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Frequently Asked Questions

Transportation Worker Identification Credential (TWIC™)

PROGRAM INFORMATION

General

• What is TWIC?
• TWIC is a common identification credential for all personnel requiring unescorted access to secure areas of MTSA-regulated facilities and vessels, and all mariners holding Coast Guard-issued credentials. Individuals who meet TWIC eligibility requirements will be issued a tamper-resistant credential containing the worker's biometric (fingerprint template) to allow for a positive link between the card and the individual.

• How was TWIC created?
• Congress directed the federal government, through the Maritime Transportation Security Act (MTSA), to issue a biometric security credential to individuals with unescorted access to secure areas of facilities and vessels and all mariners holding Coast Guard-issued credentials or qualification documents. Controlling access to secure areas is critical to enhancing port security.

• How will the TWIC be used?
• During the initial rollout, TWIC will be used for visual identity checks. TWIC holders will present their cards to authorized personnel, who will compare the holder to his or her photo, inspect security features on the TWIC and evaluate the card for signs of tampering. The Coast Guard will conduct vessel and facility inspections and use hand-held readers during spot checks to ensure credentials are valid and identity is verified. A second rulemaking will establish access control requirements, including the use of electronic readers by certain vessel and facility owners and operators.

• Who must get a TWIC?
• We anticipate that over 1.2 million individuals will apply for a TWIC. This includes Coast Guard-credentialed merchant mariners, port facility employees, long shore workers, truck drivers, and others requiring unescorted access to secure areas of maritime facilities and vessels regulated by MTSA.

• Where do I go for 'official' TWIC enrollment information and services?
• TWIC information and resources are available on the official TWIC Program web site (www.tsa.gov/twic) and through the TWIC help desk (1-866-DHS-TWIC), at no additional cost to the enrollment fee. All information about the TWIC Program, including the enrollment process, can be found at this web site, which was recently revamped based on stakeholder feedback, and the official TWIC help desk. These resources enable applicants to pre-enroll, schedule appointments for both enrollment and activation, locate a convenient enrollment center, and access comprehensive frequently asked questions – all at no additional cost, with minimal effort and time. We encourage applicants to take advantage of these resources in order to save time and to provide you with the official information on the TWIC Program.

• Does TSA utilize individuals or companies to assist in the pre-enrollment process for a TWIC?
• TSA is aware of individuals and companies offering consulting services to ports and using the TWIC name and service mark. These individuals and companies are not sponsored or endorsed by the Federal Government and therefore we can not guarantee that the information they provide on the TWIC program is accurate. The official TWIC Program web site (www.tsa.gov/twic) and TWIC help desk (1-866-DHS-TWIC) offers accurate and comprehensive information and resources on the TWIC program at no additional cost to the enrollment fee.

• Who can I reach can I get information or assistance if I believe my privacy or personal information was compromised from a vendor providing TWIC services (that are not endorsed by the Federal Government)?
• Federal Trade Commission, Privacy and Identity Protection
  The Federal Trade Commission (FTC) has comprehensive information on identity theft at http://www.ftc.gov/bcp/edu/microsites/idtheft.
• TSA Privacy Office
  If you suspect your personal information is being misused in conjunction with the program, please contact the TSA Privacy Office:
  

  Transportation Security Administration
  TSA-36 OSC Privacy
  Transportation Security Administration
  601 South 12th Street
  Arlington, VA 22202-4220

• TSA Freedom of Information Act/Privacy Act (FOIA/PA) requests (access to one's own information):
  Individuals may request access to their information by submitting a Freedom of Information Act/Privacy Act (FOIA/PA) request to TSA in writing by mail to the following address:
  

  Transportation Security Administration
  TSA-20 OSC Freedom of Information Act (FOIA)
  Transportation Security Administration
  601 South 12th Street
  Arlington, VA 22202-4220

• How will I be notified to get a TWIC?
• Facility and vessel owners/operators are required to notify employees of their responsibility to possess a TWIC based on their need to have unescorted access to secure areas of vessels and facilities. Notification should be provided in a timely manner to give individuals sufficient time to complete the entire enrollment process by the compliance date.
• Owners/operators are encouraged to provide this same information to personnel who are not facility or vessel employees (e.g. contractors, truck drivers). Coast Guard Captains of the Port (COTP) will also be working with the local Area Maritime Security Committees (AMSC) to inform individuals of TWIC requirements and compliance dates.

• Can contractors apply for a TWIC if they anticipate bidding on or receiving a contract that would require unescorted access to secure areas of MTSA-regulated vessels or facilities?
• Contractors (or individuals who are not direct employees of a port owner or operator, but rather are 'contract' employees) can apply for a TWIC as long as they meet the TWIC eligibility requirements and, at a minimum, are expecting to pursue contracts at MTSA-regulated vessels and facilities where the owners or operators have determined a need for unescorted access in secure areas. If circumstances change and the individual no longer meet certain conditions, they are required to surrender their TWIC.

• Can a TWIC be confiscated, or taken from an individual, by an employer?
• TWIC is a government-issued credential and is the property of the Transportation Security Administration (per 49 CFR 1572.19). Accordingly, the holder applies for and uses the card, however TSA owns it. Employers cannot take or otherwise 'hold' the card without the employee’s consent, regardless of who paid for it.

• How long is the TWIC card valid?
• TWICs remain valid for five years, unless the expiration date was based on a comparable credential (Free and Secure Trade (FAST) card, Merchant Mariner Document/ License, or Hazmat Endorsement). The expiration date is displayed on the face of the TWIC. TWIC holders are responsible for knowing when to begin the renewal process. For individuals who pay the reduced fee, the expiration date of their TWIC will be five years from the date listed on the credential associated with the comparable security threat assessment.

• When will I be required to have a TWIC?
• Click here to learn more about compliance

• What is the national compliance date for the TWIC program?
• Workers who require unescorted access to secure areas of maritime facilities and vessels and all U.S. credentialed mariners must enroll for a TWIC no later than April 15, 2009. Workers will be required to possess and facilities will be required to check for a TWIC on a gradual basis, by Captain of the Port zone (COTP). The compliance date for each COTP zone will be published via notice in the Federal Register 90 days prior to the compliance date. Click here for the national compliance framework for the TWIC Program.

