This is part of a continuing series of blog posts on the
public comments filed in the previous week for the Coast Guard’s TWIC
Reader NPRM. The previous posts in the series are listed below.
After a week with no comments
there were six comments filed this last week from a variety of organizations,
public and corporate. Comments came from:
Use of TWIC at ‘Each Entry’
The comment from Phillips
Cruises is generally supportive of the limited application of the TWIC Reader,
but the owner, Robert Neumann, is concerned about the requirement to show the
TWCI (as a flash pass) upon each entry into a designated secure area on a
vessel. With multiple, separated secure areas crewmembers move through and
between such areas multiple times each day. Neumann notes that they do not have
security personnel standing watch at the entrances to these areas to check
TWICs.
These comments were supported by
comments from Madeline Island Ferry Line, Port of Houston Authority, Washington
State Department of Transportation, and
CDC in Bulk
The comments submitted by the
Port of Houston Authority questions the use of the term “CDC in bulk” since it
is not defined in the NPRM. They specifically ask if a container facility
handling ISO containers of CDC are considered to be handling CDC in bulk? They
also ask if a facility that offers layberths for vessels that carry CDC in
bulk, but is not capable of handling the CDC, would it still be considered a
Group A facility?
TWIC Reader Unnecessary
The comments from MSRC question
the requirement for TWIC Readers. They note the cost for readers is very large
and that the cost of the equipment is not justified by the minimal increase in
security provided.
The Washington State DOT echoes
these comments, noting that their state of the art access control system and
video surveillance system exceeds the security provided by TWIC Readers.
Posts
No comments:
Post a Comment