The FAA return to duty process is the first step in a structured path regulated by the Federal Aviation Administration (FAA) and the Department of Transportation (DOT) for aviation employees who have violated drug and alcohol testing regulations. Whether you’re a pilot, maintenance technician, flight attendant, or other employee in a safety-sensitive position, understanding this process is critical to regaining eligibility to work.
The return-to-duty process involves evaluation, treatment, testing, and long-term follow-up monitoring all under strict federal oversight. It ensures that aviation professionals are safe, sober, and compliant before they resume safety-sensitive functions, utilizing various resources to aid in their recovery.
What Steps Must I Take to Return to the Performance of Safety-Sensitive Functions After Violating the FAA’s Drug and Alcohol Testing Regulation?
If you’ve tested positive for drugs or alcohol, refused a test, or otherwise violated the FAA’s regulations, the process to return includes meeting all duty requirements :
- Initial Evaluation by a DOT-qualified Substance Abuse Professional (SAP)
- Completion of prescribed education and/or treatment
- Follow-up SAP evaluation to confirm compliance
- A Return-to-Duty test, which must be negative
- Enrollment in a Follow-Up Testing plan
You may not return to any safety-sensitive duties until these steps have been completed in full and documented.
What to Expect from the Return-to-Duty Process:
Initial Evaluation by a Qualified DOT-SAP
The journey begins with an evaluation by a DOT-qualified SAP and may be reviewed by a federal air surgeon who will assess the employee’s situation :
- Review the violation and medical history
- Determine whether you need treatment, education, or both
- Outline a plan that must be followed before you return to work
This evaluation must occur before any other steps are taken.
Completion of Recommended Program
Depending on the SAP’s assessment, you’ll be required to complete:
- A treatment program (e.g., counselling, outpatient/inpatient rehab)
- A prescribed education course about substance misuse and compliance
Documentation of successful completion is mandatory and reviewed in your follow-up evaluation.
Follow-Up Evaluation
Once your treatment or education is finished, the same SAP will:
- Reassess your compliance and readiness
- Confirm that you’ve successfully complied with all recommendations
- Provide written approval to proceed to the Return-to-Duty testing phase
Return-to-Duty Testing
To return to work, you must adhere to the alcohol policy and :
- Complete a directly observed drug and/or alcohol test
- Receive a negative result
- Provide documentation of SAP clearance
This test is your gateway back into safety-sensitive functions, and it must be conducted in full compliance with FAA and DOT rules.
Follow-Up Drug Testing
Even after returning to duty, you’ll be subject to a mandatory follow-up testing schedule, with examples provided of what to expect :
- At least six unannounced drug and/or alcohol tests in the first 12 months
- Duration of testing may extend up to 5 years
- All follow-up tests are directly observed
Failure to comply results in immediate removal from duties, which is an answer to the question of what happened and re-entry into the return-to-duty process.
Federal Aviation Administration Drug & Alcohol Testing Overview
The Federal Aviation Administration (FAA) enforces strict drug and alcohol testing rules for aviation employees in safety-sensitive positions. These regulations are guided by 49 CFR Part 40, the Department of Transportation (DOT) rule that outlines when and how testing must occur.
The goal is to maintain a drug-free aviation environment and ensure public safety. As such, testing is required in several scenarios — from hiring to post-incident assessments, including the return-to-duty process.
The FAA requires testing for both, as stipulated on the federal air surgeon’s dated documentation :
- Prohibited drugs: Marijuana (THC), cocaine, opioids, amphetamines, and PCP
- Alcohol misuse: Especially within 4 hours of duty or if alcohol concentration exceeds 0.04%
Different Types of DOT FAA Drug Tests
Understanding the types of drug and alcohol testing can help aviation employees prepare and remain in compliance. Each test serves a specific purpose:
Pre-Employment Testing
Before performing any safety-sensitive duties, applicants must pass a pre-employment drug test. A negative result is required before hiring.
💡 Note: Alcohol testing is not required pre-employment, but an employer may choose to include it under their alcohol testing program.
Post-Accident Testing
If an employee is involved in a qualifying accident, testing for both drugs and alcohol is required:
- Alcohol test: within 8 hours
- Drug test: within 32 hours
The Drug Abatement Division strictly enforces testing timelines.
Random Testing
Employees in safety-sensitive functions are subject to random drug and alcohol tests throughout the year. These tests, often overseen by service agents :
- Occur without warning
- Must be conducted during, before, or just after performing job duties
- Are tracked for compliance through your employer’s drug and alcohol testing program
Reasonable Suspicion Testing
Supervisors may initiate testing if there’s observable evidence of:
- Drug use (e.g., slurred speech, erratic behaviour)
- Alcohol use while on duty
These tests are based on documented behaviour and must be done immediately, along with appropriate forms.
Return-to-Duty Testing
Once you’ve completed the return-to-duty process, you must pass a return-to-duty drug test and/or alcohol test. This test is critical for reinstatement:
- Directly observed
- Conducted only after SAP clearance
- A condition for returning to any safety-sensitive position
Follow-Up Testing
Follow-up drug and alcohol testing is conducted after the return-to-duty test as part of the determination process. It’s:
- Random but scheduled over 12–60 months
- Always directly observed
- Mandated by the SAP as part of your follow-up testing plan
FAA Background Check & Screening
In addition to drug testing, the FAA requires a comprehensive background screening for employees in regulated positions. This check may include:
- Verification of previous employment in safety-sensitive roles
- Review of failed drug tests or prior SAP referrals
- Airman certification and medical review officer records
Employers must evaluate whether an applicant is eligible to begin or return to a safety-sensitive function based on these records.
Pre-Employment Drug Testing for FAA
Before an employee can begin FAA-regulated work, a pre-employment drug test must be:
- Scheduled through an authorized collection site
- Reviewed by a Medical Review Officer (MRO)
- Verified as negative
If a positive drug test is returned, the applicant is not permitted to begin work and may be referred to an SAP for a potential return to duty path in the future.
Why Choose AACS Counseling?
At AACS Counseling, we specialize in helping aviation employees navigate the complex requirements of the FAA return to duty process, especially when an airman medical certificate is involved. We offer:
- Access to DOT-qualified SAPs
- Personalized return-to-duty plans
- Support through treatment programs
- Coordination of return-to-duty and follow-up testing
- Guidance for compliance and FAA documentation
Whether you’re a first-time violator or re-entering the system, our certified team can help safety-sensitive employees get back on track — quickly, safely, and fully compliant.
Frequently Asked Questions
❓ Does a Failed FAA Drug Test Go on Your Record?
Yes. A failed FAA drug test is recorded in the FAA Drug Abatement Division database. It may be reported to the PRIA (Pilot Records Improvement Act) system or stored in your employer’s records. You must complete the return-to-duty process and follow-up testing before becoming eligible to return to a safety-sensitive position within the FAA guidelines.
❓ What Are the FAA Alcohol Regulations?
FAA regulations prohibit:
- Performing safety-sensitive duties within 4 hours of alcohol use
- Operating with a blood alcohol concentration (BAC) of 0.04% or higher
- Refusing a test during duty hours
Violating these rules triggers mandatory removal from duty and entry into the return-to-duty testing protocol.
❓ Do FAA Drug and Alcohol Regulations Apply to Flight Attendants?
Yes. Flight attendants are considered safety-sensitive employees under FAA regulations. They are subject to:
- Pre-employment and random drug testing
- Post-accident and reasonable suspicion testing
- Return-to-duty process if a violation occurs