Ministry of Labour Enforcement Approach for the Health Care Sector, Including Infection Control

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Tuesday, March 23, 2004

Operator: Good afternoon, ladies and gentlemen. Welcome to Health Care Health and Safety Association Ministry of Labour Approach in Health Care, including infection control, conference call. I would now like to turn the meeting over to Mr. Craig Lawrie, OSACH consultant, Kingston region. Please go ahead, Mr. Lawrie.

Craig Lawrie, OSACH Consultant, Kingston Region: Good afternoon, and on behalf of the Ontario Safety Association for Community and Healthcare, I'd like to thank and welcome all the participants for attending today. Today our presentation is about the Ministry of Labour's enforcement strategies in the health-care sector, including infection control.

Following the presentation of both of our speakers, we invite you to stay on the line for a question and answer period. Please note that the question and answer period is on a limited time, so if time runs out and your question is not addressed, please stay on the line and the operator will take your information.

Before introducing our speakers, I have a few reminders for the audience. First, please try to eliminate all background noise or discussion during your call, since this will affect audio quality. Come to the microphone if you're in a large room so that everyone will be able to hear you. Turn off all of your pagers and cell phones. And finally, if your building has a PA system, turn it down or turn it off, if possible.

I would like to point out at this time that this teleconference is related to the Ministry's proactive activities in the health-care sector. Ministry staff will not be able to discuss issues related to SARS either generally or specifically.

Okay. Our speakers today are Audrey Birkbeck and Dr. Leon Genesove. Audrey Birkbeck is a provincial specialist with the Ministry of Labour's Industrial Health and Safety Program, which is part of the Occupational Health and Safety branch. Audrey provides program support and technical guidance to health and safety inspectors and other Ministry staff across the province. Her responsibilities include the development of industrial sector enforcement strategies by monitoring existing Ministry enforcement activities and consulting with Ministry staff, Health and Safety System partners and other stakeholders to identify emerging health and safety issues. As well, Audrey plays a key role in evaluating the application of Ministry policies and regulations, working with the Ministry's policy division and legal services branch. As the Ministry spokesperson for a variety of industrial sectors, Audrey often provides information on program direction and works closely with Health and Safety System partners on the development of various prevention strategies.

Dr. Genesove is a provincial physician with the Ontario Ministry of Labour. He advises the Ministry on the health needs of both individuals and groups with respect to their working environment. Dr. Genesove is certified in the specialty of occupational medicine by the Royal College of Physicians and Surgeons of Canada. He lectures on occupational medicine at the University of Toronto, Faculty of Medicine.

Welcome, Audrey and Dr. Genesove.

Audrey Birkbeck, Ministry of Labour Industrial Health & Safety Program, Provincial Specialist: Thank you, Craig. I'll begin by speaking generally about the Ministry of Labour's role within the occupational health and safety system in Ontario. I'll be speaking about our general approach towards enforcement in the industrial program, and as well I'll be speaking out our general approach with regards to enforcement in the health-care sector.

If you'd like to turn along with me, if you've got your slides available to you, I'd like to just start by giving a very broad overview of the Occupational Health and Safety System in Ontario. You may know it's made up of three key partners: the Workplace Safety and Insurance Board, Health and Safety Association, and the Ontario Ministry of Labour. Of course, the Workplace Safety and Insurance Board administers injury insurance programs, financial interventions, certified member programs for joint health and safety committees, and it oversees health and safety associations.

Health and safety associations like the Health Care Health and Safety Association conduct training, they are responsible for consultative interventions, as well as opportunities to volunteer. And as well, we have broader health and safety partnerships including public health departments for outbreaks of infectious diseases in workplaces, for example, the Ministry of Health and Long-Term Care, and other key stakeholder groups such as OHA, ONA, to bring provincial issues to the attention of the Ministry of Labour.

So within the Occupational Health and Safety System, the Ministry of Labour is committed to the prevention of workplace deaths, injuries and disease by setting standards, communicating standards and enforcing standards.

Under the Occupational Health and Safety Act, the roles and responsibilities and powers and duties of the workplace parties, as I hope you know, are very well laid out, the powers of inspectors as well. The Health and Safety regulations are more specific: either workplace regulations or hazard-specific regulations that address specific issues and hazards-for example, the regulation for health care and residential facilities, the WHMIS regulations, the X-ray regulations.

