5

Policies and Programs at Sea

Once a vessel leaves port, meeting the challenge of alcohol and other substance use, sexual misconduct, and mariner well-being requires a set of well-designed and implemented policies and programs. Key topics covered in this chapter include the permissible alcohol level; the role of alcohol and other drug testing; programs to reduce bullying,¹ harassment, and sexual misconduct;² physical changes on the vessel to enhance safety; wellness policies; and access to health care services.

PERMITTED ALCOHOL LEVELS

This section reviews the evidence for the maximum alcohol level compatible with performing safety-sensitive functions at sea, and, based on this evidence, makes a recommendation for a new regulatory standard to be set by the U.S. Coast Guard. Additional data regarding how an update to the legal limit impacts the amount of blood alcohol content (BAC)-related incidents would better support the need for such a change.

___________________

¹ Federal laws prohibit bullying when it is based on a protected characteristic such as race, sex, religion, or disability.

² “Sexual misconduct” is not itself a defined federal crime, but certain acts that fall under this term—such as sexual assault on federal property (18 U.S.C. §§ 2241-2244), sex trafficking (18 U.S.C. § 1591), or civil rights violations involving sexual acts (18 U.S.C. § 242)—are federal offenses, while others are governed by state law or civil statutes like Title VII and Title IX.

Evidence and Best Practices

Policies Related to Permitted Alcohol Levels

The U.S. Department of Transportation (DOT) sets the minimum regulation for permitted alcohol levels for transit fields under its purview, including Federal Aviation Administration, Federal Railroad Administration, Federal Motor Carrier Safety Administration, and the Pipeline and Hazardous Materials Safety Administration (49 C.F.R. § 40.23, 2000). This minimum level is a BAC of .04%; testing at this level or higher while on duty is prohibited and is considered a positive test. In response to a positive test, professionals within these transportation industries must be immediately removed from safety-sensitive responsibilities. The U.S. Coast Guard follows 49 C.F.R. Part 40, the DOT standard for workplace drug and alcohol testing for mariners in the U.S. Coast Guard and the maritime industry it regulates, even though the U.S. Coast Guard is part of the Department of Homeland Security.

Modal agencies may adopt stricter regulations than the DOT minimum requirements. Based on direction from 49 C.F.R. 40.23, agencies other than the U.S. Coast Guard have established standards that if an employee tests between .02–.039%, removal from safety-sensitive functions is mandatory. Most agencies also require that someone with a test result in this range take a repeat test and have a result below .02% before returning to work. The Federal Motor Carrier Safety Administration requires that an employee who tested between .02–.039% cannot return to duty until the next day or the start of their next shift, but no less than 24 hours following the test.

The U.S. Nuclear Regulatory Commission and the Canadian Nuclear Safety Commission consider any BAC below .02% to be a negative test, and anything above this BAC requires, at minimum, confirmatory testing.

Research Related to Permitted Alcohol Levels

The effects of alcohol on human skills and performance commence at the lowest measurable BACs and increase in a roughly dose-related manner (Ogden & Moskowitz, 2004). In the United States, state laws prohibit operating a vehicle with a BAC over .08% for people over the age of 21 (the state of Utah has set a limit of .05%); state laws set lower limits for operating a vehicle under the age of 21, ranging from 0–.02% (Vandervort-Clark, 2023, 2024).

Existing evidence suggests that alcohol begins to impair driving-related skills with even slight increases above zero BAC, visual functioning is affected at BAC levels as low as .03%, and there is some evidence that reductions in peripheral detection ability can occur at low to moderate BAC

levels (Chamberlain & Solomon, 2002; Moskowitz & Florentino, 2000). Alcohol also negatively impacts visual function, motor coordination, and psychological responsiveness—functions that are crucial for safe ship operations (Grütters et al., 2003). Larger and more representative samples are needed to demonstrate the ecological validity of laboratory tasks and to better understand the effects of low alcohol exposure.

The ability to sustain attention and remain alert shows impairments at .03% and above, the ability to accurately process and respond to information is impacted at levels as low as .021%, impairment in steering ability begins at BACs as low as .035%, and the greatest effects of alcohol are on divided attention skills which can show impairment at levels as low as .01% (Chamberlain & Solomon, 2002). Cognitive performance (i.e., short-term memory, long-term memory, sustained attention, and psychomotor speed) is also impacted due to next day effects of alcohol (Gunn et al., 2018). As described by the National Institute on Alcohol Abuse and Alcoholism (NIAAA), “alcohol makes it harder for the brain areas controlling balance, memory, speech, and judgment to do their jobs, resulting in a higher likelihood of injuries and other negative outcomes” (NIAAA, 2022).

Relatively few empirical studies have investigated the specific effects of alcohol on maritime safety. While some simulator-based research and studies involving Cadets or novice navigators have been conducted, comprehensive data on alcohol’s impact in real maritime contexts remain limited (Gug et al., 2022). As noted in Chapter 3, the U.S. Coast Guard has identified alcohol as a factor following multiple marine casualty incidents.

Current Practice

As described in Chapter 2, federal regulations prohibit mariners from having a BAC of .04% or higher while on duty. A BAC of .04% or higher is considered a positive test, and a mariner with a positive test must be immediately removed from safety-sensitive responsibilities. The regulations permit lower amounts of alcohol in the bloodstream and therefore do not prohibit all alcohol use.

Beyond this minimum requirement, actual practices can vary significantly based on the BAC level, company policy, and the ship leadership and culture. Some companies ban all alcohol use and consider any positive test to be disqualifying. The committee learned policies related to testing at the time mariners return to the vessel from shore leave vary by company policy and vessel type.

