OSHA Strategic Partnerships Program > Region III

PARTNERSHIP AGREEMENT
BETWEEN

DEPARTMENT OF LABOR
OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION
WILKES-BARRE AREA OFFICE

AND

WEIS MARKETS, INC, DISTRIBUTION CENTER
MILTON, PENNSYLVANIA

Opening Statement

In a cooperative effort to foster safe and healthful worksites and meet the Occupational Safety and Health Administration’s (OSHA) strategic goal of improving the safety, health, and well-being of the nation’s workforce, OSHA and Weis Markets, Inc, for the Weis Markets, Inc. Distribution Center, Milton, Pennsylvania have agreed to the joint implementation of this Safety Partnership.

The primary goal of this partnership is to develop a cooperative relationship with Weis Markets Distribution Center to assist it in creating safety and health management systems at the worksite that will insure its employees are protected from injuries and illnesses and will encourage the company’s application to VPP. The partnership is to be established with Weis Markets Distribution Center for up to a two-year period.

Identification of Partners

Wilkes-Barre OSHA Area Office
Weis Markets Inc., Distribution Center, Milton, Pennsylvania
Background, Purpose and Scope

By entering into this agreement, OSHA and Weis Markets Distribution Center agree to work cooperatively to improve the safety and health program at Weis Markets Distribution Center and to eliminate the hazards at the site that are cause of injuries and illnesses to its workers.

Employee rights which are guaranteed under the OSH Act shall not be infringed upon as a result of this partnership. This partnership does not preclude employees and/or employers from exercising any right provided under the OSH Act, nor does it abrogate any responsibility to comply with rules and regulations adopted pursuant to the Act.

It is anticipated that routine worker involvement in the day to day implementation of worksite safety and health programs will be assured, including worker participation in team meetings, job hazard analyses, safety and health program reviews and accident investigations.
Goals, Strategies, Measures (See Appendix B for full statement).

Weis Markets Distribution Center and OSHA will work in partnership to achieve the following goals:

Promote, institute and maintain a safety and health management system based on OSHA’s 1989 Guidelines which incorporates these four basic program elements: Management Leadership and Employee Involvement; Worksite Analysis; Hazard Prevention and Control; Training.

Reduce or maintain injury and illness rates to/at levels that would meet eligibility requirements for VPP (3 year average TCIR and DART Rates (or equivalent rates) are below at least 1 of the most recent 3 years BLS rates for the established NAICS code).

Encourage Weis Markets Distribution Center’s participation in OSHA’s Voluntary Protection Program (VPP).
Partnership Management

The Partnership Management Team (PMT) will facilitate the direction of the Partnership. The PMT will consist initially of representatives from management and representatives from the hourly workforce as indicated in Appendix A. OSHA’s representative will serve in an advisory capacity to the PMT and will perform duties as outlined in Section VI.

The PMT will perform a variety of activities to facilitate the success of the Partnership, including:

Using the OSHA Challenge Program Stages for General Industry (Appendix C) as a guide, select and assign the steps and duties needed to carry out Weis Markets Inc. Milton Distribution Center’s commitments under the partnership agreement.

Encourage Weis Markets Distribution Center’ participation in VPP. ¹

Meet at least quarterly to track Weis Markets Distribution Center’s progress under the agreement and to make adjustments as needed. Weis Markets Distribution Center’s Partnership Management Team will establish and/or adjust written timelines and task assignments to close gaps in their safety and health management system in order to meet eligibility requirements to apply to VPP.

Communicate partnership activities, including best practices and successes, throughout Weis Markets Distribution Center.

Prepare an annual evaluation with final approval by OSHA. The evaluation will be due each year on the effective date of the partnership, and will follow the written format shown in Appendix D.
Weis Markets Distribution Center agrees to:

Visibly lead in the design, implementation, and continuous improvement of the site’s safety and health policies and activities.

Implement safety and health programs with a commitment that routinely extends beyond what is required by OSHA regulation.

Provide the necessary resources of staff, time and money to ensure that all persons on the worksite are protected from injury and illness hazards.

Ensure that all employees, from the top-level management down, have clearly written and defined safety and health responsibilities.

Ensure that written safety and health management systems are implemented that effectively address worksite hazards by identifying and tracking them to guarantee their correction and control.

