Random Drug Testing

[CAPTAINMIKESSII]

The rules for a commercial vessel for hire are black and white...all designated crew must be in the random drug testing program belonging to the vessel they work on..And to my knowledge havent been changed(but they should)
...The enforcement isnt so cut and dry and it really makes no sense for a "shared" crew member to be in multiple programs.
The issue of "crew sharing" has been around for a long time and every MSO and DAPI officer seems to have a different approach to the issue. Naco had been working on this because CFR Part 40.25 doent allow it...in 2008 CG Rear Admiral Salerno conveyed his opinion that this (40.25)was essentially overkill and that the intent of the regulation was to get all crew members IN a random program.

To date I have not seen any official document detailing an approved procedure for crew sharing.

The final answer is its not worth the $50 to stress on the issue for me I just enroll all my crew.
JMHO

 

[Tortuga James]

It is a good idea to give your crew members the "Return to Service" process document BEFORE they get called for their first random test. Should they get called and test positive they have to immediately be removed from your crew and cannot return to any job on the water until they complete this very extensive process, and must submit to increased testing for a period of 5 years afterwards. It is reported to the Coast Guard and if they are credentialed their ticket is immediately suspended. Doesn't look good for us operators either, plus you lose a crew member. Best policy is to make it clear to everyone that the Coast Guard takes "zero tolerance" very seriously. It is best to let that thing pass right on by, I don't care how good the party is. Better yet, don't even put yourself in a situation where one makes the rounds. That is tough, given the nature of 20 something year old crew members in coastal communities.

 

[Wookie]

It is wrong that every crew member has to be in a random testing program, and CG Galveston wrote me a letter so stating. Every crew member in a safety sensitive position muct be in a random testing program, and we verify this every year during our annual inspection. So, what does this mean? Our chef and stewardess specifically do not have any duties to the vessel beyond saving themselves (as would a passenger) in an emergency. Their only responsibility during routine drills or during an actual emergency is to go to the evacuation station, don appropriate life saving gear, and abandon the vessel upon the order of the Captain/Mate/Senior Deckhand.
In your case, does the mate stand a watch, help in the event of a man overboard, help divers/snorklers into and out of the water? If so, they must be a consortium member, or in a random testing program of your choice. If they are just cooking, perching out onthe trampoline as eye candy, or cleaning the cabin during the run, they are non-safety sensitive and are excused from the program.

 

[ComputerJoe]

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".

Still a "Company Representitive" is still allowed to ride without diminishing the 6 paying customers of a 6 pak.

 

[ComputerJoe]

A friend who tows his boat had a discussion with a state trooper. Since the dot is clamping down on small tows, those over 10,000 lbs combined which some trucks would exceed even without a trailer. Any who apparently the drug program he was on for his 100 ton was not acceptable for the DOT requirement so he was told he would have to be enrolled in another random drug test program.