Posted:
October 30, 2015
By Christian Spain
National Assistant Vice President, Government Relations
All officers: Before you read any further, go get your cell phone. Now that you have it add a new contact:
Mike Reny, AMO Coast Guard Legal Aid Attorney
Cell: 419-346-1485
Work: 419-243-1105
Home: 419-843-2411
No matter who you are or what rating you are sailing as, you need Mike's contact information at your fingertips at all times. If you are involved in an incident that is reportable to the USCG on a 2692, or is reportable to USCG during renewal of your documents, such as having a drug or alcohol incident ashore or afloat, your first call needs to be to Mike before you interact with the USCG. You do not want to be looking for Mike's information after an incident in the heat of the moment so make sure it is in your phone. Mike answers his cell phone 24 hours a day seven days a week. His guidance on this is simple - be polite, be professional, and be clear: The AMO Coast Guard Legal Aid Program in which you are a participant requires you to speak with Mike before speaking with the USCG.
First, let me make it clear that Mike has been retained by AMO and is paid by the plans, at no cost to the member, to defend your License. That said, he can also help you obtain a criminal defense attorney if you are going to need one. Many articles have been published by AMO over the years with Mike's information, but this has now become exponentially more important with some new USCG processes, which have been implemented in their License Suspension & Revocation (S&R) procedures.
It is now USCG policy to have a USCG lawyer involved in all investigations that are referred to S&R proceedings; in the past USCG investigators often with little or no legal training or experience performed these tasks. Also, in the future, all cases referred to S&R proceedings will be reviewed at a single point in the USCG rather then at the COTP level. This essentially means that decisions to go ahead with S&R proceedings will now be made at a much higher "national" level rather than locally.
All officers should also be aware that, increasingly, maritime employers are using hair samples for drug testing, which has the obvious benefit of making it more difficult for people to evade a test result and also increases the time window for detection. Finally, 75 percent of all S&Rs are related to drug and alcohol use. In drug cases, unless a settlement is reached, the USCG investigating officer is required to seek revocation. USCG DOT tests are done for five specific drugs. Some companies are choosing to test mariners for additional drugs, including synthetics. USCG will now begin proceedings against anyone who tests positive for these non-DOT tests as long as use of these drugs is against company policy.
Whenever you are involved in a casualty, licensing issue, or if you need advice on either issue, call Mike on his cell phone.
USCG changes policy on suspension and revocation
By Christian Spain
National Assistant Vice President, Government Relations
All officers: Before you read any further, go get your cell phone. Now that you have it add a new contact:
Mike Reny, AMO Coast Guard Legal Aid Attorney
Cell: 419-346-1485
Work: 419-243-1105
Home: 419-843-2411
No matter who you are or what rating you are sailing as, you need Mike's contact information at your fingertips at all times. If you are involved in an incident that is reportable to the USCG on a 2692, or is reportable to USCG during renewal of your documents, such as having a drug or alcohol incident ashore or afloat, your first call needs to be to Mike before you interact with the USCG. You do not want to be looking for Mike's information after an incident in the heat of the moment so make sure it is in your phone. Mike answers his cell phone 24 hours a day seven days a week. His guidance on this is simple - be polite, be professional, and be clear: The AMO Coast Guard Legal Aid Program in which you are a participant requires you to speak with Mike before speaking with the USCG.
First, let me make it clear that Mike has been retained by AMO and is paid by the plans, at no cost to the member, to defend your License. That said, he can also help you obtain a criminal defense attorney if you are going to need one. Many articles have been published by AMO over the years with Mike's information, but this has now become exponentially more important with some new USCG processes, which have been implemented in their License Suspension & Revocation (S&R) procedures.
It is now USCG policy to have a USCG lawyer involved in all investigations that are referred to S&R proceedings; in the past USCG investigators often with little or no legal training or experience performed these tasks. Also, in the future, all cases referred to S&R proceedings will be reviewed at a single point in the USCG rather then at the COTP level. This essentially means that decisions to go ahead with S&R proceedings will now be made at a much higher "national" level rather than locally.
All officers should also be aware that, increasingly, maritime employers are using hair samples for drug testing, which has the obvious benefit of making it more difficult for people to evade a test result and also increases the time window for detection. Finally, 75 percent of all S&Rs are related to drug and alcohol use. In drug cases, unless a settlement is reached, the USCG investigating officer is required to seek revocation. USCG DOT tests are done for five specific drugs. Some companies are choosing to test mariners for additional drugs, including synthetics. USCG will now begin proceedings against anyone who tests positive for these non-DOT tests as long as use of these drugs is against company policy.
Whenever you are involved in a casualty, licensing issue, or if you need advice on either issue, call Mike on his cell phone.