Tag Archives: enforcement

Top OSHA Trends Facing Employers

OSHA is in something of a holding pattern while it awaits a new administrator. Nevertheless, now is not the time for employers to let their guards down.

The agency has operated under the acting leadership of Loren Sweatt since July 2017. The president’s October nomination of Scott Mugno, vice president of safety at FedEx Ground, to be the next OSHA administrator continues to be delayed amid political wrangling. With many career agency personnel in place, enforcement looks similar to the Obama administration in many ways.

Overall Trends

“Confusion, compliance and anticipation” is the phrase that best sums up OSHA during the first year-and-a-half of the new administration. There have been delays in enforcement and effective dates for some regulations; however, OSHA has not retreated from inspections or enforcement activities.

Expectations for a more business-friendly environment under the Trump administration have yet to materialize, although there have been signs that there will, ultimately, be moves toward deregulation and less aggressive enforcement.

No long-standing regulations have yet been repealed, which is not surprising, given the lack of a permanent leader and the fact that OSHA regulations cannot be revoked solely for economic reasons.

However, we have seen activity on regulations that were already in process. They are among the clear indications that the Trump administration plans to take a different tone than the Obama administration:

2-for-1 Requirement. The president’s signature on Executive Order 13771 requires agencies to eliminate two regulations for every one promulgated.

Rule changes. The president employed the rarely used Congressional Review Act to repeal 14 regulations, including:

  1. The Volks Act. The president effectively overturned the rule that made recordkeeping requirements a continuing obligation for employers. Essentially, OSHA had the ability to enforce recordkeeping requirements for five-and-a-half years, rather than six months.
  2. Fair Pay and Safe Workplaces Rule. The president signed a resolution that blocked the Obama-era rule requiring federal contractors to disclose and correct serious safety and other labor law violations.

Rule movement. Several OSHA rules have been moved to “long-term actions” or completely eliminated from the administration’s first two regulatory agendas.

  • 1. Removed from regulatory agendas:
    • Vehicle backing hazards
    • Updates to chemical permissible exposure limits (PELs)
    • Comprehensive combustible dust rule
    • Hearing protection in construction
  • 2. Moved to long-term actions, essentially putting them on an indefinite delay:
    • Workplace violence
    • Emergency preparedness and response
    • Process safety management (PSM) rule reform
    • Infectious diseases in healthcare

Another signal of the Trump administration’s intentions toward deregulation is the changing of the name “Regulatory Agenda” to “Unified Agenda of Federal Regulatory and Deregulatory Actions.”

See also: Health Consumerism, Stress Management  

Controversial Initiatives

Employers need to be aware of several regulations in the pipeline to ensure they understand and comply with the requirements.

Electronic Recordkeeping

OSHA’s effort to improve tracking of workplace injuries and illnesses requires certain employers to electronically submit data they are already required to keep. But there has been significant confusion and consternation over the standard. One issue is the implementation schedule.

There are clear indications that OSHA intends to amend this rule to ease some of the requirements on employers. As it appears now, the deadlines are:

July 1, 2018: Employers with 250 or more workers, and those with 20 – 249 employees in “high-hazard industries,” must electronically submit information from their 300A annual summaries of work-related injuries and illnesses.

March 2, 2019: Every establishment must submit information from their 300A summaries. The rule has been fraught with controversy and questions, such as:

  • Where will OSHA put the information? There are concerns that employers’ information may become publicly available. However, if the agency opts not to collect the 300 logs and 301 forms as expected, that concern would be eliminated.
  • How will OSHA use the information? With data on fatalities, amputations, hospitalizations and other factors available on computers, OSHA compliance officers could determine inspection priorities based on that information. But there are indications that the Trump administration may back off from the forceful enforcement mentality.

OSHA’s about-face: The agency recently announced that employers in all states must electronically submit their data for calendar year 2017 by July 1. This caught many by surprise, as several states with OSHA-approved state plans had not yet updated their recordkeeping requirements and employers in those states were under no such requirements. Additionally, the announcement means that the states involved are now under a greater regulatory compliance burden.

Silica

OSHA established a new eight-hour weighted average PEL on silica for affected industries. The construction sector was first up in September, although the agency delayed enforcement for one month.

The agency will begin enforcing the rule for general industry on June 23, including training requirements. While there is a chance the deadline will be delayed, employers should nevertheless be prepared to comply.