Analysis

Alcohol intoxication and withdrawal pose significant risk in all safety-sensitive roles. When crises arise for a vessel, all crewmembers may be required to work and available evidence indicates that alcohol has impacts on performance and safety at levels below .04% and during periods of withdrawal, when a mariner would test negative. Testing following marine casualties reveals impacts associated with alcohol consumption. Moreover, while DOT policy allows for a BAC of .04%, in practice, most federal agencies under its purview remove people from safety-sensitive responsibilities for any result above .02%; however, the U.S. Coast Guard is the exception.

There are potential alternatives to lowering the acceptable BAC. For example, if there were a performance test, it could be administered to assess whether the level of functioning is acceptable. Or if additional research quantified the impact of fatigue and alcohol together, it might be possible to have a matrix of risk. If additional research were to suggest differences in different maritime settings, it might be possible to build into an enforcement guideline. However, such data are not now available.

The committee finds that given the current state of evidence, the safety and well-being for all mariners at sea will be enhanced by lowering the acceptable BAC to .02%. The .02% BAC level leaves room for potential error in testing and would remove ambiguity in next steps after a BAC above .02% but below .04%.

Conclusion 5-1: Available evidence indicates alcohol negatively impacts performance at blood alcohol concentrations below .04%.

Conclusion 5-2: The U.S. Coast Guard is the only regulator of transportation modes that does not require the removal of employees from safety-sensitive responsibilities when a blood alcohol concentration between .02% to .039% is present.

Conclusion 5-3: There is a need for additional research on the low blood alcohol concentrations of alcohol on maritime safety and on policy alternatives; however, the available literature on performance impacts is applicable.

Recommendation 5-1: To improve maritime safety and crew readiness, the U.S. Coast Guard should:

• Update the U.S. Coast Guard policy to align with other transportation modes and require removal from duty at blood alcohol concentration (BAC) levels of .02–.039%.

• Require reporting of reasonable cause tests where apparent intoxication led to removal from duty when the confirmed BAC falls between .02–.039%.

Recommendation 5-2: To minimize potential for alcohol use that exceeds acceptable standards, the U.S. Coast Guard should prohibit alcohol possession and use by crew on U.S.-flagged vessels.

ALCOHOL AND OTHER DRUG TESTING

Alcohol and other drug testing are central to enforcing alcohol and other drug policies. Because of the impact of alcohol and other substance use on performance, standard practices in safety-sensitive industries include testing at different points in the employment process (SAMHSA, 2024a). These include:

• pre-employment screening (covered in Chapter 4);
• random testing;
• reasonable cause testing, to permit investigation of circumstances of concern; and
• post-incident testing, as part of an investigation into incidents that caused harm.

Best practice includes the use of a standardized base testing panel so testing is equitable; if a specific substance is of concern at one of these points the urine drug screen panel can be expanded. The number of drug classes included in a panel varies by industry but generally ranges from five to 12, with the panels with additional tests generally covering commonly misused prescription drugs, including benzodiazepines.³ While urine is the most common testing mechanism used across industries, breath alcohol concentration is also regularly used; hair, nail, oral fluid, and blood testing is less common, but also used.

Post-incident testing for motor vehicle accidents may be much more comprehensive than random testing. A 2022 report from the National Transportation Safety Board, while noting that there is no national standard for testing, found that states may test for potentially 20 or more substances to identify factors in accidents. These include potentially impairing neuropsychiatric medications, hallucinogens, inhalants, sedatives, novel psychoactive substances, and other potentially impairing drugs (National

___________________

³ Benzodiazepines were one of the more commonly found drugs affecting pilot performance. https://www.faa.gov/sites/faa.gov/files/data_research/research/med_humanfacs/oamtechreports/201402.pdf

Transportation Safety Board, 2022). DOT has also defined a wide array of substances that impact driving performance (Couper et al., 2024).

For entities under its jurisdiction through 49 C.F.R. 40.23, DOT sets minimum standards for testing, including requirements for testing equipment and review of test results by qualified medical officers. These requirements now include a 5+ panel of amphetamines, cocaine, marijuana, opiates, and PCP, with an additional test of four semi-synthetic opioids, hydrocodone, oxycodone, hydromorphone, and oxymorphone (U.S. Department of Transportation, 2018). The U.S. Coast Guard follows these DOT standards and oversees additional regulations specific to the maritime industry.

Random Testing

The U.S. Coast Guard requires that maritime employers conduct random drug testing. Selection for testing requires the use of a “scientifically valid method, such as a random number table or a computer-based random number generator that is matched with crewmembers’ Social Security numbers, payroll identification numbers, or other comparable identifying numbers.” Alternatively, the U.S. Coast Guard permits testing all crewmembers of a vessel at the same time, if all the vessels have an equal chance of selection. Random testing is not required for alcohol (46 C.F.R. § 16, 1988).

Reasonable Cause Testing

U.S. Coast Guard regulations require that maritime employers conduct reasonable cause testing for drugs based on a “reasonable and articulable belief that the individual has used a dangerous drug based on direct observation of specific, contemporaneous physical, behavioral, or performance indicators of probable use.” The regulations also require that “where practicable, this belief should be based on the observation of the individual by two persons in supervisory positions.” Reasonable cause testing is mandated to occur for alcohol (33 C.F.R. § 95.035, 1987) when the effect of alcohol is observed in the “person’s manner, disposition, speech, muscular movement, general appearance or behavior” (46 C.F.R. § 16, 1988).

Post-incident Testing

For a broad range of incidents described in Chapter 3, U.S. Coast Guard regulations require maritime employers to “determine whether there is any evidence of alcohol or drug use by individuals directly involved in the casualty” (46 C.F.R. § 4.05-12, 1998). These testings involve breath

tests for alcohol (ideally within two hours), as well as urine tests for other substances.⁴

Overall, there are several gaps in current testing requirements. As noted in Chapter 2, under federal law, unlike employees in the aviation, railroad, motor carrier, and mass transit industries, covered by the Omnibus Transport Employees Testing Act of 1991, maritime workers are not required to participate in random testing for alcohol. Alcohol testing is only required in the post-incident setting, even though the logic for testing for alcohol, a serious threat to the safety of the vessel and crew, extends to random and reasonable suspicion testing. Additionally, the current panel of drug tests is considered a 5+ panel and not a more comprehensive panel of substances used by other safety-sensitive industries, which would, for example, cover other commonly used substances that affect performance, such as benzodiazepines. Nor is there a standard for testing of longer list of potentially contributory drugs in the post-incident setting.

