Officials from the SIU and its affiliated training center participated in all four public meetings recently conducted by the Transportation Security Administration (TSA) and the Coast Guard after the government issued proposed regulations for documenting mariners and port personnel.At press time, the union was preparing formal comments on the seemingly inevitable Merchant Mariner Qualification Credential (MMC) and the Transportation Worker Identification Credential (TWIC). The deadline for comments was July 6, though efforts were under way to secure an extension.
“The union is monitoring and participating in this process with the utmost care and energy,” said SIU Secretary-Treasurer David Heindel. “We will use every resource necessary to make sure that our input is fairly considered by the appropriate agencies. Meanwhile I would ask that the membership remain patient and stay informed as this situation unfolds in the coming months and years.”
Generally, the upshot for Seafarers is expected to be as follows, though this may change once the final regulations are issued by the Department of Homeland Security: The TWIC and the MMC together eventually will replace the merchant mariner document (z-card) and STCW certificate. In other words, whereas today an SIU member may be required to carry a merchant mariner document and an STCW certificate, within a few years those credentials will have been phased out and supplanted by a TWIC (currently envisioned as a card similar in size to a z-card or driver’s license) and an MMC (projected to be a larger, paper document).
However, as with the rest of the notice of proposed rulemaking (NPRM) issued on May 22, nothing has been finalized. SIU members are asked to keep in mind that the final regulations likely won’t be finished for at least a few months.
Understandably, the proposed details for issuing the new credentials—including time-frames, content and costs, among numerous other considerations—are under intense discussion throughout the industry. Some of those discussions took place at the public meetings which quickly were arranged after the NPRM was released. The meetings took place from May 31-June 7 in Newark, N.J.; Tampa; St. Louis; and Long Beach, Calif., respectively.
Besides requesting additional time to review the NPRM and asking for additional public meetings, among the most common points and questions raised at last month’s sessions included the following:
- The new credentials were mandated in the Maritime Transportation Security Act (MTSA) of 2002.
- As currently written, the new regulations would require that the TWIC program is fully in place 18 months after the final rules have been published. The MMC program would follow and be completely in place no later than 18 months after the TWIC is implemented. However, where the MMC is concerned, a mariner may continue to serve under the authority of his or her license, z-card, certificate of registry and/or STCW certificate until the first renewal or upgrade of that credential, but not later than five years after the effective date of the final rule.
- There is great concern among ship operators regarding a requirement for a TWIC reader on every vessel. Those machines are estimated to cost $10,000 apiece.
- Mariners and their unions are asking for one credential for shipboard personnel—either a TWIC or an MMC, but not both.
- Mariners and their unions also declared that because the TWIC is a security requirement, the government should pay for it. The NPRM spells out total individual TWIC fees ranging from $95 for mariners with a z-card issued after Feb. 3, 2003 to $149 for all other applicants.
- Port workers said that excessive background checks might decimate their manpower pool.
- The recordkeeping requirement for vessels and port facilities is burdensome to execute and perhaps even more difficult to enforce. Everyone entering a port facility or vessel would have to be logged in and out, and the records would have to be maintained for at least two years.
- Numerous attendees suggested TWIC applicants should not be required to travel to an enrollment center twice (once to apply for the credential and once to pick it up), although the TSA is proposing mobile enrollment centers. (The MMC would be obtainable via mail service, basically because the TSA will share information collected from TWIC applicants with the Coast Guard. A person would need to possess a TWIC before acquiring an MMC.)
Technically there are three separate NPRMs to bring the TWIC and MMC on board. Each has its own docket for comments, with the same July 6 deadline. The proposed regulations would incorporate the new credentials into the Code of Federal Regulations (46 CFR, Parts 10, 12 and 15, covering, respectively, licensing of maritime personnel, certification of seamen, and manning requirements); authorize and explain the TWIC system; and authorize and explain the MMC program.
As previously reported, the TWIC would be required for mariners and for people needing unescorted access to secure areas of a regulated port facility or vessel. The document itself is an identification card utilizing various technologies designed to make it secure and tamper-proof. It is expected to contain two electronic chips, fingerprints and a photograph, and would be valid for five years.
The TSA envisions having 125 enrollment centers covering approximately 300 ports. Roughly 750,000 individuals are expected to need a TWIC, although foreign-flag vessels are exempt.
The MMC would appear in certificate form with many fraud protection measures. Its format hasn’t been finalized, but the credential is expected to resemble an STCW certificate.
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