Press Call: Final Rule on Expanding Recordkeeping Requirements

NWX-DOL OSEC (US)

Moderator: Jesse Lawder
September 11, 2014
12:30 pm CT

Coordinator:

Welcome and thank you for standing by. At this time all participants are in a listen-only mode until the question and answer session. If you would like to ask a question at that time, please press star 1 and record your name along with your organization or media outlet when prompted. Today's conference is being recorded. If you have any objections, you may disconnect at this time.

Now I'd like to turn the conference over to your host, Jesse Lawder. Thank you. You may begin.

Jesse Lawder:

Hi. Thanks everybody for getting on the call today. We have a lot to get through so I'm going to turn this over now to Dr. David Michaels who's going to talk to you about the rule we're announcing today.

Dr. David Michaels:

Good afternoon. Thank you for joining me. I'm Dr. David Michaels. It's my great honor to announce OSHA's final rule expanding requirements for employers to notify OSHA when a worker is killed on the job or suffers a work-related hospitalization, amputation or loss of an eye.

This new rule also updates the list of employers partially exempt from OSHA recordkeeping requirements. These new updates will go into effect for employers and states covered by Federal OSHA on January 1, 2015.

Earlier today the Bureau of Labor Statistics reported that 4,405 workers were killed on the job in 2013. Forty-four hundred and five on-the-job deaths is 4,405 too many. We can and must do better.

OSHA's new requirement to report severe injuries and illnesses will assist employers, workers and OSHA to prevent future injuries by identifying and eliminating the most serious workplace hazards, ones that have already caused injuries to occur.

With this revised rule, OSHA will now receive reports from employers whose workers were killed or suffered severe work-related injuries and illnesses. This will significantly enhance OSHA's ability to target our resources to further prevent injuries and to save lives.

The data from these new reports will enable OSHA to better identify workplaces where workers are at greatest risk and to target our compliance assistance and enforcement resources accordingly. This new rule will help establish a new relationship between OSHA and employers whose employees have been seriously injured.

The revised rule includes two key updates. First, we are updating the list of industries that are exempt from routinely keeping OSHA injury and illness records.

I want to make it very clear that even though we are updating the list of exempt industries, the new rule maintains the recordkeeping exemption for any firm with ten or fewer employees regardless of their industry classification.

Regarding the newest employers that are exempt from routinely keeping records, employers in these industries are exempt because the industries have relatively low occupational injury and illness rates.

Since 1982 this list has included establishments in finance, insurance, real estate and parts of the retail and service industries. The new list of exempt industries is based on Bureau of Labor Statistics data from 2007 through 2009 replacing a list developed using data from the 1990s.

In addition we have transitioned from the old standard industrial classification or SIC system to the North American Industry Classification System or NAICS. NAICS is the standard widely used by federal statistical agencies such as the BLS and others for the purpose of collecting, analyzing and publishing data on business establishments.

SIC codes are rarely used anymore. NAICS is the modern industry classification system used throughout the government. Updating to NAICS also fulfills a commitment OSHA made in the 2001 revision to the recordkeeping rule, as well as a 2009 commitment we made to the Government Accountability Office.

Second, we are updating the requirements for reporting work-related fatality, injury and illness information to OSHA. Currently employers in states covered by Federal OSHA are required to report all work-related fatalities and hospitalizations of three or more employees within eight hours of the event.

The revised rule retains the requirement to notify OSHA of all work-related fatalities within eight hours and adds a new requirement for employers to report all work-related inpatient hospitalizations, amputations and losses of an eye within 24 hours of the event.

Employers can report these events by telephone or in person to the OSHA area office that is nearest to the site of the incident or by calling OSHA's toll free number 1-800-321-OSHA, which is 1-800-321-6742, or through an electronic form that will soon be available on OSHA's public Web site. That's www.osha.gov.

Hospitalizations and amputations are sentinel events indicating that serious hazards are likely to be present at the workplace and an intervention is warranted to protect other workers at the establishments.

Too often we learn of a worker being killed or seriously injured and when we inspect, we learn that one or more workers have already suffered serious injuries at that establishment.

Last year, OSHA was notified after a worker was struck and killed when he entered a large wire mesh manufacturing machine to retrieve a fallen metal bar. The worker killed was 32-year-old Luis Rey Rivera Pavia. He was the sole supporter of his mother who lives in a small village in Mexico. His death should never have occurred.