As noted in Chapter 2, the U.S. Coast Guard’s testing and subsequent enforcement program is overseen by the Drug and Alcohol Program Inspectors (DAPIs). While there have been as many as 11 people in these roles across the country, currently there is one DAPI on staff in U.S. Coast Guard headquarters.⁵

Conclusion 5-4: The U.S. Coast Guard’s testing requirements do not consistently assess for alcohol or utilize an adequate panel for drugs.

Recommendation 5-3: Consistent with requirements applicable to most other commercial transportation modes, the U.S. Coast Guard should require vessel operators to include alcohol in random drug testing programs. The U.S. Coast Guard should re-evaluate and align the purpose, staffing, and funding levels of its Drug and Alcohol Program

___________________

⁴ Testing for alcohol must be conducted using equipment such as the Evidential Breath Testing Devices or Alcohol Screen Devices that are approved by the DOT National Highway Traffic and Safety Administration. If there is an unsafe condition, testing can be delayed. If for whatever reason more than eight hours expires from the time of the Serious Marine Incident then no alcohol testing needs to be done. Failure to take a required alcohol test will result in the U.S. Coast Guard taking action against the mariner. Failure to have the required equipment onboard to perform such tests may result in civil penalties. Testing for drugs is required to be completed within 32 hours following a serious marine incident. If drug test specimens cannot be collected within 32 hours, vessels must have a sufficient number of urine-specimen collection kits onboard and chain-of-custody forms meeting the requirements of 49 C.F.R. § 40 (2000) that are readily accessible for use following a Serious Marine Incident. Collection of drug test specimens can only be conducted by DOT trained personnel following all the procedures for handling, chain of custody and laboratories as outlined in 49 C.F.R. § 40 (2000).

⁵ Joseph Keefe, DAPI 101: Outreach and enforcement, Marine News, March 2019 #44, pp. 44–47. https://magazines.marinelink.com/tags/person/patrick-mannion

Inspector obligations for compliance monitoring and enforcement. The U.S. Coast Guard should ensure that the panel of substances that is covered by drug testing is kept up to date with industry best practices for identifying impairing substances.

REDUCING BULLYING, HARASSMENT, AND SEXUAL MISCONDUCT

The maritime industry faces unique challenges in mitigating workplace misconduct, including bullying and harassment. Österman and Boström (2022) highlighted that workplace bullying and harassment are significant issues at sea, exacerbated by factors such as high workload, role conflicts, and precarious employment conditions. Their study emphasized the need for proactive measures, including adequate resources and tools for managers and officers, to address underlying causes and ensure decent working conditions.

Policies and programs related to bullying, harassment, and sexual misconduct aim to reduce or eliminate worrisome behaviors aboard a vessel before incidents occur. Because workplace climate is associated with sexual harassment (Willness et al., 2007), addressing bullying and harassment generally is an important strategy to reduce sexual misconduct. This section focuses on three tools to aid these efforts: bystander support, dispute resolution, and early response.

Evidence and Best Practices

Bystander Support

Bystanders are individuals who witness—but are not directly involved in—a bullying or sexual misconduct incident. Evidence demonstrates that bystanders can play a crucial role in how these incidents progress and whether they are reported (Huitsing & Veenstra, 2012; Salmivalli et al., 1996). However, a study on workplace harassment found that the most frequent bystander responses involve inaction or actions that have a low likelihood of impacting behavior, often due to being delayed (McDonald et al., 2016).

Bystander intervention trainings have been developed to increase bystander helping behaviors in bullying and sexual misconduct situations. There is evidence that at least some of these trainings increase bystander behaviors and improve attitudes toward intervening in scenarios that may involve or are thought to be likely to escalate to sexual misconduct (see Mujal et al., 2021 for a review). Some scholars have identified factors that may act as barriers to helping. Lee and colleagues stated, “Specifically Latané

and Darley (1970) outlined five barriers to bystander helping behavior, including (a) failure to notice that a situation is occurring, (b) failure to identify that a situation is high risk, (c) failure to feel responsible to intervene in what is occurring, (d) failure to intervene due to skill deficits, and (e) failure to intervene due to the fear of looking foolish” (Lee et al., 2019, p. 54).

Bystander intervention trainings ought to address these potential barriers in order to increase the likelihood of bystanders intervening to mitigate bullying and sexual misconduct situations. Specifically, trainings should teach participants how to:

• identify bullying and sexual misconduct situations and ideally include practice with identification of potentially ambiguous scenarios;
• challenge the idea that if others are around someone else will or should intervene instead of the participant; and
• allow for behavioral rehearsal of strategies to help in a competent manner, and address concerns about negative evaluation by others for intervening (Lee et al., 2019).

