MERCHANT MARINER MEDICAL ADVISORY COMMITTEE (MEDMAC)

Medical Marijuana and the Merchant Mariner Medical Evaluation

TASK STATEMENT 16-22
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 marijuanas 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 marijuanas 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 marijuanas 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:
1. A working definition of medical marijuana.
2. How does medical marijuana differ from medications which contain the active ingredient(s) of
marijuana (most commonly, tetrahydrocannabinol or THC)?
3. What are the safety concerns related to medical marijuana use in merchant mariners?
4. How do the concerns vary, if at all, for use of medications that contain the active ingredient in
marijuana?
5. How would medical marijuana use by merchant mariners impact the maritime industry?
6. What factors or circumstances, if any, might mitigate the risks related to use of medical

MERCHANT MARINER MEDICAL ADVISORY COMMITTEE (MEDMAC)

Medical Marijuana and the Merchant Mariner Medical Evaluation
TASK STATEMENT 16-22
marijuana or medications that contain the active ingredient of marijuana?
7. In what manner do the other modes of commercial transportation address medical marijuana?
8. Recommendations to the Coast Guard on the medical evaluation of mariner applicants using
medical marijuana, if DEA scheduling were to change to Schedule II.
9. Whether the Coast Guard should undertake a medical rulemaking that makes the use of medical
marijuana disqualifying, regardless of the status of DEA scheduling.
10. 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

MERCHANT MARINER MEDICAL ADVISORY COMMITTEE (MEDMAC)

Medical Marijuana and the Merchant Mariner Medical Evaluation
TASK STATEMENT 16-22
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:
1. The Working Group shall be chaired by one member of MEDMAC.
2. The Working Group may have participation from the public and other interested parties.
3. 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.
4. 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.
5. The Working Group shall recognize the work and recommendations from previous Working
Group work.