Integrated Management System Manual

Quality-Environment-Health-Safety-Security ISO: 9001: 000 ! "#1$001% - ISO 1$001: 00&

EHS'S (olicies (lanning

#ontinual Im)rovement

Im)lementation

(lan ! ,o ! #hec-- *ct

Management "evie+

#orrective *ction

Table of Contents Introduction to Company, Inc Purpose & Scope Normati e references !n Integrated "anagement System "anagement $esponsibility & $e ie% Planning & $esource "anagement (ocumentation & $ecords Customer *ocus Product $eali+ation ."S Supporting /lements $esponsible Care0 /1S&S Supporting /lements "easurement, (ata !nalysis & !udits Continual Impro ement Page 4 Page 4 Page # Page & Page ' Page ) Page ) Page ,Page ,Page ,, Page ,3 Page ,4 Page 3

Introduction to .#om)any/0 Inc1

Xtreme Provider .#om)any/0 Inc1 23*S,*Q: .#OM(*34/5 is a less-than-truc-load )rovider of regional0 interregional and guaranteed services covering 6$ states1 .#om)any/ is home to the industry-leading 7treme 8uarantee )roduct0 +hich guarantees total customer satisfaction from )ic--u) through invoicing1 .#om)any/ offers com)lete 3orth *merican coverage through )artner agreements1 Xtreme Network .#om)any/ has: ,irect coverage throughout 6$ states

1&1 terminal locations *))ro9imately :0$00 em)loyees More than 100000 )ieces of e;ui)ment

Xtreme Growth .#om)any/ +as founded in 19 $ +ith one terminal in Houma0 <ouisiana and continued to e9)and +ith terminals throughout <ouisiana and =e9as1 In 1996 +hen 4ello+ #or)oration )urchased .#om)any/0 there +ere 6 terminals and limited coverage in & states1 In 199&0 Smalley =rans)ortation +as merged into .#om)any/0 ma-ing a nine-state service area1 *lso in 199&0 .#om)any/ o)ened terminals in 3orth and South #arolina and >estern =e9as0 allo+ing the com)any to )rovide 100 )ercent coverage of 11 Southern States1 .#om)any/ continued to gro+0 e9)anding to 1 states +ith ?@ terminals and more than $0?00 em)loyees in the late 1990s1 In Aanuary 0010 .#om)any/ integrated >estE9 and *ction E9)ress into .#om)any/0 e9)anding coverage to 1 states +ith more than 100 terminals and more than &0000 em)loyees1 In 0010 S#S =rans)ortation0 a holding com)any +as formedB o)erating com)anies included .#om)any/ and Aevic =rans)ortation1 In 00 0 4ello+ #or)oration s)un off S#S =rans)ortation into an inde)endent0 )uClicly traded com)any on the 3*S,*Q E9change1 .#om)any/ announced the ac;uisition of #lar- Dros1 in EeCruary 00$0 integrating nine additional states and 1@ terminals1 In May 00$0 the integration of the com)any +as com)lete0 )roviding .#om)any/ +ith coverage in -ey Mid+estern areas0 from a net+or- of 1 ? terminals1 In 00@0 .#om)any/ +as made the sole o)erating sector of the com)any and +as re-Cranded as .#om)any/0 Inc1 =he com)any Cegan trading on the 3*S,*Q E9change in Se)temCer under the tic-er symCol S-*-I-*1 In 3ovemCer0 .#om)any/ announced the ac;uisition of Mid+estern <=< carrier0 =he #onnection #om)any0 e9)anding their service to four additional Mid+est states1 =oday0 .#om)any/ is one of the most successful <=< carriers in the Fnited States0 ran-ing in the to) ten in the <=< sector1 =he cor)orate head;uarters of .#om)any/0 Inc1 is located in ,uluth0 8*0 +ith Cusiness offices in Houma0 <* and Doise0 I,1

No one delivers like we do. Some call it Xtreme. We can live with that.

