Food Safety Partnership

State: AZ Type: Model Practice Year: 2015

Click here  for exhibits referenced throughout this application Maricopa County is located in the southwestern portion of the United States and comprised of several large cities, including Phoenix, Mesa, Scottsdale, and Glendale.  The population size is 3,817,117 according to the 2010 US Census.  Maricopa is the 4th most populous county in the U.S.  The population is comprised of: White 73.0 %Hispanic or Latino 29.6 %Black or African American 5.0 %Asian 3.5 %Native American 2.1 %Two or more races 1.7 %  Despite the lagging economy in 2009-2010 the number of new food establishments rose 10 percent creating a significant increase in inspection demand. Maricopa County Environmental Services (MCESD) recognized that 12 additional full-time equivalent inspectors would be needed, requiring a $500,000 budget increase. With a strong belief that fewer inspections would not be in the best interest of public health and could be perceived as compromising food safety, finding a new way to improve inspection efficiency without sacrificing quality would be the aim and paramount solution. The goal of MCESD’s regulation is to apply a risk-based inspection process to reduce foodborne illness occurrences. In January 2012, the MCESD executed a new, formal, voluntary program, Cutting Edge, which rewards retail food establishments for enhancing their food safety systems above and beyond regulatory requirements. Our objectives were to encourage those enrolled in the program to take more responsibility for food safety in their establishment.  In order to meet this need, enrollees in the program are required to submit and have the MCESD-approved Standard Operating Procedures (SOP’s) for the top 10 foodborne illness risk factors.  They must include their staff training procedures on these policies.  The third required component is to develop verification procedures to determine if procedures are working and in compliance, as well as corrective actions to correct items when something goes wrong.  To assist operators in meeting the enrollment criteria, MCESD developed materials including templates for standard operating procedures and monitoring control points for all 10 foodborne illness risk factors. These resources were made available on the MCESD website (Exhibit 1) in time for the launch of Cutting Edge to the community, and information was disseminated through news outlets and MCESD’s social media tools (Twitter, Pinterest, and Facebook, and YouTube). MCESD also offers online PowerPoint presentations and a free software program that provides video training about AMC (Active Managerial Control) and a step-by-step guide for developing standard operating procedures. Additionally, every month MCESD conducts a Cutting Edge class for food establishment operators. This class provides operators with personalized assistance and tools necessary to enroll in Cutting Edge. Inspectors in the field are equiped to provide information to operators as needed. Results/Outcomes: After three full years in Cutting Edge (data from  2010-2013), there were 18 percent fewer violations (from Food Risk Illness Factor violation categories) and fewer occurrences of the top ten risk factor violations, as compared with pre-Cutting Edge measures. After joining Cutting Edge, the establishments that had violations achieved an average of 1.544 total Food Risk Illness Factor (FIRF) violations/inspection, a marked improvement as compared with the pre-Cutting Edge average of 1.67 in 2010 (Exhibit 2). Data, in 2013, showed a 70 percent reduction in violations/inspection for full service restaurants (Exhibit 3) participating in Cutting Edge (Exhibit 4). One Hundred percent of establishments participating in Cutting Edge documented “policy, train or verify” as the root cause of the violation, when noncompliance of a risk factor occurred.   The term “policy” refers to a written standard operating procedure that addresses each of the 10 foodborne illness risk factors (what is the hazard, how will the procedure be carried out correctly, how will staff be trained on the procedure, what happens if something in the procedure goes wrong, how will they verify the procedure is being done correctly, and how the manager will take a more active role in not just making an immediate correction to the violation, but develop a long term corrective action).  The term “train” is used to determine how employees in the establishment will be trained on procedures.  The term “verify” is used to demonstrate what procedures the establishment will use to ensure that policies were followed (i.e. temperature logs, etc.)  When violations were documented by inspectors in the field, “Verify” was the most common cause as to why a violation occurred even with food safety systems in place. This shows the establishment that the violation could have been prevented if they had taken the time to verify that their procedures were working properly.  This analysis provides feedback for process improvements to operators’ food safety programs.       
