Frequently Asked Questions
I am an independent contractor, I work for mutiple companies, do I need to be on each companies consortium?
Yes, if you are working at more then 1 company you must be listed on each companies list of covered employees and that company must teat you as if you are an employee even if they give you a 1099.
I have taken a drug test, am I compliant?
No, simply taking a drug test does not make you compliant. There are many aspects to Drug & Alcohol testing in the maritme industry and you must comply with all elements.
Do I need to join a Consortium?
No, you do not need to join if your company can meet all of the requirements to ensure they are compliant. Many large companies will do this all on there own, though they may have people who are trained in the administration of DOT and Coast Guard Drug & Alcohol testing rules.
What Happens if I test Positive?
Employees who test positve must not be used in a safety sensitive position until they have met all of the requirements for return to duty set forth by the MRO and SAP.
Who Needs to be in a drug & alcohol testing program?
Any employee who serves in a safety sensitive capacity. That would include any crew member aboard a vessel who might assist passengers in daily operations or in the event of an emergency.
Do 6 Pack boats need to comply?
Yes, the regulations apply to all vessels.
What happens if I am not in compliant?
The Department of Transportaion and the USCG have a wide variety of options at their disposal. Fines are the most common penalty and can be upto $5000 per day for every day the vessel or company is not in compliance. Most actions are against the vessel owner though the USCG may take action against a mariners license as well.
How do I know if I am compliant?
If you do not have a company drug policy that includes supervisor and employee training and a random testing pool. You are not compliant.
If you do not know what is considered to be a serious marine incident / what to do in the event of / how to report or follow all Coast Guard rules and procedures after a serious marine incident. You are not compliant.
If all employees in a safety sensitive position are not in your company drug & alcohol testing program you are not compliant.
If you are on an uninspected vessel with paying customers but you do not have a company drug consortium because you are the only employee. You are not compliant.
Your captain is signed up with their own consortium. Not only are you NOT in compliance but ultimately YOU, as the employer, are the responsible party in a serious marine incident.
Do you have alcohol test strips to test your crew within 2 hours of a serious marine incident?
Do you have a plan in place to drug test your employees in case of a serious marine incident?