Integrated Management System

Manual

Quality-Environment-Health-Safety-Security

ISO: 9001:2000 – RC14001® - ISO 14001:2005

EHS&S
Policies

Planning

Continual Improvement Implementation

Plan – Do – Check- Act

Management
Review

Corrective Action
 Table of Contents

Introduction to “Company”, Inc Page 3

Purpose & Scope Page 4

Normative references Page 4

An Integrated Management System Page 5

Management Responsibility & Review Page 6

Planning & Resource Management Page 7

Documentation & Records Page 9

Customer Focus Page 9

Product Realization Page 10

QMS Supporting Elements Page 10

Responsible Care® EHS&S Supporting Elements Page 11

Measurement, Data Analysis & Audits Page 13

Continual Improvement Page 14

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Introduction to “Company”, Inc.

Xtreme Provider

“Company”, Inc. (NASDAQ: “COMPANY”) is a less-than-truckload provider of regional, interregional and

guaranteed services covering 34 states. “Company” is home to the industry-leading Xtreme Guarantee
product, which guarantees total customer satisfaction from pick-up through invoicing. “Company” offers
complete North American coverage through partner agreements.

Xtreme Network

“Company” has:
 Direct coverage throughout 34 states
 151 terminal locations
 Approximately 8,400 employees
 More than 10,000 pieces of equipment

Xtreme Growth

“Company” was founded in 1924 with one terminal in Houma, Louisiana and continued to expand with
terminals throughout Louisiana and Texas. In 1993 when Yellow Corporation purchased “Company”, there
were 23 terminals and limited coverage in 5 states. In 1995, Smalley Transportation was merged into
“Company”, making a nine-state service area. Also in 1995, “Company” opened terminals in North and
South Carolina and Western Texas, allowing the company to provide 100 percent coverage of 11 Southern
States.

“Company” continued to grow, expanding to 12 states with 76 terminals and more than 4,700 employees
in the late 1990s. In January 2001, “Company” integrated WestEx and Action Express into “Company”,
expanding coverage to 21 states with more than 100 terminals and more than 5,000 employees. In 2001,
SCS Transportation, a holding company was formed; operating companies included “Company” and Jevic
Transportation. In 2002, Yellow Corporation spun off SCS Transportation into an independent, publicly
traded company on the NASDAQ Exchange.

“Company” announced the acquisition of Clark Bros. in February 2004, integrating nine additional states
and 16 terminals. In May 2004, the integration of the company was complete, providing “Company” with
coverage in key Midwestern areas, from a network of 127 terminals.

In 2006, “Company” was made the sole operating sector of the company and was re-branded as
“Company”, Inc. The company began trading on the NASDAQ Exchange in September under the ticker
symbol S-A-I-A. In November, “Company” announced the acquisition of Midwestern LTL carrier, The
Connection Company, expanding their service to four additional Midwest states. Today, “Company” is one
of the most successful LTL carriers in the United States, ranking in the top ten in the LTL sector.

The corporate headquarters of “Company”, Inc. is located in Duluth, GA, with business offices in Houma,
LA and Boise, ID.

No one delivers like we do. Some call it Xtreme.

We can live with that.

Headquarters Address:

XXXXXXXXXXXX

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1.0 Purpose & Scope
1.1 Integrated System Manual: This manual describes “Company”’s integrated
Quality, Environmental, Health, Safety and Security Management System. It
includes “Company”’s policies and describes how these policies are implemented
and sustained throughout the organization. The core processes of the company
are described throughout this manual with references to supporting procedures
and documents.

1.2 Purpose: The purpose of “Company”’s Integrated Management System is to

ensure service quality continues to meet the high standards demanded by the
organization and expected by our customers; and to ensure our processes are
carried out in an environmentally safe, responsible, and protective manner.

1.3 Scope: This Integrated Systems Manual provides specifics on the policies and
procedures used throughout our organization, and are designed to meet the
requirements specified in ISO 9001:2000; RC14001®; and ISO 14001:2004 and
are applicable to all “Company” facilities at time of implementation. New facilities
will be brought into the certification scope as applicable.