Headquarters Address: XXXXXXXXXXXX

,2-

Purpose & Scope ,2, Integrated System Manual3 T4is manual describes Company5s integrated .uality, /n ironmental, 1ealt4, Safety and Security "anagement System2 It includes Company5s policies and describes 4o% t4ese policies are implemented and sustained t4roug4out t4e organi+ation2 T4e core processes of t4e company are described t4roug4out t4is manual %it4 references to supporting procedures and documents2 ,26 Purpose: T4e purpose of Company5s Integrated "anagement System is to ensure ser ice 7uality continues to meet t4e 4ig4 standards demanded by t4e organi+ation and e8pected by our customers9 and to ensure our processes are carried out in an en ironmentally safe, responsible, and protecti e manner2 Scope: T4is Integrated Systems "anual pro ides specifics on t4e policies and procedures used t4roug4out our organi+ation, and are designed to meet t4e re7uirements specified in IS: )--,36---9 $C,4--,09 and IS: ,4--,36--4 and are applicable to all Company facilities at time of implementation2 Ne% facilities %ill be broug4t into t4e certification scope as applicable2 Company 4as e8cluded section '23 (esign and (e elopment from t4e applicable re7uirements of IS: )--,36---, due to t4e nature of our business2 !s a ser ice pro ider, t4is does not affect t4e company5s ability to pro ide ser ice t4at meets customer as %ell as applicable regulatory re7uirements2

,23

62-

Normati e reference T4e follo%ing normati e document contains pro isions, %4ic4 t4roug4 reference in t4is te8t constitute pro isions of IS: )--,36---2 *or dated references, subse7uent amendments to, or re ision of, any of t4ese publications do not apply2 *or undated references, t4e latest edition of t4e normati e document referred to is applicable2 IS: )--- .uality "anagement System ; *undamentals and <ocabulary2

32-

Terms and definitions Supplier ; contractor, endor, subcontractor :rgani+ation ; refers to Company, Inc2 Product ; Ser ice /n ironmental !spects ; /lements of Company acti ities t4at may interact %it4 t4e en ironment2 /n ironmental Impacts ; c4anges to t4e en ironment =negati e>positi e? as a result of t4ose Company acti ities identified as an aspect2 $eferences, (ocuments & *orms 42, .uality "anagement Systems ; $e7uirements !NSI>IS: )--,36--426 $C,4--, Tec4nical Specification 423 @uidelines for 7uality and>or en ironmental management systems auditing ; IS: ,)-,,36--6 424 IS: ,4--,3,))&

42-

#2-

!n integrated .uality /n ironmental, 1ealt4, Safety and Security "anagement System2 #2, IS: )--,36--- ; T4e IS: )--,36--- standard ser es as t4e frame%orA for Company5s .uality "anagement System2 !d4erence to t4e standard pro ides t4e foundation for Best in Class processes and a system t4at supports ongoing continual impro ement2 T4e IS: )--,36--- standard re7uires documented procedures for3 "anagement $esponsibility and $e ie% Control of (ocuments and $ecords Control of Nonconforming Product Correcti e and Pre enti e !ction Internal !udits #26 IS: ,4--,36--4 ; T4e IS: ,4--, standard ser es as t4e frame%orA for Company5s /n ironmental "anagement System2 T4e addition of t4e IS: ,4--, re7uirements pro ides a frame%orA for ser icing our customers in an en ironmentally responsible manner2 Company5s core procedures for t4e /"S are3 :perational Control Procedures Caste "anagement Caste%ater and Storm Cater "anagement "aintenance !cti ities Storage TanAs, SPCC !spects & Impacts /mergency Preparedness and $esponse Compliance %it4 Degal & :t4er $e7uirements including record Aeeping2 #23 $C,4--,0>$esponsible Care0 E $esponsible Care is t4e c4emical industry5s global oluntary initiati e under %4ic4 companies, %orA toget4er to continuously impro e t4eir 4ealt4, safety, en ironmental and security performance2 T4is oluntary initiati e strongly supported by top management2 $esponsible Care0 combined %it4 IS: ,4--, pro ides t4e foundation our /1S&S system2 !s a partner company, Company is committed to continued progress to%ard t4e ision of no accidents, inFuries or 4arm to t4e en ironment and %ill publicly report our progress and lead our company in %ays t4at increasingly benefit society2 Ce pledge to operate our business according to t4e @uiding Principles set fort4 as part of t4e !merican C4emistry Council5s $esponsible Care initiati e2 Gey elements of t4e $esponsible Care program include3 Gey elements described in IS: ,4--,36--4>$C,4--,0 Security "anagement Practices 1eat4 and Safety Practices /n ironment Programs to reduce %aste Community :utreac4 Programs