The light curtain that would automatically turn the machine off before he entered the danger zone had been disabled. During our inspection, OSHA learned that previously two other workers at that same factory had been severely injured on the same piece of machinery. One worker suffered an amputation and the second had his right forearm crushed by that same machine.

Earlier this year we issued a fine of almost $700,000 against Wire Mesh Sales of Jacksonville, Florida. However, I believe that if we had been notified after that amputation or after his co-worker was hospitalized with a crushed forearm, Mr. Rivera might be alive today.

We expect to be notified of many hospitalizations and amputations. We're not going to send an inspector to respond to every one of these. But we will engage with the employers whose workers have been hurt. Right now we're developing a process to determine which incidents to inspect and which to handle using other types of investigations and interventions.

This rule is an example of the application of behavioral economics to worker safety. When an employer notifies us of a severe injury among its workers, we'll ask what caused the injury and what the employer intends to do to address the hazard and prevent future injuries. That employer will then be on notice that OSHA knows about that severe injury and will have made the commitment to address the hazard.

We believe that as a result of this interaction that employer will be more likely to take the steps necessary to better protect the lives and limbs of their employees.

This rule has other important benefits. OSHA currently receives little information about serious non-fatal injuries and the new data will help us better allocate agency resources and assess the adequacy of our standards.

For example, the reports on amputations will provide us with information to better focus the scope of our amputation prevention and inspection program and evaluate possible deficiencies in our machine guarding standards. It'll also help us better target employers and industries that need the assistance of our free onsite consultation program.

These new reports of severe injuries and illnesses will all be public on the OSHA Web site providing employers, workers, researchers and the public more information about workplace safety and health and steps that need to be taken to prevent further injuries.

Since no employer wants its workplace to be known as an unsafe place, we believe that the possibility of public reporting of serious injuries will encourage or, in the behavioral economics term, “nudge” employers to take steps to prevent injuries so they're not seen as unsafe places to work.

After all, if you have a choice of applying for a job at a workplace where a worker had recently lost a hand versus one where no amputation has occurred, which would you choose?

Regarding the changes in the list of industries now required to maintain injury and illness records, we've planned extensive outreach and coordination with employers, particularly small businesses, trade associations whose members may be new to recordkeeping, unions and worker centers.

We'll notify establishments and industries that are new to keeping OSHA logs, explaining their new obligations and where to find resources to help them. These resources include tutorials, information fact sheets and frequently asked questions on our new recordkeeping Web page.

Establishments located in states under Federal OSHA jurisdictions must begin to comply with the new recordkeeping requirements on January 1, 2015. Establishments located in states that operate their own safety and health programs, the state plan states, should check with their state plan for the implementation date of the new requirements.

We encourage these states to implement the new coverage provisions on January 1, 2015, or if they're not able to meet this date, as soon as they can.

Returning to the new reporting requirements, OSHA will now also provide an opportunity for employers to report fatalities and severe injuries to OSHA electronically. This will be in addition to the methods of in-person or phone notification currently available to employers by calling the toll free OSHA hotline or notifying the nearest OSHA area office.

Updating OSHA requirements on reporting work-related injuries and illnesses is long overdue. We believe that the new, more cohesive and comprehensive reporting system will benefit all employers and workers and will contribute to lower injury rates.

The BLS estimates that employers experience nearly four million serious occupational injuries and illnesses each year. Recordable workplace injuries range in severity from those requiring care beyond simply first aid - because injuries receiving only first aid are not recordable to fatal injuries.

Nearly half of all recordable injuries are sufficiently serious to require a day away from work, job transfer or restriction for recovery. We believe this updated rule will help reduce this unacceptably high number of injuries.

The updated recordkeeping and reporting requirements are not simply paperwork but have an important, in fact, lifesaving purpose. They will enable employers and workers to prevent future injuries by identifying and eliminating the most serious workplace hazards, ones that have already caused injuries to occur.

We recognize that improving recordkeeping and reporting requirements is an ongoing process. In efforts for continuous improvement we plan an assessment of the new requirements with extensive public engagement.

Again, thank you for joining me and for your interest in protecting workers. We are excited about this new rule and how it will help us – OSHA - employers, workers and the public better identify and abate preventable workplace hazards in an effort to meet our shared goal of providing safe workplaces for all workers.

