Friday, September 11, 2009

Review of most current TWIC PAC's

While we are on the topic of PAC documents, here is a recent TWIC PAC that is likely to affect many MTSA facilities:

PAC 06-09, issued June 9, 2009, "Escorting Requirements for Passengers Traveling With Commercial Truck Drivers." The issue at hand was, Are passengers riding with commercial truck drivers required to obtain a TWIC if they stay within the cab of the vehicle while in secure areas of a 105 facility? The answer is, Yes, if it's acceptable to the owner/operator, and if the following conditions are met:

• the passenger does not require a TWIC in their own right, per 33 CFR 101.514;
• the passenger remains within the cab of the vehicle for the duration of the time that the vehicle remains within a secure area;
• the facility owner/operator agrees to permit the trucker to escort his/her passenger;
• the passenger can present personal identification that meets the requirements of 33 CFR 101.515, unless age prevents issuance of a qualifying ID;
• there is no suspicious behavior or actions on the part of the passenger or truck driver requesting to perform escorting duties;
• the passenger’s age or presence within the secure area will not interfere with facility safety policies/procedures;
• the commercial truck driver possesses a valid TWIC and meets the minimum training requirements listed in 33 CFR 105.215 (Security training for all other vessel/facility/OCS facility personnel) and any additional training requirements established by the facility; and
• the commercial truck driver must have knowledge of the owner/operator’s escorting procedures, and the procedures and contingency plans determined by the owner/operator if an escorted individual is engaged in activities other than those for which escorted access was granted. (The owner/operator is responsible for providing this information to the truck driver by classroom-style, one-to-one briefings, or via fliers/handouts outlining the various information that the escort needs to know. For further guidance, refer to Policy Advisory Council (PAC) Decision 02-09 dated 22 JAN 09.)

This PAC reinforces the importance of facility security personnel familiarity with the ID standards of 33 CFR 101.515. It is based on the decision of the owner/operator. If the owner/operator declines to allow a TWIC-less passenger back into the secure area, this is his/her decision to make. Eventually the 104.225 and 105.215 standard for basic knowledge for TWIC escort (PAC 02-09) will be enforced on a system-wide basis.

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