissioners (BCC) FAA covered employees are subject to the
provisions of the Drug-Free Workplace Act of 1988. The unlawful manufacture, distribution,
dispensation, possession or use of a controlled substance is prohibited in the FAA covered
workplace. An FAA covered employee who is convicted of any criminal drug statute for a violation
occurring in the workplace shall notify the BCC DER/DAPM no later than five days after such
conviction.
Employee Categories Subject To Testing. All persons performing any of the following safety-
sensitive functions are subject to the DOT/FAA drug and alcohol testing program:
- Flight crewmember
- Flight attendant
- Flight instruction
- Aircraft dispatch
- Aircraft maintenance/preventive maintenance
- Ground security coordinator
- Aviation screening
- Air traffic control
- Operations Control Specialist
For More Information about DOT and FAA Requirements or our Company Policy, contact
Andrew Kelly, DAPM, DER at 239-252-8091.
For more information relating to the FAA/DOT program requirements, visit the following Web sites:
For FAA: http://www.faa.gov/go/drugabatement
For DOT: http://www.dot.gov/ost/dapc/
16.F.10.b
Packet Pg. 1698 Attachment: FAA Collier County Drug & Alcohol Testing Protocol (28221 : FAA SETTLEMENT AGREEMENT)
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Prohibited Behavior
Use of illegal drugs is prohibited at all times. All FAA covered employees are prohibited from
reporting for duty or remaining on duty any time there is a quantifiable presence of a prohibited
drug in the body at or above the minimum thresholds defined in Part 40. Prohibited drugs include:
1. marijuana
2. cocaine
3. phencyclidine (PCP)
4. opioids
5. amphetamines
All FAA covered employees are prohibited from performing or continuing to perform safety-
sensitive functions while having an alcohol concentration of 0.04 or greater .
All FAA covered employees are prohibited from consuming alcohol while performing safety-
sensitive job functions or while on-call to perform safety-sensitive job functions. If an on-call FAA
covered employee has consumed alcohol, they must acknowledge the use of alcohol at the time
that they are called to report for duty. If the on-call FAA covered employee claims the ability to
perform his or her safety-sensitive function, he or she must take an alcohol test with a result of less
than 0.02 prior to performance.
All FAA covered employees are prohibited from consuming alcohol within four (4) hours prior to the
performance of safety-sensitive job functions.
All FAA covered employees are prohibited from consuming alcohol for eight (8) hours following
involvement in an accident or until he or she submits to the post-accident drug and alcohol test,
whichever occurs first.
Consequences for Violations
Following a positive drug or alcohol (BAC at or above 0.04) test result or test refusal, the FAA
covered employee will be immediately removed from safety-sensitive duty and referred to a
Substance Abuse Professional. Following a BAC of 0.02 or greater, but less than 0.04, the FAA
covered employee will be immediately removed from safety-sensitive duties for at least eight hours
unless a retest results in the FAA covered employee’s alcohol concentration being less than 0.02.
Treatment/Discipline
Per Board of Collier County Commissioners (BCC) policy, an employee who has a verified positive
drug test, has a verified alcohol concentration of 0.04 or greater, or refuses to submit to a drug or
alcohol test (including mandatory requirements of immediate removal from the safety-sensitive
function and evaluation by a SAP), and the consequences (as set forth in Part 655.35) for an
employee who has a verified alcohol concentration of 0.02 or greater but less than 0.04. The
employee may be recommended for corrective action, up to and including termination. A violating
employee who successfully completes the USDOT's RTD process will be eligible to retain
employment with Collier County.
16.F.10.b
Packet Pg. 1699 Attachment: FAA Collier County Drug & Alcohol Testing Protocol (28221 : FAA SETTLEMENT AGREEMENT)
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FAA Pre-employment / Collier County HR Conditional Post-Offer Requirements
The Department of Transportation (DOT) and Federal Aviation Administration (FAA) drug and
alcohol testing regulations (49 CFR part 40 and 14 CFR part 120) require specific steps to take
when hiring any individual for or transferring any employee into a safety-sensitive position. For
more information, visit www.faa.gov/go/drugabatement.
Prior to performing any FAA Safety Sensitive functions, Collier County shall ensure the following is
completed:
Notified applicant/employee of requirement to undergo pre-employment testing for the
presence of marijuana, cocaine, opioids, phencyclidine (PCP), and amphetamines
Asked applicant/employee if they ever tested positive or refused a pre-employment drug or
alcohol test administered by a DOT-regulated employer in the past two years, as required
by 49 CFR § 40.25(j)
Notified applicant/employee to report for DOT pre-employment drug test
Received Medical Review Officer verified negative DOT/FAA pre-employment drug and
alcohol (optional) test result
Sent Release of Information Form(s) to former employer(s), as required by 49 CFR § 40.25
or PRIA
Date Hired/Transferred employee into DOT/FAA safety-sensitive function
Added new safety-sensitive employee to the DOT/FAA random pool
Completed and documented Employee Drug and Alcohol Training and distributed drug and
alcohol informational and educational materials
The following forms/templates are located at the end of this document:
Checklist: New Hire/Transfer for Safety Sensitive Position
DOT/FAA Pre-employment drug test acknowledgment
DOT/FAA Drug & Alcohol Pre-employment Notification
Release of Information Form – 49 CFR Part 40, Drug and Alcohol Testing for Aviation
Employers
16.F.10.b
Packet Pg. 1700 Attachment: FAA Collier County Drug & Alcohol Testing Protocol (28221 : FAA SETTLEMENT AGREEMENT)
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SUBSTANCE ABUSE INFORMATION for DOT/FAA DRUG AND ALCOHOL TESTING
Collier County Board of County Commissioners complies with the drug and alcohol testing
regulations of the Department of Transportation (DOT) (49 CFR part 40) and the Federal Aviation
Administration (FAA) (14 CFR part 120).
Community Service Hotline. If you have any personal problems or questions concerning drug
abuse or alcohol misuse and need to confide in someone, you are encouraged to contact:
Name: The Standard, Employee Assistance Program Telephone: 888-293-6948
For More Information About DOT and FAA Requirements or our Company Policy, contact
Andrew Kelly, DER, Risk Manager-EHS at 941-252-8091.
For more information relating to the federal drug and alcohol testing requirements, visit the
websites below:
For FAA: https://www.faa.gov/go/drugabatement
For DOT: http://www.dot.gov/odapc/
Consequences of Using Drugs or Alcohol While Performing Safety-Sensitive Functions. A
covered employee who has engaged in prohibited drug use or alcohol misuse during the
performance of a safety-sensitive function will be immediately removed from performing safety-
sensitive functions and permanently precluded from performing the same safety-sensitive function
for any FAA-regulated employer. [14 CFR §§ 120.111(e)(2) and 120.221(b)(1)]
Consequences of a Verified Positive Drug Test or an Alcohol Test at 0.04 or Higher Breath
Alcohol Content (BAC). A covered employee who receives a verified positive drug test result or
alcohol violation on a federally required test will be immediately removed from safety-sensitive
duties. An employee who has violated the federal drug or alcohol testing rules cannot return to the
performance of safety-sensitive duties until the employee has been evaluated by a Substance
Abuse Professional and successfully completed the treatment and/or education requirements in
accordance with the return-to-duty process outlined in 49 CFR Part 40, Subpart O. [49 CFR §
40.23(d)]
A covered employee who receives a verified positive drug test on two federal drug tests or used a
prohibited drug while performing covered functions will be immediately removed and permanently
disqualified from performing the safety-sensitive functions performed prior to the second drug test.
