Public Comments TWIC Reader ANPRM – 04-24-09

More comments on the TWIC Reader ANPRM are starting to trickle into the Regulations.gov web site over the last week. We have two separate comments from one individual and comments from one company. The comments are from Tracy L Royce, #1, #2 Clipper Navigation Tracy L Royce Comments In the first comment Tracy Royce agrees that Risk Group C should not require on-board TWIC Readers. Would like to see rule specify a ‘minimum percentage of persons onboard’ are randomly verified. Royce would also like to see a ‘specified time interval’ for supplying company security officer with updated list of ‘suspended and revoked’ TWIC. Rule should require a report back to Coast Guard if person with a newly suspended or revoked TWIC were found on board. The second comment objects to the classification of coastal drilling platforms on the Outer Continental Shelf (OCS) as Risk Group B. Tracy Royce does not believe that that classification is justified. Clipper Navigation Comments Clipper Navigation echoes the comments of Jack Harmon that were reported in a previous blog that there should be public meetings outside of the Washington, DC area. Again, Clipper Navigation specifically recommends that a public meeting be held in the Seattle, WA area because of the large maritime community. My Comments on Comments Tracy Royce brings up a couple of interesting issues that were not dealt with in the ANPRM. First, off-shore facilities/vessels with large crews are going to find it difficult to do 100% weekly verification of TWIC. The suggestion for requiring a percentage of TWIC checks where there is little change in crew composition should be considered. The second suggestion points out something that should have been considered in drafting the ANPRM; what to do if a check shows that a current crew member’s TWIC is no longer valid. The planned regulation should require removal from sensitive duties and unaccompanied access to critical areas. It should certainly require reporting to the Coast Guard.