Tuesday, February 17, 2009

TWIC Final Notice

I think we're all up to date, but the deadline nears....please pass this on to all the hold-outs and doubters out there who still don't think they need a TWIC.
TWIC Information Bulletin Feb 2009

There is still one thing missing from all the notices disseminated by the USCG so far: what is the penalty for non-compliance? I have yet to see a single, definitive answer as to what they will actually do if they discover that you hold a credential and didn't get a TWIC. Will they suspend your license? Will they revoke it for life? Will they just tell you to get a TWIC and don't ever do that again?

Look, if they are going to set a deadline, fine. But shouldn't a deadline include some sort of ultimatum - a consequence for not meeting the deadline? "You do this by this date, or else!" Hello? Would someone at the USCG please tell us the consequence for blowing off the April 15th deadline.

So far, the only thing I've seen in writing is what is actually in the CFRs: (46CFR10.113)
Failure to obtain or hold a valid TWIC may serve as a basis for suspension or revocation of a mariner's license, COR or STCW endorsement under 46 U.S.C. 7702 and 7703.
Failure may serve...or... maybe not? Furthermore, 46USC7702/7703 could be interpreted as only applying if you were acting under the authority of your license. Not a single TWIC bulletin or memo from the USCG ever mentions that loophole when stating the policy of mandatory TWIC by the deadline. They all say holding, not using. Big difference.

Here is what's got my barnacles all bunched up; I think that guys who missed the deadline should suffer some consequences beyond just having to go get a TWIC. I think the USCG should issue a written policy that says so. Something like this: All mariners who failed to meet the TWIC deadline will have their credentails automatically suspended for one year. Is that so hard to say?