Ensure training programs are implemented that help employees clearly understand their occupational hazards and how to control them.

Conduct baseline safety, health and employee surveys and share results with OSHA.

Share ongoing measurement data with OSHA needed to evaluate the partnership’s effectiveness.
OSHA agrees to:

Work cooperatively with Weis Markets Distribution Center to provide safety and health information, technical assistance and training (as resources allow), to facilitate safety and health management system improvements.

Conduct an initial evaluation (Gap Analysis) of the Weis Markets Distribution Center’ safety and health management system and report the findings to the PMT to help it determine the best steps to take to carry out the partnership agreement and work toward VPP application. (Note: OSHA’s onsite non-enforcement policy for partnerships will apply during any site walk around by an OSHA Compliance Assistance Specialist. See Section VII.)

Identify a suitable Mentor from a VPP organization who can be used as a resource by Weis Markets Distribution Center for the duration of this Partnership. ²

Meet at least quarterly with the PMT to track Weis Markets Distribution Center’ progress under the agreement, review its injury and illness experience and to make adjustments as needed.
Onsite Non-enforcement Verification:

During any onsite non-enforcement verification, OSHA conducts a review of the partner’s worksite in a non-enforcement capacity to assess the implementation of the partnership agreement. During such visits, if OSHA personnel identify serious hazards, OSHA and site management will agree upon a date for correction. If OSHA identifies serious hazards that the site management refuses to correct, the OSHA Compliance Assistance Specialist will make a referral to the Area Office for an enforcement inspection.

Annually, OSHA will conduct at least one onsite non-enforcement verification visit at Weis Markets Distribution Center. The purpose of the visit is to continue to support the company’s efforts to improve its safety and health management system and to prepare the required annual evaluation to gauge the effectiveness of the partnership.

In addition to the on-site assessments conducted by an OSHA Compliance Assistance Specialist (CAS), documentation will be selected for review that relates to the agreement’s goals, objectives and stated measures and will include a review of injury and illness data and survey results.
Benefits:

Weis Markets Distribution Center at the Milton, Pennsylvania facility is granted a six month deferral from programmed inspections upon entry into the partnership.

OSHA will designate an experienced safety and health staff person to serve as a resource and liaison to Weis Markets Distribution Center to provide training and technical assistance as outlined in the agreement, and to serve as an advisor to the Partnership Management Team.

OSHA will not issue penalties for other-than-serious violations, provided the violations are abated during the inspection.

When calculating initial penalty reductions, OSHA may provide an additional 10% penalty reduction for good faith over and above what is allowed by the FOM. This additional reduction will not apply to high gravity serious, willful, failure to abate or repeat citations. In cases where Weis Markets Distribution Center’ total penalty reduction is 100 percent or more, the minimum penalty provisions of OSHA’s FOM will apply.
Formal Complaints and OSHA Investigations:

OSHA personnel will continue to conduct investigations resulting from formal complaints, referrals, fatalities, catastrophes, other accidents or significant events at this partnering worksite. These investigations will be conducted outside of this partnership agreement in accordance with established OSHA enforcement policy. Violations identified during such investigations may result in the issuance of citations and penalties.
Evaluation:

An annual evaluation will be prepared by the PMT and OSHA with final approval by OSHA. The evaluation will be due each year on the effective date of the partnership, and will follow the written format shown in Appendix D.
Termination:

This agreement will terminate two years from the date of the signing. If either OSHA or Weis Markets Distribution Center wishes to withdraw its participation prior to the established termination date, the agreement will terminate upon receiving a written notice of the intent to withdraw from either signatory.

OSHA will terminate the partnership if Weis Markets Distribution Center is issued a citation related to workplace hazards which resulted in a fatality.
Paperwork Reduction Act Notice:

Paperwork Reduction Act Notice Form Approved OMB# 1218-0244 Expires 06-30, 2012. Public reporting burden for the time needed to develop the Partnership requirements, craft agreement language, and conduct an internal review process is estimated to be an average of 11 burden hours per respondent.

(Date) ________________________________________
Mark Stelmack
Area Director
Wilkes-Barre Area Office
Occupational Safety and Health Administration

(Date) ________________________________________
Jay Ropietski
Vice President, Operations
Weis Markets, Inc.

Appendix A – Partnership Management Team

Management Employees – Jim Chamberlain – Safety Manager

Hourly Employees – to be determined. (Must be volunteers).

