Our clients that fall into this category must follow very strict guidelines.  A client of ours, Guy Maher with Lanier Media, explained it perfect in his article in, “Part 135 Lite” in Vertical Online .  He stated, ” If a pilot popped postive on a random drug test for Part 121 or 135 company, or was no longer employed with that company, there is no way that information would get to the Par 91 operator – or vice versa.”

If you are in the FAA world it is best to follow good practice and get enrolled in a program. Guy thank you for your insite and good words.