Labor and Employment Law blog

An Employment Law Book That Has Helped Over 100,000 Human Resource Professionals

What Every Business Manager And HR Professional Should Know About Federal Labor And Employment Laws is the title of a written-in-plain-English, employment law human resource guide that explains all the significant federal labor and employment laws that affect employers. Many of the articles in this blog have been taking from this terrific reference. Now in its 7th edition, the book has helped over 100,000 HR professionals and employers, and contains everything you need to know about:

• Employees & Independent Contractors
• Fair Labor Standards Act
• Anti-Discrimination Laws & the EEOC
• Family and Medical Leave Act
• Sexual Harassment in the Workplace
• American with Disabilities Act
• Age Discrimination
• OSHA
• National Labor Relations Act & Union Organizing
• Employee Health & Insurance Laws
• Drug & Alcohol Abuse in the Workplace
• Workplace Investigations
• Workplace Privacy
• Hiring & Termination Procedures
• Guidelines for Limiting Employer Liability
• And Much More...

Each of the 18 chapters focuses on particular aspects of federal labor and employment laws. They includes easy-to-understand explanations as to what the laws are, provide relevant background information as to why and how the laws were created, and offer guidance as to what organizations can do to ensure compliance and develop effective and positive employee-related programs.

You'll find numerous Q & A sections and special callouts that address issues HR managers and supervisors face every day. For example, there are over 40 frequently asked questions (with answers) regarding the Family and Medical Leave Act. Helpful checklists, such as those on hiring, evaluating performance and employee termination, offer road maps as to how to proceed. You'll learn about what you should do, as well as identify "personnel practices to avoid."

This is one outstanding reference that needs to be on the desk of your HR manager. Its price is only $59.95, and it's available from the publisher, WME Books, on its website at www.wmebooks.com.

How To Protect Yourself From The Hidden Dangers of Unpaid Internships

[Excerpts from a special article written by Louis P. DiLorenzo, Esq.]

It's that time of year when employers are swamped with requests from college students for unpaid internships. And for many employers, the benefits of such a relationship are obvious. An internship provides the student with an opportunity for real-life experiences, resume enhancement and a possible "leg up" in the working world. The employer receives the chance to evaluate a new applicant, at no cost.

The legal risks, however, may not be so obvious.

One area of risk is the Fair Labor Standards Act (FLSA) which requires that nonexempt employees receive the minimum wage for all hours worked and one-and -a-half times their regular rate of pay for all hours in ecess of 40 in a workweek. The $64,000 question, however, is whether the unpaid intern is an "employee" within the meaning of this and other federal and state statutes. The U.S. Labor Department has adopted six criteria for evaluating this issue.

1. The internship should be similar to the training given in a vocational school.
2. The training must be primarily for the benefit of the intern, not the employer.
3. The intern must not displace any regular employees, but must work under close supervision.
4. There should be no immediate advantage to the employer.
5. The intern must not be entitled to a job at the completion of the internship.
6. The intern and the employer must understand that the intern shall receive no pay for the training.

If your organization uses unpaid interns, or if you plan on starting an intern program, here are four things you may wish to consider to protect yourself from the internship pitfalls.

• Have an agreement or letter making it clear there will be no pay and no guaranteed job.
• Adopt a policy that sets up strict supervision and assigns a mentor.
• Ensure the primary benefit of the intership is for the student, not the employer. For example, minimize assigning the same duties regular employees perform.
• Arrange for a structured program of internal and, if possible, external instruction in the type of work your organization does.

The determination that an unpaid intern is, in fact, an employee can have impact beyond minimum wage and overtime. A misguided classification can lead to problems involving discrimination laws, worker's compensation, state and federal taxes, benefits and unemployment insurance coverage.

Be careful out there!

[Mr. DiLorenzo has practiced labor and employment law for 30 years and is currently the Co-Chair of the Labor And Employment Law Department for the firm of Bond, Schoeneck & King, PLLC]

Under What Conditions Should You Test For Drugs? Here's Seven Options.

This article is the last in a short series of articles we have written on drug testing in the workplace. If you have not had the opportunity to read the previous articles, here are the titles and links.

