DATIA recently submitted comments to the FAA regarding their clarification of drug testing for “each person who performs a safety-sensitive function directly or by contract (including by subcontract at any tier) for an employer.” The FAA received a large number of comments about this particular phrase when the rulemaking was first published in 2002, and therefore re-opened the comment period. View DATIA's comments in PDF and HTML.  

The docket is open until August 16th if others want to submit comments at http://dms.dot.gov, docket# FAA-2002-11301.