The DOT has the authority to test safety-sensitive employees in transportation industries through 49 C.F.R. § 40, which was first published in 1988. Transportation workers, including pilots, are subject to pre-employment, random, post-accident, and reasonable-cause testing under DOT. After a DOT+ test is confirmed, the pilot must have an evaluation by a federally qualified SAP. Most aviation psychiatrists are not SAPs but Dr. Kirk can do both HIMS and SAP evaluations.
Dr. Kirk is qualified as a HIMS psychiatrist and SAP.
Dr. Kirk, as an SAP, can evaluate pilots with positive drug or alcohol tests under the Department of Transportation (DOT) random, pre-employment, post-accident, and reasonable cause testing protocols.
The DOT regulations do not allow you to skip any step along the way.
No matter the qualification or expertise of your HIMS doctors, a HIMS psychiatrist cannot do an SAP evaluation unless being certified as an SAP.
With Dr. Kirk, the pilot will complete a HIMS evaluation at the same time as the SAP assessment.
- All reports you send to the FAA will be written to the more exacting HIMS standard instead of the SAP standard.
- Your SAP report will be written by an expert aviation psychiatrist.
- You will not have to secure a second evaluator to satisfy the FAA’s requirements.
- The pilot will be referred for treatment or education customized to FAA norms rather than generic recommendations common to the other regulated DOT industries.
- The FAA’s expectations for a pilot are radically different than what a truck driver or pipeline worker must do after a positive DOT test.
The costs of burning time are enormous. An SAP evaluation that does not address the aeromedical impact (not just general transportation) issues of a DOT+ test is not going to clear the FAA’s requirements for a pilot with a positive drug or alcohol test.
To the pilot, current or future lost wages range from $10,000 – $35,000 per month of delay. To the company, the costs of a grounded pilot, increased use of reserve crew, and inefficiency of regional, national, or global operations are measured in the hundreds of thousands to millions of dollars.
The SAP regulations are complex.
SAP recommendations often fail the FAA’s expectations of what comes next with a positive DOT test.
To a pilot, the consequences of a DOT+ are harsh. The FAA often revokes medical certificates and sometimes all pilot ratings, and then it takes time to start moving through the requirements. The “normal” workflow, when your SAP is not your aviation psychiatrist, goes something like this:
- DOT+ (pilot normally notified by MRO within seven days)
- Schedule and complete an SAP evaluation (typically 2-4 weeks to find an evaluator and schedule an appointment)
- SAP referral to education or treatment (varies, will generally take 4-12 weeks to complete the recommendations)
- Schedule and complete an SAP follow evaluation (2-4 weeks)
- If the pilot is considered in compliance by the SAP, the pilot files a report with the FAA and waits for the FAA’s determination (usually about 10 weeks)
- If the FAA does not approve the pilot as qualified for a medical certificate, the pilot will schedule an aviation psychiatry evaluation (normally takes 2-12 weeks)
- Get an aviation psychiatry report (another 2-12 weeks)
- File the report with the FAA (another 10 weeks or so to get the FAA’s decision)