Jesse Lawder:

Thank you Dr. Michaels. With that, we'd love to open it up for any questions reporters on the line might have today.

Coordinator:

If you would like to ask a question, please press star 1. Your question will be introduced by name and media outlet or organization. If you wish to withdraw your question, you may press star 1. Again, to ask a question, please press star 1. Please stand by while we wait for our first question.

Jesse Lawder:

Thank you.

Coordinator:

Thank you for your patience. The first question comes from Woody Sixel of Houston Chronicle. Your line is open.

Woody Sixel:

Thank you. I just wanted to make sure I understood that under the current rules if you have fewer than three people who die on the job, employer does not have to make - does not have to notify OSHA.

Dr. David Michaels:

Hi Woody. Let me clarify that. Thanks for the question. The current rule is that if a worker is killed on the job or three or more workers are hospitalized, the employer has to notify OSHA.

This maintains the requirement for the one fatality but changes the requirement for hospitalization to one inpatient hospitalization; one worker is hospitalized then we have to be notified as well as an amputation.

If a worker has a part of their body cut off but is not hospitalized, we still have to be notified. And if a worker has their eye removed at work, we have to be notified as well, whether or not they're hospitalized.

Woody Sixel:

Okay. So - because I thought that if somebody dies - if one person dies on the job that OSHA has to be notified. And that is the rule now and will continue to be the new rule - but I mean the rule. But the big shift here is that you're lowering the hospitalization number to one as well as adding amputations and the loss of the eye.

Dr. David Michaels:

Exactly. Thank you so much.

Woody Sixel:

Great. Great. Thank you.

Coordinator:

Thank you. The next question comes from Alexandra Berzon of Wall Street Journal. Your line is open.

Alexandra Berzon:

Hi. I was just wondering - so you talked about some sort of fill something out in order - that says how they're going to change things and they have to do that every time there's any hospitalization. I didn't quite get that.

Jesse Lawder:

Sorry. Sorry to interrupt. We didn't hear most of that question. Could you just repeat it?

Alexandra Berzon:

Oh yes. I'm sorry. What I was wondering is - I just wanted to clarify something I think I heard Dr. Michaels say, which is that every business that has a hospitalization would then be required to report to OSHA how they're going to change their practices.

Dr. David Michaels:

No, that's not what we'll be doing. What we'll - everyone will have to notify us about the event. We will then begin a conversation with those employers. In some cases we won't need additional information. In some cases we may send an inspector immediately because we think there's an imminent danger.

But in many cases we'll begin a conversation and say okay, what happened, what do you plan to do to address the hazard and ensure they get the help that they need. We don't want any worker to be hurt because the employer doesn't have the tools necessary to make sure that workplace is safe.

((Crosstalk))

Dr. David Michaels:

So this would...

Alexandra Berzon:

Sorry.

Dr. David Michaels:

...essentially begin that conversation with employers who have - who already have a worker who's seriously injured, which we think is a very important time to have that conversation.

Alexandra Berzon:

So essentially they would get like a phone call. If not an investigation they would get at the very least like a phone call that just is to talk about the situation. Is that what you're saying?

Dr. David Michaels:

Yes.

Alexandra Berzon:

Okay. Thanks.

Coordinator:

Thank you. The next question comes from Stuart Silverstein of FairWarning. Your line is open.

Stuart Silverstein:

Hi. I was wondering if you could comment on today's report from BLS about fatal occupational injuries last year. Were there any trends within those numbers of particular note to you?

Dr. David Michaels:

Sure. We're still looking. We just received it as well so we're still looking at them. Obviously we're concerned. You know, 4,405 deaths is 4,405 deaths too many. So we're looking carefully at that. We use those statistics and the injury statistics BLS provides us to better target our resources. And we'll continue to do that.

Stuart Silverstein:

Okay. But was there any particular trend, any change from a year earlier that came to your attention?

Dr. David Michaels: 

Well, we saw a big increase in fatalities as a result of explosions and fires. A lot of that was related to the Yarnell fire in Arizona and the West Fertilizer explosion. We're aware of those and, you know, we are very much involved in efforts to address some of the hazards facing first responders following the President's Executive Order on chemical plant safety and security. So this provides information to help us do that.

Stuart Silverstein:

Okay. You had also made reference to the wire mesh case in your remarks earlier. And I'm wondering about the outcome or status of that case.

