I am Chairing the Credentialing Working Group alongside the US Coast Guard for the area comprising Sector Houston-Galveston – essentially the Greater Houston Area. Our working group is tasked with coordinating implementation of the Transportation Worker Identification Credential (TWIC) in this area (more on TWIC to follow). At this time, TWIC is officially limited to maritime facilities and vessels regulated by the Maritime Transportation Security Act of 2002 (the MTSA). We have recognized that reaching out to the various segments of the industry that might be impacted is important to insure that we do not see any commercial or operational impacts when TWIC is officially implemented in our region. I’m reaching out to your organization/agency in hopes that you can help us get the word out to your membership across the nation so that they can determine the impact of TWIC on their activities and take any action that is needed before the implementation date.
The maritime industry is the first to implement TWIC. While we do not know what the long term plan is for TWIC, we suspect that TWIC will eventually phase into other parts of the transportation infrastructure of the US. There are 2 key agencies involved in the TWIC program today – the Transportation Security Administration (TSA) is responsible for implementation, and the US Coast Guard is responsible for enforcement. The first ports go online with TWIC in late October of this year, and then subsequent ports throughout the country will go online at various times between October and the final deadline of April 15, 2009. In order for an individual to have unescorted access to the secure area of a maritime facility or US flagged vessel regulated by the MTSA after the local implementation date, the individual must have a valid TWIC. While the regulations allow escorted access for non-TWIC holders (i.e. a TWIC holder can escort a non-TWIC holder), most of industry has already indicated that they lack the resources to escort the number of personnel who might need access to the secure area of their facilities/vessels, and may not allow non-company TWIC holders to escort those who do not have a TWIC. Unfortunately, it is not possible to know whether a facility is regulated without checking with that facility – in some cases, even though the maritime portion of the facility is located far from the main production unit, the entire facility may still be classified as a secure area and require a TWIC in order for personnel to have unescorted access – so, someone from your membership/agency may not even realize that a facility has a marine area that makes them subject to TWIC until they are denied entry. The only way to be sure is to take it upon themselves to find out (many facilities/vessels are notifying the personnel visiting their locations, but if you aren’t aware of what TWIC is, you might not realize that it impacts you).
To the best of our knowledge, the companies specifically regulated by the MTSA and TWIC are fully aware of the TWIC requirements and are well on their way to getting into compliance (starting next week, we will begin periodic area-wide surveys to better assess the status of implementation in our region). It also appears that the normal contractors and suppliers to these companies have been made aware of TWIC and are also working towards compliance. Unfortunately, we are seeing a major gap in many of the companies that are not typically recognized as being involved in the industry , but who have personnel or workers that may need to enter the secure area of a regulated maritime facility. I call these "non-traditional" or "periphery" organizations since they have nothing to do with maritime activities, but they may happen to have personnel who need to enter a secure area. These workers include soda and water delivery companies, janitorial workers, truckers and rail workers, land surveyors, welders, package delivery companies, utility workers (i.e. power, water, gas, pipeline), inspection crews, municipal utility districts, lawn care personnel, and the list goes on and on. Your membership appears to fit this category of workers that may be impacted, and that’s why I’m reaching out to you today.
The TSA maintains a website with lots of information on TWIC (http://www.tsa.gov/what_we_do/layers/twic/index.shtm). Members of the Coast Guard and I, as part of our working group efforts, are also doing what we can to provide outreach to get the word out, and we would be more than happy to give a presentation on TWIC or answer any questions that you or your membership might have. We are also looking for opportunities to participate in upcoming industry conferences or meetings to help get the word out. We would appreciate any help you can give us in passing this information on to your membership and helping insure that they are ready when their respective areas implement the TWIC program should they need that. It is important to remember that this is a federal law – facilities and vessels do not have any options to waive TWIC or accept other types of credentials.
Editor’s note: I responded to Prazak’s message, saying that I wasn’t sure how many of our readers were working in ports, and here’s what he had to say:
The problem is that if they do work in secure facilities, they could be impacted starting towards the end of October, since that’s when the first ports go online. We just don’t want folks to be out of work when they can’t get into facilities as each port goes online between October and April (nor do we want to be unable to get work done ourselves). We’re just trying to raise the awareness so that folks will start asking as they show up at the plants/ports. We also want them to understand that if they are handed a TWIC flyer when they go to a port/facility, that’s a good sign that TWIC may impact them. We’re concerned that some folks get the flyer and decide it’s not applicable to them since they don’t work on the docks. In reality, the entire facility could be regulated, even pipeline corridors, so they may need a TWIC to do that work.