Furthermore, trainings must challenge misconceptions about bullying and sexual misconduct, increase participants’ empathy for individuals who experience bullying and sexual misconduct, and help participants accurately evaluate the costs and benefits of providing help during a bullying or sexual misconduct incident (Lee et al., 2019). While bystander intervention training can be helpful, it is also important to consider the concept of “weighted responsibility,” which notes that when hierarchies exist, those with more power (e.g., those of higher employment ranks) should have more responsibility for intervening than those with less power.⁶

Dispute Resolution

Institutions may spend considerable time and effort anticipating and managing reports of sexual misconduct while also paying too little attention to the fact that gender-based harassment (such as sexist hostility and crude jokes) and other bullying behaviors may precede incidents of more severe sexual misconduct—including unwanted sexual attention, sexual coercion, and sexual assault. To address these problems as quickly as possible, it is possible for organizations to complement formal reporting and disciplinary measures with informal mechanisms. Gary and colleagues (2025) suggest utilizing an Ombuds office, in which an Ombuds is an institutional

___________________

⁶ Dorothy Edwards, Presentation to the Committee, September 12, 2024. https://www8.nationalacademies.org/pa/managerequest.aspx?key=DBASSE-BBCSS-23-02

employee who works within a fully confidential framework, for the benefit of employees, who provides a confidential avenue for addressing interpersonal or systemic concern, as opposed to the perception and reality of Human Resources employees who work for the benefit of the organization. When conflicts arise, an Ombuds can assist with the impartial sharing of policies and procedure and even assist with mediating between parties to arrive at a shared understanding of the potential misconduct and work to alleviate any future reoccurrences (Gary et al., 2025; Howard, 2019).

Early Response

Another best practice is for employers to respond quickly to inappropriate behavior, even when it does not rise to the level of a reportable incident. Such moments are opportunities to reinforce cultural expectations of mutual respect. Correcting instances of gender harassment early and regularly sends a clear message to entire communities that sexual misconduct in all of its forms will not be tolerated.

Changing the culture around sexual misconduct is critical to long-term improvement in personnel working relationships (National Academies of Sciences, Engineering, and Medicine [National Academies], 2018). Respect is central to creating a working environment that allows all personnel to perform successfully and at their fullest potential. Two pieces of research support the importance of creating a respectful work environment in alleviating other forms of sexual misconduct. First, perceptions of a civil work climate are better predictors of sexual misconduct incidence than are perceptions of tolerance toward sexual misconduct (Malcore, 2024). Second, experiences of workplace incivility are very closely correlated with experiences of gender harassment (Lim & Cortina, 2005). A practical implementation of taking near-misses of gender harassment (and incivility) seriously can be found in Vanderbilt University’s implementation of the Cup of Coffee program, in which early intervention is emphasized (via an off-the-record Cup of Coffee meeting—if appropriate—with a potential offender to let them know that their behavior was noted), with escalating consequences with subsequent infractions. With demonstrated efficacy (Dubree et al., 2017), this program holds considerable promise, with straightforward generalization to other institutional contexts.

Current Policy and Practice

The Every Mariner Builds A Respectful Culture (EMBARC) program is introduced in Chapter 2 and discussed in Chapter 4 regarding training that mariners working on EMBARC enrolled carriers receive about EMBARC before setting sail. Concerning while mariners are at sea, quarterly training

is required for everyone on board that addresses sexual misconduct “prevention, bystander intervention, reporting, and response procedures” (U.S. Maritime Administration, 2021). The Ship Operations Cooperative Program (SOCP) has developed a computer-based training to meet this requirement (Ship Operations Cooperative Program, 2023). Additionally, posters and guides that support a respectful workplace culture and those geared toward the prevention, reporting, and response to sexual misconduct must be displayed on board. SOCP has also developed multiple posters in line with these requirements that can be freely downloaded (Ship Operations Cooperative Program, 2023).

EMBARC does not include requirements for dispute resolution or early response. As explained in Chapter 2, vessel owners and operators are required to comply with EMBARC standards if they have U.S. Merchant Marine Academy (USMMA) Cadets on board. As a result, while many shipping companies have adopted EMBARC, these standards are not universally applied through the maritime industry. By law, these ships are still obligated to be complying and are subject to inspection.

In 2024, the International Seafarers’ Welfare and Assistance Network (ISWAN) established an international Seafarer-led program underscoring standards for behavior and Seafarer support in its Safe at Sea…It Takes All of Us program. The program highlights the role of allyship—and particularly the role that men can play—in creating safe and inclusive environments on board for female colleagues (International Seafarers’ Welfare and Assistance Network, 2024). A similar Canadian program supported by the International Transport Workers Federation, Be More than a Bystander, was launched in 2024, and the International Order of Masters, Mates and Pilots, a U.S. maritime labor union, launched the Your Shipmates are Counting on You: Building a Respectful Maritime Workforce program, based in large part on early work by Nautilus, International (International Organization of Masters, Mates and Pilots, 2022) and the U.S. Maritime Administration-led EMBARC program.

Early Response

There is no program or best practice guidance for companies regarding responding to issues that may not require a report. The U.S. Coast Guard has provided guidance to the marine industry that what is reported depends on the company’s anti-harassment policy, stating:

There is no similar guidance for how to handle issues that are not reported to prevent them from becoming more serious over time.

Analysis

On board vessels, programs and policies can serve to reduce sexual misconduct, as well as other bullying and harassment. Of the three reviewed here, only bystander training is required for a subset of vessels in the maritime industry, those that participate in the EMBARC program. The extent to which this training is available in other vessels is not known. Nor is it possible to assess the use of alternative dispute resolution or near miss protocols at sea.

Conclusion 5-5: Despite evidence of impact from approaches to reduce sexual misconduct, the extent of their adoption by the maritime industry is not well understood. The U.S. Department of Transportation (including the U.S. Maritime Administration), by virtue of its broad engagement with the maritime industry, is best placed to remedy this situation.

Recommendation 5-4: The U.S. Coast Guard should identify standards for the maritime industry to adopt alternative dispute resolution, early response, and bystander support for sexual misconduct. These standards should protect mariners on U.S.-flagged vessels, not just on vessels that participate in the Every Mariner Builds A Respectful Culture program.

PHYSICAL CHANGES ON THE VESSEL

Structural protections are modifications in the environment designed to enhance safety. This section reviews the evidence on such protections and their implementation in the maritime industry.

