TSA published Handbook 1100.73-6, Alcohol-Free Workplace, effective September 14, 2026, signed by Assistant Administrator for Human Capital Thomas J. Regan.
Most of what officers assume about discipline does not operate here. In the ordinary discipline system, management weighs twelve penalty factors and picks from a range. This handbook decides a long list of outcomes in advance and leaves the weighing for a narrow set of cases.
Who Is Subject to Testing
Not everyone. Testing applies to employees in what the handbook calls an alcohol testing designated position, abbreviated throughout as alcohol TDP. Section A(8) describes those as positions "characterized as having critical safety/security-sensitive duties related to TSA's mission," and explains that the job functions involved "have a direct and immediate impact on public health and safety, the protection of life and property, law enforcement, or national security."
The same section adds a note worth reading carefully. Positions designated for alcohol testing are also subject to drug testing, but not every drug testing designated position is an alcohol testing designated position. A position subject to neither is a non-TDP.
Section C(1) lists the five reasons an employee in an alcohol testing designated position can be tested: random, reasonable suspicion, post-accident or incident, return to duty, and follow up. Section C(6)(c) sets the annual random rate at thirty-three percent of those employees, with the Administrator holding discretion to raise or lower it.
Two provisions extend the reach. Section C(3) applies the same requirements to employees in those positions who work remotely or from an alternative worksite. Section C(4) applies all five testing reasons to an employee in a non-TDP who is detailed to an alcohol testing designated position for 90 days or more.
Section C(5) requires TSA to issue individual notices to employees whose positions are designated, and written notice before a test. Both subsections then say that failure to provide the notice "does not prevent TSA from testing the employee." An officer who was never told their position is designated can still be tested.
Prohibitions are broader than testing. Section E(3) states that all employees are prohibited from on-duty alcohol use, not only those in tested positions.
Against Giants can confirm whether your position is designated for alcohol testing and what that means for you.
The Numbers
Section A(7) sets the thresholds. A confirmation measurement of 0.04 or greater is a confirmed positive. A confirmation measurement between 0.02 and 0.039 is not-ready-for-duty.
Section D(5)(e) is worth knowing:
For anyone in a follow up testing program, the handbook is not internally consistent about the threshold. Section A(26) defines a positive result as 0.04 or greater "or 0.01 for return-to-duty and/or follow-up test." Section E(2)(a) defines the same term as 0.04 or greater "or 0.02 or greater for a return-to-duty and/or follow-up test." Section I(2) requires return to duty and follow up tests to measure less than 0.01. An officer in that program should assume the strictest of the three applies and should not rely on any of them without asking.
Where the Outcome Is Already Decided
Six categories carry a predetermined result.
On-duty alcohol use. Section H(3)(a) states TSA will initiate an action to remove any employee for a finding of on-duty use, and Section H(3)(b) states there is no opportunity to enter a rehabilitation program.
Refusal to submit to a required test. Section H(5) states TSA will initiate action to remove, with no opportunity for rehabilitation.
A second violation. Section H(6)(a) states TSA will initiate removal for a second violation of alcohol-related conduct prohibited by the handbook, and Section H(6)(b) adds that "the second violation does not have to be the same type of violation as the first violation."
A positive test while in the follow up testing program. Section H(1)(b) provides for proposed removal with no additional opportunity to enter rehabilitation.
Three or more DUI or DWI offenses. Section H(7)(e), removal with no opportunity for a rehabilitation program.
Any violation during a trial period. Section H(9) states employees serving a trial period who violate any part of the handbook "will be removed from Federal service with no opportunity for rehabilitation."
Section F(9) is the one line in this area that opens a door, and it applies to employees whose positions are not designated for alcohol testing. It directs that they be referred to the Employee Assistance Program, that a substance abuse professional assessment is not required, and that management should contact Headquarters Employee Relations "for the appropriate administrative action." That is a referral to a case-by-case determination rather than to a fixed outcome.
Against Giants can tell you which category an allegation falls into before you respond to anything.
Refusal to Test Is Broader Than It Sounds
Section E(5) defines refusal as "any action by an employee that is determined to be interfering with, obstructing, or causing undue delay in completion of such test," and then lists six specific forms, including failure to appear within a reasonable time, failure to remain at the testing site until the process is complete, failure to provide an adequate amount of breath, and "a failure to cooperate with any part of the testing process."
Other sections add more. Under Section D(4)(i), failing to report directly to the testing site once notified is a refusal. Under Section D(4)(iv), failing to return in a timely manner with photo identification is a refusal. Under Section D(4)(viii), leaving between the screening and the confirmation test is a refusal. Under Section D(6)(a)(ii), refusing a second attempt to provide breath is a refusal.
