3 SAFETYThe safety policy is established to maintain a safe working environment for all crew members, visitors, and our equipment.The Company is committed to ensuring the prevention of injury or loss of life, damage to the environment, and the protection of property.Each employee is responsible for his or her own safety and for ensuring that his or her actions do not endanger the safety of others. Through this shared commitment we will maintain an incident free operation.Each crewmember is to be familiar with and follow the procedures set forth in the TSMS, in conjunction with relevant Vessel Response Information provided aboard barges in tow.
5 This policy underlines the commitment of the Management and workforce towards continually striving to eliminate impact from our operations on the environment. The management and employees are committed to:Recognize and address public concerns regarding the potential effects of our operations on the environmentPlacing the Safety, Health and the Protection of the Environment as our top priority in operational planningOperating our vessels in a responsible manner to protect the environment as well as the health and safety of our employees, customers, and the publicOperate in compliance with all applicable laws and regulations concerning waste, while striving to reduce overall levels of bothActively participate with the government and the public in establishing responsible guidelines to ensure the protection of the environment, safe work practices and the community.Commit to reduce overall emissions and waste generationWork in partnership with manufacturers, shippers and vendors to enhance safe transportation of products and the management of associated cargo residues and cleaning wasteEnvironmental Policy
6 Environmental Policy Cont. The Management and employees are committed to be involved in the planning and effective implementation of the prevention and response procedures to mitigate the effects of incidents should they occur.Management and employees are committed to a waste minimization plan and the key to achieving this is a sound environmental policy.Operating the Company in a manner that protects human health and the environment, avoids business interruption due to environmental concerns and provides solutions that will assure cost-effective compliancePursue continuous improvement to ensure environmental performance consistent with environmental visions and principlesBe active in pollution prevention efforts to reduce or eliminate pollution and waste at their sourcesIncorporate waste minimization into management practices to ensure ongoing efforts with respect to product design, capital planning, production operations, and maintenanceIncorporate waste minimization as an integral part of organizational strategies to increase productivity and qualityPeriodically review performance versus objectives and redesign programs as necessaryCommit to implementing recommendations identified through assessments, evaluations, and the Waste Minimization Team.Environmental Policy Cont.
8 Waste Management PlanThe Company is committed to the conservation and preservation of natural resources. To ensure that our operations do not result in pollution to waterways or air, the Company has implemented a Safety and Environmental Policy.It is the policy of the Company to comply with all federal, state and local pollution laws and regulations. These laws and regulations prohibit the placement of any pollutant including trash, garbage, discarded food, oil, bilge, waste oil, contaminated bilge water, or untreated sanitation into the waterways. Burning of garbage is likewise prohibited.In the event of a discharge of oil, sewage, bilge, or other pollutant, the Captain and crewmember in charge must notify the following:USCG: Contact Local MSONational Response Center:Company (24 Hour):
9 Waste Management Plan Cont. All Company employee’s MUST observe the following policies:The disposal of any type of plastic into the navigable waters is strictly prohibited. All plastic materials must be disposed of in an approved manner, either ashore or by incineration. Always put plastic in the container designated for that purpose.All Company vessels will maintain separate waste disposal containers for different types of garbage.Individual crewmembers must not throw anything over the side, no matter where the vessel is. All waste must be placed in the disposal containers provided and then will be treated in accordance with the regulations.All vessels must record the time, date, and location of all garbage disposal operations and the approximate amount and types of disposed material. SMF 2.2 E Garbage Log Form is to be used to record garbage discharges.
10 Waste Management Plan Cont. Each vessel must display a sufficient number of MARPOL placards to be readily accessible by the vessel crew.SAMPLE MARPOL PLACARD
12 Confined Space Hazards Cont. It is the Company’s policy that no one is to enter a confined space on a vessel or a barge. We understand that in an emergency situation, entry may be necessary, but the Company does not expect any of our personnel to enter a confined space under any circumstances.Confined Space: A confined space is any poorly ventilated space that has limited entry and exit openings. Such spaces may lack sufficient oxygen to support life or may contain flammable liquids, and explosive or toxic gases. Examples of confines spaces are tanks and voids.All confined spaces should be assumed to be dangerous until proven otherwise. Such spaces must be ventilated and tested prior to entry.A confined space should not be entered without attendance of someone outside the space. This individual must be knowledgeable in identifying warning symptoms in the actions of those in the space that something is wrong, knowing what to do if something is wrong and how to get that assistance.Any time a confined space is entered, the Master shall maintain a record of that entry on form SMF 2.5 Confined Space Entry.Confined Space Hazards Cont.
