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URS Responsible Carrier Program

Responsible Carrier Program

January 2007 Revised March 2009 Revised May 2010

Revised and Updated May 2013 Revised and Updated April 2014

Revised and Updated October 2014 Revised and Updated February 2015

Commitment to Safety

Upper River Services is committed to the pursuit of the safest and healthiest work environment for all of its employees. We strive to make reasonable efforts to comply with all applicable laws and regulations. It extends to the company making a commitment to provide a safe and healthy work environment so that employees may return home each day without injury or illness. To assist in this commitment, the company has implemented the Responsible Carrier Program. Following this program will help result in uniform and consistent work practices which help to safeguard Upper River Services crewmembers, the environment and equipment. As an employee of Upper River Services, you have a responsibility to assist the company in the prevention of incidents and injuries to yourself, as well as other employees. This responsibility is to include the prevention of incidents to the environment and all equipment. Your responsibility begins with your commitment to following the company’s Responsible Carrier Program (RCP), general safety rules, safety program, and your own common sense. Only through your constant attention and commitment to safety will we be able to eliminate hazards and thereby prevent accidents.

RCP-1.1-1

TABLE OF CONTENTS

Title:

TABLE OF CONTENTS

Issue Date:

April 14, 2014 Last Revised:

March 1, 2015 Procedure Number:

RCP-1.1

Approved By:

Management Safety and Health Committee Page:

1 of 4

RESPONSIBLE CARRIER PROGRAM SECTION (1): TABLE OF CONTENTS/PROCEDURE FORMAT

RCP - 1.1 Table of Contents RCP - 1.2 Company Procedure Format

SECTION (2): VESSEL OPERATING PROCEDURES

RCP - 2.1 Navigation RCP - 2.2 Change of Watch RCP - 2.3 Trip Planning RCP - 2.4 Locking RCP - 2.5 Main Engine Shutdown During Delays RCP - 2.6 Standing Radio Watch RCP - 2.7 Job Safety Briefing (H.A.L.T.)

RCP - 2.8 Vessel Log – Required Master’s Daily Log Entries RCP - 2.9 Vessel to Office Communications RCP - 2.10 Vessel to Vessel Communications

RCP - 2.11 Vessel Manning RCP - 2.12 Scheduling Horsepower RCP - 2.13 Confined Space Entry RCP - 2.14 Bridge Transit Procedure RCP - 2.15 Minimum Rigging Requirements RCP - 2.16 Radar Failure Procedure RCP - 2.17 Required Documents on Board RCP - 2.18 Fuel Transfer Procedures RCP - 2.19 Procedures for Identifying Critical Stores and Supplies RCP - 2.20 Log of Tests and Inspections

Log of Tests and Inspections RCP - 2.21 Welding and Cutting

RCP-1.1-2

SECTION (3): VESSEL MAINTENANCE AND INSPECTION

RCP - 3.1 Equipment Maintenance Schedules

Towing Vessel Inspection Form – On Drydock RCP - 3.2 Lockout/Tagout Procedure RCP - 3.3 Maintenance and Repair Reporting RCP - 3.4 Routine Scheduled Vessel Maintenance RCP - 3.5 Non-Routine Vessel Repairs RCP - 3.6 Emergency Vessel Repairs RCP - 3.7 Piping Systems RCP - 3.8 Qualifications and Training Requirements for Person

in Charge of Maintenance

SECTION (4): SAFETY POLICIES RCP - 4.1 Company Safety Policy

RCP - 4.2 Company Safety Rules RCP - 4.3 Safety & Health Committee Structure RCP - 4.4 Employee Safety & Health Committee

Attendance Roster RCP - 4.5 Management Safety & Health Committee RCP - 4.6 Personal Protective Equipment Policy RCP - 4.7 Orientation Policy

Fleet/Vessel Orientation Checklist RCP - 4.8 Training Policy

Vessel Operator Training Matrix

Deckhand Training Matrix RCP - 4.9 Safety Training RCP - 4.10 Safety Drills

Collision/Allision Drill Form

Fall Overboard Drill Form

Grounding Drill Form

Sinking Drill Form

Oil or Hazardous Substance Spill Drill Form

Operator Incapacitation Drill Form

Fire Drill/Training Form RCP - 4.11 Safe Use of Equipment RCP - 4.12 Cargo Knowledge RCP - 4.13 Hazard Communication Procedures RCP - 4.14 Fall Overboard Prevention

RCP - 4.15 Bloodborne Pathogens RCP - 4.16 Hearing Conservation Program RCP - 4.17 Benzene Handling

RCP-1.1-3

SECTION (5): COMPANY ENVIRONMENTAL POLICIES RCP - 5.1 Company Environmental Policy RCP - 5.2 Garbage Disposal RCP - 5.3 Handling of Waste Oil, Grease, Bilge Slops, Used

Filters and Oily Rags RCP - 5.4 Hazardous Waste Disposal/Handling RCP - 5.5 Sanitary Systems/Handling of Sewage

SECTION (6): EMERGENCY RESPONSE PROCEDURES RCP - 6.1 Personal Injury or Illness RCP - 6.2 Oil or Hazardous Substance Spill RCP - 6.3 Collision/Allision Response Plan RCP - 6.4 Grounding Response Plan RCP - 6.5 Fire Response Plan RCP - 6.6 Sinking Response Plan RCP - 6.7 Fall Overboard Response Plan RCP - 6.8 Operator Incapacitation RCP - 6.9 Emergency Phone Numbers

SECTION (7): INCIDENT REPORTING PROCEDURES RCP - 7.1 Vessel Personnel Incident Reporting

• Vessel Accident/Incident Report • Personal Injury Report • Personal Injury Witness Report

RCP - 7.2 Office Personnel Incident Reporting RCP - 7.3 U.S. Coast Guard Reporting Requirements

• USCG Form 2692 • U.S. Coast Guard Reporting and Chemical Testing

Requirements Flowchart RCP - 7.4 Incident Investigation and Communication of Lessons

Learned

SECTION (8): INTERNAL AUDIT PROCEDURES

RCP - 8.1 Corrective/Preventative Action RCP - 8.2 Document Control, Updating and Distribution

• Master List of Controlled Documents RCP - 8.3 Performance Measurement Procedures RCP - 8.4 Internal Audit and Review

• Completed Audit Log RCP - 8.5 Federal Regulatory Compliance

RCP-1.1-4

RCP - 8.6 Vendor Safety Policy RCP - 8.7 Qualifications and Training Requirements for Persons

Conducting In House Inspections RCP - 8.8 Inspection Procedures

• Summary of Inspections Form SECTION (9): LEVELS OF AUTHORITY

• Organizational Chart RCP - 9.1 Shore Organization RCP - 9.2 Vessel Operator RCP - 9.3 Deckhand

SECTION (10): PERSONNEL POLICIES

RCP - 10.1 Hiring Policy • New Employee Check List

RCP - 10.2 Drug and Alcohol Policy RCP - 10.3 Proficiency Evaluation & Review Policy

• Level I Deckhand Employee Evaluation • Level II Deckhand Employee Evaluation • Level III Deckhand Employee Evaluation • Vessel Operator Evaluation Form

RCP - 10.4 Personnel Development Program RCP - 10.5 Medication Notification Policy RCP - 10.6 Disciplinary Policy

• Disciplinary / Counseling Report RCP - 10.7 Physical Exams RCP - 10.8 Physical Standards Policy RCP - 10.9 Personal Hygiene RCP - 10.10 Sanitation and Safe Food Handling Policy

SECTION (11): SECURITY POLICY

RCP - 11.1 Security Policy RCP - 11.2 Reporting Protocol for Suspicious Activities

• Vessel Reporting Protocol

RCP-1.2-1

TABLE OF CONTENTS/ PROCEDURE FORMAT

Title:

COMPANY PROCEDURE FORMAT

Issue Date:


April 14, 2014 Procedure Number:

RCP-1.2 Approved By:


1 of 2 1.0 PURPOSE:

To help provide a consistent procedure format so that procedures can be readily understood and recognized by employees.

2.0 SCOPE:

Applicable to company procedures located in the RCP Manual. 3.0 RESPONSIBILITY:

The General Manager and Vessel Operations Manager or their designate should make reasonable efforts to see that this format is used consistently in the company’s RCP Manual.

4.0 PROCEDURE:

Each procedure should contain each of the following sections:

4.1 The header shown on the top of this page should be used on the first page of procedures.

4.1.1 The title section of the header should contain the name of the

procedure and be typed in capital letters.

4.1.2 The issue date section of the header should contain the date that the procedure was first put into practice.

4.1.3 The last revised section of the header should contain the date that

any part of the procedure was last revised.

RCP-1.2-2

4.1.4 The procedure number section of the header should first contain the capital letters RCP (RCP Manual) depicting the appropriate manual that the procedure should reside in. The second item in the procedure number is a number depicting the section in the manual in which it belongs. The third and final item in the procedure number identifies the location within a particular section in which the procedure belongs.

4.1.5 The approved by section should show that procedures written for

this company should be approved by the Management Safety and Health Committee.

4.1.6 The page section of the header should show the number of pages

in the procedure.

4.2 Purpose - This section should define the reason for the procedure.

4.3 Scope - This section should help identify what the procedure applies to.

4.4 Responsibility - This section should help identify the persons that should be asked to make reasonable efforts to follow through on a particular procedure.

4.5 Procedure/Policy - This section should outline the process needed to

complete the task that a particular procedure is trying to address.

4.6 Records - This section should describe location and length of time records required by the procedure should be kept. If a particular procedure does not require record keeping, this section is not needed in the procedure.

4.7 Appendices - This section should list any forms or other appendices that

might follow a procedure. If a particular procedure does not have any appendices, this section is not needed in the procedure.

4.8 Revision History - This section should list the number of the revision (1st

revision, 2nd revision, 3rd revision, etc.) and the date of the last revision.

4.9 The contents of the RCP Manual should be reviewed at least once each year so that they are maintained current and that they accurately describe the processes in use by employees.

5.0 REVISION HISTORY:

0 Initial issue April 14, 2014

RCP-2.1-1

VESSEL OPERATING PROCEDURES

Title:

NAVIGATION Issue Date:




Management Safety and Health Committee

Page:

1 of 3 1.0 PURPOSE:

The purpose of this procedure is to establish a standard operating procedure for navigation aboard all Upper River Services (URS) vessels. Following this procedure will result in uniform and consistent work practices which help to safeguard URS crewmembers, the environment and equipment.

2.0 SCOPE:

This applies to all vessels either owned or operated by URS.

3.0 RESPONSIBILITY: 3.1 The Traffic Manager, or Designate, should implement this procedure and

ensure that the Vessel Operator is made aware of the requirements outlined in this procedure.

3.2 The Vessel Operator is responsible for following these procedures. 3.3 The Vessel Operator must be licensed by the U.S. Coast Guard as a

Master of Towing Vessels upon the Western Rivers, or hold an equivalent U.S. Coast Guard license, and must be able to produce the original license and Radar Observer certificate within 24 hours upon request.

4.0 PROCEDURE:

4.1 The Vessel Operator must navigate the vessel in a safe and prudent

manner. This includes, but is not limited to, the following:

4.1.1 Complying with all applicable U.S. Coast Guard Inland Navigation Rules.

4.1.2 Planning and carrying out orders received from the URS dispatcher

and reporting any variances or discrepancies to the dispatcher. The Vessel Operator should carry out these orders at his/her discretion in a safe and prudent manner.

RCP-2.1-2

4.1.3 Verifying that the required documentation is located in the wheelhouse of the vessel and is current, up-to-date, and maintained in an orderly manner.

4.1.4 Make reasonable efforts to confirm that the vessel and tow are

suitable for the waterway to be transited and expected operating conditions. Any deficiencies should be reported to the URS dispatch office. To be considered suitable, the vessel must:

4.1.4.1 Maintain appropriate draft, trim and dimensions for

the intended waterway; 4.1.4.2 Be staunch, tight and seaworthy; and, 4.1.4.3 Have appropriate lines, wires, and fittings for the tow

configuration to be used.

4.1.5 Contacting the URS dispatcher for an assist tug to help navigate when conditions may endanger the safety of the tow, its cargo, or the vessel crew. Such conditions may include, but are not limited to, the following:

4.1.5.1 Strong current; 4.1.5.2 High winds; 4.1.5.3 High or low river stages; and, 4.1.5.4 Transiting locks or bridges.

4.1.6 Checking U.S. Coast Guard marine information radio broadcasts regularly for relevant navigation information.

4.1.7 Maintaining in proper working order the vessel’s installed navigation

equipment, including, but not limited to:

4.1.7.1 VHF-FM radio and backup; 4.1.7.2 Radar(s); 4.1.7.3 Compass; 4.1.7.4 Searchlights; and, 4.1.7.5 Navigation lights.

4.1.8 Using the judgment of a prudent mariner and stopping operations

when conditions dictate. Such conditions may include, but are not limited to, the following:

4.1.8.1 Limited visibility; 4.1.8.2 Severe weather; 4.1.8.3 Traffic restrictions; 4.1.8.4 Lack of required crew; and,

RCP-2.1-3

4.1.8.5 Mechanical problems or failure.

4.1.9 Observing the URS look-out policy which states:

4.1.9.1 “It is Upper River Services’ policy to be in strict compliance with U.S. Coast Guard Navigation Rules regarding look-outs.”

4.1.9.2 Inland Navigation Rule No. 5 states: “Every vessel shall at all times maintain a proper look-out by sight and hearing, as well as by all available means appropriate in the prevailing circumstances and conditions so as to make a full appraisal of the situation and the risk of collision.”

4.1.9.3 The Vessel Operator shall designate a crewmember to perform lookout duties in any situation deemed appropriate.

4.1.9.4 In any situation deemed appropriate, the Vessel Operator shall take precautions including, but not limited to, the following:

• Appointing a crew member to perform look-out

duties; • Instructing the look-out person as to his or her

duties; and, • Setting up an appropriate means of

communication with the person acting as look-out.

4.1.10 Communicating with the URS dispatcher in accordance with the

Vessel to Office Communications procedure located in this manual. 4.1.11 Communicating with other vessels in accordance with the Vessel to

Vessel Communications procedure located in this manual. 4.1.12 Following the Change of Watch procedure located in this manual. 4.1.13 Complying with all applicable Safety or Security Zones as

established by the company or the U.S. Coast Guard, or any law enforcement agency.



RCP-2.2-1


Title:

CHANGE OF WATCH Issue Date:





Page:

1 of 2 1.0 PURPOSE:

The purpose of this procedure is to describe the change of watch procedure to be followed by the Vessel Operator aboard Upper River Services (URS) vessels and to provide a uniform and consistent work practice that will safeguard crewmembers, equipment, and the environment.

2.0 SCOPE:

This applies to all vessel either owned or operated by URS.

3.0 RESPONSIBILITY: 3.1 The Vessel Operations Manager should make vessel personnel aware of

the requirements outlined in this procedure. 3.2 The Vessel Operator is responsible for implementing these described

procedures. 3.3 Each crewmember is responsible for following work directions from the

Vessel Operator and the practices described in this procedure.

4.0 PROCEDURE:

4.1 The Vessel Operator must exchange with the relief person coming on duty information including, but not limited to, the following:

4.1.1 Performance of the vessel, its engines, steering system,

generators, and other critical machinery; 4.1.2 Location and direction of the vessel, including traffic in the area and

whether the tow is overtaking, or being overtaken; 4.1.3 Crew work instructions or duties in progress; 4.1.4 Condition of tow; 4.1.5 Orders or information received from the dispatcher;

RCP-2.2-2

4.1.6 River, current, and weather conditions; 4.1.7 VHF working channels in use; 4.1.8 Determine and schedule any necessary safety drills and/or

meetings; and, 4.1.9 The off going Vessel Operator should communicate to the

oncoming Vessel Operator, all pertinent safety and navigational information necessary to the safe operation of the vessel.

4.2 The crewmembers must exchange with the oncoming watch the following

information, including, but not limited to:

4.2.1 Any known mechanical issues or concerns with the vessel; 4.2.2 Current tow conditions or concerns (eg., leaking barges, current

placement of running pumps) 4.2.3 Current fuel usage – including what fuel tanks are being used; and, 4.2.4 Rigging, lines and face wire count.

4.3 Watches must change at 0600 and 1800 hours unless otherwise agreed

in advance. 4.4 Each new watch must complete the Log of Tests and Inspections. 4.5 The change of watch must be postponed if it occurs during a critical stage

of vessel operations. 4.6 The Vessel Operator must comply with applicable federal law regarding

hours worked. 46 USC 8104 (h) provides that “an individual licensed to operate a towing vessel may not work for more than 12 hours in a consecutive 24-hour period, except in an emergency.”

4.7 Deck crew members must not work more than 15 hours in a 24-hour

period or more than 42 hours in any 72-hour period. 4.8 A record must be maintained in the Master’s Daily Log with the names of

all crewmembers aboard and any crew changes that occur. 5.0 REVISION HISTORY:


RCP-2.3-1


Title:

TRIP PLANNING Issue Date:





Page:

1 of 3 1.0 PURPOSE:

This procedure will suggest a list of guidelines to assist crews in organizing and planning the shift, trip, and watch to ensure a safe and efficient transit that safeguards Upper River Services (URS) crewmembers, equipment, public property and the environment.

2.0 SCOPE:


3.0 RESPONSIBILITY: 3.1 The Vessel Operations Manager or designate should make vessel

personnel aware of the requirements outlined. 3.2 The Crew Dispatcher will consider the overall experience of the crew and

that the crew’s experience is sufficient for the planned trip. 3.3 The Vessel Operator should make reasonable efforts to comply with the

applicable elements of this procedure during his/her watch.

4.0 DEFINITIONS:

4.1 Trip – The planned transit of the vessel from a specific starting point to a planned ending point or the duration of the trip.

4.2 Watch – The daily time period that the crewmember is responsible for the

safe navigation of the vessel. 5.0 PROCEDURE:

5.1 Planning will be carried out on a trip and watch basis appropriate to the vessel’s operational assignment, crewing level and area of operations.

5.2 Upon shipping up the vessel after a dry-docking, lay-up or repair period

before getting underway the Vessel Operator shall:

RCP-2.3-2

5.2.1 Be familiar with, and comply with all company operating policies and procedures.

5.2.2 Ensure that the Log of Tests and Inspections is completed. 5.2.3 Ensure that the vessel is properly equipped and ready to perform

its assigned tasks. 5.2.4 Ensure sufficient crew is available to operate the vessel. 5.2.5 Review the status of any ongoing vessel repairs and scheduled

maintenance. 5.3 Upon receiving orders when joining the vessel underway, the Vessel

Operator shall:

5.3.1 Determine the vessel’s position, destination, tow configuration and drafts, vertical clearance, cargo, river stages along the route, and handling characteristics of the vessel and tow.

5.3.2 Be familiar with the charts, maps and light list for the planned route

and/or operating area. 5.3.3 Frequently review weather forecast, current and river conditions for

the trip period and planned route. 5.3.4 Identify any known operating hazards along the planned route

including any hazardous bridges, waterways or locks. 5.3.5 Ensure that all bridge transits will be in accordance with the Bridge

Transit Procedure located in this manual. 5.3.6 Verify that the URS vessel inspection checklist is completed in

accordance with company policy. 5.3.7 Review the current U.S. Coast Guard Notice to Mariners for the

planned route. 5.3.8 Comply with all MARSEC levels in effect along the planned route. 5.3.9 Confirm that sufficient crew is available to operate the vessel.

5.4 Planning will be carried out on a trip and watch basis appropriate to the vessel’s operational assignment, crewing level and area of operations.

RCP-2.3-3



RCP-2.4-1


Title:

LOCKING Issue Date:





Page:

1 of 3 1.0 PURPOSE:

The purpose of this procedure is to provide uniform guidelines to be followed by all personnel operating Upper River Service (URS) vessels through locks.

2.0 SCOPE:


3.0 RESPONSIBILITY: 3.1 The Vessel Operator should make reasonable efforts to see that this

procedure is followed. 3.2 The deck personnel are responsible for performing their duties described

in this procedure.

4.0 PROCEDURE: 4.1 The Vessel Operator contacts the lock to give tow information and arrival

time to the lock master.

4.1.1 The lock master may inform the Vessel Operator of any special instructions including, but not limited to, the following:

4.1.1.1 Currents and water levels; 4.1.1.2 Number of lines required by locks; 4.1.1.3 Number of deck personnel required for locking; 4.1.1.4 Communications required for locking; 4.1.1.5 Restrictions on tow length and width; and, 4.1.1.6 Locking order.

4.2 The Vessel Operator provides the lock master with information on the

following: 4.2.1 Number of barges in tow;

RCP-2.4-2

4.2.2 Tow length, width, and draft; 4.2.3 Cargo type; and, 4.2.4 Boat name and official number.

4.3 The Vessel Operator conducts a pre-locking conference with the vessel

crew, including, but not limited to, the following:

4.3.1 Special locking instructions provided by the lock master; 4.3.2 Communication requirements; 4.3.3 Personal protective equipment (PPE) required for the locking; 4.3.4 Fenders required; and, 4.3.5 Number and size of tow lines required.

4.4 The lock master contacts the Vessel Operator to bring the tow into the

lock. 4.5 The Vessel Operator sends deck personnel to the head of the tow with

the proper equipment and PPE as discussed during the pre-locking conference. Some locks may require more than one person on the tow.

4.6 The Vessel Operator maneuvers the tow into the lock.

4.6.1 The deck personnel give the Vessel Operator directions by hand signals and/or voice communications over a hand-held VHF radio.

4.6.2 The deck personnel signal the Vessel Operator to stop at

appropriate times, tie off the tow, and tend to lines until told to release the tow by the Vessel Operator.

4.7 The Vessel Operator receives a signal from the lock master to exit the

locks. 4.8 Deck personnel release the lines when directed by the Vessel Operator

and maintain position on the head of the tow, giving the Vessel Operator directions until the head of the tow clears the lock.

4.9 The Vessel Operator checks traffic before departing from the lock.

RCP-2.4-3



RCP-2.5-1


Title:

MAIN ENGINE SHUTDOWN DURING DELAYS

Issue Date:





Page:

1 of 1 1.0 PURPOSE:

The purpose of this procedure is to provide uniform guidelines to be followed by all personnel operating Upper River Services (URS) vessels during vessel delays.

2.0 SCOPE:



procedure is followed. 3.2 The deck personnel are responsible for performing their duties described

in this procedure.

4.0 PROCEDURE: 4.1 While awaiting locks, during fog delays, or when loading or discharging

barges, shut down engine(s) (if safety conditions allow), in an effort to conserve fuel and reduce cost.

4.2 Engine shutdown periods are a prime time for the deck crew to make

engine inspections to discover and correct potential problems and to perform routine maintenance.

4.3 During extended delays, engines should be restarted every 12 hours and

brought to operating temperature to check equipment, with particular attention to the main engine lube oil levels and air starters. Report any discrepancies immediately to the Port Engineer.



RCP-2.6-1


Title:

STANDING RADIO WATCH

Issue Date:





Page:

1 of 2 1.0 PURPOSE:

The purpose of this procedure is to provide uniform guidelines for the Vessel Operator standing radio watch on Upper River Services (URS) vessels. All radio watch information will be recorded on the Master’s Daily Log.

2.0 SCOPE:


3.0 RESPONSIBILITY: The Vessel Operator is responsible for standing, or designating someone to stand, the radio watch.

4.0 PROCEDURE: 4.1 While standing by at a fleet or at a dock facility, the Vessel Operator must

monitor the channel required by the facility and monitor the company communications system.

4.2 While underway, the Vessel Operator must:

4.2.1 Monitor channels 13, 16 and the designated navigation channel for the area being transited;

4.2.2 Monitor the company communications system; and, 4.2.3 Monitor for distress calls.

4.3 The Vessel Operator must notify the facility and the URS dispatcher

before leaving the wheelhouse of the approximate amount of time he will be away from the radio.

RCP-2.6-2

4.3.1 If hand-held VHF radio is available and is used to maintain communications with the fleet or facility, it is not necessary to notify the facility before leaving the wheelhouse.

4.3.2 When the vessel is secure and the operator is leaving the

wheelhouse for short periods of less than 15 minutes, it is not necessary to notify the facility before leaving the wheelhouse.



RCP-2.7-1

VESSEL OPERATING

PROCEDURES

Title:

JOB SAFETY

BRIEFING (H.A.L.T.)

Issue Date:

February 20, 2015

Last Revised:

February 20, 2015

Procedure Number:



Page:

1 of 2

1.0 PURPOSE: To raise awareness and minimize risk to crewmembers while performing tasks through job safety briefings, using Huddle, Assess, Listen, Talk (H.A.L.T.).

2.0 SCOPE:

This applies to all crewmembers on board URS owned or operated vessels.

3.0 RESPONSIBILITY: 3.1 The Vessel Operator should make reasonable efforts to see that

crewmembers comply with this procedure. 3.2 All crewmembers are required to actively participate in job safety briefings

utilizing H.A.L.T.

4.0 PROCEDURE: 4.1 Job safety briefings are not safety meetings, and should not be treated as

such. Job safety briefings need only cover the pertinent information required of the task at hand.

4.2 In order to effectively assess and manage risk, all involved crewmembers

are to actively participate in job safety briefings and provide input. Group discussions are critical to the understanding of risks and how they will be managed.

4.3 Job safety briefings should include the following:

4.3.1 Huddle your team.

4.3.1.1 Identify the job or task to be performed. 4.3.1.2 Identify and include all individuals involved.

RCP-2.7-2

4.3.2 Assess the situation.

4.3.2.1 Identify and understand the risks. 4.3.2.2 Communicate the risks to all involved.

4.3.3 Listen to the team.

4.3.3.1 Can this job be done safely? 4.3.3.2 How can we make it safer? 4.3.3.3 Do we need help or resources?

4.3.4 Talk to each other.

4.3.4.1 Verify all individuals understand the team’s plan. 4.3.4.2 Continue communicating while performing the job. 4.3.4.3 Remember to H.A.L.T. if new risks arise.


0 Initial issue February 20, 2015

RCP-2.8-1


Title:

VESSEL LOG – REQUIRED MASTER’S DAILY LOG ENTRIES

Issue Date:





Page:

1 of 3 1.0 PURPOSE:

This procedure establishes guidelines for the maintenance of and required entries on vessel logs kept for all Upper River Services (URS) vessels.

2.0 SCOPE:


3.0 RESPONSIBILITY: The Vessel Operator is responsible for following this procedure.

4.0 PROCEDURE: 4.1 Each URS vessel must maintain a Master’s Daily Log as their official log.

The following guidelines for maintaining the log must be adhered to:

4.1.1 The log must be kept daily, accurately and legibly; 4.1.2 Log entries, properly dated, must be made as soon as possible

after the occurrence for which the entry is made; 4.1.3 No erasures should be made in the log. Any incorrect statements

must be corrected by drawing a single line through the entry and initialing it; and,

4.1.4 The original log must be returned to the URS main office.

4.2 The following information is required to be entered in the URS Master’s

Daily Log:

4.2.1 A complete list of all vessel crewmembers including start and end time of watch;

4.2.2 VHF working channels in use and a note that the radios are

working properly by initialing the channels monitored;

RCP-2.8-2

4.2.3 General Alarm has been tested; 4.2.4 Number of trash bags removed from the vessel for that watch; 4.2.5 Fuel soundings taken at the beginning of the watch; 4.2.6 All barge movements including barge number, time, location and

load status; 4.2.7 Notation of entering and exiting times for different river segments

and locks; 4.2.8 Include a tow diagram for tows to or from Savage, Minneapolis, or

any tow leaving the St. Paul Harbor; 4.2.9 Any personal injuries or illnesses reported, whether to a

crewmember or another individual aboard the vessel. If there are no injuries, check and initial the box, “No personal injuries or illnesses reported today”;

4.2.10 Notation of all crew safety meetings; 4.2.11 Notation of all safety drills conducted; 4.2.12 The name of every crewmember who ceases to be a member of

the crew, other than by death, with the place, time, manner and cause of departure;

4.2.13 Weather conditions affecting navigation; 4.2.14 Report of any vessel damage; 4.2.15 Report of any collision, allision or grounding; 4.2.16 Name of any non-crewmembers carried onboard the vessel,

including their time on and off and boarding and departure points; 4.2.17 Times of any delays (groundings, Coast Guard boardings, traffic,

lock closures, etc.); and, 4.2.18 For operations outside the St. Paul Harbor, intermittent

operations such as drops or additions of barges, standby time, hire of tug and change of river segment, along with notations as to where, by whose orders and for what purpose these operations were undertaken.

RCP-2.8-3

4.3 It is extremely important that entries regarding incidents be completed, regardless of how trivial it may seem at the time. The log must contain a true and accurate record of the event, and any questions concerning the information to be included in the log should be referred to the Vessel Operations Manager.



RCP-2.9-1


Title:

VESSEL TO OFFICE COMMUNICATIONS

Issue Date:





Page:

1 of 2 1.0 PURPOSE:

This procedure establishes guidelines for communication between Upper River Services (URS) vessels and the URS office.

2.0 SCOPE:


3.0 RESPONSIBILITY: The Vessel Operator and involved office personnel should make reasonable efforts to see that this procedure is followed.

4.0 PROCEDURE: 4.1 The following information should be submitted to the URS dispatch office

after every watch:

4.1.1 Master’s Daily Log 4.1.2 Log of Tests and Inspections 4.1.3 Engine Room Log 4.1.4 Barge Pumping/Condition Reports

4.2 The following information should be submitted to the URS dispatch office

as each event occurs:

4.2.1 Safety Drill and Meeting Forms

RCP-2.9-2

4.2.2 Accident or injury Reports: Any accident must be reported to the dispatch office immediately, followed by a completed Vessel Accident/Incident Report. Regardless of how minor the accident, this report is needed so that we can answer any questions about the incident. Make sure that you send the front and back of each report form and turn in the original copy to the Vessel Operations Manager at the main office within 24 hours of the incident. This applies to all Personal Injury Reports as well as Vessel Accident/Incident Reports.

4.2.3 Barge discrepancy: When making a pick-up from a fleet,

terminal, or another boat, report any barge discrepancies, such as damage to the hull, etc., and complete a barge condition report. Submit the barge condition report to the dispatch office.

4.2.4 Navigational aids: Report any discrepancies to the dispatch

office and to the Coast Guard.



RCP-2.10-1


Title:

VESSEL TO VESSEL COMMUNICATIONS

Issue Date:





Page:

1 of 1 1.0 PURPOSE:

This procedure establishes guidelines for communication between Upper River Services (URS) vessels and other vessels.

2.0 SCOPE:


3.0 RESPONSIBILITY: The Vessel Operator should make reasonable efforts to see that this procedure is followed.

4.0 PROCEDURE: 4.1 Communications between vessels must be conducted on the VHF-FM

radio. Profanity is not allowed by law. 4.2 All communication between vessels must comply with the Bridge to Bridge

Radio Telephone Act.



RCP-2.11-1


Title:

VESSEL MANNING Issue Date:





Page:

1 of 2 1.0 PURPOSE:

This procedure is intended to see that Upper River Services (URS) vessels are properly manned.

2.0 SCOPE:


3.0 RESPONSIBILITY: 3.1 The Crew Dispatcher should make reasonable efforts to see that

adequate “manning” is available for each vessel in accordance with this policy.

3.2 Each crewmember should make reasonable efforts to follow this

procedure.

4.0 PROCEDURE: 4.1 URS provides manning on vessels in accordance with the following

criteria: 4.1.1 Properly licensed Vessel Operators are provided for all

Uninspected Towing Vessels 26’ in length or longer. When Uninspected Towing Vessels are required to work more than 12 hours out of any 24-hour period, two properly licensed Vessel Operators are provided. Vessel Operators are not allowed to work more than 12 hours out of any 24-hour period, except in an emergency or during a drill. If circumstances require, Vessel Operators at times may be on stand-by on the vessel after 12 hours, until a crew change arrives.

4.1.2 Company vessels are provided, at a minimum, one additional

person, usually a deckhand, anytime the vessel is operating.

RCP-2.11-2

4.1.3 Employees other than licensed Vessel Operators will work no more than 15 hours in a 24-hour period and no more than 42 hours in a 72-hour period.

4.1.4 Additional employees are provided, as necessary, taking into

consideration the following:

4.1.4.1 Applicable laws and regulations; 4.1.4.2 Number, size and type of barges to be towed; 4.1.4.3 Geographical towing route; 4.1.4.4 Safety of personnel, equipment, and the environment; 4.1.4.5 Service in which the tow is engaged; 4.1.4.6 Duties of employees in addition to navigation; 4.1.4.7 Extent of mechanical automation; 4.1.4.8 Vessel sizes and machinery operating requirements; 4.1.4.9 Configuration of vessel – deck and engine room

machinery; 4.1.4.10 Environment/weather/climatic conditions; and, 4.1.4.11 Overall experience of employees.



RCP-2.12-1


Title:

SCHEDULING HORSEPOWER

Issue Date:





Page:

1 of 3 1.0 PURPOSE:

The purpose of this procedure is to establish a uniform system for the scheduling of horsepower (i.e., assigning a boat to a barge or group of barges to form a tow). Following this procedure will enable the Upper River Services (URS) dispatchers to maximize horsepower efficiency.

2.0 SCOPE:

This procedure applies to all vessels either owned or operated by URS.

3.0 RESPONSIBILITY: 3.1 Dispatchers should make reasonable efforts to follow this procedure. 3.2 The Vessel Operator is responsible for following this procedure.

4.0 PROCEDURE: 4.1 The Dispatchers are responsible for the scheduling of a trip and will be

responsible to:

4.1.1 Assign horsepower to trips during business hours. 4.1.2 Coordinate with Port Engineer on scheduled or unscheduled

maintenance of URS boats. 4.1.3 Confirm that the routes to be taken by tows are navigable. 4.1.4 Advise the Vessel Operations Manager of overages or shortfalls in

horsepower availability. 4.1.5 Coordinate boat maintenance problems with Port Engineer.

RCP-2.12-2

4.2 When assigning boats to trips, each trip will be handled on a case-by-case basis and determined with the procedures listed below.

4.3 The Dispatchers will determine the amount of work needed to be

performed within a given time period. 4.4 The Dispatchers, along with the Crew Dispatcher, determine which

vessels are available to perform the workload and which they would like to operate.

4.5 After deciding which vessels to run, trips will be assigned to the individual

vessels. In making these determinations, the Dispatchers will consider the influences of the following characteristics to decide which vessel will make each trip:

4.5.1 Weather conditions – visibility or wind conditions. 4.5.2 River conditions – high or low water. 4.5.3 Characteristics of the vessel.

4.5.3.1 Horsepower 4.5.3.2 Maximum height of wheelhouse (sightline) 4.5.3.3 Experience of the Vessel Operator

4.5.4 Characteristics of the tow.

4.5.4.1 Loaded barges

• Total number • Number of boxes • Number of rakes • Drafts

4.5.4.2 Empty barges

• Total number • Height of barges

o Stacked covers o 13’ or 14’ hulls

RCP-2.12-3

4.6 After developing the planned trips, the Dispatchers will communicate the plan to the affected vessels and seek input from the Vessel Operator as to whether or not he/she believes the vessel can perform the desired trip.

4.7 If the Vessel Operator is confident with the planned trip, then nothing

further needs to be done. If the Vessel Operator does not feel that the conditions allow for the trip to go as planned, then the Vessel Operator and the Dispatchers will work together to determine an appropriate tow for the vessel. The Vessel Operator will make the final determination.



RCP-2.13-1


Title:

CONFINED SPACE ENTRY

Issue Date:





Page:

1 of 1 1.0 PURPOSE:

The purpose of this procedure is to control entry into confined spaces to protect the lives and health of all employees.

2.0 SCOPE:

This applies to all vessels either owned or operated by Upper River Services (URS).


4.0 PROCEDURE: 4.1 No crewmember is authorized to enter a Permit Required Confined Space

aboard any URS vessel or barge without having the atmosphere tested and approved for entry by a Shipyard Competent Person. No crewmember is authorized to perform hot work on board any URS vessel or barge.

4.2 The Vessel Operator will be responsible for contacting the Shipyard

Manager during normal working hours to facilitate the atmospheric testing. After hours, the Vessel Operator should call the Duty Dispatcher to arrange for testing.



RCP-2.14-1


Title:

BRIDGE TRANSIT PROCEDURE

Issue Date:





Page:

1 of 3 1.0 PURPOSE:

The purpose of this procedure is to establish an operating procedure and guideline for bridge transits for all Upper River Services (URS) vessels. Following this procedure will result in uniform and consistent navigation practices that help to safeguard crewmembers, equipment and the environment.

2.0 SCOPE:


3.0 RESPONSIBILITY: 3.1 The Vessel Operations Manager is responsible for implementing this

procedure and ensuring that the Vessel Operators are aware of the requirements outlined in this procedure.

3.2 The Vessel Operator is responsible for following the requirements

described in this procedure.

4.0 PROCEDURE: 4.1 The Vessel Operator is responsible for the transit. He/she will assess the

prevailing circumstances and determine whether additional crew and/or an assist boat is required to safely transit a particular bridge. He or she will brief the necessary crew of any assist boat(s) on the planned transit. Crewmembers will be thoroughly briefed on their duties and responsibilities during the transit.

4.2 The Vessel Operator will determine the necessity of assigning a

supplemental lookout. If a supplemental lookout is necessary, appropriate means of communication will be established and a communications check will be conducted before the transit begins.

RCP-2.14-2

4.3 The Vessel Operator will assess all prevailing circumstances before making an approach to the bridge, to include, but not limited to:

4.3.1 Visibility; 4.3.2 Vertical clearance of the bridge span and highest point of boat and

tow; 4.3.3 Direction and strength of current; 4.3.4 The width of the boat/tow combination and any assist boat(s) to

allow safe horizontal clearance of the bridge span(s); 4.3.5 Establish timely communication with the bridge tender to ascertain

the bridge lift or swing time and any other traffic affecting the transit;

4.3.6 If an opening of the bridge is required, request such opening in a

timely manner that will allow a safe transit; 4.3.7 Determine the proper towboat/tow configurations for the transit;

and, 4.3.8 Use all available means to ascertain wind conditions near bridges

before committing to a transit, especially with empty barges or barges with a large sail area and make determinations on the effect of the tow’s sail area.

4.4 During a transit, radar will be operating and adjusted to the most

advantageous range as a visual aid. (An exception is when radar scanners are lowered for bridge clearance.)

4.5 The Vessel Operator will adjust the speed of the towboat/tow combination

according to the prevailing circumstances to ensure a safe transit. 4.6 Company designated narrow span bridge transits will not be transited on

radar as the single visual aid. Supplemental lookouts will be used as deemed necessary.

4.7 If the Vessel Operator believes a transit would require operating outside of

the above parameters, said Vessel Operator should contact a Dispatcher or the Vessel Operations Manager and discuss the proposed action.

RCP-2.14-3

4.8 Guidelines

4.8.1 If, in the judgment of the Vessel Operator, the safe transit of a bridge is in doubt, he or she is to stop and assess the prevailing circumstances. Should the Vessel Operator decide to stop, the following options are available:

4.8.1.1 Await improved conditions before attempting the

transit. 4.8.1.2 Request an assist boat as authorized by management

if one is available. (Determination of the suitability of a particular vessel for an assist boat is the responsibility of said Vessel Operator. The Vessel Operator must clearly communicate his/her objectives to the operator of the assist boat prior to beginning the transit.)

4.8.1.3 Consult with a Dispatcher or the Vessel Operations Manager for additional input.

4.8.2 Transit speed will be determined according to all prevailing

circumstances at the time and must be based on the judgment of the Vessel Operator.



RCP-2.15-1


Title:

MINIMUM RIGGING REQUIREMENTS

Issue Date:





Page:

1 of 2 1.0 PURPOSE:

The purpose of this procedure is to establish a uniform system for maintaining the minimum amounts of rigging aboard Upper River Services (URS) vessels.

2.0 SCOPE:


3.0 RESPONSIBILITY: The Vessel Operators should make reasonable efforts to maintain minimum rigging aboard vessels.

4.0 PROCEDURE: 4.1 The Vessel Operator should complete the following:

4.1.1 Check rigging count at the beginning of each watch. 4.1.2 Coordinate with other vessels on scheduled or unscheduled work

assignments requiring rigging. 4.1.3 Advise the lead fleet boat and Dispatch of overages and shortfalls

in rigging availability. 4.1.4 Coordinate boat rigging exchange or delivery with lead fleet boat.

4.2 When assigning rigging to boats, each boat will be handled on a case-by-

case basis and determined with the procedures listed below. 4.3 The Dispatcher will determine the amount of work needed to be

performed within a given time period.

