Per 49 CFR §120.7 (Drug and alcohol testing program — required), every FAA-regulated aviation employer — Part 121 air carrier, Part 135 charter operator, Part 145 repair station, Part 91 Subpart K fractional operator, and certain Part 91 commercial operators — must establish and implement an anti-drug and alcohol misuse prevention program that meets the requirements of 49 CFR Part 120 and 49 CFR Part 40. The §120.7 program must include a written policy statement distributed to every safety-sensitive employee describing prohibited conduct, testing circumstances, consequences, and BAT/STT/MRO/SAP contact information; a designated Drug Abatement Program Manager (DAPM); contracts with an HHS-certified laboratory and a qualified Medical Review Officer (MRO); supervisor training on substance abuse and alcohol misuse symptoms; and (in most cases) participation in a consortium / third-party administrator (C/TPA) that manages the random selection draw. Per §120.17, specimen collection and testing procedures proceed under Part 40 by reference. Per §120.105, each employer must conduct pre-employment, random (25% annualized drug rate), post-accident, reasonable cause, return-to-duty, and follow-up drug testing on covered safety-sensitive employees (flight crewmembers, flight attendants, flight instructors, aircraft dispatchers, aircraft maintenance personnel, ground security coordinators, aviation screeners, air traffic control specialists). Per §120.215, each employer must conduct random (10% annualized alcohol rate), post-accident (8-hour window), reasonable suspicion, return-to-duty, and follow-up alcohol testing using STTs/BATs and EBT devices on the NHTSA Conforming Products List. Civil penalties under 49 U.S.C. § 46301 reach $37,377 per violation in 2026 (inflation-adjusted annually under the Federal Civil Penalties Inflation Adjustment Act).
The §120.7 program management + §120.105 drug testing + §120.215 alcohol testing + Part 40 procedural chain + §120.7 graduated retention schedule is the most operator-distinct records-side compliance surface in aviation — and the records-side version of that chain is the spine of every FAA Drug Abatement Division (AAM-800) audit request. The Drug Abatement Program Manager walks the §120.7 written policy distribution + DAPM designation + lab + MRO + C/TPA service agreement chain; the Director of Operations walks the §120.105 pre-employment + random + post-accident + reasonable cause + return-to-duty + follow-up test chain for flight crewmembers, flight attendants, dispatchers, and flight instructors; the Director of Maintenance walks the §120.105 chain for aircraft maintenance personnel and aircraft preventive maintenance personnel; the Chief Inspector walks the §120.215 alcohol testing chain across the safety-sensitive population; and the FAA AAM-800 inspector walks every one of those chains against the §120.7 graduated retention schedule. The most common records-layer finding is not a missing certificate — it is a §120.7 retention chain that broke during a system migration, a §120.107 25% random rate that fell short for the calendar year, a §120.105 post-accident test that was not collected within the §120.111 32-hour window, or an SAP follow-up testing plan record incomplete at FAA AAM-800 audit.
Important distinction: 49 CFR Part 120 is the FAA-regulated aviation drug & alcohol testing program. 49 CFR Part 382 is the FMCSA-regulated CDL driver drug & alcohol testing program — a parallel scheme with the same Part 40 procedural backbone but a distinct random selection pool, a distinct employer enforcement agency, and distinct post-accident criteria. A Part 145 repair station that also operates a commercial trucking fleet for parts delivery or AOG response may be subject to BOTH Part 120 (for aviation maintenance personnel) AND Part 382 (for CDL drivers) — under entirely separate random pools, separate consortium memberships, and separate audit jurisdictions (FAA AAM-800 vs FMCSA Office of Field Operations). For the FMCSA-side analog of this guide, see our DOT drug testing software guide covering 49 CFR Part 382. This guide covers 49 CFR Part 120 (FAA aviation D&A) specifically — buyers searching for the FAA-regulated program should bookmark this page, and buyers searching for the FMCSA-regulated program should reference the Part 382 guide.
The platforms ranked below split between bundled DOT compliance + D&A vendors (Foley Carrier Services, CarrierShield) that cover Part 120 + Part 382 + Part 199 + USCG D&A simultaneously under a per-employee + base subscription model; C/TPA + recordkeeping vendors (National Drug Testing, Drug-Free Compliance) that bundle the random selection draw + consortium pool + MRO contract + collection site network with the recordkeeping platform; aviation operations platforms with a bundled D&A module (ATP CTS); paper / spreadsheet / manual programs that carry hidden labor cost and asymmetric audit downside; and the self-serve records-side document compliance layer that FileFlo provides at $299/month flat — purchased on the website without a sales call, designed to live alongside the C/TPA + lab + MRO stack rather than replace it. The bundled platforms deliver multi-segment DOT D&A coverage or integrated C/TPA + lab + MRO service — but per-employee pricing scales with the safety-sensitive employee count and public pricing is not published.
Primary regulations cited in this guide: 49 CFR Part 120 (Drug and Alcohol Testing Program — FAA), 49 CFR §120.7 (Drug and alcohol testing program — required), 49 CFR §120.17 (Testing procedures), 49 CFR §120.105 (Drug testing — required tests), 49 CFR §120.215 (Alcohol testing — required tests), 49 CFR Part 40 (Transportation workplace D&A procedures), and 49 U.S.C. § 46301 (FAA civil penalties).
A §120.7 retention chain break plus a §120.107 25% random rate shortfall is two records-side failures stacked on the same FAA AAM-800 audit binder — and certificate action under Part 67 / Part 61 is the asymmetric downside on top of the civil penalty
The §120.7 written policy distribution, DAPM designation, lab + MRO + C/TPA service agreement, supervisor training, EAP referral; the §120.105 pre-employment + §120.107 25% random + §120.111 32-hour post-accident + reasonable cause + return-to-duty + §120.113 follow-up drug testing; the §120.215 + §120.217 10% random + §120.219 8-hour post-accident + reasonable suspicion + return-to-duty + follow-up alcohol testing; the Part 40 specimen collection + lab confirmation + MRO verification + SAP referral + STT/BAT/EBT procedural records; and the §120.7 graduated retention schedule (5-year positive, 1-year negative, 2-year random, 5-year EAP, 2-year training) form a single pre-audit records-side surface. An FAA AAM-800 finding under §120.7, §120.107, §120.111, §120.215, §120.217, or §120.219 is almost never a missing record — it is a §120.7 5-year retention chain that broke during a system migration, a §120.107 25% drug random rate that fell short for the calendar year, a §120.111 32-hour post-accident drug window that closed without a documented decision memo, or an SAP follow-up testing plan record incomplete at AAM-800 audit. The certificate action exposure compounds the civil penalty: a §120.105 verified positive result triggers immediate removal from safety-sensitive function and may trigger Part 67 medical certificate action for an airman or Part 61 airman certificate action. Records-side compliance software that enforces the §120.7 + §120.105 + §120.215 + Part 40 chain structurally is the only defense that scales across every safety-sensitive employee and every audit cycle.
