Agency-Specific DOT Testing
FAA Drug Testing Requirements
What Aviation Workers & Urine Collectors Need to Know About 49 CFR Part 120
Quick Answer — FAA Drug Testing at a Glance
- ▸FAA authority: 49 CFR Part 120 — not Part 382 (FMCSA) or Part 219 (FRA). The Federal Aviation Administration has its own drug and alcohol program regulation for the aviation industry.
- ▸8 covered employee categories (§120.105): flight crewmembers, flight attendants, flight instructors, aircraft dispatchers, maintenance/preventive maintenance personnel, ground security coordinators, aviation screeners, and non-FAA air traffic controllers.
- ▸5 testing situations: pre-employment, random (§120.109), post-accident (§120.109(c)), reasonable cause/suspicion, and return-to-duty/follow-up.
- ▸FAA random rates (§120.109): 25% for drug testing / 10% for alcohol testing — same minimums as FMCSA, with the FAA Administrator authorized to raise rates.
- ▸§40.33 is the universal collector standard — no FAA-specific collector certification exists. A collector qualified for FMCSA is already qualified to serve aviation employers.
- ▸FAA uses the standard DOT 5-panel — same as FMCSA and FTA. Unlike FRA, FAA does not require an expanded 10-panel test.
When most people think of DOT drug testing, they think of CDL truck drivers — and FMCSA Part 382 dominates the industry conversation for good reason. But the Federal Aviation Administration runs an equally rigorous federally-mandated drug and alcohol testing program under 49 CFR Part 120, covering hundreds of thousands of aviation employees across airlines, airports, maintenance facilities, and air traffic control operations.
For DOT-certified urine collectors, aviation employers represent an entirely separate client base that opens up when you have your §40.33 qualification — and no additional credential is required. This guide covers who is covered by FAA testing, what the random rates are, how post-accident testing works under §120.109(c), and exactly how collector certification applies in the aviation context.
FAA vs. FMCSA Drug Testing — Key Differences
Both FAA and FMCSA fall under the DOT umbrella and use the same collection procedure (49 CFR Part 40) — but their agency-specific regulations differ in several important ways collectors and employers need to understand.
Aviation workers in 8 safety-sensitive categories (§120.105) — flight crew, maintenance, air traffic controllers, screeners, dispatchers, and others. Regulated under 49 CFR Part 120.
CDL drivers operating commercial motor vehicles (CMVs) with a GVWR over 26,000 lbs, hazmat vehicles, or vehicles carrying 16+ passengers. Regulated under 49 CFR Part 382.
25% drugs / 10% alcohol — §120.109 minimum rates. FAA Administrator authorized to raise rates. Aviation safety-critical workforce driving high compliance standards.
50% drugs / 10% alcohol — §382.305 minimum rates. FMCSA drug random rate is set higher at 50% to reflect the high volume of CDL drivers on public roads.
49 CFR Part 120 — standard DOT 5-panel (§40.85). FAA does not expand the panel beyond the five DOT-standard substances. Same panel as FMCSA and FTA.
49 CFR Part 382 — standard DOT 5-panel (§40.85). THC, cocaine, opioids, phencyclidine, and amphetamines. Same panel as FAA.
FAA Covered Employee Categories — §120.105 & §120.215
FAA drug and alcohol testing applies to employees who perform safety-sensitive functions as defined in §120.105 (drug testing) and §120.215 (alcohol testing). Eight specific categories are covered — if an employee performs any of these functions, they are subject to the full testing program.
Flight Crewmembers
Pilots and co-pilots responsible for the operation of aircraft. The highest safety-criticality category — direct control of aircraft with hundreds of passengers.
§120.105(a)(1)Flight Attendants
Cabin crew members responsible for passenger safety and emergency procedures aboard aircraft. Subject to the full anti-drug program requirements.
§120.105(a)(2)Flight Instructors
Instructors who provide flight instruction in aircraft or in flight simulators. Covered when performing flight instruction as a safety-sensitive function.
§120.105(a)(3)Aircraft Dispatchers
Dispatch and flight-release personnel who share flight authority with pilots and are responsible for pre-flight planning, fuel loads, and weather analysis.
§120.105(a)(4)Aircraft Maintenance Personnel
Mechanics and preventive maintenance personnel who perform or directly supervise maintenance functions on aircraft. A single error in maintenance creates catastrophic risk.
§120.105(a)(5)Ground Security Coordinators
Personnel who implement and oversee ground security programs at airports — responsible for aircraft and terminal security operations.
§120.105(a)(6)Aviation Screeners
Security screeners who perform screening of persons and property. Covered under the FAA anti-drug program for security-sensitive screening functions.
§120.105(a)(7)Air Traffic Controllers (Non-FAA)
Non-federal air traffic controllers at contract towers and private facilities. FAA air traffic controllers employed directly by the FAA are covered under a separate NATCA program.
§120.105(a)(8)FAA Random Testing Rates — §120.109
Under §120.109, FAA-regulated employers must conduct random drug testing at a minimum annual rate of 25% of their covered employee workforce, and random alcohol testing at a minimum rate of 10%. These are floor rates — the FAA Administrator is authorized to adjust rates upward based on industry-wide violation data and safety conditions.
All employees in covered safety-sensitive function categories are placed into a random selection pool. Selections must be made using a scientifically random method — every covered employee has an equal statistical chance of selection in any given selection period. Employees receive no advance notice before a random test.
FAA Post-Accident Testing — §120.109(c)
Post-accident testing under the FAA program is divided into two tiers based on whether the accident involved a fatality. The trigger criteria differ significantly from FMCSA's citation-based framework and from FRA's property damage threshold.
