X3 Marine Testing,Field by Field.
Random draws, post-incident clocks and the annual MIS report for 46 CFR Part 16.
- 46 CFR 136-144Subchapter M towing vessels
- 46 CFR 199.180Monthly drills
- 46 CFR 10.301Medical certificates
- 46 CFR 16.230Random testing — 50%
- 29 CFR 1915.12Confined & enclosed spaces
- 29 CFR 1917.50Crane certification
- 33 CFR 105.220Security drills every 3 months
- 33 CFR 155.1060Spill response exercises
- 46 CFR 4.05-10CG-2692 within 5 days
- 46 CFR 4.06-32-hour / 32-hour test clocks
Every record X3 Marine Testing keeps, the rule behind it, how often it comes due, and exactly what to type in each field — with where to find it on your own paperwork.
Covered Pool
46 CFR 16.230(a)-(b), (i)-(j) · Update whenever someone is hired, changes job or leaves
The list of crew in your random drug-testing pool. Every crewmember in a safety-sensitive job must be in a random program, and a boat may not sail with a crew that isn't covered.
| Field | What it is | Where to find it | Example |
|---|---|---|---|
| Covered by random testing | Yes if this person is in your random drug-testing pool. | Your consortium/TPA pool roster. It should match this list exactly. | Yes |
| Position | The person's job aboard. | Crew list or HR file. | Deckhand |
| Consortium / TPA | The consortium or third-party administrator (TPA) running your random draws. | Your consortium enrollment letter or contract. | Maritime Testing Consortium |
| Vessel type | Inspected if the boat has a Coast Guard COI; otherwise Uninspected. | Look for a Certificate of Inspection (COI) posted aboard. | Inspected |
| Why covered | Why this person must be tested. | Their job and whether it requires an MMC. Company-policy coverage is for extra people you choose to include. | Required to hold a license… (16.230(a)) |
| Joined the pool | The date the person was added to the random pool. | Consortium roster change confirmation, or the hire date. | 06/30/2027 |
| Left the pool | The date the person was removed from the pool. Leave blank while they are still covered. | Termination date, or the consortium's removal confirmation. | 12/31/2027 |
Random Selections
46 CFR 16.230(c)-(h) · Each random draw. Tests must be spread through the year to reach the 50% rate (46 CFR 16.230); quarterly or monthly draws are common practice.
Each person picked in a random draw and what happened next. Auditors check that selected people were tested promptly or that a valid reason was documented.
| Field | What it is | Where to find it | Example |
|---|---|---|---|
| Draw period | Which draw this selection came from. | The consortium's selection list or notice. | 2027 Q3 |
| Collect by | The last day to collect the test for this draw. | Selection notice from your consortium, or the end of the draw period. | 09/30/2027 |
| Notified | When the person was told to report for testing. They must go immediately. | Written notice the person signed, or your call/text log. | 08/12/2027 07:30 |
| Collected | When the specimen was collected. | Collection date and time on the CCF (custody and control form) copy. | 08/12/2027 08:45 |
| Status | Where this selection stands. Excused means a documented reason (for example off hitch all period). | Write the reason in notes. Refusal must be treated like a positive. | Collected |
| CCF / specimen ID | The specimen ID number from the drug test form. | Pre-printed at the top of the Federal Custody and Control Form (CCF), with a matching barcode. | 1234567 |
Test Log
46 CFR 16.210-16.250 · Each test
Every drug and alcohol test you order and its result. This log must match your MIS report and is checked at Coast Guard inspections.
| Field | What it is | Where to find it | Example |
|---|---|---|---|
| Reason | Why the test was done. | Pre-employment, random selection, reasonable cause (trained supervisor's direct observation; two supervisors where practicable, 46 CFR 16.250), after a serious marine incident (SMI), etc. | Random |
| Test | Drug or alcohol. Marine alcohol tests are done after an SMI or for reasonable cause. | Drug tests are DOT urine tests; alcohol tests are breath, saliva or blood. | Drug |
| Date | The date of the test. | Collection date on the CCF or the alcohol testing form. | 06/30/2027 |
| Collected at (date & time) | Date and time the specimen was collected. After an SMI, timing matters (2 hours alcohol, 32 hours drug). | Collector's section of the CCF, or the breath test printout. | 06/30/2027 10:05 |
| Result | The final result. Only the MRO reports a drug result as negative or positive. | The MRO's verified result report, or the alcohol technician's result form. | Negative |
| Drug (if positive) | The drug found, if the MRO verified a positive. | MRO verified result report. | Marijuana |
| Refusal type | The kind of refusal, if the result was a refusal. | MRO report or collector's remarks on the CCF. | Did not appear / left |
| Notified (random selections) | For random tests: when the person was told to report. | Written notice or call log. Should be shortly before the collection time. | 06/30/2027 09:30 |
| MRO | The Medical Review Officer who reviewed the result. | Name on the MRO's verified result report. | Dr. A. Patel, MRO |
| CCF / specimen ID | The specimen ID number from the drug test form. | Pre-printed at the top of the Custody and Control Form (CCF). | 1234567 |
Positives & Refusals
46 CFR 16.201 / 49 CFR 40 Subpart O · Each time it happens
Verified positive tests and refusals, and what you did about them. A credential holder must be removed from duty and reported in writing to the Coast Guard.
