Pre-employment drug screens are used as the primary drug test for employment or licensing purposes. On November 13, 2017, the DOT testing requirements stayed as being classified as a 5 Panel DOT Screen, but what the DOT added was expanded panels for the Schedule 2 Opiates Panel. The DOT 5 panel test includes testing for:
• Marijuana (THC)
• Phencyclidine (PCP)
So, our members are still required to complete a 5 Panel DOT Screen, however, you will hear about the new expanded test that the DOT will require in January 2018. This is just a breakdown of subparts within each paneled regimen because of all the new drugs out in our society today the DOT wants to ensure all are staying/being safe when out on the waters. Bullet Opiates, numbers 4, 5, 6, and 7, are the breakdown of what has been added as well as all other paneled screens:
• Marijuana (THC)
3. 6-AM (Heroin)
• Phencyclidine (PCP)
The official drug test result form used for Coast Guard Licensing Packets (CG-719P) still refers to this as a 5-Panel test and APCA immediately updated their processes to be compliant with 46 CFR 16.210. Taking this test for APCA will enroll you into the random testing program for 12 months starting on the day you take your pre-employment drug screen. This 5 panel DOT test is the only drug screen the Coast Guard will acknowledge.
If you’ve already had a 5 Panel DOT drug screen in the last 6 months or have been susceptible to a USCG random testing program 2 of the last 6 months, you may use proof of that instead of taking a Pre-employment drug test to join APCA.
We offer some hypothetical situations that may explain it more clearly;
Captain Jack runs an 18 passenger sightseeing pontoon boat out of Bill’s Pass Marina. While he runs the boat himself, licensed by the Coast Guard, he does hire deckhands on an occasional basis. Besides keeping the boat clean they assist in making sure the passengers don’t fall overboard. While they do not carry USCG Credentials they are required to be covered by a random drug program as is Captain Jack. Additionally, it is Captain Jack’s responsibility to see to a pre-employment drug test for these deckhands. Had they been covered (in a specific period) by a random program in their last job, this could have been used in lieu of a pre-employment drug test.
Occasionally, Captain Shorty uses his 22 foot Aquasport to take four people out charter fishing on weekends. This requires a 6-Pak license (OUPV). Once in awhile he takes his teenage son along as an assistant/ deckhand to steer the boat while he helps the passengers rig their lines. By law, Captain Shorty and his son must be pre-employment tested as well as covered by a random program. Obviously it is not an easy project in this situation. The drug laws were written for large and small companies but not very specific in family situations. How does Captain Shorty randomly select himself and his son? Does he flip a coin and say, , “Oops, it’s your turn this time.”
The easy answer to the question is joining a drug consortium program that offers simple solutions to these seemingly complex problems. APCA started a random drug consortium program to solve problems.
Periodic drug screens are used solely for the mariner who is seeking or renewing their license and does not intend to work on the water. This type of test is only good within 6 months of the test date and will not enroll you into the random testing program. A periodic test through APCA will be compliant with 46 CFR 16.220 and is sufficient for licensing purposes.
In the event of a Serious Marine Incident, the primary concern is safely getting everyone back on land. As soon as that has happened, mandatory post-accident drug testing must occur for all safety sensitive employees aboard the affected vessel. An alcohol screen must be completed within 2 hours of the incident and a DOT drug screen must be completed within 32 hours. APCA provides the materials to complete these tests for our registered companies per 46 CFR 16.240. There are additional costs involved, However, since it isn’t a part of the random testing program.
Occasionally employers become wary of their employee’s actions and want to have them drug tested to ensure there is no substance abuse. However, companies cannot request random tests, because it defeats the nature of being a random test. Instead, companies have the option to have their employee tested as a Reasonable Suspicion test. All the employer needs to do is record the causes for reasonable suspicion and request the test from APCA. Ideally, two supervisory personnel should attest to the causes of requesting the reasonable suspicion test but keeping a detailed note of the causes is sufficient. Once the test arrives, the employer must notify the employee of the causes for the test when it’s handed over for completion. There is an additional charge for this type of test since it isn’t a part of the random testing program and APCA will observe DOT collection guidelines while assisting in the Reasonable Suspicion testing process.
APCA’s random testing program is mandatory for merchant mariners in a safety sensitive position and is compliant with 46 CFR 16.230. Safety sensitive is defined as any mariner overseeing the safety of civilians aboard their vessel and especially includes those with duties during a serious marine incident. Mates are NOT exempt from this regulation. APCA will manage all test records per 49 CFR 40 and 46 CFR 16 and will issue a Letter of Compliance as proof of successful enrollment into APCA’s random testing program. We ensure the Coast Guard’s mandated minimum testing percentage rate is observed and the annual MIS Report detailing our end-of-year totals is submitted for all of our members.