At about 1:20 p.m. on March 23, 2005, a series of incredibly powerful blasts at BPâ€™s Texas City refinery, ignited during the restarting of a hydrocarbon isomerization unit, killed 15 workers and injured approximately 170. Many victims were in or around trailers located near an atmospheric vent stack that blew when a distillation tower flooded with hydrocarbons was overpressurized. Workers were injured in trailers as far as 479 feet away, and trailers damaged as far as almost 1,000 feet from the explosion.
Less than a year later, between 6 a.m. and 6:30 a.m. on January 2, 2006, a methane gas explosion at the Sago Mine in West Virginia, possibly set off by an unusually large lightning strike, occurred as two groups of miners in separate carts entered the mine to resume work after the holidays. Miners in the rear cart heard or felt the blast ahead of them and quickly retreated. Thirteen miners in the first cart were trapped by falling debris, about 260 feet underground and an estimated 1,500 feet into the five-and-a-half-foot tall tunnel. It would take 40 hours to reach the miners.
Compounding the nightmare, news reports set church bells pealing by initially claiming 12 miners were found alive. After realizing the mistake, it took company officials three hours to confirm the error and tell the truth: one man survived and 12 died.
Stunning storiesThese tragedies stand as the two biggest EHS news events of the past 18 months, according to ISHNâ€™s recent poll of more than 40 "expert advisors."
"We always viewed BP as a world-class company, so Iâ€™m amazed at the problems they are facing in the U.S.," says Tom Cecich, former EHS manager for Glaxo, another major British company.
"The Sago Mine disaster really brought the hazards of the workplace to the forefront (for at least a little while)," says Linda Tapp, president of Crown Safety, a consulting firm. In many ways, a refinery owned by one of the worldâ€™s wealthiest and most prominent corporations, sitting on 1,500 acres and employing about 3,300 workers, confronts the same safety issues as an obscure West Virginia coal mine employing, at its fullest, 154 people. The gap between big and small isnâ€™t what it once was in the shrinking EHS world.
"The really good companies are starting to try to uncover the reasons for these catastrophic events," says Jim Spigener, vice president for Behavioral Science Technology. "They are desperately searching for answers."
Surveying the fieldIn mid-August, we e-mailed 154 "ISHN VIP advisors" â€” EHS professionals in large and small companies, pros young and old, plus consultants, academics, association leaders, union leaders and agency officials weâ€™ve come to know over the years â€” and asked them to select the biggest national EHS stories of the past 12-18 months.
We offered a list of 17 candidate stories to choose from, though the VIP advisors were not limited to these. Bottom line: We wanted to learn what recent national stories had the most significant impact on the day-to-day jobs of EHS pros everywhere.
We heard back from 42 respondents, for a 27 percent response rate. Respondents were permitted to select up to three top stories.
Here, then, are the top stories of the past 18 months (listed in order by number of "votes"):
The Big NewsThe growth in EHS management systems
The rise of global EHS regulations affecting U.S. enterprises
- The slowdown in OSHA standards-setting
- Sago Mine explosion
- Health effects of nano-size particles
- Explosion at BPâ€™s Texas City, Texas, refinery
- Popularity of safety culture principles and tactics
- Hurricane Katrina emergency response problems
- Lean EHS staffing practices
- College EHS programs struggling to recruit students
- Health problems of ground zero cleanup workers
- Reproductive health hazards
- Avian Flu threat
- Meth lab cleanup hazards
- Chinese safety and health disasters
- Leadership void and loss of vision in EHS
- Declining interest in behavior-based safety
- Influx of immigrant workers
- Rising professionalism of EHS staff
- Increase in security/terrorism protection practices
Interestingly, several candidate stories we listed for votes received no attention.
Off the radar?
- Edwin Foulke becomes OSHA chief
- VPPâ€™s booming growth
Specifically, Sago and Texas City highlight eight trends that sooner or later will touch almost every EHS professional.
Trend #1 â€” GlobalizationSmall workplaces donâ€™t always remain independent, isolated, and off the public and media radar screens in the era of globalization.
"If you work in a small company that does not do business internationally, you might think these (international EHS) standards donâ€™t matter," says Gary Lopez, a member of the committee that drafted the ANSI/AIHA Z10 occupational health and safety management standard. "But one day your company might be acquired by an international company. Or if your company decides to expand internationally, your interests suddenly change. It pays to see the bigger picture."
