CG Seeks Comments on Voluntary TWIC Guidance for Facilities, Etc.
The Coast Guard is requesting comments by May 16, 2011 on the Policy Advisory Council (PAC) Decision1 for the voluntary use of TWIC readers. The Decision provides guidance to vessel and facility owners and operators that purchase and install Transportation Security Identification Credential (TWIC) readers and systems as part of their Vessel/Facility Security Plan.
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(TWIC is an identification credential for all personnel requiring unescorted access to secure areas of Maritime Transportation Security Act (MTSA) regulated facilities and vessels, and all mariners holding CG-issued credentials. TWIC tamper-resistant cards contain the worker's biometric (fingerprint template) and are being used by CG to check visual identity and inspect vessels and facilities using hand-held readers.
The SAFE Port Act2 of 2006 required TSA to conduct a pilot test to evaluate the impact of verifying a worker's identity by using card readers to conduct a one-to-one match of a worker's biometric to the biometric stored on the TWIC. The technical performance of readers and the operational and business impact of using readers will be evaluated by the pilot. See ITT's Online Archives or 10/19/11 news, 06101920, for BP summary.)
Operators Have Been Reluctant to Buy TWIC Equip as Pilot Not Yet Finished
The Coast Guard (CG) states that this PAC Decision facilitates the voluntary use of transportation security card readers to leverage the full security benefits of the TWIC. As the TWIC reader pilot program is still in the process of being finished, CG notes that many facility owners and operators who received grant funding have been reluctant to move forward on purchasing TWIC reader equipment.
This PAC Decision provides guidance on how vessel and facility owners and operators can use TWIC readers to meet existing regulatory requirements for effective identity verification, card validity, and card authentication.
TWIC Readers’ Fingerprint Check Same or Better than Visual ID Inspection
The current requirement for identify verification is to visually compare the photograph on the TWIC to the person at the access point. However, CG states that it with this PAC Decision, it has determined that a biometric match, using a TWIC reader3 to confirm that the biometric template stored on the TWIC matches the fingerprint of the individual presenting the TWIC, meets or exceeds the effectiveness of visual inspection.
TWIC Readers Can also be Used for Card Validity and Authentication
CG also states that a vessel or facility owner or operator may also use a TWIC reader to check for card validity by either (1) comparing the card’s internal Federal Agency Smart Card Number to the TSA Canceled Card List, or (2) using a Certificate Revocation List. An owner or operator may also perform card authentication by using a TWIC reader to perform the CHALLENGE/RESPONSE protocol using the Card Authentication Certificate and the card authentication private key on the TWIC.
Certain Readers May No Longer be Valid After Promulgation of TWIC Final Rule
CG notes that the PAC Decision states that TWIC readers used under this determination should be used in accordance with manufacturer instructions, and operated by trained personnel.
Additionally, it points out that the voluntary use of TWIC readers pursuant to this interim guidance may (or may not) be valid after promulgation of a TWIC reader final rule requiring the use of readers. Lastly, it reminds vessel and facility owners/operators using PAC Decision 01-11 that they must submit a Vessel Security Plan or Facility Security Plan amendment in accordance with applicable regulations.
1PAC Decision 01-11, "Voluntary Use of TWIC Readers."
2The Security and Accountability for Every Port Act of 2006.
3The TWIC readers must be from the TSA list of readers that have passed the Initial Capability Evaluation Test.
(See ITT's Online Archives or 01/31/07 news, 07013115, for BP summary of TSA and CG final rule to implement TWIC in the maritime sector.
See ITT's Online Archives or 03/27/09 news, 09032720, for BP summary of CG advanced notice of proposed rulemaking on TWIC reader requirements.
See ITT's Online Archives or 12/28/09 news, 09122830, for BP summary of GAO report on the challenges with the TWIC biometric reader pilot.
See ITT's Online Archives or 09/24/07 news, 07092420, for BP summary of TWIC biometric reader and smart card application specifications.)
CG Contact -- Loan O'Brien (202) 372-1133
(DN USCG-2011-0129, FR Pub. 03/15/11)
PAC Decision 01-11 is available here.
TSA list of readers that have passed the Initial Capability Evaluation Test is available here.