Making Sure the Self-Employed Keep an Eye on Their Employees

The owner and sole pilot of a small helicopter charter company meets with a Federal Aviation Administration inspector:

Finally, the FAA inspector looked at my random drug testing program to make sure that everything was in place. I'm subject to the same drug testing requirements as United Airlines. I am the drug testing coordinator for our company, so I am responsible for scheduling drug tests and surprising employees when it is their turn to be tested. As it happens, I'm also the only "safety-sensitive employee" subject to drug testing, so basically I'm responsible for periodically surprising myself with a random drug test. As a supervisor, I need to take training so that I can recognize when an employee is on drugs. But I'm also the only employee, so really this is training so that I can figure out if I myself am on drugs. As an employee, I need to take a second training course so that I learn about all of the ways that my employer might surprise me with a random drug test and find out about drug use. But I'm also the employer so really I'm learning about how I might trap myself….

Five minutes after the FAA inspector left, I received a phone call. "I'm from the FAA and we'd like to schedule an audit of your drug testing program." I remarked that a fully qualified FAA inspector was barely out of the driveway and had just gone through every document that I had on the subject. "He was from the FSDO (Flight Standards District Office)? That's a completely different department. We're going to send two inspectors up from Atlanta next month." Why two? "We always send them in pairs."

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[Via Walter Olson.]