[14 CFR § 120.111(e)(1)] A covered employee who had an alcohol test result with a BAC of 0.04
or higher on a federal alcohol test and had a previous alcohol test result with a BAC of 0.04 or
higher will be immediately removed from performing safety-sensitive functions and is permanently
disqualified from performing the same safety-sensitive functions performed prior to the second
alcohol test. [14 CFR § 120.221(b)(2)]
Consequences of an Alcohol Test with a BAC of 0.02 but less than 0.04. Immediate removal
from safety-sensitive functions, until the employee's breath alcohol concentration measures less
than 0.02, or the start of the employee's next regularly scheduled duty period, but not less than 8
hours following administration of the test.
16.F.10.b
Packet Pg. 1701 Attachment: FAA Collier County Drug & Alcohol Testing Protocol (28221 : FAA SETTLEMENT AGREEMENT)
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[14 CFR § 120.221(f)]
Consequences of Refusing to Submit to a Required Drug or Alcohol Test. Immediate
removal from performing safety-sensitive functions until or unless the employee successfully
completes the return-to-duty process outlined in 49 CFR Part 40, Subpart O. A verified adulterated
or substituted drug test result will be considered a refusal to test.
[49 CFR § 40.23(b)]
Reporting to the FAA. Any violation by an employee who holds an airman medical certificate
issued under 14 CFR Part 67 must be reported to the FAA’s Federal Air Surgeon. [14 CFR §
120.113(d)(1) and 120.221(c)(1)] If you are a pilot, drug and alcohol testing information may be
entered into the FAA’s Pilot Records Database in accordance with 14 CFR part 111. In addition,
any employee who holds a certificate under 14 CFR Part 61, Part 63, 65, or 67 and who has
refused to submit to a FAA required drug or alcohol test must be reported to the FAA. [14 CFR §§
120.111(d) and 120.221(d)]
THIS SPACE LEFT BLANK INTENTIALLY
An individual hired to perform safety-sensitive functions directly or by contract is subject to drug and alcohol testing in
accordance with 14 CFR part 120. This includes part-time, full-time, temporary, or intermittent employees regardless
of degree of supervision. [14 CFR §§ 120.105 and 120.215] An employee is subject to alcohol testing during any
period when performing a safety-sensitive function. An employee is performing a safety-sensitive function during any
period in which he or she is actually performing, ready to perform, or immediately available to perform such functions.
[14 CFR § 120.7]
16.F.10.b
Packet Pg. 1702 Attachment: FAA Collier County Drug & Alcohol Testing Protocol (28221 : FAA SETTLEMENT AGREEMENT)
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Circumstances Under Which a Covered Employee will be Tested for Drugs
Pre-Employment Testing
A negative pre-employment drug test result is required before an FAA covered employee can first
perform safety-sensitive functions. If a pre-employment test is cancelled, the individual will be
required to undergo another test and successfully pass with a verified negative result before
performing safety-sensitive functions.
If a FAA covered employee has not performed a safety-sensitive function for 90 or more
consecutive calendar days, and has not been in the random testing pool during that time, the FAA
covered employee must take and pass a pre-employment test before he or she can return to a
safety-sensitive function.
A FAA covered employee or applicant who has previously failed or refused a DOT pre-employment
drug and/or alcohol test must provide proof of having successfully completed a referral, evaluation,
and treatment plan meeting DOT requirements.
Reasonable Suspicion Testing
All FAA covered employees shall be subject to a drug and/or alcohol test when Board of Collier
County Commissioners (BCC) has reasonable suspicion to believe that the FAA covered employee
has used a prohibited drug and/or engaged in alcohol misuse.
A reasonable suspicion referral for testing will be made by a trained supervisor or other trained
company official on the basis of specific, contemporaneous, articulable observations concerning
the appearance, behavior, speech, or body odors of the FAA covered employee. Reasonable
suspicion tests for alcohol misuse can only be performed if the observations are made just before,
during, or just after the performance of safety sensitive functions.
FAA covered employees may be subject to reasonable suspicion drug testing any time while on
duty. FAA covered employees may be subject to reasonable suspicion alcohol testing while the
FAA covered employee is performing safety-sensitive functions, just before the FAA covered
employee is to perform safety-sensitive functions, or just after the FAA covered employee has
ceased performing such functions.
Post-Accident Testing
FAA covered employees shall be subject to post-accident drug and alcohol testing under the
following circumstances:
Fatal Accidents
As soon as practicable following an accident involving the loss of a human life, drug and alcohol
tests will be conducted on each surviving FAA covered employee operating the public
transportation vehicle at the time of the accident. In addition, any other FAA covered employee
whose performance could have contributed to the accident, as determined by Board of Collier
16.F.10.b
Packet Pg. 1703 Attachment: FAA Collier County Drug & Alcohol Testing Protocol (28221 : FAA SETTLEMENT AGREEMENT)
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County Commissioners (BCC) using the best information available at the time of the decision, will
be tested.
Non-fatal Accidents
The Federal Aviation Administration's (FAA’s) drug and alcohol testing regulation (14 CFR part
120) describes when an employer is required to conduct and when an employee must submit to
post-accident drug and/or alcohol testing.
As soon as practicable following an accident, each employer must test each surviving safety-
sensitive employee for the presence of marijuana, cocaine, opioids, phencyclidine (PCP), and
amphetamines, or a metabolite of those drugs in the employee's system, and for alcohol, if that
employee's performance either contributed to the accident or cannot be completely discounted as
a contributing factor to the accident.
For post-accident drug testing, the employee must be tested as soon as possible but not later than
32 hours after the accident.
For post-accident alcohol testing, the employee must be tested as soon as possible but the time of
testing cannot exceed 8 hours from the time of the accident. If a test is not administered within 2
hours following the accident, the employer must prepare and maintain on file a record stating the
reasons why the test was not promptly administered. If a test is not administered within 8 hours
following the accident, the employer must cease attempts to administer an alcohol test and must
prepare and maintain the same record.
The decision not to administer a test must be based on the employer’s determination, using the
best information available at the time of the determination, that the employee's performance could
not have contributed to the accident.
The FAA and the National Transportation Safety Board (NTSB) define an accident as an
occurrence associated with the operation of an aircraft which takes place between the time any
person boards the aircraft with the intention of flight and all such persons have disembarked, AND
in which any person suffers death or serious injury or in which the aircraft receives substantial
damage. The NTSB regulations (49 CFR part 830) define "serious injury" and "substantial
damage" as follows:
“Serious injury means any injury which: (1) Requires hospitalization for more than 48 hours,
commencing within 7 days from the date of the injury was received; (2) results in a fracture of any
bone (except simple fractures of fingers, toes, or nose); (3) causes severe hemorrhages, nerve,
muscle, or tendon damage; (4) involves any internal organ; or (5) involves second- or third-degree
burns, or any burns affecting more than 5 percent of the body surface.”
