Direct Answer — Who Must Be Tested at a Part 145 Repair Station
A Part 145 repair station employee must be in an FAA drug and alcohol testing program when they perform safety-sensitive maintenance or preventive maintenance — directly or by contract, including by subcontract at any tier — on the aircraft of a Part 121 or Part 135 certificate holder. That covered work is defined as a safety-sensitive function in 14 CFR §120.105 (drugs) and §120.215 (alcohol); §120.1 lists Part 145 certificate holders as persons to whom Part 120 applies. The station may either be folded into the air carrier's program as a contractor or hold its own FAA program — but every covered technician must be in one of them. Testing follows the six DOT types under 49 CFR Part 40, with positives, refusals, and ≥0.02 BAC alcohol results retained for five years. Work performed only on Part 91 / general-aviation or off-aircraft components generally carries no Part 120 mandate.
The most common gap: the "covered but in no program" technician
The failure mode is rarely a missing test. It is a technician who performs covered maintenance for a Part 135 customer but is in neither the air carrier's antidrug program nor the station's own — a coverage hole that surfaces only when someone asks for the proof. This is a records problem first: you must be able to show, per covered person, exactly which program covers them and that the chain is intact. It is the same proof discipline as the Part 135 drug & alcohol records checklist — viewed from the maintenance-provider side.
Who Is Subject: The Work, Not the Title
The single most misunderstood point in repair-station drug and alcohol compliance is the trigger. It is not your A&P certificate. It is not whether you hold a Part 145 certificate. It is whether a specific person performs a safety-sensitive function on a covered aircraft. Both halves matter.
14 CFR §120.105 lists nine safety-sensitive functions for drug testing, and §120.215 lists the identical functions for alcohol testing. One of them is the maintenance trigger:
The covered function
"Aircraft maintenance and preventive maintenance duties" — 14 CFR §120.105(e) (drugs); "Aircraft maintenance or preventive maintenance duties" — §120.215(a)(5) (alcohol).
The reach to contractors is explicit. 14 CFR §120.7 defines a "covered employee" as an individual who performs a listed safety-sensitive function "either directly or by contract" for an employer, and the function lists themselves extend coverage to performance "directly or by contract (including by subcontract at any tier)." A repair station is a contractor to the air carrier. A second-tier shop the repair station hires is a subcontractor. The mandate follows the covered work all the way down the chain.
Generally SUBJECT to Part 120
- Mechanics & technicians performing maintenance on Part 121/135 air carrier aircraft
- Inspectors making airworthiness / return-to-service determinations on covered aircraft
- Contract and temp technicians performing the covered work — at any tier
- On-aircraft line maintenance for an air carrier customer
Generally NOT subject (verify each case)
- Stations working only on Part 91 / general-aviation aircraft
- Off-aircraft component or accessory overhaul not tied to a covered air carrier
- Purely administrative, sales, parts-counter, or front-office staff
- Work on experimental or non-covered aircraft categories
"Generally not subject" is not the same as "exempt forever"
The moment a station takes on a Part 121/135 air carrier customer for safety-sensitive maintenance, the technicians who touch that work move into scope — even if 90 percent of the shop's volume is general aviation. Coverage is determined customer-by-customer and function-by-function. Keep a documented analysis of which of your customers are covered air carriers and which of your staff perform the covered work; that analysis is the foundation of your personnel roster and training records.
Two Coverage Models: Air-Carrier Program vs. Your Own Program
Once you have identified covered technicians, the next question is whose program covers them. 14 CFR §120.1 lists both air carriers and Part 145 certificate holders as persons to whom Part 120 applies, and it contemplates contractors participating. In practice there are two legitimate structures, and a station may even use both for different customers.
Model A — Covered under the air carrier's program
The Part 121/135 air carrier extends its antidrug and alcohol misuse prevention program to the repair station as a contractor. The carrier (or its C/TPA) administers testing for your covered technicians.
What the station must still hold:
- Written agreement / documentation that the carrier covers named technicians
- A current list of which technicians are in the carrier pool
- Confirmation that covered staff are in the pool before they touch covered work
Model B — The station holds its own FAA program
The repair station registers its own antidrug and alcohol misuse prevention program with the FAA, names a DER, contracts a C/TPA, and administers all six test types itself — then certifies its coverage to the carriers it serves.
What the station must hold:
- The full written program (DATP) and FAA registration / authorization
- DER designation + C/TPA service agreement
- The complete random, MRO, SAP, and supervisor-training record set
There is no third option called "neither"
A technician performing covered maintenance who is in neither the carrier's program nor the station's own is a live violation — and the air carrier carries ultimate responsibility for ensuring its safety-sensitive maintenance is performed only by covered personnel. When a station works for multiple air carriers, the records get harder, not easier: you may have some technicians in Carrier X's pool, others in your own program, and the inspector will want to see, per person, which program applies and that the coverage was in place before the work was performed.