RCP-2.15-2

4.4 The Dispatchers along with the Crew Manager, determine which vessels are available to perform the workload.

4.5 The Dispatchers and the Crew Manager determine which of the available

vessels they would like to operate. 4.6 After deciding which vessels to run, rigging will be assigned to the

individual vessels. In making these determinations, the Vessel Operator will consider the influences of the following characteristics to decide what rigging each vessel will carry:

4.6.1 Number of barges to be towed 4.6.2 Availability of rigging on barges in fleet or on rigging flat 4.6.3 Rigging will consist of wire 7/8” in diameter and at least 35’ in

length 4.6.4 Nature of work to be performed (switching, tow work, or

combination of both):

4.6.4.1 Savage/or State Street switch boat – 6 full sets 4.6.4.2 St. Paul Lower Fleet boat – 6 full sets 4.6.4.3 Lead Fleet Boat – 10 full sets 4.6.4.4 Minnesota River Shuttle (6-9 barge tows) – 14 full

sets 4.6.4.5 Minnesota River Shuttle (< 6 barge tows) – 10 full

sets 4.7 Specifications of facewires will be determined by the Port Engineer. 4.8 Inspection of Facewires and Barge Rigging

4.8.1 Visually inspect facewires and rigging for worn areas, kinks and

twists before each watch according to the Log of Tests and Inspections.

4.8.2 Replace facewires and rigging when necessary.



RCP-2.16-1


Title:

RADAR FAILURE PROCEDURE

Issue Date:





Page:

1 of 2 1.0 PURPOSE:

The purpose of this procedure is to establish a standard operating procedure that Upper River Services (URS) may use in the event of a radar failure.

2.0 SCOPE:


3.0 RESPONSIBILITY: 3.1 The Vessel Operations Manager is responsible for implementing this

procedure and should make reasonable efforts to see that vessel personnel are aware of the requirements outlined.

3.2 The Dispatcher is responsible for making the proper notifications and

required communications outlined in the procedure. 3.3 The Port Engineer shall exercise due diligence and is responsible for

arranging qualified repair technicians to resolve the radar problem at the earliest time practicable.

3.4 The Vessel Operator is responsible for making the initial notification to the

Dispatcher on Duty and noting in the Master’s Daily Log of the radar failure.

4.0 PROCEDURE:

4.1 Should a radar failure occur, the Vessel Operator shall, as soon as

practical, notify the Dispatcher of the failure and make a note of such failure in the Master’s Daily Log.

4.2 The Vessel Operator and the Dispatcher shall discuss the prevailing

conditions (including weather, visibility, traffic and the dictates of good seamanship) to determine whether it is safe for the vessel to proceed.

RCP-2.16-2

4.2.1 If the Vessel Operator and the Dispatcher determine the conditions are safe enough to proceed, then the Vessel Operator will continue on his or her trip.

4.2.2 If it is determined that conditions do not allow for safe transit, the

Vessel Operator and Dispatcher will coordinate with other URS’ vessels the best course of action to get the vessel and its tow safely to their respective destinations.

4.3 The Dispatcher notifies the Port Engineer of the radar failure as soon as

practicable so the Port Engineer can schedule repair technicians. 4.4 If the radar is repaired within the first 96 hours of the failure, no further

action is required. 4.5 If, for whatever reason, the radar cannot be repaired or replaced within

the first 96 hours of the failure, the Port Engineer must notify the Dispatcher of the inability to make the repairs.

4.6 The Dispatcher shall then contact the Captain of the Port and seek a

temporary deviation from the radar requirements and authorization to continue operations until the radar can be repaired or replaced. Note: The initial request to the Captain of the Port for a temporary deviation and authorization may be done orally, but must be followed up in written form. This written request must outline why immediate repairs are impractical and outline a timeframe when the repairs will be completed.



RCP-2.17-1


Title:

REQUIRED DOCUMENTS ON BOARD

Issue Date:





Page:

1 of 3 1.0 PURPOSE:

The purpose of this procedure is to provide a list of documents that are required to be maintained on board Upper River Services (URS) vessels.

2.0 SCOPE:


3.0 RESPONSIBILITY: 3.1 Vessel Operator should make reasonable efforts to see that this

procedure is followed. 3.2 Each crewmember is responsible for following the practices described in

this procedure.

4.0 PROCEDURE: 4.1 All vessel documents must be current (in date) and maintained in the

wheelhouse or available electronically for review where possible. 4.2 The following vessel-related documents must be kept onboard URS

vessels at all times or be available electronically:

4.2.1 Current navigation charts or maps for the area to be transited; 4.2.2 Current copy of U.S. Coast Guard Inland Navigation Rules; 4.2.3 Notice to Mariners; 4.2.4 FCC radio station license (COPY – original is in the main office); 4.2.5 U.S. Coast Guard Certificate of Documentation; 4.2.6 Fuel transfer procedures;

RCP-2.17-2

4.2.7 VHF-FM Radio Operations Manual; 4.2.8 Radar Operations Manual; 4.2.9 Vessel response plan emergency action checklist for towing

vessels; 4.2.10 URS operations memos, safety memos, safety notices, and

Regulatory Updates Manual; 4.2.11 Updated light lists for areas of operation; 4.2.12 Responsible Carrier Program Manual; 4.2.13 Fire Detection System Manual; and, 4.2.14 Letter from a registered engineer certifying the fire detection

system. 4.3 The following crew-related documents must be carried by all personnel

requiring such documentation while aboard all URS vessels:

4.3.1 Coast Guard-required operating licenses or Merchant Mariner’s Documents, if required;

4.3.2 Transportation Worker Identification Credential, if required, and, 4.3.3 FCC radiotelephone operator’s license, if required.

4.4 The following is a list of forms used aboard all URS vessels:

4.4.1 Master’s Daily Log 4.4.2 Radio logs; 4.4.3 Engine room logs; 4.4.4 Barge condition and damage reports; 4.4.5 Tow diagram; 4.4.6 Vessel Accident/Incident Report; 4.4.7 Supply list order forms;

RCP-2.17-3

4.4.8 Deckhand evaluation form; 4.4.9 Log of Tests and Inspections; and, 4.4.10 Personal Injury Report



RCP-2.18-1


Title:

FUEL TRANSFER PROCEDURES

Issue Date:





Page:

1 of 1 1.0 PURPOSE:

The purpose of this procedure is to provide guidance on Upper River Services (URS) fuel transfer procedures.

2.0 SCOPE:


3.0 RESPONSIBILITY: The Person-in-Charge must follow the vessel’s Fuel Transfer Procedures at all times during oil or fuel transfers to or from a company towing vessel.

4.0 PROCEDURE: 4.1 Vessel specific Fuel Transfer Procedures are kept on board each vessel

in the Vessel Information Book located in the wheelhouse. 4.2 Vessel specific Fuel Transfer Procedures are either posted or available on

all company towing vessels. 4.3 Fuel Transfer Procedures should be readily available to each Person-in-

Charge of any transfer of oil or fuel to or from a company towing vessel.



RCP-2.19-1


Title:

PROCEDURES FOR IDENTIFYING CRITICAL STORES AND SUPPLIES

Issue Date:





Page:

1 of 1 1.0 PURPOSE:

The purpose of this procedure is to establish uniform guidelines for identifying critical stores and supplies to be ordered for Upper River Services (URS) vessels.

2.0 SCOPE:

This applies to all vessels owned or operated by URS.

3.0 RESPONSIBILITY: The Vessel Operator is responsible for ensuring that routine supply orders are sent in to the URS Wharf Purchasing Office, and for controlling and approving the number of supply orders.

4.0 PROCEDURE: 4.1 Routine supply requests should be sent in to the Purchasing Office on

order forms during crew changes or by whatever means practicable. 4.2 Each requisition is to be reviewed, signed and dated by the Vessel

Operator before it is forwarded to the Purchasing Office, where it will be logged in and recorded.

4.3 Items should only be ordered via voice communication if they are

necessary for the vessel to perform a particular job at hand or to ensure the immediate safety of the crew or the vessel.



RCP-2.20-1

VESSEL OPERTATING

PROCEDURES

Title:

LOG OF TESTS AND

INSPECTIONS

Issue Date:

April 14, 2014

Last Revised:

February 20, 2015

Procedure Number:



Page:

1 of 2

1.0 PURPOSE: The purpose of this procedure is to see that Upper River Services (URS) vessels are in compliance with the requirements of USCG regulations shown in 33 CFR 164, which require certain tests and inspections.

2.0 SCOPE:

This procedure applies to all vessels either owned or operated by URS.

3.0 RESPONSIBILITY: 3.1 The Vessel Operations Manager or his/her designate should make

reasonable efforts to see that vessel personnel follow this procedure. 3.2 Vessel Operators are responsible for completing the Log of Tests and

Inspections in accordance with this procedure.

4.0 PROCEDURE:

4.1 Actual inspections should be conducted verifying that each item addressed on the form is actually working in a satisfactory manner and visual inspections should be adequate to allow the inspector to reasonably determine if significant deficiencies are present.

4.2 The Log of Tests and Inspections should be completed prior to each

watch. Once completed, the Vessel Operator must initial the Master’s Daily Log confirming that the tests and inspection were completed.

RCP-2.20-2

5.0 RECORDS:

If a vessel is involved in a reportable marine casualty, the Master’s Daily Log should be filed with and kept for the same length of time as the Vessel Accident/Incident Report.

6.0 APPENDICES:

Log of Tests and Inspections


0 Initial issue April 14, 2014 1 First revision – Removed paragraph 5.1, renumbered as appropriate and revised paragraphs 4.2 and 5.1 February 20, 2015

Log of Tests and Inspections 33CFR164.80: The owner, master, or operator of each towing vessel of less than 1,600 GT shall ensure

that the following tests and inspections of gear occur before the vessel embarks on a voyage of more than 24 hours or when each new master or operator assumes command:

COMPLETE BEFORE EACH WATCH.

ONCE COMPLETED THE OPERATOR MUST INITIAL THE MASTER’S DAILY LOG.

Steering Systems A test of the steering-gear-control system; a test of the main steering gear from the alternative power supply, if installed; a verification of the rudder-angle indicator relative to the actual position of the rudder; and a visual inspection of the steering gear and its linkage.

Navigational

Equipment

A test of all installed navigational equipment, including: Marine Radar Searchlight (A searchlight, directable from the vessel’s main steering station and

capable of illuminating objects at a distance of at least two times the length of the tow.

VHF Radio (Two VHF radios are required) Magnetic Compass (An illuminated card-type magnetic steering compass readable

from the vessel’s main steering station. Electronic Position-Fixing Device (Either a LORAN-C receiver or Global Positioning System (G.P.S.), if the vessel engages in towing seaward of Navigable waters of the U.S.

Communications Operation of all internal vessel control communications and vessel-control alarms, if

installed.

Lights Operation of all navigational lights and all searchlights.

Terminal Gear Visual inspection of tackle; of connections of bridle and towing pendant, if applicable; of

chafing gear, kevels, roller chocks, and of the winch brake, if installed. (FACE WIRES and

WINCHES)

33CFR164.76-Towline and terminal gear for towing alongside and pushing ahead: The owner, master or operator of each vessel towing alongside or pushing ahead shall ensure that the face wires, spring lines, and push gear used-

(a) Are appropriate for the vessel’s horsepower; (b) Are appropriate for the arrangement of the tow; (c) Are frequently inspected; and (d) Remain serviceable.

Propulsion

Systems

Visual inspection of the spaces for main propulsion machinery, of machinery, and of

devices for monitoring machinery.

NOTE ANY ISSUES/COMMENTS ON THE MASTER’S DAILY LOG.

February 20, 2015

RCP-2.21-1

VESSEL OPERATING

PROCEDURES

Title:

WELDING AND

CUTTING

Issue Date:

February 20, 2015

Last Revised:

February 20, 2015

Procedure Number:



Page:

1 of 1

1.0 PURPOSE: The purpose of this procedure is to protect company employees, company property and equipment, and the environment.

2.0 SCOPE:

This applies to all crewmembers onboard vessels either owned or operated by Upper River Services (URS).


4.0 PROCEDURE: 4.1 No crewmember is authorized to perform hot work on board any URS

vessel or barge.



RCP-3.1-1

VESSEL MAINTENANCE

AND INSPECTION

Title:

EQUIPMENT

MAINTENANCE

SCHEDULES

Issue Date:

April 14, 2014

Last Revised:

February 20, 2015

Procedure Number:



Page:

1 of 3

1.0 PURPOSE: This procedure establishes guidelines for maintaining equipment on board Upper River Services (URS) vessels, and lists those items which should be checked routinely.

2.0 SCOPE:


3.0 RESPONSIBILITY: 3.1 The Deck Crew is responsible for completing onboard maintenance as

assigned to them in the vessel maintenance system, and reporting any discrepancies within the vessel maintenance system.

3.2 The Vessel Operator is responsible for completing onboard maintenance

as assigned to them in the vessel maintenance system, and reporting any discrepancies within the vessel maintenance system. Any discrepancies needing immediate attention must also be reported to the Dispatch office.

3.3 The Port Engineer is responsible for determining the most cost-effective,

efficient and timely means of equipment repair. Unscheduled maintenance and repairs are reported to the Vessel Operations Manager and used to update the maintenance file on each boat.

4.0 PROCEDURE: 4.1 URS generally follows the maintenance schedules recommended by

various machinery manufacturers. 4.2 Crewmembers should log on to the vessel maintenance system at the

beginning of each watch and complete assigned tasks.

RCP-3.1-2

4.3 Vessels should be dry-docked annually or no less than every 36 months, for regular maintenance according to the service in which they operate. The Port Engineer must schedule the dry-docking at the proper time. The Port Engineer will supervise and authorize all repairs made while the vessel is on dry-dock and complete the Towing Vessel Inspection Form – On Drydock. 4.3.1 All watertight closures (including deck and freeboard closures) will

be checked at least annually and any gaskets which are disturbed will be replaced.

4.3.2 All closures, doors, vent pipes, etc. will be checked for water

tightness and structural integrity. 4.3.3 The hull and its integrity will be checked annually when the vessel

is dry docked. 4.3.4 All piping systems should be checked for appropriate markings

when the vessel is dry-docked. 4.3.5 All freeing ports and scuppers (if applicable).

4.4 Guards will be placed around any exposed moving parts where practical

(eg. shafts, belts, pulleys). 4.5 Inspection and checklist forms should be used during all routine

equipment maintenance checks. 4.6 All maintenance records will be maintained for the duration of ownership

of the vessel.

5.0 RECORDS:

Completed Towing Vessel Inspection Forms – On Drydock should be kept for the duration of ownership of the vessel.

6.0 APPENDICES:

Towing Vessel Inspection Form – On Drydock

RCP-3.1-3


0 Initial issue April 14, 2014 1 First revision – Removed paragraphs 4.3, 4.4 and 4.5, renumbered as appropriate, revised paragraphs 3.1, 3.2, 4.2, 4.3 and 4.3.1, added paragraphs 5.0 and 6.0 February 20, 2015

Upper River Services

Towing Vessel Inspection Form – on Dry Dock

M/V:

Date Inspected:

Inspected by:

Location: State Street Dry Dock Pigs Eye Marine Ways

Item Inspected: Visual Inspection Original Port Center Starboard

Propeller for damage to blade:

Propeller diameter: 68 x 54.5

Propeller hub: keyway & taper: 1.375 w x 1”

6” marine std

Tailshaft run-out reading:

Tailshaft – outboard sleeve or wear area: 7” O.D. O.D. O.D. O.D.

Tailshaft – inboard sleeve or wear area: 6.625” O.D. O.D. O.D. O.D.

Steering rudder – bent?

Steering rudder – damaged?

Steering rudder lower sleeve or wear area: 6” O.D. O.D. O.D. O.D.

Steering rudder upper sleeve or wear area: 6” O.D. O.D. O.D. O.D.

Flanking rudder – bent?

Flanking rudder – damaged?

Flanking rudder lower sleeve or wear area: 6” 6” 6” 6” Inboard Outboard Center Inboard Outboard

Flanking rudder upper sleeve or wear area: 6” 6” 6” 6” Inboard Outboard Center Inboard Outboard

Strut bushing / bearing: 9” O.D. O.D. O.D. O.D.

Inboard bushing / bearing: 6.75” O.D. O.D. O.D. O.D.

Packing gland / packing:

Sea chest – screen, mud, zebra mussels, etc.:

Generator skin coolers:

Main engine skin coolers:

Tailshaft Pucker Seals:

Rudder Pucker Seals:

M/V:

Date:

Inspected by:

Annual Inspection Continued Page 2 of 2

Item Inspected: Comments:

Piping System – Paint & Markings legible

Watertight Closures:

Bow Headlog:

Port Rub Rail:

Stern Rub Rail:

Starboard Rub Rail:

Fuel tanks, external inspection:

Fresh water tanks (non-potable), external inspection:

Towknees:

Hull – port knuckle:

Hull – starboard knuckle:

Hull – bow rake and transition:

Hull – stern, over propellers:

February 20, 2015

RCP-3.2-1

VESSEL MAINTENANCE AND INSPECTION

Title:

LOCKOUT/TAGOUT PROCEDURE

Issue Date:





Page:

1 of 4 1.0 PURPOSE:

This procedure describes the conditions under which lockout/tagout procedures should be undertaken and provides a uniform and consistent work practice that will safeguard Upper River Services (URS) crewmembers, operating personnel, equipment, and the environment. It applies to all URS vessel crewmembers and operations shore personnel. Following this procedure will assist in reducing accidents and injuries due to operating errors.

2.0 SCOPE:


3.0 RESPONSIBILITY: 3.1 The Vessel Operations Manager is responsible for implementing a

company-wide lockout/tagout procedure for marine operations. 3.2 The Port Engineer is responsible for implementing a lockout/tagout policy

and procedure for work done under his or her supervision. 3.3 The Port Engineer and Mechanics should make reasonable efforts to

comply with and enforce the lockout/tagout procedures on URS vessels. 3.4 The Vessel Operator should make reasonable efforts to ensure that

equipment he or she deems as not fit for service is locked out or tagged out.

3.5 Other crewmembers are responsible for reporting unsafe or unusable

equipment to the Vessel Operator.

RCP-3.2-2

4.0 PROCEDURE: 4.1 When boat gear or shop equipment becomes worn or damaged, and is no

longer safe or suitable for its intended use, it must be tagged out of service. The tagout list includes, but is not limited to, the following:

4.1.1 Air or electrically operated tools; 4.1.2 Air compressors; 4.1.3 Portable pumps; 4.1.4 Bilge pumps; 4.1.5 Emergency engine shutdown; 4.1.6 Spotlights; 4.1.7 Radars; 4.1.8 Electrical appliances; 4.1.9 Fans or blowers; and, 4.1.10 Other devices that may present a hazard if used in their present

unsuitable condition. 4.2 The Vessel Operator must require that marine gear, tools, and safety

equipment be tagged and, when possible, physically removed to an out-of-service location so it cannot be mistakenly used.

4.3 The following information must be written on the tag:

4.3.1 “Do Not Operate” on one side; 4.3.2 “Do Not Remove This Tag” on the other side; 4.3.3 Description of the problem with the item; 4.3.4 Name of the boat to which the equipment is assigned; 4.3.5 Signature of individual tagging item; and, 4.3.6 Date of tagging.

RCP-3.2-3

4.4 When vessel maintenance is being conducted, energy sources that present a hazard to the maintenance personnel must be disconnected, de-energized, depleted or eliminated. This includes, but is not limited to, the following:

4.4.1 Securing electrical power and bleeding off air from compressor

tanks before working on engines or starters; 4.4.2 Turning off electrical breakers to steering motors, winches,

spotlights, etc., before working on the unit; 4.4.3 Securing the source of propulsion and steering when a diver is

under a boat for maintenance or inspection. 4.5 The Vessel Operator must require that appropriate energy source, switch,

valve or breaker box be locked and tagged out of service. 4.6 In the event a repair cannot be made immediately, the Vessel Operator,

Port Engineer, mechanic or Vessel Operations Manager must ensure that the energy sources are tagged “Do Not Operate” and physically locked with appropriate devices, such as:

4.6.1 Key locks; 4.6.2 Clamps; 4.6.3 Tie wraps; or, 4.6.4 Other suitable methods and material that cannot be removed

except by forcefully cutting or destroying. 4.7 “Do Not Operate” tags must be attached to the gear and its power source

when applicable. The tags should be replaced when they become unreadable.

4.8 These precautions are taken because some time may elapse before an

item is repaired and put back in operation. This procedure should prevent an employee from using broken or worn-out equipment by mistake.

4.9 Portable equipment sent for repair must be securely tagged. The tag

must be filled out with a complete description of the equipment problem. 4.10 Energy sources for boat operating equipment must remain locked and

tagged out until the equipment is repaired or removed.

RCP-3.2-4

4.11 After a unit is restored to service, the energy source may be unlocked and the tag removed jointly by the Vessel Operator and the individual completing the maintenance or repair to the unit.



RCP-3.3-1


Title:

MAINTENANCE AND REPAIR REPORTING

Issue Date:





Page:

1 of 2 1.0 PURPOSE:

This procedure establishes a system for reporting and handling mechanical and engineering problems aboard Upper River Services (URS) boats.

2.0 SCOPE:


3.0 RESPONSIBILITY: The Port Engineer or designate is responsible for performing the duties required by this procedure.

4.0 PROCEDURE: 4.1 The Port Engineer or a designate receives boat problem information from

the boats in any of the following formats:

4.1.1 The Dispatch Office receives telephone calls during normal working hours at the main office.

4.1.2 Calls are directed to the Port Engineer. If there is no answer, a

message should be left. 4.1.3 Non-emergency boat repair information is written up on the Engine

Room Log in the remarks section and turned into the Dispatch Office.

4.2 The Port Engineer evaluates the problem to determine if it is routine, non-

routine or emergency repair. 4.3 The Port Engineer notifies the Dispatch Office of the problem and

estimated time for repair, and may ask to remove the boat from service depending on the repair designation.

RCP-3.3-2

4.4 The Dispatch Office notifies the Port Engineer when the boat will be available for repair.

4.5 The Port Engineer coordinates repairs as needed and reviews the Engine

Room Log daily. 4.6 The Port Engineer notifies the Dispatch Office and the Vessel Operations

Manager when the repairs are complete and the boat is ready for service. 4.7 When the repair is completed, the Port Engineer completes the Vessel

Repair Logbook that is specific to that boat with all the pertinent information (part numbers, hours of labor, etc.).



RCP-3.4-1


Title:

ROUTINE SCHEDULED VESSEL MAINTENANCE

Issue Date:





Page:

1 of 2 1.0 PURPOSE:

This procedure establishes guidelines for handling routine repairs to Upper River Services (URS) boats, including, but not limited to, dry-docking, topside, and machinery maintenance.

2.0 SCOPE:



4.0 PROCEDURE: 4.1 The Dispatcher and the Port Engineer schedule boats for routine repairs

or dry dockings using the scheduled maintenance program. 4.2 The Port Engineer takes the following steps:

4.2.1 Notifies the Vessel Operations Manager when a boat is nearing its scheduled repair or dry-docking period.

4.2.2 Prepares a list of repairs with the assistance of the boat crew. 4.2.3 Refers to the Daily Maintenance and Repair Schedule, Vessel

Visit Form, and the Vessel Inspection Report for any additional items to add to the list of repairs.

4.2.4 Reviews the list of repairs with the shipyard representative and

together they estimate the time required to perform the repairs.

RCP-3.4-2

4.2.5 Notifies the Dispatcher of the boat’s routine repair and the estimated time out of service for the repairs.

4.2.5.1 The Dispatcher notifies the Port Engineer when the

boat is available for the repairs.

4.2.6 Schedules the shipyard for routine repairs. 4.2.7 Conducts a machinery survey or dry-dock report and a hull

inspection if the boat has been dry-docked. 4.2.8 Inspects the items on the repair list and adds additional items

captured during the hull and machinery survey. 4.2.9 Reviews the additions to the repair list with the shipyard

representative and modifies the estimated completion time if affected by the additional items.

4.2.10 Notifies the Vessel Operations Manager and the Dispatcher of

the additional repairs and the new completion time. 4.2.11 Inspects and verifies repairs made by the vendor and/or shipyard

against the repair list. 4.2.12 Notifies the Dispatcher when the repairs are complete and the

boat is ready for service. 4.2.13 Completes the Vessel Repair logbook, and makes appropriate

corrections to the daily schedule. 4.2.14 Reviews the repairs with the Vessel Operations Manager. 4.2.15 Files completed forms, reports and lists in the Boat Maintenance

file for the boat on which the repairs were made.



RCP-3.5-1


Title:

NON-ROUTINE VESSEL REPAIRS

Issue Date:





Page:

1 of 2 1.0 PURPOSE:

This procedure establishes guidelines for handling non-routine vessel repairs aboard Upper River Services (URS) vessels, including, but not limited to, dry-docking, topside, and machinery repairs which do not affect the vessel’s ability to run or operate safely.

2.0 SCOPE:


3.0 RESPONSIBILITY: 3.1 The Port Engineer or designate is responsible for performing the duties

required by this procedure. 3.2 The Dispatcher is responsible for arranging for boats to be available for

repair.

4.0 PROCEDURE: 4.1 The Vessel Operator reports problems involving the boat’s hull, machinery

or equipment to the Dispatcher. 4.2 The Port Engineer or designate takes the following steps:

4.2.1 Gathers the information and notifies the Dispatcher of the problem. 4.2.2 Notifies the Dispatcher of the repairs needed and estimated time to

correct the problem. 4.2.3 Notifies the Dispatcher when the repairs are complete and the boat

is back in service.

RCP-3.5-2

4.3 The Port Engineer or Mechanic reviews the repairs made to the boat and any additional problems encountered while making repairs, with the Vessel Operations Manager.

4.4 The Port Engineer updates the Vessel Repair Logbook.



RCP-3.6-1


Title:

EMERGENCY VESSEL REPAIRS

Issue Date:





Page:

1 of 2 1.0 PURPOSE:

This procedure establishes guidelines for handling emergency vessel repairs on Upper River Services (URS) boats, including, but not limited to, dry-docking, topside and machinery repairs which affect the boat’s ability to run or operate safely.

2.0 SCOPE:



4.0 PROCEDURE: 4.1 The Vessel Operator reports problems involving the boat’s hull, machinery

or equipment to the Dispatcher or Port Engineer. 4.2 The Port Engineer or designate takes the following steps:

4.2.1 Contacts the Vessel Operator to determine if the boat can safely travel to a designated site to make repairs.

4.2.2 Notifies the Dispatcher of the problem and requests assistance, if

needed, to get the boat to a designated site to make repairs. 4.2.3 Obtains an estimated time for repairs to be complete. 4.2.4 Notifies the Dispatcher of the estimated time the boat will be out of

service for repairs. 4.2.5 Follows the repairs through completion.

RCP-3.6-2

4.2.6 Notifies the Dispatcher when repairs are complete and the boat is back in service.

4.2.7 Notifies the Vessel Operations Manager of the problem and

corrective action taken. 4.2.8 Updates the Vessel Repair Logbook.

4.3 Failure or malfunction of vessel equipment may require notification of the U.S. Coast Guard both verbally and written with the submission of Form CG-2692. See the Incident Reporting Procedures in this manual for further guidance.



RCP-3.7-1


Title:

PIPING SYSTEMS Issue Date:





Page:

1 of 1 1.0 PURPOSE:

This procedure establishes a consistent system for the identification of piping systems throughout all Upper River Services (URS) boats.

2.0 SCOPE:


3.0 RESPONSIBILITY: 3.1 The Port Engineer is responsible for making a standard color coded

diagram for all piping systems aboard URS boats. 3.2 The Port Engineer should make a reasonable effort to verify that all piping

systems have been marked and painted correctly. This should be inspected annually.

3.3 All crewmembers should make reasonable efforts to become familiar with

the colors for the piping systems and tanks onboard all URS boats.

4.0 PROCEDURE: 4.1 Each vessel shall have a posted sign in the engine room with the

appropriate color coding for that vessel. 4.2 All URS boats shall be painted or marked appropriately. This should be

inspected during the annual inspection.



RCP-3.8-1


Title:

QUALIFICATIONS AND TRAINING REQUIREMENTS FOR PERSON IN CHARGE OF MAINTENANCE

Issue Date:





Page:

1 of 2

1.0 PURPOSE:

This procedure describes the qualifications and training requirements for persons in charge of vessel maintenance.

2.0 SCOPE:

This procedure is applicable to all Upper River Services (URS) personnel in charge of vessel maintenance.

3.0 RESPONSIBILITY: 3.1 The Port Engineer is responsible for performing and overseeing

maintenance work on company vessels. 3.2 The Port Engineer should make reasonable efforts to train the appropriate

personnel in the necessary requirements of vessel maintenance procedures.

4.0 PROCEDURE:

4.1 Qualifications:

4.1.1 Must have working knowledge of the vessel and its operating systems.

4.1.2 Knowledge of company policies and vessel requirements. 4.1.3 Knowledge of marine safety and environmental protection

requirements. 4.1.4 Must meet company qualifications for job position.

RCP-3.8-2

4.2 Training:

4.2.1 Employees performing maintenance should receive on-the-job training as he/she advances through various job classes.

4.2.2 Personnel should be initially trained on maintenance processes

and procedures by the Port Engineer. 4.2.3 Additional training should be provided as needed to maintain

proficiency. 4.2.4 URS management should provide updated maintenance

information and process updates as such information becomes available. These should be provided to employees through memos and company meetings.



RCP-4.1-1

SAFETY POLICIES

Title:

COMPANY SAFETY POLICY

Issue Date:





Page:

1 of 2 1.0 PURPOSE:

This procedure establishes the Upper River Services (URS) Safety Policy.

2.0 SCOPE:

This procedure is applicable to all URS personnel.

3.0 RESPONSIBILITY: All Upper River Services employees should make reasonable efforts to follow this policy.

4.0 PROCEDURE: URS Management is committed to safety in all phases of our operations. We strive to make reasonable efforts to comply with all applicable laws and regulations. Our corporate safety program supplements existing safety standards as a means of providing additional protection for our employees, the environment, and our cargo. Every URS employee is expected to give his or her full support to our corporate effort to promote safety. We believe that all accidents are preventable by establishing rules and safe working procedures, exercising good judgment, and using common sense. Preventing accidents will prevent injuries and death. All URS employees have the opportunity and responsibility to protect themselves and to contribute to the protection of their fellow crewmembers, the environment, and the equipment for which they are responsible. The individual is always directly responsible for his or her immediate actions, or inaction, and is therefore the only person who can guarantee his or her own safety. A job is well done only when it is done safely.

RCP-4.1-2

We expect to maintain efficiency in our daily operations by making an effort to do every job safely and correctly the first time and every time. Accidents and injuries that occur as a result of carelessness or attempting to save a few minutes are unacceptable. Everyone is expected to recognize the need to practice “safety first” when engaged in any task. Safety policies or procedures are always subject to amendment if an employee has a suggestion for a better way. Everyone is encouraged to participate in the development of new procedures, or revisions to existing procedures, by making recommendations to the URS Safety Committee. You may call, send your suggestions in written form, or stop by the office to discuss your ideas. Your efforts will be very much appreciated.



RCP-4.2-1

SAFETY POLICIES

Title:

COMPANY SAFETY

RULES

Issue Date:

April 14, 2014

Last Revised:

February 20, 2015

Procedure Number:



Page:

1 of 5

1.0 PURPOSE: It is the policy of Upper River Services (URS) that we will operate safely and will make reasonable efforts to comply with all safety regulations. All employees are to support this policy and follow all procedures established by the company. The following rules establish, at a minimum, a basic outline for all employees.

2.0 SCOPE:


3.0 RESPONSIBILITY: 3.1 The Vessel Operations Manager is responsible for posting the most

current copy of URS’ Safety Rules on board the vessel at all times. At the time of the spring meeting, the Vessel Operations Manager will review the Safety Rules with the crew.

3.2 The Vessel Operations Manager is responsible for reviewing, updating,

and maintaining the Safety Rules. 3.3 Each new employee will review the Safety Rules during URS’s online new

hire orientation. 3.4 All URS employees should report any safety deficiency or non-conformity

to a member of the Safety Committee or any member of management. 3.5 All URS employees must follow company Safety Rules at all times

4.0 PROCEDURE:

4.1 Safety is a condition of employment!

RCP-4.2-2

4.2 No one may board any URS vessel if he or she is under the influence of alcohol or drugs. No alcohol or drugs are allowed aboard any vessel owned or operated by URS. Violation of this rule will result in immediate dismissal. See the Drug and Alcohol Policy located in this manual for further details.

4.3 Report all injuries or accidents, regardless of how slight. 4.4 Work vests will be worn in accordance with the Personal Protective

Equipment (PPE) Policy located in this manual. 4.5 Each crewmember must review his/her role aboard the vessel as listed in

the Station Bill and be prepared to respond in an emergency. The Station Bill must be posted on each vessel.

4.6 Foot protection will be worn in accordance with the PPE Policy. 4.7 All newly hired personnel must be aware that hazards are involved in

learning a new job. When in doubt, ask. Always know exactly what you are supposed to do before you try to do it.

4.8 The boat and tow must be kept clean and free of obvious safety hazards.

Good housekeeping will eliminate most hazards before an accident occurs. Stow lines, rigging, buckets, etc. when you finish a task.

4.9 Stairways and ladders must always remain unobstructed, clean, and free

of tripping hazards. Never lay lines, cords, or wires across or down stairs. 4.10 Decks and walkways must be kept dry and free of slippery areas. All

cargo residues, wet or dry, must be removed in accordance with the company’s VGP policy.

4.11 Deck fitting tops and deck edges should be painted white or some other

high visibility contrasting color. 4.12 Employees should use sound judgment when transiting stairwells, step

ladders, etc. Face the stairs when going up or down them. Never attempt to use the stairs when both hands are full or your vision is obstructed.

4.13 When walking on the tow, whenever possible, use an inboard walkway,

not the outside edges. 4.14 Always carry a load on your outboard shoulder. Be prepared to let the

item you are carrying fall overboard instead of yourself.

RCP-4.2-3

4.15 Treat vessel drills as a real emergency. Always respond with the appropriate equipment and report to your specified location.

4.16 No smoking areas must be observed without fail. Smoking is NOT

permitted on:

4.16.1 Any tank barge (loaded or empty); 4.16.2 In the deck locker; 4.16.3 At fueling stations; 4.16.4 When fueling outboard engines; 4.16.5 When painting or mixing paint; 4.16.6 When using spray cans; or 4.16.7 When handling any flammable product.

4.17 Learn the location of all emergency equipment aboard your vessel. Know

how to use the equipment before an emergency arises. 4.18 If you discover a fire, report the fire first, and then, if at all possible, fight

the fire with the available equipment until help arrives. 4.19 Always wear clothing appropriate for the task you are performing. Long

pants and shirts are always required. 4.20 Eye protection must be worn in accordance with the PPE policy. 4.21 Hearing protection must always be worn in accordance with the PPE

policy. 4.22 Personal fall arrest protection must be used in accordance with the PPE

policy. 4.23 When laying wires, handling lines, working ratchets, etc., always work on

the inside side of the line and protect yourself from a fall overboard. When possible, ratchets must be tightened inboard.

RCP-4.2-4

4.24 Line handling while locking or docking a tow may present a hazard to anyone who is not alert to his/her surroundings.

4.24.1 Pay very close attention to the lines at each station. 4.24.2 Keep yourself away from lines under strain - stay out of the direct

line of fire. 4.24.3 Never straddle a line or place your feet in the bight. 4.24.4 Hard bumps and gaps between the barges or between a barge

and the lock wall may occur. 4.24.5 Avoid an unsafe situation by paying close attention to what is

happening around you. Leave any area that might create an immediate hazard.

4.25 Always help other crewmembers stay safe by passing the word about

bumps or other situations that might catch them by surprise. Hold on to something when you hear the word “bump” or see one coming up.

4.26 Never try to jump from barge to barge, barge to lock wall, barge to dock,

etc. Wait until you can make the move safely. 4.27 Never lean on lifelines, rails, lock walls or over the edge of a vessel. 4.28 Always use a portable ladder correctly. Set the ladder at a safe working

angle on secure footing. Do not try to use a ladder as a horizontal bridge. Whenever possible, secure one end of the portable ladder.

4.29 Repair or replace defective tools. Do not use a tool that is inappropriate

for the job. Follow the Lockout/Tagout Procedure in this manual for defective tools and machinery.

4.30 Vessel crews are not permitted to spray paint in enclosed spaces. 4.31 Never operate machinery unless all protective guards and alarms are in

place and working as designed. Take special care when working around operating machinery.

4.32 Never step on manhole covers. Always replace a manhole cover and

secure it.

RCP-4.2-5

4.33 Always keep your fingers, hands, and feet away from a pinch point at lines and deck fittings.

4.34 Never place your hand or foot between a barge and tow knee, between

barges in the tow, or between the dock and a vessel. 4.35 Use caution when transporting rigging or lines, carry the equipment as

taught. 4.36 Never engage in horseplay or practical jokes. 4.37 Do not allow unauthorized personnel aboard the boat or tow. 4.38 Always use a flashlight at night. Be sure that you illuminate the deck area

rather than step into a shadow. Never step where you cannot see the edge of a vessel or the deck. Use your flashlight carefully to avoid blinding the pilot, yourself, or another crewmember. Always use the buddy system at night when checking the tow.

4.39 Never go out on the tow or aloft without checking with the Vessel Operator

first. 4.40 Entry into cargo spaces, wing tanks, rakes, or voids is prohibited without

prior permission from the Vessel Operator and strict adherence to the Confined Space Entry procedure located in this manual.

4.41 On URS vessels, where practical, decks and walkways will be treated with

non-skid paint. The condition of non-skid paint will be inspected in accordance with the Inspection Procedures.

4.42 Flammable and combustible liquids will be stored in the appropriate area

and marked. Flammable and combustible liquids should be used where there are no open flames or other sources of ignition and with natural or mechanical ventilation to disperse vapors.

4.43 The best safety tip of all is: PAY ATTENTION. Be alert to everything and

everyone as you perform your task. You will contribute to a safer operation.


0 Initial issue April 14, 2014 1 First revision – Revised paragraphs 4.22, 4.41 and 4.42 February 20, 2015

RCP-4.3-1

SAFETY POLICIES

Title:

SAFETY AND HEALTH COMMITTEE STRUCTURE

Issue Date:



RCP-4.3

Approved By:


1 of 2

1.0 PURPOSE:

To give a brief introduction to the safety program structure and purpose. 2.0 SCOPE:

All vessel employees should be given the opportunity to be involved in the Upper River Services (URS) safety program.

3.0 RESPONSIBILITY:

The Vessel Operations Manager should make reasonable efforts to see that all employees are given an opportunity to be involved in the safety program.

4.0 PROCEDURE:

4.1 URS’ Vessel Division should utilize two separate Safety and Health Committees in its effort to assure both active commitment to the safety program as well as creating the opportunity for an honest and open exchange of ideas related to safety problems and issues. The Safety and Health Committees are;

4.1.1 Employee Safety and Health Committee

4.1.2 Management Safety and Health Committee

4.2 The Management Safety and Health Committee should oversee the

actions of the Employee Safety and Health Committee.

4.3 These committees were established for the following purposes:

4.3.1 To keep the employees updated on the new regulations and laws. 4.3.2 To help URS follow the proper procedures outlined by applicable

government and regulatory agencies.

RCP-4.3-2

4.3.3 To help employees follow the guidelines and regulations as set forth by company policy as well as government agencies.

4.3.4 To discuss employee suggestions and complaints.

4.3.5 To provide back-up to employees and follow-up to employee

questions. 5.0 REVISION HISTORY:

0 Initial Issue April 14, 2014

RCP-4.4-1

SAFETY POLICIES

Title:

EMPLOYEE SAFETY AND HEALTH COMMITTEE

Issue Date:



RCP-4.4

Approved By:


1 of 4

1.0 PURPOSE:

To explain the role of the Employee Safety and Health Committee. 2.0 SCOPE:

This procedure applies to the Employee Safety and Health Committee. Management should make reasonable efforts to have as many vessel crewmembers as possible attend the appropriate Employee Safety and Health Committee meetings.

3.0 RESPONSIBILITY:

The Vessel Operations Manager or his/her designate should make reasonable efforts to see that the functions of the Employee Safety and Health Committee are carried out.

4.0 PROCEDURE:

4.1 EMPLOYEE SAFETY AND HEALTH COMMITTEE

4.1.1 The Employee Safety and Health Committee should have as standing members; the Vessel Operations Manager and other vessel crewmembers that are available at the time of the meeting. This committee should meet in formal session at least once each month during the operating season.

4.1.2 An Attendance Roster should be kept for each meeting. The Safety

and Health Meeting Attendance Roster is located at the end of this procedure. A copy of the Attendance Roster from each meeting should be maintained for the appropriate period of time for later review.

RCP-4.4-2

4.1.3 The Vessel Operations Manager or his/her designate should prepare an agenda for each Employee Safety and Health Committee meeting. The agenda should include but not be limited to the following subjects:

4.1.3.1 A review of outstanding issues from the previous

month’s meeting. 4.1.3.2 A review of accidents, injuries and near misses that

have occurred since the committee's last meeting. 4.1.3.3 A discussion of the most recent safety inspections. 4.1.3.4 A review of employee safety training needs with

written recommendations forwarded to the Management Safety and Health Committee.

