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    Nece pres ergo2010 Nece pres ergo2010 Presentation Transcript

    • The Role ofErgonomics inTelecommuting -NECEJessica Ellison, M.S., CPE, CSPellisonj@eorm.com 408-790-9209
    • Workshop Goals► To understand the ergonomic risks associated withtelecommuting► To become aware of the policy decisions that each companymust address when implementing a telecommuting program► To obtain an understanding of the tools that are available tohelp address ergonomic risk in a telecommuting environment► To learn how some programs are effectively addressingtelecommuting workstations► How to conduct remote evaluations© 2010 EORM, Inc. 2
    • Agenda► Background► Telework/Telecommuting overview► Safety & Ergonomics► Solutions► How to Conduct a Remote (Phone) Evaluation© 2010 EORM, Inc. 3
    • Jessica Ellison, M.S., CPE, CSP► Consultant at EORM for over 5 years► Masters in Biomedical Engineering with a focus inBiomechanics► Both a Certified Professional Ergonomist and a Certified SafetyProfessional► Developed and rolled out ergonomic programs worldwide► Experience with multiple industries and settings such as office,lab and industrial© 2010 EORM, Inc. 4
    • Course Participants - Industry© 2010 EORM, Inc. 5
    • Course Participants - Role© 2010 EORM, Inc. 6
    • Course Participants - % of PopulationTelecommuting© 2010 EORM, Inc. 7
    • Course Participants – Where is your company in theprocess of rolling out a telecommuting program?© 2010 EORM, Inc. 8
    • Part 1 – TelecommutingPrograms
    • Telecommuting & Telework► Terms coined by Jack Nilles in1973 – Researcher at USC► Work done someplace otherthan the corporate office (i.e.,homes, coffee shops, airplanes,cars, etc.)© 2010 EORM, Inc. 10
    • Telework Trends► Feb 2009 World at Work– Employees who telework (atleast 1 day per month) rosefrom 12.6 M in 2006 to 17.2 Min 2008– Just over 11% of total employeepopulation in 2008– Contract employees whotelework rose from 16.2 M in2006 to 16.6 M in 2008– Total employees– 23.5 M in 2003– 33.7 M in 2008– 43% Increase© 2010 EORM, Inc. 11Contents © 2009. Reprinted with permission from WorldatWork. Content is licensed foruse by purchaser only. No part of this article may be reproduced, excerpted orredistributed in any form without express written permission from WorldatWork.
    • Telework Trends© 2010 EORM, Inc. 12Contents © 2009. Reprinted with permission from WorldatWork. Content is licensed for use by purchaseronly. No part of this article may be reproduced, excerpted or redistributed in any form without expresswritten permission from WorldatWork.
    • Telework Trends© 2010 EORM, Inc. 13Contents © 2009. Reprinted with permission from WorldatWork. Content is licensed for use bypurchaser only. No part of this article may be reproduced, excerpted or redistributed in any formwithout express written permission from WorldatWork.
    • Telework Trends► Trend is increasing and may be due to the following:– Reduce operational costs associated with energy use and employeedown time– Reduce Carbon Footprint; “Green Movement” and Sustainability– Offer more attractive work structure for employee recruitment andretention– Increase in gas prices– Increase in ability for employees to connect to office from home orother locations– Increase in call for better work/life balance– Globalization – working 24/7– Use of more flexible staff – contractors, consultants, part time, etc.© 2010 EORM, Inc. 14
    • Telework Trends – In the News► “H1N1 fears could lead to rise in telecommuting”– by Peter Tertzakian, Calgary Herald – October 11, 2009► “Agencies Told To Reduce Emissions”– "As the largest consumer of energy in the U.S. economy, the federalgovernment can and should lead by example when it comes to creatinginnovative ways to reduce greenhouse gas emissions, increase energyefficiency, conserve water, reduce waste, and use environmentally-responsibleproducts and technologies," – President Obama– by Juliet Eilperin – October 6, 2009© 2010 EORM, Inc. 15
    • Telework Trends – In the News► “Report: Two of every five workers telecommute”– by Lance Whitney, Business Tech CNET News – October 9, 2009– “Once considered a novelty, telecommuting has now becomemainstream, thanks largely to technology.”© 2010 EORM, Inc. 16► “Outsourced Call Centers Return, To U.S.Homes”– by Carolyn Beeler, NPR - August 25, 2010– Estimated 60,000 people doing call center workfrom home– Lower cost point due to low overhead– Allows for 20% lower charge that traditional UScall centers
