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TWIC Escorting Policy

In accordance with 33 CFR 101.514, all persons requiring unescorted access to restricted access areas of Alabama State Port Authority (ASPA or “the Authority”) facilities must possess a Transportation Worker Identification Credential (TWIC). A TWIC must be obtained via the procedures established by TSA in 49 CFR Part 1572.

Persons seeking access to ASPA facilities who do not possess a TWIC may only enter ASPA facilities with an ASPA approved TWIC escort as a side-by-side companion. Each approved TWIC escort will be allowed to escort a maximum of five (5) individuals at any one time.

Persons who are granted escort privileges must possess a valid TWIC and a valid ASPA escorting credential and must be sponsored by their employers to serve as TWIC escorts within ASPA restricted access areas. Such persons must be direct full-time employees of the employer submitting the nomination, and may not be nominated by more than one employer.

The employer must submit the application for escort privileges on electronic forms supplied by the Authority and the sponsoring employer must agree to accept all responsibilities for sponsored employees meeting the requirements of TWIC related to restricted access areas and agree to accept any fine or liability imposed upon ASPA by the U.S. Coast Guard, or other federal entities, for failure of such employees to fulfill those responsibilities.

TWIC escorting privileges are granted at the sole discretion of the Authority, for a period determined by and at the sole discretion of the Authority, and the Authority reserves the right to deny granting escorting privileges or to suspend, revoke or deny renewal of escorting privileges previously granted, as follows:

  1. Submittal by an employer or nominated applicant of false or misleading information
  2. Failure to adhere to the policies, rules and regulations of the Authority or other applicable federal, state or local laws and regulations, including, but not limited to
    • Any attempt to gain entrance to the Authority’s facilities, or restricted areas within its facilities, through fraud or deception
    • Any attempt to bypass established entry points
    • Use or attempted use of a credential issued to anyone other than the approved TWIC escort, or loaning of an approved TWIC escort credential to another person
    • Failure to perform escorting duties in the manner prescribed in this policy
  3. Submittal by an approved TWIC escort of false or misleading information or refusing to cooperate in a security-related investigation
  4. Conviction of an approved TWIC escort of any offense for which he or she would have initially been denied approval in accordance with the policies of the Authority
  5. Failure to present a TWIC upon request or loss of TWIC privileges, or
  6. An employer no longer meets the criteria under which its eligibility was initially established or an approved TWIC escort leaves the employment of the company for which escorting privileges were approved.

The following employers are eligible to sponsor their direct full-time employees and apply for TWIC escorting privileges for such employees:
  • Tenants leasing land, buildings or office space within ASPA restricted access areas;
  • Steamship agents who are licensed by ASPA;
  • Companies who are licensed by ASPA to provide transportation services for such ASPA licensed steamship agents or tenants;
  • Class I railroads who provide direct service to ASPA facilities;
  • Companies who have been licensed by ASPA to provide guard services;
  • Regulated public utilities providing services to the Authority or tenants leasing land or buildings within the boundaries of ASPA restricted access areas;
  • ASPA employees designated by the Authority, and
  • ASPA police officers as described in ASPA GCI tariff item number 203.

Each sponsoring tenant, licensed steamship agent, licensed transportation company, licensed guard service or public utility may nominate a maximum of five (5) direct full-time employees for TWIC escort privileges. Requests for additional nominations by eligible sponsoring employers will be considered on a case-by-case basis.

No person may act as an escort until such person has been approved by ASPA and has met the training requirements listed in 33 CFR 105.215, (Security training for all other facility personnel). Specifically, escorts must have knowledge of ASPA escorting procedures, and the procedures and contingency plans determined by the Authority if an escorted individual is engaged in activities other than those for which escorted access was granted. View the ASPA TWIC Escort Training Presentation (PDF) >>

Approved TWIC escorts may escort a maximum of five (5) persons who do not possess required ASPA credentials and must receive permission to enter port property at the appropriate access point and apply for visitor’s access credentials for escorted persons at the Port Authority Police Department or at designated access control facilities at the Authority’s McDuffie Coal Terminal or Middle Bay Port property. Such escorted persons must be logged into the custody of the approved TWIC escort by port security officers upon arrival and logged out by port security officers upon departure from restricted access areas.

