MEMPHIS, Tenn. — Fannie Stanberry had been on the job for two months as a package handler at FedEx Express’ massive World Hub when, toward the end of her overnight shift, packages started to fall from a huge shipping container that rolled past her.
As Stanberry, then 61, bent to pick up the packages, she fell and became trapped between the catwalk she’d been standing on and the wheeled platform carrying the shipping container, also known as a dolly. “I thought I was a goner,” Stanberry said. She broke eight ribs and her left arm and lacerated her liver, she said. “I had to learn how to walk over again.”
FedEx, which is headquartered in Memphis, reported the Nov. 22, 2016, incident to the Tennessee Occupational Safety and Health Administration, the agency charged with protecting workers. TOSHA asked the shipping giant to investigate itself and suggest corrections, according to state records reviewed by MLK50: Justice Through Journalism and ProPublica and reported here for the first time.
FedEx told TOSHA it would train employees on safe work methods, and the agency declared the company’s response sufficient and closed its case.
Nearly three years later, a strikingly similar incident at the same location claimed the life of Duntate Young, a 23-year-old temporary worker who’d been on the job just shy of a month. Like Stanberry, his job was to unload packages from shipping containers pulled by motorized tugs.
A worker closed but didn’t lock the vinyl door of a container, a practice that was common. When packages fell against the door, it swung open, hitting Young in the back of the leg. He fell chest first into a metal pole. The church musician, devoted father and rapper was pronounced dead at a nearby hospital.
This time, TOSHA did an on-site investigation. It concluded that FedEx was aware from Stanberry’s injury of the hazards associated with containers and the equipment ferrying them around, but that the company had not done enough to fix the problem.
FedEx, whose annual revenue tops $75 billion, was fined $7,000 in March for failing to provide a workplace “free from recognized hazards that were causing or likely to cause death or serious physical harm to employees.”
The penalty was later reduced to $5,950, after FedEx provided TOSHA with a list of measures it took to prevent similar incidents.
As FedEx faces what is its busiest season ever — delivering holiday packages and long-awaited COVID-19 vaccine doses across the country — experts say what happened to Young and the citation that resulted raise key questions about the company’s safety practices.
Young’s death was “extremely preventable,” said Peter Dooley, a certified industrial hygienist for the National Council for Occupational Safety and Health, which promotes worker safety.
“The fact that this similar circumstance ends up in fatality several years later just shows how inadequate the investigation and follow up was into the previous incident.”
Workers interviewed by MLK50 and ProPublica said that they were pressured to work faster than they felt was safe, and that the training they received, if any, bore little resemblance to what they actually did on the job.
“A lot of stuff they just overlook because everybody is just trying to rush to get through,” said former FedEx employee Aisha Prater, who was packing shipping containers at the hub the night Young was killed.
FedEx’s data shows the rising hazards to its workers: The number of fatalities at FedEx locations increased from seven in its 2017 and 2018 fiscal years to 10 last year, according to its most recent Global Citizenship Report. Its rate of time off taken after nonfatal, traumatic injuries rose 28% in North America between fiscal 2017 and 2019, though the data is not broken out for its World Hub or other locations. That rate is higher than for competitor UPS, whose own global sustainability report says that it has expanded safety mentoring for new employees because research shows most injuries happen in the first year on the job.
Last month, Young’s father, Leanell “Troy” McClenton, filed a wrongful death lawsuit against FedEx and Satco Inc., the manufacturer of the shipping container involved in Young’s death, seeking $3 million in compensatory damages for Young’s two sons.
The lawsuit alleges that FedEx didn’t provide adequate training for temporary workers and allowed workers to engage in dangerous practices “because it valued getting their customers packages delivered on time (and making money) more than it valued the safety of its employees and temporary workers.”
In a statement, FedEx stressed its core commitment to “Safety Above All” and the “hundreds of millions” it spends on safety training each year, as well as the millions spent on equipment and technology to prevent injuries and accidents.
“We fully cooperated with the Tennessee Occupational Safety and Health Administration throughout its investigation, and we have implemented and are continuing to implement measures to further enhance our safety measures and training,” the statement said.
“While we cannot comment about ongoing litigation, we will defend the lawsuit. ... The safety and well-being of our team members is our top priority, and we are committed to providing a safe and secure work environment for our team members.” (Read the full statement here.)