Both International Coal Group (ICG), owner of the Sago Mine, and BP had to answer questions about possible safety risks arising from aggressive business acquisition strategies. ICG acquired the Sago Mine in November 2005 when it completed its merger with Anker Coal Group. Wilbur Ross, Jr., owner of ICG, has acquired bankrupt steel companies, textile companies and coal companies in the last decade through his investment firm, W.L. Ross & Co.
BP has expanded its footprint in the U.S. for decades. It bought the remainder of Sohio, formerly Standard Oil of Ohio, in the 1980s. In 1998, BP shareholders approved the purchase of Amoco, which included the Texas City refinery. In 2000, BP acquired Los Angeles-based Atlantic Richfield Company (ARCO).
"When ARCO owned Prudhoe (the Alaskan oil field) it was treated like the crown jewel of the company," a former ARCO industrial hygienist told ISHN. "Now itâ€™s just another BP oil field to run into the ground. Same thing for the tragedy in Texas. How many other self-described â€˜world-classâ€™ companies are out there, ticking, ticking, ticking?"
"Mergers and acquisitions create an unsettled period that can diminish safety performance," reported two corporate culture consultants in an August 15, 2006, Reuters dispatch.
Flat-sizing: The title of Thomas Friedmanâ€™s best-seller, "The World is Flat," (Farrar, Straus, Giroux 2006) applies to the EHS world as well. Friedmanâ€™s thesis: the old power structures are gone and the economic playing field is now level. Tech advances, in computing power, software, digitized information and telecommunications, have shrunk the world, lowered barriers to new business entry, and drawn trading partners much closer together.
Globalization is making its mark on the EHS world, too. Many of our respondents pointed to the United Nationâ€™s Globally Harmonized System (GHS) of Classification and Labeling of Chemicals as exhibit 1A. "We are quickly learning that harmonization doesnâ€™t mean everyone else will have to do it like us," says Tom Grumbles, manager, product safety and occupational health for Sasol North America.
On September 12th, OSHA published an Advance Notice of Proposed Rulemaking soliciting public comment on how to adopt the GHS, which will require the agency to make changes to its hazard communication standard.
"Diverse and sometimes conflicting national and international requirements can create confusion among employers," said OSHA chief Edwin Foulke. Adopting GHS would provide a consistent format for labels and safety data sheets, making information easier to understand, he said.
(See Dan Markiewiczâ€™s "Managing Best Practices" column on page 16 in this issue for more details on probable changes to the hazard communication standard as a result of adopting GHS.)
Globalization also affects the protective gear your employees might wear. Explains Dan Shipp, president of the International Safety Equipment Association: "More and more imported PPE is being private-labeled and sold by companies that may have only a rudimentary idea of performance standards. Thereâ€™s no mandatory certification, purchasers look for the lowest costs, and workers donâ€™t know a product is non-compliant unless it fails."
Trend #2 â€” Management systemsBPâ€™s Web site goes into detail describing the multinationalâ€™s myriad safety management systems:
- Major accident risk assessments (MAR) are conducted for major plants and equipment. A prioritized investment plan is to be developed to address the recommendations of the MAR assessments. BP forecasts that during the next five years investment in "integrity management" at its sites will total more than $3.5 billion. (BP had sales of $262 billion in 2005.)
- In 2006 BP is launching a group standard on integrity management (IM) to be implemented by 2008. The new IM standard will include the MAR process for assessing plants, and is designed to minimize the number of incidents involving loss of containment or failure of an engineering system. The IM standard identifies the individuals accountable for integrity of facilities and assesses if employees have the necessary competencies.
- BP is augmenting its current management system ("Getting HSE Right") to produce a more comprehensive management system that will help improve safety management processes and better integrate them with operational procedures.
"Sure, all these certified systems add to a consultantâ€™s pocket and create a potential mountain of paperwork, but each provides some good structure with which to align our systems," explains Mike Kalbaugh, EHS manager for Avery Dennison Retail Information Services. "I use portions of various systems â€” OHSAS 18001, VPP, ANSI Z10 â€” to help guide development of our systems. Through the use of these management systems we can better align EHS as part of the overall manufacturing processes, rather than viewing EHS as a â€˜separate thing to doâ€™."