    • Benefits of Telework► What are you seeing as benefits?© 2010 EORM, Inc. 17
    • Benefits of Telework► Happy employees– Recruiting and retention– Increase in productivity– Reduced absenteeism– Increase in morale– Decrease in stress– Reduction in the spread of illnesses© 2010 EORM, Inc. 18
    • Benefits of Telework► Reduce need for office space – Saves $$– Energy savings– Cost savings for smaller buildings– Insurance decrease– Less furniture– Cost savings are significant for those organizations that have reducedtheir real estate portfolio» An average annual cost savings of $3,000 to $10,000 per employeewas reported» Two organizations reported annual cost savings of roughly $200million related to real estate reduction through telework© 2010 EORM, Inc. 19
    • Benefits of Telework► Corporate Responsibility Reports/Dow JonesSustainability Index Score► Green impact– Less traffic– Less CO2 emissions– Corporate responsibility reports► Aids with emergency planning– Pandemics– Natural Disasters► Flexible dependent care► Accommodates employees with disabilities© 2010 EORM, Inc. 20
    • Drawbacks / Push Back to Telework► What issues or reasons for push back are you seeing inyour company or companies you work with?► How do you address these concerns?© 2010 EORM, Inc. 21
    • Drawbacks of Telework► Concern from managers that staff is not working when athome► Less face to face meeting time► How to manage staff when working from home?► Social dynamics can change► Some work is difficult to perform remotely© 2010 EORM, Inc. 22
    • Telecommuting Success Stories in the News► Sun Microsystems– 56% of employees do not have an assigned workstation– Divided into three categories of telecommuters» “Sun Assigned”» “Flexible”» “Home Assigned”– $387 million in IT and Real Estate Savings– 28,000 reduction in CO2 annuallyhttp://www.msnbc.msn.com/id/20281475/© 2010 EORM, Inc. 23
    • Telecommuting Success Stories in the News► Internal Revenue Service (IRS)– Telecommuting allowed office to stay open during 2006 floodthat shut down headquarters– Real Estate savings of $585,000 for 150 pilot participants© 2010 EORM, Inc. 24
    • Steps to Implementing a TelecommutingProgram► Identify Goals and Objectives► Appoint a Telecommuting Advocate► Create a Steering Committee► Draft Telecommuting Policies and Worker Agreements► Analyze Voice and Data Needs and Costs► Secure Senior Management Buy-In► Train Managers and Telecommuters► Implement a Pilot Program► Get the Word Out► Provide Ongoing Evaluation and SupportSource: Telecommute Connecticut© 2010 EORM, Inc. 25
    • Teleworking Policies► Definitions of Levels of Teleworking– Location—Will telecommuting be limited to working at homeor will you allow other alternative work sites as well?– Frequency—Will your telecommuters telecommute full-timeor part-time? One day a week or five?– Hours—Will they be allowed to set their own hours or, mustthey work during the regular work hours? Or will you set upcore hours during which all telecommuters must work,leaving the rest of their work hours up to them?► (HR Magazine, Telecommuting Policies that Work)© 2010 EORM, Inc. 26
    • Teleworking Policies► Eligibility► Liability Statement► Workers’ Compensation– Employee’s home is an extension of the workplace soworkers’ compensation regulations apply► Homeowners’ and Liability Insurance► Security– Data and employee► Telephone / Data Connection► Equipment and Supplies© 2010 EORM, Inc. 27
    • Possible Teleworking Equipment► Ergonomically-designeddesk and chair► Surge protection► Lighting► Computer, laptop,software, peripherals► Broadband or wireless► Printer/copier► Fax, scan capacity► Phone► Cell phone► Voicemail► Storage and shelves► PDA. Blackberry, Pager► Ergonomic and safetyguidelines© 2010 EORM, Inc. 28eWorkPlace
    • Participant Survey – What ergonomic equipment doyou provide for your remote workers?© 2010 EORM, Inc. 29
    • Is a laptop, keyboard and mouse enough?© 2010 EORM, Inc. 30
    • Participant Survey – Budget for ergonomicequipment© 2010 EORM, Inc. 31