In its Global Citizenship Report, FedEx attributed the rise in lost time to an increase in its North America operations. “We have investigated the root causes of this increase and are working to improve safety performance going forward through new training methods, additional implementation of industry-leading technology, and initiatives to make sure our Safety Above All approach is reflected in every action.”
Satco officials did not respond to multiple requests for comment.
A year after his son’s death, McClenton remembered his son’s insatiable sweet tooth and all the times they’d played music together at church Young on drums, McClenton on guitar and vocals and his wife, Jeanette, on keyboard and vocals. It feels like his son’s life was disposable, he said.
“I don’t think they actually care about them,” said McClenton, a maintenance technician who lives in West Memphis, Arkansas. “The only thing they want is them to move those packages out, and that’s it.”
One in six Memphis metro area workers labor in the logistics industry, and FedEx is the industry’s giant, with 30,000 employees in the region. More than a third of them work at the World Hub, which is next to the Memphis International Airport.
The company’s name marks the FedExForum, where the Memphis Grizzlies play, the FedEx Institute of Technology at the University of Memphis and the World Golf Championship-FedEx St. Jude Invitational.
The city’s growth is inextricably linked to FedEx’s; a $1.5 billion expansion and modernization project underway at the airport will be completed in 2025. FedEx’s World Hub contributes $4.7 billion in wages to the regional economy, according to a 2018 Memphis Business Journal article.
FedEx is also playing a starring role in the nation’s fight against the coronavirus pandemic. FedEx trucks provided the backdrop for a Dec. 3 roundtable discussion about vaccine distribution at the airport, featuring Vice President Mike Pence, who was joined by top FedEx officials. As of Tuesday, the company’s stock had risen 80% this year, exceeding the benchmarks for its peer companies and the transportation sector.
The logistics industry, which plays an essential role in the nation’s economy, can be dangerous. Of the major occupational groups, transportation and material moving has the highest number of fatal work injuries and the second-highest rate of fatal work injuries, according to the Bureau of Labor Statistics’ 2019 data.
Between 2016 and 2019, more than 70 injuries were reported at the site where Stanberry was hurt and Young was fatally injured, according to a log that FedEx turned over to the state as part of its investigation into Young’s death. OSHA requires employers to keep for five years the logs of work-related injuries and illnesses, which include a brief description of what happened.
The physical toll of hazardous jobs falls hardest on workers of color: In the past six years, four workers have died at FedEx Memphis’ hub; all but one was Black. Studies using data from the U.S. census and the Bureau of Labor Statistics show Black workers nationwide are more likely than whites to work in dangerous industries and more likely to be injured on the job.
A 2018 video of FedEx’s World Hub shows a bustling operation, as loaders lift and lower shipping containers on and off planes. Motorized tugs pull cargo containers on dollies across the facility, which spans 880 acres, an area larger than New York’s Central Park.
“As you can see, the process happens very quickly. However, safety guidelines require strict adherence to procedures that ensure safety comes before schedule,” the narrator says as shipping containers like the one involved in Young’s death are loaded onto a plane.
But TOSHA investigation reports and interviews with former workers show that FedEx didn’t enforce its own guidelines.
For many workers, FedEx’s lure is that it pays above minimum wage, no small feat in a state whose share of minimum wage jobs exceeds that of more than 40 states. In Memphis, 1 in 4 Black residents live below the poverty line but fewer than 1 in 10 white residents do.
Stanberry, who like many of the hub employees is Black, was working at the Food Rite in Somerville, Tennessee, about 40 miles east of Memphis, when she met a FedEx recruiter. After two years at the grocery store, Stanberry was still making minimum wage and didn’t have any benefits.
So she quit the store and joined FedEx as a part-time employee, where she’d earn just over $11 an hour and have health insurance. FedEx even provided transportation from the town’s post office parking lot to the World Hub, the company’s largest sort facility in the world.
Stanberry worked in an input area. Massive aluminum shipping containers are unloaded from planes and are loaded onto dollies, which pull them up to one of several lines in the input area.
Stanberry stood on a grated catwalk just inches from the shipping containers and the tug. Her job was to take packages out of the containers and place them on conveyor belts.
“You gotta be fast when you take the packages off,” she said. “I just wasn’t fast like I should have been. ... I did it as fast as I could for somebody my age.”