In the past our department has been fortunate enough to have the ability to increase staff size to meet inspection numbers.  However, due to the struggling economy, increasing staff size has not been an option. In order to meet inspection frequency in our food establishments, an analysis showed that we needed 12 additional full time inspectors, as well as a budget increase of $500,000 to cover this requirement. MCESD was faced with the age-old question of how to accomplish more with less and turned the challenge into an opportunity. MCESD has 21,976 food permits that are inspected annually.  These establishments are inspected between 2-4 times per year depending on menus and advanced food preparation.  Enrollment in the Cutting Edge program to date is 1,281 establishments, for a total of approximately 6%.  After the inception of the program, we had an 11% increase per month in 2011, 7.3% increase per month in 2012, 3.4% increase in 2013 per month, and 7.4% increase per month through September 2014. The Centers for Disease Control (CDC) estimates that 1/6 Americans (48 million people) get sick from foodborne illness each year, 128,000 people are hospitalized and 3000 people die each year from foodborne illness.  The top contributing foodborne illness risk factors are:   ·         Improper cooking temperatures ·         Improper cooling of food ·         Improper re-heating of food ·         Improper cold holding of food ·         Improper hot holding of food ·         Improperly washing hands and preventing bare hand contact ·         Preventing cross contamination of food and equipment ·         Improperly cleaning and sanitizing food contact surfaces ·         Unapproved food source ·         Employee health and illness   Armed with the knowledge that the vast majority of illnesses are caused by the above risk factors, along with a strong belief that efficiencies are created when establishments have sound food safety systems in place, the conceptual Cutting Edge plan was created. The critical role of food safety systems further was reinforced by Maricopa County’s adoption of the 2009 U.S. Food and Drug Administration Food Code and the passing of the Food Modernization Act, which emphasize a proactive approach to food safety.      
Food Safety
In 2008, inspectors conducted a baseline survey in accordance with the FDA Retail Food Program Standards of more than 600 food establishments to determine which risk factors occurred most frequently in Maricopa County. The top ten most frequently occurring risk factor violations, identified in the survey, are the focus of the Cutting Edge policies and procedures. Cutting Edge uses a three-pronged approach whereby AMC is established: policy, train, and verify. To be eligible for the program, establishments are first required to develop written safe food handling policies and procedures. Second, food service workers must be trained on these procedures. Third, a system must be in place for verifying that the activities are being performed. Once a food establishment has developed and completed the three steps, they submit their paperwork to MCESD. A Cutting Edge committee member reviews their policies to determine that they meet minimum code requirements and have addressed the training and verification requirements.  Once policies have been approved, they are enrolled into the program.  “Conditions” are then added on the permit in our computer program to notify inspectors that the establishment is now enrolled in the Cutting Edge program.  As a standard practice, MCESD conducts unannounced inspections of every permitted food establishment two to four times a year, based on risk level, to ensure compliance with food code requirements. Establishments that use raw ingredients, prepare food ahead of time, or regularly cook, cool or reheat potentially hazardous foods are considered to be higher risk and are therefore, inspected more often. When food safety violations are discovered during inspections, operators react by correcting the violation. Unfortunately, this reactive approach often fails to attain long-term correction of the violation. Through Cutting Edge, food establishments partner with MCESD to achieve long-term control of the foodborne illness risk factors by incorporating AMC into their day-to-day activities.  A “routine, unannounced” inspection is one where the inspector is evaluating the entire facility, from foodborne illness risk factors, to good retail practices, including inspecting the physical facility.  This is an “inspector-led” inspection.  A “verification visit” is also an unannounced inspection, but this inspection focuses on only the ten foodborne illness risk factors.  This inspection is generally led by the person in charge (PIC) at the establishment (time permitting), so that the PIC can show the inspector what is occurring at the establishment and how they are preventing a violation from occurring (demonstrating active managerial control).  While Cutting Edge participants receive unannounced inspections just like all other permitted establishments, every other inspection is conducted as a “verification visit,” the sole focus of which is to assess the effectiveness of the enhanced food safety management system and AMC for the ten foodborne illness risk factor violations. Is the restaurant implementing its standard operating procedures? Is someone in charge of kitchen operations? Are there imminent health hazards? Are staff properly trained? For example, inspectors observe food service workers regularly taking food temperatures to be sure they are properly trained (train) and that they check their own performance regularly (verify).  This strategy of rotating comprehensive inspections and verification visits results in ongoing monitoring, assessment, and improvement of the food safety management systems.   