    • Teleworking Policies► Dependent Care– “The telecommuter shall have family arrangements, whichallow the telecommuting work site to be a productiveworking environment.”(Finance and Administration – Telecommuting Program, State of Tennessee 2001)► Travel Expenses► Safety & Ergonomics© 2010 EORM, Inc. 32
    • Safety & Ergonomics► Often an afterthought once program is in place► Important to track the impact of telecommuting onsafety / injury record– Data lacking on impact of telecommuting on safety and injuryrecords– Once an ergonomic program is implemented, need to showROI - metrics are important– Need to work with internal HR departments on Workers’Compensation data© 2010 EORM, Inc. 33
    • How are people working at home?© 2010 EORM, Inc. 34
    • Participant Survey – Effect of Injury Rate Dueto Telecommuting Program (2009 Results)© 2010 EORM, Inc. 35
    • Why is Safety so Important?► General Duty Clause – Federal OSHA(a) Each employer --(1) shall furnish to each of his employees employment and a place ofemployment which are free from recognized hazards that arecausing or are likely to cause death or serious physical harm to hisemployees;(2) shall comply with occupational safety and health standardspromulgated under this Act.(b) Each employee shall comply with occupational safety and healthstandards and all rules, regulations, and orders issued pursuant tothis Act which are applicable to his own actions and conduct.© 2010 EORM, Inc. 36
    • Why is Safety so Important?► Workers’ Compensation– If the employee is injured performing work duties then theywill be covered under workers’ compensation laws regardlessof where they are working.© 2010 EORM, Inc. 37
    • Steps to Implementing a TelecommutingProgram► Identify Goals and Objectives► Appoint a Telecommuting Advocate► Create a Steering Committee► Draft Telecommuting Policies and Worker Agreements► Analyze Voice and Data Needs and Costs► Secure Senior Management Buy-In► Train Managers and Telecommuters► Implement a Pilot Program► Get the Word Out► Provide Ongoing Evaluation and SupportSource: Telecommute Connecticut© 2010 EORM, Inc. 38
    • Get the Word Out► How do you launch new initiatives/programs within yourcompany?© 2010 EORM, Inc. 39
    • Get the Word Out► Advertise the launch of the program– eNewsletters– Desk Drops– Posters– Announcement Screens– Emails– Manager Involvement► Consider incentives!© 2010 EORM, Inc. 40
    • Provide Ongoing Support and Evaluation► Communication must continue and should come fromdifferent sources to grab employee attention© 2010 EORM, Inc. 41020406080100120140Apr-09 May-09 Jun-09 Jul-09 Aug-09 Sep-09 Oct-09NumberofOnlineAssessmentsMonthNumber of Online Assessments By MonthInitialFollow UpPoly. (Initial)Launch ofAdditionalSites
    • Provide Ongoing Support and Evaluation► Rolled out new communications plan– “Ergonomics Day” at each major campus– Raffle for Amazon gift card or iPod Shuffle© 2010 EORM, Inc. 420100200300400500600700800900FY 2006 (5Months)FY 2007 FY 2008 FY 2009 FY 2010 (11.5Months)367487408276807741207592350Initial SAFEFollow up SAFE
    • Part 2 – Ergonomics &Safety
    • Summary of NIOSH Study – 2007► Study Background– 380 Teleworkers– 12 Federal & State Agencies– 42 Private Companies– Across 37 states and District of Columbia► Training Is Needed– Pretest showed 38% of employees were in pain or experiencingdiscomfort» Back» Neck» Wrists» Shoulders© 2010 EORM, Inc. 44
    • Summary of NIOSH Study – 2007► Training Is Needed – Pre-Test– 32% bought own office equipment (*note no training prior topurchase)– “At pretest, participants did not know many basic safety conceptsrelated to ergonomics, fire safety, electrical safety, indoor air quality,and accident prevention.”» 58% did not have a disaster recovery plan» 42% did not have a home fire plan» 6 participants reported injuries» 2 participants reported home fires» 82% have not received any safety training© 2010 EORM, Inc. 45
    • Summary of NIOSH Study – 2007► Post-Training Results– One month after ergonomics training, decrease in shoulderand wrist discomfort– 66% participants made positive changes – ergonomichighlights» organized, cleaned, and reduced clutter» ergonomically adjusted office chairs» evaluated and/or modified office lighting» adjusted and/or relocated computer monitors» evaluated and/or relocated desks to eliminate glare oncomputer screens» maintained an increased awareness of posture© 2010 EORM, Inc. 46
