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Comments to OFCCP on Nondiscrimination Obligations
Topics/
Employment Law/
Unions/
CHAMBER OF COMMERCE OF THE UNITED STATES OF AMERICA
MARC FREEDMAN
1615 H STREET, N.W.
VICE PRESIDENT, WORKPLACE POLICY
EMPLOYMENT POLICY DIVISION
Mr. Craig E. Leen
Room C-3325
200 Constitution Avenue, NW
By Electronic Submission: www.regulations.gov
RE: RIN 1250-AA10 - Nondiscrimination Obligations of Federal Contractors and Subcontractors, 84 Fed. Reg. 71875 (December 30, 2019)
Dear Director Leen:
The U.S. Chamber of Commerce ("the Chamber") submits the following comments in response to the Office of Federal Contract Compliance Programs ("OFCCPs" or "the Agency") Notice of Proposed Rulemaking Rule regarding Nondiscrimination Obligations of Federal Contractors and Subcontractors ("NPRM" or "the proposed rule") published in the Federal Register on December 30, 2019 (84 Fed. Reg. 71875, December 30, 2019). Among the Chamber's members are many federal contractors subject to OFCCP's jurisdiction who will be directly affected by the outcome of this rulemaking.
INTRODUCTION AND EXECUTIVE SUMMARY
As an initial matter, the Chamber recognizes the Agency's recent efforts, to promote transparency regarding its compliance evaluation procedures and processes. The Chamber also acknowledges that the Agency's stated goal with regard to this NPRM is to provide some measure of regulatory certainty regarding the Predetermination Notice ("PDN") and Notice of Violation ("NOV") process and the statistical evidence on which it will rely when pursuing claims of systemic discrimination. All too often, OFCCP has relied on sub-regulatory guidance, rather than formal notice and comment rulemaking, to establish its governing processes and procedures. The Chamber shares the Agency's interest in providing government contractors greater certainty and transparency with respect to its PDN and NOV process.
Notwithstanding the laudatory goals of the NPRM, the Chamber has significant concerns with the proposed rulemaking. The central thrust of the NPRM is the Agency's treatment of statistical and non-statistical proof in its assessment of potential systemic discrimination in compensation and other personnel practices. While the Chamber supports certain elements of the NPRM, including its appropriate recognition that variances must be both statistically
significant and practically significant, the Chamber has substantial concerns about much of the NPRM's treatment of statistical and non-statistical evidence. The Agency should not adopt a formulaic approach to statistical evidence, particularly in the context of compensation. OFCCP should continue to recognize that its statistical models: (1) must be tailored to each contractor's particular compensation or personnel practices; (2) must be based on groupings of similarly situated individuals (in accordance with Title VII ); and (3) must account for all factors that impact the dependent variable. Any final rule should continue to require that any finding of discrimination must be supported by evidence that the variance at issue is practically significant as well as statistically significant, and accompanied by non-statistical evidence.
The Chamber believes the NPRM has the following significant problems:
The NPRM's proposed declaration that non-statistical evidence is necessary only when a statistical variance is less than three standard deviations is arbitrary and without support in Title VII case law. Case law analyzing the disparate treatment/pattern and practice framework requires the showing of non-statistical evidence in all except the most extreme cases, such as the "inexorable zero." Accordingly, the Agency should refrain from establishing a statistical threshold above which it can rely solely on statistical evidence in support of a finding of discrimination. Such an assertion of policy, devoid of support in Title VII case law, is beyond the scope of the Agency's authority.
The arbitrary statistical thresholds of "discrimination" the Agency attempts to establish will work to the unfair disadvantage of large employers where applicant pools or incumbent pools are large.
Further, the Agency has, in practice, improperly aggregated across different populations and multiple years to generate larger statistical variances so that they are statistically significant but not necessarily practically significant; such data manipulation creates false presentations of asserted discrimination. Issuing a PDN without non-statistical evidence of discrimination, based only on a statistical variance of at least three standard deviations, will only further encourage improper aggregations and exacerbate this pattern. Without any supporting evidence of discriminatory actions mere statistical variances cannot suffice as support for a PDN.
The NPRM does not expressly limit its application to matters involving OFCCP claims of disparate treatment/pattern and practice discrimination. Any final rule should state that it does not extend to matters arising under the disparate impact theory of discrimination.
With regard to the proposed codification of the PDN process, the Chamber appreciates OFCCP's efforts to codify its sub-regulatory guidance on PDNs, but believes the Agency should go a step further in the interests of efficiency and transparency. The Agency should require a pre-PDN conference with the contractor to address all alleged violations and permit the contractor an opportunity to respond before the PDN issues. Postponing this exchange until after the PDN issues, and requiring contractor responses within 15 days, is an unworkable and inadvisable approach. Moreover, a 15-day period to respond if a PDN is issued is unreasonably short and should be extended to 45 days to provide for meaningful review, reflection, and an opportunity to understand and resolve a PDN.
Finally, the Agency should expressly endorse use of the Early Resolution Process (ERP) and Early Resolution Conciliation Agreements (ERCAs) in its final rule and codify the process. The NPRM and proposed regulatory language fail to adequately codify ERCAs as a meaningful path for resolving audits.
The Agency Should Not Set a Statistical Threshold at Which it Will Proceed to a PDN or NOV Without Supporting Non-Statistical (Anecdotal) Evidence of Discrimination.
In the NPRM, OFCCP provides that non-statistical evidence of discrimination is not necessary when a statistical disparity is greater than three standard deviations. In support of its bright-line "numbers evidence without more" test, OFCCP claims its position is "in keeping" with Title VII case law. On this issue, OFCCP is wrong.