Fall Protection

The Walking/Working Surfaces Rule has caught many employers by surprise. The rule went into effect in January 2017, and OSHA is strongly enforcing it.

To date, OSHA has cited and imposed hefty fines on at least 12 employers for violating the rule, despite having no associated injuries. For example:

  • One employer was penalized $114,000 for failing to ensure each surface could support a maximum load.
  • Another was fined $36,000 for failure to guard unprotected sides and edges at a height of at least four feet.

Despite some confusion surrounding this rule, we can expect OSHA to inspect and cite companies for violations. Employers should research how they are affected and what they need to do.

Beryllium

As of May 11, affected employers were required to abide by new PELs and short-term exposure limits.

On a positive note, the agency recently clarified that the rule only applies to areas where there are significant amounts of beryllium, rather than just trace amounts. That will save on business compliance costs, and it eliminates some of the vagueness of the rule.

Enforcement

The public shaming via press releases under former OSHA Administrator David Michaels subsided in 2017, but there seems to be a renewed effort in 2018. One recent example was the announcement of a $40,000 fine imposed for trenching operation violations that OSHA officials discovered while doing a drive-by of a construction site.

Additionally, there has been an unexpected slight uptick in inspections in 2017. Combined with the congressionally mandated increase in penalties in 2016, it means employers need to pay attention. Again, the increased number of inspections may be due to the fact that career OSHA personnel are operating with no official leader.

Look-back period: This is an issue to watch closely, to see if the administration may decrease the look-back period for violations that OSHA can use for repeat violations. The previous three-year period was expanded to five years during the Obama administration. Also during the Obama administration, repeat violations were cited more frequently and with higher fines. A recent court ruling in New York said the look-back period is non-binding. That does not bode well for employers that have enhanced their programs and are doing the right thing, only to have the agency cite them for violations that occurred years ago.

Another change under the previous administration was the consideration of workplaces as being under the same corporate umbrella. Previously, workplaces were deemed individual, stand-alone establishments, regardless of the parent company.

We believe the administration will eventually roll the look-back period to three years and consider workplaces to be individual establishments again. However, this may not happen until late this year or beyond, as these changes likely will not be an immediate priority for the new OSHA administrator.

Compliance Assistance

We have seen a clear focus lately on helping employers comply with OSHA regulations, rather than the “enforcement, enforcement, enforcement” effort of previous administrations. There have already been announcements of new alliances between OSHA and various industries or organizations, including one with the Board of Certified Safety Professionals. We expect efforts to provide more assistance and guidance to continue, possibly through the use of “letters of interpretation” to change the tone to one of more compliance assistance.

The Voluntary Protection Program (VPP) was not a favorite of the previous administration. It was viewed as too easy to get in, and difficult to expel companies. But the Trump administration already held a stakeholders meeting to discuss revitalizing the program. Topics included ways to:

  • Encourage participation
  • Ease entry
  • Enhance the benefits
  • Engage network members

One concern, however, is whether there will be enough funding to support these compliance assistance programs. Positions that were eliminated two years ago would need to be resurrected.

State Plans

Twenty-two states have their own OSHA-type programs, and there has definitely been an increase in activity — especially in some of the blue states. California, for example, has hired a number of enforcement officers. That state is also implementing a workplace violence standard for healthcare and an injury prevention rule for hotel and housekeeping. Additional proposals in California may be approved. Washington and Oregon are also taking steps that are stronger than the federal OSHA requirements.

One concern for employers is the patchwork of compliance among states that are failing to meet OSHA-required deadlines. Maryland, Arizona, Hawaii, Utah and Wyoming, for example, have not adopted a silica rule, despite the requirement to do so by late 2016. Even if these states lack appropriate funding, they could easily adopt the federal rule — but have chosen not to. We may see the agency step in as it did with the electronic recordkeeping rule recently.

See also: Healthcare: Need for Transparency  

Dates to Remember

Employers need to ensure compliance for the following:

Beryllium — March 12: Employers had to comply with the majority of requirements.

Silica — June 23: 

  • General industry and maritime employers must be in compliance with all requirements except action-level triggers for medical surveillance; they must also offer medical exams to employees with exposure above PEL for 30 days or more in a year.
  • Construction employers must comply with methods of sample analysis.

Electronic Recordkeeping — July 1: 

  • Companies with 250-plus employees must electronically submit 300A data.
  • Certain high-risk establishments with 20 – 249 employees must submit 300A forms.

