Sunday, February 9, 2020

DHS Publishes TWIC Assessment 30-day ICR Notice

The Department of Homeland Security published a 30-day information collection request (ICR) notice in Monday’s Federal Register (available yesterday; 85 FR 2020-02529) for conducting a an assessment of the risk-mitigation value of the Coast Guard’s Transportation Workers Identification Credential (TWIC). This assessment was required the by Transportation Worker Identification Credential Accountability Act of 2018 (PL 115-230) and it must be completed and reported to Congress before the Coast Guard can require implementation of the TWIC Reader Rule.

There is no mention of the required 60-day ICR notice provided in this Notice. I can find no record of such a notice being posted to the Federal eRulemaking Portal ( under docket DHS-2019-0023.

There are few details about the information that will be collected as part of this assessment by the Homeland Security Operational Analysis Center (HSOAC), a federally funded research and development center operated by the RAND Corporation. The target of the ICR is broadly described as:

“Port security subject matter experts such as Port Authority Security Managers, Facility Security Managers, Industry Security Managers, and local law enforcement; Labor, Other Industry Operation and Technology Managers.”

The Notice explains that HSOAC expects to receive responses from 400 individuals/organizations during this assessment with each response taking 60 minutes. DHS does not include a copy of the questions that will be asked. That will only become available once the OMB’s Office of Information and Regulatory Affairs (OIRA) approves the ICR.

DHS is soliciting input on this ICR notice. Comments should be submitted directly to OIRA via electronic mail to Comments should be submitted by March 11th, 2020.

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