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NVIC 03-07
NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 03-07
Subj: GUIDANCE FOR THE IMPLEMENTATION OF THE TRANSPORTATION WORKER
IDENTIFICATION CREDENTIAL (TWIC) PROGRAM IN THE MARITIME SECTOR
Ref: a. Title 33 of the Code of Federal Regulations (33 CFR) Parts 101-106
b. Title 49 of the Code of Federal Regulations (49 CFR) Part 1515, 1540, 1570, and 1572
c. NVIC 03-03 Change 1 – Implementation of MTSA Regulations for Facilities
d. NVIC 04-03 Change 2 – Verification of Vessel Security Plans for domestic vessels in
accordance with MTSA Regulations and ISPS Code
e. NVIC 05-03 – Implementation of MTSA Regulations for Outer Continental Shelf
Facilities
1. PURPOSE. This Navigation and Inspection Circular (NVIC) provides guidance on implementation
of the Final Rule – Transportation Worker Identification Credential Implementation in the Maritime
Sector; Hazardous Material Endorsement for a Commercial Driver’s License (72 FR 3492) (referred
to as the TWIC rule) - which made major changes to 33 CFR Chapter I Subchapter H, 46 CFR
Chapter I Subchapter B, and 49 CFR Chapter XII Subchapter D. The Transportation Worker
Identification Credential (TWIC) will satisfy the requirement for a biometric credential as mandated
by 46 U.S.C. § 70105, which was enacted by the Maritime Transportation Security Act of 2002
(MTSA) and then amended by the Security and Accountability For Every (SAFE) Port Act of 2006.
The information in this NVIC details the enrollment and issuance process, provides guidance for
successful execution of compliance requirements, provides clarification of the regulations found in
references (a) and (b), and includes a more detailed discussion of the actions required by those
regulations, with examples, to increase understanding and promote nationwide consistency. These
guidelines are intended to help industry comply with the new regulations and the Coast Guard
Captains of the Port (COTP) implement the TWIC Program.
2. ACTION.
a. The following individuals must obtain a TWIC (as stated in 46 U.S.C. § 70105):
Commandant
United States Coast Guard
2100 Second Street, S.W.
Washington, DC 20593-0001
Staff Symbol: CG-3PCP
Phone: (202) 372-1092
Fax: (202) 372-1906
2
1) All credentialed U.S. merchant mariners with active credentials (hereafter referred to as
mariners). This includes all persons holding a Coast Guard-issued Merchant Mariner
License, Merchant Mariner Document, or Certificate of Registry;
2) Anyone allowed unescorted access to secure areas of U.S.-flagged vessels, facilities, and
Outer Continental Shelf (OCS) facilities subject to 33 CFR Parts 104, 105, and 106
respectively (hereafter referred to as vessels and facilities);
3) A vessel pilot;1
4) All individuals working aboard towing vessels that push, pull or haul alongside tank
vessels.2
b. Vessel and facility owners/operators, mariners, and maritime transportation workers are
encouraged to use this circular as guidance for the enrollment and receipt of TWICs.
c. Vessel and facility owners/operators are also encouraged to use this guidance to assist in
ensuring that they meet TWIC Program requirements. These include but are not limited to:
informing personnel of TWIC responsibilities, escorting procedures, and management of access
control. This guidance will also assist in preparation for annual Coast Guard compliance
inspections and spot checks of their vessels and facilities.
d. COTPs shall use this guidance in addition to Coast Guard internal direction to assist industry in
implementing the TWIC Program and preparing for annual compliance inspections and spot
checks of vessels and facilities.
e. COTPs are encouraged to bring this circular to the attention of maritime transportation interests
within their COTP zones. This circular will be distributed by electronic means only. It is
available on the World Wide Web at
http://www.uscg.mil/hq/g-m/nvic/index00.htm.
f. The Marine Safety Center, COTPs, and district offices can use this guidance to review Vessel
Security Plan (VSP) and Facility Security Plan (FSP) submissions. Though no vessels are
required to submit amendments to their VSP by the TWIC rule, some may choose to do so as
allowed by reference (a). The only facilities that are required to submit an amendment to their
1 Note: This population is incorporated into the requirement for all credentialed U.S. Merchant Mariners to possess a TWIC and is not
specifically addressed in the regulatory text of the TWIC final rule. At this time, we have not extended this requirement to address the
issue of non-Federal pilots (those few pilots holding only state commissions or credentials, who do not also hold a Federally-issued
merchant mariner license or document). The requirements of 46 U.S.C. 70105(b)(2)(C) [all vessel pilots] will be further addressed in a
future notice and comment rulemaking.
2 Note: This population is incorporated into the requirement for all vessels subject to 33 CFR Part 104 to comply with TWIC and is not
specifically addressed in the regulatory text of the TWIC final rule. At this time, we have not extended this requirement to address the
issue of all individuals working aboard non-Subchapter H regulated towing vessels that push, pull or haul alongside tank vessels (towing
vessels less than or equal to eight meters in registered length and some larger towing vessels that meet the exemptions listed in 33 CFR
104.105). The requirements of 46 U.S.C. 70105(b)(2)(D) [all towing vessels] will be further addressed in a future notice and comment
rulemaking.
Navigation and Vessel Inspection Circular 03-07
3
FSP are those that have a significant non-maritime transportation portion and voluntarily desire
to redefine their secure area.
3. DIRECTIVES AFFECTED. This NVIC provides the guidance needed to implement the new TWIC
Program. The information contained herein supplements the guidance contained in previously
issued MTSA NVICs and will be incorporated into references (c), (d), and (e) in the future.
4. BACKGROUND.
a. 46 U.S.C. § 70105, which was enacted by the MTSA, requires the Secretary of DHS to
promulgate regulations to prevent an individual from gaining access to a secure area of a vessel
or facility which has a security plan unless he/she is authorized to be in the area and holds a
“transportation security card” or he/she is “accompanied by another individual who holds a
transportation security card.” The law further states who must comply (as listed in Action
above), that the individual must be determined not to pose a terrorism security risk, and general
requirements for how the terrorism security risk determination must be made. The TWIC
regulations were developed from this law.
b. The TWIC rule, which amended the regulations found in references (a) and (b), requires
standardized identification procedures for personnel needing unescorted access to secure areas of
facilities and vessels in order to reduce risk and mitigate the effects of a transportation security
incident (TSI). This is a joint rulemaking with the Transportation Security Administration (TSA)
and the Coast Guard. Reference (a) includes the Coast Guard portions of the TWIC rule and
reference (b) includes the TSA portions of the rule.