1. The Six Key Elements Of A Drug Abuse Prevention Program
2. Drug Testing In The Workplace...Six Reasons Why Companies Do It.
3. Drug Testing In The Workplace - Six Reasons Why Companies Don't Do It

When an employer decides to include drug testing in its drug abuse prevention program, it must decide under what conditions to test. Here are seven options employers may want to consider:

• Job applicant testing: The drug screening of job applicants prior to employment is the most common employer drug testing practice, has the greatest deterrent effect, an is the most cost-effective. Keeping drug users out of the workforce helps avoid costly problems involving safety, productivity and absenteeism. Bill Reynolds has written a very informative article about how pre-employment drug testing can positively affect your worker's compensation cost. It's worth a read.
• The testing of employees in safety-conscious jobs: Jobs involving the safety, health, and security of the employee, his or her co-workers, and the public, represent a compelling public interest and may warrant special employer precautions to assure that its workforce is "drug-free."
• Incident-driven drug testing: Specific incidents may trigger employer suspicions of drug abuse and warrent drug testing. Examples include a medical emergency that appears to be drug-related, the observance of drugs or drug paraphernalia at an employee's desk or work station, or other evidence that an employee's behavior is influenced by drugs.
• Post-accident investigation drug-testing: On-the-job accidents that may involve human error often trigger drug testing of those employees involved.
• Retesting of employees during and after rehabilitation: Employees who are or have participated in drug rehabilitation programs, are commonly and appropriately retested for the presence of drugs in their systems. Without random testing, successful rehabilitation may be difficult to assure.
• Periodic drug testing with advance notice: Scheduled in advance, usually as part of an annual employee physical, and uniformly administered, periodic testing is common for jobs involving stress, requiring physical endurance, or involving senior-level decision making.
• Random, unannounced drug tests: Random testing without pre-notification is most likely to identify drug users. However, it also is most likely to create morale problems and trigger union grievances or employee legal claims. Employers should proceed with caution before selecting this option.

If you are interested in obtaining more information about businesses and organizations that offer drug testing services, this google link offers a sizeable directory, and may be a good place to start your search.

Although not part of our drug testing series, in future articles we will present information and ideas regarding drug testing and the American with Disabilities Act, the Drug-Free Workplace Act and some special regulations involving the transportation industry

Labor And Employment Law Blog Publishes 100th Article

This past Tuesday, laborandemploymentlawblog.com published its 100th article on HR employment law issues. Our goals since day one have been (1) to provide relevant information and content about the many federal labor and employment laws that affect businesses and organizations, and (2) to offer suggestions that employers and HR professionals might wish to consider when creating or evaluating employee-related programs and policies or when faced with an employee issue. We hope that we are meeting these goals in the eyes of our readers. Your comments are always invited.

To celebrate the occasion, and to make it easy for anyone to find a particular article he or she might be interested in, below is a complete list of titles (with links) organized by employment law category. By the way, (here comes a brief commercial) the 100th article is about an excellent guidebook that should be in every HR professional's library. Many of the articles written in this blog have been based on content from the book. Check it out.

Here's our list of 100:

American with Disabilities Act

1. EEOC Guidelines On Psychiatric Or Emotional Illness
2. Frequently Asked Questions About Reasonable Accommodation
3. ADA Compliance - Six Tips On How To Respond To A Request 
4. Eight Factors In Determining When A Test Is A Medical Examination 
5. Medical Confidentiality And The ADA
6. The ADA and Disability-Related Employment Questions

Current Affairs

7. Pension Protection Act of 2006
8. State Web Links To Employment Laws
9. Seven Reasons Why You Need A Quick Reference Employment Law Guidebook
10. The U.S. Department of Labor Offers Online Employment Law Guidance To Employers
11. HRGuru - A New Monster HR Website Gets High Marks

Drugs And Alcohol in the Workplace

12. Drug Abuse And Drug Testing In The Workplace
13. Setting Up An Alcohol Abuse Prevention Program
14. The Six Key Elements Of A Drug Abuse Prevention Program
15. Drug Testing In The Workplace...Six Reasons Why Companies Do It.
16. Drug Testing In The Workplace - Six Reasons Why Companies Don't Do It

EEO – Discrimination and Retaliation

17. What Is The Age Discrimination in Employment Act?
18. Some Things To be Aware Of - If You Have Older Workers
19. Frequently Asked Questions Relating To Pregnant Employee Rights
20. Age Discrimination - Two Trouble Spots For Employers
21. Beware Of Stray Remarks
22. Blogs Abuzz About Burlington Northern