| Field | What it is | Where to find it | Example |
|---|---|---|---|
| Verified by the MRO | The date the MRO verified the positive or refusal. | Date on the MRO's verified result report. | 06/30/2027 |
| Type | What the violation was. Adulterated or substituted specimens count as refusals. | MRO verified result report. | Positive |
| Holds a Coast Guard credential | Yes if the person holds a Coast Guard MMC, license or other credential. | Your Credentials records or a copy of their MMC. | Yes |
| Removed from safety-sensitive duty | When the person was taken off safety-sensitive duty. This should be right away. | Your DER's notes or the master's logbook entry. | 06/30/2027 11:00 |
| Written report sent to the OCMI | The date you sent the written report to the nearest OCMI (Coast Guard Sector or MSU). | Your copy of the letter or email, with the MRO report attached. | 07/01/2027 |
| SAP evaluation | The date of the Substance Abuse Professional's first evaluation. | SAP's initial evaluation report. | 07/10/2027 |
Return-to-Duty
49 CFR 40 Subpart O · Each case, until follow-up testing ends
The steps before someone with a positive or refusal can go back to work: SAP evaluation, return-to-duty test, MRO clearance and follow-up tests.
| Field | What it is | Where to find it | Example |
|---|---|---|---|
| SAP evaluation | The date of the SAP's initial evaluation. | SAP initial evaluation report. | 07/10/2027 |
| Return-to-duty test | The date of the return-to-duty test. It must be directly observed. | CCF from the return-to-duty collection. | 08/20/2027 |
| Return-to-duty result | The MRO's result for the return-to-duty test. Must be negative before work. | MRO verified result report. | Negative |
| MRO return-to-work decision | The date the MRO cleared the person to return to work. | MRO return-to-work letter. The person may not work before this date. | 08/25/2027 |
| Follow-up tests planned | Total follow-up tests the SAP set. At least 6 in the first 12 months. | SAP's follow-up testing plan (follow-up report). | 6 |
| Follow-up tests done | How many follow-up tests have been done so far. | Count them in your Test Log. | 2 |
| Follow-up period (months, 12–60) | How long follow-up testing lasts, in months (12 to 60). | SAP's follow-up testing plan. | 24 |
| Next follow-up due | When the next follow-up test is planned. Keep it unannounced to the person. | Your follow-up schedule, spread through the period. | 10/15/2027 |
Program Vendors
46 CFR 16.230 / 49 CFR 40 · Once per vendor, update at renewal
Your testing service agents: MRO, SAP, consortium, lab and collectors. Inspectors ask who they are, and you are still responsible for their mistakes.
| Field | What it is | Where to find it | Example |
|---|---|---|---|
| Vendor | What the vendor does for your program. | Your service agreement. The lab must be HHS-certified. | Medical Review Officer (MRO) |
| Name | The company or person's name. | Service agreement or invoice. | ABC Medical Review |
| Phone / email | A phone number and email that works, ideally 24/7. | Service agreement or the vendor's website. | 800-555-0100 |
| Agreement or certificate expires | When the agreement ends, or when the MRO/SAP's qualification must be renewed. | Contract end date, or the requalification date on their training certificate. | 12/31/2027 |
EAP Training
46 CFR 16.401 · Once per person, refresh per your policy
Employee Assistance Program training given to crew and supervisors. Supervisors who may order reasonable-cause tests need at least 60 minutes of training.
| Field | What it is | Where to find it | Example |
|---|---|---|---|
| Group | Crewmember or Supervisor. Supervisors need the longer reasonable-cause training. | Their job: anyone who can order a reasonable-cause test is a Supervisor. | Supervisor |
| Trained | The date the training was given. | Training sign-in sheet or course certificate. | 06/30/2027 |
| Minutes of training | Length of the training in minutes. Supervisors: at least 60. | Course certificate or the class agenda. | 60 |
| Refresh every (days, your policy) | How often your policy says to repeat the training, in days. | Your drug and alcohol policy. 365 = yearly. | 365 |
Pre-Employment
46 CFR 16.210 / 49 CFR 40.25 · Each new hire
Proof a new hire was cleared before their first safety-sensitive job: a negative test or valid waiver, plus the prior-employer check.