#24 T4e interErelations4ips among Company5s integrated management system and procedures are illustrated by t4e "anagement Support Process "odel2 T4e correlation bet%een t4e IS: )--,36---, IS: ,4--,36--4 and $C,4--, are illustrated in t4e inde8 of $e7uirements and Procedures2 #2# Quality Policy3 Company5s policies and obFecti es are designed to ensure our transportation ser ices fully comply %it4 t4e customer5s stated re7uirements2 Ce subscribe to a p4ilosop4y of continual impro ement by maintaining and re ie%ing a

&

7uality process intended to conform to t4e re7uirements of IS: )--,36--- as rele ant to our operations2 Stipulations of t4e 7uality process are applicable to all employees %4o s4all obser e and implement suc4 practices according to t4eir Fob responsibilities2 Company5s employees s4all stri e to ac4ie e complete customer satisfaction t4roug4 our commitment to 7uality2 !ll employees s4all remain focused on a common goal as defined by t4e company mission statement3 Provide the best-in-class regional service defined by our Customer Service Indicators with cost effective processes in an environment that respects employees and recogni es e!cellence" Customer Ser ice Indicators0 PicA up Performance :nEtime deli ery ClaimsEfree ser ice Claims under H,--- settled %it4in 3- days In oicing accuracy Proof of deli ery turnaround

#2& #nvironmental Policy Statement: Company management stri es to lead t4e company in an et4ical, safe and secure manner t4at increasingly benefits society, t4e economy, and t4e en ironment %4ile complying %it4 applicable la%s, regulations and ot4er re7uirements and programs including, but not limited to, t4e $esponsible Care @uiding Principles02 Company seeAs to operate its facilities in a manner t4at protects t4e en ironment and t4e 4ealt4 and safety of t4e company5s internal and e8ternal staAe4olders2 Company is dedicated to its ision of 4a ing no accidents t4at can cause inFury or 4arm to t4e en ironment2 T4e company5s progress is continually measured t4roug4 programs %4ic4 set target obFecti es t4at gauge Company5s success as %ell as t4roug4 pollution pre ention programs t4at support our en ironmental commitment2 :ur pledge to t4e en ironment is supported by our status as a Smart Cay Transport Partner, collaboration bet%een t4e /n ironmental Protection !gency and t4e freig4t industry t4at seeAs to increase energy efficiency %4ile reducing green4ouse gases and air pollution2 Company is committed to t4e follo%ing goals3 No accidents No inFuries $educing Caste $eduction of @reen4ouse @ases and !ir Pollution Community :utreac4 "inistries #2' Core Beliefs Best in Class = Excellence Customer #!cellence: Company recogni+es t4at consistently deli ering on time ser ice is only one c4aracteristic of a $est in Class pro ider2 $elations4ips %it4 our customers are e7ually important2 Company continually stri es to anticipate customer needs and re7uirements, impro e our responsi eness to customers, and pro ide our customers %it4 t4e Best in Class ser ice t4ey 4a e come to e8pect, as reflected in t4e %Company& Customer Service Indicators #mployer #!cellence: T4e de elopment and continual impro ement of Company5s business is e8pected at all le els of t4e organi+ation2 Company5s management and leaders4ip stri e to impro e ser ice to our customers by pro iding employees %it4 information, training, and opportunities to impro e processes2

#2I Policy Communication ' (eview3 T4e .uality and /1SS policies and practices are communicated and discussed %it4 ne% employees as part of t4eir orientation, and are displayed in arious locations t4roug4out t4e %orAplace2 Periodically, management re ie%s t4ese policy statements to ensure t4eir ongoing suitability to t4e organi+ation2

