Who this service is for
This service is designed for Part 135 operators and aviation employers that need help building, reviewing or maintaining their drug and alcohol compliance program. It is also useful when an employee takes over DER responsibilities, the organization changes service providers, or management wants a structured review before an inspection.
Support can focus on a specific administrative issue or a broader program assessment. The initial discussion identifies your operating context, the responsibilities already assigned and the information available. We then define the work around the employer’s actual needs, rather than assuming that every aviation business has the same testing program or staffing model.
The DER remains an employer responsibility
Under 49 CFR 40.3, the DER is an employee authorized by the employer to make required decisions and take immediate action concerning safety-sensitive duties. Service agents cannot act as DERs. Our consulting and training support is intended to strengthen the employer’s designated employee and administrative processes, not substitute an outside consultant for that required role.
Clear boundaries matter in everyday work. Staff should know who can receive communications, who can make decisions, and how the employer’s DER is reached. A vendor agreement or consultant relationship should not leave the organization uncertain about who owns a time-sensitive employer decision.
Typical problems we help address
A program may have a written policy but inconsistent instructions for supervisors. Records may be difficult to locate, vendor contacts may be outdated, or responsibilities may depend on a single person’s memory. Different departments can hold different versions of the same process. These weaknesses make routine administration harder and complicate an inspection response.
Another common challenge is separating aviation requirements from information intended for another transportation mode. We help teams organize the applicable program information and identify questions that require verification with the governing agency or qualified service provider. A familiar procedure should still be checked when its assumptions or regulatory basis change.
What we can deliver
An agreed engagement can include policy and procedure review, a program gap assessment, an administrative responsibility matrix, DER orientation or refresher support, and improvements to record organization. We can help review the flow of communications between the employer and service providers and develop practical checklists for recurring administrative tasks.
MIS reporting support can address the organization and review of program information where applicable. Training material can help managers understand their assigned responsibilities and escalation routes. The purpose is to make the program understandable and usable, with clear ownership of the decisions that remain with the employer.
A practical starting point
The review begins with the program structure, relevant policies, assigned roles and a defined sample of administrative records. We discuss gaps, prioritize improvements and identify how completion will be checked. Sensitive testing information should be handled through an agreed, appropriate process; do not include employee test results or personal medical information in an initial website inquiry.
MMM Consultations is based in Orlando, Florida and supports aviation organizations nationwide. Luis F. Macías brings experience directing aviation drug and alcohol programs and holds a Certified DER credential. Contact us to discuss DER support for your Part 135 operation, a policy review or a structured assessment of your existing program.