“Company” has excluded section 7.3 Design and Development from the
applicable requirements of ISO 9001:2000, due to the nature of our business. As
a service provider, this does not affect the company’s ability to provide service
that meets customer as well as applicable regulatory requirements.

2.0 Normative reference

The following normative document contains provisions, which through reference in this
text constitute provisions of ISO 9001:2000. For dated references, subsequent
amendments to, or revision of, any of these publications do not apply. For undated
references, the latest edition of the normative document referred to is applicable.

“ISO 9000 Quality Management System – Fundamentals and Vocabulary”.

3.0 Terms and definitions

Supplier – contractor, vendor, subcontractor
Organization – refers to “Company”, Inc.
Product – Service
Environmental Aspects – Elements of “Company” activities that may interact with the
environment.
Environmental Impacts – changes to the environment (negative/positive) as a result of
those “Company” activities identified as an aspect.

4.0 References, Documents & Forms

4.1 Quality Management Systems – Requirements ANSI/ISO 9001:2000
4.2 RC14001 Technical Specification
4.3 Guidelines for quality and/or environmental management systems auditing – ISO
19011:2002
4.4 ISO 14001:1996

5.0 An integrated Quality Environmental, Health, Safety and Security Management System.

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5.1 ISO 9001:2000 – The ISO 9001:2000 standard serves as the framework for
“Company”’s Quality Management System. Adherence to the standard provides the
foundation for “Best in Class” processes and a system that supports ongoing continual
improvement. The ISO 9001:2000 standard requires documented procedures for:
 Management Responsibility and Review
 Control of Documents and Records
 Control of Nonconforming Product
 Corrective and Preventive Action
 Internal Audits

5.2 ISO 14001:2004 – The ISO 14001 standard serves as the framework for
“Company”’s Environmental Management System. The addition of the ISO 14001
requirements provides a framework for servicing our customers in an environmentally
responsible manner. “Company”’s core procedures for the EMS are:
 Operational Control Procedures
 Waste Management
 Wastewater and Storm Water Management
 Maintenance Activities
 Storage Tanks, SPCC
 Aspects & Impacts
 Emergency Preparedness and Response
 Compliance with Legal & Other Requirements including record keeping.

5.3 RC14001®/Responsible Care® - Responsible Care is the chemical industry’s global

voluntary initiative under which companies, work together to continuously improve their
health, safety, environmental and security performance. This voluntary initiative strongly
supported by top management. Responsible Care® combined with ISO 14001 provides
the foundation our EHS&S system.

 As a partner company, “Company” is committed to continued progress

toward the vision of no accidents, injuries or harm to the environment
and will publicly report our progress and lead our company in ways that
increasingly benefit society. We pledge to operate our business
according to the “Guiding Principles” set forth as part of the American
Chemistry Council’s Responsible Care initiative. Key elements of the
Responsible Care program include:
 Key elements described in ISO 14001:2004/RC14001®
 Security Management Practices
 Heath and Safety Practices
 Environment Programs to reduce waste
 Community Outreach Programs

5.4 The inter-relationships among “Company”’s integrated management system and

procedures are illustrated by the Management Support Process Model. The correlation
between the ISO 9001:2000, ISO 14001:2004 and RC14001 are illustrated in the index of
Requirements and Procedures.

5.5 Quality Policy: “Company”’s policies and objectives are designed to ensure our
transportation services fully comply with the customer’s stated requirements. We
subscribe to a philosophy of continual improvement by maintaining and reviewing a
quality process intended to conform to the requirements of ISO 9001:2000 as relevant to
our operations. Stipulations of the quality process are applicable to all employees who
shall observe and implement such practices according to their job responsibilities.

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 “Company”’s employees shall strive to achieve complete customer satisfaction through
our commitment to quality. All employees shall remain focused on a common goal as
defined by the company mission statement: Provide the best-in-class regional service
defined by our Customer Service Indicators® with cost effective processes in an
environment that respects employees and recognizes excellence.