The Six Test Types — and the Records Each One Generates
Whether coverage runs through the carrier or the station's own program, the testing follows the same six DOT types, conducted under 49 CFR Part 40 procedures. 14 CFR §120.109 sets the drug testing circumstances and §120.217 sets the alcohol testing circumstances.
| Test type | When it applies to a covered technician | Record generated |
|---|---|---|
| Pre-employment | Before first performance of safety-sensitive maintenance (drug test required; alcohol optional) | Negative drug result + MRO verification on file before work begins |
| Random | Unannounced selection from the covered pool, spread across the year at the FAA-published rate | Selection record, draw date, test result, year-end rate calculation |
| Reasonable suspicion / cause | When a trained supervisor observes indicators of drug use or alcohol misuse | Supervisor observation documentation + test result |
| Post-accident | After a qualifying accident where the technician’s performance may have contributed | Post-accident determination + test result (or documented decision not to test) |
| Return-to-duty | Before returning to covered work after a positive, refusal, or violation | Negative RTD test + SAP clearance |
| Follow-up | Unannounced, SAP-directed, after return to duty (min. 6 in first 12 months) | Each follow-up test result + the SAP follow-up plan |
On rates: the regulatory baseline in §120.109 is a minimum annual random drug testing rate of 50 percent of covered employees, and §120.217 sets a minimum annual random alcohol testing rate of 25 percent. The FAA Administrator adjusts these based on industry violation data and publishes the applicable rate each calendar year — in recent years the published minimums have been lower than the regulatory baseline. Always confirm the current rate against the Federal Register or the FAA Drug Abatement Division before administering the pool. Documenting the rate you actually applied each year, and proving you met it, is one of the most commonly cited deficiencies — the same lesson the Part 135 records checklist covers in depth on the operator side.
Prove every covered technician is in a program — before the inspector asks
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The Records: What to Keep and For How Long
Retention is governed by 49 CFR §40.333 (the DOT recordkeeping rule incorporated for FAA programs) plus the Part 120 program record provisions in 14 CFR §120.111. If the station holds its own program, it owns all of these. If it is covered under an air carrier program, it must still hold its coverage documentation and be able to point to where the underlying records live.
Coverage documentation (per covered technician)
Keep current; retain historical for the audit windowThe foundational record specific to repair stations: a documented analysis of which customers are covered air carriers, which staff perform covered maintenance, and — for each covered technician — whether they are in the air carrier’s program or the station’s own. This is the record that closes the “covered but in no program” gap.
Drug test results & chain-of-custody (CCF) forms
5 years (positives, refusals, adulterated/substituted); 1 year (negatives/cancelled)Federal Drug Testing Custody and Control Forms for each test, with the MRO-verified result. Under 49 CFR §40.333, verified positives, refusals, and adulterated or substituted results are retained five years; negative and cancelled results one year. Many stations retain everything five years to simplify the archive.
Alcohol test records & EBT calibration
5 years (≥0.02 BAC); 1 year (<0.02); 2 years (EBT calibration)Alcohol Testing Forms (ATFs) for breath tests, plus evidential breath testing device calibration and quality-assurance records. Results at or above 0.02 BAC are kept five years, results below 0.02 one year, and EBT calibration records two years under §40.333.
Random program documentation
Selection-process records min. 2 years; keep current + prior years for inspection readinessThe rate applied each year, the covered-employee count, pool construction, the selection method (computer-generated draws), draw dates, notifications, completion confirmations, the spread across the year, and the year-end rate calculation. This is the most frequently cited deficiency category in aviation drug-program inspections.
MRO result records & DER notifications
5 years (program records); MRO retains positives 5 years (§40.163 / §120.111)The Medical Review Officer’s written verification of each non-negative result and the Designated Employer Representative’s copies of those notifications. Do not outsource your retention entirely to a vendor — if a C/TPA or MRO relationship ends and data does not transfer, the burden of production still falls on you.
SAP, return-to-duty & follow-up testing chain
5 yearsFor any technician who tested positive, refused, or violated the alcohol prohibitions: the SAP evaluation report, education/treatment completion, the negative return-to-duty test, and the complete follow-up testing record (minimum six unannounced tests in the first 12 months; extendable to 60 months). A single gap in the follow-up sequence is a finding.