Approved TWIC escorts must possess a working cellular telephone while engaged in escorting duties in restricted access areas and must immediately report loss of side-by-side contact with escorted individuals, or any suspicious activity engaged in by such escorted individuals, to ASPA port police officers at 251-441-7777. Hand-off of escorted persons to a second TWIC escort is not permitted. The approved TWIC escort will not be relieved of custody and responsibility for escorted persons until such persons have been properly released from his or her custody by port police officers.

Vehicles used to escort non-TWIC holder driven vehicles must have appropriate TWIC Escort magnetic placards affixed to the driver and passenger side doors of the vehicle. Placards must be 12” X 24” with the company name and “TWIC Escort Vehicle” in red letters on a white background. Vehicles that do not have the required signage may not be used for escorting.

Written requests for exceptions to the size and placement of placards may be granted on a case-by-case basis for vehicles that cannot meet the standard requirements. Those requests should be addressed to ASPA Police Chief Jimmie Flanagan at jflanagan@asdd.com.

Requests to visit with ship’s officers or crew, by individuals who do not possess a TWIC and an ASPA ID, should be referred to the Port Authority Police Department, or designated access control facilities at the Authority’s McDuffie Coal Terminal or Middle Bay Port property, and such persons must be escorted side-by-side from a designated access point to the vessel and from the vessel to a designated access point by an approved TWIC escort.

Vessels that have a Coast Guard Approved Security Plan – The TWIC escort must transfer responsibility for the escorted person to the custody of the ship’s Vessel Security Officer (VSO) or his/her alternate using the Transfer of Visitor Custody Form, which must be signed by the VSO and returned to ASPA security officers at the access point through which entrance was gained by the visitor and TWIC escort.

Persons who have been transferred into the custody of a VSO may only depart the vessel and transit ASPA facilities in the custody of an ASPA approved TWIC escort who must log the visitor out at a designated ASPA access point.

Barges and Vessels that do not have a Coast Guard Approved Security Plan – The TWIC escort must remain with the escorted person as a side-by-side companion for the duration of the visit. Hand-off of escorted persons to crew members of such vessels or a second TWIC escort is not permitted except as noted below:

  • If the visitor remains on such vessel more than eight (8) hours, the TWIC Escort may transfer custody of the visitor to another ASPA approved TWIC escort by returning to the access point through which entrance was gained by the visitor and the TWIC escort and logging the visitor into the custody of another ASPA approved TWIC escort

Crew members that do not possess a TWIC and an ASPA ID, who wish to disembark from the vessel while at berth, must be escorted side-by-side from the vessel to a designated access point or from a designated access point to the vessel by an approved TWIC escort.

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 maintenance, read load lines, load stores, etc.). Such mariners will be permitted limited access to the area immediately adjacent to their vessels without escort.

The following definitions explain terms used in this policy:

Possess means to have physical custody of a credential and to present the credential for inspection when seeking access to restricted access areas.

Restricted access area means any area located within the boundaries of ASPA regulated facilities which the Authority has designated as a restricted area and has posted signage identifying such areas as restricted areas.

Authorized access point or designated access control facility means a designated entrance/exit location, manned by ASPA police officers or contract guards, through which access to ASPA facilities is normally gained.

Approved TWIC escort means an individual holding a valid TWIC and a valid ASPA escorting credential who has been approved by ASPA to escort non-TWIC holders on ASPA premises.

Escorting means ensuring that the escorted individual is continuously accompanied while within ASPA facilities in a manner sufficient to observe whether the escorted individual is engaged in activities other than those for which escorted access was granted.

