TWIC IMPLEMENTATION ACCESS AND ESCORTING

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AAPA Port Operations, Safety and Information Technology Seminar TWIC IMPLEMENTATION ACCESS AND ESCORTING June 10,2009

STATUS OF ENROLLMENTS Mobile has the sixth highest number of enrollments of the 146 TWIC enrollment centers. 32,803 transportation workers have enrolled. 28,033 cards have been activated. Nationally, only Houston (95,833), Baton Rouge (57,439), NY/NJ (48,161), New Orleans (45,956), and Long Beach (38,129) have enrolled more transportation workers. TSA originally estimated the TWIC population for Mobile at 20,000; however 60-70 applicants continue to enroll every day.

OUTREACH ASPA began stakeholder outreach 8-9 months prior to the September 2008 implementation. The TWIC enrollment contractor was provided free space in our Executive office building. A dedicated parking area was reserved for TWIC applicants. 60 days prior to the TWIC implementation date a TWIC was required to renew or apply for an ASPA access credential.

OUTREACH Outreach activities consisted of: Meetings with port users. Distribution of flyers to port workers and arriving vessels. Hanging banners at port entrances. Regular email updates to the Mobile port user community. A series of surveys designed to measure compliance levels.

PRE-IMPLEMENTATION SURVEYS ASPA conducted five 24-hour trucker surveys over a five week period in October 2008. Truckers who did not have a TWIC were asked if they knew about TWIC and if they had applied for a TWIC. Daily number of trucks 349 88% of the truckers surveyed either had a TWIC or knew about TWIC. 66% either had a TWIC or had applied for the credential.

POST-IMPLEMENTATION SURVEYS ASPA conducted a second series of five 24-hour trucker surveys in February 2009. Truckers who did not have a TWIC were asked if they had applied for a TWIC. Daily number of trucks - 228 87% of the truckers surveyed either had a TWIC or had applied for a TWIC. 85% had received their TWIC.

SURVEY OF ALL WORKERS ASPA conducted ten full 24-hour surveys of all persons accessing our facilities from December 30, 2008 to January 8, 2009. 12,454 persons were checked 96.2% of those surveyed had enrolled. 93.1% had received their TWICs. 415 escorts were provided 115 persons were denied access (.009%)

ASPA REVISED ACCESS POLICY Who must have a TWIC and ASPA ID: All ASPA staff, tenants and their employees, surveyors, agents, stevedores, longshoremen, chaplains, contract labor, delivery persons, vendors, contractors, and temporary workers must have an ASPA issued photo ID badge. A valid TWIC must be presented to ASPA credentials officers to initiate the application process.

ASPA REVISED ACCESS POLICY Who does not need a TWIC and ASPA ID: Federal officials. However, a federal official must present his/her agency issued official credential. State or local law enforcement officials in the normal performance of their duties. Such officials must present his/her agency issued credential. Emergency responders at the State or local level. Such officials may be required to present his/her agency issued credential. Operators of over-the-road cargo vehicles, who present a valid TWIC, a valid CDL and proper cargo documentation, do not have to have an ASPA ID, but must remain with their vehicles at all times while on port property.

TWIC INFORMATION TWIC applicants can check to see if their credential has been received at the TWIC enrollment center by calling 251-441-1953 or emailing twic@asdd.com The ASPA Access Policy, TWIC Escorting Policy, TWIC Escort Application and TWIC Escort FAQs may be viewed on the ASPA website: www.asdd.com

ASPA TWIC ESCORTING POLICY All persons requiring unescorted access to restricted access areas of ASPA facilities must possess an ASPA ID and a TWIC. Persons who do not possess a TWIC may only enter ASPA facilities with an ASPA approved TWIC escort as a side-by-side companion.

ASPA TWIC ESCORTING POLICY Enclosure (3) to USCG Navigation and Vessel Inspection Circular (NVIC) 03-07 addresses escorting in restricted areas as follows: Escorting must be accomplished by side-byside accompaniment with a TWIC holder. Sideby-side accompaniment requires continuous physical proximity to and visual contact with the escorted individual in order to enable the TWIC holder to witness the escorted individual s actions.

