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New Serious Marine Accident (SMI)
Alcohol and Drug Testing Requirements from the
US Coast Guard In Effect as of June 20, 2006
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As of June 20, 2006 each commercial vessel which is more than 2 hours from an open collection site capable of doing alcohol or drug test -- is now required to have a alcohol test device on board to administer to each person involved in a potential accident, as well as report for a drug test to the closest facility. For the full rule, please see this Federal Register site, or this PDF. A summary is contained below:
When did this come about and does it affect smaller vessels?
It was the result of a Congressional Passed law in 1998, and has been in the rulemaking process for many years, the above links provide background on the regulation. The statute requiring that alcohol testing be conducted within 2 hours of an SMI, 46 U.S.C. 2303a, does not provide for an exemption based on the size of the crew or the crew's safety history. The rule does allow relatively inexpensive Alcohol Screening Devices (ASDs) to be used provided the proper procedures are taken.
Can I use my usual collection site?
Yes. If you operate at all outside the site's business hours of operation (such as early mornings, evenings or weekends), or two hours or more from the site during business hours, you will need to have an alcohol kit for each person aboard your vessel. You will also need to have a chain of custody for the drug test.
What paperwork is needed?
The Coast Guard 2692 and 2692b forms must be completed for the alcohol test, the Chain of Custody form for the drug test, the applicable steps in using the device, and the regulation on SMI.
How to comply?
Maritime now offers its members a M-PAK® to guarantee full compliance with this new rule, containing:
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The needed DOT approved alcohol testing device (ASD), with instructions for its use |
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A Chain of Custody (COC) form for the drug test, which includes a full Coast Guard compliant drug test and collection at no fee, the COC is preprinted with each company's name and information as required (not a blank form). |
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Post-accident instructions including needed Federal Forms from the Coast Guard, including the updated form providing for the alcohol results. |
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The Coast Guard's requirement for training on the alcohol screening device's use is met with a Maritime developed one page Fact Sheet summary. |
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The M-PAC® contains the above referenced in a waterproof and tearproof envelope uniquely suitable for the marine environment. |
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