§120.109(c) Post-Accident Trigger Criteria
Fatality Involved
When an aircraft accident results in a human fatality, post-accident drug and alcohol testing is mandatory for all covered employees whose performance could have contributed to the accident. No supervisory discretion — testing must occur.
Performance-Contributing Factors
For non-fatal accidents, post-accident testing is discretionary based on whether the employer determines there is reasonable cause to believe covered employee performance may have contributed to the accident. Supervisory judgment applies — but the standard must be documented.
Collection Windows
Alcohol collection must be attempted within 2 hours of the accident. If not completed, the employer must document why and continue attempting for up to 8 hours. After 8 hours, attempts must cease and the reason must be documented.
Drug specimen collection must be completed within 32 hours of the accident. After 32 hours, the employer must document the reason and cease attempts — the drug test cannot be conducted after this window closes.
Post-Accident Timing Is Unforgiving — Use a Qualified Collector
With a 2-hour alcohol window and a 32-hour drug window, aviation employers cannot afford to search for an uncertified site. A specimen collected by a non-§40.33-qualified collector may be deemed invalid — and an invalid post-accident specimen carries the same legal exposure as a missed collection. The employer's anti-drug program records must show a qualified collector conducted the collection.
FAA 5-Panel Drug Test — Substances & Cutoff Levels
Unlike the FRA — which requires a 10-panel expanded test — the FAA uses the standard DOT 5-panel drug test defined in 49 CFR §40.85. The collection procedure is identical to any DOT urine collection: urine specimen, Federal Custody and Control Form (CCF), and §40.91 specimen integrity checks.
Initial cutoffs are per §40.85; confirmation (GC/MS) cutoffs are per §40.87.
| Substance | Initial Cutoff (§40.85) | Confirmation Cutoff (§40.87) | Aviation Relevance |
|---|---|---|---|
| Marijuana (THC) | 50 ng/mL | 15 ng/mL | Impairs judgment and spatial awareness — critical risks for pilots, controllers, and maintenance personnel. |
| Cocaine | 150 ng/mL | 100 ng/mL | Creates overconfidence and impairs decision-making — a direct hazard in aircraft operations and air traffic control. |
| Amphetamines / Methamphetamines | 500 ng/mL | 250 ng/mL | Stimulants that alter risk assessment and attention — incompatible with safety-critical aviation functions. |
| Opioids (Heroin / Morphine / Codeine) | 2,000 ng/mL | 2,000 ng/mL | Sedation and slowed reaction time are an unacceptable risk for flight crew, maintenance, and air traffic roles. |
| Phencyclidine (PCP) | 25 ng/mL | 25 ng/mL | Causes severe perceptual distortion and impaired reality testing — extreme risk in any aviation safety function. |
The FAA uses the same DOT 5-panel as FMCSA and FTA — not the 10-panel expanded panel required by FRA for railroad workers.
One §40.33 Collector Certificate Works for Every DOT Agency — Including FAA, FRA, FMCSA, FTA, and PHMSA
Aviation, trucking, railroad, transit, pipeline — §40.33 is the single federal standard. Cedar & Crown's $99 course certifies you to collect for all of them.
Get Certified for $99§40.33 Is the Collector Standard — No FAA-Specific Cert Exists
Even though FAA drug testing is governed by 49 CFR Part 120, the actual urine collection procedure is still controlled by 49 CFR Part 40 — the universal DOT collection regulation that applies across all five DOT agencies. This means:
- ✓The same Federal Custody and Control Form (CCF) is used for FAA aviation collections
- ✓The same §40.91 specimen integrity checks (temperature range, color, clarity) apply
- ✓The same §40.33 collector qualification and training requirements are mandatory
- ✓The same chain-of-custody procedures govern every specimen from collection to SAMHSA-certified lab
A Collector Certified for Trucking Is Already Qualified for Aviation
There is no "FAA-specific" collector certification — §40.33 is the universal DOT collector standard across all agencies. A Cedar & Crown-certified collector who has been conducting FMCSA-covered CDL driver collections is already fully qualified to serve aviation employers: airlines, charter operators, aircraft maintenance facilities, and contract air traffic control towers. Aviation employers cannot use a non-certified collector for Part 120-required tests without risking FAA Drug Abatement Division enforcement action.
The FAA Drug Abatement Division (DAD) — §120.117 Oversight
The FAA Drug Abatement Division (DAD) is the internal FAA unit responsible for overseeing anti-drug and anti-alcohol misuse program compliance across the aviation industry. Unlike FMCSA, which uses compliance reviews and SMS data to monitor trucking carriers, the FAA DAD has direct oversight authority over certificate holders' testing programs.
Employer Compliance Program Requirements
- ▸Maintain a written anti-drug program meeting §120.103 standards
- ▸Designate an Employer Representative (DER) responsible for testing compliance
- ▸Use only SAMHSA-certified laboratories for specimen analysis
- ▸Retain collection and test result records per §120.117(e) retention schedules
How Collectors Interface with Aviation Employers
- ▸Collections are ordered by the DER or C/TPA on behalf of the aviation employer
- ▸Collectors must use the Federal CCF form and document the collection per §40.61–103
- ▸All specimens go to a SAMHSA-certified lab — same pipeline as FMCSA specimens
- ▸MRO reviews all non-negative results before reporting to the DER
Frequently Asked Questions — FAA Drug Testing
Do FAA employees need a special drug test different from other DOT tests?+
What happens if an FAA-covered employee refuses a drug test?+
Can a DOT collector certified for trucking employers also collect for FAA-covered employers?+
What are the FAA random drug testing rates?+
Does the FAA test for more drugs than other DOT agencies?+
Ready to Collect for FAA and Every Other DOT Agency?
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