Friday, March 22, 2013

More from TWIC Reader Notice of Proposed Rulemaking

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 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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