&2-

"anagement $esponsibility & $e ie% &2,Management Commitment3 Company e8ecuti e management is committed to and acAno%ledges its responsibility for pro iding a 7uality policy, establis4ing a management representati e, and conducting management system re ie%s2 "anagement is responsible for3 Pro iding leaders4ip and communication to t4e organi+ation Promoting an open door policy (efining strategic goals and obFecti es, including statutory and customer re7uirements2 /nsuring continual impro ement of processes and products and t4e integrated management system2 (efining Fob descriptions and organi+ational responsibilities for all employees2 &26 (esponsibility for Integrated Management System3 Company5s management and leaders4ip are responsible for creating and implementing policies and procedures2 !ll process o%ners are responsible for ensuring t4at processes are properly controlled and carried out as planned2 !ll employees are responsible for t4e 7uality of t4eir %orA, as it contributes to t4e 7uality of our ser ice2 "anagers and leaders recogni+e t4at t4ey must ensure e ery employee is appropriately trained, and able to taAe correcti e action %4en necessary2 In addition, opportunities to impro e e8isting processes are soug4t and taAen %4en beneficial2 /8ecuti e planning strategies are communicated to employees t4roug4 management staff, 7uarterly meetings, and arious electronic communications2 T4e 7uality department is responsible for3 /nsuring re7uirements of t4e integrated management system, comprised of IS: )--,36---, IS: ,4--,36--4 and t4e $C,4--,0 tec4nical specification, are understood, implemented, and maintained t4roug4out t4e organi+ation2 /nsuring correcti e actions are implemented to resol e issues identified in internal and>or e8ternal audits2 Conducting system audits to ensure conformance to t4e integrated management system re7uirements2 $eporting to top management on t4e effecti eness of t4e integrated ."S>/1SS including process conformance and customer data2 &23Management (eview3 "anagement re ie% of t4e ."S>/1SS occurs at least annually to ensure its continuing suitability, ade7uacy and effecti eness2 T4is re ie% includes assessing opportunities for impro ement and t4e need for c4anges to t4e system, including ."S>/1SS polices and related obFecti es2 $ecords generated as a result of management re ie% are maintained2 "anagement re ie% meetings are conducted more fre7uently in certain locations due to t4e nature of t4e operation, comple8ity, si+e, and particular issues2 Support and>or $eference (ocuments "anagement $e ie% "inutes>$ecords

'2-

Planning & $esource "anagement '2,Quality Planning: Company is dedicated to ensuring ser ices conform to t4e standards and specifications re7uired by our customers2 Process specific instructions supporting t4ese acti ities are referred to as t4e Integrated .uality and /1S&S system2 T4e integrated management system is comprised of t4e Integrated "anagement System "anual, procedures, process instructions, and associated templates, forms and records2 Corporate obFecti es including Company5s Customer Ser ice Indicators are defined and documented2 T4ese obFecti es are re ie%ed as part of t4e management re ie% process and are considered as part of t4e business planning process2 :perational obFecti es are establis4ed by t4e operations management team and are designed to measure and erify appropriate performance and>or conformance t4roug4out t4e life of t4e process2

#nvironmental Management: /n ironmental obFecti es are establis4ed based on t4e !spect and Impacts study2 :bFecti es are translated into specific departmental targets2 $esponsibility for ac4ie ing t4ese targets is gi en to t4e appropriate department managers or teams as designated by top management2 /n ironmental !spects3 Company conducts regular re ie%s of its business to identify and prioriti+e t4e significant en ironmental aspects associated %it4 its operations2 T4is assessment is re ie%ed as part of t4e management re ie% process at least annually2 !dditional re ie%s of en ironmental aspects and impacts may be initiated as a result of a significant c4ange to facility location, process c4anges or ot4er business planning acti ities2 /n ironmental aspects and impacts are integrated %it4 t4e 4a+ards and risAs assessment2 T4e 4a+ard and t4e aspect are bot4 t4e cause, and t4e risA and t4e impact are t4e effect, %4et4er ad erse or beneficial in %4ole or part, as a result of acti ities, processes, products or ser ices2 In ot4er %ords, Company considers an en ironmental aspect to be one form of a 4a+ard, and an en ironmental impact to be one form of a risA2 T4us, all 4a+ards %4et4er en ironmental, 4ealt4, safety, or security related are e aluated and compared using t4e same met4odology to determine t4eir relati e significance2 )a ards and (is*s3 /1S&S 4a+ards, and risAs associated %it4 t4ose 4a+ards, are identified and e aluated for ne% and e8isting products and processes, c4anges to e8isting products and processes, for t4e distribution and transportation of materials, and for acti ities associated %it4 operations2 +egal and (egulatory (e,uirements3 !s part of its responsibilities arious departments suc4 as Safety and 1$ maintain a liaison %it4 applicable outside 3 rd party and go ernmental agencies regarding legal and regulatory re7uirements suc4 as en ironmental, (:T and :S1! regulations2 T4ese re7uirements are considered and re ie%ed periodically and communicated as part of obFecti es and performance targets2 -b.ectives ' /argets3 !ll obFecti es associated %it4 t4e integrated management system are defined and documented %it4in planning processes and communicated to functional areas and departments as necessary2 (esource Management3 $esources are allocated against re7uirements and are re ie%ed and supplemented %4ere necessary2 T4is includes resources needed for maintenance of t4e .uality and /1S&S system2