Cranes and Derricks — Nov. 10: Crane operators must be certified

Walking/Working Surfaces – Nov. 19:

  • New fixed ladders greater than 24 feet must be installed with fall arrest or ladder safety systems.
  • Existing ladders greater than 24 feet must be equipped with cage, well, personal fall arrest systems or ladder safety systems.
  • Replacement ladders and ladder sections must be installed with fall arrest or ladder safety systems.

What EPA Is Targeting for Enforcement

Every three years, the U.S. Environmental Protection Agency (EPA) identifies certain national environmental problems where it believes it can make a difference by dedicating direct enforcement resources. Starting on Oct. 1, 2016, and for the next three fiscal years, these “National Enforcement Initiatives” (“NEIs”) include two new ones, an expanded one and four existing initiatives.

These seven enforcement priorities offer insights into how the EPA plans to allocate its enforcement resources to specific environmental hazards concerning water, air, hazardous chemicals and energy extraction.

As the EPA moves forward with these priorities, businesses need to be cognizant of the increased enforcement potential, especially to avoid non-compliance, and thus mitigate the associated environmental risk.

Here is a recap of the initiatives:

1. Water Pollution

Pollution of waterways from raw sewage systems, storm drains, underground storage tanks, runoff and waste disposal continues to be a high priority for the EPA. Recent attention from the lead- contaminated water in Flint, MI, and the Gold King Mine wastewater release have underscored the need for heightened enforcement.

The EPA’s “new” water enforcement focus is keeping industrial pollutants out of the nation’s waters. The EPA will be directing enforcement resources on certain industrial sectors identified as “disproportionate contributors” to pollution, including chemical and metal manufacturing, mining and food processing. Concentrated Animal Feeding Operations (CAFOs) and Animal Feeding Operations (AFOs) will also continue to be enforcement priorities.

See also: Minding the Gap: Investment Risk Management in a Low-Yield Environment  

Water-related enforcement initiatives are:

  • Industrial pollutants (new initiative): The EPA will rely on water pollution data to target facilities in industrial sectors like chemical, metal manufacturing, mining and food processing to cut illegal discharge of nutrient and metal pollution into lakes, rivers and streams.
  • Raw sewage and contaminated storm water: The EPA is targeting municipal sewer systems, using Clean Water Act violations to reduce pollution and volume of storm water runoff and to prevent unlawful discharges of raw sewage. Sources for this pollution include industrial runoff, fertilizers, fossil fuels and general human activities.
  • Animal waste: The EPA will use innovative monitoring and targeting techniques to reduce and control chemicals and waste from controlled animal feeding operations.

2. Air Pollution

Primary contributions to air pollution come from large industrial facilities like coal-fired power plants, acid, glass and cement manufacturing operations. Ensuring that these facilities comply with the Clean Air Act and reduce emissions has been a focus of the EPA since 2005.

EPA investigations have found that many of these facilities failed to upgrade or install pollution-control devices during modification and construction of new plants. The results have prompted new and continued focus on air-enforcement initiatives:

  • Reducing air pollution from large sources: This new initiative aims to ensure that large industrial facilities install state-of-the-art air pollution controls when they build new facilities or make significant modifications to existing facilities.
  • Cutting hazardous air pollutants: This expanded initiative is focused on accurate reporting for refineries, chemical plants and other industries that emit hazardous air pollutants or air toxics. The initiative has now been expanded to include large product storage tanks, hazardous waste generators and treatments, as well as storage and disposal facilities.

3. Hazardous Chemicals

This year’s new hazardous chemical enforcement priority targets chemical plant pollution for causing large volumes of hazardous substances and having a high frequency of catastrophic accidents (150/year). Because many of these facilities are located in low-income communities, activists’ calls for environmental justice have made this a priority.

Mining and mineral processing operations continue to generate more toxic and hazardous waste than any other industrial sector. Through its continued enforcement efforts, the EPA has reduced the risk of mining waste contamination of drinking water, rivers and streams, and is working to clean up mining sites across the nation.

The areas of priority are:

  • Accidental releases: This new initiative attempts to step up scrutiny of pollution sources (i.e. chemical and manufacturing plants), ensuring that these facilities reduce the risk of accidental releases through innovative accident prevention measures and improving response capabilities.
  • Mineral processing operations: Focus is on discharges from mining operations and cleanup of point sources that the EPA believes are threaten drinking water, rivers and streams.