Dr. David Michaels:

We'll have to get back to you on that. I don't know offhand.

Stuart Silverstein:

Okay. Thank you.

Coordinator:

The next question comes from Bruce Rolfsen of Bloomberg BNA. Your line is open.

Bruce Rolfsen:

Hello Secretary. Couple of questions. You mentioned that the exemption for workplaces with ten or fewer workers will still stand. Does that exemption also apply to having these new reporting requirements? In other words, if I'm, you know, Joe's Garage and one of my workers loses a thumb, do I still need to call OSHA about that or am I exempt from that?

Dr. David Michaels:

That's a very good question. The partial exemption has never exempted employers from reporting fatalities or other severe injuries. In the past and going forward if an employer has a worker who is killed on the job, they must call us no matter what size the employer.

Bruce Rolfsen:

Okay.

Dr. David Michaels:

That ten or fewer doesn't apply to those reporting requirements.

Bruce Rolfsen:

And my other question, and this kind of goes with an issue of the other recordkeeping rule that's in the works right now. By posting this information online - a lot of folks out there say this is going to encourage people not to report these incidents. What would you tell them?

Dr. David Michaels:

Well...

Bruce Rolfsen: 

Are there any ways where you would hope to keep that from happening?

Dr. David Michaels:

You know, if an employer at their workplace has a worker who loses a part of their body or is hospitalized overnight, it's really unthinkable that they wouldn't call OSHA and attempt to address the problem.

Bruce Rolfsen:

Okay.

Dr. David Michaels:

We believe every employer cares about their workers and will try to do everything they can to make sure that doesn't happen again. I think we provide some useful tools for that employer to help them.

Bruce Rolfsen:

Okay. Thank you.

Coordinator:

The next question comes from Josh Eidelson of Business Week. Your line is open.

Josh Eidelson:

Yes. Thanks for having the call. Wondering - the Chamber of Commerce is arguing that this creates an enforcement trap where employers genuinely won't know within 24 hours about some of these events particularly if it's a later hospitalization for something that happened earlier. Is that a reasonable concern?

Dr. David Michaels:

No. We address that actually in the text of the regulation. And we don't expect them to notify us if they haven't learned it. And there are some time limits after which they don't have to contact us.

If someone is hospitalized, you know, long after the events occurred, they don't have to contact us. So I think that's really a red herring.

Josh Eidelson:

And they also are arguing that this will create some kind of flood of too much information to OSHA, that OSHA will essentially have a harder time identifying the really important accidents once they get this information. Is there anything to that?

Dr. David Michaels:

Well it's hard to say that when someone is hospitalized or someone loses a part of their body it's not an important accident. We certainly take all of those events very seriously. We think the workers involved take them seriously. And frankly I think every employer takes them seriously.

So we don't see that as too much information. It's surprising now that OSHA doesn't get that information. In fact we often find when we go into workplaces after a referral for example when a worker has been seriously hurt and we find that, you know, the same thing happened earlier.

This, you know, I can give you several examples of. So we think more information is useful.

Josh Eidelson:

Thank you very much.

Coordinator:

Thank you. The next question comes from Talia Buford of Center for Public Integrity. Your line is open.

Talia Buford:

Hi. Thanks for having the call. I know that OSHA has been doing a lot with temporary workers or contract workers as BLS kind of categorizes them. I know that you mentioned that you're still looking at the data that was released this morning but can you say anything to the increase in contract worker deaths and also Hispanic or Latino workers. They also saw an increase in 2013 in the number of workplace related fatalities.

Can you say anything about, you know, maybe what this reporting requirement might mean for, you know, finding out how many more contractors are dying on the job or kind of how this plays into OSHA's larger commitment to addressing contractor deaths and injuries?

Dr. David Michaels:

Thank you. That's a good question. And we are very concerned about the increased number of fatal injuries occurring among Hispanic or Latino workers. After being flat for a year from 2011, 2012 we saw a spike this year. And that's of great concern to us and something we're looking at now.

OSHA already recognizes that non-English speaking workers, immigrant workers are vulnerable workers and they often have the worst jobs, they often are not well trained, they don't know what their rights are.

So we have a number of programs that reach out to them to give them information, tell them what their rights are, help them ensure that they're in safe workplaces. This gives us more impetus to do that.