4.1.3.5 A review of safety enforcement problems and how these problems have been addressed.

4.1.3.6 A review of the safety equipment needs. Written recommendations should be forwarded to the Management Safety and Health Committee for appropriate action.

4.1.3.7 A review of the Safety and Health Program as a whole.

4.1.3.8 Open the floor for any additional comments concerning safety and health issues.

4.1.4 Following the Employee Safety and Health Committee meetings the

Vessel Operations Manager or his/her designate should create a summary report of the meetings for Management Safety and Health Committee review.

4.2 ADDITIONAL EMPLOYEE SAFETY AND HEALTH COMMITTEE

RESPONSIBILITIES

4.2.1 The Employee Safety and Health Committee should assist the Management Safety and Health Committee in the development of the Annual Training Calendar by identifying specific training needs as they arise in the work place. These needs should be discussed in each Employee Safety and Health Committee meeting then forwarded to the Management Safety and Health Committee with a recommendation for training.

4.2.2 The safety committee will conduct monthly meetings and area

inspections to review accident reports, identify hazards, and address any and all safety concerns raised by employees, supervisors and the Vessel Operations Manager. (From A.W.A.I.R.)

RCP-4.4-3

4.2.3 The committee will review the AWAIR program at least annually and make recommendations concerning updates and revisions to the program to senior management and the Vessel Operations Manager. (From A.W.A.I.R.)

4.2.4 Safety committee members each represent their particular work area and, therefore, should address all safety concerns brought to them by their coworkers. These concerns should be handled by initially investigating the issue with the area supervisor to determine if the concern is valid and then, as necessary and appropriate, bring the issue to the Vessel Operations Manager or the full safety committee. (From A.W.A.I.R.)

4.2.5 The Vessel Operations Manager or his/her designate should make

reasonable efforts to implement the Annual Training Calendar by seeing that the training topics for each month are presented to each employee.

4.2.6 Supervisors are encouraged to supplement the formal safety

meetings with less formal and more frequent safety sessions. 4.2.7 In addition to monthly responsibilities, each year the safety

committee may review accident investigations, historical data, training activity, injury reports, inspection reports, corrective action records, and OSHA 300 Logs to identify areas of ongoing concern and accomplishment. The noteworthy results of this review are reported to the Management Safety and Health Committee. (From A.W.A.I.R.)

4.2.8 The Employee Safety and Health Committee may also compare the

company’s annual safety goals with the safety records and data from other sources and recommends goals and direction(s) for the next year to the President. (From A.W.A.I.R.)

4.3 PURPOSE FOR ESTABLISHING EMPLOYEE SAFETY AND HEALTH

COMMITTEES

4.3.1 To provide a safe work environment for employees. 4.3.2 To investigate, discuss and review personal injuries to prevent

future incidents of the same nature. 4.3.3 To remain current on new regulations and laws.

RCP-4.4-4

4.3.4 To help URS follow the proper procedures as outlined by applicable government regulatory agencies.

4.3.5 To help employees in following the guidelines and regulations as

set forth by company policy. 4.3.6 To discuss and provide follow-up to employee suggestions. 4.3.7 To provide a forum in which employees have the opportunity to

provide input in regards to company policy and rules. 5.0 RECORDS:

5.1 The Vessel Operations Manager or his/her designate should keep Employee Safety and Health Committee Meeting Attendance Rosters on file for at least 5 years.

5.2 The Vessel Operations Manager or his/her designate should keep

Employee Safety and Health Committee Meeting Agendas on file for at least 5 years.

5.3 The Vessel Operations Manager or his/her designate should keep

Employee Safety and Health Committee Meeting Summary Reports on file until the next Management Safety and Health Committee meeting. All unanswered questions and unaddressed issues should be moved to the next month’s Employee Safety and Health Committee Meeting Agenda.

6.0 APPENDICES:

Safety and Health Committee Meeting Attendance Roster



SAFETY AND HEALTH COMMITTEE MEETING ATTENDANCE ROSTER

Location of Meeting:

Date:

Type of Meeting:

Employees/Members Present Signature: 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. 16. 17. 18. 19. 20.

Print Legibly:

April 14, 2014

RCP-4.5-1

SAFETY POLICIES

Title:

MANAGEMENT SAFETY AND HEALTH COMMITTEE

Issue Date:



RCP-4.5

Approved By:


1 of 3

1.0 PURPOSE:

The purpose of this procedure is to explain the role of the Management Safety and Health Committee.

2.0 SCOPE:

The Management Safety and Health Committee should oversee the Employee Safety and Health Committee.

3.0 RESPONSIBILITY:

The General Manager or his/her designate should make reasonable efforts to see that the functions of the Management Safety and Health Committee are carried out.

4.0 PROCEDURE:

4.1 MANAGEMENT SAFETY AND HEALTH COMMITTEE

4.1.1 The function of the Management Safety and Health Committee is to provide oversight, guidance and support to the Upper River Services (URS) Employee Safety and Health Committee.

4.1.2 The members of this committee are the President, General

Manager, Vessel Operations Manager and other employees as designated by the members of the committee.

4.1.3 Management Safety and Health Committee meetings should be

held at least twice per year during the operating season to provide feedback to the questions, suggestions, and safety concerns of the Employee Safety and Health Committee.

RCP-4.5-2

4.1.4 The General Manager or his/her designate should make reasonable efforts to prepare an agenda for each Management Safety and Health Committee meeting. The agenda should include, but not be limited to the following subjects:

4.1.4.1 A review of the outstanding issues from the Employee

Safety and Health Committee summary reports submitted since the last Management meeting.

4.1.4.2 A review of the outstanding issues from the last Management Safety and Health Committee summary report.

4.1.4.3 A review of accidents and injuries that have occurred since the last meeting.

4.1.4.4 The development of Safety Program priorities to be communicated.

4.1.5 The General Manager or his/her designate should make

reasonable efforts to write a summary report for each of these quarterly meetings. These summaries should be reviewed by the members of the Management Safety and Health Committee.

4.1.6 A Safety Meeting Attendance Roster should be completed for each

Management Safety and Health Committee meeting (this form is located in the Employee Safety and Health Committee Procedure).

4.2 ADDITIONAL MANAGEMENT SAFETY AND HEALTH COMMITTEE

RESPONSIBILITIES

4.2.1 Management Safety and Health Committee should make reasonable efforts to develop an annual Safety Training Program. This comprehensive training program should be designed to meet both current and long-range safety needs. With input from members of the Employee Safety and Health Committee, the Management Safety and Health Committee should prepare an annual calendar of training topics and activities to be discussed or conducted for each employee.

4.2.2 The Management Safety and Health Committee should make

reasonable efforts to determine Safety Training needs from a variety of sources including the Employee Safety and Health Committee. When training needs are determined, the General Manager or his/her designate should make reasonable efforts to gather or identify the resources necessary to develop training plans and outlines for each subject to be presented.

RCP-4.5-3

4.2.3 The Annual Training Calendar should be distributed to the Employee Safety and Health Committee each year before the operating season begins.

4.2.4 General Manager or his/her designate should make reasonable

efforts to implement the Annual Training Calendar. 5.0 RECORDS:

5.1 The General Manager or his/her designate should keep Management Safety and Health Committee meeting summary reports on file until the next Management Safety and Health Committee meeting. All unanswered questions and unaddressed issues should be moved to the next month’s Employee meeting agenda.

5.2 The General Manager or his/her designate should keep the Safety

Meeting Attendance Roster on file for at least 5 years. 5.3 The General Manager or his/her designate should keep the Safety

Meeting Agendas on file for at least 5 years. 6.0 REVISION HISTORY:


RCP-4.6-1

SAFETY POLICIES

Title:

PERSONAL

PROTECTIVE

EQUIPMENT POLICY

Issue Date:

April 14, 2014

Last Revised:

February 20, 2015

Procedure Number:



Page:

1 of 6

1.0 PURPOSE: To provide a written policy, so that employees can be aware of the proper personal protective equipment (PPE) requirements.

2.0 SCOPE:

This procedure is applicable to all Upper River Services (URS) vessel personnel and vessels.

3.0 RESPONSIBILITY: 3.1 The Vessel Operations Manager is responsible for approving the selection

of PPE and providing training to vessel crews. He/She must also review any changes in the equipment supplied to URS employees.

3.2 The Vessel Operations Manager should make reasonable efforts to

distribute and replace the required company sponsored PPE to URS employees.

3.3 The Vessel Operator should make reasonable efforts to see that each

crewmember is effectively and correctly using the required PPE for the task being completed.

3.4 All URS crewmembers are personally responsible and will be held

accountable for wearing the approved PPE at the appropriate times. Taking the necessary steps to procure and wear protective equipment during prescribed work activities is a company safety requirement.

RCP-4.6-2

4.0 PROCEDURE: 4.1 Personal protective equipment (PPE) is a barrier between the employee

and workplace hazards. While PPE can make our work place hotter and more uncomfortable, the results of not taking precautions in the workplace can be tragic. A serious laceration, loss of eyesight, chemical overexposure, hearing loss, or even drowning may result from not wearing personal protective equipment.

4.2 Vessel crewmembers must wear the appropriate gear and keep it readily

available. Personal protective equipment must be considered a part of our daily operation for every employee, from new trainees to Vessel Operators.

4.3 Because PPE has a wide variety of uses depending on the material and

style, changes in the equipment supplied to URS employees must be reviewed by the Vessel Operations Manager.

4.4 All PPE should be cleaned, inspected, and stored after each use. 4.5 Company-supplied personal protective equipment will be replaced by the

company when it becomes substandard due to normal wear-and-tear. Damage to company-issued PPE should be reported to the Vessel Operator. Lost or intentionally damaged PPE requiring replacement will be charged to the employee.

4.6 Eye Protection

4.6.1 Safety glasses or safety goggles must be worn when eye impact hazards exist. Acceptable safety glasses are American National Standards Institute (ANSI)-approved impact-resistant eye wear with side shields. Acceptable safety goggles are ANSI-approved chemical splash-resistant eye wear with splash-resistant covers over the ventilation openings. Work situations that require eye protection include, but are not limited to, the following:

4.6.1.1 Chipping, scaling, grinding, hammering, or

brush/roller painting; 4.6.1.2 Cutting, repairing, or installing wire rope; 4.6.1.3 Bleeding off air pressure; and, 4.6.1.4 Changing out spotlight bulbs or fluorescent tube

lights.

RCP-4.6-3

4.6.2 Safety goggles must be worn when splash hazards exist or when an impact hazard exists with an employee wearing prescription non-safety glasses. Work situations that require safety goggles include, but are not limited to, the following:

4.6.2.1 Spray painting; 4.6.2.2 Removing blank flanges, plugs, or caps from lines or

hoses when residual pressure exists; 4.6.2.3 Disconnecting hydraulic hoses or fuel hoses, where

residual pressure may exist.

4.7 Foot Protection

4.7.1 Approved safety-toed leather work boots must be worn by trainees and deckhands when performing work duties.

4.7.2 Approved safety-toe foot protection must be worn by the Vessel

Operator. 4.8 Hand Protection

4.8.1 Synthetic rubber gloves must be worn where hand contact with cargoes or chemicals is possible. Examples of situations where synthetic rubber gloves must be worn include, but are not limited to, the following:

4.8.1.1 Cleaning with paint thinner or degreasers; 4.8.1.2 Changing oil or fuel filters; and, 4.8.1.3 Working on the vessel’s marine sanitation device.

4.8.2 Leather gloves or other approved gloves should be worn when

hands may come into contact with surfaces that can cut or penetrate the skin.

4.9 Clothing

4.9.1 Long pants and shirts must be worn at all times when working for URS.

4.10 Head Protection

4.10.1 Hard hats must be worn when there is a potential for head injury due to impact or penetration from overhead objects. Work situations in which hard hats are required include, but are not limited to, the following:

RCP-4.6-4

4.10.1.1 Walking near, working near, or with, an operating crane; and,

4.10.1.2 Walking in a designated hard hat area. 4.11 Respiratory Protection

4.11.1 Equipment - For your everyday use, the company provides dust masks. These masks can be used for respiratory protection against low level dusts and mists. These respirators are light weight and easy to speak and breathe through. They can be worn any time you are working in a dusty or misty environment, or at the request of an employee.

4.11.2 Although it is not likely, should you encounter heavy concentrations

of dust or mists, notify your supervisor immediately. If crewmembers experience situations where the level of contaminants exceeds the capability of the dust masks provided, all activities should cease, until the levels of contaminants subside. If it becomes necessary to work in a heavily contaminated environment, notify the office, so office personnel can supply additional equipment. In the event that you should have any questions concerning the environment you will be working in, ask your supervisor.

4.11.3 Dust masks must only be used where there is sufficient oxygen for

breathing. 4.11.3.1 Dust masks must not be used in atmospheres where

concentrations of contaminants exceed the capability of the mask to filter out the contaminants. Read the information printed on the package. If you do not understand the information, ask your supervisor to explain.

4.12 Hearing Protection

4.12.1 Hearing protection is required whenever sound levels require raising your voice to be heard. Situations in which ear muffs and/or ear plugs (ANSI-approved over and in-the-ear protection) must be worn include, but are not limited to, the following:

4.12.1.1 In the boat engine room when the main engines

and/or generator are operating; 4.12.1.2 When using a deck scaler, needle gun, or portable

grinder; and,

RCP-4.6-5

4.12.1.3 All areas posted “Hearing Protection Required.” 4.13 Drowning Protection – Personal Floatation Devices

4.13.1 Working life vests (Type 5, Coast Guard-approved with reflective material on all floatation cells) are required to be worn, but are not limited to, the following:

4.13.1.1 Anytime a person is working for or with URS, and the

individual is outside of the cabin of a vessel; 4.13.1.2 While using ladders, pilings, or fender works to gain

access to or from a barge; and, 4.13.1.3 In emergency response team boats.

4.13.2 There are only a few exceptions to URS life vest rule:

4.13.2.1 Individuals authorized to enter cargo or void tanks

need not wear a life vest when in the tanks; 4.13.2.2 When the vessel is faced up to the wharf barge or

Ohio.

4.13.3 Life jackets (Type 1) must be kept available for emergency situations. If an employee must enter the water because of an emergency, a Type 1 personal floatation device must be donned, time permitting. If circumstances do not allow the use of Type 1 PFD, carry a life jacket, working life vest, ring buoy, or any other available floatation device when you must enter the water.

4.13.4 Life jackets, work vests, and personal flotation devices (PFDs)

must be worn snug to the body with reflective tape on all cells, and fastened or zippered completely.

4.13.5 URS employees are not permitted to enter the water during the

performance of normal work duties. If an emergency occurs and an employee enters the water to save a life, he/she must carry some type of floatation device.

4.14 Fall Arrest Protection

4.14.1 Personal fall arrest protection is required when any crewmember is performing any work activity or assignment, while aboard towing vessels, from a height greater than six (6) feet above lower levels and outside of the hand rails. Each crewmember will be trained in the proper usage, inspection and maintenance of the fall arrest protection equipment.

RCP-4.6-6

4.14.2 Each body harness should be attached to a suitable attachment point.

4.14.3 Approved full body harnesses with approved lanyards and

hardware are required to be worn in, but not limited to, the following situations:

4.14.3.1 On top of the wheelhouse or when working outside

the guardrails. 4.14.3.2 Any time a person is exposed and has the potential to

fall from a height of more than six (6) feet while working in the machinery spaces.

4.14.3.3 When working six (6) or more feet above lower levels without benefit of regulation scaffolding, or when working on platforms without regulation guardrail/toeboard systems at the same heights.

4.14.3.4 In addition to the previously mentioned situations, a harness should be worn any time that harnesses may appear necessary by reason of hazards encountered in a manner capable of causing injury or impairment due to a fall.


0 Initial issue April 14, 2014 1 First revision – Revised paragraph 4.14.1 February 20, 2015

RCP-4.7-1

SAFETY POLICIES

Title:

ORIENTATION

POLICY

Issue Date:

April 14, 2014

Last Revised:

February 20, 2015

Procedure Number:



Page:

1 of 3

1.0 PURPOSE: To help new employees understand their responsibilities, and the company rules and requirements.

2.0 SCOPE:

All new employees, including experienced employees, should receive a safety orientation as prescribed by this procedure.

3.0 RESPONSIBILITY: The Vessel Operations Manager or his/her designate should make reasonable efforts to see that new employees (including experienced personnel) have undergone an orientation. The Online Orientation should be conducted during the first week of their employment. The Fleet/Vessel portion of the orientation should be conducted the first day the new hire boards the vessel.

4.0 PROCEDURE: 4.1 New URS employees should receive a Safety Orientation. After

completing the orientation process, each employee should review and understand the contents of this RCP Manual. The RCP Manual is available on the online Employee Portal.

4.1.1 Each new employee should be subject to a training period, during

which the employee will be placed with an experienced employee who should provide instruction and answer questions regarding safe methods to perform the new employee’s duties. Upon completion of the training period, the new employee should be evaluated to determine his/her knowledge of the job to which they have been assigned, as well as his/her understanding of the safety rules, safe procedures for performing the job, and to assess their job performance to date.

RCP-4.7-2

4.2 Fleet or Vessel Employees

4.2.1 New employees should be enrolled in the company’s Online Orientation as part of the employment process. New employees being assigned to their first job with the company and existing employees being assigned to a new job should receive an orientation to that new job position. This orientation should be conducted by the appropriate supervisor, along with the experienced employee who will help train the employee in the requirements of the new job. The Online Orientation covers the following topics, but not limited to:

4.2.1.1 Drug and Alcohol Policy; 4.2.1.2 Safety Program and Policy; 4.2.1.3 Safety as a Condition of Employment; 4.2.1.4 Safety Equipment and Personal Protective

Equipment; 4.2.1.5 Injury Prevention Including Back Training; 4.2.1.6 Slip, Trip and Fall Prevention; 4.2.1.7 Job Responsibilities / Responsibility and Authority of

Position; 4.2.1.8 Confined Space Hazard Awareness; 4.2.1.9 Fall Overboard Prevention; and, 4.2.1.10 Emergency Response Procedures:

• Fire; • Collision and allision; • Sinking; • Grounding; • Man Overboard; and, • Personal Injury and illness

4.3 Members of the Fleet Safety and Health Committees, or their designate,

should make reasonable efforts to give each newly assigned employee, whether experienced or inexperienced, a Safety Orientation on the new employee’s assignment to the work area.

4.4 Upon successful completion of the company’s Online Orientation, a

Certificate of Completion and Score Report should be printed. The Fleet/Vessel Orientation Checklist, located at the end of this procedure, should be completed during the vessel orientation. It is to be signed by the new employee and the supervisor who gives the orientation.

RCP-4.7-3

4.5 When the checklist has been completed, it should be sent to the office. The original should be placed in the employee’s folder along with the Certificate of Completion and Score Report from the Online Orientation.

5.0 RECORDS:

The completed Fleet/Vessel Orientation Checklist, Certificate of Completion and Score Report should be kept in the employee’s personnel file for their length of employment plus three years.

6.0 APPENDICES:

Fleet/Vessel Orientation Checklist


0 Initial issue April 14, 2014 1 First revision – Revised paragraph 4.1 February 20, 2015

FLEET/VESSEL ORIENTATION

Safety Orientation must be completed for newly hired deck crew within 24 hours

of boarding vessel (46CFR27.209).

The following are some areas you should be briefed on during a vessel tour:

Vessel Orientation including Deck

Operations

Line Tying/Handling

Face Wire Safety

Terminology

Hand Signals

Radio Etiquette

Crew Change Locations

Barge Orientation

Barge Rigging

Supplies Used for Work

Reporting Procedures

Alarm Sounds

Show How to Activate the

General Alarm

Inoperative Alarm Reporting

Work Hours

Location of First Aid Equipment

Location of Ring Buoys

Cover Emergency Response

Procedures

Station Bill

Cover Fire Fighting Equipment

and Emergency Equipment

Emergency Fuel Shut-off

Procedures and Operate

the Fuel Shutoff for the

Engine Room

Fire Extinguisher

Locations

Fire Pump Location and

Operation

Conduct Fire Drill

Cover Falls Overboard Procedure

Employee Signature: Supervisor Conducting Vessel Tour: Date:

(A copy of this page should be filed in the new employee’s personnel folder)

February 20, 2015

RCP-4.8-1

SAFETY POLICIES

Title:

TRAINING POLICY Issue Date:





Page:

1 of 2 1.0 PURPOSE:

This policy identifies the minimum training to be provided to all new and experienced vessel employees.

2.0 SCOPE:

This procedure is applicable to all Upper River Services (URS) vessel personnel.

3.0 RESPONSIBILITY: The Vessel Operations Manager or his/her designate is responsible for establishing minimum training requirements, maintaining the Training Matrix (attached) and making a reasonable effort to see that the training is conducted.

4.0 PROCEDURE: 4.1 URS believes that personnel training programs influence behavior in a

positive way. To that end the company has established an effective orientation and training program for vessel crewmembers.

4.2 The following elements comprise the URS training philosophy:

4.2.1 Training must be justified by hazards analysis, and/or legal requirements, and must be approved by management.

4.2.2 If initial training is deemed to be justified, a refresher training

schedule must also be identified. 4.2.3 Learning objectives must be defined and communicated to training

participants by competent instructors. 4.2.4 Post-training evaluation must be conducted to measure the

effectiveness of the training. 4.2.5 Management will review the training conducted and determine its

effectiveness for future programs

RCP-4.8-2

4.3 The Vessel Operations Manager must work with the General Manager to determine minimum training requirements for vessel employees. The Vessel Operations Manager must document completed training for the employee’s personnel file.

4.4 The Vessel Operations Manager must make a reasonable effort to see

that employees are trained according to the minimum requirements laid out in the Training Matrix.

5.0 APPENDICES:

5.1 Vessel Operator Training Matrix 5.2 Deckhand Training Matrix



UPPER RIVER SERVICES RESPONSIBLE CARRIER PROGRAM - TRAINING MATRIX

VESSEL OPERATOR

INITIALLY (Within 1st year of employment)

20X1 &

20X6

20X2 &

20X7

20X3 &

20X8

20X4 &

20X9

20X5 &

20X0 New hire orientation (Upon Hire) YES

Vessel orientation (Upon Hire) YES

Responsibility & authority of operator (Upon Hire) YES YES

Supervisory skills training YES YES

Radar training (REQUIRED BY USCG FOR LICENSE RENEWAL)

Navigation/boat handling training/or proficiency evaluation

YES YES YES YES YES YES

Rules of the road refresher training YES YES YES YES YES YES

USCG required - “supervisor” - drug and alcohol training YES YES YES YES YES YES

Company policy and procedure orientation YES YES

Federal requirements and company conformance YES YES

Marine firefighting / fire prevention YES YES YES YES YES YES

CPR Awareness YES YES YES YES YES YES

First Aid Awareness YES YES YES YES YES YES

Confined space hazard awareness YES YES YES YES YES YES

Injury prevention, including back training YES YES YES YES YES YES

First responder/spill mitigation YES YES YES YES YES YES

Benzene awareness training YES YES YES YES YES YES

Cargo knowledge/hazard awareness YES YES YES YES YES YES

Injury prevention, including slips, trips, and falls YES YES YES YES YES YES

Fall overboard prevention YES YES YES YES YES YES

For additional training topics: See annual training calendar for training provided to all employees April 14, 2014

UPPER RIVER SERVICES RESPONSIBLE CARRIER PROGRAM - TRAINING MATRIX

DECKHAND (Includes both experienced and inexperienced)

INITIALLY (Within 1st year of employment)

20X1 &

20X6

20X2 &

20X7

20X3 &

20X8

20X4 &

20X9

20X5 &

20X0 New hire orientation (Includes both experienced and inexperienced) (Upon Hire)

YES

Vessel / Facility orientation (Upon Hire) YES

Responsibilities of a deckhand (Upon Hire) YES YES

Deck operations and safety training YES YES

Company policy and procedure orientation YES YES

Federal requirements and company conformance YES YES

Vessel firefighting / fire prevention YES YES YES YES YES YES

CPR Awareness YES YES YES YES YES YES

First Aid Awareness YES YES YES YES YES YES

Confined space hazard awareness YES YES YES YES YES YES

Injury prevention, including back training YES YES YES YES YES YES

Lock-out / Tag-out YES YES YES YES YES YES

First Responder/Spill Mitigation YES YES YES YES YES YES

Injury prevention, including slips, trips, and falls YES YES YES YES YES YES

Fall Overboard Prevention YES YES YES YES YES YES

For additional training topics: See annual training calendar for training provided to all employees April 14, 2014

RCP-4.9-1

SAFETY POLICIES

Title:

SAFETY TRAINING

Issue Date:

April 14, 2014

Last Revised:

March 13, 2015

Procedure Number:



Page:

1 of 2

1.0 PURPOSE: 1.1 The purpose of Upper River Services (URS) safety training is to

accomplish several important missions:

1.1.1 One of the goals of URS safety training is to motivate crewmembers to observe company safety practices and policies.

1.1.2 Safety training calls a stop to unsafe practices. 1.1.3 Finally, safety training demonstrates URS’ commitment to safety.

Each employee must realize that we are not trying to promote safety on an intermittent basis. Rather, we are committed to safety as a way of operating. Crewmembers should understand that their safety comes before anything else. There is no exception to this policy.

2.0 SCOPE:

This procedure is applicable to all URS vessel personnel.

3.0 RESPONSIBILITY: 3.1 The Vessel Operations Manager, or designate, is responsible for making

crewmembers aware of this policy and how to access online safety training.

3.2 Each crewmember is responsible for completing online safety training

topics as scheduled.

RCP-4.9-2

4.0 PROCEDURE: 4.1 The Vessel Operations Manager with assistance from the Employee

Safety Committee should prepare an Annual Safety Training Calendar. This calendar lists the topics to be covered during Vessel Safety Meetings, and the safety training topics to be completed online in each trimester.

4.2 Online Safety Training:

4.2.1 Except for that training completed during the annual spring meetings, all regularly scheduled safety training topics should be completed online via the URS learning management system.

4.2.2 Crewmembers should complete all online training topics required

for the trimester before the trimester ends.

4.2.2.1 For each trimester, crewmembers can earn 10% of their annual bonus for completing the required training before the end of the trimester (e.g., if a crewmember is late in completing the required training for each trimester, this could result in the crewmember not earning 30% of their annual bonus).

4.2.2.2 If any training is incomplete from a previous trimester, the training must be completed during the current trimester to earn the annual bonus for the current trimester.

4.2.2.3 Trimesters are as follows:

First trimester: Opening of season to May 31

Second trimester: June 1 to August 31

Third trimester: September 1 to end of season


0 Initial issue April 14, 2014 1 First revision – Removed paragraph 1.1.1 and renumbered, revised Procedure Title, paragraphs 1.1, 1.1.1 through 1.1.4, 3.1, 3.2, and section 4.0 March 1, 2015 2 Second revision – Revised paragraphs 4.2.2.1 and 4.2.2.2 March 13, 2015

RCP-4.10-1

SAFETY POLICIES

Title:

SAFETY DRILLS

Issue Date:

April 14, 2014

Last Revised:

February 20, 2015

Procedure Number:



Page:

1 of 3

1.0 PURPOSE: The purpose of a drill is to protect yourself and your fellow employees and to protect other individuals from inclusion in the problem. Drills help us to protect the environment, to protect company and customer equipment, and, finally, to prepare for the worst and still remain in control.

2.0 SCOPE:

This procedure is applicable to all Upper River Services (URS) vessel employees.

3.0 RESPONSIBILITY: 3.1 The Vessel Operator is responsible for conducting and supervising all

drills. He is also responsible for assigning responsibilities for each crewmember on board and ensuring that each crewmember’s role is explained thoroughly to him or her before any drills are held.

3.2 The Vessel Operator is responsible for completing at least one (1) Fire

Drill monthly in addition to any other scheduled drills. 3.3 All URS crewmembers on board at the time of a drill are required to

participate.

4.0 PROCEDURE: 4.1 A drill is a process of physical and mental training by simulating an

emergency situation. It is an art to control one’s emotions when an emergency prevails. Drills help crewmembers react to emergencies in an organized and automatic fashion in accordance with company procedures and emergency response plans.

RCP-4.10-2

4.2 Drills should be conducted during the watch with no advance notice given, after the crew is made aware of their responsibilities for each situation which may be the subject of a drill. The timing of drills should be selected carefully. For example, a good time to hold a drill might be when the crew is awaiting orders, when the vessel is awaiting dock space, when the vessel is underway in light boat condition or when the vessel is secured in a fleet. Drills should not be held when the vessel is docking, locking, fueling, making its way under a bridge or underway with a tow.

4.3 All drills must be conducted as if an actual emergency exists, but safely.

No one is to generate any smoke, enter the water, or place an employee in danger at any time.

4.4 In addition to the required monthly Fire Drill and Training, the Vessel

Operator and the crew must train and drill on the following scenarios at least once per year:

4.4.1 Collision/Allision Drill 4.4.2 Grounding Drill 4.4.3 Sinking Drill 4.4.4 Fall Overboard Drill 4.4.5 Oil or Hazardous Substance Drill 4.4.6 Operator Incapacitation Drill

4.5 First Aid/CPR and personal injury will be discussed and included in these

drills. 4.6 The drill action plan should proceed as follows:

4.6.1 The Vessel Operations Manager prepares the drill scenario and writes it down.

4.6.2 The Vessel Operator sounds the appropriate signals on the vessel

horn and general alarm system. 4.6.3 The Vessel Operator announces over the vessel P.A. system to all

stations: “This is a drill! This is a drill!”. Then, the Vessel Operator states the specific drill scenario, such as, “Collision, collision! all hands to the wheelhouse”; or “Fire in the engine room!”.

RCP-4.10-3

4.6.4 The Vessel Operator directs crewmembers to carry out URS operating procedure or response plan for the selected scenario.

4.6.5 The Vessel Operator notes any actions or procedures that need

correcting for post-drill critique. 4.6.6 Crewmembers secure the vessel after the drill and properly stow

away any equipment used.

5.0 APPENDICES:

5.1 Collision/Allision Drill Form 5.2 Fall Overboard Drill Form 5.3 Grounding Drill Form 5.4 Sinking Drill Form 5.5 Oil or Hazardous Substance Spill Drill Form 5.6 Operator Incapacitation Drill Form 5.7 Fire Drill/Training Form


0 Initial issue April 14, 2014 1 First Revision – Revised paragraphs 3.2, 4.4, 4.5 and 5.1, added paragraphs 4.4.1 through 4.4.6, removed paragraph 5.5 and renumbered as appropriate February 20, 2015

Collision/Allision Drill Form

M/V: Pilot:

Crew Members: Date:

Time (Begin Drill) : Time (Finish Drill):

Activity

Yes No (Check One)

Can general alarm be heard at all locations? Are there any injuries? If so explain the nature of the injury and the

necessary treatment below.

Was First Aid/CPR included in this drill? Does P.A. system work properly at all locations, if applicable? Are walkie-talkies available? All equipment functions properly? Other: If No, explain the defect:

Onboard correction made?

Yes No

Requires shore based assistance to make correction? Yes No

Evaluate Employee Performance: Excellent Good Fair Poor

Suggestions/ Comments:

April 14, 2014

Fall Overboard Drill Form

M/V: Pilot:

Crew Members: Date:


Activity Yes No (Check One)

Can general alarm be heard at all locations? Was First Aid/CPR included in this drill? Does P.A. system work properly at all locations, if applicable? Are life rings and lights in good repair and ready for use? Are there any injuries? If so explain below. All equipment functions properly? Other: If No, explain the defect:


Yes No




Return to: Upper River Services Dispatch Office Received by:

April 14, 2014

Grounding Drill Form

M/V: Pilot:

Crew Members: Date:


Activity

Yes No (Check One)

Can general alarm be heard at all locations? Are there any injuries? Is so explain below. Was First Aid/CPR included in this drill? Does P.A. system work properly at all locations, if applicable? Crew instructed on the proper use of safety equipment? All equipment functions properly? Other: If No, explain the defect:


Yes No





April 14, 2014

Sinking Drill Form

M/V: Pilot:

Crew Members: Date:


Activity

Yes No (Check One)

Can general alarm be heard at all locations? Are there any injuries? If so explain below. Was First Aid/CPR included in this drill? Does P.A. system work properly at all locations, if applicable? Are walkie-talkies available? All equipment functions properly? Other: If No, explain the defect:


Yes No





April 14, 2014

Oil or Hazardous Substance Spill Drill Form

M/V: Pilot:

Crew Members: Date:


Activity

Explain drill and deckhand duties. Shutdown, contain and notify (i.e.

shut down fuel transfer, contain spill, and notify pilot and appropriate

parties).

Yes No (Check One)

Can general alarm be heard at all locations? Are there any injuries? If so explain below. Does P.A. system work properly at all locations, if applicable? Crew instructed on the proper use of safety equipment? All equipment functions properly? Other: If No, explain the defect:

Onboard correction made? Yes No





April 14, 2014

Operator Incapacitation Drill Form

M/V: Pilot:

Crew Members: Date:


Activity Yes No (Check One)

Can general alarm be heard at all locations? Does P.A. system work properly at all locations, if applicable? Did the crewmember demonstrate to the operator the appropriate

steps to reduce power and maintain steerage?

Was First Aid/CPR included in this drill? Did the crewmember(s) demonstrate knowledge of radio operation? Are the crew member(s) knowledgeable in First Aid /CPR? Other: If No, explain what training could be provided in the future:

Was this a useful drill? Yes No




April 14, 2014

Fire Drill/Training Form

M/V: Pilot Signature:

Crew Signatures:

Date:


Yes No (Check One)

Can general alarm be heard at all locations? Are there any injuries? Was any first aid necessary? If so explain

below.

Does P.A. system work properly at all locations, if applicable? Did you charge and test the fire pump? Are fire extinguishers charged and ready for use? All equipment functions properly? If No, explain the defect: Test (Inspect) fire detection equipment (Heat sensors & smoke alarms) Provide instruction on emergency fuel shut-off operations. Onboard correction made? Yes No





April 14, 2014

RCP-4.11-1

SAFETY POLICIES

Title:

SAFE USE OF EQUIPMENT

Issue Date:





1 of 5 1.0 PURPOSE:

The following procedure is intended to see that deck machinery and equipment is safely and appropriately used.

2.0 SCOPE:


3.0 RESPONSIBILITY:

3.1 Vessel Operators should make reasonable efforts to see that this

procedure is followed. 3.2 Employees are directly responsible for the following work practices

outlined in this procedure. The individual is always responsible for his or her immediate actions, or inaction, and therefore is the only person who can guarantee his or her own safety.

4.0 PROCEDURE:

4.1 Employees are cautioned to use proper lifting and carrying procedures

when working with rigging or other heavy objects. 4.2 Handling of facewires

4.2.1 Ensure that facewires are free of obstructions. 4.2.2 Ensure that an adequate amount of slack is in the facewire to

perform the job without difficulty. 4.2.3 Walk the facewire towards the fitting using both hands and

ensuring footing is adequate to perform the job.

RCP-4.11-2

4.2.4 The Vessel Operator may assist the deckhand by maneuvering the vessel, which provides less resistance on the facewire, creating slack for ease of movement.

4.2.5 Remove the facewire from the button installed on the tow knee of

the vessel. 4.2.6 When placing facewires on fittings, make sure that your hands

and fingers are not in the bight of the wire. 4.2.7 Repeat the above steps when handling opposite facewires. 4.2.8 After facewires are in proper placement on the barge, the Vessel

Operator should tighten the facewires using the deck winches aboard the vessel.

4.2.9 Electric or electric over hydraulic winches may be operated from

the wheelhouse of the vessel by the Vessel Operator. 4.2.10 Always wear gloves when working with rigging.

4.3 Handling of barge rigging

4.3.1 Ensure that each pelican hook is fastened to its keeper before carrying it onto the barge or boat.

4.3.2 Ensure that the rigging wires are rolled up in a tight coil so that no

loose ends are available to cause tripping hazards. 4.3.3 Lift rigging by using your legs, not your back. 4.3.4 Carry rigging on your outboard shoulder. 4.3.5 When handing rigging from one person to another, make sure

that the receiving person has proper footing and that rigging is handed over in a safe manner. Do not toss, throw, or drop rigging to another person.

4.3.6 When required, wear gloves when working with rigging.

4.4 Safe use of ratchets

4.4.1 When carrying ratchets, always carry them on your outside shoulder so you can drop the ratchet and grab the barge if you slip or fall.

RCP-4.11-3

4.4.2 When using a ratchet to jerk slack from a wire, make sure you keep your feet widely spaced and keep your balance so you will not fall if you encounter sudden slack.

4.4.3 Never tighten ratchets outboard. Always tighten them inboard so

if you get sudden slack in the wire or if the “dog” slips and catches you off balance, you will fall on the barge deck and not in the river. If for some reason, you encounter a ratchet which is part of the stationary rigging on a barge, which must be tightened outboard, use special care and pay close attention to make sure you don’t fall overboard.

4.4.4 When tightening ratchets, keep fingers in the clear on a

downward stroke or when tightening toward a barge coaming to ensure your fingers are not mashed if sudden slack is encountered or if the “dog” slips.

4.4.5 Use caution when inserting or removing toothpicks due to high

tension on the wires and ratchets. Always keep toothpicks angled slightly toward the center of the ratchet to ensure they are not dislodged and thrown as the wire untwists.

4.4.6 Always remove your toothpicks when you have finished tightening

the wire. 4.4.7 When required, wear gloves when working with rigging.

4.5 Safe use of deck fittings

4.5.1 Do not use any deck fitting that is damaged or that has cracked welds. Report damaged deck fittings to the Vessel Operator immediately.

4.5.2 Always place lines or wires on deck fittings properly and in the

manner the fittings were designed for. 4.6 Safe use of winches

4.6.1 When tightening a winch, plant your feet firmly so you will not slip and fall if unexpected slack occurs.

4.6.2 NEVER use your feet to tighten a winch. 4.6.3 Do not reach through the wheel or over the crank to engage or

disengage the “dog”.

RCP-4.11-4

4.6.4 Keep hands and clothing clear of the gears and “dog” when using the winch.

4.6.5 Always wear gloves when working with winches.

4.7 Safe use of abrasive grinders (bench type and portable)

4.7.1 Machinery with rotating abrasive disks can be used only when all equipment guards and components are in place and properly adjusted and functioning.

4.7.2 The safety guard covering the spindle end, nut and flange

projections must be mounted to maintain proper alignment with the wheel.

4.7.3 Before mounting of the abrasive wheel on a bench type grinder, a

visual inspection and a “ring” test must be conducted to ensure the wheel is not damaged.

4.7.4 Safety glasses with top and side protection must be used by

personnel operating the equipment. Face shields and installed equipment shields are not sufficient by themselves.

4.7.5 Work rests should be adjusted to permit a maximum opening of

1/8”. 4.7.6 The tongue guard shall be adjusted as the wheel decreases in

diameter to expose only the necessary area of the wheel and to ensure a maximum ¼ inch tongue opening.

4.8 Safe use of portable electric/air hand tools

4.8.1 Portable electric hand tools

4.8.1.1 Ensure that electrical wire and connections are in good operating condition and have no loose or unshielded wires. If any damage is found, follow the Lockout/Tagout Procedure located in this manual.

4.8.1.2 Ensure that electrical tools with locking trigger mechanisms are left in the open position before electrical power is connected.

4.8.1.3 Do not lock trigger mechanisms. 4.8.1.4 Do not operate electrical tools in wet weather or in

conditions that may lead to contact with water. 4.8.1.5 Don all appropriate PPE before use.

RCP-4.11-5

4.8.2 Portable air hand tools

4.8.2.1 Inspect air tools to ensure that they are in proper working order.

4.8.2.2 Ensure air hoses are made of sufficient material and are in sufficiently good physical condition to withstand the operating pressure needed to operate the tool.

4.8.2.3 Use air supply through an airline equipped with a regulator set for the maximum pressure for which the tool was designed. Never leave an air hand tool unattended at a work site while under pressure.

4.8.2.4 Turn the air off before disconnecting the hose. Bleed off any remaining pressure in the line through the tool. Never disconnect air hoses while under pressure.

4.8.2.5 Ensure all guards are in place and in good working order.

4.9 Safe use of deckline (headline) operation

4.9.1 As a minimum, use a two-part 2-inch Poly line in good condition. 4.9.2 Unless otherwise directed by the Vessel Operator, allow enough

slack in the line to allow the boat to lay flat against the barge when working the headline to move a barge at fleets, docks, etc.

4.9.3 Use caution when working headlines. For example:

4.9.3.1 Do not stand directly behind the line or in an area

where the line could recoil and strike personnel if the line parts.

