Hiring an FAA DER Program Manager: Key Qualities to Consider
- glradiohour
- 2 days ago
- 7 min read
By G.L. Henderson | Federal Drug Testing Services (FDTS)
Former FAA Drug and Alcohol Compliance Enforcement Inspector
Choosing the right person to run your FAA Drug and Alcohol Testing Program is one of the most important staffing decisions for any aviation employer, yet it is often misunderstood.
Many hiring managers treat this role like any other compliance job. They look for someone who is organized, pays attention to details, and ideally has experience in HR or safety, then give them the manual. After that, they just hope everything goes smoothly until an FAA inspector arrives.
This hiring approach has led to more enforcement cases than I can remember.
The person you choose for this job will be responsible, both officially and in daily work, for every part of your program under 14 CFR Part 120 and 49 CFR Part 40. They will make on-the-spot decisions with real regulatory and legal effects. When your company is audited, an FAA Drug Abatement Division inspector will speak directly with them.
So what qualities should you really look for? The answer is more complex than most job postings suggest, and the best candidate might already be working in your organization, even if their résumé does not mention "compliance."
Why the Job Description Alone Won't Find Your Candidate
The typical job posting for a DER or drug and alcohol program manager emphasizes things like:
Knowledge of DOT regulations
Experience with HR or safety systems
Strong organizational skills
Attention to detail
Those points aren’t wrong, but they don’t tell the whole story. They often bring in candidates who look great on paper but freeze up when inspectors ask questions, or who handle paperwork fine until a real situation calls for judgment.
This job needs something more specific. You have to work accurately under pressure, speak confidently with both regulators and employees, and make solid decisions on the spot, often without a supervisor to sign off. These skills don’t always come with a compliance credential. They come from real experience, and often from backgrounds you might not expect.
The Core Competencies You're Actually Hiring For
Before you consider background or title, define what you need the person to actually do well. The DER role under Part 120 requires:
Regulatory fluency means more than just memorizing rules. It is about truly understanding how 49 CFR Part 40 and 14 CFR Part 120 work together, what they require, and why they matter. Someone who can explain the reasoning behind a regulation is more valuable than someone who only knows the section numbers.
Decision-making under pressure is essential. After an accident, tests need to be scheduled right away. Reasonable suspicion calls must be made on the spot, and if someone refuses to test, you have to act immediately. The person in this role must move quickly, make the right choices, and keep proper documentation.
Communication across all levels is important. The DER will work with front-line employees, MROs, collection sites, TPAs, SAPs, legal counsel, senior leaders, and FAA inspectors. Each conversation needs a different approach, but all require clear and confident communication.
Documentation discipline is more than just filing paperwork. It means understanding that records tell a story. Every entry, date, signature, and note can become evidence for or against you during an inspection.
Vendor management is a key part of the DER’s job. The DER must ensure that every service agent in your program, such as collection sites, laboratories, MROs, TPAs, and BATs, meets regulatory standards. This means knowing what proper performance looks like and having the confidence to speak up when it falls short.
Confidentiality and integrity are essential. Drug and alcohol test results are some of the most sensitive employee records. The person handling them must know the confidentiality rules under Part 40 and exercise the discretion that protects both employees and the company.
Transferable Skills: Where to Look Beyond Obvious Candidates
This is a common area where hiring managers overlook strong candidates. The backgrounds listed below often produce professionals who are well-suited for FAA drug and alcohol program management, even without direct compliance experience.
Military Veterans with Administrative or Legal Specialty Backgrounds
Veterans who worked in roles involving regulatory compliance, investigations, law enforcement, or administrative decisions have a mindset that fits this work well. They know how to handle the chain of custody, document everything, stay calm in high-pressure situations, and follow strict rules.
A veteran who managed administrative records, conducted investigations, or served in a legal, JAG, or military police role will know what good documentation looks like in practice and will naturally follow those habits.
Law Enforcement and Investigative Professionals
Former law enforcement officers, especially those with experience in evidence handling, chain of custody, report writing, and regulatory enforcement, bring a level of precision to the DER role that is hard to teach. They know that documentation is as important as actions, and they can communicate with authority figures while staying calm.
This experience applies directly to inspection situations. When an FAA Drug Abatement Division inspector asks detailed questions about your program, it is essentially a regulatory interview. Someone with a law enforcement background will handle this calmly.
