Friday, February 27, 2009

TWIC reminder for owners and operators of US vessels

We have seen numerous reminders, mostly from the US Coast Guard, of the progressive deadlines for enforcement of the Transportation Worker Identification Credential (TWIC) regulations at regulated facilities in the various Captain of the Port (COTP) zones. We have also seen the reminders that each US merchant mariner must have a valid TWIC as of April 15. The reminder that we have not seen relates to owners and operators of US-flag vessels. As of April 15, they will be required to enforce the TWIC regulations on their vessels, in a manner similar to the obligation being imposed on the owners and operators of regulated shoreside facilities. In other words, they may grant unescorted access to secure areas on the vessel only to an individual possessing a valid TWIC. For most vessels, the entire ship is considered a secure area. Crewmembers must be trained to properly check arriving persons for possession of a valid TWIC and to properly escort those persons without a TWIC. It is recommended that owners and operators of US-flag vessels start now, if they haven’t already, to develop procedures and training for this on-rushing requirement. (2/27/09).

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