Farm Labor: New MIOSHA Rules & Labor Recruitment Planning
February 15, 2021
Good afternoon everyone. Welcome to the Michigan Ag, Ideas to Grow with virtual conference. My name has Florencia Colella I am a farm business Management Extension Educator with MSU covering West Central Michigan. And it is my pleasure to welcome you to this session. Farm Labor: New MIOSHA Rules and Labor Recruitment Planning. We will hear today from Stan Moore and Craig Anderson, Stan Moore is a farm business management educator with Michigan State University. He covers the northern part of the state. And Craig Anderson manages the Ag labor and safety services program, and has been doing dealing with safety and labor issues for the better part of the last 30 years. Please know that this session is being recorded and session recordings will be shared a few weeks after the conference. So before we get started we'd like to take a quick moment to thank our sponsors that you can see on this slide. And we are also able to offer a college scholarship opportunity. On this slide here, please check out the website for more information. Also, I have a short video that we'd like to share with you. Carrying for crops and animals creates a unique stress and pressure that can be hard on farmers and agribusiness professionals. Caring for one's own health and wellness is, in this high-stress profession is often overlooked, but it's just as critical as caring for the farm business. Whether these stresses come from a financial issue or the stress of everyday life. Msu Extension can help. So let me switch over to our video. Hi, my name is Eric are Belsky and M behavioral health educator with MSU Extension that focuses on farm stress. With your farm stress tip. We know that farming is inherently an independent occupation. With that, do you know the importance of staying connected? According to an article posted by the Centers for Disease and Control, although it's hard to measure social isolation and loneliness, there is strong evidence that many adults age 50 and older are socially isolated or lonely. A recent study found that social isolation significantly increase a person's risk of premature death. A risk that may rival those of smoking, obesity, and physical inactivity. Social isolation was also associated with about 50 percent of increase risk of dementia. Poor social relationships was associated with 29 percent risk of increased heart disease and a 32 percent increase of stroke. Loneliness was also associated with higher rates of depression, anxiety, and suicide. So with that, reach out to someone that you know already that you've been thinking about. Invite them to a coffee, give them a phone call, send them a text. You never know how important that phone call or visit. Could be to somebody that is struggling. There's also a number of resources on our MSU Extension farm stress website. And I'd encourage you to go there and know that there are a lot of people that are working very hard behind the scenes to support you as you support us. Thank you and have a great day. All right, So if you would like to learn more about farms trust, please join us on Friday, February 19th at 11 AM for the session mending the trust fence. You can find the Zoom link and passcode on the final schedule that was emailed to you. Now let's jump into today's presentation. If you have any questions during the presentation, please type them into the Q and a that's at the bottom of your screen. And let's get started. Stand more in Craig Anderson. The floor is yours. Craig, I think you go first, then you will have to share your screen. Okay. So for whatever reason, it is not allowing me to get out price topic my chair first, maybe that helps. Chair. Not yet. They're like, Yeah. Thank you. Okay. So today we're going to talk a little bit about my osha and what we have both here in the state and then a little heads up on the national level. My osha emergency rule has been here for a period of time since back in October. Now for many of our operations, we recognize that your operations were actually winding down and getting prepared to really ramp back up into our normal production season. So the current state executive or excuse me, emergency, my osha rule is in effect until April 14th. Now, we do need to recognize that within our emergency structure within the my ocean standard, we do have the opportunity to extend it for an additional six months without review, and that would be either through the regular rules process or through legislative oversight. So it is possible that the role could be extended through October 13th, 2021. Let's take a look at the coverage. So the coverage is very broad under our state actor state osha Act, it applies to all places of employment in the state. So that's pretty significant. It doesn't go into the areas that we have qualifications and exceptions for agricultural activities. Then the second part that we need to recognize is that an employee is a person who has suffered, are permitted to work by the employer. And that's very important as well because many cases we have people who are assisting us. That could be family members, they could be neighbors, but we're sharing the fact that we don't have a paycheck does not matter in this situation. So we really need to recognize anyone doing labor or work activities on our operations is covered by this emergency rule. Now what are some of the provisions we need to pay attention to? One of the biggest challenges we've heard out there is the ability to go through and