The MSIB indicates that when USCG regulations cannot reasonably be met as a result of COVID-19, the USCG will exercise flexibility to help ensure the domestic supply chain continues uninterrupted. The MSIB goes on to provide the following clarifications regarding TWIC operations at Maritime Transportation Security Act (MTSA)-regulated facilities:
- Escort Ratios – To provide flexibility due to COVID-19 related health impacts, escort ratios in Secure Areas may be adjusted to meet employee shortages or other demands. This would require a change to the FSP and/or Captain of the Port (COTP) approval.
- New Hires – After TWIC enrollment has been completed and a new hire has presented an acceptable form of identification to the Facility Security Officer, that new hire may be allowed access to an area designated as Secure and Restricted when another person is present who holds a TWIC and can provide reasonable monitoring. Side-by-side escorting required in an area designated as Secure and Restricted will not be enforced during the COVID-19 pandemic.
- Noncompliance – If a situation arises where a facility will not be able to comply with MTSA requirements, it must contact the COTP to request and receive permission to temporarily deviate from the requirements. The request to continue operations should include new measures or safeguards the facility plans to employ to mitigate any risk from non-compliance.