Most hub employees work overnight shifts, handling packages coming in from around the world and heading back out around the globe.
Stanberry wasn’t the only one to notice that almost all of her co-workers were much younger. One co-worker “asked why they put me on that line because I was a little too old to be sorting the packages,” she recalled.
A key part of the safety protocol is the commands team members issue, such as “standby,” when co-workers need to move away from equipment preparing to move, and “clear,” when they need to stand still, facing the moving equipment.
After 2 a.m. on Nov. 22, 2016, according to the TOSHA report, workers had unloaded the containers when an employee gave the “clear” command, “which means to face forward, back to the belts, and do not move,” a FedEx staffer noted in the report it sent TOSHA. “As the containers moved forward, some freight fell out.”
Stanberry doesn’t remember exactly what happened next, only what she was told when she regained consciousness in the hospital: She bent to pick up the packages, lost her footing and her balance, fell and was trapped under the dolly.
“All I know (is) they said they had to lift the big ole silver thing up off me,” she said, referring to the shipping container.
FedEx reported the incident to TOSHA as required for all workplace incidents that lead to in-patient hospitalizations, loss of limbs or an eye, or death — and the agency responded by letter.
“While ... this letter is not a citation, and we do not intend to conduct an investigation at this time, we ask that you immediately conduct your own investigation into the incident and make any necessary changes to avoid further incidents,” a TOSHA representative wrote to FedEx in a Dec. 1, 2016, letter.
FedEx returned a two-page form and in three sentences described the corrective actions recommended and taken: To review the safety procedures that instructed workers to stand with their backs against the belts when containers are moving and wait until equipment has come to a complete stop to move.
Injured two days before Thanksgiving, Stanberry spent that holiday, as well as Christmas, New Year’s and her birthday in the hospital, followed by weeks of rehab.
In hindsight, she regrets leaving the grocery store and a 35-year career in food service. “I was just with FedEx to get some extra money, because I had to pay rent.”
Stanberry, who received a small settlement from FedEx, is now unemployed and collects Social Security. “My arms and everything was messed up. I can’t even lift nothing heavy no more. ... I can’t go back to work even if I wanted to.”
She acknowledges that workers were trained to stand still when the containers were moving, but when working the line, she followed what her more experienced co-workers did.
Dooley, of the National Council for Occupational Safety and Health, wasn’t surprised that the safety protocols in the training didn’t match what workers did on the job.
“The pace of work and the pressure to be doing so many unloads in a certain amount of time ... challenges any conformity with procedures and rules,” Dooley said.
Between the time of Stanberry’s accident and Young’s death, more than 50 people were injured at the hub seriously enough to require treatment beyond first aid, according to the OSHA logs. The logs include bare-bones descriptions of the incidents and the number of days missed from work. Many more were injured but didn’t require further care.
In one incident, a worker missed 119 days of work after being caught between a container and dolly. In another, an employee missed 46 days of work after being struck by a package.
Caught-under incidents can be deadly. The night before Thanksgiving in 2017, Ellen Gladney, 60, was working on a crew unloading packages from a 777.
Gladney’s job that night was to make sure the loader didn’t make accidental contact with the plane. It was her third day on the team, one worker told TOSHA.
There were no witnesses to the incident, but workers discovered Gladney under a platform attached to the cargo loader’s deck. She was pronounced dead at the scene.
“Ms. Gladney was following procedures,” TOSHA’s compliance officer wrote, but faulted FedEx for failing to correct for the blind spots and failing to have procedures to ensure all crew members were accounted for before the cargo loader started moving.
Standing in front of moving equipment and out of sight of the loader operator is “easily recognized as a serious safety hazard,” the TOSHA report said.
While team leaders typically watch crew members to be sure safety rules are being enforced, a worker told TOSHA, “Employees take short cuts all the time when Managers aren’t around. Doing the right thing is based on your own integrity.”
As in Young’s death, FedEx was fined $7,000. FedEx told TOSHA that it had since amended its aircraft ramp operations manual to make sure the ground crew is out of the loader’s path before it moves.
Young started working at FedEx in mid-October 2019, hired at around $14 an hour by Volt Workforce Solutions, a temporary agency that supplied workers to FedEx.
Staffing agencies regularly supply seasonal workers to FedEx, but the lawsuit alleges that the company doesn’t provide them with enough training.
