Safety, Environmental, and Quality Policy

The Great Lakes Towing Company places the highest priority on individual safety, prevention of pollution, and customer satisfaction. We are committed to safety in all phases of our operations. Because of our desire to provide the best service possible to our customers, while ensuring the safety of our employees and protection of the environment, The Great Lakes Towing Company has implemented environmental, safety, and quality assurance systems.

· To fulfill these expectations we will:

· Operate our vessels and facilities in compliance with rules and regulations

· Promote the health, safety and security of our employees

· Ensure the safety and security of our vessels, equipment and facilities

· Prevent pollution and protect the environment

· Manage operations with continual improvement

· Provide safety, security, environmental protection, and quality training

· Meet or exceed our safety, environmental, and quality objectives

· Provide services to our customers in conformance with established procedures

· Ensure our work will be done right the first time, every time

The Great Lakes Towing Company is dedicated to the highest standards of quality and customer service, and is vitally committed to ensuring the safety and protection of people and the environment. Examples of our commitment to quality and safety include our membership in the American Waterways Operators’ Responsible Carrier Program which is a third-party independently audited safety management program, recognized by the US Coast Guard. The program is complementary to the International Safety Management (ISM) code and designed to raise management standards and promote marine safety and environmental protection. Additionally, The Great Lakes Towing Company participates in the US Coast Guard’s Voluntary Towing Vessel Cooperative Boarding Program, a program which enhances marine safety standards.

The Great Lakes Towing Company implements its policies with the use of the Company’s Responsible Carrier Program Manual, which is a manual of operational, safety, and environmental policies and procedures, and the Company’s Quality Assurance Program. This Company Manual encompasses the AWO Responsible Carrier Program Guidelines and constitutes Company policy. All employees are required to comply with the policies and procedures set forth therein.

It is our mission to continually evaluate and improve our level of quality and safety based on our customers’ satisfaction and how well we have met their needs.

ISO & RCP COMPARISON

	ISM	RCP
Safety policy statement	a	a
Environmental protection policy statement	a	a
Statement of company responsibilities and authority	a	a
Designation of person responsible for safety management system	a	a
Appropriate personnel procedures, training, and resources available	a	a
Vessel safety and pollution prevention	a	a
Emergency preparedness procedures	a	a
Procedures for reporting and investigation accidents and non-conformities	a	a
Vessel maintenance procedures	a	a
Documentation of safety management system and associated data	a	a
Internal audit procedures	a	a

The AWO and its Responsible Carrier Program

The American Waterways Operators is a national association representing the inland and coastal tugboat, towboat and barge industry. It represents the vast majority of the industry.

The Responsible Carrier Program (RCP) is a comprehensive safety code of practice that encompasses virtually every aspect of fleet operations, including company management and administration, vessel equipment and inspection, and human factors. The program was designed specifically for the unique operational environments encountered within its various segments of the tugboat and barge industry. All AWO member companies are required to commit to compliance with the RCP as a condition of membership in the association. The Responsible Carrier Program is recognized by both government regulators and industry customers, including the U.S. Coast Guard, the Department of Transportation, and leaders of the shipping and insurance companies.

All members of AWO must confirm their compliance with the RCP through verification by an independent third-party auditor. Approved and certified third-party auditors verify that the company has met rigorous standards of professional competence, marine experience and ethical conduct. The audit must be repeated every three years. The Company's Responsible Carrier Program is approved by the Coast Guard District in which the tugs operate as satisfying the requirements of the District's Voluntary Towing Vessel Cooperative Boarding Program.