• Where can I find TWIC documents translated in other languages?
• The TWIC program provides communications materials in Spanish and English for the following areas:
• Pre-enrollment https://twicprogram.tsa.dhs.gov/TWICWebApp/
• Help desk (1-866-347-8942)
• The TWIC Disclosure Form accommodates the use of a translator in order to assist individuals who are not proficient in English.
• General fact sheets and informational flyers http://twicinformation.tsa.dhs.gov/twicinfo/twic_information.jsp
• Port-specific materials http://twicinformation.tsa.dhs.gov/twicinfo/schedule.jsp
• TWIC background check and applicant's rights to an appeals and waivers process. Please note: other translations can be found on the NELP site at http://www.nelp.org/nwp/second_chance_labor_project/.
• Note: the accuracy of these translations has not been confirmed by TSA and it is important to note that they do not replace or amend the TWIC appeal and waiver process in any way. TSA is providing the link to the NELP translations for your information.

• Can employers require their employees to enroll for a TWIC even if their job does not require them to have unescorted access to facilities and vessels regulated by Maritime Transportation Security Act (MTSA)?
• No. All applicants must certify that they need a TWIC to perform their job. Applicants either have to currently be, or are applying to be, a port worker requiring unescorted access to secure areas of maritime facilities and vessels regulated by MTSA; or they are a commercial HME driver licensed in Canada or Mexico. Applicants also certify that the information they provide during the enrollment process is true, complete, and correct. If required, civil or criminal action may be taken if an individual provides false statements (per 49 CFR 1570.5 and 18 U.S.C. 1001).

• Will these rules affect all Merchant Mariners?
• Yes. All credentialed U.S. merchant mariners must obtain a TWIC. This includes all persons holding a Coast Guard-issued merchant mariner's license, merchant mariner's document (MMD), Operator of Uninspected Passenger Vessels (OUPV), Standards of Training, Certification and Watchkeeping (STCW) Certificate, or certificate of registry (COR). With the implementation of TWIC, the Coast Guard MMD would primarily serve as proof of professional qualifications. The Coast Guard has drafted a supplementary proposed rule (published in the same Federal Register edition as the TWIC final rule) that proposes to combine the elements of all four current merchant mariner professional credentials into one certificate called the Merchant Mariner Credential (MMC). The Coast Guard and TSA are streamlining the process for the two credentials to reduce costs, duplication of effort and processing time for mariners. If the MMC proposed rulemaking is finalized as currently written, the Coast Guard would begin issuing the MMC in September of 2008 and would phase in the replacement of mariner's current credentials over a period of five years. Mariners would be issued their credential in the form of an MMC at the time they renew their current credential, or when applying for a new credential. The proposed rulemaking would not affect the validity of a mariner's current credential.

• What measures are in place to protect small businesses, such as small passenger vessels?
• TSA and the Coast Guard worked with the Small Business Administration to minimize adverse financial and operational impacts on small businesses wherever possible. The rule includes provisions that allow MTSA -regulated passenger vessels (excluding cruise ships) to establish employee access areas for crewmembers that do not require unescorted access to secure areas such as the pilot house and engine room. Employee access areas are typically include locations where waiters, entertainers and galley staff work and live. This provision reduces the impact on employees who rarely need to use spaces beyond those designated for support of passengers, while maintaining the integrity of a vessel's secure areas.
  
  The Small Entity Guide for Owners and Operators and a Small Entity Guide for Applicants provides useful information to small businesses and their personnel on the TWIC program.

• How do I know my personal information is safeguarded?
• Privacy and the security of your personal information are critical to the TWIC program. Information collected at the enrollment center or during the pre-enrollment process (including the TWIC Disclosure Form and identity or immigration-related documents) is scanned into the TWIC system for the security threat assessment process. To ensure privacy is protected, applicant data is encrypted and stored at a secure government facility using methods that protect the information from unauthorized retrieval or use.

• Will this credential be required for all modes of transportation?
• At this time, the TWIC program is focused on the maritime mode, specifically MTSA-regulated facilities and vessels.

• Is TWIC an acceptable form of ID at an airport screening checkpoint?
• Yes, the TWIC card is an approved government issued photo ID.

• Who can I contact to get more information on TWIC?
• Web site: www.tsa.gov/twic
• TWIC Program Help Desk: 1-866-DHS-TWIC (1-866-347-8942) Monday through Friday from 8 a.m. - 12 a.m. EST.
• Please visit homeport.uscg.mil/twic for answers relating to Coast Guard enforcement and TWIC implementation.
• Owners/operators/FSOs/VSOs/CSOs are encouraged to seek guidance directly from their local Captain of the Port TWIC action officer.

Rulemaking

• Where can I read the TWIC rule?
• The TWIC Final Rule is available on TSA's website and more information on port security is available at the U.S. Coast Guard's Homeport site.

• How was the public involved in the rulemaking?
• In addition to direct involvement from the National Maritime Security Advisory Committee, TSA and the U.S. Coast Guard held four public meetings around the nation and received more than 1,900 comments from workers, port owners and operators, small businesses and others who would be affected by the new program. All comments were carefully considered and significant changes to the rule were incorporated as a result.

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ELIGIBILITY

General

• What are the eligibility requirements for a TWIC?
• An individual must be a U.S. citizen or fall into an eligible immigration category (click here for immigration categories) and can not have been convicted of certain crimes. In addition, individuals cannot be connected to terrorist activity or lack mental capacity.

• What if I do not meet the eligibility requirements?
• Applicants who are denied a TWIC will be sent a letter explaining the reason for denial and instructed on how to apply for an appeal or waiver. See the disqualifications, waivers, and appeals section for more information. Once issued a TWIC, the applicant has an obligation to inform TSA if they are no longer eligible to hold a TWIC.

Immigration

• What immigration categories are eligible to apply for a TWIC?
• Click here for the eligible immigration categories (PDF, 161 KB)

• Will a non-U.S. citizen be able to get a TWIC?
• The rule includes a list of various immigration categories that are eligible to apply for a TWIC, including nationals, refugees, lawful non-immigrants with unrestricted work authorization, and certain professionals with restricted work authorization.

• Can a U.S. citizen born outside the U.S. receive a TWIC?
• An applicant that is a U.S. citizen but was born outside the U.S must bring the proper documentation to the enrollment center or they may be initially disqualified related to their immigration status.
• In this case, the applicant should make a photocopy of one of the documents listed below and submit an appeal using the TWIC cover sheet (that comes with their IDTA).