    • Summary of NIOSH Study – 2007► Employees added the following equipment– document holders– wristrests– adjustable task lighting– keyboard trays– headsets© 2010 EORM, Inc. 47
    • Home Office Safety Issues► Fire Hazards– Free of frayed wires– Not cluttered with large amounts of combustibles► Electrical Hazards– Outlets should be grounded (3 pronged)– Circuit breakers should be labeled– Computer equipment should be plugged into a surgeprotector© 2010 EORM, Inc. 48
    • Home Office Safety Issues► Egress– Should have easy movement in the space and easy to exit► Stairs with four or more steps need handrails► Disaster Recover Plan► Emergency Action Plan© 2010 EORM, Inc. 49
    • Ergonomic Risk Factors► Force► Repetition► Awkward Postures► Static Postures► Vibration© 2010 EORM, Inc. 50
    • Ergonomic Risk Factors► Working at home is no different than in the office interms of risks but intensity may be increased – let’s take alook at some examples© 2010 EORM, Inc. 51
    • Examples of Home Offices© 2010 EORM, Inc. 52
    • Examples of Home Offices© 2010 EORM, Inc. 53
    • Examples of Home Offices© 2010 EORM, Inc. 54
    • Examples of Home Offices© 2010 EORM, Inc. 55
    • Examples of Home Offices© 2010 EORM, Inc. 56
    • Examples of Other Locations► Coffee Shop© 2010 EORM, Inc. 57
    • Working remotely► Use travel equipment to get correct fit.© 2010 EORM, Inc. 58
    • Examples of Other Locations► In the Car© 2010 EORM, Inc. 59
    • Vehicle Ergonomics► Select the right vehicle– Review fit, adjustability, comfort, and features– Utilize a checklist► Adjust the vehicle to fit– Balance between reach and too close for airbags► References– http://www.ccohs.ca/oshanswers/ergonomics/driving.html– http://www.ohcow.on.ca/resources/handbooks/ergonomics_driving/Ergonomics_And_Driving.pdf– http://www.drivingergonomics.com/© 2010 EORM, Inc. 60
    • Working on a laptop in vehicle► What solutions have you seen that have worked?© 2010 EORM, Inc. 61
    • Hoteling / Hot Desking► Offices or areas within an office where employees use anyworkstation available► Not assigned workstations© 2010 EORM, Inc. 62
    • Hoteling / Hot Desking► Issues– Accommodating individual physical needs– Accommodating individuals tasks and function needs– Employees may not adjust workstation each time they sitdown at a new workstation to work.– Making adequate resources available to maintain productivityversus creating distractions– Concern over the spread of flu and diseases – sanitation© 2010 EORM, Inc. 63
    • Hoteling / Hot Desking► Benefits– Can work face to face with co-workers from time to time– Need less space then assigned cubes and offices© 2010 EORM, Inc. 64
    • Hoteling / Hot Desking► Ergonomic Considerations– Supply each workstation with docking station, adjustablechairs, adjustable monitors (monitor arms), keyboard, mouse,keyboard tray– Programmable phones where employees can be reached withtheir standard number or cell phones (depends on culture)– Reminders in each work area on quick set up tips– Reminders / cues where printers, copiers, standard officeequipment supplies are located© 2010 EORM, Inc. 65
    • Hoteling / Hot Desking© 2010 EORM, Inc. 66
    • Part 3 - Solutions
    • Participant Survey – How do you addressergonomics? (2009 Results)© 2010 EORM, Inc. 68
    • Informal Benchmarking Study – HomeOffices► 5 software / hardware industry clients surveyed► Proactive Companies Programs Include –– Online ergonomic evaluation process. In some companies, it is alsopart of an initial qualification process– Training and/or guidelines and tips on ergonomics– Phone evaluations to support remote setup in the event of discomfortreport – most companies do not send ergonomists to the house– Ergo budget (range is $500-1,500 depending on the company). Thebudget includes the following preapproved equipment: chair, monitor,keyboard, mouse, keyboard tray, headset, and gel wrist rests etc. Inone particular company, they also approve desks© 2010 EORM, Inc. 69
    • Informal Benchmarking Study – HomeOffices► Reactive Companies– Only provide equipment once a requested or a complaint is made– Equipment recommendations are the same as the company standardproduct recommendations– One example company - when pain, discomfort or claim of injury isreported,» Employee takes pictures of his/her remote workstation» Request that the employee visit a preapproved occupational health clinic» Send the pictures to the clinic and have the medical provider determinethe work relatedness of the injury/discomfort.© 2010 EORM, Inc. 70