14 PPEPersonal Protective Equipment (PPE) is a barrier between the employee and workplace hazards. While PPE can sometimes cause employee discomfort and slow down the job, the results of taking precautions in the workplace are beneficial.Employees MUST keep PPE readily available and wear it properly. PPE must be considered a part of our daily operation for every employee!All PPE must be cleaned, inspected, and stored properly after each use.Company supplied PPE will be replaced by the Company as required due to normal wear- and-tear or work-related damages. Damage to Company issued PPE should be reported to your Supervisor.
15 PPE Cont. Hearing Protection If the area contains the placard “HEARING PROTECTION REQUIRED IN THIS AREA”, employees must wear the approved hearing protectionHearing Protection is required whenever sound levels become uncomfortable, these situations includeIn the vessel engine room when the main engine and/or generators are operatingWithin 25 feet of an operating barge pump engineWhen using a deck scaler, needle gun, or portable grinder
16 PPE Cont. Eye Protection Safety glasses or safety goggles must be worn when eye impact hazards exist.Either cover glasses or prescription safety glasses must be worn by those individuals requiring vision correction.Work situations that require eye protection include:Chipping, scaling, grinding, hammering, buffing, scraping or brush/roller painting,Start up of barge pump enginesCutting, repairing or installing wire ropeBleeding off air pressureEntering facilities that require eye protectionChanging light bulbsAny other situation that may expose the eyes to splash, dust, or debris
17 PPE Cont. Full face protection is required when Performing heavy grinding or buffingDust hazards existUsing any type of pneumatic toolWork situations that require the use of safety goggles include:Over non-safety prescription glasses when safety eyewear is requiredHooking up or disconnecting cargo, stripping or vent hosesBleeding air off of cargo pumpsCleaning with a wash down gun or spray paintingRemoving blank flanges, plugs, or caps from lines or hosesDisconnecting hydraulic hoses, fuel hoses, or cargo linesDuring barge cargo transfer start-ups when checking hoses and connections for leaks
18 PPE Cont. Foot Protection Approved safety footwear is required while aboard barges, on the deck of motor vessels, and at customer facilities as required. OSHA/ANSI approved steel toe or equal work shoes/boots will be required for field workers. Sneakers, sandals or shoes with slits or holes cut in them will not be permitted.PPE Cont.
19 PPE Cont. Hand Protection Gear and tools that must be handled with leather gloves are:Wire RopeRatchets, Slings, Winch Wheels, Sledge Hammers, Toothpicks, Chains, Grating and Deck PlatesExamples of situations where synthetic rubber gloves must be worn include:Removing or connecting blank hose flangesMaking or breaking cargo tanksStripping or mopping cargo tanksCleaning with paint thinner or degreasersChanging oil or fuel filtersHanding calcium hypochlorite tabletsUsing over cleanersWorking on the vessel’s marine sanitation devicePPE Cont.
20 PPE Cont. Head Protection The hard hat shall be worn squarely on the head and not over another hat or cap, cocked to one side, or reversed is prohibited.The following work situations where there is a potential for exposure to falling objects require hard hatsWhen customer and vendor policies require itWorking near, or with, an operating craneWorking on a bunker barge when alongside a shipWalking or working in a shipyardWalking or working in a plant or marine dock facility when not aboard the boat or bargeWorking on the barge, when required by the plant or marine dock facilityWhen in the company yardWhen an overhead exposure exists
21 PPE Cont. Skin Protection All personnel conducting cargo transfers or maintenance must wear, as a minimum, short sleeved shirts and long pants n addition to the previously listed PPE.Two Piece PVC rain suits or chemical resistant, impermeable, disposable slash suits must be worn when skin contact to carcinogens (such as Benzene or a benzene mixture) is possible.ClothingWhen supplied, uniforms are required to be worn at all times by Company personnel when on duty.All crew members must wear high-visibility clothing whenever they are on the deck of any towing vessel or barge.PPE Cont.