“Substantial damage means damage or failure which adversely affects the structural strength,
performance, or flight characteristics of the aircraft, and which would normally require major repair
or replacement of the affected component. Engine failure or damage limited to an engine if only
one engine fails or is damaged, bent fairings or cowling, dented skin, small punctured holes in the
16.F.10.b
Packet Pg. 1704 Attachment: FAA Collier County Drug & Alcohol Testing Protocol (28221 : FAA SETTLEMENT AGREEMENT)
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skin or fabric, ground damage to rotor or propeller blades, and damage to landing gear, wheels,
tires, flaps, engine accessories, brakes, or wingtips are not considered “substantial damage” for
the purpose of this part.”
Monetary damage is not a factor in determining what constitutes an "accident."
Random Testing
Random drug and alcohol tests are unannounced and unpredictable, and the dates for
administering random tests are spread reasonably throughout the calendar year. Random testing
will be conducted at all times of the day when safety-sensitive functions are performed.
Testing rates will meet or exceed the minimum annual percentage rate set each year by the FAA
administrator. The current year testing rates can be viewed online at
www.transportation.gov/odapc/random-testing-rates. (Currently 50/10)
The selection of FAA covered employees for random drug and alcohol testing will be made by a
scientifically valid method, such as a random number table or a computer-based random number
generator. Under the selection process used, each FAA covered employee will have an equal
chance of being tested each time selections are made.
A FAA covered employee may only be randomly tested for alcohol misuse while the FAA covered
employee is performing safety-sensitive functions, just before the FAA covered employee is to
perform safety-sensitive functions, or just after the FAA covered employee has ceased performing
such functions. A FAA covered employee may be randomly tested for prohibited drug use anytime
while on duty.
Each FAA covered employee who is notified of selection for random drug or random alcohol
testing must immediately proceed to the designated testing site.
Random Testing – End of Shift
Random testing may occur anytime an FAA covered employee is on duty so long as the FAA
covered employee is notified prior to the end of the shift. FAA covered employees who provide
advance, verifiable notice of scheduled medical or child care commitments will be random drug
tested no later than three hours before the end of their shift and random alcohol tested no later
than 30 minutes before the end of their shift. Verifiable documentation of a previously scheduled
medical or child care commitment, for the period immediately following an FAA covered
employee’s shift, must be provided at least 8 hours before the end of the shift.
Return to Duty Testing
Any FAA covered employee who is allowed to return to safety-sensitive duty after failing or
refusing to submit to a DOT drug and/or alcohol test must first be evaluated by a substance abuse
professional (SAP), complete a SAP-required program of education and/or treatment, and provide
a negative return-to-duty drug and/or alcohol test result. All tests will be conducted in accordance
with 49 CFR Part 40, Subpart O.
16.F.10.b
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Follow-up Testing
FAA covered employees returning to safety-sensitive duty following leave for substance abuse
rehabilitation will be required to undergo unannounced follow-up alcohol and/or drug testing for a
period of one (1) to five (5) years, as directed by the SAP. The duration of testing will be extended
to account for any subsequent leaves of absence, as necessary. The type (drug and/or alcohol),
number, and frequency of such follow-up testing shall be directed by the SAP. All testing will be
conducted in accordance with 49 CFR Part 40, Subpart O. DRUG TESTING PROCEDURES
1) Testing shall be conducted in a manner to assure a high degree of accuracy and reliability and
using techniques, equipment, and laboratory facilities which have been approved by the U.S.
Department of Health and Human Service (HHS). All testing will be conducted consistent with
the procedures set forth in 49 CFR Part 40, as amended. The procedures will be performed in
a private, confidential manner and every effort will be made to protect the employee, the
integrity of the drug testing procedure, and the validity of the test result. Collier County requires
all individuals who collect samples in our program meet the requirements of Section 40.31(a)
which states "Collectors meeting the requirements of this subpart are the only persons
authorized to collect urine specimens for DOT drug testing. (b) A collector must meet training
requirements of §40.33."
2) The drugs that will be tested for include Marijuana metabolites/THC. Cocaine metabolites,
Amphetamines (including methamphetamine, MDMA), Opioids (including codeine, heroin (6-
AM), morphine, hydrocodone, oxycodone, hydromorphone, and oxymorphone) and
Phencyclidine (PCP). After the identity of the donor is checked using picture identification, a
urine specimen will be collected using the split specimen collection method described in 49
CFR Part 40, as amended. Each specimen will be accompanied by a Federal Chain of
Custody and Control Form and identified using a unique identification number that attributes the
specimen to the correct individual. The specimen analysis will be conducted at a HHS certified
laboratory. An initial drug screen and validity test will be conducted on the primary urine
specimen. For those specimens that are not negative, one of two tests will be performed 1.A
confirmatory Gas Chromatography/Mass Spectrometry (GC/MS) or, 2. A Liquid
Chromatography/ Mass Spectrometry (LC/MS). The test will be considered positive if the
amounts of the drug(s) and/or its metabolites identified by the GC/MS or LC/MS test are at or
above the minimum thresholds established in 49 CFR Part 40, as amended.
3) The test results from the HHS certified laboratory will be reported to a Medical Review Officer.
A Medical Review Officer (MRO) is a licensed physician with detailed knowledge of substance
abuse disorders and drug testing. The MRO will review the test results to ensure the scientific
validity of the test and to determine whether there is a legitimate medical explanation for a
confirmed positive, substituted, or adulterated test result. The MRO will attempt to contact the
employee to notify the employee of the non-negative laboratory result, and provide the
employee with an opportunity to explain the confirmed laboratory test result. The MRO will
subsequently review the employee’s medical history/medical records as appropriate to
16.F.10.b
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determine whether there is a legitimate medical explanation for a non-negative laboratory
result. If no legitimate medical explanation is found, the test will be verified positive or refusal to
test and reported to the Collier County EHS Manager (DER/DAPM). If a legitimate explanation
is found, the MRO will report the test result as negative to the DER/DAPM.
4) If the test is invalid without a medical explanation, a retest will be conducted under direct
observation. Employees do not have access to a test of their split specimen following an
invalid result.
5) Any covered employee who questions the results of a required drug test may request that the
split sample be tested. The split sample test must be conducted at a second HHS-certified
laboratory with no affiliation with the laboratory that analyzed the primary specimen. The test
must be conducted on the split sample that was provided by the employee at the same time as
the primary sample.
6) The method of collecting, storing, and testing the split sample will be consistent with the
procedures set forth in 49 CFR Part 40, as amended. The employee's request for a split
sample test must be made to the Medical Review Officer within 72 hours of notice of the
original sample verified test result. Requests after 72 hours will only be accepted at the
discretion of the MRO if the delay was due to documentable facts that were beyond the control
of the employee.
7) If the analysis of the split specimen fails to confirm the presence of the drug(s) detected in the
primary specimen, if the split specimen is not able to be analyzed, or if the results of the split
specimen are not scientifically adequate, the MRO will declare the original test to be canceled.
