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.