Document 4oqp2GGNMEVvK5OZj5bpZbDp

<1- vU ENVIRONMENTAL HEALTH i> *v - . '-I, NEWSLETTER Published by the ILZRO/L1A Environmental Health Dept. 292 Madison Ave. New York 10017 212-532-2373 Written by. N. Maresc: Emphasis on Training and Personal Hygiene Reduces Blood-Lead Levels in Japanese Battery Plants Blood-lead levels of workers in Japanese battery plants were found to be considerably lower than those of workers in comparable American plants, even though Japanese worl- ers do-not werrfi^>iratars andTHdre were rfo differences in process equipment, process materials or work practices. Management practices and administrative controls seemed- to be responsible for the lower blood leads according, to a report issued by Jeff Burton of Radian Corporation.` which, con ducted a study in three Japanese battery plants during 1979-1980 on behalf of NIOSH/EPA.* Japanese management practices place a heavy emphasis upon em ployee participation in production, quality control and health main tenance. U.S. managers, on the other hand, have traditionally placed their faith in their ability to control lead exposure through engineering con- * The study was conducted upon the urging of John Bitier of General Battery Corporation and we owe our thanks to him both for promoting the study in the first place and for bringing it to our attention. trois. As a nation long famous and justifiably proud of our technolog ical expertise, it is only logical that managerial approaches have devel oped that stress technological solu tions to business problems. This bias ` is even evident in federal regulation : of business. The OSHA Lead Stand ard. for example, places primary reliance upon the use of engineering ^controls to reduce employee lead exposure and blood-lead levels. This .-attitude has some times led us to neglect the importance of the indi vidual in controlling his .own lead exposure and reducing his own blood lead levels. While: techno logical advances and engineering controls are irfdeed important, the Radian study of Japanese manage ment practices clearly illustrates the importance of management partici pation, employee training, and per sonal hygiene in the maintenance of health. continued on p. 2 Japanese worker wearing gauze mask during post burning operation CYWI 3-000846 iupanev: Balter' Workers continued from p. ! Air Lead - Blood Lead Radian Corporation was unable to obtain time-weighted-average breath ing-zone exposure levels for Japanese workers: however. !ead-tn-a:r samples were provided using tripod-mounted stationary collectors which drew air for ten minutes through 50mm glassfilters mounted at approximately breathing level height. The samples were analyzed by atomic absorption. The area air sampling results ranged from 1 to 148 ,ugPb/mJ, with the average air-lead levels ranging from 19 to 63 MgPb/m-b Table 1 shows the 'air-lead leveis (PbA) as measured in four different departments of three Japanese battery plants. Radian Corporation also obtained summary data of the blood-lead levels (PbB*s) of 1.079 Japanese workers. PbB determinations were made following familiar atomic absorption spectroscopy methods and were confirmed by sending split samples to university and govern ment laboratories in Japan. Table 2 shows PbB data for the three plants studied. Most of the workers fell into `class A* (PbB<30ug/dl) and no worker was included in `class C (PbB>60Mg/dl). Figure l is even more startling, revealing that 95% of the employees sampled had PbB's lower than 40 Mg/di with an average PbB level of 20 Mg/dl. These results were achieved without the use of respirators! No conclusions were drawn by Radian concerning the relative contributions of inhaled and ingested lead to blood-lead leveis. or the relation between exposure and blood-lead levels. Nor were they able to quantify the impact of administra tive controls and management prac tices on the maintenance of bloodlead levels. However, faced with the evidence of three battery plants with PbA-'s* reaching 148 Mg/m-3 and average PbB's of 20 Mg; dl the report concludes "....it seems reasonable to assume that the methods (administra tive controls and management prac tices) have had a significant impact on blood-lead levels, and that these methods might be useful in domestic lead user or production facilities." Training The Radian Corporation investi gators were only able to visit one plant, a production facility for industrial batteries. The physical pfant is 60 plus years old. but has been modernized. It employs 320 production personnel and consumes 600-650 metric tons of lead per month. Plant process equipment and technology were felt to be equivalent to those round in the l.S. The plant incorporates the following major processes or equipment: lead oxide production in an oxide mil! pasting macninings grid casting electric forming post making battery assembly maintenance and auxiliary operation continued on p. 5 Table 1 Average Air-Lead Levels in Japanese Battery Plants by Department Oalda mill** Caacla* * rn>CMl 4 Faatxa* PUca nc 4 I'iimi rM (a 33 23-43 t 30 5-lU 33 tz-M Plot 1 w mi ran la (a*/**) tmw 19 10-13 a 11-107 4 t1-130 ruac e lairaa<ia*f/aW*3- a a 57 L4-44 H 1*-12# 2> If -12* is 1-114 43 12-13* Table 2 Blood-lead levels of Workers in Japanese Battery Plants II 1 1 Plant A Plant 5 Plant C No. of vorksrs inspactsd 387 571 121 No. of vorknr* Judgad aa: Class A (biov 30 ug/dl) 370 534 116 Class B (30-60 ug/dl) 17 37 S Class C (over 60 ug/dl) 0. 