If the split specimen is not available to analyze the MRO will direct Collier County to retest the
employee under direct observation.
8) The split specimen will be stored at the initial laboratory until the analysis of the primary
specimen is completed. If the primary specimen is negative, the split will be discarded. If the
primary is positive, the split will be retained for testing if so requested by the employee through
the Medical Review Officer. If the primary specimen is positive, it will be retained in frozen
storage for one year and the split specimen will also be retained for one year. 9) Observed collections
a) Consistent with 49 CFR part 40, as amended, collection under direct observation (by a
person of the same gender) with no advance notice will occur if:
1) The laboratory reports to the MRO that a specimen is invalid, and the MRO reports to
Collier County EHS Manager (DER/DAPM) that there was not an adequate medical
explanation for the result;
2) The MRO reports to Collier County that the original positive, adulterated, or
substituted test result had to be cancelled because the test of the split specimen
could not be performed;
3) The laboratory reported to the MRO that the specimen was negative-dilute with a
16.F.10.b
Packet Pg. 1707 Attachment: FAA Collier County Drug & Alcohol Testing Protocol (28221 : FAA SETTLEMENT AGREEMENT)
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creatinine concentration greater than or equal to 2 mg/dL but less than or equal to 5
mg/dL, and the MRO reported the specimen to you as negative-dilute and that a
second collection must take place under direct observation.
4) The collector observes materials brought to the collection site or the employee's
conduct clearly indicates an attempt to tamper with a specimen;
5) The temperature on the original specimen was out of range;
6) Anytime the employee is directed to provide another specimen because the original
specimen appeared to have been tampered with.
7) All follow-up-tests; or
8) All return-to-duty tests
Dilute Urine Specimen
If there is a negative dilute test result, Board of Collier County Commissioners (BCC) will conduct
one additional retest. The result of the second test will be the test of record.
Dilute negative results with a creatinine level greater than or equal to 2 mg/dL but less than or
equal to 5 mg/dL require an immediate recollection under direct observation (see 49 CFR Part 40,
section 40.67).
Split Specimen Test
In the event of a verified positive test result, or a verified adulterated or substituted result, the FAA
covered employee can request that the split specimen be tested at a second laboratory at their
own expense. Board of Collier County Commissioners (BCC) guarantees that the split specimen
test will be conducted in a timely fashion.
THIS SPACE LEFT BLANK INTENTIALLY
16.F.10.b
Packet Pg. 1708 Attachment: FAA Collier County Drug & Alcohol Testing Protocol (28221 : FAA SETTLEMENT AGREEMENT)
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ALCOHOL MISUSE PREVENTION POLICY (AMPP) for DOT/FAA ALCOHOL TESTING
Functions and Period of the Work Day Employees are Covered by the AMPP
Any employee performing a safety-sensitive function is subject to alcohol testing and must refrain
from consuming any alcohol (not just alcoholic beverages) whenever they are performing, ready to
perform, or immediately available to perform these functions.
Conduct Prohibited by the AMPP
Alcohol and Alcohol Use
Alcohol is defined as the intoxicating agent in beverage alcohol, ethyl alcohol, or other low
molecular weight alcohols, including methyl or isopropyl alcohol.
Alcohol use is defined as the consumption of any beverage, mixture, or preparation,
including any medication (prescribed or over-the-counter, intentional or unintentional),
containing alcohol.
Alcohol Concentration
Covered employees may not report for duty or remain on duty in a position requiring the
performance of safety-sensitive functions while having an alcohol concentration of 0.04 or
greater.
Pre-Duty Use
Employees may not perform flight crewmember, flight attendant, or air traffic controller
duties within 8 hours after consuming alcohol.
Employees may not perform flight instruction, aircraft dispatcher, aircraft maintenance or
preventive maintenance, ground security coordinator, or aviation screening duties within 4
hours after consuming alcohol.
On-Duty Use
Covered employees may not consume alcohol in any form while performing safety-sensitive
functions.
This prohibition also applies to covered employees who are at work and immediately
available to perform safety-sensitive functions.
Use After an Accident
Covered employees with knowledge of an accident involving an aircraft for which they
performed a safety-sensitive function at or near the time of the accident may not use alcohol
for 8 hours after the accident unless they have been given a post-accident test, or Collier
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Packet Pg. 1709 Attachment: FAA Collier County Drug & Alcohol Testing Protocol (28221 : FAA SETTLEMENT AGREEMENT)
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County Risk Management’s EHS manager or his designee has determined that their
performance could not have contributed to the accident.
Accident is defined as an occurrence associated with the operation of an aircraft which
takes place between the time any person boards the aircraft with the intention of flight and
the time that all such persons have disembarked, and in which any person suffers death or
serious injury or in which the aircraft receives substantial damage.
Refusal to Submit to Testing
Covered employees may not refuse to submit to a post-accident, random, reasonable
suspicion, return-to-duty, or follow-up alcohol test. Collier County will not permit an
employee who refuses to submit to such a test to perform or continue to perform safety-
sensitive functions.
Refusal to submit to a pre-employment test is not a violation of the FAA AMPP rule, but a
refusal will preclude any person from being hired for a safety-sensitive function, unless he or
she completes the SAP and return-to-duty processes.
Circumstances Under Which a Covered Employee will be Tested for Alcohol
Covered employees are subject to the following Federally mandated alcohol tests. It is an
employer’s option whether to require alcohol pre-employment testing. If a company elects to do
so, all applicants/employees must be subject to testing after a contingent offer of employment is
made or the employee is transferred and prior to the first performance of safety-sensitive function.
Post-Accident
As soon as practicable following an accident, each covered employee must be alcohol
tested if that employee’s performance either contributed to the accident or cannot be
discounted as a contributing factor to the accident.
A covered employee who is subject to post-accident alcohol testing will remain readily
available for testing or may be deemed by the Collier County DER, or assistant DER if
primary DER is not available, to have refused to submit to testing.
Attempts to conduct post-accident alcohol testing will cease 8 hours after the accident, even
if no alcohol test has been conducted.
The Federal Aviation Administration's (FAA’s) drug and alcohol testing regulation (14 CFR part
120) describes when an employer is required to conduct and when an employee must submit to
post-accident drug and/or alcohol testing.
As soon as practicable following an accident, each employer must test each surviving safety-
sensitive employee for the presence of marijuana, cocaine, opioids, phencyclidine (PCP), and
amphetamines, or a metabolite of those drugs in the employee's system, and for alcohol, if that
employee's performance either contributed to the accident or cannot be completely discounted as
a contributing factor to the accident.
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Packet Pg. 1710 Attachment: FAA Collier County Drug & Alcohol Testing Protocol (28221 : FAA SETTLEMENT AGREEMENT)
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For post-accident drug testing, the employee must be tested as soon as possible but not later than
32 hours after the accident.
For post-accident alcohol testing, the employee must be tested as soon as possible but the time of
testing cannot exceed 8 hours from the time of the accident. If a test is not administered within 2
hours following the accident, the employer must prepare and maintain on file a record stating the
reasons why the test was not promptly administered. If a test is not administered within 8 hours
following the accident, the employer must cease attempts to administer an alcohol test and must
prepare and maintain the same record.
