Convergint is working with Maritime Transportation Security Act (MTSA)-regulated facilities to ensure compliance with the Transportation Worker Identification Credential (TWIC) Final Reader Rule (FRR) that was issued on August 23, 2016. Over the first half of 2017, the industry has pushed back from adopting these radical modifications, putting the industry and the United States Coast Guard (USCG) in divergent positions. Aspects of the TWIC Reader Final rule were unclear and the industry was not given ample opportunity to provide input when the notice of proposed rulemaking (NPRM) was open for comment.  Therefore, it is expected that the USCG will issue a NPRM by September 2017, announcing their intent to open the entire regulation for comment. It is estimated that the TWIC Reader Rule implementation day will be pushed back to August 2021.

To help navigate the complexity of this regulation and its subsequent developments, Convergint can provide ongoing TWIC regulatory compliance support for customers.

Options for Implementing a TWIC Solution

Regarding implementation options, the 2016 FRR provides additional flexibility with regards to use of electronic readers. Per the “Electronic TWIC Inspection” referenced in the 2016 TWIC FRR, all persons must pass an electronic TWIC inspection before being granted unescorted access to a secure area. As per the 2016 TWIC FRR, prior to granting access, an electronic TWIC inspection includes the following elements:

  • Card Authentication – The TWIC must be authenticated using the card authentication private key stored in the TWIC.
  • Card Validity Check – The TWIC must be checked against TSA’s list of cancelled TWICs to ensure that the TWIC has not expired or been revoked.
  • Identity Verification – The biometric template stored on the TWIC (i.e. fingerprint) must be matched to the TWIC holder’s scanned fingerprint.

Components Required for Compliance

The United States Coast Guard estimated the cost of TWIC readers at $5,375 (fixed) and $7,035 (portable). These costs only reflect the physical cost of purchasing the readers and do not reflect the costs to install. Each effected MTSA site must define next steps and consider the challenges in complying with the 2016 TWIC FRR. Facilities should consider the following:

  • What card will I utilize? TWIC or company issued prox card?
  • Where will the bio templates be stored? On the reader or on the card?
  • What infrastructure exists for the new electronic TWIC readers?
  • How does the FRR affect gates throughput following the electronic TWIC implementation? How long will bio plus proximity take? Will more gates be needed to accommodate throughput?
  • How many electronic TWIC readers will I need?

Convergint Can Help

Convergint provides strategic planning, consulting, assessment, design, integration, and services to ensure ongoing TWIC regulatory compliance for its customers. These solutions include:

  • Physical Access Control System (PACS)
  • TWIC registration engine
  • TWIC certificate manager for authenticating and integrating to the canceled card list
  • Enrollment readers
  • Fixed readers
  • Portable readers

We suggest you engage a Convergint security professional who is highly involved in the industry and engaged with the regulators to ensure all affected sites are compliant before the final reader rule compliance date.

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