determine where we have exposures. Under the rule, we have to take a look both at the routine and reasonably expected tasks and procedures. So by virtue of looking at the tasks and procedures, were not just saying, Okay, you're a tractor operator. So therefore, we have to take a look at both sides of the activity. So if I'm in a CAD, an attractor, day long, yes, my exposure is relatively low. But for most of us, we have multiple tasks that occur throughout the day. And those would be a combination of that work activity and the actual procedures that you look at. Then we need to categorize. So we're going to look and low, medium, high, very high. For nearly all of the activities that we have on the farm, they're going to be classified in either the low or medium level. If you look at low, do not require contact with people known to be or suspected of being infected. So for many of us, we have an additional requirement out there and that is four, testing before work and begin. But that testing doesn't necessarily say that throughout the course of our employment that I am going to be negative. So generally our field work activity is going to fall into the low area. But we could have situations and packing and processing in particular, where we would have frequent and close contact, in other words, within six feet. Or we may have situations that we could have an infected situation or a positive situation. These could elevate us into a higher level depending on the circumstances and I'll touch base with those in a moment. High density work environments are probably the area that we need to look at. We do have planning activities that are going to be very dense in terms of where people are going to be at. And we would have to recognize those and potentially minimize the contact that we would have during that process. So once we've made that determination that we do have people that are covered and that we've identified where the exposure could be. Then we look at developing that Preparedness and Response Plan. Generally, most of us have some form of planning already in place. And we'd highly recommend that you take a look at what's currently doing. Try and simply incorporate some of these. Although if you have an inspection in many cases it's easier to simply say, okay, here is what I've done for this plan. Within the plant structure speaks to engineering controls. And yes, you've seen the plexiglass barriers that are out there, those would be engineering controls, administrative controls, adjusting work schedules so that you minimize overlap. You minimize people at the time clock that is inside when most everyone work outside. Engineering controls might be even moving the time clock and have a portable time clock out to the locations. Or adapting a bone based Recording structure to identify the hours that would be worked. Basic infection prevention measures if you're engaged with FISMA, gap, GHP. Those are the areas that we have a fairly significant and substantial opportunity to simply recognize what we're doing, add and disinfectants in certain situations to those protocols. We already have personal protective equipment. This is one of the areas to recognize that PPE is really different in terms of its use and operation than the masks that we're talking about. Masks are not ppb within the definition of my own ship. And if we do go a step further and go into N95 structures than we have additional requirements that we would need to utilize. The house surveillance? Yes. We do still have the daily requirements to determine whether or not we have people who are expressing symptomology and that additional work that your management team should be paying attention to see whether or not people have the potential symptoms that are expressing themselves throughout the course of the day. The overall training, most of us have seen that over and over, we do need to continue the training to remind folks of their responsibilities and also what is happening in terms the day-to-day activity within COVID. When we do those task and procedure terminates determinations, we do need to recognize that these should be added to our plan during my osha inspections. This is one of the areas that they do look for that once those determinations are made, they should be available upon inspection, can be part of your plants and that only the inspector can take a look at them, but also your workers couldn't look at him as well. When we look at the health surveillance, daily screenings, we do have some record required for this. We are required to inform our workforce that they do need to report their symptoms. And when we have to isolate or remove a suspected worker from the workplace. One of the areas that some operations have added challenge with is that if we have a known case, now that is little bit different than the symptoms. If we have a known case, in other words, the positive case, we do have 24 hours to report to the local health department. And that's very important because failure to report can lead to a fairly significant penalty structure. For that operation, and then returned to work. Now, in the coda does say they are no longer infectious. And what does that mean? So right now we are looking at what CDC's current guidance is. So if you do a search for return to work procedures, CDC does have guidance up there and they do also have guidance for agricultural situations that allow for a short period of time than the 14 day original requirement for return to work. So please review that to determine when