TSA Management Directive 1100.33-1, TSO Daily Fitness for Duty, was revised effective May 4, 2026. The revision added one requirement that changes the character of something every TSA officer does at the start of every shift. When you swipe in, you are making a daily certification under TSA policy that you are fit for duty, ready and able to meet your work obligations.
The Statutory Basis
The daily fitness for duty requirement is not a TSA policy choice. It is a federal statutory requirement that has existed since the Aviation and Transportation Security Act was enacted in 2001. Under 49 U.S.C. 44935(e)(2)(A)(v), TSA officers must have the ability to demonstrate daily a fitness for duty without any impairment due to illegal drugs, sleep deprivation, medication, or alcohol. That requirement exists in federal law and governs continued employment as a security screener. The May 4 directive implements that longstanding statutory standard with new operational specificity.
What the Revision Changed
The prior version of MD 1100.33-1, dated August 14, 2014, required supervisors to observe officers at the start of each shift and throughout the workday. The May 4 revision added a new element. The swipe-in itself is now the explicit operational mechanism of the daily fitness for duty certification. That is the meaningful operational change the revision introduced.
What Your Swipe-In Now Certifies
MD 1100.33-1 Section 5.D.(2)
Officers are responsible for understanding that swiping in at the start of the shift is their daily certification that they are reporting to work fit for duty, ready and able to meet their work obligations.By swiping in, you are certifying that to the best of your knowledge you are physically and psychologically able to perform the essential functions of your position safely and effectively, consistent with the Medical and Psychological Guidelines for TSOs.
That certification is made every shift.
What Impairment Covers
The revised directive defines impairment as a condition that reduces a TSO's ability to perform his or her job safely. The definition includes but is not limited to physical impairments, fatigue, drowsiness, lethargy, sluggishness, and other similar limitations due to sleep deprivation, alcohol, illegal drugs, or medication, including the failure to take prescription medicine as directed.
What This Covers That Officers May Not Realize
Fatigue, drowsiness, lethargy, and sluggishness have been named as forms of impairment since at least the 2014 version of this directive. Officers working overnight shifts, managing chronic conditions that affect sleep, or taking medications that cause those side effects are swiping in and certifying against a standard that expressly covers those states.Medication is defined broadly to include prescription medicines, over-the-counter medicines, and nutritional or other supplements and similar substances that may affect a TSO's performance. An officer taking a legally prescribed medication that causes drowsiness is certifying fitness under a standard that identifies that condition as a potential impairment.
The failure to take prescription medicine as directed is also listed as a form of impairment. An officer who misses a dose of a medication that manages a condition covered by the Medical and Psychological Guidelines and then swipes in has made a certification with potential consequences.
What Happens After the Swipe-In
The swipe-in does not end the daily fitness assessment. Within 30 minutes of the start of each shift, a supervisor will observe each officer for signs of impairment. That observation continues throughout the shift.
If a management official has a reasonable belief that a TSO is not fit for duty, or if the officer discloses an impairment and the supervisor concurs, the management official may offer the officer an opportunity to recover, such as taking a short break.
If the officer cannot remedy the impairment, the supervisor may permit the officer to request leave. If the officer does not have sufficient leave balance, leave without pay is available.
The AWOL Pathway
AWOL is not itself a disciplinary action. It is however a basis for taking corrective, disciplinary, or adverse action under MD 1100.75-3. Officers who fail to demonstrate fitness for duty must be notified in writing that future instances will be considered unauthorized absences and charged as AWOL. An officer charged with AWOL or repeatedly reporting not fit for duty may be subject to disciplinary or adverse action.
When the Daily Process Escalates
The daily fitness for duty process and the management-initiated fitness for duty evaluation process are distinct but connected. MD 1100.33-1 governs the daily certification and supervisory observation. When a management official develops a reasonable belief that an officer is not physically or psychologically able to safely and effectively perform the essential functions of their position consistent with the Medical and Psychological Guidelines, MD 1100.33-1 directs management to follow the procedures in MD 1100.33-2, Management-Initiated Fitness-for-Duty Evaluations.
That escalation process involves OCMO review, a formal determination of medically qualified, temporarily not medically qualified, or not medically qualified, and subsequent administrative actions that may include light duty, job search, or removal proceedings.
Light Duty Is Temporary
Adjustments or modifications to duties or schedule may be explored under the Light Duty Assignments directive while the escalated process is underway. The revised MD 1100.33-1 is explicit that such adjustments are temporary and not permanent. The TSO position cannot be modified. An officer on light duty may still be subject to a fitness for duty evaluation.
The Intersection With the AMC Program
What Collective Bargaining Can and Cannot Address
Officers have been told that collective bargaining is underway over the Annual Medical Certification program and the broader May 4 policy changes to make them less stressful. That claim is worth understanding in context.
The fitness for duty requirement itself is not subject to collective bargaining. Federal statute establishes that TSA officers must demonstrate daily fitness for duty and that standard cannot be bargained away.
What the CBA Does and Does Not Cover
The 2024 Collective Bargaining Agreement Article 32 addresses the management-initiated fitness for duty evaluation process that may follow when a daily fitness concern escalates under MD 1100.33-2. It establishes procedural protections for bargaining unit employees in that escalated process, including notification requirements, the right to be informed of the reason for the evaluation, and cost responsibilities for independent medical examinations.The daily swipe-in certification standard and the impairment definition that governs it flow from federal statute and are not addressed in Article 32.
What impact and implementation bargaining may produce is negotiated procedural protections around how the fitness for duty requirement is administered, including how supervisory observations are conducted and how officers are notified of their rights. What bargaining cannot produce is a change to the statutory standard itself, the impairment definition, or the requirement that officers certify fitness at swipe-in.
The 2024 CBA is currently preserved under federal court injunction in AFGE v. Noem, with a bench trial scheduled for September 2026.
What Officers Should Understand
The swipe-in certification is not new in concept. TSA officers have always been required to report fit for duty. What is new is that the swipe-in itself is now the explicit operational mechanism of that daily certification, grounded in a statutory requirement that has existed since ATSA was enacted, and that the impairment definition, which has included fatigue, medication effects, and sleep-related limitations since at least 2014, remains in full effect.
Officers managing chronic conditions, working overnight shifts, or taking medications that affect alertness should understand what they are certifying each time they swipe in. Officers who are unsure whether their current condition is consistent with the daily certification should consult their treating provider and review the Medical and Psychological Guidelines before their next shift.