22 PPE Cont. Personal Flotation Devices (PFD’s) Work vests (Type V), USCG approved with reflective material on all flotation cells, whistles, and lights, must be worn when there is a risk of entering the water unexpectedly.Life jackets (Type I) must be kept available for emergency situations on vessels. If an employee must enter the water because of an emergency, a type I PFD must be donned. Company employees are not permitted to enter the water during the performance of normal work duties.Situations in which PFD’s must be worn include:While walking on docksWhile boarding or departing a vesselOn the bargeOn the boat main deckIn a work boat
24 Personal Hygiene Some good personal hygiene practices include: Washing the body and hair frequently, using deodorant is recommendedFrequent washing of hands and faceOral hygiene (taking care of teeth and gums, and treating or preventing bad breath)Cleaning of clothes and living areasWearing of clean clothing and underwear dailyChanging the bed sheets when a new person sleeps on the bedAvoiding contact with bodily fluids such as blood, feces, urine, and vomitWashing hands after using the restroom and before preparing foodNot licking your fingers before picking up sheets of paper or turning pages in a book
26 Benzene Awareness/ Handling The Company does not typically, but may at some time, handle products that would be expected to contain benzene levels requiring the implementation of this policy.Should a product indicate a benzene exposure potential, monitoring (conducted by the Company personnel or by a third party) using appropriate methods, over an eight hour period with organic vapor monitors should be conducted. Followed by being sent to a certified laboratory for analysis.Benzene emergency procedures. Should an individual be significantly over-exposed to benzene containing cargo the following actions should be taken:Eye and face exposure- wash immediately with large amounts of water. If irritation occurs see a physician ASAPSkin Exposure- Remove contaminated clothing and wash exposed skin with soap and water immediatelyInhalation- Move the victim to fresh air immediately. If breathing has stopped, provide artificial respiration. Call for medical assistance.Swallowing- If for some reason an individual has swallowed a product containing benzene, do not induce vomiting. Call for medical assistance immediately.
28 Falls Overboard Prevention LightingDeck lights should remain on from dusk until dawnIlluminate all shadows with a flashlight or headlamp before walking through themCritical Activities for CrewConduct job briefings or “safety huddles” to prepare for tasks beforehand.The towing vessel should not be underway while placing sounders/head gearMaintain extreme caution while facing or un-facing boat to tow because of close proximity to the waterWhile on deck always walk with one hand freeAlways position portable ratchets so they are tightened inboardUse the boat to more the equipment rather having crew carry itAvoid working and standing with your back to the waterWhen tightening hatch dogs, position yourself inboard of the hatch.
29 Falls Overboard Prevention Cont. Barge/Tow IssuesPaint perimeter and all tripping hazards in contrasting colors and use non-skid deck coatingsInstall life-lines and handrails when practical and protect duck ponds3CommunicationAlways receive authorization from the wheelhouse when you are conducting activities on the tow, main deck, and outside of the bulwarksUse the “buddy” system at all timesCommunicate “watch bump” when you see a bump is about to occur and grab ahold of a secure object and lower your center of gravity for stability to prevent falling.Communicate the timeframe or duration of expected workUse of routine, VHF radio checks, or voice activated devicesRecord all unusual hazards and conditions so they may be communicated to the next watch
30 Falls Overboard Cont. Walk and Working Surfaces PPE Keep guard ropes in place at all times, never hang, swing, or lean on lifelines or railKeeps deck clear of trip and slip hazards such as cargo, debris, or slippery products that may get on shoesHave de-icing procedures in place to keep work area free of icePPEWear appropriate PPE for required work taskPFD must be worn while working on outside on the lower deckAlways wear approved work/boat shoes with good non-slip solesEnsure radio and flashlight have fresh batteries before going out on tow
32 Respiratory Protection Program This section is for informational purposes, in the event that employees must work with cargoes high in Benzene content then those workers would be required to be trained and adhere to this program.RespiratorDepartment/Work AreaDust maskVoluntary use when chipping, painting, working in warehouse, or performing yard work.Half mask APR with organic vapor cartridge.5-10 ppm airborne concentration of benzene. Refer to SPM 2.8Full facepiece APR with organic vapor cartridges.11-50 ppm airborne concentration of benzene. Refer to SPM 2.8Full facepiece PAPR with organic vapor canister.ppm airborne concentration of benzene.Refer to SPM 2.8SAR with full facepiece in positive pressure mode.ppm airborne concentration of benzene.SAR with full facepiece in pressure demand mode.Exposure to greater than 10 ppm H2S in your breathing area as defined in SPM 2.9.SCBAMust be present while working in IDLH atmospheres.