Customer Service Indicators®

 Pick up Performance
 On-time delivery
 Claims-free service
 Claims under $1000 settled within 30 days
 Invoicing accuracy
 Proof of delivery turnaround

5.6 Environmental Policy Statement: “Company” management strives to lead the company in an
ethical, safe and secure manner that increasingly benefits society, the economy, and the
environment while complying with applicable laws, regulations and other requirements and
programs including, but not limited to, the Responsible Care Guiding Principles®. “Company”
seeks to operate its facilities in a manner that protects the environment and the health and safety
of the company’s internal and external stakeholders. “Company” is dedicated to its vision of
having no accidents that can cause injury or harm to the environment. The company’s progress
is continually measured through programs which set target objectives that gauge “Company”’s
success as well as through pollution prevention programs that support our environmental
commitment. Our pledge to the environment is supported by our status as a Smart Way
Transport Partner, collaboration between the Environmental Protection Agency and the freight
industry that seeks to increase energy efficiency while reducing greenhouse gases and air
pollution. “Company” is committed to the following goals:
 No accidents
 No injuries
 Reducing Waste
 Reduction of Greenhouse Gases and Air Pollution
 Community Outreach Ministries

5.7 Core Beliefs

Best in Class = Excellence

Customer Excellence: “Company” recognizes that consistently delivering on time service is

only one characteristic of a Best in Class provider. Relationships with our customers are
equally important. “Company” continually strives to anticipate customer needs and
requirements, improve our responsiveness to customers, and provide our customers with the
“Best in Class” service they have come to expect, as reflected in the “Company” Customer
Service Indicators®

Employer Excellence: The development and continual improvement of “Company”’s

business is expected at all levels of the organization. “Company”’s management and
leadership strive to improve service to our customers by providing employees with
information, training, and opportunities to improve processes.

5.8 Policy Communication & Review: The Quality and EHSS policies and practices are
communicated and discussed with new employees as part of their orientation, and are
displayed in various locations throughout the workplace. Periodically, management
reviews these policy statements to ensure their ongoing suitability to the organization.

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6.0 Management Responsibility & Review

6.1Management Commitment: “Company” executive management is committed to and

acknowledges its responsibility for providing a quality policy, establishing a management
representative, and conducting management system reviews. Management is
responsible for:
 Providing leadership and communication to the organization
 Promoting an open door policy
 Defining strategic goals and objectives, including statutory and customer
requirements.
 Ensuring continual improvement of processes and products and the
integrated management system.
 Defining job descriptions and organizational responsibilities for all
employees.

6.2 Responsibility for Integrated Management System: “Company”’s management and

leadership are responsible for creating and implementing policies and procedures. All
process owners are responsible for ensuring that processes are properly controlled and
carried out as planned. All employees are responsible for the quality of their work, as it
contributes to the quality of our service. Managers and leaders recognize that they must
ensure every employee is appropriately trained, and able to take corrective action when
necessary. In addition, opportunities to improve existing processes are sought and taken
when beneficial. Executive planning strategies are communicated to employees through
management staff, quarterly meetings, and various electronic communications.

The quality department is responsible for:

 Ensuring requirements of the integrated management system, comprised
of ISO 9001:2000, ISO 14001:2004 and the RC14001® technical
specification, are understood, implemented, and maintained throughout
the organization.
 Ensuring corrective actions are implemented to resolve issues identified
in internal and/or external audits.
 Conducting system audits to ensure conformance to the integrated
management system requirements.
 Reporting to top management on the effectiveness of the integrated
QMS/EHSS including process conformance and customer data.

6.3Management Review: Management review of the QMS/EHSS occurs at least

annually to ensure its continuing suitability, adequacy and effectiveness. This review
includes assessing opportunities for improvement and the need for changes to the
system, including QMS/EHSS polices and related objectives. Records generated as a
result of management review are maintained. Management review meetings are
conducted more frequently in certain locations due to the nature of the operation,
complexity, size, and particular issues.

