Random drug tests must continue during COVID-19 emergency

Written by Nick Blenkey
Coast Guard emblem

The Coast Guard has issued a Marine Safety Information Bulletin (MSIB) saying that marine employers with mariners in safety sensitive positions who are subject to drug testing under 46 Code of Federal Regulations (CFR) Part 16 must continue to conduct random urinalysis tests reasonably spread throughout the current year as per 46 CFR 16.230.

However, says the MSIB, “the Coast Guard understands that introducing third party collectors onto a vessel or sending mariners to a collection site, increases human contact during the pandemic. In order to minimize human contact and safeguard the uninterrupted flow of vital commerce, maritime operators are encouraged to adjust random selection dates and use their own office employees or mariners to administer the drug tests during the pandemic emergency. Many companies already have ‘in-house’ qualified collectors who are also authorized to train and certify other collectors.

“Virtual training options are also available on-line to certify urine collectors. However, the Coast Guard realizes that the challenges related to the pandemic, including the time to get employees trained, could make it difficult to reach the required 50% random test rate for all covered employees in 2020. Thus, the Office of Investigations and Analysis (CG-INV) will give due consideration to those challenges when deciding whether or not to initiate an enforcement action against marine employers who fall short of the 50% requirement. If a marine employer does fall short of the 50% requirement they should provide an explanation along with their 2020 Management Information System (MIS) reports describing the testing complications and/or delays encountered during the pandemic, and describe the steps taken to maintain their random testing programs.’’

The MSIB also gives guidance on requirements for pre-employment testing, post-casualty testing for serious marine incidents and reasonable cause testing.

You can download the MSIB HERE


American Maritime Safety, Inc.(AMS), the non-profit trade association that 400 vessel owners and operators use to facilitates compliance with the random testing requirements, had called for a three-month moratorium on the testing requirements.

Noting that 49 CFR Part 40 permits collections to be conducted by a supervisor when other collection options are not available, AMS has developed an emergency specimen collection training program that can be conducted for individuals or small groups (no more than five participants) via Zoom or Skype. The normal individual charge will be reduced by 40% to $300.

“Because the instructional method is necessarily inferior to the in-person method preferred by the DOT,” says AMS, “the duration of these collection certificates will be limited to the duration of the current national health crisis. However, trainees receiving these emergency certificates will be permitted to re-certify by participating in any regularly scheduled in-person AMS collector training at no additional charge.”

More on the AMS training program HERE

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