While in rare instances, such as the existence of an "inexorable zero"1 of successful minority candidates or incumbents, there may be a sufficient basis to establish a prima facie case of discrimination, without non-statistical evidence, there is simply no support for moving forward with a PDN or NOV based solely on an arbitrary statistical threshold of more than three standard deviations. OFCCP's position finds no support in existing case law and demonstrates a deep misapplication of the meaning of statistical significance as it relates to determining whether employment discrimination has occurred.
As explained by Labor Economist Dr. J. Michael DuMond, a disparity designated as "statistically significant" suggests only that the observed disparity is unlikely to have been the result of a random occurrence. (Declaration of Dr. DuMond ("DuMond Decl."), ¶ 14.)2 However, a statistically significant disparity does not automatically mean that the reason for the identified disparity is discrimination. Id. ¶ 14, 17. Dr. DuMond's declaration is backed by a treatise OFCCP cites on its own public website, which explains that "significant differences may be evidence that something besides random error is at work. They are not evidence that this something is legally or practically important."3
A statistical situation characterized by the absence, or near absence, of any examples to counter the inference of discrimination.
Dr. DuMond's declaration is attached as Exhibit 1.
D. Kaye & D. Freedman, Washington, D.C.: National Academy of Sciences Press, Reference Guide on Statistics (2011), available at https://www.fjc.gov/content/reference-guide-statistics-2 (last visited Jan. 24, 2020); Office of Federal Contractor Compliance, Practical Significance in EEO Analysis, Frequently Asked Questions, available at https://www.dol.gov/ofccp/regs/compliance/faqs/PracticalSignificanceEEOF... (last visited Jan. 24, 2020).
The statements regarding the limits of what a statistically significant finding means (and what it does not mean) are supported by Title VII case law. See Carpenter v. Boeing Co., 456 F.3d 1183, 1195 (10th Cir. 2006) (citing Hazelwood Sch. Dist. v. United States, 433 U.S. 299, 308 n.14 (1977)) (reasoning that statistical significance only rules out "chance" as an explanation for observed disparities in an employer's workforce and allows a court to infer that "something" must be causing these statistical anomalies). However, statistical significance does not, on its own, establish that "the something" is the challenged practice under consideration. Foxworth v. Police, 228 Fed. App'x 151, 156 (3rd Cir. 2007) (agreeing with district court that statistics "showed a disparity" but were "insufficient as a matter of law to prove that the automatic disqualification policy caused it"); Carpenter, 456 F.3d at 1202 (noting that while "something in the overtime process consistently results in males obtaining more overtime" the "large number of standard deviations tells us nothing about what that 'something' is[.]").
Rather, in intentional discrimination cases, the Supreme Court and other Courts have relied on evidence of statistical disparity, but have also required more as a way of bringing the "cold numbers convincingly to life" through anecdotal and other evidence. Int'l Bhd. Of Teamsters v. U.S., 431 U.S. 324, 329-30, 342-43 (1977). To hold otherwise would result in employers being held potentially liable, not for the alleged discriminatory practice, but for "the myriad of innocent causes that may lead to statistical imbalances in the composition of their workforces." Watson v. Fort Worth Bank and Trust, 487 U.S. 977, 992 (1988); Wards Cove Packing Company, Inc. v. Atonio, 490 U.S. 642, 657 (1989).
In fact, the cases cited by OFCCP do not provide the sweeping support for OFCCP's reliance on mere statistical evidence to establish discrimination. For instance, in Adams v. Ameritech Servs., Inc., the court did not suggest that statistical evidence could establish discrimination on its own, but instead observed that while "statistical evidence can be very useful to prove discrimination… it will likely not be sufficient in itself" and reached its conclusion by relying on the fact that additional, non-statistical evidence had been introduced. 231 F.3d 414, 423-24, 427 (7th Cir. 2000) ("If [the statistical analysis] on its own is all the plaintiffs' had introduced, we would agree … that the record would have supported summary judgement against them. It was not, however, and in our view, the other items of evidence if believed by the jury could have done the rest of the job").
OFCCP's reference to Malave v. Potter—a disparate impact, not disparate treatment, case—does not lend support for its position that it may proceed without non-statistical evidence. 320 F.3d 321 (2nd Cir. 2003). As noted in the NPRM, the Court did remand the case and instruct the district court to "determine whether the plaintiff can show a statistically significant disparity of two standard deviations." Id. at 327. But it said more. It also said that the District Court must decide whether plaintiff's "statistical analysis and other evidence, is of a kind and degree sufficient to show" the promotion practices was the cause of the disparity. Id. (emphasis added). It also emphasized that "no bright line rules exist to guide courts in deciding whether [a] plaintiff['s] statistics raise an inference of discrimination," and offered some "overarching principles [that] inform the issue." Id. at 325-326. Among these principles was a caution that any statistics relied upon "must be of a kind and degree sufficient to reveal a causal relationship between the challenged practice and the disparity" when combined with other evidence. Id.
Rather than lending support for OFCCP's position, the body of Title VII case law makes clear that context matters and that there is no bright line threshold that can be applied under which non-statistical evidence is no longer necessary. Palmer v. Shultz, 815 F.2d 84, 92 (D.C. Cir. 1987) (noting that Supreme Court has not established "an exact legal threshold at which statistical evidence, standing alone, establishes an inference of discrimination"). Rather, the Chamber urges the Agency to follow Title VII principles and refrain from setting arbitrary thresholds that apply to all findings. 4 See also, Chin v. Port Auth. of New York & New Jersey, 685 F.3d 135, 153 (2d Cir. 2012) ("no minimum statistical threshold requiring a mandatory finding [of] … a violation of Title VII. Courts should take a 'case-by-case approach' in judging the significance or substantiality of disparities, one that considers not only statistics but also all the surrounding facts and circumstances."); Watson, 487 U.S. at 996 n. 3, 108 S.Ct. 2777 (approving the case-by-case approach because "statistics 'come in infinite variety and ... their usefulness depends on all of the surrounding facts and circumstances.'") (quoting Teamsters v. United States, 431 U.S. 324, 340, 97 S.Ct. 1843, 52 L.Ed.2d 396 (1977)). These cases demonstrate the caution expressed by courts against bright line rules at which statistical evidence, standing alone, establishes an inference of discrimination.