The 7 Best Aviation Drug & Alcohol Testing Program Platforms
Ranked by §120.7 program management coverage (written policy distribution, DAPM designation, lab + MRO + C/TPA contracts, supervisor training, EAP), §120.17 testing procedures, §120.105 drug testing categories + §120.107 25% random rate + §120.111 32-hour post-accident, §120.215 alcohol testing categories + §120.217 10% random rate + §120.219 8-hour post-accident, 49 CFR Part 40 procedural chain (Part 40 Subpart D/F/G/M/O), §120.7 graduated retention schedule, sales motion (self-serve vs C/TPA-bundled vs per-employee bundled), and the pre-audit records package the FAA Drug Abatement Division (AAM-800) requests.
FileFlo
Top Pick — Best Self-Serve Records-Side Document Layer for 49 CFR Part 120Best For
Part 121, Part 135, Part 145, and Part 91 Subpart K aviation employers under 49 CFR Part 120 that need a §120.7 written policy distribution + DAPM designation + lab + MRO + C/TPA contract + §120.105 drug testing + §120.215 alcohol testing + SAP referral + return-to-duty + follow-up + supervisor training + §120.7 graduated retention pre-audit records-side index — purchased on the website without a sales call, alongside a C/TPA already managing random selection draws
Key Feature
AI document classification — upload any §120.7 written policy distribution, DAPM designation memo, HHS-certified lab contract, MRO contract, C/TPA service agreement, §120.105 pre-employment / random / post-accident / reasonable cause / return-to-duty / follow-up test record, §120.215 alcohol screening / confirmation test record, §120.111 post-accident decision memo, §120.219 post-accident decision memo, SAP referral, SAP evaluation summary, return-to-duty completion record, follow-up testing plan, supervisor training certificate (substance abuse + alcohol misuse), or BAT/STT/MRO credential renewal and FileFlo files it against the correct §120.7 / §120.17 / §120.105 / §120.107 / §120.111 / §120.215 / §120.217 / §120.219 / Part 40 paragraph and §120.7 retention clock automatically
Records Focus
49 CFR §120.7 program management (written policy distribution, DAPM designation, lab + MRO + C/TPA contracts, supervisor training, EAP), §120.17 testing procedures, §120.105 drug testing categories + §120.107 25% random rate + §120.111 32-hour post-accident window, §120.215 alcohol testing categories + §120.217 10% random rate + §120.219 8-hour post-accident window, Part 40 specimen collection + MRO + SAP + STT/BAT/EBT procedural chain, §120.7 graduated retention schedule (5-year positive, 1-year negative, 2-year random, 5-year EAP, 2-year training), one-click FAA AAM-800 Drug Abatement Division audit binder
Strengths
- AI document parsing — every uploaded §120.105 test record, §120.215 test record, MRO verification, SAP referral, return-to-duty completion record, follow-up plan, or supervisor training certificate classified against the correct §120.7 / §120.105 / §120.107 / §120.111 / §120.215 / §120.217 / §120.219 / Part 40 paragraph and retention clock
- §120.7 written policy distribution tracking — written policy + DAPM designation + lab + MRO + C/TPA service agreement + EAP referral records enforced structurally
- §120.105 drug testing program enforcement — pre-employment, §120.107 25% random selection draws, §120.111 32-hour post-accident, reasonable cause, return-to-duty, and §120.113 follow-up testing plans against the SAP report
- §120.215 alcohol testing program enforcement — §120.217 10% random selection draws, §120.219 8-hour post-accident, reasonable suspicion, return-to-duty + follow-up testing tracked against STT/BAT credentials and EBT serial numbers
- Part 40 procedural chain enforcement — CCF + ATF + chain-of-custody + lab confirmation + MRO verification + SAP referral + return-to-duty completion records inventoried against the Part 40 Subpart D/F/G/M/O timeline
- §120.7 graduated retention schedule enforcement — 5-year positive test, 1-year negative test, 2-year random selection, 5-year EAP, 2-year supervisor training retention clocks all surfaced before lapse
- Pre-audit single-view check — §120.7 program records + §120.105 drug testing + §120.215 alcohol testing + Part 40 procedural records + SAP records + return-to-duty + supervisor training all displayed in one click for FAA AAM-800 audit binder request
- One-click FAA Drug Abatement Division (AAM-800) audit-defensible binder — complete audit packet in under 60 seconds
- $299/mo flat regardless of safety-sensitive employee count or aviation segment (Part 121 / 135 / 145 / 91K) — no per-employee fees
- 5-day free trial, no credit card, no sales call, no multi-year contract — purchased on the website
- Designed to live alongside the C/TPA managing random selection draws and the MRO contract, not replace them
Limitations
- Not a C/TPA — does not perform random selection draws or manage the consortium pool (pair with National Drug Testing, Drug-Free Compliance, or other DOT-registered C/TPA for the random selection draw service)
- Not an HHS-certified laboratory or MRO service — does not perform specimen analysis or MRO verification (pair with HHS-certified lab + MRO contract for those Part 40 procedural services)
- Not a collection site network — does not perform §120.17 specimen collection or §120.215 alcohol testing in person (pair with collection site network for in-person collections)
Our take: FileFlo is the self-serve records-side document compliance complement to the C/TPA + HHS-certified lab + MRO stack already in place at most Part 121, Part 135, Part 145, and Part 91K aviation employers: it inventories every §120.7 written policy distribution, every DAPM designation, every lab + MRO + C/TPA contract revision, every §120.105 pre-employment / random / post-accident / reasonable cause / return-to-duty / follow-up drug test record, every §120.215 alcohol screening + confirmation test record, every SAP referral + evaluation + return-to-duty completion, every follow-up testing plan, every supervisor training certificate, and every Part 40 procedural artifact in a single pre-audit index — tying each entry back to the specific §120.7, §120.17, §120.105, §120.107, §120.111, §120.215, §120.217, §120.219, or Part 40 paragraph that governs it. For aviation operators whose primary records-side risk is a §120.7 retention chain that broke during a system migration, a §120.107 25% random rate that fell short for the calendar year, a §120.105 post-accident test that was not collected within the §120.111 32-hour window, or an SAP follow-up testing plan record incomplete at FAA AAM-800 audit — not the random selection draw itself — FileFlo fills the §120.7 + §120.105 + §120.215 + Part 40 records-side gap at a self-serve flat rate that complements the C/TPA + lab + MRO stack.
