Random Drug Testing

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grouchyturtle

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What are the requirements for drug testing, for crew members on a UPV who don't hold any type of credential?

I'm having trouble with the Coast Guard getting back to me with a definitive answer as to where the line is drawn.
Charter Boat Consortium's answer is yes...but of course they have an interest in that answer being yes.
I find it really hard to believe that unlicensed crew members on a small boat are actually required to be in a drug testing program.
 
In our area we have the same questions and ambiguous answers. My understanding is the CFR's say that all crewmenbers (licensed and unlicensed) must be on the vessel's drug program. But that makes it difficult for mates to work on multiple boats on a freelance basis. What I have been told is that as long as they are on "some random program" it is acceptable. All in all, the only real way to find out how your local MSO interprets the rules is to have an accident and find out. In that case, I hope the unlicensed crew member is a part on my program.
 
Good point. May as well just enroll the first mate then for the measly $50/year.
 
I have also been told the drug program also serves a purpose on UPV's beyond making sure the crew members aren't stoned. It also makes it more difficult to get around the 6 person passenger limit by assigning crew member status to non-crew to carry extra passengers. An example would be giving away a 7th spot to a group leader or instructor and calling them "crew".
 
Wow! Big brother is watching us under the microscope.

Again, it really never comes in to play until you have an accident and they investigate. Unless someone that doesn't like you (like that overbearing PITA customer that you yelled at) drops a dime on you.
 
Short answer in our area of NC (and fairly sure that the CG District in FL is no different) that your crew members need to be in a program. We do trade deck mates around and there has been no issue that they were not on "my" program, just as long as they had a drug test card from some program.

I have used deck mates that are on a random program at their full time work and that fit the requirement according to the MSO that I dealt with. You need to have something that fits the DOT rules to show the CG when the issue comes up. You would need to check with your local MSO to be sure they don't have ideas or rules different for your area.

Really you need to join NACO and use the consortium they have. It is not expensive for either membership and makes the drug program easy to administer. Costs $50 per member after the initial. I even have several of the regular customers who are instructors/DM types on the program...
 
I already am a member of NACO and the consortium. I'm asking the question for the first mate. But you're right, considering all the other costs of running, this is very minor, and I need to just get her signed up.
 

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