Healthcare and Medical Administration Professionals
People who have worked in clinical settings, hospital administration, or medical records know the importance of confidentiality, proper documentation, and the risks of procedural mistakes better than most. They are used to environments where even a single documentation error can have serious consequences. They also usually understand the MRO process and medical review terms, which helps them communicate more clearly with Medical Review Officers and avoid misunderstandings.
Human Resources Professionals with Employee Relations Experience
An HR professional who has handled sensitive employee issues such as terminations, investigations, accommodation requests, or fitness-for-duty concerns brings strong documentation skills and knows how to handle emotional situations professionally. They may need to learn more about regulations, but their ability to manage the human side of a positive test or refusal is a unique strength.
Many of the best DERs in large organizations started in HR and then received strong compliance training. They know how to manage employee interactions without letting situations escalate, which is a skill you cannot learn in a classroom.
Aviation Operations and Safety Professionals
Anyone who has worked in aviation safety, quality assurance, or operations oversight already understands the FAA's regulatory culture. They know what it means to be ready for an audit, why documentation matters, and they are not caught off guard by inspections. They may need to learn the details of drug and alcohol regulations, but they already have the right mindset.
An aviation safety professional who completes formal DER training often becomes one of the best program managers in the industry because they combine an understanding of the culture with regulatory knowledge.
Paralegals and Legal Professionals
People with paralegal or legal backgrounds have excellent documentation habits, know the difference between procedural and substantive compliance, and can read and interpret regulations accurately. They also understand that every record could be reviewed, so they act with care. In enforcement situations, such as responding to FAA investigation letters, preparing for hearings, or dealing with civil penalties, a DER with a legal background is a great asset.
Red Flags in Candidates for This Role
It's important to know what to look for, but that's just part of the process. Some patterns often signal trouble in this role, no matter how strong a candidate looks on paper.
Watch out for candidates who can't explain how they make decisions.
In the DER role, the reasoning behind a decision is just as important as the decision itself. Someone who makes good choices but can't explain their thinking can be a risk during inspections.
Be cautious with candidates who struggle with uncertainty.
Regulations won't cover every possible situation. Strong DERs know how to apply regulatory intent when clarity is lacking, and they reach out for help when needed. Candidates who need strict rules for everything will likely struggle.
Look out for candidates who see compliance as just paperwork rather than a real responsibility. This job matters because people's lives depend on a safe, unimpaired workforce. If someone doesn't see the bigger purpose behind the paperwork, the program can slowly slip in ways that lead to inspection problems.
Be wary of candidates who avoid conflict.
Sometimes, a DER will need to remove a senior employee from duty while waiting for a test result. They may have to challenge a collection site that isn't following the rules or deliver tough news. If a candidate can't stand firm in these situations, the program could be at risk.
Training Is Not Optional, It Is the Foundation
No matter their background, every DER needs proper training. The regulations do not set a specific minimum training requirement for DERs, but Part 120 expects them to be competent. FAA inspectors check this directly.
Even the best hiring decision will not go far if the new DER is simply given a binder and left to figure things out on their own. Providing formal DER training before the inspector visits, rather than after, can mean the difference between a smooth-running program and one that faces problems.
FDTS Level I DER training covers the basics of regulations. Level II teaches candidates to think like inspectors and review their own program, as it will be checked during an audit. With both levels, a DER becomes not only compliant but also able to defend their work.
The Question Worth Asking Before You Post the Job
Before you write the job description, ask yourself this: If an FAA inspector came in tomorrow, spent two days reviewing every record in our program, and then had a two-hour interview with our DER, would you feel confident?
If your honest answer is no, the solution is not just hiring someone new. It is making sure your hire is well-trained. The right person, with the right background and training, is the best compliance investment an FAA-regulated employer can make.
Preparing your DER new or experienced for what inspectors actually evaluate?
G.L. Henderson is the founder of Federal Drug Testing Services (FDTS) and a former FAA Drug and Alcohol Compliance Enforcement Inspector. He is the author of Trust but Verify: FAA Drug & Alcohol Compliance: What Every DER, Manager, and Executive Needs to Know, available on Amazon. FDTS provides FAA DER certification training, DOT compliance consulting, and international aviation drug and alcohol program support.
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