these procedures would allow for that person to come back to work. Handwashing alcohol wipes. One of the things pay particular attention to is that we have a lot of chemicals around agriculture. We use a lot of pesticides, and we also do an awful lot of cleaning activities in terms of food safety. Please be aware that many of the materials that we are using, including alcohol, including a variety of disinfectants that are out there, are causing a significant amount of potential injuries. Now most of these are relatively minor. Contact dermatitis, for example. But we have to pay attention to our use of those products. You look at disinfectants. Disinfectants are labeled product. Clearly, you can go to the EPA, enlist and figure out which ones would be appropriate not only for your operation, but also would be food safe as well. With those product labels, you will find the potential for the need for actual PPE, whether that be gloves, aprons. I protections, face protections depending on the circumstances that you're using in. But in this situation, that would be specific PPE and would require some additional training sick workers. Now, here's one of the areas that many operations have come up. Right now. An awful lot of people are suffering. We have sinus issues and a normal basis. We get that drainage and the throat. We want to have coughing. So we're expressing a symptom that isn't incorporated into that discussion on that daily situation. So how do we look at that? If we have a combination symptoms, two or more of the symptoms that are on the list. There is a provision here that allows for work in an isolated location. Many aberrations do have remote work on a day to day basis that that person could in fact be employed. The issue is if we're going to have them working with other workers at that point in time. Then we need to minimize or eliminate the contact between other workers. Multiple equipment Utes, we do have situations where we need to use the same pruning shears Lauper as if we're operating right now. We need to understand how to properly sanitized and clean ups disinfect of suspected or known positive areas. There are protocols on the CDC say, to pay attention to those high touch surfaces. Parts, products, any type of shared equipment, even the machinery and vehicles. Most of us are sharing vehicles in terms of the farm activities. So how do we maintain clean surfaces for those? And then when we look at the disinfectant, what we're looking at is for those that are quote, harder to kill viruses. That makes it a little bit more difficult in terms of selecting which product that we use. And please recognize that any of the disinfectants that we use and most of the cleaners that we use would also have to be added to your normal hazard communication program. You want to obtain the safety data sheets for those products. Take a look at a personal protective equipment that would be necessary for those products as well. Now, one of the provisions in the rule is that you need to develop a policy that prohibits in-person work. Now for most of us, we can't do that. We have agricultural activities that are outdoors. You really can't do it from a remote office structure. There are some on the farms such as your office staff that may in fact be able to work off the farm. So the rules specifically provides that we need to create this policy. So I need to work. That's where you need to have a thoughtful and reasoned policy for why work needs to be completed in person. My ocean is indicating that they're not looking for an elaborate structure, but in that determination of the task and procedure, there should be an identification why it is not feasible to be done remotely. So even though it's pretty clear about planning the cornfield, that doesn't matter. We need to have the documentation in terms the fact that that no, I've deemed that I can't do that in terms that task and procedure identification and that should be recorded and included within your plan. So additional requirements, it does require safety coordinator and my osha does ask right away to determine who is in charge of the overall program postings. If you have a labor camp, there's one set of postings that are out there if you have the general structure. In other words, the CDC postings that are available through the meiosis site or through the CDC site on the general symptoms and the general procedures follow the six-foot provision. And they're going to take a look at both the employer and the employee to take a look and whether or not they understand how you are going to implement those physical structure or physical work practices to maintain that non-medical grade masks. That has changed a little bit based on some of the CDC recommendations. But the Maya she's standard does say provide free non-medical grade masks for your workers and then require mask wearing where anyone is within six feet. Now remember, we changed from a structure where it is 15 minutes and 16 to 15 minutes throughout the course of your work schedule. If you're closer than six feet for a total of 15 minutes, then additional protections would need to be looked at. Face shields where you're working within three feet in addition to the masks. And then we do have some additional meat plants provisions that would apply there as well. If you provide isolation housing. So if you're a camera operator in this situation, if you're providing isolation housing, you also need to provide assistance in terms of that person who is under isolation, such as the