Will there be
a different requirement for TWIC reader use at elevated MARSEC Levels for Risk
Group A?
The Coast Guard recognizes that the system of MARSEC
Levels creates a useful mechanism for the Coast Guard to elevate security
requirements at times of heightened risk. Nonetheless, the Coast Guard uses this
mechanism in a targeted manner, and at this time, the Coast Guard does not
believe that elevated TWIC reader requirements at higher MARSEC Levels are
generally practical or appropriate. In considering the comments above, the
Coast Guard notes the change that it has made from the ANPRM to this NPRM with
respect to TWIC reader requirements. In the NPRM, the Coast Guard proposed TWIC
reader requirements for Risk Groups A and B, with stricter TWIC reader requirements for both risk groups at
higher MARSEC Levels. The ANPRM’s stricter TWIC reader requirements would have
primarily affected Risk Group B because the ANPRM proposed routine biometric scanning
with a TWIC reader for Risk Group A at all MARSEC Levels. For example, the
ANPRM would have required Risk Group B to use TWIC readers at MARSEC
Level 1 for card authentication (i.e., no routine biometric scan) and
once-monthly biometric identity verification. The ANPRM, however, would have
only required Risk Group B to regularly use TWIC readers for biometric identity
verification at higher MARSEC Levels. In this NPRM, the Coast Guard has
eliminated the proposed TWIC reader requirements for Risk Group B. The
requirements for routine biometric scanning with a TWIC reader for Risk Group A
remain the same as in the ANPRM. Note that the Coast Guard proposes increased
requirements at higher MARSEC Levels to the extent that the NPRM would require
Risk Group A to perform daily updates of CCL information at higher MARSEC Levels,
instead of the weekly updates required at MARSEC Level 1.
What types of
readers may be utilized?
The Department of Commerce’s National Institute of
Standards and Technology (NIST) and TSA are developing TWIC reader
specifications. TSA will establish a process to qualify TWIC readers, and will
maintain a Qualified Technology List (QTL) of acceptable TWIC readers. The Coast Guard anticipates that
there may be changes from the ICE Test list to the QTL list, based on final TWIC
reader specifications resulting from the QTL process.
A list of TWIC readers that have passed the Initial
Capability Evaluation (ICE) Test is available at http://www.tsa.gov/assets/pdf/twic_ice_list.pdf.
As stated in PAC–D 01–11, however, TWIC readers allowed pursuant to PAC–D
01–11 may no longer be valid after promulgation of a TWIC reader final rule,
and DHS will not fund replacement TWIC readers.
TSA is developing the QTL so that approved readers
meet durability standards. Additionally, in this NPRM, we’re proposing
requirements that provide owners and operators the flexibility to choose the
TWIC reader that best suits their operational needs.
Section 101.105, Definitions.TWIC reader means
an electronic device listed on TSA’s Qualified Technology List (QTL) and used
to verify and validate: the authenticity of a TWIC; the identity of the TWIC-holder as the
legitimate bearer of the credential; that the TWIC is not expired; and that the TWIC is
not on the CCL. TSA’s QTL of acceptable TWIC readers may be accessed online at
http://(TBD).
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