ILTA Presses U.S. Coast Guard to Publish Timetable for TWIC-Reader Risk Analysis
ILTA, in cooperation with both American Fuel & Petrochemical Manufacturers and the American Chemistry Council, on October 2 requested that the U.S. Coast Guard develop and publish a timetable for risk analysis on its new TWIC-reader rule.
The new TWIC-reader program has come under increased scrutiny over the past year as initial cost estimates to industry continue to escalate and ambiguity remains around the enforcement structure of the new rule.
In comments filed to a Coast Guard Information Collection Request, the associations noted several specific concerns, including a drastic surge in the number of facilities subject to the rule (from the current 500 to potentially 2,000), an increasing number of entry points subject to the rule’s biometric access control requirements (causing an increase in per-facility costs), and the projected industry-wide annual cost reaching an estimated $100 million.
Citing their previous success when working with the Homeland Security Operational Analysis Center during its earlier assessment of the risk mitigation value of the TWIC program, the associations called on USCG to organize similar meetings and onsite visits to terminal facilities so USCG and its contractors could receive more direct, detailed feedback on the implications of the new rule. The group also argued that USCG, “...should develop and publish a timetable for the risk analysis, including when it would make determinations that will affect compliance obligations...no later than May 2021. Otherwise, USCG should exercise its enforcement discretion to ensure that companies have 24 months to comply after conclusion of the risk analysis.”