)uman (esources3 !ll employees are 4ired based on t4e defined 7ualifications for a specific position2 T4is 7ualification includes specific regulatory re7uirements, certifications etc2, %4ere applicable2 Competence0 awareness and training: !ll employees are deemed competent on t4e basis of appropriate education, training, sAills and e8perience2 "anagement determines t4e necessary competence, pro ides training or taAes ot4er actions to satisfy t4ese needs, e aluates t4e effecti eness of t4e actions taAen, ensures t4at employees are a%are of t4e rele ance and importance of t4eir acti ities and 4o% t4e contribute to t4e ac4ie ement of t4e .uality and>or /1S&S obFecti es2 !ppropriate records of education, training, sAills and e8perience are maintained as applicable2 Infrastructure and 1or* #nvironment: Company determines, pro ides for, and maintains t4e infrastructure needed to ac4ie e conformity to re7uirements2 Infrastructure includes, as applicable3 buildings, %orAspace and employed utilities, process e7uipment =bot4 4ard%are and soft%are?, and supporting ser ice2 /7uipment, tools, and supplies are made a ailable as appropriate to eac4 Fob function and area2

I2-

(ocumentation and $ecords I2, Controlled 2ocuments: T4e Integrated ."S>/1S&S manual, associated procedures, process instructions and forms are controlled documents2 T4ese documents and any c4anges to t4ese documents are under re ie%, appro al, and re ision control2 !t minimum, c4anges to any ."S>/1S&S documentation re7uires t4e appro al of t4e .uality "anager and>or (irector of Safety and Training2 :t4er appro als are obtained as necessary2 Control of (ecords: $ecords re7uired in support of t4e integrated ."S>/1S&S system are identified and maintained by t4e appropriate department2 T4is includes bacAup and storage of electronic records2 $ecords are stored and maintained in a manner to pre ent deterioration, damage, or loss and are readily accessible %4ere needed2 "inimum retention periods are establis4ed2 !fter t4e minimum retention period, records may be destroyed, stored at an offEsite location, or retained for 4istorical purpose2 3ncontrolled 2ocuments: Printed copies of documents are considered uncontrolled2 !ll employees are ad ised to erify any printed documents against t4e electronic ersion to ensure current re ision2 Controlled copies are maintained in electronic format on t4e intranet %%Company&net2 !ll documents and records are identifiable and maintained in a legible format2

I26

I23

)2-

Customer *ocus3 )2, Customer focus: Company continually stri es to impro e its responsi eness to its customers, to anticipate and meet customers5 re7uirements, and to pro ide Best in Class ser ice as defined by our Customer Ser ice Indicators02 Customer feedbacA is managed and collected t4roug4 arious met4ods suc4 as t4e Correcti e !ction Procedure, Customer !d isory Boards, and periodic customer sur eys2 Customer Property3 Company e8ercises care %it4 customer property %4ile it is under our control or being utili+ed by our company2 Company identifies,

)26

erifies, protects and safeguards any customer property pro ided2 If customer property is lost, damaged or ot4er%ise fount to be unsuitable for use, it is reported to t4e customer, and records maintained2 )23 Customer Contracts: Contract in7uiries are re ie%ed by appropriate personnel to ensure re7uirements are understood and t4e necessary information is a ailable to fulfill t4e re7uirements of t4e contract2 Contracts are re ie%ed prior to acceptance, including rene%als and amendments, to ensure t4e understanding of re7uirements, t4e internal capabilities, and Company5s capacity to meet t4e re7uirements as specified2 Customer Service: Customer Ser ice is responsible for pro iding tec4nical support and customer training2 Support ser ices are e8tended at arious capacities based on t4e customers5 needs2 T4is includes call centers, customer ser ice personnel responsible for arious guaranteed ser ices and>or monitoring and communication re7uirements2 Customer Satisfaction: Customer isits, customer sur eys, customer ad isory board meetings and ot4er customer communications are used to gat4er information on customer satisfaction2 T4e results of customer feedbacA are reported, and re ie%ed as part of t4e management re ie% process2

