DHS in late February submitted the long-awaited RAND report, “Results from the Assessment of the Risk Mitigation Value of the Transportation Worker Identification Credential.” This 300-page report makes several findings about applying for, the processing of and the issuance of TWICs, and on the security value of the TWIC Program. RAND found that the TWIC credentialing process operates appropriately (as far as meeting vetting standards, cost of vetting and fees, no overlap with other transportation credentials, and appropriateness of varied threat assessments and access controls). RAND also found the length of time to review a TWIC application to be acceptable.
Regarding the security value of the TWIC program, RAND claims the program addresses known and likely maritime security risks, offers the option of a non-biometric alternative, and also addresses the concerns previously raised by the Government Accountability Office and Department of Homeland Security – Office of Inspector General.
However, RAND concluded that there is a high cost-to-benefit ratio for the TWIC Reader Rule, which requires the use of biometric TWIC readers. The study found that about 1,500 facilities would be required to implement biometric TWIC readers, as opposed to the 525 estimated by the USCG.
Immediately following the submission of the RAND Report, the USCG extended the effective date of the TWIC Reader Rule by three years, to May 8, 2023. The USCG did not account for any of the new cost or impact findings provided in the RAND report and will continue to apply biometric reader requirements broadly. The Reader Rule covers facilities transferring Certain Dangerous Cargo (CDC) over their docks, facilities that handle CDC via any mode of transportation in a location of the facility where a TWIC is required, and facilities where vessels carrying CDC dock, but do not transfer that CDC.
Industry now has three years to adjust TWIC areas within their facilities, where possible, and begin to plan for access control measures that employ the biometric reader options permitted in the regulation.