Commercial Vessel Compliance

MSIB: Guidance for Maritime Operators on Compliance with Federal Drug Testing Requirements

Editors note: The Office of Investigations and Analysis writes about the challenges facing employers to conduct mandatory drug testing during the COVID-19 pandemic response. In this article they explain options to maintain compliance in this challenging environment.

Submitted by: Patrick Mannion, Office of Investigations & Analysis
Drug & Alcohol Prevention & Investigation Program Manager

The Coast Guard has published Marine Safety Information Bulletin 10-20 to reiterate the importance of drug and alcohol testing and provide suggestions to overcome the challenges of compliance during the COVID-19 pandemic.  

This guidance seeks to communicate three important messages. First, it reaffirms the importance of drug and alcohol testing as a critical factor in marine safety. Second, the Coast Guard recommends employers seek to train employees in conducting urine collection to reduce the need to bring third-party collectors aboard vessels or need for crew to transit to a collection facility ashore. Third, it provides opportunities to request a waiver of pre-employment testing for credentialed mariners recalled to service early who have been covered in another random testing program for at least 60 days within the last 365-days. Employers should develop contingencies for drug and alcohol testing as part of their continuity of operations and crew-protection planning.

The reliability of the maritime transportation system is vital to our nation, The COVID-19 pandemic has caused great concern for the health and safety of mariners. Employers have enacted new safety-measures with the goal of protecting employees from infection and to ensure that their crews and vessels are able to support the transportation needs of our nation during this national emergency. These efforts are laudable and reasonable. However, these efforts must not prevent the continuation of meeting drug and alcohol testing requirements for random, reasonable-suspicion and post-casualty testing events.

The Coast Guard Drug and Alcohol Program is responsible for ensuring industry compliance with the drug and alcohol testing regulations. It has received hundreds of inquiries since the declaration of COVID-19 as a national emergency on how to comply with the drug and alcohol testing regulations. The Department of Transportation has also received questions and has published drug and alcohol testing guidance on its website.

The publication of MSIB 10-20 and this article is to address the common elements of these inquiries and to specifically offer recommendations and guidance to facilitate compliance.

MSIB 10-20 advises mariners and employers that the Coast Guard has not authorized the suspension of any drug or alcohol testing requirements, including random drug testing. Illegal use of dangerous drugs  or alcohol poses a tremendous risk to mariner, vessel, public and environmental safety. The reliability of the maritime transportation system is vital to overcoming the COVID-19 pandemic and for protecting our national security during emergency.

The Coast Guard recognizes that accessibility issues for drug testing are real in this time of travel restrictions and COVID-19 transmission concerns. To improve access to urine collectors for drug testing, the Coast Guard recommends employers consider training select employees as urine collectors in accordance with Department of Transportation regulations. This would allow timely and correct collection of a drug test in the narrow window of time as required by 46 CFR Part 16. Additional information on the training of employees to become urine drug test collectors is available from the Department of Transportation website.   

The Coast Guard acknowledges the training process may require time. However, the MSIB does provide a viable pathway for companies to avoid Coast Guard enforcement action if they fail to meet the federally required 50% random testing level for their covered employees for the calendar year.  The guidance explains that the Coast Guard will consider exercising enforcement discretion if companies maintain their drug testing programs throughout the pandemic and clearly articulate and report the challenges and delays faced in their end of year Management System Information reports to the Coast Guard. 

COVID-19 has challenged every aspect of our nation and the American people. In these times, maritime safety, and its drug testing component, remains a fundamental need to ensure the reliability and resilience of the maritime industry.

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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.

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