Section D(3)(c) covers leaving for an emergency. An employee who leaves the testing site must provide "verifiable documentation on official letterhead from a credible outside professional" within a reasonable time, and failure to do so "will result in a refusal to test determination, which is grounds for removal from Federal service."
Against Giants advocates for officers facing refusal to test determinations, and the facts of what happened at the testing site are usually the whole case.
Insufficient Breath, at Your Expense
Section D(6) governs what happens when an employee cannot produce enough breath. Three attempts are allowed under Section D(6)(b). After that, Section D(6)(c) requires an immediate medical evaluation by a physician specializing in pulmonology or occupational medicine, and states that "the cost of the evaluation will be incurred by the employee."
The employee must schedule within five business days and provide the appointment details to management five business days before the appointment. Section D(6)(f) states a qualifying medical condition "does not include unsupported assertions of situational anxiety or hyperventilation." If the Medical Review Officer finds no medical explanation, Section D(6)(l) makes it a refusal to test.
Off-Duty Conduct Reaches In
Section E(7) covers DUI and DWI. Section H(7)(a) requires all employees to report a DUI or DWI offense to a management official within twenty-four hours.
Section H(7)(c) sets a proposed seven day suspension for a first offense for non-law enforcement employees, plus an alcohol awareness education program at the employee's expense. Section H(7)(d) sets fourteen days for a second. Law enforcement officers face fourteen days on the first offense under Section H(7)(f) and proposed removal on the second under Section H(7)(g).
Two provisions matter for anyone in that position. Section H(7)(h) states the proposed penalty "may be increased or decreased if aggravating or mitigating factors are present," which is where a mitigation argument lives. And Section H(7)(j) states management "is not required to wait for a final disposition of any criminal proceeding" before proposing action.
Section E(4)(d) lists how an abstinence failure may be established, including direct observation, the employee's own admission, administrative inquiry, and off-duty alcohol-related conduct or arrests. A note beneath it states TSA may learn of an off-duty situation "through any available means," naming reports of investigation, newspaper articles, police sources, and information obtained from a medical examination.
Against Giants can work through a DUI response with you, including the mitigation the handbook expressly allows.
Self-Referral, and When the Door Closes
Section F(1) provides that an employee in an alcohol testing designated position who voluntarily identifies as someone who misuses alcohol is considered to have self-referred, and that an employee identified through other means, including arrests, testing, reports of investigation, or direct observation, is not.
Section F(2) sets the cutoff plainly:
Section F(7) states that no disciplinary or adverse action is required where the employee successfully completes the recommended rehabilitation program and refrains from further alcohol misuse or illegal drug use while employed with TSA.
There is one exception and it is significant. The note at the end of Section F states that admission of on-duty alcohol use is a violation of the on-duty prohibition, and that any employee who voluntarily identifies as having used alcohol while on duty "will be subject to removal for a finding of on-duty alcohol use."
Where the Protections Actually Are
Section C(7)(b) sets a real standard for reasonable suspicion testing. The determination "must be based on specific, contemporaneous, articulable observations concerning the appearance, behavior, speech, or body odors of the employee," and the section states that "mere 'hunches' are insufficient to meet the standard for a reasonable suspicion test."
Sections C(7)(c) and (d) require the supervisor to gather the information, obtain concurrence from a second-line or higher supervisor, and obtain legal concurrence from Chief Counsel. Section C(7)(e) states that if Chief Counsel does not concur, "the request for testing will be canceled."
Section C(7)(g) sets time limits. A test not conducted within two hours requires an incident report. A test not conducted within eight hours must be canceled.
And Section C(7)(h)(iii) is the sentence to remember:
Section D(10)(b) lists two fatal flaws that cancel a test: no 0.00 result on the air blank conducted before the screening or confirmation test, and the technician failing to print and sign their name on the form. Section D(10)(a) states a test may not be canceled for a minor procedural error that does not prejudice the employee's right to a fair and accurate test.
Against Giants examines whether these procedural requirements were met in your case, because the handbook makes some of them dispositive.
What It Costs You
Section I(4) provides that the initial SAP assessment and the aftercare sessions are at no cost, and that "cost for further diagnostic or rehabilitation services or treatment is the responsibility of the employee." Section D(6)(c) puts the pulmonary evaluation on the employee. Sections H(7)(c) and H(7)(d) put the alcohol awareness education program on the employee.
What This Means
The handbook fixes most outcomes in advance and leaves discretion in a narrow set of places, most of them before or during a test rather than after one. The moments that matter are the reasonable suspicion determination, the conduct at the testing site, whether a self-referral came before or after notification, and the mitigation the handbook expressly permits for DUI offenses.
An officer who learns those provisions after a determination has been made has learned them too late.
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