4.9.3.2 Do not stand in the bite of the line or allow the line to wrap around your feet or legs.

4.9.3.3 Keep a firm footing and watch for line “jerks” when the line tightens.

4.9.3.4 Watch for the “bump” when the boat and barge make contact.

4.9.3.5 Do not stand on top of the towknee to catch the headline while the boat is moving.



RCP-4.12-1

SAFETY POLICIES

Title:

CARGO KNOWLEDGE Issue Date:





Page:

1 of 3 1.0 PURPOSE:

The following procedure is intended to see that deck machinery and equipment is safely and appropriately used.

2.0 SCOPE:


3.0 RESPONSIBILITY:

3.1 The Vessel Operations Manager is responsible for circulating customer

Safety Data Sheets (SDS) documentation to the fleet. 3.2 The Vessel Operations Manager is responsible for working with customers

to obtain SDS documentation when not provided by the dock. 3.3 The Dispatchers are responsible for notifying the Vessel Operator of the

cargo the vessel will have in tow.

4.0 PROCEDURE: 4.1 SDS’s are located in the wheel house of each vessel. The SDS or

Chemical Data Card contains, at a minimum:

4.1.1 The name and address of the manufacturer; 4.1.2 An emergency telephone number; 4.1.3 Cargo name that matches the cargo being transferred; 4.1.4 Cargo hazard information; 4.1.5 Special personal protective equipment requirements;

RCP-4.12-2

4.1.6 Spill or leak information; and, 4.1.7 Fire fighting information.

4.2 Liquid cargoes:

4.2.1 Personnel going aboard the barge should routinely verify the cargo information and hazards previously communicated to personnel responsible for the barge. Discrepancies should be promptly brought to the attention of the Vessel Operations Manager and Vessel Operator.

4.3 Dry cargo barges:

4.3.1 The Vessel Operations Manager should make reasonable efforts to obtain current information about the potential hazards associated with dry cargoes which URS vessels are expected to tow.

4.3.2 The Vessel Operations Manager should communicate this cargo

information to the Dispatchers who will then pass it along to the Vessel Operator that may be handling that barge.

4.3.3 The Vessel Operator should communicate these potential health

hazards to the crewmembers working around or with the cargo prior to picking up the barge(s). The Vessel Operator should make reasonable efforts to see that the required controls and personal protective equipment are being used by employees.

4.4 Fumigation of cargo and other hazards:

4.4.1 Covered dry cargo barges at times display various placards indicating that a particular cargo or other hazardous material may be contained within the barge.

4.4.2 If, at any time, you are to add a barge to your tow that displays a

placard indicating a hazardous cargo, prior to placing this barge in your tow, you are instructed to contact the Duty Dispatcher or a customer representative for instructions. This applies – NO MATTER WHAT THE TIME OF DAY OR NIGHT!

RCP-4.12-3

4.4.3 One particular and common hazard you may encounter will be placards that indicate the cargo in a particular barge is being fumigated. The placard will read something like the following:

DANGER FUMIGATION HAZARDOUS GASES

If you encounter this type of placard, special attention is required. Notify the Duty Dispatcher immediately and follow their instructions.

4.5 Hazardous dry cargo list:

The following cargoes may have hazardous characteristics. This list is not all inclusive, as other cargoes may also be hazardous. If in doubt, check SDS sheets, read placards that may be posted on these barges, or contact the Duty Dispatcher for more information. Entry into confined spaces of barges containing these cargoes is not allowed.

ALUMINUM DROSS FISH METAL ALUMINUM NITRATE HOT BRICKETTED IRON (HBI) AMMONIUM NITRATE FERTILIZER HOT PETROLEUM COKE BARIUM NITRATE LEAD NITRATE COLD BRICKETTED IRON (CBI) MAGNESIUM NITRATE DIRECT REDUCED IRON (DRI) POTASSIUM NITRATE FERRO PHOSPHORUS SILICON MANGANESE FERRO MANGANESE SODIUM NITRATE

FERROUS METAL BORINGS STRONTIUM NITRATE SHAVINGS, TURNINGS OR SULFUR

CUTTINGS ZINC CONCENTRATE FERRO SILICON ZINC SULFATE



RCP-4.13-1

SAFETY POLICIES

Title:

HAZARD COMMUNICATION PROCEDURES

Issue Date:





Page:

1 of 3 1.0 PURPOSE:

The purpose of the Upper River Services (URS) Hazard Communication Procedures is to alert employees to the presence of hazardous chemicals in the workplace and to show how to work safely with these chemicals. It is company policy that each individual understand emergency procedures and safety precautions associated with hazardous substances utilized on all vessels or facilities either owned or operated by URS.

2.0 SCOPE:

This applies to all URS vessel employees. 3.0 RESPONSIBILITY:

3.1 The Vessel Operations Manager or their designate should make

reasonable efforts to train employees in hazard communication procedures and to develop, implement, and maintain a hazard communication training program.

3.2 The Vessel Operations Manager or their designate should make

reasonable efforts to see that new information regarding product reclassification, new safety data sheets, or new hazards posed by hazardous substances used in the workplace, stemming from the Globally Harmonized System (GHS) are incorporated into this program, and the information is communicated to employees.

3.3 The Vessel Operations Manager or their designate should also make

reasonable efforts to see that new employees receive an initial orientation which includes training on the HAZCOM Program prior to starting work.

3.4 The Vessel Operations Manager or their designate should make a

reasonable effort to see that appropriate training records are maintained.

RCP-4.13-2

4.0 PROCEDURE: 4.1 Major elements of this program include:

4.1.1 A comprehensive list of the hazardous chemicals found in the

workplace;

4.1.2 Readily available Safety Data Sheets (SDS) in a designated location(s);

4.1.3 Assurance that containers of hazardous substances are

appropriately labeled, tagged, or marked; 4.1.4 Training on the Hazard Communication Procedures, in using and

comprehending SDS labeling, and the requirements of the OSHA Hazard Communication Standard; and,

4.1.5 A system to inform employees, customers, subcontractors, or

visitors of hazardous chemicals to which they may be exposed and suggest protective measures.

4.1.6 It is the policy of URS to obtain and review the SDS prior to using

any substance deemed to be hazardous. As new SDS that comply with GHS become available, they will be incorporated into this program and replace those currently on hand. All hazardous materials that are the property of URS, must have an updated SDS on file no later than June 1, 2016.

4.1.7 Supervisory personnel must review the information on the SDS to

ensure safe handling and ascertain that all individuals working with the substance are informed of potential hazards, emergency procedures, and required protective measures. This includes reviewing potential changes in how substances currently used in the workplace, but listed as non-hazardous, may be listed as hazardous substances as a result of changes under GHS.

5.0 TRAINING:

5.1 Employees should be instructed in the following topics:

5.1.1 Requirements of the OSHA/GHS Standard;

5.1.2 Operations in the workplace where hazardous substances are present;

RCP-4.13-3

5.1.3 How to read and understand labeling and SDS format to include those currently in use and those mandated by GHS;

5.1.4 Locations of SDS, the written URS Hazard Communication

Procedures, and the list of hazardous chemicals found in the workplace;

5.1.5 Methods to detect the presence or release of a hazardous

substance in the workplace;

5.1.6 Physical and health hazards of identified hazardous substances in the workplace;

5.1.7 Personal protective equipment requirements for handling

hazardous substances; and,

5.1.8 The company Hazard Communication Procedures contents.

5.2 The Vessel Operations Manager or their designate should make reasonable efforts to provide new employees with information and training on hazardous chemicals in the employee’s work area at the time of initial assignment. Training should also be provided when a new chemical is introduced into the work area, and refresher training should be provided on a yearly basis. Employees must be trained with respect to any new hazards or reclassified products as a result of GHS implementation no later than June 1, 2016. The Vessel Operations Manager or their designate should maintain training rosters of personnel having received training.

6.0 RECORDS:

Training records should be kept on file for at least 5 years. 7.0 REVISION HISTORY:


RCP-4.14-1

SAFETY POLICIES

Title:

FALL OVERBOARD PREVENTION

Issue Date:





Page:

1 of 4 1.0 PURPOSE:

1.1 The purpose of Upper River Services (URS) fall overboard prevention

program is to alert employees to the hazards associated with working in close proximity to the water’s edge and to prevent falls overboard.

1.2 The majority of towing vessel crew fatalities are the result of falls

overboard. By following these procedures vessel crewmembers can reduce the risks to themselves and their fellow crewmembers.

2.0 SCOPE:

This applies to all vessels either owned or operated by URS. 3.0 RESPONSIBILITY:

3.1 The Vessel Operations Manager is responsible for training employees in

fall overboard prevention procedures and for developing, implementing, and maintaining a fall overboard prevention training program and for maintaining training records.

3.2 The Vessel Operations Manager is responsible for providing new

employees with information and training on fall overboard prevention at the time of initial assignment.

3.3 The Vessel Operator should make reasonable efforts to ensure that the

practices described in this procedure are implemented. 3.4 The employee is directly responsible for following the work practices

outlined in this procedure. The individual is always directly responsible for his or her immediate actions, or inaction, and is therefore the only person who can guarantee his or her own safety.

RCP-4.14-2

4.0 PROCEDURE: 4.1 All falls overboard, whether or not they result in injury or death, must be

reported using the Vessel Accident/ncident Report. 4.2 Employees must be instructed in the following topics:

4.2.1 Procedures to be followed before going on the tow:

4.2.1.1 Always receive authorization from the wheelhouse before going out on board the tow;

4.2.1.2 Discuss known hazards such as notches, duck ponds, walking conditions and current weather conditions with the off-going watch;

4.2.1.3 Don proper Personal Protective Equipment (PPE) including:

• Properly fastened work vest • Flashlight during hours of limited visibility; and, • Any other company-required PPE.

4.2.1.4 Use the “Buddy System” at all times. Maintain visual and/or verbal contact when outside the vessel. In some circumstances, your buddy could be someone in the wheelhouse.

4.2.2 Procedures to be followed while on the tow:

4.2.2.1 Do not walk on the outside of the tow unless it is

absolutely necessary; 4.2.2.2 Do not walk or step between the forward corner deck

fittings and the end of barges; 4.2.2.3 Always carry loads outboard when walking along the

edge of boats and barges; 4.2.2.4 When on deck, always walk with one hand free; 4.2.2.5 Do not step over open water when landing or facing

up to a tow ; 4.2.2.6 Do not work or stand with your back to the water; 4.2.2.7 Always position portable ratchets so they may be

tightened inboard; 4.2.2.8 When using stationary rigging that must be tightened

outboard use extreme caution; 4.2.2.9 Keep both feet on deck when tightening rigging;

RCP-4.14-3

4.2.2.10 Stay aware of bump hazards and communicate them to your buddy and the rest of the crew;

4.2.2.11 Stay aware of and communicate locations of notches, duck ponds, or any other like hazards; and,

4.2.2.12 Illuminate all shadows before walking through them.

4.2.3 Procedures to be followed when returning from the deck or the tow:

4.2.3.1 Inform the wheelhouse that you have returned from the tow and your current location on the boat; and,

4.2.3.2 Record all unusual conditions or hazards so they may be communicated to the oncoming watch.

4.2.4 General rules and safe work practices for URS vessels;

4.2.4.1 Where practical decks and walkways will be treated

with non-skid paint; 4.2.4.2 Make sure all deck fitting tops and deck edges are

painted white or some other high visibility contrasting color for better nighttime visibility;

4.2.4.3 Inspect handrails regularly and replace when defective;

4.2.4.4 Make sure all guard chains are hooked, except when persons are boarding or departing the vessel;

4.2.4.5 Salt icy walkways; 4.2.4.6 Replace rigging, face wires, and stationary wires

when worn, or if they have kinks or twists; and, 4.2.4.7 Report, and if possible, clean up any spilled and/or

loose cargo immediately, remember: nothing should go in the river.

4.2.5 General rules and safe work practices for barges;

4.2.5.1 Contact the wheelhouse prior to going on deck, and

at night, ensure that the guard (deck) lights are turned on;

4.2.5.2 Keep all work areas clean and clutter-free; reduce trip hazards when possible;

4.2.5.3 Report, and if possible, clean up any spilled and/or loose cargo immediately, remember: nothing should go in the river; and,

4.2.5.4 When in locks or landings, make sure the tow is stopped before climbing lock walls or ladders while carrying gear, use a handy line to lift gear.

RCP-4.14-4



RCP-4.15-1

SAFETY POLICIES

Title:

BLOODBORNE PATHOGENS

Issue Date:




Management Health and Safety Committee

Page:

1 of 3 1.0 PURPOSE:

Recognizing that the potential exists for contracting bloodborne diseases as a result of coming in contact with blood or other body fluids, the pupose of the Bloodborne Pathogens Program is to provide guidance and safety to employees who may be exposed to another’s bodily fluids while aboard Upper River Services (URS) vessels.

2.0 SCOPE:


3.1 The Vessel Operations Manager is responsible for implementing the

Bloodborne Pathogens Program onboard all vessels. 3.2 The Vessel Operations Manager is responsible for providing annual

training and reporting all exposure incidents to the General Manager immediately following a known exposure.

3.3 Vessel personnel should make reasonable efforts to follow this procedure.

4.0 PROCEDURE: 4.1 Universal precautions (as explained in training) shall be used to prevent

contact with blood and other potentially infectious materials. All blood or other potentially infectious materials shall be considered infectious regardless of the perceived status of the source individual.

4.2 Protective gloves are readily available in all first aid kits and/or bloodborne

pathogen kits.

RCP-4.15-2

4.3 Each vessel must have one Bloodborne Pathogen Kit (biohazard kit) and should be accessible within 10-15 minutes. The kit generally consists of a disposable apron, germicidal wipes, disposable mouth/nose cover, safety goggles, antimicrobial wipes, gloves, sealable scoop bag, biohazard bag, identification sticker, and step-by-step instructions. The kit is to be kept in the galley of each vessel so that it will be common knowledge among crewmembers of its location.

4.4 Always take precautionary measures when providing first aid or

assistance in such cases where there is exposure to another’s bodily fluids. Dispose of all contaminates and sharp objects properly, as explained in training.

4.5 Waste shall be placed in containers that are closeable, constructed to

contain all contents, and will prevent leakage of fluids during handling, storage, transportation or shipping. All waste containers shall be labeled or color-coded and closed prior to removal to prevent spillage or protrusion of contents during handling, storage, transport or shipping. Containers shall be made available within the major first aid supplies.

4.6 Barrier tape should be available for the purpose of roping off an area

before and during cleanup following an incident. The yellow rolls of caution tape or yellow handy line will be sufficient to use for this situation.

4.7 In an effort to minimize contact with blood or bodily fluids, rescuing

employees should let the injured employee help himself/herself if he/she is able. For instance, if an employee is bleeding and pressure needs to be applied to a wound, an employee giving aid could get a clean cloth and provide it to the injured employee to apply pressure to his/her own wound if they are conscious and able.

4.8 Contact with blood or other bodily fluids does not necessarily mean that

an individual has been exposed. An exposure incident is defined as a specific eye, mouth, other mucous membrane, non-intact skin, or contact with blood or other potentially infectious material that results from the performance of an employee’s duties.

4.9 If it has been determined that an exposure incident has definitely

occurred, the exposed employee should complete an exposure report and he/she will be offered a medical examination and HBV vaccination.

RCP-4.15-3

4.10 When it is uncertain whether or not an actual exposure incident has occurred, all contact with blood or other human body fluids should be considered as a possible exposure. In this case, the Vessel Operations Manager will inform the “exposed” employee that he/she has the option of a consultation with a physician whom is qualified to make the exposure determination and recommend whether or not the HBV vaccination is necessary.

4.11 The “exposed” employee will have the opportunity to have a physician

consultation to determine if an exposure has taken place. If the employee declines this consultation, he/she should sign a Declination Form, which will be kept on file.

4.12 An Incident Statement from Employee is available for the purpose of

reporting suspected or actual exposures. This report contains the information needed by the physician, and covers what is required to be kept on file. It should be the “exposed” employee's responsibility to complete this form. This responsibility should be conveyed to all employees during training.



RCP-4.16-1

SAFETY POLICIES

Title:

HEARING CONSERVATION PROGRAM

Issue Date:




Management Health and Safety Committee

Page:

1 of 6 1.0 PURPOSE:

The principal objective of the Hearing Conservation Program is to protect Upper River Services (URS) employees against noise in the work environment which by its intensity and/or duration constitutes a hazard to hearing.

2.0 SCOPE:

This applies to all crewmembers onboard vessels either owned or operated by URS.

3.0 RESPONSIBILITY:

3.1 The Vessel Operations Manager is responsible for managing the Hearing

Conservation Program onboard all vessels. 3.2 The Port Engineer is responsible for reducing high noise level operations,

wherever possible. 3.3 The Vessel Operations Manager should make reasonable efforts to

provide suitable hearing protection devices when employees are exposed to sound levels above the action level of 85 dBA.


provide annual training. 3.5 The Vessel Operator should make reasonable efforts to see that

employees are wearing hearing protection when appropriate or required. 3.6 Employees are responsible for using hearing protection in areas where

exposure can exceed applicable exposure limits.

RCP-4.16-2

4.0 PROCEDURE: 4.1 The Hearing Conservation Program is implemented and controlled by the

Vessel Operations Manager and it involves the coordinated application of noise hazard evaluations, engineering control measures, the use of hearing protective devices, audiometric testing, and recordkeeping, supplemented by training, and enforcement.

4.2 Effective engineering noise control is the most desirable hearing

conservation measure since it can eliminate the hazard and render other elements of the program unnecessary. Whenever feasible, engineering control methods must be used to reduce excessive noise levels to the maximum extent possible. Engineering noise control is generally deemed feasible if implementation is technologically and operationally practical and cost effective. New equipment is purchased or designed with consideration for noise emission levels. Engineering control measures must be a consideration in the design of new vessels where there is potential for hazardous noise.

4.3 When engineering controls are not feasible, administrative controls (i.e.,

rotation of employees) must be implemented whenever possible. Such controls must be designed to reduce the noise exposure to the employee below the action level.

4.4 When available, copies of Occupational Noise Exposure will be made

available upon request to affected employees. 4.5 Areas that have been determined to exceed acceptable noise levels must

be posted with the wording “EAR PROTECTION REQUIRED.” 4.6 Noise hazard evaluation (noise monitoring)

4.6.1 Implementation of the Hearing Conservation Program requires that noise surveys be conducted by the Vessel Operations Manager in order to identify areas, equipment, or operations containing noise exposure hazards. The Safety Manager must identify noise hazardous areas/operations and notify affected supervisors.

4.6.2 Noise exposures must be computed in accordance with

applicable health and safety standards and regulations without regard to any attenuation provided by the use of personal protective equipment.

RCP-4.16-3

4.6.3 An initial determination must be made to ascertain whether noise exposure may equal or exceed an 8-hour of 85 decibels (dB) measured on the A scale. This determination is based on all information, observations, or calculations which indicate that employee noise exposure may be at or above that level.

4.6.4 The initial determination process must be repeated for any

change in production, processes, equipment, controls, or personnel which may result new noise exposures at or above of 85 decibels (dB).

4.6.5 Employees must be notified of the results of exposure monitoring

and be allowed to observe, if requested. 4.6.6 An accurate record of all noise exposure measurements must be

retained on file. 4.7 Audiometric Testing Program

4.7.1 The first audiometric test will be performed by qualified personnel during the new hire physical.

4.7.2 A baseline audiogram must be performed within 6 months of an

employee's first exposure at or above an 8-hour of 85 dB. 4.7.3 An annual audiogram must be conducted within one year of the

baseline for each employee exposed at or above an action level of 85 dBA in order to identify changes in hearing acuity so that protective follow up measures can be initiated.

4.7.4 Each employee's annual audiogram must be compared to that

employee's baseline audiogram to determine if the audiogram is valid and if a standard threshold shift (STS) has occurred.

4.7.5 An audiologist, otolaryngologist, or physician reviews the

audiogram to determine whether there is a need for further evaluation.

4.7.6 If a comparison of the annual audiogram to the baseline

audiogram indicates a standard threshold shift (STS), and it is determined to be work related, the following steps will be taken:

4.7.6.1 Employees not using hearing protectors must be fitted

with hearing protectors, trained in their use and care, and required to use them.

RCP-4.16-4

4.7.6.2 Employees already using hearing protectors must be refitted and retrained in the use of hearing protectors offering greater attenuation, if necessary.

4.7.6.3 The employee must receive written notification that an STS exists. This notification is provided within 21 days following the determination of an STS.

4.7.6.4 The employee is referred for a clinical audiological evaluation or an otological examination, as appropriate, if additional testing is necessary or if the professional responsible for the audiometric program suspects that a medical pathology of the ear is caused or aggravated by the wearing of hearing protectors.

4.7.6.5 Employees must be notified of the need for an otological examination if a medical pathology of the ear, which is unrelated to the use of hearing protectors, is suspected.

4.7.7 Audiometric tests must be pure tone, air conduction, hearing

threshold examinations, with test frequencies including as a minimum 500, 1000, 2000, 3000, 4000, 6000, and 8000 Hz. Tests at each frequency must be taken separately for each ear.

4.7.8 Audiometric test records must be retained indefinitely.

4.8 Hearing protection

4.8.1 Hearing protective devices consisting of ear plugs or earmuffs, or a combination of these items must be made available and must be worn by employees who:

4.8.1.1 Are exposed to an 8-hour of 85 dB or greater. 4.8.1.2 Have not yet had a baseline audiogram in a noise

environment. 4.8.1.3 Have experienced a standard threshold shift (STS).

4.8.2 Hearing protection must be worn by all employees working in

posted areas or performing operations which require it. 4.8.3 Hearing protection must be worn by all employees whose

audiometric tests show a significant threshold shift. 4.8.4 The General Manager should ensure that required audiometric

testing is performed on an annual basis for all affected employees.

RCP-4.16-5

4.8.5 Hearing protection devices must be made available at all locations.

4.8.6 Employees requiring hearing protectors must:

4.8.6.1 Have a variety of selections of suitable types. 4.8.6.2 Be trained in their use and care. 4.8.6.3 Be properly fitted initially.

4.8.7 Hearing protector attenuation must be evaluated for the specific

noise environment in which it will be used.

4.8.7.1 The protectors must attenuate employee exposure at least to an 8-hour of 90 dB.

4.8.7.2 For employees who have experienced an STS, hearing protectors must attenuate employee exposure to an 8-hour, time weighted average of 85 dBA or below.

4.8.7.3 The adequacy of hearing protector attenuation must be reevaluated whenever employee noise exposures increase to the extent that the protectors may no longer provide adequate attenuation.

4.8.8 No one ear protector should be considered best for all employees

under every condition of work and a selection of ear protectors should be made available depending on attenuation properties, comfort, fit, and applicability.

4.8.9 It is important that the employee be properly informed of the need

and requirements for wearing ear protectors and supervisors must ensure that a follow up is made to ensure that employees are wearing the devices properly and to correct any faulty practices that might be evident or provide another type of protector if necessary.

4.8.10 Ear protectors should be washed with a mild soap and water on a

daily basis. Dirty ear protectors may cause the ear to become sore or inflamed. Ear plugs that are properly cared for remain effective six months or more. Whenever they become stiff and uncomfortable, they should be discarded.

RCP-4.16-6

4.9 Definitions

4.9.1 Action Level: An 8-hour, time weighted average of 85 decibels measured on the A scale, slow response, or an equivalent dose of 50 percent.

4.9.2 Audiogram: A graph or table obtained from an audiometric test

showing an individual's hearing threshold levels as a function of frequency.

4.9.3 Audiologist: A professional specializing in the study and

rehabilitation of hearing, who is certified by the American Speech, Language, and Hearing Association or licensed by a state board of examiners.

4.9.4 Baseline Audiogram: The audiogram against which future

audiograms are compared. 4.9.5 Decibel (dB): Unit of measurement of sound level. 4.9.6 Decibels, A Weighted (dBA): A unit of measurement of sound

level corrected to the A weighted scale as defined in ANSI SI. ~1971 (R 1976).

4.9.7 Dual Hearing Protection: A TWA8 dBA, or equivalently, a dose of

800% of that permitted by Part 62 standard, integrating all sound levels from 90 dBA to at least 140 dBA.

4.9.8 Excessive Noise: Noise that equals or exceeds the current

Occupational Health and Safety Administration (OSHA) standards and is considered hazardous.

4.9.9 Hearing Level: The deviation in decibels of an individual's

threshold from the zero reference of the audiometer. 4.9.10 Otolaryngologist: A physician specializing in diagnosis and

treatment of disorders of the ear, nose, and throat. 4.9.11 Sound Level Meter: An instrument for the measurement of sound

level. 4.9.12 STS: Standard threshold shift.

RCP-4.16-7

4.9.13 Time Weighted Average (TWA): An average, over a given period of a person's exposure, as determined by sampling at given times during the period.



RCP-4.17-1

SAFETY POLICIES

Title:

BENZENE HANDLING Issue Date:





Page:

1 of 1 1.0 PURPOSE:

To inform employees of the Upper River Services (URS) Benzene Handling Policy.

2.0 SCOPE:

This applies to all crewmembers on board URS owned or operated vessels. 3.0 RESPONSIBILITY:

The Vessel Operations Manager should make reasonable efforts to see that this policy is followed.

4.0 PROCEDURE: URS does not handle Benzene.



RCP-5.1-1

COMPANY ENVIRONMENTAL POLICIES

Title:

COMPANY ENVIRONMENTAL POLICY

Issue Date:





Page:

1 of 2 1.0 PURPOSE:

Upper River Services (URS) is committed to the environmental integrity of this nation’s natural resources. We must all work together to positively ensure that nothing our associates do in the day to day operations of our vessels results in a pollution incident.

2.0 SCOPE:


The Vessel Operations Manager should make reasonable efforts to see that employees are aware of the requirements of this procedure.

4.0 PROCEDURE: 4.1 URS recognizes the importance of efficiently meeting the waterborne

transportation needs of the United States in an environmentally sound manner while protecting the health and safety of our employees and the public. The management and employees are committed to continuously improving the compatibility of our operations with the environment. We must all work together to positively ensure that nothing our associates do in the day to day operations of our vessels results in a pollution incident.

As such, the company including all employees, agree to do the following:

4.1.1 Conduct our business and operate our vessels in a manner that

protects the environment and the safety and health of our employees and the general public.

4.1.2 Recognize and be responsive to public concerns about waterborne

transportation and its effects on the environment. 4.1.3 Make safety, health, and the environment priorities in our business

planning.

RCP-5.1-2

4.1.4 Work in partnership with manufacturers, shippers, and vendors to enhance safe transportation of products and the management of associated cargo residues and cleaning wastes.

4.1.5 Commit to reduce overall emissions and waste generation, and

comply with all laws and regulations concerning emissions and waste.

4.1.6 Participate with government and the public in creating responsible

laws and regulations and standards to safeguard the workplace, community, and environment.

4.1.7 Establish and maintain, in cooperation with public authorities and

others, contingency procedures and plans to mitigate the effects of accidents which may occur.

4.2 Environmental compliance guidelines:

4.2.1 It is the policy of URS to comply with applicable Federal, State, and Local pollution laws and regulations. The laws and regulations prohibit the placement of any pollutant including trash (includes leaving line or lock line scraps), garbage, discarded food, oil, bilge slop, waste oil, containment bilge water, or untreated sanitation into the waterways.

4.2.2 Nothing is to be discharged from or thrown overboard from a URS

vessel except gray water. Pumping of bilge oil, water, or other vessel waste at any time or place, except at approved locations using methods set forth below is strictly prohibited and constitutes a violation of this policy.

4.2.3 Violations of any of the prohibitions listed above could subject the

employee to disciplinary action including discharge, and may subject both the employee and the company to criminal prosecution and/or civil penalties.



RCP-5.2-1

COMPANY ENVIRONMENTAL

POLICIES

Title:

GARBAGE DISPOSAL

Issue Date:

April 14, 2014

Last Revised:

February 20, 2015

Procedure Number:



Page:

1 of 2

1.0 PURPOSE: The purpose of this procedure is to describe the work processes to be followed in handling waste such as garbage, trash and absorbents aboard all Upper River Services (URS) vessels. By following these procedures, we will provide quality service to our customers, a safe work place for our employees, and protection of the environment.

2.0 SCOPE:


3.0 RESPONSIBILITY: 3.1 The Vessel Operations Manager should make reasonable efforts to

implement this procedure and to see that vessel personnel are aware of the requirements outlined in this procedure.

3.2 The Vessel Operator should make reasonable efforts to see that the

practices described in this procedure are practiced on the job. 3.3 All Vessel personnel should comply with this procedure.

4.0 PROCEDURE: 4.1 Annex V of the International Convention on Prevention of Pollution from

Ships – Marine Pollution (MARPOL) lays down strict rules relating to the disposal of garbage. These requirements are summarized on the placards posted on each vessel.

4.2 Consistent with the requirements of MARPOL, all URS employees must

observe the following procedures:

4.2.1 The disposal of any type of plastic into the navigable waters is strictly prohibited. All plastic materials, including such items as synthetic fiber ropes and plastic trash bags, must be disposed of in an approved manner. Never throw any plastic material overboard.

RCP-5.2-2

4.2.2 Individual crewmembers must not throw anything overboard, no matter where the vessel is located. All waste must be placed in the disposal containers provided. It will then be treated in accordance with the regulations.

4.2.3 All vessels must record the approximate quantities of disposed

garbage removed from the vessel on the Master’s Daily Log. 4.2.4 Each vessel must display a sufficient number of MARPOL placards

to be readily accessible by the vessel crew.

4.2.4.1 Each placard must be at least 8 inches wide by 5 inches high, made of durable material, and legible.

4.2.4.2 Each placard must contain, at a minimum:

Notify the reader of the operating requirements contained in 33CFR151.67 through 33CFR151.73 as they apply.

Discharge of all garbage is prohibited in the navigable waters of the United States and in all other waters except as specifically allowed.

Discharge of all forms of plastic or garbage mixed with plastic in all waters is prohibited.

Regional, state and local restrictions on garbage discharge may also apply.

A person who violates the above requirement is liable for civil and/or criminal penalties.


0 Initial issue April 14, 2014 1 First revision – Revised paragraph 4.2.3 February 20, 2015

RCP-5.3-1


Title:

HANDLING OF WASTE OIL, GREASE, BILGE SLOPS, USED FILTERS AND OILY RAGS

Issue Date:





Page:

1 of 3

1.0 PURPOSE:

The purpose of this procedure is to describe the work processes to be followed in handling bilge slops, waste oil, oily rags, and used oil filters. By following the procedures below, we will provide quality service to our customers, a safe work place for our employees, and help to protect our environment.

2.0 SCOPE:



implement this procedure and ensure that vessel personnel are aware of the requirements outlined in this procedure.

3.2 The Vessel Operator should make reasonable efforts to see that the

practices described in this procedure are followed. 3.3 The crewmembers should follow this procedure.

4.0 PROCEDURE: 4.1 Bilge slops

4.1.1 When handling bilge oil, do not pump or pour bilges that contain oil or oily mixtures overboard. Retain oily mixtures in the boat’s bilge; bilges will be stripped out at either the State Street Wharf Barge or the Pigs Eye Fueling Station.

4.1.2 Only pump used oil directly from the engine into the boat slop tank

or drums.

RCP-5.3-2

4.1.3 Pump or deliver used oil only into a reception facility on shore. Each URS boat of 100 gross tons and above has at least one fixed or portable pump to discharge bilge oil through adequate piping to a reception facility on shore.

4.1.4 Only a qualified person shall be responsible for the transfer of oil

from or to the boat to ensure a pollution-free operation. Only a person instructed by the Vessel Operator in his or her duties and in applicable Federal Water Pollution Control Act requirements may serve as a qualified person.

4.1.5 When pumping bilges ashore, observe the following procedures:

4.1.5.1 Ensure that the transfer system has the acceptable

shore connection; 4.1.5.2 Align transfer system properly; 4.1.5.3 Ensure connections are secure and contained; 4.1.5.4 Remain on site when the transfer is in progress; and, 4.1.5.5 Stop transfer operations in the event of a spill.

4.1.6 A placard stating the following must be placed in the engine room

of each URS vessel:

DISCHARGE OF OIL PROHIBITED The Federal Water Pollution Control Act prohibits the discharge of oil or oily waste into or upon the navigable waters of the United States, or the waters of the contiguous zone, or which may affect natural resources belonging to, appertaining to, or under the exclusive management authority of the United States, if such discharge causes a film or discoloration of the surface of the water or causes a sludge or emulsion beneath the surface of the water. Violators are subject to substantial civil penalties and/or criminal sanctions including fines and imprisonment.

4.2 Used filters and oily rags

4.2.1 Discard used oil filters and fuel filters only after they have been drained aboard the vessel of any residual product.

4.2.2 Dispose of used lube oil filters and fuel filters in recycling drums

provided at company operating facilities. Do not dispose of used filters by mixing with trash.

RCP-5.3-3

4.2.3 Oily rags will be disposed of in the proper disposal containers and not mixed in with trash.

4.3 Waste oil

4.3.1 No waste oil may be placed in the water, on shore, in a trash dumpster, or in any receptacle that is not provided specifically for oily waste. URS specifically prohibits the placement of waste oil in open containers, in barge wing tanks, in drip pans, or any area that is not designed for specifically for the collection of waste oil.

4.3.2 Oily waste, including rags, bilge residue, old engine parts, oily

wood, etc., must be disposed of as if it is waste oil. Oily waste must be transferred to a facility that is equipped to handle the product and knowingly accepts the responsibility for safely and lawfully disposing of the waste material.



RCP-5.4-1


Title:

HAZARDOUS WASTE DISPOSAL/HANDLING

Issue Date:





Page:

1 of 2 1.0 PURPOSE:

The purpose of this procedure is to describe the work processes to be followed in handling and disposing of hazardous waste. By following the procedures below, we will provide quality service to our customers, a safe work place for our employees and help to protect our environment.

2.0 SCOPE:


3.0 RESPONSIBILITY:


implement this procedure and ensure that the vessel personnel are aware of the requirements outlined in this procedure.

3.2 The Vessel Operator should make reasonable efforts to see that this

procedure is followed. 3.3 The crewmembers should follow this procedure.

4.0 PROCEDURE: 4.1 All hazardous waste materials, such as old paint, solvents, degreasers,

lithium batteries, etc. must be stored in a sealed and approved container clearly marked with its contents. DO NOT dump hazardous material into the slop tank or other unauthorized container.

4.2 All hazardous waste material must be disposed of in accordance with

applicable federal and state regulations.

RCP-5.4-2

4.3 All medical hazardous waste must be disposed of in appropriate containers clearly marked with the contents and disposed of properly. Medical hazardous waste disposal bags are in the Body Fluid Cleanup Kits located in the Galley of each boat. Medical waste will be disposed of at Twin Cities Occupational and Health office.

4.4 Wear appropriate personal protective equipment when handling

hazardous waste.



RCP-5.5-1


Title:

SANITARY SYSTEMS/HANDLING OF SEWAGE

Issue Date:





Page:

1 of 2 1.0 PURPOSE:

The purpose of this procedure is to describe the maintenance and environmental procedures for marine sanitation devices located aboard Upper River Services (URS) vessels. By following these procedures, we will safeguard our crews, equipment and the environment.

2.0 SCOPE:



implement this procedure and ensure that vessel personnel are aware of the requirements outlined in this procedure.

3.2 The Vessel Operator should make reasonable efforts to ensure that the

practices described in this procedure are implemented.

4.0 PROCEDURE: 4.1 Human waste must be disposed of through the sewage tank on each URS

boat. 4.2 No one may alter the flow of waste water or divert the flow of waste from

the sewage tank. If a sewage tank becomes inoperative, it must be reported to the Vessel Operations Manager and repaired immediately.

4.3 Sewage tanks are pumped at URS facilities either by:

4.3.1 An approved sanitation truck that will pump the tank, or

RCP-5.5-2

4.3.2 Pumping the tank into a shore side tank, that is then drained into the sanitary sewer system.



RCP-6.1-1

EMERGENCY RESPONSE PROCEDURES

Title:

PERSONAL INJURY OR ILLNESS

Issue Date:





Page:

1 of 3 1.0 PURPOSE:

This procedure describes what to do in case of a personal injury or illness aboard an Upper River Services (URS) vessel. Following this procedure will enable vessel personnel to provide assistance to the injured or ill crewmember.

2.0 SCOPE:



implement this emergency plan, provide training and make crewmembers aware of the requirements outlined in this procedure.

3.2 The Vessel Operator is responsible for evaluating the degree of

emergency and taking the action deemed appropriate as defined in this guideline.

3.3 The crewmembers should make reasonable efforts to follow this

procedure.

4.0 PROCEDURE: 4.1 In the event of an emergency personal injury or illness, the person in

charge must take action including, but not limited to:

4.1.1 Determine the injured or ill person’s need for emergency care. 4.1.2 Call 911, if appropriate. 4.1.3 If qualified, administer first aid to the injured or ill person.

RCP-6.1-2

4.1.4 If there is no need for additional medical assistance:

4.1.4.1 Notify URS Dispatcher of injury or illness; 4.1.4.2 Fill out U.S. Coast Guard Form CG-2692, if required

and notify the U.S. Coast Guard; and, 4.1.4.3 Fill out the Vessel Accident/Incident Report and

complete the Declination of Medical Treatment, if necessary.

4.2 The remainder of this procedure applies to injuries and illness requiring

more than onboard emergency first aid.

4.2.1 Call the URS Dispatcher; and let them know this is an Emergency call.

4.2.2 Give appropriate information, including, at a minimum, the

condition of the person and the location of the vessel. 4.2.3 Give the estimated time of arrival at the nearest location where

emergency help can meet the vessel, and either:

4.2.3.1 Proceed to that location and if possible, send a crewmember out to the main road to flag down emergency personnel; or,

4.2.3.2 Obtain assistance to evacuate the person via emergency air or water transportation.

4.2.4 Continue first aid until emergency help arrives. 4.2.5 If possible, obtain information from the person regarding history

of the accident or illness. 4.2.6 Ensure that the person has identification and personal belongings

before leaving the vessel. 4.2.7 Fill out the Vessel Accident/Incident Report. 4.2.8 Fill out U.S. Coast Guard Form CG-2692 if requested by the U.S.

Coast Guard. 4.2.9 Call the Dispatcher for further instructions. 4.2.10 Complete any Drug or Alcohol testing as required for the crew

and injured crewmember.

RCP-6.1-3

4.3 Report significant “near miss” personal injury incidents to the Vessel Operations Manager. This includes any falls overboard.



RCP-6.2-1


Title:

OIL OR HAZARDOUS SUBSTANCE SPILL

Issue Date:





Page:

1 of 6 1.0 PURPOSE:

This procedure for response to a spill of a petroleum or petrochemical product (“product”) provides a uniform and consistent plan of action to be taken aboard Upper River Services (URS) vessels. By following this procedure, URS intends to provide a plan that will ensure the safety of the crew, URS equipment, and the operating environment by lowering the risk of operating error.

2.0 SCOPE:



implement this emergency plan and make vessel personnel aware of the requirements outlined in this procedure.

3.2 The Vessel Operator is responsible for evaluating the spill and ensuring

that appropriate action is taken and for following the practices described in this procedure.

3.3 The Vessel Operator is responsible for notifying the Duty Dispatcher @

651-292-9293. If the Duty Dispatcher cannot be reached within thirty minutes, a call should be made to the Vessel Operations Manager.

3.4 The Vessel Operations Manager is responsible for, but not limited to, the

following:

3.4.1 Notifying the National Response Center @ 1-800-424-8802 or 202-267-2672 as required by applicable law and regulation;

3.4.2 Recording the NRC case number and all pertinent information and

notifying the U.S. Coast Guard; 3.4.3 Initiating control procedures to minimize risk to vessel

crewmembers, URS equipment, and the environment;

RCP-6.2-2

3.4.4 Assign an employee as On-Scene Coordinator. 3.4.5 Determining spill containment, cleanup, and removal action

necessary; 3.4.6 Coordinating and disseminating information to the media; and, 3.4.7 Handling the legal obligations and responsibilities of the company

in the event of a spill. 3.5 An On-Scene Coordinator, who will be assigned at the time of an incident,

will be responsible for coordinating decisions regarding various aspects of a spill, including, but not limited to, the following:

3.5.1 Designating employees to be included in the Emergency Response

Team (ERT); 3.5.2 Directing the ERT, vessel crewmembers, other URS employees,

and contractors on the following:

3.5.2.1 Methods of controlling the flow of product; 3.5.2.2 Spill clean-up methods; and, 3.5.2.3 Methods for disposing of waste material.

4.0 PROCEDURE:

4.1 Poor weather conditions, high winds, and strong currents will dictate the

safety and effectiveness of boom deployment. Contact the URS dispatcher if these conditions exist:

4.2 Do not enter void compartments. 4.3 Do not enter fuel tanks. 4.4 Spill on the deck during a transfer

4.4.1 Shut down the transfer, using the emergency shutdown procedure agreed to during the pre-transfer conference.

4.4.2 Stop and contain the flow of product, provided that available

personal protective equipment is adequate to ensure personal safety.