Cutting Edge also encourages enrollees to take more responsibility/ownership for food safety and even determine what types of verification activities are most effective for their specific operations. Another distinct feature of the verification visit is to continually assess the effectiveness of the food safety systems. Even with food safety systems in place, the opportunity for risk factors to be out of compliance can occur. Now, for the first time, documentation about the “root cause” or “why” risk factors are out of compliance is reported. Operators must assess whether the root cause of the noncompliance was most likely due to the policy, training or verification aspect of their program and inspectors document this on their inspection report. This information provides an opportunity for continual improvement of the operator’s food safety system and reduces the likelihood that the same risk factor will be out of compliance in the future. If, during a verification visit, it is clear an establishment is not managing its food safety risks, the MCESD inspector immediately will shift to a comprehensive routine inspection. Examples of this include:  3 or more risk factors not in compliance, the PIC not recognizing a violation or knowing how to correct a violation without the inspector’s assistance, or operating with an imminent health hazard (i.e. no electricity, no water, sewage flowing). The food establishment will be given an opportunity to correct its deviations from the approved plan at the next visit. However, failing to properly address deviations will result in release from Cutting Edge. Cutting Edge creates efficiencies for both MCESD and its industry partners because establishments take ownership of their individual food safety programs and develop a deeper understanding of the food code and inspection process, while successfully lowering foodborne illness risk factors. Participating operators state that they are “on the same page” as the MCESD inspectors, better prepared for inspections, and empowered to “work together.” A Cutting Edge committee was formed with one manager, several supervisors as well as the training officer to begin developing this program and then having the committee train all of our inspectors on this program.  The committee developed training materials for stakeholders to use (including SOP’s and logs), developed a PowerPoint for both internal training and external training to stakeholders, as well as technical materials.   Free, monthly courses are provided for stakeholders interested in learning about the program.  This course reviews a PowerPoint of the program, provides sample templates for each of the 10 risk factors, sample logs to verify each of the 10 risk factors, as well as suggestions for training staff.  One of the more important internal stakeholders involved in the process are our department Public Information Officer’s (PIO).  They were very involved in reviewing the technical material developed by our Cutting Edge committee.  They help develop the flyer and brochure used for distribution to restaurant operators and assisted with the development of the “Cutting Edge” business card, which is distributed to operators who may have more specific questions regarding the program.  After each participant is approved for the Cutting Edge, our PIO sends out “tweets” as well as updates on Facebook congratulating the new enrollees.  They have been instrumental in contacting the media and setting up interviews with our Cutting Edge committee members to promote the program, as well as working with enrollees to boast of their successes in the program. Our internal Information Technology (IT) department has been involved in creating the internal verification visit inspection report that inspectors utilize in the field when conducting verification visits.  IT has also been involved in updating our department website by developing a new tab and placing all of our materials, tools and resources on this page. In order to receive “Buy-in” from our stakeholders, our committee members actively went into the restaurant community and contacted managers, owners, large chains, corporations, school districts, retail grocery stores, etc. to inform them of the new program.  Committee members spoke at management team meetings for chain establishments and large corporations.  Social media was used to highlight stakeholder successes. The Department has fostered collaboration with stakeholders through the formation of task force committees.  The purpose of these committees is to have open communication and to review the Department’s programs and procedures to ensure they are in line with customer/ stakeholder expectations while still meeting mandated services.  Invitations to participate in the taskforce were sent to permit holders as well as industry association members.  The committee discussions were led by stakeholders while Department staff was available to answer questions and provide any requested information.   Feedback from the stakeholders about the Cutting Edge Program was extremely positive.  Stakeholders identified the benefits of the Cutting Edge Program to food service operators, Department staff, and citizens, and subsequently formed 2 subcommittees/focus groups dedicated to the enhancement of the program.  One subcommittee worked on the development of incentives to food service operators for joining the program. They saw the inherent benefits to documenting and developing internal food safety systems but also understood that some operators may need additional incentives.  Additionally, stakeholders identified that although Department staff had been promoting the Cutting Edge Program to operators, the message was not being effectively received by operators.  This may have been due to the message or the information not being delivered to key decision makers for the food service operation, such as a general manger or owner.  As a result, a second subcommittee was formed and they worked on the development of a marketing plan for the program to promote the benefits of the program to both food service operators as well as citizens. This committee is currently working with Department staff, including our public information officers, to development new messaging/branding for the Cutting Edge Program and researching novel ways to deliver this information, such as social media and smart phone applications. The stakeholder committee recently suggested a new Cutting Edge logo and decided on the content for a business flyer explaining the benefits of the Cutting Edge program to customers (Exhibit #5a). This collaboration displays the strong partnership that the Environmental Services Department has with its stakeholders. The committee has requested a web-based “map” application to highlight those establishments in the Cutting Edge.  This would allow customers to click on a map to see “The Best of the Best” (Exhibit #5b).  GIS analysts have begun designing this type of technology for our department to feature Cutting Edge participants as the main feature. Currently we are determining what platforms and resources we can utilize to promote member participation most effectively.   No capital costs were incurred while developing or implementing Cutting Edge. A total cost of $440 was necessary for a two-year supply of collateral materials used for the program – Cutting Edge window decals, color brochures to advertise the program and business cards to distribute. There were no additional labor or computer costs for the marketing the program and training stakeholders.  