a. Nonstatistical Evidence is Required in All But Extreme Cases Which Generally Requires More than Simply a Finding of More than Three Standard Deviations.
Although the Chamber strongly opposes a bright line test that applies a "no non-statistical evidence requirement" if there is a finding of three standard deviations or more, it acknowledges that there are rare exceptions that do not require non-statistical evidence. For instance, the Supreme Court has recognized that in certain extreme cases, exemplified by the presence of the "inexorable zero"—i.e., the total or near total absence of members of a protected group—it may be appropriate to reach an inference of discrimination, without additional non-statistical evidence. The basis for the Supreme Court's reasoning was that no amount of "fine tuning" could have overcome the "glaring absence" of minority drivers. Teamsters v. United States, 431 U.S. at 342.
However, even in those cases, courts have often relied on additional non-statistical evidence. See Johnson v. Transp. Agency, 480 U.S. 616, 665 n.4 (1987) (Scalia, J., dissenting) ("[E]ven an absolute zero is not 'inexorable.' While it may inexorably provide 'firm basis' for belief in the mind of an outside observer [that discrimination occurred], it cannot conclusively establish such a belief on the employer's part, since he may be aware of the particular reasons that account for the zero.")
Additionally, not only do most of the inexorable zero cases also rely on non-statistical anecdotal evidence, those extreme cases involve statistical significance that far exceed three standard deviations. See Teamsters, 431 U.S. at 342 (even in the face of evidence that no Black employees were ever employed on a regular basis, it still relied on anecdotal evidence);
See also, D. Baldus & J. Cole, supra, § 9.4, at 188–89 (Supp.1987) (courts should use tests of statistical significance only as "an aid to interpretation" and not as a "rule of law"); Tagatz v. Marquette Univ., 861 F.2d 1040, 1044 (7th Cir.1988) ("Correlation is not causation."); Chin v. Port Auth. of New York & New Jersey, 685 F.3d 135, 153 (2d Cir. 2012) ("no minimum statistical threshold requiring a mandatory finding [of] … a violation of Title VII. Courts should take a 'case-by-case approach' in judging the significance or substantiality of disparities, one that considers not only statistics but also all the surrounding facts and circumstances.").
Calloway v. Westinghouse Elec. Corp., 642 F.Supp. 663 (M.D. Geo. 1986) (finding there were no black managers or supervisors over a 14 year period, but still relied on anecdotal evidence); EEOC v. Boeing Co., 577 F.3d 1044 (9th Cir. 2009) (applying inexorable zero where plaintiff was the only woman in her skill code who was laid off while every male employee identified for termination in all three RIFs ultimately remained, but also relied on anecdotal witness testimony); EEOC v. O&G Spring and Wire Forms Specialty Co., 38 F.3d 872 (7th Cir. 1994) (applying inexorable zero where there were no black hires over a 6 year period, but still relied on anecdotal evidence); Grant v. Bethlehem Steel Corp., 635 F.2d 1007, 1016–17 (2d Cir. 1980) (applying inexorable zero where defendant rejected applications by all three appellants for foremen's jobs, but still relied on anecdotal evidence that less qualified white applicants were appointed to such positions).
These cases demonstrate that while Courts do recognize that in some instances when the number of individuals in a group is zero, or near zero, that statistical information alone may be sufficient to support an inference of discrimination, there is often non-statistical evidence that supports the data and brings the "cold numbers convincingly to life." Teamsters, 431 U.S. at 329-30, 342-43 (1977).
b. OFCCP's Proposed "Greater Than Three Standard Deviation" Framework, By Design, Will Disproportionally Lead to More Findings of Discrimination.
Employers with large workforces in particular, will be disproportionally impacted with findings of discrimination if OFCCP proceeds with the NPRM as drafted. This is so because such employers generally have larger applicant or incumbent pools, and even minor discrepancies can be considered statistically significant when the difference is measured across a large number of observations. (DuMond Decl. ¶ 13.) Relatedly, any aggregation of data can lead to results that are statistically significant, again simply because of larger pool sizes. (DuMond Decl. ¶ 10). Dr. DuMond offers a table to illustrate the point: small average pay disparities for females (under 1%) in two groups are not statistically significant when considered separately, but reach statistical significance based solely on the larger sample size:
(DuMond Decl. ¶¶ 12-13.) As the table shows, simply combining the pools and increasing the number of observations analyzed, caused a significant jump in the level of significance, such that the variance went from not statistically significant to over three standard deviations. Yet under each grouping (A, B or A&B), the adjusted pay difference remains relatively the same. Thus, the driver of the statistically significant finding has nothing to do with alleged discriminatory decision-making, rather, it is being driven by applying the same percentage variance to a larger population.5 And in this example, the level of variance surpasses OFCCP's proposed threshold of more than three standard deviations, such that OFCCP would proceed to an PDN with no additional supporting non-statistical evidence. (Id. ¶ 11.) It is nonsensical to allow mere aggregation or large sample sizes to be the driver of moving from statistical non-significance to significance.