Supervisor training & (if applicable) MIS reports
Training: keep current; MIS copies: 5 yearsDocumentation that supervisors who make reasonable-suspicion determinations received the required training. If the station holds its own program and has 50 or more covered employees, copies of the annual MIS Data Collection Form submitted to the FAA by March 15 must be retained five years under §120.111.
These records live alongside your other Part 145 documentation
Drug and alcohol records do not sit in isolation — an FAA inspection touches the whole station. They belong in the same disciplined system as your repair station recordkeeping requirements, your Repair Station and Quality Control Manual (RSQCM), and the ratings and capability list that scopes the work you are authorized to perform. When the auditor arrives, see what inspectors actually ask for.
The 2027 Foreign Repair Station Rule
For years, FAA-certificated repair stations outside the United States were not subject to the Part 120 testing mandate. That is changing on a phased schedule. On December 18, 2024, the FAA published the final rule "Drug and Alcohol Testing of Certificated Repair Station Employees Located Outside of the United States" (effective January 17, 2025), with a compliance date of December 20, 2027.
Applies to FAA-certificated repair stations outside the US whose employees — including contractor employees — perform safety-sensitive maintenance on certain Part 121 air carrier aircraft
Testing must be conducted under 49 CFR Part 40, using HHS-certified laboratories
MROs, SAPs, collectors, and breath/saliva technicians must be qualified under Part 40
Adds a process for a foreign government to apply for a waiver where domestic law conflicts with Part 120 / Part 40
Compliance date: December 20, 2027 (final rule effective January 17, 2025)
If you operate a foreign repair station serving US air carriers, the practical takeaway is to begin building program and coverage documentation now rather than waiting for the 2027 date. Until then, the existing program structure and any applicable bilateral arrangements govern. For US stations working with foreign maintenance providers, the bilateral relationship is its own records question — see the EASA Part 145 / FAA MAG bilateral repair station records guide. (The FAA–EASA Maintenance Annex Guidance is a bilateral arrangement and guidance, not US CFR text — verify any specific requirement against the current MAG revision.)
Drug/alcohol testing is one regime — SMS is a different one
Do not conflate the Part 120 testing program with a Safety Management System. SMS lives in 14 CFR Part 5, and the May 28, 2027 SMS compliance mandate covers Part 121, Part 135, §91.147, and certain Part 21 holders — Part 145 repair stations are not in that general SMS mandate. See the Part 135 SMS 2027 deadline, Part 135 SMS requirements, and the Part 135 SMS gap analysis for that separate workstream. Whether a repair station needs SMS is covered in is SMS required for a Part 145 repair station.
Related repair-station & aviation compliance guides
Frequently Asked Questions
Do FAA repair station mechanics get drug tested?
Not because they hold an A&P certificate or work at a Part 145 repair station by itself — testing is triggered by the work, not the title. Under 14 CFR Part 120, "aircraft maintenance and preventive maintenance duties" is one of the nine safety-sensitive functions (§120.105 for drugs, §120.215 for alcohol). A mechanic, technician, inspector, or anyone else who performs that maintenance — directly or by contract, including by subcontract at any tier — on the aircraft of a Part 121 or Part 135 certificate holder must be in a Part 120 testing program. A repair station that works only on Part 91 general-aviation aircraft, components off-aircraft, or experimental aircraft generally has no Part 120 mandate. The dividing line is whether the safety-sensitive maintenance touches a covered air carrier or commercial operator.
Does the repair station run its own drug program, or does the air carrier cover it?
Either model is allowed and both are common. The Part 121/135 air carrier is ultimately responsible for ensuring everyone performing its safety-sensitive maintenance is covered, so a repair station can be folded into the air carrier's antidrug and alcohol misuse prevention program as a contractor, or the repair station can hold its own FAA testing program and certify its coverage to the carriers it serves. 14 CFR §120.1 lists Part 145 certificate holders directly as persons to whom the part applies, and the definition of "covered employee" in §120.7 reaches anyone performing a listed function "either directly or by contract." What is never acceptable is a gap — a technician performing covered maintenance who is in neither the carrier's program nor the station's own. The records must show, for each covered person, exactly which program covers them.
What does a failed FAA drug test mean for a repair station employee?
A verified positive drug test, an alcohol test at 0.04 BAC or above, or a refusal to test removes the employee from all safety-sensitive functions immediately. Under 49 CFR Part 40 Subpart O, the employee cannot return to safety-sensitive duties until a Substance Abuse Professional (SAP) evaluates them, they complete any prescribed education or treatment, they pass a return-to-duty test, and they begin a SAP-directed follow-up testing plan (a minimum of six unannounced tests in the first 12 months, extendable up to 60 months). Because 49 CFR §40.285 makes the consequence cross-modal, the employee cannot perform safety-sensitive duties for any DOT-regulated employer in any transportation mode until that process is complete. The repair station must retain the full SAP and return-to-duty record chain for five years.
