Friday, April 22, 2011

Reader Comment – TWIC Delivery Issues

Readers will probably recognize the name of the latest commentor on the blog; John C.W. Bennett, from the Maritime Transportation Security News and Views blog. He provides some additional insight on the comments I made in my posting on the GAO report on TWIC delivery options. His entire comment is well worth reading, but I would like to highlight just a couple of points he addresses in these comments.

Convenience vs Security

John makes the following observations:

“I don’t think the Congressional types who advocate mailing TWICs are knowledgeable about the distinction between delivery and activation. I suspect they think that a TWIC is ready to go as soon as it’s delivered. If they were to realize TWICs need to be activated, the debate would still be over worker convenience versus security. Those still in favor of convenience for their constituents would simply want to see activated TWICs delivered by mail.”
This is always one of the problems that security managers need to deal with. Security measures are frequently an inconvenience. Particularly with regards to terrorist attacks, workers do not fully understand the need for security since there are generally so few attacks that the average worker does not appreciate (or believe) the potential risk. There is a similar problem with management’s appreciation of the risk which frequently results in the failure to enforce security rules where they do exist.

TWIC and CFATS

John points out that one of the impediments to the use of TWICs for access to CFATS facilities is that the current rules specifically limit the use of TWIC to transportation workers. While some facility operators might want to be able to use a TWIC based identification instead of producing their own picture ID system, I don’t think that ISCD will try to authorize the general use of TWIC as a general facility ID system.

What the real push behind the TWIC-CFATS debate has been the issue of truck drivers and how the facility would be able to ensure that they can provide unescorted access for commercial transportation while remaining CFATS compliant. Transportation companies and workers are concerned about the potential need for getting yet another type of ID to be able to access CFATS facilities.

The ISCD personnel surety rules will probably specifically allow facility operators to accept TWIC and Hazmat Endorsed CDLs as ways to authorize truck drivers to have access to their facilities. This will probably lead to more trucking companies requiring their driver’s to have TWICs or Hazmat endorsements as a condition of employment.

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