Thoughts and observations by Sareth Neak, Publisher of Maritime Security Outlook
I got a chance to skim through the 256 pages of the TWIC NPRM and got a very good summary from a very reputable friend and I find that there are many flaws. This post is to have you scratch your heads and that's really it. From the grouping of the users to the reader providers, there are a lot to discuss here.
If you have the time and are truly impacted by the TWIC rules, please click here to read the full NPRM.
I spent three hours reading the NPRM a few weeks ago and I still have a headache from it. I've spoken to a number of folks since then that are directly affected by this and learned that as the new rules actually takes a lot of weight off some of their shoulders, it ignores some of the real risk and vulnerabilities in some of their facilities.
This new rules focuses too much on the type of cargo, number of passengers and number of TWIC carrying crew members (of vessels), but it ignores the fact that some of our group B and C guys are high risk facilities due to the impact a disruption or attack on their facility has to commerce and national security. Isn't that the true goal of terrorism, to disrupt our economy and or cause mass casualty? Have we forgotten about the term soft targets?
The issues raised by the NPRM can be discussed without a repeat of one topic over the course of a week minus one day furlough. From the classification of the Groups, to the specification of reader technology or lack thereof.
When writing your comments to the NPRM, let's think about the possiblity of your facility being a soft target in Group B or C? Or you can say, this new NPRM will take the burden off us to scan every badge and just leave it alone. It's up to you.
Lastly, I want to throw another fighter into the ring. TWIC reader manufacturers and integrators have spent millions of dollars in R&D and business development over the last five years to get a piece of the action. The new rules have just swiped away 70% of their potential market. There are no rumblings yet that I have heard, but it is coming.
Agree or disagree, write me at This email address is being protected from spambots. You need JavaScript enabled to view it.
