Have you selected your Third-Party Organization for Subchapter M Compliance? Have you entered into a formal agreement yet? Don’t wait until July 20, 2018 to start planning for your External Management Audit for a TSMS Certificate. You must be operating under a valid TSMS Certificate for a minimum of 6 months prior to the issuance of a COI for a vessel.
If you are AWO RCP Certified and have a Mid-Period Management Audit due this year, you should consider having your External Management Audit for a TSMS Certificate completed in conjunction with your RCP Mid-Period Management Audit. Your Mid-Period Management Audit will need to review the gap between your last certification audit and the 2016 revisions to the RCP, in addition to the requirements for a Mid-Period Management Audit. The delta between that audit and a TSMS Compliance audit is not that great.
If your company is AWO RCP Certified, have you considered what you audit rotation cycle will look like? There could be an overlap of audit cycles for RCP and TSMS compliance. TVIB stands ready to work with your organization to set up a plan to give you the greatest value in your upcoming audits while lessening the burden of overlapping audit cycles or “audit creep.”
TVIB will be releasing the External TSMS Management Process and Audit Checklist to its members in the coming days. Make certain that you have updated your contact information on the Member Portal so you can access these documents as soon as they are published. We will send out an announcement when they are available for download from the Member Portal on the TVIB website.
For more information on selecting TVIB as your TPO or if you have questions related to Subchapter M compliance, contact Tava Foret at 832-323-2155 or tavaf@thetvib.org or Chris Parsonage at 832-323-2188 or chrisp@thetvib.org.