)24

)2#

,-2-

Product (eali ation ,-2- Company defines product reali+ation as t4ose acti ities t4at occur from marAeting to deli ery of customer product2 Company plans and de elops t4e processes needed for product reali+ation2 Planning of product reali+ation is consistent %it4 re7uirements of t4e ot4er processes of t4e ."S>/1S&S integrated system2 In planning product reali+ation Company determines as appropriate3 :bFecti es and re7uirements for t4e process>product2 T4e need to establis4 processes, documents and pro ide specific resources2 $e7uired erification, alidation, monitoring, inspection and test acti ities specific to t4e process>product and t4e criteria for appro al and>or acceptance2 $ecords needed to pro ide e idence t4at t4e reali+ation processes and resulting product meets re7uirements2 !ny 1a+ards and $isAs including en ironmental, 4ealt4, safety, and>or security related t4at can impact t4e product>process2 T4e output from t4ese planning acti ities is in a format suitable for our company5s operation2 ,-2, 2esign and 2evelopment3 Permissible e8clusion Company is not design and de elopment responsible2 If at any time t4is re7uirement becomes applicable as part of our operations, %e %ill address as appropriate2

,,2-

."S Supporting elements ,,2, Process Control3 "onitoring and control of product is tracAed in t4e !S>4-database2 "onitoring and control of suitable parameters and ser ice c4aracteristics ensures ser ice meets specified re7uirements2 Inspection records are maintained as obFecti e e idence2 !nalysis of inspection results is used to identify problems2

10

Compliance %it4 %orAmans4ip standards =7uality, en ironmental etc2? is confirmed t4roug4 inspection reports2 ,,26 Control of Process Changes3 C4en significant c4ange=s? are made to an establis4ed process =e2g2 ne% operator, mac4ine, met4od, or tec4ni7ue? an e8amination is maAe ,,23 Purchasing: Purc4asing documents contain clear descriptions of t4e product or ser ice ordered, including appropriate identification codes, numbers, references, re7uirements etc2 T4e manager or designated personnel are responsible for ensuring t4at product recei ed conform to t4e re7uirements of t4e purc4ase order2 !ll purc4asing documents are re ie%ed and appro ed prior to release2 !ll appro ed suppliers are maintained ia an online database2 ,,24 Supplier (eview3 Periodically, appro ed suppliers are re ie%ed as re7uired to ensure t4eir continuing suitability to meet Company5s needs2 T4is re ie% may include items suc4 as3 :nEtime deli ery, instances of nonconformance, %orAmans4ip standards, and>or applicable permit re7uirements2 ,,2# Production and Service3 Company plans and carries out production and ser ice pro ision under controlled conditions suc4 as3 t4e a ailability of information t4at describes t4e c4aracteristics of t4e product9 t4e a ailability of %orA instructions as necessary, t4e use of suitable e7uipment, t4e a ailability and use of monitoring and measuring de ices, t4e implementation of monitoring and measurement acti ities, and t4e implementation of product release, deli ery and postEdeli ery acti ities2 ,,2& Product4Service 5alidation: Compliance %it4 standards and>or specifications is confirmed t4roug4 inspection and testing acti ities2 $elating primarily to t4e release of ne% soft%are>programs, rigorous inspection and test acti ities occur to ensure t4e proper functioning, measurement capabilities etc, prior to release into production2 ,,2' Product Preservation: Company preser es t4e conformity of customer product during internal processing and deli ery to t4e intended destination2 T4is preser ation includes identification, 4andling, JpacAaging, Jstorage, and protection2 T4is preser ation also applies to t4e constituent parts of a product2 JPacAaging ; Company does not pacAage customer goods, 4o%e er, employees are e8pected to recogni+e if pacAaging is sufficient to %it4stand transport and may be re7uired to secure %it4 additional resources as necessary2 JStorage ; Storage is limited to c4arging for storage in t4e e ent disposition cannot be obtained and storage c4arges are applicable9 storage of c4emicals>products onE4and as part of maintenance acti ities, for %4ic4 "S(S s4eets are maintained9 and storage of 4a+ardous %astes based on S.@ or D.@ re7uirements2 ,,2I Identification and /raceability: Traceability of ser ice and customer product is a re7uirement of product reali+ation as applicable to Company5s operations2 /ac4 customer5s s4ipment is assigned a uni7ue identification number =pro number? %4ic4 allo%s for traceability of t4e customer5s s4ipment from time of picAup t4roug4 deli ery2 $ecords of deli ery are maintained as identified in t4e $ecords Control procedure2 ,,2) Control of 6onconforming Product: NonEconforming product is identified and segregated from conforming product2 T4e :S( (epartment>$epresentati e is responsible for notifying customers %it4 regards to s4ipments re7uiring disposition, notification of lost, damaged, or determined to be ot4er%ise unsuitable for use2 Specific procedures e8ist to control reporting and 4andling %4en nonconforming product is a