Foley Carrier Services
Bundled Aviation D&A Module + DOT + FMCSA Cross-Segment ComplianceBest For
Multi-segment operators (aviation maintenance + FMCSA CDL trucking + USCG marine) that need a single bundled compliance platform covering Part 120 + Part 382 + Part 199 + USCG D&A simultaneously, alongside MVR + CDL + DOT driver qualification + IFTA + IRP services — public pricing is sales-led and gated behind a discovery call
Key Feature
Bundled DOT compliance platform with Part 120 aviation D&A module, Part 382 FMCSA D&A module, CDL driver qualification file, MVR monitoring, IFTA + IRP filing, and CSA score monitoring — built for multi-segment commercial operators that need a single vendor across aviation + trucking + marine
Records Focus
Bundled Part 120 + Part 382 + Part 199 + USCG D&A program management with C/TPA service, random selection draws, MRO contract, supervisor training tracking; cross-segment DOT driver qualification + MVR + IFTA + IRP coverage for mixed aviation + CDL operators
Strengths
- Bundled multi-segment DOT D&A platform across Part 120 (FAA) + Part 382 (FMCSA) + Part 199 (FRA) + USCG with single C/TPA pool and single MRO contract
- Integrated CDL driver qualification file + MVR monitoring + IFTA + IRP filing for mixed aviation + trucking employers
- Established commercial DOT compliance services pedigree with national C/TPA reach
- Single-vendor relationship across multiple DOT-regulated segments simplifies procurement for multi-segment operators
- CSA score monitoring + FMCSA Clearinghouse integration for the trucking-side employee population
Limitations
- Per-employee pricing on top of base subscription scales linearly with safety-sensitive employee count — costs rise with each new Part 145 mechanic or Part 121 flight attendant added to the program
- Public pricing is not published — sales-led discovery call required before quote
- Bundled platform breadth (aviation + trucking + marine + IFTA + IRP) trades depth in any single segment for breadth across all
- AI document classification is not the primary workflow — records management is largely operator-managed
- Aviation-specific §120.7 / §120.105 / §120.215 / Part 40 records-side audit binder export workflow is bundled with broader DOT D&A reporting, not the single-purpose primary deliverable
Our take: Foley Carrier Services is the established bundled multi-segment DOT compliance + D&A platform for operators that need Part 120 (aviation) + Part 382 (FMCSA) + Part 199 (FRA) + USCG D&A coverage under one vendor with one C/TPA pool and one MRO contract. For a multi-segment commercial operator with mixed aviation + CDL trucking + marine safety-sensitive populations, the bundled model is the procurement simplification advantage. For aviation-only operators that want a self-serve records-side §120.7 + §120.105 + §120.215 + Part 40 records-side index purchased on the website without a per-employee pricing dimension, FileFlo is the complementary records-side layer alongside the operator-managed C/TPA + MRO stack.
CarrierShield
DOT Compliance + D&A Module for Aviation + Trucking Cross-Segment OperatorsBest For
Cross-segment operators with safety-sensitive populations under both Part 120 (FAA) and Part 382 (FMCSA) that need a single platform managing driver qualification, MVR monitoring, D&A C/TPA, and supervisor training across aviation + commercial trucking workflows — most often a Part 145 repair station that also operates a commercial trucking fleet for parts delivery, ferry, or AOG response
Key Feature
Bundled DOT compliance platform with Part 120 + Part 382 D&A program management, CDL driver qualification file, MVR monitoring, and supervisor training tracking — multi-segment coverage for operators with both aviation safety-sensitive employees and CDL drivers
Records Focus
Bundled Part 120 + Part 382 D&A program management with random selection draws, MRO contract, supervisor training, and SAP referral tracking; cross-segment DOT driver qualification + MVR monitoring for operators with both aviation maintenance + CDL drivers
Strengths
- Bundled Part 120 + Part 382 D&A program management with single C/TPA pool and single MRO contract
- Integrated CDL driver qualification file + MVR monitoring for the trucking-side employee population
- Supervisor training tracking aligned with both §120.115 (aviation supervisor training) and §382.601 (FMCSA supervisor training) requirements
- Cross-segment DOT compliance procurement simplification for mixed aviation + CDL operators
Limitations
- Per-employee pricing scales linearly with safety-sensitive employee count
- Public pricing is not published — sales-led discovery call required
- Bundled DOT compliance breadth trades depth in the aviation-specific §120.7 / §120.105 / §120.215 / Part 40 records-side workflow
- AI document classification is not the primary workflow
- Aviation-specific FAA AAM-800 audit binder is bundled with broader DOT D&A reporting, not the single-purpose primary deliverable
Our take: CarrierShield is a bundled multi-segment DOT compliance + D&A platform for cross-segment operators with both Part 120 aviation and Part 382 FMCSA safety-sensitive populations. For a Part 145 repair station with a commercial trucking fleet, the bundled model is the procurement simplification advantage. For aviation-only operators or operators that want a self-serve records-side §120.7 + §120.105 + §120.215 + Part 40 records-side index purchased on the website without a per-employee dimension, FileFlo is the complementary records-side layer alongside the C/TPA + MRO stack.
