There are a number of issues related to implementation of the new Transportation Worker Identification Credentials (TWIC) program, according to Jonathan K. Waldron, partner in the law firm of Blank Rome LLP. Costs will be high; applicants will be charged a fee ranging from $95 to $149, with associated economic costs topping $1bn over 10 years. Some current employees, especially those with criminal records or questionable immigration status, will be unable to get a TWIC. Delays in processing applications are likely to occur, due to the large number of workers to be vetted. In addition, employers must submit amendments to their security plans within 60 days of publication of the final rule, "a deadline which may not be feasible depending on multiple factors."

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