USCG Drug Test Requirements for Mariners: CG-719P, the 185-Day Rule, and Testing Programs

What Drug Test Is Required

Every USCG MMC application — original, renewal, or endorsement upgrade — requires a completed CG-719P form documenting a passing 5-panel DOT/HHS drug test. The test must be:

• Conducted at a SAMHSA-certified laboratory
• Administered under direct observation (split specimen)
• Completed within 185 days of the date your application is received by the NMC
• Showing a negative result on all five panels

The five panels test for marijuana (THC), cocaine, opiates, phencyclidine (PCP), and amphetamines. Some programs also add extended opioids (oxycodone, oxymorphone, hydrocodone, hydromorphone) — these are called 10-panel tests. A 5-panel DOT test meets the USCG requirement; a 10-panel does too.

The CG-719P Form Explained

CG-719P is the USCG Medical Evaluation Record for drug testing. The form has two parts: the mariner section (your information, the test you are applying for) and the MRO section (completed by a Medical Review Officer after the laboratory reports results).

You do not complete the MRO section yourself. Your employer's drug program administrator (DPA) or a collection site will coordinate testing and MRO review. What you receive and submit to the NMC is the completed CG-719P with both sections filled out and signed by the MRO.

Common CG-719P Deficiency Reasons

• Test too old

  Date on the CG-719P is more than 185 days before NMC receipt. Schedule your test as late as possible — within 60 days of mailing the full packet is the target.

• MRO signature missing

  The MRO section is blank or unsigned. A lab report alone is not sufficient — the CG-719P itself must be signed.

• Wrong form version

  An outdated CG-719P version was submitted. Use the current version from uscg.mil or your DPA.

• Positive result noted

  Any non-negative result triggers a character review process. See below.

• Test not DOT compliant

  Random workplace tests using a different panel structure may not satisfy the USCG requirement. Always confirm with your employer's DPA.

Drug Testing Program Enrollment

For a renewal (not an original MMC application), you typically do not need a one-time test if you are enrolled in a Coast Guard-accepted DOT random testing program and have no positive tests in the past year. However, most mariners submit a CG-719P with a recent negative test regardless — it is cleaner and avoids any ambiguity about program participation dates.

If you are not currently employed on a commercial vessel, you are likely not enrolled in a company DOT program. Your options are:

Option 1: Third-Party Consortium/TPA (Third-Party Administrator)

A drug testing consortium pools independent mariners into a compliant random testing program. You pay a monthly fee (typically $15–$30/month) and remain in the pool. When randomly selected, you receive a notification and must test within 24 hours. This satisfies the "currently enrolled in a program" requirement.

Well-known maritime TPAs include National Drug Screening, Quest Diagnostics Drug & Alcohol Programs, and Consortium Manager. Your local licensed mariner association may have preferred vendors.

Option 2: One-Time Pre-Employment Test

If you are applying for your first MMC, joining a new company, or have never been in a program, a one-time pre-employment drug test at a certified collection site satisfies the application requirement. This is administered as a DOT specimen collection at a LabCorp, Quest, or similar SAMHSA-certified facility.

Finding a Collection Site

The easiest way to find a SAMHSA-certified collection site near you is through the Department of Transportation's collection site locator at DOT's ODAPC resource page. LabCorp and Quest both have walk-in DOT collection at most clinic locations.

If You Have a Positive Test History

A positive drug test in your history — whether on or off the water — can trigger a USCG character review under 46 CFR Part 10.211. The NMC will not automatically deny your application, but the review adds significant time (often 3–6 months or more).

If you have a positive test on record, the path forward depends on whether you completed a Substance Abuse Professional (SAP) evaluation and a return-to-duty program. A maritime attorney who specializes in USCG credentialing is the right resource here — not a general employment lawyer.

Timing Strategy

The optimal window for getting your drug test is 30–60 days before mailing your full packet. This gives you enough buffer to resolve any collection issues while keeping well inside the 185-day limit.

A common mistake is getting tested the same day as a physical exam (CG-719K) to save a trip. This is fine if you then mail the packet within 60 days. The problem comes when mariners get the test early — sometimes months before assembling the rest of the packet — and the test expires before the NMC receives the application.

If your drug test expires before you can submit: get a new one. There is no shortcut.

Drug Test Checklist Before Submitting

• +CG-719P form (current version) is included in your packet
• +MRO section is fully completed and signed
• +Test date on the form is within 185 days of today (add 2 weeks for mail)
• +Result is negative (or you have SAP return-to-duty documentation)
• +Test was conducted at a SAMHSA-certified lab
• +Test was DOT-compliant 5-panel (or 10-panel)