Our role in enforcing standards is twofold. We conduct, on a reactive basis, investigations. We also conduct, on a proactive basis, inspections to targeted workplaces. Investigations can result from workplace injuries and fatalities, from workplace complaints, from work refusals, or for occurrences where there are no injuries. It's our job with regards to inspections to get to the priority workplaces and targets for priority hazards.

But how do we do that with over 4.5 million workers in the province? We try to concentrate our enforcement on the poor performers, the vulnerable workers, and workplaces where self-reliance is not evident. We then encourage self-reliance in other workplaces.

We consider vulnerable workers to include those that may be non-unionized, temporary or contract workers, workers where there are language barriers present who may be underqualified, et cetera. And we regard self-reliance to be the ability of a workplace and the workplace parties to identify and address the health and safety issues without outside intervention. A self-reliant workplace is able to demonstrate improvements in health and safety performance.

In order to get to priority workplaces in the industrial health and safety program, we group workplaces into 29 industrial centres. These are based on standard industrial classifications whereby we put similar types of industries into 29 different sectors made up of similar industries. We try to identify the priority sectors using a risk assessment to allocate our field visit resources.

In developing our sector-specific enforcement strategies, we do consult with our health and safety system partners in the Occupational Health and Safety System to identify some of the merging hazards and issues for each of the sectors, and we develop sector-specific enforcement strategies that are used in conjunction with WSIB and Ministry of Labour data to target the priority workplaces for inspection purposes.

The benefits of this approach are multifold. First of all, it gives us an efficient use of resources. We have better alignment of the health and safety system's strategic plans both at the MOL, the Workplace Safety and Insurance Board, and the various health and safety associations. It ensures that our resources are focused on priority workplaces and priority hazards

It promotes effective enforcement as well. Through a risk-assessed based targeting strategy for the 29 sectors, we can be responsive to changes in the different workplaces, emerging hazards that might be coming towards us, new technology, a different labour relations climate. As well, it ensures quality of enforcement, consistent enforcement cross the province, creating a level playing field and a basis for formal performance measurements and progress improvements at the Ministry of Labour.

Specifically dealing with the health-care sector, this is quite a diverse sector. It's made up of various-if you're looking at slide number 8, you'll see it includes very different types of health-care services, including acute-care facilities, long-term care facilities, home-care services, group homes, health laboratories, doctors' offices and clinics, and social service organizations. It therefore requires various enforcement strategies.

Specifically, section 2(1) of the health care regulation specifies the types of facilities that would fall under the health-care regulations. It is a comprehensive regulation and has a very powerful requirement for written measures and procedures for the protection of workers. This is a formal approach of reducing any measures and procedures taken to protect workers into writing that must be reviewed annually, applied broadly and must involve the participation of all workers-of all workplace parties, excuse me.

Slide 10 illustrates the various areas of coverage under the health-care regulations with very specific requirements. Furthermore, on slide 11, you'll see that the written measures and procedures that are required under section 9(1) of the regulations are listed; however, the employer is not limited to the list of items in slide 11. Section 9(1) of the health-care regulations states that the employer shall reduce all measures and procedures to protect workers to writing, and they may deal with, but are not limited to, the list on side number 11.

In doing so, the employer must consult with the joint health and safety committee on all measures and procedures for items such as workplace violence, patient handling, and lifting, and any other hazards in the workplace that are not included here. Once again, this is a very powerful requirement within the health-care regulations that you should be familiar with.

Other regulations that may apply to the health-care sector include the WHMIS regulation (as mentioned before), the X-ray regulation, regulation regarding exposure to biological and chemical agents, various designated substance regulations, asbestos on construction, and window-cleaning regulations.

There are workplaces in the health-care sector that don't fall under the specific workplace regulation. This would include home-care services and various clinics. Ministry of Labour inspectors enforce the general duty requirements under the Occupational Health and Safety Act in these workplaces.

The key hazards that we target generally in this sector include the top non-injury types based on WSIB and Ministry of Labour data. They include, as you hopefully know, sprains and strains due to over-exertion, slips, trips and falls, communicable diseases, hazardous substances, workers being struck be objects and patient violence. We utilize WSIB injury and illness claims data as well as our own Ministry of Labour data including reported injuries and fatalities, previous orders we might have issued associated with our inspections or investigations, and any complaints and work refusals that have been notified to the Ministry of Labour.

