How August 23, 2018, or 448 days and a wake up. That's when your Risk Group A facility must be read to go, which includes:

• Having the required electronic TWIC readers or PACS operational.

• Having a Coast Guard COTP approved FSP or FSP amendment that includes electronic TWIC inspection.

Remember, you should plan to submit your new FSP (that will require a new/updated FSA) or FSP amendment in ample time to obtain Coast Guard approval. That means at least 60 days prior to August 23, 2018. Trust us, it'll take you at least 60 days to adequately prepare/amend your FSP to meet the TWIC Final Rule requirements. All considered, that's 120 days before August 23, 2018. 

Are you paying attention? August 2018 just became April 2018 on your TWIC Final Rule planning calendar. That's the latest when you should be underway and making way in preparing to comply with the TWIC Final Rule.