providing of food and the daily need supplies, or going in and doing cleaning activities in this situation, you would need to have that N95 respirator goggles, face shield, and a gown for any any of the employees that are assisting with in that housing. And these are personal protective equipment. And the N95, if you're requiring it, you do need to go through the medical evaluation, fit testing for that as well. Ultimately, the training Infection Control, general provisions, fairly straightforward property SPB excuse me, and how to report unsafe conditions. So we do need to identify who in the operation that if if the worker does see a problem, who in the operation to report to and then also the myers to outline. And then a must be in a language familiarity. Sorry. So on the records, please keep that record of training and then the screenings of employees. Now I talked about employees, but it also provides for visitors as well. And then a record of illness reports. So if you do have a positive and you did report it to your local health department, you do need to maintain that. And then recognize that if you have a COVID hospitalization or a fatality hospitalization, you're required to report to my osha within 24 hours. If you have a work-related fatalities due to COVID, you are required to report that to my osha within eight hours. And these two situations are a recordable injury or a fatality in terms of your annual LOD 300 provisions. So failure to report failure to log, general duty clause is where many of the violations related to this standard will be respiratory programs. These are all subject of panelists and recognized by virtue of an emergency standard, the penalties can be very significant. So the within this stage, we have maximums 57 up to 70 thousand for a violation. And typically, we had been seeing somewhere in the neighborhood of the 400 dollar range. But if you get into the general duty clause, it could be 5 thousand minimum penalties as well. So what are the possible feather? Excuse me. What are the possible? See, as I said, we do have drainage. So we have possible federal structure. We do anticipate some form of mask requirement nationwide, but it also provides that if such standards are determined necessary, that they will be issued by March 15th. So does allow for standards above and beyond just the mask side of the equation. Please stay tuned to determine whether or not we have these. So let's take a look at the integration. I mentioned that we do need to pay a little bit of attention to all the rest. You do it most all these already. So really look at the integration side of the equation. The MSU champs program does give you kind of a template to be able to organize your thoughts. It is an Excel-based structure, so you can very rapidly put these in and there are several abilities for you to incorporate with your regular programs right now at that site, work groups. One of the most significant things that I've heard from firearms is that they've developed a much greater structure of a work group. And they've been able to minimize the number of people who are ill and actually increase productivity through the development of work groups. They're going to be a group that really does not have contact with other people during the course of the day outside of a phone call or communications in some other form than in-person activities, and then organize the production activities. This is really caused a lot of operations truly organize what, how, when, where, why, and this to his gains and productivity. The people who did not expect in terms of what we're looking at, the sanitation protocols and disinfection. That is really a necessity to be able to minimize both the disease spread and also maintain that food quality. And then take a look at this standard operating procedures that you have. A lot of operations that modify those. And it found that they've been able to streamline and actually improve their work processes by virtue of adopting this type of structure. So have we struggle? Absolutely. In many cases it is the lack of labor. And some outbreaks, the number of outbreaks have been actually declining in a relatively small in terms of agriculture. But the combination of lack of labor has really led far more people to apply for H program status. Remember, you do need approximately 90 days before your data need to begin the process, to go through the program, to get yourself ready to be able to have H2A workers who show up this year. Other operations have increased productivity in many, many different ways, but really group them into three areas, strong communication, bringing your workers on and say, Hey, here we have a requirement, what is working, what is not working? And then really listen to them and make some modifications to improve that work activity. Incentive auctions. One of the areas that a lot of operations have done is not incentivize being at work, but incentivize the ability to get work done. So whether this is a weekly bonus type of structure, whether it is a P3 type of structure. These two have been quite effective in terms of improving. And then the paid leave. Most of our operations are smaller and would not have a requirement for paid leave. But even some of the smaller operations have really taken a look, particularly those that are engaged in the PPP program. They took a look in and did offer a paid leave to be able to to help the employee out. And then coordination with local employers. We have had a number of situations where people