TSA Immediate Revocation of a TWIC or Hazmat Endorsement

If TSA immediately revoked or invalidated your Transportation Worker Identification Credential or hazardous materials endorsement, stop using the affected credential and review the entire notice immediately.

An Initial Determination of Threat Assessment and Immediate Revocation is more serious than an ordinary initial denial. TSA has determined both that you do not presently meet the applicable security-threat-assessment standards and that the information may indicate an imminent threat warranting immediate action.

For a TWIC holder, TSA may immediately invalidate the card and the holder’s authorization for unescorted access to secure maritime areas. For a commercial driver, TSA may direct the state licensing authority to revoke the HME immediately.

You still may have appeal rights. Under 49 C.F.R. § 1515.5(h), a person subject to an immediate revocation may use the applicable TSA appeal procedures. The notice generally requires the appeal to be initiated within 60 days after receipt, but filing an appeal ordinarily does not make the credential valid while the case is pending.

National Security Law Firm represents TWIC holders and commercial drivers nationwide in TSA appeals and waivers. We have handled TWIC and HME matters since 2016 and have represented applicants in hundreds of TSA credential cases.

Our flat legal fee for qualifying initial-stage TWIC or HME appeals and waivers is $2,495. We review the notice, obtain ordinary court records, identify the alleged disqualification, prepare the legal response, organize the evidence, and manage the case through the covered TSA stage.

Schedule an urgent free consultation or call (202) 600-4996. When contacting the firm, provide the complete TSA notice and the date you received it.

What Is an Initial Determination and Immediate Revocation?

TSA ordinarily issues an Initial Determination of Threat Assessment when it concludes that an applicant or credential holder does not satisfy the federal standards for a TWIC or HME.

An immediate-revocation case includes an additional finding.

Under 49 C.F.R. §§ 1572.15 and 1572.21, TSA may issue an Initial Determination of Threat Assessment and Immediate Revocation when it determines that the individual does not meet the security-threat-assessment standards and may pose an imminent threat to transportation or national security.

The notice should include:

A statement that TSA determined the person poses a security threat warranting immediate revocation;
The basis for TSA’s determination, subject to restrictions on protected information;
Information explaining how to appeal; and
A warning that the initial determination becomes final if the person does not timely appeal.

An immediate revocation can arise from:

A reportedly disqualifying criminal conviction;
A newly discovered warrant or indictment;
A criminal record without a reported disposition;
Immigration-status information;
A qualifying mental-capacity determination;
Terrorism-related, intelligence, or other security information;
Information obtained after the credential was issued; or
An inaccurate or incomplete record that TSA believes establishes ineligibility.

The notice’s exact title and stated basis matter. Appeals involving criminal history, immigration status, or mental capacity ordinarily proceed under § 1515.5. Different procedures under § 1515.9 may apply when the determination rests on terrorism-related, intelligence, or other security analyses.

What Should You Do Immediately?

Take the following steps as soon as you receive the notice:

Stop using the affected credential or endorsement.
Read every page of the TSA notice.
Record the date you received it.
Preserve the envelope and electronic delivery information.
Determine whether TSA revoked a TWIC, directed revocation of an HME, or took both actions.
Identify everyone TSA notified.
Save copies of any employer or state licensing communications.
Calendar the appeal deadline.
Begin gathering court, corrections, immigration, or other official records.
Obtain legal advice before submitting an incomplete response or making unnecessary admissions.

Do not assume the physical expiration date printed on the TWIC or CDL means the credential remains usable. TSA can electronically invalidate a TWIC before its printed expiration date, and a state can revoke an HME that otherwise appears unexpired on the physical CDL.

Who Does TSA Notify About an Immediate Revocation?

The recipients depend on the credential involved.

TWIC Immediate Revocation

Under 49 C.F.R. § 1572.21(d)(3), TSA may serve an Initial Determination and Immediate Revocation on:

The TWIC holder;
The holder’s employer, where appropriate;
The appropriate Federal Maritime Security Coordinator; and
The Coast Guard when the holder is a mariner applying for or holding a TWIC.

Facilities and vessels may then be able to confirm that the card is invalid through the applicable TWIC verification systems.