What we will do though is look within this when we get more data as to what industries, what locations those are occurring in. So we plan to follow up on this.

The contractor information is also very interesting. It doesn't tell us what sort of contractual relationship these workers were in but suggests we have to look at this further. So we're optimistic that the data that we'll start receiving will provide us with a lot more information to understand this better.

To look at what's going on with temporary workers, to look at what's going on with contract workers because instead of only having information about fatalities, which are, you know, the most severe problems, we will have thousands or more reports of workers who are seriously injured and so we'll understand better what's going on among these groups of workers.

So we think within, you know, a year or so we'll have a lot more information and we can better target our resources accordingly.

Talia Buford:

Thank you.

Coordinator:

Thank you. The next question comes from Katherine Lymn of Dickinson Press. Your line is open.

Katherine Lymn:

Hi. Thanks for taking my question. Just looking at the overall new rule, is it a case that for those hospitalizations for three or more employees the reporting time will actually be lengthened from 8 to 24 hours?

Dr. David Michaels:

That's actually true. In the interest of consistency we've said that hospitalizations employers have up to 24 hours to report them. We know that most employers are eager to report these to get some help. So we don't think this will change significantly the information we get. But we didn't want different reporting times for different numbers of workers hospitalized. And so we've made them consistently 24 hours.

Katherine Lymn:

Thank you.

Coordinator:

The next question comes from Jerry Laws of Occupational Health and Safety Magazine. Your line is open.

Jerry Laws:  

Thank you. And I'll add to the others, thank you Dr. Michaels for having this conference call. I've got two questions really. You mentioned thousands of reports potentially. Do you have an estimate of how many reports you think will come in based on this new requirement?

Dr. David Michaels: 

Yes.

Jerry Laws:

And the second part is you described the follow up that OSHA will do is a conversation. So it's not a single phone call apparently. Is it repeated calls? What do you envision for that?

Dr. David Michaels:

Yes. Well let me take these one at a time. You know, six states have requirements right now to report either hospitalizations or amputations or some combination of them. So we - on that basis we're estimating that this year or, I'm sorry, next year we may see, you know, 25,000 or so reports. That's just a guess. We don't know.

We know that there are more than 100 - based on record studies done in a couple different states, we know that there are more than 100,000 hospitalizations that are the result of work-related events that occur every year. We don't expect to get that many reports this year but we will get in the tens of thousands. Come back in a year. We'll tell you how we're doing.

The second question was, you know, the conversations. It's going to depend on the specific situation. We know that some employers will contact us who we've had no contact with and they could be a small employer who really doesn't have a clue on how to deal with some of these problems and we may shift them directly into our free, state-run onsite consultation program.

Other employers, you know, we may have one conversation where they say, you know, I understand what the cause was. This is what I'm going to do about them. We may say to them for example, you know, share some emails with some pictures of what you've done. And so we could see what the changes you made.

It's going to be case specific. But it will develop a relationship between our area offices and local employers that they'll have now. And I think really lead to improvements in the places where they most seriously are in need of improvement and those are workplaces where workers are seriously injured.

Jerry Laws:

Thank you.

Coordinator:

The next question comes from Marc Freedman, U.S. Chamber of Commerce. Your line is open.

Dr. David Michaels:

Marc, congratulations on becoming a reporter.

Marc Freedman:

I've been a reporter in my previous life and I do lots of writing and I even put things on the Internet. So with that in mind, the provision you've described says that these reports will be put on the Internet. I did not see that in the proposal. Was that in the proposal?

Dr. David Michaels:

You know, we're a public agency. Our work is public. Right now we put reports of fatalities and three hospitalizations on the Internet. And this is just continuing - we put it on our Web site. This continues that process.

When we get a report, when we do an inspection, it's public. The public gets to know that we've been - the previous administration was sued by the New York Times. The court was very clear. Our data are public and this - these data will be public.

Marc Freedman:

With all due respect, that's not the question I asked. Was that provision in the proposed rule?

Dr. David Michaels:

The provision was -the proposed rule was about the reporting provision. I don't think we specifically mentioned that but all of our material is public. And that's the principle that we operate under.

Marc Freedman:

And...

Jesse Lawder:

Thank you for that question.

Marc Freedman:

Okay. One more quick one. You described this conversation that OSHA will have with these employers in fairly consultative terms. Will there be any...

