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Membership Agreement
The Keys Consortium will provide each member:
New membership or Renewal of your membership shall be deemed as consenting to the following agreement.
Members must:
Last Updated: October 16, 2026
Each firm must have a written policy on drug and alcohol use. This must be signed by all members and a copy must posted. We will supply you with a compliant policy.
1 hour of training on drug and alcohol use/abuse for each employee is required. We provide the necessary video and written materials with paid membership.
All results must be reviewed by a certified MRO. The Keys Consortium provides a MRO that reviews each test result. In case of a positive the MRO will interview the donor by telephone to determine if there is a valid reason for the results.
Records must be kept for all test results, negatives for 1 year, positives for 5 years. Keys Consortium maintains all test results for you. We also complete the annual MIS form for each client in good standing.
Testing must be done by a lab that meets DOT/HRS standards. Keys Consortium tests are done in strict accordance with the DOT/HRS by certified collection site technicians and processed by a SAMHSA certified lab
A negative test result must be provided prior to membership into any drug testing program. A test is not necessary if proof of a negative result is provided from within 6 months of membership date with no positive result during that 6 month period or during the previous 185 days proof of membership in another compliant drug program in good standing for at least 60 days
All members are required to be randomly tested at a rate of 50% of the testing pool. Selection must be statistically valid so that there is an equal chance for any member to be selected. Keys Consortium administers a valid program for all members. All random tests are covered with membership, regardless of number of times a member is selected. Keys Consortium combines multiple local business and sole operators into on central pool and 50% of this pool is selected and tested throughout the calendar year.
Under 46 CFR § 16.250, marine employers must require drug testing when a covered crewmember is reasonably suspected of using a dangerous drug. The decision must be based on direct observation of specific, current physical, behavioral or performance indicators of probable drug use. Where practicable, two supervisors should observe the individual. The crewmember must be informed and directed to provide a urine specimen as soon as practicable. The testing direction and any refusal must be recorded in the vessel’s official logbook, if one is required. Contact Keys Consortium for testing coordination.
Under 46 CFR § 16.220, drug-testing requirements apply to specified Merchant Mariner Credential applications, including original issuance, certain upgrades and officer endorsement renewals. An additional test may not be necessary if the applicant provides satisfactory evidence of a qualifying negative test within the previous six months with no subsequent positive results, or participation in a USCG-required random testing program for at least 60 days during the previous 185 days without a failed or refused test. Keys Consortium provides supporting documentation after verifying eligibility.
Under USCG regulations in 46 CFR Part 4, Subpart 4.06, marine employers must arrange drug and alcohol testing for individuals directly involved in a serious marine incident. Alcohol testing is required within 2 hours unless incident-related safety concerns prevent it; testing must then occur as soon as those concerns are addressed, but is not required beyond 8 hours. Drug-test specimens must be collected within 32 hours, or as soon as incident-related safety concerns permit. Employers must document required testing that was not completed. Contact Keys Consortium promptly for testing coordination.
The use of the term U.S. Coast Guard does not imply an endorsement from the U.S. Coast Guard.