Aviation is an industry where the consequences of impaired performance are measured in human lives. While much of the public focus on aviation safety centres on pilots and air traffic controllers, the ground-based workforce — from aircraft maintenance engineers to ground handling staff — plays an equally critical role in ensuring that every flight departs and arrives safely.

The Civil Aviation Safety Authority (CASA) recognises this through its Drug and Alcohol Management Plan (DAMP) requirements, which extend testing obligations well beyond the flight deck. For aviation operators and ground service providers, understanding and complying with these requirements is both a legal obligation and a fundamental safety imperative.

CASA Drug and Alcohol Management Plans

CASA’s DAMP requirements are established under Part 99 of the Civil Aviation Safety Regulations 1998 (CASR). The regulations require certain aviation operators and organisations to develop, implement, and maintain a DAMP that addresses the management of drug and alcohol risks within their operations.

Who Must Have a DAMP?

The DAMP requirements apply to:

• Regular public transport (RPT) operators — airlines operating scheduled passenger services.
• Charter operators — organisations conducting charter flights.
• Aerial work operators — organisations conducting specialised aviation operations (crop dusting, aerial surveying, etc.).
• Approved maintenance organisations (AMOs) — organisations that maintain aircraft under CASA approval.
• Air traffic service providers — organisations providing air traffic control and related services.
• Aerodrome operators — operators of certified aerodromes.

Each of these organisations must have a DAMP that is approved by CASA and that meets the requirements of CASR Part 99.

DAMP Requirements in Detail

A DAMP under CASR Part 99 must include the following elements:

Policy Statement

A clear statement of the organisation’s policy on drugs and alcohol, including the prohibited substances and the consequences of a breach.

Education and Awareness

An education program that ensures all persons covered by the DAMP understand their obligations, the effects of drugs and alcohol on aviation safety, and the support available to them.

Testing Program

The DAMP must include a testing program that covers:

• Random testing — genuinely random selection of covered personnel at a frequency sufficient to act as a deterrent.
• Post-incident testing — testing following an aviation safety occurrence.
• Reasonable suspicion testing — testing when there are grounds to suspect impairment.
• Pre-employment testing — screening of candidates for safety-sensitive roles.
• Return-to-duty testing — testing before a person who has previously breached the DAMP is permitted to resume safety-sensitive duties.

Testing Standards

Testing must be conducted in accordance with Australian Standards — AS 4760 for oral fluid and AS/NZS 4308 for urine. The choice of method should be appropriate to the operational context and the substances of concern.

Management of Positive Results

The DAMP must define the process for managing positive test results, including immediate stand-down, confirmation testing, disciplinary procedures, and any rehabilitation or return-to-duty pathway.

Record-Keeping

Comprehensive records of all testing, including selection events, test results, and any actions taken, must be maintained and made available to CASA on request.

Which Roles Are Covered?

The DAMP requirements apply to persons performing “safety-sensitive aviation activities” (SSAA). This is a defined term under the regulations and captures a wide range of roles beyond flight crew.

Ground Crew Roles Typically Covered

• Aircraft maintenance engineers and technicians — personnel who inspect, service, repair, and certify aircraft for flight. This is one of the most critical ground-based roles, as a maintenance error can have catastrophic consequences.
• Ground handling staff — personnel involved in aircraft loading and unloading, fuelling, pushback, and marshalling.
• Ramp operators — workers operating ground support equipment (GSE) including tugs, belt loaders, and catering vehicles in the vicinity of aircraft.
• Baggage handlers — workers operating in and around aircraft cargo holds and on the airfield.
• Refuellers — personnel responsible for aircraft fuelling operations.
• Airfield maintenance workers — workers who maintain runways, taxiways, and other airfield infrastructure.
• Aviation security personnel — screeners and other security staff at airports.

The key determinant is whether the role involves a safety-sensitive aviation activity. Organisations should conduct a thorough assessment to identify all covered roles within their operation.

Testing Methods for Aviation Ground Operations

The operational environment of aviation ground crews influences the choice of testing method:

• Oral fluid — portable, quick to administer, and does not require toilet facilities. Well-suited to ramp operations and maintenance environments where workers are dispersed across the airfield.
• Urine — provides a longer detection window and is commonly used for pre-employment screening. Requires access to appropriate toilet facilities, which may be less convenient in airfield environments.

Many aviation organisations use oral fluid for random and for-cause testing and urine for pre-employment screening. The choice should be documented in the DAMP and applied consistently.

Reporting Obligations

Aviation operators have specific reporting obligations to CASA in relation to their DAMP:

• Annual reporting — CASA may require operators to submit annual reports on their DAMP activities, including the number of tests conducted, the number of positive results, and the actions taken.
• Occurrence reporting — positive test results and any DAMP breaches that involve a safety-sensitive aviation activity may need to be reported as part of the operator’s safety occurrence reporting obligations.
• DAMP review — CASA may review an operator’s DAMP at any time, and operators must be able to demonstrate that their DAMP is being implemented effectively.

Failure to comply with DAMP requirements can result in regulatory action by CASA, including conditions on the operator’s Air Operator’s Certificate (AOC), infringement notices, or, in serious cases, suspension or cancellation of the AOC.

Practical Challenges for Ground Operations

Shift Coverage

Airport ground operations run around the clock, with peak periods often occurring in the early morning and late evening. Random testing must cover all shifts, including overnight operations where supervision may be reduced.

Airfield Access and Security

Testing on the airfield side of an airport requires the collection personnel to hold valid Aviation Security Identification Cards (ASICs) and to comply with airfield safety procedures. This limits who can conduct testing and where it can occur.

Operational Tempo

Aircraft turnaround times are tight, and removing a worker for testing during a critical phase of operations requires careful management to avoid safety or operational impacts.

Meeting the Standard

CASA’s DAMP requirements reflect the aviation industry’s uncompromising approach to safety. For ground crew operations, compliance requires a structured, documented program that covers all safety-sensitive roles, operates across all shifts, and produces the records and reports that CASA expects.

If your aviation organisation needs to implement or strengthen its DAMP, FairTest provides the platform to manage your testing program to the standard CASA requires — from automated random selections and digital test records to the reporting and audit trail that demonstrates compliance. Start your free trial today.