This guidance seeks to communicate three important messages. First, it reaffirms the importance of drug and alcohol testing as a critical factor in marine safety. Second, the Coast Guard recommends employers seek to train employees in conducting urine collection to reduce the need to bring third-party collectors aboard vessels or need for crew to transit to a collection facility ashore. Third, it provides opportunities to request a waiver of pre-employment testing for credentialed mariners recalled to service early who have been covered in another random testing program for at least 60 days within the last 365-days. Employers should develop contingencies for drug and alcohol testing as part of their continuity of operations and crew-protection planning.

MSIB 10-20 advises mariners and employers that the Coast Guard has not authorized the suspension of any drug or alcohol testing requirements, including random drug testing. Illegal use of dangerous drugs  or alcohol poses a tremendous risk to mariner, vessel, public and environmental safety. The reliability of the maritime transportation system is vital to overcoming the COVID-19 pandemic and for protecting our national security during emergency.

The Coast Guard acknowledges the training process may require time. However, the MSIB does provide a viable pathway for companies to avoid Coast Guard enforcement action if they fail to meet the federally required 50% random testing level for their covered employees for the calendar year.  The guidance explains that the Coast Guard will consider exercising enforcement discretion if companies maintain their drug testing programs throughout the pandemic and clearly articulate and report the challenges and delays faced in their end of year Management System Information reports to the Coast Guard.

COVID-19 has challenged every aspect of our nation and the American people. In these times, maritime safety, and its drug testing component, remains a fundamental need to ensure the reliability and resilience of the maritime industry. - USCG comments

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