TWIC Reader Requirements Final Rule - So far this month we discussed Who, What, When, Where and Why, so we will cover a few “What if” questions this week.

What if my TWIC card is stolen, damaged or lost? – Unescorted access can be granted up to 30 days if:

  • TWIC card appears on the Cancelled Card List (CCL)
  • Individual was known to have had a TWIC card
  • Individual reported it lost, stolen or damaged

Facilities using a Physical Access Control System (PACS) - If after 30 days the individual has NOT linked their facility access card to a valid TWIC card, the PACS must deny unescorted access to secure areas.

What if I forgot my TWIC card at home? – Unescorted access is DENIED unless electronic TWIC inspection can be performed by PACS with facility access card.  If you have TWIC readers, the individual will NOT be able to perform a required electronic TWIC inspection.

What if my job requires me to go between secure and unsecure areas to complete my duties, do I need to complete an electronic TWIC inspection every time I re-enter the secure area? – NO, an electronic TWIC inspection is not required for reentry into a secure area as long as certain requirements and conditions are met.  This includes the following:

  • Designated Recurring Access Area (DRAA) – An unsecure area adjacent to a secure area with access gates where employees require frequent access between the unsecure and secure areas to complete their duties.
  • Recurring Unescorted Access (RUA) – TWIC holding employees going between secure and unsecure areas without going through an electronic TWIC inspection each time they pass from unsecure to secure after an initial electronic TWIC inspection was conducted.

DRAA Requirements

  • Must be designated and approved in FSP
  • Security Guards at each secure area access point
  • Entire DRAA must be visible to security personnel
  • Electronic TWIC inspection completed for initial entry into secure area (beginning of work shift) and TWIC holder can have RUA as long as they do NOT leave DRAA
  • If TWIC holder leaves DRAA for ANY reason, they must conduct an electronic TWIC inspection upon return into the secure area

Some possible DRAA scenarios are:

Cruise ship porters carry baggage from curbside check-in area (unsecure) to baggage storage area (secure) for cruise ship passengers

Forklift operators transport packages from loading area (unsecure) to secure storage area on vessel or facility.

NOTE – Seebald & Associates presented a Webinar last Thursday (February 22nd) that covered everything you need to know about TWIC Reader Requirements.  If you missed the webinar, S&A Platinum members can view the recorded presentation via our website.