ASPA TWIC ESCORTING POLICY Persons who are granted escort privileges must possess a valid TWIC and a valid ASPA escorting credential and must be sponsored by their employers. TWIC escorts must be direct full-time employees of the employer submitting the nomination, and may not be nominated by more than one employer.

ASPA TWIC ESCORTING POLICY The sponsoring employer must submit the application for escort privileges via an online form and must upload a color copy of the sponsored employee s TWIC. The sponsoring employer must agree to accept any fine or liability imposed by the Coast Guard for failure of its employees to fulfill escort responsibilities.

ASPA TWIC ESCORTING POLICY Who may apply for escorting privileges: Tenants leasing space within restricted areas Steamship agents licensed by ASPA Transportation services licensed by ASPA Guard services licensed by ASPA Regulated public utilities ASPA port police officers ASPA employees designated by the FSO

ASPA TWIC ESCORTING POLICY Each sponsoring employer may nominate a maximum of five full-time employees. No person may act as an escort until they have been approved by ASPA and have met the training requirements listed in 33 CFR 105.215. Escorts must have a working cell phone and knowledge of ASPA escorting procedures. Escorts must know what is required if an individual engages in activities other than those for which escorted access was granted.

ASPA TWIC ESCORTING POLICY One (1) approved TWIC escort may escort a maximum of five (5) persons on foot or the capacity of one vehicle. Truck drivers who do not have a TWIC must be escorted by an individual who holds a TWIC, and has been granted escorting privileges by ASPA, as a side-by-side companion for the duration of their visit. ASPA will allow escorting in the vehicle or with an escort vehicle, as long as the requirements of escorting, as defined in the policy, are met. Each TWIC escort may only escort one vehicle at any time, whether the escort is in the escorted vehicle or in an accompanying escort vehicle.

ASPA TWIC ESCORTING POLICY Escorted persons must be logged into the custody of the approved TWIC escort upon arrival and logged out upon departure. The TWIC escort will not be relieved of responsibility for escorted persons until they have been properly released from his or her custody by port police officers.

ASPA TRUCK ESCORTING PROCEDURES ASPA issues a Truck Escort Pass and assigns escorts at its Truck Control facility for all arriving cargo trucks that do not have TWICs. General cargo trucks proceed directly to the Main Gate with their escort and continue on to the destination designated by the receiving stevedore. Freezer trucks proceed without an escort to a designated holding area where they are met by an escort and continue to the Main Gate and on to the freezer facility. At the completion of loading/unloading, the escort accompanies the cargo truck back to the Main Gate and completes the releasing paperwork.

ASPA TRUCK ESCORTING PROCEDURES To further expedite cargo truck escorting when required, we have eliminated log in/log out procedures at the port police building for cargo trucks, and require it only for visitors, vessel crew, delivery vehicles, vendors, etc. All licensed Transportation Services, Guard Services and Cargo Handlers are authorized to escort cargo trucks at such reasonable rates as they may impose for their services. ASPA does not provide escorts for cargo trucks.