The approach that we take with respect to enforcement is multi-disciplinary. We have a team of health and safety inspectors in each of our four regions. As well, we have technical experts-ergonomists, hygienists, medical consultants, engineers and radiation protection officers-to provide assistance to our health and safety inspectors. Our Ministry of Labour inspectors are provided with recommended field delivery strategies on an annual basis for identification of key hazards and emerging issues.

We use risk-based criteria to identify the individual workplaces that are to be inspected, and the WSIB data used identifies a high injury cost to workplaces to the sector, including small business firms. As with all sectors, the internal responsibility system is generally enforced with orders, particularly in workplaces with fewer health and safety resources and with vulnerable workers.

Within the last week, the Minister of Labour has announced a minister's action group for the health-care sector. This action group will include employers, unions, health and safety system partners, and other experts. It will identify gaps in existing prevention strategies and it will also identify best practices, programs, policies and standards to reduce injuries and illnesses.

The Minister of Labour feels that, with almost 2,000 nurses currently on long-term disability, injury rates that are approximately 150 times the provincial average, there is definitely a need to work together to identify some of the immediate steps to achieve measurable improvements to health and safety in this sector. This group will be asked to examine the challenges and seek new and innovative ways to make health-care workers safer and healthier.

If you're interested in finding out more about this action group, there is information on our Ministry of Labour website, and I encourage you to have a read, and if you have any questions, feel free to call me. Thank you.

I'd like to now turn the call over to Dr. Genesove.

Dr. Leon Genesove, Ontario Ministry of Labour, Provincial Physician: Thank you, Audrey.

In the proactive inspection program in the health-care sector, this program started in December 2003, and the Ministry of Labour began with inspections of 11 acute-care hospitals in the greater Toronto area. This program is being rolled out throughout the entire province with the goal of visiting all Ontario acute-care facilities during 2004. Once that's achieved, we'll be moving on to long-term care facilities also.

There are a number of items of interest in the proactive inspection program. The major focus is on prevention of illness and injury.

Next slide. I just want to talk briefly about occupational health section controls, some of the legislation that applies, standards and guidelines.

The main legislation, of course, is the Occupational Safety Act which Audrey has outlined for us, and the regulation for health-care residential facilities. There are also a number of other standards and guidelines that we'll be looking at in addition to the regulation for health-care residential facilities. We'll be evaluating health-care facilities and their implementation if appropriate, to the circumstances, to the directed standards published by the Ministry of Health and Long-Term Care.

We're also looking at, in terms of a proactive inspection, the Health Canada infection control guidelines, the two main ones being the Routine Practices and Additional precautions, 1999 and the prevention and control occupation infections document from 2002. These are both excellent documents on infection control and prevention of occupational infections.

Another excellent guideline from the Health Care and Safety Association on many infection controls and on respirator uses in the health-care sector, the documents from Health Care and Safety Association are excellent documents and there's excellent resources there. And I urge everyone to make good use of the professional resources available from the Health Care and Safety Association.

In addition, there are other guidelines from Health Canada on infection control issues, the guidelines from the CDC in the United States, BC and from the World Health Organization that may also be relevant to the issue of infection control and prevention of occupational infection.

In addition, there's another handbook. There's a handbook published by APIC, the association for professionals in infection control and epidemiology, which is also a very useful resource that I refer to.

On the next slide, slide 3, just a general overview of the scope of our health care sector activities and the proactive inspections. The main thing here is that we are looking at first is the joint health and safety committees, we're looking at employer responsibilities, assuming more health and safety in the health-care sector, infection control procedures which of course is the main focus that we're looking at, physical plant issues such as ventilation and general maintenance, and WHMIS: workplace hazardous material information system.

On page 4, the joint health and safety committee, what are we looking for? What are the Ministry of Labour inspectors looking for during the course of their inspections? They'll be checking the structure and functionality of the joint health and safety committee as outlined in section 9 in the Occupational Health and Safety Act, the issues of certification of members according to, again, subsection 9(12), monthly inspections as carried out by the committee. The inspectors will also be looking at the frequency of meetings over the past year, they may be looking at minutes of the joint health and safety committee meetings, and they'll be looking for postings of names or work locations of the joint health and safety committee members as required by the Occupational Health and Safety Act.