The decision not to administer a test must be based on the employer’s determination, using the
best information available at the time of the determination, that the employee's performance could
not have contributed to the accident.
The FAA and the National Transportation Safety Board (NTSB) define an accident as an
occurrence associated with the operation of an aircraft which takes place between the time any
person boards the aircraft with the intention of flight and all such persons have disembarked, AND
in which any person suffers death or serious injury or in which the aircraft receives substantial
damage. The NTSB regulations (49 CFR part 830) define "serious injury" and "substantial
damage" as follows:
“Serious injury means any injury which: (1) Requires hospitalization for more than 48 hours,
commencing within 7 days from the date of the injury was received; (2) results in a fracture of any
bone (except simple fractures of fingers, toes, or nose); (3) causes severe hemorrhages, nerve,
muscle, or tendon damage; (4) involves any internal organ; or (5) involves second- or third-degree
burns, or any burns affecting more than 5 percent of the body surface.”
“Substantial damage means damage or failure which adversely affects the structural strength,
performance, or flight characteristics of the aircraft, and which would normally require major repair
or replacement of the affected component. Engine failure or damage limited to an engine if only
one engine fails or is damaged, bent fairings or cowling, dented skin, small punctured holes in the
skin or fabric, ground damage to rotor or propeller blades, and damage to landing gear, wheels,
tires, flaps, engine accessories, brakes, or wingtips are not considered “substantial damage” for
the purpose of this part.”
Monetary damage is not a factor in determining what constitutes an "accident."
Random
Covered employees will be selected for random alcohol testing through a scientifically valid
method.
Random tests will be spaced throughout the year and will be unannounced.
Employees notified of selection for random testing must proceed immediately to the testing
site.
16.F.10.b
Packet Pg. 1711 Attachment: FAA Collier County Drug & Alcohol Testing Protocol (28221 : FAA SETTLEMENT AGREEMENT)
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Random tests will be conducted while the employee is performing safety-sensitive functions,
just before the employee is to perform safety-sensitive functions, or just after the employee
has ceased performing safety-sensitive functions.
Reasonable Suspicion
A covered employee must submit to an alcohol test if Collier County Risk Management DER
has determined that reasonable suspicion exists that the employee has violated the alcohol
misuse prohibitions.
This determination must be based on a trained supervisor’s specific, contemporaneous,
articulable observations concerning the appearance, behavior, speech or body odors of the
employee.
Even if an alcohol test cannot be administered, no employee who is under the influence of
or impaired by alcohol, as shown by behavioral, speech, or performance indicators of
alcohol misuse, should report for duty or remain on duty requiring the performance of safety-
sensitive functions until a test can be administered and the results are below 0.02 or until
the commencement of the employee’s next duty period if at least 8 hours has elapsed.
Similarly, even if an alcohol test cannot be administered, Collier County BCC will not permit
any employee who is under the influence of or impaired by alcohol, as shown by behavioral,
speech, or performance indicators of alcohol misuse, to report for duty or remain on duty
requiring the performance of safety-sensitive functions until a test can be administered and
the result is below 0.02 or until the commencement of the employee’s next duty period if at
least 8 hours has elapsed.
A supervisor who identifies an employee for a reasonable suspicion test cannot conduct the
alcohol test as the breath alcohol technician for that employee.
Return-to-Duty
Before a covered employee returns to duty in a safety-sensitive function after engaging in
prohibited conduct, he or she will undergo a return-to-duty test.
The employee cannot perform a safety-sensitive function until a result indicating an alcohol
concentration of less than 0.02 is obtained.
Follow-Up
Each covered employee who has been identified by a substance abuse professional (SAP)
as needing assistance in resolving a problem with alcohol misuse and who has returned to
duty performing a safety-sensitive function will be subject to follow-up testing.
Follow-up tests will be unannounced.
The schedule for follow-up alcohol testing is established by the SAP.
Retests
If Collier County BCC desires to permit an employee to perform a safety-sensitive function
within 8 hours following administration of an FAA-mandated alcohol test indicating an
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Packet Pg. 1712 Attachment: FAA Collier County Drug & Alcohol Testing Protocol (28221 : FAA SETTLEMENT AGREEMENT)
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alcohol concentration of 0.02 or greater but less than 0.04, Collier County BCC will first
retest the employee.
The employee may return to the safety-sensitive function if the retest result indicates an
alcohol concentration of less than 0.02.
PROCEDURES THAT WILL BE USED TO TEST FOR THE PRESENCE OF ALCOHOL;
PROTECTING THE EMPLOYEE AND THE INTEGRITY OF THE BREATH TESTING PROCESS;
SAFEGUARDING THE VALIDITY OF THE TEST RESULTS; AND ENSURING THAT THOSE
RESULTS ARE ATTRIBUTED TO THE CORRECT EMPLOYEE.
Collier County BCC will be using Harris Health Service on behalf of Vault Workforce Screening
(Alternate Testing Facility is Advance Medical) to conduct alcohol testing. All tests will use one
of the following procedures:
Preparation for Breath Alcohol Testing
When the employee enters the alcohol testing location, the breath alcohol technician (BAT)
/screening test technician (STT) will require the employee to provide positive identification
(photo I.D. or identification issued by Collier County BCC). On request, the BAT/STT will
provide positive identification to the employee. The BAT/STT will explain the testing
procedures to the employee.
Screening Tests
The BAT/STT will complete Step 1 on the alcohol testing form (ATF), and the employee will
then complete Step 2 on the form, signing the certification. Refusal by the employee to sign
this certification will be regarded as a refusal to take the test.
Breath Tests
An individually sealed mouthpiece will be opened in view of the employee and the BAT and
will be attached to the evidential breath-testing device (EBT) in accordance with the
manufacturer’s instructions.
The BAT will instruct the employee to blow forcefully into the mouthpiece for at least 6
seconds or until the EBT indicates that an adequate amount of breath has been obtained.
If the EBT does not have a printer capable of generating a printed result showing a
sequential test number, the manufacturer’s name for the device, the device’s serial number,
and the time and date of the test, the BAT will record the displayed result, test number,
testing device, serial number of the testing device, date, time and quantified result in Step 3
of the form. The BAT will then complete the rest of Step 3 in its entirety.
If the EBT provides a printed result, but does not print the results directly onto the form, the
BAT will show the employee the result displayed on the EBT. The BAT will then affix the test
result printout to the ATF in the designated space, using a method that will provide clear
evidence of removal (e.g., tamper-evident tape).
If the EBT prints the test results directly onto the form, the BAT will show the employee the
result displayed on the EBT and on the ATF.
16.F.10.b
Packet Pg. 1713 Attachment: FAA Collier County Drug & Alcohol Testing Protocol (28221 : FAA SETTLEMENT AGREEMENT)
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In any case in which the result of the screening test is a breath alcohol concentration of less
than 0.02, the BAT will date the form and sign the certification in Step 3 of the form.
If a test result printed by the EBT does not match the displayed result, the BAT will note the
disparity in the remarks section. Both the employee and the BAT will initial or sign the
notation. The test is then invalid and Collier County BCC and the employee will be so
advised.
