Roberts Law Group News

TWIC Reader Rule Update

Despite informally announcing that it intended to delay implementation of the Transportation Worker Identification Credential (TWIC) Reader Final Rule until 2021 earlier this year, the U.S. Coast Guard (USCG) is now indicating that implementation of the Rule will move forward with the original deadline of August 23, 2018. The USCG has also indicated that any compliance waivers or temporary stay requests will be handled at the Captain of the Port (COTP) level.  
While the USCG is moving forward with the TWIC Reader Rule for Certain Dangerous Cargo (CDC) facilities, it has indicated that only facilities with areas that have a CDC direct maritime nexus will be subject to the Final Rule – essentially meaning facilities that have areas where CDC flows directly to or from a marine dock.  Accordingly, the USCG appears to be backing off of the statement that “[a]ny areas where bulk CDC is transferred, passed through, or stored (permanently or temporarily) would be subject to the electronic TWIC inspection access control requirements.”

Certain USCG Sectors and Marine Safety Units have begun reaching out to regulated facilities to reengage on the TWIC Reader Rule and facility-specific CDC analyses.