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DAMP organisation contracting third-party DAMP contractors (Non-DAMP organisations)
CASA EX70/19 — Implementation of Drug and Alcohol Management Plans (Non-DAMP Organisations) Instrument 2019
What is it?
This CASA instrument contains an exemption that is in accordance with proposed policy changes in future amendments to the CASR Part 99 regulations.
This exemption permits the following: a DAMP organisation (ie listed under CASR Part 99.030) to contract a DAMP contractor (ie a Non-DAMP third-party) without having to apply its DAMP to the contracted employees performing Safety-Sensitive Aviation Activities (SSAA).
What are the benefits?
The exemption permits one DAMP organisation that contracts a Non-DAMP organisation, for example the holder of an Air Operator’s Certificate (AOC) contracting the services of a ground handling agent, to accept the DAMP-like program of the contracted organisation. This removes the requirement of the DAMP organisation from having to apply its DAMP to the SSAA employees of the contracted Non-DAMP organisation.
How do I take advantage of the exemption?
For DAMP organisations (ie those organisations requiring a DAMP under regulation 99.030 of the CASR)
A DAMP organisation is not required to submit any applications to CASA for this exemption. It is a standard exemption published in accordance with proposed Part 99 policy changes in future amendments.
As a DAMP organisation, this exemption will allow for your organisation to accept the DAMP-like program of a DAMP contractor/Non-DAMP organisation, with certain conditions required to be met by your organisation as outlined in the exemption.
For DAMP contractors (ie third-party Non-DAMP organisations)
As this exemption allows for a DAMP organisation to accept your organisation’s DAMP-like program, your organisation would be required to submit an application form to CASA for assessment and approval of your organisation’s DAMP-like program.
As a Non-DAMP organisation, why do I need to apply?
DAMP organisations have their DAMP reviewed and accepted as part of a certificate approval process, for example, as part of an Air Operator Certificate or Certified Aerodrome under Part 139.
As a Non-DAMP organisation, your DAMP-like program will require assessment and approval by CASA to ensure that it meets the requirements of CASR subpart 99B, as this is the same standard required of all DAMP organisations. CASA will provide a regulatory service fee estimate upon review of your application, and an instrument of approval for your DAMP-like program will be issued following successful assessment.
We already have an alcohol and drug policy / DAMP-like program that is more stringent than CASR Subpart 99B. Will we need to change anything?
As your organisation’s DAMP-like program is assessed to CASR Subpart 99B requirements, this is taken as the minimum level of compliance. Therefore, if your program differs from CASR Subpart 99B, a gap analysis will help you determine if it is missing anything. This would also be part of the assessment conducted by CASA.
Ultimately your organisation has the right to choose to be more restrictive than the regulatory requirements. If the documented processes are not less restrictive than required, then a level of safety is being maintained and is accepted by CASA.
How do I apply?
Download an Approval of Drug and Alcohol Management Plan (DAMP)-like program (pdf 97.42 KB) and provide all documentation and information as detailed within the form. Details of where and how to submit the application are also included. The application will be assigned to the relevant area for review, issuing of estimate fee, and subsequent assessment once any required payment has been received.
If you have any further queries that are not addressed by the information provided above, please direct your inquiry to National.Operations@casa.gov.au.
CASA EX19/20 Amendment
Note: In relation to the record keeping requirements outlined in CASA EX70/19 being required to remain in force beyond the repeal date of the instrument itself, one amendment was made to address this as CASA EX19/20 Amendment Instrument. This does not affect the policy detailed in CASA EX70/19 and is published only as a correction of the repeal date issue. You will not be required to read EX19/20 in order to obtain any of the above related to EX70/19, however, you can access the CASA EX70/19 compilation to view what was amended for information purposes.