Last week we discussed WHO is expected to comply with TWIC Reader Requirements, WHAT is required to complete an Electronic TWIC Inspection, and WHY this is a requirement.  This week we will go over the WHEN, WHERE, and HOW for different implementation options along with administrative requirements.

There is quite a bit of apprehension in how to purchase or enhance current systems to be in compliance with the TWIC Reader Requirement Final Rule.  We are asked all the time - How do I know what TWIC Readers to purchase? or Can I enhance the Physical Access Control System (PACS) I have in place at my facility?  I will address each question and provide guidance that will assist you in determining which solution is better for you.

TWIC Readers – TSA has a Qualified Technology List (QTL) outlining companies that have approved readers meeting the Electronic TWIC inspection requirements.  That list can be found at: TSA QTL:  https://universalenroll.dhs.gov/permalinks/static/twic-reader-qtl   If your TWIC reader is not on the list, that is OK as long as it meets the Electronic TWIC Inspection Requirements – see last week’s blog for details.

PACS -  Facilities are authorized to enhance their current systems to meet the Electronic TWIC inspection requirements.  I am sure you are picking up a theme here – whatever system or reader you use, it must meet the Electronic TWIC inspection requirements.

Can the TWIC Readers and PACS be portable? – Yes, there is no requirement for either to be fixed or stationary, portable systems are acceptable.

What if TWIC Reader or PACS malfunctions? – You are required by law to have a back-up system or portable TWIC readers at the ready that perform the Electronic TWIC Inspection requirements (Visual inspection of the TWIC cards is NOT authorized).  NOTE: If you cannot provide a back-up for that access point, you must report it to your Captain of the Port and obtain permission to operate.

Once you have decided on the hardware solution, there are some administrative requirements that must be met and those are:

  • Must record/document each ENTRY into a secure area and you are required to maintain these records for two years.

We are asked -  What if we document both the entry and exit of all personnel in and out of a secure or secure/restricted area?  A lot of facilities track who enters and exits for accountability reasons and this is permissible and accepted by the Coast Guard, but make sure you maintain those records for two years.

Next week’s blog will discuss what is required if a TWIC card is lost, stolen or damaged as well as what requirements need to be met if you routinely move between a secure area and an unsecure area to perform your duties.

Reminder – Seebald & Associates will host a Webinar this week.  We’ll discuss the TWIC Reader Requirements Final Rule on Thursday, February 22, at 11:00am ET and 3:00pm ET.