CAPTAINMIKESSII
Registered
The rules for a commercial vessel for hire are black and white...all designated crew must be in the random drug testing program belonging to the vessel they work on..And to my knowledge havent been changed(but they should)
...The enforcement isnt so cut and dry and it really makes no sense for a "shared" crew member to be in multiple programs.
The issue of "crew sharing" has been around for a long time and every MSO and DAPI officer seems to have a different approach to the issue. Naco had been working on this because CFR Part 40.25 doent allow it...in 2008 CG Rear Admiral Salerno conveyed his opinion that this (40.25)was essentially overkill and that the intent of the regulation was to get all crew members IN a random program.
To date I have not seen any official document detailing an approved procedure for crew sharing.
The final answer is its not worth the $50 to stress on the issue for me I just enroll all my crew.
JMHO
...The enforcement isnt so cut and dry and it really makes no sense for a "shared" crew member to be in multiple programs.
The issue of "crew sharing" has been around for a long time and every MSO and DAPI officer seems to have a different approach to the issue. Naco had been working on this because CFR Part 40.25 doent allow it...in 2008 CG Rear Admiral Salerno conveyed his opinion that this (40.25)was essentially overkill and that the intent of the regulation was to get all crew members IN a random program.
To date I have not seen any official document detailing an approved procedure for crew sharing.
The final answer is its not worth the $50 to stress on the issue for me I just enroll all my crew.
JMHO