What do you need to know to perform drug and alcohol testing in the maritime industry? Part 5
Drug and Alcohol testing for Coast Guard Regulated Employers
Whenever a Serious Marine Incident (SMI) event occurs as described in the previous article, there is a requirement for the marine employer to conduct drug and alcohol tests on personnel whose actions cannot be discounted as contributing to the accident or was a causal factor leading to the accident. This can include the vessel Master/Captain and senior ship officers.
There are required reports to be submitted to the area Coast Guard Investigating Officer. These reports are designed to aid in the investigation of a Serious Marine Incident (SMI).
There are three different forms with two of them required for all SMI events. The first form titled CG-2692 (Report of Marine Casualty) is required to be completed within 5 days and reported within 5 days to the nearest Coast Guard Marine Safety Unit or Activity. The Form is two pages in length with 3 pages of instructions on how to correctly complete the form. This particular form asks general logistical questions, (Vessel name and type, location, weather and other pertinent information). A description of how the accident occurred and damage plus other information is required to be competed. Lastly the person making the report is required to sign and give contact information.
Another form is the CG-2692A (Barge Addendum) and is used in conjunction with the previous form when there is involvement with barge(s) that have caused damage or have sustained damage as described in CG-2692. It is never to be completed by itself.
The other required form is the CG-2692B (Report of Required Chemical Drug and Alcohol Testing Following a Serious Marine Incident). As described in a previous article, drug and alcohol tests are required to be conducted within certain time frames. Those test results also become part of the investigation into the SMI.
Information required on the CG-2692B includes basic vessel identification information with the name of the vessel master along with the name and address of the marine employer. There are 8 boxes listing the reasons why SMI testing is required. One or more of these boxes are to be completed along with the incident location.
Other required information is:
- Name of personnel involved in the SMI;
- Are these personnel licensed or hold a certification;
- A checkbox for each listed mariner to attest if the drug test was provided within 32 hours;
- Was an alcohol test provided within two hours with the type of specimen provided (saliva, breath or blood)?
- This should be accompanied with the test results. The test results can be a numerical value or a negative or positive response.
- The name and address of the SAMHSA accredited is required along with the name of the laboratory conducting blood alcohol tests (if blood was used) or the name of the individual conducting the breath of saliva alcohol testing.
The name and contact information of the person making this report is required along with a signature. A date is required to annotate when the form was completed and signed.
If the required testing was not completed within the required time frames, there is a block to be completed specific to the circumstances. This can also be used if there is a test refusal or unusual circumstances for testing. It should be noted that additional paper can be used as needed to complete this report.
This report is reviewed by the Coast Guard Investigative Officer and by NTSB, if they involved in the investigation.
An accident investigation can take months to complete depending upon the causal factors to be investigated.
By Bob Schoening
Robert Schoening is well renowned for his knowledge and influence in the drug-testing arena. As the Drug and Alcohol Program Manager for the US Coast Guard (December 2001-March 2013) he developed and managed a successful drug testing program for the marine industry nationwide and internationally. During this time he developed and implemented a new compliance audit checklist as well as the writing and publishing a new Marine Employers Guidebook for Drug Testing. He is also the author of the federal regulation commonly known as the two-hour alcohol testing for maritime incidents.