0 0 2 CYWI 3-000847 Lead. i-i Dunng the public hearings which were conducted by OSHA while formulating the present Lead Stand ard. a great deal was heard about the relationship between air lead levels (PbA) and blood lead levels tPbB). and. quite possibly, the debate is not over yet. The question is an impor tant one, for the answer to it may provide the basis for much of OSHA's rulemaking during their announced reconsideration of the Lead Standard. Unfortunately, it is also a highly controversial issue and one which is sure to generate a lot of possibly very confusing testimony. The question, simply stated, is this: Is there a correlation between PbA levels and PbB levels such that given a certain increase in PbA. a predictable- increase in PbB will occur? If there is. then theoretically at least, one could regulate blood lead levels by controlling air lead levels. (Assuming that nothing else other than PbA impacts upon PbB). This, indeed, was the conclusion reached by OSHA following the original public hearings on the Lead Standard which resulted in the estab lishment of the 50 microgram PEL. In reaching this conclusion. OSHA adapted what has become known as the "Bernard Model** to describe the dynamic behavior of human blood levels in response to changing indus trial air-lead levels. Dr. Bernard used a 5-compartment mammillary model, together with information on ba boons, humans, dogs, and rodents, to generate equations for retention of radioactive lead in the bone, liver, kidney, tissues and blood. The model postulates that lead first appears in the blood, and then is transported or diffused into a number-of different compartments, corresponding to the different organ systems in the body. Using this model as a base. OSHA sponsored a second study, known as the "Ashford Study', to determine what would happen in the various 'companments' given an increase in air lead levels. In order to do this, three assumptions had to be made: 1) that the transfer rates of lead between the biological compartments are linear: 2) chat the airborne lead to which workers are exposed consists of 12.5 micrograms of small particles absorbed with il% efficiency and 87.5 rmcrograms of large particles absorbed with 8% efficiency; and 3) the blood-lead level of the average person starting work in a lead plant is 19 ug; 100g a .5 Mg/ lOOg. Relying on data compiled in the Ashford Study, OSHA concluded that an air lead level of 50 Mg Pb/m-3 would result in average blood-lead levels of 40 Mg/100g. and consequently estab lished the PEL at that point. However, during the past three years, additional study has been undertaken on the PbA-PbB rela tionship. One of the most recent studies ("The Impact of Air-Lead on BIood^Lead in Man - A Critique of the Recent Literature-. Food and Cosmetic Toxicology. Voi. 19. pp 631-638. 1981) conducted by P. B. Hammond. E. J. O'Flaherty. and P. S. Gartside produced some startling results. Hammond et al. evaluated the PbA-PbB relationship using all the available data from published studies in which "the subjects were in an approximately steady state with regard to lead exposure, and bloodlead could be related to air-lead measurements made in the individ ual's breathing zone" (data drawn from studies conducted by Drs. Azar. Griffin and Kehoe). They then compared the observed PbA-PbB relationship with that which had been predicated by hypothetical models constructed by Rabinowitz et al. and Bernard. (See figure 2) They found the models predictions to be incon sistent with their observations. Where the models predicted a Ifnear PbAPbB relationship, the observed PbAPbB relationship was curvilinear with the slope decreasing as bloodand-air-leads increased. In other words, after a short period of rapid nse. PbB tends to reach a plateau at "3 which point it is relameiv unaffected bv increases in PbA. (See figure 3) 9rCT,Al '!00 .... I-.,.... I9*-* Hit. -<. na i. .i Fig. 2 Models proposed to describe lead disposition kinetics by (a) Rabinowuz er al. (1976) and (b) Bernard (19771. The amounts of lead in each compartment, exchanging daily between companments. and excreted dailyare shown for steady state conditions of coot incus exposure to food, water, and air lead. The amounts of lead shown entering the central compartment in each case are the aqjounts that are assumed to be absorbed dauly into the systemic circulation from all sources. WaomviB Fig. 3 Predicted and observed PbB level as a function of PbA, The Kehoe data points represent 12 individuals, some studied more than once: data points from individuals exposed to large panicle aerosols (A): pomes from one individual. DH. whose measured PbB from non-air lead sources was excep tionally high ( ). All data pointsare adjusted to a PbB from