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that are still debating on their Sub M biggest bene? t is that due to the pool another day of doing business. How- compliance avenue, the TPO option of certi? ed talent available, there ever, for those still uncertain about may be right choice, especially this is scheduling and pricing ? exibil- selecting the USCG or TPO/TSMS late in the game. Here are some of ity available to owner/operators and option, there is no time to wait. Re- the key differences and planning tips with each day getting closer to July, member, there is no wrong choice. to consider. that becomes invaluable. (Refer to The only wrong choice is to not make • Select a TPO that best meets USCG CVC Policy letter 18-01 for a decision and move ahead. Consider your needs, including your wallet: further guidance.) this your warning: The ? nal count-

Owner/operators should be aware of Many owners/operators have done down to Subchapter M is of? cially the bene? ts to outsource their exter- their due diligence and are in good here and you’re running out of time. nal audit and vessel surveys through position to make July 20, 2018, just Choose wisely.

TPOs. There is added ? exibility to shop around to use certi? ed auditors and surveyors that meet owners/opera- tors’ needs. The TPO market is ? lled with both established players such as

ABS, DNV-GL, ClassNK America and also newer TPOs, such as TVIB and Meridian Global. • Schedule a TSMS Exter- nal Audit/Vessel Survey: Owners/ operators must demonstrate compli- ance and pro? ciency to the require- ments of the TSMS. This is veri? ed by a TSMS approved Lead Auditor and a Certi? ed vessel surveyor. Certi- ? ed auditors and surveyors have been vetted and are authorized to work through TPOs. This area provides owner/operators with the greatest tool to meet their compliance needs. The

Richard Paine is a licensed mariner, certi? ed TSMS & AWO-

RCP Lead Auditor and DPA with over 20 years of maritime and auditing experience ranging from deep sea, tugs & towing, and passenger vessels. He is an alumnus of SUNY Maritime College in both undergraduate and graduate studies. A member of PVA’s Safety &

Security Committee, he is currently is the Regional Director, HSSQE for

Hornblower’s NYC Ferry & Statue

Cruises operations. Richard can be reached at [email protected] www.marinelink.com MN 27

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