On June 9, 2026, TSA issued an interim revision to MD 1100.33-1, TSO Daily Fitness for Duty. Against Giants published its analysis of the May 4 directive on this site. This update addresses what the June 9 revision changed and what it did not.
What Changed
The interim revision clarifies that the daily fitness for duty certification is not limited to the swipe-in mechanism. When electronic swipe-in systems are unavailable or impracticable, including during deployed TDY assignments, approved attendance or accountability procedures may be used to document daily certification.
What Did Not Change
Unchanged by the June 9 Revision
The impairment definition is unchanged.The statutory basis under 49 U.S.C. 44935(e)(2)(A)(v) is unchanged.
The AWOL pathway is unchanged.
The escalation process to management-initiated fitness for duty evaluations under MD 1100.33-2 is unchanged.
The core daily certification obligation is unchanged.
What This Means
The June 9 interim revision clarifies the operational mechanics of how the daily certification is made. It does not alter the standard officers are certifying against or the consequences of failing to meet that standard. The analysis in AG's original article remains accurate on all substantive points.