No further testing is authorized. The BAT will transmit the result of less than 0.02 to Collier
County BCC Risk Management in a confidential manner and Collier County Risk
Management Division will receive and store the information so as to ensure that
confidentiality is maintained as required.
Saliva Alcohol Screening Device (ASD)
The BAT/STT will check the expiration date on the device or on the package containing the
device and show it to the employee. A device must not be used after its expiration date.
The BAT/STT will open an individually wrapped or sealed package containing the device in
the presence of the employee.
The BAT/STT will offer the employee the opportunity to use the device. The BAT/STT will
instruct the employee to insert it into his/her mouth and use it in a manner described by the
device’s manufacturer.
If the employee chooses not to use the device, or in all cases in which a new test is
necessary because the device did not activate, the BAT/STT must insert the device into the
employee’s mouth and gather saliva in the manner described by the device’s manufacturer.
When the device is removed from the employee’s mouth, the BAT/STT must follow the
manufacturer’s instructions regarding the necessary next steps to ensure that the device
has activated.
The BAT/STT must read the result displayed on the device no sooner than the device’s
manufacturer instructs. In all cases the result displayed must be read within 15 minutes of
the test. The BAT/STT must then show the device and its reading to the employee and
enter the result on the ATF.
The BAT/STT must note the fact that a saliva alcohol screening device was used in Step 3
of the ATF.
Breath Tube Alcohol Screening Device (ASD)
The BAT/STT will check the expiration date on the detector device and the electronic
analyzer or on the package containing the device and the analyzer and show it to the
employee. A device or the analyzer must not be used after their expiration date. The
BAT/STT must not use an analyzer which is not specifically pre-calibrated for the device
being used in the collection.
The BAT/STT will remove the device from the package and secure an inflation bag onto the
appropriate end of the device, as directed by the manufacturer on the device’s instructions.
The BAT/STT will break the tube’s ampoule in the presence of the employee.
The BAT/STT will offer the employee the opportunity to use the device. If the employee
chooses to use the device, the BAT/STT will instruct the employee to blow forcefully and
16.F.10.b
Packet Pg. 1714 Attachment: FAA Collier County Drug & Alcohol Testing Protocol (28221 : FAA SETTLEMENT AGREEMENT)
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steadily into the blowing end of the device until the inflation bag fills with air (approximately
12 seconds).
If the employee chooses not to hold the device, the BAT/STT must hold it and provide the
use instructions.
Once the employee completes the breath process, the BAT/STT will take the device from
the employee, remove the inflation bag, and prepare the device to be read by the analyzer
in accordance with the manufacturer’s directions.
After waiting the required amount of time directed by the manufacturer for the detector
device to incubate, the BAT/STT must place the device in the analyzer in accordance with
the manufacturer’s directions. The result must be read from the analyzer no earlier than the
required incubation time of the device. In all cases, the result must be read within 15
minutes of the test.
The BAT/STT must follow the manufacturer’s instructions for determining the result of the
test. The BAT/STT must show the analyzer result to the employee and record the result on
Step 3 of the ATF.
The BAT/STT must note the fact that a breath tube alcohol screening device was used in
Step 3 of the ATF.
Confirmation Tests
If the result of the screening test is an alcohol concentration of 0.02 or greater, a
confirmation test will be performed. If a different BAT will conduct the confirmation test, the
BAT who conducts the screening test will complete and sign step 3 of the ATF. The BAT will
provide the employee with Copy 2 of the form.
In the presence of the employee, the BAT will conduct an “air blank” to ensure that the
device is working correctly. You must show the reading to the employee. The air blank result
must be 0.00. If the reading is greater than 0.00, the BAT will conduct one more air blank. If
the reading is greater than 0.00, testing will not proceed using the instrument. However,
testing may proceed on another instrument.
The BAT will instruct the employee not to eat, drink, put any object or substance in his or
her mouth, and, to the extent possible, not belch during a waiting period before the
confirmation test. This time period begins with the completion of the screening test, and will
not be less than 15 minutes. The BAT will explain to the employee the reason for this
requirement (i.e., to prevent any accumulation of mouth alcohol leading to an artificially high
reading) and the fact that it is for the employee’s benefit. The BAT will also explain that the
test will be conducted at the end of the waiting period, even if the employee has disregarded
the instruction, the BAT will so note in the “Remarks” section of the ATF.
If a BAT other than the one who conducted the screening test is conducting the confirmation
test, the new BAT will initiate a new ATF. The BAT will complete step 1 on the form. The
employee will then complete Step 2 on the form, signing the certification. Refusal by the
employee to sign this certification will be regarded as a refusal to take the test. The BAT will
note in the “Remarks” section of the form that a different BAT conducted the screening
process.
If the employee does not sign the certification in Step 4 of the form, it will not be considered
a refusal to be tested. In this event, the BAT will note the failure to sign in the “Remarks”
section of the form.
16.F.10.b
Packet Pg. 1715 Attachment: FAA Collier County Drug & Alcohol Testing Protocol (28221 : FAA SETTLEMENT AGREEMENT)
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A breath alcohol test is invalid under the following circumstances:
o The EBT does not pass its next external calibration check (invalidates all test results
of 0.02 or greater on tests conducted since the last valid external calibration test; this
does not invalidate negative tests).
o The BAT does not observe the minimum 15-minute waiting period prior to the
confirmation test.
o The BAT does not perform an air blank on the EBT before a confirmation test, or
such an air blank does not result in a reading of 0.00.
o The BAT does not sign the form.
o An EBT fails to print a confirmation test result.
o The sequential test number or alcohol concentration displayed on the EBT is not the
same as the sequential test number or alcohol concentration on the printed result.
Employee records pertaining to alcohol testing will be maintained in a secure location with
controlled access.
These records will be promptly released to the employee, or a person identified by the
employee (including subsequent employers), upon written request of the employee. This
release of information will not be contingent upon payment for records other than those
specifically requested.
These records must be released to Department of Transportation agency representatives
upon request.
These records may must be released to the National Transportation Safety Board when
requested as part of an accident investigation.
These records may be released to a Federal, state, or local safety agency with regulatory
authority over the employer or the employee upon request.
REQUIREMENTS THAT A COVERED EMPLOYEE SUBMIT TO ALCOHOL TESTS
The Federal Aviation Administration (FAA) Alcohol Misuse Prevention Program (AMPP)
prohibits certain conduct by, and requires alcohol testing of persons who perform specified
safety-sensitive functions. Persons who violate this regulation will be subject to
consequences, including removal from safety-sensitive functions.