Support and/or Reference Documents

Management Review Minutes/Records

7.0 Planning & Resource Management

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7.1Quality Planning: “Company” is dedicated to ensuring services conform to the
standards and specifications required by our customers. Process specific instructions
supporting these activities are referred to as the Integrated Quality and EHS&S system.
The integrated management system is comprised of the Integrated Management System
Manual, procedures, process instructions, and associated templates, forms and records.

Corporate objectives including “Company”’s Customer Service Indicators are defined

and documented. These objectives are reviewed as part of the management review
process and are considered as part of the business planning process.
Operational objectives are established by the operations management team and are
designed to measure and verify appropriate performance and/or conformance
throughout the life of the process.

Environmental Management: Environmental objectives are established based on the

Aspect and Impacts study. Objectives are translated into specific departmental targets.
Responsibility for achieving these targets is given to the appropriate department
managers or teams as designated by top management.
Environmental Aspects: “Company” conducts regular reviews of its business to
identify and prioritize the significant environmental aspects associated with its
operations. This assessment is reviewed as part of the management review process
at least annually. Additional reviews of environmental aspects and impacts may be
initiated as a result of a significant change to facility location, process changes or
other business planning activities. Environmental aspects and impacts are integrated
with the hazards and risks assessment. The hazard and the aspect are both the
cause, and the risk and the impact are the effect, whether adverse or beneficial in
whole or part, as a result of activities, processes, products or services. In other
words, “Company” considers an environmental aspect to be one form of a hazard,
and an environmental impact to be one form of a risk. Thus, all hazards whether
environmental, health, safety, or security related are evaluated and compared using
the same methodology to determine their relative significance.

Hazards and Risks: EHS&S hazards, and risks associated with those hazards, are
identified and evaluated for new and existing products and processes, changes to
existing products and processes, for the distribution and transportation of materials,
and for activities associated with operations.

Legal and Regulatory Requirements: As part of its responsibilities various

departments such as Safety and HR maintain a liaison with applicable outside 3 rd
party and governmental agencies regarding legal and regulatory requirements such
as environmental, DOT and OSHA regulations. These requirements are considered
and reviewed periodically and communicated as part of objectives and performance
targets.

Objectives & Targets: All objectives associated with the integrated management
system are defined and documented within planning processes and communicated to
functional areas and departments as necessary.

Resource Management: Resources are allocated against requirements and are

reviewed and supplemented where necessary. This includes resources needed for
maintenance of the Quality and EHS&S system.

 Human Resources: All employees are hired based on the defined

qualifications for a specific position. This qualification includes specific
regulatory requirements, certifications etc., where applicable.
 Competence, awareness and training: All employees are deemed competent
on the basis of appropriate education, training, skills and experience.

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 Management determines the necessary competence, provides training or
takes other actions to satisfy these needs, evaluates the effectiveness of the
actions taken, ensures that employees are aware of the relevance and
importance of their activities and how the contribute to the achievement of
the Quality and/or EHS&S objectives. Appropriate records of education,
training, skills and experience are maintained as applicable.
 Infrastructure and Work Environment: “Company” determines, provides for,
and maintains the infrastructure needed to achieve conformity to
requirements. Infrastructure includes, as applicable: buildings, workspace
and employed utilities, process equipment (both hardware and software), and
supporting service. Equipment, tools, and supplies are made available as
appropriate to each job function and area.

8.0 Documentation and Records

8.1 Controlled Documents: The Integrated QMS/EHS&S manual, associated

procedures, process instructions and forms are controlled documents. These
documents and any changes to these documents are under review, approval,
and revision control. At minimum, changes to any QMS/EHS&S documentation
requires the approval of the Quality Manager and/or Director of Safety and
Training. Other approvals are obtained as necessary.

8.2 Control of Records: Records required in support of the integrated QMS/EHS&S

system are identified and maintained by the appropriate department. This
includes backup and storage of electronic records. Records are stored and
maintained in a manner to prevent deterioration, damage, or loss and are readily
accessible where needed. Minimum retention periods are established. After the
minimum retention period, records may be destroyed, stored at an off-site
location, or retained for historical purpose.