c. The TWIC Program aims to ensure that only persons who successfully undergo a security threat
assessment are able to receive a TWIC. The credential will include a reference biometric -
fingerprint template that positively links the credential holder to the identity of the individual to
whom the credential was issued. TWIC holders will be required to choose and remember a
Personal Identification Number (PIN). TWIC holders will be asked by a vessel or facility
owner/operator to produce the TWIC before being granted unescorted access or during Coast
Guard inspections or spot checks. In addition, an individual’s credential can be revoked by TSA
if disqualifying information is discovered by, or presented to, TSA or if the credential is lost,
stolen, or damaged. Once revoked, the credential should not be used to obtain unescorted access
to secure areas. While an owner/operator is not currently required to verify if a TWIC is
revoked, if he/she has knowledge that a TWIC is revoked, that TWIC cannot be accepted for
unescorted access. TSA has designed the TWIC process to maintain strict privacy controls so
that a holder’s biographic and biometric information are securely protected.
d. The Coast Guard and TSA are currently conducting screening of facility employees and
longshoremen, known as the interim vetting program, pursuant to a Federal Register Notice on
April 28, 2006. For this program, facility operators and longshore unions have submitted names
of employees and long-term contractors for vetting through select Federal databases. We
anticipate that this requirement will continue to be in force until TWIC initial enrollment has
been completed. A Federal Register notice will be published when this program is cancelled.
4
5. DISCUSSION.
a. Vessels and facilities must be in compliance with the TWIC regulations as discussed in
paragraphs 6 b., c., and d. below, but in no case later than September 25, 2008, , which is 20
months after the publication date of the final rule. A detailed implementation plan is contained in
Enclosure (5) to this NVIC.
b. The regulations implementing TWIC require that the TWIC be used initially as a visual
identification badge. This means that for normal use at a vessel or facility, the holder’s facial
features will be compared to the photo imprinted on the card, the expiration date will be checked,
and the unique identifying surface features of the card will be examined for signs of tampering to
identify fraudulent or altered cards. This type of use is more commonly known as a “flash pass”,
and is the method that is currently used for checking identification as required by reference (a).
During Coast Guard inspections and spot checks, handheld biometric readers will be used to
electronically verify that the card is valid (e.g. has not been revoked) and to match the individual
to the biometric template stored on the card.
c. Possession of a TWIC is required for an individual to be eligible for unescorted access to secure
areas of vessels and facilities. The term “secure area” is defined as “the area over which the
owner/operator has implemented security measures for access control in accordance with their
security plan.” The terms “secure area” and “restricted area” have different definitions and
purposes. Regulations at 33 CFR 101.105 define restricted area as “a location requiring a higher
degree of security protection” which is used in a number of regulatory requirements. A secure
area covers a broader space encompassing restricted areas and includes everything within an
access control boundary, as defined in existing security plans. For vessels, the secure area
encompasses the entire vessel, with a few exceptions such as passenger access areas and
employee access areas. For facilities, the secure area encompasses the entire facility footprint as
described in their currently approved facility security plan, with the exception of public access
areas and those facilities with significant non-maritime transportation portions who submit an
amendment to redefine their secure area. All of these provisions are explained in Enclosure (3)
(section 3.3 b).
d. An individual with a TWIC who is authorized to be in a secure area by the vessel or facility
owner/operator is not required to be escorted. An individual who does not have a TWIC must be
escorted. Individuals covered under the new hire provision must be accompanied, as opposed to
escorted, as explained in Enclosure (3) (section 3.3 h (3)(d)).
e. Company, vessel, and facility security officers and company, vessel, and facility personnel
responsible for security duties are required by regulation to obtain a TWIC. We expect that
individuals who frequently access secure areas in the course of their employment will obtain
TWICs. These populations include: non-credentialed mariners in vessel crew; longshoremen;
drayage truckers; facility employees who work in a secure area; truckers bringing cargo onto a
facility or picking up cargo at a facility; surveyors; agents; chandlers; port chaplains; and other
maritime professionals. This list is not exhaustive and other populations may be included.
Casual laborers who frequently access secure areas in the course of their employment would also
be expected to obtain a TWIC. Casual laborers who only occasionally access secure areas and
Navigation and Vessel Inspection Circular 03-07
5
therefore do not have a TWIC would need to be escorted. Additional details are provided in
Enclosure (2) (section 2.1).
f. Escort requirements differ within secure areas depending on whether the area is also a restricted
area or not. An individual not in possession of a TWIC who is authorized escorted access to a
restricted area requires physical, side-by-side accompaniment by a TWIC holder. An individual
not in possession of a TWIC who is authorized escorted access by the vessel or facility owner or
operator to a secure area that is not also a restricted area requires monitoring in a manner
sufficient to identify whether the individual is engaged in activities other than those for which
escorted access was granted and that allows for quick response. Additional details are provided
in Enclosure (3) (section 3.3 c).
g. Newly hired employees (new hires) are able to gain accompanied access to secure areas for up to
30 consecutive days while awaiting issuance of their TWIC, with an additional 30 days at COTP
discretion. Owners/operators must complete additional steps before new hires may be granted
accompanied access. Additional details on this provision are provided in Enclosure (3) (section
3.3 h(1)).
h. Two non-secure areas have been carved out of the secure area for vessels: the passenger access
area and the employee access area. Within these areas, individuals will not be required to
possess a TWIC to be eligible for unescorted access. The rest of the vessel remains a secure area
for which a TWIC is required for unescorted access. Additional details are provided in
Enclosure (3) (section 3.5 b).
i. The TWIC may be incorporated into existing physical access control systems. If this is done
individuals must still always have their TWIC in their possession or readily available and the
existing systems should be updated so that they deny access when the TWIC expires or if the
TWIC holder no longer requires unescorted access to a secure area. Additional details on this
provision are provided in Enclosure (3) (section3.3 f).
j. Amplification of the knowledge requirements for Company, Vessel, and Facility Security
Officers, for personnel with security duties, and for all other personnel is provided in Enclosure
(3) (section 3.3 g).
k. If an individual’s TWIC is lost, stolen, or damaged, unescorted access to secure areas may be
granted for seven consecutive calendar days while the individual awaits a replacement.
Additional steps must be completed by both the individual and the Company Security Officer
(CSO), Vessel Security Officer (VSO), or Facility Security Officer (FSO). These additional
details are provided in Enclosure (3) (section 3.3 h (2)).
l. All vessel personnel may apply for a TWIC at any enrollment center at any time during the 18
month implementation period, but they all must obtain a TWIC to be eligible for unescorted
access to secure areas by September 25, 2008. Until this date, all mariners will be eligible for
unescorted access to secure areas of facilities by providing alternative identification, in lieu of a
TWIC. The list of alternative identifications and additional details on this provision are provided
in Enclosure (3) (section 3.3 h (3)).