have shared workforces where there was a positive. So that is something to pay attention to. And that coordination is ongoing. Whether that be through the development of an association structure within that community, or simply who has the employees that are available at a particular time. So your local employer communication channels are very essential as well. With that, I will leave it open and we're going to take questions at the end and stand and I'll put it over to you. All right. I will share my screen and allow fan does that. Just a reminder to everyone to enter any comments or questions in the Q and a box. You're going to start seeing the questions on the Q&A box, but we'll address them at the end. Think camera and Florencia, I'll be whole number 3 here momentarily, so so you're okay. Are you ready for that? So thank you, Craig. Appreciate good insight on what's what the newest developments are in the my ocher world. And yes, we'll try to try to keep it so we hit the little bit of time for questions here at the end of the program. So I want to talk little bit about labor, share a little bit about a little bit from a recent research paper that was published in Journal of dairy science by myself and some of my colleagues. And then talk a little bit about maybe an opportunity that you haven't heard of before or considered. So certainly labor sources are getting tighter on farms and I like to break it down into kind of the left and the right side columns here. Things that you can't do a lot about on the left, but certainly have an impact on what you can do on your farm and finding labor. But then there's a whole host of things on the right hand side there that can really impact how, how likely you are to be successful in finding and keeping labor on your farm. So this our first poll question, I'd like to know kind of what your top two ways of recruiting labor on your farm right now is. So if you work with farmers, you could just answer based on what you've heard from farmers as well. So that we can get you in there. You could choose, you can choose. A couple of those would be fine. We'll give you not more than a minute here. So we got two out of eight. So if we can get a few more responses there, that would be great. Good deal. That's probably good for us here. Thank you. And and so I feel you've shared that now you can see see the results. I think that would be pretty typical of what we'd hear from producers is that word of mouth is kind of the biggest ones. Some local advertising. Maybe you've had to change a few things to make that more successful. And then interstate job orders as another possibility for farms depending on what you're what you're looking for as far as labor goes. So we went backwards there. Okay, good. So I'm going to, I'm going to jump like a switch the way I'm clicking, so it doesn't do two at a time. So labor certainly not getting easier to find. So our proposition would be that how you manage lever, the team work on your farm equipment condition, pay benefits, all that becomes more important in a tight labor market. And I think farms and businesses in general are finding this out as we, as we go here. So what I'm going to propose today is, is if you could become an employer of choice, then you're going to have more success in finding and keeping employees. Well, what is a employer of choice? It's somebody that attracts, optimizes and holds top talent for a long tenure. And this is really important because the employee chooses to be there. They stay, they come to your farm because they hear a view the year of your reputation, they stay because of how you treat them, the work environment they're in. So how do you become an employer of choice? Well, I'm not going to have you do this as a live pool, but it's just like you to think about, you know, if you are comparing your farm to other farms in your area, maybe other businesses in your area would be even better. You know, how would you rate yourself? Would you say that you're in the top 10%? Top 25 average lower 25, lower 10. Because it's certainly makes a difference if, if you're in that lower 10 or 20 or maybe even average, are you really going to attract the top 10 percent of employees? Probably not going to be super likely to do that, but I'm guessing that you probably don't want the bottom 25%. Me feel like you get them. But that's probably not what you want, right? So how do you become an employer of choice? While we think if you improve your employee management skills in practice though, is that you have had an opportunity to become an employer of choice. And you would be more successful in recruiting, get applicants, hiring good employees and keeping those employees and helping them develop. So I wanted to share just a little bit about some research, just one piece of it here. I put the link there. You can, if you've got access to journal of dairy science course, you can see the full article, but you can also read the abstract there. But this is some research that I did with filters to colleague of mine as well as Felix, sorry, I know a private consultant through through risk management grant that we got through USDA Nipah, spent a few years back, but we just published a second paper on this project this year in the journal. And just a little bit about the farms. We had 1212 farms from four different states. These are all dairy farms, but I think the application is certainly good across farms. You'll notice that we had 77 English speaking as their primary language, 86 Spanish-speaking, the