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Using a Drug Testing Letter from Your Employer for Your USCG License

Learn how to use a drug testing letter from your employer to meet the USCG drug testing requirements for licensing.

5 mins read・Oct 10, 2023
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Maritime employers will typically either include the correct statement on your company sea service letter or they will give you a separate memo on company letterhead.

Aerial view of marina boats.

What kinds of employers can provide Drug Testing Documentation? 

Maritime related employers can provide Drug Testing Documentation for USCG licensing. The maritime related employer must have a random testing program meeting the criteria of Title 46 CFR 16.230. 

Examples of Maritime related employers are:

  • Tour boat operators
  • Passenger cruise lines
  • Charter fishing companies
  • Ferry operators
  • Deep sea shipping companies
  • Tug and barge companies
  • Marine construction companies
  • Coastal shipping companies
  • Shipyards
  • Inland shipping companies
  • Port authorities

If you are working in any other industry that has a random drug testing program meeting the criteria of Title 46 CFR 16.230 it will not be acceptable as it needs to be from a maritime related employer. 

When am I Eligible for a Drug Testing Document From my Maritime Employer?

There are two options. 

  • The most common is that you need to have been enrolled in their random testing program for at least 60 days during the previous 185 days. 
  • The second option is that you’ve passed a pre-employment drug test that meets the criteria of Title 46 CFR 16.230.

Obviously, you need to have passed the drug tests and not refused to participate in any drug tests as part of their program.

What Counts as Passing a Drug Test From my Maritime Employer?

You must always get a negative on your DOT 5 Panel Drug test that is conducted according to 49 CFR part 40 that is signed by an MRO (Medical Review Officer).

The USCG will not accept any other result - including “negative – dilute” or “positive”. They will also not accept any other drug test, only the DOT 5 Panel Drug test called out in 49 CFR part 40.

If you test positive or have a negative – dilute, the MRO and your employer are required to report it to the Coast Guard Investigations team at your nearest USCG Sector and they will open an investigation which could cause you to lose your USCG license.

What Needs to be on the Drug Testing Letter from a Maritime Employer when I’m part of a Random Drug Testing Program?

There are three main things that the USCG requires for license applications when you are part of your company's random drug testing program. 

The letter must include the following:

  1. The letter is on a marine company's letterhead
  2. The letter is signed by a company representative with a clear date with 185 days of USCG license application submission
  3. The letter from the marine company says verbatim: APPLICANT’S NAME / (SSN or MMC Reference Number) has been subject to a random testing program meeting the criteria of Title 46 CFR 16.230 for at least 60 days during the previous 185 days and has not failed nor refused to participate in a chemical test for dangerous drugs. 

What Needs to be on the Drug Testing Letter from a Maritime Employer when I’ve Passed a Pre-employment Drug Test?

There are three main things that the USCG requires for license applications when you are using documentation from passing a pre-employment drug test for your new maritime employer.

The letter must include the following:

  1. The letter is on a marine company's letterhead
  2. The letter is signed by a company representative with a clear date with 185 days of USCG license application submission
  3. The letter from the marine company says verbatim: APPLICANT’S NAME / (SSN or MMC Reference Number) passed a chemical test for dangerous drugs, required under Title 46 CFR 16.210 within the previous six months of the date of this letter with no subsequent positive drug test results during the remainder of the six month period.

What Needs to be on a Sea Service Letter for Drug Testing Documentation from an Employer? 

Your sea service letter must include all of the information required by 46 CFR 10.232 for a sea service letter on company letterhead and it may include documentation for meeting the Drug Testing Requirement for USCG licensing. 

The sea service letter must include the following:

  1. The letter is on a marine company's letterhead
  2. The letter is signed by a company representative with a clear date with 185 days of USCG license application submission

Then depending on your situation it can either say verbatim: 

Part of Random Drug Testing Program:
APPLICANT’S NAME / (SSN or MMC Reference Number) has been subject to a random testing program meeting the criteria of Title 46 CFR 16.230 for at least 60 days during the previous 185 days and has not failed nor refused to participate in a chemical test for dangerous drugs. 

OR

Recently Passed a Pre-employment Drug Test:
APPLICANT’S NAME / (SSN or MMC Reference Number) passed a chemical test for dangerous drugs, required under Title 46 CFR 16.210 within the previous six months of the date of this letter with no subsequent positive drug test results during the remainder of the six month period.

Have Questions About Drug Testing Documentation from a Maritime Employer?​​

As you can see, there are a few different ways to meet the USCG drug testing requirements for licensing. If you are working for a maritime related employer, you can either provide documentation of your participation in a random drug testing program or documentation that you passed a pre-employment drug test that meets the criteria of Title 46 CFR 16.230.

It is important to note that the USCG has very specific requirements for the drug testing documentation that they will accept. Make sure to carefully review the information above to ensure that your documentation meets all of the requirements.

If you have any questions about the USCG drug testing requirements make sure to reach out inside of MM-SEAS using the help icon and our team of MM-SEAS USCG Licensing Specialists will help get you pointed in the right direction.

MM-SEAS is free to use on your own and if you need some more personalized help you can upgrade to MM-SEAS Pro inside of the site.

No matter what, when you are ready to submit your application, you can choose to have the MM-SEAS staff create a perfect application, handle the USCG application fees and work with the USCG on your behalf to resolve any issues for a flat fee of $349 or you can choose to submit on your own.

Pro MM-SEAS members get access to unlimited live 1 on 1 calls with one of our USCG Licensing Specialists. We've found that answering questions live with screen sharing in a video call makes both of our lives easier. Pro MM-SEAS members can access these features inside of MM-SEAS under License Guidance.

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About the author

Nate Gilman
Nate Gilman
Captain
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Nate has over 15 years of professional maritime experience and has hawsepiped his way to a 3rd Mate Unlimited Endorsement with full STCW compliance. He is proud veteran of the NOAA Commissioned Corps.

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