Appendix B – Goals, Strategies, Measures

Goals	Strategies	Measures
Promote, institute and maintain a safety and health management system based on OSHA’s 1989 Guidelines which incorporates these four basic program elements: Management Leadership and Employee Involvement; Worksite Analysis; Hazard Prevention and Control; Training. Reduce or maintain injury and illness rates to/at levels that would meet eligibility requirements for VPP (3 year average TCIR and DART Rates (or equivalent rates) are below at least 1 of the most recent 3 years BLS rates for the established NAICS code). Encourage Weis Markets Distribution Center’ participation in OSHA’s Voluntary Protection Program (VPP).	1st Year of Agreement: As soon as the agreement is signed, OSHA will conduct an initial evaluation of Weis Markets Distribution Center’ safety and health management system. The evaluation will include a walk around of the facility to become familiar with the manufacturing processes and their associated health and safety risks and a review of the programs and management systems that are in place to ensure that control over these risks is maintained. The findings of this initial assessment will be reported to the Partnership Management Team in the form of a Management System Gap Analysis which will include references to the appropriate Challenge Elements and Stages to be used as a starting point to close identified gaps. OSHA’s onsite non-enforcement partnership policy will apply during this evaluation. Quarterly, OSHA will meet with the PMT to review their progression through the Challenge Stages with particular emphasis placed on those VPP Challenge elements where significant gaps were identified. During these visits, any concerns, questions, or other issues can be addressed regarding gap closure or the VPP application process. Specific training can also be conducted to ensure that the team has the necessary knowledge and understanding of VPP/VPP Challenge Elements that will lead to successful implementation of the components. 2nd Year of Agreement: PMT meets at least quarterly with OSHA to track progress in completing ALL Challenge Stages, review injury and illness experience and make adjustments as needed to meet partnership goals. OSHA representative and VPPPA mentor conduct mock VPP audit. Weis Markets Distribution Center completes VPP application with assistance from VPPPA Mentor and OSHA as needed.	1st Year of Agreement: Gap Analysis Completed Challenge Stages TCIR and DART rates 2nd Year of Agreement: Completed Challenge Stages TCIR and DART rates Mock VPP inspection with results reported to company by 3rd quarter of the 2nd year of partnership. Completed VPP application by end of agreement.

