COVID-19 – Transportation Worker Identification Credential (TWIC) Operations

USCG Navigation Circulars(NVICs) and Policy

Document Number:13-20
Type of Document:MSIB
Published Date:April 03, 2020
Effective Date:April 03, 2020
Superseded Date:August 31, 2020
Current Status:Superseded
This document provides clarification regarding the Transportation Worker Identification Credential (TWIC), which is jointly managed by the USCG and the Transportation Security Administration (TSA). TSA may grant a temporary exemption from certain requirements in 49 CFR part 1572 for the expiration of the TWIC for current cardholders. If this occurs the Coast Guard will take these exemptions into consideration:

Maritime Facilities and Vessels:

TWIC Readers
The implementation date of June 7, 2020, remains in effect. However, the Coast Guard will delay enforcement until October 5, 2020. Applicable facilities and vessels are not required to update facility security plans (FSP)/vessel security plans (VSP) or install readers until the revised enforcement date.

Escort Ratios
Escort ratios described in NVIC 03-07 may be adjusted due to shortages or other demands. This would constitute a change to the FSP or require COTP approval via noncompliance as discussed in MSIB 07-20.

New Hires
Once a new hire has completed enrollment and presented appropriate identification, access to restricted areas is allowed with another person holding a TWIC. However, the "side-by-side" escorting requirements will not be enforced during the COVID-19 pandemic.

Alternative Security Program (ASP)
Local users unable to comply with the requirements in an approved ASP may pursue temporary relief via noncompliance (discussed below) or an amendment can be submitted to cover the entire ASP via submission to CG-FAC.

If a facility or vessel is unable to comply with the noncompliance requirements of 33 CFR parts 104 or 105, they must contact the COTP to request and receive permission for temporary deviation. Operators should evaluate and consider safety risks created from noncompliance. This request should include new measures or safeguards employed to mitigate those risks.

Merchant Mariner Credentials:
The Coast Guard is providing flexibility with regard to requirements of valid TWICs when applying for a credential or when serving under the authority of a credential. Several situations are explained regarding the MMC application process, applications for original or renewal of credentials, TWIC pre-enrollment, working on expired TWICs, and other scenarios.

TSA Enrollment Centers:
Most Enrollment Centers remain open and are processing TWIC enrollments. TSA encourages individuals to use the "Find an Enrollment Center" to determine if the center is open, and hours of operation. Enrollments must be completed in-person with required identity/immigration documentation. It is recommended that individuals schedule an appointment online.
    View this regulation in PDF format.

J. Connor Consulting, Inc. Teaming with Industry