TWIC Reader ANPRM – Security Plan Requirements

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 TWIC Reader ANPRM – Recurring Unescorted Access 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 requirements for changes to security plans. Security Plan Amendments Current vessel and facility security plans were prepared, submitted and approved before these requirements were developed for the use of the TWIC Reader to identify, validate and verify the people authorized unescorted access to secure areas within the vessel or facility. Amendments to those security plans will have to be completed to take into account these new requirements. The Coast Guard is considering a six month (from the time of the publication of the final rule) time limit to submit the amended security plan, or perhaps setting up a staggered schedule to avoid having all security plans come due for renewal at the same time. Public comment on these time schedules and deadlines is requested. Security Plan Amendments could be required to address a wide variety of implementation requirements to include:

TWIC verification requirements; Unreadable fingerprint identification requirements; Separate physical access system requirements, including identity protection; Recurring unescorted access (RUA) requirements; Escort requirements at RUA facilities or on RUA vessels; Periodic card validity check requirements at RUA facilities or on RUA vessels;

Alternative Security Plan Amendments The Coast Guard does not currently believe that these TWIC Reader rules will require re-writing § 101.120. That is because there is already existing authority {§ 101.120(d)(i)(ii)} to allow the Coast Guard to order the amendments to existing ASPs. The Coast Guard expects to use the same time limits in such orders, but requests public comments on the suitability of those time limits. An organization ASP could cover more than one vessel and/or facility and could cover more than one risk group. With this in mind the Coast Guard notes that they would expect the amended ASP to address each relevant risk group.