Appendix C – Challenge Stages

Challenge Stages at a Glance
1.1 Management Commitment
Mission and Policy Statements	Develop S&H Mission Statement, with input from employees, and a S&H Policy Statement.	Communicate statements; incorporate into new employee/contractor orientation.	Take proactive steps to ensure understanding by all employees and contract workers and that they become a routine part of regular communication.
Leadership by Example	Begins to participate in S&H activities and follow S&H rules.	Continue; increase frequency of manager participation in S&H activities.	Continue; ensure total involvement of all executives, managers, & supervisors
Resources	Commit initial resources to control identified hazards. Begin integrating S&H into other aspects of management planning.	Provide additional resources for S&H activities, including access to certified S&H and licensed health care professionals, and improve integration of S&H into other planning processes.	Continue committing and ensuring the utilization of adequate resources. Ensure integration of S&H into all planning processes in the site.
Goals and Objectives	Establish & communicate annual S&H goals & objectives based on findings from baseline hazard and trend analyses; and assessment of the site’s safety and health practices.	Review the site’s progress towards achievement of S&H goals & objectives; establish & communicate new goals, as appropriate.	Review, revise, and continue communicating S&H goals and objectives. Ensure S&H goals and objectives are routinely considered in site’s activities and programs.
Responsibility, Authority, and Accountability	Develop a safety and health accountability plan for managers, supervisors, and non-supervisory employees.	Enforce accountability plan.	Fully implement accountability system for all workers, including incorporation of S&H responsibilities into job descriptions and performance plans. Assign additional responsibilities to non-supervisory employees as appropriate.
Communication	Establish clear lines of communication with employees & provide reasonable access to top management re: S&H issues.	Maintain clear lines of communication with employees re: S&H issues	Encourage open dialogue between management staff and employees.
Disciplinary Plan	No action required	Develop & begin implementing disciplinary plan for managers and employees.	Ensure discipline is equability enforced, ensure higher levels of compliance.
Annual Self-Evaluation	No action required	No action required	Develop system and written procedures to annually evaluate the total site’s S&H management system. Complete at least one annual self-evaluation of the site’s safety and health management system.
1.2 Employee Involvement
Employee S&H Perception Survey	Conduct baseline employee S&H practices perception survey.	No action required	Conduct follow-up employee S& H perception survey.
S&H Practices Change Plan	Develop an action plan to address findings from the baseline employee S&H practices perception survey.	Implement steps defined in the site’s action plan to improve S&H culture.	Continue; ensure significant improvement in S&H culture
Employee Notification	Notify all employees of their S&H rights, the site’s participation in Challenge, & VPP principles.	Notify new employees of their S&H rights, site participation in Challenge, & VPP principles. Incorporate into new employee/contractor orientation.	Continue for new employees. At least annually, reenforce for all employees. Encourage freely reporting workplace hazards without reprisal.
Meaningful Employee Involvement	Establish a few key S&H teams; begin involving employees in S&H activities.	Increase participation on teams, and/or form additional teams. Involve employees in safety and health activities (e.g., accident/near-miss investigations).	All needed teams are functioning and meaningfully contributing to S&H. Ensure regular teams are routinely conducting audits, accident/incident investigations, self-inspections, and job hazard analyses. Improve and continue the site’s hazard reporting system.
1.3 Contract Worker Coverage
Adherence to Rules	Require contractors and their employees to comply with OSHA and site S&H rules.	Improve and continue to enforce policy for S&H violations.	Improve and continue- enforce policy for safety and health violations.
Contractor Selection	No action required	Consider contractors’ safety and health performance in the bidding process, including a review of injury/illness rates.	Fully establish and use selection criteria. Encourage contractors to develop their own S&H management systems & decrease high rates.
Contractor Hazards	Contractor ensures correction of any hazards in their work areas.	Develop & implement a formalized method including assignment of responsibility to identify, correct, & track hazards in contractors’ work areas.	Include responsibility for hazard correction in writing, in the contracts.
Removal Policy	No action required	Develop & implement contractor policy for S&H violations, including removal and other penalties.	Penalty policy is understood by all contractors, described in their contracts, and adhered to.



Baseline Safety and IH Hazard Analysis	Conduct the baseline analysis (may use outside sources), including a chemical inventory and evaluation of typical safety and health hazards.	No action required	Re-do baseline survey, if warranted by significant changes in tasks, equipment, or processes.
Hazard Analysis of Routine Jobs, Tasks, And Processes	No action required	Conduct hazard analysis and recommend controls for routine jobs, tasks, & processes that have had associated injuries/illnesses or significant incidents or near-misses; are perceived as high-hazard; or are required by a regulation or standard; observe guidelines.	Conduct hazard analysis and recommend controls for routine jobs, tasks, and processes that have written procedures, have been recommended for more indepth analysis, or are determined by the Challenge participant to warrant hazard analysis.
Hazard Analysis of Significant Changes	No action required	No action required	Conduct hazard analysis for significant changes (e.g., non-routine tasks or new processes, materials, equipment and facilities) and recommend controls prior to the activity or use.
Pre-use Analysis	No action required	No action required	Conduct pre-use hazard analysis of new equipment, chemicals, facilities, or significantly different operations or procedures. and recommend controls prior to the activity or use.
IH Program	No action required (See Baseline Hazard Analysis).	Follow up on results of baseline IH study. Conduct more in-depth analysis if warranted to determine actual employee exposures. Establish, document, & implement future sampling schedule, strategy, and rationale.	Continue to follow the written IH program; take proactive steps to improve control of health hazards to prevent occupational disease.
Routine Self-inspections	No action required	Develop a documented system for routinely scheduled self-inspections of the workplace; conduct inspections with S&H staff; covering entire worksite, at least semi-annually.	Continue to conduct routine self-inspections. Increase frequency to at least monthly, with the entire worksite covered at least quarterly.
Employee Hazard Reporting System	No action required	Develop & begin implementing hazard-reporting system for employees (maybe anonymous),	Encourage more active reporting; ensure regular feedback, using different media, to all employees on status of hazards reported.
Investigation of Accidents and Near-Misses	Develop and implement system to report and investigate accidents. Determine root causes and track correction to completion.	Expand system to include reporting and investigation of near misses. Continue investigating accidents, begin investigating near-misses, and making corrective actions.	Thoroughly report and investigate all accidents and near-misses.
Trend Analysis	Conduct trend analysis of injury & illness history (previous 3 years of OSHA 200/300 logs) and begin developing a plan for conducting analysis of other S&H-related information	Conduct trend analysis of other S&H information not yet studied; conduct one of injury & illness history if a year has gone by since initial analysis.	Trend analysis takes place regularly (at least annually) for all types of S&H information, and is utilized in setting future goals to address identified trends.