Portuguese. And so they were interviewed by a bilingual or trilingual interviewer. And some questions, we called those management related questions. And the employees gave a score of one to five. And most of those questions, there were some open-ended questions as well. But one was always a poor score and five was always a high score. And then we group those responses. And we said, you know, if the employee said that the employer was a 1, 2, or 3 in this area, we're going to call that low score, even though 3's average, we want to be above average. So one to three is the lowest score of four to five was a high score. Here's the types of questions that we asked them. What do you like most or least obviously that was an open-ended question, but then what's the team like, work like on this farm? You know, the farms goals and how your job applies to those goals fits in with those goals. Do you have equipment to do the job and training to do the job. What's your view, the supervisor, we had several questions around their relationship with the supervisor, their own personal commitment to learning in the business and whether they got performance feedback or not, and whether that was positive or not. And then do they think of ways to improve the business or the kind of engaged as their mind engaged as well as their hands and back. In. We then compared those to four outcome variables, how they responded to these four questions. We're going to concentrate just on the willingness to recommend the farm to others. Because as you so aptly pointed out in your answer to that poll question, that was 80 percent was used by word of mouth. Well, if, if word of mouth is important than how your employees recommend your farm to others, whether they do or not, what they say about your farm becomes really important. And so this is how we ask that question. We asked him, would you recommend this workplace to others on a scale of one to five? With one, I would actually discourage them from working here. Or five, I would strongly recommend this place to them. And you'll see that the average response was actually pretty good across our 12 farms for 0.2 out of five. So there were, you know, in general, the employees felt pretty high about their employers. So again, if, if the most popular is word of mouth, it really matters what your employees say about your business and whether they would recommend or discourage them. And that has huge implications for your farms. Let's There's a lot on this slide, but let me just talk you through it a little bit. So across the bottom are kind of the eight questions that we asked that showed the most difference in whether they were willing to recommend the farm to others, to other potential workers. So if you work your way across the bottom, the red bars are those employees that gave that particular question a low rating of one to three? And the purple or blue bars are those that the employees that gave it a high rating for that particular question. And then you compare that against here on the left. The y axis is their willingness to recommend the farm to others. So if an employee, for instance, gave a low rating on their relationship with their supervisor, they rated that farm, their weight. They rated their willingness to recommend the farm to others at about a 3.2 versus those that said they had a good relationship with their supervisor, gave it a 4.3. So greater than 11 difference between those two. And so what we really are seen then, yeah, I guess catch back up with it or really see it as a dramatic effect between, between these questions and their willingness to recommend the farm to others. And if you look at those first four, those are all about their relationship with their supervisor. What's the relationship you talk with your supervisor about problems. Is the employer working to improve the operation or they just kind of let it go. So I'll progressive as the employer, house, open and honest communication with your supervisor. So those are, that relationship is huge. In fact, the old saying is that people higher on to your company because of your reputation, they leave because of their direct me integer. And so just encourage you to take a look at that and think about ways to improve in those areas. A couple other factors related to that. When we group the relationship questions altogether, those they rated those above average or that 45 were twice as likely to recommend the farms to other workers as those that rated those relationship questions low. In interestingly, Spanish-speaking employees were almost twice as likely to recommend the farm to other workers. So what do you do with that? One of my things that I encourage farms as if if word of mouth is the most popular method, let's make it easier on our employees to recommend the farm to others. Do they have a business card that they can share? Or a card that's the size of a business card that says, you know, here's some opportunities on this farm. Maybe the mission statement of the farm looking for good workers in are you making those available in English and Spanish? Do they have a job announcement that they can forward on by e-mail to another potential worker that's both in English and Spanish. So some things to think about to try to improve that word of mouth. The remainder of my couple of minutes here. I wanted to talk a little bit about a program that you may or may not know about. It's MSU's Institute of Agriculture Technology Program. And it's, it's an entrenched they have an internship part to that