4.4.3 Put on appropriate chemical protective clothing.

RCP-6.2-3

4.4.4 If the product does not go into the water:

4.4.4.1 Notify the Vessel Operator and obtain assistance. 4.4.4.2 Contain product on the deck using absorbent pads.

4.4.5 Contact the Dispatcher. This is an EMERGENCY call. Give

pertinent spill information. (Pertinent spill information includes, but is not limited to, the following):

4.4.5.1 Name of the person reporting the spill; 4.4.5.2 Name of the towing vessel; 4.4.5.3 Time of the spill; 4.4.5.4 Location and source of the spill; 4.4.5.5 Identity of the product spilled; 4.4.5.6 Estimate of quantity of product spilled on the deck

and/or in the water; 4.4.5.7 Existing or potential hazard (fire, explosion, etc.), if

any; 4.4.5.8 Corrective action being taken; 4.4.5.9 Weather conditions on scene; and, 4.4.5.10 Current condition of the vessel.

4.4.6 Evaluate with the Dispatcher and the Vessel Operations Manager

the risk involved in clean-up depending upon the product and the quantity spilled.

4.4.6.1 If the spill is small and personnel exposure risk is low:

• Pick up contaminated absorbent and/or spill pads

and dispose of in accordance with URS waste disposal procedures.

• Resume transfer operations when the cause of the spill has been determined and corrected.

4.4.6.2 If the spill is large or personnel exposure risk is high:

• Leave absorbent and/or spill pads until an

authorized clean-up contractor arrives on scene. • Follow the instructions given by the URS On-

Scene Coordinator. 4.5 Spill in the water during a transfer

4.5.1 Shut down the transfer, using the emergency shutdown procedure agreed to during the pre-transfer conference.

RCP-6.2-4

4.5.2 Stop the flow of product, provided that available personal protective equipment is adequate to ensure personal safety.

4.5.3 Put on appropriate chemical protective clothing. 4.5.4 Notify the Vessel Operator and obtain assistance. 4.5.5 Contact the Dispatcher. This is an EMERGENCY call. Give

pertinent spill information. Pertinent spill information includes, but is not limited to, the following:

4.5.5.1 Name of the person reporting the spill; 4.5.5.2 Name of the towing vessel; 4.5.5.3 Time of the spill; 4.5.5.4 Location and source of the spill; 4.5.5.5 Identity of the product spilled; 4.5.5.6 Estimate of quantity of product spilled on the deck

and/or in the water; 4.5.5.7 Existing or potential hazard (fire, explosion, etc.), if

any; 4.5.5.8 Corrective action being taken; 4.5.5.9 Weather conditions on scene; 4.5.5.10 Current condition of the vessel; and,. 4.5.5.11 Ensure that the U.S. Coast Guard has been notified.

4.5.6 Evaluate with the Dispatcher and the Vessel Operations Manager

the risk involved in clean-up, depending upon the product and the quantity spilled.


• Pick up contaminated absorbent and/or spill pads

and dispose of in accordance with URS waste disposal procedures.

• Leave sweep boom and plastic containment boom in place until notified otherwise.

• Resume transfer operations upon approval from the U.S. Coast Guard.




Scene Coordinator.

RCP-6.2-5

4.6 Spill on a dock during transfer

4.6.1 Shut down the transfer, using emergency shutdown procedures agreed to during the pre-transfer conference.

4.6.2 Notify the Vessel Operator. 4.6.3. Contact the Dispatcher. State this is a “PRIORITY” call. Give

pertinent spill information. 4.6.4 If the spill has entered the water, ensure that the U.S. Coast Guard

is notified.

4.6.4.1 It is the responsibility of the dock personnel to call the U.S. Coast Guard and report the spill.

4.6.4.2 However, if the dock personnel do not call the U.S. Coast Guard, the Vessel Operator must notify the Dispatcher and the Dispatcher will report the spill to the U.S. Coast Guard.

4.7 Spill in the water due to a vessel grounding or collision

4.7.1 If appropriate, don the appropriate chemical protective clothing. 4.7.2 Evaluate the condition of the vessel and the extent of the spill. 4.7.3 Contact the Dispatcher. State this is a “PRIORITY” call. Give

pertinent spill information. 4.7.4 Evaluate how to stop the flow of the product with the Vessel

Operations Manager. Measures which may be taken include, but are not limited to, the following:

4.7.4.1 Pump water from flooded void compartments; 4.7.4.2 Ground vessel in shallow water; or, 4.7.4.3 Other appropriate action as determined by

maintenance and repair personnel.

4.7.5 Evaluate with the Dispatcher and the Vessel Operations Manager the risk involved in clean-up, depending upon the product and the quantity spilled.

RCP-6.2-6


• Pick up contaminated absorbent and/or spill pads and dispose of in accordance with URS waste disposal procedures.

• Leave sweep boom in place until notified otherwise.




Scene Coordinator.

4.7.6 Follow URS procedures for response to grounding or collision. (See the Collision/Allision Response Plan located in this manual.)

4.8 Follow-up

4.8.1 Fill out the Vessel Accident/Incident Report. 4.8.2 Fill out U.S. Coast Guard Form CG-2692, if required. 4.8.3 Follow the Personal Injury or Illness procedure located in this

manual, if appropriate.



RCP-6.3-1


Title:

COLLISION/ALLISION RESPONSE PLAN

Issue Date:





Page:

1 of 4 1.0 PURPOSE:

This procedure describes what to do in the case of a collision between an Upper River Services (URS) vessel and another vessel or a structure. This procedure will minimize the potential for personal injury and for environmental and equipment damage.

2.0 SCOPE:



implement this emergency plan and make vessel personnel aware of the requirements outlined in this procedure.


emergency and ensuring that appropriate action is taken. 3.3 Crewmembers should make reasonable efforts to follow this procedure.

4.0 PROCEDURE: 4.1 In the event a collision is imminent, the Vessel Operator must take action

including, but not limited to:

4.1.1 Sound five short blasts on horn; 4.1.2 Sound general alarm; and, 4.1.3 Instruct crew to put on life jackets.

RCP-6.3-2

4.2 In the event a collision occurs, the Vessel Operator must take action including, but not limited to:

4.2.1 Attend to any injured crewmember; 4.2.2 Notify nearby marine traffic if collision is in, near, or blocking a

navigable channel; 4.2.3 Assess damage to the boat, tow, and/or structure; and, 4.2.4 Notify the Duty Dispatcher.

4.2.4.1 The Duty Dispatcher will then notify the Vessel

Operations Manager or President to determine if the U.S. Coast Guard should be notified. If the Dispatcher is unable to reach the persons, then he/she should make the determination as to whether or not the U.S. Coast Guard should be notified.

4.3 If collision is with another vessel, and the damage DOES NOT require

reporting to the U.S. Coast Guard:

4.3.1 Obtain pertinent information from the Captain in charge of the other vessel;

4.3.2 Notify the Dispatcher; 4.3.3 Document the damage, including photographs if possible; 4.3.4 Fill out the Vessel Accident/Incident Report; and, 4.3.5 Get underway.

4.4 If the collision is with another vessel, and the damage DOES require

reporting to the U.S. Coast Guard:

4.4.1 Notify the Dispatcher. 4.4.2 Verify that the U.S. Coast Guard has been notified. 4.4.3 If water is leaking in a void compartment, pump water out with

portable pump. DO NOT pump water if mixed with hazardous cargo unless the vessel is in imminent danger.

RCP-6.3-3

4.4.4 If cargo, fuel or other hazardous material is leaking from the towboat or barges, follow the Oil or Hazardous Substance Spill procedure located in this manual.

4.4.5 When pumping the void compartments, maintain the barge in

stable condition. Contact the Dispatcher for further assistance. 4.4.6 If pumping the void compartments does not or will not keep the

barge afloat, ground the barge in shallow water and contact the Dispatcher for further assistance.

4.4.7 Await advice from a U.S. Coast Guard representative on a course

of action to be taken and when to get underway. 4.4.8 Fill out the Vessel Accident/Incident Report.

4.5 If the collision is with an aid to navigation:

4.5.1 Notify the Dispatcher. 4.5.2 Verify that the U.S. Coast Guard has been notified if required. 4.5.3 Document the damage, including photographs if possible. 4.5.4 Fill out the the Vessel Accident/Incident Report. 4.5.5 Obtain permission from the U.S. Coast Guard to get underway.

4.6 If the collision is with a structure or fixed object.

4.6.1 Notify the Dispatcher. 4.6.2 Notify the appropriate person in charge (Lockmaster, Bridgetender,

Dockmaster, etc.). 4.6.3 Verify that the U.S. Coast Guard has been notified if required. 4.6.4 Document the damage, including photographs if possible. 4.6.5 Fill out the Vessel Accident/Incident Report. 4.6.6 If the U.S. Coast Guard is not notified, the Vessel Operator, the

Dispatcher, and the Vessel Operations Manager will decide a course of action and when to get underway.

RCP-6.3-4

4.6.7 If the U.S. Coast Guard is notified, they will decide a course of action to be taken and when to get underway.



RCP-6.4-1


Title:

GROUNDING RESPONSE PLAN

Issue Date:





Page:

1 of 3 1.0 PURPOSE:

This procedure provides a uniform and consistent plan of action to be taken aboard company vessels in the event of a grounding.

2.0 SCOPE:


3.0 RESPONSIBILITY:


implement this emergency plan and see that vessel personnel are aware of the requirements outlined in this procedure.


emergency and ensuring the appropriate action is taken. 3.3 The crewmembers should make reasonable efforts to follow this

procedure.

4.0 PROCEDURE: 4.1 The company expects that during emergencies, an organized effort be

made to protect personnel from further injury, as well as to minimize property damage. All of the company’s resources can be made available to respond to any emergency.

4.2 In the event of a “bump and go” grounding that meets the following

definition: “The touching of the bottom of the inland waterways by uninspected towing vessels and uninspected barges in the navigation channel without damage, pollution, personnel injuries, or unintentional breaking apart of tow, and where the tow maintains motion or is immediately able to regain motion of the tow,” the Vessel Operator or person in charge must take action, including but not limited to:

RCP-6.4-2

4.2.1 Have the crewmembers inspect the towing vessel and/or barge(s), as appropriate, to determine that the incident actually meets the above definition, and that no damage has occurred as a result of the incident.

4.2.2 Notify the Duty Dispatcher or Vessel Operations Manager and

decide who will handle required U.S. Coast Guard reporting requirements. If the grounding meets the definition of a “bump and go” grounding, a U.S. Coast Guard Form CG-2692 in NOT required, but a verbal report of grounding incidents is always required.

4.3 In the event of a grounding other than a “bump and go” grounding as

defined above, the Vessel Operator or the person in charge must take action including, but not limited to:

4.3.1 Sound general alarm if appropriate. 4.3.2 Instruct crew to put on life jackets. 4.3.3 Notify nearby marine traffic if grounding is in, near, or blocking a

navigable channel. 4.3.4 Notify the Dispatcher. 4.3.5 The Dispatcher or Vessel Operations Manager should then notify

the U.S. Coast Guard, as required in 46 CFR 4.05-10. 4.3.6 If unable to reach the Dispatcher or Vessel Operations Manager,

the Vessel Operator should notify the U.S. Coast Guard, as required by 46 CFR 4.05-10.

4.3.7 Inspect the barge or vessel for damage. 4.3.8 If fuel is leaking from the towboat, follow the Oil or Hazardous

Substance Spill procedure located in this manual. 4.3.9 If water is leaking in the void compartment, pump the water out

with a portable pump.

4.3.9.1 If pumping succeeds in floating the barge, make temporary external repairs if possible and contact the Dispatcher for further instructions. Be sure to follow the Confined Space Entry procedure located in this manual if these repairs require employees to enter a confined space.

RCP-6.4-3

4.3.9.2 If pumping does not succeed in floating the barge, call the Dispatcher for assistance.

4.3.9.3 Determine if water is leaking into cargo compartments.

4.3.9.4 If water is leaking into cargo compartments, call the Dispatcher for assistance.

4.3.10 Follow instructions from the Vessel Operations Manager or

Dispatcher for getting off ground. Such instructions may include, but are not limited to:

4.3.10.1 Wait for the water to rise. 4.3.10.2 Obtain assistance from other towing vessels, as

appropriate. 4.4 General procedures to follow in the event of a grounding include, but are

not limited to:

4.4.1 Do not enter void compartments without following the Confined Space Entry procedure located in this manual.

4.4.2 Do not enter cargo compartments. 4.4.3 Fill out the Vessel Accident/Incident Report form.

4.5 Follow-up:


manual, if appropriate.



RCP-6.5-1


Title:

FIRE RESPONSE PLAN

Issue Date:





Page:

1 of 5 1.0 PURPOSE:

This procedure describes what to do in case of a fire aboard an Upper River Services (URS) vessel. This procedure describes what to do from the moment a fire is noticed on a vessel to the time the fire is extinguished and the proper paperwork is completed.

2.0 SCOPE:



implement this emergency plan and ensure that vessel personnel are aware of the requirements outlined in this procedure.


emergency and taking action deemed appropriate. 3.3 The crewmembers should make reasonable efforts to follow this

procedure.

4.0 PROCEDURE: 4.1 Fire in areas other than the engine room.

4.1.1 In the event of a galley fire, or fires other than an engine room fire, take steps including, but not limited to:

4.1.1.1 Notify the Vessel Operator or other crewmember

before attempting to put the fire out. 4.1.1.2 Sound the general alarm and announce “FIRE” on the

P.A. System. 4.1.1.3 Alert the crew. Yell “FIRE!”. 4.1.1.4 Put on a life jacket. 4.1.1.5 Take a head count of the crew.

RCP-6.5-2

4.1.1.6 Follow the Personal Injury or Illness procedure located in this manual, if appropriate.

4.1.1.7 Investigate the fire to determine its size, location, and suspected source.

4.1.2 If the fire can be put out with a hand-held fire extinguisher:

4.1.2.1 Put out the fire. 4.1.2.2 Notify the Vessel Operator. 4.1.2.3 Assign a fire reflash watch. 4.1.2.4 Determine the source of the fire. 4.1.2.5 Take corrective action. Follow the Lockout/Tagout

Procedure located in this manual, if applicable. 4.1.2.6 Assess the damage from the fire. 4.1.2.7 Determine if it is safe to continue to operate the

vessel. 4.1.2.8 Notify the Dispatcher and formulate a plan based on

the damage to the vessel. 4.1.2.9 Fill out the Vessel Accident/Incident Report.

4.1.3 If the fire cannot be put out with a hand-held fire extinguisher,

report to the Vessel Operator.

4.1.4 If the fire can be put out with the on board fire hose:

4.1.4.1 Put out the fire. 4.1.4.2 Notify the Vessel Operator. 4.1.4.3 Assign a fire reflash watch. 4.1.4.4 Determine the source of the fire. 4.1.4.5 Take corrective action. Follow Lockout/Tagout




4.1.5 If the fire cannot be put out with the on board fire hose, report to

the Vessel Operator. 4.1.6 Prepare to abandon the vessel.

4.1.6.1 Put on life jackets. 4.1.6.2 Request assistance from nearby vessels.

RCP-6.5-3

4.1.6.3 Notify the Dispatcher. This is a “PRIORITY” call. 4.1.6.4 Bring hand-held radios. 4.1.6.5 Ground and/or stop tow. 4.1.6.6 Separate boat from barge(s). Put crew onboard

barge if safe to do so. 4.1.6.7 Ground and/or stop boat away from barges. 4.1.6.8 Abandon the vessel. 4.1.6.9 Use emergency signaling devices to request

assistance – send out mayday. 4.1.6.10 Get to the shore as soon as possible or to another

boat, barge, or structure. 4.1.6.11 Get upwind and/or a safe distance from the fire.

4.2 Fire in the engine room

4.2.1 In the event of a fire in the engine room, take steps including, but not limited to, the following:

4.2.1.1 Notify the Vessel Operator or another crewmember

before attempting to put out the fire. 4.2.1.2 Sound the General Alarm and announce “FIRE” on

the P.A. System. 4.2.1.3 Alert the crew. Yell “FIRE!”. 4.2.1.4 Put on a life jacket. 4.2.1.5 Take a head count of the crew. 4.2.1.6 Follow the Personal Injury or Illness procedure

located in this manual, if appropriate. 4.2.1.7 Investigate the fire to determine its size, location, and

suspected source. 4.2.1.8 If the fire can be put out with a hand-held fire

extinguisher:

• Put out the fire. • Notify the Vessel Operator. • Assign a fire reflash watch. • Determine the source of the fire. • Take corrective action. Follow the Lockout/Tagout

Procedure located in this manual, if applicable. • Assess the damage from the fire. • Determine if it is safe to continue to operate the

vessel. • Notify the Dispatcher and formulate a plan based

on the damage to the vessel. • Fill out the Vessel Accident/Incident Report.

RCP-6.5-4

4.2.1 If the fire cannot be put out with a hand-held fire extinguisher, report to the vessel Captain or wheelhouse person.

4.2.2 If the fire can be put out with the fire hose aboard the boat:

4.2.2.1 Put out the fire. 4.2.2.2 Notify the Vessel Operator. 4.2.2.3 Assign a fire reflash watch. 4.2.2.4 Determine the source of the fire. 4.2.2.5 Take corrective action. Follow the Lockout/Tagout




4.2.3 If the fire cannot be put out with the on board fire hose, report to

the Vessel Operator. Prepare to abandon the vessel.

4.2.3.1 Request assistance from nearby vessels. 4.2.3.2 Notify the Dispatcher. State this is a “PRIORITY” call. 4.2.3.3 Pull Emergency Fuel Shut Off Valve for all engines. 4.2.3.4 Bring hand-held radios. 4.2.3.5 Use barge for refuge if it is safe to do so. Separate

boat from barge(s). 4.2.3.6 Abandon the vessel. 4.2.3.7 Get to the shore as soon as possible or to another

boat, barge, or structure. 4.2.3.8 Get upwind and/or a safe distance from the fire.

4.3 Follow-Up

4.3.1 If a crewmember is injured, follow the Personal Injury or Illness procedure located in this manual.

4.3.2 Stay upwind of toxic or poisonous gases or vapor. 4.3.3 Stay out of smoke-filled areas. 4.3.4 Fill out the Vessel Accident/Incident Report. 4.3.5 Fill out U. S. Coast Guard Form CG-2692, if required.

RCP-6.5-5



RCP-6.6-1


Title:

SINKING RESPONSE PLAN

Issue Date:





Page:

1 of 2 1.0 PURPOSE:

This procedure describes what to do in the event of an imminent sinking. It provides a uniform and consistent plan of action to be taken aboard Upper River Services (URS) vessels. This procedure describes the course of action to be taken from the moment that vessel personnel note that the boat may be sinking to the time when personnel need to obtain assistance if it is necessary to abandon the vessel. Following this procedure will allow the crew the optimum opportunity to avoid sinking and avoid personal injury as well as loss of the vessel.

2.0 SCOPE:





emergency and taking action deemed appropriate. 3.3 Crewmembers should make reasonable efforts to follow this procedure.

4.0 PROCEDURE: 4.1 In the event the vessel appears to be sinking, the Vessel Operator must

take action including, but not limited to, the following:

4.1.1 Sound the general alarm. 4.1.2 Instruct crew to put on life jackets if applicable. 4.1.3 Sound five short blasts on the horn if other traffic is in the area.

RCP-6.6-2

4.1.4 If the crew can prevent the vessel from sinking, take appropriate emergency action and call the Dispatcher. This is a “PRIORITY” call.

4.1.5 If the crew cannot prevent sinking, call “Mayday” on VHF Channel

16. 4.1.6 Contact other boats in the area and request assistance. Use the

appropriate VHF Channel to establish contact. 4.1.7 If the engines are running and the crew can ground the vessel,

ground the vessel in shallow water and call the Dispatcher. 4.1.8 If the crew cannot ground the vessel and the engines are not

running, prepare the crew to abandon the vessel. 4.1.9 Take hand-held radios and abandon the vessel. 4.1.10 Get on board the barge.

4.2 Follow-Up


manual, if applicable.



RCP-6.7-1


Title:

FALL OVERBOARD RESPONSE PLAN

Issue Date:





Page:

1 of 2 1.0 PURPOSE:

This procedure describes what to do in the case of a fall overboard. It provides a uniform and consistent plan of action to be taken aboard Upper River Services (URS) vessels. This procedure describes what to do from the moment that it is noticed that a person is overboard to the time of retrieval and the proper paperwork is completed. Following this procedure will enable the crew to quickly and effectively respond to a fall overboard situation.

2.0 SCOPE:





emergency and taking action deemed appropriate. 3.3 Crewmembers should make reasonable efforts to follow this procedure.

4.0 PROCEDURE: 4.1 In the event of a fall overboard situation, the Vessel Operator must take

action including, but not limited to:

4.1.1 Take evasive measures to avoid running over the person overboard, including putting engines in neutral gear and using rudder action to swing the boat and tow away from the person in the water.

4.1.2 Sound the general alarm. 4.1.3 Announce “FALL OVERBOARD” on the P.A. system.

RCP-6.7-2

4.1.4 Sound five short blasts on the horn. 4.1.5 If the victim is visible, keep him/her in sight at all times or designate

another crewmember to keep him in sight.

4.1.5.1 Determine if the victim is conscious. 4.1.5.2 If the victim is conscious, determine whether you can

reach him/her with the life rings. 4.1.5.3 If possible, throw the life ring or any available

floatation device to the victim or into his/her general vicinity.

4.1.5.4 Stop the tow when you are sure that the victim in the water is clear of the boat.

4.1.5.5 Instruct crewmembers to put on life jackets. 4.1.5.6 Retrieve the victim from the water. 4.1.5.7 If you cannot reach the victim with a life ring, retrieve

the victim by an alternative method such as getting help from another vessel.

4.1.5.8 If the victim is not conscious, use whatever means available for retrieval.

4.1.6 If the victim is not visible, note a landmark or mark in the area near

where the victim was last seen.

4.1.6.1 Notify marine traffic in the area and request assistance.

4.1.6.2 Notify the U.S. Coast Guard. 4.1.6.3 Search for the victim, using available light at night. 4.1.6.4 Call the Dispatcher. 4.1.6.5 Continue to search for the victim until he/she is found

or until the search is called off by the U.S. Coast Guard.

4.2 Follow-up:


manual, if applicable.



RCP-6.8-1


Title:

OPERTOR INCAPACITATION

Issue Date:





Page:

1 of 2 1.0 PURPOSE:

The purpose of this procedure is to establish a standard operating procedure for all Upper River Services (URS) vessels when responding to the incapacitation of the Vessel Operator. Following this procedure will result in a uniform response to safeguard crewmembers, equipment, public property and the environment.

2.0 SCOPE:



implement this procedure and ensure that vessel personnel are aware of the requirements outlined.

3.2 The Vessel Operator should make reasonable efforts to ensure that

vessel crewmembers are trained and drilled in this procedure.

4.0 PROCEDURE: 4.1 The Vessel Operator shall assign a crewmember on duty to make regular

checks on him/her to ensure that he/she is alert and in control of the vessel. These checks should be made at:

4.1.1 Time intervals not to exceed 1 hour; 4.1.2 Before navigating through bridges; 4.1.3 Known areas of high vessel traffic density; and, 4.1.4 Other areas that may require timely, critical vessel maneuvers.

4.2 In the event the Vessel Operator becomes incapacitated, the

crewmember that discovers the emergency shall take the following actions:

RCP-6.8-2

4.2.1 Sound the general alarm; 4.2.2 Take control of the vessel. Reduce power and maintain steerage; 4.2.3 Attempt to ascertain and avoid any immediate navigational

hazards; 4.2.4 If qualified, crewmembers may start administering first aid to the

incapacitated vessel operator; 4.2.5 Contact other vessels in the area or use the emergency Channel

16, and advise the U.S. Coast Guard of the emergency situation.; Provide the following information:

4.2.5.1 “THIS IS AN EMERGENCY!” 4.2.5.2 “This is the Motor Vessel _____________.” 4.2.5.3 “I am the (engineer/deckhand) onboard.” 4.2.5.4 “I am at (give a geographic location or read the

position from the GPS) with a (loaded/empty) (oil/cargo) barge and the Captain is incapacitated. Request that you advise vessels in my vicinity and I request assistance from any vessel available immediately.”

4.2.6 Call 911 for emergency medical services and continue to render

first aid as appropriate; and, 4.2.7 Call the Dispatch Office and apprise them of the situation.



RCP-6.9-1


Title:

EMERGENCY PHONE NUMBERS

Issue Date:


February 20, 2015 Procedure Number:

RCP-6.9

Approved By:


1 of 2

1.0 PURPOSE:

To provide an accurate list of telephone numbers to call in an emergency. There are telephone numbers listed in this procedure for key company personnel, U.S. Coast Guard, local emergency departments, and oil or hazardous spill notification numbers.

2.0 SCOPE:


3.0 RESPONSIBILITY:

The Vice President of Operations or his/her designate should make reasonable efforts to see that this list is accurate and that appropriate employees are familiar with the location of this list.

4.0 PROCEDURE:

4.1 COMPANY TELEPHONE NUMBERS

Office (Pigseye) Office Phone: 651-292-9293 President - Lee Nelson Cell Phone: 651-260-0185 General Manager - Molly Isnardi Cell Phone: 651-262-8215 Vessel Operations Manager - Doug Hosszu Cell Phone: 612-590-4852 Port Engineer - John DeVaan Cell Phone: 651-485-3276 Shipyard Manager - Gary Lewis Cell Phone: 651-485-3438

RCP-6.9-2

4.2 U.S. COAST GUARD SECTOR UPPER MISSISSIPPI RIVER

City, State Address Phone Number

St. Louis, MO 1222 Spruce St. Suite 7103

314-269-2500 314-269-2463

4.3 U.S. COAST GUARD MARINE SAFETY DETACHMENT

City, State Address Phone Number

St. Paul/Minneapolis 5600 American Blvd West Suite 750

952-805-5666

4.4 OIL SPILL NOTIFICATION NUMBERS

NATIONAL RESPONSE CENTER 1-800-424-8802


0 Initial issue April 14, 2014 1 First revision – Revised 4.1 February 20, 2015

RCP-7.1-1

INCIDENT REPORTING

PROCEDURES

Title:

VESSEL PERSONNEL

INCIDENT

REPORTING

Issue Date:

April 14, 2014

Last Revised:

February 20, 2015

Procedure Number:



Page:

1 of 3

1.0 PURPOSE: The following procedures are to be followed by Upper River Services (URS) vessel crewmembers in communicating emergency situations to the proper personnel.

2.0 SCOPE:


3.0 RESPONSIBILITY: 3.1 Vessel crewmembers are responsible for immediately reporting

emergency situations to the Vessel Operator. 3.2 The Vessel Operator is responsible for implementing URS emergency

procedures. 3.3 The Dispatcher on duty is responsible for receiving emergency response

calls from URS vessels and contacting the Vessel Operations Manager. 3.4 The Vessel Operations Manager should make reasonable efforts to

ensure that each vessel is provided with a copy of URS emergency procedures.

4.0 PROCEDURE: 4.1 Whenever the Vessel Operator experiences one of the emergency

situations listed below, he/she must institute the provisions of URS emergency response plan which may include, but is not limited to:

4.1.1 Immediately reporting emergency response situations to the

Dispatcher by calling (651) 292-9293 and stating, “I HAVE A VESSEL EMERGENCY!”; if unable to reach the Dispatcher within thirty minutes call the Vessel Operations Manager; and,

RCP-7.1-2

4.1.2 Serving as the company On-Scene Representative until properly relieved.

4.1.3 Emergencies include, but are not limited to:

4.1.3.1 Collisions/allisions; 4.1.3.2 Groundings; 4.1.3.3 Spills (not limited to cargo spills), whether on deck or

in the water; 4.1.3.4 Sinking; 4.1.3.5 Personal injury; 4.1.3.6 Serious or potentially serious illness; 4.1.3.7 Fire on board the towing vessel or the barge; 4.1.3.8 Fall overboard; 4.1.3.9 Operator incapacitation; and, 4.1.3.10 Major mechanical or structural failure.

4.1.4 After the emergency action plan has been completed, the Vessel

Operator must complete the Vessel Accident/Incident Report and within 24 hours either:

4.1.4.1 Provide the report to the Vessel Operations Manager; 4.1.4.2 Fax the report to the Operations Office (651) 227-

8456; or, 4.1.4.3 Turn the report in with the Master’s Daily Log.

4.1.5 In the event of an injury, the injured person (if possible) should complete a Personal Injury Report.

4.1.5.1 A Personal Injury Witness Report should be filled out

by the supervisor conducting the interview following the incident. This form must be filled out for everyone who witnessed the incident. The Personal Injury Witness Report can be found at the end of this procedure.

4.2 The Dispatcher on duty must receive emergency response calls from URS

vessels and:

4.2.1 Immediately contact the Vessel Operations Manager; and, 4.2.2 Stand by and render assistance as necessary.

RCP-7.1-3

4.3 The Vessel Operations Manager must receive response calls from the Dispatcher on duty and institute the provisions of URS emergency response plan.

4.4 The Vessel Operations Manager must make the notifications required by

URS emergency response plan. 4.5 To determine if U.S. Coast Guard reporting is required, refer to the U.S.

Coast Guard Reporting Requirements procedure in this section.

5.0 RECORDS:

5.1 Vessel accident/Incident Report should kept for 3 years after the accident. 5.2 Personal Injury Report should be kept for 3 years after the accident.

5.3 Personal Injury Witness Report should be kept for 3 years after the accident.

6.0 APPENDICES:

6.1 Vessel Accident/Incident Report 6.2 Personal Injury Report 6.3 Personal Injury Witness Report


0 Initial issue April 14, 2014 1 First Revision – Added paragraph 4.1.5.1 and 6.3 and section 5.0 Records October 14, 2014 2 Second Revision – Revised paragraph 4.4, removed paragraph 4.4.1 and added paragraph 4.5 February 20, 2015

VESSEL ACCIDENT/INCIDENT REPORT NAME OF TOWBOAT DATE OF REPORT

PILOT DECKHAND TRIP: BOUND FROM TO DATE OF ACCIDENT TIME OF ACCIDENT LOCATION OF ACCIDENT (MILE PT., ETC/) WEATHER CONDITIONS VISIBILITY RIVER CONDITIONS DAY/NIGHT PERSON RESPONSIBLE FOR ACCIDENT NATURE OF ACCIDENT

(Grounding, Struck Submerged Object, Collision, Other) DESCRIBE ACCIDENT IN DETAIL DESCRIBE IN DETAIL DAMAGE TO OTHER VESSEL OR PROPERTY DESCRIBE IN DETAIL DAMAGE TO URS VESSEL(S) HAS U.S. COAST GUARD BEEN NOTIFIED? HAVE TEMPORARY REPAIRS BEEN MADE? IF YES, DESCRIBE NAME(S) OF WITNESS(ES) TO THIS ACCIDENT ON THE BACK OF THIS REPORT, SKETCH RIVER AND TOW AT THE TIME OF ACCIDENT. (SHOW POSITION OF VESSELS, DOCKS, BRIDGES, ETC., DIRECTION OF WIND, CURRENT) SIGNED BY DATE

April 14, 2014

PERSONAL INJURY REPORT 1. Name of injured: ___________________________________________________ SS # ______ ______ ______ Last First Middle Initial 2. Address: _________________________________________________________________________________ 3. Phone No: ________________________________ Date of Birth: _______________________________ 4. Employment History: (required by USCG) Year(s) Month(s)

a. In the Industry _______ _______

b. With the Company _______ _______

c. In the present job or position _______ _______

d. On present vessel _______ _______

e. Hours on duty when accident occurred _______

5. Date of injury: ________________ Time: _____________ Job Title:________________________________ 6. Name of Vessel: ____________________________ Pilot on Watch: ________________________________ 7. Vessel location at time of accident: Mile _______ River ___________________ Direction_______________ 8. Weather conditions: ________________________________________________________________________ 9. Detailed description of how injury occurred and what employee was doing at time of accident: ___________________________________________________________________________________________ ___________________________________________________________________________________________ ___________________________________________________________________________________________ ___________________________________________________________________________________________ 10. Type of Injury : Body part injured:

Type included: Contusion, burns, foreign body (eye), fractures, illness, lacerations, strains (back), Body parts: Abdomen, ankle, arm, elbow, back, fingers, foot, hand, head/face, knee, leg, neck, shoulder, skin, toe

11. Describe First Aid treatment if any and who administered: _________________________________________ ___________________________________________________________________________________________ 12. Was injured employee able to resume regular duties? YES ____ NO ____ 13. Did injured employee leave vessel? YES ____ NO ____ Date __________ Locations ________________ 14. Has injured employee ever had the same or similar injury? YES ____ NO ____ If yes, explain _________ ___________________________________________________________________________________________ 15. Name and address of doctor that treated the previous injury: ______________________________________ ___________________________________________________________________________________________ COMPLETE crew list:

Name Position Witnessed incident (yes or no)

________________________ ________________________ ____________________________

________________________ ________________________ ____________________________

________________________ ________________________ ____________________________ I have read the contents of this report, including the paragraph describing how the accident occurred, and I attest that it is true and correct. INJURED EMPLOYEE’S SIGNATURE: DATE: April 14, 2014

PERSONAL INJURY WITNESS REPORT

(This form must be completed by anyone witnessing the incident.) 1. Name of the Witness___________________________________________________ Last First Middle Initial 2. Address of the Witness: _________________________________________________________________________________ 3. Phone No of the Witness: _________________________________________________________ 4. Name of injured: ___________________________________________________ Last First Middle Initial 5. Date of injury: ________________ Time: _____________ 6. Location where injury took place: ____________________________ 7. Supervisor: ________________________________ 8. Detailed description of how injury occurred and what the employee was doing at time of accident: __________________________________________________________________________________________ __________________________________________________________________________________________ __________________________________________________________________________________________ __________________________________________________________________________________________ 10. Type of Injury: Body part injured: ___________________________ Type included: Contusion, burns, foreign body (eye), fractures, illness, lacerations, strains (back), Body parts: Abdomen, ankle, arm, elbow, back, fingers, foot, hand, head/face, knee, leg, neck, shoulder, skin, toe 11. Did injured employee leave vessel? YES ____ NO ____

I have read the contents of this report, including the paragraph describing how the accident occurred, and I attest that it is true and correct. WITNESS’S SIGNATURE: DATE:__________________________ October 14, 2014

RCP-7.2-1

INCIDENT REPORTING

PROCEDURES

Title:

OFFICE PERSONNEL

INCIDENT

REPORTING

Issue Date:

April 14, 2014

Last Revised:

February 20, 2015

Procedure Number:



Page:

1 of 2

1.0 PURPOSE: The following procedures provide instructions to be followed by Upper River Services (URS) office personnel in handling and reporting emergency situations.

2.0 SCOPE:

This policy applies to all URS office personnel.

3.0 RESPONSIBILITY: 3.1 The Vessel Operations Manager should make reasonable efforts to follow

this procedure. 3.2 The Vessel Operations Manager is responsible for updating, revising,

maintaining and distributing the emergency response plan.

4.0 PROCEDURE: 4.1 Emergencies must be reported by vessel personnel through the

Dispatcher. Emergencies include, but are not limited to:

4.1.1 Collisions/allisions; 4.1.2 Groundings that exceed one hour or in which equipment is

damaged; 4.1.3 Spills (not limited to cargo spills), whether on deck or in the water; 4.1.4 Vessel sinking; 4.1.5 Personal injury; 4.1.6 Fall overboard; 4.1.7 Operator incapacitation; and,

RCP-7.2-2

4.1.8 Fire on board the towing vessel or the barge. 4.2 The Dispatcher must place a call to the Vessel Operations Manager. 4.3 The Vessel Operations Manager must follow URS emergency response

procedures to handle and report the emergency. 4.4 The Vessel Operations Manager must keep a log of parties to whom the

incident has been reported, including the name of the person contacted and time of contact.

4.5 To determine if U.S. Coast Guard reporting is required, refer to the U.S.

Coast Guard Reporting Requirements procedure in this section.


0 Initial issue April 14, 2014 1 First revision – Revised paragraphs 1.0 and 4.5, removed paragraphs 4.5.1 through 4.5.8 February 20, 2015

RCP-7.3-1

INCIDENT REPORTING

PROCEDURES

Title:

U.S. COAST GUARD

REPORTING

REQUIREMENTS

Issue Date:

February 20, 2015

Last Revised:

February 20, 2015

Procedure Number:



Page:

1 of 6

1.0 PURPOSE: To provide guidance for compliance with U.S. Coast Guard reporting requirements.

2.0 SCOPE:

This procedure should be followed by all Upper River Services (URS) employees to see that the required U.S. Coast Guard reporting is completed.

3.0 RESPONSIBILITY: 3.1 In the event of an incident, it is the responsibility of the Vessel Operator or

person in charge to notify the office as soon as possible. If the Vessel Operator or person in charge is unable to notify the office, the Vessel Operator or person in charge is to make a determination as to whether the incident involves a marine casualty which requires notification of the U. S. Coast Guard, and make the required notification by calling the appropriate U.S. Coast Guard Group on VHF channel 16, or call the appropriate Marine Safety Office. See the Emergency Phone Numbers procedure in this manual for the phone numbers.

3.2 It is the responsibility of the management person receiving a report of

casualty from a company vessel to make the determination as to whether the casualty requires reporting to the U.S. Coast Guard. If reporting is required, make the report immediately by calling the appropriate Marine Safety Office and report the incident to the duty officer.

3.3 The U.S. Coast Guard requires reports of incidents to be made

immediately after addressing resultant safety concerns, and generally no longer than 30 minutes after the time of the incident.

3.3.1 What is “immediately after addressing resultant safety

concerns”? No one expects responsible individuals on scene to delay emergency or essential response and recovery actions; however, immediate reporting as soon as is practicable is essential for proper Coast Guard response actions.

RCP-7.3-2

4.0 PROCEDURE: 4.1 Should the incident/injury be verbally reported to the U.S. Coast Guard?

4.1.1 Upon receipt of the initial report of a vessel incident or injury to a marine employee, the office should determine if U.S. Coast Guard notification is required (remember, if unable to notify the office, the Vessel Operator or person in charge assumes this responsibility). To make this determination, follow the instructions in 46CFR 4.05-1, which reads as follows:

46CFR4.05-1 NOTICE OF MARINE CASUALTY

(a) Immediately after the addressing of resultant safety concerns, the owner, agent, Master, Pilot, or person in charge, shall notify the nearest Sector Office, Marine Inspection Office or Coast Guard Group Office whenever a vessel is involved in a marine casualty consisting in--

(1) An unintended grounding, or an unintended strike of (allison with) a bridge; (2) An intended grounding, or an intended strike of a bridge, that creates a hazard to navigation, the environment, or the safety of a vessel, or that meets any criterion of paragraphs (a)(3) through (8); (3) A loss of main propulsion, primary steering, or any associated component or control system that reduces the maneuverability of the vessel; (4) An occurrence materially and adversely affecting the vessel’s seaworthiness or fitness for service or route, including but not limited to fire, flooding, or failure of or damage to fixed fire extinguishing systems, lifesaving equipment, auxiliary power-generating equipment, or bilge-pumping systems; (5) A loss of life; (6) An injury that requires professional medical treatment (treatment beyond first aid) and, if the person is engaged or employed on board a vessel in commercial service, that renders the individual unfit to perform his or her routine duties; or

RCP-7.3-3

(7) An occurrence causing property damage in excess of $25,000, this damage including the cost of labor and material to restore the property to its condition before the occurrence, but not including the cost of salvage, cleaning, gas freeing, dry docking or demurrage. (8) An occurrence involving significant harm to the environment as defined by 46 CFR 4.03-65.

(b) Notice given as required by 33CFR160.215 satisfies the

requirement of this section if the marine casualty involves a hazardous condition as defined by 33CFR160.204.

33CFR160.215 - Whenever there is a hazardous condition aboard a vessel or caused by a vessel or its operation, the owner, agent, Master, Pilot, or person in charge shall immediately notify the nearest Coast Guard Sector Office or Group office. 33CFR160.204 - Hazardous condition - means any condition that may adversely affect the safety of any vessel, bridge, structure, or shore area or the environmental quality of any port, harbor, or navigable water of the United States. It may, but need not, involve collision, allision, fire, explosion, grounding, leaking, damage, injury or illness of a person aboard, or manning-shortage.

4.1.2 If the incident requires notification of the U.S. Coast Guard, the

office should immediately notify the appropriate U.S. Coast Guard office by telephone (if unable to notify the office, the Vessel Operator or person in charge assumes this responsibility). The

U.S. Coast Guard requires “immediate” reporting of all reportable incidents.

4.2 If the incident/injury does require an immediate verbal report to the U.S.

Coast Guard, what information will they ask for?

46CFR4.05-5 Substance of marine casualty notice

The notice required in 46CFR4.05-1 must include the name and official number of the vessel involved, the name of the vessel’s owner or agent, the nature and circumstances of the casualty, the locality in which it occurred, the nature and extent of injury to persons, and the damage to property.

