Part 135 AOG: Drug & Alcohol Testing for Mechanics

Kent S. Jackson | November 8, 2016

Welcome to the Bahamas! After landing, the PIC notices a damaged part which requires emergency maintenance. The 135 operator is now AOG in a foreign country. The foreign airport has a licensed A&P mechanic that is qualified to perform the work, but the mechanic is not in a Part 135 AOG Drug Alcohol Testing Program.  What is a 135 operator to do?

Under the Gucwa Interpretation (January 11, 2016), the FAA explained that yes the licensed A&P mechanic can perform emergency maintenance.  The operator must comply with § 120.35(c) and § 120.39(c) which requires notice to the FAA Drug Abatement Program Division and re-inspection of the aircraft. This isn’t a free ride, but it does provide an AOG solution.

What if the same scenario happens in the United States? The same analysis applies. If the only available A&P mechanic isn’t on a DOT/FAA drug and alcohol testing program, the operator can use the A&P for emergency maintenance. The FAA’s notice and re-inspection requirements still apply.