8.3 Uncontrolled Documents: Printed copies of documents are considered

uncontrolled. All employees are advised to verify any printed documents against
the electronic version to ensure current revision. Controlled copies are
maintained in electronic format on the intranet ““Company”net”. All documents
and records are identifiable and maintained in a legible format.

9.0 Customer Focus:

9.1 Customer focus: “Company” continually strives to improve its responsiveness to

its customers, to anticipate and meet customers’ requirements, and to provide
“Best in Class” service as defined by our Customer Service Indicators®.
Customer feedback is managed and collected through various methods such as
the Corrective Action Procedure, Customer Advisory Boards, and periodic
customer surveys.

9.2 Customer Property: “Company” exercises care with customer property while it is
under our control or being utilized by our company. “Company” identifies,
verifies, protects and safeguards any customer property provided. If customer
property is lost, damaged or otherwise fount to be unsuitable for use, it is
reported to the customer, and records maintained.

9.3 Customer Contracts: Contract inquiries are reviewed by appropriate personnel to

ensure requirements are understood and the necessary information is available

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 to fulfill the requirements of the contract. Contracts are reviewed prior to
acceptance, including renewals and amendments, to ensure the understanding
of requirements, the internal capabilities, and “Company”’s capacity to meet the
requirements as specified.

9.4 Customer Service: Customer Service is responsible for providing technical

support and customer training. Support services are extended at various
capacities based on the customers’ needs. This includes call centers, customer
service personnel responsible for various guaranteed services and/or monitoring
and communication requirements.

9.5 Customer Satisfaction: Customer visits, customer surveys, customer advisory

board meetings and other customer communications are used to gather
information on customer satisfaction. The results of customer feedback are
reported, and reviewed as part of the management review process.

10.0 Product Realization

10.0 “Company” defines product realization as those activities that occur from marketing
to delivery of customer product. “Company” plans and develops the processes needed
for product realization. Planning of product realization is consistent with requirements of
the other processes of the QMS/EHS&S integrated system. In planning product
realization “Company” determines as appropriate:
 Objectives and requirements for the process/product.
 The need to establish processes, documents and provide specific resources.
 Required verification, validation, monitoring, inspection and test activities
specific to the process/product and the criteria for approval and/or
acceptance.
 Records needed to provide evidence that the realization processes and
resulting product meets requirements.
 Any Hazards and Risks including environmental, health, safety, and/or
security related that can impact the product/process.

The output from these planning activities is in a format suitable for our company’s
operation.

10.1 Design and Development: “Permissible exclusion” “Company” is not design and
development responsible. If at any time this requirement becomes applicable as
part of our operations, we will address as appropriate.

11.0 QMS Supporting elements

11.1 Process Control: Monitoring and control of product is tracked in the AS/400
database. Monitoring and control of suitable parameters and service characteristics
ensures service meets specified requirements. Inspection records are maintained as
objective evidence. Analysis of inspection results is used to identify problems.
Compliance with workmanship standards (quality, environmental etc.) is confirmed
through inspection reports.

11.2 Control of Process Changes: When significant change(s) are made to an

established process (e.g. new operator, machine, method, or technique) an examination
is make

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 11.3 Purchasing: Purchasing documents contain clear descriptions of the product or
service ordered, including appropriate identification codes, numbers, references,
requirements etc. The manager or designated personnel are responsible for ensuring
that product received conform to the requirements of the purchase order. All purchasing
documents are reviewed and approved prior to release. All approved suppliers are
maintained via an online database.

11.4 Supplier Review: Periodically, approved suppliers are reviewed as required to

ensure their continuing suitability to meet “Company”’s needs. This review may include
items such as: On-time delivery, instances of nonconformance, workmanship standards,
and/or applicable permit requirements.

11.5 Production and Service: “Company” plans and carries out production and service
provision under controlled conditions such as: the availability of information that
describes the characteristics of the product; the availability of work instructions as
necessary, the use of suitable equipment, the availability and use of monitoring and
measuring devices, the implementation of monitoring and measurement activities, and
the implementation of product release, delivery and post-delivery activities.