HME Immediate Revocation

Under 49 C.F.R. § 1572.15(d)(3), TSA may serve the determination on:

The commercial driver;
The driver’s employer, where appropriate; and
The state that issued the HME.

The state, rather than TSA, controls the CDL document and the endorsement displayed on it. Under § 1572.13, the state must immediately revoke the HME when TSA issues the state an Initial Determination of Threat Assessment and Immediate Revocation.

TSA’s decision can therefore reach an employer or government agency before—or around the same time—that the credential holder receives the mailed notice.

What Happens When a TWIC Card Is Revoked?

An immediately revoked TWIC is no longer valid for the access it previously authorized.

The holder should not:

Present the TWIC for unescorted access;
Attempt to enter a secure area based on the invalidated card;
Represent to an employer or facility that the card remains valid;
Assume that filing an appeal automatically reactivates the card; or
Continue performing duties that legally require a valid TWIC unless the employer confirms a lawful alternative.

TSA’s notice should explain the immediate action and appeal process. Follow any instructions concerning possession, return, or surrender of the physical card.

Loss of Unescorted Access to Secure Maritime Areas

A TWIC is generally required for unescorted access to secure areas of regulated maritime facilities and vessels.

Once TSA invalidates the TWIC, the worker ordinarily loses the ability to use it for unescorted access. That can affect:

Longshore and terminal work;
Vessel assignments;
Port trucking;
Shipyard access;
Maritime construction;
Stevedoring;
Facility maintenance;
Contractor work; and
Other jobs requiring entry into a Maritime Transportation Security Act-regulated secure area.

Whether the worker can remain employed in another capacity depends on the employer, facility-security rules, available nonsecure work, applicable collective-bargaining provisions, and other legal requirements.

An escort arrangement may be possible in limited circumstances under facility or vessel security procedures, but it is not an automatic right and may not be practical for the worker’s normal duties. The employer and facility security personnel control access consistent with the applicable security plan.

What Happens to a Merchant Mariner Credential?

A TWIC revocation and a Merchant Mariner Credential revocation are distinct government actions, but one can affect the other.

When TSA issues an immediate TWIC revocation involving a mariner, TSA may notify the Coast Guard. Under 46 C.F.R. § 10.235:

A mariner whose TWIC is revoked for a nonadministrative reason is deemed ineligible for an MMC;
The Coast Guard may initiate suspension-and-revocation proceedings against the MMC;
The TSA decision itself ordinarily is not relitigated in the later Coast Guard proceeding; and
Failure to hold a valid TWIC can be treated as proof that the mariner is not eligible for the MMC.

This means a mariner may need to address the TSA matter promptly to protect both secure-area access and the underlying maritime credential.

A TSA appeal does not necessarily halt every Coast Guard or employment consequence. Mariners should preserve all TSA and Coast Guard correspondence and determine whether a separate response is required in any Coast Guard proceeding.

For information about separate Coast Guard credential matters, review our Merchant Mariner Credential representation.

What Happens When an HME Is Immediately Revoked?

TSA conducts the federal security-threat assessment for a hazardous materials endorsement, but the state licensing authority issues, renews, transfers, denies, and revokes the HME.

When TSA issues an Initial Determination and Immediate Revocation, 49 C.F.R. § 1572.13 requires the state to revoke the endorsement immediately.

The driver may remain licensed to operate commercial vehicles for which the remaining CDL class and endorsements are valid, but the driver cannot lawfully perform work requiring the revoked HME.

The practical consequences may include:

Removal from hazardous-materials routes;
Loss of tanker or fuel-delivery assignments that require the HME;
Reassignment to nonhazardous freight;
Suspension from work;
Loss of a conditional job offer;
Employer reporting requirements; or
Separate state licensing correspondence.

The driver should promptly obtain:

The TSA determination;
The state’s revocation notice;
A current CDL record;
Any Commercial Driver’s License Information System update;
The employer’s written response; and
Any deadline stated in a separate state notice.

A successful TSA appeal can resolve the federal security-threat determination. It does not automatically resolve an unrelated CDL disqualification imposed under state law or 49 C.F.R. § 383.51.

For an explanation of the division between TSA and state licensing authorities, review our hazardous materials endorsement guidance.

Does Filing an Appeal Restore the TWIC or HME?

Ordinarily, no.