| Field | What it is | Where to find it | Example |
|---|---|---|---|
| Basis | How the person was cleared to start. | Use a waiver only with written proof of the earlier test or random-pool membership. | Passed a pre-employment test |
| Test or evidence date | Date of the negative test, or of the proof used for a waiver. | MRO verified negative report, or the letter from the prior employer or consortium. | 06/15/2027 |
| Signed consent for prior-employer check | The date the applicant signed the release for you to ask prior employers. | Signed release form in the hiring file. | 06/10/2027 |
| DOT employers in the last 2 years | DOT-regulated employers the person worked for in the last 2 years (only 2 years are required). | Job application or résumé. List each employer's name. | Gulf Towing Co.; River Barge LLC |
| Records requested | The date you sent the requests to prior employers. | Your copy of the request letter, fax or email. | 06/10/2027 |
| Records received | The date the prior employers' answers came back. | Their reply. Aim to have it within 30 days of first duty. | 06/24/2027 |
| Good-faith effort documented if not received | Yes if records didn't come back but you documented your efforts to get them. | Your notes of calls, emails and dates tried. Keep them in the file. | No |
| First safety-sensitive duty | The date the person first did safety-sensitive work. | Hitch start date or crew list. Must be on or after the negative result. | 06/18/2027 |
Reasonable Cause
46 CFR 16.250 / 33 CFR 95.035 · Each time it happens
Tests ordered because a supervisor saw signs of drug or alcohol use. The order must be based on specific behavior that was directly observed.
| Field | What it is | Where to find it | Example |
|---|---|---|---|
| Observed | When the behavior was seen. | Supervisor's written notes made at the time. | 06/30/2027 14:20 |
| What was seen (specific behavior) | Exactly what was seen, heard or smelled. Facts, not opinions. | Supervisors' notes. E.g. slurred speech, stumbling, odor of alcohol. | Slurred speech, unsteady on deck |
| Directed to test | When the person was told to test. | Supervisor's notes and the logbook entry of the order. | 06/30/2027 14:35 |
| Test | Which tests were ordered. | Pick Both if you suspect either drugs or alcohol. | Both |
| Refused | Yes if the person refused to test. Treat it like a positive. | Supervisor's notes and the official logbook entry. | No |
MIS Filings
46 CFR 16.500 · Every year by March 15
Your yearly drug-testing data report (MIS) to the Coast Guard. It covers drug tests only and is due March 15 for the year before.
| Field | What it is | Where to find it | Example |
|---|---|---|---|
| Calendar year reported | The calendar year the report covers (last year). | Use the year the tests were done, not the filing year. | 2026 |
| Filed | The date the MIS report was submitted. | DOT DAMIS confirmation or your consortium's filing letter. Due March 15. | 03/01/2027 |
| Filed by (you or consortium) | Who submitted it: your company or your consortium. | If your consortium files, get a letter or copy from them. You are still responsible. | Maritime Testing Consortium |
| Confirmation | The confirmation number or receipt for the filing. | DAMIS confirmation screen or email, or the consortium's letter. | DAMIS-2027-55821 |
EAP Posting Check
46 CFR 16.401(a) · On your schedule (for example every 90 days)
A check that the drug and alcohol information is posted and available aboard each boat, as part of your Employee Assistance Program.
| Field | What it is | Where to find it | Example |
|---|---|---|---|
| Checked | The date someone checked the boat's postings. | The person checking walks the boat and records it. | 06/30/2027 |
| Information material displayed | Yes if drug and alcohol information is posted where crew can see it. | Look at the crew bulletin board or mess area. | Yes |
| Hotline number posted | Yes if a help hotline number is posted. | Same bulletin board. Check the number is current. | Yes |
| Drug & alcohol policy distributed | Yes if each crewmember has received the drug and alcohol policy. | Signed acknowledgment forms in the crew files. | Yes |
| Repeat every (days) | Days between posting checks. | Your policy. 90 = quarterly. | 90 |
Policy & Acknowledgments
46 CFR 16.401 / 49 CFR 40 · At hire and whenever the policy changes
Proof each crewmember received your drug & alcohol policy and signed for it.
| Field | What it is | Where to find it | Example |
|---|---|---|---|
| Policy given to the crewmember | The day they got the policy. | The signed acknowledgment form. | 09/01/2026 |
SMI Readiness Kit
46 CFR 4.06-15 / 4.06-20 · Check expiry dates quarterly
What you need to test within 2 and 32 hours after a serious marine incident: devices, kits, a collection site that answers at night, and trained people.
| Field | What it is | Where to find it | Example |
|---|---|---|---|
| Expires or calibration due | Expiry or calibration due date. | Label on the kit or the device's calibration sticker. | 03/31/2027 |
| Count on hand | How many are on hand. | Count them. | 6 |
Compliance information, not legal advice. Rules cited are current as we publish; confirm against the official eCFR.