Public Comments TWIC Reader ANPRM – 05-01-09

One comment on the TWIC Reader ANPRM was reported the Regulations.gov web site over the last week; it came from Noble Drilling Services. In addition, the Coast Guard added some additional supporting documents that were used in the formulation of the ANPRM. These documents were Coast Guard advisory committee responses to specific questions asked by the rule developers. The responses were received from: Towing Safety Advisory Committee (TSAC) National Maritime Security Advisory Committee (NMSAC) Merchant Marine Personnel Advisory Committee (MERPAC) Noble Drilling Services Comments Noble supports the three risk group categories and specifically believes that the assignment of MODU’s regulated under 33 CFR 104 to risk group C is appropriate. They disagree however with the assignments of Outer Continental Shelf (OCS) facilities to risk group B; they don’t believe that level of risk assessment is warranted. They believe that it is the employer’s responsibility to decide where to reassign people who’s TWIC has been suspended or revoked. Records of such actions should be subject to inspection. Finally they don’t believe that off shore facilities should be required to have a TWIC reader on board; they suggest that the TWIC Readers should be used to verify identity and validate the TWIC card of employees at embarkation points enroute to the facility. My Comments on Comments As I have noted in earlier blogs, there appears to be a wide spread misunderstanding of the concept of recurring unescorted access (RUA). Here Noble makes the comment that: “Noble believes for offshore facilities this is an inappropriate number to safely supervise and ensure their actions as safe. A typical work party on the drill floor may be made up of this many persons but at a minimum there should be at least 2-3 supervisory TWIC holding personnel on hand.” The RUA proposal does not remove the requirement to possess a TWIC for personal placed in the RUA status; it just relives the requirement to have to use a TWIC Reader every time the RUA crew members enter the secure area of the facility or vessel.