"Just like quality and environmental professionals, safety practitioners now have a strong opportunity to integrate their safety systems with other management system standards," adds Wayne Pardy, a Canadian EHS consultant.
Economic drivers: The growing use of global EHS management system standards like ISO 14001, OHSAS 18001 and ANSI Z10 is a prime example of the downsized, more integrated EHS world. There has been a 36-percent increase in the number of certificates issued to OHSAS 18001 since 2004 (now over 15,000 worldwide), according to a survey by the OHSAS Project Group, reports Thea Dunmire of ENLAR Compliance Services. "New international guidance and/or standards are currently being developed on social responsibility, third-party conformity assessment activities, risk assessment, food safety, and addressing environmental considerations in product design," says Dunmire. "These activities are becoming more important to businesses than U.S. regulatory programs because if they donâ€™t comply, they canâ€™t sell. For many businesses, this is a much greater motivator than non-compliance penalties, however big."
A global ISO safety and health management system standard is "still inevitable," predicts Gary Lopez. "We operate in a truly international market, and the market will push demand for this standard."
Trend #3 â€” Non-governmental organizationsNGOs had been suspicious of BPâ€™s "Beyond Petroleum" credo long before the Texas City refinery explosion.
In 2002, Greenpeace awarded Lord John Browne, BPâ€™s chief executive, an Earth Day "Oscar" for "Best Impression of an Environmentalist." The Multinational Monitor, a magazine critical of corporate economy founded by Ralph Nader, named BP one of the ten worst corporations of 2005. "We believe the families of the (Texas City) dead deserve a full-blown reckless homicide investigation by the district attorney in Galveston County," wrote the Monitor.
And more than a year after the explosion, the Rev. Jesse Jackson, a one-man NGO, led a march in front of BPâ€™s Texas City refinery. "We are going to engage in direct action against BP to change their behavior," Jackson said.
The new regulators: NGOs are a force to be reckoned with in the globalization story. A 1995 U.N. report estimated nearly 29,000 international NGOs existed at the time. These non-profits lobby, pressure and take direct action mostly on social, cultural, legal and environmental goals. National numbers for NGOs are even higher. The U.S. has an estimated two million NGOs, and in Kenya alone, some 240 NGOs are created every year, according to the Web site Wikipedia.
"The burgeoning influence of non-governmental organizations on the behavior of corporations as it relates to EHS and social responsibility is arguably greater in certain parts of the world than the local government," reports Mark Katchen of The Phylmar Group, an international consultancy.
"In some cases, the NGO can make or break a brand through their media channels," Katchen says. "In many cases, the NGOs have forced corporations operating in Third World areas to develop codes of conduct and audit their supply chain against these codes."
Trend #4 â€” Corporate social responsibility With all the attention given to corporate behavior, ethics and values, a company can hardly enter the marketplace without waving at least a code of conduct. The International Coal Groupâ€™s Code of Business Conduct and Ethics calls for rules compliance and prompt reporting of accidents, injuries, and unsafe equipment, practices, or conditions to a supervisor or more senior manager. ICG has also set up a "Performance Group Initiative" that gives every employee a forum for addressing any safety or production concerns or suggestions, anonymously if they so choose.
BP, of course, is one of the original poster powers for corporate social responsibility (CSR). Its Code of Conduct, which can be downloaded from its Web site in Arabic, Mandarin and ten other foreign languages, "summarizes our standards for the way we behave," states Lord Browne. "All our employees must follow the code of conduct." Smiling faces: "Advertising on environmental issues by corporations has grown significantly over the past five years, and now we are beginning to see this advertising expand into social issues," notes James Leemann, Ph.D., of The Leemann Group. "These advertising initiatives allow companies to differentiate themselves in a socially responsible positive manner with their customers."
Indeed, a recent full-page ad from Toyota shows cheery factory workers standing above the headline, "Being a good corporate citizen starts with hiring lots of good citizens." Toyota explains in the ad copy: "Our team members care about doing whatâ€™s right: at work as well as in their local communities. They really are good citizens. Which in turn makes Toyota a better corporate citizen. Isnâ€™t it nice when things work out?"
That last line summarizes the optimism of CSR in a nutshell.
Microsoft promotes a similar "make-a-difference" pitch in a recent ad for "software that makes people ready, so they can make all the difference."