OFCCP can still accomplish its stated desire of greater transparency and consistency without setting the arbitrary thresholds contemplated here. To achieve this desired result, OFCCP should instead consider clearly stating that: (1) the Agency will mirror a contractor's compensation system or other personnel practice when developing its statistical models; (2) the Agency will compare only individuals who are similarly situated (pursuant to Title VII standards); and (3) the appropriate statistical methodology to be applied in each matter will depend on a number of factors, including the size of the comparison groups at issue, the personnel practice at issue, the variables impacting the personnel practice at issue, and the availability of data to perform appropriate statistical analyses.
Accordingly, the Chamber strongly urges OFCCP to withdraw its position that it will move forward with a PDN, based solely on a statistical finding of more than three standard deviations.
As Dr. Dumond notes in his Declaration, aggregating across subgroups also carries the risk of ignoring the fact that variables in a regression may impact the various subgroups differently, such that aggregation is improper. (DuMond Decl. ¶ 8.) As Dr. DuMond notes, economists and statisticians can rely on a statistical test (i.e., a Chow test) to determine if the pay of subsets of employees is determined not only by the same factors (e.g., experience, education), but also whether the relative weights of those factors are similar among the subsets. When the Chow test fails, the conclusion that follows is that it is improper to aggregate the subgroups into a combined analysis.
The Agency Properly States that Variances Must Be "Practically Significant" to Warrant A PDN or NOV, but OFCCP Should Provide Further Explanation of this Key Concept.
The NPRM states that OFCCP shall issue a PDN only after "first considering" whether "the unexplained [statistical] disparity is both practically and statistically significant." 84 Fed. Reg. at 71885. The preamble explains further that to "determine whether the evidence of discrimination is sufficient to warrant a PDN, OFCCP considers whether an employment or compensation disparity identified during the compliance evaluation is both practically and statistically significant." Id. at 71876. The preamble then explains in footnote six that "practical significance refers to whether an observed disparity in employment opportunities or outcomes reflects meaningful harm to the disfavored group." Id. at 71876, n.6. (emphasis added) - Citing OFCCP FAQs at https://www.dol.gov/ofccp/regs/compliance/faqs/PracticalSignificanceEEOFAQs.htm#5.
The Chamber endorses OFCCP's decision to incorporate the key concept of "practical significance" into its regulations. For several reasons, the Chamber urges OFCCP, in its final rule, to state affirmatively that any alleged disparity must be practically significant for OFCCP to move to a PDN with regard to the employment practice at issue.
Practical significance is not a novel concept. It is expressly referenced in the Uniform Guidelines on Employee Selection Procedures (UGESP). 41 C.F.R. Part 60-3 (1978). Section 60-3.4D discusses the "four-fifths rule" and states that "[s]maller differences in selection rate may nevertheless constitute adverse impact, where they are significant in both statistical and practical terms." 41 C.F.R. Section 60-3.4. Indeed, labor economists agree that the four-fifths rule, itself, is a practical significance concept. See "Measuring Practical Significance in Adverse Impact Analyses", Frederick L. Oswald, Eric M. Dunleavy, and Amy Shaw (Adverse Impact Analysis: Understanding Data, Statistics, and Risk. Routledge 2017).
Practical significance has likewise been recognized by the courts and by OFCCP. See, e.g., Waisome v. Port Authority, 948 F.2d 1370, 1376 (2d Cir. 1991) (finding no discrimination where variance in passing scores on written test was statistically-significant, but selection rates passed the four-fifths test and the disparity, though statistically significant, "was of limited magnitude"); Apsley v. Boeing, 691 F.3d 1184 (10th Cir. 2012) (finding no discrimination where variance in selection rates for reduction in force was statistically significant, but the shortfall was small in relation to the total number of employees in the analysis, such that selection rates were "practically nonsignificant"); Contreras v. City of Los Angeles, 656 F.2d 1267 (9th Cir. 1981) (no discrimination notwithstanding statistically-significant difference in selection rates where difference was approximately 2%).
The concept of practical significance and its relevance to OFCCP determinations can be readily illustrated by just a few examples. The table below shows the criticality of practical significance whenever the incumbent pool or applicant pool at issue is large. For this example, we show that even a 1% difference in selection rates can be statistically significant when the sample sizes reach a certain threshold. Without consideration of practical significance (i.e., the difference in selection rates is just 1%), OFCCP could assert that the statistically significant result when the sample size reaches 8,400 evinces discrimination; it does not. Moving to a PDN based solely on statistical significance in this example would be wholly unwarranted.
The next table shows a similar result in the compensation context, where very small differences in average pay to women and men yield a variance that is statistically significant, but not practically significant. For instance, in Case 1 below, a practically insignificant difference in pay – just 0.5% – yields a variance of 2.04 standard deviations when the pool of incumbents compared reaches just over 1,500.
In none of the cases identified in the second table should OFCCP advance claims of discrimination in pay, given the practical insignificance of the pay differences. Without examining the data through that lens, and if OFCCP were to rely solely on statistical significance, the contractor in each of the three scenarios would be faced with a PDN alleging discrimination in pay.
These tables also reflect the reality that, unless the Agency is required to show practical significance in each instance in which it pursues a PDN, large contractors will be disadvantaged. See DuMond Declaration at ¶13. Large contractors with thousands or tens of thousands of applicants for jobs in a single job group each Affirmative Action Plan year, or with tens of thousands of employees in their AAPs for purposes of compensation analyses, will be much more likely than small contractors to have some areas of statistically-significant differences. In
