With the TWIC Reader Rule enforcement right around the corner, this month’s blogs will focus on the 30-30-60 rule:

  • 30 days - An amendment to a facility security plan (FSP) must be submitted to the Coast Guard at least 30 days prior to the change in your FSP going into effect – 33 CFR 105.415
  • 30 days – If the audit results require an amendment to your FSA or FSP, the amendments must be submitted no later than 30 days after the completion of the audit and a letter certifying that the amended FSP meets the applicable requirements of this part – 33 CFR 105.415
  • 60 days – A 5 year FSP rewrite needs to be submitted at least 60 days prior to the FSP’s 5 year anniversary date – 33 CFR 105.410

Submit Your Electronic TWIC Reader FSP Amendment 30 Days in Advance

30 days – Remember that we have to submit an amendment to our plan at least 30 days prior to that change in our FSP going into effect.  With the TWIC Reader Final Rule going into effect on August 23, 2018, means Risk Group A facilities that are expected to comply and submit an amendment by July 24, 2018 are:

  • CDC Facilities – facilities that receive vessels and engage in vessel to facility interface that involves the transfer of CDCs, in bulk, to or from the vessel they receive
  • Facilities that receive vessels certificated to carry more than 1,000 passengers

July 24, 2018 is little more than three weeks away, so if you are a Risk Group A facility to which the TWIC Reader Final Rule applies - Where are you in preparing your facility to be compliant with the TWIC Reader Final Rule and the amendment process?

If you need assistance or have any questions, please do not hesitate to contact Seebald & Associates.