What random drug and alcohol testing rates apply to a Part 145 repair station?
Repair-station covered employees go into the random pool of whichever program covers them, at the FAA-published minimum annual rate for the aviation industry. The regulatory baseline in 14 CFR §120.109 is a minimum random drug testing rate of 50 percent of covered employees, and §120.217 sets a minimum random alcohol testing rate of 25 percent — but the FAA Administrator adjusts these rates based on industry violation data and publishes the applicable rate each year. Operators must verify the current calendar-year rate against the Federal Register or the FAA Drug Abatement Division before administering the program; in recent years the published minimums have been lower than the regulatory baseline. Selections must be unannounced and spread reasonably throughout the year — a batch of draws all done in one quarter is not a valid random program even if the annual count is met.
Are foreign (non-US) repair stations now required to drug and alcohol test?
Yes, on a phased timeline. On December 18, 2024 the FAA published a final rule, "Drug and Alcohol Testing of Certificated Repair Station Employees Located Outside of the United States" (effective January 17, 2025), extending 14 CFR Part 120 to FAA-certificated repair stations outside the territory of the United States whose employees — including contractor employees — perform safety-sensitive maintenance on certain Part 121 air carrier aircraft. The compliance date is December 20, 2027. Collections must follow 49 CFR Part 40 with HHS-certified laboratories and Part 40-qualified MROs, collectors, and technicians, and the rule adds a process for a foreign government to seek a waiver where local law conflicts. Until that compliance date, the existing program (and any applicable bilateral arrangements) governs — but foreign stations serving US carriers should be building their program documentation now.
What drug and alcohol testing records does an FAA inspector expect a repair station to have?
The FAA Drug Abatement Division (DAD) — a separate inspectorate from your FSDO Principal Inspector — can inspect a repair station that has its own program, and inspections may be unannounced. Expect requests for: the written antidrug and alcohol misuse prevention program (often called the DATP); identification of the Designated Employer Representative (DER) and the C/TPA; random program documentation (pool construction, selection method, draw dates, the rate applied, and the year-end rate calculation); chain-of-custody forms for a sample of tests traced through MRO verification; SAP evaluation and follow-up records for any return-to-duty employee; and supervisor reasonable-suspicion training records. If the station is folded into an air carrier program instead, the station must still produce documentation showing each covered technician is in that program. Under 49 CFR §40.333, positive results, refusals, and alcohol results at or above 0.02 BAC are kept five years; negatives one year; EBT calibration records two years.
Is a repair station drug and alcohol program the same thing as Part 135 SMS?
No — they are different regulatory regimes with different records. The drug and alcohol program lives in 14 CFR Part 120 (and 49 CFR Part 40 procedures) and governs who is tested, how, and what records are kept. A Safety Management System (SMS) lives in 14 CFR Part 5 and is a structured framework of safety policy, safety risk management, safety assurance, and safety promotion. They intersect — both touch personnel and both generate records an inspector may pull — but a clean Part 120 program does not satisfy SMS, and an SMS manual does not cover drug testing. Note that the May 28, 2027 SMS compliance mandate covers Part 121, Part 135, §91.147, and certain Part 21 certificate holders; Part 145 repair stations are not included in that general SMS mandate, though a repair station that is part of a covered air carrier may participate in that carrier’s SMS.
How long must a Part 145 repair station keep its drug and alcohol testing records?
Retention is governed by 49 CFR §40.333 (the DOT recordkeeping rule that 14 CFR Part 120 incorporates) plus the Part 120 program record rules. Verified positive drug results and their chain-of-custody documentation, alcohol results at 0.02 BAC or above, refusals to test, and SAP / return-to-duty / follow-up records are each kept for five years. Records of negative and cancelled results are kept one year. Previous-employer testing inquiry records are kept three years, and evidential breath testing device (EBT) calibration and quality-assurance records two years. Copies of any annual MIS report submitted to the FAA are kept five years under §120.111. These are minimums; many stations and their C/TPAs retain longer. The practical risk is not the retention period itself but proving, on demand, that the complete chain exists for every covered technician.
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This article reflects a compliance document management perspective and is not legal, HR, or program-administration advice. Drug and alcohol program design, applicability determinations, and enforcement responses should be made with a qualified Drug and Alcohol Program Manager, your C/TPA, and legal counsel. Regulatory citations were verified against the eCFR/Cornell LII text of 14 CFR Part 120 and 49 CFR Part 40 as of June 2026; always confirm the current text and the applicable calendar-year random testing rates before relying on them.