The regulations give a person the right to appeal an immediate revocation, but they do not provide that merely filing the appeal automatically restores the TWIC, HME, or unescorted access while TSA considers the case.

The credential generally remains invalid unless and until TSA withdraws the adverse determination and the other responsible agencies complete any necessary restoration steps.

For an HME, that may mean the state must update the driver’s licensing record after receiving a favorable TSA determination. The driver should not resume hazardous-materials transportation until the state confirms that the endorsement is valid.

For a TWIC, the holder should not attempt to use the card until TSA and any affected facility confirm that the credential is valid.

How Do You Appeal an Immediate Revocation?

Under 49 C.F.R. § 1515.5(h), a person may appeal:

TSA’s direction to a state to revoke an HME; or
TSA’s invalidation of a TWIC through an Initial Determination of Threat Assessment and Immediate Revocation.

For an ordinary determination based on criminal history, immigration status, or mental capacity, the appeal follows the procedures in § 1515.5(b).

The credential holder generally initiates the appeal by:

Submitting a written reply disputing TSA’s determination;
Submitting a written request for the releasable materials on which TSA relied; or
Requesting an extension of time for good cause.

If the person does not initiate an appeal within 60 days after receiving the Initial Determination and Immediate Revocation, the determination ordinarily becomes final.

If the case involves terrorism-related, intelligence, or other security analyses, the procedures in § 1515.9 may apply instead. Read the notice carefully because the appropriate procedure depends on TSA’s stated basis.

When Is an Appeal Appropriate?

An appeal argues that TSA’s immediate-revocation determination is factually or legally incorrect.

Potential grounds include:

The criminal record belongs to another person;
TSA reported an arrest as a conviction;
The criminal-history report omitted a dismissal or acquittal;
The conviction was for a misdemeanor rather than a listed felony;
The original felony charge was amended or reduced;
TSA relied on an incorrect conviction date;
TSA relied on an incorrect release-from-incarceration date;
An interim offense falls outside the seven-year and five-year periods;
The offense does not match TSA’s identified regulatory category;
TSA misclassified simple possession as distribution or possession with intent to distribute;
A warrant was recalled or satisfied;
An indictment was dismissed;
A conviction was reversed or vacated;
A qualifying pardon affects TSA’s treatment of the conviction;
TSA relied on inaccurate immigration documentation; or
The mental-capacity information is incomplete or legally inapplicable.

An appeal should address every basis stated in the notice. Resolving one record may not help if a second ground independently supports TSA’s determination.

For a detailed explanation of the process, review how to appeal a TWIC denial or our guidance for a denied hazmat endorsement.

Should You Request TSA’s Underlying Materials?

Often, yes.

Under § 1515.5, the credential holder may timely request copies of the releasable materials on which TSA based the determination.

This can be particularly important when:

The notice describes the alleged offense only generally;
You do not recognize the case;
The dates do not match your records;
Several criminal matters could have triggered the action;
TSA’s legal classification is unclear;
The notice relies on a warrant or indictment you believe was resolved; or
You need to identify whether the information came from the FBI, a state repository, a court, or another agency.

A timely request for materials generally initiates the appeal. The applicant ordinarily may submit the complete written reply within 60 days after TSA serves its response to the request.

TSA will not disclose classified information and may withhold other information protected by law.

Requesting TSA’s file does not restore the credential and should not delay independent evidence collection. Begin requesting the likely court, corrections, immigration, and agency records immediately.

What Records Can Support an Immediate-Revocation Appeal?

Depending on TSA’s stated basis, relevant evidence may include:

Government-issued identity documents;
Certified charging instruments;
Certified judgments;
Dismissal or nolle prosequi orders;
Judgments of acquittal;
Amended charges;
Sentencing records;
Corrections records establishing release dates;
Warrant-recall or quashing orders;
Orders dismissing an indictment;
Appellate mandates;
Vacatur orders;
Pardons;
Corrected FBI Identity History Summaries;
Corrected state criminal-history records;
Immigration-status documents;
Medical or judicial records relevant to a mental-capacity determination;
Court clerk certifications; and
Evidence establishing that a record belongs to someone else.

An attorney’s legal argument can explain why the evidence defeats TSA’s determination, but argument does not substitute for official proof of the underlying disposition or correction.