11

4a+ardous material or c4emical2 $ecords of nonconformance are maintained as applicable2 ,62$esponsible Care0 /1S&S Gey /lements Communication: In addition to a formal Communications (epartment, Company 4as a compre4ensi e program t4at focuses on direct, consistent communication, pro iding a number of outlets in an effort to Aeep information flo%ing2 T4roug4 t4is program, Company 4as establis4ed tools t4at 4a e been pro en to be instrumental in deli ering Aey messages from management to employees, and at t4e same time, gi ing employees an opportunity to meet and discuss arious topics %it4 management2 Ce belie e t4at t4e message is %4at dri es t4e type of communication tool %e use, and %e encourage all employees to become familiar %it4 t4e tools a ailable and use t4em to t4eir benefit2 T4e follo%ing is a list of t4e ongoing communication tools currently utili+ed3 Company (irections ; "ont4ly ne%sletter mailed directly to employees 4omes2 Company .uestion & !ns%er Dine =Toll *ree? ,EI''E''-E'6463 T4is number can be used to asA general 7uestions or for story ideas and comment for t4e Company (irections ne%sletter2 /mployee $oundtables ; (iscussion meeting 4eld bet%een President $icA :5(ell and 4ourly employees representing arious terminals to discuss topics of employee interest>concern2 .uarterly /mployee "eeting ; "anagement isits eac4 terminal to bring employees upE toEdate on t4e status of t4e company2 Company Ceb Site ; !n Internet site ; %%%2Company2com ; for customers, t4e general public and employees to ie% upEtoEdate information on Company2 !lso a ailable on t4e %ebsite is t4e Contact Ks section %4ere employees and t4e general public can asA 7uestions2 @enerally, ans%ers %ill be pro ided %it4in 4I 4ours2 !nnual $eport3 /ac4 year an !nnual $eport is prepared and presented to Company5s public s4are4olders2 Customer !d isory Boards3 !nnually, Company 4osts a Customer !d isory Board by in itation only2 T4e participants are a mi8ture of e8isting customers, potential customers, past customers etc2 Based on need, information is also communicated to employees ia3 <ideotapes /Email messages Bulletin board postings Detters to employees5 4omes Detter included %it4 payc4ecA Compliance with +egal and -ther (e,uirements3 "anagement designates specific positions responsible for tracAing rele ant la%s, regulations and ot4er re7uirements to %4ic4 t4e facility subscribes, and e aluates t4eir potential impact on a facility5s operations2 Procedures are establis4ed to identify, 4a e access to, and update as

necessary all legal and ot4er re7uirements to %4ic4 t4e facility subscribes concerning t4e /1S&S system2 -perational Control: !s necessary, for eac4 identified operation or acti ity associated %it4 t4e significant /1S&S aspects identified, documented control procedures and>or %orA instructions are establis4ed to ensure t4e %orA performed is in compliance %it4 /1S&S policies, as %ell as corporate obFecti es and targets2 #mergency Preparedness and (esponse3 Company5s Safety Committee implements and e aluates t4e emergency response procedures including employee safety, coordinating response acti ities %it4 t4e applicable agencies, and addressing any /1S&S impacts resulting from an emergency situation2 Security3 Company 4as security in estigators assigned to address security related matters2 T4e Security (epartment maintains updated security profiles and risA assessments of eac4 terminal2 In addition, detailed procedures define training re7uirements, additional responsibilities and actions encompassing a %ide array of security related issues, including, but not limited to3 Personnel Security Knaut4ori+ed !ccess /nEroute security Cyber security /mployee $esponsibilities !ctions to taAe in t4e e ent of a breac4 /mergency $esponse and Contingency Plans :rgani+ational Structure for reporting security related issues Terminal opening and Closing procedures Po%ered <e4icle Security Trailer Security Cargo Security Criminal BacAground In estigations