4. Energy Extraction

Referred to as a “bridge-fuel,” natural gas serves as a lower-CO2 alternative to coal, as the country tries to refine and expand its renewable energy sources. However, the extraction of natural gas poses risks from improperly maintained wells that can leak natural gas into waterways and water sources. Combustion of methane produces a potent greenhouse gas, and communities in and around these operations can also be exposed to carcinogens like benzene and other smog-forming pollutants. This initiative aims to ensure that natural gas extraction and production is done in a way that minimizes these risks.

In the past three years, the EPA has settled a number of high-impact cases under this initiative and will continue to address noncompliance through greater use of advanced pollution monitoring and reporting techniques.

Past Enforcement Highlights:

The EPA’s enforcement highlights for 2015 provide a constructive snapshot of the breadth of the agency’s enforcement authority:

  • $7 billion by companies in equipment upgrades and clean-ups;
  • $404 million in combined federal administrative, civil judicial penalties and criminal fines;
  • $4 billion in court-ordered environmental projects resulting from criminal prosecutions;
  • 129 combined years of incarceration for sentenced defendants;
  • $1.98 billion in commitments from responsible parties to clean up superfund sites; and
  • $39 million for community environmental mitigation projects.

According to the latest EPA enforcement statistics, more than 98% of cities with large combined sewer systems, and more than 90% of cities with large sanitary sewer systems, are under enforceable agreements. About 59% of individual power generating units at coal-fired power plants have installed the required pollution controls or are under a court order to do so. Meanwhile, the agency says it has settled with 217 concentrated animal feeding operations for regulatory violations and issued enforcement actions to 196 natural gas extraction and production sites.

See also: Developing A Safe Work Environment Through Safety Committees  

Meanwhile, the focus on larger cases is expected to continue, with the EPA stating that it will specifically target facilities that operate in multiple states to support “a consistent national strategy.” Consider the following recent EPA enforcement settlements:

Water:

A large farming cooperative and processing facility that manufactures refined sugar, liquid sugar and other products from sugar beets will pay $6 million in an agreement to resolve Clean Water Act violations at its processing facility. Under the terms of the settlement, the company will model the volume of its wastewater ponds, audit its wastewater piping systems, drain lines from spray irrigation fields and use automatic cut-off valves to prevent further discharges.

Air:

A large cement manufacturer will invest $10 million to cut emissions of harmful air pollution at five of its manufacturing plants to resolve alleged violations of the Clean Air Act. As part of the agreement, the company will install and operate modern pollution controls for nitrogen oxide (NOX) emissions at its kilns, conduct detailed diagnostic energy audits and spend $150,000 in mitigation on energy efficient projects that reduce nitrogen oxide emissions.

Hazardous Chemicals:

Under an amendment to a 2012 agreement, a large petroleum company will spend $319 million to install state-of-the-art flare gas recovery systems (FGRSs) that will capture and recycle gases that would otherwise be sent to flares at facilities in Illinois, Kentucky, Louisiana, Michigan and Ohio. These efforts are projected to reduce emissions from flares by 896 tons per year.

Energy Extraction:

A large oil and natural gas exploration and production company will pay $5 million to resolve federal and state violations of requirements for the installation, operation, maintenance, design and sizing of vapor control systems at condensate storage tanks. The company will make necessary modifications to ensure that each vapor control system is properly designed and operated, and will spend at least $4.5 million on environmental mitigation projects that will reduce volatile organic compounds and nitrogen oxides.

With evolving environmental standards, businesses need to remain well-informed of these EPA enforcement priorities.

Breaking Through The Barrier Of Hardnosed Workers, Part 2

Righting The Ship Wrongly
For torturous purposes, let’s say that you are an executive manager who has inherited the type of hardnosed workforce described in Part 1 of this series.Your laborers are largely emotionally repressed, unsympathetic, narcissistic, uncontrollable and prone to permanently go AWOL. Ditto for your supervisors and managers. Collectively, your work force constitutes a change-resistant barrier that thwarts every attempt at achieving continuous improvement.

As risk strategist Greg Pena suggests, you set about to correct the obstructionist nature of your workforce. Otherwise, your best management efforts are “doomed from the start.”

Which quick-action strategy do you choose?

