Reader Comment – Coast Guard TWIC ANPRM

Maritime Protective Services and his comments on all things Coast Guard are always valuable. This time he points us at §809 of the Coast Guard Authorization Act of 2010 as a possible topic for the ANPRM.

Section 809 Provisions

In summarizing the provisions of that section John writes:

“In a somewhat convoluted way, section 809 reduces the number of people required to have TWICs by limiting these TWIC requirements to those people serving on vessels that have MTSA Vessel Security Plans.”

John’s comment goes on to explain some of the potential problems with that provision and its potential effects on chemical facilities. His comment is relatively brief but well worth reading, as usual.

Other TWIC Provisions

John’s comment caused me to go back and look at my earlier blog posting about the final version of that bill when it passed last year. I completely missed the potential import of §809, but it is one of those convoluted amendments that you see packed into these authorization bills. In any case I did briefly summarize some other TWIC provisions that might also be included in this ANPRM. I wrote:

The TWIC program continues to attract Congressional attention. Section 814 allows the use of a “secondary authentication system to verify identification” when an individuals fingerprints cannot be taken or read. Section 815 requires an assessment of the adequacy of TWIC enrollment sites. Section 818 addresses the time it takes to get a TWIC issued, both allowing escorted access to individuals awaiting a TWIC to be re-issued and requiring studies about the time it takes get cards issued. And §819 allows the Secretary to extend TWIC expirations to align that expiration with “the expiration of a license, certificate of registry, or merchant mariner document”.

Again, there is nothing in the OMB announcement that would provide a clear indication which, if any of these provisions may be addressed in the proposed regulations. If, in fact, this ANPRM does address provisions of this Authorization Bill, it doesn’t explain why the Administration did not include this in their Spring Regulatory Agenda.