EEO – Sexual Harassment

23. Six Elements Of An Anti-Harassment Policy
24. Sexual Harassment - Do You Have A Policy And Prevention Program?
25. Sexual Harassment - Guidelines For Creating An Effective Complaint Procedure
26. Ten Guidelines For Conducting A Sexual Harassment Investigation
27. Preventing Sexual Harassment - Ten Steps You Can Take
28. Responding To A Sexual Harassment Complaint - Guidelines For Employers
29. Sexual Harassment - 15 Questions Employers Should Ask The Complainant
30. Sexual Harassment - Questions Employers Should Ask Alleged Harasser And Third Parties
31. Reducing Employer Liability
32. Workplace Harassment - Preventative And Corrective Actions Employers Should Consider

Employees versus Independent Contractors

33. Is Your New Hire An Employee Or An Independent Contractor?
34. The IRS Common Law Test
35. Employing Independent Contractors - 10 Guidelines For Avoiding Problems

Fair Labor Standards Act and Minimum Wage

36. Federal Law May Require Companies To Pay Minimum Wage/Overtime To Interns
37. Minimum Wage - Which Direction Is It Going?
38. Fair Labor Standards Act - It's Purpose and Coverage
39. When Are Trainees Considered Employees? - Six Rules To Follow
40. Child Labor - Some Things You Should Know
41. FSLA Guidelines - Defining The "Workweek" And Minimum Wage Compliance
42. Do You Need To Pay Overtime To Commission-Paid Employees?

Family and Medical Leave Act

43. Family Medical Leave - Take The Quiz
44. FMLA - The Most Complicated Employment Law Of Them All
45. FMLA - Ten Questions You Should Know The Answers To
46. FMLA Leave - Is It Paid Or Unpaid? It Depends.
47. Rules About Informing Employees of Their FMLA Rights
48. Employee Rights Upon Returning To Work From FMLA Leave
49. FMLA - Defining A "Serious Health Condition"

Health and Insurance Laws

50. Rising Health Care Costs For Employers
51. HIPAA - How Can An Employer Ensure It Is In Compliance?
52. Workers' Compensation - 10 Suggestions For Controlling Cost
53. An Employer Health Care Cost Savings Checklist
54. Employee Wellness Programs Can Reduce Employer Healthcare Costs And Liability

Employee Handbooks and Policies

55. Do You Have A Telecommuting Policy?
56. Employment Laws Mistake # 1 - Equal Employment Opportunity Policy
57. Workplace Privacy - Do Your Employees Know What Your Policies Are?
58. Employment Law Mistake #9 - The Employee Handbook
59. Employee Handbooks And Policy Manuals - Should They Be Combined?

Employee Hiring, Performance Evaluations and Terminations

60. Radio Shack - An Example In How Not To Terminate
61. What Is A "Just Cause" Checklist
62. Tell me about your former employee? Should I hire her?
63. Hiring Procedures - Seven Personnel Practices To Avoid
64. How To Handle An Employee Termination
65. Employment Laws Mistake #5 - "At Will" Employees
66. Employment Laws Mistake # 8 - Terminating Employees
67. Terminating An Employee - Use This Handy Checklist
68. Guidelines For Conducting Employee Termination Meetings
69. Pre-Employment Inquiries - Things Employers Should Know
70. Checklist For Hiring Employees
71. The ADA and Disability-Related Employment Questions
72. "Employment-at-Will" - What Employers Should Know
73. How Well Do You Communicate With Your Employees?
74. Guidelines For Orienting New Employees
75. Performance Reviews - Is It A Plus Or A Minus
76. A Performance Review 5-Point Checklist
77. Employment Laws Mistake #3 - Addressing Poor Employee Performance
78. Employment Laws Mistake #4 - Employee Discipline

Immigration Laws

79. Some Facts About Immigration Laws
80. Frequently Asked Questions About Immigration Laws

NLRA and Union Organizing

81. Is Your Employee Really A Supervisor?
82. Seven Reasons That Can Trigger Union Organizing

OSHA Regulations

83. It's Time To Review Your Self-Inspection OSHA Checklist - Do You Have One?
84. OSHA - Guidelines for Recordkeeping and Reporting

