The Coast Guard has recently put out enforcement guidance regarding the TWIC Reader Requirements Final Rule, which was in last week’s blog.  This week we will recap WHO is expected to comply, WHAT is required during an Electronic TWIC Inspection, and WHY this is a requirement. 

WHO IS REQUIRED:  The following facility types will be expected to comply starting August 23, 2018:

  1. Facilities that receive vessels certified to carry more than 1,000 passengers; and
  2. Facilities subject to 33 CFR 105.295 - Certain Dangerous Cargo (CDC) facilities.
    (Guidance regarding how 33 CFR 105.295 is applied can be found in Policy Advisory Council Decision 20-04 – Certain Dangerous Cargo Facilities.)

WHAT IS REQUIREDElectronic TWIC inspection –  conducted by TWIC Readers or Physical Access Control Systems (PACS) and required each time a person is granted unescorted access to a secure area and must be in place by August 23, 2018.

What is an Electronic TWIC Inspection? – Three things must happen in order to fulfill the requirements:

  1. Card Authentication – validates Card Holder Unique Identification (CHUID) and Federal Agency Smart Credential – Number (FASC-N)
  1. Card Validity – TWIC card is checked against Cancelled Card List (CCL) - is TWICrevoked or expired?   TSA CCL: https://universalenroll.dhs.gov/

           How Often must the CCL be checked?

                  MARSEC 1 – CCL is updated and checked every 7 days

                  MARSEC 2 & 3 – CCL is updated and checked daily

  1. Identity Verification – cardholder’s identity confirmed with biometrics

           Biometrics – accepted templates:

fingerprints

digital facial image with PIN

Alternative biometrics (vascular) are authorized if this biometric template is tied to TWIC holder & approved in FSP

If you have any questions on whether your facility will be expected to comply or what is required, we recommend you contact your local Captain of the Port.  Also, you are always welcomed to contact Ed Seebald or any of our Associates.

Remember - Everyone presenting a TWIC, along with a reason to access the secure or secure-restricted portion of a maritime facility, is also subject to random screening.  

WHYIT’S THE LAW!!! 

Next week’s blog will discuss WHEN, WHERE, and HOW regarding TWIC Reader implementation options and administrative requirements. 

NOTE:  Join us for our WEBINAR on Thursday February 22 that will explain all this and provide you an opportunity to ask questions.  Details will be sent out separately on the Webinar.