APCA USCG Consortium — How We Operate

Dear Member,

Thank you for enrolling in the APCA USCG drug testing consortium. This letter explains exactly how our program operates so you know what is expected of you, what to expect from us, and how each requirement ties back to U.S. Coast Guard and Department of Transportation regulations. It is intended as a plain-language companion to our Terms & Conditions; where the two ever appear to conflict, the Terms & Conditions and the underlying federal regulations control.

APCA administers a random chemical testing program that meets the requirements of 46 CFR Part 16 (USCG Chemical Testing) and follows the collection, laboratory, and Medical Review Officer procedures of 49 CFR Part 40 (DOT Procedures for Transportation Workplace Drug and Alcohol Testing Programs).

1. Activation in the Consortium

Enrollment and activation are two different things. You are enrolled when you sign up and pay your membership fee. You become active in the random testing pool — and therefore eligible to receive a USCG-acceptable Letter of Compliance from APCA — when one of the following is satisfied:

1. 1

   APCA receives a verified negative drug test result for you from the Medical Review Officer; or

2. 2

   You provide acceptable documentation that you have been continuously enrolled in a compliant random testing consortium, or have produced a verified negative DOT/USCG drug test result, within the last 185 days.

Until one of those conditions is met, APCA cannot place you in the random selection pool and cannot issue a Letter of Compliance on your behalf.

Regulatory basis: 46 CFR 16.210 (pre-employment testing and the waiver permitted when a mariner has been subject to a compliant random program for at least 60 days during the prior 185 days); 46 CFR 16.230 (random testing program criteria); 49 CFR Part 40, Subpart G (MRO verification of test results).

2. Random Testing & Notification Process

Once active, you are included in APCA's random selection pool. Selections are made by a scientifically valid, computer-based random number method as required by 46 CFR 16.230(e). If you are selected, you must report to a collection site and complete the test within the window APCA assigns to you, unless you furnish documentation showing why you cannot — for example, that you are at sea, hospitalized, or otherwise verifiably unable to reach a collection facility.

When you are selected, APCA will reach you in the following order:

1. 1

   An initial email and text message to the contact information on file;

2. 2

   Up to three phone-call attempts if we have not heard back.

APCA maintains a record of every notification attempt — date, time, channel, and outcome — for each random selection. If a selection results in a refusal report to the U.S. Coast Guard, that contact log is submitted to the USCG with the report.

Under 49 CFR 40.191, failing to appear for any required test within a reasonable time, failing to remain at the collection site until the process is complete, or failing to cooperate with any part of the testing process constitutes a refusal to test. Under 46 CFR 16.201 and the broader USCG enforcement framework, a refusal can result in suspension or revocation of a Merchant Mariner Credential and denial of safety-sensitive employment.

It is your responsibility to keep your phone number, email address, and mailing address current in the APCA portal. We cannot defer a refusal report because the contact information on file was out of date.

Regulatory basis: 46 CFR 16.230 (random selection method and rate); 46 CFR 16.201 (general application and consequences); 49 CFR 40.191 (definition and consequences of a refusal to take a DOT drug test).

3. Pausing Your Membership

APCA recognizes that mariners are often working on the water, beyond practical reach of a collection site. You may pause your membership for periods during which you are unavailable for testing. Pauses are intended for legitimate on-the-water absences, not as a way to avoid selection.

The pause rule has two parts, both anchored in USCG requirements:

• Up to 125 days of pause in any rolling 185-day window is permitted with no additional test required upon return. This cap exists to keep your participation within the random pool consistent with the requirements of 46 CFR 16.210, which conditions the use of a consortium letter on a mariner having been subject to a compliant random testing program for at least 60 days during the previous 185 days.

• If your pauses exceed 125 days within a 185-day window, your membership will be frozen. While frozen, APCA will not issue a Letter of Compliance for you. To reactivate, you must complete a new drug test and submit the verified negative result to APCA. Per our Terms & Conditions, a reactivation fee applies to cover the cost of that test.

Pauses do not extend the term of your annual membership, and per our Terms & Conditions, billing continues on the normal annual cycle while a membership is paused.

Regulatory basis: 46 CFR 16.210 (60-of-185-day random pool participation requirement); 46 CFR 16.230 (random testing program criteria the pool must meet); NMC guidance accepting consortium letters that reflect the 60/185 standard.

What APCA Will Do for You

• Maintain your enrollment and random pool participation records in accordance with 46 CFR 16.365 retention requirements.

• Notify you promptly of random selections and document every contact attempt.

• Issue a USCG-compliant Letter of Compliance on request, provided you are in good standing.

• Report verified non-negative results and refusals to the U.S. Coast Guard as required by 46 CFR Part 16 and 49 CFR Part 40.

• Maintain the confidentiality of your records, releasing them only as required by law or with your authorization.

Questions

If anything in this letter is unclear, or you are unsure whether a specific situation requires a pause, a new test, or a notification to APCA, contact us before the situation becomes a compliance issue. We would much rather answer a question than file a refusal report.

Sincerely,

APCA Drug Testing