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 must ask an 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.” An employee’s failure to cooperate constitutes refusal to take the test. Although the direct observation rule is final, the FAA was accepting comments on that portion until September 25.