Notably, under OFCCP's proposed rule, the Agency could move to a PDN on this variance – 3.10 standard deviations – without non-statistical evidence of discrimination. This example underscores the frailty of that approach, as well.
those cases, requiring a showing of practical significance is critical to ensuring that large contractors are not disadvantaged or unfairly identified for enforcement actions.
As such, the appropriate measure of practical significance will vary from audit to audit and from one employment practice to another. Because of this variety, how OFCCP applies practical significance should be one of the issues addressed in negotiations between the Agency and the employer.7 As discussed more thoroughly below, the ideal opportunity for this would be a pre-PDN conference.
The Proposed Rule Has No Application Over Disparate Impact Claims And Should Be Explicitly Limited to Disparate Treatment Cases.
The NPRM is ambiguous on the question of whether the proposed treatment of statistical evidence will apply only to Title VII claims of disparate treatment (i.e., intentional discrimination), or if disparate impact claims, which encompass unintentional discrimination, fall within the scope of the proposed rule. E.E.O.C. v. Joe's Stone Crab, Inc., 220 F.3d 1263, 1278 (11th Cir. 2000) ("As we have noted, the central difference between disparate treatment and disparate impact claims is that disparate treatment requires a showing of discriminatory intent and disparate impact does not.")
For instance, the resolution procedures that would be adopted under the NPRM provide that a PDN would be issued only after a finding of practical and statistical significance and, where relevant, the non-statistical evidence demonstrates "an intent to discriminate." 84 Fed. Reg. No. 249, 71875 at 71885 (Dec. 30, 2019). (emphasis added) Similarly, in the background section of the NPRM, the OFCCP provides that "non-statistical evidence, such as a cohort analysis, demonstrates an intent to discriminate." Id. at 718777. (emphasis added)
Disparate impact claims require showings of both statistical evidence that a neutral policy or practice has a substantial adverse impact on a protected group and the demonstration of a causal relationship between the employment policy or practice at issue and the statistical disparity. See Wards Cove Packing Co. v. Antonio, 490 U.S. 642, 657 (1989) (plaintiffs must show that the challenged practice had a "significantly disparate impact on employment opportunities for whites and nonwhites."); Watson v. Fort Worth Bank & Trust, 487 U.S. 977, 995 (1988) (disparities must be "sufficiently substantial that they raise such an inference of causation.").
The NPRM makes no mention of the types of proofs implicated in disparate impact cases, namely the required explicit identification of a neutral policy or practice, nor does it describe the process by which employers can demonstrate the business necessity for the challenged practice.
The absence of this type of language as it relates to disparate impact claims, creates the impression that the Agency intends to extend the application of the NPRM only to intentional conduct, i.e. disparate treatment cases. Accordingly, OFCCP should clarify that the NPRM applies only to intentional discrimination claims.
As discussed at length in the literature, there are a number of potential measures of practical significance, including impact ratios (the four-fifths rule), phi coefficient, odds ratios, absolute differences in selection rates, Cohen h-statistic, and shortfall statistics.
The Agency Should Add a New Step in the Case Resolution Procedure that Will Precede a PDN: the Pre-PDN Conference.
In September 2017, the Chamber issued "Office of Federal Contract Compliance Programs: Right Mission, Wrong Tactics, Recommendations for Reform," a white paper detailing the Chamber's concerns about OFCCP's enforcement efforts and its relationship with the contractor community. The Chamber highlighted the Agency's lack of transparency, its perceived antagonism towards contractors, its drawn-out, overly invasive compliance review practices, and its aggressive conciliation posture.
The Chamber is encouraged by a change in OFCCP's tone. In recent years, the Agency has repeatedly expressed a desire to work with contractors to identify and resolve issues in a timely manner. In furtherance of these goals, the Agency has issued a number of guidance documents, including Directive 2018-01 Use of Predetermination Notices (PDN), Directive 2018-08 Transparency in OFCCP Compliance Activities, and Directive 2019-01 Compliance Review Procedures. Contractors have also seen changes in some of the regional offices, where compliance officers have struck a more collaborative tone in audits, and have sought to close or resolve compliance reviews in a more efficient manner. While these changes in policy and practice have been well received by the contracting community, there is more that can and should be done to improve the Agency's effectiveness and efficiency, and OFCCP should take the opportunity in its proposed regulatory changes to do just that.
Directive 2018-01 (Use of Predetermination Notices (PDN)) mandates that OFCCP issue a PDN and provide the contractor at least fifteen (15) days to rebut OFCCP's proposed findings of discrimination prior to issuing an NOV. The Directive also requires that both the regional Office of the Solicitor and OFCCP's national office review and approve all PDNs before they are issued. The NPRM codifies in the regulations this requirement to issue a PDN prior to issuing an NOV, stating "for discrimination violations, OFCCP may issue the notice of violation following issuance of a predetermination notice if the contractor does not respond or provide a sufficient response within 15 calendar days of receipt of the notice, unless OFCCP has extended the predetermination notice response time for good cause shown."
The Chamber appreciates that OFCCP is seeking to codify the PDN requirement in the regulations. However, this action does not go far enough to address OFCCP's stated desire to improve the efficiency of the compliance review process and the collaboration between contractors and the Agency. Under the proposed structure, a contractor has no opportunity to address potential areas of discrimination until the Agency (1) has made preliminary findings, (2) has those findings reviewed and approved by the Regional Office of the Solicitor, and then (3) has the findings reviewed and approved by the National Office of OFCCP. As such, the Agency is required to expend a significant amount of time and effort preparing, reviewing, and approving the preliminary findings before the contractor is even made aware of the potential issues and given an opportunity to respond. This is inefficient and inconsistent with the Agency's stated interest in collaboration.