34 HAZCOM/ Hazardous Materials It is our company policy not to use, or accept a hazardous chemical for which no SDS (safety data sheets) has been received.SDS’s for routinely handled hazardous materials are maintained aboard each vessel in the HazCom Manual.No containers may be accepted onboard until the data below is verified.The Captain will be responsible for ensuring that all product/ chemical containers received for use are labeled with:The trade name of the productsThe name and address of the manufacturerThe appropriate hazard warnings (target organs & type of PPE required)
38 Avoid over reading or stretching to pick up or put down the load Always push, not pull the object when possibleDo not twist or turn your body once you have made the liftSplit the load into smaller ones when possibleYou can also use alternative material handling techniques to include the use of mechanical lifting equipment such as:Hoists, forklifts, cranes, dollies, carts, conveyors, lift tables, and workstation designs.Make sure housekeeping is nice and tidy to decrease the risk of slip, trip and fall hazardsBack Safety
40 The MAJOR cause of deckhand fatalities is fall overboard incidents, therefore, prevention of slips, trips, and falls is essential to the safety of each and every one of us.Be aware of your surroundings and take precautions:Watch out for reduced visibilityNever step on hatch coversWatch out for the “bump”Keep all walking and surfaces clean, dry, and unobstructedStack materials in a stable mannerAvoid walking on the notch or outboard edgeRepair leaks from hoses, pipelines, and valves immediately.Remember the G.A.P.S principle:G-Gait (walking)A-AwarenessP-Physical ConditioningS-Shoe WearSlips, Trips, and Falls
41 Company Responsibility, Commitment, and Authority
42 Company Responsibility, Commitment, and Authority In general, Safety is the responsibility of everyone in the Company.It is the responsibility of the Captain to maintain the Vessel in a safe condition.The Vice President and Director of Safety & Compliance are responsible for the establishment and implementation of the Safety and Environmental Protection Policy, and ensuring adequate resources for the Towing Safety Management System in support of these policies.The Company office will handle day-to-day operations of the Vessel.Company Responsibility, Commitment, and Authority
44 Company Communication Incidents: Any incident must be reported to the main Company office immediately, followed by a completed CG report (for injuries) and an Incident Report Form (SMF 9.6). Regardless of how minor the incident, this report is needed so that we can answer any questions about the incident. Make sure that you send the report form original copy to the Director of Safety & Compliance at the main office as soon as possible. This applies to all incidents as defined in SMM 9.6.The Wheelman on Duty has the responsibility of contacting the dispatch office between each morning and afternoon providing the following information:a) ETA to the destination;b) Vessel position at 0700 hours and 1400 hours;c) Trafficd) Port timese) Transfer timesf) Locking timesg) List of events other than normal vessel operations that have not been reported to the office;h) Number and description of all delays encountered within the last 24 hours.
46 Designated PersonThe Designated Person responsibilities include monitoring the safety and pollution prevention aspects of the operation of each vessel and ensuring that adequate resources and shore-based support are applied, as required. The Designated Person is to ensure the safe operation of each vessel and provide the link between the Company and those onboard. The Designated Person also has access to the highest level of management when that access is needed.During working and non-working hours, the Designated Person shall be one of the first persons notified of a shipboard emergency by shipboard personnel.From time to time, the Designated Person may delegate to members of his staff various tasks associated with the duties of a Designated Person within the meaning of the ISM Code.
48 Captain’s Responsibility and Authority The Captain is responsible for The safe and efficient day-to-day operation of the vessel.Complying with the laws of navigation and the entire body of statutes that regulate ships and seagoing matters.Maintaining the seaworthiness of the vessel and protecting the interests of the Company.Accomplishing the objective of each voyage as defined in the ‘Voyage Plan’ forwarded from the vessel to the office.Implementing the Safety and Environmental Protection policies of the Towing SafetyManagement System as defined in this manual and maintain compliance with the TSMS.Motivating the crew in the observation of those policies.Monitoring and reviewing the Towing Safety Management System and reporting any deficiencies to the office in accordance with other provisions of this manual.Adherence to the provisions of the COI.Compliance with the applicable provisions of Subchapter M (46 CFR).The supervision of all persons onboard in carrying out their assigned duties.