(1) Department of State - Certificate of Report of Birth (Form DS-1350);
(2) Department of State - Consular Report of Birth Abroad (Form FS-240); or
(3) U.S. Passport.

• What documents should Mexican truck drivers present at the time of TWIC enrollment?
• Mexican truck drivers are to provide the following combination of documentation at the time of TWIC enrollment in order to verify their immigration status:
1. Passport and Visa or
2. Passport and SENTRI Card or
3. Passport and Border Crossing Card (BCC) or
4. BCC and I-94 or
5. FAST Card and BCC/Visa/Passport/SENTRI/I-94 or
6. BCC

• What is required of TWIC applicants with Temporary Protected Status (TPS)?
• The National Employment Law Project (NELP) has prepared information for TWIC applicants with TPS status. The English version of this information can be found at: http://www.nelp.org/docUploads/TPS%20Notice%2Epdf, and the Spanish version at: http://www.nelp.org/docUploads/TPSNoticeSpanish%2Epdf. Please note: the accuracy of these translations has not been confirmed by TSA, but we are providing them as a convenience for our applicants.

• What should an applicant do if they receive an initial disqualification letter (IDTA) due to their citizenship/immigration status?
• Applicants should follow the instructions in the enclosure section of their IDTA letter. Applicants should request an appeal using the TWIC cover sheet and provide valid documentation demonstrating they are one of the categories identified above.

• What happens to my TWIC when my lawful nonimmigrant status expires?
• The applicant must report the disqualifying condition to TSA and surrender the TWIC. In addition, the TWIC becomes invalid if the applicant is in one of the permissible visa categories and the employment for which the visa was granted ends; one of the following then needs to take place:
• The employer retrieves the TWIC from the applicant and provides it to TSA,
• The applicant surrenders the TWIC to the employer, or
• If an employer terminates an applicant working under a nonimmigrant status or the applicant otherwise ceases working for the employer, the employer must notify TSA within five business days and provide the TWIC to TSA if possible.

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DISQUALIFICATION, WAIVERS, AND APPEALS

Disqualification

• What can disqualify me from getting a TWIC?
• An individual who lacks lawful presence and certain immigration status in the United States, has a connection to terrorist activity, has been determined to lack mental capacity or was convicted of certain crimes will be ineligible for a TWIC.

• What if I do not meet the qualification standards?
• Applicants who are denied a TWIC will be notified of the reason for denial and instructed on how to apply for an appeal or waiver. Once issued a TWIC, the applicant has the continuing obligation to inform TSA if they are no longer eligible for a TWIC.

• What are the disqualifying offenses? What are the waiver policies for each type of offense?
• Parts A and B provide a comprehensive list of disqualifying offenses and the waiver policies for each.

Part A – Permanent Disqualifying Offenses
Conviction for one of the following felonies is disqualifying regardless of when it occurred, and the applicant is not eligible for a waiver.

1. Espionage or conspiracy to commit espionage.
2. Sedition, or conspiracy to commit sedition.
3. Treason, or conspiracy to commit treason.
4. A federal crime of terrorism as defined in 18 U.S.C. 2332b(g), or comparable State law, or conspiracy to commit such crime.

Conviction for one of the following felonies is disqualifying regardless of when it occurred, and the applicant may apply for a waiver.

5. A crime involving a transportation security incident. A transportation security incident is a security incident resulting in a significant loss of life, environmental damage, transportation system disruption, or economic disruption in a particular area, as defined in 46 U.S.C. 70101. The term "economic disruption" does not include a work stoppage or other employee-related action not related to terrorism and resulting from an employer-employee dispute.
6. Improper transportation of a hazardous material under 49 U.S.C. 5124, or a State law that is comparable.
7. Unlawful possession, use, sale, distribution, manufacture, purchase, receipt, transfer, shipping, transporting, import, export, storage of, or dealing in an explosive or explosive device. An explosive or explosive device includes an explosive or explosive material as defined in 18 U.S.C. 232(5), 841(c) through 841(f), and 844(j); and a destructive device, as defined in 18 U.S.C. 921(a)(4) and 26 U.S.C. 5845(f).
8. Murder.
9. Making any threat, or maliciously conveying false information knowing the same to be false, concerning the deliverance, placement, or detonation of an explosive or other lethal device in or against a place of public use, a state or government facility, a public transportations system, or an infrastructure facility.
10. Violations of the Racketeer Influenced and Corrupt Organizations Act, 18 U.S.C. 1961, et seq., or a comparable State law, where one of the predicate acts found by a jury or admitted by the defendant, consists of one of the crimes listed in Column A.
11. Attempt to commit the crimes in Part A, items 1 - 4.
12. Conspiracy or attempt to commit the crimes in Part A, items 5 – 10.

Part B – Interim Disqualifying Offenses
Conviction for one of the following felonies is disqualifying if the applicant was convicted, pled guilty (including 'no contest'), or found not guilty by reason of insanity within 7 years of the date of the TWIC application; OR if the applicant was released from prison after conviction within 5 years of the date of the application. The applicant may apply for a waiver.

1. Unlawful possession, use, sale, manufacture, purchase, distribution, receipt, transfer, shipping, transporting, delivery, import, export of, or dealing in a firearm or other weapon. A firearm or other weapon includes, but is not limited to, firearms as defined in 18 U.S.C. 921(a)(3) or 26 U.S.C. 5 845(a), or items contained on the U.S. Munitions Import List at 27 CFR 447.21.
2. Extortion.
3. Dishonesty, fraud, or misrepresentation, including identity fraud and money laundering where the money laundering is related to a crime described in Columns A or B. Welfare fraud and passing bad checks do not constitute dishonesty, fraud, or misrepresentation for purposes of this paragraph.
4. Bribery.
5. Smuggling.
6. Immigration violations.
7. Distribution of, possession with intent to distribute, or
   importation of a controlled substance.
8. Arson.
9. Kidnapping or hostage taking.
10. Rape or aggravated sexual abuse.
11. Assault with intent to kill.
12. Robbery.
13. Fraudulent entry into a seaport as described in 18 U.S.C.
    1036, or a comparable State law.
14. Violations of the Racketeer Influenced and Corrupt
    Organizations Act, 18 U.S.C. 1961, et seq. , or a comparable State law, other than the violations listed in Part A, item 10
15. Conspiracy or attempt to commit felonies listed in Part B.

