b'COAST GUARD NEWS:MSIB: Exemptions to TWIC requirements COAST GUARDrelated to COVID-19Update (Change 3)T heuninterruptedfl ofcommerceRule implementation date of June 7, 2020,areas will not be enforced during the COVID-19ow on our Marine Transportation Systemforfacilitiesthatreceivevesselscertifi catedpandemic. Additional compliance options for new (MTS)iscriticaltobothnationaltocarrymorethan1,000passengersandhires can be found in 33 CFR 104.267 and 105.257securityandthenationseconomicwell- vessels certifi cated to carry more than 1,000or via noncompliance (discussed below).being.Duringthisnationalemergencyforpassengers.However, theCoastGuard COVID-19 it is paramount that the U.S. CoastwilldelayenforcementuntilJanuary1,AlternativeSecurityProgram(ASP) Local Guard safeguards the continued operation of2022. Applicablefacilitiesandvesselsareusers who are unable to comply with the requirements the MTS to ensure our domestic supply chainnot required to update facility security plansin an approved ASP may pursue temporary relief via continuesuninterrupted.Theregulations(FSP)/vesselsecurityplans(VSP)orinstallnoncompliance (discussed below) or an amendment outlinedthroughout33and46Codeofreaders until the revised enforcement date. canbesubmittedtocovertheentireASPvia FederalRegulationsremaininforce,andsubmission to CG-FAC.maritime operators are expected to continueEscort Ratios Escort ratios for secure and to comply with these requirements. However,restrictedareasofafacilityareprovidedinNoncompliance 33 CFR 104.125 and 105.125whencompliancewiththeseregulationsNavigation and Inspection Circular (NVIC)discussesnoncompliancewithfacilityandvessel cannotreasonablybemetasaresultof03-07. To provide fl exibility due to COVID-19security requirements. If a situation arises where a COVID-19,theCoastGuardwillexerciserelated health impacts, the escort ratio may befacility or vessel will not be able to comply with the fl topreventunduedelays.Theadjusted to meet employee shortages or otherrequirements of 33 CFR parts 104 or 105, they mustexibility followingclarifi cationisprovidedregardingdemands.Thiswouldconstituteachangecontact the Captain of the Port (COTP) to request theTransportationWorkerIdentifi cationtotheFSPorrequireCaptainofthePortand receive permission to temporarily deviate from Credential (TWIC), which is jointly managedapproval via noncompliance (discussed belowthe requirements. While not discussed in 33 CFR by the Coast Guard and the Transportationand in MSIB 07-20). 104.125 or 105.125, the vessel or facility operator SecurityAdministration(TSA).TSAmayshould evaluate and consider any safety risks that may grantatemporaryexemptionfromcertainNewHires Afterenrollmenthasbeenbe created from the noncompliance. This request to requirementsin49CFRpart1572forcompletedandanewhirehaspresentedcontinue operations should include new measures theexpirationoftheTWICforcurrentanacceptableformofidentifi cationper33or safeguards the facility or vessel plans to employ to cardholders. If this occurs the Coast GuardCFR 101.515(a) to the vessel security officermitigate any risk from the non-compliance with 33 will take these exemptions into consideration. or facility security officer, that new hire mayCFR part 104 or 105.be allowed access to secure or restricted areas MARITIME FACILITIES & VESSELS whereanotherperson(s)ispresentwhoMERCHANT MARINER CREDENTIALSTWICReadersthe Coast Guard is notholdsaTWICandcanprovidereasonableThe Coast Guard is providing fl exibility with regard changingordelayingtheTWICReadermonitoring.Theside-by-sideescortingto requirements to have a TWIC when applying for requiredin33CFR101.105forrestricteda credential or when serving under the authority of a credential. To date, the processing of submitted TWIC enrollments has not been impacted by the 4519-DCT Passenger Ferry COVID-19 crisis, and there is no delay in vetting, COI 49 passengers + crew card production, and issuance. However, TSA and the Coast Guard recognize that this is an evolving Formerly Armstrong Marine USA publichealthsituationandenrollmentcenters closures or processing delays will impact applicants foramerchantmarinercredential(seebelowfor more on TSA enrollment centers).Under the 46 CFR 10.203(b), failure to hold a valid TWICmayserveasgroundsforsuspensionor revocation of a merchant mariner credential (MMC). The Coast Guard will not pursue any suspension andrevocationactionsbasedonexpiredTWICs during the COVID-19 pandemic. The Coast Guard will update industry prior to reinstating enforcement ofthisrequirement.Thisenforcementdiscretion for expired TWICs does not apply to cases where a mariners TWIC has been suspended or revoked due Raising the Standards for Passenger Vessels to a determination that they are a security threat. In sales@brixmarine.com | (360) 457-5752 | www.brixmarine.com Continued on page 46COAST GUARD44 FOGHORN'