OCIMF: Guidelines for the control of drug and alcohol onboard

OCIMF and the maritime industry in general have recognized the potentially serious impact and risks associated with the use and abuse of alcohol, drugs or other impairing substances by maritime personnel. The amended 2010 STCW Convention requires administration should put in place adequate measures to prevent drug and alcohol abuse.

 

Seafarers | 30/06/20

 

Research shows that a properly designed random workplace drug and alcohol testing programme can mitigate the risk of inappropriate drug and alcohol use and reduce workplace incidents and accidents.

In this regard, OCIMF has issued updated guidelines for the control of drug and alcohol onboard to identify best practices for the following key areas:

• Drug and alcohol programme management (Section 2)

• Elements of drug and alcohol policy (Section 2)

• Position categories and drug and alcohol testing recommendations

• Medication disclosure

• Alcohol programme and testing recommendations

• Drug specimen collection

• Custody and control forms

• Stand-down

• Drug panel

• Laboratory and drug specimen validity recommendations

• Drug test review process

• Laboratory and drug specimen validity recommendations

• Drug test review process

OCIMF informs that the updated version replace those published in 1995. The new guidelines are contestant with the Oil and Gas Contractor Drug and Alcohol Testing Guidelines (IPIECA, IOGP).

In comparison with the 1st edition there is a totally different approach. The 38 pages report now includes requirements, guidance, statistics and methodology for an effective drug and alcohol control on board ships and terminals.

 

Oil and gas companies in contract with vessel and terminal operators can refer to these guidelines for their drug and alcohol programme requirements. Vessel operators and marine terminal operators can use them as well.

Among others, OCIMF guidelines include checklists for meeting responsibilities with regards to developing and implementing a workplace drug and alcohol programme.

 

In this context, companies should consider the following resources for developing a policy and testing programme:

• legal support knowledgeable in the applicable country or jurisdictional laws

• Drug and alcohol programme professional;/ Subject Matter Expert

• Human resource professional

• Occupational medicine physician/ medical service provider

• Certified laboratory to conduct screening/ confirmation testing

• Medical Review Officer (MRO) - may be an in-house physician, contracted by the operator or provided/ selected by the TPA

• Designated Employer Represantative (DER)/ Program Administrator

• Collector/ collection agency

• TPA

• Supervisor/ managers

The updated guidelines explain in details every requirement, however if they conflict with local law, the local law requirements should be followed, OCIMF states.

 

Some new definitions have been introduced for individuals’ duties. The most important is the designation of Marine Safety Sensitive (MSS) position. This position is defined as “A position where job performance can affect the safety of the employee and others, and can be defined as”

“Any vessel or terminal operator employee or contractor working on operator premises, whether ashore or at sea, whose job responsibilities are such that a lapse by the MSS employee could increase the probability of a fatality or serious injury, or an event that could substantially and adversely impact the environment, operator assets or the community.”

 

When managing Companies or terminal operators, develop their procedures for drug and alcohol management they have to specify which positions considered to be Marine Safety Sensitive.

Some other important definitions are the Stand-Down and Cut off.

• Stand down is defined as “The immediate removal of an employee from performing work on an operator worksite/vessel pending the outcome of a drug or alcohol test”

• Similarly Cut-off is “The value used to establish and report a specimen as negative or positive for the presence of a drug or alcohol or as adulterated, substituted, or invalid. Often expressed as a concentration (i.e. mass of a substance in a defined volume).” Limits of stand down and cut off for employees should be defined in the Drug and alcohol Policy.

The policy should also include provisions for:

a.    Unannounced searches for drugs and alcohol

b.    Employee Assistance Programme (EAP) for confidential assessment and treatment/referral for employees who voluntarily/self-disclose a drug or alcohol use problem.

c.    Drug and alcohol testing programme.

d.    Consequence of a breach of policy (guidelines recommend to set disciplinary actions including termination, however under the note that this is strictly Company’s decision)

 

The testing for drug and alcohol is to be performed based on the role of each individual (Marine safety sensitive (MSS) or not (NSS))

As some seafarers or terminal employees may be under medication for a specified period, an appropriate medication disclosure program is to be implemented in order to  ensure that MSS positions who use medication (e.g. prescription drugs, over-the-counter medication, herbal medicines) that may impact their ability to safely perform their duties are assessed for fitness for duty before starting work. This should be conducted taking into consideration if:

 

a.    The medication has been obtained in a manner consistent with applicable laws and regulations.

b.    MSS employees have notified the operator that they will be in possession of, or using, medication with effects that may impact their ability to safely perform their duties. In locations where disclosure of a specific medication is prohibited, the operator will require the employee to obtain a medical evaluation for fitness for duty as determined by a qualified physician. •

c.    The operator’s licensed health professional has assessed the capability or fitness for duty of the employee to safety perform their duties.

Companies are required to have a set of instruments in order to be used for drug and alcohol testing (e.g. Evidential Breath Test (EBT) and drug collection kits/urine POCT) and provide collector training to at least two crew positions who are onboard each vessel at any time (i.e. Masters/Captains and first mates, chief and assistant engineers).

 

Additionally the collection equipment is to be properly maintained and within the expiry date. The trained collectors to receive periodic collector training (around every three to five years) focusing to collectors who are not collecting on a regular basis should be trained more frequently.

 

Also, detailed instructions are provided in guidelines for all parts of collection, sampling and analyzing procedures, involving the laboratories qualified to provide information and test analyses to samples.

In order to comply with guidelines, a Ship manager or terminal should follow the below steps (all items should be in accordance with the guidelines):

1.    Issue an effective Drug & Alcohol Policy

2.    Determine the MSS positions

3.    Create the Custom Pool for testing (in accordance with duties and responsibilities of each individual)

4.    Define the 50%, 35% and 25% annual random testing rate, required in accordance with number of managed ships

5.    Provide the appropriate calibrated, and valid equipment for tests

6.    Ensure the collectors’ training

7.    Perform the tests as required (covering all aspects of guidelines: Pool random tests, Reasonable suspicion tests, Post-incident tests, Unannounced group tests)

8.    Implement appropriate record keeping as per Appendix E of guidelines

9.    Monitor statistical KPIs as per Appendix E of guidelines which should be reportable.

 

Explore more by reading OCIMF Guidelines herebelow(첨부 참조)