The FAA Drug Abatement Division has updated the “Records/Document Necessary for Inspection” document that accompanies the Letter of Notification (LON) for FAA drug and alcohol program inspections.

The following is a summary of the main updates to the document:

• New Requirement – 12-Month Positive/Refusal Roster now required
  • The 2006 Letter of Notification has a added a new item requiring that you provide a separate list of every employee who tested positive on a drug test, had an alcohol result of 0.04 or above, or who refused a test in the last 12-months.  The list must contain the full name, date of birth, and safety-sensitive function of the employee.  You also will need to provide the supporting documentation for all names on the list (verified MRO result, confirmed alcohol testing form, or refusal documentation).
• Requirement Removed – Blind Specimen Testing Verification
  • Previously employers with 2000 or more covered employees were required to submit to their SAMHSA laboratory blind positive controlled specimens each year.  This no longer appears on the list.
• Expanded Scope – Two items have expanded requirements
  • The lookback period for Annual Management Information System Reports (MIS) has doubled from just the previous calendar year to the previous two (2) calendar years.
  • Pre-employment alcohol testing forms (where alcohol testing was conducted) are now spelled out as their own required item.  Note: Pre-employment alcohol testing is not required, but for the companies that do opt to conduct pre-employment alcohol testing the forms must be produced during an inspection.
• Important Wording Change – “Be Prepared to Provide” is now “Provide”
  • “Be prepared to provide” can be interpreted as you may be asked so only pull if requested versus the item is mandatory and you will be asked to provide so have it ready.
• Reorganization of the Requested Document List
  • Items that were previously a stand-alone item on the prior request list are now combined into other numbered items.  The obligation to produce is still the same, it has just been relocated on the list.
    • Previous Employer Testing Requests – Was its own item on previous record/document request list but now it is a clause as part of the pre-employment documentation bullet (#2 on new 2026 list)
    • Quarterly Random Pool Eligibility List – Was its own item on previous record/document request list but now a bullet under “all random test records” (#6 on new 2026 list)
    • Recurrent Training – Was previously very general but is now narrowed to “recurrent reasonable cause training” specifically in item #15 in new 2026 list.
    • Job Description/First Safety-Sensitive Duty Docs – Were separate sub-items (1a/1b).  Now folded into the main per-employee documentation list (#2 on new 2026 list)