National Drug Testing
C/TPA + Random Selection + Aviation D&A RecordkeepingBest For
Aviation employers that need an integrated C/TPA random selection draw service + consortium pool membership + MRO contract + collection site network + recordkeeping platform under a single vendor — the all-in-one C/TPA + software bundle for operators that prefer to outsource the random selection and the lab + MRO chain
Key Feature
Integrated C/TPA service with §120.107 25% drug random rate and §120.217 10% alcohol random rate selection draws, consortium pool membership, MRO contract, national collection site network, and recordkeeping platform for §120.7 program records, §120.105 drug testing records, §120.215 alcohol testing records, and Part 40 procedural records
Records Focus
C/TPA random selection draws + consortium pool membership + MRO contract + collection site coordination + §120.7 program records, §120.105 drug testing records, §120.215 alcohol testing records, Part 40 procedural records; primary motion is C/TPA service, not records-side document management
Strengths
- Integrated C/TPA random selection draw + consortium pool membership for operators that prefer outsourced random selection management
- National HHS-certified lab + MRO contract bundled with the C/TPA service
- National collection site network reach for §120.17 specimen collection and §120.215 alcohol testing
- Established aviation D&A C/TPA pedigree
- Bundled service simplifies procurement for operators that prefer a single C/TPA + lab + MRO + recordkeeping vendor
Limitations
- Per-employee + per-test pricing scales linearly with safety-sensitive employee count and testing volume
- Public pricing is not published — sales-led discovery call required
- AI document classification is not the primary workflow — records management is largely the operator side of the C/TPA service
- Records-side §120.7 graduated retention schedule enforcement is procedural, not structurally enforced
- FAA AAM-800 audit binder export is part of the C/TPA service but not the single-purpose primary deliverable
Our take: National Drug Testing is the integrated C/TPA + random selection + MRO + collection site + recordkeeping platform for aviation employers that prefer to outsource the random selection draw and the lab + MRO chain under a single vendor. For operators that want a turnkey C/TPA + lab + MRO bundle managed by a single service provider, the integrated bundle is the procurement simplification advantage. For operators that want a self-serve records-side §120.7 + §120.105 + §120.215 + Part 40 records-side index purchased on the website without a per-employee dimension to complement the C/TPA service, FileFlo is the complementary records-side layer.
Drug-Free Compliance
C/TPA + Aviation D&A Program AdministrationBest For
Aviation employers that need a C/TPA random selection draw + consortium pool + supervisor training + DAPM advisory service under a single vendor — the C/TPA-led model for operators that prefer to outsource the program administration entirely
Key Feature
Integrated C/TPA service with §120.107 + §120.217 random selection draws, consortium pool, supervisor training + reasonable suspicion training, DAPM advisory, and Part 120 program administration
Records Focus
C/TPA random selection draws + consortium pool + supervisor training + DAPM advisory + Part 120 program administration; primary motion is C/TPA service + program administration, not records-side document management
Strengths
- Integrated C/TPA + program administration model for operators that prefer to outsource program management
- Supervisor training + reasonable suspicion training tracked against §120.115 (aviation supervisor training) requirements
- DAPM advisory service for operators without a dedicated full-time Drug Abatement Program Manager
- Established aviation D&A C/TPA + program administration pedigree
Limitations
- Per-employee + per-test pricing scales linearly with safety-sensitive employee count
- Public pricing is not published — sales-led discovery call required
- AI document classification is not the primary workflow
- Records-side §120.7 graduated retention schedule is part of the C/TPA service workflow, not structurally enforced as a software primary
- FAA AAM-800 audit binder export is part of the C/TPA service workflow
Our take: Drug-Free Compliance is the C/TPA-led aviation D&A program administration vendor for operators that prefer to outsource the program management entirely — including the DAPM advisory + supervisor training + reasonable suspicion training + C/TPA random selection draws. For operators that prefer a fully-outsourced program administration model, the C/TPA-led bundle is the procurement simplification advantage. For operators that want a self-serve records-side §120.7 + §120.105 + §120.215 + Part 40 records-side index purchased on the website to complement the C/TPA program administration, FileFlo is the complementary records-side layer.
ATP CTS (Compliance Module)
Aviation Operations Platform + D&A Compliance ModuleBest For
Part 121, Part 135, and Part 145 operators already running ATP CTS for pilot training records, maintenance tracking, and crewmember qualification management that want the bundled D&A compliance module alongside the broader ATP CTS aviation operations platform — single-vendor relationship across aviation training + maintenance + D&A
Key Feature
Aviation operations platform with bundled D&A compliance module — Part 120 program records, §120.105 drug testing records, §120.215 alcohol testing records, supervisor training tracking, alongside the broader ATP CTS pilot training + maintenance + crewmember qualification platform
Records Focus
Bundled aviation operations + Part 120 D&A module — primary motion is the broader ATP CTS aviation operations platform; D&A is a bundled module rather than a single-purpose primary deliverable
Strengths
- Bundled aviation operations + D&A compliance under one vendor — single-vendor procurement simplification
- Established aviation operations platform pedigree across Part 121 + Part 135 + Part 145 operators
- Integration with broader ATP CTS pilot training, maintenance, and crewmember qualification workflows
- Aviation-specific operator workflow rather than cross-segment DOT compliance breadth
Limitations
- Per-employee pricing scales linearly with safety-sensitive employee count
- Public pricing is not published — sales-led discovery call required
- D&A is a bundled module within a broader operations platform, not the single-purpose primary deliverable
- AI document classification is not the primary D&A module workflow
- Records-side §120.7 graduated retention schedule is part of the D&A module, not structurally enforced as a software primary
- FAA AAM-800 audit binder export is part of the D&A module workflow, not the primary deliverable
Our take: ATP CTS is the aviation operations platform with a bundled D&A compliance module for operators already running ATP CTS for pilot training, maintenance tracking, and crewmember qualification workflows. For operators that want a single-vendor relationship across aviation training + maintenance + D&A and are willing to pay per-employee pricing on top of the base ATP CTS subscription, the bundled module is the procurement simplification advantage. For operators that want a self-serve records-side §120.7 + §120.105 + §120.215 + Part 40 records-side index purchased on the website without a per-employee dimension, FileFlo is the complementary records-side layer alongside the C/TPA + lab + MRO stack.