___________________

⁷ U.S. Coast Guard, Report to the Committee, April 4, 2025. https://www8.nationalacademies.org/pa/managerequest.aspx?key=DBASSE-BBCSS-23-02

Evidence and Best Practices

The National Institute for Occupational Safety and Health has established a taxonomy of controls for managing hazardous workplace exposures. After the most effective types of controls—those that eliminate the hazard or substitute a safer alternative—the National Institute for Occupational Safety and Health recommends “engineering controls.” These are changes to the environment that protect workers from hazards and are most effective when they operate “without interfering with the work process” (National Institute for Occupational Safety and Health, 2024). An example of engineering control might be implementing a maximum speed for a piece of equipment.

Several opportunities exist within the maritime work environment for structural protections, which, in theory, could act like engineering controls. These include enhancing lighting, to prevent areas where assaults may be more common, and increasing visibility, to prevent places where people could be separated from others. There are additional mechanisms that could be considered to help reduce the risk of an intoxicated mariner causing harm, such as a breathalyzer device. Three specific ideas that have surfaced in the maritime industry related to structural protections include establishing video surveillance, limiting access to the master key, and requiring posting of information about hotlines and other resources related to alcohol and other substance misuse and sexual misconduct.

Audio and Video Surveillance

The theory behind 24/7 video surveillance is that if people know of the likelihood of being caught on video, they will be less likely to conduct themselves inappropriately. However, concerns over such surveillance include violation of privacy, the potential to defeat surveillance systems, the potential for misuse of surveillance data, and the idea that there are certain conditions (such as inebriation) for which video monitoring may not deter unwanted conduct (American Civil Liberties Union, 2002).

Evidence to support video surveillance of high-risk areas comes from policing, with studies generally finding a modest impact of closed-circuit television, with benefits for property crimes in some settings and most pronounced with active monitoring (Alexandrie, 2017; Piza et al., 2019).

Limiting Access to Master Key

To prevent access to restricted areas, including living quarters, it is generally considered a best practice to limit access to master keys. For example, in the context of reducing contraband, Annex 14 of the International

Convention on the Facilitation of International Maritime Traffic of the International Maritime Organization, instructs that “master keys should be controlled by the ship security officer” (The Maritime Safety Committee, Annex 14, Resolution MSC.228(82), 2006, p. 20).

Posting of Information

Rather than relying on individual company practices or word of mouth to provide access to key resources, such as hotlines for reporting misconduct, a structural change is to require posting of information in prominent locations. According to the Ethics and Compliance Initiative, a large membership and research organization focused on ethics compliance, “to be truly successful, an organization must be concerted in its messaging—across its internal departments, functions and businesses—of the necessity to create a ‘speak up’ culture” (Ethics & Compliance Initiative, 2019, p. 10). In a best practices document about hotlines and investigations, the Institute says that “materials should [...] be effectively distributed to drive results,” including not only “posters, literature and intranet postings,” but also “management training sessions” and other “more aggressive marketing measures” (p. 10).

Current Policy and Practice

Individual companies are able to implement structural protections on their vessels as they see fit. In addition, as a result of the Safer Seas Act (10 U.S.C. § 101, 11608, 2022), the maritime industry has adopted several structural changes designed to reduce alcohol and other substance use and sexual misconduct.

Audio and Video Surveillance

The law requires certain larger vessels to install “video and audio surveillance equipment […] in passageways on to which doors from staterooms open […] ensuring the visibility of every door in each such passageway.” These records must be maintained for at least one year, or five years in case of an alleged incident. Retention may be kept via secure physical storage on board the vessel or office or via a cloud-based service if the statutory timeframes for retention are met.

The law prohibits the use of these records “as part of a labor action against a crew member or employment dispute unless used in a criminal or civil action.” There is no requirement for active monitoring of this equipment (46 U.S.C. § 4901, 2023).

These provisions, recently implemented, have been controversial. The committee heard from union representatives who argued that the

surveillance, because it extends 24/7 to working and living conditions, is more extensive than for any other class of employee.

Limiting Access to Master Key

The law requires that larger vessels have a master key control system, which limits access to specified persons and requires the use of a logbook to identify “dates and times of access,” “the room or location accessed,” and “the name and rank of the crew member that used the master key.” Such records must be available to the U.S. Coast Guard and other law enforcement officials conducting investigations (46 U.S.C. § 3106, 2023).

Posting of Information

The law requires that vessels that are more than 100 gross tons must post information “in each berthing area” about policies prohibiting “sexual assault and sexual harassment, retaliation and drug and alcohol usage” as well as on:

In addition, each head must have posted “information regarding procedures and resources to report crimes upon the vessel, including sexual assault and sexual harassment, and vessel owner or company policies prohibiting sexual assault and sexual harassment, retaliation, and drug and alcohol usage” (46 U.S.C. § 111101, 2023).

The committee viewed numerous examples of these posted materials during its site visit in Jacksonville, Florida.

Analysis

While the logic for implementing structural protections in general is strong, there is limited evidence for specific interventions in the maritime environment. With respect to 24/7 surveillance, the monitoring costs include

the cost of the equipment as well as the lack of privacy for crew members. The master key controls are advisable as a general security practice, with little downside to the work environment. The posting of information in prominent locations is consistent with best practices, but it may not be sufficient to make sure that mariners feel comfortable utilizing these resources. Significant gaps in evidence related to these and other structural protections may represent an underutilized opportunity to prevent problems at sea. Closing these gaps could inform investments that pay off in greater safety and health.

Conclusion 5-6: Further research can define the benefits and drawbacks of structural protections in the maritime work environment and inform future changes to policy and practice.

WELLNESS POLICIES

Wellness policies have the potential to support both physical and mental well-being of mariners as they are working, regardless of the length of time spent onboard the ship.

Evidence and Best Practices

Best practices exist for the spectrum of workplace wellness policies, covering physical and mental well-being. In this section, the committee explores several of the most cited areas of workplace wellness, but this section is not intended to be a comprehensive list that can be addressed to enhance mariner well-being.

