Drug testing: CG-719P and 46 CFR Part 16

When a test is required

46 CFR 16.220(a) — you must pass a test for:

• An original MMC.
• The first issuance, raise of grade, or renewal of an officer endorsement.
• A raise of grade.
• A first endorsement as Able Seafarer, Lifeboat Operator, QMED, or a tank vessel endorsement.
• Reissuance with a new expiration date.

The CG-719P puts it more usefully: a drug test is required for all transactions except endorsements, documents of continuity, duplicates, and STCW certificates.

The 185-day window

CAUTION — 185 days, not 'six months' 46 CFR 16.220(a)(5): the test must be completed and dated not more than 185 days before submission of the application. The NMC checklists say "within 6 months," which is a rounding — and in most months 185 days is slightly longer than six calendar months. The regulation controls. Work to 185 days and you will never be caught out by the difference.

The exemptions

46 CFR 16.220(c) — you need not submit a test if you have:

1. Passed a test required by Part 16 within the previous 6 months, with no positive test since; or
2. During the previous 185 days, been subject to a random testing programme under 46 CFR 16.230 for at least 60 days, without failing or refusing.

If you work for an employer with a compliant random programme, a letter from them satisfies the requirement and saves you the test. And 16.220(d): only one test is needed however many transactions are covered by a single application.

The panel

The CG-719P lists five: marijuana, cocaine, amphetamines, opiates, PCP. That is the old five-panel, and it is a summary of a form, not the law. The controlling table is 49 CFR 40.85, which since 2018 also includes:

• Hydrocodone and hydromorphone
• Oxycodone and oxymorphone
• 6-acetylmorphine
• MDMA and MDA

This matters to anyone taking prescribed opioids. A valid prescription is handled by the Medical Review Officer, but it must be disclosed to the MRO, not discovered by them. Say it before the result comes back, not after.

The mechanics

• The test must meet 49 CFR Part 40 — a SAMHSA-accredited laboratory and an MRO-verified result. A result from a pharmacy kit is worthless here.
• The cost is yours, not the Coast Guard's. The CG-719P says so in terms.
• CG-719P is formally optional — it is a convenient format. What is mandatory is the substance: a Part 40-compliant, MRO-verified negative.
• Refusal is treated as a failure, and is referred for action against the credential.

The Medical Review Officer

The MRO is a licensed physician who stands between the laboratory and the Coast Guard. A laboratory reports a result; the MRO decides what it means. That distinction is the applicant's protection, and it is worth understanding before you need it.

If a test comes back positive, the MRO contacts you before reporting anything. A lawful prescription, properly evidenced, is resolved at that stage and the result is reported as negative. Miss the MRO's call, or fail to produce the evidence, and the positive stands — and a positive result under 46 CFR 10.209(h) ends the application.

Testing does not stop at issue

46 CFR Part 16 governs the working mariner as well as the applicant. Once you are sailing you remain subject to:

The random programme is the one that also does you a favour: sixty days inside it, in the previous 185, and you are exempt from testing for your next application entirely.