Paper / Spreadsheet / Manual
The Status Quo Most Small Part 135 + Part 145 Operators Are QuittingBest For
Very small Part 145 limited-rating repair stations or single-pilot Part 91K fractional operations with a very small safety-sensitive employee population, a stable C/TPA random selection draw cadence, and no recent §120.111 post-accident test event — these conditions describe almost no Part 121, Part 135, or larger Part 145 aviation employer in 2026
Key Feature
No software vendor relationship; full local control over paper §120.7 written policy distribution acknowledgments, paper §120.105 drug test records, paper §120.215 alcohol test records, paper §120.7 retention chain, and paper Part 40 procedural records
Records Focus
Whatever the Drug Abatement Program Manager builds in SharePoint, network shares, paper binders, and spreadsheets — vulnerable to §120.7 retention chain breaks during system migration, §120.107 25% random rate calculation errors at calendar year close, §120.105 post-accident 32-hour window missed, §120.215 confirmation test record incomplete, and SAP follow-up testing plan record incomplete at FAA AAM-800 audit
Strengths
- Zero software cost
- No vendor lock-in
- Familiar to long-tenured Drug Abatement Program Managers and small-operator program administrators
- Works for a very small Part 145 limited-rating repair station with a single safety-sensitive mechanic, a stable C/TPA, and no recent §120.111 post-accident event — these conditions describe almost no Part 121, Part 135, or larger Part 145 aviation employer in 2026
Limitations
- No structural §120.7 written policy distribution enforcement — surfaced at FAA AAM-800 audit when a safety-sensitive employee was added without a documented policy distribution acknowledgment
- No structural §120.107 25% drug random rate or §120.217 10% alcohol random rate calculation against the rolling 12-month covered-employee count — surfaced at calendar year close
- No structural §120.111 32-hour post-accident drug window or §120.219 8-hour post-accident alcohol window enforcement — surfaced when a post-accident decision memo was incomplete
- No structural §120.7 graduated retention chain enforcement — surfaced at FAA AAM-800 audit when a 5-year positive test record was destroyed prematurely or a 2-year random selection record was lost during a system migration
- No structural SAP follow-up testing plan tracking against the §120.113 / §120.221 12-to-60-month follow-up schedule — surfaced when a follow-up test was missed
- FAA AAM-800 audit binder reconstructed manually under audit time pressure
- Hidden labor cost + FAA AAM-800 finding risk + certificate action risk when the records chain breaks: a Drug Abatement Program Manager + Director of Operations + Director of Maintenance team spending hours per week on manual records assembly plus a single AAM-800 finding that drives a Notice of Proposed Civil Penalty commonly exceeds the software cost within the first audit cycle
Our take: Paper records, SharePoint folders, network shares, and spreadsheets are the status quo most small Part 145 + Part 135 + Part 91K operators are actively quitting in 2026 as FAA AAM-800 surveillance frequency increases and §120.7 retention chain integrity expectations harden. The hidden labor cost of manual records assembly plus the asymmetric downside of a single FAA AAM-800 audit finding — up to $37,377/violation under 49 U.S.C. § 46301 — plus the certificate action exposure when a §120.105 verified positive result implicates a Part 67 medical certificate or Part 61 airman certificate makes the status quo more expensive than a self-serve flat-rate records-side platform within the first audit cycle.
Side-by-Side Comparison
All 7 platforms across the criteria that matter most for the FAA-regulated 49 CFR Part 120 program: random selection management (in-house vs C/TPA-bundled), pre-employment tracking, post-accident workflow (§120.111 32-hour drug + §120.219 8-hour alcohol windows), 49 CFR Part 120 coverage depth, pricing motion, and free trial availability. Bundled and C/TPA vendor pricing is sales-led and not published — pricing motion is the actionable buyer-side distinction.
| Platform | FileFlo | Foley | CarrierShield | National Drug Testing | Drug-Free | ATP CTS | Paper |
|---|---|---|---|---|---|---|---|
| Random Selection Mgmt | ⚠️ Pair with C/TPA for draws | ✅ Bundled C/TPA + draws | ✅ Bundled C/TPA + draws | ✅ Integrated C/TPA + draws | ✅ Integrated C/TPA + draws | ⚠️ Module pairs with C/TPA | ❌ Spreadsheet |
| Pre-Employment Tracking | ✅ §120.105 records + AI classify | ⚠️ Per-employee module | ⚠️ Per-employee module | ✅ C/TPA-managed | ✅ C/TPA-managed | ⚠️ Bundled module | ❌ Paper |
| Post-Accident Workflow | ✅ §120.111 32-hr + §120.219 8-hr clocks | ⚠️ Cross-segment bundled | ⚠️ Cross-segment bundled | ✅ C/TPA-coordinated | ✅ C/TPA-coordinated | ⚠️ Bundled module | ❌ Manual memo |
| 49 CFR Part 120 Coverage | ✅ §120.7 + §120.105 + §120.215 + Part 40 | ⚠️ Bundled Part 120 + Part 382 | ⚠️ Bundled Part 120 + Part 382 | ✅ Part 120 C/TPA + records | ✅ Part 120 C/TPA + records | ⚠️ Aviation-bundled | ❌ Paper |
| Pricing | ✅ $299/mo flat — purchased on site | ❓ Per-employee + base (sales-led) | ❓ Per-employee + base (sales-led) | ❓ Per-employee + per-test | ❓ Per-employee + per-test | ❓ Per-employee + base | $0 + hidden labor |
| Free Trial | ✅ 5 days, no credit card | ❌ Demo only | ❌ Demo only | ❌ Demo only | ❌ Demo only | ❌ Demo only | N/A |
⚠️ = partial or limited support. ❓ = unknown / not published. Bundled and C/TPA vendor pricing is sales-led and not published as of May 2026; pricing motion is the actionable buyer-side distinction.