Can You Request a Waiver After an Immediate Revocation?

Potentially, if the condition is waivable.

An appeal and a waiver make different arguments:

An appeal asserts that TSA’s facts or legal conclusion are wrong.
A waiver generally accepts that a covered disqualifying condition exists but asks TSA to determine that the individual does not pose a security threat.

Not every offense or condition is waivable. Waiver eligibility depends on the precise category in TSA’s regulations.

Some credential holders should appeal and request a waiver in the alternative. For example, the holder may dispute whether a state offense matches TSA’s federal category while also presenting rehabilitation evidence if TSA rejects that legal argument.

Alternative submissions require careful drafting. A poorly worded waiver request can appear to concede a fact or legal conclusion that the person intended to challenge.

Learn more about TWIC waiver and appeal representation and HME waiver representation.

Can You Request an Extension?

Yes. Under § 1515.5(f), TSA may grant an extension for good cause.

The written request should:

Identify the credential holder and determination;
State the current deadline;
Explain why additional time is necessary;
Identify the records already requested;
Describe delays outside the holder’s reasonable control;
State the additional time requested; and
Be submitted within a reasonable time before the deadline.

If the deadline has already expired, the person may submit a written request explaining why the late filing was excusable. TSA has discretion to grant or deny the request.

An extension does not automatically restore a revoked credential. Continue preparing the substantive response while the request remains pending.

Emergency Employment Documentation

A worker whose TWIC or HME was immediately revoked may need to address employment consequences before TSA decides the appeal.

Create an organized employment-protection file containing:

The complete TSA notice;
The envelope or proof of electronic delivery;
Proof that an appeal or request for materials was submitted;
The employer’s written notice;
Any state HME revocation letter;
Any Coast Guard correspondence;
The collective-bargaining agreement, if applicable;
Relevant employer credentialing policies;
A written job description;
Records of seniority and employment history; and
Documents showing any request for reassignment, leave, or alternative duties.

Depending on the workplace, possible interim measures may include:

Reassignment to work outside secure areas;
Reassignment to commercial driving that does not require an HME;
Temporary administrative duties;
Paid or unpaid leave;
Use of a contractual grievance procedure;
Union representation; or
A narrowly tailored confirmation that the TSA appeal is pending.

These measures are not guaranteed. The available option depends on the credential’s status, the worker’s duties, employer policy, applicable labor agreements, and safety requirements.

What Should You Tell Your Employer?

Be accurate and restrained.

Do not claim that:

The credential remains valid;
TSA made only a clerical error before confirming the evidence;
Filing an appeal reinstated the credential; or
Approval is guaranteed.

When appropriate, a worker may provide written confirmation that:

The TSA notice was received on a particular date;
A timely appeal or request for materials was filed;
The credential cannot presently be used;
The worker is requesting temporary reassignment or leave; and
The worker will provide an update when TSA issues a decision.

Avoid disclosing unnecessary medical, immigration, or criminal-history information beyond what is required by law, policy, or a legitimate employment process.

What Happens After TSA Reviews the Appeal?

After receiving the credential holder’s written reply, TSA may:

Request additional information;
Withdraw the Initial Determination; or
Issue a Final Determination of Threat Assessment.

TSA ordinarily issues a decision within 60 days after receiving the reply, although it may extend its time for good cause. Actual processing times vary.

If TSA Withdraws the Determination

If TSA concludes that the person does not pose a security threat, it serves a Withdrawal of the Initial Determination. TSA may also notify the employer where applicable.

Further administrative steps may still be necessary:

A TWIC holder may need confirmation that the card has been reactivated or instructions concerning replacement;
A maritime facility may need updated credential information;
An HME holder may need the state to restore the endorsement and update CDLIS; or
A mariner may need to address any separate Coast Guard proceeding.

Do not resume credential-dependent work until the responsible agency or facility confirms that the credential or endorsement is valid.

If TSA Issues a Final Determination

A Final Determination based on an ordinary criminal-conviction, immigration-status, or mental-capacity appeal is a final TSA order for purposes of judicial review under 49 U.S.C. § 46110.

A person with a waivable condition may also be able to request a waiver within the applicable period. A waiver denial generally may be reviewed by a TSA Administrative Law Judge if the request for review is filed within 30 calendar days after service.

