Okay, I’ve had a chance to do a quick once thru of the TWIC Reader Pilot Study Report that I mentioned yesterday. Additionally, a long time reader pointed me at a publicly available summary prepared by JTAC consulting (okay ‘summary’ is a little misleading; its 24 pages long) that condenses the important information in the report. Both documents are worth reading in detail if you are planning on installing a TWIC Reader as part of your facility/vessel access control system. The JTAC web site has a number of other documents available that may also be of use, but I have not (and probably will not) reviewed each of them to be able to specifically recommend any specific information.
One thing is clear, installing a TWIC Reader as part of an access control system (either stand alone or as part of a more complete system) is going to be expensive. Right now, MTSA covered facilities are not required to use TWIC Readers (that may or may not change when the subsequent regulations are written) so a careful evaluation of the need for installing a reader is necessary.
Transportation Workers Identification Credential
First you need to understand what a TWIC is. The TWIC is a biometric based identity document that establishes that an individual has been vetted by a established background check process. The government has established by regulation what standards are used to approve a person for issuance of a TWIC and that approval can be removed (TWIC Cancellation) at any time that additional information is received through follow-up background checks.
A TWIC can be used as a photo ID (and that is all that it can practically be used for without a TWIC Reader). When used in that manner it only verifies that the pictured individual was, at the time of issuance, vetted by the TSA background check process. While TSA publishes daily lists of canceled TWICs, it is not practical for those lists to be checked at an access control station without a TWIC Reader. HR or Security could check those daily lists against approved employee lists, but that is unlikely to occur on a regular basis; and almost certainly will not be done on a daily basis.
An electronic chip within the card contains an electronically encoded sample of the holder’s finger print that allows for biometric confirmation that the person in possession of the card is actually the person vetted by TSA. This information is only accessible by a TWIC Reader.
MTSA covered facilities are required by law to use the TWIC as the method to identify individuals granted unaccompanied access to covered facilities and vessels. Facilities and vessels are allowed to further restrict access of TWIC holders as they deem fit.
The TWIC process was designed to provide port transportation facilities with a means of vetting a transient population that can change significantly on a daily basis. There is no other practical way for a facility to ensure that a known set of background checks (particularly screening against the Terrorist Screening Database –TSDB) have been completed on such a transient population.
TWIC and CFATS
There has been a lot of loose discussion about the use of the TWIC process as a substitute for a facility personnel surety program. Under current regulations that is not legally possible because a TWIC applicant is required to swear on their application that they are requesting a TWIC so that they can access an MTSA covered facility. There is only a very small percentage of CFATS employees that can so truthfully swear. Of course those regulations could be changed, but it is difficult to cross load regulatory requirements across different agencies (Coast Guard and NPPD in this case).
The TWIC system could be used to supplement the facility personnel surety program as a means for vetting transient populations, particularly truck drivers. To get the full benefit for such a population a TWIC Reader will be an absolute necessity as it is the only practical way of ensuring that the TWIC is currently valid.
Unfortunately not all truck drivers will have been issued a TWIC. For the TWIC to be used as the means of validating background checks for truck drivers (and the only alternative to ensure vetting against the TSDB is checking the Hazardous Material Endorsement – HME – to the driver’s CDL; again not issued to all truck drivers) the facility will have to establish with their vendors and supporting truck lines that all drivers entering the facility will be required to have a valid TWIC or HME. In many instances (particularly away from port areas) this may greatly restrict the number of drivers available to service a facility. This will inevitably add to shipping costs and shipping delays.
Practical Aspects of TWIC Readers
With that background information out of the way, I’ll discuss some of the practical implications for the use of TWIC readers in some subsequent blogs.