Personnel surety is a key element to properly vetting people who are allowed to come onsite to a chemical facility, which is why ACC and our members were glad to see the release of two much anticipated reports examining the effectiveness of the Transportation Worker Identification Credential program.
The Congressionally mandated reports are important because they should help put the U.S. Coast Guard’s (USCG) troubled program for screening workers at chemical facilities back on track. The reports are the result of bipartisan legislation authored by Congressman Katko (R-NY), the Transportation Worker Identification Credential (TWIC) Accountability Act of 2018, which was passed to help the Coast Guard correct its course on imposing new requirements to install biometric readers for TWIC cardholders at thousands of chemical facilities.
The Act ordered the Department of Homeland Security (DHS) to complete a long overdue review of the effectiveness of the TWIC program before requiring companies to implement the Coast Guard’s 2016 TWIC reader rule.
The first report done by the RAND Corporation found that the USCG overstated the security benefits of the new biometric readers for screening personnel entering a regulated chemical facility.
The latest report was conducted by the Department of Homeland Security in the form of a Corrective Action Plan (CAP). Essentially, the purpose of the CAP is to identify actions that the Coast Guard and the Transportation Security Administration (TSA), which both operate under DHS, must take to address deficiencies identified by the RAND report.
Most importantly, the CAP directs the USCG to conduct a risk analysis to properly identify which facilities need to install TWIC card readers for screening people entering secure areas. It also calls on the USCG and the TSA to develop an education and outreach plan to clear up confusion within the regulated community about their requirements. Finally, the report instructs the USCG to review all existing instructions, policies, and procedures related to the TWIC program to determine the need for updates and clarification.
Combined with the three year delay provided by the TWIC Accountability Act, both of these reports should give the TSA and the USCG the necessary time and direction to fix the issues with the TWIC program and the reader rule.
While we have been disappointed in the USCG’s unwillingness to constructively engage with the regulated community in the past, we are ready and willing to help the Coast Guard work through the issues raised in these reports so we can put a strong and effective screening program in place that will help protect chemical facilities.