I operate a flight school. Does instruction in a flight simulator qualify as a safety-sensitive function?
Yes. A flight instructor who provides instruction in a flight simulator qualifies as a safety-sensitive function when the instruction is provided to individuals that perform directly or by contract (including subcontractor at any tier) for a Part 119 certificate holder who is authorized to operate under Parts 121 and/or 135 and sightseers operating under 91.147. Flight instruction duties have been considered a safety-sensitive function since the inception of the drug testing program. Although individuals that conduct ground instruction are not subject to the drug and alcohol testing regulations; we do consider simulator flight instruction a safety-sensitive function. Simulator flight instructors are responsible for making evaluations regarding the trainees’ performance and judgment. Therefore, we consider simulator flight instruction a safety-sensitive function that must be subject to drug and alcohol testing.