non-air sources of 16 yg.dl. Standard deviations are shown for Griffin a at. points (). The line of best fit to the Azar et at. data is shown dashed beyond the range of actual measurement. The Rabinowitz(-- land Bernard (-) predicted lines (after 5'vrs.i reflect maximum and minimum impact conditions. continued on p. 4 CYWI 3-000848 . - : i i c a i: n continued from p. J j r i !i o '0 J<J JC *0 A /m1 Fig. 4 a as a function of A PbA. The line of best fit to the A/ar a ai. data and the 93^. confidence limits to the line (above and below) are shown dashed beyond the range of actual measurement. Griffin n at. mean values i*): K.ehoe data points (A): Kshoe data points from individuals exposed to large-particle aerosols (A): the only positive value of a from subject DH (Kehoe). whose measured PbB from non-air lead sources was exceptionally high ill. Four negative values for Kehoe subjects have not been plotted. This curvUmearity with regard to a. the increment in PbB associated with a given increment of PbA (as illustrated in Figure 4) has important implications for OSHA. and the lead industry, during this period of reconsideration of the lead standard. The Hammond Study suggests that the "Ashford Study', upon which OSHA relied to establish the 50 microgram PEL may have been inaccurate in its description of the kinetics of lead absorption and distribution. The problems, however, don't stop even here, for none of the studies takes into account a myriad of other factors that can influence.a person's blood lead level such as his personal hygiene habits, his smoking and drinking habits and his work prac tices. Indeed, it seems questionable that any meaningful correlation between PbA and PbB can be drawn at ail. . 'kirk Rrii'js ______ OSHA has recently announced its decision to issue an interpretive and procedural rule which it hopes will ""clear the air" regarding the legality of its inspectors' use of personal air monitoring devices. OSHA which has been charged with the responsibility of assuring "....so far as possible....healthful working conditions,"has also been given the authority to inspect and investigate "during regular working hours and at other reasonable times, and within reasonable limits and in a reasonable manner any such place of employment and all pertinent condi tions, structures, machines, operat ing devices, equipment and materials therein, and to question privately any such employer, owner, operator, agent or employee." OSHA has always assumed that one of its "reasonable" investigative tools was the portable personal air From the Editor's Despite the attempts by OSHA chiefThorne Auchter to improve the climate between business and gov ernment, some businessmen are still distrustful of the regulatory agency - nor is this surprising considering the adverserial relationship which had existed between the two in the past. Unfortunately, as a result of that relationship, the history of gov ernment-business confrontation has been written, so far at least, in the court record. 1 Hopefully, that chapter of the history is complete and a new one being written, one in which the main idea is cooperation not confront ation. There is a slight, but nevertheless persistent sense of some thing new in the air. Call it a willingness to listen, an admission that, after all, management is not necessarily and always the enemy, a recognition that over regulation benefits no one. Under the leadership of Thome 4 sampling devices. In fact, based on 1903.7 which authorizes compliance officers "to take photographs and samples, (and) employ other reason able investigative techniques." the Secretary issued a Field Operations Manual (FOM) which contained instructions regarding sampling me thods. The first FOM was issuedin 1971 and every subsequent revision has included a section on personal air sampling. However, despite the apparent clarity of the intention of the regulation, air sampling through the use of personal monitors has had a long court history. The Plum Creek Decision In January of 1978. OSHA attempted an investigation of Plum Creek's plant in Columbia Fails. Montana but was denied permistion continued on p. S - Auchter. OSHA has significantly revised the "Target Industries Pro gram" and introduced some new programs which attempt to protect employee health and are more equitable to business. For the lead industry, perhaps one of the most promissing signs is OSHA's inten tion to reconsider segments of the Lead Standard. 