The FAA has revised drug and alcohol testing procedures, specifically requiring “direct observation” in all return-to-duty and follow-up drug tests. Effective November 1, observers of the testing must do the following: “As the observer, you must request the employee to raise his or her shirt, blouse or dress/skirt, as appropriate, above the waist; and lower clothing and underpants to show you, by turning around, that they do not have a prosthetic device. After you have determined that the employee does not have such a device, you may permit the employee to return clothing to its proper position for observed urination.” The FAA also issued a final rule effective August 25 on specimen validity testing. Failure to cooperate by raising clothing above the waist, lowering clothing and underpants and turning around for the direct observation constitutes refusal to take the test. Although the direct observation rule is final, the FAA is accepting comments on that portion by September 25 (see www.regulations.gov, docket number OST-2003-15245).