Public Comments TWIC Reader ANPRM – 04-17-09

More comments on the TWIC Reader ANPRM are starting to trickle into the Regulations.gov web site. We have three new comments posted in the last two weeks. Additionally the Coast Guard has posted two new supporting documents to the site. The comments were received from: Judy Visscher Lake Carrier’s Association Jack Harmon The supporting documents are: USCG Analysis in Support of the Transportation Worker USCG Analysis in Support of the Transportation Worker Identification Credential (TWIC) Program Independent Verification and Validation of Development of Transportation Worker Identification Credentials Reader Requirements Judy Visscher Comments Ms Visscher, writing for the James De Young Generating Facility, applauds the Coast Guard establishing the Risk Groups, noting that, with the limited use of the restricted area at their facility, it would not make economic sense to buy and maintain a TWIC Reader. Lake Carrier’s Association Comments LCA represents companies operating 65 US-flag vessels on the Great Lakes. LCA supports not requiring low-risk vessels to have a TWIC Reader on board. They do, however, doubt that there will be enough TWIC readers located in the Great Lakes area to meet the requirements of the one-time biometric match requirement. They recommend that computer software be made available to accomplish that match. They recommend that the Recurring Unaccompanied Access (RUA) provisions be extended to cover a loading crew of up to 14 individuals at each Port of Call. LCA notes that their members use an Association developed Alternative Security Plan (ASP). They recommend that they be allowed to avoid making the required changes to that 200 page ASP until the next required review. They suggest that a one-page supplemental document covering the RUA provisions would be an adequate interim measure. Jack Harmon Comments Mr. Harmon’s comments are actually on the planned public meeting in the Washington, D.C. He would like to suggest that the Coast Guard conduct additional public meetings at other areas across the country, particularly in the Seattle, WA area. Mr. Harmon notes that many smaller operators cannot afford to travel to Washington, D.C. to attend such meetings. Supporting Documents The two documents posted to the docket website last week deal with the risk analysis that was done to establish the Risk Groups used to regulate when a TWIC Reader would be required to be used to verify the identity of a worker to granted unaccompanied access to a secure area of an MTSA covered vessel or facility. The Coast Guard document details the analytical method used to establish the Risk Groups. The second document details the peer review process conducted by the Homeland Security Institute to validate the Coast Guard method. Both documents are heavily redacted, removing a wide range of Sensitive Security Information (SSI) that was used in the analysis. My Comments on Comments It seems to me that LCA misread the intent of the Recurring Unaccompanied Access provisions of the TWIC Reader ANPRM. The way that I read the ANPRM, the Coast Guard intended the RUA procedure to be used (on vessels) to avoid repetitive ID checks of the vessel crew. The intent was not to allow shore based personnel at each new port of call to have RUA to the vessel. RUA is based on personal recognition of the personnel that one works with on a daily basis. Once an individual’s identity is adequately identified, personal recognition by co-workers, especially in the intimate setting of a vessel or small facility, is always going to be a more secure method of identification than any other kind of ID system. That intimate personal recognition would be absent for the work crews that had to board a ship for a relatively brief period of time involved in a loading/unloading situation.