Not so fast: CSR has many unconverted skeptics. A recent study by a Scottish professor at St. Andrews University found less than four percent of the worldâ€™s 50,000 major companies produce reports on corporate social responsibility, and the quality of the reports that are produced is "almost universally trivial," stated the researcher.
"Is corporate social responsibility merely a â€˜feel goodâ€™ marketing initiative, or are corporate decision-makers really taking environmental quality, worker safety and health, and public health and welfare into account when making decisions?" asks Leemann.
"The $60-million question is: Do corporate leaders have the moral fortitude to institute effective voluntary safety performance standards without government requirements?" asks a safety and health manager.
Trend #5 â€” Failure of the fedsBoth Sago and Texas City show that regulators, in these cases MSHA and OSHA, respectively, have little power to force companies to go beyond compliance, despite levying in some cases millions of dollars in penalties. (OSHAâ€™s $21.3 million penalty for the Texas City incident, paid in full by BP, pales next to the companyâ€™s $262 billion in 2005 revenues.) And as EHS pros have claimed for decades, compliance merely establishes a floor, the minimum, for safety and health programs.
Thatâ€™s one reason companies both large and small are moving to implement management systems and codes of conduct, and attempting to build "cultures" of safety. These complex issues of organizational performance are not covered by any OSHA or MSHA standards, except in the case of OSHAâ€™s process management standard, which deals specifically with the handling and storage of about 140 toxic and reactive highly hazardous chemicals. Losing faith: A distinct lack of faith in federal agencies runs through the comments of a number of ISHNâ€™s VIP advisors. Recent failures by agencies responsible for workplace and public safety and health have regulators and bureaucrats looking like the gang that couldnâ€™t shoot straight â€” or plan, communicate and lead â€” in the eyes of some of our respondents.
Notes one veteran safety pro: "It didnâ€™t take the government much time to have the EPA declare that the (Word Trade Center) towers disaster site and surrounding areas would not pose significant health concerns. Thereâ€™s no need to elaborate on how FEMA botched Hurricane Katrina emergency response. How many times did MSHA inspect and cite the Sago Mine? Current permissible exposure limits (PELs) are from what year now?"
"The continuing inability by OSHA to update PELs, what else can you say? A sad story with no end," says Tom Grumbles.
"The continuing dead-in-the-water status of updating regulations is amazing and unconscionable," says Margaret Carroll, a former member of OSHAâ€™s national advisory committee. "OSHA is fast becoming an anachronism, useless to the very people it is supposed to protect."
"FEMA has learned nothing from Katrina except how to get bigger and make bigger plans to screw up bigger disaster responses," says Gary Rosenblum, a municipal risk manager. "I make all my plans assuming no assistance from federal agencies and hope they arrive so slowly that we will have some response in place before they start federalizing everything." This past April, a bipartisan Senate committee said FEMA was so fundamentally inept during Katrina that Congress should abolish it and create a new disaster response agency from scratch.
Politicized inside and out, and in many instances lacking ambition and energy, U.S. EHS regulators are setting up many businesses, especially multinationals, for long-distance compliance with rules they had no chance to even comment on.
"The U.S. is no longer in the forefront of EHS regulatory activity, and in many cases it is not even being listened to," says Thea Dunmire. "Part of the reason for this is the truism that â€˜standards are drafted by those who show up,â€™ and the U.S. increasingly is not showing up and not supporting (international) standards-setting activities. Guess what â€” the rest of the world is going ahead without us."
Trend #6 â€” No place to hideEighteen months after the BP refinery explosion in Texas, a Google search using keywords "BP Texas City explosion" turned up about 324,000 Internet postings. They ran the gamut from the latest update from the U.S. Chemical Safety and Hazard Investigation Board to an eyewitness account reported by the Houston Chronicle to rants on Liberty Blog; The Arctic Beacon; the Mostly Cajun, All American and Opinionated Blog; to this ad from Williams Bailey law firm: "Find out how we can help you if you or a loved one was a victim of the BP explosion in Texas City."
Nine months after the Sago mine disaster, a Google search fetched about 169,000 postings. Along with a report from National Public Radio were more slanted reports from the Center for American Progress, the Labor Blog, the Confined Space blog, The Progressive magazine and a source called "Corporate Crime Pays."