ISSUED: October 30, 2008   REVISED: August 16, 2010
EFFECTIVE: December 30, 2008   REVISED: August 15, 2011

ASPA TWIC Escort Policy FAQ

Q: Is it a USCG/TSA policy that you have to be certified to be an escort? Or is this an ASPA policy?
A:
USCG does not require regulated facilities to allow escorting, but if facilities do allow it, the regulations require that TWIC escorts meet training standards established by the Coast Guard. Further, the Coast Guard has emphatically stated that they will hold the regulated facility responsible for the failure of escorts to maintain required escort standards. ASPA could be subject to fines of up to $35,000 per incident per day for allowing improper escorting on our facilities.

Q: Are you all going to have a class that the escorts will attend? Or do we have to train ourselves?
A:
Our draft policy places the responsibility for training escorts on the sponsoring company, but we can look at providing some kind of assistance if folks think it would be helpful.

Q: When will we be able to send the sponsorship request for authorized escorts to you?
A:
We will send out a final version of the policy after everyone has had a chance to review it and offer comments. Requests can be submitted then.

Q: How will sponsorship requests be submitted?
A:
The Application for TWIC Escort Sponsorship will be posted on the ASPA website in the Security Information section as “TWIC Escort Application”. Companies whose name appears on the drop-down list should complete an application form for each sponsored employee and submit it to fso@asdd.com.

Q: How long will it take to be approved as a TWIC escort?
A:
A sponsoring employer must submit an application for a TWIC escort at least seven days prior to assigning the employee to escort duties, but the employee can not engage in escort duties until they have received their ASPA escort credential.

Q: If you are certified to be an escort in Mobile, will you be allowed to escort in other ports?
A:
Each regulated facility will establish its own escort policy. The draft policy we have distributed is strictly an ASPA escort policy.

Q: How long will the escort credential be valid?
A:
The initial escort credential will be valid for the same period of time as the applicant's current credential or one (1) year, whichever is longer.

Q: Can I get an ASPA escort credential if I don't have a TWIC?
A:
No, you must have a valid TWIC to receive an escort credential and you must be sponsored by your employer. Authorized employers will submit TWIC escort applications on behalf of their employees.

Q: Why do I have to get an ASPA escort credential; can't I use the TWIC card if my employer approves me as an escort?
A:
USCG regulations allow a facility owner to use their own facility specific card as their access control measure, as long as they ensure individuals without a TWIC cannot gain unescorted access to restricted areas and the TWIC is checked at least once before the specific card is accepted or reissued. ASPA has elected to use its own access control and escort credentials for reasons stated in the answer to the first question on page one.

Q: The policy states that a sponsoring employer must agree to accept fines imposed by federal authorities if sponsored employees fail to meet Coast Guard requirements for escorting. What kind of fine is possible?
A:
Coast Guard regulations allow for a fine of up to $35,000.00 per incident per day.

Q: Is there a fee for sponsoring an employee?
A:
No, there is not a fee for sponsoring an employee. There is a normal credential fee of $25.00 when a credential is first issued or when it is renewed.

Q: According to the policy, mariners are exempt from the escort requirement while engaged in normal operations in support of the vessel. Would meeting a chandler at the gate or delivering ship's papers to port police be considered normal operations in support of the vessel?
A:
No, the key phrase here is limited access to the area immediately adjacent to their vessels, Mariners are only permitted unescorted access while performing the kinds of activities mentioned in the policy.

Q: How do you become licensed as a transportation company?
A:
Please refer to the ASPA General Cargo & Intermodal (GCI) tariff item 203b for information. Applications are available at the GCI office.

Q: Is there a charge for a transportation service license?
A:
Yes, there is a licensing fee of $500.00, payable with the application and an annual renewal fee of $250.00.