Gyms

Workplace wellness programs emerged in the 1980s with a goal of improving physical health to reduce health care spending (Reardon, 1998). Research subsequently found that investments in employee wellness could reduce medical costs and absenteeism (Baicker et al., 2010). As part of this effort, some employers began to offer reduced-price or free gym membership for their employees. As workers in the maritime industry can work weeks, if not months, at a time on board a vessel, the ability for these mariners to regularly work out on gym equipment is dependent upon the vessel having an equipped exercise center or gym.

Safety Teams

Another strategy to protect health is to involve employees in safety teams. These teams typically include members from different departments to develop safety policies, help train employees, conduct inspections, and generally help promote a healthy culture of safety within the organization. Safety teams have been a useful tool to decrease physical damage, personal injury, and death in work environments. In the academic arena, student-led laboratory safety teams have been incorporated and have potential to improve the attitudes related to the health and safety in the laboratory setting, as well as safety education (Hensley et al., 2024; Martin et al., 2020). The oil and gas sector has utilized safety teams to increase the health and safety of its employees (Nkrumah et al., 2021).

Connectivity

Social isolation has been found to be a strong predictor of poor health outcomes, including mortality, with risks on the order of those observed for smoking and obesity (Holt-Lunstad et al., 2010, 2015). Social isolation is a predictor of cardiovascular disease (Leigh-Hunt et al., 2017; Valtorta et al., 2016) and is also linked to physical illness, including increased risk of high blood pressure (Shankar et al., 2011) and lung disease (Shankar et al., 2017) as well as risky health behaviors including physical inactivity and smoking (Shankar et al., 2011). It has also been shown to negatively affect mental health (Cornwell & Waite, 2009; Leigh-Hunt et al., 2017). In a study of faculty, students, and staff at the University of North Carolina at Chapel Hill, socially isolated people reported nearly twice the rate of anxiety and depression than their non-socially isolated counterparts (Evans & Fisher, 2022).

Best practices in addressing social isolation include maintaining connections to family and friends through internet access and phone calls. Also important are expressions of empathy, trust, and caring from employers alongside offering or providing behavioral or material assistance with practical tasks or problems (Semmer et al., 2008).

Work Schedules

Shift work, or atypical working time arrangements, force workers to exist in a divergent pattern from that of their family and community (Arlinghaus et al., 2019). This temporal isolation, along with circadian misalignment, increases mental health issues experienced by these shift workers. These mental health issues include increased depression (Angerer et al., 2017), prevalence of burnout (Woo et al., 2020), sleep disorders

(Eldevik et al., 2013; Wright et al., 2013), and suicide ideation (Petrie et al., 2020; Violanti et al., 2008). In a study by Thun and colleagues (2014), nurses who switched from night work to day work experienced in improvements in anxiety and depressive symptoms. Other studies of night workers recruited from the general population revealed an elevated risk of depression after several years (Angerer et al., 2017).

Irregular and unpredictable shifts resulted in a greater adverse effect on mental health than permanent night and evening shifts (Zhao et al., 2019). The number of hours worked per week, as well as the time off between shifts, affect mental health (Eldevik et al., 2013). A study of junior doctors by Petrie and colleagues (2020) revealed that working over 55 hours per week doubled the likelihood of reporting a mental disorder or suicide ideation than those that worked between 40 and 44 hours per week. In a study involving a safety-sensitive population, working 12-hour rotating shift schedules resulted in lower sleep duration and reduced quality of sleep (McNamara & Robbins, 2023). These 12-hour shifts were also associated with reduced exercise, an activity that correlates with good sleep. This safety-sensitive population was shown to be impacted by poor sleep quality, which has broader implications for health and safety.

Employee Support Programs

Chellam and Divya (2022) noted that the key for a successful organization is communication that includes a way to connect with its employees so that their concerns can be addressed at the correct time. Absence of proper communication can lead to employee dissatisfaction and disengagement. There are three dimensions of communication, namely, in-person, team, and virtual.

• In-person employee assistance allows nonverbal communication so that body cues can be read and proper comfort/action provided in time of crisis. Building long-term relationships with employees yields the most effective communication.
• Team communication forms the underpinning for collaborative effort within organizations. In times of personal crisis, it allows employees to support one another.
• Virtual communication connects employees beyond geographical boundaries. It creates an atmosphere where they feel connected and increases their network of support beyond those in physical proximity.

Human Resources professionals and supervisors can be trained in the best practices for communication, as well as the best practices for time

management, conflict resolution, and identification of common mental health challenges.

Employee Assistance Programs

One important component of support is an employee assistance program (EAP). EAPs often offer a variety of confidential resources to provide general mental health support as well as to help diagnose and treat mental health and substance use disorders (Institute of Medicine & National Research Council, 1994).

In practice, the actual set of services available to employees can vary, services can be limited in time or quantity, and people may avoid accessing care through their EAP due to concerns that the services provided are not confidential (Albrecht, 2014).

When effective, workplace counseling through an EAP allows for a humanistic approach to organizational development (Chellam & Divya, 2022). The counseling allows an employee to have a safe environment to discuss and gain skills to manage personal problems that are affecting their work. Ideally, the employees’ families would be included in the care program as disturbances within an employee’s family circle will affect their mental health at work. This is especially relevant to mariners as they are often away from home for weeks or months at a time.

Current Policy and Practice

Gyms

Collective bargaining agreements and company policies may include welfare provisions that encourage—but do not require—the inclusion of fitness facilities on U.S.-flagged vessels (Merchant Navy Info., n.d.). Where available, onboard gyms are typically equipped with cardio machines such as stationary bikes, treadmills, and ellipticals, along with free weights and strength-training equipment (Dmitry, 2024). The type and quantity of exercise equipment vary by vessel; some ships also feature stair climbers or rowing machines. However, space limitations often prevent smaller vessels from accommodating a dedicated fitness area. Even when fitness centers are provided, demanding work schedules can restrict mariners’ opportunities to use them.