6
m. Area Maritime Security (AMS) Committee members are not required to obtain a TWIC.
However, if they have access to Sensitive Security Information (SSI), they will be required to
undergo name-based security checks if they do not already possess a TWIC. Additional details
are provided in Enclosure (3) (section 3.3 i).
n. Owners or operators of facilities containing both a maritime transportation portion and a nonmaritime
transportation portion, such as areas devoted to manufacturing or refining operations,
may voluntarily request a redefinition of their secure area through an amendment to their FSP.
COTPs will review and approve these amendments, as appropriate. Additional details on this
option are provided in Enclosure (3) (section 3.4).
o. The preamble to the TWIC rule provides additional information regarding the intent of the
regulations and is available on the Coast Guard’s Homeport website under the
Missions/Maritime Security/TWIC heading at
http://homeport.uscg.mil.
6. IMPLEMENTATION.
a. Enrollment and issuance of the TWIC will be carried out by TSA. Enforcement of the TWIC as
an access control measure in the maritime sector will be carried out by the Coast Guard. TWIC
enrollment will begin in selected ports and will expand nationwide to provide ample opportunity
for individuals to apply for and receive their TWIC. The requirement to use the TWIC as an
access control credential will be based on location and type of operation as explained below.
b. Compliance with this rule for facilities will be phased in by COTP zone in accordance with the
following process:
(1) A notice will be published in the Federal Register to announce when enrollment begins in
each COTP zone.
(2) A notice of the compliance date for each COTP zone will be published in the Federal
Register. Each notice will be published at least 90 days in advance of the compliance date
for its respective COTP zone. In addition, COTPs and the TWIC enrollment contractor will
work with port stakeholders to provide notice of the compliance date. This notice may be
published in conjunction with the notice which announces the beginning of enrollment.
(3) The published compliance date will be the day that all facilities within the specific COTP
zone must be in compliance with the requirements in the TWIC rule. It is also the day that
Coast Guard enforcement within that COTP zone may begin. In no case will the compliance
date be later than September 25, 2008 in any COTP zone.
(4) A rollout plan, describing implementation across all COTP zones, is provided in Enclosure
(5).
(5) The Coast Guard and TSA will also work with AMS Committees and other local forums to
communicate compliance dates, enrollment center locations, and other vital information to
maximize the availability of this information to stakeholders.
Navigation and Vessel Inspection Circular 03-07
7
c. Compliance for OCS facilities is no later than September 25, 2008. Federal Register notices for
enrollment dates will be published for port areas as described above. OCS facility employees
requiring TWICs should apply while centers are open in their local areas, despite the later
compliance date.
d. Compliance with this rule for vessels is no later than September 25, 2008. On this date, all
individuals must present a TWIC to be eligible for unescorted access to secure areas of vessels.
e. Also by September 25, 2008, all mariners will be required to hold a TWIC in order for their
license, MMD, COR, or STCW endorsement to remain valid. Until then, if the vessel or facility
has started TWIC compliance and enforcement, mariners may present an alternate identification
to be eligible for unescorted access to secure areas of the vessel or facility. Alternative mariner
identifications are listed along with additional details in Enclosure (3) (section 3.3 h (3)).
f. A vessel or facility not implementing a TWIC Program after the published compliance dates is
subject to civil penalty action and may be subject to additional control and compliance measures,
including suspension of facility or vessel operations [see Enclosure (4)].
g. Enclosure (1) is a TSA flowchart of the TWIC enrollment and issuance process.
h. Enclosure (2) is a TSA publication that provides more detail and guidance for the enrollment and
issuance process.
i. Enclosure (3) provides guidance on facility and vessel implementation.
j. Enclosure (4) provides guidance on enforcement of the TWIC requirements.
k. Enclosure (5) is the implementation schedule for enrollment nationwide.
7. INFORMATION SECURITY. TWIC credentials and associated databases contain sensitive
personal information that, if released to the general public or improperly accessed or used by
personnel executing their official duties, could compromise the privacy of an individual. This
information shall be protected under the requirements of the Privacy Act, 5 U.S.C. 552a.
8. DISCLAIMER. While the guidance contained in this document may assist the industry, the public,
the Coast Guard, and other Federal and State agencies in understanding the TWIC statutory and
regulatory requirements, this guidance is not a substitute for the applicable legal requirements, nor is
it in itself a regulation. It is not intended to, nor does it impose legally binding requirements on any
party, including the Coast Guard, other Federal agencies, the States, or the regulated community.
9. CHANGES. This NVIC will be posted on the web at
www.uscg.mil/hq/g-m/nvic/index00.htm and
Homeport at
http://homeport.uscg.mil. Changes to this circular will be issued as necessary. Timesensitive
amendments will be issued as “urgent change” messages to COTPs and posted on the
website for the benefit of industry, pending their inclusion in the next change to this circular.
8
Suggestions for improvement of this circular should be submitted in writing to Commandant
(CG-3PC).
10. FORMS AND REPORTS. None.
Encl: (1) TWIC Enrollment and Issuance Process Flowchart
(2) Enrollment and Issuance Process Description
(3) TWIC Program Implementation for Vessels and Facilities
(4) Enforcement Guidance
(5) Implementation Schedule
Enclosure (1) to Navigation and Vessel Inspection Circular 03-07
1
U.S. Department of Homeland Security
Arlington, VA 22202
STA results
returned to TSA
4 TSA receives and
transmits data to
government
agencies to conduct
STA. (49 CFR
1572.21)
USCIS
FBI
TSA
4b Criminal History
Records Check
(49 CFR 1572.21 &
1572. 103)
4c Immigration
Status Check
(49 CFR 1572.105)
4a Terrorism /
Intelligence Check
(49 CFR 1572.21)
Enrollment
information sent to
TSA
5 TSA
adjudicates
results of
STA.
7a Applicant retrieves
TWIC at enrollment
center.
1 Federal Register Notice
and COTP inform
owners/operators of start
date of enrollment before
it begins.
2 Owners/operators
instruct transportation
workers (applicants)
where and when to
enroll. (33 CFR
104.200, 105.200, &
106.200)
2a Applicants may
pre-enroll (optional
online submission
of biographic
information).
