Maritime Compliance Report
Welcome. Staying in compliance takes dedication, diligence and strong leadership skills to stay on top of all the requirements which seem to keep coming at a rapid pace. With this blog I hope to provide visitors with content that will help them in their daily work of staying in compliance. I hope you find it a resource worthy of your time and I look forward to your feedback, questions, comments and concerns. Thanks for stopping by.
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TWIC Readers
"I thought TWICs were going away?" I have heard this many times over the past year. They are not. Many believe TWIC is a useless program. The truth is TWIC is a very important program, but few understand it.
Basically, the most important purpose of a TWIC is to not allow anyone, unescorted, into a secure area of a vessel or facility unless we know they are not a terrorist and they have a card to prove it. This may seem like nonsense to some, but if a major terrorist organization can send a terrorist spy to the U.S. and infiltrate the CIA, FBI and Army Special Warfare command, then they can surely send some to infiltrate the maritime industry. In fact, during one joint FBI/ USCG operation, a significant number of individuals "having a nexus to terrorism matters," were found to have U.S. merchant mariner documents and they were subsequently placed on the terrorist watch list and the no-fly list. Furthermore, officials recently uncovered a major plot to attack the maritime industry because it is viewed as a soft target by terrorists.
Due to the lack of understanding, or acceptance of the threat, the way TWIC has been implemented and enforced in many instances makes no sense, and therefore it appears to be "useless" to the casual observer who assumes the TWIC process they observe is the one prescribed by the government.
The TWIC was designed to be a biometric credential to be used with a TWIC Reader. Realizing that we don't yet have TWIC readers, that fake TWICs are a reality, and that someone could gain access using a stolen TWIC on an automated system without biometric interface, years ago the Coast Guard published fairly specific requirements on how a TWIC should be verified by the person granting access to the secure area.
The Coast Guard recently released a Proposed Rule on the TWIC Readers. Vessels and facilities were placed in risk categories A through C. According to the proposed rule only risk category A vessels and facilities will have to use a TWIC Reader. Risk Category A is limited to vessels and facilities that handle Certain Dangerous Cargoes (CDCs) in bulk, including barge fleeting facilities with CDCs, and vessels with more than 1,000 passengers. So, the vast majority of Subchapter H compliant vessels and facilities will have to continue to verify TWICs manually. There's the rub. This sounds like a good deal, until it is enforced.
Basically, the most important purpose of a TWIC is to not allow anyone, unescorted, into a secure area of a vessel or facility unless we know they are not a terrorist and they have a card to prove it. This may seem like nonsense to some, but if a major terrorist organization can send a terrorist spy to the U.S. and infiltrate the CIA, FBI and Army Special Warfare command, then they can surely send some to infiltrate the maritime industry. In fact, during one joint FBI/ USCG operation, a significant number of individuals "having a nexus to terrorism matters," were found to have U.S. merchant mariner documents and they were subsequently placed on the terrorist watch list and the no-fly list. Furthermore, officials recently uncovered a major plot to attack the maritime industry because it is viewed as a soft target by terrorists.
Due to the lack of understanding, or acceptance of the threat, the way TWIC has been implemented and enforced in many instances makes no sense, and therefore it appears to be "useless" to the casual observer who assumes the TWIC process they observe is the one prescribed by the government.
The TWIC was designed to be a biometric credential to be used with a TWIC Reader. Realizing that we don't yet have TWIC readers, that fake TWICs are a reality, and that someone could gain access using a stolen TWIC on an automated system without biometric interface, years ago the Coast Guard published fairly specific requirements on how a TWIC should be verified by the person granting access to the secure area.
The Coast Guard recently released a Proposed Rule on the TWIC Readers. Vessels and facilities were placed in risk categories A through C. According to the proposed rule only risk category A vessels and facilities will have to use a TWIC Reader. Risk Category A is limited to vessels and facilities that handle Certain Dangerous Cargoes (CDCs) in bulk, including barge fleeting facilities with CDCs, and vessels with more than 1,000 passengers. So, the vast majority of Subchapter H compliant vessels and facilities will have to continue to verify TWICs manually. There's the rub. This sounds like a good deal, until it is enforced.
Here's a quiz: What are the three words on the triangle at the center of all TWICs? If a person granting access to a secure area has actually been examining TWICs each time as required, then surely they would remember that those three words are: "privacy, security and commerce." And by the way, poor eyesight is not a good excuse for not complying with a federal regulation. If they cannot see what they are required to check by regulation, they have no business being posted at such a position. Reading glasses or a magnifying glass would come in handy in those situations. Also, you'd also be surprised with what an inexpensive black light will show on a TWIC.
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