Whistleblower Issues

85. Whistleblowers And The Sarbanes-Oxley Act
86. How To Avoid Whistleblower Retaliation Claims - Part 1
87. How To Avoid Whistleblower Retaliation Claims - Part 2

Workplace Issues

88. Employment Laws - The 10 Most Common Mistakes Made By Employers
89. Veteran Rights When Returning To Work - What Employers Need To Consider
90. Reducing Employer Liability
91. Employment Laws Mistake #2 - Electronics In The Workplace
92. Alternative Dispute Resolution - Eight Steps To Setting Up A Program
93. Conducting A Proper Workplace Investigation - 13 Factors To Consider
94. Beware Of Stray Remarks
95. Employment Laws Mistake #7 - Documenting Workplace Issues.
96. E-mail And Voice Mail - Some Employer Liability Issues To Consider And Guidelines To Follow
97. Guidelines For Limiting Employer Liability - 12 Actions Employers Should Take.
98. Critical Employer Mistakes Made By Supervisors
99. How Good Is Your Employee Training Program - Do You Even Have One?

Human Resource Employment Law Reference Guide

100 . An Employment Law Book That Has Helped Over 100,000 Human   Resource Professionals

Next week, we will start in our next 100.

FMLA - Defining A "Serious Health Condition"

One of the four circumstances under which an employer is required to grant family or medical leave is a "serious health condition" - that is, a health condition that makes the employee unable to perform the functions of his or her job. Such a condition can be further defined as an illness, injury, impairment, or physical or mental condition that involves either inpatient care (i.e. an overnight stay) in a medical care facility or continuing treatment of the serious health condition by a health care provider.

Continuing treatment by a health care provider can include any one or more of the following five situations:

1. A period of incapacity for more than three consecutive days, and any subsequent treatment or period of incapacity relating to the same condition that involves (a) two or more treatments by a health care provider, or (b) one treatment by a health care provider with a continuing regimen of treatments under the supervision of that provider.
2. Any period of incapacity due to pregnancy or for prenatal care.
3. A period of incapacity on account of a chronic serious health condition that (a) requires periodic visits for treatment by a health care provider, (b) continues over an extended period of time, or (c) may cause episodic rather than a continuing period of incapacity (i.e. asthma, diabetes, epilepsy, etc.).
4. A period of incapacity that is permanent or long term due to a condition for which treatment may not be effective (i.e. Alzheimer's, a severe stroke, or the terminal stages of a disease).
5. Any period of absense to receive multiple treatments including restorative surgery that is likely to result in a period of incapacity of more than three consecutive calendar days (i.e. chemotherapy, radiation, etc.).

In doing an Internet search, we found a great website that gives numerous examples of serious health conditions. Check out the St Louis County (Missouri) website. It has a lot of useful information.

During our research, we also discovered Carl Bosland's FMLA blog. Carl's articles cover a variety of sub-topics, all under the FMLA umbrella. You'll find his link, "FMLA Blog", has been added to our "Blogs & Sites to Watch."

How Good Is Your Employee Training Program - Do You Even Have One?

If the forecasts are correct, employers are facing a shortage of well-educated and well-trained workers to meet the nation's economic needs. There is an enormous challenge to employers to improve the nation's job-related learning system. If you are not spending 2 to 4 percent of payroll on training, you are probably making an insufficient commitment.

In a study conducted by the American Society for Training and Development (ASTD) and the Department of Labor, employers were urged to take the following steps:

1. Create an institutional environment that encourages the proactive use of human resource development as a tool to encourage efficiencies, quality improvements, new applications, and innovations.
2. Use selection and appraisal procedures that assess job-related training needs.
3. Use reward systems that provide compensation based on skill.
4. Build training-related, performance-based requirements into management and supervisory job descriptions and work objectives.
5. Treat training as an investment with the same payoff a R&D.
6. Work together, sharing development and delivery costs of training materials, technologies, and basic research on applied learning among adults.

An employee training program offers benefits to employers, because those who are trained end up with productivity increases more than twice as high as the wage increases that come with training. Unfortunately, the vast majority of American employees never receive formal training that is provided and paid for by their employers.

Now may be a good time to evaluate how good your employee training program is. Or, if you don't have one, now is probably a good time to start.

