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.
Posts
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