TASK TITLE:  Medical Marijuana and the Merchant Mariner Medical
Evaluation 

PROBLEM STATEMENT: 

The Coast Guard seeks the input of industry, via MEDMAC, on the medical
evaluation of merchant mariners who use medical marijuana.

BACKGROUND:

Marijuana is a potent drug with well-documented impairing effects on
cognitive ability, judgment, and reaction time.  Mariners operating
under the influence of this substance pose an unacceptable risk to the
Maritime Transportation System.  Currently, marijuana is listed as a
Schedule I drug indicating that it is a substance with high potential
for abuse that has no currently accepted medical use in treatment in the
United States.  On the basis of marijuana’s Schedule I designation,
mariners who test positive for the presence of this drug are subject to
enforcement action under 46 CFR 16.105 and 33 CFR Part 95.  Likewise,
applicants for merchant mariner medical certification who use medical
marijuana are denied medical certification.

The Drug Enforcement Agency (DEA) recently considered a petition for
rulemaking which requested that marijuana’s classification be changed
from Schedule I to Schedule II.  Schedule II drugs have a high potential
for abuse, but have a currently accepted medical use in treatment in the
United States.  Use of a Schedule II drug is considered legal if
accompanied by a valid prescription.  If the DEA were to change
marijuana’s classification from Schedule I to Schedule II, then the
use of medical marijuana would fall outside the realm of Coast Guard
enforcement action.  Mariners with a valid prescription for medical
marijuana, who are found to have marijuana in their system during drug
testing, would not have their results reported to the Coast Guard as a
positive drug test. Additionally, applicants for merchant mariner
medical certification who use medical marijuana would be evaluated in
the same manner as applicants on any other medication.

Ultimately, the DEA declined the rulemaking petition, however the
process raised concerns about how such a change could affect, and would
be managed by federal commercial transportation safety agencies if such
a change were to happen in the future.   

TASK/DELIVERABLES:

Provide recommendations/findings for the following:

A working definition of medical marijuana.

How does medical marijuana differ from medications which contain the
active ingredient(s) of marijuana (most commonly, tetrahydrocannabinol
or THC)?

What are the safety concerns related to medical marijuana use in
merchant mariners? 

How do the concerns vary, if at all, for use of medications that contain
the active ingredient in marijuana?

How would medical marijuana use by merchant mariners impact the maritime
industry?

What factors or circumstances, if any, might mitigate the risks related
to use of medical marijuana or medications that contain the active
ingredient of marijuana?

In what manner do the other modes of commercial transportation address
medical marijuana?

Recommendations to the Coast Guard on the medical evaluation of mariner
applicants using medical marijuana, if DEA scheduling were to change to
Schedule II.

Whether the Coast Guard should undertake a medical rulemaking that makes
the use of medical marijuana disqualifying, regardless of the status of
DEA scheduling. 

Whether such a rulemaking should also include a prohibition on use of
medications that contain the active ingredients of marijuana.

Coast Guard technical representative: Dr Adrienne Buggs

Annex to Task 16-22

MISSION AND GUIDING PRINCIPLES

MEDICAL MARIJUANA AND THE MERCHANT MARINER MEDICAL EVALUATION

The Merchant Mariner Medical Advisory Committee (MEDMAC) hereby
establishes a standing Working Group to provide a recommendation to the
Coast Guard concerning the medical evaluation of merchant mariners who
use medical marijuana.

 

The Working Group shall respond to specific task assignments requested
by the Coast Guard or the Chair of the MEDMAC.

The Working Group shall make recommendations to the MEDMAC in the form
of specific written reports.  

In carrying out its work the following guiding principles apply:

The Working Group shall be chaired by one member of MEDMAC. 

The Working Group may have participation from the public and other
interested parties.  

Meetings of the Working Group shall occur at regular meetings of the
MEDMAC at a minimum.  Additional meetings may be called by the Working
Group Chair or at the request of the MEDMAC Chair of the Coast Guard. 
All meetings of the Working Group will be announced in the Federal
Register.

Meetings of the Working Group should be guided by Roberts Rules of Order
and the Working Group Chairman shall organize and conduct the meetings. 
In the absence of the Chairman, another MEDMAC member from the Working
Group shall act as Working Group Chair. 

The Working Group shall recognize the work and recommendations from
previous Working Group work.



 

MERCHANT MARINER MEDICAL ADVISORY COMMITTEE (MEDMAC)

Medical Marijuana and the Merchant Mariner Medical Evaluation

TASK STATEMENT 16-22

