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To TWIC or Not to TWIC, that is the question du jour for Master Mariners

By Alex and Daria Blackwell

After 9/11, the USCG and Department of Homeland Security set up a new requirement for licensing of captains and master mariners.  Everyone applying for an OUPV or a Master’s ticket had to obtain a Transportation Worker Identification Credential (TWIC).  It required going to a special center qualified to conduct the security checks on mariners.  You had to bring specific documentation of who you are and where you live, you had to be fingerprinted, photographed and background checked. They then issued you a laminated TWIC card with a chip which would theoretically provide access to secure areas of ports.  It required two visits to the center in person. First to be fingerprinted and photographed, then to pick up the card.  And it still does.

After the TWIC requirement was introduced, a captain’s (OUPV) or master’s license could not be renewed unless the mariner had a valid TWIC card.  One evaluated the mariner’s qualifications, the other certified the person’s security status.  We were fortunate in that we lived in Bergen County and there was a TWIC center set up near Hackensack, which was very convenient.  We went down there and got ourselves security cleared even before we knew what the deal would be.

In the meantime, we’ve had to renew our merchant mariner documents (MMD) which has been replaced with the new merchant mariner credential (MMC) which is a passport style document. It requires the insertion of a TWIC card in the back pocket for it to be valid. Naturally, our MMD expiration date was out of sync with our TWIC by several years. Fortunately, with quite a bit of back and forth, we managed to renew our MMDs with new MMCs while overseas.

The old MMD vs the new MMC

Fast forward 5 years, the original TWIC cards are now expiring, and there are still no machines installed that can read the TWIC cards at the security checkpoints – so the card is expensive and useless.  And, the mariners with the TWIC cards are of course en route all around the world.  To get them somewhere where they can have two visits to a center weeks apart without schedule is wreaking havoc with the transportation system.  So what does the USCG do?  They offer everyone with a valid card a three-year extension for a set fee. All you have to do is call a special number.  http://www.maritimedelriv.com/Port_Security/TSA/files/TWIC_Expiration_Policy_Bulletin.pdf You do, however, have to pick it up in person.  Instead of two visits, it takes only one. But if you’re on a vessel bound for Singapore and your TWIC expires next month, you may be out of luck. All for a useless card.

The Department of Homeland Security issued a notice on March 22, 2013 (DEPARTMENT OF HOMELAND SECURITY Coast Guard 33 CFR Parts 101, 104, 105 and 106 [Docket No. USCG–2007–28915] RIN 1625–AB21 Transportation Worker Identification Credential (TWIC)—Reader Requirements) that requires certain vessels and facilities to comply with the reader requirements and security plans. They think it will take three years to implement which is why they offer a three year extension on the cards. (http://www.maritimedelriv.com/Port_Security/TSA/files/TWIC_Exemption_%20Signed_20120615.pdf) However, the businesses that have thousands of transportation workers working for them at countless locations are struggling to figure out what they have to do and how they can possibly get it done.

But the rule that affects all of us here in the merchant marine associated with the leisure boating market most is a letter.  CG543 Policy Letter 11-15 dated December 19, 2011 reverses the need for mariners holding an OUPV or certain other categories to have a TWIC card in order to renew their captain’s license.  You still can if you want to, but you no longer need to. (http://www.maritimedelriv.com/Port_Security/TSA/files/Policy_Letter_11_15.pdf)

But wait there’s more. Mariners who do not require unescorted access to a vessel with a security plan also are exempt but must have a letter stating the reason why they don’t need a TWIC. A sample can be found somewhere here http://www.uscg.mil/nmc/.  

And, even if you are not required to hold a TWIC, you will need to apply at a TWIC enrollment center and pay all applicable fees associated with getting a TWIC if you’ve never had one. However, you will not be required to pick up your TWIC as a precondition for receiving your MMC. Reference Policy Letter 11-15(5)(a) paragraph 3. http://www.uscg.mil/nmc/faq/twic/TWIC%20FAQ.pdf

Confused yet?  So to answer the question to TWIC or not to TWIC?  Your guess may be as good as anyone else’s.  



     
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