On August 2nd, President Trump signed into law the Transportation Worker Identification Credential Accountability Act of 2018 (HR.5729). This formally prohibits the Coast Guard from implementing the Rule until DHS submits a satisfactory assessment of the TWIC program to Congress.
Furthermore, a U. S. District Court (Eastern, Virginia) issued a court order delaying the Rule at certain CDC facilities “until a further order of the court.” This is in response to lawsuits from several industry groups.
We will track this activity closely and keep you all informed.
The Transportation Security Administration (TSA) began issuing the new TWIC NexGen cards on July 10, 2018. The new cards incorporate enhanced security features (click here to read more).
Details about the new TWIC NexGen card:
- Current TWIC card holders do not need to replace a valid TWIC card with the new TWIC card design.
- Regulated entities that require TWIC for access will accept and recognize both the current and new TWIC designs until the card’s expiration.
- The new card design is compatible with qualified TWIC readers.
- To deter alteration of the card’s expiration date, the new card includes a color-coded expiration date box that will update on an annual basis.
- The fee for the newly re-designed TWIC card remains unchanged ($125.25) and the credential is valid for five years.
Click here to read more about the TWIC NexGen cards.
Click here for a TWIC NexGen Authentication Guide
Effective immediately, USCG facility inspectors are going to start using a new form for facility inspections. The new form, CG-835F, replaces CG-Form 835, “Vessel/Facility Inspection Requirements”. CG-835F is specifically formatted for facility inspections. There are no major changes to the new form or the information collected during the inspection.
Facility owners and operators may start seeing Coast Guard facility inspectors using the new form immediately, but some inspectors may still use the older CG-835 form during the transition.
Click here for a link to the new CG-385F form.
The Coast Guard has proposed to delay the effective date for implementation of TWIC Readers for certain facilities. The proposed delay is for two categories of facilities:
- Facilities that handle certain dangerous cargoes in bulk, but do not transfer these cargoes to or from a vessel, and;
- Facilities that receive vessels carrying certain dangerous cargoes in bulk, but do not, during that vessel-to-facility interface, transfer these bulk cargoes to or from those vessels.
The Coast Guard proposes delaying the effective date for these two categories of facilities by 3 years, until August 23, 2021.
Other vessels and facilities, including facilities that receive large passenger vessels and facilities regulated under 33 CFR 105.295 that handle certain dangerous cargoes in bulk and transfer it to or from a vessel, would be required to comply with the final rule by August 23, 2018.
Click here for the Notice of Proposed Rulemaking.
Click here and here for additional information regarding the TWIC Reader Rule.
Review this list with your contract Branch Manager or Supervisor and make these activities part of their everyday routine.
- Conduct meaningful daily Post Checks. In his book, management guru Ken Blanchard counseled – “Catch them doing something right (a moment of praise); or catch them doing something wrong (counsel them or take corrective action); or have a training moment (briefly review TWIC procedures or emergency call out processes, for example).
- Don’t deviate from your own rules. If homework is prohibited in the post orders, do not make exceptions. Same with Internet surfing, digital games, etc. When you deviate from your own rules, the whole operation can degrade and you are likely to be accused of favoritism.
- Daily mini-drills keep them on their toes: Place a ladder against the perimeter fence and see how long it takes for patrol to find it. Spend a moment in the guard building drilling them on proper truck inspections or baggage screening. Then fill out a brief drill report and file it with your FSP.
- Require detailed daily activity reports. Insist they are detailed, and follow up on entries often enough so the guards know you review them.
- Be receptive to questions. Create an atmosphere that encourages security officers to ask questions, seek clarification, and report unusual circumstances.
Don Greenwood & Associates has comprehensive templates for guard contracts, post orders, and security officer training programs. Give us a call if we can help develop procedures and tune up your guard force.
“I knew this was going to happen.” That is the statement given in more than 50% of workplace and school rage killings.
We have learned that employees are unlikely to report emerging situations to management unless they feel confident that management has a plan and an organized response to address the issue.
Don Greenwood & Associates has supported clients with workplace violence prevention and response programs since 1995 – companies in oil & gas, field services, manufacturing, business, chemicals and computing.