The following process will be outlined in 5 steps to evaluate the differences between inspection results corresponding to Cutting Edge participation and whether their inspections demonstrate significantly better results when compared to non-participating inspections:   1.      Defining the data source and time of the inspection dataset to observe results 2.      Determining permit and inspection types involved 3.      Identifying variables specific to Cutting Edge participation 4.      Defining performance measures used and explaining how the results were analyzed 5.      Explaining the measurable differences between Cutting Edge and non-Cutting Edge inspection results Step 1:  Primary Data Sources Accela is proprietary software used to maintain and manage the Environmental Health Division’s permits and inspections. The inspection data was extracted by the Environmental Health Management Analyst. The Accela Guidesheet and Annual Inspection Summary reports were utilized for this research. The Guidesheet report includes detailed inspection information such as inspection results and description of violations that occurred at the time of inspection. The Guidesheet report primarily functions as a record of individual inspections. The Annual Inspection Summary (AIS) manages individual permits and their inspection status. The AIS summarizes comprehensive inspections for a specific permit and therefore changes as inspections are conducted throughout the annual cycle. Inspections occurring January 2014 through September 2014 were used for observations. Guidesheet reports from Accela were queried by month and then merged into one file. The Cutting Edge status of a permit and the Cutting Edge condition information were queried from the AIS reports and joined by the permit number to the Guidesheet file. The condition information included Cutting Edge issue dates. The Cutting Edge issue date is used to differentiate between Cutting Edge and non-Cutting-Edge inspections. Step 2:  Determining Permits Issued Permits The total number of inspections from the Guidesheet report before any edits is 60,395 inspections (Exhibit 6). This set includes all inspection types including non-food related inspections (Exhibit 7).  Active permits with the permit status of “Issued” will be used for this research. Permits with either “Closed” or “Pending” status will be deleted.   Active permits with “Issue” status comprised of 91% of the observations; 6% were closed, and 3% were pending plan reviews (Exhibit 8). Permit Classifications Food permits are classified by the type of food establishment (i.e. school, hospital, jail, full services, etc.) and how much advanced preparation is required. They are categorized into Class 2’s through Class 5’s, which is determined during plan review. The higher the class #, the more advanced preparation is done.  Permit classes without a class specification were removed (Exhibit 9). There were 21 total “blank” classes found and these were removed from analysis. Of these 21 inspections, the permit statuses were “closed” for 15 inspections. Another five had a “pending” status on their permits.  One “Issued” permit status is a special event inspection. Permit Types Permit types defined as Food Peddler, Mobile Food Unit, Mobile Pet Shop, Push Cart, Seasonal Food Establishment and Temporary Food Service were excluded from the dataset (Exhibit 10). These permit types do not qualify for the Cutting Edge Program. Also permits without the prefix FD were deleted from the inspection dataset (Exhibit 11).  FD-stands for a food permit, MF stands for a mobile food permit, and NF stands for a non-food permit (i.e. school ground, pet shop, or hotel). Missing Data 539 inspections were without a score marked by the inspector.  Of those 539 inspections, 527 non-Cutting-Edge participants and 12 Cutting Edge inspections (Exhibit 12) will be excluded from the grading section of the analysis.   However, they will be included in the non-violation count. This missing data represents 1% of total the number of comprehensive inspections used as observations. Deletions as follows: ·         10% of the dataset are issued or pending statuses ·         22 with no classes ·         3,254 Permit Types - Food Peddler, Mobile Food Unit, Mobile Pet Shop, Push Cart, Seasonal Food Establishment and Temporary Food Service Step 3:  Determining Inspection Types Routine, unannounced inspections are referred to as comprehensive inspections.  A comprehensive inspection includes verifying all of the foodborne illness risk factors and good retail practices, which is a 52 item checklist.  Verification Visits are unique to Cutting Edge Participants and replace a portion of the required Routine Inspections in an annual cycle.  These inspections verify active managerial control by only focusing on the ten foodborne illness risk factors.  Complaint Inspections are conducted after a citizen files a complaint.  At this time, a routine inspection will be conducted, which is the same as a routine inspection, with extra focus being spent on the complaint filed.   