Consistent with the Agency's desire to seek early resolution of potential findings of non-compliance or discrimination, the Chamber proposes that OFCCP add to the regulations a new step in the compliance review process that would precede issuance of a PDN. This step would
involve a meeting between OFCCP and the contractor to discuss, in detail, all potential issues of non-compliance or discrimination. OFCCP would share its statistical and non-statistical evidence in that meeting, and how it has applied the requirement for practical significance, and the contractor would be given an opportunity to respond and provide additional information, before OFCCP issues a PDN.
If the contractor is not able to address the potential issues to OFCCP's satisfaction, the parties can attempt to resolve the matter at this stage using the expedited conciliation option contemplated by the NPRM, discussed further below. If the parties are unable to reach a resolution, the Agency can proceed with the PDN process. Adding this additional step in the process will enable OFCCP and contractors to collaborate on an informal basis to reach understanding/resolution before OFCCP expends the time and effort of drafting a PDN and obtaining the necessary approvals to issue.
Finally, the Chamber believes contractors should be provided a period longer than 15 days to respond to a PDN. In nearly every case, and in complex cases in particular, 15 days is a period too short to permit a meaningful response. Rather than requiring contractors to routinely seek extensions of time to respond, OFCCP should modify this time period to 45 days and continue to permit requests for additional time.
OFCCP Should Formally Incorporate the Early Resolution Procedures and Early Resolution Conciliation Agreements in its Substantive Regulations.
One of the more effective actions taken by OFCCP in recent years to improve the efficiency and effectiveness of its enforcement efforts was its issuance of Directive 2019-02 – Early Resolution Procedures ("ERP"). The Agency's ERP Directive offers contractors and the Agency a path to resolve purported violations identified by the agency during the audit through conciliation prior to the issuance of a NOV. It also permits the parties to agree on a broader resolution to address any similar alleged violations at a subset, or at all, of the contractor's other establishments. The ERP Directive established the Early Resolution Conciliation Agreement (ERCA). Pursuant to an ERCA, a contractor agrees to remedy the Agency's alleged violations at the establishment under review and agrees to review all, or a subset, of its other establishments for similar violations and implement corrective action as appropriate. The contractor is required to submit progress reports to the Agency for five years regarding its remediation of the alleged violations at all covered establishments. In recognition of the contractor's willingness to engage in these proactive corrective measures, OFCCP agrees to not audit the establishments encompassed by the ERCA for seven years (the five-year ERCA reporting period plus two years after the end of the reporting period).
The Agency first began utilizing the ERP and ERCAs in 2019, and made effective use of ERCAs at the end of Fiscal Year 2019 to resolve compliance evaluations that had been open for years and for which OFCCP sought significant back pay amounts. Multiple companies, large and small alike, entered into ERCAs that resolved numerous long-standing audits; some resulted in multi-million dollar settlements. Each contractor that entered into an ERCA committed to an array of remediation and reporting obligations, and was given a seven-year reprieve from audit to effectuate these changes.
The NPRM references the ERP and ERCAs but does not sufficiently codify in the regulation the essential elements of these resolution mechanisms. The NPRM adds the following language to the regulations: "Expedited Conciliation Option. A contractor may waive the procedures set forth in paragraphs (a) [pre-determination notice] and/or (b) [notice of violations] of this section to enter directly into a conciliation agreement." 84 Fed. Reg. at 71885. This proposed language does not explain the process by which the Agency and contractor can negotiate such an early resolution and it does not articulate the opportunity for the Agency and the contractor to reach a resolution that encompasses more than just the establishment(s) currently under review. And, of key importance, nowhere do the proposed regulations codify the seven-year audit moratorium that is at the heart of the ERP and ERCA process.
The NPRM codifies the PDN and NOV processes in some significant detail, enumerating the number of days a contractor has to respond to a PDN and mandating that the Agency cannot issue an NOV until it has gone through the PDN process. The final regulations should address the ERP and ERCAs in a similar manner, detailing the approach and codifying the option of a multi-establishment or corporate-wide resolution and a seven-year audit moratorium.
The proposed regulation has some commendable provisions. However, there are several very troubling components to the NPRM. OFCCP's intent to rely solely on statistical evidence when it produces a variance of more than three standard deviations is an invitation to manipulate the data to find discrimination in the absence of any other factors such as non-statistical evidence. This provision should be reconsidered and withdrawn. Further, while stating that statistical variances must be "practically significant" as well as statistically significant, there is much uncertainty about what "practically significant" means. Finally, OFCCP should clarify that the processes identified in this regulation will not be used to support cases based on a "disparate impact" theory, and will be restricted to cases based on "disparate treatment."
Camille Olson
Annette Tyman
Kris D. Meade
Rebecca Springer
Seyfarth Shaw LLP
975 F Street, N.W.
Crowell & Moring LLP
1001 Pennsylvania Avenue, N.W.
Sens. Sinema, Kelly Hold the Line on an Economic Disaster: The PRO Act
If at First You Don't Succeed, Have the Labor Board Intercede
AB-5 Sponsor Calls It Quits
By Glenn Spencer
The NLRB's Amazon Antics II
By Sean P. Redmond
Arkansas Passes Covid Vaccine Bill