How to Choose the Right Aviation D&A Testing Program Platform
49 CFR Part 120 vs FMCSA 49 CFR Part 382 (Key Distinctions)
Per 49 CFR Part 120, the FAA-regulated aviation D&A program covers Part 121 air carriers, Part 135 charter operators, Part 145 repair stations, Part 91 Subpart K fractional operators, and certain Part 91 commercial operators — with safety-sensitive functions defined under §120.105 (flight crewmember, flight attendant, flight instructor, aircraft dispatcher, aircraft maintenance, ground security coordinator, aviation screener, air traffic controller). The §120.107 minimum annualized drug random rate is 25%; the §120.217 minimum annualized alcohol random rate is 10%. The §120.111 post-accident drug testing window is 32 hours; the §120.219 post-accident alcohol testing window is 8 hours. Enforcement is by the FAA Drug Abatement Division (AAM-800). Per 49 CFR Part 382, the FMCSA-regulated CDL driver D&A program covers interstate motor carrier employers and CDL drivers operating CMVs — with the FMCSA Office of Field Operations as the enforcement agency. Both Part 120 and Part 382 incorporate 49 CFR Part 40 procedures by reference, so the specimen collection + HHS-certified lab + MRO + SAP + STT/BAT/EBT procedural backbone is shared — but the random pools, enforcement agencies, and post-accident criteria are distinct. A Part 145 repair station that also operates a commercial trucking fleet may be subject to BOTH Part 120 (aviation maintenance personnel) AND Part 382 (CDL drivers) — under separate random pools, separate C/TPA memberships, and separate audit jurisdictions. For the FMCSA-side records-side compliance guide, see our DOT drug testing software guide.
Random Selection + Consortium (C/TPA) Mgmt
Per 49 CFR §120.105 and §120.107, the §120.107 minimum annualized drug random rate is 25% of covered safety-sensitive employees; per §120.215 and §120.217, the §120.217 minimum annualized alcohol random rate is 10%. Both rates are calculated against the rolling 12-month covered-employee count and audited at calendar year close. Most aviation operators participate in a consortium / third-party administrator (C/TPA) that manages the random selection draw across a pooled population — the C/TPA is responsible for the draw integrity, the testing notification, and the C/TPA-managed random selection audit trail. Smaller Part 145 repair stations and Part 91K operators almost always use a C/TPA; larger Part 121 carriers may run an in-house random selection program. The records-side records of each random selection draw (date, randomized employee list, notification, completion, refusal, no-show) must be retained for at least 2 years under §120.7 — and surfaced to the FAA AAM-800 inspector during audit. Records-side compliance software complements the C/TPA random selection service: the C/TPA performs the draw, the records-side platform inventories the draw evidence + completion records + refusal records against the §120.7 2-year random selection retention clock.
Post-Accident Testing Workflow (§120.111 + §120.219)
Per 49 CFR §120.111, each FAA-regulated employer must conduct post-accident drug testing on each surviving covered employee whose performance of a safety-sensitive function could not be completely discounted as a contributing factor to the accident — and the drug specimen must be collected as soon as practicable, but no later than 32 hours after the accident. Per §120.219, each employer must conduct post-accident alcohol testing on each surviving covered employee — and the alcohol specimen must be collected as soon as practicable, but no later than 8 hours after the accident. If the alcohol test is not collected within 2 hours of the accident, the employer must prepare and maintain a written record stating the reasons the test was not promptly administered; if the alcohol test is not collected within 8 hours, the employer must cease attempts to administer the test and must prepare and maintain a written record. Records-side compliance software must enforce the §120.111 32-hour drug window + the §120.219 8-hour alcohol window + the §120.219 2-hour and 8-hour written-record requirements + the post-accident decision memo documenting why each safety-sensitive employee on duty was or was not tested — and produce the post-accident testing audit binder for FAA AAM-800 audit on demand.
Safety-Sensitive Employee Tracking (§120.105 covered categories)
Per 49 CFR §120.105, the covered safety-sensitive employee categories under the FAA-regulated D&A program include flight crewmembers (pilots, flight engineers), flight attendants, flight instructors, aircraft dispatchers, aircraft maintenance personnel and aircraft preventive maintenance personnel, ground security coordinators, aviation screeners (where applicable), and air traffic control specialists not employed by the FAA. Each covered employee must complete pre-employment drug testing under §120.105 before performing safety-sensitive functions for the first time; must participate in the §120.107 25% random drug pool and §120.217 10% random alcohol pool; must be subject to §120.111 post-accident drug testing within 32 hours and §120.219 post-accident alcohol testing within 8 hours; must be subject to reasonable cause / reasonable suspicion testing on documented supervisor observation; and (if previously verified positive or refused) must complete §120.113 return-to-duty and follow-up testing per the SAP-directed plan. Per §120.7, the safety-sensitive employee roster must be maintained, the §120.7 written policy distribution acknowledgment must be on file before first performing safety-sensitive functions, and the §120.7 graduated retention schedule applies to every record category. Records-side compliance software must inventory each safety-sensitive employee against the §120.105 categories, the §120.7 written policy distribution acknowledgment, the pre-employment test record, the random pool membership, the §120.111 + §120.219 post-accident decision memo, the reasonable cause / suspicion documentation, the SAP referral, the return-to-duty completion, and the §120.113 / §120.221 follow-up testing plan — and produce the §120.105 safety-sensitive employee audit binder for FAA AAM-800 audit on demand.
§120.7 + §120.105 + §120.215 + Part 40 — every Part 120 records chain in one self-serve pre-audit index
FileFlo inventories every §120.7 written policy distribution acknowledgment, every DAPM designation memo, every HHS-certified lab + MRO + C/TPA service agreement, every §120.105 pre-employment / random / post-accident / reasonable cause / return-to-duty / follow-up drug test record, every §120.215 alcohol screening + confirmation test record, every SAP referral + evaluation + return-to-duty completion, every §120.113 / §120.221 follow-up testing plan, every supervisor training certificate, and every Part 40 procedural artifact (CCF + ATF + chain-of-custody + lab confirmation + MRO verification + STT/BAT/EBT serial number) in a single pre-audit cross-reference index — and surfaces lapsed or expiring §120.7 retention clocks before the next FAA AAM-800 audit. AI document classification routes every uploaded record to the correct §120.7, §120.105, §120.107, §120.111, §120.215, §120.217, §120.219, or Part 40 paragraph automatically. $299/month flat, no contract, no per-employee fees, no sales call — purchased on the website to live alongside the C/TPA + lab + MRO stack.