  1. Create and enforce more rules designed to secure better worker behavior?
  2. Implement a system of rewards and awards designed to reinforce good behavior?
  3. Pursue an aggressive program of quality assurance that requires strict behavioral compliance and reporting?
  4. Institute a behavior observation program that results in establishment of improved work procedures and oversight?

This is not a trick question.

Damage Control

To begin, you might start by quickly doing what others have traditionally done in similar situations.

  1. Assess where the most “damage” is being done by the most resistant workers.
  2. Speed headlong in pursuit of the holy grail of gaining control of those workers.

You do this because you’ve been taught that lack of control is the foundational cause of rebellious behavior. Control is considered a weapon. To heck with human resource management laws and employee management policies. They are slow, ineffective weapons of change. You need something that works quickly.

So to gain instant influence, you deploy whichever of the quick-action strategies (above, a–d) that you think will give you the fastest results. Each approach promises control; all are known quantities. Together, they constitute the bulk of management’s current wisdom in wrestling control from hardnosers.

The strategies are as follows.

a. Control By Directive — create and enforce more rules.
This is an old tactic closely associated with authoritarian or directive leadership style — it is dependent upon the strict use of the chain-of-command for enforcement. The strategy involves using rules and regulations to achieve (by demand) behavior compliance — control. It is the attempt to regulate and regiment behavior.

b. Control By Incentive — implement a system of rewards and awards.
This is a popular method of gaining control because it seems to “make the most sense” when it comes to worker motivation. It is based upon the belief that workers will be motivated to better behavior if they receive objective rewards, incentives or other strokes of positive reinforcement. Typically these take the form of safety awards, cash rewards or financial incentives that depend on the utilization of performance evaluations, merit ratings, or periodic reviews.

c. Control By Quality — pursue an aggressive program of quality assurance.
This is an old but evolving strategy, currently masquerading as the GRC (Governance, Risk & Compliance) movement. It promises the possibility of simultaneously achieving quality assurance, risk control, regulatory compliance, and behavioral control — with a dash of ethics, integrity, and maturity thrown in — if only we pursue the perfect quality assurance processes. This strategy started as the ISO quality certification process in which rigid paperwork and reporting processes are utilized by managers as an accountability tool.

d. Control By Observation — institute a behavior observation program.

This is a relatively new approach to gaining control of worker behavior. It is known by its popular name, behavior-based safety. In this approach, workers are trained to make intense and frequent observations of common work tasks in order that they might consult together and develop better methods for carrying out the work task. Workers are also taught the basics of how to communicate with each other when feedback is given on performance of work tasks. They are typically required to submit observational reports to authorities.

You don’t need to look hard to find assistance in whichever line of attack you choose. Professional pundits and practitioners of each stratagem are plentiful. So you select a plan. And it initially appears to work.

But its effectiveness in providing you anything other than short-term victory is sadly wasteful — your plan does not consider the characteristics of hardnosed behavior described in Part 1 of this series. None of the traditional control strategies do.

Eventually, you join the ranks of the frustrated transportation manager (Part 1) who implemented a safety training observation program, improved his operational policies, and led his organization in the ISO 9000 certification process — all to little avail. He still couldn’t control his hardnosers.

Changing the emotionally insular nature of rejection-prone people is hard. But as the manager stated, “The alternative, letting them continue to drag our company down, is not an option.”

Rejection On Demand
The fundamental mistake made by a majority of managers is assuming that control is the main issue, that control reduces resistance. And while control certainly occupies a high priority, the real issue is how it is obtained and why it is necessary to sustain it.

The tendency is to forget the lesson learned by all authorities. Any attempt to gain and maintain control of people in the wrong way ultimately results in the rejection of the authority.

Historian Page Smith states it this way. “The whole course of history indicates that one of the most potent bases of common action is a common sense of unjust subordination.”

Unjust. Fair or not, that’s how the common hardnoser views your attempt to gain control of him when you employ any of the well-intentioned strategies listed above. Setting aside the perception of justice, the hardnoser makes a valid point. Many times management demonstrates that it doesn’t know how to gain control, nor bother to explain why it is necessary.

What? Is Not The Question
Tom Slattery, Environmental Health and Safety Manager at POET Plant Management, pulls no punches in holding management accountable. “The way management and safety people talk to and treat the workforce,” he says, “is largely responsible for the ‘bad attitudes’ in the workforce.”

Slattery cites instances in which management says it wants one thing yet subtly rewards the opposite, essentially abusing its control. Placing himself in the mix, he says, “We do not follow through on promises, ask for true employee participation, nor explain the ‘why’ behind policies.”