AN EXPLANATION OF WHAT CONSTITUTES A REFUSAL TO SUBMIT TO AN ALCOHOL
TEST AND THE ATTENDANT CONSEQUENCES
As a safety-sensitive employee, you are considered to have refused to take an alcohol test
if you:
1. Fail to appear for any test (except a pre-employment test) within a reasonable time, as
determined by the employer, consistent with applicable DOT agency regulations, after
being directed to do so by the employer. This includes the failure of an employee
(including an owner-operator) to appear for a test when called by a C/TPA (see 49 CFR
Part 40.241(a));
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Packet Pg. 1716 Attachment: FAA Collier County Drug & Alcohol Testing Protocol (28221 : FAA SETTLEMENT AGREEMENT)
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2. Fail to remain at the testing site until the testing process is complete; Provided, that an
employee who leaves the testing site before the testing process commences (see 49
CFR Part 40.243(a)) for a pre-employment test is not deemed to have refused to test;
3. Fail to provide an adequate amount of saliva or breath for any alcohol test required by
this part or DOT agency regulations; Provided, that an employee who does not provide
an adequate amount of breath or saliva because he or she has left the testing site before
the testing process commences (see 49 CFR Part 40.243(a)) for a pre-employment test
is not deemed to have refused to test;
4. Fail to provide a sufficient breath specimen, and the physician has determined, through
a required medical evaluation, that there was no adequate medical explanation for the
failure (see 49 CFR Part 40.265 (c));
5. Fail to undergo a medical examination or evaluation, as directed by the employer as part
of the insufficient breath procedures outlined at 49 CFR Part 40.265(c);
6. Fail to sign the certification at Step 2 of the ATF (see 49 CFR Part 40.241 (g) and 49
CFR Part 40.251(d)); or
7. Fail to cooperate with any part of the testing process.
Any covered employee who holds an airman certificate issued under 14 CFR Part 61, Part
63, or Part 65 and refuses to submit to required random, post-accident, reasonable
suspicion, or follow-up alcohol testing will be reported to the FAA’s Drug Abatement
Division.
The attendant consequences are described in the following section.
THE CONSEQUENCES FOR COVERED EMPLOYEES FOUND TO HAVE VIOLATED THE
PROHIBITIONS OF THE AMPP, INCLUDING THE REQUIREMENT THAT THE EMPLOYEE BE
REMOVED IMMEDIATELY FROM PERFORMING SAFETY-SENSITIVE FUNCTIONS, AND THE
PROCESS IN 49 CFR PART 40, SUBPART O:
Immediate Removal from Safety-Sensitive Functions
Covered employees are prohibited from performing safety-sensitive functions if they have
engaged in prohibited conduct under the FAA rule or another DOT agency’s alcohol misuse
rule (including refusal to submit to random, reasonable suspicion, post-accident, or follow-up
testing). Any employee who has violated the rules of the AMPP will be immediately removed
from performing safety-sensitive functions.
Permanent Prohibition from Service
If a covered employee is determined to have violated the on-duty use of alcohol prohibition,
he or she is permanently precluded from performing the safety-sensitive duties he or she
performed before such a violation.
If a covered employee is determined to have violated the prohibited alcohol-related conduct
provision, other than on-duty use, two times after the employee becomes subject to the
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Packet Pg. 1717 Attachment: FAA Collier County Drug & Alcohol Testing Protocol (28221 : FAA SETTLEMENT AGREEMENT)
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prohibitions, he or she is permanently precluded from performing the safety-sensitive duties
he or she performed before such a violation.
The bar on two-time violators will apply both to persons who go through rehabilitation and to
those who, after evaluation by an SAP, are determined not to need treatment.
Notice to the Federal Air Surgeon
Any covered employee who holds an airman medical certificate issued under 14 CFR Part
67 and violates the provisions of the rule will be reported to the Federal Air Surgeon.
No covered employee who holds a Part 67 airman medical certificate will perform a safety-
sensitive function after a violation unless and until, in addition to the required return-to-duty
steps in 49 CFR Part 40, the Federal Air Surgeon has recommended that the employee be
permitted to perform such duties.
Return-to-Duty Process and Follow-Up Procedures (49 CFR Part 40, Subpart O)
As an employee, when you have violated DOT drug and alcohol regulations, you cannot
again perform any DOT safety-sensitive duties for any employer until and unless you
complete the SAP evaluation, referral, and education/treatment process set forth in 49 CFR
Part 40, Subpart O and in applicable DOT agency regulations.
A verified positive DOT drug test result, a DOT alcohol test with a result indicating an
alcohol concentration of 0.04 or greater, a refusal to test (including by adulterating or
substituting a urine specimen) or any other violation of the prohibition on the use of alcohol
or drugs under a DOT agency regulation constitutes a DOT drug and alcohol regulation
violation.
An employer must provide to each employee (including an applicant or new employee) who
violates DOT drug and alcohol regulation a listing of SAPs readily available to the employee
and acceptable to the employer. The list of SAPs must include names, addresses, and
telephone numbers. The employer cannot charge the employee any fee for compiling or
providing this list.
An employer is not required to provide a SAP evaluation or any subsequent recommended
education or treatment for an employee who has violated a DOT drug and alcohol
regulation. However, if an employer offers that employee an opportunity to return to a DOT
safety-sensitive duty following a violation, the employer must, before the employee again
performs that duty, ensure that the employee receives an evaluation by a SAP meeting the
requirements of 40.281 and that the employee successfully complies with the SAPs
evaluation recommendations. Payment for SAP evaluations and services is left for
employers and employees to decide and may be governed by existing management-labor
agreements and health care benefits.
A SAP is charged with:
1. Making a face-to-face clinical assessment and evaluation to determine what assistance
is needed by the employee to resolve problems associated with alcohol and/or drug use;
2. Referring the employee to an appropriate education and/or treatment program;
16.F.10.b
Packet Pg. 1718 Attachment: FAA Collier County Drug & Alcohol Testing Protocol (28221 : FAA SETTLEMENT AGREEMENT)
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3. Conducting a face-to-face follow-up evaluation to determine if the employee has actively
participated in the education and/or treatment program and has demonstrated
successful compliance with the initial assessment and evaluation recommendations;
4. Providing the DER with a follow-up drug and/or alcohol testing plan for the employee;
and
5. Providing the employee and employer with recommendations for continuing education
and/or treatment.
If an employer decides to permit the employee to return to the performance of safety-
sensitive functions, the employer must ensure that the employee takes a return-to-duty test.
This test cannot occur until:
1. The employee has been evaluated by a SAP to determine what education and/or
treatment the employee needs to resolve problems related to alcohol use. A minimum of
education is required;
2. The employee has successfully complied with the prescribed education and/or
treatment;
3. The employee has been re-evaluated by the SAP to ensure that the employee has
properly followed the education and/or treatment program.
A SAP must establish a written follow-up testing plan for each employee who has committed
a DOT drug or alcohol regulation violation and who seeks to resume the performance of
safety-sensitive functions. The SAP does not establish this plan until after it is determined
that the employee has successfully complied with the education and/or treatment
recommendations. The SAP must present a copy of the follow-up testing plan directly to the
employer’s designated representative. The SAP is the sole determiner of the number and
frequency of follow-up tests and whether these tests will be for drugs, alcohol, or both,
unless otherwise directed by the appropriate DOT agency regulation. For example, if the
employee had a positive drug test, but the SAP evaluation or the treatment program
professionals determined that the employee had an alcohol problem as well, the SAP
should require that the employee have follow-up tests for both drugs and alcohol. However,
the SAP must, at a minimum, direct that the employee be subject to six (6) unannounced
follow-up tests in the first 12 months of safety-sensitive duty following the employee’s return
to safety-sensitive functions. The SAP may require a greater number of follow-up tests
during the first 12-month period of safety-sensitive duty. The SAP may also require follow-
up tests during the 48 months of safety-sensitive duty following this first 12-month period.
