How can Risk Group A facilities comply with TWIC Final Rule requirements? These are some of the capabilities and capacities to bring you into compliance:

• TWIC Readers & Physical Access Control Systems (PACS) – Not required to be stationary/fixed – portables are acceptable

• TWIC Reader – If not on TSA’s Qualified Technology List (QTL), it must meet electronic TWIC inspection requirements. You can verify if your TWIC reader is approved by check the TSA QTL at: https://homeport.uscg.mil/mycg/portal/ep/contentView.do?contentTypeId=2&channelId=-24886&contentId=544123&programId=50398&pr

• PACS – facilities are authorized to enhance their current PACS to meet electronic TWIC inspection requirements.

• TWIC Reader or PACS malfuntions – Must have a back-up system or portables that perform Electronic TWIC inspection requirements (Note: A visiual inspection is NOT authroized.)

• If your electronic TWIC reader fails and you do not have an operable back-up, you MUST report it to COTP and obtain permission to operate. The Coast Guard will require suitable risk mitigation before granting permission to operate.

• TWIC Reader or PACS – must record/document ENTRY into a secure area and Risk Group A facilities are required to maintain these records for two years.

Remember:

The TWIC Final Rule is a credentialing law, it does NOT replace screening.