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UNITED STATES OF AMERICA 

U.S. DEPARTMENT OF HOMELAND SECURITY 

UNITED STATES COAST GUARD 

_________________________________ 

UNITED STATES COAST GUARD 

Complainant 

vs. 

SCOTT HAMISH WILSON, 

Respondent. 

_________________________________ 

Docket Number 2023-0418 

Enforcement Activity No. 7813798 

ADMISSION ORDER 

Issued: January 30, 2024 

By Administrative Law Judge: Honorable George J. Jordan 

Appearances: 

CWO Stephen Cheney 

Sector Puget Sound 

and 

Daniel Schaefer, Esq. 

Suspension and Revocation National Center of Expertise 

For the Coast Guard 

Scott Hamish Wilson, Pro se

For the Respondent 
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DECISION AND ORDER 

 On October 24, 2023, the United States Coast Guard Sector Puget Sound (Coast Guard) 

issued a Complaint against Scott Hamish Wilson (Respondent) alleging use of a dangerous drug 

as described by 46 U.S.C. § 7704(b) and defined by 46 C.F.R. § 5.35. Specifically, the Coast 

Guard alleges on July 06, 2023, Respondent took a required Pre-employment drug test pursuant 

to 46 CFR Part 16. A urine specimen was collected from Respondent by Susan Porter of Glacier 

Family Medical Clinic, Seward, AK in accordance with 49 CFR Part 40. Respondent signed a 

Federal Drug Testing Custody and Control Form for providing urine specimen ID # 9680819 

which was received by and subsequently analyzed pursuant to 49 CFR Part 40 by Quest 

Diagnostics, Inc., Lenexa, KS, a SAMHSA certified laboratory.. On 11 July 2023, urine 

specimen ID# 9680819 tested positive for Marijuana metabolites (THCA) as reported by Quest 

Diagnostics, Inc. On 12 July 2023, Dr. Andrew Holtz, the Medical Review Officer, determined 

that Respondent failed a chemical test for dangerous drugs, raising the presumption of use 

established by 46 CFR § 16.201(b). Respondent has been the user of a dangerous drug as 

described by 46 U.S.C. § 7704(b). The Coast Guard proposes a sanction of revocation of 

Respondent’s Merchant Mariner Credential (MMC or credential). 

 In Respondent’s Answer, dated December 15, 2023, he admits to all jurisdictional 

and factual allegations. Additionally, he asserted an affirmative defense by indicating 

that the Coast Guard served of the Complaint beyond the time limits allowed. 46 C.F.R. 

§ 5.55(a) provides time limits for service of a Complaint on a Merchant Mariner 

Credential holder based on the statute or regulation violated. In this case, Coast Guard 

alleged Respondent was a user of dangerous drugs violating 46 U.S.C. § 7704(b). There 

is no time limit for service of complaint on those alleged to be users of a dangerous drug 
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under 46 U.S.C. § 7704. 46 C.F.R. § 5.55(a)(1). Therefore, Respondent’s affirmative 

defense is meritless and does not prevent the allegations in the Complaint from being 

admitted and proved. Further, Respondent agrees with the Coast Guard’s proposed order 

of Revocation. 

 WHEREFORE, 

 
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ORDER 

IT IS HEREBY ORDERED that Respondent’s violation of use of a dangerous drug 

under 46 U.S.C. § 7704(b) and 46 C.F.R. § 5.35 is PROVED BY ANSWER. I have carefully 

reviewed the file and find that the proposed sanction is appropriate under the provisions of 46 

C.F.R. § 5.569. 

IT IS FURTHER ORDERED that Respondent’s Merchant Mariner Credential is 

REVOKED, commencing on the date deposited with the Coast Guard. 

SO ORDERED. 

Done and dated January 30, 2024, 

Seattle, WA 

______________________________ 

HON. GEORGE J. JORDAN 

ADMINISTRATIVE LAW JUDGE 

UNITED STATES COAST GUARD