| 31 January 2012
The TWIC program began with Congress passing “The National Maritime Security Act” in 2002. The TSA and Coasties required all Merchant Marine license holders to obtain a TWIC under the guise of “security” for the maritime industry. However, the Coast Guard Authorization Act of 2010 exempted mariners on vessels not required to have a “security plan” (generally vessels carrying less than 150 passengers) from the TWIC requirement. That exemption was also in the original Congressional Act that authorized the TWIC, but because the Coasties didn’t know how to identify vessels without “secure areas” and written “security plans” they forced all licensed mariners to get a TWIC by April 15, 2009.
I questioned the logic of the TWIC and Captain Mark O’Malley, Chief of Port and Facility Activities in his letter to me of March 22, 2007 said: “The Coast Guard is aware that this statute affects the licensed masters of several small passenger vessels. Although these licensed masters may not need to use their TWIC to gain access to their vesselsthey will be required to possess the credential in order to apply for or renew their merchant marine licenses or documents.” I responded: “The tone of your letter confirms a lack of understanding by Coast Guard and NMC staff relative to what people are licensed by the Coast Guard. The lack of staff field experience is certainly a prime factor for the lack of comprehension of, and empathy for, the lower level licensed segment of the maritime industry.”Coast Guard Policy Letter No. 11-15 sent out on December 23rd clarified the “new” TWIC policy. “… mariners not serving on vessels required to have a Vessel Security Plan are exempt from the requirement to hold a valid TWIC. However, … the mariner must have completed the TWIC process at least one time… in order for the Coast Guard to process a credential application for a mariner who is not in possession of a valid TWIC the mariner must submit a statement indicating an understanding of the possible delays associated with processing the safety and suitability check and verifying that they do not require a TWIC…”
In plain English, that means that 6-PAK operators, including fishing guides, do not have to renew their TWIC in order to renew their license.
Click here to read the new policy letter from the Coast Guard.
Click here for a sample statement to include with your renewal.
-----------------------------------------------------------------------------------------------------
Captain Paul McElroy has been involved in licensing regulations for thirty years. He can be reached at This e-mail address is being protected from spambots. You need JavaScript enabled to view it or (772) 288-1066.