    • Informal Benchmarking Study –Esuites / Remote Leased Offices► Esuites– Small offices– Leased– Majority include furniture with the lease of building► Concerns Raised– How to get these staff ergonomic equipment if not provided withinlease?– Can lease be negotiated to provide ergonomic equipment?– If equipment purchased and sent to site, how do you keep inventoryand retrieve furniture if office closes?© 2010 EORM, Inc. 71
    • How do you address ergonomics remotely?► Digital Pictures► Web Cameras► Checklists► Online Self-Evaluations► Phone Evaluations► Pre-established resources (vendors, equipment, etc)Note – Onsite evaluations are needed in Ireland© 2010 EORM, Inc. 72
    • Digital Pictures► Advantages– Give you a quick look at what equipment employee is using– If employee is in picture gives idea of possible issues and howemployee interacts with the workstation– Employee can see their own posture and position► Disadvantages– Only a snapshot– How does the employee sit and work when not on camera?© 2010 EORM, Inc. 73
    • Web Cameras► Advantages– Live pictures of employee working– Employee can also see evaluator who can show how theywant employee to be positioned► Disadvantages– Everyone may not have a camera– If camera built into monitor only one view – can’t seeemployee from the side© 2010 EORM, Inc. 74
    • Home Office Safety Checklists► Advantages– Quick for employee to complete and evaluator to review► Disadvantages– Typically yes/no questions– No visual of the workstation– Employees may have different interpretations of questions– No feedback mechanism unless evaluator calls employee to discussand make recommendations for improvement© 2010 EORM, Inc. 75
    • Home Office Safety Checklists► Includes Ergonomics and General Safety– Ergonomics» Adjust your chair and use your back support» Adjust the position of your monitor (top at eye height, arm’sdistance away)» Adjust your position or your keyboard and mouse to elbowheight.» Adjust equipment to keep your arms relaxed and wrists straight» Use a document holder if referencing printed materials» Ensure that there is enough room under your desk for your legs© 2010 EORM, Inc. 76
    • Home Office Safety Checklists► Includes Ergonomics and General Safety– General Safety» Keep office clean and neat and free of excessive amounts ofcombustibles» Electrical hazards (frayed cords, overloaded circuits, daisy chainedpower strips, etc.)» Easy egress» Secure wires to reduce tripping hazards» Use a chair in good repair – fix loose casters, chair rungs, etc.» Secure carpets and make sure they are free of worn or frayedseams» Emergency action plan developed© 2010 EORM, Inc. 77
    • Online Self-Evaluations► Advantages– Teaches employees how to adjust their own workstation– Can integrate online training (Cal-OSHA regulation)– Includes checklist with feedback on what changes to make► Disadvantages– Limited personal interaction with employee© 2010 EORM, Inc. 78
    • Online Self-Evaluations© 2010 EORM, Inc. 79
    • Online Self-Evaluations© 2010 EORM, Inc. 80
    • Online Self-Evaluations© 2010 EORM, Inc. 81
    • Online Self-Evaluations© 2010 EORM, Inc. 82
    • Online Self-Evaluations© 2010 EORM, Inc. 83
    • Online Self-Evaluations© 2010 EORM, Inc. 84
    • Online Self-Evaluations© 2010 EORM, Inc. 85
    • Online Self-Evaluations© 2010 EORM, Inc. 86
    • Online Self-Evaluations© 2010 EORM, Inc. 87
    • Online Self-Evaluations© 2010 EORM, Inc. 88
    • Online Self-Evaluations© 2010 EORM, Inc. 89
    • Online Self-Evaluations© 2010 EORM, Inc. 90
    • Online Self-Evaluations© 2010 EORM, Inc. 91
    • Phone Evaluations► Advantages– Direct interaction with employee– Can ask questions– Can direct employee how to set up workstation► Disadvantages– Have to rely on employee’s description of workstation– Need practice in asking questions and experience with enough inperson evaluations to understand challenges and solutions– Takes evaluator’s time© 2010 EORM, Inc. 92
    • Pre-Established Vendors and Equipment► Advantages– Employees and evaluators know what equipment is available– Quick and easy ordering– Discount prices► Disadvantages– employees do not select own equipment– mercy of vendor if only choose one© 2010 EORM, Inc. 93