Different review procedures apply to determinations based on other security analyses.

When Is an Attorney Particularly Useful?

Legal representation may be especially valuable when:

Your TWIC or HME has already been invalidated;
Your employer or state was notified;
Your livelihood depends on immediate secure-area or hazardous-materials access;
You hold a Merchant Mariner Credential;
The criminal record is incomplete;
TSA classified a state offense under the wrong federal category;
Several criminal matters are involved;
A warrant or indictment has been resolved but remains in a database;
Conviction or release dates determine eligibility;
Immigration documents are involved;
TSA’s notice refers to other security information;
You may need both an appeal and a waiver; or
The deadline is approaching.

An immediate-revocation case is not strengthened by sending the fastest possible personal letter. It is strengthened by identifying TSA’s exact basis, obtaining reliable source records, applying the correct federal standard, and protecting every available remedy.

What Does National Security Law Firm Do?

For qualifying immediate-revocation matters, our work generally includes:

Reviewing every page of the TSA notice;
Confirming the type of determination and deadline;
Identifying who TSA notified;
Determining whether § 1515.5 or § 1515.9 applies;
Requesting TSA’s releasable materials when appropriate;
Distinguishing an appeal from a waiver;
Identifying the source of disputed information;
Obtaining ordinary court and disposition records;
Reviewing criminal-history reports;
Calculating conviction and release-from-incarceration periods;
Analyzing whether the offense matches TSA’s regulatory category;
Developing supporting evidence;
Preparing the written legal submission;
Organizing and labeling exhibits;
Submitting the response;
Preserving proof of filing; and
Managing ordinary TSA requests through the covered initial stage.

We represent TWIC holders and commercial drivers nationwide. We have handled TWIC and HME matters since 2016 and have represented applicants in hundreds of TSA credential cases.

Our experience does not give us special influence over TSA, a state licensing agency, the Coast Guard, or an employer. It helps us identify the procedural, evidentiary, and legal issues that need to be resolved promptly.

How Much Does an Immediate-Revocation Lawyer Cost?

National Security Law Firm charges a flat legal fee of $2,495 for qualifying initial-stage TWIC or HME appeal or waiver representation.

The covered service generally includes legal analysis, ordinary court-record procurement, evidence development, preparation, submission, and management through the covered TSA stage, as described in the written engagement agreement.

Unless expressly included, the fee does not cover:

Unusual third-party expenses;
Extensive litigation to correct a source record;
An expungement or post-conviction proceeding;
A separate waiver after completion of an appeal;
Administrative Law Judge review;
TSA Final Decision Maker review;
Federal-court litigation;
A Coast Guard suspension-and-revocation proceeding;
A state CDL proceeding;
A union grievance; or
An employment dispute.

The signed engagement agreement controls the precise scope.

Eligible clients may use Pay Later by Affirm to divide the legal fee into monthly payments. Financing availability and terms are determined by the financing provider.

Financing and the Written Refund Guarantee

National Security Law Firm offers a written refund guarantee in certain qualifying accepted TWIC and HME matters.

The refund guarantee does not promise that TSA will withdraw the revocation, that a state will restore an HME, that the Coast Guard will preserve an MMC, or that an employer will reinstate the worker. Those decisions remain under the control of the responsible government agency or employer.

When the guarantee applies, the signed engagement agreement identifies the covered result and the circumstances under which NSLF will refund the covered $2,495 legal fee if that result is not achieved.

The guarantee:

Applies only when expressly included in the signed engagement agreement;
Covers only the legal fee identified in that agreement;
Is subject to stated terms, exclusions, and client responsibilities;
Does not control or guarantee a government decision; and
Does not necessarily cover third-party expenses or advanced proceedings.

We do not accept every immediate-revocation case for guaranteed representation. We first review the complete TSA notice, procedural stage, deadline, alleged disqualification, available records, and known facts.

Frequently Asked Questions About TWIC and HME Revocations

Why was my TWIC card revoked before its expiration date?

The printed expiration date does not prevent TSA from invalidating the card earlier. TSA may issue an Initial Determination and Immediate Revocation if it concludes that the holder does not meet the security-threat standards and may pose an imminent security threat.