• What if a conviction is "exonerated?"
• If a conviction is expunged or pardoned, the criminal records may reveal this. If they do not, TSA sends the applicant a letter (Initial Determination) explaining what the records show and how the applicant can correct inaccurate records.

• What if my initial disqualifying crime is no longer applicable? Can I reapply for a TWIC?
• Applicants are encouraged to reapply if their initial disqualifying offense is no longer applicable. Applicants will need to understand the nature of the initial disqualification and the corresponding look-back periods of 5 or 7 years if applicable. Reapplying can occur as long as there are no secondary disqualifying events.

• What if I have a disqualifying crime that was expunged from my record?
• The applicant should proceed with TWIC enrollment as though they do not have a disqualifying offense, as long as the record is truly expunged. Per 49 C.F.R. §1570.3, a conviction is expunged when "the conviction is removed from the individual's criminal history record and there are no legal disabilities or restrictions associated with the expunged conviction, other than the fact that the conviction may be used for sentencing purposes for subsequent convictions." However, if the applicant is a credentialed mariner or intends to apply for a mariner credential, he or she must report convictions that were expunged on their application to obtain the MMC. Failure to disclose expunged convictions could result in a determination that the application for the mariner credential is fraudulent.

• Can a person under indictment apply for a TWIC? Do they still have the appeal and waiver process available to them?
• An individual under indictment for a disqualifying criminal offense may not hold a TWIC until the indictment is dismissed. If the applicant has an indictment pending, the applicant could apply for a waiver; however a request for a waiver does not guarantee that a waiver will be granted.

Waivers and Appeals

• What options are available to me if I'm denied a TWIC?
• Applicants who are denied a TWIC will be provided justification and instructed on how to apply for an appeal or waiver. All applicants have the opportunity to appeal a disqualification, and may apply for a waiver if qualified. Applicants who seek a waiver and are denied may seek review by an Administrative Law Judge (ALJ). Also, applicants who are disqualified due to intelligence-related issues and are denied an appeal or a waiver may seek ALJ review.

• What is the process and timeframe for appealing a disqualification? Applying for a waiver?
• Applicants must send appeal requests to TSA within 60 days of receiving TSA's IDTA. Within 60 calendar days of receipt of an applicant's appeal request, TSA will provide notice as to whether an appeal request has been granted or denied. Please note that for good cause, TSA may take longer than 60 days to provide notification. If an applicant needs more than 60 days to request an appeal, the applicant should send a letter to TSA asking for an extension.

  Applicants must send waiver requests no later than 60 days after the date of the Final Determination of Threat Assessment (FDTA). However, applicants do not need to wait until receiving a FDTA and may file the waiver at any time after receiving the IDTA. Within 60 calendar days of receipt of an applicant's waiver request, TSA will provide notice whether the waiver request has been granted or denied. If an applicant needs more time to request a waiver, the applicant should send a letter to TSA asking for an extension of time. Please note that for good cause, TSA may take longer than 60 days to effect notification.

• If someone is denied, can they access secure areas of a port pending the appeal/waiver process or do they have to wait for its completion?
• Access to these areas will depend on the owner/operator security plan and their escorting procedures, as well as the enforcement and compliance date for that particular USCG Captain of the Port zone.

• Where else can I get information on the appeals and waivers process?
• The National Employment Law Project (NELP) has prepared materials related to the TWIC background check and applicant's rights to an appeals and waivers process. You can find translations in many other languages on the NELP website at http://www.nelp.org/nwp/second_chance_labor_project. Please note: the accuracy of these translations has not been confirmed by TSA and it is important to note that they do not replace or amend the TWIC appeal and waiver process in anyway. TSA is providing the link to the NELP translations for your information.

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ENROLLMENT

General

• When will I be able to get a TWIC?
• Click here to view the quarterly schedule for the deployment of TWIC enrollment centers

• What is the process for obtaining a TWIC?

• Applicants can save time by pre-enrolling online or via phone (optional) • During pre-enrollment, applicants will: - Enter biographic information required for the security threat assessment - Make an appointment at the enrollment center • Pre-enrollment is available by clicking here	• Applicants are required to bring identity documents to the enrollment center • Click here to access the latest listing of acceptable documents (to include those documents required to prove immigration status if not born in the U.S.).	• Applicants must visit an enrollment center where they will: - Complete a TWIC Application Disclosure Form - Pay the enrollment fee - Provide biographic information (if applicant did not pre-enroll) and a complete set of fingerprints - Sit for a digital photograph	• Applicants will be notified by email or phone, as specified during enrollment, when their TWIC is available at the enrollment center • Applicants must return to the center at which they enrolled to pick up their TWIC • TWICs will be issued to workers 3 – 4 weeks after enrollment • Applicants can check the status of their card and schedule a pick-up appointment by clicking here

• How long does enrollment take?
• The enrollment process for a pre-enrolled applicant takes approximately 10 minutes. The enrollment process for those who did not pre-enroll takes approximately 15 minutes. There may be a wait time at the enrollment center depending on the amount of workers choosing to enroll at any particular time. Individuals can save time by making an appointment – you can make an appointment by pre-enrolling online.

• What are the addresses and hours of operation for the enrollment centers?
• Click here to get enrollment site locations and hours of operation

• How can I pre-enroll and make an appointment?
• Pre-enrollment is available by clicking here.
• The pre-enrollment process allows applicants to provide much of the biographic information required for enrollment; to select an enrollment center where they wish to complete the enrollment; and to make an appointment. Applicants are encouraged, but not required, to "pre-enroll."

• Are appointments required for enrolling?
• No. Appointments are encouraged to save applicants time, but are not required and walk-ins are welcome.

• How can I get a mobile enrollment workstation at my facility?
• Click here to view a document that provides background information, requirements, and contact information for requesting and hosting a mobile enrollment facility.

• Can hats or religious headgear be worn for the photo taken during TWIC enrollment?
• Unless worn daily for religious reasons, all hats or headgear should be removed for the photo. For clarification, a ball cap, knit cap, or do-rag is not considered religious headgear. A signed statement from the applicant must be submitted at the time of enrollment verifying the item is worn daily for religious reasons. In all cases, no item or attire should cover or otherwise obscure any part of the face.

• Can eyeglasses be worn for the photo?
• Eyeglasses worn on a daily basis can be worn for the photo. However, there should be no reflections from the eyeglasses that obscure the eyes. Dark glasses or nonprescription glasses with tinted lenses are not acceptable unless they are needed for medical reasons. A medical certificate may be required.

