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Services - Regulatory Compliance

Frank's Vacuum Truck Service, Inc. has an in-house Compliance Department that monitors the safety and performance of all company operations.



Transportation-Related Compliance
The Compliance Department has a specialized computer software package that tracks all aspects of the company's transportation operation. Utilizing this system, Department personnel constantly monitor the status of company permits, licenses, and operating authorities - ensuring that they are always up-to-date. The computerized system also is used to track each individual load. Compliance Department personnel know where company equipment is at all times and maintain instant communication with drivers via a Nextel communication network including GPS Tracking. Drivers are required to call in every pick-up to review paperwork with an experienced compliance representative before leaving the project site. Compliance Department personnel review all shipping and disposal documents upon receipt to insure accuracy.

Additional transportation-related compliance issues handled by the Department include coordinating and tracking vehicle inspection, maintenance, and registration; training employees in the company's "Highway Spill Contingency and Emergency Response Plan" and "Transportation Security Plan"; and ensuring that all vehicles are equipped with appropriate emergency spill response equipment and paperwork supply boxes. The paperwork supply box is unique to Frank's Vacuum Truck Service, Inc. It is designed to prevent on-site delays caused by inadequate paperwork and includes bills of lading, sets of Customs paperwork, customs cargo control documents, a disposable camera, accident report forms, various labels, markers, and placards, and uniform hazardous and non-hazardous manifests.



Safety and Regulatory Compliance Training
All company personnel participate in an on-going, in-house environmental, health and safety awareness program. This program is designed to meet the requirements of OSHA's Hazardous Waste Operations and Response (HAZWOPER) Standard. The level and type of training provided is dependent on individual job classification as described below. Current certificates of training, licenses, registrations, etc. are maintained in the personnel files of each company employee and are available for review upon request.

Transportation Service Employees: Employees of hazardous waste transportation companies are unique to the transportation industry in that they must be well versed in the safety regulations as prescribed by the United States Department of Transportation (USDOT) Federal Highway Administration in Parts 383, 387 and 390-399 of the Code of Federal Regulations (CFR) Title 49. Equally as important are sections 100-179 in 49 CFR, which deals with DOT regulations for generators, shippers, carriers and the transportation of hazardous materials, chemicals and waste. These regulations outline the specific requirements for identification, classification, packaging, marking, labeling, placarding, and transportation. Transportation service employees also are exposed to 40 CFR containing the EPA regulations for protection of the environment relative to air, land and water. These regulations outline compliance responsibilities under the Clean Water Act (CWA), Toxic Substance and Control Act (TSCA), Resource Conservation and Recovery Act (RCRA), and the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA/ Superfund).

Transportation Services personnel receive initial 24-hour HAZWOPER training as prescribed under 29 CFR 1910.120, supplemented by annual 8-hour refresher training. Because the company routinely transports waste in and out of Ontario, transportation service employees also are trained in Regulation 347 under the Canadian Environmental Protection and Transportation of Dangerous Goods Acts.



Environmental, Health and Safety (EHS) Compliance
Frank's Vacuum Truck Service, Inc. ensures compliance with applicable federal, state, and international (Canadian) environmental regulations through the development and implementation of site-specific Health and Safety Plans, Environmental Protection Plans, Spill Prevention and Contingency Plans, Emergency Response Plans, etc. Operational plans developed by the company's various service groups are reviewed by the Compliance Department to ensure that they are both compliant and usable.



Alcohol and Substance Abuse Programs
Frank's Vacuum Truck Service, Inc. maintains a "Controlled Substances and Alcohol Use and Testing Policy" that is in compliance with the requirements set forth by the United States Department of Transportation and the Federal Motor Carrier Safety Administration. A copy of this policy will be made available for review upon request.



QUALITY COMMITMENT STATEMENT
Frank's Vacuum Truck Service is committed to providing expert, cost-effective service of unequaled excellence. To that end, the company has established corporate quality control and audit programs designed to constantly monitor its operations - ensuring that they meet client expectations and comply fully with applicable laws and regulations.

All employees are subject to performance evaluations - the results of which are used in determining employee compensation, bonuses, and advancement.



Contacts:
Ms. Susan Abraham  
Regulatory Compliance Manager E-Mail: susana@franksvac.com
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