The SAP is not to establish the actual dates for the follow-up tests he/she prescribes. The
decision on specific dates to test is the employer’s. An employer must not impose additional
testing requirements (e.g., under company authority) on the employee that go beyond the
SAP’s follow-up testing plan.
16.F.10.b
Packet Pg. 1719 Attachment: FAA Collier County Drug & Alcohol Testing Protocol (28221 : FAA SETTLEMENT AGREEMENT)
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THE CONSEQUENCES FOR COVERED EMPLOYEES FOUND TO HAVE AN ALCOHOL
CONCENTRATION OF 0.02 OR GREATER BUT LESS THAN 0.04
If a covered employee is found to have an alcohol concentration of 0.02 or greater but less
than 0.04, that employee will be immediately removed from performing safety-sensitive
functions, until the employee is retested with a result below 0.02, or until the start of the
employee’s next regularly scheduled duty period, if it occurs at least 8 hours following
administration of the test.
16.F.10.b
Packet Pg. 1720 Attachment: FAA Collier County Drug & Alcohol Testing Protocol (28221 : FAA SETTLEMENT AGREEMENT)
25
DOT / FAA
CHECKLIST: New Hire/Transfer for Safety-Sensitive Position
Note: The Department of Transportation (DOT) and Federal Aviation Administration (FAA) drug and alcohol testing regulations (49 CFR part 40
and 14 CFR part 120) require specific steps to take when hiring any individual for or transferring any employee into a safety-sensitive position.
For more information, visit www.faa.gov/go/drugabatement.
GENERAL INFORMATION
Applicant/Employee’s Name/ID or SSN:
Safety-Sensitive Position:
ACTION CHECKLIST
Notified applicant/employee of requirement to undergo pre-employment testing for the presence of marijuana, cocaine,
opioids, phencyclidine (PCP), and amphetamines.
Date Notified:
Asked applicant/employee if they ever tested positive or refused a pre-employment drug or alcohol test administered by a DOT-
regulated employer in the past two years, as required by 49 CFR § 40.25(j).
Date Asked:
Notified applicant/employee to report for DOT pre-employment drug and alcohol (optional) test.
Date Notified:
Received Medical Review Officer verified negative DOT pre-employment drug and alcohol (optional) test result.
Date Received:
Sent Release of Information Form(s) to former employer(s), as required by 49 CFR § 40.25 or PRIA.
Employer: Date Sent: Date Received:
Employer: Date Sent: Date Received:
Employer: Date Sent: Date Received:
Hired/Transferred employee into DOT safety-sensitive function.
Date Hired/Transferred:
Added new safety-sensitive employee to the DOT random pool. Date Added:
Completed and documented Employee Drug and Alcohol Training and distributed drug and alcohol informational and
educational materials.
Date Completed:
Copy of all pre-employment documents and results received by Director of Flight Operation and/or Director of Maintenance.
Name and Signature of Official Completing Form:
Comments/Additional Information:
16.F.10.b
Packet Pg. 1721 Attachment: FAA Collier County Drug & Alcohol Testing Protocol (28221 : FAA SETTLEMENT AGREEMENT)
26
DOT/FAA Pre-Employment Acknowledgement
I understand and acknowledge that I will be required to undergo a DOT/FAA pre-employment drug test for
the following prohibited drugs (as defined in 49 CFR § 40.3) prior to being hired or transferred into a
Department of Transportation (DOT) safety-sensitive position as defined in 14 CFR part 120 :
• Marijuana,
• Cocaine,
• Opioids,
• Phencyclidine (PCP), and
• Amphetamines
(Print Name)________________ (Signature)________________ (Date)____________
16.F.10.b
Packet Pg. 1722 Attachment: FAA Collier County Drug & Alcohol Testing Protocol (28221 : FAA SETTLEMENT AGREEMENT)
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DOT/FAA Drug & Alcohol Pre-Employment Notification
The Department of Transportation’s (DOT’s) Procedural regulation, 49 CFR part 40, § 40.25(j), requires an
employer to ask: Have you previously tested positive, or refused to test, on any pre-employment drug or
alcohol test administered by a DOT employer to which you applied and did not obtain employment?
NO If no, sign below.
YES If yes, did you successfully complete the DOT return-to-duty procedures described in 49 CFR
part 40, Subpart O, with a qualified Substance Abuse Professional (SAP), as well as the return-to-
duty and follow-up testing? Please indicate your response and explanation below:
YES; please explain:
(Print Name)________________ (Signature)________________ (Date)____________
16.F.10.b
Packet Pg. 1723 Attachment: FAA Collier County Drug & Alcohol Testing Protocol (28221 : FAA SETTLEMENT AGREEMENT)
28
FAA/Drug Abatement Division’s Suggested
“Release of Information Form -- 49 CFR Part 40 Drug and Alcohol Testing”
for Aviation Employers
Section I. To be completed by the new aviation employer, signed by the safety-sensitive employee, and transmitted to
the previous DOT-regulated employer:
Employee Printed or Typed Name:
Employee SS or ID Number:
I hereby authorize release of information from my Department of Transportation regulated drug and alcohol testing records by my previous employer, listed
in Section I-B, to the aviation employer listed in Section I-A. This release is in accordance with DOT regulation 49 CFR Part 40, § 40.25 and FAA regulation
14 CFR part 120. I understand that information to be released in Section II-A by my previous employer, is limited to the following DOT-regulated testing
items:
1. Alcohol tests with a result of 0.04 or higher;
2. Verified positive drug tests;
3. Refusals to be tested;
4. Other violations of DOT agency drug and alcohol testing regulations;
5. Information obtained from previous employers of a drug and alcohol rule violation;
6. Documentation, if any, of completion of the return-to-duty process following a rule violation.
Employee Signature: Date:
I-A.
New Aviation Employer Name:
Address:
Phone #:
Designated Employer Representative:
I-B.
Fax #:
Previous Employer Name:
Address:
Phone #:
Designated Employer Representative (if known):
Section II. To be completed by the previous employer and transmitted by mail or fax to the new employer:
II-A. While employed ~
1. Did the employee have alcohol tests with a result of 0.04 or higher? YES
2. Did the employee have verified positive drug tests? YES
3. Did the employee refuse to be tested? YES
4. Did the employee have other violations of DOT agency drug and
alcohol testing regulations? YES
5. Did a previous employer or the employee report a drug and alcohol rule
violation to you? YES
6. If you answered “yes” to any of the above items, did the
NO
NO
NO
NO
NO
employee complete the return-to-duty process? N/A YES NO
NOTE: If you answered “yes” to any of the above items, you must provide the records concerning the result, violation and/or return-
to-duty documentation (e.g., SAP report(s), follow-up testing results, etc.).
II-B.
Name and Title of person providing information in Section II-A:
Phone #: Date:
16.F.10.b
Packet Pg. 1724 Attachment: FAA Collier County Drug & Alcohol Testing Protocol (28221 : FAA SETTLEMENT AGREEMENT)