• Are photographs required for TWIC enrollment?
• Since the TWIC serves as a form of visual identification, a photograph is required for all applicants.

Required Documentation

• What identity documentation is required for a TWIC?
• TWIC applicants are required to provide identity verification documents to complete the enrollment process. There are two lists of identity verification documents; applicants are required to furnish either one identity document from List A or two documents from List B, with one of the two being a government-issued photo ID. Click here to access the latest listing of acceptable documents.

• What is the purpose of the TWIC Disclosure Form?
• The TWIC Disclosure Form provides additional information to the applicant on the security threat assessment process, as well as a notice on privacy and paperwork reduction. The applicant is also required to review and certify statements pertaining to eligibility for a TWIC, military service, and, once a TWIC is issued, their responsibility to disclose information to TSA that would disqualify them from holding a TWIC. The applicant is required to sign and date the form. If participating in the process, the helper/translator will also sign the form and provide contact information.

Applicants are encouraged to complete the TWIC Disclosure Form and bring it with them to the enrollment center.

• What if I do not have the required forms of identification or do not wish to sign the TWIC Disclosure Form?
• You will not be able to enroll or obtain a TWIC.

Payment

• How much does a TWIC cost?
• The fee for TWIC is $132.50 and is valid for five years. Workers with current, comparable background checks will pay a reduced fee of $105.25. If workers are eligible to pay the lower price, their TWIC will expire 5 years from the date of the comparable credential (additional information is provided in the next question). The cost of a replacement TWIC, if the original is lost, stolen, or damaged, is $60.

• What are the methods of payment?
• Payment must be made with credit card (Visa® or MasterCard® only), money order, or certified/cashier's check. Checks should be made payable to Lockheed Martin. An additional option has been provided through the use of company purchased pre-paid debit cards. For companies choosing to use the pre-paid option, please visit http://www.twiccard.com .

  In all cases, payment will be made at the enrollment center at the beginning of the enrollment process.

• What is the fee for a replacement card?
• The card replacement fee (for lost, stolen, or damaged TWICs) is $60.

• How can employers purchase TWIC cards for their employees?
• This method of payment is a prepaid Visa® card and is intended for employers who wish to purchase TWICs for their employees. They may be purchased in bulk and are redeemable at any TWIC enrollment center. The website for additional information or purchasing them is at: http://www.twiccard.com.

• If I have a comparable assessment, how can I determine which fee is more economical -- the reduced fee or the full, 5 year fee?
• It is most beneficial for applicants who will use a comparable security threat assessment and pay the reduced fee to do so within 12 months of receiving the comparable threat assessment. After 12 months, it is more cost effective to pay the full fee for TSA to complete the security threat assessment and issue a TWIC with an expiration date 5 years from the date of issuance.

Security Threat Assessment

• How is the security threat assessment conducted?
• The assessment includes checks against criminal history records, terrorist watch lists and immigration databases.

• Will the results of my threat assessment be shared with my employer?
• If TSA determines that an applicant poses an imminent threat to the transportation system or national security, TSA may notify the applicant's employer. Generally, TSA will not provide the reason(s) for a disqualification to an employer. However, if TSA has reliable information concerning an imminent threat posed by an applicant and providing limited threat information to an employer, facility, vessel owner or Coast Guard Captain of the Port would minimize the risk, then TSA would provide such information.

• What if I have already completed a comparable threat assessment?
• 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 valid Hazardous Materials Endorsement (HME) issued after May 31, 2005,
• applicants who hold a valid Free and Secure Trade (FAST) card,
• applicants who hold a Merchant Mariner Document (MMD) issued after February 3, 2003, or
• applicants who hold a Merchant Marine License (MML) issued after January 13, 2006.

Note: 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.

• Are the background checks for a TWIC the same as the background checks conducted for an individual applying for a Hazardous Material Endorsement?
• Yes. They have the same eligibility requirements, share a consistent waivers and appeals process and leverage the same fingerprint-based criminal history records check.

• Does someone with a Hazardous Material Endorsement (HME) have to repeat the criminal history records check (CHRC) if they are applying for a TWIC?
• No. As a result of this, an applicant who applies for a TWIC after successfully completing the HME security threat assessment does not have to pay for a second CHRC - and the fee for the TWIC is reduced by $27.25. All TWIC applicants must pay the fees that cover the other components of the TWIC program, including enrollment and card issuance.

Card Issuance

• How will the cards be issued?
• The applicant will be notified by email or phone, as specified during enrollment, when his/her credential is available at the enrollment center. The applicant must return to the same enrollment center to pick up his/her TWIC.

• How long does it take to receive a TWIC?
• Currently, there is typically three to four week turnaround from enrollment until card activation. Eligibility issues or insufficient paperwork may increase the turnaround time.

• How can I check the status of my card and schedule a pick-up?
• Click here to check the status of your card and schedule a pick-up

Card Technology and Durability

• What technologies are being used on the TWIC?
• The TWIC is a Smart Card (i.e., a card with a small integrated circuit chip embedded in the card) and contains the following technologies:
• Dual Interface Integrated Circuit Chips (ICC) - a small computer chip that can be read by either inserting the card in a slot in a "contact" card reader; or, holding the card within 10 centimeters of a "contactless" card reader
• Magnetic Stripe - commonly found on the back of credit cards; read by "swiping" the card through a magnetic stripe card reader
• Linear Bar Code - commonly used to quickly identify items by scanning the codes with an optical reader—i.e. scanning grocery items at a checkout counter

• How durable is the TWIC?
• In general, while TWIC holders should treat their cards with care, they were created to be durable in the maritime operational environment. The durability of the TWIC is based on the FIPS 201-1 and ANSI 322 card durability requirements and testing conditions (refer to paragraph 4.1.3 Physical Characteristics and Durability in FIPS 201, page 16). These tests include: card flexure, U/V exposure, humidity, surface abrasion, fading, and a "laundry test."

• Can a hole be punched in a TWIC in order to hang it on a lanyard?
• Punching a hole in a TWIC card will likely break the antenna that resides at the edge of the card (the antenna is used for the contact-less mode of the card when using with access control systems). Punching a hole in a TWIC card should be strongly discouraged since it would affect the usefulness of the card.

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COMPLIANCE

General

• When will I be required to have a TWIC?
• Workers will be required to possess a TWIC by the compliance date set for their specific Captain of the Port (COTP) zone.
• Below is the latest schedule for COTP zone compliance. All compliance announcements will be made in the Federal Register at least 90 days in advance.

