1. U.S. Coast Guard
LCDR Brett Thompson

2. TWIC Reader Requirements
TWIC Reader Rule:
Published in Federal Register on August 23, 2016
2 year implementation from date of publication
Applicability:
Requires higher risk MTSA regulated vessels/facilities (Risk Group A) to conduct electronic TWIC inspections for access to secure areas, or upon boarding a vessel.

3. TWIC Reader Requirements
Risk Group A includes:
Vessels that carry certain dangerous cargo (CDC) in bulk or are certificated to carry more than 1000 passengers; also, vessels engaged in towing either of the above.
Facilities that handle CDC in bulk; receive vessels that carry CDC in bulk, or receive vessels that carry more than 1000 passengers.

4. TWIC Reader Requirements
Performance based requirement allows owners/operators to integrate electronic TWIC inspection and biometric matching into a new or existing Physical Access Control System (PACS).
Exempts any vessel with 20 or fewer TWIC-holding crewmembers from electronic TWIC inspection requirements.

5. Non-Risk Group A
Electronic TWIC inspection for Non-Risk Group A facilities:
May voluntarily use a TWIC reader to perform electronic inspection (must meet requirements of reader rule).
If using a PACS, must comply with PAC (Incorporating TWIC into Existing Physical Access Control Systems) in demonstrating completion of card validation, card authentication & identity verification.
Must maintain records in compliance with 33CFR (b)(9) and (c) as appropriate.

6. History of Risk Group A Developed using MSRAM & group of SME’s
Difficulty translating highest risk group into easily identifiable categories for regulatory enforcement.

7. NPRM vs. FR

8. Issues
Different use of the term “handle” between MTSA and TWIC Reader Rule (PAC 20-04)
Unintended consequences of FR changes
Unknown number of facilities that may be considered Risk Group A

9. Current Enforcement Strategy
Categories of facilities that are Risk Group A that are expected to comply with implementation on 23 August 2018:
Facilities that receive vessels certificated to carry more than 1,000 passengers; and
Facilities subject to 33 CFR : Additional requirements – Certain Dangerous Cargo (CDC) Facilities
Other facilities considered Risk Group A based on the Final Rule publication can expect implementation guidance, regulatory updates, etc. in the future.

10. LCDR Kevin McDonald, USCG
Questions?
LCDR Brett J. Thompson, USCG USCG TWIC Help Desk
MTSA-AID ( )
LCDR Kevin McDonald, USCG