Just to let you know, I saw a very nice outline recently of a joint health and safety committee terms of reference in the spring of 2004 this year Safe Angle from Ontario Safety Association for Community and Healthcare. You may want to make reference to that in terms of reference. It's a very good outline.

One of the other issues that has become apparent during these practice inspections is the joint health and safety committee liaising with the hospital infection control committee. On the issue of prevention of occupational infections, it's very clear that the two committees-the joint health and safety committee and the infection control committee-has to be in liaison with each other to ensure that proper infection control measures are implemented to protect worker health and safety.

On slide 5, employer duties, outline several responsibilities the employer has to implement from an administrative standpoint. There has to be a health and safety manual, there has to be policies, written policies and procedures, reporting requirements, and I'll be elaborating a little bit on this as we go along. There has to be details of personal protective equipment to be used in situations, training records. Training is an extremely important issue, and it's very important that all health-care workers be trained in infection control procedures and the other measures and procedures I'll be talking about today, and that the employer carry out this responsibility.

There are requirements for infection control measures and protocols that are outlined in the regulation for health-care residential facilities, there are occupational and safety references required. In terms of the physical plant, for example, records of inspections of the mechanical ventilation system and maintenance of equipment. Again, there's requirements for reporting occupational illnesses and critical injury notifications.

There are requirements for written measures and procedures that our inspectors would be looking for, and this is just one of the programs for legal compliance. Sharps injury prevention, work immunization, respiratory protection, and possibly some disease-specific guidelines-for example, for influenza and tuberculosis - those are some of the issues that they'll be looking for in the written policies and procedures.

Now, slide 6 touches a little bit on infection control measures and procedures, again from the standpoint of employer obligations. But as I mentioned, there has to be worker education and training in place, and I think that's one of the cornerstones of worker protection. So it's to provide them with education and training, personal protective equipment, as I mentioned, whatever's required to protect them, whether it be respirators, gloves, gowns, et cetera, whatever is appropriate to the situation. And again, as I mentioned, the specific physical plant requirements, whether it be isolation in negative pressure rooms, whether the requirement is to inspect the mechanical ventilation system.

In section 9 of the regulations for health care and residential facilities, there's a list of measures and procedures which the employers discuss with the joint health and safety committee and implement, write down those measures and implement them when they're appropriate. These are the measures and procedures. I've mentioned some of them already, but they include and are not limited to the following: safe work practices, proper hygiene practices, use of PPE, control of infections, immunization against infectious disease, use of appropriate antiseptics, disinfectants and decontaminants against specific issues hazards of biological, chemical and physical agents in the workplace, including the hazards of infections. There have to be measures and procedures to protect workers from exposure to biological, chemical or physical agents that may be hazardous to the reproductive capacity of a worker or to the pregnancy of a worker or to the nursing of a child of the worker. It's all specified in the regulations.

Again, the list going to the use, wearing and care of personal protective equipment and its limitations; and the handling, cleaning, disposal of soiled linen, sharp objects and waste through the use of safe procedures, and I'm going to say this further on, the engineered devices to prevent needle stick injuries.

Now, all these written measures and procedures have to be reviewed at least once a year and revised as necessary in the light of current knowledge and practice in the area of health safety. The review and revision of these written measures and procedures has to be done more frequently than annually if there is a change in circumstances. And then the employer is required to develop and establish and revise training and educational programs in the health and safety measure and procedures for workers that are relevant to the workers' work.

Okay. Going on to slide number 7, a little bit about notification requirements for occupational procedures and illnesses. The notification requirements are listed in these regulations for health care and residential facilities section 5(5): if a worker does develop an occupational illness as a result of the workplace, the notification requirement in terms of the information that has to be provided and who that has to be provided to is listed in the regulations, including the details that have to be listed, with the name and address of the employer and the nature of the occupational illness, the description of the occupational illness, and a list of other items, and then, again, the steps taken to prevent further illness. So this protection issue is extremely important and one of the items the inspectors look at when they receive such notifications.

Slide 8 is WHMIS workplace hazardous material information systems. I'll just briefly discuss that. It involves having written measures and procedures and labelling requirements for biologic, chemical and physical agents. There's requirements for labelling of biologic waste containers, there has to be an annual review in consultation with the joint health and safety committee, and there should be other, instruction and training in WHMIS.

