Original Message

by supplement to act for the safety of the aircraft, is to put them on a certificate holder's drug and alcohol program!   Otherwise, they come to work, intoxicated, hide in the bedroom, and sleep it off, as has been seen many times over and over.   But, because they are not employees of the certificate holder in many cases, they are putting the certificate holder at huge risk because they are insulated.

They are crewmembers, on a Part 135 aircraft, obligated under 91.17, and the certificate holder (and FAA) should consider them in the same vein as a flight attendant, since they perform just about all the same duties as a flight attendant in the back of the aircraft isolated from the pilot station by curtains and physical barriers.

That was the point of this whole excercise above.   They are crewmembers working for the certificate holder who should have them on the certificate holders random drug testing program, whether a direct employee or not!