In case you missed last week’s blog because you were being a patriot and enjoying the 4th of July holiday, here is a recap and what additional information that needs to be in the amendment. 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
TWIC Reader amendment – What needs to be in the amendment? It is not as simple as stating that we are in compliance with the TWIC Reader Final Rule because we bought TWIC readers.
You need to first review all the additional 33 CFR 105 requirements for TWIC Reader Final Rule. In short, it explains in detail what electronic TWIC inspection requirements are (card authentication, card validity check, & identity verification), Cancelled Card List (CCL) frequency updates, facility recordkeeping requirements, Physical Access Control System (PACS) requirements, and what is required content for outlining your TWIC program.
If your facility is using or plans to use a TWIC reader on the Transportation Security Administration’s Qualified Technology List (QTL), then your amendment process just got a little easier because these readers meet the electronic TWIC inspection requirements. You are still required to document in your amendment CCL updates, recordkeeping and the security measures for access control using your TWIC readers.
With that said, those facilities using a PACS must outline in your amendment that an electronic TWIC inspection is being completed along with all the other security measure requirements that are being changed with the enhancement of the PACS. Since a lot of these requirements are all done electronically, how do you show the Coast Guard during a compliance inspection you meet all the requirements? You need to work closely with your information technology department to figure this out and remember this data is Sensitive Security Information (SSI) and must be protected in accordance with 49 CFR 1520.
Again, please do not hesitate to contact us if you have any questions or need assistance in becoming compliant with the TWIC Reader Final Rule.