ASPA TRUCK ESCORTING PROCEDURES The following information is given to each non-twic driver at ASPA Truck Control: A Truck Escort Pass is issued at ASPA Truck Control for all arriving cargo trucks that do not have TWICs. General cargo trucks will proceed directly to the Main Gate with their escort and continue on to the destination designated by the receiving stevedore. Freezer trucks will proceed without an escort to the holding area at the south side of the Hope Overpass, where they will be met by an escort and continue to the Main Gate and on to the freezer facility. At the completion of loading/unloading, the escort will escort the cargo truck back to the Main Gate and complete the releasing paperwork. U.S. Coast Guard regulations require that escorting must be accomplished by side-by-side accompaniment and requires continuous visual contact by the escorting individual for the duration of your visit. You will receive a copy of the Truck Escort Pass when you depart the ASPA Main Gate and you should check to be sure information shown on the Truck Escort Pass is accurate. All ASPA licensed Transportation Services, Guard Services and Cargo Handlers are authorized to escort cargo trucks at such rates as they may impose for their services. ASPA does not provide escorts for cargo trucks. Your receiving stevedore has been authorized to provide escort services. Also, the following transportation and guard services have been authorized by ASPA to provide escort services: Alabama Line Services 251-661-2105 Alberts Transportation Service 251-432-1611 CPS/Eagle Maritime Security 251-433-7850 Dockside Transportation, Inc. 251-438-2362 MO-BAY Shipping Services, Inc. 251-433-1621 Seaport Security Services 251-443-7390 Operators of over-the-road cargo vehicles, who present a valid TWIC and a valid Commercial Driver s License with a recognizable photograph, and who possess proper cargo documentation, will be granted unescorted access to port facilities, but must remain with their vehicles at all times while on port property. You may obtain information about the Transportation Workers Identification Credential (TWIC) online at www.tsa.gov/twic or by calling 1-866- 347-8942. If you experience a problem with the ASPA escort procedures you may contact ASPA Port Police at 251-441-7777 or at 251-441-7200 for general information.

ASPA TRUCK ESCORTING PROCEDURES ASPA Logo Control Number ALABAMA STATE PORT AUTHORITY Truck Escort Pass Date Time Arrived at Truck Control Driver s Name Driver s CDL Number Trailer License Number Receiving Stevedore Escort Name Escort Company Escort Cell Number Time Escort Accepted Driver Escort Fee Charged Driver Departure Time ASPA Releasing Official I certify that escorting was accomplished by continuous side-by-side accompaniment and visual contact with the escorted driver during the time the escorted driver was in my custody. Escort (Signature) Yellow-Truck Control; Green-Escort; Blue-Driver; White- ASPA Releasing Official

ASPA TWIC ESCORTING POLICY Ship s visitors must report to the ASPA Police Department, and must be escorted side-by-side to the vessel and side-by-side from the vessel by an ASPA approved TWIC escort. Crew members, who do not have a TWIC and who wish to disembark from the vessel while at berth, must be escorted side-by-side from the vessel to any destination within ASPA facilities by an approved TWIC escort.

ASPA TWIC ESCORTING POLICY The TWIC escort requirements do not apply to mariners working immediately adjacent to the vessels they are employed aboard while in the conduct of normal operations in support of the vessel (e.g. attach shore ties, perform routine maintenance, read load lines, load stores, etc.). Mariners will be permitted limited access to the area immediately adjacent to their vessels without escort.

ENROLLMENT PROBLEMS A small number of our employees (about 1.5%) were required to make repeated trips to the enrollment center. For some of these employees, the enrollment process lasted 16 months. Employees did not understand the importance of remembering their PIN. There was a dramatic drop off in enrollments when implementation was pushed back to December 30, 2008.

IMPLEMENTATION PROBLEMS The Port of Mobile has a high non-union labor population. Many long haul truckers have not enrolled in the TWIC program about 30% still do not have TWICs. We were never able to utilize the USCG New Hire procedure; it did not work. Failure to require readers in conjunction with the TWIC roll-out led ASPA to decide to continue using its own credential.

ESCORTING PROBLEMS A few port users resisted the Escort Policy: Pressure from unapproved companies for escort privileges. Requests to allow longshoremen to escort other longshoremen. Requests to allow hand-off of escorted individuals. Requests to escort multiple trucks. Requests to allow escorting for contractors.

CREW MEMBER ACCESS Vessel owners and agents are unfamiliar with USCG regulations and blame the port for crew access restrictions. Some crew members are not aware of the restrictions to shore access. Many crew members who wish to go ashore have not been informed of the free escorting services available to them. City merchants do not understand that the Coast Guard has imposed crew access restrictions.

TWIC IMPLEMENTATION QUESTIONS? Hal Hudgins Alabama State Port Authority 251-441-7237 hhudgins@asdd.com www.asdd.com