Date	COTP Zone(s)
October 15, 2008	Northern New England Boston Southeastern New England
October 31, 2008	Buffalo Duluth Detroit Lake Michigan Sault Ste. Marie
November 28, 2008	Corpus Christi Port Arthur North Carolina Cape Fear River
December 01, 2008	Long Island Sound Charleston Savannah Jacksonville
December 30, 2008	Baltimore Delaware Bay Mobile Pittsburgh Ohio Valley Lower Mississippi River San Diego
January 13, 2009	Hampton Roads Morgan City New Orleans Upper Mississippi River Miami Key West St. Petersburg
February 2009	Honolulu South East Alaska Prince William Sound Western Alaska Puget Sound Portland(OR) San Francisco Bay
March - April 2009	New York Guam Houston/Galveston Los Angeles/Long Beach San Juan

• Why should I get a TWIC now if I can wait until a couple of months before the compliance date for my port?
• The national compliance date, when all workers who require unescorted access to secure areas of maritime facilities and vessels, and all U.S. credentialed mariners must have a TWIC, is April 15, 2009. However, TWIC requirements for regulated maritime facilities will be phased in by Captain of the Port (COTP) zones leading up to April 2009. Workers needing unescorted access to secure areas at those facilities will be required to possess a TWIC. We strongly encourage workers to apply as soon as possible to avoid any delays and enforcement actions being taken. If workers are concerned about their eligibility due to disqualifying crimes or other circumstances, it is recommended that they apply as soon as possible to account for the appeals and waivers process.

• What Captain of the Port zones (COTPs) have compliance dates been announced for?
• Click here for recent compliance announcements.

• Why was the compliance date recently realigned?
• The April 15, 2009 compliance date reflects a realignment of the Sept. 25, 2008 compliance date set in the final rule. The seven month extension is a direct result of collaboration with port officials and industry, and honors our commitment to provide an 18 month enrollment period.
• What areas will require individuals to possess a TWIC?
• Secure areas have been designated to meet specific security measures in accordance with a Coast Guard approved security plan and are specific to the vessel and facility security plans at each port.
• Does TWIC apply to mutual aid, first responders, etc. in the event of an emergency?
• State and local emergency responders are exempt from the requirement to have a TWIC when they are responding to an emergency. Additional guidance has been included in the U.S. Coast Guard Navigation and Vessel Inspection Circular (NVIC).

• Will the facility ID card, which would be based on the TWIC, be acceptable for access to secured areas?
• Regulations allow a plant or facility owner to use their own plant/facility specific card as their access control measure, as long as they ensure individuals without a TWIC cannot gain unescorted access to secure areas and the TWIC is checked at least once before the specific card is reissued/accepted. There is no requirement to check/verify TWICs for access to restricted areas, only secure areas.

• Can a TWIC be confiscated, or taken from an individual, by an employer?
• TWIC is a government-issued credential and is the property of the Transportation Security Administration (per 49 CFR 1572.19). Accordingly, the holder applies for and uses the card, however TSA owns it. Employers cannot take or otherwise 'hold' the card without the employee’s consent, regardless of who paid for it.

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OUTREACH

General

• What outreach efforts have been deployed in support of TWIC?
• TSA, the U.S. Coast Guard and its contractors have conducted extensive outreach to educate workers on the impact of this critical security program. This includes:
• Regular meetings with ports, unions, trade groups and others affected by TWIC
• Four formal public hearings for workers and industry
• A toll free contact center 1-866-DHS-TWIC (1-866-347-8942) to answer workers' specific questions
• Ongoing communication via the Web site, which includes an extensive question and answer section
• Signage, pamphlets and other port specific communications that will keep workers informed on enrollment dates and resources to answer their questions - stakeholders can get a copy of these materials here.

Members of TSA and the Coast Guard will continue to meet with unions, associations and other industry stakeholder groups to provide updates on the status of the program and will update materials on the TSA and USCG web sites. Small entity guides for TWIC applicants and owners/operators are available here. The U.S. Coast Guard Navigation and Vessel Inspection Circular (NVIC) is also available. The majority of stakeholder outreach efforts supporting the deployment of the program will be coordinated and carried-out by TSA's contractor, Lockheed Martin.

• What materials can I use to promote TWIC at my port or facility?
• Click here for materials to promote TWIC at your port or facility

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TWIC Pilot Test

FAQs pertaining to v1.1 of Specification:

• Is there any change in scope in Version 1.1 of the specification from the previous release?
• Version 1.1 retains the same scope as the previous release though some details have been expanded in Version 1.1 as a result of vendor enquiries and the specification editorial process.

• Who can I contact if I have questions on either version of this specification?
• General questions can be submitted using the email link available on the TSA / TWIC pilot test web page. Specification detailed technical questions or proposed contributions should be directed to the Project Editor; refer to Section 1.3 of the Version 1.1 specification for contact details.

• Which version will TSA use for evaluating TWIC readers for possible use in the Pilot test?
• TSA plans to use Version 1.1 for the TWIC reader baseline as will be published soon in the Federal Register.

• Will TSA / Coast Guard provide any outreach on the Version 1.1 specification as well as an update on the Pilot Test?
• Several options are under consideration to provide the latest Pilot Test information and the revised TWIC reader specification to the public. TSA / Coast Guard will make an announcement in the near future on how this outreach will be achieved.

• Do you expect that fixed readers will test the validity of the Security Object? I don't see the Security Object referenced in any of the workflow descriptions.
• It is not expected that fixed readers will test the validity of the TWIC Application Security Object.

• The Security Object on the TWIC card issued to me does not contain a hash for the TWIC Privacy Key, as specified in the TWIC spec (page 30):
  "The objects hashed are: the Unsigned CHUID (0x3002), The TWIC Privacy Key (0x2001), the Signed CHUID (0x3000), and the signed fingerprint templates (0x2003)." The other object hashes are there. Is this a problem that the card producer should be notified about?
• The problem here lies in the specification; not an omission by the card producer. The security object may contain mappings and hash values for any data objects selected by the Issuer per policy. In this case the TPK is NOT included in the security object. The specification will be amended to reflect this fact.