One of the things the inspectors will be looking for is for all the procedure manuals for the particular facility essentially that deals with WHMIS controls. They'll be looking for labelling of containers that are required for physical biologic hazards, ensuring that these labels are fixed to the containers. If there's any new chemicals from a chemical standpoint that are used in health care facilities, these should be understood and procedures specifically in place for that, an annual review by the health and safety committee, and again order, education and training.

Moving on to slide 9, a little bit more on instruction and control measures. The measures that you should be looking for again relate to sections 8 and 9 in the regulations for health care and residential facilities: infection control policies and procedures for workers' safety. And again if you would like, some of the resources and documents from the Health Care Health and Safety Association would assist with this. We expect these health-care facilities, that when these policies and procedures for infection control are developed, that it be on a risk-based approach.

And this is outlined in the Health Canada documents for 2002 and it discusses in developing and putting into effect policies and procedures for infection control, this should be based on a risk assessment which includes an evaluation of the workplace to identify hazards related to different occupations such as nursing or housekeepers, laundry, lab workers, contractor workers, as well as looking at risk-control measures. So what control measures have been implemented to prevent or manage exposures or infections of the workers?

So, for example, safety engineering control- negative pressure rooms, for example, for isolation. Are there safety engineered medical devices? Are there administrative controls in place (meaning policies and procedures) to support these engineering controls and work practices and use of personal protective equipment where required? Are proper workplace practices in place to reduce risk of exposure? Are there immunizations in place? Are there gloves and gowns and respirators or masks available? Are splash shields or eye goggles available to the appropriate situation?

Is there appropriate education programming? People, workers need training and educational programs with respect to the measures and procedures that are necessary for infection control, and it has to be relevant to the work.

And again, the last part of this approach that Health Canada outlined is the evaluation: there has to be a review of the measures and procedures and improvements or changes if necessary, depending on the outcome of the implementation.

The other items I've listed on the slide, education I've mentioned, monitoring and follow-up for worker implementation of measures (that's part of the evaluation process), and the evaluation of the physical plant, including the general mechanical ventilation system and facility maintenance schedules. So when a Ministry of Labour inspector comes in, they may be asking to see your maintenance records for mechanical ventilation system to ensure that the proper evaluations have been done. Health-care regulations require inspections every six months of the mechanical ventilation system.

There are a number of other issues in infection prevention that are important to implement, and it'll be part of the Ministry of Labour's enforcement activity, and this includes the prevention of needle stick injuries, the use of safety engineered medical devices. Again, the inspectors will be looking at appropriate personal protective equipment as well as the worker instruction and training in the use of personal protective equipment, they'll be looking at measures that are implemented to ensure the proper fit and use and maintenance of personal protection equipment. Again, that's all required in the regulations for health-care and residential facilities. In section 10, it outlines requirements for personal protective equipment. And there are other issues in terms of hygiene facility, other equipment used in the hospital and handling of waste, and various other procedures.

A little bit more on needle stick injuries in terms of needle stick injury prevention. This is on slide 10. One of the things we're looking at is the evaluation of risk in your particular facility. Now, there are a number of high-risk devices, medical devices identified by Health Canada, and you may want to look in Health Canada's recent report, it's a communicable disease report of December the 15th, 2003, on blood-borne pathogens, and they have the list of higher risk medical devices, and these are some of the things our inspectors may be looking at when they come into your facility.

Again, these are things that are very important in your facility for the employer, for the joint health and safety committee to review the use of these devices, but there are safety engineered medical devices available: for phlebotomy needles, for hypodermic needles, for intravenous catheter needles, for wing needles, and, generally speaking, we would expect that the use of these devices would be evaluated in your facility and implemented as appropriate.

This additional information, safety engineered medical devices. If you need additional information from the Ontario Safety Association for Community and Healthcare, call your local consultant for further advice. They have some excellent material also, and some of the Health Canada guidelines are available to help you with that.

Just briefly in terms of interim results, from our inspection activity, as I mentioned it began in December, so what I call phase one of our December visits to health-care facilities, Ministry of Labour inspectors visited 11 acute-care hospitals in the GTA trial area in early and middle December. In those 11 acute-care facilities, there are 200 or so compliance orders issued. It was a very active session and enforcement program that we see here.

Phase two in January, January 2004, early January 2004, nine acute-care hospitals have been visited, and in those nine acute-care hospitals in the GTA area, 65 compliance orders were issued.