Virtual watchdogs: The Internet has drastically diminished the size of the EHS world. Time and distance are irrelevant. Daily news alerts using keywords from Google and other search services give global publicity to minor workplace accidents that never would have been reported beyond local newspapers. And an ever-expanding army of bloggers (a sort of free-agent nation of news commentators estimated to be in the millions in the U.S. alone) is quick to cast judgment on those incidents and the companies involved.
And "bad news" doesnâ€™t fade away on the Internet. It sits there, waiting to be searched out. With the pervasiveness of Internet news coverage and instant flogging from bloggers, itâ€™s no wonder at least some companies with EHS problems are becoming both more open and aggressive. International Coal Group Inc. has a "Sago FAQ" on its Web site, as well as a response to a preliminary report by the state of West Virginia into the explosion.
BPâ€™s sunny yellow and green Web site â€” a clean, attractive serving of CSR positivism â€” offers the companyâ€™s response to pipeline maintenance problems in Alaska that were the subject of Senate hearings in September. An entire page is devoted to the "Texas City Incident," describing in largely spin-free detail what happened, what BP is doing about it, and ending with this survey question: "Is BPâ€™s response to the Texas City incident clear and understandable?"
Trend #7 â€” Lean operatorsBoth BP and ICG were attacked immediately and fiercely after the incidents by the mainstream media, Internet bloggers, and NGO advocacy groups over alleged cost-cutting, lean staffing, and skimping on safety training.
In Texas City, BPâ€™s own findings concluded unit supervisors were absent from the scene during critical parts of the startup, and unit operators failed to take effective action to control the process upset or to sound evacuation alarms after the pressure relief valves opened. At the Sago Mine, the company employed no rescue team on site. According to MSHA:
"Rescue teams have always been an elite aspect of the coal industry. MSHA regulations specify that mine rescue stations must be within two hours ground travel of a coal mineâ€¦ most mining operations only have the minimum coverage defined in the regulations. Teams are expensive to create and maintain."
Stressed and stretched: "I meet so many EHS professionals who are ripping their hair out, frustrated and stressed. Iâ€™m one of them, with the ever-changing business systems that are lean, lean, lean," reports one obviously harried pro. "I now have responsibility for 45 facilities worldwide on four continents and support from six full-time EHS pros.
"The key is to find new ways to incorporate EHS into the everyday business operations, so it is not seen as â€˜just another thing we have to do,â€™ and rather seen as a part of the way we do business," he says. "The profession is in the midst of a paradigm shift from regulatory-focused to business-focused."
Trend #8 â€” Culture curesBPâ€™s internal investigation of the Texas City explosion and fire also fingered cultural problems â€” "the team found many areas where procedures, policies and expected behaviors were not met," according to the final report.
"Over the years, the working environment had eroded to one characterized by resistance to change and lacking of trust, motivation, and a sense of purpose," stated the report. Unclear expectations around supervisory and management behaviors meant "rules were not consistently followed"â€¦ and "individuals felt disempowered from suggesting or initiating improvements."
Prior to the March 23 explosion, BP had begun to implement a "Just Culture" in which people are held accountable for their job performance. "We are creating an environment in which people know that what they say matters, that they know what is expected of them and that they will deliver what is expected of them," explained Colin Maclean, manager of the Texas City refinery, on BPâ€™s Web site. "We must keep our promises to each other. It is the first step in rebuilding trust and the only way to earn the respect and obtain the commitment of a very skilled and very experienced workforce."
BPâ€™s daunting challenge is to cast that kind of culture of safety over a global workforce of some 96,200 employees. While BP settled with OSHA and agreed to pay the $21.3 million fine for more than 300 alleged violations relating to the Texas City blast, the company is fighting OSHA fines of $2.4 million following an inspection this April of its Toledo, Ohio, refinery that found a number of violations similar to those that caused the deadly Texas City incident, according to OSHA.
"It is extremely disappointing that BP Products failed to learn from the lessons of Texas City to assure workersâ€™ safety and health," said OSHA boss Edwin Foulke in a statement. Coupled with alleged environmental problems at a BP chemical plant outside of Chicago, a BP pipeline spill in Alaska this March and the partial shutdown of the same Alaskan oil field after more corroded transit lines were discovered in August, Carolyn Merritt, chairman and chief executive of the U.S. Chemical Safety and Hazard Investigation Board, told the Chicago Tribune:
"When you have the lack of maintenance, procedures, oversight and training (found at the Texas site), these things are pretty systemic and itâ€™s unusual to find it only at one facility." A BP spokesman told the Tribune there was no evidence to conclude that the incidents were related.
