ILTA Advocates for Fair Implementation of the TWIC Reader Rule

ILTA is working to address problematic Coast Guard rulings related to initial implementation of the TWIC biometric reader rule. In many cases, Coast Guard officials are unfamiliar with the regulation, existing policy and reader rule history. This has led to fundamental misunderstandings of the compliance options available to facility operators to reduce costs and operational impacts. ILTA is concerned that facilities that have already taken action to comply with the new rule based on preliminary assurances from Coast Guard officials could be required to rework implementation plans at considerable additional costs.

The new TWIC reader rule presents expensive and impactful operational changes in how a facility that stores, transfers or processes certain dangerous cargoes implements facility access controls and measures. Compliance options, such as redesignation of TWIC areas, must continue to be available to facilities – and be acknowledged by the Coast Guard as fully consistent with the new rule.

ILTA has devoted significant time on educational outreach, including working with members and the Coast Guard to raise awareness on means to mitigate both the capital investment and recurring costs associated with the TWIC reader rule regulation.

Data Collection for Rand Study

In response to the lawsuit filed by ILTA and allied trades, the Coast Guard commissioned RAND to reexamine the costs of implementing the TWIC reader rule. RAND began work on the study last month and is seeking industry data. This is an opportunity for ILTA, and the aligned trades, to provide material support for its argument that the scope of the TWIC reader rule inappropriately exceeds the subset of facilities that it had considered when the Coast Guard conducted the original cost-benefit analysis several years ago. ILTA is conducting a survey of terminal member companies to provide anonymized data to RAND documenting the mismatch between the TWIC reader rule and the underlying analysis. 

If your company’s MTSA-regulated facilities store and transfer certain dangerous cargoes (CDCs), please participate in the ILTA member survey to collect the industry-wide data that we need to assure fair implementation of the TWIC reader rule.