While the U.S. Coast Guard and the Transportation Security Administration expect mariners to comply with 33 and 46 Code of Federal Regulations, the agencies recently announced that they will “exercise flexibility” if COVID-19 makes compliance with the Transportation Worker Identification Credential unreasonably difficult to meet.
This flexibility helps to “prevent undue delays” and keep the Marine Transportation System and the flow of commerce moving amid the pandemic.
For Maritime Facilities and Vessels:
On TWIC Readers: Vessels certified to carry more than 1,000 passengers and the maritime facilities that receive those vessels must comply with the TWIC Reader Rule enacted June 7, but the Coast Guard won’t enforce the rule until Dec. 31. Facilities and vessels don’t have to update facility security plans/vessel security plans or put in readers until Dec. 31.
On the TWIC exemption: TWICs that expired between March 1, 2020, and July 31, 2020, have an exemption extension that is valid 180 days from the card’s expiration date. Email TWIC.Issue@tsa.dhs.gov for more.
On escort ratios: Escort ratios for secure and restricted areas of a facility may change to meet employee shortages or other demands due to COVID-19, constituting an adjustment to the facility security plan or approval from the Captain of the Port.
On new hires: – Generally, a new hire with proper identification can access secure or restricted areas as long as another person with a TWIC can monitor the new hire. During the pandemic, the side-by-side escorting for restricted areas mandated in 33 CFR 101.105 won’t be enforced. More new hire compliance options are available in 33 CFR 104.267 and 105.257.
On the Alternative Security Program: Those unable to comply may seek temporary relief via noncompliance or an amendment to cover the entire ASP can be submitted to CG-FAC.
Operators need to consider the safety risks of noncompliance. “This request to continue operations should include new measures or safeguards the facility or vessel plans to employ to mitigate any risk from the non-compliance with 33 CFR part 104 or 105,” according to the agency.
For Merchant Mariner Credentials:
The NSA and Coast Guard understand that the pandemic, the closure of enrollment centers and potential processing delays may affect those seeking a merchant mariner credential. During the pandemic, the Coast Guard will not suspend or revoke a merchant mariner credential for those having an expired TWIC. The Coast Guard will notify the industry before it resumes enforcement of this requirement. However, this doesn’t apply to mariners whose TWICs have been suspended or revoked because they posed a security threat.
Mariners applying for an original credential need to show that they have enrolled for a TWIC. They can pre-enroll and set up an appointment at https://universalenroll.dhs.gov or by calling 855-DHS-UES1 (855-347-8371). TWIC enrollments must be completed in-person at an enrollment center. While this is enough to start the MMC process, applicants for an original credential won’t be able to get a MMC until their biographic and biometric data is given to the Coast Guard by TSA.
For Mariners who already have a MMC, no action is needed if their TWIC expires and their credential remains valid. Mariners seeking a renewal, raise of grade, new endorsement or duplicate merchant mariner credential may apply without a valid TWIC if they can show that they have enrolled for a TWIC renewal.
Nearly all TSA Enrollment Centers are open processing new and renewing TWIC enrollments without delays. Visit https://universalenroll.dhs.gov/locator to see if a nearby center is open.