text:
Q: bootstrap background image not responsive to mobile devices I am trying to put a background on bootstrap webpage. Background image is working fine when webpage is loaded to laptop or desktop. But the problem occurs when pages are loaded on mobile devices some of the part of the screen remains unfilled.
Following is my code:
<body style="background: url(img/backgroung.jpg) no-repeat center center fixed"
    style="-webkit-background-size: cover"
    style="moz-background-size: cover"
    style="-o-background-size: cover"
    style="background-size: cover"
    style="background-size:100% auto"
   >

A: probably you want something like that:
body {
background: url('img/backgroung.jpg');
background-repeat: no-repeat;
background-position: center center;
background-attachment: fixed;
-webkit-background-size: cover;
-moz-background-size: cover;
-o-background-size: cover;
background-size: cover;
}

redpajama_set_name: RedPajamaStackExchange


One of our missions is to prepare students to live and work in the globally connected world. Our language teaching and learning philosophy is to provide students with an authentic language and cultural learning experience.
Chinese is a compulsory subject for all students at The College from Prep through to Year 8 and becomes an elective subject in Years 9-12.
Learning a second language is much more than learning simple greetings. We provide real life learning scenarios which enable students to build the capacity for intercultural understanding. Language learning benefits our young learners' personal, cognitive, academic, social and cultural development. It ultimately allows them to appreciate the world from other perspectives.
The College is committed to providing students with a diverse language learning experience by building partnerships and working with schools in surrounding areas. The Lakes College recognises the importance of a language program and this is evident by offering Chinese, Japanese, Italian, French and Spanish alternatives to suit student interest.


text:
Q: How can I move a loadCategories() func from SomeViewController to SomeViewModel? So I have the following function:
var categoryArray: [Category] = []

private func loadCategories() {

    downloadCategoriesFromFirebase { (allCategories) in

      self.categoryArray = allCategories
      self.collectionView.reloadData()
    }
  }

that is currently in my SomeViewController. I need to move it to SomeViewModel.
Sorry if my question is not well formulated, please do ask if you need any more information since I am so new at all this.
Thanks in advance

A: Assuming you have a reference to SomeViewModel in your SomeViewController, you can move the code over there.
For example:
import UIKit

class ViewController: UIViewController {

    private var viewModel: ViewModel!