Drug Testing In The Workplace - Six Reasons Why Companies Don't Do It

Earlier this week, we presented six reasons why companies do drug testing in the workplace. Today, we offer an opposing viewpoint. We suggest that you read both articles, should you be considering a drug testing program.

Although there are very good reasons to incorporate drug testing in a drug abuse prevention program, there are also good reasons to not include drug testing. Here are six reasons why companies and organizations have decided not to implement a drug testing program:

1. To avoid morale problems: Drug testing can upset even those employees most opposed to illegal drug use. Unless handled fairly and with full explanations, drug testing can create resentment in the workforce.
2. To avoid union grievances or union organizing: Most unions actively oppose drug testing in the workplace. An attempt to implement drug testing may defeat or detract from other collective bargaining goals. In a non-union shop, it can provide union organizers with a major issue to be used against the employer.
3. To avoid an "overreaction:" Based on a thorough analysis, employers may conclude that the best response is no response, or that a prevention program without testing is sufficient.
4. To avoid additional expenses: Drug testing, if done correctly, is expensive. Rehabilitation is also. Some companies decide that a full, comprehensive drug abuse prevention program that includes drug testing is non-affordable.
5. To avoid legal claims: Some employers see the implementation of a drug testing program as an invitation to legal challenges, and avoid testing to avoid litigation. While it is agreed that an employer must be aware of the laws covering drug abuse, if drug testing is clearly needed, the bigger question is should an employer avoid it merely to minimize the risk of litigation?
6. To observe privacy interests of employees: An employer may feel that the legitimate individual rights and privacy interests of employees outweigh a company or societal interest in preventing drug abuse.

If you are interested in reading more about drug testing in the workplace, we suggest you read an excellent article by Jonathan Cracknell.

In a final, follow-up article to be written sometime in the future, we will present to any employer considering drug testing, some options as to when to conduct such tests.

Drug Testing In The Workplace...Six Reasons Why Companies Do It.

In an article published on March 24, we presented "The Six Key Elements of a Drug Abuse Prevention Program." One of these elements is drug testing. As a follow-up to that article, we are going to post two articles this week on whether or not to implement a drug testing program. The first article will present six reasons why companies implement drug testing programs. The second article will present six reasons why companies don't.

Here then, are six reasons why companies implement drug testing programs:

1. To help the community: By addressing the drug abuse problem effectively, employers "do their part" in addressing the needs of the community. All segments of society must fight the war on drugs.
2. To maintain productivity: At this time of heightened national concern about the competitiveness of American business, employers cannot afford to carry significant numbers of employees who are one-third less productive because they have drugs in their systems.
3. To protect employees and customers: Workers on drugs present a clear and present danger to themselves, co-workers, and members of the public. Employers cannot and should not allow the safety and health of others to be jeopardized by drug abusers in the workplace.
4. To contain health care costs: Drug users are not only more likely to injure others on the job, they also incure four times the medical expenses of the average employee. Some state workers' compensation laws deny overage if the injury resulted from the use of illicit drugs or alcohol. Taking advantage of these statutes is virtually impossible without testing.
5. To deter drug use: If drug users know a company makes "being drug-free" a condition of employment, they are more likely to refrain from illegal drug use or to apply for employment elsewhere.
6. To rehabilitate employees: To the extent that drug testing uncovers drug dependency problems and forces people to face up to them, drug testing can be constructive, humane and even life-saving.

Whether or not to establish a drug testing program is an important decision that should not be made lightly. Hopefully, the above reasons as to why and our follow-up article as to why not, will be helpful.

Do You Need To Pay Overtime To Commission-Paid Employees?

There is a special provision 7(i) of the Fair Labor Standards Act (FLSA) that allows an employee of a "retail or service establishment" paid on a commission basis or whose compensation includes commissions, to be exempt from the payment of overtime providing that two conditions are met.

1. The regular rate of pay of this employee must be more than one and one-half times the prevailing minimum wage, and
2. More than half of the compensation for a "representative period" (not less than one month) must represent commissions on goods or services.

The term "retail or service establishment" means that a business must engage in the selling of goods or services and 75 percent of its sales of goods or services must be recognized as traditionally in a "retail" concept. Further, not over 25 percent of its sales of goods or services may be for resale. The purpose of this exemption was to relieve a retail employer from the obligation of paying overtime compensation ro employees who typically sell "big ticket" items, such as home furnishings, floor covering, and major applicances.