Coordinator:

The next question comes from Mark Gruenberg from Press Associates. Your line is open.

Mark Gruenberg:

Yes. Several fast questions. First of all, given what you've been saying before Dr. Michaels about going into a workplace where there's been a fatality and you find there's been previous injuries or previous accidents, what makes you think that employers will be eager to comply?

Second is following up on the contract workers. How are you going to get around basically the fact that the contract workers are working for subcontractors when the real - when the firm that really should be responsible is the big guy, say Wal-Mart subcontracting to a warehouse who in turn hires contract workers. Can - is it one step removed?

Dr. David Michaels:

I think some - there's a range of employers. And we know this from all the work that we do. There are some employers who are willing to have their employees suffer injuries and they don't do anything. That's the example that we've seen.

And those employers just - that conversation may not be adequate. But most employers I think are really are both shocked and affected significantly when a worker is injured and they want to make sure that that never happens again.

And so we have different tools for different types of employers. For the vast majority of employers, especially small ones who have never had a serious injury, we can now help them immediately but hopefully the reports (will encourage some employers to even reach out to us before workers are hurt.

Other employers - those ones we go into where a worker had been previously injured and nothing was done well, this is an opportunity to get to them in a different way. And we plan to do that as well.

On the second question, which is the relationship between various contractors and temporary workers, you know, we've just issued recommended practices for temporary workers. And we are working very closely with the American Staffing Association, a number of different trade associations.

We're trying to get information out. We're recommending that there be constant communication between staffing agencies and host employers about workplace hazards, training and also injuries.

Our rules say that only one employer must keep an OSHA log and that's the employer who provides the direct supervision. But it's very important for both the host employer and the staffing agency to keep track of these injuries, to make sure they're reported, to get essentially the intervention that's taken place. And we think this new reporting requirement will also help that.

But I'd like to refer you to our temporary worker Web page. We have a lot of great information and these new recommended practices that go directly to your question.

Mark Gruenberg:

Okay. One more fast question. What did you hear on the way to issuing this new proposed rule from various stakeholders particularly unions?

Dr. David Michaels:

Well we've, you know, let me suggest - take a look at the preamble in the material we posted on our Web site.

Mark Gruenberg:

Okay.

Dr. David Michaels:

We have pages and pages of discussion about the comments we received from various stakeholders and how they helped shape the rule.

Mark Gruenberg:

Okay. Thank you.

Coordinator:

Thank you. Our final question comes from Chris Cole with Inside OSHA. Your line is open.

Chris Cole:

Hi. Thanks for the call. Dr. Michaels, I was just wondering. I have a quick question about the eye enucleation issue. You mentioned in the preamble to the proposal a question about that. But here as I understand it you've got - you're using a BLS manual definition of amputations that does not include enucleation but you include a section separately on bylaws.

Is that something you had contemplated putting in the initial proposal? What - could you walk us through your thinking on that?

Dr. David Michaels:

We asked the question in the proposal because, you know, we often talk about amputations. But when you look at the actual definition of amputation, (unintelligible) different parts of the body for various reasons does not include losing an eye.

And so we asked specifically whether we should include that. And we got some feedback. And we decided on the basis of that that we - that should be included. But if you just use the phrase amputation, (unintelligible) we want to clarify that. So that's where that comes from.

We think the loss of an eye is a significant enough injury that we should be notified.

Chris Cole:

Just quickly. Could you kind of characterize the scope of this regulatory look back on recordkeeping? You know, what is that going to be looking at?

Dr. David Michaels:

We're going to put that together. We're very interested in the impact of the way we make our categories and (unintelligible) over - after we get these changes in place we'll begin to put that together.

Chris Cole:

Okay. I just have one more quick question. It's related to recordkeeping but you have a pending rule to propose on addressing this case about continuing violations on recordkeeping logs and clarifying your view of a continuing violation. Could you tell us where that stands?

Dr. David Michaels:

It's in development. We don't have a proposal yet.

Chris Cole:

Could you - do you know when you might or...

Dr. David Michaels:

I can't predict.

Chris Cole:

Okay. Thanks so much.

Jesse Lawder:

All right. I think that's all the time we've got today. Thank you everyone for participating in this call and for your interest in our work. Have a great day.

Coordinator:

Thank you for your participation in today's conference. Participants you may disconnect at this time.

END