The National Maritime Security Advisory Committee (NMSAC) recently issued a list of TWIC working group discussion items and recommendations that emphasize some concerns that the SIU and the Maritime Trades Department of the AFL-CIO have been expressing for some time.NMSAC was established under authority of the Maritime Transportation Security Act of 2002 and provides advice to the Secretary of the Department of Homeland Security (DHS) via the Commandant of the U.S. Coast Guard on matters such as national security strategy and policy, actions required to meet current and future security threats, international cooperation on security issues, and security concerns of the maritime transportation industry. During its work, NMSAC consults with industry stakeholders such as the SIU and MTD, asking for their opinions and insight on various maritime issues including TWIC.
In its July 30 finding, NMSAC recognizes some successes of the Coast Guard and the Transportation Security Administration (TSA) for its TWIC efforts, especially the creation of the informational “TWIC Dashboard,” but points out a number of areas that it says need to be improved.
NMSAC’s recommendations include:
Compliance Dates: NMSAC expresses surprise that when the TWIC final compliance date was extended to April 15, 2009 by DHS, no maritime stakeholders were consulted. NMSAC says its feel strongly that DHS should have consulted with the industry before it made the decision and that future policy should not be made without input from the industry.
Because of the compliance date change, NMSAC recommends that anyone who acquired their TWIC card prior to the original September 2008 deadline not be penalized due to the shift in enrollment. The committee suggests that the expiration dates on those cards should be extended by an additional year. NMSAC said, in short, that TWIC is a user-funded program and users must not be penalized for working to help TSA meet its goal.
Communications/Outreach: NMSAC says that other than providing updates on when enrollment is beginning in certain ports, more TSA communications work must be done about TWIC requirements to cardholders and shipping owners/operators and ports.
NMSAC also says the TSA should ask its contractors to proactively reach out to local stakeholders and offer to support discussions at the port level. Further, contractor Lockheed Martin should share the list of local stakeholder primary contacts so that these individuals can get together to share information as needed.
Cards: NMSAC says the process to report a lost/stolen card, including payment for a replacement card and printing of receipt, must be available through a web interface to minimize the number of trips to the enrollment center.
Facilities are still unclear whether unescorted access can be provided to someone who has reported a revoked, suspended, lost or stolen card; this information is necessary for facilities to make risked-based decisions on whether to grant access.
TSA/Contractor Performance: The committee is concerned that the TSA has not met its stated goals for card delivery dates. According to NMSAC, only approximately 219,000 of the estimated 1.5 million potential TWIC holders, or just over 14 percent, had received their cards (as of late July) and the TSA at times is still not delivering cards within its targeted goal of seven to 10 days after enrollment.
According to NMSAC, since February of 2007, stakeholders have repeatedly requested information on the performance measures specified in the TSA contract with Lockheed Martin. Most recently, NMSAC made this request at its April 2008 meeting. The committee also requested a copy of any TSA evaluations of the contractors, success/non-success in achieving the stated measures. This had yet to be provided as of last month.
NMSAC says it would like some definitive assurance that there is an oversight process – not only with Lockheed Martin, but with any and all contractors and sub-contractors associated with this project. Stakeholders, who are ultimately funding this program, should also have the opportunity to comment on the contract parameters.
Failure to Capture Biometric: As previously reported in the Seafarers LOG, a number of individuals’ fingerprint biometrics are unable to be captured to be read by biometric readers. NMSAC calls for a software patch to be applied to the TWIC enrollment stations in order to enhance the ability to capture a damaged or otherwise unreadable biometric. NMSAC says while this will aid in the enrollment process, there remains the concern that TWIC readers, without the same patch, will be unable to read these particular biometrics. Unless this issue is addressed by the reader manufacturers, according to NMSAC, the USCG and TSA need to assess the impact on daily operations if biometrics are unreadable due to lower quality fingerprint capture.
Card Design: NMSAC says the TWIC program missed an opportunity to provide a visual identifier on the TWIC card for essential non-uniformed port personnel that might require access on local roadways and to the port for critical response and recovery operations. Since it is a well recognized fact the 85% of the nation’s critical infrastructure is owned by the private sector, the individuals that work for these private sector businesses will be critical to response, recovery and resiliency activities. However, if these individuals are not able to travel on local roadways because they are shut down for anything other than emergency vehicles, as New York/New Jersey roadways were for several weeks after 9/11, these individuals would be unable to fulfill essential duties.
The TSA should revisit the physical design of the TWIC card to include an indicator that would designate certain individuals as essential personnel that would require access in an emergency.
Enrollment Center Locations: NMSAC explains that many enrollment centers are too far away from ports and are often too difficult to find. An example NMSAC gave was an enrollment center that was established at a hotel two towns away from the port facility because the contractor felt compelled to meet a deadline and the “permanent” site was not yet operational. The report finds this as a gross misuse of program dollars; TWIC applicants will not be inclined to travel to this site when they know the permanent site is forthcoming.
NMSAC says fixed sites should offer weekend or evening hours to accommodate workers’ schedules. More flexible enrollment hours are likely to positively affect enrollment rates.
Other issues pointed out by the committee included incorrect names or other information on cards; photos being processed with darkened photos; expiration date errors; and security features not printing properly. Also, many applicants have reported enrollment processing of several hours or more at enrollment centers.
Applicants have reported that multiple visits for both enrollment and activation – in some cases as many as six visits – to enrollment centers have been necessary because of various technical or operational difficulties.
In addition to the technical problems associated with enrollment, stakeholders also reported a number of issues regarding both the TWIC web site and the TWIC Program Help Desk. NMSAC said it acknowledges and appreciates the improvements made to the help desk to date; however the TSA must continue to monitor progress and performance closely.
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