The "representative period" to test an employee's compensation should be of sufficient length to reflect, fairly, as many factors as possible. The period chosen should be long enough to stabilize the measure of the balance between the portions of the employee's compensation that respectively represents commissions and other earnings (bonuses and contest prizes) against purely seasonal or plainly temporary changes.

It is a good policy for retail and service employers to have a written agreement with commission salespersons acknowledging that the compensation plan is based upon Section 7(i) of the FLSA and, therefore, no overtime will be paid. Such an agreement should at least contain these elements:

• definition of the pay period (i.e. calendar month),
• the pay date for each pay period,
• the hourly rate for every hour worked (may not be less than one and one half times the prevailing minimum wage),
• definition of the representative period, and statement of the basis of the Section 7(i) exemption from the overtime provisions, and
• the signature and date of both parties.

FSLA Guidelines - Defining The "Workweek" And Minimum Wage Compliance

Here are some FSLA guidelines regarding what constitutes a "workweek" and minimum wage compliance that all employers should be aware of.

The workweek (i.e. seven consecutive, regular, recurring, 24-hour periods, totaling 168 hours) is the unit of time used for determining minimum wage compliance. The computation and recording of hours worked should be done on a workweek basis, and the employee must be paid, free and clear, compensation equal to at least the minimum wage for each hour worked in the workweek.

A workweek may begin on any day of the week and any hour of the day established by the employer. As long as the average hourly earnings for non-overtime hours in each workweek equal the minimum wage, the requirement is considered satisfied for that week. Average hourly earnings above the minimum in one workweek may not be used to offset earnings below the minimum wage in another workweek.

An employer can change the payday of its employees so long as the change is intended to be permanent, is done for legitimate business purposes, does not evade minimum wage and overtime requirements, and does not cause an unreasonable delay in payment of wages.

Specific to minimum wage compliance, here are four typical wage computations in which the minimum wage payment is the issue:

1. In the case of an employee hired on an hourly rate basis, it is required that the rate at least equal the statutory miminum.
2. In the case of a commission employee (i.e. commissions are the sole basis of compensation), the individual's earnings must be at least equal to the miminum wage rate for each of the hours worked, exclusive of overtime.
3. In the case of an employee who is paid an hourly rate for a portion of the workweek and a commission for the balance, earnings at the hourly rate which exceed the minimum may not be applied to make up differences in the commission earnings during the other part of the week.
4. In the case of a piece-rate worker, earnings must equal at least the legal hourly minimum over the course of the workweek.

For more information about the the employment workweek, minimum wage compliance and exempt/non-exempt employees, we suggest you check out the Department of Labor's FLSA webpage.

Conducting A Proper Workplace Investigation - 13 Factors To Consider

Employers are often faced with the very difficult task of determining what actually occurred when one or more employees engage in possible workplace misconduct. While conducting workplace investigations is not a core activity for most employers, today's decision makers, for many reasons including media exposure to sophisticated investigation techniques, expect a competent, thorough and unbiased investigation.

There are inherent competing interests whenever a workplace investigation occurs. There is a need to obtain the necessary factual information in order to verify or dismiss the allegations. The competing interest is protecting and respecting employee privacy and other rights. There is a need for a thorough examination of the facts and circumstances and a competing need for immediate action and avoidance of a determination that the conduct has been condoned. There is the need for appropriate corrective or remedial action. This need raises just cause and due process concerns.

Achieving the objectives of an investigation and avoiding additional liability requires careful planning and skillful execution of the plan. To help you in developing such a plan, the following 13 characteristics of a proper workplace investigation offer some factors you should consider.

1. Selection of an appropriate investigator
2. Promptness
3. Open-mindedness
4. Protection of participants from retaliation or reprisals
5. Progression from open-ended questions to covering all of the specifics
6. Thoroughness (all parties and potential witnesses are interviewed and all relevent work records an other documents are reviewed)
7. Accuracy
8. Minimal intrusiveness
9. Maximum confidentiality
10. Follow-up with the complainant
11. Documentation (keeping in mind the possibility of discovery in a future lawsuit)
12. A conclusion
13. Remedial action if appropriate

If you're interested in reading more about conducting proper workplace investigations, virginialaborlaw.com has a rather lengthy article on the subject, but contains a lot of useful information.