Quick reference guide for a DAMP Medical Review Officer (MRO)

The following is a guide for a medical practitioner who may be asked to be consulted as a DAMP medical review officer (MRO) for the purposes of Subpart 99B of the Civil Aviation Safety Regulations (CASR) 1998.

What are aviation's drug and alcohol regulations?

In 2004, the Australian Transport Safety Bureau (ATSB) recommended the introduction of mandatory alcohol and other drug (AOD) testing for the aviation industry.

In response, the Australian Government directed the Civil Aviation safety Authority (CASA) to develop a drug and alcohol management program for the aviation industry, similar to programs in place in other transport sectors. In March 2009, Part 99 of the Civil Aviation Safety Regulations 1998 (CASR) was introduced.

What is a DAMP?

Part 99, Subpart B of the Civil Aviation Safety Regulations 1998 requires certain aviation organisations to develop a Drug and Alcohol Management Plan (DAMP). These organisations have employees who perform tasks that directly or indirectly affect aviation safety. These tasks are referred to as safety sensitive aviation activities (SSAA).

An organisation's DAMP must include the following:

• a drug and alcohol education program
• a drug and alcohol testing program
• a drug and alcohol response program.

Alcohol and drug tests must be conducted to the following Australian standards;

• Alcohol tests - AS 3547, Breath alcohol testing devices for personal use or NMI R 126, Pattern Approval specifications for Evidential Breath Analysers; and
• Drug tests - AS 4760 for oral fluid testing and/or AS/NZS 4308 for urine testing.

In certain circumstances, a DAMP organisation must consult a medical review officer (MRO). More detailed information follows. 

What competencies must a DAMP MRO have?

A DAMP MRO is a medical practitioner who must have:

• competence in the field of interpreting drug and alcohol test results; and
• knowledge of substance use disorders; and
• knowledge of the contents of Part 99, Subpart 99B.

What knowledge of Part 99 is required?

When must an organisation consult an MRO? r99.055

A DAMP organisation must consult an MRO in the following three circumstances:

• If a confirmatory drug test conducted under that organisation's DAMP returns a positive result - to determine if the presence of the testable drug could be the result of legitimate therapeutic treatment or some other innocuous source
• If a SSAA employee has failed to give a body sample for AOD testing due to a medical condition – to confirm that there is a valid medical reason for that failure
• To determine if the employee is fit to resume performing or being available to perform a 'safety sensitive aviation activity' (SSAA) after they have been prevented from doing so following a 'suspension event'.

What is a 'suspension event'? r99.070(1)

Part 99, Subpart 99B requires that a DAMP organisation must not let an employee to perform, or be available to perform, an applicable SSAA, in the following circumstances or 'suspension events':

• If a positive result for a confirmatory drug test has been recorded under the organisations testing program and the MRO has not ruled out that the result recorded could be due to legitimate therapeutic treatment or some other innocuous source.
• If the organisation is aware that a SSAA employee after having been required to take a drug or alcohol test:
  • refused to take the test
  • interfered with the integrity of the test

What are the requirements for a SSAA employee to be returned to work? r99.070(2)

In the circumstance of a suspension event, a DAMP organisation must only permit an employee to return to SSAA duties or be available to perform SSAA if the following applies;

1. the employee has undergone a comprehensive assessment  for drug or alcohol use;
2. if the comprehensive assessment recommended the employee commence a drug or alcohol intervention program — the employee has begun participating in a nominated drug or alcohol intervention program;
3. the employee is considered fit to resume performing, or being available to perform, an applicable SSAA by:
   
   1. DAMP medical review officer; and
   2. the employee's treating clinician, if any;
4. if the suspension event related to a drug test — at the time the employee was considered fit under paragraph (c), the employee receives a confirmatory drug test and records, for the test, a result that:
   
   1. was not a positive result; and
   2. a DAMP medical review officer is satisfied indicates the absence of testable drug use.

What is a comprehensive assessment? r99.010

A comprehensive assessment, in relation to a person's drug or alcohol use, means an examination of the person's physiological and psychosocial indicators carried out:

1. by a psychiatrist; or
2. by a medical practitioner who is a Fellow of the Australasian Chapter of Addiction Medicine; or
3. jointly by:
   
   1. a person entitled to practice as a medical practitioner under a law of a State or Territory; and
   2. an appropriately qualified drug and alcohol professional.

What is a nominated drug and alcohol intervention program? r99.010

The drug or alcohol intervention program, in relation to a person who has a drug or alcohol problem, means a program that includes any of the following measures for that problem:

1. assessment;
2. treatment, including any of the following:
   
   1. education;
   2. counselling;
   3. consultation with health care professionals;
   4. pharmacotherapy;
   5. residential or non-residential treatment programs;
3. monitoring and follow-up action.

Is there a difference between a DAMP MRO and CASA MRO?

A DAMP organisation consults an MRO for testing conducted by their organisation under the DAMP. CASA MRO's are appointed by CASA and conduct their duties in relation to testing under CASA's random testing program.