• Finally, a suggestion on the TWIC Privacy Key Network Processing portion of the spec (page 39): I think it might be better in the long run to return not just the AES encryption key, but the whole contents of the TWIC Privacy Key buffer. That way, applications would not need to be hard-coded to use AES-ECB-128, but could easily be written to support any of the other AES types in the future. It wouldn't add much network overhead and would enhance expandability.
• This is a very good suggestion as it allows changes to the AES key length without having to modify reader communications software.

• The spec says "The reader shall provide an automated alert or lockout after a configurable number of biometric matching attempts (facility chooses). Is the intent of this specification to provide an automated alert or lockout after a configurable number of consecutive failed biometrics matching attempts?
• The automated alert is intended to trigger after X (configurable) consecutive failures to match.

• The spec says that Appendix B is "the method used to perform the TWIC Privacy Key retrieval from the PACS system." Does this really mean that this is the only way this can be done, or that it's the preferred way, or just a suggested way?
• Appendix B should be read as an Informative Annex in that the method described is preferred and suggested; but not mandated.

• The spec says "The input parameter value corresponds to the unique user ID that was read from the TWIC card as a binary value and base64 encoded". What is this unique user ID?
• The unique user ID is determined by the local facility but is expected to be the FASC-N or a portion of the FASC-N (such as the Personal Identifier field).

• The spec says "The response would be the base64-encoded 128-bit (16-byte) AES encryption key", but the example response decodes to 17 bytes. Is this a mistake?
• The annex has incorrect information in both of the value fields. Here is a simplified example ->
• For Annex B set the Content-length to "xx" for both the input request and the response indicating "length was not computed for this example"
• The TPK shall be 16 bytes [30313233343536373839303132333435] base64 encoded as [MDEyMzQ1Njc4OTAxMjM0NQ==]
• For the "unique user ID" use a full FASC-N of 25 bytes [D70339DAA1822C10842125A1685821084216C1B9870339A3EB] base64 encoded as [1wM52qGCLBCEISWhaFghCEIWwbmHAzmj6w==].
• Note that [ ] are not part of either the hexadecimal value or the base64 encoded string.

• Does TWIC offer a Certificate Revocation List (CRL)?
• Yes. The TWIC program CRL maintains a regularly updated list of all revoked TWIC certificates. The CRL is in addition to the Hotlist mechanism found on the pre-enrollment web site. TWIC readers can automatically retrieve the location of the CRL by looking at any of the certificates on the TWIC Card. TWIC certificates are formatted per rfc3280 and support the "CRL Distribution Points" extension indicating the Internet addresses available to reach the TWIC CRL.

OVERVIEW

The following responses are to questions submitted to TSA and the U.S. Coast Guard by the International Biometric Industry Association (IBIA). These questions and responses are specific to the November 19, 2007 public meeting to discuss the TWIC reader hardware and card application specification.

GENERAL

Estimate of Number of TWIC Readers

• Manufacturers of reader devices will need to make engineering changes to existing products to meet the requirements of the TWIC Reader Hardware and Card Application specification. There is a need for manufacturers to accurately forecast the potential market for these readers to enable an informed business decision as to how to price their products competitively and in such a way that they recover the unique product development costs over a reasonable time period. The requirement for TWIC readers in the maritime environment, in terms of projected quantities, is heavily dependent on several policy positions that have yet to be fully developed by the Coast Guard and TSA. Specifically, there are 3,200 facilities and 10,000 vessels that are subject to regulations under the Maritime Transportation Security Act (MTSA) and each maritime worker will be required to present a TWIC card for unescorted access to secure areas. Reader manufacturers are asking for policy guidance regarding the extent to which TWIC readers will be required for use in reading the TWIC card at entry points and the reader authentication mechanisms that will be required at various threat levels (e.g., CHUID only, CHUID + biometric). Reader manufacturers also need to know if policy will require TWIC readers at each facility exit point (in addition to the entry points), in order to enable awareness of what personnel are in the secure area at any given time. Can the Government please provide general guidance as to the expected operational use of TWIC readers?
• In due course, we will be providing guidance. That said, the operational use case is expected in the short term to vary dramatically from one location to another due to the need to satisfy local operational practice, provisional law, and established policy.

• Can the government provide guidance on the expected ratio of fixed indoor; fixed outdoor; and handheld devices in a typical deployment?
• There is no "typical deployment". Each deployment has unique characteristics in terms of access control policy, secure areas, manpower, etc. As such there is no general guidance available as of today with respect to the distribution of reader types (fixed outdoor, fixed indoor and mobile).

Feature Extractor Used to Store Reference Fingerprint Minutiae Templates

• What specific vendor template feature extractor has been used by the TWIC implementation contractor to generate the reference fingerprint minutiae templates stored on the TWIC card?
• The TWIC program has selected a NIST certified extractor.

• Has this template generator been tested and approved as a compliant feature extractor by NIST through the MINEX on-going testing program?
• The selected template generator is NIST tested and approved.

• If so, what is the specific SDK code that is used to create the reference fingerprint templates on the TWIC card?
• See http://fingerprint.nist.gov/minex/QPL.html for reference. The TWIC program has selected a NIST recognized SDK.

Pre-Pilot Reader Test and Certification

• What is the process under which TWIC readers will be approved for participation in the upcoming TWIC reader pilot field test?
• The testing process is under development and no further details are available as of this writing.

• Will the Government provide TWIC test cards to reader manufacturers?
• Cards for testing TWIC readers are under investigation with a recommended process for manufacturers to obtain cards forthcoming.

• Will readers be submitted for environmental conformance testing (i.e., temperature, humidity, shock, vibration, etc.)?
• We anticipate that all readers will need to meet both laboratory testing and some level of real world operational testing requirements. In drafting the reader test plan we are considering how to perform the environmental portion of the testing that will both meet the needs of maritime facility and vessel operators as well as provide a range of environmental test options to vendors. As soon as the reader test plan is approved we will provide specific guidance to all vendors.

• Will readers be submitted for "scenario" testing with human subjects to validate such requirements as throughput and matching accuracy?
• Scenario testing is under investigation. It is reasonable to presume a combination of laboratory and real world operational testing will occur to determine such factors as throughput and matching accuracy.

• Is there any fee to be charged to vendors who submit products for such testing?
• There is no decision on this point as of this writing. A fee based testing methodology is one option under consideration.

• Will completion of conformance testing be on a "pass" or "fail" basis?
• The testing process is under development and no further details are available as of this writing. Our goal is to allow the introduction of as many types of readers that will meet the needs of maritime facility and vessel operators while having a level of assurance that a supply of readers will operate in some of the harsh conditions found in maritime operations. That said; we expect that all readers must accurately read a TWIC. Card reading performance (technical read of the card) would therefore be on a PASS / FAIL basis.

