FAA Part 120 Drug and Alcohol Testing Program

Last reviewed June 16, 2026 · By Chad Griffith

14 CFR Part 120 establishes the drug and alcohol testing program for safety-sensitive aviation employees, applying to Part 121 air carriers, Part 135 carriers, Part 145 repair stations (when performing safety-sensitive maintenance), Part 91 Subpart K fractional ownership operations, contractors performing covered functions, and certain air traffic control operations. The program covers six categories of testing (pre-employment, random, post-accident, reasonable suspicion, return-to-duty, and follow-up) and applies to seven safety-sensitive functions.

Safety-Sensitive Functions Covered

Per Section 120.105, drug and alcohol testing applies to employees performing: flight crewmember duties; flight attendant duties; flight instruction duties; aircraft dispatcher duties; aircraft maintenance and preventive maintenance; ground security coordinator duties; and aviation screening duties. Air traffic control specialists in air carrier facilities are also covered. Contractors performing these functions for covered employers are subject to the testing program.

Required Test Categories

Six categories: Pre-employment: before performing safety-sensitive function for the first time with the employer; Random: minimum annual percentage of safety-sensitive employees (50% drug, 25% alcohol annually for most aviation operators in 2026); Post-accident: within 32 hours of any accident or specific qualifying incident; Reasonable suspicion: based on supervisor observation of impairment indicators; Return-to-duty: required after a positive test, refusal, or DOT regulation violation; Follow-up: 6 unannounced tests in the first 12 months after return-to-duty plus additional tests at SAP recommendation up to 60 months.

Recordkeeping

Per Section 120.111, employers must retain: positive drug and alcohol test results, refusals, and SAP evaluations: 5 years; records pertaining to driver who fails the alcohol test: 5 years; negative test results: 1 year; random testing selection lists: 5 years (must show non-discriminatory selection process); blind specimen results: 1 year; employee training records: 3 years.

DER Responsibilities

Each Part 120 employer must designate a Drug and Alcohol Program Manager (DER, Designated Employer Representative) responsible for: receiving test results from the Medical Review Officer; managing the random selection process; coordinating return-to-duty processes; maintaining program records; and serving as the company contact for FAA program audits. DER training is required and must be retained as part of the employer's training records.

Recordkeeping and Audit Exposure

Part 120 requires employers to retain detailed drug and alcohol testing records: individual test results, the annual MIS (Management Information System) report, random-selection pool documentation, refusals, and return-to-duty and follow-up testing administered through a Substance Abuse Professional (SAP), plus the Designated Employer Representative (DER) decision trail. Retention ranges from one to five years depending on the record. Both Part 135 operators and Part 145 repair stations with safety-sensitive employees must comply.

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