A Volt manager said she could not comment on the “tragic” incident that killed Young, but she did say FedEx is still a client and that all Volt temporary workers there are supervised by a full-time FedEx employee.
It isn’t unusual for temp workers to receive different or less training than permanent employees for doing the same work, said Dave Desario, director of Temp Worker Justice, an advocacy organization.
Young convinced two childhood friends — Kevin Donnerson and Drekeon Smith to join him, and they too got hired through Volt. All emerging rappers, they planned to save their earnings to record a music video.
They shared a home in suburban Germantown, Tennessee, and on Nov. 12, 2019, Young drove them to work in what Donnerson said was essentially the family car.
Smith and Donnerson worked in a mailroom indoors, but they say Young told them how unsafe it was where he worked, in the courtyard input area described in the TOSHA investigative report as a sprawling, 70,000-square-foot covered space. (A football field is 57,600 square feet.)
Containers are taken off planes, placed on dollies and pulled via a motorized tug to one of four lines in the input area. Each line had room for three tugs pulling containers.
The 10-foot-long, 8-foot-tall container involved in Young’s death was manufactured by Satco, a California-based company. It had the company’s “exclusive curve contour,” a rounded back that fit neatly into cargo planes.
Another plus of this container’s design: speed. “Taking only seconds to open and close, the patented fabric roll-up door assembly has proven to be the most cost effective door assembly ever produced by Satco,” the company says on its website.
On the night he was killed, Young was working on an input line, standing with more than a dozen co-workers on an elevated grated walkway 14 inches off the ground. On the other side of the walkway was a three-tier conveyor belt system.
Handlers such as Young would take the packages from the containers and put them onto one of the belts. Even if containers weren’t fully unloaded, the tug would move forward, witnesses told TOSHA. It was common for containers’ roll-up doors to be left partly open or unlocked, and common for packages to fall out of the containers. Both happened that night, the TOSHA report said.
Toward the end of what would be Young’s last shift, workers were still unloading the last container on line No. 2 when a worker gave the “standby” command, alerting workers to exit the containers because the tug was about to move. Interviews revealed that a worker lowered the last container’s roll-up door but didn’t lock it at the bottom.
An employee made the “clear” sign — forearms crossed at head level — which tells workers to stand with their backs to the conveyor belts. When a worker signaled for the tug operator to pull forward, six workers stood with their backs to the conveyor belts, per the safety protocol. But the team leader, as well as Young and six others walked in the direction the tug was moving.
Young was the worker at the end of the line, and as the tug driver pulled forward, packages in the last container fell out, pushing the partially locked door over the grated walkway and into Young’s leg. He fell into a metal rail on the conveyor belt system, “stood up, took a few steps, and fell back onto the grating,” according to the TOSHA report.
When the shift ended around 3 a.m., Donnerson and Smith waited for Young in their usual meeting spot, the clock out lobby.
When he didn’t show, they went to the car, where their phones were locked inside. (FedEx doesn’t allow workers to have cellphones inside the hub.) They went back to the lobby where they saw some of Young’s co-workers, who were uncharacteristically mute. “Everyone was just looking at us weird,” Donnerson recalled.
Finally, a FedEx human resources employee told them to get in touch with the family.
The family was already at Regional One Health, the area’s only Level 1 trauma unit, by the time Donnerson and Smith found a ride there.
Bresha Mitchell, the mother of Young’s youngest son, knew the news wasn’t good when the hospital moved the family into a private waiting room. “I was just hoping for a miracle,” she said.
When the family went into the hospital room, Young was lying on a gurney.
“They said I couldn’t touch him,” McClenton recalled. “I remember leaning over and whispering in his ear, and I said, ‘Wake up.’”
The hospital gave Young’s car keys to McClenton, as well as his wallet, which McClenton carries every day. It had $8 inside.
Just like in the incident that killed Gladney, TOSHA found that in Young’s death FedEx didn’t have adequate procedures to protect employees from known hazards.
The manufacturer Satco told TOSHA that the door is only secure when it’s rolled up all the way, or closed and locked on the bottom. Workers told TOSHA that they didn’t know whether doors were supposed to be completely open, partially opened or locked when the containers moved with packages inside, the report said. A manager told TOSHA that it was a “judgement (sic) call” by employees whether to close the doors partially or leave them open when the containers moved.