• Will there be a Qualified Products List (QPL) maintained by the Government for the TWIC readers and will there be an opportunity for on-going testing for conformance as new products are developed?
• We anticipate that some form of a qualified product list will be maintained by the program at some point prior to the effective date of the TWIC reader rule.

• If a stand-alone product does not meet some of the environmental requirements (e.g., temperature range), but could comply with these requirements when integrated into an enclosure (e.g., a heated pedestal/stand), how will these products be tested for conformance?
• The testing process is under development and no further details are available as of this writing.

• When will a calendar-based milestone schedule for the pre-pilot test and certification process be published?
• We will publish a milestone schedule along with the release specifics regarding the reader test plan.

• Will the pre-pilot test plan protocols be published for public comment? If so, when?
• The testing process is under development and no further details are available as of this writing. Should such protocols be published the public will be notified prior to publication.

• Will detailed pre-pilot test results data and analysis be made available to the participating vendors? To what extent, if any, will this information also be available to the public and to other vendors?
• The testing process is under development and no further details are available as of this writing.

Pilot Test

• What organization will be purchasing reader products used in the pilot test?
• Facility and vessel owners participating in the pilot test will purchase readers and other infrastructure.

• Will Port Security Grant Program funds be used for the acquisition of readers used in the five pilot test locations? If so, does the Government then have final approval authority over the purchase of readers to be used in the pilot test?
• Port Security Grant (PSG) funds will be used to acquire readers and other infrastructure necessary to conduct the pilot test. The Government does NOT have final approval authority over the purchase of readers. That said, all readers purchased with PSG funds must meet TWIC test requirements.

• Is the Government's intention to test all three reader types during the pilot test (e.g., handheld, fixed outdoor, fixed indoor)?
• The desire is to test all configurations of readers in the Pilot phase of the program.

• We have heard reference to an "early operational assessment" reader test that will occur at ports or vessels before the full operational test commences. Can the Government provide more details on the scope of this phase of the pilot test?
• The Early Operational Assessment (EOA) reader test is under development. More information will be communicated to industry as relevant details become available.

• What is the expected time line for the start and completion of early operational assessment pilot testing and full production pilot testing?
• We anticipate starting the EOA early in 2008. Full production testing (System Test and Evaluation Phase) will begin in mid-2008.

SPECIFIC QUESTIONS RELATED TO SECTIONS OF TWIC SPECIFICATIONS

Section 4.2.1.2 - 4th and 6th bullets

• The specification requires the use of the stored fingerprint templates on the TWIC card to be matched during the mode "Biometric Verification - Network Attached Reader". There is no mention of a provision for an alternate "operational" biometric that may be stored off of the TWIC card. While not explicit in the specification, our assumption is that when the reader is in "CHUID only" mode, the local operator could require the user to present an "operational" biometric that is indexed by the CHUID pointer within a repository of separately enrolled biometric data. We assume that such an implementation would be permitted but is outside the scope of the TWIC reader hardware and card application specification. Is this assumption correct?
• The assumption is correct.

Reference Sections 5.1.4, 5.1.4.1, and 5.1.4.2

• Please define or give examples of how "…or equivalent commercial practice…" may be successfully demonstrated.
• It is preferred to meet the requirements as stated in the referenced clauses. Alternate, equivalent means to meet these referenced requirements are yet to be defined and may not ultimately be considered.
  
  The following example is offered as guidance on the use of equivalent commercial practice.
  
  EXAMPLE: "equivalent commercial practice" might be a certification obtained by an accredited test house that performed similar tests to those referenced in the specification. Such documentation might be reviewed against the specification referenced requirements and, on a case by case basis, considered as proof of successfully demonstrating the referenced requirements have been satisfied using "commercial practice". This example presumes what would be submitted in lieu of documentation of performing the preferred, required tests would include:
  - the name, address, and contact within the accredited test house,
  - the certification obtained,
  - the test methods and procedures used to achieve the certification, and
  - a statement by the manufacturer indicating what specification requirements are considered in scope of the equivalent commercial practice.

Reference Section 8 - Last Paragraph

• Does the TWIC reader require the use of template matchers that have been certified by NIST under the MINEX On-Going Test Program?
• Yes. The reader and card application specification references SP800-76 which requires said certification by NIST.

Reference Section 11.1

• The note below the table describing the Card-application Identifier states: "As not all TWIC cards may be issued with the TWIC application as the default selected card-application, the reader shall explicitly select the TWIC card-application." Please describe an example of a TWIC card that is not issued with the TWIC application as the default selected card-application.
• Future versions of the TWIC card may have more than one version of the TWIC application (as determined by the Proprietary Extension (PIX) of the Application identifier). In addition future applications may desire to return File Control information (FCI) to the reader that contains "discovery information" useful to the transaction session. This is why an explicit SELECT is warranted.

Reference Appendix A.2 - 8) b)

• This reference states that "the reader could be locally configured with a copy of every trusted document signing certificate." Since there is only one central issuing authority for TWIC cards, what is the estimate of the maximum number of document signing certificates that will need to be stored in the reader?
• The exact number is not defined. The total number is expected to be small given the central issuing authority structure. Further document signing is not currently anticipated as a normal mode of operation.

Reference Appendix A.3

• Since active card authentication over the contactless interface is only supported through selection of the PIV application and is not directly performed within the TWIC card application, is it correct to assume that this function will typically not be performed during routine access with a TWIC reader and will more likely occur at a PC workstation such as in a security office when a worker is being initially registered into a physical access control system?
• It is NOT correct to presume the TWIC card will be used in this way.

• The fifth paragraph in this section states: "The reader (or bi-directional panel) would need to have access to a system clock capable of providing the current date and time in order to determine the expiration status of the credential." Is it not also possible for the expiration data of a TWIC card to be registered one time in the PACS head end server during initial privilege granting and have the PACS disable any CHUID that has expired? In such a scenario, there is no need for the reader to send the expiration date to the panel - only the CHUID. Is this a valid implementation scenario?
• The expiration date might be stored at the head end. The expiration date is part of the CHUID. [If you meant to just send the FASC-N within the CHUID in this scenario this MAY be acceptable depending on the requirement to verify the signature field of the CHUID].

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