FAA DOT Drug Testing: What Happens After a Positive Test and How to Get Back to Work

If you work in a safety-sensitive role regulated by the FAA and DOT, such as a pilot, mechanic, dispatcher, or ground crew member, a verified positive drug test is a serious matter. Whether it was a one-time mistake or part of a larger issue, the consequences are immediate and non-negotiable.

Let’s walk through what happens next and how you can move forward the right way.

Step One: Immediate Removal from Safety-Sensitive Duties

Once your employer receives a verified positive drug test result from the Medical Review Officer (MRO), they are required by law to remove you from your safety-sensitive position immediately. This is a federal safety mandate.

Even if your company has a second chance policy, you will likely be placed on administrative leave while the return-to-duty process begins.

Step Two: Meet with a Substance Abuse Professional (SAP)

Your first step toward eligibility is meeting with a DOT-qualified Substance Abuse Professional. The SAP will:

• Evaluate your situation
• Recommend education, treatment, or both
• Determine whether you are in compliance or non-compliance
• Indicate whether you are eligible for a return-to-duty test

Important: The SAP does not recommend that you return to work. That decision belongs to your employer. The SAP’s role is to assess compliance and eligibility for testing, not employment status.

Step Three: Return-to-Duty Test Under Direct Observation

Once the SAP determines you are eligible, your employer will schedule a return-to-duty drug test. This test:

1. Must be conducted under direct observation
2. Must be negative before you can resume safety-sensitive duties

Your employer must coordinate with the collection site to ensure the correct procedures are followed. If the test was not properly observed, it must be repeated immediately.

Step Four: Follow-Up Testing Begins

After you return to work, the SAP’s follow-up testing plan begins. Here is what you need to know:

1. The schedule starts the day you resume safety-sensitive duties
2. All follow-up tests must be directly observed
3. The plan may extend over multiple years, based on clinical judgment

Important: Neither the SAP nor the employer is permitted to tell the employee how long the follow-up testing will last. The duration is confidential and part of the SAP’s internal plan.

If you take extended leave or change employers, the follow-up testing clock pauses. Your new employer must resume the plan where it left off. Time away from safety-sensitive work does not count toward completion.

The DER’s Role

Every FAA DOT-regulated employer must have a Designated Employer Representative (DER). This individual is responsible for:

1. Removing employees from safety-sensitive duties after a violation
2. Providing a list of qualified SAPs
3. Coordinating return-to-duty and follow-up testing
4. Ensuring compliance with FAA and DOT regulations

The DER must also:

1. Communicate directly with collection sites to confirm test type and observation requirements
2. Ask employees how their collection was conducted to verify proper procedures
3. Reschedule testing immediately if direct observation was missed

Final Thought

A positive drug test does not have to end your career, but it does require accountability, follow-through, and respect for the process. The SAP and DER are not just compliance checkpoints. They are part of the system designed to help you return to work safely and legally.

If you are given a second chance, take it seriously. Your future and public safety depend on it.