Frequently Asked Questions
What is aviation drug & alcohol testing program software (49 CFR Part 120)?
Aviation drug & alcohol testing program software helps the Drug Abatement Program Manager, Director of Operations, Director of Maintenance, Chief Inspector, and accountable executive at a Part 121 air carrier, Part 135 charter operator, Part 145 repair station, or Part 91 Subpart K fractional operator inventory and prove the FAA-regulated Drug + Alcohol Testing Program required under 49 CFR Part 120. The program covers pre-employment, random, reasonable cause/suspicion, post-accident, return-to-duty, and follow-up testing of safety-sensitive employees (flight crewmembers, flight attendants, flight instructors, aircraft dispatchers, aircraft maintenance personnel, ground security coordinators, aviation screeners, and air traffic controllers under §120.105). The best platforms tie each test record back to the specific paragraph under 49 CFR §120.7 (program management), §120.17 (testing procedures), §120.105 (drug testing — required), §120.107 (random testing rate — 25% drug rate), §120.215 (alcohol testing — required), §120.217 (alcohol random rate — 10%), and 49 CFR Part 40 (transportation workplace testing procedures — incorporated by reference), surface random selection pool integrity, consortium audit trail, MRO (Medical Review Officer) verification, BAT (Breath Alcohol Technician) and STT (Screening Test Technician) credentials, SAP (Substance Abuse Professional) referrals, and DOT Drug + Alcohol Clearinghouse-equivalent record retention, and produce an FAA Drug Abatement Division (AAM-800) audit-defensible binder on demand.
What is the difference between 49 CFR Part 120 (FAA) and 49 CFR Part 382 (FMCSA)?
This is the single most common buyer-side confusion in the drug & alcohol testing software category. 49 CFR Part 120 governs FAA-regulated aviation employers — Part 121 air carriers, Part 135 charter operators, Part 145 repair stations, Part 91 Subpart K fractional operators, and certain Part 91 commercial operators — with safety-sensitive functions defined under 49 CFR §120.105 (flight crewmember, flight attendant, flight instructor, aircraft dispatcher, aircraft maintenance, ground security coordinator, aviation screener, air traffic controller). 49 CFR Part 382 governs FMCSA-regulated motor carrier employers — interstate trucking companies operating CMVs requiring a CDL — with safety-sensitive functions tied to CDL operation. Both Part 120 and Part 382 incorporate 49 CFR Part 40 procedures by reference (specimen collection, lab procedures, MRO verification, SAP referral), so the procedural backbone is shared — but the random selection pools, employer enforcement agency, and post-accident criteria are distinct. A Part 145 repair station that also operates a commercial trucking fleet may be subject to BOTH Part 120 (for safety-sensitive aviation maintenance personnel) AND Part 382 (for CDL drivers) — under entirely separate random pools, separate consortium memberships, and separate audit jurisdictions (FAA AAM-800 vs FMCSA OFR). For FMCSA-side drug & alcohol testing software, see our companion guide at /blog/dot-drug-testing-software. This guide covers the FAA-side 49 CFR Part 120 program specifically.
What does 49 CFR §120.7 require for FAA drug & alcohol program management?
Per 49 CFR §120.7 (Drug and alcohol testing program — required), each FAA-regulated employer must establish and implement an anti-drug and alcohol misuse prevention program that meets the requirements of 49 CFR Part 120 and 49 CFR Part 40. The §120.7 program must include a written policy statement provided to each safety-sensitive employee describing prohibited conduct, testing circumstances (pre-employment, random, post-accident, reasonable suspicion, return-to-duty, follow-up), consequences for prohibited conduct, BAT/STT/MRO/SAP credentials and contact information, employee assistance program (EAP) information, and the substance abuse education + supervisor training requirements. The §120.7 program must designate a Drug Abatement Program Manager (DAPM) responsible for day-to-day program management, must contract with an HHS-certified laboratory under 49 CFR Part 40 Subpart F, must contract with a qualified MRO under 49 CFR §40.121, and must (in most cases) participate in a consortium / third-party administrator (C/TPA) that manages the random selection pool. Per §120.7, the program records must be retained on a graduated schedule — positive test records for 5 years, negative test records for 1 year, random selection records for 2 years, training records for 2 years, EAP referral records for 5 years — and must be made available to the FAA Drug Abatement Division (AAM-800) on demand. Compliance software must enforce the §120.7 program management chain structurally — written policy distribution, DAPM designation, lab + MRO + C/TPA contracts, random selection pool integrity, and the §120.7 graduated retention schedule — and must produce the §120.7 program audit binder for FAA AAM-800 surveillance on demand.
What does 49 CFR §120.105 require for FAA-regulated drug testing?
Per 49 CFR §120.105 (Drug testing — required tests), each FAA-regulated employer must conduct six categories of drug testing on its covered safety-sensitive employees: pre-employment testing (before performing safety-sensitive functions for the first time), random testing (at a minimum annualized rate of 25% of covered employees per §120.109), post-accident testing (after each accident as defined in §120.111), reasonable cause testing (when trained supervisors document a reasonable cause to believe an employee has used a prohibited substance), return-to-duty testing (after a verified positive or refusal, before resuming safety-sensitive functions), and follow-up testing (during the 12 to 60 months after return-to-duty, per the SAP follow-up plan under §120.113). The §120.105 covered employee categories include flight crewmembers, flight attendants, flight instructors, aircraft dispatchers, aircraft maintenance personnel and aircraft preventive maintenance personnel, ground security coordinators, aviation screeners, and air traffic control specialists not employed by the FAA. Specimen collection, chain-of-custody, lab analysis, MRO review, and result reporting all proceed under 49 CFR Part 40 procedures by reference. Compliance software must inventory each §120.105 test category against the covered employee, the C/TPA random selection draw, the collection site receipt, the lab + MRO verification chain, and the §120.7 retention schedule — and produce the §120.105 testing program binder for FAA AAM-800 audit on demand.
What does 49 CFR §120.215 require for FAA-regulated alcohol testing?