RCP-7.3-4

4.3 When do drug or alcohol tests have to be conducted?

4.3.1 At the time of the casualty, the marine employer is required to make a good faith effort to determine if the casualty is, or is likely to become, a “Serious Marine Incident.”

4.3.1.1 If it is determined that the incident is NOT a “Serious

Marine Incident”, the marine employer shall determine whether there is any evidence of alcohol or drug use by the individuals directly involved in the casualty, as required by block 44 on the USCG form 2692.

4.3.2 The Vessel Operations Manager or his/her designate will have the

responsibility for ensuring that any required drug and alcohol testing is accomplished in accordance with U.S. Coast Guard regulations (if unable to notify the office, the Vessel Operator or person in charge assumes this responsibility).

4.3.3 Drug and alcohol testing requirements are as follows:

When a marine casualty, discharge of oil, or release of a hazardous substance occurs, the marine employer needs to make a timely, good faith determination as to whether the occurrence is or is likely to become a serious marine incident. A marine employer shall require all persons (not limited to crewmembers) on board the vessel(s) whom the employer determines to be directly involved in a serious marine incident to be chemically tested for dangerous drugs and alcohol. In the event of a serious marine incident, the marine employer is required to make a good faith effort to have alcohol testing completed within two hours after the time of the incident.

A serious marine incident, as defined by 46CFR4.03-2, includes the following events:

1. A discharge of 10,000 gallons or more of oil into the navigable

waters of the United States, whether or not resulting from a marine casualty,

2. A discharge of a reportable quantity of a hazardous substance into the navigable waters of the United States, whether or not resulting from a marine casualty, or

3. A marine casualty or accident that is required by 46CFR4.05-1 to be reported to the U. S. Coast Guard which results in any of the following:

a. One or more deaths;

RCP-7.3-5

b. An injury to any person (including passengers) which requires medical treatment beyond first aid, and in the case of a person employed on board a commercial vessel, which renders the person unable to perform routine vessel duties;

c. Damage to property in excess of $100,000.00; d. Actual or constructive total loss of any inspected vessel; or e. Actual or constructive total loss of any uninspected, self-

propelled vessel of 100 gross tons or more. 4.4 Does the U.S. Coast Guard require a written report to be sent to them?

46 CFR 4.05-10 Written report of marine casualty

(a) The owner, agent, Master, Operator, or person in charge shall, within five days, file a written report of any marine casualty required to be reported under 46CFR4.05-1. This written report is in addition to the immediate notice required by 46CFR4.05-1. This written report must be delivered to a Coast Guard Marine Safety Office or Marine Inspection Office. It must be provided on form CG-2692 (Report of Marine Accident, Injury or Death), supplemented as necessary by appended Forms CG-2692A (Barge Addendum) and CG-2692B (Report of Required Chemical Drug and Alcohol Testing Following a Serious Marine Incident).

(b) If filed without delay after the occurrence of the marine casualty,

the report required by paragraph (a) of this section suffices as the notice required by 46CFR4.05-1(a). (For this paragraph to be applicable,

the written report must be filed immediately after the incident, which is usually not practical or even possible in most cases.)

4.4.1 If required, upon receipt of the completed written incident reports

from the facility or vessel, the Manager will prepare a USCG Form 2692, 2692A, and/or 2692B (these forms are located at the end of this procedure), as required, and send the completed form(s) to the appropriate U.S. Coast Guard office. USCG Forms 2692 are required to be sent to the U.S. Coast Guard as soon as possible, and in all cases, within five working days of the incident.

4.4.2 All USCG Forms 2692 are to be filled out by the Vessel Operations

Manager or their designate.

RCP-7.3-6

4.5 What if the accident/incident involves an aid to navigation?

46 CFR 4.05-20 Report of Accident to Aid to Navigation

Whenever a vessel collides with a buoy, or other aid to navigation under the jurisdiction of the Coast Guard, or is connected with any such collision, it shall be the duty of the person in charge of such vessel to report the accident to the nearest Officer in Charge, Marine Inspection. No report on Form CG-2692 is required unless one or more of the results listed in 46CFR4.05-1 occur.

5.0 RECORDS:

Copies of all USCG Form 2692s should be kept in the office for at least 5 years.

6.0 APPENDICES:

6.1 USCG Form 2692 6.2 U.S. Coast Guard Reporting and Chemical Testing Requirements

Flowchart



INSERT USCG FORM 2692 HERE

U.S. COAST GUARD REPORTING AND CHEMICAL TESTING REQUIREMENTS FLOWCHART

TYPE OF ACCIDENT

Immediate

Verbal Report to

Coast Guard

Submit

CG-2692

Determine if Drug/Alcohol

Use Involved & Include in

CG-2692

Chemical Test

Required Submit CG-2692B

1. Accidental grounding or bridge striking YES YES YES NO NO*

2. Intentional grounding or bridge striking

Creates hazard to navigation, environment, or safety of vessel

YES YES YES NO NO*

Otherwise reportable YES YES YES NO NO*

None of the above NO NO NO NO NO

3. Loss of propulsion/steering/control system YES YES YES NO NO*

4. Seaworthiness/fitness for service adversely affected (e.g., fire, flooding, failure of fire extinguishing systems/lifesaving equipment/auxiliary equipment/auxiliary generator/bilge pump

YES YES YES NO NO*

5. Loss of life YES YES YES YES YES

6. Injury (professional medical treatment beyond first aid and unfit to perform routine duties)

YES YES YES YES YES

7. Property damage (to a company vessel, third party vessel, dock, terminal, bridge or fender system, lock wall, etc.; not including salvage, cleaning, gas-freeing, dry-docking, or demurrage costs)

$25,000 or less NO NO NO NO NO*

$25,000 to $100,000 YES YES YES YES NO*

Greater than $100,000 YES YES YES YES YES

8. Actual or constructive total loss of vessel

Inspected vessels (including tank barges or seagoing barges)

YES YES YES YES YES

Self-propelled vessels (100 gross tons or more)

YES YES YES YES YES

Any other vessel YES YES YES YES YES

9. Oil Spill

Less than 10,000 gallons YES YES** YES** NO NO*

10,000 gallons or more YES YES** YES** YES YES

10. Chemical Spill YES YES** YES** YES YES

* Form 2692B must be submitted if incident is, or becomes a Serious Marine Incident ** Required if casualty causing spill was otherwise reportable. February 20, 2015

RCP-7.4-1

INCIDENT REPORTING

PROCEDURES

Title:

INCIDENT

INVESTIGATION AND

COMMUNICATION OF

LESSONS LEARNED

Issue Date:

April 14, 2014

Last Revised:

February 20, 2015

Procedure Number:



Page:

1 of 2

1.0 PURPOSE: This procedure provides directions for determining whether an investigation of an incident should be conducted.

2.0 SCOPE:



determine the severity of incidents and decide which incidents should be investigated. When an incident is determined to require investigation, the investigation should be done by a professional investigator in a timely manner.

3.2 The Vessel Operations Manager assists in the investigation when required

and disseminates lessons learned and related safety information to the fleet.

4.0 PROCEDURE: 4.1 When a decision to investigate is made, the Vessel Operations Manager

in consultation with the company’s legal advisor and/or insurance broker should make arrangements for the professional investigator.

4.2 The Vessel Operations Manager or designate should send a copy of the

investigation report, prepared by the attorneys or other professional investigators, made in anticipation of litigation, to the company’s insurance broker if necessary, as soon as circumstances permit.

4.3 Investigation reports prepared by the attorneys or other professional

investigators, made in anticipation of litigation should be reviewed by all members of the Management Team as soon as possible.

RCP-7.4-2

4.4 The Vessel Operations Manager should make reasonable efforts to verbally distribute safety related facts and lessons learned to company vessels and employees as soon as this report has been approved by the members of the Management Team.

4.5 Records used to complete an investigation of a personal injury should be

kept along with the final report of the investigation at least three years from the date of the incident.

4.6 Records used to complete an investigation of equipment damage or a spill

should be kept along with the final report of the investigation at least five years from the date of the incident.


0 Initial issue April 14, 2014 1 First revision – Revised Procedure Number February 20, 2015

RCP-8.1-1

INTERNAL AUDIT PROCEDURES

Title:

CORRECTIVE/ PREVENTATIVE ACTION

Issue Date:





Page:

1 of 2 1.0 PURPOSE:

This procedure is designed to ensure that when a deficiency or opportunity for improvement is identified, corrective/preventative action is taken and is effective in preventing recurrence of the opportunity for improvement.

2.0 SCOPE:


3.0 RESPONSIBILITY:

3.1 The Vessel Operations Manager, and/or the incident investigator,

prepares a corrective/preventative action plan based on information gathered from the investigation.

3.1.1 The Vessel Operations Manager implements corrective/

preventative action or approves implementation of corrective/preventative action recommended by the investigator if the investigator does not have the authority to approve and implement the corrective/preventative action.

3.1.2 The Vessel Operations Manager ensures that corrective/

preventative action taken is verified for effectiveness. 3.2 The President reviews the long-term effectiveness of corrective action

taken during monthly management review meetings.

4.0 PROCEDURE: 4.1 The Vessel Operations Manager, or the investigator, determines the

corrective/preventative action required based on the investigation results. 4.2 The Vessel Operations Manager, or the investigator, enters the

recommended corrective/preventative action on the form.

RCP-8.1-2

4.2.1 The form is initialed by the individual with authority to approve and/or implement the corrective/preventative action.

4.3 The individual with authority implements the corrective/preventative

action. 4.4 The Vessel Operations Manager signs and dates the form for closing

once the corrective/preventative action is approved and/or implemented. 4.5 The Vessel Operations Manager returns the form to the investigator for

further investigation if the corrective/preventative action plan is not approved.

4.6 The Vessel Operations Manager sends copies of the closed corrective/

preventative action to the following persons:

4.6.1 Affected departments, vessels, and personnel; 4.6.2 General Manager; and, 4.6.3 President.



RCP-8.2-1


Title:

DOCUMENT CONTROL,

UPDATING AND

DISTRIBUTION

Issue Date:

April 14, 2014

Last Revised:

February 20, 2015

Procedure Number:



Page:

1 of 3

1.0 PURPOSE: This procedure establishes a system to identify, organize, revise and maintain documents in the Upper River Services (URS) safety management system to see that holders of these documents have the latest revision of documents and that out of date documents are removed from the system.

2.0 SCOPE:

This policy applies to all Upper River Services vessel division employees.

3.0 RESPONSIBILITY: 3.1 The General Manager should make reasonable efforts to maintain a

master list of controlled documents that are part of the URS safety management system identifying the current revision and status of controlled documents.

3.2 The General Manager should make reasonable efforts to see that

documents are distributed and controlled in accordance with this procedure.

3.3 The holder of a controlled document should make reasonable efforts to

make the appropriate additions, changes, and/or deletions to the various manuals assigned to them as advised by the General Manager.

4.0 PROCEDURE: 4.1 The master list of controlled documents is a database that contains

information necessary to maintain the URS controlled document system. The General Manager maintains the database in Microsoft Excel.

4.2 The Responsible Carrier Program Manual is a controlled document. 4.3 The system of controlling documents at URS is by issuance of controlled

binders which contain relevant sections, procedures, and forms.

RCP-8.2-2

4.4 The General Manager should make reasonable efforts to maintain a master list of controlled documents indicating the holders of controlled copies.

4.5 To issue new or revised documents, the General Manager should prepare

a Document Transmittal Form. The Document Transmittal Form should indicate if the document is new or revised, the type of document along with the revision date and number.

4.6 When revisions to documentation are made, they should be transmitted to

all holders of controlled copies using Document Transmittal Form. 4.7 Upon receipt of a new or revised document, the holder of the document

should put the document in the correct place in the manual. In the case of a revised document, the holder of the controlled document should remove and destroy the previous revision of the document.

4.8 A copy of the Document Transmittal Form may be made and placed in the

manual, but a signed copy should be returned to the General Manager within ten (10) working days.

4.9 The General Manager should make reasonable efforts to track the

Document Transmittal Forms to see that the holders of controlled documents have received their copies of the documents.

4.10 Thirty (30) days after the original transmittal, the General Manager should

follow up on all personnel who have not responded to the document transmittal.

4.11 As revisions to controlled documents are issued, superseded

documentation should be destroyed to preclude the inadvertent use of the document in a process that could have an effect on quality or safety. Only the most recent revision of documents is used in any process covered by the safety management system.

4.12 Controlled documents should be reviewed by the General Manager at

least annually and at a minimum during the Internal Audit. 4.13 A Document Transmittal Form does not need to be filled out when

controlled documents are hand delivered to the holder of these documents.

4.14 The master list of controlled documents should be kept current and on file

indefinitely.

RCP-8.2-3

4.15 The contents of this manual are available to employees through our employee portal on the Upper River Services website.

5.0 APPENDICES:

Master List of Controlled Documents


0 Initial issue April 14, 2014 1 First revision – Added paragraph 4.15 February 20, 2015

MASTER LIST OF CONTROLLED DOCUMENTS

Document Name Copy

Number

Issued to Issued by Date

Issued

April 14, 2014

RCP-8.3-1


Title:

PERFORMANCE MEASUREMENT PROCEDURES

Issue Date:





Page:

1 of 2 1.0 PURPOSE:

This procedure establishes a system for maintenance, analysis, and distribution of injury, navigational, and spill statistics to provide a means of measuring Upper River Services (URS) safety performance. URS participates in the AWO Voluntary Statistics Program.

2.0 SCOPE:


3.1 The General Manager is responsible for submitting data as requested by

the AWO Statistics Program quarterly. 3.2 The General Manager should use AWO’s Injury Recordkeeping

Guidelines to classify statistics.

4.0 PROCEDURE: 4.1 Information is recorded and tracked quarterly on the following types of

incidents and information: 4.1.1 Employee hours; 4.1.2 Fatalities; 4.1.3 Recordable injuries; 4.1.4 Lost time injuries; and 4.1.5 Falls overboard;

4.2 Incidents are classified according to AWO’s Injury Recordkeeping

Guidelines.

RCP-8.3-2

4.3 A summary of the URS safety performance is shared annually with all URS vessels and operating divisions.

4.4 Management will review the AWO reports annually in order to identify

areas for improvement.



RCP-8.4-1


Title:

INTERNAL AUDIT AND REVIEW

Issue Date:





Page:

1 of 3 1.0 PURPOSE:

The purpose of this procedure is to help maintain Upper River Services (URS) procedures, vessels and equipment in accordance with company policy. This procedure should also help the company see that the safety inspection checklists are completed and that maintenance requirements are followed as required by company procedures.

2.0 SCOPE:


3.1 The Vessel Operations Manager, the Port Engineer or their designate

should make reasonable efforts to conduct an audit, at least once a year, of each URS vessel that is being inspected on a monthly basis by employees.


conduct internal audits of the URS Responsible Carrier Program.

4.0 PROCEDURE: 4.1 The Vessel Operations Manager, or designate, will conduct an annual

internal audit of the company’s RCP. This internal audit will be performed on an annual basis unless a significant situation arises that demonstrates the need for additional auditing prior to the annual review.

4.2 The internal auditor should obtain the most recent RCP Audit Checklist

and, when appropriate, meet with the General Manager and/or the Vessel Operations Manager to conduct the audit.

4.3 Upon completion of the audit, the Vessel Operations Manager will review

the audit to identify whether or not there are any nonconformities.

RCP-8.4-2

4.4 In the case of nonconformities, the Vessel Operations Manager will arrange to meet with the General Manager to discuss the nonconformities and develop a plan to correct them.

4.5 For each nonconformity, the plan shall include the following:

4.5.1 Identifying the person or persons responsible for determining and implementing the appropriate corrective action.

4.5.2 The timeframe for which corrective action must be taken (maximum

of 90 days). 4.5.3 A tentative date to meet again to check on progress or verify that

the nonconformity has been resolved. 4.6 Auditors should use the most current safety inspection checklist to audit

each vessel and piece of equipment’s level of compliance with the inspection procedures.

4.7 Audits for compliance with maintenance procedures should be

accomplished by using the maintenance checklists designed for the vessel or equipment being audited.

4.8 The auditor should make a reasonable effort to discuss discrepancies and

opportunities for improvement discovered during the audits with the managers of the departments.

4.9 Audit deficiencies should be corrected within 90 days and in accordance

with the inspections procedures. 4.10 Following each audit, an entry should be made in the “Completed Audit

Log”. 4.11 Initial training should be provided to employees who conduct these

internal audits.

5.0 RECORDS: 5.1 Copies of the audits will be kept on file at least until the noted deficiencies

have been corrected. 5.2 The “Completed Audit Log” should be kept on file for at least five (5)

years.

RCP-8.4-3

6.0 APPENDICES:

Completed Audit Log 7.0 REVISION HISTORY:


COMPLETED AUDIT LOG

RCP Manual Audited Auditor’s Name Date of the Audit

April 14, 2014

RCP-8.5-1


Title:

FEDERAL REGULATORY COMPLIANCE

Issue Date:





Page:

1 of 2 1.0 PURPOSE:

The purpose of this procedure is to provide a method whereby the company can remain in compliance with applicable federal laws and regulations concerning marine safety and environmental compliance.

2.0 SCOPE:


3.0 RESPONSIBILITY:

3.1 Every member of the management team should make reasonable efforts

to become current and remain current with federal laws and regulations that concern marine safety and environmental protection.

3.2 The Vessel Operations Manager should make reasonable efforts to stay

abreast of proposed and current rulemaking efforts of those federal agencies having jurisdiction over marine safety and environmental protection issues for the towing industry and its operations.

3.3 Members of management involved in daily operations should make a

reasonable effort to review mailings from available resources such as: The American Waterways Operators (AWO), U.S. Coast Guard newsletter, USACE notices and correspondence from company attorneys, etc. in order to keep themselves current with these regulatory issues.

4.0 PROCEDURE:

4.1 The company utilizes a monthly safety inspection process to verify vessel

compliance with marine safety and environmental issues. The process involves completion of a checklist to determine if non-compliance issues need to be addressed and outlines the steps to be taken if such deficiencies are found. The Vessel Operations Manager should make reasonable efforts to see that the inspection process is implemented and that deficiencies are corrected in a timely manner as appropriate.

RCP-8.5-2

4.2 The General Manager, Vessel Operations Manager and President should make reasonable efforts to attend various seminars, meetings, training sessions, etc. as are reasonably available during the year in order to remain current with regulatory issues.

4.3 The company is a member of AWO. Because of this membership, the

company has access to current information concerning various types of federal regulatory activity through AWO meetings and newsletters. This membership enhances our ability to achieve compliance with new regulations in a timely manner. The Vessel Operations Manager and General Manager should make reasonable efforts to use these services.

4.4 Members of company management should maintain ongoing relationships

with the company legal advisors and marine consultants and receive current information concerning new issues affecting company operations as these new issues arise. Reasonable efforts should be made to make use of these resources.

4.5 The members of the management team should make reasonable efforts

to conduct an annual review of company policies and procedures to establish that appropriate additions, deletions, or corrections, affecting regulatory compliance, have been made to the program.



RCP-8.6-1


Title:

VENDOR SAFETY POLICY

Issue Date:





Page:

1 of 1 1.0 PURPOSE:

To provide guidelines for selecting subcontractors that provide towing or vessel assist services.

2.0 SCOPE: This applies to the selection of subcontractors that provide towing or vessel assist services.

3.0 RESPONSIBILITY: The Vessel Operations Manager should make reasonable efforts to see that this policy is complied with.

4.0 PROCEDURE: Upper River Services (URS) does not hire nor have any subcontractors that provide towing or vessel assist services.



RCP-8.7-1


Title:

QUALIFICATIONS AND TRAINING REQUIREMENTS FOR PERSONS CONDUCTING IN HOUSE INSPECTIONS

Issue Date:





Page:

1 of 2

1.0 PURPOSE:

This procedure describes the qualifications and training requirements for persons responsible for conducting in-house inspections.

2.0 SCOPE:

This procedure is applicable to all Upper River Services (URS) personnel involved in the in-house inspection process.

3.0 RESPONSIBILITY:

3.1 The Vessel Operator, Vessel Operations Manager and Port Engineer are

responsible for conducting in-house inspections. 3.2 The Vessel Operations Manger should make reasonable efforts to train

the appropriate personnel, ensuring that they meet the necessary requirements for the conduction of in-house inspections.

4.0 PROCEDURE:

4.1 Qualifications

4.1.1 Must have working knowledge of the vessel and its operating systems.

4.1.2 Knowledge of company policies and vessel requirements. 4.1.3 General knowledge of U.S. Coast Guard regulations and other

federal requirements. 4.1.4 Must meet company qualifications for job position.

RCP-8.7-2

4.2 Training

4.2.1 Employees conducting in-house inspections should receive on-the-job training as he/she advances through various job classes.

4.2.2 Personnel should be initially trained on inspection process and

procedures by the Vessel Operator, Vessel Operations Manager or Port Engineer.

4.2.3 Additional training should be provided as needed to maintain

proficiency. 4.2.4 URS management should provide updated inspection and

regulatory requirements as they become available. These should be provided to employees through memos and company meetings or in the form of revised inspection forms, as appropriate.



RCP-8.8-1


Title:

INSPECTION PROCEDURES

Issue Date:





1 of 3 1.0 PURPOSE:

To help maintain company vessels in a safe manner. 2.0 SCOPE:

Two types of safety inspections should be utilized to see that Upper River Services (URS) vessels are maintained in a safe manner. These inspections should be in addition to the routine checking of safety and work conditions usually performed by each supervisor.

3.0 RESPONSIBILITY:

The Vessel Operations Manager should make reasonable efforts to see that safety inspections are completed on time and in the appropriate manner.

4.0 PROCEDURE:

4.1 INFORMAL WALKABOUT:

4.1.1 The Vessel Operator should make a daily tour of their vessel and determine the overall safety conditions which exist. Items to be checked include, but are not limited to the following:

4.1.1.1 General housekeeping; 4.1.1.2 Immediate hazardous conditions; 4.1.1.3 Engine room; and, 4.1.1.4 Any other areas the Vessel Operator deems

important.

4.1.2 A discussion of the findings from these informal inspections should be discussed at the Employee Safety and Health Committee meetings.

RCP-8.8-2

4.2 FORMAL WRITTEN INSPECTIONS:

4.2.1 Each month, the Vessel Operator should make reasonable efforts to see that a thorough safety inspection is completed using the written vessel specific safety inspection checklist as a guide and actually checking each item on the checklist. The inspector should then fill in the deficiency column on the inspection log.

4.2.2 A copy of this inspection log should be maintained in the work area

until the deficiencies are corrected or the next month’s inspection log is completed.

4.2.3 By the last day of the month following the inspection, the

designated inspector should see that the corrective actions, date of correction and the person’s initials that made the correction, are recorded on the inspection log for each vessel, and send the completed log to the Vessel Operations Manager. Any uncorrected deficiencies should be carried over to the next month’s inspection log.

4.2.4 URS expects employees to conduct the safety inspection in the

manner intended.

4.2.5 Members of the Employee Safety and Health Committees should review inspection results during the next Employee Safety and Health Committee meeting.

4.2.8 The Vessel Operations Manager or his/her designate should keep a

copy of the vessel specific safety inspection and records of deficiencies corrected for the appropriate period of time. The ”INSPECTION LOGS” will be completed and maintained in the appropriate work area, until all noted deficiencies are corrected, or until the next month’s inspection is completed. Uncorrected deficiencies should be moved to the next month’s inspection log.

4.2.9 At the completion of each month’s inspection cycle, the Vessel

Operations Manager or his/her designate should log the name of each vessel inspected that month and the date of the inspection on the “Summary of Inspections” form (this form is located at the end of this procedure).

RCP-8.8-3

5.0 RECORDS:

5.1 Inspection logs should be kept until all noted deficiencies are corrected or until the next month’s inspection is completed.

5.2 Completed inspection checklists should be kept on file for one month.

5.3 The “Summary of Inspections Form” should be kept on file indefinitely.

6.0 APPENDICES:

Summary of Inspections Form 7.0 REVISION HISTORY:


SUMMARY OF INSPECTIONS

EQUIPMENT NAME INSPECTOR’S NAME DATE OF INSPECTION

April 14, 2014

RCP-9.1-1

LEVELS OF AUTHORITY

Title:

SHORE

ORGANIZATION

Issue Date:

April 14, 2014

Last Revised:

February 20, 2015

Procedure Number:



Page:

1 of 2

1.0 PURPOSE: This policy outlines the principal responsibilities and authorities of the management team of Upper River Services (URS).

2.0 SCOPE:

This procedure is applicable to all URS shore side personnel.

3.0 RESPONSIBILITY: 3.1 The Vessel Operations Manager is responsible for maritime safety and

environmental compliance and for overseeing all URS vessel operations. 3.2 The Dispatchers exercise general oversight of vessels owned and/or

operated by URS. As such they are responsible for scheduling and dispatching vessels owned and chartered by the company.

3.3 The Crew Manager is responsible for crewing all URS vessels. 3.4 The Port Engineer of URS arranges and supervises the major

modifications of existing vessels, carries out research and testing of equipment and related practices, and provides advice on mechanical matters relating to the construction and operation of vessels.

3.5 The General Manager furnishes advice and guidance on employee

relations, practices, and procedures. The General Manager is the designated person with direct access to the President.

3.6 The President exercises general oversight of all operations, and provides

general supervision of all other shore side personnel. 3.7 There are other units in the company that are necessary for the marine

operation. These units generally do not have a direct interface with vessel personnel and the details of such groups are therefore not included herein.

RCP-9.1-2


0 Initial issue April 14, 2014 1 First revision – Revised paragraph 1.0, added paragraph 3.6 and renumbered February 20, 2015

RCP-9.2-1

LEVELS OF AUTHORITY

Title:

VESSEL OPERATOR

Issue Date:

April 14, 2014

Last Revised:

February 20, 2015

Procedure Number:



Page:

1 of 6

1.0 PURPOSE: This policy outlines the principal responsibilities of the Vessel Operator.

2.0 SCOPE:

This procedure is applicable to all Upper River Services (URS) Vessel Operators.

3.0 AUTHORITY: The Vessel Operator is the Master of the vessel.

4.0 QUALIFICATIONS: A Vessel Operator must have a current and valid U.S. Coast Guard license as Master of Towing Vessels upon Western Rivers, a valid and current Transportation Worker Identification Credential (TWIC), a current radar endorsement and a valid FCC Restricted Radiotelephone Operator’s Permit.

5.0 RESPONSIBILITY: 5.1 As a member of the URS supervisory team, each Vessel Operator should

make reasonable efforts to know, follow, and implement Safety Program rules, procedures, and policies. Likewise, each Vessel Operator should make reasonable efforts to train, instruct, and supervise employees regarding the safety requirements of tasks being carried out in the work area or on company vessels.

5.2 General responsibilities

5.2.1 The Vessel Operator is responsible for the safe and efficient operation and performance of his crew, vessel and tow, and for making a reasonable effort to keep the equipment neat, clean, and in good working order. The Vessel Operator must also make a reasonable effort to comply with company policies and rules, and federal and state laws and regulations.

RCP-9.2-2

5.2.2 The Vessel Operator must report to the office all violations of URS policy or violations of federal, state, or local laws.

5.2.3 The Vessel Operator must comply with the U.S. Coast Guard

Navigation Rules (Rules of the Road). 5.3 Personnel responsibilities

5.3.1 The Vessel Operator must instruct every crewmember to be courteous to all people at fleets, docks, locks, etc.

5.3.2 The Vessel Operator must instruct all crewmembers of their

respective duties in case of an emergency. 5.3.3 The Vessel Operator must delegate daily assignments and work

orders to crewmembers, and direct the activity of crewmembers to perform duties according to company policy, federal and state laws and regulations.

5.3.4 The Vessel Operator must manage and monitor the performance of

crewmembers, and must assign, responsibly direct, discipline and resolve concerns of all crewmembers.

5.4 Equipment responsibilities

5.4.1 The Vessel Operator must make, at a minimum, daily visual inspections of heads, the galley, engine room, and all other areas to ensure the boat is neat, clean, orderly and in working condition.

5.4.2 The Vessel Operator must ensure that all barges are inspected and

in navigable condition and must report any deficiencies to the office. Damaged barges must be reported immediately and appropriate measures taken to ensure their safety.

5.5 Operational responsibility

5.5.1 Master’s Daily Log

5.5.1.1 It is the responsibility of the Vessel Operator to maintain the Master’s Daily Log completely with accurate times and barge names and see that it is turned into the office at the end of each watch.

5.5.1.2 Note any trash removed from the vessel during that watch.

RCP-9.2-3

5.5.2 Crew Injury and Illness Reports

5.5.2.1 The Vessel Operator will report all personal injuries or illnesses of crewmembers or any illness occurring on his/her vessel on an the Vessel Accident/Incident Report as soon as he becomes aware of such injury or illness.

The Vessel Operator will report any serious personal injury/illness or fatality to the main office. Remember that mobile phones and radios are not private.

5.5.2.2 Report by radio any other personal injuries or

illnesses which in the Vessel Operator’s opinion warrant such action. This verbal report does not relieve the Vessel Operator of the obligation to submit the Vessel Accident/Incident Report. In addition, the Vessel Operator should enter the incident in the Master’s Daily Log and have the injured party sign or initial the entry, if possible.

5.5.3 Accident reports

5.5.3.1 The Vessel Operator will report all accidents resulting

in actual or possible damage to any URS tow or boat, other vessel or tows, fixed objects such as bridges, docks or locks, other objects such as buoys, or damage which results in cargo loss, contamination, spills or pollution on the Vessel Accident/Incident Report form. Groundings and wheel foulings should be reported, regardless of the extent of damage.

5.5.3.2 Serious accidents, such as collisions with other vessels or tows, which seriously disrupt the voyage and result in the grounding, sinking, or overturning of the barge, cargo loss, pollution, or major fire should be reported on VHF radio. This verbal report does not relieve the Vessel Operator of the obligation to submit the Vessel Accident/Incident Report form.

5.5.3.3 The Vessel Operator should enter the incident in the Master’s Daily Log.

5.5.3.4 The original report should be turned in to the main office. The Vessel Operator should retain a copy of the Vessel Accident/Incident Report form should any future developments on the incident occur.

RCP-9.2-4

5.5.4 Ordering supplies

5.5.4.1 Before placing orders for supplies the Vessel Operator should determine the need and the necessity of each item.

5.5.4.2 The Vessel Operator must sign off on all Supply Order Forms.

5.5.5 The Vessel Operator is responsible for coordinating and managing

barge movement with dispatchers, other company vessels and other company departments.

5.6 Safety responsibilities

5.6.1 The Vessel Operator is responsible for the following:

5.6.1.1 Having a fire hose with a nozzle at each fire station, if applicable;

5.6.1.2 Checking to make certain that dewatering pumps are on board the vessel and ready to used;

5.6.1.3 Having an adequate number of approved Type 1 life preservers in good condition on board;

5.6.1.4 Checking to make certain that there is an adequate quantity of first aid supplies onboard the vessel;

5.6.1.5 Making a reasonable effort to ensure all crewmembers are properly trained in emergency procedures, including participating in all drills and safety briefings;

5.6.1.6 Making a reasonable effort to expose all crewmembers to the contents of the Deckhand’s Manual and the safety regulations in this manual, and that all crewmembers adhere to these regulations;

5.6.1.7 Checking with each crewmember for acknowledgment in the appropriate use of Personal Protective Equipment when necessary;

5.6.1.8 Conducting monthly drills in accordance with URS policies and procedures;

5.6.1.9 Requires employees to comply with the Safety Program in his/her work area or on company vessels,

5.6.1.10 Uses opportunities such as safety meetings and new employee safety orientations to stress the importance of accident prevention as a matter of employee welfare, as a part of safe and efficient operations;

5.6.1.11 From time to time, serve as a member of the Safety Committee and participate in its activities;

RCP-9.2-5

5.6.1.12 Supports management on any Safety Program enforcement issues;

5.6.1.13 Sets the proper example for employees by demonstrating a positive attitude toward safety awareness, by complying with safety rules, regulations and policies, and by supporting company safety activities;

5.6.1.14 In all company activities, understands that accident prevention is necessary for the safe, efficient operation of the company;

5.6.1.15 Being accountable for the accidents and injuries in his/her areas of responsibility;

5.6.1.16 Having a thorough knowledge of hazards which may be present in operations of his/her and know how these hazards may be controlled;

5.6.1.17 Instructing employees under his/her supervision in the safe and proper way to perform their work;

5.6.1.18 Immediately correcting any improper or unsafe work habit; and

5.6.1.19 Making certain that each crewmember is aware of any potential dangerous cargos in tow and has an understanding of any hazards associated with said cargo.

5.7 The Vessel Operator must be able to perform duties immediately, and

must be able to perform the functions of any job on the vessel.

6.0 WORK ENVIRONMENT AND PHYSICAL DEMANDS:

6.1 The Vessel Operator primarily operates from the wheelhouse, but must also be able to work outside in varying temperatures, weather conditions and daylight or darkness.

6.2 The Vessel Operator must be able to:

6.2.1 Communicate clearly in English using a radio, speaker or other electronic means;

6.2.2 Write in English and read in English proficiently and clearly; 6.2.3 Tolerate repetitive and prolonged postures involving standing,

sitting, twisting, squatting, kneeling and stooping, and reaching to full range from above the head to the deck;

RCP-9.2-6

6.2.4 Frequently use one and two hands throughout the work period for grasping and clutching the controls of the vessel;

6.2.5 Climb ladders, stairwells and pushknees; 6.2.6 Lift and carrying objects ranging from less than 10 lbs. to weights in

excess of 100 lbs; and 6.2.7 Wear personal protective equipment in accordance with the PPE

Policy.

7.0 WORK SCHEDULE: During the navigation season (early Spring to late Fall) shifts are 12 hours per day, day or night, seven days per week. Personal time off is at the discretion of the Crew Dispatcher.


0 Initial issue April 14, 2014 1 First revision – Revised paragraphs 4.0, 5.2.1, 5.6.1.5, and 5.6.1.18 and added paragraphs 5.3.3, 5.3.4, 5.5.5, 5.6.1.19, 5.7, 6.0 and 7.0 February 20, 2015

RCP-9.3-1

LEVELS OF AUTHORITY

Title:

DECKHAND

Issue Date:

April 14, 2014

Last Revised:

February 20, 2015

Procedure Number:



Page:

1 of 3

1.0 PURPOSE: This policy outlines the principal responsibilities of the Deckhand.

2.0 SCOPE:

This procedure is applicable to all Deckhands on board Upper River Services (URS) vessels.

3.0 RESPONSIBILITY: 3.1 Deckhands have the authority under the direction of the Vessel Operator

to carry out the following duties. 3.2 The Deckhand is directly responsible and accountable to the Vessel

Operator, working directly under him and following his/her instructions. 3.3 The Deckhand is primarily accountable for his/her own health, safety, and

cleanliness. He/she must be familiar with URS policies, procedures, safety rules and regulations, and must abide by them at all times.

4.0 DUTIES: 4.1 Deckhand duties vary from vessel to vessel and from watch to watch.

Those duties may include, but are not limited to, the following:

4.1.1 Operational duties

4.1.1.1 Making up the tow; 4.1.1.2 Dropping, spotting, and switching barges at docks; 4.1.1.3 Assisting the vessel and tow in making locks; 4.1.1.4 Standing lookout, or riding the head of the tow as a

lookout as directed by the Vessel Operator; 4.1.1.5 Performing the various tasks necessary to carry out

the above, such as making a coupling, operating winches and ratchets, and line handling including splicing and throwing lines;

4.1.1.6 Dewatering the barge as necessary;

RCP-9.3-2

4.1.1.7 Placing running lights about the tow as required for save navigation, and maintaining a vigil to ensure their operation; and

4.1.1.8 Examining and repairing lines and wires used to lash and moor vessel.

4.1.2 Maintenance duties

4.1.2.1 Chipping and painting the vessel; 4.1.2.2 Shingling minor cracks in barges after obtaining office

permission to enter any void tank in accordance with the URS Confined Space Entry procedure; and,

4.1.2.3 Other equipment maintenance as needed.

4.1.3 Housekeeping duties

4.1.3.1 Maintaining the cleanliness of the vessel. This includes, but is not limited to, cleaning all floor areas; emptying trash cans; cleaning galley stove, freezers, and refrigerators; cleaning shower stalls, sinks and toilets; polishing all brass; dusting furniture and shelving; laundering of bed linen and towels; and cleaning walls, ceilings and windows; and

4.1.3.2 Performing other cleaning chores as directed by the Vessel Operator.

4.1.4 Safety duties

4.1.4.1 Reporting any hazardous or unsafe condition to the

Vessel Operator and making “on-the-spot” corrections when capable.

4.1.5 Other duties as directed by the Vessel Operator or his relief.

4.2 The Deckhand must be able to perform essential functions training guide within 30 days.

5.0 WORK ENVIRONMENT AND PHYSICAL DEMANDS:

5.1 The Deckhand must work outside on barges in varying temperatures, weather conditions and daylight or darkness. Commitment to shift completion is required except for emergencies.

5.2 The Deckhand must be able to:

RCP-9.3-3

5.2.1 Climb ladders and stairs; 5.2.2 Enter confined spaces; 5.2.3 Tolerate repetitive bending and stooping, lifting heavy equipment,

and walking on steel decks for extended periods of time; 5.2.4 Lift and carry objects ranging from less than 10 lbs. to weights in

excess of 100 lbs. Average weight to be lifted is a minimum of 50 lbs.;

5.2.5 Lift and use heavy equipment and tools from various levels; and 5.2.6 Wear personal protective equipment in accordance with the PPE

Policy.

6.0 WORK SCHEDULE: During the navigation season (early Spring to late Fall) shifts are 12 hours per day, day or night, seven days per week. There are occasional days in excess of 12 hours. Personal time off is at the discretion of the Crew Dispatcher.


0 Initial issue April 14, 2014 1 First revision – Revised paragraph 4.1.3.1, removed paragraph 4.1.3.2, added paragraphs 4.1.1.6, 4.1.1.7, 4.1.1.8, 4.2, 5.0 and 6.0, renumbered as appropriate February 20, 2015

RCP-10.1-1

PERSONNEL POLICIES

Title:

HIRING POLICY

Issue Date:

April 14, 2014

Last Revised:

February 20, 2015

Procedure Number:



Page:

1 of 3

1.0 PURPOSE: This policy establishes procedures to be followed by the General Manager and Crew Manager in interviewing and reviewing potential applicants for positions as crewmembers on Upper River Services (URS) vessels.

2.0 SCOPE:

This procedure applies to all URS vessel personnel.

3.0 RESPONSIBILITY: 3.1 The Crew Manager is responsible for:

3.1.1 Receiving applications from potential applicants; 3.1.2 Mailing out applications to potential candidates; 3.1.3 Reviewing applications when received; 3.1.4 Reviewing and researching the job history of applicants; 3.1.5 Conducting personal interviews; and, 3.1.6 Scheduling physical exams and drug screens.

3.2 The General Manager is responsible for:

3.2.1 Reviewing all applications for final approval before a personal interview is scheduled;

3.2.2 Sending out criminal background check requests; 3.2.3 Receiving and documenting the results of applicants’ physical

exams, drug screens, and criminal background checks; 3.2.4 Reviewing physical exam results;

RCP-10.1-2

3.2.5 Reviewing qualified applicants for placement; 3.2.6 Reviewing criminal background check results; and, 3.2.7 Sending results of qualified employees to the Crew Manager for

scheduling of initial training.

4.0 PROCEDURES: 4.1 Receive completed application from potential applicant. 4.2 To be considered for a position as a crewmember, an applicant must

meet the following criteria:

4.2.1 Be 18 years of age or older; and, 4.2.2 No untreated drug or alcohol related problems or incomplete DOT

required drug or alcohol treatment programs over the past three years.

4.3 Review applications. Research work history. 4.4 Submit application to General Manager for approval to schedule a

personal interview. 4.5 Initiate criminal background check (completed by Minnesota Employers

Association). 4.6 Conduct personal interview.

4.6.1 Explain job description. 4.6.2 Discuss salary. 4.6.3 Discuss company benefits.

4.7 Evaluate application. Discuss evaluation with General Manager. 4.8 Offer the applicant a conditional offer of employment or notify the

applicant that he or she does not qualify. 4.9 Schedule physical exam and drug screen.

RCP-10.1-3

4.10 Send out “Release of Information Form – Drug and Alcohol Testing” to all former DOT covered employers. A log of all requests will be kept on file in the General Manager’s office along with a copy of the request.

4.11 Review physical exam and drug screen results upon receipt from Clinic. 4.12 Review criminal background check results. Criminal background checks

are performed on prospective employees after the General Manager has approved the applicant for an interview. Because of the different states and counties involved, there is no specific time frame for receiving the results of a criminal background check. Prospective employees will be hired prior to receipt of a background check. Upon review by the General Manager, appropriate action will be taken.

4.13 Notify applicant that he/she does or does not qualify for employment. 4.14 Schedule new hire training for prospective crewmember. 4.15 A New Employee Check List should be completed for each new hire.