In the realm of change-resistance, telling someone what to do and how to do it without telling them why they are doing it — why it is to their benefit to do it — is a cardinal sin. As Slattery emphasizes, telling them poorly adds fuel to the fire. It is the equivalent of assuming the listener has no needs other than the need to obey the management. Part 3 of this series explores the depth of the disdain created by this assumption.

Any child knows that asking an uncaring parent the why question (in a response to a command) almost always solicits the brusque answer, “Because I said so.” Yep, that really works.

Ignoring the need of workers to know why they must relinquish autonomy in order to follow the lead of management will provoke resistance from even-tempered people, much less needy hardnosers. Yet historically, that’s what management has done.

In the attempt to gain control of hardnosers, we’ve employed a lot of ‘what to do’ and ‘how to do it’ tactics without first considering the felt needs of the worker. Management asks for the rejection it anticipates.

As a result, a Cycle of Rejection develops. Most organizations that spawn hardnosers are guilty of entering this 6-step cycle. As illustrated below, the black colored steps represent management; red represents workers.

The 6 R’s Leading To Rejection

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Frequently the cycle of management missteps — the six R’s — that reinforce an ever-increasing change-resistant work force is as follows. If the object is control, this is how not to get it.

Revelation — Often using poor and impersonal communication, management tries to educate the worker with bits and pieces of the performance puzzle, most often “what we want you to do” and “how we want you to do it.” These are typically the minimum requirements of compliance — the policies, practices, or procedures that the worker is expected to obey/follow.

Response — The worker responds negatively to poor communication and perceived command-and-control tactics — they remain largely unresponsive to performance expectations. The worker equates poor communication with perceived neglect of both his real and felt needs. He begins to develop an attitude of skepticism/pessimism towards management.

Rationalization — Based upon the worker’s non-response, management perceives a resistance in the worker. Rationalizing that the only way to accomplish its desired performance goals is to use more direct commands, they resort to directive leadership methods designed to seize control of the sources of resistance and to force worker compliance.

Regimentation — Upon rationalizing that the worker will only respond to authoritative command structure, managers put forth a regimented series of operational rules and regulations — more specifics about what to do and how to do it — designed to force the worker to shape up (comply).

Resistance — The worker resists management even further, thinking that management is overbearing and taking away his ability to conduct his job as he sees fit. The process of addressing performance management through poor communication skills and mistaken tactics results in an increasingly change-resistant hardnosed worker.

Repeat — Management redoubles its effort to control the worker without rethinking its strategy. Nor does it stop to analyze the nature of the resistant worker and his felt needs. Repeated failure to do so leads the worker to forthrightly reject any and all attempts by management to seize control. To the worker, management becomes an unjust usurper.

Management’s inclination to simultaneously consider the steps of Rationalization and Regimentation are why they appear back-to-back in the cycle. As management becomes more entrenched, determined to win the control war, the gap between the two steps narrows. It becomes easier to rationalize that more regimentation is needed.

Duck & Cover
What the Cycle of Rejection illustrates is the futility of thinking that command will result in the control of hardnosers. Quite the opposite. But while it’s folly to follow this path of thinking, there is an even more damaging option to choose: doing nothing.

An operations manager whose supervisors had long been on the road to rebellion had this exact strategy in mind — do nothing — when he sheepishly asked the author, “You aren’t going to stir the pot, are you?”

The manager was worried that a few forthright words from the author’s keynote address to the supervisors would enflame the emotions that lay, he thought, comfortably submerged below the thin surface of civility. Yet his boss, the business owner, wanted a permanent solution to his hardnosers’ resistance. He wanted to take back control of his workforce. But no one knew how, much less why. Part 3 of this series will show you both.

Yes, the pot will be stirred.

Bibliography

“Focus On Teamwork, Attitude Improves Quality And Safety.” The Waterways Journal. April 25, 1994: 41-44

Newton, Ron. No Jerks On The Job. Irving, TX. PenlandScott Publishers, 2010.

Riddle, Glenden P. An Evaluation Of The Effectiveness Of Stress Camping Through The Use Of The Taylor-Johnson Temperament Analysis Exam. Research Project. Dallas Theological Seminary, December 1978.

Taylor, Robert. Taylor-Johnson Temperament Analysis Manual. Thousand Oaks: Psychological Publications, Inc., 1992.