,32-

"easurement, (ata !nalysis and !udits ,32, @eneral3 "easurement and analysis tools and processes are designed so t4ose responsible for specific areas and information can maAe decisions independent of organi+ational 4ierarc4y2 C4ere possible, decision maAing is based on facts gat4ered t4roug4 measurement and analysis2 "easurements are made in arious areas including, but not limited to3 Production Ser ice Customer *eedbacA !c4ie ement of obFecti es>goals *inancial $esults Process Performance Integrated "anagement System Performance ,326 "onitoring and "easurement of Product3 Company monitors and measures t4e c4aracteristics of t4e product to erify t4at re7uirements 4a e been met2 T4is is carried out at appropriate stages of t4e product reali+ation process in

16

accordance %it4 planned arrangements as stated2 / idence of conformity %it4 acceptance criteria is maintained2 $ecords indicate t4e person=s? aut4ori+ing release of product2 Product release and ser ice deli ery does not proceed until planned arrangements 4a e been satisfactorily completed, unless ot4er%ise appro ed by a rele ant aut4ority and>or %4ere re7uired by t4e customer2 ,323 Control of "onitoring and "easurement (e ices3 !ll applicable measurement e7uipment is subFect to systematic calibration c4ecAs at appropriate inter als to erify conformity %it4 specified accuracy limits2 C4ere calibration is re7uired, records are maintained2 Internal !udits3 T4e Safety& .uality (epartments 4a e t4e aut4ority and responsibility for coordinating auditErelated acti ities associated %it4 t4e ."S>/1S&S integrated system2 !udits are sc4eduled at regular inter als to ensure all aspects of t4e system are re ie%ed2 !n audit sc4edule is establis4ed, 4o%e er, t4e fre7uency and sc4edule may be adFusted based on t4e results of pre ious audits, and t4e significance of indi idual system acti ities2 !udit $esults3 *indings and obser ation from internal and>or e8ternal audits are re ie%ed by person=s? responsible for t4e area audited2 !ctions as a result of audits include in estigation for root cause, correcti e action, and>or continual impro ement suggestions2 !udit acti ities>results are summari+ed and included as part of management re ie%2 !nalysis of (ata3 (ata is collected to monitor arious acti ities %it4 regard to process conformance and 7uality, product conformance and 7uality, customer satisfaction etc2 (ata is analy+ed and e aluated to tracA and>or disco er trends, opportunities for impro ement, t4e need for c4anges, additional resources etc2

,324

,32#

,32&

,42- Continual Impro ement ,42, Impro ement3 Continual Impro ement is part of t4e culture at Company2 In order to maintain continual impro ement, t4ere is ongoing collecti e feedbacA of results2 !dditionally, specific indi iduals and>or departments %it4in t4e organi+ation identify goals and create plans to ac4ie e t4ose goals2 ,426 Correcti e !ction3 Company taAes action to eliminate t4e cause of nonconformities in order to pre ent recurrence2 Correcti e actions are appropriate to t4e le el of t4e nonconformity encountered2 Procedures for correcti e action define t4e re7uirements for re ie%ing nonconformities =including customer complaints9 determining t4e causes of nonconformities, e aluating t4e need for action to ensure t4at nonconformities do not recur9 determining and implementing t4e action needed9 recording t4e results of actions taAen and, re ie%ing actions taAen2 ,423 Pre enti e !ction3 Company determines actions needed to eliminate t4e causes of potential nonconformities in order to pre ent t4eir occurrence2 !lt4oug4 any employee 4as t4e aut4ority to identify potential nonconformities and to initiate action, t4e primary tool in place is a documented 1a+ards and $isAs assessment process2 !s appropriate pre enti e action is taAen to address potential problems, customer issues, or management system failures2 Procedures for pre enti e action define t4e re7uirements for3 determining potential nonconformities and t4eir causes9 e aluating t4e need for action to pre ent occurrence of nonconformities9 determining and implementing action needed, recording results of action taAen, and re ie%ing actions taAen2

1$

T4is page intentionally left blanA

1&

1@

1?