5.0 RECORDS:

The completed New Employee Check List should be kept in the employee’s personnel file for their length of employment plus three years.

6.0 APPENDICES:

New Employee Check List


0 Initial issue April 14, 2014 1 First revision – Added paragraphs 4.15, 5.0 and 6.0 February 20, 2015

New Employee Check List EMPLOYEE NAME: _________________________________ Date: ___________ Date Initial

________ ________ Application

________ ________ Job Description

________ ________ Interviewed By

________ ________ Contingent Job Offer

________ ________ MRA Release and Pre-employment Drug Screen Release Signed

________ ________ Physical Scheduled

________ ________ Results of Physical / Drug Screen Results

________ ________ Background Check Completed

________ ________ Scheduled Start Date (Paperwork/Videos)

___________________________________________________________________________________________________

________ ________ Employment Eligibility Information (I-9)

________ ________ W-4 Filled Out

________ ________ Payroll Information Sheet

________ ________ Emergency Contact Form

________ ________ Direct Deposit Form

________ ________ Drug Policy Received / Acknowledgement Form Returned

________ ________ Employee Handbook received / Acknowledgement Form Returned

________ ________ No-Fault Attendance Policy Received / Acknowledgement Form Returned

________ ________ Deckhand Development Program Booklet Received / Acknowledgement Form Returned

________ ________ Conduct & Working Environment Policy Received

________ ________ Electronic Media Use Policy Received / Acknowledgement Form Returned

________ ________ Sexual Harassment Policy Received / Acknowledgement Form Returned

________ ________ Boot Slip / Gear Bag / Equipment Checklist

________ ________ Safety Training – Orientation Completed

___________________________________________________________________________________________________

________ ________ Time Card for Training (Turned into Payroll)

________ ________ Employee Status Change Form / Employee Number Created

________ ________ VGP, SINEX, TowWorks, TalentLMS, and Employee Portal Usernames and Passwords

________ ________ Benefits Information & Forms Received

________ ________ Benefits Eligibility Date ___________ (1st of month following 60 days)

February 20, 2015

RCP-10.2-1

PERSONNEL POLICIES

Title:

DRUG AND ALCOHOL POLICY

Issue Date:





Page:

1 of 31 1.0 PURPOSE:

Upper River Services (URS) has established this alcohol and controlled substances testing program for those crewmembers who are providing service on vessels owned and/or operated by URS, to meet requirements of the U.S. Department of Transportation. The overall goals of this testing program are to ensure a safe and drug-free transportation environment, to reduce the potential for accidents and casualties related to accidents involving Company-owned/operated vessels, and to cooperate with the U.S. Department of Transportation and the transportation industry in efforts to eliminate the misuse of alcohol and the illegal use of controlled substances in the shipping industry. With these objectives in mind, URS has established the following policy and procedures for DOT-covered crewmembers with regard to drugs and alcohol, as well as those circumstances under which testing for drugs and alcohol will be required. Full compliance with this policy is a condition of employment with URS.

2.0 SCOPE:

This constitutes URS’ Drug and Alcohol Policy for DOT-Covered Crewmembers. It applies to all full-time, part-time and temporary crewmembers of the Company who are “covered crewmembers” as defined in Section 3.5.2. In addition, this policy covers all job applicants for such positions as are described in Section 3.5.4.2 below. In circumstances that are not addressed by DOT regulations or in this policy, DOT-covered employees are subject to rules and testing as defined in this Company’s Drug and Alcohol Policy for Employees.

3.0 POLICY: 3.1 Employees who are aware or concerned that they may need help or

rehabilitation for drug and/or alcohol problems are encouraged to contact URS’ Employee Assistance Program (EAP) for referral to resources and assistance. URS would consider such inquiry to be confidential, and without consequence.

RCP-10.2-2

3.2 An individual who violates the prohibitions of this policy will be immediately removed from service in accordance with Department of Transportation rules and regulations, and, under URS’ independent authority, will be subject to disciplinary action up to and including termination of employment. URS also reserves the right to take action against an employee, where appropriate, for violation of other general Company policies, procedures and/or rules, defined in rules which are separate from this policy for DOT-covered crewmembers.

3.3 Rules of Conduct

3.3.1 A covered crewmember may not engage in any of the conduct(s) prohibited in Section 3.5.3 below.

3.3.2 The possession or consumption of alcohol by crewmembers while

aboard a vessel owned or operated by URS is strictly prohibited. 3.3.3 The use of any over-the-counter medication by a crewmember on

duty is prohibited if such use may detrimentally affect or impair the safety of coworkers, customers or members of the public, or the crewmember’s ability to safely perform job duties and assignments.

3.3.4 An individual who uses prescribed medication(s) will not be

permitted or required to perform duties until and/or unless URS is provided with appropriate authorization from the licensed medical professional who prescribed the medication(s). [See Section 3.4 below]

3.3.5 Cases of suspected trafficking, possession or use of illegal

substances or drug paraphernalia on URS vessels and/or premises, including parking lots, may be referred to law enforcement authorities.

3.3.6 URS encourages employees who wish to voluntarily seek

assistance for questions or problems related to drugs and alcohol to so do without fear of job loss or other retaliation. DOT-covered employees who seek assistance voluntarily, without having violated DOT regulations, and who return to work after rehabilitation will not be subject to mandated DOT follow-up testing related to that particular occurrence.

RCP-10.2-3

3.3.7 If a crewmember is concerned about drug and alcohol use by a coworker at work, or of drug trafficking, or of safety or job performance as it relates to another crewmember’s drug and alcohol use, including managers and supervisors, such concern may be reported confidentially to his/her immediate supervisor, or to the Vessel Operations Manager or General Manager, without fear of recrimination or reprisal by the Company.

3.3.8 URS considers a conviction for criminal drug activity to be very

serious. The conviction of any employee for the illegal sale or possession of any controlled substances may result in disciplinary action, up to and including termination, to the extent that URS, in its sole discretion, determines that such conviction or any other off-duty involvement with illegal substances reflects adversely on the Company or is otherwise detrimental to the Company’s best interests. An employee who receives a conviction for a criminal drug statute must report that conviction to the Vessel Operations Manager or the General Manager within five (5) days of receiving it. An employee who fails to report such a conviction will, upon the Company’s discovery of the conviction, be immediately terminated from employment and is ineligible for rehire.

3.3.9 URS reserves the right to test a DOT-covered employee for

alcohol or controlled substance use under the Company’s independent authority when DOT regulations do not apply. In that case, testing levels would be identical to DOT levels, but the test would be conducted as a non-DOT test. An employee who tests positive under these circumstances would be required to comply with the recommendations of the EAP. Failure to cooperate with the assessment process or failure to comply fully with the assessment recommendations will result in termination, under URS’ independent authority.

3.4 Authorized Use of Controlled Substances

3.4.1 If an individual undergoes prescribed medical treatment with a

drug or controlled substance, the individual is expected to report this treatment to the Vessel Operations Manager or the General Manager.

RCP-10.2-4

3.4.2 URS requires an individual to make such notification as soon as possible, and prior to boarding a vessel to perform any safety-sensitive function. In order to conduct duties on board the vessel and continue to take the prescribed medication(s), the individual must provide written documentation from the prescribing licensed medical practitioner that the medication(s) and dosage level is consistent with the safe performance of the crewmember’s duties. The physician who provides this documentation must be familiar with the crewmember’s assigned duties and with the individual’s available and pertinent medical history. If the individual is receiving medical treatment/care from more than one medical practitioner, the individual must inform the practitioner who prepares the written documentation of all medications prescribed.

3.4.3 URS reserves the right to obtain an independent medical opinion

regarding the potential effects of a prescription or over-the-counter drug on an individual's ability to perform safety-sensitive functions or other aspects of his/her job. Further, URS reserves the right to place any employee who is taking medication(s) on time off without pay pending a decision as to whether the individual may continue to perform his/her regular job duties while taking the medication(s).

3.5 Testing For Controlled Substances and Alcohol

3.5.1 URS will conduct controlled substance and alcohol testing of its

applicants and its crewmembers in compliance with regulations established by the U.S. Department of Transportation (DOT), 33 CFR Part 95 and 46 CFR Parts 4, 16.

3.5.2 Covered Crewmembers

3.5.2.1 In accord with U.S. Department of Transportation and USCG Regulations, an individual subject to drug and alcohol testing is any individual who is performing duties related to the vessel's safety:

• Who is on board a vessel that is acting under the

authority of a license, certificate of registry, or merchant mariner’s document, whether or not the individual is a member of the Company’s vessel’s crew;

RCP-10.2-5

• Who is engaged or employed on board a vessel that is owned in the United States, and that is required by law or regulation to engage, employ, or be operated by an individual holding a license, certificate of registry, or merchant mariner’s document.

3.5.2.2 Exceptions to this definition are:

• Individuals on fish processing vessels who are primarily employed in the preparation of fish or fish products, or in a support position, and who have no duties that directly affect the safe operation of the vessel;

• Scientific personnel on an oceanographic research vessel;

• Individuals on industrial vessels who are industrial personnel; and,

• Individuals who have no duties that directly affect the safe operation of the vessel.

3.5.3 DOT Prohibitions:

3.5.3.1 While on board a vessel inspected, or subject to inspection, under Chapter 33 or Title 46 United States Code, a crewmember (including a licensed individual), pilot, or watchstander who is not a regular member of the crew:

• Shall not perform or attempt to perform any

scheduled duties within four (4) hours of consuming any alcohol (including medications that contain alcohol);

• Shall not be intoxicated at any time; • Shall not consume any intoxicant while on watch

or duty; • May consume a legal non-prescription or

prescription drug only if the drug does not cause the individual to be intoxicated;

• Shall not report for duty or remain on duty while having an alcohol concentration of 0.04 or greater.

• Shall not refuse to submit to a post-accident, random, reasonable suspicion, or follow-up chemical test.

RCP-10.2-6

• Shall not report for duty, remain on duty, or perform safety-sensitive functions if he/she tests positive for controlled substances.

3.5.4 Tests Required

3.5.4.1 As provided in U.S. Department of Transportation

rules and regulations, an individual who provides safety-sensitive function on a commercial shipping vessel shall be subject to pre-employment, random, and follow-up testing (drug only), and reasonable cause and post-accident testing for alcohol and drugs.

3.5.4.2 Pre-employment Testing

• Every applicant will be asked whether he/she has tested positive, or refused to test, on any DOT pre-employment drug or alcohol test for a DOT employer during the past two years. An applicant who has previously tested positive, or refused to be tested, will not be considered for employment until or unless he/she successfully completes DOT's return to duty process. (See Section 3.8 below).

• URS will not engage or employ any individual to serve as a crewmember unless and until that individual passes a chemical test for dangerous drugs.

• An individual/applicant is not required to submit to a urine drug test if:

o URS can verify that the individual has

previously participated in a valid drug testing program (that meets the requirements of DOT rules and regulations), passed a chemical test for dangerous drugs within the previous six (6) months, and has had no subsequent positive drug tests during the remainder of the six-month period; or

o During the previous 185 days, the individual has been subject to a random testing program (that meets the requirements of DOT rules and regulations) for at least 60 days, and did not fail or refuse to participate in any DOT-required chemical test.

RCP-10.2-7

• If the individual is a new hire, the testing must occur before the individual’s first day in a duty status. If the test result is positive, the job offer will be immediately withdrawn, and the applicant will be provided with the names, addresses and phone numbers of qualified SAPs.

• If an applicant holding a license, certificate of registry, or merchant mariner’s document fails a chemical test for dangerous drugs, URS will report the test results in writing to the nearest Coast Guard Officer in Charge, Marine Inspection (OCMI), as required by 46 CFR Part 16.201(c). The individual shall be subject to suspension and revocation proceedings against his/her license, certificate of registry, or merchant mariner’s document, under 46 CFR Part 5.

3.5.5 Mandatory Testing Following a Serious Marine Incident (SMI)

3.5.5.1 When URS determines that a casualty or incident is,

or is likely to become, a SMI, the Company shall take all practicable steps to have each individual engaged or employed on board the vessel who is directly involved in the incident chemically tested for evidence of drug and alcohol use. The term individual directly involved in a serious marine incident is an individual whose order, action or failure to act is determined to be, or cannot be ruled out as, a causative factor in the events leading to or causing a SMI.

3.5.5.2 If a law enforcement officer determines that additional individuals are directly involved in the serious marine incident, URS shall take all practicable steps to have those individuals also tested.

3.5.5.3 An individual who has been identified for required testing related to a serious marine incident may continue to perform duties in the aftermath of the incident when his/her performance is necessary to respond to safety concerns directly related to the incident, except when a trained supervisor has knowledge or suspicion of the individual’s use of alcohol or controlled substances, in which case the individual will not be permitted or requested to perform safety-sensitive function.

RCP-10.2-8

3.5.5.4 Alcohol testing must be conducted within two (2) hours of when the SMI occurred, unless precluded by safety concerns directly related to the incident. If such concerns prevent the alcohol testing from being conducted within the required two (2) hours, then alcohol testing must be completed as soon as the safety concerns are addressed. After eight (8) hours, attempts to conduct alcohol testing shall cease. If alcohol tests were required, but were not conducted, the Company must document on Form CG-2692B (Report of Required Chemical Drug and Alcohol Testing Following a Serious Marine Incident) the reason(s) why the testing was not conducted.

3.5.5.5 The ship may carry a supply of saliva-specimen collection kits, readily accessible for use following a SMI. The ship is not required to carry such kits if it is possible to obtain those kits and conduct the required test within two (2) hours from the time of the occurrence of a SMI.

3.5.5.6 Drug testing must be conducted within thirty-two (32) hours of when the SMI occurred, unless precluded by safety concerns directly related to the incident. After thirty-two (32) hours, attempts to conduct drug testing shall cease. If drug tests were required, but were not conducted, the Company must document on Form CG-2692B (Report of Required Chemical Drug and Alcohol Testing Following a SMI) the reason(s) why the testing was not conducted.

3.5.5.7 The ship may carry a supply of urine-specimen collection and shipping kits, readily accessible for use following a serious marine incident. The ship is not required to carry such kits if it is possible to obtain those kits and collect the required urine specimens within thirty-two (32) hours from the time of the occurrence of a SMI.

3.5.5.8 When an individual engaged or employed on board a vessel dies as a result of a SMI, chemical testing will be conducted on blood and urine specimens obtained from the remains of the individual. URS will provide the specimen collection and shipping kit, and request the appropriate local authority or other custodian of the remains to assist in obtaining the necessary specimens.

RCP-10.2-9

3.5.5.9 If the local authority or custodian declines to cooperate in obtaining the necessary specimens, the Company will provide an explanation of the circumstances on Form CG-2692B.

3.5.5.10 If a chemical test following a SMI indicates the presence of alcohol, drugs, or drug metabolites, the individual’s use of drugs or alcohol will not be necessarily assumed to be the probable cause of that SMI. When chemical test results have been received, the Company shall submit a copy of the test results for each person listed on the Form CG-2692B to the Coast Guard Office in Charge, Marine Inspection (OCMI) to whom the CG-2692B was submitted.

3.5.5.11 URS may use alcohol-testing results from tests conducted by Coast Guard or local law enforcement personnel to satisfy the alcohol testing requirements, provided that the testing meets the requirements of this federal law. Under independent authority, the individual will be required to sign a release of information for URS to obtain those results.

3.5.6 Mandatory Testing Following a Marine Casualty

3.5.6.1 For each marine casualty required to be reported (46

CFR Part 4, Subpart 4.05-10), URS shall determine whether there is any evidence of alcohol or drug use by individuals directly involved in the casualty. Included in the Company’s written report, Form CG-2692, will be:

• Identification of those individuals for whom

evidence of drug or alcohol use, or evidence of intoxication, has been obtained; and

• The method by which such evidence was obtained, such as personal observation of the individual, or by chemical testing of the individual.

3.5.6.2 An entry shall be made in the Master Daily Log

pertaining to those individuals for whom evidence of intoxication is obtained. Each individual will be informed of this entry and the entry must be witnessed by a second person.

RCP-10.2-10

3.5.6.3 If an individual under this circumstance refuses to submit to, or cooperate in, the administration of a timely chemical test when directed by URS or by a law enforcement officer, this fact will be noted in the Master Daily Log and in the written report (Form CG-2692), and shall be admissible as evidence in any administrative proceeding.

3.5.7 Random Testing

3.5.7.1 A percentage of crewmembers will be subject to

random drug testing each year. (At the effective date of this policy, the minimum annual percentage is fifty [50] percent of the average number of crewmembers.) The annual rate for random drug testing may be adjusted, in accordance with DOT mandate. URS will conduct random tests at an annual rate not less than that specified by DOT, and reserves the right to test at a higher rate if it is deemed appropriate or if the method of selection does not allow for exact 50 percent selection.

3.5.7.2 Vessels of URS are uninspected vessels. Therefore, in accordance with USCG rules and regulations for uninspected vessels, URS will conduct random drug tests on crewmembers who:

• Are required by law or regulation to hold a license

issued by the Coast Guard in order to perform their duties on the vessel;

• Perform duties and function directly related to the safe operation of the vessel;

• Perform the duties and functions of patrolmen or watchmen; or,

• Are specifically assigned the duties of warning, mustering, assembling, assisting, or controlling the movement of passengers during emergencies.

3.5.7.3 URS will meet the requirements of random testing by

periodically selecting one or more vessels, and to then test all crewmembers on that vessel, provided that each vessel subject to this selection process remains equally subject to this selection mechanism at all times.

RCP-10.2-11

3.5.7.4 Random tests will be unannounced; the dates for random tests will be spread throughout the year.

3.5.7.5 An individual who is selected for random testing will be required to report to the collection site immediately upon notification. If the individual engages in conduct that does not lead to a collection as soon as possible after notification, such conduct may be considered as a refusal to submit to a test.

3.5.8 Reasonable Cause Testing

3.5.8.1 URS or a law enforcement officer shall require a

crewmember to submit to drug and/or alcohol testing for reasonable suspicion when that crewmember manifests physical or behavioral symptoms or reactions commonly attributed to the use of controlled substances or alcohol. Such crewmember conduct must be witnessed and documented by a supervisor who has been trained in compliance with DOT rules and regulations. Should a supervisor observe such symptoms or reactions, URS shall not allow that individual to continue to stand watch or perform other duties, the individual must be informed of the requirement to submit to testing, and the collection must occur as soon as is practicable.

3.5.8.2 Reasonable cause exists when either or both of the following occur:

• The individual was directly involved in the

occurrence of a marine casualty as defined in Chapter 61 of Title 46, United States Code (See Section 3.6, Marine casualty).

• The individual is suspected of being intoxicated.

3.5.8.3 When practicable, the determination of reasonable cause under 3.5.8.2 should be based on observation by two persons who have been trained in accordance with the regulations.

3.5.8.4 A law enforcement officer may direct an individual operating a vessel to undergo a chemical test when reasonable cause exists.

RCP-10.2-12

3.5.8.5 If an individual refuses to submit to or cooperate in the administration of a timely chemical test for reasonable cause when directed by a law enforcement officer, evidence of the refusal is admissible as evidence in any administrative proceeding, and the individual will be presumed to be intoxicated.

3.5.8.6 If an individual refuses to submit to or cooperate in the administration of a timely chemical test for reasonable cause when directed by URS, evidence of the refusal is admissible as evidence in any administrative proceeding.

3.5.9 Periodic testing

3.5.9.1 An applicant for an original issuance or a renewal of a

license or a certificate of registry (COR), a raise in grade of a license, a higher grade of COR, an original issuance of a merchant mariner’s document (MMD), the first endorsement as an able seaman, life boatman, qualified member of the engine department, or tankerman, or a reissuance of an MMD with a new expiration date shall be required to pass a chemical test for dangerous drugs.

3.5.9.2 An applicant shall provide the results of the test to the Coast Guard Regional Examination Center (REC) at the time of submitting an application. The test results must be completed and dated not more than 185 days prior to submission of the application. An applicant need not submit to testing if he or she is able to provide evidence as defined above, in 3.5.4.2, Pre-Employment Testing.

3.5.9.3 Each pilot who is required to receive an annual physical examination must pass a chemical test as a part of that examination. The individual shall provide the results of each test to the REC when the pilot applies for a license renewal or when requested by the Coast Guard.

RCP-10.2-13

3.5.10 Follow-up Testing

3.5.10.1 An individual who is returned to duty upon recommendation of the Medical Review Officer (MRO) is subject to unannounced follow-up alcohol and/or controlled substances testing as directed by the MRO. Follow-up testing may be scheduled for a period of up to sixty (60) months after the crewmember’s return-to-duty date.

3.5.10.2 The cost of all follow-up tests, as recommended by the MRO, will be borne by the individual.

3.5.10.3 If a newly-hired crewmember is subject to follow-up testing from a previous violation while working for a previous employer, that crewmember will be responsible for the cost of any remaining follow-up tests as required by the MRO, and such costs will be deducted from the individual’s next paycheck.

3.5.11 General Testing Information (Standards and Integrity of the

Testing Process)

3.5.11.1 Chemical testing will be conducted on urine, breath, saliva or blood specimens, and drug tests shall be conducted as specified in 49 CFR Part 40.

3.5.11.2 URS shall ensure that specimens for required tests will be collected as soon as practicable following a SMI.

3.5.11.3 URS shall ensure that the collection site is adequate to provide for the collection, security, temporary storage, and shipping of specimens to a certified drug-testing laboratory.

3.5.11.4 Procedures shall provide for the collection site to be secure during specimen collection.

3.5.11.5 No unauthorized personnel shall be permitted in any part of a collection site when specimens are collected, or into an area where specimens are stored.

3.5.11.6 Collection site personnel will take precautions to ensure that each specimen is not adulterated or diluted during the collection process.

3.5.11.7 Specimens not immediately prepared for shipment will be safeguarded during temporary storage.

RCP-10.2-14

3.5.11.8 When blood, breath, saliva and urine specimens are obtained, URS will ensure that the collection process is supervised by qualified collection personnel, by the Company, by a law enforcement officer, or by a representative named by the Company. For alcohol testing, a breath sample, if taken, will be collected and analyzed using an Evidential Breath Testing device (EBT) and operated by an individual who has been trained on that specific instrument; a saliva sample, if taken, will be collected and analyzed by an individual who has been trained to use that specific instrument, or a blood specimen, if taken, will be drawn only by qualified medical personnel.

3.5.11.9 All urine specimens for controlled substance testing and blood specimens for alcohol testing shall be analyzed by a laboratory that is approved by the U. S. Department of Health and Human Services (DHHS), and that observes applicable chain-of-custody procedures.

3.5.11.10 URS shall ensure that all specimens are promptly shipped to the testing laboratory. Blood specimens will be shipped in a cooled condition to ensure delivery within twenty-four (24) hours of receipt by the carrier.

3.5.11.11 An applicant or crewmember has the right to request and receive from URS a copy of the test result report on any drug or alcohol test for which he/she provided a urine, blood, saliva, or breath sample. The request, in writing, should be addressed to the Vessel Operations Manager.

3.5.11.12 Collection and testing procedures will be such as to protect the individual and the integrity of the testing process, safeguard the validity of the test results, and ensure that test results are attributed to the correct crewmember.

3.5.11.13 When a crewmember is required to obtain a medical examination by a medical specialist (related to inability to provide a sufficient breath or urine specimen), under our independent authority, the crewmember will be required to pay the costs associated with that examination.

RCP-10.2-15

3.5.12 Alcohol Testing and the Reporting of Alcohol Test Results

3.5.12.1 Breath alcohol tests (screening and confirmatory) will be performed on a device that appears on the National Highway Traffic Safety Administration’s (NHTSA) Conforming Products List (CPL) and that meets the DOT’s testing requirements.

3.5.12.2 For alcohol testing (screening and confirmatory), a breath sample will be collected and analyzed, using an Evidential Breath Testing device (EBT) and operated by an individual who has been trained on that specific instrument, or a saliva sample may be collected with an Alcohol Screening Device, by an individual who has been trained to operate the specific device that is being used.

3.5.12.3 If the confirmatory test is positive (0.04 and above BrAC), the individual conducting the test shall immediately forward the results to the Vessel Operations Manager.

3.5.12.4 An alcohol retest can be conducted only if the tested specimen was blood.

3.5.13 Controlled Substance Testing, the MRO process and Reporting of

Test Results

3.5.13.1 The DHHS-approved testing laboratory shall forward the results of every drug test (and alcohol tests on a blood specimen) to a Company-designated Medical Review Officer (MRO) for review to determine if there is a legitimate medical explanation.

3.5.13.2 If the test result is negative, the result will be reported by the MRO to the Vessel Operations Manager.

3.5.13.3 All controlled substance testing specimens shall be analyzed by a laboratory that is approved by the U.S. Department of Health and Human Services (DHHS), and that observes applicable chain-of-custody procedures.

3.5.13.4 When a specific time for an employee’s test has been scheduled, and the employee does not appear at the collection site at the scheduled time, the collection site personnel will contact our DER, who may determine that the employee has refused to be tested.

RCP-10.2-16

3.5.13.5 At the collection site, the employee will be required to empty his/her pockets and display the items in them. A refusal to empty all pockets as directed by the collector will be a refusal to be tested.

3.5.13.6 If a urine specimen temperature is outside the acceptable range (90 – 100 degrees F.), the collector must immediately require a new collection, under direct observation. An employee who refuses to provide a second specimen, or who refuses to permit a direct observation collection, will be determined to have refused to be tested.

3.5.13.7 The DHHS-approved testing laboratory shall forward the results of every drug test to a Company-designated Medical Review Officer (MRO) for review.

3.5.13.8 If the test result is negative, the result will be reported by the MRO to the Company’s DER.

3.5.13.9 If the test result is confirmed positive, adulterated, substituted or invalid, the employee will be given an opportunity to discuss the test result with the MRO.

3.5.13.10 If the test result is verified as positive, or as a refusal to test because of adulteration or substitution, the MRO shall inform the employee of his/her right to request a retest of the same specimen at a different DHHS-approved laboratory, and of the process for doing so. Such request must be made by the employee within seventy-two (72) hours of the employee having been informed of a verified positive test result.

3.5.13.11 URS, under independent authority, requires that the cost of a retest shall be borne by the employee, and will be deducted from the employee’s subsequent paycheck.

3.5.13.12 If, after making 3 attempts in a 24-hour period, the MRO is not able to contact the employee, the MRO shall report to the Company’s DER that all reasonable efforts have been made to contact the employee, without success. The DER shall then, as soon as practicable, ask the employee to contact the MRO within the next seventy-two (72) hours, and shall apprise the MRO that the employee has been so notified.

RCP-10.2-17

3.5.13.13 The MRO may verify a test as positive (or a refusal because of adulteration or substitution) without communicating with the employee if:

• The employee expressly declines the opportunity

to discuss the test result; or • The Company’s DER has successfully made and

documented a contact with the employee and instructed the employee to contact the MRO and more than seventy-two (72) hours have passed since the time the employee was successfully contacted by the DER; or

• Neither the MRO nor the DER, after making all reasonable efforts, has been able to contact the employee within 10 days of the date on which the MRO receives the confirmed positive test result from the laboratory.

3.5.13.14 If a test is verified positive under the circumstances

specified in 3.5.13.13 above, the employee may, within 60 days, present to the MRO information documenting that serious illness, injury or other circumstances unavoidably prevented the employee from being contacted by the MRO or the Company’s DER, or from contacting the MRO, as applicable, within the times provided. The MRO, on the basis of such information, may reopen the verification, allowing the employee to present information concerning a legitimate explanation for the confirmed positive test. If the MRO concludes that there is a legitimate explanation, the MRO will declare the test to be negative.

3.5.13.15 When a required drug test (pre-employment, return-to-duty, or follow-up) is canceled, the employee will be required to immediately take another test, with minimum advance notice.

3.5.13.16 Results of additional tests that are arranged by an employee, or requested by a medical practitioner, will not be considered. This includes testing of blood samples, hair samples, DNA, or any other testing methods or protocols.

RCP-10.2-18

3.5.13.17 When a test is reported as negative dilute, the employee will be required to submit to an immediate recollection, with minimum advance notice. If the employee refuses, it will be a refusal to be tested.

3.5.13.18 If, in the MRO's opinion, the employee provides information that medically disqualifies the employee from providing safety-sensitive functions, or that causes the MRO to have concern about the employee’s ability to safely perform his/her safety-sensitive duties, the MRO is required to give that information to our DER.

3.5.13.19 After verifying the test results, the MRO shall report the test results in a confidential manner to the Vessel Operations Manager. The MRO's report will include:

• The employee’s name and Social Security # or

employee ID #; • The date of the collection; • The reason for the test (e.g., random, post-

accident, etc.); • The test results will be reported as either positive

(with the identity of the specific controlled substance), negative, dilute, refusal to test, or canceled, and the date the result was verified by the MRO.

• The verified results of an alcohol test on a blood specimen, either positive or negative, and, if positive, the specific BAC level.

3.6 Definitions

3.6.1 Accident (see marine casualty, and/or serious marine incident

below). 3.6.2 Adulterated specimen means a specimen that contains a

substance that is not expected to be present in human urine, or contains a substance expected to be present but is at a concentration so high that it is not consistent with human urine.

3.6.3 Alcohol means any form or derivative of ethyl alcohol (ethanol). 3.6.4 Alcohol concentration (or content) means the alcohol in a

volume of breath expressed in terms of grams of alcohol per 210 liters of breath as indicated by an evidential breath test (BrAC), or in a specimen of blood (BAC).

RCP-10.2-19

3.6.5 Alcohol screening device (ASD) means a breath or saliva device, other than an EBT, that is approved by the National Highway Traffic Safety Administration (NHTSA) and placed on a conforming products list (CPL) for such devices.

3.6.6 Alcohol screening test means an analytic procedure to

determine whether an employee may have a prohibited concentration of alcohol in a breath, blood or saliva specimen.

3.6.7 Alcohol use means the drinking or swallowing of any beverage,

mixture or preparation, including any medication, containing alcohol.

3.6.8 Canceled test means a drug or alcohol test that has a problem

identified that cannot be or has not been corrected, or which is otherwise required, by Part 40, to be canceled. A canceled test is neither a positive nor a negative test.

3.6.9 Chemical test means a scientifically recognized test that

analyzes an individual’s breath, blood, urine, saliva and/or other bodily fluids or tissues for evidence of dangerous drug or alcohol use.

3.6.10 Collection site means a place designated by URS where

individuals present themselves for the purpose of providing a specimen of their urine to be analyzed for the presence of controlled substances, or for purposes of providing a breath, saliva or blood sample to be analyzed for alcohol concentration.

3.6.11 Company property means all URS owned and/or operated

vessels, owned- and/or leased- property, including but not limited to owned and/or leased buildings and other real estate, parking lots and vehicles located on parking lots, and Company-owned and/or -leased vehicles, lockers, desks.

RCP-10.2-20

3.6.12 Confirmatory test

3.6.12.1 For alcohol testing with breath or saliva, a confirmatory test is a second test following a screening test with a result of 0.02 or greater, conducted 15-30 minutes later, that provides quantitative data of alcohol concentration. This test is performed on an Evidential Breath Testing Device (EBT), and is conducted by an individual who has been trained to use that specific instrument.

3.6.12.2 For controlled substances or alcohol testing with urine or blood, a confirmatory test is a second analytical procedure to identify the presence of a specific drug or metabolite. This confirmatory test is independent of the initial test and uses a different technique and chemical principle from that of the screening test in order to ensure reliability and accuracy.

3.6.13 Consortium/Third party administrator (C/TPA) means a

service agent who provides or coordinates the provision of a variety of drug and alcohol testing services to employers. A C/TPA typically performs administrative tasks concerning the operations of the employer’s drug and alcohol testing programs. This term includes, but is not limited to, groups of employers who join together to administer, as a single entity, the DOT drug and alcohol testing programs of its members.

3.6.14 Controlled substances has the same meaning assigned by 21

U.S.C. 802 and includes all substances listed on Schedules I through V as they may be revised from time to time (21 CFR Part 1308).

3.6.15 Crewmember means an individual as defined in 3.5.2 above,

Covered Individuals. 3.6.16 Dangerous drug means a narcotic drug, a controlled substance,

or a controlled-substance analog.

RCP-10.2-21

3.6.17 DER (designated employer representative) means an employee(s) authorized by URS to take immediate action(s) to remove employees from safety-sensitive duties and to make required decisions in the testing and evaluation processes. A DER also receives test results, SAP reports, and other communications on behalf of URS. Our DER will be our Vessel Operations Manager. The Company may designate more than one DER.

3.6.18 DHHS-approved laboratory means a laboratory that is certified

under the U.S. Department of Health and Human Services Mandatory Guidelines for federal workplace drug testing programs. Drug tests for URS crewmembers will be conducted by a DHHS-certified laboratory.

3.6.19 Dilute specimen means a specimen with creatinine and specific

gravity values that are lower than expected for human urine. 3.6.20 Drug means any substance (other than alcohol) that has known

mind- or function-altering effects on a person, specifically including any psychoactive substance, and including, but not limited to, controlled substances.

3.6.21 Drug test means a chemical test of an individual’s urine for

evidence of dangerous drug use. 3.6.22 Fails a chemical test for dangerous drugs means that the

result of a chemical test conducted in accordance with 49 CFR Part 40 was reported as “positive” by a Medical Review Officer because the chemical test indicated the presence of a dangerous drug at a level equal to or exceeding the levels establish in 49 CFR Part 40.85.

3.6.23 Initial test means an immunoassay screen to eliminate

“negative” urine or blood specimens from further consideration. 3.6.24 Invalid drug test means a result of a drug test for a urine

specimen that contains an unidentified adulterant or an unidentified interfering substance, has abnormal physical characteristics, or has an endogenous substance at an abnormal concentration that prevents the laboratory from completing or obtaining a valid drug test result.

3.6.25 Intoxicant means any form of alcohol, drug or combination

thereof.

RCP-10.2-22

3.6.26 Intoxication means

3.6.26.1 The individual is operating a vessel other than a recreational vessel and has an alcohol concentration of 0.04 or more, by weight, in his/her blood;

3.6.26.2 The individual is operating any vessel, and the effect of the intoxicant(s) consumed by the individual on his/her manner, disposition, speech, muscular movement, general appearance or behavior is apparent by observation.

3.6.27 Job applicant means a person, independent contractor, or

person working for an independent contractor, who applies to become an employee of URS, and includes a person who has received a job offer made contingent on the person passing a drug test.

3.6.28 Law enforcement officer means a Coast Guard commissioned,

warrant, or petty officer, or any other law enforcement officer authorized to obtain a chemical test under Federal, State, or local law.

3.6.29 Marine employer means the owner, managing operator,

charterer, agent, the Company, or person in charge of a vessel other than a recreational vessel.

3.6.30 Marine casualty (or accident) includes any accidental

grounding, or any occurrence involving a vessel which results in damage by or to the vessel, its apparel, gear, or cargo, or injury or loss of life of any person; and includes among other things, collisions, strandings, groundings, founderings, heavy weather damage, fires, explosions, failure of gear and equipment and any other damage which might affect or impair the seaworthiness of the vessel. It also includes occurrences of loss of life or injury to any person while diving from a vessel and using underwater breathing apparatus.

3.6.31 Medical facility means an American hospital, clinic, physician’s

office or laboratory, where blood and urine specimens can be collected according to recognized professional standards.

RCP-10.2-23

3.6.32 Medical Review Officer means a licensed physician responsible for receiving laboratory results generated by URS’ drug testing program who has knowledge of substance abuse disorders and who has appropriate medical training to interpret and evaluate an individual’s confirmed positive test result together with his/her medical history and any other relevant biomedical information.

3.6.33 Operating a vessel occurs when the individual is a crewmember

(including a licensed individual), pilot, or watchstander not a regular member of the crew, of a vessel other than a recreational vessel.

3.6.34 Operation means to navigate, steer, direct, manage, or sail a

vessel, or to control, monitor, or main the vessel’s main or auxiliary equipment or systems. Operation includes:

3.6.34.1 Determining the vessel’s position, piloting, directing

the vessel along a desired trackline, keeping account of the vessel’s progress through the water, ordering or executing changes in course, rudder position, or speed, and maintaining a lookout.

3.6.34.2 Controlling, operating, monitoring, maintaining, or testing: the vessel’s propulsion and steering systems, electric power generators; bilge, ballast, fire, and cargo pumps, deck machinery including winches, windlasses, and lifting equipment; lifesaving equipment and appliances; firefighting systems and equipment; and navigation and communication equipment; and

3.6.34.3 Mooring, anchoring, and line handling; loading or discharging of cargo or fuel; assembling or disassembling of tows; and maintaining the vessel’s stability and watertight integrity

3.6.35 Pass a chemical test for dangerous drugs means the result of

a chemical test conducted in accordance with 49 CFR Part 40 is reported as “negative” by a Medical Review Officer in accordance with that part.

3.6.36 Positive rate means the number of positive results for random

drug tests conducted under this part plus the number of refusals to take random tests required by this part, divided by the total number of random drug tests conducted under this part plus the number of refusals to take random tests required by this part.

RCP-10.2-24

3.6.37 Positive Test (alcohol) occurs when an individual’s confirmatory test result reads 0.04% BrAC or higher.

3.6.38 Positive Test (drug) occurs when an individual’s confirmatory

test or retest result is at or above cutoff levels specified by DHHS in DOT rules and regulations.

3.6.39 Qualified medical personnel means a physician, physician’s

assistant, nurse, emergency medical technician, or other person authorized under State or Federal law or regulation to collect blood and urine specimens.

3.6.40 Reasonable cause means a reasonable and articulable belief

that an individual has used alcohol or controlled substances, based on specific, contemporaneous physical behavioral or performance indicators of probable use.

3.6.41 Recreational vessel means a vessel meeting the definition in 46

U.S.C. 2101(25) that is then being used for pleasure. 3.6.42 Refusal to submit to a required alcohol test includes failure to

appear for any test, failure to provide a breath or saliva specimen for a required test, failure to remain at the testing site until the testing process is complete, failure to provide a sufficient breath specimen without a medical explanation, failure to undergo a medical examination following inability to provide a sufficient breath specimen, failure to sign Step 2 of the Alcohol Testing Form, and failure to cooperate with the testing process.

3.6.43 Refusal to submit to a required drug test includes failure to

appear for any test within a reasonable time, failure to remain at the collection site until the testing process is complete, failure to provide a urine specimen for a required drug test, failure to permit a directly observed or monitored collection when required, failure to provide a sufficient amount of urine without a medical explanation, failure to take a second test when required by a collector or this employer, failure to undergo a medical examination following inability to provide a sufficient urine sample, and failure to cooperate with the collection/testing process (including adulterating or substituting a specimen, and refusing to empty pockets at the collection site).

RCP-10.2-25

3.6.44 Screening test (for alcohol) means an analytical procedure to determine whether an individual may have a prohibited concentration of alcohol in a breath or saliva specimen.

3.6.45 Serious marine incident includes the following events involving

a vessel in commercial service, and which:

3.6.45.1 Must be reported to Coast Guard as a result of the occurrence of one or more of the following:

• one or more deaths; • an injury to a crewmember, passenger, or other

person which requires professional medical treatment beyond first aid, and, in the case of a person employed on board a vessel in commercial service, which renders the individual unfit to perform routine vessel duties;

• damage to property in excess of $100,000; • actual or constructive total loss of any vessel

subject to inspection under 46 U.S.C. 3301; • actual or constructive total loss of any self-

propelled vessel, not subject to inspection under 46 U.S.C. 3301, of 100 gross tons or more; or

• Results in a discharge of oil in the amount of 10,000 gallons or more into the navigable waters of the United States, whether or not resulting from a marine casualty; or

• Results in a discharge of a reportable quantity of a hazardous substance into the navigable waters of the United States, or a release of a reportable quantity of a hazardous substance into the environment of the United States, whether or not resulting from a marine casualty.

3.6.46 Substituted specimen means a specimen with creatinine and

specific gravity values that are so diminished that they are not consistent with human urine.

3.6.47 Testing levels means levels established by the U.S. DHHS, at

which a specimen or sample is determined to be either negative or positive, according to 49 CFR Part 40, Procedures for Transportation Workplace Drug and Alcohol Testing Programs.

RCP-10.2-26

3.6.48 Underway means that a vessel is not at anchor, or made fast to the shore, or aground.

3.6.49 Vessel includes every description of watercraft or other artificial

contrivance used, or capable of being used, as a means of transportation on water.

3.7 Recordkeeping

3.7.1 Records pertaining to the alcohol and controlled substances

testing program shall be maintained in secured and locked confidential files in the office of the Vessel Operations Manager. Access to these records shall be limited to management officials on a need-to-know basis, including Coast Guard officials upon request.

3.7.2 Records and report data shall be maintained as specified in U.S.

Department of Transportation’s rules and regulations. Records of positive test results will be retained for at least 5 years, in accordance with Federal regulations.

3.7.3 Except as required by law or expressly authorized or required by

U.S. Department of Transportation’s rules and regulations, testing information maintained under the alcohol and controlled substances testing program will be released only to the tested individual (on written request), or to an identified person as directed by the specific, written consent of the individual authorizing the release of the information.