3 Applicants must submit
biographic and biometric
information at TWIC enrollment
center & pay user fee. (33 CFR
101.514, 49 CFR 1572.17) Note:
When required, enrollment
information to be shared with Coast
Guard in order to complete MML,
MMD, Certificates of Registry, and
SCTW endorsement, and MMC (if
Coast Guard begins to issue them)
2b Applicants may
apply for a waiver
from certain
disqualifying
standards. (49 CFR
1515.7)
6a Determination
of No Security
Threat
(49 CFR 1572.21)
6b Initial
Determination of
Security Threat
(49 CFR 1572.21)
6c Initial
Determination of
Security Threat &
Immediate
Revocation. This is
relayed only to
applicants with an
existing TWIC and
where there is an
imminent threat.
(49 CFR 1572.21)
6d Final Determination of Security Threat and applicant denied TWIC.
(49 CFR 1572.21)
Note: Final Determination is made if the applicant does not take action on the
Initial Determination of Security Threat within 60 days of receipt, or if it is
determined that the applicant does not meet the TWIC standards within 60
days of an applicant supplying the required information for an appeal .
8 If an appeal or
waiver is
initiated, TSA
reviews relevant
material
submitted by
applicant and
makes final
decision.
(49 CFR 1515.5
& 1515.7)
TSA informs
applicant of 1 of 4
STA results:
7b(i) Applicant may
appeal determination or
ask for a waiver within
60 days of
determination.
(49 CFR 1515.5 &
7b(ii) If no appeal or
waiver is filed within
60 days, determination
becomes final and
applicant denied TWIC.
7c(i) Applicant may
appeal determination or
ask for a waiver within
60 days of
determination.
(49 CFR 1515.5 &
1515.9)
7c(ii) If no appeal or waiver is
filed within 60 days,
determination becomes final
& applicant denied TWIC.
9a If appeal or
waiver is
granted,
applicant
retrieves TWIC
at enrollment
center.
9b If appeal or
waiver is
denied,
applicant
denied TWIC.
(49 CFR 1515.5
& 1515.9)
1. Enrollment (this includes
pre-enrollment and fee collection)
2. Security Threat Assessment (STA) 3. Notification of Results, Issuance, Appeals & Waivers
10 Applicant
may seek
review by an
Administrative
Law Judge if
TSA denies
waiver or
appeal request
under 49 CFR
1572.107.
(49 CFR
1515.11)
Time
Note: If applicant is
using a comparable
background assessment,
complete steps 1
through 3, information
will be sent to TSA, and
then go to step 7a.
TWIC Enrollment and Issuance Process Flowchart
This diagram depicts the process of applying for and obtaining a TWIC. More information is available by viewing the references to the Code
of Federal Regulations (CFR) sections included in each box. Further clarification is also provided in Enclosure (2) of this Navigation and
Vessel Inspection Circular. Other information is available at
http://www.tsa.gov/twic and
http://homeport.uscg.mil.
This page intentionally left blank
Enclosure (2) to Navigation and Inspection Circular 03-07
i
Table of Contents
Enclosure (2) – Enrollment and Issuance Process Description Page
2.1 Who must get a TWIC? .................................................. .................................................. .......1
2.2 Who can apply for a TWIC?............................................. .................................................. ....1
2.3 What happens to my TWIC when my lawful nonimmigrant status expires? .........................2
2.4 What can disqualify me from getting a TWIC?............................................. .........................2
2.5 What if TSA determines that I do not meet the qualification standards?...............................3
2.6 TWIC Enrollment .................................................. .................................................. ...............3
Employee Notification Requirement .................................................. ........................................ 3
Location and Timing............................................ .................................................. ..................... 4
Enrollment Process .................................................. .................................................. ................. 4
(1) Pre-Enrollment .................................................. .................................................. ............. 4
(2) Enrollment........................................ .................................................. ............................. 5
(3) Fee Collection .................................................. .................................................. .............. 7
(4) Security Threat Assessment and Notification .................................................. ................ 8
(5) TWIC Issuance.......................................... .................................................. ..................... 8
2.7 Waivers and Appeals .................................................. .................................................. .........9
Waivers .................................................. .................................................. ............................... 9
Appeals .................................................. .................................................. ............................. 10
2.8 Privacy and Information Security.......................................... ..............................................10
2.9 TWIC Help Desk .................................................. .................................................. .............10
2.10 TWIC Renewal .................................................. .................................................. ................11
2.11 Lost, Stolen, or Damaged TWICs............................................. ...........................................11
This page intentionally left blank
Enclosure (2) to Navigation and Inspection Circular 03-07
1
U.S. Department of Homeland Security
Arlington, VA 22202
Enrollment and Issuance Process Description
2.1 Who must get a TWIC?
All mariners and individuals who will need unescorted access to secure areas of a vessel or
facility will need to obtain a TWIC. Vessel or facility owners/operators determine who
will need unescorted access to the secure area(s) of their vessel or facility.
Owners/operators can require escorted access of a TWIC holder if they choose to do so.
Possession of a TWIC does not guarantee unescorted access to secure areas;
permission must be granted by the vessel or facility owner/operator. We expect that
the following communities will need frequent access to secure areas in the course of their
employment and will obtain TWICs (this list is not exhaustive, but is illustrative of those
who will likely need a TWIC):
- Vessel crew (in addition to credentialed mariners).
- Longshoremen.
- Drayage truckers.
- Facility employees if working in a secure area.
- Truckers bringing cargo onto a facility or picking up cargo at a facility.
- Surveyors.
- Agents.
- Chandlers.
- Port Chaplains.
- Casual laborers who frequently access secure areas.
- Other maritime professionals.
Company, vessel, and facility security officers and company, vessel, and facility personnel
responsible for security duties are required by regulation to obtain a TWIC.
Personnel responsible for security duties include individuals whose fundamental
responsibilities focus on security of the vessel or facility. These positions include security
guards, baggage screeners, and persons making access control decisions as a primary duty.
While recognizing that security is everyone’s duty, it does not include individuals who
perform security duties as an occasional task or as a collateral duty.