Certified Professional Resources	(see Management Commitment)	(see Management Commitment)	(see Management Commitment)
Hazard Elimination & Control Methods	Develop an action plan to prioritize and implement controls for hazards identified, through the baseline S&IH study, trend analysis of OSHA logs and accident investigations. Implement controls or (interim protection if long-term abatement) for top priority hazards before moving onto Stage II.	Complete long term abatement projects from Stage I. Develop an action plan to prioritize and implement controls for hazards identified through self-inspections, employee reports of hazards, and nearmiss investigations. Implement hazard controls (or interim protection) for top priority hazards before moving onto Stage III.	Complete long term abatement projects from Stage II. Continue to pro-actively identify, prioritize, and implement controls for hazards identified through all means (hazard analysis, trend analysis, accident and near miss investigation, self-inspections, employee reports of hazards, pre-use analysis, etc) so that there is a continuous loop of hazard id and control.
Hazard Control Programs	Inventory existing hazard control programs required by OSHA standards. Develop missing programs or modify existing programs.	Implement hazard control programs developed or modified in Stage I and train all workers on these programs.	Review hazard control programs annually and updated as new processes, jobs, and tasks are begun.
Documented System for Hazard Correction Tracking	Develop and begin implementing a hazard tracking system for hazards identified through the baseline hazard analysis, trend analysis of OSHA logs, and accident investigations.	Expand tracking system to include hazards identified through hazard analysis of routine jobs; self-inspections; employee reports of hazards; and near miss investigations.	Tracking system is fully functioning and includes hazards identified through all methods.
Preventive Maintenance	Conduct an inventory of equipment and machinery requiring preventive maintenance.	Review equipment inventory. Establish and implement preventive maintenance schedule.	Ensure schedule is routinely observed and preventive maintenance is regularly conducted.
Occupational Health Care Program	Conduct records review of previous three years OSHA 200/300 logs. Compare with insurance claims forms and ensure records are in order. Provide physician services for emergencies (see below).	Continue to provide access to licensed health care providers, health services, physician care, and emergency medical care. Arrange for services based on the outcomes of the baseline safety and health analysis.	Continue providing services listed in Stage I and II. In addition- Health Care providers visit the site, and assist in identifying causes and symptoms of injury/illness. Care provided in within the scope of licensure.
Emergency Preparedness and Response	Establish & communicate written procedures for responding to all types of emergencies; Make emergency services available on all shifts including: ambulances, EMT’s, emergency clinics, or hospital emergency rooms. Provide at least one employee trained in first aid & CPR for each shift or an equally effective alternative. Conduct at least one evacuation drill & assess its effectiveness.	Continue providing emergency medical services. Establish an Emergency Response Team including first aid and CPR trained employees. Conduct at least one drill and assess it’s effectiveness and follow-up on recommendations to improve emergency evacuation drills.	Continue providing emergency medical services. Establish a Haz. Mat. Team if necessary. Consult with local fire department to ensure adequate coverage for fire, explosion, or chemical release. Conduct evacuation drills at least annually and assess their effectiveness. Provide AED and training on its use for those on the Emergency Response Team.



