On October 31, 2024, the U.S. Coast Guard (USCG) announced a significant update regarding the enforcement of the TWIC Reader Rule in its Federal Register notice titled “TWIC–Reader Requirements; Second Delay of Effective Date.” This rulemaking delays the enforcement of TWIC Reader requirements for specific categories of facilities until May 8, 2029.
Who Is Affected by the TWIC Reader Rule Delay?
The delayed enforcement applies to the following three categories of facilities:
- Facilities that handle Certain Dangerous Cargoes (CDC) in bulk and transfer such cargoes from or to a vessel.
- Facilities that handle CDC in bulk but do not transfer it from or to a vessel.
- Facilities that receive vessels carrying CDC in bulk but, during the vessel-to-facility interface, do not transfer it from or to the vessel.
Why the Delay?
The USCG’s decision to delay enforcement stems from the need to review the 2022 TWIC Reader assessment report conducted by the Homeland Security Operational Analysis Center (HSOAC). The report analyzed key factors, including:
- Types of CDC;
- Population density within proximity to facilities handling CDC; and
- Broader consequences of CDC-related risks.
This delay allows the USCG to fully consider the findings and explore a more risk-based approach to TWIC Reader applicability.
New Pilot Project for TWIC Reader Applicability
In addition to reviewing the HSOAC report, the USCG will initiate a pilot project in 2025 to evaluate a proposed tiering process for determining TWIC Reader applicability.
What Is the Tiering Process?
The proposed process leverages the Chemical Security Assessment Tool (CSAT) tiering engine, previously used under the Chemical Facility Anti-Terrorism Standards (CFATS) regulation. By considering the CSAT’s risk assessment methodology, the USCG aims to identify more precise criteria for determining which facilities require TWIC Reader enforcement.
How the Delay Affects Your Facility
The delayed enforcement provides additional time for facilities to prepare for potential changes to TWIC Reader requirements.
Next Steps for Facilities
The USCG plans to use data from the pilot project and the HSOAC analysis to evaluate potential changes to TWIC Reader applicability. These efforts reflect a move toward a more risk-based approach to chemical facility security. Please do not hesitate to contact us with any questions or additional information.