2.2 Who can apply for a TWIC?
The following individuals are eligible to apply for a TWIC per 49 CFR 1572.105:
a. A national (includes citizen) of the United States.
b. A lawful permanent resident of the United States.
c. A refugee admitted under 8 U.S.C. 1157.
d. An alien granted asylum under 8 U.S.C. 1158.
e. An alien in valid M-1 nonimmigrant status who is enrolled in the United States
Merchant Marine Academy or a comparable State maritime academy. Such individuals
Enclosure (2) to Navigation and Inspection Circular 03-07
2
may serve as unlicensed mariners on a documented vessel, regardless of their
nationality, under 46 U.S.C. 8103.
f. A nonimmigrant alien admitted under the Compact of Free Association between the
United States and the Federated States of Micronesia, the United States and the
Republic of the Marshall Islands, or the United States and Palau.
g. A commercial driver licensed in Canada or Mexico who is admitted to the United
States under 8 CFR 214.2(b)(4)(i)(E) to conduct business in the United States.
h. An alien in lawful nonimmigrant status who has unrestricted authorization to work in
the United States, except—
(1) An alien in valid S-5 (informant of criminal organization information) lawful
nonimmigrant status;
(2) An alien in valid S-6 (informant of terrorism information) lawful nonimmigrant
status;
(3) An alien in valid K-1 (Fiancé(e)) lawful nonimmigrant status; or
(4) An alien in valid K-2 (Minor child of Fiancé(e)) lawful nonimmigrant status.
i. An alien in the following lawful nonimmigrant status who has restricted
authorization to work in the United States—
(1) H-1B Special Occupations;
(2) H-1B1 Free Trade Agreement;
(3) E-1 Treaty Trader;
(4) E-3 Australian in Specialty Occupation;
(5) L-1 Intracompany Executive Transfer;
(6) O-1 Extraordinary Ability;
(7) TN North American Free Trade Agreement;
(8) C-1/D, Crew Visas.
2.3 What happens to my TWIC when my lawful nonimmigrant status expires?
The applicant must report the disqualifying condition to TSA and surrender the TWIC.
In addition, the TWIC becomes invalid.
If the applicant is in one of the permissible visa categories listed in 2.2(i), and the
employment for which the visa was granted ends:
• the employer retrieves the TWIC from the applicant and provides it to TSA,
• the applicant surrenders the TWIC to the employer, or
• if an employer terminates an applicant working under a nonimmigrant status listed in
paragraph 2.2(i), or the applicant otherwise ceases working for the employer, the
employer must notify TSA within 5 business days and provide the TWIC to TSA if
possible.
2.4 What can disqualify me from getting a TWIC?
• Criminal – an individual is wanted for any crime, under indictment for one of the
disqualifying felonies listed in 49 CFR 1572.103, or has been convicted or
incarcerated for those disqualifying felonies within prescribed time periods.
• Immigration – an individual does not meet the immigration status requirements listed
in 49 CFR 1572.105.
• Security threat – an individual is identified as having a connection to terrorist activity.
Enclosure (2) to Navigation and Inspection Circular 03-07
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• Mental incapacity – an individual is or has been determined to lack mental capacity as
defined in 49 CFR 1572.109.
2.5 What if TSA determines that I do not meet the qualification standards?
• All applicants have the opportunity to appeal an Initial Determination TSA makes
that an applicant does not meet the standards. TSA provides applicants the reason for
the Initial Determination and instructions on how to apply for an appeal. Typical
reasons for an appeal would be ‘my conviction was later expunged,’ or ‘you have the
wrong John Smith.’
What if I know I do not meet the qualification standards?
• If an applicant knows that he or she does not meet the standards concerning criminal
activity or mental capacity, or is in Temporary Protected Status at the time of
enrollment, the applicant should annotate by initialing they are applying for a waiver
on the ‘TWIC Application Disclosure Form.’ If the applicant becomes aware that he
or she does not meet the standards concerning criminal activity or mental capacity
when TSA issues an Initial Determination, the applicant may apply for a waiver at
that time as well.
2.6 TWIC Enrollment
Employee Notification Requirement
• Facility and vessel owners/operators, under 33 CFR 104.200, 105.200, and 106.200,
are required to inform facility and vessel employees of their responsibility to possess
a TWIC and what parts of the facility and vessel are secure areas, passenger access
areas, employee access areas, and public access areas. The intent of this requirement
is for owners/operators to determine which of their employees will need a TWIC and
inform those employees in enough time for them to comply with the requirements.
Owners/operators are also encouraged, but not required, to provide this same
information to personnel who are not facility or vessel employees, e.g. contractors.
• Notification should assist the employee in determining the following:
- his/her responsibility to possess a TWIC;
- if he/she will need unescorted access to a secure area;
- what parts of the facility or vessel are secure, public, employee, or passenger
access areas;
- when compliance will begin in his/her COTP zone; and
- locations of enrollment centers where he/she can apply for his/her TWIC.
• Some acceptable forms of notification include the following examples:
- Signs posted in common areas;
- Company newsletters;
- Announcements by company officials;
- Company website; and
- Inserts in wage and salary statements or other payroll documents.
Enclosure (2) to Navigation and Inspection Circular 03-07
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Location and Timing
• Approximately 130 ports have been identified for enrollment sites. TSA will use a
combination of fixed and mobile enrollment stations to make the enrollment process
as efficient as possible for applicants and owners or operators. The TSA enrollment
contractor is responsible for identifying the specific enrollment sites. The enrollment
locations and directions to these sites will be available on the TWIC website at
www.tsa.gov/twic, and there will be a link provided on the Coast Guard’s Homeport
site to this information as well (
http://homeport.uscg.mil).
• TSA and Coast Guard will work closely with the maritime industry to ensure that
owners or operators and applicants are given as much notice as is possible of the
commencement of enrollment at their location. See Enclosure (3) (section 3.2) for
more details.
Enrollment Process
• The enrollment process consists of 5 components: pre-enrollment (optional),
enrollment, fee collection, security threat assessment and notification of the results,
and issuance of the TWIC to the applicant. The time from enrollment to credential
availability is expected to take less than 30 days, not including potential appeal or
waiver processing. If the security threat assessment does not reveal any questionable
or negative information about an individual, the process is expected to take less than
10 days.
(1) Pre-Enrollment
• Applicants are encouraged, but not required, to “pre-enroll” online at
www.tsa.gov/twic. The pre-enrollment process allows applicants to provide much of
the biographic information required for enrollment over a secure site; to select an
enrollment center where they wish to complete enrollment; and to make an
appointment to complete enrollment at the enrollment center of their choosing.
• The benefits of pre-enrollment include:
- May reduce the time needed to complete the entire enrollment process at an
enrollment center.
- Allows applicants to provide much of the biographic information required for
enrollment from home or another convenient location.
- Provides the list of documents to bring to the enrollment center for identity
verification and other purposes. This list is also available on the TSA/TWIC
website, but consolidating it with the pre-enrollment documents should make the
process more efficient applicants.
- Allows the applicant to become familiar with the disclosure form, which should
be signed at the beginning of the enrollment process, in the presence of the
Trusted Agent at the enrollment center.
- Provides the enrollment site locations and hours of operation. This list is also
available on the TSA/TWIC website, but consolidating it with the pre-enrollment
documents should make the process more efficient applicants.