49 Captain’s Responsibility and Authority Cont. The Captain is in overall command of all personnel and operations aboard the ship. His/her authority at sea is supreme and overriding. He/she has the authority and responsibility to make decisions with respect to safety, security and pollution prevention and to request assistance from the office or any other appropriate source.In all decisions, the Captain will consider the following order of priorities:Protection of Health and LifeProtection of the EnvironmentProtection and conservation of Company and Customer PropertyContractual Obligations Operational Responsibilities: Captain’s will make sure that the following operational procedures are carried out:Vessel Daily Log ReportsCrew Injury and IllnessAccident ReportsRequisitioning SuppliesVessel Safety ReportsNavigation Underway
51 Drug and Alcohol Policy Cont. The company prohibits the unlawful manufacture, distribution, dispensing, possession or use of a controlled substance in the workplace. Crewmembers and visitors are subject to drug and alcohol testing requirements for reasonable cause and in the event of a “Serious Marine Incident”.Crew Members are subject to random drug testing.If an individual receives a positive drug test result or refuses to submit to requested drug testing, the company shall remove that individual from active duty and place the member on involuntary unpaid leave or terminate his/her employment.If the individual is a marine crewmember and holds a license, or MMC document, the company must also report any positive drug test result or refusal to the USCG Officer in Charge, Marine Inspection. This crew member faces license and or document revocation under USCG procedures.The company reserves the right to conduct searches, without notice, of all employees, subcontractors and their possessions on, in or while operating company property.
52 Drug and Alcohol Policy Cont. All employees and applicants are required to participate in prohibitive substance screenings for the following reasons:Pre- employment, periodic sampling, random sampling, post incident, Reasonable suspicion.A person with blood alcohol content of 0.04 percent by volume is considered to be under the influence of alcohol.A crew memberShall not perform or attempt to perform any scheduled duties within four hours of consuming any alcoholShall not be intoxicated at any timeShall not consume any intoxicant while on watch or dutyMay consume a legal non-prescription or prescription drug provided the drug does not cause the individual to be in intoxicated
54 Smoking PolicySmoking is not allowed anywhere within the interior spaces of the vesselsSmoking is not allowed in vehicles, equipment, shops or the office.Smoking is permitted only on open decks and in well ventilated machinery spacesSmoking is permitted outside of the office only in the designated smoking area.All cigarette butt ends are to be properly extinguished and disposed of in the butt receptacle.
56 The company has developed a disciplinary process for counseling purposes that includes counseling sessions, written warnings, probation, and dismissal. Each situation is evaluated individually and the company will apply the steps most appropriate to a given infraction.Discipline is not necessarily progressive, meaning that discipline will be imposed depending on the nature of the act or omission warranting discipline.The form of discipline should reflect the seriousness of the infraction.Disciplinary Policy
57 Disciplinary Policy Cont. Some violations are serious enough to warrant immediate dismissal. These include:An act of dishonest, including theft or wrongful use of moneyWillfully or negligently destroying or damaging company propertyAssaulting or threatening to do bodily harm to anyone on company propertyThe use of alcohol or illegal drugs on company property/ vessels. The abuse of prescription drugs.Refusal to participate in a drug or alcohol testPossession of a fire arm on company propertyInsubordinationAllowing any unauthorized person access to company propertyLeaving the vessel to which the crew member is assigned without prior approval or relief.Willfully giving false information on reports or application for employment.
59 Injuries and Illnesses In the event of an emergency personal injury or illness, the person in charge must take action including;If necessary, obtain assistance from off-watch crew members by sounding the general alarmAdminister first aid to the injured or ill personDetermine the injured or ill person’s need for emergency careIf there is no need for additional medical assistance fill out SMF 8.5 Personal Illness/ Injury Report and notify the director of safety and compliance.For information on if the injured or ill person needs more medical attention than onboard the vessel refer to section SMM 8.4.
61 Reporting Oil SpillsThe Emergency Response team is an assigned group of employees that are responsible for taking action in the event of an emergency situation. Their responsibilities include:Notify state, local, and federal authorities required by lawInitiate control procedures to minimize risk to vessel crewmembers, equipment and the environmentDetermine spill containment, cleanup and removal if necessaryCoordinate and disseminate information to the mediaHandle the legal obligations and responsibilities of the company in the event of a spill.All spills require that the CAPTAIN fill out SMF 9.6 Incident Report.
63 Near Miss ReportingA near miss is an occurrence or circumstance that did not result in an injury or damage but certainly had the potential. The report documents what went wrong or what could have gone wrong and it provides information to correct future work.It is very important to emphasize that the process is not to assign blame to any crewmember but to make for an ever safer working environment. The usefulness of the near miss program is only as good as the information that is collected.Near misses are unique because they give us a second chance to correct dangerous behaviors or conditions before they result in future injury or property damage.When you witness a near miss or experience one please fill out SMF 9.2 Near Miss Report.
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