This morning, my good friend, and renowned blogger, Dennis Bryant reported that the Office of Management and Budget (OMB) had erred when it posted that it had received for “regulatory review” a US Coast Guard proposed rule on card reader requirements for the Transportation Worker Identification Credential (TWIC). What the USCG had actually sent OMB was “a proposed policy letter providing guidance on voluntary use of the TWIC reader.” Dennis reports that the OMB posting has been corrected, but I can only find the original version and the proposed rule is still listed on January 18th tally of Executive Order Submissions Under Review.
Dennis has excellent sources in both government and industry, so I conclude that my previous post lauding the apparent speed up in developing the TWIC Reader Requirements Rule was off base. If something’s too good to be true, it probably isn’t. One of the reasons the rule has been delayed repeatedly is to allow the incorporation of the results of the pilot test of TWIC readers being run by the Transportation Security Administration (TSA). TSA hasn’t said much recently about the pilot test, which involves facilities and vessels in five ports and vessel operations in four more areas. The last word on its progress, of unknown vintage, was: “The EOA [Early Operational Assessment] commenced in 2008. Full production testing, System Test and Evaluation Phase began at some facilities in 2009. Some facilities have completed both EOA and ST&E phases while others are not expected to complete before early in 2011.” Presumably, once the test is complete, the data will have to be massaged in order to develop conclusions that can inform the proposed TWIC reader rule. (I don’t know how the readers have held up in the test, but I have heard that lots of people have had to replace their TWICs (at their own expense) well before their five-year expiration, because the cards have broken down.)
If the Coast Guard is to ensure meeting the most recent official estimate of November 2011 for issuance of the Notice of Proposed Rulemaking, it will have to get its proposal in to OMB by the end of August. NOTE: This post may be copied, distributed, and displayed and derivative works may be based on it, provided it is attributed to Maritime Transportation Security News and Views by John C. W. Bennett, http://mpsint.com
