PVA: TWIC Readers Not Needed in Many Cases

Monday, June 01, 2009

Security on the majority of domestic U.S.-flagged passenger vessels can be ensured without a requirement for electronic readers of crew members’ Transportation Worker Identification Credentials (TWICs), according to the Passenger Vessel Association (PVA).

PVA made this observation in comments filed on May 26 to the Coast Guard’s regulatory docket soliciting advance comments on the possibility of a rule to require TWIC readers on certain vessels and marine facilities.

Under the preliminary proposal, a TWIC reader would interact with the biometric data stored in TWICs issued to specified maritime workers to confirm the validity of the card and to verify the identity of the person using it.  In material published in the Federal Register of March 26, 2009, the Coast Guard suggested that it was considering the use of TWIC readers on a wide class of vessels and facilities, including U.S. vessels with an authorized capacity of 500 passengers or more.  The exact use of the reader would depend on what Coast Guard-declared maritime security level is in effect and what risk group the vessel is placed in.

Key points in the PVA submission to the docket include:
•    PVA supports the concept suggested by the Coast Guard that security for a domestic passenger vessel can be ensured without placing a TWIC reader on board.  PVA urged that a large percentage of U.S. passenger vessels will fit within this category.
•    Most domestic passenger vessels are operated by small businesses and small entities that would find installation of TWIC readers costly and unnecessary to ensure security.
•    With regard to domestic passenger vessel operators, a TWIC reader could be used to check the validity and status of the TWIC on a periodic basis, but it should not be considered as an “access control” device (passengers boarding vessels, as well as many crewmembers will not have TWICs).
•    The recently enacted SAFE Ports Act directs that there can be no requirement for the placement of a TWIC reader on a vessel unless it carries a designated number of TWIC holders among the crew (the Secretary of Homeland Security is to establish this number) or unless the vessel is found to be at risk of a “severe” transportation security incident.
•     When the Coast Guard proposes a TWIC reader rule, it should schedule multiple public hearings on the Atlantic, Pacific, and Gulf of Mexico coasts, in the Great Lakes region, and at a location on the inland rivers.

A copy of the PVA comment letter to the TWIC reader docket can be accessed at: www.pvastaff.com/pvamemberupdate/TWICReaderAnprm5-26-09.pdf


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