Per 49 CFR §120.215 (Alcohol testing — required tests), each FAA-regulated employer must conduct four categories of alcohol testing on its covered safety-sensitive employees: random testing (at a minimum annualized rate of 10% of covered employees per §120.217 — lower than the 25% drug rate), post-accident testing (after each accident as defined in §120.219, within 8 hours for alcohol testing), reasonable suspicion testing (when trained supervisors document a reasonable suspicion based on specific articulable observations), and return-to-duty + follow-up testing (per the SAP follow-up plan under §120.221). Alcohol testing proceeds under 49 CFR Part 40 Subpart M procedures with a screening test by a Screening Test Technician (STT) using an FDA-cleared device, followed by a confirmation test by a Breath Alcohol Technician (BAT) using an Evidential Breath Testing (EBT) device on the National Highway Traffic Safety Administration (NHTSA) Conforming Products List if the screening test produces a result of 0.02 BAC or higher. A confirmation test result of 0.04 BAC or higher is a violation; a result of 0.02 to 0.039 BAC is not a violation but requires removal from safety-sensitive function for at least 8 hours. Compliance software must inventory each §120.215 test category against the §120.217 10% random rate, the post-accident 8-hour window, the STT/BAT credentials and EBT serial number, and the §120.7 retention schedule — and produce the §120.215 alcohol testing program binder for FAA AAM-800 audit on demand.
What does 49 CFR Part 40 add to the Part 120 program?
Per 49 CFR Part 40 (Procedures for Transportation Workplace Drug and Alcohol Testing Programs), the procedural backbone of every Part 120 (aviation), Part 382 (FMCSA), Part 199 (FRA), Part 219 (PHMSA pipeline), Part 655 (FTA transit), and USCG drug & alcohol testing program is unified — including specimen collection (Subpart D), HHS-certified lab analysis (Subpart F), Medical Review Officer (MRO) verification (Subpart G), Substance Abuse Professional (SAP) qualifications and the SAP-directed return-to-duty + follow-up testing plan (Subpart O), and alcohol testing using STTs/BATs and Evidential Breath Testing (EBT) devices on the NHTSA Conforming Products List (Subpart M). Part 40 also defines the test refusal categories (Subpart I), the prohibited employee conduct categories (Subpart B), the employer record retention obligations (Subpart P — generally aligned with the §120.7 graduated schedule for FAA-regulated employers), and the C/TPA service agent requirements (Subpart Q). Aviation D&A compliance software must enforce the Part 40 procedural chain structurally — collection site receipts, custody-and-control form (CCF) data, alcohol testing form (ATF) data, lab confirmation results, MRO verifications, SAP referrals, return-to-duty completion records, follow-up testing schedules, and the Part 40 / §120.7 retention timelines — and must produce the Part 40 + Part 120 audit binder for FAA AAM-800 surveillance on demand.
How much does aviation drug & alcohol testing program software cost?
Aviation drug & alcohol testing program software is typically priced under one of three motions. Bundled compliance vendors with a dedicated aviation D&A module (Foley Carrier Services, CarrierShield, ATP CTS) typically price the D&A module as a per-employee fee on top of a base compliance subscription, with most aviation operators in the $25–75 per safety-sensitive employee per year range plus a one-time program setup fee — public pricing is rarely listed and is typically gated behind a sales call. Specialized C/TPA + software vendors (National Drug Testing, Drug-Free Compliance) typically bundle the C/TPA random selection service, the consortium pool membership, the MRO contract, and the recordkeeping software for a combined per-employee fee in the $40–100 per safety-sensitive employee per year range plus per-test collection fees. Paper / spreadsheet / manual programs have no software cost but carry hidden labor cost (Drug Abatement Program Manager assembling records manually before AAM-800 audit) and asymmetric downside risk (a single records-side lapse implicating multiple flights). FileFlo is a self-serve, $299/month flat-rate records-side document compliance platform purchased on the website without a sales call, 5-day free trial, no per-employee fees — designed to inventory the §120.7 written policy distribution, DAPM designation, lab + MRO + C/TPA contracts, §120.105 drug test records, §120.215 alcohol test records, SAP referral records, return-to-duty records, follow-up testing plan records, supervisor training records, and the §120.7 graduated retention schedule alongside an aviation operator already running a C/TPA for random selection.
What FAA civil penalty applies to a 49 CFR Part 120 violation?
Under 49 U.S.C. § 46301(a)(1), the FAA may impose civil penalties up to $37,377 per violation for most Part 120 drug & alcohol testing program failures as of the 2026 inflation-adjusted schedule (penalties adjusted annually under the Federal Civil Penalties Inflation Adjustment Act). Records-side findings — a §120.7 written policy that was not distributed to a safety-sensitive employee before first performing safety-sensitive functions, a §120.107 random testing rate that fell below the 25% drug rate or §120.217 10% alcohol rate for the calendar year, a §120.105 post-accident test that was not collected within the §120.111 32-hour drug window or §120.219 8-hour alcohol window, a §120.7 graduated retention schedule that broke during a system migration, or an SAP follow-up testing plan record that was incomplete at FAA AAM-800 audit — are among the most consequential entries in FAA Drug Abatement Division surveillance findings because each records-layer lapse can implicate every flight, dispatch release, or maintenance signoff operated against the lapsed record. Beyond the FAA civil penalty exposure, a §120.105 verified positive or §120.215 confirmed positive result triggers immediate removal from safety-sensitive function and may trigger certificate action against an FAA-certificated airman under 14 CFR Part 67 medical certification and Part 61 airman certification. The pre-audit Part 120 records package — §120.7 written policy distribution + DAPM designation + lab + MRO + C/TPA contracts + §120.105 drug testing + §120.215 alcohol testing + supervisor training + SAP referrals + return-to-duty + follow-up testing — is the spine of every FAA AAM-800 audit and the §120.7 records retention chain.
Stop reconstructing the §120.7 + §120.105 + §120.215 + Part 40 chain the week before the FAA AAM-800 audit
FileFlo holds every §120.7 written policy distribution acknowledgment, every §120.105 drug test record, every §120.215 alcohol test record, every MRO verification, every SAP referral + return-to-duty + follow-up plan, every supervisor training certificate, and every Part 40 procedural artifact across every safety-sensitive employee — all for $299/month flat, no contract, no per-employee fees, no sales call.
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