These orders in the two phases so far have dealt with issues such as maintenance, training, policies and procedures, WHMIS, notification of occupational disease, joint health and safety committee issues, the measures to procedures that I mentioned in section 8 and 9 of the health care reg, especially the issues surrounding controlled infection and safe work practices and hygiene facilities and the proper use and maintenance of equipment, disposal of hazardous waste in a safe manner, issues surrounding personal protective equipment including training and ensuring that the personal protective equipment has a proper fit as required by section 10.2(b) in the regulations for health-care and residential facilities, orders surrounding the mechanical ventilation systems to ensure that they're inspected every six months and that reports on these inspections be given to the joint health and safety committees, and orders have been issued for safety engineered medical devices in some of the facilities, or to the facilities to perform assessments of the implementation of the engineered medical devices on a risk-assessment basis. And there have been additional orders issued of a more miscellaneous nature, and this is where we're standing right now.

As I say, up until mid-January. These sessions have been continuing in February and March and are continuing right now to acute health-care facilities in the province, following acute health-care facilities in the province, and then moving on to the long-term care facilities.

Thank you very much. Craig, I'll return it to you.

Craig Lawrie: Okay. This concludes the formal part of the presentations today, and at this time we will open it up to questions from the community at large.

Operator: Thank you, Mr. Lawrie. We will now take questions from the telephone lines. If you have any questions, please press *1 on your telephone keypad. If you are using a speaker phone, please lift the handset and then press *1. If at any time you wish to cancel your question, please press the pound sign. Please take note that we will only accept one question per participant. Please press *1 at this time if you have a question. There will be a brief pause while the participants register for questions. Thank you for your patience. (pause) The first question is from Sharon Thompson. Please go ahead.

Sharon Thompson: I had a question about the immunization procedures in the hospital and the relatively poor rates of compliance with influenza immunization. I'm just wondering what if anything you're going to be doing about compliance orders in that regard, because the issue of civil rights of the worker not to have vaccines thrust upon them has been raised. This is an issue not only in terms of employee health and making your employees sick, but it's also a very real issue for the patients who very often contract those illnesses from staff that are carrying it. Thank you.

Dr. Leon Genesove: Okay. That certainly is a question in get periodically, and a difficult one. There's two aspects. In terms of the regulation for health-care and residential facilities, there's a requirement for the employer to have measures and procedures dealing with immunization and inoculation against infectious diseases. So from a staff point of implementation and enforcement, the Ministry of Labour wants to ensure that employers are offering or arranging the appropriate vaccinations, making it available to employees, and providing education and training to the employees in the immunizations that are necessary, and what the risks and benefits are of the immunizations.

From the other standpoint, in terms of the staff vaccinations, this gets a little bit more complex, because there's other players in the game: the public health departments also have the protection of patients. That gets a little bit more complex. So one of the things you have to look at is the surveillance protocols developed by the Ontario Medical Association and the Ontario Hospital Association that are required to be implemented in hospitals, what's appropriate, and there are other issues.

So there are also a few labour relations issues in there which I acknowledge, but they aren't part of the Occupational Safety Act or the regulations for health-care residential facilities.

Basically, the bottom line is, from the standpoint of the Occupational Health and Safety Act, the employer has to make the vaccines available and has to provide education and training to the workers on what vaccines are appropriate to protect their own safety.

Operator: Thank you. The next question is from Charlene Loady from the Ontario Association. Please go ahead.

Charlene Loady: Yes. You spoke about the various phases that you're going through with the focus right now being on-I think you said acute-care hospitals. I represent the long-term care sector and I know you've made reference to "and move on to long-term care." Do you have any sense of when that will be?

Dr. Leon Genesove: Any minute now. Be prepared.

Operator: Thank you. Please press *1 at this time if you have a question. (pause) There are no further questions registered at this time. I would now like to turn the meeting back over to you, Mr. Lawrie.

Craig Lawrie: Okay then. Well, I'd like to thank our speakers for taking the time out of their busy schedules to speak to us today. I'm sure we all agree how valuable it is to get current and up-to-date information from the field. Thank you once again, Audrey and Dr. Genesove.

This concludes our presentation today, but before we end, I'd like to remind you that our next teleconference will take place on June 22nd of this year, and at that time we will be presenting defensive driving and driver safety. Please check our website at www.osach.ca for more details, or contact our head office at 416-250-7444 for further information about that.

Once again, I thank you and I wish you a safe day.

 
  

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