What Aviation Body's Revised Breath Analyser Rules Mean For Pilots, Cabin Crew

Earlier, any detectable amount of alcohol was treated as a positive breath analyser result. Now, the Directorate General of Civil Aviation (DGCA) has defined Breath Analyser (BA) positivity as above 0.009 grams per 100 mL of blood.

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The most significant revision concerns the limit of alcohol that counts as a violation.
New Delhi:

India's aviation regulator has revised its norms on alcohol testing for pilots and cabin crew under the Civil Aviation Requirement (CAR). The revised rules moderate the regulatory baseline.

The most significant revision concerns the limit of alcohol that counts as a violation.

Earlier, any detectable amount of alcohol was treated as a positive breath analyser result. Now, the Directorate General of Civil Aviation (DGCA) has defined Breath Analyser (BA) positivity as above 0.009 grams per 100 mL of blood.

The revised CAR states, "For confirmatory BA readings up to 0.009% BAC or mg/dl for the first time, the crew shall be off-rostered and subjected to counselling."

In other words, readings up to 0.009 g/100 mL are not treated as a punishable violation. Instead, the crew member is counselled and temporarily taken off the roster.

This specific definition follows long-standing concerns from pilots and cabin crew that incidental exposure, such as through mouthwash, perfume, or certain medicinal products, could trigger trace readings.

At the same time, the CAR cautions that "no crew member shall consume any drug/formulation or use any substance such as mouthwash/tooth gel or any such product that has alcoholic content. This may result in a positive breath analyser test."

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First Violation: Counselling Instead of Immediate Suspension

Under the earlier framework, a first violation led to a three-month suspension of license.

The revised rules introduce a softer approach at the lowest end of the scale. A missed preflight breath analyser test for the first time and a negative post-flight test after the first landing are seen as the first violation, amounting to a warning.

For confirmatory readings up to 0.009 for the first time, the crew member shall be off-rostered and counselled. For scheduled operators, this counseling is to be carried out by the Chief Medical Officer and Chief of Flight Safety, with a focus on the adverse impact of alcohol.

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However, repeat cases are treated more seriously. The CAR makes it clear that "any repeat BA positive case shall be considered as a first violation and shall attract enforcement action" under the penalty table.

Penalties for Pre-Flight Violations

If a crew member is found positive in a pre-flight breath analyser test beyond the permissible threshold, the enforcement action escalates depending on whether it is a first, second, or third violation.

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A first-time positive test attracts a three-month suspension of licence or approval. A second positive test results in a three-year suspension. A third positive test leads to cancellation of licence or approval.

Missed tests also carry penalties. A first missed pre-flight test followed by a negative post-flight test results in a warning but is still counted as a violation. A second missed test can attract a three-month suspension, while repeated missed tests can lead to a one-year suspension.

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If an examiner, instructor, line training captain, or check pilot tests positive, the individual faces loss of approval or authorisation for three years in addition to other penalties. For expatriate pilots operating in India, a positive pre-flight test leads to cancellation of their Foreign Aircrew Temporary Authorisation (FATA), which will not be reconsidered.

Penalties for Post-Flight Violations

Post-flight violations are treated more severely.

If a crew member tests positive in a post-flight breath analyser test for the first time, the penalty is a one-year suspension of licence or approval. Action is also initiated under Schedule VIA of the Aircraft Rules, 1937. In the case of expatriate pilots, FATA is cancelled.

A second positive post-flight test leads to cancellation of licence or approval. If a crew member tests positive once in a pre-flight test and in a separate instance in a post-flight test, the suspension period rises to four years.

Missed post-flight tests also attract suspensions ranging from three months to one year, depending on whether it is a repeat offense.

Airlines Can Be Stricter

While the DGCA has moderated the regulatory threshold to 0.009 g/100 mL, airlines are free to impose stricter employment policies.

For instance, Air India last year stipulated that a reading above 0.020 grams per 100 mL of blood would lead to termination. A reading below 0.020 g/100 mL, though above the DGCA's threshold of 0.009, would invite a three-month suspension without pay. IndiGo follows a similar framework.

This means that even if a case falls within the DGCA's counselling bracket, an airline may still impose tougher service conditions under its internal rules.

The Legal Basis: 12-Hour Abstinence Still Mandatory

The core rule has not changed. Under Rule 24 of the Aircraft Rules, 1937, no crew member may consume alcohol within 12 hours of a flight. The CAR reiterates that no person acting as pilot, cabin crew, or other operating crew shall have taken any alcoholic drink "within 12 hours of the commencement of the flight" and must not be "in a state of intoxication or have detectable blood alcohol whatsoever."

The DGCA also notes that blood alcohol level alone is not the sole indicator of safety. Even when levels fall to zero, "hangover" effects can impair performance. That is why the 12-hour bottle-to-throttle rule remains firmly in place.

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