- Provides applicants the opportunity to make an appointment at an enrollment
center. Although applicants may schedule an appointment to complete enrollment
at an enrollment center, appointments are not required.
Enclosure (2) to Navigation and Inspection Circular 03-07
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• Applicants may pre-enroll from any computer with access to the World Wide Web.
The web site for pre-enrollment and additional information relating to the TWIC
program will be available from
www.tsa.gov/twic. This web site also will list the
documents the applicant must bring to the enrollment center to verify identity and for
other purposes so that all applicants can be properly prepared.
• A unique registration number will be assigned to an applicant when they pre-enroll.
At the end of the pre-enrollment process, the applicant will be instructed to print out a
page with their registration number (it is displayed as a bar code) or to write down
their registration number if they do not have access to a printer. This page will also
include information on the applicant’s enrollment appointment, if selected. Note:
other methods will exist for retrieving the pre-enrollment data if an individual does
not have their registration number with them at the time of enrollment.
(2) Enrollment
• During enrollment, applicants will be required to visit the enrollment center to
provide biographic information and a complete set of fingerprints, sit for a digital
photograph, and pay the enrollment fee. As stated above, if the applicant pre-enrolls,
they are asked to bring their registration number by either printing out the page
identifying it during the pre-enrollment process or by writing it down.
• Regardless of whether the applicant pre-enrolls, the applicant must bring identity
verification documents and in the case of aliens, immigration documents to the
enrollment center so that they can be scanned into the electronic enrollment record.
The list of required documents an applicant must present will be posted on the TWIC
website at
www.tsa.gov/twic, but is also listed here. Applicants provide either one
document from List A or two documents from List B, one of which must be a
government-issued photo ID.
List A
• Unexpired Passport
• Unexpired Permanent Resident card or Unexpired Alien Registration
Receipt Card with photograph
• Unexpired Foreign passport with one of the following:
?? I-551 Stamp
?? Attached INS Form I-94 indicating unexpired employment authorization
?? Unexpired employment Authorization Document (I-766)
?? Unexpired Employment Authorization Card (INS-688B)
?? Unexpired Visas: E-1, E-2, E-3, H-1B, H-1B1, L-1, O-1, TN, M-1, C-
1/D
• Unexpired Free and Secure Trade (FAST) Card
• Unexpired Merchant Mariner Document (MMD)
List B (need two and one must be a government-issued photo ID)
• U.S. Certificate of Citizenship (N-560,561)
• U.S. Certificate of Naturalization (N-550 or 570)
• Driver’s license or ID card issued by a state or outlying possession of the
United States
Enclosure (2) to Navigation and Inspection Circular 03-07
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• Original or certified copy of birth certificate issued by a state, county,
municipal authority, or outlying possession of the United States bearing an
official seal
• Voter’s Registration Card
• Consular Report of Birth Abroad
• U. S. Military ID or Retired Military ID
• Military Dependent’s Card
• Expired U.S. Passport
• Native American Tribal Document
• U.S. Social Security Card
• U.S. Citizen Card I-197
• U.S. Military Discharge Papers DD-214
• Department of Transportation (DOT) Medical Card
• Civil Marriage Certificate
• Unexpired U.S. Merchant Mariner’s License
• Applicants must sign the TWIC Application Disclosure Form at the enrollment
center; minors can sign without parental/guardian consent.
• All U.S. credentialed merchant mariners must provide proofs of citizenship and/or
alien status required by the Coast Guard at 46 CFR Chapter I, Subchapter B, to TSA
at the time of TWIC enrollment. TSA will scan these documents into the enrollment
record and provide them to the Coast Guard for use in evaluating applicants for
original or renewal merchant mariner’s licenses, merchant mariner’s documents,
certificates of registry, Standards of Training, Certification and Watchkeeping
(STCW) endorsements, and if the Coast Guard begins to issue them, merchant
mariner credentials. Requiring this information to be submitted at TWIC enrollment
allows the Coast Guard to remove the requirement that all mariners travel to one of
the 17 Coast Guard Regional Exam Centers to submit this information. TSA will also
provide digital photographs, fingerprints, and FBI numbers to the Coast Guard for use
in evaluation of applicants. Sharing this information between TSA and USCG is
expected to occur at the time that TWICs are required for all credentialed merchant
mariners.
• All applicants will receive a TWIC Application Disclosure Form which must be
signed in the presence of the enrollment personnel under contract to TSA at the
beginning of the enrollment process. The enrollment personnel are known as
“Trusted Agents” because they must successfully complete a rigorous threat
assessment and extensive training on the enrollment process. If an applicant fails to
sign the disclosure form or does not have the required documents to authenticate
identity, enrollment will not proceed. For applicants who pre-enroll, the disclosure
form is provided with the application on-line for them to familiarize themselves.
• Applicants will provide a complete set of fingerprints and sit for a digital photograph.
Fingerprints will be used for the security threat assessment and to create the template
for the biometric information stored on the credential and the photograph will be
placed on the TWIC card for identification purposes. If an applicant refuses to sit for
a photograph, enrollment will not proceed. Fingerprinting will consist of 10 fingers
unless the applicant has lost or seriously injured his or her fingers. For applicants
who cannot provide any fingerprints, TSA will use alternate procedures approved by
Enclosure (2) to Navigation and Inspection Circular 03-07
7
the FBI to conduct the security threat assessment. (After card activation, these
applicants will confirm their identity when required by using their photograph and
PIN.) The fingerprints and photograph will be electronically captured at the
enrollment center and made part of the applicant’s TWIC enrollment record.
• Applicants who know they do not meet the qualification standards due to criminal
activity or mental incapacity, or are aliens in Temporary Protective Status and wish to
use the waiver process may initiate it during enrollment should so state on the
disclosure form. Individuals who fail to notify TSA of disqualifying events are
subject to immediate revocation (if they already possess a TWIC) and civil penalties,
if TSA so chooses. In addition, if an applicant is not truthful on the application,
criminal sanctions may apply.
• Information on the TSA website
www.tsa.gov/twic will provide guidance on the
process. Additionally, section 2.8 (Privacy and Information Security) identifies
program controls in place to protect an applicant’s privacy.
(3) Fee Collection
• Applicants will pay a fee in accordance with the following table:
Category Fee
Individuals requiring a security threat
assessment
$137.25
Individuals not requiring a security threat
assessment (e.g. Hazardous Materials
endorsement issued after 5/31/2005, FAST
card, or MMD issued after 2/3/2003 or
Merchant Mariner license issued after
1/13/2006)
$105.25
Card replacement fee (lost, stolen, or
damaged).
$36
* Proposed to be increased
to $60
• The fee, which covers the cost of enrollment, security threat assessment, and
credential production and delivery, will be collected from the applicant at enrollment.