TOSHA interviewed more than a dozen workers in the input area and all said they were trained on line calls and safety procedures, including standing with their backs to the conveyor belt when the containers moved. But many also said that employees move when the containers move and eight said they’d seen the roll-up doors swing over the grated walkway, as the door did in Young’s death.
“Interviews revealed inconsistencies between the written procedures and employee practice,” the report said.
Again, speed may have been a factor: “Employees don’t always stop moving when the freight moves,” one temporary worker told TOSHA during the investigation. “Employees were expected to move as the freight moved in order to get the freight unloaded quicker.”
For about a month or two after the incident, team leaders “made it a necessity to stop moving while the freight moved but now it is back to the way it was before the incident,” the worker said. “The only thing that has changed since the incident is that Temp employees are now given safety vests to wear.”
This worker had a near accident when a partially closed door “caught my pant leg and dragged me up the line,” the worker told the TOSHA compliance officer. “I reported the incident to two Team Leaders but neither one of them reported it to a Manager because I was not injured severely enough to be reported.”
Two managers received warning letters and an employee was fired following the incident that killed Young, according to disciplinary records FedEx provided to TOSHA.
Safety concerns and the pressure to work faster eventually led Prater, 26, to leave the job she started the same month Young did. Her job was to take packages from a conveyor belt and load them into the shipping containers lined up behind her and her co-workers.
Before she started, she watched about four hours of training and safety videos, which would have been sufficient, she said, “if we were actually going to do what the videos showed us how to do.”
“But it seemed like it was a waste, ’cause you get out there and it’s nothing like what they say they want you to do in the video.”
Workers aren’t supposed to throw boxes from the conveyor belt into the containers, but they did, she said, and sometimes co-workers would be struck by flying packages. The protocol for stacking boxes in the containers was routinely ignored.
She narrowly avoided being injured herself, when one night she slipped on ice inside one of the containers she was loading. She managed to catch herself on the container’s wall. She reported the hazard to her supervisor, but it took hours for the icy container to be replaced and in the meantime, packages piled up.
By February, she’d had enough. FedEx wasn’t her first warehouse job, but she vows it will be her last. She’s studying to be a dental assistant. “I do not recommend it for anybody,” she said. “I tell everybody it’s hell out there.”
FedEx did not respond to questions about the experiences of Prater and other employees. Instead its general statement reiterated the company’s concerns about employee safety.
When Stanberry was injured in 2016, TOSHA conducted what’s called a rapid response investigation, but the term is a misnomer, as it doesn’t involve sending an inspector to the site to interview workers.
Instead, TOSHA asked the employer to investigate itself, which FedEx did.
The practice of sending a letter to the employer and then waiting for the employer to write back is “horrible,” said Eric Frumin, health and safety director of Change to Win, a federation of labor unions. He worked as a union labor health and safety expert for more than 40 years and has focused on issues in the South.
“There’s almost no worker involvement in it, and the workers are at the mercy of the relationship between OSHA and the employer.”
But when FedEx reported the fatal incident that killed Young, TOSHA’s investigators collected witness statements, the medical examiner’s report, surveillance videos, police reports, FedEx’s safety procedures, Satco equipment manuals and other documents. Those, along with the investigative report, fill more than 450 pages. Many parts are redacted because they contain witnesses’ names or because FedEx contends the information contains trade secrets, such as a six-page document titled “FedEx Express How to be Safe!”
The fixes that FedEx suggested were all focused on training and safety, but it’s a mistake to focus simply on training and not the equipment too, said Michael Felsen, a retired U.S. Department of Labor attorney during the Obama and Trump administrations.
Employers concerned about safety should also focus on “engineering controls,” such as modifying the equipment, which “do not rely on the workers having to behave in a particular way, but rather they’re protected by virtue of the nature of the process,” said Felsen, who litigated and supervised worker safety cases for OSHA in the New England region. This is particularly true in the case of temporary workers, he said.
While Felsen and other experts placed the majority of the onus for workplace safety on the employer, a top TOSHA official noted that the workers bore some responsibility too.
“Employers train their employees to follow the rules and in some cases, we can’t protect employees from hazards,” said Larry Hunt, TOSHA’s assistant administrator.
“Employees can get complacent. What FedEx needs to do is to ensure that its training system is effective, and it’s not just training, but enforcement of their own rules.”