11.6 Product/Service Validation: Compliance with standards and/or specifications is

confirmed through inspection and testing activities. Relating primarily to the release of
new software/programs, rigorous inspection and test activities occur to ensure the proper
functioning, measurement capabilities etc, prior to release into production.

11.7 Product Preservation: “Company” preserves the conformity of customer product

during internal processing and delivery to the intended destination. This preservation
includes identification, handling, *packaging, *storage, and protection. This preservation
also applies to the constituent parts of a product.

*Packaging – “Company” does not package customer goods, however, employees are
expected to recognize if packaging is sufficient to withstand transport and may be
required to secure with additional resources as necessary.

*Storage – Storage is limited to charging for storage in the event disposition cannot be
obtained and storage charges are applicable; storage of chemicals/products on-hand as
part of maintenance activities, for which MSDS sheets are maintained; and storage of
hazardous wastes based on SQG or LQG requirements.

11.8 Identification and Traceability: Traceability of service and customer product is a

requirement of product realization as applicable to “Company”’s operations. Each
customer’s shipment is assigned a unique identification number (pro number) which
allows for traceability of the customer’s shipment from time of pickup through delivery.
Records of delivery are maintained as identified in the Records Control procedure.

11.9 Control of Nonconforming Product: Non-conforming product is identified and

segregated from conforming product. The OSD Department/Representative is
responsible for notifying customers with regards to shipments requiring disposition,
notification of lost, damaged, or determined to be otherwise unsuitable for use. Specific
procedures exist to control reporting and handling when nonconforming product is a
hazardous material or chemical. Records of nonconformance are maintained as
applicable.

12.0 Responsible Care® EHS&S Key Elements

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Communication: In addition to a formal Communications Department, “Company” has a
comprehensive program that focuses on direct, consistent communication, providing a
number of outlets in an effort to keep information flowing.

Through this program, “Company” has established tools that have been proven to be
instrumental in delivering key messages from management to employees, and at the
same time, giving employees an opportunity to meet and discuss various topics with
management.

We believe that the message is what drives the type of communication tool we use, and
we encourage all employees to become familiar with the tools available and use them to
their benefit. The following is a list of the ongoing communication tools currently utilized:

“Company” Directions – Monthly newsletter mailed directly to employees homes.

“Company” Question & Answer Line (Toll Free) 1-877-770-7242: This number can be
used to ask general questions or for story ideas and comment for the “Company”
Directions newsletter.

Employee Roundtables – Discussion meeting held between President Rick O’Dell and
hourly employees representing various terminals to discuss topics of employee
interest/concern.

Quarterly Employee Meeting – Management visits each terminal to bring employees up-
to-date on the status of the company.

“Company” Web Site – An Internet site – www.”Company”.com – for customers, the

general public and employees to view up-to-date information on “Company”. Also
available on the website is the “Contact Us” section where employees and the general
public can ask questions. Generally, answers will be provided within 48 hours.

Annual Report: Each year an Annual Report is prepared and presented to “Company”’s
public shareholders.

Customer Advisory Boards: Annually, “Company” hosts a “Customer Advisory Board” by

invitation only. The participants are a mixture of existing customers, potential customers,
past customers etc.

Based on need, information is also communicated to employees via:

Videotapes
E-mail messages
Bulletin board postings
Letters to employees’ homes
Letter included with paycheck

Compliance with Legal and Other Requirements: Management designates specific

positions responsible for tracking relevant laws, regulations and other requirements to
which the facility subscribes, and evaluates their potential impact on a facility’s
operations. Procedures are established to identify, have access to, and update as
necessary all legal and other requirements to which the facility subscribes concerning the
EHS&S system.

Operational Control: As necessary, for each identified operation or activity associated

with the significant EHS&S aspects identified, documented control procedures and/or

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 work instructions are established to ensure the work performed is in compliance with
EHS&S policies, as well as corporate objectives and targets.