1 have heard some people com plain that the regulatory relief they had hoped for has been too long in coming. Unfortunately, change oc curs siowly; and mistrust is not easily laid by. But now the opportunity seems to exist for business and government to rewrite the record book. OSHA has taken the first step by reopening the record; business has taken the next step, by providing information on PbA's and PbB's to OSHA contractors. It is still too early to tell what will result from this new spirit of cooperation. Hopefully, it will produce legislation that is realistic, feasible and effective. ~ cYSn 3-o0849 Bt u Tn c ontinued from 4 co fit employees with personal air samplers. Plum Creek Lumber main tained that, since the men worked around moving machinery, the wear ing of air monitoring devices created a safety risk which was unacceptable: it therefore instituted a company policy forbidding the wearing of such devices. The district court which heard the case supported Plum Creek. Al though it found the evidence con cerning the safety of the devices "very questionable." it noted that they were not "specified by law. or by the regulations." The court further found that the use of personal samplers "would be reasonable." but con cluded that "in the absence of law. the OS HA inspectors have no power to make Plum Creek do something simply because the inspectors think it reasonable." The Metro-East, Century-Casting Decision In May of 1980. OSHA attempted an investigation of two brass found ries. Metro-East and Century Brass Works. Inc.. After conducting a "walk around" inspection, the OSHA compliance officers were denied permission to attach personal samp ling pumps to employee's belts. The problem eventually wound up in court with OS HA claiming it had the right to use personal sampling pumps and the two affected firms arguing that neither OSHA nor the court had the right to force the use of the devices. In this situation, the ques tion was not one of safety. MetroEast and Century Casting contended that there was no existing rule or regulation authorizing, the use of such devices, and that the regulation, as it was then constituted, failed to give "fair warning" that an employer must permit the use of personal monitoring devices during inspec tions. The court found in favor of Metro-East and Century Casting, agreeing with them that "...a regula tion cannot be construed to mean what an agency intended but did not adequately express." Furthermore, the court found that the Secretary "...has the responsibility to state with ascertainable certainty what is meant by the standards he has promul gated." and added that "it would impose no hardship on the Secretary to amend the rules to give "fair warning" of the types of investigation deemed "reasonable." In response to these court deci sions. OS HA has in 47 FR 6530--6533 clarified the existing regulation. 29 CFR 1903.7 (b) to specifically include the use of personal air samplers during the course of inspec tion. OSHA is hopeful that by this action the legal battles over their use of these devices will be ended. * ** Japanese Battery Workers continued front p. 2 While the plant itself is similar to many U.S plants, plant officials, however, differed from their U.S. counterpans in their belief that ingestion is a major route of exposure and in the lengths they were willing to go to minimize uptake by ingestion. They place great emphasis upon training. First of all, during preemployment training, employees receive general instruction regarding lead exposure, washing procedures, etc. Then* through periodic training sessions, personal hygiene practices are reviewed. Finally, each year the company sponsors a "Hygiene Cam paign Week." which is designed to remind employees of the importance of ingestion protection, personal hygiene, proper work practices and the hazards associated with lead exposure. Three important aspects of the training program deserve special attention: One. training responsibil ities lie directly with the manager of each manufac turing department. Daily 5 instruction and the respons ibility for on-going training rests with the foreman of each operation. Two. training is treated as an on-going and integral part of the manufacturing process and is- repeated periodically throughout the year. Three, employees partici pate in the monitoring and implementation of training programs. Protective Equipment As in the U.S.. protective devices such as rubber gloves, boots, aprons, etc. are distributed to the workers each day. although cartridge-type respirators are not used. Also as.in the U.S. work clothing is laundered regularly, but the Japanese' hive found that adding acetic acid to the wash water assists in the removal of lead contamination from work cloth ing. Instead of respiratory equipment, Japanese workers wear surgical guaze masks which are comfortable to wear and which prevent them from placing their hands or lead-contam inated objects in their mouths. While the mask may reject larger lead particulate which enters the breath ing zone, its primary purpose is not filtration of respirable air, but prevention of accidental ingestion through the nose or mouth. Japanese, workers are encouraged to wear the masks at all times and not to remove them until after their hands and forearms have been cieansed. Hygiene Facilities and Proced ures Employees are not permitted to eat. drink or smoke in production areas. Rest stations and lunch rooms continued on p. 6 CYW1 3*000850 Jjpvinesc Batten Workers continued from p. 5 are provided but before entering, workers are required to remove their outer protective clothing, wash foot gear and wash hands, arms .and faces thoroughly. They are also urged to gargle with a mouth wash