Final assessmentEven in todayâ€™s flattened EHS world, where high-visibility employers like BP (28,500 service stations and active exploration in 26 countries) and isolated operators like the Sago Mine (population of Tallmansville, West Va., which includes Sago: 418) contend with similar challenges, the solutions largely remain the same:
"I see four major issues," wrote Tom Durbin, coordinator of health and safety consulting services for ORC Worldwide, in an e-mail.
"Leadership: Safety deserves its fair share of executive leadership and problem-solving skills. Leadership in safety is finally getting some press and some attention from some of the leading consultants. However, the challenges to make this work are substantial. "Employee involvement: Always a topic in safety, but few companies know how to structure it efficiently and effectively.
"Metrics: Still too much focus on the OSHA data, not enough understanding of what you must change (exposure reduction) to make meaningful reduction in workplace (and non-workplace) incidents.
"Resources: Global competition adds to this issue that is with us forever, but properly resourced with the right talent (not necessarily with more staff folks, either) makes an effective safety process (and health and environmental) a competitive advantage."
Sidebar: ISHNâ€™s VIP AdvisorsThese experts kindly took the time to respond â€” some more than once â€” to our e-mail poll about the big stories in the EHS world.
Bill Borwegen, Occupational Health and Safety Director, Service Employees International Union
Dan Brockman, Dan Brockman Recruiters
Tom Cecich, President, TFC & Associates
Margaret Carroll, President, Margaret M. Carroll Co., LLC
Aaron Chen, Clean & Disinfect Global Product Steward/Sr. Industrial Hygienist, DuPont Chemical Solutions Enterprise
Andrew Cutz, Manager - Occupational Hygiene, T. Harris Environmental Management Inc.
David Coble, President, Coble, Taylor and Jones Safety Associates
Raymond Colvin, Director Safety & Security, Eternal Word Television Network
Lawrence "Chip" Dawson, Dawson Associates
Thea Dunmire, ENLAR Compliance Services
Tom Durbin, Coordinator, Health & Safety Consulting Service, ORC Worldwide
Donald Eckenfelder, Social Operating Systems, Ltd.
Joy Erdman, Safety and Occupational Health Program Manager
Tom Grumbles, Manager, Product Safety & Occupational Health, Sasol North America
Earl Hansen, Professor, Director of the Office of Ergonomics and Safety, Northern Illinois University
Larry Hansen, President, L2H
Ernie Huelke, General Manager of Safety & Training, Oâ€™Hare Airport Transit System Inc.
Mike Kalbaugh, EHS Manager, Avery Dennison Retail Information Services
Mark Katchen, Principal, The Phylmar Group Inc.
Tom Lawrence, Principal, RRS Engineering
Vince Laquidara, environmental manager
James Leemann, The Leemann Group
Steven Levine, Emeritus Professor, University of Michigan School of Public Health
Anne Lewis, Senior Project Manager, Coastal Training Technologies
Zack Mansdorf, Safety, Industrial Health & Environment Director, Lâ€™Oreal Production & Technology
Dan Markiewicz, Markiewicz & Associates
John Meagher, Environmental Health and Safety Scientist, International Center for Toxicology and Medicine
Jeff Meddin, safety and health manager
Wayne Pardy, Vice President of Safety and Audit Management, Q5 Systems Limited
Dan Petersen, Dan Petersen Associates
Georgi Popov, Kingston Environmental Laboratory
Gary Rosenblum, Risk Manager, City of Palm Desert, Calif.
Phillip Safe, Safety Manager, Astro-Air LP
Dan Shipp, President, International Safety Equipment Institute
Jim Spigener, Vice President, Behavioral Science Technology, Inc.
James Swartz, Director Corporate Safety Health and Environment, Delta Airlines
Linda Tapp, President, Crown Safety
Mike W. Thompson, safety and health manager
Michael T. Weeks, Environmental Consultant, Boelter & Yates Inc.
John Wesley, EHS Manager, Howmet Castings
Frank White, Senior Vice President, ORC Worldwide
Dee Woodhull, Senior Consultant, ORC Worldwide
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