    • The Best Solution?► Tiered Approach– Online self-evaluation with checklist & training– Phone evaluation with pictures and/or web camera whenneeded– Use pre-established vendors and equipment► Let’s talk more about how to conduct phoneevaluations…© 2010 EORM, Inc. 94
    • QuestioningThe Discovery ProcessQuestioning, listening andbeing genuinely curious
    • Closed-Ended Questions► Barriers to open communication– Require short responses (Yes/No)– Usually answer or clarify one fact or point– Tend to “lead the witness”– Are less efficient in discovery– Create a false sense of getting “good” information► Barrier to building relationships– Do not show curiosity– We carry the burden of the conversation– Hinders communication– Relationships are not a usual outcome of closed-ended questions► Are appropriate 10−20% of the time© 2010 EORM, Inc. 96
    • Closed-Ended Questions► Are you typing on a standard keyboard?► Are you using a standard mouse?► Is the top of your monitor at your eye height?► Is there anything else that you can think of?► Are you experiencing back pain?► Do you take breaks?© 2010 EORM, Inc. 97
    • Open-Ended Questions► Enable open communication– Require an explanation» avoids yes/no responses– Allows interaction to find out about the employee’s needs– Is the foundation of building rapport– Allows you to identify and clarify “points-of-view”– Helps you uncover the employee’s needs without making assumptions– Allows interaction to find out about the employee’s needs► Enable relationship building– Get the employee to start talking– Allow the conversation to follow the employee’s motivation andpriorities– Allows interaction to find out about the employee’s needs© 2010 EORM, Inc. 98
    • Open-Ended Questions► Please tell me about why you were looking for someassistance?► Give me an overview of your workstation?► What motivated your outreach to ergonomics?© 2010 EORM, Inc. 99
    • Layering and Probing► Tell me more about...► What did you mean when you said _____?► Why is that important?► What are your ideas on?► What does _____ mean to you?► Give me an example of?► Why is that?► Elaborate for me…► Clarify for me what you meant by…► What are your thoughts on…© 2010 EORM, Inc. 100
    • Open-Ended Questions Exercise► Groups of 4 or 5► Take turns giving examples of open ended questions► If speaker gives a closed ended question the group buzzesthe speaker and they have to give a new answer© 2010 EORM, Inc. 101
    • Conducting Phone Evaluations► Use open-ended questioning to start► Let the employee do most of the talking in your discoveryphase► Once you have all of the employees thoughts then walkthrough the basic setup from the bottom up– Chair adjustments– Keyboard and mouse at elbow height– Top of monitor at eye height© 2010 EORM, Inc. 102
    • Role Play - Examples► Find a partner► 1st person sit with back to screen► 2nd person sit facing screen► 1st person is the evaluator and should ask questions and walk2nd person through how to set up workstation► 2nd person is the employee – use the picture on the screen asyour workstation setup to describe to the evaluator► Switch after each situation© 2010 EORM, Inc. 103
    • Situation #1© 2010 EORM, Inc. 104
    • Situation #2© 2010 EORM, Inc. 105
    • Situation #3© 2010 EORM, Inc. 106
    • Situation #4© 2010 EORM, Inc. 107
    • Situation #5© 2010 EORM, Inc. 108
    • Situation #6© 2010 EORM, Inc. 109
    • Role Play Wrap-Up► What did you learn from the role play?► What will you take back with you to use at your company?© 2010 EORM, Inc. 110
    • Summary / Wrap-Up
    • Summary / Wrap-Up► Telecommuting is still on the rise and is a huge benefit tocompanies and employees► Safety is important in home offices► Use a tiered approach to address ergonomics– Online self-evaluation with checklist & training– Phone evaluation with pictures and/or web camera when needed– Use pre-established vendors and equipment► Communication, communication, communication!© 2010 EORM, Inc. 112
    • Thank You!Jessica Ellison, M.S., CPE, CSPSenior EHS ConsultantEORM, Inc.T: 408.790.9209ellisonj@eorm.comwww.eorm.comStrengthening business advantage through Environmental,Health, Safety, and Sustainability© 2010 EORM, Inc. 113