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

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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?

Future Merchant Mariner Credential?

With the mandatory imposition of the TWIC, we heard some discussion about the future of the Merchant Mariner Credentials. Credentials are Licenses (like 100 ton or OUPV), Certificates (like STCW), Endorsements (like Radar), and the like. Basically, a Credential gives you the authority to preform certain duties, or proves your proficiency in training for certain tasks. Vessels can be documented, but a vessel's document is not a Credential. Merchant Mariner Documents (MMDs), on the other hand, are Credentials. Got it?

The USCG has been contemplating combining all your credentials into one place, and an idea that is gaining traction is a "passport" style booklet.

I got the monthly performance update from the Nat. Maritime Center, which you can see here. The update is just 16 page powerpoint style PDF that has lots of charts and nonsense that amounts to some self-congratulations on the part of the NMC.

Even a blind squirrel roots up an acorn once-in-awhile. On page six I found this very interesting little picture, a copy of which you see here. The graphic implies that this passport style Merchant Mariner Credential is the product of the NMC credential center. A sign of things to come?

You saw it here first (unless you saw it someplace else already...)

Upside: this will be much easier to carry around than the current 8x10 license.

Reduced TWIC fees for Recent License Renewals

Did you know that if your current USCG license was issued after Jan 13, 2006, you're eligable for a reduced "security threat assessment"?
From the TSA TWIC page FAQs:

A reduced fee of $105.25 will be made available for applicants who will not require the security threat assessment. The reduced fee is available for the following:
>applicants who hold a Merchant Marine License (MML) issued after January 13, 2006.

For those applicants seeking to pay the reduced fee, they must present their HME, FAST card, MMD, or MML (meeting the requirements outlined above) at the time of enrollment.

Now, aren't you glad you subscribed to Red Right Returning? This might save you $27.25!

A Very TWICilicious Page

Maybe I'm spending too much time surfing the net, but I can't believe how much BS and just plain bad information is running around concerning the requirement for a Transportation Worker Identification Credential (TWIC). I put together all my links and research onto a single webpage: Doug's TWICilicious Page. Most of my readers are up to speed on this, but feel free to spread this link around to anyone who might make use of it.

License Creep

Are you aware of the concept of license creep? When you renew your USCG license, the new license will expire exactly 5 years from the date of issue of the renewed license. So, if you renew 5 months before your current license expires, you will loose 4 or 5 months of the fee you paid when you got the previous license. If you are on your 4th or 5th renewal, you may have lost over a year's worth of user fees.

Say you got your first license on January 1, 1980. You would have been required to renew in '85, '90, '95, 2000 and 2005 to be current today. So, you should be on the 6th issue of your license. But, if you always tried to be a good scout and renewed 6 months early each time, you would actually already be on your 7th issue rather than your 6th.

Here is the deal: you pay about $100 in fees to get a 5 year license, but you can only use all 60 months of that if you wait to the very last day to renew. Over the course of your career, you end up getting cheated, because you're paying fees based on a 60 month renewal cycle, but you are forced to "surrender" some of those months when you renew.

Well, the Coast Guard calls this license creep. They recognize that it happens, and they have put in place system to keep it at a minumum. Here is a link to the official Policy Letter that explains to the REC how to deal with the problem.

http://www.marinecompliance.org/downloads/Oct2003/NMC%2016721%20Policy%20Letter%2009-03%20Credentials%20Validity.pdf


When I renewed in December, I asked about this issue, but I didn't have this Policy Letter in hand, and the license examiner didn't seem to know anything about this policy and just kinda shrugged his shoulders and said "too bad"...

If your renewal is coming up, print this out and request "delayed issuance" of your next license.