program. And so MSU has relationships with 12 different community colleges across the state of Michigan in offering this program. Now it looks a little bit different from location to location as far as which particular programs they offer with an egg technology. But it's still a great connection. And it's a program that has internship as part of its requirements for the students. So the program, the objective of the program is to provide professional internships to students, providing them an opportunity for continued professional growth and development through a practical work experience. And then I underlined in their chosen area of study. So it's really about trying to build on that education that they receive at the community college with practical work experience out in the field. We think that's really important. What this does then for farms as it's an opportunity to provide mentorship to that student to help them grow. It may be an opportunity for not only a current employee, but maybe a future employee down the road. A little bit about the internship program. It's 12 weeks of full-time career related employment. So typically done in summertime. And it's an opportunity for classroom information to really be linked to job responsibilities. And they get three academic credits for participating in this as well. The student has to put together an internship agreement with the employer. In collaboration with the employer. They have to satisfy the employer's requirements and successfully carry out the job duties. So there's a there's a duty on their part to do the job, fulfill the contract if you will, the agreement. Student stays in regular contact with their faculty advisor. They participate integrated internship MSU course where they actually give feedback to other students. They give a presentation at the end of that experience to other students. And then they have a project that they would like them to complete. Now it's preferred that that's at the place of employment. It may be doing some data research at your farm saying, Okay, what, I'd like to kind of find out what this is, you know, what's the incidence rates of this particular disease and what might be contributing to that. So it's really giving them something to dig a little bit deeper into. It's not required at the place of employment, but obviously that's it's really nice if it is something that you can work together with them on a set them up to do. As far as the employer, what your commitment, you have to fulfill the terms of employment and provide for that accomplishment of learning objectives. So coordinate with the faculty advisor and they do come out and visit the farm at least once to look at the progress of the internship. Then they complete an evaluation at the end of the summer. I like to say what it's not. It's not it's not free and easy. This is, this is something where you're working to help students grow in their career, potential career, giving them a great hands-on experience. These are to be paid internships and there's been very few, very, very few exceptions to that. Maybe if it's being overseas in there, pay on your way to go overseas or something like that would be one thing. But usually these are paid internships. So it's not, it's not free and easy, but I think it, it does provide a great opportunity for a student. It does provide labor for your farm for part of the season. And then I've seen some farms really make good use of this type of program, whether it's an internship or just a summer help with students coming up, working on the farm. I've really turning that into a career post-graduation. So it's an opportunity to get yourself out there as a farm, be known as a good place of employment. And a potential for that employee to actually come back or that student to come back and look for a full-time job in the future. So really good opportunity to make some connections there. And I think in the short labor supply that were at firms really have to look for ways that they can get themselves out there. I did for a year. Obviously, you're not going to write all this down. You'll have this in your when these presentations are shared. But you can actually go on and search for MSU is a technology program. They come up with the same list, but I put this list together with my staff. You were to have it all in one place for you with phone numbers and where the different locations are at across the state of Michigan. And then I wanted to finish by just letting you know that we do have a lot of resources up on our farm business management website. We do have a special farm labor or Human Resources page there that has labor law and bulletins and checklists and handbooks and lots of different links to help you with your labor reporting needs. One thing that I did want to point out is we have Craig and I work on IE eg labor law bulletin that some undergoing an update right now, we're really excited that we have a new relationship at the state level with a workforce development agency to really bring back some definition of what's required under US labor laws in the state of Michigan. In recognizing the egg has an exemption. Under for a number of the rules that are out there. Not to say that we want to promote, you know, any unsafe work, but just that we have the ability to to hire youth in that 171617 year age rate, her age range i and provide them with some work experiences on the farm that they couldn't get any other place, and so on. We're excited about that opportunity. When that egg labor law