FAA Drug and Alcohol Violations: Understanding the DOT SAP Process

If you perform FAA safety-sensitive duties and have a drug or alcohol violation, you can’t return to those duties until you complete the DOT return-to-duty process with a qualified Substance Abuse Professional (SAP). That process includes an initial evaluation, the education or treatment your SAP recommends, a follow-up evaluation, a return-to-duty test and follow-up testing. If you hold an FAA medical certificate, completing the SAP process doesn’t restore it on its own. Proactive Wellness provides DOT SAP evaluations by secure video in New York, New Jersey, Georgia and Massachusetts.

Who the FAA rules cover

FAA drug and alcohol testing rules apply to employees of airlines, charter and air tour operators, repair stations and contract air traffic facilities who perform safety-sensitive functions (14 CFR Part 120). Those functions include:

• Flight crewmember and flight attendant duties
• Flight instruction and aircraft dispatch
• Aircraft maintenance and preventive maintenance
• Ground security coordination and aviation screening
• Air traffic control and operations control

Coverage depends on the duties you perform, not just your job title or employer. Many airport jobs, such as most ramp and baggage roles, are not FAA safety-sensitive.

What counts as a violation

• A verified positive drug test
• An alcohol test result of 0.04 or higher
• A refusal to test, which can include not showing up, leaving early or an adulterated or substituted specimen

After a violation, your employer must remove you from safety-sensitive duties and give you a list of qualified SAPs (49 CFR Part 40). Read more about why a refusal counts as a violation.

The FAA return-to-duty process, step by step

• Removal from duty. You stop all safety-sensitive aviation work.
• FAA reporting. If you hold an FAA medical certificate, the violation is reported to the FAA. Pilot violations are also entered in the Pilot Records Database.
• Initial SAP evaluation. A face-to-face clinical assessment, which we provide by secure video, with recommendations for education, treatment or both. See what happens at a SAP evaluation.
• Education or treatment. You complete every recommendation.
• Follow-up evaluation. You return to the same SAP, who confirms compliance and reports to your employer.
• Return-to-duty test. Your employer directs it. Drug results must be negative and alcohol below 0.02.
• Follow-up testing. At least six unannounced tests in your first 12 months back, and testing can continue for up to five years. Read about follow-up testing after return to duty.

Pilots and other medical certificate holders

If you hold an FAA medical certificate, completing the SAP process does not by itself restore it. You may also need FAA medical clearance before you can use your certificate again. Refusals to test by holders of pilot, mechanic and other FAA certificates are also reported to the FAA. Your SAP can explain how the two processes fit together, and our FAA SAP page has more detail.

A SAP evaluation is not therapy

The SAP process is a federal safety requirement with a specific job: deciding what education or treatment you need before returning to safety-sensitive work. It’s separate from voluntary therapy. Many people find counseling helpful during this time for stress, family strain or substance use concerns, and it can be arranged separately. Don’t assume an employee therapy benefit, such as Spring Health, covers a SAP evaluation.

What to do first

1. Stop safety-sensitive work and follow your employer’s instructions. Ask your Designated Employer Representative (DER) for the list of qualified SAPs.
2. Start your SAP intake promptly. The process can’t begin until your initial evaluation is complete.
3. Gather what you have. Your test result notice, your employer contact and any letters from the MRO or your employer.
4. If you hold an FAA medical certificate, plan for the medical side too. Ask your AME how FAA medical clearance works in your situation.
5. Get support for yourself and your family. A violation is stressful. Voluntary counseling, separate from the SAP process, can help.

Who pays for a SAP evaluation

Payment depends on your situation. Some employers or EAPs pay, and many people pay on their own. Proactive Wellness charges a $500 professional fee plus an $18.15 administrative fee ($518.15 total) for all professional SAP services: the initial evaluation, recommendation and report, the follow-up evaluation, the compliance report and the follow-up testing plan. Outside education or treatment, testing and third-party fees aren’t included. If your employer’s EAP is through Revive (formerly BHS), you might be eligible to have SAP services covered. Coverage is never assumed, so we’ll help you check.

Out of work? You can still complete the SAP process. Read completing the SAP process without an employer.

Keep reading

• FAA SAP evaluations and return-to-duty for aviation employees
• Can you do a DOT SAP evaluation online?
• How long does the DOT SAP process take?
• Pilot Mental Health: Stress, Fatigue and Seeking Confidential Support

Frequently asked questions