This month’s Seebald & Associates blogs focus on the TWIC Final Rule impacts of Who needs it? What is needed? How you can meet the requirements? What are your Next Steps? When you need to submit your amendments or new FSP to be compliant

The TWIC Final Rule defines Risk Group A as facilities that handle Certain Dangerous Cargo (CDC) in bulk or receive vessels carrying CDC in bulk, as well as facilities that receive vessels certificated to carry more than 1,000 passengers.

Bulk or in bulk means a commodity that is loaded or carried on board a vessel without containers or labels, and that is received and handled without mark or count. This includes cargo transferred using hoses, conveyors, or vacuum systems.

There seems to be a level of confusion in industry as to what determines whether a facility is a CDC facility or not regarding the TWIC Final Rule, especially facilities that receive CDCs by truck or rail. Because of this confusion, the Coast Guard is considering additional guidance, policy determinations, and/or regulatory updates. Seebald & Associates will stay tuned for guidance the Coast Guard provides and we’ll keep you up to date on Coast Guard policy decisions.

Still, lack of guidance does NOT relieve you of being compliant with the TWIC Final Rule – because it is the law.