The Coast Guard issued Marine Safety Advisory 01-20 to ensure that mariners, marine employers, and sponsoring organizations are aware that some products marketed as hemp or cannabidiol (CBD) may contain enough tetrahydrocannabinol (THC) to cause a positive drug test.
In accordance with 46 CFR 16.201(c), an individual who fails a chemical test for dangerous drugs must be removed from duties directly affecting the safe operation of the vessel, and is subject to suspension and revocation proceedings against his or her credential under 46 CFR part 5. Use of hemp or CBD products is not accepted as an affirmative defense (acceptable excuse) against a THC-positive drug test result. For these reasons, mariners wishing to avoid a positive THC drug test result should exercise extreme caution when considering the use of any hemp or CBD product because such use could result in the loss of their merchant mariner credential and immediate removal from safety sensitive duties aboard a vessel. This warning applies to hemp and CBD products in any form, including those that are taken by mouth and those that are applied to the skin.
THC is the primary psychoactive component of the Cannabis sativa plant. Hemp and marijuana are different strains of the Cannabis sativa plant and both contain varying concentrations of THC and CBD. THC is considered a dangerous drug because it produces an intoxicating effect on the user and poses safety-risks to vessel operations. The U.S. Coast Guard prohibits THC use by mariners because of its known debilitating effects, and all U.S. Coast Guard-required drug tests screen mariners for use of THC.
Recent changes to Federal and State laws have resulted in a surge in the availability of over-the-counter hemp products and CBD products throughout the United States. Hemp products and CBD products are marketed to the general public in several forms such as food and medicinal products, dietary supplements, oils, cosmetics, and hair products. In some cases, product manufacturers market these products as low in THC, or THC-free. Mariners should be aware that over-the-counter hemp products and CBD products have not been approved as medications by the U.S. Food and Drug Administration (FDA) and are not regulated by the FDA. Therefore, users lack federal assurances of their ingredients, THC-content, quality, effectiveness, or safe use. As a result, mariners using these products put themselves at risk of having a THC-positive drug test result.
It remains unacceptable for any U.S Coast Guard credentialed mariner or other safety-sensitive worker working aboard a vessel that is subject to U.S Coast Guard drug testing regulations to use THC. Claimed use of hemp products or CBD products is not an acceptable defense for a THC- positive drug test result.
To learn more about the risks of hemp and CBD products visit the FDA website. This Safety Advisory was developed by the U.S. Coast Guard Office of Investigations and Analysis. Questions or comments should be sent to: DAPI@uscg.mil.
This blog is not a replacement or substitute for the formal posting of regulations and updates or existing processes for receiving formal feedback of the same. Links provided on this blog will direct the reader to official source documents, such as the Federal Register, Homeport and the Code of Federal Regulations. These documents remain the official source for regulatory information published by the Coast Guard.
Categories: Investigations & Casualty Analysis, Mariner Credentialing, Safety
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