3.8 Consequences For An Individual Who Tests Positive

3.8.1 An applicant who tests positive for drugs will not be permitted to

begin work as a crewmember. If an applicant who has tested positive, or who refused to be tested, intends to re-apply to the Company, or apply to another transportation industry employer, he/she must successfully complete a SAP assessment and recommendation before he/she can be considered.

3.8.2 A crewmember who tests positive for drugs and/or alcohol will be

immediately removed from duties which directly affect the safe operation of the vessel as soon as practicable, and shall be subject to suspension and revocation proceedings against his or her license, certificate of registry, or merchant mariner’s document, in accordance with Federal requirements.

RCP-10.2-27

3.8.3 If an individual (applicant or crewmember) holding a license, certificate of registry (COR), or merchant mariner’s document (MMD) fails a chemical test for dangerous drugs, URS will report the test result in writing to the nearest Coast Guard Office in Charge, Marine Inspection (OCMI), in accordance with Federal requirements.

3.8.4 An individual who has failed a required chemical test for

dangerous drugs may not be reemployed or reinstated or permitted to return to the vessel until the Company’s Medical Review Officer (MRO) has determined that the individual is drug-free and able to return to his or her work. In addition, the individual must agree to be subject to increased, unannounced testing for a period, as determined by the MRO, of up to 60 months.

3.8.5 Under its independent authority, URS, will temporarily hold an

employee’s position open when that employee has been removed from safety-related duty after testing positive, pending a decision from the MRO regarding the employee’s return to work. If the provider or the MRO reports that the individual is not fully cooperating with the MRO’s recommendation, or that the individual has little or no chance of being drug-free, URS may at that time consider the individual to have voluntarily resigned, and may take steps to fill the position with another crewmember or applicant.

3.8.6 Any costs incurred in regard to treatment and/or education

recommended by the MRO, or by the treatment provider, or by the EAP, which are not covered by an individual’s insurance plan, will be the responsibility of the individual.

3.8.7 When a SAP requires an employee to participate in a program of

aftercare, the employee’s compliance with that requirement will be monitored by the EAP or the SAP. Under independent authority, any costs related to this monitoring will be the responsibility of the employee. The aftercare requirement will be included in a Return-to-Duty Agreement, which must be signed by the employee. Failure to sign such agreement, or failure to adhere to the terms of a signed agreement, will result in termination of employment.

RCP-10.2-28

3.9 Education and Training

3.9.1 Any crewmember who has questions or concerns regarding this policy may seek clarification and further details from the Vessel Operations Manager or the General Manager.

3.9.2 URS will provide an Employee Assistance Program (EAP) for all

employee crewmembers. 3.9.3 The EAP will be responsible for providing educational materials

and information concerning the effects of alcohol and controlled substances use on an individual’s health, work and personal life, signs and symptoms of an alcohol or controlled substances problem (the individual’s or a coworker’s) and available methods for intervening when an alcohol or controlled substances problem is suspected, to each crewmember. Additional materials may be requested and answers to questions about the materials may be obtained by contacting the Vessel Operations Manager or the General Manager.

3.9.4 URS’ EAP will provide informational material (including a copy of

the Company’s policy regarding drugs and alcohol in the workplace), a 24-hour telephone number for crewmembers’ and family members’ assistance with drug and alcohol-related problems and concerns.

3.9.5 URS will require all individuals who are engaged or employed on

board a vessel to attend any scheduled training programs regarding these regulations, provided by the Company’s EAP. The training programs will include the effects and consequences of drug and alcohol use on personal health, safety, and the work environment, and the manifestations and behavioral cues that may indicate drug and alcohol use and abuse.

3.9.6 In addition, supervisors who are designated to determine whether

or not reasonable suspicion exists and who then order a crewmember to undergo testing under DOT rules and regulations, will receive at least 60 minutes of training on recognizing alcohol misuse and controlled substances use. The training shall cover the physical, behavioral, speech, and performance indicators of probable alcohol misuse and use of controlled substances.

RCP-10.2-29

3.9.7 All supervisors who participate in training will be given a certificate of completion of such training. The original certificate will be kept in Company records, and a copy will be provided to each supervisor for his/her own records, when requested.

3.10 Searches

3.10.1 Each employee, as a condition of continued employment, will be

required, upon request of Company personnel, to submit to search of his/her personal vehicle, desk, locker, office, cabin, stateroom, berth or similar item or place upon any work site, or on Company premises, or on a Company vessel or equipment.

3.11 Rules Under Independent Authority

3.11.1 The following consequences, and any other consequences

described in this policy which differ from the minimum requirements of DOT rules and regulations, are imposed by URS, under its independent authority, and are not necessarily requirements of DOT regulations.

3.11.2 Termination

3.11.2.1 URS will not guarantee reinstatement of an individual

who has engaged in prohibited conduct after violating any part of this policy.

3.11.2.2 An individual who violates prohibited conduct a second time will be terminated from employment.

3.11.2.3 An employee who refuses to submit to required testing for alcohol and/or controlled substances will be immediately removed from safety-sensitive function, and will be considered to have voluntarily resigned.

3.11.2.4 URS will hold an individual’s position open while the individual is actively participating in the EAP’s and MRO’s recommended program for education and/or rehabilitation. The EAP and/or MRO will make periodic reports to the Company regarding the individual’s participation. If at any time the individual is not cooperating, or has dropped out of the program, URS will consider that the individual has voluntarily resigned, and may take steps to replace the individual.

RCP-10.2-30

3.11.3 Suspended Status

3.11.3.1 When an individual is using a prescription medication and provides no written notice or authorization from a licensed medical practitioner advising that the individual may continue to safely work on a vessel, URS reserves the right to place the individual on time off without pay until such information is received by the Vessel Operations Manager or the General Manager, or until the medication is no longer required.

3.11.4 Crewmember Costs for Testing

3.11.4.1 When the cost of a test or a retest, as specified in this

policy, is to be borne by the individual, that individual may elect to sign an authorization form that permits URS to deduct those costs from the individual’s subsequent paycheck. Such arrangements will be made through the Vessel Operations Manager.

3.12 References

3.12.1 Title 33 CFR Part 95, Operating a Vessel While Intoxicated 3.12.2 Title 46 CFR Part 4, Marine Casualties and Investigations

(Subparts 4.01-4.06 only) 3.12.3 Title 46 CFR Part 16, Chemical Testing 3.12.4 Title 49 CFR Part 40, Procedures for Transportation Workplace

Drug and Alcohol Testing Programs (Drug testing only)

Note: If there are conflicts between federal regulations and this policy, attributed in part to revisions to the law or changes in interpretations, and when those changes have not been updated or accurately reflected in this policy, the federal law shall prevail.

THIS DRUG AND ALCOHOL POLICY IS NOT AN EMPLOYMENT CONTRACT, OR AN OFFER OF AN EMPLOYMENT CONTRACT.

Upper River Services may change, alter, or eliminate any or all portions of this policy as it deems appropriate, or as mandated or permitted by applicable laws, and may interpret it in response to any particular circumstance. An up-to-date copy of the policy is kept in the Company’s Traffic Office. Crewmembers may request to see the policy at any time during normal business hours.

RCP-10.2-31



RCP-10.3-1

PERSONNEL POLICIES

Title:

PROFICIENCY EVALUATION & REVIEW POLICY

Issue Date:





Page:

1 of 2 1.0 PURPOSE:

To establish a policy for evaluating Upper River Services (URS) vessel personnel.

2.0 SCOPE:

This applies to all URS vessel personnel.

3.0 RESPONSIBILITY: 3.1 The Vessel Operator must complete a performance review on each

crewmember as designated by the Crew Manager. 3.2 The Crew Manager should make reasonable efforts to have evaluations

completed for each crewmember. The performance evaluation(s) must be completed no later than December 15th.

3.3 The Dispatchers must complete a performance evaluation form for all

Vessel Operators at least once during a three year cycle. 3.4 The General Manager should make reasonable efforts to check that

evaluations are completed for each Vessel Operator and crewmember. 3.5 Completed reviews will be shared with the employees at the end of each

season, or earlier if deemed necessary for development purposes.

4.0 PROCEDURE:

4.1 Proficiency reviews will be conducted at least every three years by the employee’s direct supervisor. Performance evaluations are performed for the following reasons:

4.1.1 Developmental purposes: Performance evaluations help to

determine the employee’s level of training and expertise, and point out areas in which further training is needed. In addition, they can aid in the evaluation of previous training programs.

RCP-10.3-2

4.1.2 Motivational purposes: The presence of a properly used performance evaluation program can have a positive motivational effect on employees. It can encourage initiative, develop a sense of responsibility and accountability, and provide the stimulus for improved performance.

4.1.3 Management assistance: A performance evaluation system assists

management in making promotion, transfer, reward, and disciplinary decisions.

4.1.4 Human resource and employment planning purposes: The

performance evaluation system can aid the company in assessing future staffing needs, and in the planning and development of recruiting strategies and developmental training programs.

4.1.5 Communications purposes: A performance evaluation system

provides an opportunity for one-to-one communication between supervisor and employee. It offers workers an opportunity to express frustrations and difficulties, and enables the supervisor to recommend personal developmental strategies.

5.0 APPENDICES:

5.1 Level I Deckhand Employee Evaluation 5.2 Level II Deckhand Employee Evaluation 5.3 Level III Deckhand Employee Evaluation 5.4 Vessel Operator Evaluation Form



LEVEL I DECKHAND EMPLOYEE EVALUATION

NAME:___________________________________________ M/V:_________________________________ DATE:_________________ PARTICIPANTS:__________________________________________________ Instructions: The Vessel Operations Manager and/or the Crew Manager and the Vessel Operator will

evaluate each Employee in accordance with company policy. It is very important that evaluations be task oriented and as objective as possible.

PERFORMANCE SCALE

LEVEL DEFINITION

4. Excellent Consistently performs above expected work standards. 3. Good Performance meets expected work standards. 2. Fair Performance needs improvement. 1. Poor Performance is unacceptable.

E G F P 1. Has general knowledge of safety rules and an understanding of safety in the workplace 4 3 2 1 2. Has general knowledge of safety procedures 4 3 2 1 3. Has general knowledge of the environmental policy 4 3 2 1 4. Has general knowledge of towboat terminology 4 3 2 1 5. Has general knowledge of the station bill 4 3 2 1 6. Has general knowledge of the proper use of required PPE 4 3 2 1 7. Has general knowledge of the basics of tow building 4 3 2 1 8. Has general knowledge of radio protocol 4 3 2 1 9. Has general knowledge of the vessel confined space policy 4 3 2 1 10. Shows ability to participate in all training and drills 4 3 2 1 11. Shows skills and ability to use emergency equipment 4 3 2 1 12. Shows skills and ability to face up to a barge (use face wires) 4 3 2 1 13. Shows skills and ability to handle lines and tie off barges 4 3 2 1 14. Shows skills and ability to use proper hand signals 4 3 2 1 15. Shows skills and ability to splice lines 4 3 2 1 16. Shows skills and ability to inspect barges 4 3 2 1

E G F P 17. Shows skills and ability to use barge pumps 4 3 2 1 18. Shows skills and ability to read and record draft marks 4 3 2 1 19. Shows skills and ability to maintain the vessel and

perform basic housekeeping tasks 4 3 2 1 20. Shows skills and ability to take fuel readings 4 3 2 1 Recommendations for Improvement: 1._____________________________________________________________________________________________ _______________________________________________________________________________________________ 2._____________________________________________________________________________________________ _______________________________________________________________________________________________ 3._____________________________________________________________________________________________ _______________________________________________________________________________________________ I have reviewed my evaluation and recommendations for improvement with the Employee named above on this date. _______________________ Vessel Operator’s Signature Date I acknowledge that I have discussed my evaluation and recommendations for improvement with the Vessel Operator. By signing below, I do not necessarily agree or disagree with the evaluation or recommendations for improvement. _______________________ Employee’s Signature Date Employee’s Comments:

________________________________________________________________________________________

________________________________________________________________________________________

________________________________________________________________________________________

________________________________________________________________________________________

For Office Use Only:

April 14, 2014

LEVEL II DECKHAND EMPLOYEE EVALUATION

NAME:___________________________________________ M/V:_________________________________

DATE:_________________ PARTICIPANTS:_____________________________________________________

Instructions: The Vessel Operations Manager and/or the Crew Manager and the Vessel Operator will

evaluate each Employee in accordance with company policy. It is very important that

evaluations be task oriented and as objective as possible.

PERFORMANCE SCALE

LEVEL DEFINITION

4. Excellent Consistently performs above expected work standards.

3. Good Performance meets expected work standards.

2. Fair Performance needs improvement.

1. Poor Performance is unacceptable.

E G F P

1. Has complete knowledge of fire pump systems on

all vessels 4 3 2 1

2. Has complete knowledge of boat supplies (inventory and

ordering procedures) 4 3 2 1

3. Has complete knowledge of tow building 4 3 2 1

4. Has complete knowledge of locking (knowledge of all company

rules and USACE locking rules and procedures) 4 3 2 1

5. Has complete knowledge of how to complete company

forms 4 3 2 1

6. Has complete knowledge of rigging exchange 4 3 2 1

7. Shows skill and ability to fire up and shut down all

vessels 4 3 2 1

8. Shows skills and ability to maintain the engine room on

company vessels on which they normally work 4 3 2 1

9. Shows skills and ability to roll an eye in a wire 4 3 2 1

10. Shows skills and ability to make a bumper 4 3 2 1

11. Shows skills and ability to conduct monthly vessel

Inspections for all company vessels 4 3 2 1

Recommendations for Improvement: 1._____________________________________________________________________________________________ _______________________________________________________________________________________________ 2._____________________________________________________________________________________________ _______________________________________________________________________________________________ 3._____________________________________________________________________________________________ _______________________________________________________________________________________________ I have reviewed my evaluation and recommendations for improvement with the Employee named above on this date. _______________________ Vessel Operator’s Signature Date I acknowledge that I have discussed my evaluation and recommendations for improvement with the Vessel Operator. By signing below, I do not necessarily agree or disagree with the evaluation or recommendations for improvement. _______________________ Employee’s Signature Date Employee’s Comments:

________________________________________________________________________________________

________________________________________________________________________________________

________________________________________________________________________________________

________________________________________________________________________________________


April 14, 2014

LEVEL III DECKHAND EMPLOYEE EVALUATION

NAME:___________________________________________ M/V:_________________________________

DATE:_________________ PARTICIPANTS:_____________________________________________________

Instructions: The Vessel Operations Manager and/or the Crew Manager and the Vessel Operator will

evaluate each Employee in accordance with company policy. It is very important that

evaluations be task oriented and as objective as possible.

PERFORMANCE SCALE

LEVEL DEFINITION

4. Excellent Consistently performs above expected work standards.

3. Good Performance meets expected work standards.

2. Fair Performance needs improvement.

1. Poor Performance is unacceptable.

E G F P

1. Has complete knowledge of safety drills 4 3 2 1

2. Has complete knowledge of the security policy and security

procedures 4 3 2 1

3. Has complete knowledge of fueling procedures 4 3 2 1

4. Shows skills, ability and willingness to run drills and training 4 3 2 1

5. Shows skills, ability and willingness to train and mentor new

deckhands 4 3 2 1

6. Shows skills and ability to maintain the engine room on all

company vessels 4 3 2 1

Recommendations for Improvement:

1._____________________________________________________________________________________________

_______________________________________________________________________________________________

2._____________________________________________________________________________________________

_______________________________________________________________________________________________

3._____________________________________________________________________________________________

_______________________________________________________________________________________________

I have reviewed my evaluation and recommendations for improvement with the Employee named above on this date. _______________________ Vessel Operator’s Signature Date I acknowledge that I have discussed my evaluation and recommendations for improvement with the Vessel Operator. By signing below, I do not necessarily agree or disagree with the evaluation or recommendations for improvement. _______________________ Employee’s Signature Date Employee’s Comments:

______________________________________________________________________________________

______________________________________________________________________________________

______________________________________________________________________________________

______________________________________________________________________________________


April 14, 2014

VESSEL OPERATOR EVALUATION NAME: M/V: EVALUATION DATE: Instructions: The Dispatcher(s) should evaluate each Vessel Operator in accordance with company policy. It is very important that evaluations be task oriented and as objective as possible. PERFORMANCE SCALE

LEVEL DEFINITION

4. Excellent Consistently performs above expected work standards. 3. Good Performance meets expected work standards 2. Fair Performance needs improvement 1. Poor Performance is unacceptable

E G F P

1. Performs Duties Safely 4 3 2 1 2. Communication Skills 4 3 2 1 3. Emergency Preparedness Knowledge 4 3 2 1 4. Understands and Follows Navigation Rules 4 3 2 1 5. Understands and Follows Company Policies and Procedures 4 3 2 1 6. Learns New Skills 4 3 2 1 7. Initiative and Willingness to Work 4 3 2 1 8. Ability and Willingness to Follow Directions 4 3 2 1 9. Ability to Work Well with Others 4 3 2 1 10. Personal Hygiene and Living Area 4 3 2 1 11. Sets a Good Example for Subordinates 4 3 2 1 12. Does he/she operate the vessel to its full potential 4 3 2 1 13. Proficiency evaluation 4 3 2 1 14. Appropriately Completes all Required Paper Work 4 3 2 1 15. Overall Rating 4 3 2 1

Page Two Recommendations for Improvement: 1.

2.

3.

I have reviewed my evaluation and recommendations for improvement with the Vessel Operator named above on this date.

Evaluator’s Signature: Date: I acknowledge that I have discussed my evaluation and recommendations with the Evaluator. Check one box below: I do agree with the evaluation and recommendations for improvement and will make a reasonable

effort to achieve the goals set during this evaluation. I do not necessarily agree with the evaluation or recommendations for improvements, but will

make a reasonable effort to achieve the goals set during this evaluation.

Vessel Operator’s Signature: Date: Vessel Operator’s Comments:


April 14, 2014

RCP-10.4-1

PERSONNEL POLICIES

Title:

PERSONNEL DEVELOPMENT PROGRAM

Issue Date:





Page:

1 of 1 1.0 PURPOSE:

The following procedure addresses the professional development of Upper River Services (URS) employees.

2.0 SCOPE:


3.0 RESPONSIBILITY: 3.1 The Vessel Operations Manager should make reasonable efforts to make

promotions of employees to positions of higher responsibility. 3.2 Vessel Operators should observe employees on the job and make

recommendations to management for personnel promotions. 3.3 Employees should pursue opportunities to broaden their work experience

and abilities. The development of employees is up to each individual.

4.0 PROCEDURE:

For details, refer to the Deckhand Development Program and the Steersman Program.



RCP-10.5-1

PERSONNEL POLICIES

Title:

MEDICATION

NOTIFICATION

POLICY

Issue Date:

April 14, 2014

Last Revised:

February 20, 2015

Procedure Number:



Page:

1 of 2

1.0 PURPOSE: To provide guidelines for the safe use of prescription and non-prescription medication while on board an Upper River Services (URS) vessel.

2.0 SCOPE:


3.0 RESPONSIBILITY: All employees should comply with applicable portions of this policy.

4.0 PROCEDURE:

4.1 The use of prescription or non-prescription (over-the-counter) medication may affect the ability of an individual to safely perform the duties of an URS vessel crewmember.

4.2 Employees undergoing prescribed medical treatment with a legal drug or

controlled substance must report this fact and present satisfactory written evidence from his/her treating physician, that such drug or controlled substance will not adversely affect behavior or work performance, to the Vessel Operations Manager or General Manager as soon as the medication is prescribed. The Vessel Operations Manager or General Manager will provide this information to the company’s physician for review. Under these circumstances, it may be necessary to limit or restrict an employee’s work schedule during the course of such treatment as determined by a medical professional.

RCP-10.5-2

4.3 Some non-prescription drugs (for example, those sold for the relief of cold symptoms which contain antihistamines) can cause drowsiness and should not be taken by persons operating vessels, machinery or motor vehicles. In addition, some medications which have no harmful effects if taken on their own or in the quantity recommended by the manufacturer may become dangerous if the proper dosage is exceeded or if taken in conjunction with alcohol or other medications. The directions supplied with any medication should always be read carefully and followed precisely.

4.4 No prescription drug shall be brought upon a work site or upon Company

property, equipment or vessels by any person other than the person for whom the drug is prescribed by a licensed medical practitioner, and shall be used only in the manner, combination and quantity prescribed. No prescription drug shall be contained in any other than that in which it was originally obtained bearing the pharmacist’s label. Abuse of prescription drugs which affects performance or results in excessive absenteeism or tardiness or is the cause of an accident will result in disciplinary action up to and including suspension or discharge. In this regard, the disciplinary action taken shall be solely determined by the Company.


0 Initial issue April 14, 2014 1 First revision – Revised paragraphs 3.0 and 4.2 February 20, 2015

RCP-10.6-1

PERSONNEL POLICIES

Title:

DISCIPLINARY

POLICY

Issue Date:

April 14, 2014

Last Revised:

February 20, 2015

Procedure Number:



Page:

1 of 3

1.0 PURPOSE: Upper River Services (URS) has the responsibility to maintain a safe work place for all its employees. In order to meet that obligation, we have the right to impose discipline when and where needed. It is our intention to be consistent in dealing with individuals who violate our personnel or safety policies; therefore, the following disciplinary standards have been established.

2.0 SCOPE:


3.0 RESPONSIBILITY: All vessel personnel should comply with this policy.

4.0 PROCEDURE:

4.1 In most instances, minor infractions will result in a reprimand or counseling from management personnel. Employees who are counseled on their behavior should understand that their performance is expected to improve and that there should be no need for additional counseling sessions. Repetitive counseling for failure to observe company policies or acceptable standards of conduct will result in dismissal.

4.2 If an employee is counseled for misconduct or a perceived violation of

URS operating policies, he/she has the right to respond. If there is a misunderstanding or if inaccurate information has been given to management, the employee should make every effort to help management correct the information. Every employee will be given the opportunity to speak to a manager or present his or her position. Do not ignore counseling sessions or warnings without providing your explanation of events.

RCP-10.6-2

4.3 Some violations are so serious that we have no choice but to dismiss an individual immediately. Listed below are some, not all of the infractions that could be grounds for immediate dismissal:

4.3.1 Any act of dishonesty, including theft or wrongful use of money,

equipment, supplies, or materials belonging to the company or to a fellow employee;

4.3.2 Willfully giving false information, including providing false

information on an application for employment, an accident report, on official logs, or while acting in your capacity as an employee of URS;

4.3.3 Willfully or negligently destroying or damaging company-owned

property, including equipment on boats, in the office, or in vehicles, and including such items as written directives, publications, and notices;

4.3.4 Assaulting, threatening, or attempting to do bodily harm to anyone

on company property, in a company-operated vehicle, or while engaged in company business;

4.3.5 The use of alcohol or illegal drugs while on company vessels,

property, or vehicles or while on company business; the abuse of prescription drugs; or, the possession, distribution, or consumption of illegal drugs. URS is required by regulation to report drug violations by licensed or documented persons to the U.S. Coast Guard. Conviction of a drug offense or failure to pass a drug screen will result in the loss of an individual’s license, or preclude the issuance of an original license. Therefore, it is extremely important that every URS employee understand the importance of staying drug-free.

4.3.6 Refusal to participate in a drug or alcohol test. 4.3.7 Possession of a firearm aboard an URS vessel, in company

vehicles, or on company property; 4.3.8 Allowing any unauthorized person to visit a company boat or

company property; and, 4.3.9 Insubordination: Insubordination includes failure to observe

management’s instructions, disrespectfully disagreeing with your supervisor or manager, or acting in an insolent or threatening manner.

RCP-10.6-3

4.4 All instances of disciplinary action or counseling should be documented by the supervisor, employee and a witness using the Disciplinary / Counseling Report.

4.5 If you have questions about any of these standards, contact the General

Manager or Vessel Operations Manager for guidance. 4.6 Crewmembers terminated for violation of company policy or safety rules

are not eligible for re-employment for a period of twelve (12) months. 4.7 Crewmembers terminated for violation of the URS’ Drug and Alcohol

policy are not eligible for re-employment until proof of successful completion of an acceptable rehabilitation program has been received.

4.8 Crewmembers terminated twice for similar violations are not eligible for re-

employment at URS.

5.0 RECORDS:

Disciplinary / Counseling Reports should be kept in the employee’s personnel file for their length of employment plus three years.

6.0 APPENDICES:

Disciplinary / Counseling Report


0 Initial issue April 14, 2014 1 First revision – Added paragraphs 4.4, 5.0 and 6.0, and renumbered as appropriate February 20, 2015

Disciplinary / Counseling Report

Employee Name: ____________________________ Dept.: _____________ Date: ___________

Date of Occurrence: __________ Time: [ ] AM [ ] PM Location: ___________

Employee was Offered Representation: Yes No Supervisor Initials: __________

Representation was: Accepted Declined Employee Initials: __________

Description of Issue: Subject: ________________________ [ ] Absenteeism & Tardiness [ ] Policy / Procedure Violation [ ] Behavior / Conduct Infraction [ ] Performance Transgression [ ] Safety Violation

Action Taken: [ ] Verbal Correction [ ] Written Warning [ ] Investigatory Leave [ ] Final Written Warning [ ] Without Decision-Making Leave [ ] With Decision-Making Leave (Memo Attached) [ ] With Unpaid Suspension [ ] Termination

Explanation of offense: _______________________________________________________________________________ _______________________________________________________________________________ _______________________________________________________________________________ _______________________________________________________________________________ Goals/ Corrective Action to be taken: _______________________________________________________________________________ _______________________________________________________________________________

Should your record continue to be unacceptable in the above area(s), the company will find

it necessary to take the following disciplinary action (or more depending on the situation): [ ] Written Warning [ ] Suspension ____ day(s) [ ] Termination [ ] Other_______________

Employee comments: _______________________________________________________________________________ _______________________________________________________________________________

You are formally being warned to bring your attention to the severity of this situation. Failure

to correct this behavior and/or further violation of company policy will result in additional

disciplinary action up to and including discharge. By signing below you acknowledge that you have received and understand this notice. Employee: ____________________________________________ Date: ____________________

Supervisor: ___________________________________________ Date: ____________________

Witness: _____________________________________________ Date: ____________________

February 20, 2015

RCP-10.7-1

PERSONNEL POLICIES

Title:

PHYSICAL EXAMS Issue Date:





Page:

1 of 1 1.0 PURPOSE:

This procedure provides a list of physical examinations required for all vessel personnel by Upper River Services (URS) and/or federal regulation.

2.0 SCOPE:


3.0 RESPONSIBILITY: 3.1 The General Manager should make reasonable efforts to see that the

required physical exams of this policy are completed. 3.2 The Vessel Operations Manager is responsible for monitoring the

administration of this program.

4.0 PROCEDURE:

4.1 The following physical exams and tests are required of URS vessel crewmembers by company policy or by regulation:

4.1.1 Pre-employment physical and drug screen; 4.1.2 Essential task assessment; and, 4.1.3 Random, for cause, and post-accident drug testing.

4.2 These exams are performed at the company’s request and copies made

available to employees upon request. 5.0 REVISION HISTORY:


RCP-10.8-1

PERSONNEL POLICIES

Title:

PHYSICAL STANDARDS POLICY

Issue Date:





Page:

1 of 3 1.0 PURPOSE:

Upper River Services (URS) is committed to complying with the letter and the spirit of the Americans with Disabilities Act of 1990 and to maintaining a safe workplace for all URS employees. This policy outlines the job responsibilities and physical demands associated with various positions aboard URS vessels.

2.0 SCOPE:


3.0 RESPONSIBILITY: All vessel personal should make reasonable efforts to follow this policy.

4.0 PROCEDURE:

4.1 Captain/Relief Captain/Pilot

4.1.1 Work schedule - The standard work schedule for Vessel Operators on “lunch-bucket” vessels is determined by the Crew Manager based on work load. Pilots will stand 12 hour watches generally beginning his or her shift at either 6 a.m. or 6 p.m.

4.1.2 Physical demands of the job

4.1.2.1 All pilothouse personnel are required to communicate

with other vessels, U.S. Coast Guard stations, Corps of Engineers lockmasters and their own crewmembers. Communications may be made via a VHF radio, orally, by sound signals or by hand signals. All pilothouse personnel must have hearing that allows them to communicate effectively in the conditions that might be encountered aboard a towboat.

4.1.2.2 Pilothouse personnel must have vision that is up to the U.S. Coast Guard vision standard.

RCP-10.8-2

4.1.2.3 Pilothouse personnel must be capable of ascending and descending stairs or ladders safely, of lifting or moving equipment that may be used while they are aboard the boat, and of performing their emergency duties. Pilothouse personnel must know how and when to use the emergency equipment located on the boat.

4.1.2.4 Pilothouse personnel must be able to read well enough to understand U.S. Coast Guard Notices to Mariners, Rules of the Road, federal regulations, company directives, Corps of Engineers publications, and river charts. They must be able to write well enough to accurately record all required events in the vessel’s log and to communicate as required in the course of their job.

4.2 Deckhand

4.2.1 Work schedule - The standard work schedule for “lunch-bucket” vessels is determined by the Crew Manager based on expected work load. Deckhands will stand 12 hour watches generally beginning his or her shift at either 6 a.m. or 6 p.m.

4.2.2 Physical demands of the job

4.2.2.1 Standard deckhand duties include making tow,

transferring rigging, laying rigging, handling lines, shifting barges, dropping or picking up barges, checking the tow, moving and operating portable pumps, assisting in making locks or bridges, routine housekeeping duties, and general maintenance. In addition, deckhands may be required to catch a line on deck fittings, work lines at locks, cast lines free when getting underway, and assist in the navigation of the boat. These duties will be performed during all types of weather, night and day, and while the vessel is underway.

4.2.2.2 Deckhands are required to use hand tools, power tools, painting equipment, and personal protective gear. Power tools may be heavy or awkward and generate dust or loud noise.

RCP-10.8-3

4.2.2.3 Deckhands are frequently required to move equipment that is heavy or awkward. Moving this equipment may require more than one person in order to move or lift the item safely. No deckhand should lift more than he/she can safely handle. It is the responsibility of the individual deckhand to request assistance from other members of the crew when he/she feels it is necessary.

4.2.2.4 Medical facilities are not readily available in many areas along the river system. In some instances a lengthy delay in obtaining medical assistance or medicine may occur. Anyone needing medicine or periodic medical treatment is responsible for obtaining such treatment or medicine during his time off the boat.

4.2.2.5 It is the responsibility of every URS crewmember to report to the vessel in a timely manner, fit and ready for duty.



RCP-10.9-1

PERSONNEL POLICIES

Title:

PERSONAL HYGIENE

Issue Date:





Page:

1 of 2 1.0 PURPOSE:

Upper River Services (URS) has the responsibility to maintain a safe workplace for all its employees. Due to the unique environment aboard our vessels (close quarters, time aboard the vessel, and the close proximity to water) proper personal hygiene is vital to limit the spread of infections and bacteria. All employees should familiarize themselves with the following policy.

2.0 SCOPE:


3.0 RESPONSIBILITY: Every employee is responsible for his/her own personal hygiene.

4.0 PROCEDURE:

4.1 Hand washing

4.1.1 Basic hand washing and skin care can prevent work exposures and diseases. Good washing and scrubbing with water (warm or hot, when possible) and soap helps to remove germs, contaminants and chemicals. It can also prevent exposure by ingestion and cross-contamination of touched objects and surfaces.

4.1.2 Proper hand washing technique is to first wet hands under the

faucet and then lather with soap. Hands should be scrubbed and lathered for at least 20 seconds. Then, rinse hands with clean water and dry them.

4.1.3 Recommended times for hand washing:

4.1.3.1 Before and after using the restroom 4.1.3.2 Before and after food preparation. 4.1.3.3 Before breaks to eat, drink or rest. 4.1.3.4 After sneezing, blowing one’s nose or coughing.

RCP-10.9-2

4.2 Personal protective equipment (PPE) is an element of personal hygiene, since PPE (e.g., gloves, coveralls and boots) forms a barrier over the skin. PPE should be checked for excessive contamination, wear, tear, cuts or pinholes. PPE should be cleaned, decontaminated or replaced to make sure it does not collect or absorb contaminants.



RCP-10.10-1

PERSONNEL POLICIES

Title:

SANITATION AND SAFE FOOD HANDLING POLICY

Issue Date:





Page:

1 of 1 1.0 PURPOSE:

The purpose of this policy is to inform employees of the company’s sanitation and safe food handling guidelines.

2.0 SCOPE:



policy is followed by crewmembers. 3.2 All vessel employees should make reasonable efforts to comply with this

policy.

4.0 PROCEDURE:

4.1 Food storage:

4.1.1 Perishable food should be refrigerated within two hours. 4.1.2 Refrigerator should be kept clean and in proper operating

condition. 4.2 Preparation:

4.2.1 Wash hands with warm water and soap before and after food handling.

4.2.2 Microwaves should be kept clean and wiped out after each use.



RCP-11.1-1

SECURITY POLICY

Title:

SECURITY POLICY

Issue Date:

April 14, 2014

Last Revised:

February 20, 2015

Procedure Number:



Page:

1 of 4

1.0 PURPOSE: Essential to the prevention of any terrorist event, the purpose of this security policy is to increase awareness of security threats, training to ensure readiness, personnel practices that guard against security threats from personnel, and the development of response procedures to take in the event of an incident.

2.0 SCOPE:

It is Upper River Services (URS) policy that each employee understands the security policy procedures and safety precautions associated with these potential threats.

3.0 RESPONSIBILITY: 3.1 The Vessel Operations Manager is responsible for implementing the

Company Security Policy aboard all vessels. 3.2 The Vessel Operator is ultimately in charge of the vessel, crew, tow, etc.

and has overriding authority unless relieved of his/her command. 3.3 The Vessel Operations Manager is responsible for providing onboard

training. The Vessel Operator is responsible for reporting all suspicious activity. Security drills shall take place periodically.

3.4 Employees are responsible for taking appropriate actions to safeguard the

vessel and its crew and to report all suspicious activity to the vessel operator.

4.0 PROCEDURE:

4.1 The Vessel Operator shall confirm with the URS office or the agency of the boarding individual(s), the boarding of all visitors prior to allowing them aboard the vessel.

RCP-11.1-2

4.2 The Vessel Operator is responsible for ensuring that no person boards a company vessel unless they are escorted, they have prior approval from the office, and they have shown the proper government issued identification credentials as described in 33 CFR 101.515 and included in this procedure.

33 CFR Part 101.515 Personal identification.

4.2.1 Any personal identification credential accepted under the access control provisions of this subchapter must, at a minimum, meet the following requirements:

4.2.1.1 Be laminated or otherwise secure against tampering; 4.2.1.2 Contain the individual’s full name (full first and last

names, middle initial is acceptable); 4.2.1.3 Contain a photo that accurately depicts that

individual’s current facial appearance; and 4.2.1.4 Bear the name of the issuing authority.

4.2.2 The issuing authority in the above section must be:

4.2.2.1 A government authority, or an organization authorized

to act on behalf of a government authority; or 4.2.2.2 The individual’s employer, union, or trade association.

4.3 The General Manager shall confirm the individual’s eligibility to work in the

United States. 4.4 The U.S. Coast Guard and U.S. Army Corps of Engineers recognize

vessel crews as being the “eyes and ears” on the water. Crewmembers should be alert to suspicious activity at all times. Suspicious activity should be reported to the Vessel Operator.

4.5 The following are examples of suspicious activities to which companies

and crewmembers should be attuned.

4.5.1 Unknown persons photographing vessels or facilities. 4.5.2 Unknown persons attempting to gain access to vessels or

facilities. 4.5.3 Suspicious individuals establishing businesses or roadside food

stands either adjacent or in proximity to facilities. 4.5.4 Unknown persons loitering in vicinity for extended periods of time.

RCP-11.1-3

4.5.5 Unknown persons calling facilities to ascertain security, personnel, or standard operating procedures.

4.5.6 Vehicles with personnel in them loitering and perhaps taking

photographs or creating diagrams of vessels or facilities. 4.5.7 Small boats with personnel on board loitering and perhaps taking

photographs or creating diagrams of vessels or facilities. 4.5.8 Suspicious general aviation aircraft operating in proximity to

vessels or facilities. 4.5.9 Any bomb threats to the vessel or company facilities. 4.5.10 Unknown persons attempting to gain information about vessels or

facilities by walking up to personnel or their families and engaging them in a conversation.

4.5.11 Suspicious vendors attempting to sell merchandise. 4.5.12 Theft of facility vehicles, vehicle passes, personnel identification,

or personnel uniforms. 4.5.13 Theft of standard operating procedures documents. 4.5.14 Unknown or suspicious workmen trying to gain access to facilities

to repair, replace, service, or install equipment. 4.5.15 Suspicious emails on internet, public affairs attempting to obtain

information regarding the facility, personnel, or standard operating procedures.

4.5.16 Suspicious package drop offs/attempted drop offs. 4.5.17 Anti-American sentiment being expressed by employees or

vendors. 4.5.18 Anti-American pamphlets or flyers distributed to employees or

placed on windshields in parking lots. 4.5.19 Repeated or suspicious out-of-ordinary phone calls. 4.5.20 Recreational boaters posing as mariners in distress to attract

assistance from other vessels.

RCP-11.1-4

4.6 At times the vessel crew may interface with companies that are required to have U.S. Coast Guard-Approved Security Plans and may have to sign a Declaration of Security. During times that the vessel and crew interface with another company’s security plan, this in no way relieves the vessel captain or crew of their responsibilities aboard their own vessel.

4.7 Awareness is heightened through the reinforcement of the company’s

communications policy. The communication policy provides all employees with a means of contacting the appropriate company officials and authorities in the event of a terrorist emergency. The U.S. Coast Guard National Response Center (NRC) has been designated as the national clearinghouse for information for all suspected or actual terrorist attacks in the U.S. domestic marine industry. The NRC can be reached 24 hours a day at 1-800-424-8802.

4.8 Callers to the National Response Center should be prepared to provide as

much of the following information as possible:

4.8.1 Their own name and contact information; 4.8.2 The name and contact information of the suspicious or responsible

party; 4.8.3 The location of the incident, as specifically as possible; and 4.8.4 The description of the incident or activity involved.

4.9 The Vessel Operations Manager should relay security information

including the security level (Coast Guard MARSEC Levels) and any specific threat information to all vessels.


0 Initial issue April 14, 2014 1 First revision – Revised paragraph 4.2 February 20, 2015

RCP-11.2-1

SECURITY POLICY

Title:

REPORTING PROTOCOL FOR SUSPICIOUS ACTIVITIES

Issue Date:





Page:

1 of 2 1.0 PURPOSE:

The purpose of this procedure is to provide a uniform and consistent reporting structure for all Upper River Services (URS) vessel employees.

2.0 SCOPE:


3.0 RESPONSIBILITY: All URS vessel employees should make reasonable efforts to follow this procedure.

4.0 PROCEDURE:

4.1 Information materials issued by the U. S. Coast Guard and the Department of Homeland Security encourage the maritime industry as well as the public to report suspicious activities to the National Response Center as a clearinghouse to gather information.

4.2 URS does not move red flag tank barges or federally designated

dangerous cargoes; therefore, no formal vessel security plan is required. To simplify reporting and minimize confusion, the following reporting protocol for Homeland Security concerning suspicious activities is to be adhered to by all vessel personnel:

4.2.1 Non-Vessel Operators: Report suspicious activities to the Vessel

Operator. 4.2.2 The Vessel Operator should immediately call the National

Response Center (NRC) at 1-800-424-8802 to report suspicious activities. Make sure to give your vessel’s cell phone number and the Company’s main office number (651-292-9293) as contact numbers in the event the NRC needs further information.

RCP-11.2-2

4.2.3 Once the NRC has been contacted, the company’s internal contact personnel shall be notified, starting with the primary contact until all notification has been made. URS has designated a 24-hour number (651-292-9293) for contacting shoreside operations personnel.

4.2.3.1 Company’s Primary Contact: Molly Isnardi 4.2.3.2 Company’s Secondary Contact: Lee Nelson 4.2.3.3 Company’s Alternate Contact: Hokan Miller

4.3 The shoreside operations contact will immediately initiate all additional

internal and external reporting as directed by federal guidelines and/or company policy.

5.0 APPENDICES:

Vessel Reporting Protocol 6.0 REVISION HISTORY:


Vessel Reporting Protocol For Suspicious Activities

The U. S. Coast Guard and the U.S. Department of Homeland Security encourage the maritime industry as well as the public to report suspicious activities to the National Response Center at 1-800-424-8802 or 1-202-267-2675. If your vessel is involved in a terrorist incident or should you observe any activity you should first call the National Response Center and then notify one of the Dispatchers either by contacting them directly or by calling the main office at 651-292-9293.

April 14, 2014

Incident or Suspicious Activity

Call National Response Center

800-424-8802 or 202-267-2675

Call Dispatcher