To capture these types of inspection results, the inspection types listed below will be used. Inspection Types Used in Analysis ·         Routine Inspection ·         Complaint Inspection ·         Verification Visits (only Cutting Edge participants qualify) Step 4:  Performance Measures After edits, deletions, and specifications that determine inspection types, there are 40,718 inspections to analyze. Non-Cutting Edge inspections represent 93% of all inspections (Exhibit 13). Voluntary Grading System The Maricopa County Environmental Services Department (MCESD) implemented a voluntary grading system that started on October 14, 2011. This voluntary grading system is now used to provide an “at a glance” indication of how each food establishment performs as a result of their required, unannounced food safety inspection. The inspector verifies with the owner/person in charge at the beginning of the inspection whether the food establishment will participate in the grade card system and the posting of the letter grades online.   The grade card system is voluntary and allows the inspector to give the establishment a grade of A, B, C, or D depending on the number of Priority, Priority Foundation, and Core violations.  This number of violations is documented on the Internet.  If an establishment chooses to opt out of the grade card system or are “not participating”, the inspector will still document the number of violations, but not assign a letter grade.  All inspection reports are public record; therefore, all inspections are posted on the Internet.  The reports also referred to as awards and are captured in this analysis. An inspector awards grades A through D as a result of a scoring matrix (Exhibit 14).  MCESD understands that the public and the food establishments share the same concern for food safety. This voluntary program is designed to grade the food establishments in terms of food safety requirements and acknowledge those that do a good job. For this reason “Not Participating” is measured as a performance measure to capture participation status. Risk Factors Violations are summed and totaled for Foodborne Illness Risk Factor violations and are included in this analysis.  Foodborne Illness Risk Factors (FIRF) are captured as “Out” of compliance  and summed for each inspection. Items that are marked "Out" are violations noted on the inspection report. The first 28 rows on the inspection guidesheet are all Foodborne Illness Risk Factor violations. These violations are selected as either "In", "Out", "Not Observed" N/O or "Not Applicable" N/A. Good Retail Practice (GRP) violations are excluded from the violation performance analysis. GRP violations are categorized as not directly correlated to foodborne risks associated to food handlers. GRPs are associated with violations that may lead to FIRFs.  These items only marked as “Out” if a violation exists. For the purpose of analyzing performance and reducing observing food safety risks, a variable recognizes inspections with zero violations when the FIRF sum is zero.  Step 5:  Results In this section the analysis will be outline by the following: 1.      Grading Analysis 2.      Voluntary Grading Participation 3.      No violations/Zero violations Grading Analysis Cutting Edge enrollees received an A grade for 81% of their inspections while non-Cutting-Edge businesses received A grade for 42% of their inspections (Exhibit 15). Voluntary Participation Analysis Ninety percent of inspections for Cutting Edge enrollees opted in the Award Card Program and were awarded a letter grade on the Internet.  Only 56% of non-cutting edge inspections opted in the Award Card program and had their letter grades posted on the Internet (Exhibit 15). No Violations Cutting Edge enrollees have no food-borne risk violations during 84% of their inspections versus 60% for non-participants (Exhibit 16). As the number of Cutting Edge participants qualify for the Cutting Edge program, the number of zero violations also increases. In 2014, Cutting Edge participants demonstrated a growing trend annually in decreased FIRF and zero/no violations compared to Cutting Edge participants in previous years (Exhibit #16).  Conclusion After developing policies, training staff, and verifying that their policies work, establishments in the Cutting Edge program saw a decrease in the number of foodborne illness risk factor violations on unannounced inspections.  Establishments in the Cutting Edge consistently implemented discipline in reducing foodborne illness risk factors when compared to non-Cutting Edge establishments.  Participating in the voluntary grading system also indicates which businesses take food safety practices to the next level and are responsive to the consumers’ concern for food safety.  The Maricopa County Environmental Services Department (MCESD) initiated the Cutting Edge program to promote food safety to the populations they serve and to help establishments gain more active managerial control in their establishments.  Top performing restaurants are now showcasing their successes.  Voluntary participation and their effects are measurable in the data and the corresponding inspection results of Cutting Edge participant’s food safety practice and efforts. The increase in no violations for non-participants from 2010 to 2013 is 6% (Exhibit #17) and the increase is 25% for Cutting Edge (Exhibit 18 and 19). This demonstrates that these businesses are benefitting from the program, whereas if Cutting Edge participants were already consistently high-performing in this area, the zero violations would have stayed higher and constant.   However, we see a significant trend after 2010.  Therefore acquiring effective health standardization through the Cutting Edge Program is contributing in the growing trend in zero violations.        