Payment can be made by cashier’s check, money order, or credit card. The TWIC
enrollment fee is non-refundable, even if the threat assessment results in denying the
applicant a TWIC.
• Applicants who have completed a comparable threat assessment (hazardous materials
endorsement (HME), FAST card, merchant mariner’s document (MMD), or merchant
mariner license) may pay a reduced TWIC fee because they do not need another
threat assessment. In order to do so, they must present their HME, FAST card,
MMD, or merchant mariner license at the time of enrollment. The TWIC expiration
date for HME, FAST, MMD, and merchant mariner license holders will be five years
from the date those credentials were issued.
• Note: It is most beneficial for applicants who will use a comparable threat
assessment and pay the reduced fee to do so within 14 months of receiving the
comparable threat assessment (HME, FAST, MMD, license, etc.). After 14 months,
Enclosure (2) to Navigation and Inspection Circular 03-07
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it is more cost effective to pay the full fee for TSA to complete the security threat
assessment and issue a TWIC with an expiration date 5 years from the date of
issuance.
(4) Security Threat Assessment and Notification
• TSA will conduct a security threat assessment on all applicants consisting of the
following components in order to determine whether or not the individual poses a
security threat:
- Fingerprint-based criminal history records check (CHRC).
- Intelligence-related check to identify potential ties to terrorism.
- Immigration status.
• The applicant will be notified of the results of the threat assessment as follows:
1) Determination of No Security Threat (TWIC is ready for pick-up): via
email or telephone, whichever method the applicant selects on the application.
2) Initial Determination of Threat Assessment: via mail.
3) Initial Determination of Threat Assessment and Immediate Revocation: via
mail.
4) Final Determination of Threat Assessment: via mail.
• In the case of 2) and 3) above, the notification will include a written statement that
the applicant may pose or poses a security threat warranting denial of the TWIC, the
basis for the determination, information on how to appeal the determination, seek a
waiver or request materials, and a statement that if the applicant does not reply to
TSA within the time period (60 days), the ‘Initial Determination of Threat
Assessment’ will become a ‘Final Determination of Threat Assessment.’ See the
Waivers and Appeals section below for more information.
• The ‘Final Determination of Threat Assessment’ is served to the individual and, in the
case of a mariner, also to the Coast Guard (this notification would be sent to the
National Maritime Center so that they would not be issued a mariner
document/license/credential).
• If the applicant decides to appeal the ‘Initial Determination of Threat Assessment’ or
the ‘Initial Determination of Threat Assessment and Immediate Revocation’, then the
procedures in 49 CFR Part 1515 apply.
• Generally, TSA will not provide the reasons for a disqualification to an employer.
However, if TSA has reliable information concerning an imminent threat posed by an
applicant and providing limited threat information to an employer, facility, vessel
owner, or COTP would minimize the risk, then TSA would provide such information.
Additionally, TSA will notify law enforcement when appropriate.
(5) TWIC Issuance
• As stated above, an applicant who has received a ‘Determination of No Security
Threat’ will be notified, by email or phone, as indicated on their application, when
their credential is available at the enrollment center. The applicant must return to the
same enrollment center where they enrolled to activate and pick up the TWIC.
• At the enrollment center, the photograph and name on the card are compared to the
applicant and the identity documents presented by the applicant to authenticate their
identity. The applicant places a designated finger on a reader to perform a biometric
Enclosure (2) to Navigation and Inspection Circular 03-07
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verification with the biometric template stored on the credential and in the TSA
system.
• Upon successful biometric match, the applicant selects a 6-digit personal
identification number (PIN) that is stored on the credential. The PIN can
subsequently be used to authenticate identity and authorize use of the credential. The
PIN can also be used as the primary verification tool if the biometric is inoperative.
The PIN will be used during Coast Guard inspections and spot checks to match
the biometric on the TWIC to an individual and therefore it is extremely
important that it be remembered! Individuals should take care to choose a PIN that
can be remembered even if used infrequently.
• Once the enrollment and issuance process is completed, the credential is activated and
is ready to be presented at a facility or vessel for use as an access control tool.
• The TWIC security threat assessment and credential are valid for five years, except
when the TWIC is based on a previous comparable security threat assessment. TSA
will conduct perpetual vetting on all TWIC holders throughout the 5 year life of the
credential. TSA will revoke the credential based on any subsequent disqualifying
event (refer to regulation). In these cases, the TWIC holder will be notified via mail
and if information exists indicating that the person is an imminent threat, then this
will be shared with appropriate parties (e.g. employer, facility or vessel
owner/operator, COTP, or law enforcement.)
• Additionally, individuals are required to notify TSA if they have been convicted of a
disqualifying offense or no longer meet the immigration standard.
2.7 Waivers and Appeals
• All applicants have the opportunity to appeal a disqualification, and may apply to
TSA for a waiver if disqualified for certain crimes or mental incapacity, or are aliens
in Temporary Protected Status. Applicants who are denied a TWIC will be provided
a brief explanation and instructions on how to apply for an appeal or waiver.
• Waivers
o TSA has designed a waiver process that is straightforward. Applicants need not
be represented by counsel nor be conversant with legal terms and processes. TSA
accepts hand-written applications, so the applicant does not need to have a
computer or typewriter to apply for a waiver.
o Applicants must annotate the enrollment disclosure form that they will be
applying for a waiver at the time of enrollment if they know they will not meet the
standards and are eligible for a waiver. The TSA website (
www.tsa.gov/twic.)
will contain guidance on the process. The applicant has 60 days from the time
they receive a ‘Final Determination of Threat Assessment’ to provide the required
information to TSA for consideration.
o When completing the waiver request, the applicant should describe why he/she no
longer poses a security threat. Information that assists TSA with this
determination includes:
- the circumstances surrounding the conviction.
- the applicant’s work and personal history since the conviction.
- the length of time the applicant has been out of prison if sentenced to
incarceration.
Enclosure (2) to Navigation and Inspection Circular 03-07
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- references from employers, probation officers, parole officers, clergy and
others who know the applicant and can attest to his/her responsibility and
good character.
o Applicants denied due to mental incapacity may also apply for a waiver. Court
records or official medical release documents that state the applicant no longer
lacks mental capacity will be considered in the waiver, although are not always
necessary to obtain a waiver.
o If TSA denies an applicant’s waiver request, the applicant may seek review of the
decision by an Administrative Law Judge (ALJ). Information on the ALJ process
is available in section 49 CFR 1515.11 of the TWIC final rule.
