DHS Issues Long-Awaited TWIC Reader Report
The maritime industry’s implementation of TWIC readers will be a lot more complicated than simply hanging some machines at the entry points of vessels and facilities regulated under the Maritime Transportation Security Act (MTSA) of 2002. That’s one thing that’s very clear from the lengthy and sometimes murky Department of Homeland Security (DHS) Final Report on the TWIC Reader Pilot Program that the Transportation Security Administration (TSA) had run in response to section 104 of the SAFE Port Act of 2006. The Report was forwarded to Congress by the DHS Secretary on February 27th.
Key aspects of the Report include:
- When designed, installed, and operated consistent with the characteristics and business needs of the facility or vessel operation, TWIC reader systems can make access decisions efficiently and effectively.
- Numerous options for validating TWIC card authenticity and verifying holder identification provided Pilot participants with flexibility to meet their business needs. Regardless of the ultimate regulatory requirements for TWIC readers, suitable options should be available for maritime operators.
- Despite challenges, the Pilot developed enough data to evaluate reader performance and assess the impact of readers on ports and maritime facilities.
- Reader robustness, quality, reliability, and performance varied. Contactless readers were preferred by Pilot participants, as contact readers were more susceptible to intrusions by water and debris.
- TWIC reader implementation will require advanced planning and attention to detail by facility and vessel operators. Installation time, effort, and cost varied widely: Times averaged from 45 days for operations using mostly portable readers; while the average time for container terminals was 180 days. Costs ran from around $15,000 for one small vessel operation to over $2.2 million for a particular container terminal.
- Except for Pilot participants that used portable readers predominately, implementation required access control systems, infrastructure upgrades, and installation, the costs of which generally far outstripped the simple cost of fixed readers.
- Portable readers offer a viable solution for operations with small TWIC holder populations and access points with minimal traffic.
- There are potential savings for operations that adopt the TWIC card as a site access, as well as an identification card, as they can eliminate the costs of operating their own badging system (which sometimes involved background checks).
- Training both security personnel and the general employee population on the operation and use of the readers will be absolutely essential.
- DHS will provide the maritime industry with lessons learned during the Pilot, which will include valuable information for maritime users regarding readers and access control systems, but there is no one-size-fits-all solution.
What’s next? In section 802(b) of the Coast Guard Authorization Act of 2010, Congress tasked the Government Accountability Office to provide the appropriate committees with an assessment of the Report, once it was submitted. While that’s being worked on, the US Coast Guard is using the information gathered during the Pilot in drafting its proposed TWIC Reader Requirements regulation to be issued later this year. For my part, I hope to examine various aspects of the Pilot Program and the Final Report in future posts. Stay tuned.
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