Q: Currently over-the-road drivers, who have a valid Commercial Driver's License and proper cargo documentation, are granted unescorted access to port facilities. Will this change when the TWIC is required?
A:
Yes, drivers who do not have a TWIC will have to 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.

Q: Does side-by-side mean in the vehicle or could an escort vehicle be used?
A:
ASPA will allow either method as long as the requirements of escorting as defined in the policy, are met.

Q: How many vehicles can an escort be responsible for?
A:
Each TWIC escort may only escort one vehicle at any time, whether in the vehicle or in an accompanying escort vehicle.

Q: The policy states that each TWIC escort can escort a maximum of five individuals at one time. Does that apply if they are in a bus or van?
A:
The one to five escort ratio is applied when escorts are on foot or outside of a vehicle. One TWIC escort may escort the seating capacity of a vehicle, but the escorted individuals must remain in the vehicle at all times. Example – If the seating capacity of a van is 10 people, one TWIC escort can escort 9 people (9 persons + escort = seating capacity). But if the passengers disembark from the vehicle, a second escort would be required to satisfy the 1-5 ratio.

Q: Will utility company service technicians be required to have a TWIC?
A:
Yes, all persons, except those specified in the policy, must have a TWIC or an escort.

Q: Will FedEx and UPS drivers have to have a TWIC?
A:
Yes, all persons, except those specified in the policy, must have a TWIC or an escort.

Q: Are we open to allowing passage to a worker who can demonstrate proof of applying for the credential? That may add some capacity for our needs. It's not a problem solver but will give some consideration to this quagmire.
A:
Coast Guard regulations do not provide for a "proof of having applied for a TWIC card" exception. You either have a TWIC or you must be escorted.

Q: The policy states that you will need a TWIC by December 30th to have unescorted access. If you have applied for an escort credential but haven't received it yet, will you be able to escort on December 30th?
A:
No, December 30th is the implementation date for both the TWIC and the escort credential.

Q: The Assistant USCG Commandant for Marine Safety, Security and Stewardship recently sent a message to Captains of the Port stating that they should encourage, support, and facilitate vigorously any accommodations at regulated facilities, including but not limited to escort provisions, to make shore leave and access to seafarer welfare organizations possible. These accommodations should not impose an undue burden on 3 the seafarer or seafarer's welfare organization representative seeking access by way of exorbitant fees, extreme limitations in hours of availability, or other unreasonable restriction to the movements of these persons unless exigent, confirmed security concerns dictate such restriction is necessary, Does the ASPA escort policy comply with this directive?
A:
ASPA is well aware of this Coast Guard message and we believe our policy complies both in spirit and letter. We are making access available through escorting and are not imposing exorbitant fees or restricting hours of access. Seafarer's welfare organizations can obtain escort credentials at no cost and provide escort services to crew members at no cost if they desire. Vessels can also require their agents to provide these same services as a part of their husbanding duties.

Q: The policy mentions in accordance with 33 CFR 101.514; however, the policy goes beyond that by basically forcing foreign seamen, who cannot obtain and/or are not required to obtain a TWIC, to find a willing approved escort or pay an ASPA employee a minimum of $40/hour for escorting. Many seamen would simply not go ashore or be able to afford to pay what would amount to an extra $80 to go shopping ($40 in and $40 out). If I understand properly they will also be unable to use the pay phones without an escort and I find it hard to understand how this might increase security as they come in on a foreign vessel and if they have the credentials (landing permit) to go ashore have been vetted by our Federal Government.
A:
The Coast Guard specifically exempted 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 maintenance, read load lines, load stores, etc.) from the escort requirement. Such mariners will be permitted limited access to the area immediately adjacent to their vessels without escort, but all other shore activities will require an escort and USCG regulations require that TWIC escorts meet training standards established by the Coast Guard. Further, there is no requirement to use an ASPA escort and we simply don't have the manpower to escort everyone who arrives at our gates or docks without a TWIC. As we have stated above, there are available options for seamen who wish to disembark from their vessels.


 




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