Sunday, June 16, 2013

Comments for TWIC Reader NPRM – 6-15-13

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.


Only six comments were received in the last week and there is less than a week left in the extended comment process. The commenters include two industry organizations, a petrochemical manufacturer, a barge operator, a local government ferry operator, and a local port authority.

Barge Fleet Exemption

A barge and tugboat association urges the Coast Guard to exempt barge fleeting operations from the requirement of using TWIC Readers. They argue that the current requirement based upon periodic handling of Certain Dangerous Cargo (CDC) ignores the unique situation of these facilities and the limited access already allowed.

Electronic Flash Pass

A major petrochemical manufacturer recommends that the Coast Guard specifically authorize the use of the TWIC in conjunction with an electronic access control system (not a full TWIC Reader) as an electronic flash pass instead of requiring visual inspection when a TWIC Reader is not deployed.

Portable TWIC Readers

The petrochemical manufacturer requests that the final rule specifically address the use of portable TWIC Readers at infrequently used entrances to facilities.

Risk Group A Designations

The petrochemical manufacturer objects to “the arbitrary re-designation of petroleum refineries, non-CDC bulk hazardous materials facilities, and petroleum storage facilities into Risk Group A”. They don’t believe that the designation is justified upon a risk-based analysis.

A local government ferry operator objects to the designation of ferries in Risk Group A solely based upon the number of passengers carried. They would rather see a vessel-specific risk assessment used to determine the risk group assignment of vessels. A local government port operator makes the same argument for assessing the risk group assignments for port facilities.


TWIC Reader Expansion to Risk Group B Facilities

A biometric industry association recommends the expansion of the use of TWIC Readers to Risk Group B facilities. The petrochemical manufacturer disagrees and calls the suggestion self-serving.


A local government ferry operator objects to the designation of ferries in Risk Group A solely based upon the number of passengers carried. They would rather see a vessel-specific risk assessment used to determine the risk group assignment of vessels.

Comment Period Ending


The extended TWIC Reader extended comment period will end this Thursday. Based upon previous TWIC related rulemakings, there will almost certainly be a surge in the number of comments submitted during the coming week.

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