Editorial: Making TWIC Not A Walk In The Park

A comment about “temps” being hired as trusted agents to work in the enrollment centers to handle of Transportation Workers Identification Cards (TWIC) sent us to the Internet and telephone. Our first impulse was to question why temporary workers were to be placed in such critical jobs. The deeper we dug, the more we realized “temps” should not be our focus. Instead, the best way to serve readers is to provide critical information about TWIC.

To put this into perspective, we need to remember that it all started after September 11, 2001, and is in the hands of the Department of Homeland Security (DHS), of which the Coast Guard is a part. DHS is responsible for the entire nation, not just the marine industry. The task has never been just a walk in the park. It is extensive and complicated.

To provide some idea as to the immensity of this undertaking, we can say that by going to Google, one can find more than 208,000 entries on the subject. These entries date back to earlier news accounts wherein critics said data on TWIC cards wasn’t (or wouldn’t be) safe, to Department of Homeland Security progress announcements. In July 2006, the Electronic Privacy Information Center cited a DHS Inspector General’s report, highlighting the opinion that there was inadequate security to protect against unauthorized access to confidential data.

“Due to the number and significance of the weaknesses identified, TWIC prototype systems are vulnerable to various internal and external security threats,” the report said.

Many early complaints were not substantiated, because the hardware to read TWIC cards had not been (and is not yet) developed. Published on September 11, 2007, was the 45-page TWIC Reader Hardware & Card Application Specifications.

Some TWIC enrollment centers have opened, some are opening, and others will open. Details about where to find this material will be provided later in this editorial. The site will give examples of some data that may cause application rejection.

More to the point, mariners on boats are not required to have TWIC cards until September 25, 2008. At marine facilities, it is up to the captain of the port to decide when the securing of TWIC cards has progressed sufficiently to post a 90-day deadline notice informing workers the requirement is in force. Workers in both venues are encouraged to begin the process as soon as they can get to an open enrollment center.

The TWIC, according to DHS, will be “a smart card (i.e., a card with a small integrated circuit chip imbedded in the card), and will contain the following technologies: Dual Interface Integrated Circuit Chips (ICC)—a small computer chip that can be read by either inserting the card in a slot in a ‘contact’ card reader or holding the card within 10 centimeters of a ‘contactless’ card reader; and Magnetic Stripe—commonly found on the back of credit cards, read by ‘swiping’ the card through a magnetic stripe card reader Linear Bar Code—commonly used to quickly identify items by scanning the codes with an optical reader—i.e. scanning grocery items at a checkout counter.”

Why are they beginning to issue cards when the reader is not ready? The Coast Guard explains that an important part of security has been achieved by the time the cards are ready for issuance. At this point the background checks have been completed and some potentially bad risks have been eliminated. Will the results of the threat assessment be shared with the applicant’s employer? The TSA Web site reveals that if TSA determines an applicant poses an imminent threat to transportation or national security, TSA may notify the applicant’s employer. “Generally, TSA will not provide the reasons for a disqualification to an employer. However, if TSA has reliable information concerning an imminent threat posed by an applicant and [if] providing limited threat information to an employer, facility, vessel owner, or Coast Guard Captain of the Port would minimize the risk, then TSA would provide such information.” (Emphasis ours.)

Until card readers are required, the TWICs will be used as a visual identification badge or “flash pass.” An individual will present his/her card, and the checker will match the photo to the person presenting it, verify that the card has not expired, and check security features to verify that the card has not been forged or tampered with.

The complicated TWIC program requires special contractors who deal in security issues. The DHS has contracted with Lockheed Martin, which also subcontracts to Deloitte, which is a leading provider of identity and access management services and solutions. A prime contractor in the overall homeland security field is BearingPoint. Senture, another security company, has been subcontracted to help BearingPoint deploy and support their global turnkey security identity management solution as part of Homeland Security Presidential Directive (HSPD).

TSA and the Coast Guard are responsible for implementing the TWIC program. TSA is to keep the industry informed, selecting and staffing enrollment centers, processing applications and issuing TWICs. The Coast Guard’s role is to enforce compliance and help industry comply. It will conduct spot-check and annual inspections, review and approve security plans, and work with TSA toward successful integration.

As to the cost of TWICs, estimates vary so much that we believe accuracy is at risk. It is law that the employer is responsible to provide TWIC information to his employees. However, those with access to the Internet can go to: http://homeport.uscg.mil. On the right side of the page is a list that includes TWIC. Click on it. When the new page emerges, scroll down to the “Outreach Resources” subhead. Beneath it are several links. One provides information about the “Transportation Worker Identification Credential Program.” Another is the “Small Entity Guide for Owners and Operators.”

The TWIC program’s director at DHS, told Government Executive.com in October, “This is one of the world’s most advanced, biometric-enabled programs, with more than a million workers expected to enroll over the next year.” Director Maurine Fanguy, responding to a question about the five years it has taken thus far to develop the program, said, “For a program of that size and scale, we wanted to make sure we checked [the system].”

It certainly has not been a walk in the park.

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