Maricopa County Environmental Services has learned many lessons since the inception of the Cutting Edge program. An important lesson learned from our field staff is to keep staff up to date and provide recurring training.  After introducing the program to staff and providing initial training, the focus switched to training the restaurant operators.  It wasn’t until much later in the process that we realized that many employees did not feel comfortable with explaining the program or re-focusing their inspections to address only the Top 10 Risk Factors.  At this point, we provided additional training to our staff and demonstrated how to conduct the inspection (role-playing).  This sufficiently increased our staff’s knowledge on the procedure.  Approximately 9 months later, we reviewed some of the challenging real life situations that our employees were dealing with and put together an additional training for our employees.  This additional training provided approximately 20 “real” scenarios that employees encountered in the field and the answers to how to address those scenarios.  This training was given during mandatory office meetings to keep everyone up to date.  Any additional questions were compiled and sent out with administrative answers to each office so that everyone heard the same message.  This has provided the additional training and confidence that our employees needed to maintain the success of the program.  Field inspectors are confident in their understanding of the program and are now “selling” it while out in the field to their operators. Another important lesson learned from our stakeholders is to keep asking for their input in the decision making process.  Because this program affects them directly, their feedback is vital to keeping the program thriving.  During the initial development of the program, stakeholder input was requested.  At the same time, our internal Cutting Edge committee reviewed policies and procedures as it relates to the Cutting Edge Program, as well as making decisions on how we would market the program and move it forward.  We solicited feedback for the flyers that we developed from a few operators.  We used local news channels to put out stories about the program.  Over time, and through meetings with industry, we started to advertise success stories using social media.  As interest in the program has increased, a focus group of stakeholders was put together to provide feedback.  The focus group has brought together new ideas that we are currently working on internally.  We are working on a new, higher level, award for those in the Cutting Edge program.  We currently use the A, B, C, D award for restaurant inspections, but we are now working on developing an A+ award for those establishments on the Cutting Edge.  We are also developing new promotional materials that can be used and customized by operators.  The ideas for this include bulleted informational points on the program to be used as table tents or flyers to hang on restaurant walls and to show the additional requirements that these establishments are meeting.  We are trying to expand on social media and are working on developing smart phone apps that will identify establishments enrolled in the program for going above and beyond.  We are developing more online tools, educational materials, and videos to educate the general public and promote the program and its participants.  Our goal is to help educate the public on the program so that they can influence establishments on enrolling in the program.  We believe that by creating more in-depth involvement with stakeholders during the decision making process, it will surely add value to the program while ensuring stakeholder buy-in. Efficiencies provided by the new approach to inspections demonstrate an insignificant overall reduction in inspection times for participating establishments (Exhibit 20). Full service restaurants showed an average of 83 minutes/inspection before participating in Cutting Edge as compared with a 73 minute average inspection time during Cutting Edge participation (Exhibit 21).  Excluding full service restaurants, average of minute savings is minimal per inspection (Exhibit 22).  This may not appear to be significant, however, annual productive hours saved with 1,235 participating establishments equates to 260, on average, productive hours, which then can be applied toward other inspection needs (Exhibit #23).  As participation continues to increase, so grows the number of productive hours.  
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