The International Brotherhood of Teamsters (IBT) is pleased to provide comments to the Federal Aviation Administration’s (FAA) Notice of Proposed Rulemaking (NPRM) entitled Drug and Alcohol Testing of Certain Maintenance Provider Employees Located Outside of the United States. The Teamsters are proud to represent tens of thousands of members in the aviation industry who ensure, and rely on, the safety of aircraft and of our National Airspace System. This includes pilots and flight attendants for whom planes are their workplaces, and demand that aircraft be maintained safely, regardless of where the maintenance is performed. Important to this rulemaking, this also includes the world’s most highly skilled maintenance technicians, who maintain aircraft across the nation and whose work is increasingly threatened by carriers’ outsourcing schemes which place profit above safety.