The 11 Federal DOT and Coast Guard Requirements
The Coast Guard regulation states that each company, which includes sole operators who carry passengers, tow boats, or are engaged in any other marine commerce, must have a written policy on drug abuse and controlled substances. This policy must be kept in the company's files and be readily accessible. ASTS will provide a company policy that meets the Coast Guard requirements. A letter of compliance is also provided to the company member.
Reports and Recordkeeping
Each year, a summary of the firm's drug testing records must be prepared and submitted to the Coast Guard (MIS Form). The drug rule also requires the maintenance of all records of the administration and results of the program for five years. ASTS will prepare and maintain all necessary records and summaries for each firm. The MIS report is mailed at the end of each calendar year to the employer for processing.
Employee Assistance Program
Each firm must have a written employee assistance program, and conduct one hour of anti-drug training for all employees. ASTS will provide each marine firm with a written employee assistance program, and a training manual for its employees. A video rental is also available upon request.
Collection Sites, Chain of Custody and
Certified Testing Laboratories
Each firm must have one or more designated collection sites which have the resources to comply with all required procedures. ASTS will designate an approved collection site for each firm. The collection sites are always located within 30 miles (usually less) of the Company's main address. Careful chain of custody must be followed. ASTS will provide all necessary forms and shipping supplies. Tests will be reviewed at a laboratory certified by the Department of Health and Human Services (DHHS). ASTS has a contract with a major DHHS certified laboratory to conduct all member tests.
Anyone hired must be tested before they join a drug testing program, unless they submit proof of having passed a periodic or pre-employment drug test within the past six months, or unless they were covered under a random testing program for the past 60 days. This includes crew hired on a full-time or temporary basis, whether for one day or longer. In addition, ASTS will issue each employee a plastic wallet identification card to prove enrollment in the program.
Serious Marine Incident Testing
Employees must submit specimens after a "serious marine incident", as defined by the Coast Guard. ASTS will assist the Employer with the collection of the specimen(s) by providing a local collection site. Specimen(s) will be collected and submitted for testing to the designated DHHS certified laboratory.
Reasonable Cause Testing
According to the Coast Guard regulation, a marine firm that believes an employee has used an illegal drug must arrange for a specimen to be collected from the employee. ASTS will assist the Employer with the collection of the specimen(s) by providing a local collection site. Specimen(s) will be collected and submitted for testing to the designated DHHS certified laboratory.
Periodic tests must be conducted at the same time that physical exams are given and Coast Guard licenses are renewed. All periodic tests are conducted at your local Occupational Health Center/Physician's Office. As long as you have been enrolled in a random testing program for 60 days, you are exempt from a periodic test, and ASTS will provide you a letter to provide to the Coast Guard upon license renewal.
The Coast Guard requires all firms to randomly test (using a statistically valid random selection process) a number of employees equal to 50 percent of all employees each year. ASTS administers a qualified computer random testing program for all members.
Medical Review Officer
All results must be reviewed and interpreted by an approved Medical Review Officer (MRO). ASTS provides four(4) certified Medical Review Officers to review and interpret each test result. In the case of a positive test, the MRO interviews the employee by telephone, before a result is reported to the employer.
Crewmember Background Check
It is a required by the USCG for employers to conduct a background check on ALL prospective employees/crewmembers (49 CFR§40.25). As a courtesy, ASTS has provided its members with the following form to aid in complying with this regulation. Complete and download a Release of Information Form in PDF.