United States Coast Guard (USCG) Drug and Alcohol Testing

Although the U.S. Coast Guard has operated under the Department of Homeland Security since 2003, its drug and alcohol testing protocols still align with the Department of Transportation (DOT) guidelines. Specifically, the USCG adopts DOT’s stringent drug testing standards as outlined in 49 CFR Part 40, while also enforcing additional maritime-specific rules under 46 CFR Part 16 and 46 CFR Part 4.

Who Must Comply with USCG Drug Testing?

According to the Coast Guard, a “covered employee” is anyone onboard a vessel who is working under the authority of a Coast Guard-issued credential—such as a license, Certificate of Registry (COR), or Merchant Mariner Document (MMD). This also includes crew members employed on U.S.-flagged vessels that must be staffed or operated by credentialed mariners.

USCG Testing Requirements and Standards

The Coast Guard mandates drug and alcohol testing to ensure maritime safety and regulatory compliance. The rules include:

• Substances Tested: Urine drug tests must screen for five specific substances: marijuana, cocaine, amphetamines, opiates, and PCP.
• Laboratory Analysis: All specimens must be tested at certified labs approved by the U.S. Department of Health and Human Services (HHS), using DOT procedures from 49 CFR Part 40.
• Alcohol Testing: Alcohol tests in marine operations may be conducted via breath or blood, depending on the situation.
• Employee Assistance Program: Marine employers must implement an Employee Assistance Program (EAP) that includes both education and supervisor training.
• Reporting Obligations: Employers must report any verified positive drug test for individuals holding Coast Guard-issued credentials, whether or not the individual is ultimately hired.

Steps to Obtain a Merchant Mariner Credential (MMC)

1. Determine the appropriate officer endorsement or rating by visiting the National Maritime Center’s Checklist.
2. Apply for a Transportation Worker Identification Credential (TWIC), indicating "merchant mariner" as your occupation.
3. Complete Form CG-719B: Application for MMC.
4. Submit Form CG-719C: Disclosure Statement (if applicable).
5. Fill out the required medical forms: CG-719K or CG-719K/E.
6. List any optional disclosures as needed on application forms.
7. Complete a DOT-compliant drug test and obtain a signed CG-719P Periodic Drug Testing Form.
8. Pay the required fees and retain a copy of the receipt for your records.
9. If applicable, include sea service documentation (e.g., Form CG-719S).
10. Submit photocopies of any relevant training certificates or assessments.
11. Submit the complete application package to a Regional Exam Center (REC). Email submission is recommended.
12. Optionally, use an expedited shipping service for credential delivery tracking.

Employer Compliance and Enforcement

Marine employers are legally obligated to report all verified positive or refused drug and alcohol tests to the Coast Guard for any individual holding a USCG-issued credential. This is required regardless of whether the position required credentials or whether the applicant was hired.

Failure to follow these reporting requirements can lead to severe civil penalties of up to $5,000 per day, per violation.

Consequences of a Positive or Refused Test

If a mariner refuses or fails a drug or alcohol test, the employer must immediately remove them from safety-sensitive duties. In the case of pre-employment screening, employment must be denied. For existing mariners, refusal or failure typically leads to suspension or revocation of their MMC, license, or COR.

If a mariner refuses a chemical test when directed by law enforcement, the refusal itself is admissible as evidence in administrative proceedings and can result in a presumption of intoxication. This may directly lead to suspension or revocation of Coast Guard-issued credentials.

Alcohol Intoxication Thresholds

A mariner is deemed intoxicated with a blood alcohol concentration (BAC) of 0.04% or higher. Additionally, visible signs of intoxication—such as impaired speech, unsteady movement, or unusual behavior—may also serve as sufficient grounds for disciplinary action or removal.

The Role of a Medical Review Officer (MRO)

A drug test result becomes officially "positive" only after it has been reviewed and verified by a licensed Medical Review Officer (MRO). The MRO evaluates the result to ensure it aligns with DOT procedures and verifies whether a legitimate medical explanation—such as prescribed medication—exists. Only after completing this verification does the MRO report a result as positive to the marine employer.

The MRO also reviews the testing process for accuracy and chain-of-custody compliance. If there are any discrepancies or valid medical justifications, the result may be overturned. This added step provides a critical safeguard against erroneous or unfair testing outcomes.