Our program is comprehensive, ready for rapid deployment throughout the workforce, and includes:
- A template for establishing a Threat Management Team (consistent with ASIS and SHRM guidelines) that includes specific responsibilities for Security, HSE, HR, Legal, and Operations.
- A Quick Action Guide addressing active shooter situations – ready for distribution to your employees immediately.
- A PowerPoint training program for employees that encourages reporting, engagement, and concise standards of behavior.
- A PowerPoint for managers and supervisors with guidelines and standards for intervening in and managing workplace disruption.
- Training materials to help employees formulate their own plans for run, hide, and fight – based on their immediate workplace environment.
- Guidelines on assessing the potential for violence in emerging situations and strategies for managing these threats.
The program is complete, cost effective, and ready to tailor to your company’s needs and culture.
Send me an email or give me a call for more information – Don Greenwood, email@example.com, 281-435-2339.
Check out our website – www.greenwoodsecurity.com
Don Greenwood & Associates, Inc. – Full Service Security Management Consultants since 2003
Yesterday, the Department of Homeland Security and FEMA posted the 2018 Port Security Grant Notice of Funding Opportunity (NOFO). Federal allocation this year is $100 million, more than last year. However, for private, for profit companies, the federal match is 50/50 vs the 25%/75% if last year. Which means, that if a recipient applies for $100,000 in funding for an appropriate security project, DHS will award $50,000 and the company receiving the award will need to provide $50,000 in matching funds.
That may make the grants program less attractive for many companies; however, it is logical that fewer will apply, so the chances of winning an award may be better than last year.
The deadline for filing applications is June 20th – we have less than 30 days.
In the last few years, Don Greenwood & Associates Inc. has help clients write and submit ten grant applications and have won awards for eight of the ten, including the largest award given to a private company in 2016 – just under $1 million dollars. Writing successful grant applications depends on the consultant’s ability to draft a persuasive argument that the facility in question needs the award to support the goals of the larger community, the Area Maritime Committee, as well as the submitting company and port facility.
Contact us at 281-435-2339 or firstname.lastname@example.org for more information.
It is not too soon to start the registration processes:
The Administration has budgeted $100 million for port security grant awards in 2018.
- Likely before the end of May
- Like last year, there will be a short window to submit applications
- Last year grants were announced on June 2 and applications due by June 22, only 20 days to prepare and submit applications.
Grant priorities will probably remain the same.
- Enhancing Maritime Domain Awareness
- TWIC Technology
- Cybersecurity Capabilities
- Training and Exercises
Let’s get started. Before we can develop an application, we need to discuss your facilities, what is needed, and whether or not the needs meet the grant priorities. Successful grant writing is more an art than a science. Give us a call at 832-717-4404 or email email@example.com.
To read more on preparing a grant application, click here.
TWIC Reader Rule Delay
On April 18, 2018, the Office of Management and Budget’s Office of Information and Regulatory Affairs announced that they received a proposed rule to delay the implementation date for the USCG TWIC Reader Rule.
To read more about the TWIC Reader Rule click here, here and here.
To read more about the delay, click here.
From TWIC Stakeholders Communications Committee Meeting – March 2018
TWIC Reader Requirements Final Rule
- As we are now within 6 months of the implementation date of the TWIC Reader Rule, CG-FAC wanted to reiterate a Maritime Commons Blog post dated March 31, 2017 (http://mariners.coastguard.dodlive.mil/2017/03/31/3312017-twic-reader-rule- update/), and where units should expect to enforce TWIC reader rule “on time” at:
- a) Facilities that receive vessels certificated to carry more than 1,000 passengers; and
- b) Facilities subject to 33 CFR 105.295.
- USCG is still working to establish how/when all other facilities that were captured by the Final Rule language will have to comply with the TWIC Reader requirement; however, until then, facility inspectors should be socializing the above guidance for “on time” enforcement with industry.
USCG TWIC Handheld Reader Status
USCG is currently conducting technical evaluations of potential vendors for TWIC Handheld Readers. The current plan is once a vendor is selected, 250 readers will be issued out to the field. The current projected award date is late March to early April with distribution out to the field shortly thereafter.