What the rule requires
The trigger for mandatory testing is not "a collision" and not "an injury." It is a casualty or incident that is, or is likely to become, a serious marine incident as defined in §4.03-2 46 CFR §185.212. That phrase decides more exam questions than anything else on this topic, because it removes the option of waiting. You do not wait for the Coast Guard to classify the event, and you do not wait for the injured crewman's prognosis. If the incident is trending toward serious marine incident status, the testing duty is already running.
Who owes that duty is the second thing questions turn on. The marine employer shall ensure that all persons directly involved in a serious marine incident are chemically tested for evidence of dangerous drugs and alcohol in accordance with 46 CFR 4.06 46 CFR §16.240. Two words in that sentence are load-bearing. All persons directly involved — not the operator alone, not "the crew on watch." And drugs and alcohol — one specimen collection does not satisfy the requirement if it covers only the drug panel.
The procedures themselves — how, when and with what specimens — are in 46 CFR 4.06, and both §16.240 and §185.212 send you there rather than restating them. In an open-book exam that is the section to open, not the one to memorise.
A separate and weaker duty attaches to every casualty required to be reported by §185.202. For each of those, the owner, agent, master, or person in charge shall determine whether there is any evidence of alcohol or drug use by individuals directly involved 46 CFR §185.210. This is a determination, not necessarily a chemical test. The regulation expressly contemplates personal observation of the individual as a method of obtaining that evidence, alongside chemical testing, and the written report must identify the individuals for whom evidence was obtained and specify which method was used.
The paperwork and the log
The written report of any marine casualty is due within five days, delivered to a Coast Guard Sector Office or Marine Inspection Office, on Form CG-2692, supplemented as necessary by CG-2692A (Barge Addendum) and CG-2692B (Report of Required Chemical Drug and Alcohol Testing Following a Serious Marine Incident) 46 CFR §185.206. That written report is in addition to the immediate notice required by §185.202 — filing one does not excuse the other, though a notice filed without delay after the occurrence suffices as the notice required.
Where evidence of intoxication is obtained, an entry must be made in the Official Logbook if one is carried. Three things travel with that entry: the individual shall be informed of it, and the entry shall be witnessed by a second person .
Refusal is not a dead end for the employer or the investigation. If an individual directly involved in a casualty refuses to submit to, or cooperate in, a timely chemical test when directed by a Coast Guard commissioned, warrant, or petty officer, by another authorised law enforcement officer, or by the owner, agent, master, or person in charge, that fact must be noted in the Official Logbook if carried and in the written report on CG-2692 — and it is admissible as evidence in any administrative proceeding.
A deckhand refuses the post-casualty urine specimen when you direct him to provide it. Has the requirement simply failed?
No. The refusal itself becomes reportable evidence. It must be noted in the Official Logbook if one is carried and in the written report on Form CG-2692, and it is admissible in any administrative proceeding . Note also who may lawfully direct the test: a Coast Guard commissioned, warrant, or petty officer, any other law enforcement officer authorised under Federal, state or local law, or the owner, agent, master, or person in charge. Your direction as master carries that weight.
The panel and the laboratory
Drug testing programmes under 46 CFR part 16 are conducted in accordance with 49 CFR part 40, and must use only laboratories certified by the Department of Health and Human Services (DHHS) 46 CFR §16.113. Each specimen is tested, as provided in 49 CFR 40.85, for marijuana, cocaine, opiates, phencyclidine (PCP), and amphetamines.
The common device for those five is MCOPA — Marijuana, Cocaine, Opiates, PCP, Amphetamines, in the order the regulation lists them. It is worth using and worth correcting in the same breath: MCOPA is the drug panel only. Alcohol sits outside it and is required separately after a serious marine incident, so a candidate who answers the panel question correctly and then forgets alcohol on the testing question has used the mnemonic against himself.
Telling it apart
Three duties overlap on the same casualty, and the single criterion that separates them is what switches each one on.
- Any marine casualty required to be reported by §185.202 — switches on the determination duty and the paperwork. The owner, agent, master, or person in charge determines whether there is evidence of alcohol or drug use by individuals directly involved, and reports the result on CG-2692 within five days. No chemical test is compelled by this duty alone; personal observation is an accepted method 46 CFR §185.210. Most often misfiled: a minor casualty with no injury, where candidates assume no drug or alcohol duty exists at all.
- A casualty that is, or is likely to become, a serious marine incident — switches on mandatory chemical testing of all persons directly involved, for drugs and alcohol, under 46 CFR 4.06 46 CFR §185.212. Most often misfiled: the candidate holds off because nobody has yet declared it a serious marine incident. "Likely to become" already covers him.
- The marine employer's programme under part 16 — switches on the laboratory and panel requirements: DHHS-certified laboratory, 49 CFR part 40 procedures, the five substances 46 CFR §16.113. Most often misfiled: a question about what is screened for answered from part 4 rather than part 16.
Who acts is the second separator, and exam options are built on it. The marine employer ensures the chemical testing is carried out 46 CFR §16.240. The owner, agent, master, or person in charge makes the evidence determination, files the CG-2692, and makes the Official Logbook entry . Neither of those is the Coast Guard, which does not conduct the required testing for you.
A distractor reads "The Coast Guard will conduct the required chemical testing of persons directly involved." Why is it wrong?
The obligation runs to the marine employer, who shall ensure that all persons directly involved in a serious marine incident are chemically tested in accordance with 46 CFR 4.06 . A Coast Guard officer may direct a test, and refusal of that direction is reportable , but the duty to get the testing done is the employer's.
Working a question
You are master of a charter vessel that grounds hard coming off a berth in fog. One deckhand is thrown and injured; the hull is holed above the waterline. Assume the facts put this in serious marine incident territory, or make it likely to become one — the exam question will either say so or expect you to check §4.03-2, which is in your library.