Safety Teams

Onboard safety teams serve as the primary mechanism for implementing these policies. Vessel masters, safety officers, and designated crew representatives coordinate health and safety activities through structured

programs such as daily Job Safety Analyses, toolbox talks, and permit-to-work systems (Berg, 2013). These activities encourage open communication, risk awareness, and collaborative problem solving—factors increasingly recognized as contributors to psychological safety and morale. Regular emergency drills and safety meetings reinforce both preparedness and collective accountability for well-being.

Connectivity

In order to remain in touch with families and friends while on board, mariners require internet access (Bugis, 2022). As recently as 2016, almost half of surveyed mariners noted that they had no internet access on board their vessel (Sampson et al., 2018). Over recent years, there has been increased access through hybrid networks of satellite technology (e.g., Very Small Aperture Terminals, FleetBroadband, and Starlink) to ensure coverage for internet connectivity and broader safety and primary communications (Benecki, 2025).

The coverage, quality, and affordability of internet access while onboard is still limited by current technology and economic constraints. Maritime satellite connections tend to be expensive with low transmission speeds compared to terrestrial broadband connections.

Work Schedules

Many vessels are operated 24/7 and must be staffed with qualified crew. This, coupled with the industry’s desire to limit crew for economic reasons, results in mariners working long hours. There are a variety of shift schedules employed in the maritime industry (Holley, 2017; Marando et al., 2023; Naval Postgraduate School, n.d.). These include

• 4/8: four hours on watch, eight hours off watch, such that crew are scheduled to work eight hours per 24-hour period;
• 6/6: six hours on watch, six hours off watch, such that crew are scheduled to work twelve hours per 24-hour period;
• 3/9: three hours on watch, nine hours off watch, such that crew are scheduled to work six hours per 24-hour period; and
• 5/10: five hours on watch, 10 hours off watch. Thus, crew are scheduled to work five hours per 15-hour period. This schedule does not align with a 24-hour day, thus is a non-circadian watch bill.

Some vessels incorporate rotating schedules whereby the burden of night-shift work is shared by all the crew.

The International Labor Organization and International Maritime Organization mandate the maximum number of working hours for mariners is 14 hours per day or 72 hours per seven days, yet the International Federation of Transport has stated that 25% of mariners work for more than 80 hours per week (Mansyur et al., 2021).

In addition to safety-critical operations, wellness practices now emphasize fatigue risk management, adherence to work-rest hour requirements (46 C.F.R. § 15.1111, 2024), and attention to nutrition, rest, and ergonomic conditions. U.S. Coast Guard regulations mandate that personnel assigned to watchkeeping or safety duties receive at least 10 hours of rest within a 24-hour period and 77 hours within a seven-day period, with limited allowances for division of rest periods (46 C.F.R. § 15.1111, 2024).

These provisions are intended to safeguard mariners from fatigue-related risks, ensuring sufficient recovery time to maintain alertness and operational safety. Masters are responsible for maintaining compliant watch schedules, documenting rest periods, and providing each crewmember with a signed record of their rest hours.

Exceptions to these rest requirements are permitted only under specific conditions—such as emergencies, drills, or overriding operational demands—and must be followed by compensatory rest. While the rule allows flexibility in exceptional circumstances, it preserves strict limits to prevent cumulative fatigue. Together, these rest standards and company-level initiatives form the foundation of a comprehensive wellness framework that links regulatory compliance with crew health, safety, and performance.

Regularly scheduled rotations and crew schedules have traditionally been adopted by oil and gas shipping companies, offshore energy companies, heavy-lift and special purpose maritime operations, and U.S. Navy-contracted Military Sealift Command (MSC) vessels have recently adopted mixed crew schedules, allowing mariners some flexibility in scheduling and rotations, in an attempt to make service with MSC more attractive and competitive with commercial shipping schedules (Burchett, 2024). USMMA, state maritime academy, and union trainee Cadets have opportunities to sail with regularly scheduled crews and often return to those companies for full-time employment because of the regularity of the ship schedules (Marine Engineers Beneficial Association, 2021).

Employee Support Programs

Some companies have implemented a safety team approach for the mental health and well-being of their mariners, though the extent of these programs is unknown. Several companies are known to have implemented support programs that include the families of their employees. These companies will meet with family members to discuss the issues related to having

the mariner away from home for long periods of time, sometime with limited contact. They also assist these families in time of need to help alleviate the stress on their employee (International Seafarers’ Welfare and Assistance Network, 2024).

Employee Assistance Programs

Maritime companies are required by the U.S. Coast Guard to offer an EAP. The minimum requirements include “display and distribution of informational material; display and distribution of a community service hot-line telephone number for crewmember assistance; [sic] and display and distribution of the employer’s policy regarding drug and alcohol use in the workplace” (46 C.F.R. § 16, 1988).

However, beyond this minimum, the specific clinical services and participation vary, and the committee is aware of no data evaluating the use or success of these programs.

Analysis

Mariner well-being is critical to success of the maritime industry and is core to challenges that lead to alcohol and other substance misuse and sexual misconduct. There are opportunities to improve support for mariner well-being, including greater access to gyms, more use of safety teams, better and more reliable internet access, more consistent and healthy schedules, and more holistic and comprehensive support programs.

Conclusion 5-7: There are multiple dimensions to employee well-being and many opportunities for employee support. The U.S. Department of Transportation (including the U.S. Maritime Administration), by virtue of its engagement with the maritime industry, is best placed to lead efforts to advance this effort.

Recommendation 5-5: The U.S. Maritime Administration should develop a research program to improve maritime employee well-being. This research should assess different interventions and their impact on rates of social isolation, depression, anxiety, and substance use among mariners, as well as their sense of belonging and support in their work. The research should also explore the minimum staffing levels required to maintain employee well-being.

Such research should inform regularly updated guidance for mariner employers to enhance employee well-being. The guidance should cover, at a minimum, the information pertaining to access to exercise

equipment, safety teams, connectivity, shift schedules, and employee support and assistance programs.

