Hello Everyone I hope all of you are doing well, I must say my blood pressure is up a bit, Oh yes, that is because I am dealing with NMC isn’t it, I almost forgot that. Here I go again jumping on my SOAP BOX yet again, this time it is about nonexistent, non-published IN HOUSE POLICY UP-DATES. The only way we find out about them is when you get bitten by an NMC Evaluator whom NMC has been training NOT TO THINK and not to use common sense! I know that consistency is imperative to a well functioning organization of any kind and I am sure you do also, so I can almost understand. HOWEVER, if you want total automation or you want a robot, then you go build a NON-Thinking machine right? Geeze, already my brain boggles at the thought- oops I forgot, thinking not allowed, just doing my young padawan.
Here is an exact quote out of an e-mail response I received from NMC.
“…to bring us together after centralization and treat all mariners the same,
we train to use CG791P, verbiage on back referencing 46 CFR 16, Part B or
Guidance Document 03-04….”
BEWARE all Evaluators at NMC have been instructed, trained, taught, turned into an automaton or what ever you want to call it, to see only BLACK AND WHITE, no gray areas thank you very much and no using common sense either. Thinking on their own, OUT OF THE QUESTION!
Here is the latest and greatest in the IN HOUSE POLICY OF THE NEW AND IMPROVED NMC. I am presuming here that this goes for everything being presented and sent into NMC, not just what I am about to explain to you so be prepared and be forewarned.
USE EXACT EXAMPLE VERBIAGE ONLY, no alterations, no variations. I had a client who has been with a company for years and that I have been familiar with for the last 20 odd years who sent their mariner a letter of sea service with the drug test verbiage in it that has been acceptable for the past how many ever years. There letter simply stated that Mr. X has been involved in our random drug testing program for the past x number of years under 46 CFR part 16 and has not failed or refused testing. NMC is now sending it back saying it was unacceptable because it did not state SPECIFICALLY one of the following examples, and I do mean SPECIFICALLY:
Please note that each one of these say “EXAMPLE” however, I suggest that you word it exactly like one of the EXAMPLES LISTED, otherwise, I’m sure you will confuse the evaluators at NMC.
So, to all of the employers out there, take heed and be specific in your letters. Cut and paste one of the examples into your letters of sea service until NMC comes out with another “unwritten”, “unpublished”, in house, policy.
REQUIREMENTS:
- A drug test is required for all transactions EXCEPT endorsements, duplicates and STCW certificates.
- ONLY a DOT 5 Panel (SAMHSA 5 Panel, formerly NIDA 5), testing for Marijuana, Cocaine, Opiates, Phencyclidine, and Amphetamines will be accepted.
OPTION I
PERIODIC TESTING
PROGRAM
- A USCG drug test conducted within the past 185 days by a laboratory accredited by Substance Abuse and Mental Health Services Administration (SAMHSA), Department of Health and Human Services.
- COLLECTION of a urine sample may be conducted by an independent medical facility, private physician or at an employer-designated site as long as the collection agent meets the qualification requirements to be a collection agent given Title 49 CFR Part 40.31. It is CRITICAL that the sample is sent to an accredited SAMHSA laboratory for ANALYSIS or the drug test is invalid. A list of service agents that can assist in meeting these requirements is included or a list of service agents can be obtained at www.uscg.mil/hq/g-m/moa/dapip.htm.
- The ORIGINAL results are required. A FACSIMILE is acceptable, if it is originated from the Medical Review Officer (MRO) or the Service Agent assisting the mariner, and sent directly to our office. The drug test result must be signed and dated by the MRO or by a representative of the service agent who assisted you in meeting this requirement.
OPTION II
RANDOM TESTING
- An ORIGINAL DATED letter on marine employer stationary or, for ACTIVE DUTY MILITARY MEMBERS, an ORIGINAL DATED letter from your command on command letterhead attesting to participation in random drug testing programs.
EXAMPLE (From Marine Employers): APPLICANT’S NAME / SSN 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.
EXAMPLE (Active Duty Military/Military Sealift Command/N.O.A.A./ Army Corps of Engineers): APPLICANT’S NAME / SSN has been subject to a random testing program and has never refused to participate in or failed a chemical drug test for dangerous drugs.
OPTION III
PRE-EMPLOYMENT
TESTING
- An ORIGINAL DATED letter on marine employer stationary signed by a company official, stating that you have passed a pre-employment chemical test for dangerous drugs within the past 185 days.
EXAMPLE: APPLICANT’S NAME / SSN passed a chemical test for dangerous drugs, required under Title 46 CFR 16.210 within the previous six months of the dateof this letter with no subsequent positive drug test results during the remainder of the six month period.
I will soon be sending out an e-mail to all of the companies that I have e-mail addresses for giving them this updated information (or at least updated as of the 4th of February 2010) remember, this could change at any moment and we won’t know about it until an evaluator sends it back as being wrong. I just hope all of the evaluators are reading the same hand book, but unfortunately, I don’t think they are.
Touch Keys with you later,
N.