General guidelines	Observe OSHA guidelines in providing training for required programs.	Continue observing OSHA VPP guidelines in providing training.	Continue observing OSHA VPP guidelines in providing training.
Training for all workers	Provide training to all workers on their S&H rights, Challenge, VPP fundamental principles, hazards in the workplace, PPE, emergency evacuation procedures, and individual emergency responsibilities.	Continue providing training to all workers, including new workers, on their S&H rights, Challenge, VPP fundamental principles, hazards in the workplace, PPE, emergency evacuation procedures, and individual emergency responsibilities.	Take proactive steps to improve & continue providing training to all workers, including new workers, on their S&H rights, Challenge, VPP fundamental principles, hazards in the workplace, PPE, emergency evacuation procedures, and individual emergency responsibilities.
Training for specific groups of workers	Provide specific training to managers and supervisors, to designated S&H staff and others with S&H responsibilities, and to contract workers to equip them with knowledge & skills needed to perform their S&H responsibilities in Stage I (i.e., hazard recognition, accident investigation and root cause analysis, hazard controls, OSHA standards, and VPP requirements).	Provide specific training to managers and supervisors, to designated S&H staff and others with S&H responsibilities, and to contract workers to equip them with knowledge & skills needed to perform their S&H responsibilities in Stage II.	Take proactive steps to provide specific training to all employees and contract workers to equip them with the knowledge & skills they need to perform their S&H responsibilities in Stage III.

Appendix D

OSHA Strategic Partnership Program
Annual Partnership Evaluation Report

Cover Sheet






Goal	Strategy		Measure






Construction		Amputations in Manufacturing
General Industry

Amputations in Construction		Oil and Gas Field Services
Blast Furnaces and Basic Steel Products		Preserve Fruits and Vegetables
Blood Lead Levels		Public Warehousing and Storage
Concrete, Gypsum and Plaster Products		Ship/Boat Building and Repair
Ergo/Musculoskeletal		Silica-Related Disease
Landscaping/Horticultural Services

Section 1 General Partnership Information



Start Date		End Date


# Active Employers		# Active Employees

Partner	SIC		NAICS

Section 2 Activities Performed


	Required	Performed
a. Training
b. Consultation Visits
c. Safety and Health Management Systems Reviewed/Developed
d. Technical Assistance
e. VPP-Focused Activities
f. OSHA Enforcement Inspection
g. Offsite Verifications
h. Onsite Non-Enforcement Interactions
i. Participant Self-Inspections
j. Other Activities

Training session conducted by OSHA staff
Training session conducted by non-OSHA staff
Employees trained
Training hours provided to employees
Supervisors/managers trained
Training hours provided to supervisors/managers



Consultation visits to partner sites



Systems implemented or improved using the 1989 Guidelines as a model



	Provided by OSHA Staff	Provided by Partners	Provided by Other Party
Conference/Seminar Participation
Interpretation/Explanation of Standards or OSHA Policy
Abatement Assistance
Speeches
Other (specify)



Partners/participants actively seeking VPP participation
Applications submitted
VPP participants



OSHA enforcement inspections conducted
OSHA enforcement inspections in compliance
OSHA enforcement inspection with violations cited
Average number of citations classified as Serious, Repeat, and Willful



Offsite verifications performed



Onsite non-enforcement verifications performed


Self-inspections performed
Hazards and/or violations identified and corrected/abated

Section 3 Illness and Injury Information A

Year	Hours	Total Cases	TCIR	# of Days Away from Work Restricted and Transferred Activity Cases	DART
2009
2010
2011
Total

BLS National Average for 2007*			12.4		7.1
Baseline
Comments
*Search Bureau of Labor Statistics databases at www.bls.gov/iif “ under NAICS 321991 (manufactured housing) for TCIR and DART Rates needed to calculate eligibility requirements for VPP application. Rates are given from present to several years back.

A Sample Chart – not required format

Section 4 Partnership Plans, Benefits, and Recommendations


	Changes	Challenges
Management Structure
Participants
Data Collection
Employee Involvement
OSHA Enforcement Inspection
Partnership Outreach
Training
Other (Specify)


	Improvements	N/A
Meet more often
Improve data collection
Conduct more training
Change goals



Increased safety and health awareness
Improved relationship with OSHA
Improved relationship with employers
Improved relationship with employees or unions
Increased number of participants
Other (specify)



Partnership Completed
Continue/Renew
Continue with the following provisions:

Terminate (provide explanation)

1. VPP is administered separately from OSHA’s Strategic Partnership Program. Participation in the partnership is not a guarantee of acceptance into VPP.

2. Under the partnership, OSHA is requesting the VPP mentor assist OSHA in conducting and reporting to the company the results of the initial safety and health management system gap analysis, advise the company on the VPP application and implementation process and help conduct a mock VPP inspection toward the end of the two-year agreement. Additional help is at the discretion of the mentor and should be worked out on a case-by-case basis as time and resources allow.


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