DAMP
DRUG AND ALCOHOL MANAGEMENT PROGRAMS
GUIDANCE FOR COMMON ISSUES
In the past 5 years many organisations have been audited or have submitted DAMP
enquiries. In this time there have been several common issues found by CASA DAMP
auditors.
The following are the most common issues found.
Organisation has no DAMP
There are many organisations with a relevant CASA permission and SSAA employees, who
do not have a DAMP implemented.
If the organisation has no DAMP whatsoever in place, an NCN should be issued against
r99.035 [SUBPART 99B Drug and alcohol management plans] and the audit process would cease at that point.
In such a case, the remedial action required of the DAMP organisation would be to
develop a DAMP. The corrective action would be for the DAMP organisation to implement
a DAMP. A new surveillance event would then be opened to audit that DAMP.
Organisation has a basic CASA template/framework DAMP
We have found the majority of organisations have a CASA template/framework DAMP, and
many of these DAMPS do not contain the extra detail required for a compliant DAMP.
If the organisation does have some form of DAMP in place (however basic or incomplete) the audit
process moves to examine:
1. the content of the DAMP; and
2. whether the specific regulatory requirements (set out elsewhere in Subpart 99B) for its
implementation have been met.
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DAMP
DRUG AND ALCOHOL MANAGEMENT PROGRAMS
GUIDANCE FOR COMMON ISSUES
Confusion over who the DAMP applies to
There is some confusion over who a DAMP organisations DAMP should cover.
For example, whether it should cover part time employees, administrative staff, contractors,
including contractors who have their own DAMP under CASR Part 99, volunteers, work
experience students, and student pilots.
As the regulations are currently written, DAMP organisations must cover all SSAA employees,
whether they are full time or part time, direct employees or contractors, paid or unpaid, so this
covers most of those listed above.
Administration staff that do not perform, or are not available to perform, or who cannot effect
aviation safety if airside are not considered ‘SSAA; employees, this will be better defined
when our contractor exemption in completed and made available.
Student pilots are not currently covered by the regulations as they are not employees. This
however may change with the PIR.
A regulatory requirement under 99.045 Content of DAMP is that
‘A DAMP organisation’s DAMP must:
(a)
apply to all SSAA employees of the organisation, and state each category of the
organisation’s SSAA employees covered by the DAMP;’
Testing
The most common issues found with testing are as follows:
How testing is carried out
There is a lack of understanding of meeting the regulatory requirement to test to the AS/NZ
Standards.
Many organisations believe they are testing in accordance with the regulations, due to their
provider assuring them they can test in accordance with the relevant standards.
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DAMP
DRUG AND ALCOHOL MANAGEMENT PROGRAMS
GUIDANCE FOR COMMON ISSUES
Unfortunately many of these testing providers are not accredited to test in accordance with the
relevant standards. The organisation must produce a NATA scope of accreditation which will
show if the testing provider is in fact accredited to test to the relevant standard.

The organisation should have evidence or a contract in place to ensure that tests are
conducted to the relevant standards. AS/NZS 4308 (urine) or AS 4760 (oral fluid)
OR

If the organisation is outside of a capital city, they could take advantage of the
testing and
screening exemption
Remote and rural locations (outside of a capital city) with no access to accredited
testing providers:
Many organisations are in remote and rural areas and may not have access to accredited
testing providers. If they are, they could take advantage of the testing and screening exemption. (a
Doctor, Nurse or trained collector can be used to conduct tests).
Many do this anyway without knowing about the exemption. They need to ensure they are
testing as per the exemption conditions.
When Testing is carried out
Organisations do not always test when they are meant to.
The instances in which they must test are as follows
All employees, including contractors, sub-contractors and volunteers, who perform, or are
available to perform SSAAs must be AOD tested in the following circumstances:

When an employee first joins an organisation as a ‘regular SSAA employee’.

When a DAMP supervisor has ‘reasonable grounds’ to believe that an SSAA
employee may be adversely affected by AOD.

When an SSAA employee is returning to work after suspension due to testing
positive to a testable drug.

After an ‘accident’ or ‘serious incident’. [DAMP GUIDANCE].
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DAMP
DRUG AND ALCOHOL MANAGEMENT PROGRAMS
GUIDANCE FOR COMMON ISSUES
Education
The most common issues found with education are as follows:
Education program not meeting the required components

Policy

Testing

Support and assistance

Risk to aviation safety

Additionally for DAMP supervisors – education and training to manage people who
engage in problematic AOD use.
If the organisation is using their own education program they must ensure it covers these
components. Implementing a DAMP - Drug and alcohol education program
CASA has developed an eLearning package to help organisations deliver SSAA employee
and DAMP supervisor education. This package is available on the CASAs learning platform,
AviationWorx, and consists of two modules:


'Alcohol and Other Drugs - Managing the Risk’ (for SSAA employees)
'Alcohol and Other Drugs - DAMP Supervisor’ (for DAMP supervisors).
The AOD eLearning contains general information relevant to all DAMP organisations.
Some organisations do not realise they must In addition, ensure that all SSAA
employees (including contractors, subcontractors and volunteers) understand their individual
responsibilities under their organisation’s DAMP.
It is not compulsory to use the CASA eLearning, but is recommended to ensure compliance.
Organisations not educating at the required times
Not all organisations educate their SSAA employees and DAMP Supervisors at the required
times. These are:

SSAA employees must complete the education program before commencing SSAA
duties. This requirement applies to new employees as well as existing employees
whose role is changing to include SSAAs.

DAMP supervisors must complete training for that role before commencing it.

SSAA employees and DAMP supervisors must complete subsequent education at
least once every 30 months.
Implementing a DAMP - Drug and alcohol education program
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DAMP
DRUG AND ALCOHOL MANAGEMENT PROGRAMS
GUIDANCE FOR COMMON ISSUES
Lack of knowledge about or misuse of exemptions
The issue here is that industry either don’t know about their existence or they are using them
when not eligible or not meeting conditions of the exemption.

Testing Exemption testing and screening exemption
To use this, an organisation must be outside of a capital city or arranging testing for an
employee outside of a Capital city.

Micro Business DAMP Exemption DAMP exemption for micro-businesses
To use this, and organisation must not be RPT or service RPT and must have 10 or less
SSAA employees. They must adopt the CASA MICRO DAMP
* DAMP framework, guidance material, administrative obligations and fact sheets for the
organisation are available on the CASA website [DAMP GUIDANCE].
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