- Fix the immediate notice. The casualty is reportable, so the notice required by §185.202 is owed at once. The written report does not replace it 46 CFR §185.206.
- Ask the serious marine incident question before anything else, and answer it conservatively. The test for the testing duty is whether the incident is, or is likely to become, a serious marine incident 46 CFR §185.212. With an injured crewman and hull damage, the honest answer at the pierhead is "likely." The duty is live.
- Identify every person directly involved. The helmsman is obvious. So is the deckhand handling lines, and anyone else whose act or omission bears on the grounding. The standard is all persons directly involved, not the licensed operator alone 46 CFR §16.240.
- Ensure both drugs and alcohol testing happens, and follow §4.06 for the mechanics. The employer's obligation covers both classes of substance. Specimens go to a DHHS-certified laboratory and are screened for the five substances under 49 CFR part 40 procedures 46 CFR §16.113.
- Make the evidence determination independently of the test results. As master you must determine whether there is any evidence of alcohol or drug use by individuals directly involved, and the CG-2692 must identify those individuals and state the method by which the evidence was obtained — personal observation, chemical testing, or otherwise 46 CFR §185.210.
- Log any evidence of intoxication properly. Entry in the Official Logbook if carried, the individual informed of the entry, the entry witnessed by a second person. Miss the witness and the entry is defective.
- File within five days. CG-2692 to a Coast Guard Sector Office or Marine Inspection Office, with CG-2692B appended to report the chemical drug and alcohol testing conducted after the serious marine incident .
Where candidates lose the point
Tests the operator and nobody else. The distractor reads "the master and any licensed crew" or "the individual at the helm," which sounds like accountability running with the licence. The rule says all persons directly involved 46 CFR §16.240.
Waits for a determination that it was a serious marine incident. Attractive because it sounds procedurally careful, and because the candidate does not want to test people over a fender rub. The words "or is likely to become" in §185.212 defeat it 46 CFR §185.212. A delay while someone decides is a failure to comply.
Answers drugs only. The five-substance panel is the memorable part of the topic, so a question asking what testing is required after a serious marine incident pulls the candidate toward MCOPA and away from the words "dangerous drugs and alcohol."
Treats the CG-2692 as satisfying the immediate notice, or the notice as satisfying the report. The written report is in addition to the notice required by §185.202 46 CFR §185.206. Only one direction works: a notice filed without delay serves as that notice, not as the five-day written report.
Puts the five-day clock on the wrong thing. Five days attaches to the written report. Candidates who half-remember the number attach it to testing or notification, then pick the option that says the Coast Guard must be notified within five days.
Makes an Official Logbook entry without informing the individual or without a witness. The habit is to log and move on. Both of the other steps are required by the same paragraph 46 CFR §185.210.
Sends specimens to any accredited laboratory. Only DHHS-certified drug testing laboratories may be used 46 CFR §16.113. Options offering a state-licensed or hospital laboratory are built on this.
Adds a sixth substance to the panel. Barbiturates, benzodiazepines and alcohol all appear in distractors. The listed five are marijuana, cocaine, opiates, PCP, and amphetamines.
Check yourself
Your vessel is involved in an incident you judge likely to become a serious marine incident, though nothing has been formally determined. What is required of the marine employer?
Chemical testing of all persons directly involved, for evidence of dangerous drugs and alcohol, in accordance with 46 CFR 4.06. The duty attaches to a casualty or incident that is, or is likely to become, a serious marine incident 46 CFR §185.212, and the employer must ensure the testing is carried out 46 CFR §16.240. No formal determination is a precondition.
Which form reports the chemical drug and alcohol testing conducted after a serious marine incident, and when is it due?
Form CG-2692B, appended to Form CG-2692, delivered within five days to a Coast Guard Sector Office or Marine Inspection Office 46 CFR §185.206. CG-2692A is the Barge Addendum and does not concern testing.
A reportable casualty occurs with no injury and minor damage. Does any drug or alcohol obligation apply?
Yes. For each marine casualty required to be reported by §185.202, the owner, agent, master, or person in charge must determine whether there is any evidence of alcohol or drug use by individuals directly involved, and must report on CG-2692 who those individuals are and the method used to obtain the evidence 46 CFR §185.210. Personal observation is an accepted method; mandatory chemical testing is a separate duty tied to serious marine incidents.
You obtain evidence that a crewman directly involved was intoxicated. What must be done in the Official Logbook?
An entry must be made if a logbook is carried, the individual must be informed of the entry, and the entry must be witnessed by a second person . All three are required; the witness is the element most often omitted.
For which substances is each specimen tested, and what laboratory may perform the analysis?
Marijuana, cocaine, opiates, phencyclidine (PCP), and amphetamines, as provided in 49 CFR 40.85. Only laboratories certified by the Department of Health and Human Services may be used, and the programme is conducted in accordance with 49 CFR part 40 46 CFR §16.113.
Only the licensed operator was on watch when the casualty occurred. Two deckhands were working cargo. Who is subject to mandatory testing?
Everyone directly involved in the incident, which can include the deckhands depending on their part in it — the standard is not "who held a licence" or "who was on watch" . Narrow the group by involvement in the incident, not by rating.
The immediate notice was passed to the Sector by telephone within the hour. Does that close out your reporting?
No. The written report on CG-2692 is required within five days and is in addition to the immediate notice required by §185.202 . The relationship works only the other way: a report filed without delay after the occurrence suffices as that notice.
Check your understanding
One real exam question on Chemical testing after a marine casualty, cited to source. No account.
When a marine employer requires reasonable cause drug testing of a crewmember, what must be entered in the vessel's official logbook, if one is required?
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