bulletin comes out this next time you'll see some more definition, more education for egg employer so that they know that they're on the right side of the rules and understand what they need to do to comply with those rules. That's just a little bit. This is the bulletin I'm talking about the 2966 that was updated back in 2018. That will be updated again soon. With that, we will take a few questions in our remaining time. I know we saw I saw a couple coming Craig hi, into the Q and a. The last time I checked it, it looked like they were both probably more directed toward you and you have answered at least one of them, so I answered three of them. Okay. All right. So maybe we're all set there. You know, actually what common are known chemicals are associated or causal to known health concerns and act from farm to factory? That question, I don't think it has been answered yet. I put it up here so that we remember to try to address said if Craig has any comments. Oh, okay. Sure. I presume you're looking at the comments I made about disinfectants. So if you look at the common one, let's say it's an alcohol-based understand that 70 percent alcohol generally, is it going to be labeled as a flammable material? So it does lead to desiccation of the skin and in terms of its usage. But 70% is what you're looking at for effective control of the COVID virus. And the analyst does provide those. And I posted the enlist in one of the answers. The Endless does give you a very good opportunity to go through and make a determination of which products might be the most effective for your particular circumstances at the, at the least hazard. And that's always the challenges. What's more active at the, at the limited hazard to producer or the user. So thanks Craig. I did have one. You can check this too. But looking at the the math and drug usage, I think certainly on farms have been less likely to have a drug testing policy just because of the shortage of workers? Well, that's still certainly still have a drug policy review, I'll say and I think frankly agree with me on this, but I'll let him chime into that. If you're going to write something down as policy, you actually have to follow it consistently as policy. And so you do want to make sure that you've thought through what wording you're going to use. Some farms require at, at hiring time. Others say that it's at hiring. And if there's a suspected or if there's an incident, accident happens, those are certainly easier times to do it. Easier to define that. We need to deposit because it was accidental harm and give me an IT issue. Or just anytime there's an actual farm, we're going to do drug testing. So but just be really consistent, be really clear in your language that if you're gonna put together a policy around drug use, So did you have anything you wanted to add to that Craig? Sure. In the question and these were any answered so I missed this one. Where it where you take a look at firms discontinuing? Yes. There is a higher prevalence of marijuana positives and recognize the marijuana is still a federally regulated drug. And if you're in any safety sensitive activities, The positive test really indicates that person needs to be remote. So if you have a CDL driver, you are required to maintain the drug and alcohol testing procedures. And I would highly recommend if anyone is looking to either establish or operate a program to really look at the federal highway or fm, see if a Federal Motor Carrier Safety Division drug and alcohol testing procedures for employers. This is an area that is getting an awful lot of discriminatory activities. So for example, a stand indicated if if you say it, you need to follow it. So many of the policies say no drugs and alcohol. Yet, the family and the weekend who are on the fire, I'm working in the shop, bring out a six pack and drink. Well, if the sun is drinking, then you need to implement whatever your policy says regarding to that activity. So be very cautious. I would highly suggest that you look at where girls to begin with and move on to a policy. A policy is a contract of employment and you really need to follow it at all times. And have a couple open ones there to Florence. He I don't know if we can get all those, but I can just say on that on our survey with the Spanish-speaking employees, twice as likely to walk in and the farm. There was no If it was a across the board. Those employees just redid their willingness to recommend the farm higher than English-speaking employees. There's a lot of things wrapped up in that tenure was less with Spanish-speaking employees than English-speaking employees as as we looked across those farms. So you may have been scenes some still of the honeymoon period, if you will, for newer employees and unwillingness to recommend the farm. But there was, it was an interesting distinction that I want to point out in. I think the importance of saying, Okay, we need to make sure that we're not letting communication barriers get in the way of helping to recruit employees. So okayed. So it looks like we've run out of time. Stand and Craig, Do you have any closing thoughts? Thank those that were able to join us. And thank you Florencia for or you're moderating this session. I would hope that with those 12 partnering schools that will have a 100 percent internship rate this year. And also look down at the high-school level because the federal rules have changed, that will allow for schoolwork programs, the high school level as well. Okay. Thank you, Stan and Craig for your time.