Emergency Preparedness and Response: “Company”’s Safety Committee implements

and evaluates the emergency response procedures including employee safety,
coordinating response activities with the applicable agencies, and addressing any
EHS&S impacts resulting from an emergency situation.

Security: “Company” has security investigators assigned to address security related

matters. The Security Department maintains updated security profiles and risk
assessments of each terminal. In addition, detailed procedures define training
requirements, additional responsibilities and actions encompassing a wide array of
security related issues, including, but not limited to:

Personnel Security
Unauthorized Access
En-route security
Cyber security
Employee Responsibilities
Actions to take in the event of a breach
Emergency Response and Contingency Plans
Organizational Structure for reporting security related issues
Terminal opening and Closing procedures
Powered Vehicle Security
Trailer Security
Cargo Security
Criminal Background Investigations

13.0 Measurement, Data Analysis and Audits

13.1 General: Measurement and analysis tools and processes are designed so those
responsible for specific areas and information can make decisions independent of
organizational hierarchy. Where possible, decision making is based on facts gathered
through measurement and analysis. Measurements are made in various areas including,
but not limited to:
 Production
 Service
 Customer Feedback
 Achievement of objectives/goals
 Financial Results
 Process Performance
 Integrated Management System Performance

13.2 Monitoring and Measurement of Product: “Company” monitors and measures

the characteristics of the product to verify that requirements have been met. This
is carried out at appropriate stages of the product realization process in
accordance with planned arrangements as stated. Evidence of conformity with
acceptance criteria is maintained. Records indicate the person(s) authorizing
release of product. Product release and service delivery does not proceed until
planned arrangements have been satisfactorily completed, unless otherwise
approved by a relevant authority and/or where required by the customer.

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 13.3 Control of Monitoring and Measurement Devices: All applicable measurement
equipment is subject to systematic calibration checks at appropriate intervals to
verify conformity with specified accuracy limits. Where calibration is required,
records are maintained.

13.4 Internal Audits: The Safety& Quality Departments have the authority and
responsibility for coordinating audit-related activities associated with the
QMS/EHS&S integrated system. Audits are scheduled at regular intervals to
ensure all aspects of the system are reviewed. An audit schedule is established,
however, the frequency and schedule may be adjusted based on the results of
previous audits, and the significance of individual system activities.

13.5 Audit Results: Findings and observation from internal and/or external audits are
reviewed by person(s) responsible for the area audited. Actions as a result of
audits include investigation for root cause, corrective action, and/or continual
improvement suggestions. Audit activities/results are summarized and included
as part of management review.

13.6 Analysis of Data: Data is collected to monitor various activities with regard to
process conformance and quality, product conformance and quality, customer
satisfaction etc. Data is analyzed and evaluated to track and/or discover trends,
opportunities for improvement, the need for changes, additional resources etc.

14.0 Continual Improvement

14.1 Improvement: Continual Improvement is part of the culture at “Company”. In order

to maintain continual improvement, there is ongoing collective feedback of results.
Additionally, specific individuals and/or departments within the organization identify goals
and create plans to achieve those goals.

14.2 Corrective Action: “Company” takes action to eliminate the cause of

nonconformities in order to prevent recurrence. Corrective actions are appropriate to the
level of the nonconformity encountered. Procedures for corrective action define the
requirements for reviewing nonconformities (including customer complaints; determining
the causes of nonconformities, evaluating the need for action to ensure that
nonconformities do not recur; determining and implementing the action needed; recording
the results of actions taken and, reviewing actions taken.

14.3 Preventive Action: “Company” determines actions needed to eliminate the causes
of potential nonconformities in order to prevent their occurrence. Although any employee
has the authority to identify potential nonconformities and to initiate action, the primary
tool in place is a documented Hazards and Risks assessment process. As appropriate
preventive action is taken to address potential problems, customer issues, or
management system failures. Procedures for preventive action define the requirements
for: determining potential nonconformities and their causes; evaluating the need for
action to prevent occurrence of nonconformities; determining and implementing action
needed, recording results of action taken, and reviewing actions taken.

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