Recommendation 5-6: The U.S. Maritime Administration should conduct an assessment of insurance coverage, employee assistance programs, and clinician licensing rules that apply to the care of mariners, including when they are at sea. This assessment should include whether new standards are needed to provide mariners with meaningful access to effective treatment services for mental health and substance use disorders.

ACCESS TO HEALTH CARE

Mental health conditions, including alcohol and other substance use disorders, are treatable, with many millions of Americans receiving benefits from a broad range of treatment services. In particular, addiction is a chronic, relapsing illness, often requiring extended treatment (National Institute on Drug Abuse, 2020). Mariners, however, face unique obstacles in accessing effective care. This section provides a brief overview of this challenge.

Evidence and Best Practices

Mental health disorders include a broad range of debilitating conditions, including anxiety, depression, schizophrenia, and post-traumatic stress disorder, among others. Substance use disorders are a subset of mental health conditions involving the compulsive use of alcohol or other substances (e.g., cannabis, hallucinogens, inhalants, opioids, stimulants, tobacco, etc.). Together, these chronic conditions affect about one in five Americans (National Institute of Mental Health, 2024).

Fortunately, there are highly effective treatments for many mental health disorders, including substance use disorders. These treatments include psychological therapy and medications, such as naltrexone for alcohol use disorder and buprenorphine and methadone for opioid use disorder However, according to the Substance Abuse and Mental Health Services Administration (SAMHSA), “most people with mental illness do not receive mental health services that they need” (SAMHSA, 2024b). The treatment gap is particularly pronounced for alcohol and other substance use disorders. In July 2024, SAMHSA reported that of those needing substance use treatment, just 16.6% of people aged 18 to 25 and 24.2% of people aged 26 or older received services in the last year (SAMHSA, 2024c, p. 44).

A core element of access to care is the ability to pay. Third-party insurance coverage can provide payment for services, as well as facilitate access

to a clinical network. People who have insurance are more than twice as likely to report receiving mental health treatment as those who lack insurance (Panchal & Lo, 2024).

Another key component of access is being able to find an available qualified clinician. For both mental health and substance use disorder treatment, telehealth offers a pathway for access to care for populations like mariners, who may be mobile, need assistance when not at home, or are concerned about privacy. Telehealth also allows health care providers to offer services outside of their geographic location, casting a wider catchment area for their expertise. Some professions offer interjurisdictional compact agreements to facilitate the delivery of services across state lines (e.g., PSYPACT for psychologists [Psypact, 2026]; IMLC for physicians [Interstate Medical Licensure Compact., 2025]) without the requirement that the provider be licensed in each state within the compact. This arrangement can be particularly advantageous for mariners who would benefit from providers with specialized expertise (e.g., treatment of safety-sensitive professionals with substance use disorders or the co-occurrence of substance use disorders and trauma) but live in areas with limited access to qualified providers.

Current Policy and Practice

Many mariners obtain health coverage through their unions or employers. Under federal parity law, the mental health and addiction benefits may not be offered in a more restricted way than other health benefits. However, these plans are not required to offer a particular set of benefits. The committee could not assess the completeness of these benefits within the maritime industry, or the frequency of use of services for mental health or substance use disorder treatment.

Employers in the maritime industry are required under 46 C.F.R. § 16.401 (1988) to offer an EAP, which must include informational material, a hotline number, and a training program (46 C.F.R. § 16.401, 1988). However, regulation does not require employers to provide access to specific counseling or treatment services, and the committee was not able to assess the completeness of these programs.

Global telehealth services in the maritime industry are generally focused on emergency services, so a special challenge for mariners relates to accessing non-emergency telehealth services and their regulation. Generally, within the United States, providers are only able to provide care based on the physical location of the patient due to state licensure restrictions. For example, a Maryland-licensed provider can only provide care for patients

physically in Maryland. In some states, some professionals with an active license in another state may be able to provide services for a limited number of days (e.g., a psychologist or addiction counselor licensed in another state could work for 20 days in Colorado) without being licensed or participating in one of the compacts described above (Colorado Revised Statutes, Title 12, 2023). Furthermore, the consequences of practicing medicine in another state without proper licensure can result in significant legal involvement, a risk many highly qualified providers will be unwilling to take. As an example of a state with a large mariner population, providing services without an active license in Florida (Title XXXII, Chapter 456, Section 065, 2024) can result in a felony charge. These rules and the consequences vary by state but create significant complications to accessing consistent physical and mental healthcare for mariners who move across the country and into the open sea. There is no agreement or compact known to the committee that facilitates the delivery of telehealth services while a mariner is at sea, without risking a medical professional’s license and potential legal ramifications.

The committee found little available information about access to and use of clinical services for alcohol and other substance use disorders among mariners, whether through private health insurance, EAP, or telehealth.

Analysis

Meaningful access to effective treatment for mental health and substance use disorders promotes mariner safety and well-being and accordingly, can help reduce incidents of sexual misconduct. However, while there are efforts by unions, employers, and the government to provide access to services, there are also significant barriers to services, and there is little data available to assess the use of treatment services.

CONCLUSIONS

Conclusion 5-8: While access to treatment for mental health conditions and substance use disorders advances mariner well-being and should decrease incidents of sexual misconduct, data is needed to assess whether mariners are able to access these services effectively.

Conclusion 5-9: Even in situations in which a mariner wants to access care, they may be limited by provider state licensing restrictions. The licensing structure across health care professions and across state lines is complex, and there are no known federal laws in place to protect

providers offering services while a patient is at sea. This is a particular challenge to accessing care for mariners on blue water vessels and mariners with longer periods at sea.

Recommendation 5-7: The U.S. Congress should consider allowing licensed medical professionals to provide medical care to mariners on ships, within the scope of their training and license, regardless of a mariner’s location.

REFERENCES

This page intentionally left blank.