prior to eating, drinking or smoking to remove any traces of lead which may have entered the mouth. Change rooms are provided, as in the U.S.. but stringent measures are taken to prevent the importation of lead dust from production areas into the hygiene facility. Before entering, employees are required to remove foot gear, and at the end of each shift they are required to bathe in a luke warm tub of water which contains a very dilute solution of sodium sulfide, which combines with lead on the skin to produce a black lead sulfide spot everywhere there is Pb contamination. This contamination can be scrubbed off. The employee then rinses, enters a hot bath after which he again rinses prior to changing into street clothing. Al though cultural differences between Japanese and American workers would, in ail likelihood, preclude the use of such extensive wash facilities as those described above, it is clear 30 - that management insistance upon thorough cleaning before leaving work can have a significant impact upon employee health. Ail areas of the plant are main tained relatively dust-free through the usual water and vacuum cleaning procedures. Daiiy cleaning is con ducted once each shift, and once per week, a massive fioor-to-ceiiing clean-up us conducted. Some Useful Management Prim cip/es One thing becomes very obvious while reading the Radian report; the Japanese take ingestion protection, work practices, training, and person al hygiene very seriously and go to great lengths to teach and enforce good personal hygiene practices. The results, however, seem to show that their efforts are worth the trouble. Here, in summary, ant some manage ment principles observed by the Radian group which might prove helpful in reducing PbB's of U.S. workers. Provide intensive training * on a plant-wide and individ ual basis. continued on p. 7 6 Questions. Answers and Opinions------ The article on smoking in the January edition of "Lead Environ mental Health Newsletter" provoked quite a bit of interest. Below are two of the letters which were received on the subject. "I read your new Lead Occupa tional Health Newsletter with interest and particularly the article concerning smokers and blood levels. May I suggest that you include the sources of the information you used in the article so the reader may research the subject further. Our company has some em ployees who are exposed to lead fumes and we made a similar survey at one plant to determine ifthere was. in factua relationship between smokers and non-smokers and blood lead levels'. Though not very scientific, our survey of 103 employees indicated that those who smoked had blood lead levels an average of 18% higher than non-smokers. In the group 56 were smokers. We used the information to stress work rules and housekeeping in areas we have lead exposure." Bob P. Corporate Director of Safety Thanks for the information on smokers and PbB level. It is very interesting and certainly seems sup portive of the data in the studies I used. By the way, the references are as follows: Brown.C.Perry, et a!.. "Cigarette Smoking and Lead Levels in Occupationally Exposed Lead Workers," Journal of Toxicol ogy and Environmental Health. 6:877 - 833. 1980. continued on p. 8 3-000851 CYW1 Japanese workers remove their shoes before entering hygiene facilities Japanese Battery Workers vontinued from p. 6 Make employee training the responsibility of the line manager. * Establish a-joint employer/ employee committee to conducr lead related inspec tions. supervise weekly clean ups. provide training ses sions and foster communica tion. Stress the importance of housekeeping and personal hygiene. require their use before leaving work. Most important of all. manage ment must adopt a policy establish ing the importance of personal and industrial hygiene and then support the implementation of that policy. If Burton's report is accurate. PbB's cad be significantly lowered without recourse to expensive engineering controls which will result not only in savings on these- items, but also in savings onMRP and related medical benefits. Along with engineering controls. Medical Removal Protection (MRP) is one the the most controversial and costly requirements of the Lead Standard. It is also one of the most complex. Recently, OSHA denied an industrywide petition for a delay of the 6(M0 "triggers' for MRP, and even though several smelters and battery plants, were granted interim relief, most of the lead industry has to abide by the new rales. This means that any worker whose blood lead level reaches or exceeds 60 micro- grams lead per 100 grams of whole blood (60 must be removed from any work area where the iead- in-air is equal to or greater than the "Action Level" (30 Mg/ m3), and he or she cannot return to work (in an area > 30 ug/m*) until his or her blood lead level decreases to 40 Mg/100 g or lower. The temporary removal ofL a worker is not based on a simple blood-lead test, however; the Stand ard provides that removal only takes place when two consecutive blood lead samples exceed the trigger level. Therefore, at the first warning sign .that an employee's blood-lead level is elevated, administrative action ought to be taken to bring his or her blood conrmiM'J on p. X * Provide protective equip ment daily and see that it is thoroughly cleaned. Establish a rigorous inges tion protection program which includes personal hy giene facilities and practices, prohibition of eating, drink ing. and smoking except in safe areas, and then only after decontamination. Con sider the use of surgical gau2e masks where respir ators are not already worn. * Provide shower facilities and CVWI 3-000852 QUcMihH1* Ulcers commut'd tram p 6 Tola.S. and P.H. Norman. "Smok ing and Blood Lead Concentra tion in Lead-Exposed Workers and an Unexposed Population." Environmental Research 13. 