• Appeals
o The appeal process is available to all applicants if they believe TSA has not
applied the disqualifying standards appropriately or has based its security threat
assessment determination on incorrect court records or mistaken identity.
Applicants who file an appeal may supply the correct records to TSA.
o Following TSA’s Initial Determination, an applicant must initiate an appeal by
requesting documents from TSA, responding to TSA, or providing TSA with
corrected records or other proof that the Initial Determination was based on
erroneous court records or mistaken identity.
o Applicants who are disqualified due to the intelligence-related check and appeal
unsuccessfully may seek review from an ALJ.
2.8 Privacy and Information Security
• Privacy and information security are critical to the TWIC program. Information
collected at the enrollment center or during the pre-enrollment process, including the
signed disclosure form and identity documents, is scanned into the TWIC system for
storage. Information is encrypted or stored using methods that protect the
information from unauthorized retrieval or use.
• The fingerprint images collected from each applicant will be submitted to appropriate
government agencies for the criminal history records check. The images of two of
the fingerprints will be converted to fingerprint minutiae templates, not the actual
fingerprint, and used on the credential as the reference biometric to verify identity.
• The entire enrollment record (including all fingerprints collected) will be encrypted,
transmitted to the central database, and segmented to prevent unauthorized use. The
TSA system acknowledges receipt of the enrollment record, at which time all
enrollment data is automatically deleted from the enrollment workstation.
• Additional information on this topic is also available in the TWIC Privacy Impact
Assessment (PIA) which is available on TSA’s website.
2.9 TWIC Help Desk
• A toll-free TWIC help desk (1-866-DHS-TWIC) provides around-the-clock service
for merchant mariners, transportation workers, facility and vessel owners and
operators, and others who require assistance related to the TWIC program.
Additional information on the help desk will be available at
www.tsa.gov/twic.
Enclosure (2) to Navigation and Inspection Circular 03-07
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• Assistance includes help for enrollment, lost, stolen, or damaged cards, PIN resets
(note: an applicant will have 10 tries to get their PIN correct before needing to have
the PIN reset), etc. Assistance is also available for scheduling enrollment
appointments, locating the closest enrollment facility to an applicant, and guiding
applicants through the web-based pre-enrollment process.
• Both TSA (571-227-4545) and the Coast Guard (877-687-2243) will have a help desk
in order to address calls that do not come directly through 1-866-DHS-TWIC. These
help desks will coordinate/communicate as appropriate.
2.10 TWIC Renewal
• Generally, TWICs remain valid for five years, unless renewed before the five-year
expiration date, deactivated, or revoked. Upon renewal, an applicant receives a new
credential and the old credential is invalidated in the TSA System. TSA does not plan
to notify TWIC holders when their credential is about to expire because the expiration
date is displayed on the face of the credential.
• If the applicant paid a reduced fee for a TWIC based on an earlier comparable threat
assessment and credential (FAST, HME, MMD, COR, or merchant mariner license),
the TWIC will expire five years from the date of the comparable threat assessment
and credential issuance.
• To renew a TWIC, the holder must appear at any enrollment center. Mariners are
urged to start the renewal process approximately 180 days before the expiration date
of the credential to accommodate Coast Guard processing of mariner qualifications.
All other applicants should apply at least 30 days prior to expiration in order to
facilitate timely processing of the TWIC renewal.
• When renewing the TWIC, applicants must again provide biographic and biometric
information and identity verification documents, and pay the associated fees. Note
that the TWIC web site will maintain a list of documents that may be used to verify
identity, which may change over time.
• TSA issues a new credential once the enrollment process and threat assessment is
complete. The expired credential will be deactivated. The new credential will expire
five years from the date of issuance. Although renewal occurs every five years, TSA
conducts recurring security threat assessments on applicants throughout the five year
period.
2.11 Lost, Stolen, or Damaged TWICs
• Applicants who determine that their TWIC is lost, stolen or damaged should contact
the TWIC help desk immediately at 1-866-DHS-TWIC.
• After the applicant reports the card as lost, stolen, or damaged, the help desk will
contact the card production facility to trigger production of a replacement TWIC.
The replacement credential will be sent to the enrollment center designated by the
applicant for pick up.
• TSA will add the lost, stolen, or damaged credential to the list of revoked cards to
decrease the chance that the credential could be used by an unauthorized person to
gain unescorted access. This list of revoked cards (the ‘hotlist’) will be available on
the TWIC portal to appropriate individuals within the maritime community (VSO,
FSO, COTP) in order to monitor access to secure areas. Once the replacement TWIC
Enclosure (2) to Navigation and Inspection Circular 03-07
12
arrives at the enrollment center, the applicant will pick it up and pay the card
replacement fee of $36. (An increase to $60 has been proposed.)
• The replacement card will have the same expiration date as the original.
Enclosure (3) to Navigation and Inspection Circular 03-07
i
Table of Contents
Enclosure (3) – TWIC Program Implementation for Vessels and Facilities Page
3.1 TWIC Applicability .................................................. .................................................. ............1
3.1 a. Vessels .................................................. .................................................. ......................... 1
3.1 b. Facilities........................................ .................................................. ................................ 2
3.2 TWIC Implementation Schedule .................................................. ..........................................2
3.2 a. Enrollment........................................ .................................................. ............................. 2
3.2 b. Compliance .................................................. .................................................. .................. 3
Table 1 – Compliance dates based on type of operation .............................................. 4
3.3 Vessel and Facility Guidance .................................................. ...............................................4
3.3 a. Access Control – Using TWIC as a Visual Identification Badge.................................... 4
3.3 b. Secure Areas .................................................. .................................................. ................ 6
Figure 1 – Cargo vessel............................................ .................................................. ... 8
Figure 2 - Passenger vessel .................................................. ......................................... 8
Figure 3 - Marine terminal, wholly transportation related........................................... . 9
Figure 4 - Marine terminal, some non-maritime transportation portions after COTP ...
approval of FSP amendment redefining secure area.............................................. ....... 9
3.3 c. Escorting .................................................. .................................................. .................... 10
Table 2 – Escort guidance for secure areas that are not also restricted areas and
secure areas that are also restricted areas............................................. ....................... 13
3.3 d. Employee Notification Requirement .................................................. ........................... 14
3.3 e. Incorporation of the TWIC Procedures into Security Plans .......................................... 14
3.3 f. Incorporation of the TWIC into Existing Physical Access Control Systems ................ 15
3.3 g. Knowledge Requirements for Personnel .................................................. ..................... 16
3.3 h. Special Provisions for Access Control........................................... ................................ 17
Table 3 – Criteria for individuals, vessels, and facilities to use the new h
TWIC for captains 
