I have been getting many calls from near and far regarding the TWIC Final Rule requirements that go into effect August 23, 2018. My advice to you has not changed since our last conversation when I visited this topic.

The Coast Guard is not going to release anything in writing until the final rule making process has been completed. Time of that release would only be a guess.

My advice to you is – If you are in Risk Group A:

You will be required to use TWIC Readers or Physical Access Control System (PACS) that meets electronic TWIC inspection requirements (Card Authentication, Card Validity & Identity Verification). If those access points do not have the infrastructure (power and connectivity) to the nodes where you are planning to install fixed TWIC readers or PACS, continue planning and installing the infrastructure because civil engineering, project planning, trenching and running power and connectivity are your long lead-time projects.

If your access points (turnstiles, gates, and doors) already have PACS but do not meet electronic TWIC inspection requirements, you should WAIT to replace the PACS hardware and software.

Do not buy the readers, software or hardware! Research and evaluate systems, but do not commit resources just yet.

My reason for this advice:

– Technology is advancing so quickly and the price is continually decreasing. If you buy it now it could be obsolete by the time the Coast Guard is going to enforce the law.

– We are evaluating multiple hardware and software options at this time and hope to have some of these vendors at the Facility Security Symposium in June of 2018.

– Wait for the Coast Guard to come out with their written enforcement guidance. This is common practice for them to provide industry a grace period to allow facilities to purchase, install and execute all of the hardware and software, modify the FSPs and educate their people.

– During a major construction period, you can still use portable readers if your infrastructure is not in place.

Final thoughts, patience is a virtue and the bureaucracy moves very, very slowly.

We will keep you advised.

Ed