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Government Update issued. The TSA now estimates that issuance can be accomplished in as little as 30 days. In addition, the agency is looking into allowing new workers temporary access during the processing period. Federal law requires that rulemakings consider and minimize adverse impact on small businesses. In addition, common sense dictates that small businesses such as whale watching boats present less risk to national security than do large ships engaged in international commerce. The proposed rule, though, makes no distinction between big and small business. The GAO report states that the TSA now plans to obtain additional comments on the small business impact as part of its rulemaking regarding installation and use of TWIC card readers. In other words, the workers at small facilities and vessels will have to obtain (and pay for) biometric cards, but the small facilities and vessels may not have to purchase the readers to make the cards effective. Am I missing something? The TSA is assigning much of the blame for problems during prototype testing to the political mandate it faced to accelerate the program. It reassured the GAO that this will not occur when the system is actually implemented. The GAO is not so easily taken in. It notes that the TSA is now being directed by the DHS (and Congress, but the GAO omits that element) to deploy the TWIC program immediately. The TSA has publicly stated that it will move forward rapidly, at least with issuance of the TWIC cards. The GAO cautions, though, that poor planning got the program into trouble before and is likely to do so again. It recommends that none of the TWIC program be deployed until problems identified in prototype testing and during the comment period are resolved. In its official response to the GAO report, DHS states that it concurs with the recommendations. It then states that DHS and TSA will continue implementation of the TWIC program as scheduled. My thoughts return to Halloween -- or maybe the Charge of the Light Brigade. For more information firstname.lastname@example.org Dennis L. Bryant, Senior Maritime Counsel at the law firm of Holland & Knight, Washington, D.C., is a contributing editor of MR/EN. Contact Dennis at email@example.com Atlantic Cordage is now the exclusive distributorof "Defiance" brand of marine products offering high strength fiber rope, including mooring lines, wire ropes, and heavy marine towing hardware. One call gets you quick delivery to any port in North America... Visit us at booth 537 Defiance Products Defiance Hardware: Tonsburg Mooring Links Mandel Fairlead Shackles Towing Shackles Thimbles ® Defiance Wire Ropes: Mechanical splicing up to 5" diameter Mooring Wires - 6 x 37 Galvanized Crane Ropes - 4 x 39 and 35 x 7 Lifeboat Falls · Fire Wires · Gangway Falls Defiance Mooring Lines: · DanLine · Superflex · SuperDan · PolyDac · Orca MSD's are designed to treat black water only or black & grey water from vessels with 24 to 500 persons · Orca is very light weight with fully automatic microprocessor control panel · Orca is USCG / IMO / EC certified To view our complete catalogue of products, go to www.atlantic-group.com Atlantic Cordage Corp. Visit our booth at the Workboat Show #1925 EVAC NORTH AMERICA INC. 1260 Turret Drive Rockford, Illinois 61115-1486 Tel. +1 815 6548300, fax +1 815 6548306 firstname.lastname@example.org - www.evac.com - www.zodiac.com 35 Mileed Way · Avenel, New Jersey 07001 · 1-800-458-5722 30 Maritime Reporter & Engineering News