Can I use my physical TWIC card while the appeal is pending?

No. Do not rely on the physical card if TSA has invalidated it. Filing an appeal ordinarily does not reactivate the credential or restore unescorted access.

Can I still enter a port if my TWIC was revoked?

You cannot use the revoked TWIC for unescorted access. Whether a facility permits any escorted access depends on its security plan and operational decisions. Escorted access is not an automatic substitute for a valid TWIC.

Can I keep working if my HME was revoked?

You cannot perform driving that requires a valid HME. You may be able to perform other commercial-driving or nonhazardous-materials duties if your CDL otherwise remains valid and your employer has appropriate work available.

Does TSA revoke my entire CDL?

TSA determines federal eligibility for the HME. The state issues and controls the CDL and its endorsements. An immediate TSA determination requires the state to revoke the HME, but separate rules determine the status of the underlying CDL and other endorsements.

Will my employer be notified?

TSA may notify the employer where appropriate. In a TWIC case, TSA also notifies the appropriate Federal Maritime Security Coordinator and may notify the Coast Guard for a mariner. In an HME case, TSA notifies the state.

Does TWIC revocation automatically revoke my MMC?

The actions are legally distinct. However, TSA may notify the Coast Guard, and Coast Guard regulations provide that a mariner whose TWIC is revoked for a nonadministrative reason is ineligible for an MMC. The Coast Guard may initiate a separate suspension-and-revocation proceeding.

How long do I have to appeal?

The notice generally provides 60 days after receipt to initiate the appeal. Review the exact notice immediately because the governing process can differ depending on whether TSA relied on criminal history, immigration status, mental capacity, or other security information.

Does requesting TSA’s records count as initiating an appeal?

A timely written request for the releasable materials on which TSA relied generally initiates an appeal under § 1515.5. The holder ordinarily may submit the complete written reply within 60 days after TSA serves its response to the records request.

Can TSA refuse to disclose some of the evidence?

Yes. TSA does not disclose classified information and may withhold other information protected from disclosure by law.

Can I obtain an emergency or expedited TSA decision?

The regulations provide appeal procedures but do not guarantee expedited adjudication because employment is at risk. The submission should document urgent consequences where relevant, but TSA controls its processing and decision timeline.

Does filing an appeal protect my job?

No. Filing an appeal preserves the TSA challenge but does not automatically restore the credential, prevent state action, or require an employer to continue a particular assignment. Employment rights depend on the applicable law, policies, contracts, and facts.

Can rehabilitation restore an immediately revoked credential?

Rehabilitation generally supports a waiver rather than an appeal. If the underlying condition is accurate and waivable, a properly supported waiver may provide relief. If TSA’s facts or legal classification are wrong, the appropriate remedy is an appeal.

Does NSLF guarantee that my credential will be restored?

No. TSA, the state, the Coast Guard, and other responsible entities control their own decisions. Any refund guarantee applies only to qualifying accepted matters under the precise written terms of the engagement agreement.

Request an Urgent Review of Your Revocation Notice

An immediate revocation can affect port access, commercial-driving assignments, an MMC, and a worker’s income before TSA decides the appeal. The response should begin immediately with the complete notice, the correct deadline, the underlying records, and a coordinated plan for the TSA and employment consequences.

National Security Law Firm represents TWIC holders and HME drivers nationwide. Our flat legal fee for qualifying initial-stage TSA appeal or waiver representation is $2,495. Financing may be available, and certain accepted cases may include a written refund guarantee subject to the engagement agreement.

When contacting us, provide:

Every page of the TSA notice;
The envelope or electronic delivery information;
The date you received it;
Any employer, state, or Coast Guard correspondence;
Court or agency records already in your possession; and
The date of any threatened suspension, termination, or licensing action.

Schedule an urgent free consultation or call (202) 600-4996.

Official Immediate-Revocation Resources

Author: Katherine O’Brien, Esq., Founder, National Security Law Firm
Attorney Reviewed: August 26, 2026

This page provides general information and is not legal advice. Viewing this page or contacting the firm does not create an attorney-client relationship. Past results do not guarantee future outcomes. This website is an attorney advertisement. Any fee, scope of representation, financing arrangement, or refund guarantee is governed exclusively by a signed written engagement agreement.