250255 (1977). "I have jusr read the January issue (1982) of the ILZRO Environmental Health News letter. There is a rather glaring error on pages 3 and 4. On page 3 reference is made to a study in Finland of lead workers and smoking habits, and attention is drawn to Fig. I giving the data, which is actually Table V from Olsen era/, on "Indicators of lead exposure in an adult Danish suburban population"* published in the Danish Medi cal. Butlerin (1981) and has nothing to do with lead work ers. The median blood leads given in your Fig. I range from 11-14 MS/ dl. not very impres sive for lead workers {or perhaps very impressive!) and do not of course line up with the UCLA study as is stated and shown in Fig. 2 (incident ally since Fig. 1 and 2 are Tables, shouldn't they be so called)."* P. S. I. Barry. Chief Medical Officer Thanks for pointing out the errors. You are absolutely correct on both counts. The correct table appears beiow: Lead .`>undard continued from p. 7 lead down to acceptable levels before MRP is implemented. Employees may also be removed, even though their blood lead levels are below the trigger levels, if a physician discovers *a detected medical condition which places the employee at increased risk of material impairment from expos ure to lead.* What to do with medically re moved workers has been a problem for many companies. The Standard does not specify what an employer is to do with the removed worker other than to say that *OSHA intends that this transfer (to a low lead exposure) be to work that the employee is capable of performing and which is located in the same geographical area as the employee's normal job.* Several possibilities, therefore, exist. Most advantageous to the com pany would be to reduce the employee's exposure administrative ly; that is. reassigning him to a similar job which does not have lead exposure, or shortening his exposure through job rotation. Some firms have assigned workers on MRP to yard work, shipping or similar positions where lead exposure is low. And some firms have "bitten the bullet"* and simply sent workers home. There doesn't seem to be a simple solution to this problem because even in those firms where a transfer is feasible, other complica tions arise. Suppose, for example, the transfer of one individual on MRP subsequently causes "bump 1140* Ua* OsicamraciaM tut/lOOBl) t wnti m ltd etmeaiea --i fiiiwn tmuias eum. S 21 1-20 itevp** fruirn nn fruit llaatf IMMMIKlai 11/10111 .Mm* rmmmurmt J*ea i ham a.* 2t.l 7.7 24.3 1.1 23.1 24. 23.7 27.3 20.7 ing"* on other jobs and the eventual layoff of another individual who now loses his job and income as a result of the first worker's medical problem. Are any benefits due the laid-off worker under MRP? And what if contractual agreements prevent the easy transfer of individuals? While the worker is on MRP, he is entitled to the rate of pay he would normally earn plus benefits and seniority he would normally accumu late. He. is also entitled to his former job back when he is medically able to return to it. The employer may, however, deny MRP benefits to employees who have been removed if the employee refuses to participate in 'reasonable follow-up medical sur veillance.* Finally, a worker may be returned to work when either (a) his blood lead reaches the return level, :or (b) failing to accomplish that, at the'end of 18 months, the physician recom mends his return. At that time, the physician may also recommend either the continuance for a few more months on MRP, or severence if he deems the worker ought not undergo further lead exposure. If the employee disagrees with the physician's recommendations, he may have a second physician, of his choice and at company expense, review the findings of the first physician. If the two physicians disagree, they must choose a third physcian who will arbitrate the dispute and whose decision is bind ing. Tkit manna! Has bam funded is wboie or m part federal funds from the <J.S. Department of Labor under frost number IJ~2S4&393. indmduats undertaking tuefi projects under governmast sponsorship an encouraged 10 esprta /stir professional judgement. Therefore. these mattnats do sot neetssanly reflect the vwvo or policies of the U. S. Department ofLabor, nor doc any mention of trade namas. commercial products, or organizations imply endorsements by the U.S. government. 8 CYWI 3-000853