TWIC Reader ANPRM – Recurring Unescorted Access

This is another in a series of blogs about the advanced notice of proposed rule making (ANPRM) that the Coast Guard recently published about the potential regulation of transportation worker’s identification credential (TWIC) reading devices. These devices would be used to verify the identity of people working in ships and facilities covered under the Maritime Transportation Security Act (MTSA). The other blogs in this series include: TWIC Reader ANPRM – Identification Techniques TWIC Reader ANPRM – Risk Groups TWIC Reader ANPRM – Reader Use by Risk Groups The ANPRM expresses the Coast Guard’s current thinking about what types of requirements will be included in the regulations that will be formally proposed later this year. This post looks at potential policies related to recurring unescorted access to security areas on MTSA covered vessels and facilities. Small Vessel or Facility For small, tight knit groups personal recognition is the best form of identification. As long as the initial identification is secure and accurate, small work teams that work together on a daily basis are nearly impossible to infiltrate. It is this concept that the Coast Guard is utilizing in suggesting that small vessels and facilities may not have to require the use of a TWIC reader for Recurring Unescorted Access to secure areas within that vessel or facility. The Coast Guard is suggesting that an appropriate number of personnel that would meet this requirement is fourteen or fewer personnel. This is based on the concept of a small vessel where “the crew would typically include up to one Master, one Chief Engineer, and three four-person crews who rotate through watch shifts” (74 FR 13368). An MTSA covered vessel or facility with no more than 14 people who require unaccompanied access to the secure areas within that vessel or facility could include rules for Recurring Unescorted Access in their security plan. Personal Identification When an individual is hired to work on the small vessel or facility the individual’s identity is verified biometrically with the TWIC and a Reader. The TWIC is authenticated and validated at the same time. While working on the vessel or facility with an approved Recurring Unescorted Access plan, the TWIC will serve as a photo ID that will have to be checked periodically (on a schedule specified in the plan) but not every time that the individual enters a secure area on that vessel or facility. The individual’s TWIC will have to be periodically verified, but a TWIC reader will not be required for this validation. If a TWIC reader would not be available for the check the operator would be required to maintain a list of FASC-Ns and names of the employees in the Recurring Unescorted Access program. This list could then be verified against a current TSA Hot List of invalidated TWIC. It would actually be a negative verification; no match would be a good thing. Schedule for Validation The frequency of validation would vary by the vessel/facility Risk Group and the current MARSEC Level. For Risk Groups A and B the validation would be required weekly at MARSEC Level 1 and daily for MARSEC Levels 2 and 3. For Risk Group C the validation would have to be done monthly at MARSEC Level 1 and weekly for MARSEC Levels 2 and 3.