Given the similarities between the incident that injured Stanberry and the one that killed Young, one safety expert wondered why TOSHA didn’t cite FedEx with a repeat violation, or even a willful violation, which comes with steeper fines and allows for criminal prosecution.
Hunt said he didn’t think TOSHA could have proven that the 2016 and 2019 incidents were similar enough to sustain a willful violation with the information the agency had available.
“We have to prove that the employer had knowledge that these doors weren’t latched and the disregard allowed that situation to continue. I don’t think that they could prove that,” he said. “It’s difficult to determine everything that’s going on when you show up on the site to do the inspections.”
Asked how TOSHA could be confident that FedEx would do now what it said it’d do in 2016 when Stanberry was injured, Hunt said workers can file complaints by mail or online. “We can’t know what’s going on in every place, that’s just not practical,” he said.
Gov. Bill Lee, a Republican, has made no secret of his desire to make the state attractive to businesses.
When FedEx announced an additional financial investment in its Memphis hub modernization project last year, Lee highlighted the company’s role as a major job producer.
The state of Tennessee awarded FedEx $21 million in tax incentives for the project, an amount Lee declared fitting.
“They are a major contributor to what happens in this state,” Lee was quoted in the Commercial Appeal as saying. “So our office, our administration, has regular communication about what they’re doing and what their plans are and what we can do to create a business environment not only for FedEx, but for every company.”
That business-first approach from the state’s highest elected office invariably filters down to workplace safety enforcement and investigations, Felsen said.
“If states are all going to be competing against one another to make sure that they’re as business-friendly as possible, who’s there to protect the workers?
“We want (FedEx) to help save the lives of people by shipping the vaccine. We don’t want their own workers to be sacrificing their lives because of the crunch of having to do that.”
Young’s funeral was held on a gray Saturday at a West Memphis Baptist church. Hundreds of mourners filed by the shiny casket, and when Young’s mother approached for a last look, she collapsed in tears on her son’s chest.
McClenton, himself a Baptist pastor, mustered the strength to preach his son’s eulogy. He vacillated between bold proclamations of his faith in God and wrenching grief and confusion.
“To this day, I don’t know what the hell happened to him,” McClenton said that day. “Ain’t nobody telling me nothing.”
“Right now, what you looking at before you, you looking at an atomic bomb,” he told those gathered. “I’m not an advocate for violence, but I am so angry.”
A year later, McClenton’s grief was still raw, but his rage had been replaced.
“No one at FedEx is wanting to cooperate as far as I’m concerned,” he said. “No sympathy letters, no flowers, no actual concern about the family. I mean we lost a child. We lost a child. ... The anger is gone. The disappointment is there.”
In a statement, FedEx said that a manager offered condolences to the family at the hospital. “We also reached out to the family on multiple occasions afterward to again offer condolences and seek an opportunity to discuss what happened.”
Young’s eldest son turned 6 the day Young died. His youngest son is his namesake, Duntate Young Jr., who is not quite 2 years old.
“These young boys will have to grow up not knowing their father, only looking at pictures and whatever memories they have of him,” McClenton said.
Donnerson and Smith never went back to FedEx. They too say they’re done with warehouse work. After Young’s death, his friends published “Long Live Tate,” an album of songs they’d done together.
Mitchell can see Young’s sense of rhythm in Duntate Jr. and wants to nurture it. “I just make beats with him and I try to play his dad’s music,” Mitchell said. “I think he can recognize his voice because he will just stare at the speaker.”
In an odd coincidence, she worked at FedEx in 2017, the year before she met Young. She was hired through a temp agency to unload shipping containers and remembers feeling unprepared to do the job.
“We didn’t know what to do, we were kind of just looking at each other, asking the people that were working there,” she said. “You learn as you go.”
Mitchell is now studying music recording at the University of Memphis, working a part-time marketing job from home and raising her son, who pulled on his mother’s braids as she did a Zoom interview.
The death benefits mandated through the state worker’s compensation means that the temporary agency that hired Young will pay the mothers of both sons $97 per week until the boys are adults.
But to the people who loved Young, that’s not nearly enough, and it’s not justice.
“Justice to me,” Mitchell said, “would be just restructuring (FedEx’s) whole process or setup as far as safety of the employees.”