    override func viewDidLoad() {
        super.viewDidLoad()
        callToViewModel()
    }

    func callToViewModel() {
        viewModel.loadCategories {
            self.collectionView.reloadData()
    }

    // rest of your code
}

The ViewModel could look something like this:
import Foundation

class ViewModel: NSObject {

    var categoryArray: [Category] = []

    override init() {
        super.init()
    }

    func loadCategories(completion: (() -> Void)?) {
        downloadCategoriesFromFirebase { (allCategories) in
            self.categoryArray = allCategories
            completion?()
        }
    }
}

When reloading your data, make sure to refer to viewModel.categoryArray instead of self.categoryArray now.
Please notice that I'm making use of a completion handler to notify the ViewController the call in the ViewModel was finished. There are other (perhaps better) ways to do this, like the Combine framework.


text:
Author Hot Press Filipino And Filam Literary Reading
Author: Hot Off the Press, Filipino and FilAm Literary Reading
Saturday, 10/9/2021
sfplcpp@sfpl.org
The Hot Off the Press (HOTP) Literary Reading, a program which is part of the Filipino American International Book Festival. Hosted and Moderated by author Cecilia Manguerra Brainard, Hot Off the Press Literary Readings have been showcasing Filipino and FilAm authors and their new books since 2011.
This year's HOTP Literary Reading includes nine Filipino and Filipino American authors: Gina Apostol, Jhoanna Lynn Cruz, George Gonzaga Deoso, Caroline Sy Hau, Mae Respicio, Randy Ribay, Brian Ascalon Roley, Ricco Siasoco and Lara Stapleton.
Watch on YouTube.
Gina Apostol is the author of critically acclaimed novels The Revolution of Raymundo Mata, Bibliolepsy, Insurrecto and Gun Dealers' Daughter. Her essays and stories have appeared in The New York Times, Los Angeles Review of Books, Foreign Policy, Gettysburg Review, Massachusetts Review and others.
Jhoanna Lynn B. Cruz is the author of the memoir, Abi Nako, Or So I Thought, which is about her starting her life over in Davao City as a lesbian writer. Her writings and edited works include: Women Loving: Stories and a Play, Women on Fire and Tingle Anthology of Pinay Lesbian Writing. She is an Associate Professor at the University of the Philippines Mindanao.
George Gonzaga Deoso is the author of The Horseman's Revolt and Other Horrors, a collection of dark short stories. His fiction, poetry, and essays had appeared in Liwayway Magazine, Philippine Panorama, Philippines Graphic, Philippine Daily Inquirer and the Sunday Times Magazine, among others. He was a fellow for poetry in the University of Santo Tomas and Silliman national writers workshop.
Caroline S. Hau is Professor at the Center for Southeast Asian Studies, Kyoto University, Japan. She obtained her BA degree from the University of the Philippines and her MA and PhD from Cornell University. She recently received the Grant Goodman Prize in Historical Studies from the Philippine Studies Group of the Association of Asian Studies. The novel, Tiempo Muerto, is her debut novel.
Mae Respicio writes middle grade novels, including The House that Lou Built; Any Day With You and How to Win a Slime War, all from Random House/Wendy Lamb Books. She lives with her family in the suburban wild of Northern California.
Randy Ribay is the author of An Infinite Number of Parallel Universes, After the Shot Drops, and, most recently, Patron Saints of Nothing—which received five starred reviews, was selected as a Freeman Book Award winner and was a finalist for the National Book Award, LA Times Book Prize, Walden Book Award, Edgar Award, International Thriller Writers Award and the UK's CILIP Carnegie Medal.
Brian Ascalon Roley has received fellowships and awards from the National Endowment of the Arts (2020 Literature Fellow), University of Cambridge, Cornell University, the Ohio Arts Council, the Djerassi Foundation, Ragdale and the VCCA, among others. His books include American Son: a Novel, The Last Mistress of Jose Rizal and the award-winning chapbook, Ambuscade.
Ricco Villanueva Siasoco has received fellowships from The Center for Fiction, Lambda Literary, and the National Endowment for the Humanities. He lives in San Francisco where he is a Grade Dean at the Urban School of San Francisco. The Foley Artist is his first book of stories; it was awarded Honorable Mention in the 2021 Asian American Studies Book Award.
Lara Stapleton is the author of The Lowest Blue Flame Before Nothing and The Ruin of Everything. Her work has appeared in The LA Review of Books, Poets and Writers, The Brooklyn Rail, Ms., Glimmer Train and The Indiana Review, among others. She received a Ludwig Vogelstein Foundation Grant for writers. She was a two-time winner of the University of Michigan's Hopwood Award for fiction. She was also the winner of the Columbia Journal fiction prize.
This event is a partnership with Philippine American Writers and Artists.
Check out books from HOTP from your favorite library or buy from Eastwind Books of Berkeley or your favorite local bookstore.
Gina Apostol – The Revolution According to Raymundo Mata, Soho 2021
Jhoanna Lynn Cruz – Abi Nako or So I Thought, University of the Philippines Press, 2020
George Deoso – The Horseman's Revolt and Other Horrors, University of Santo Tomas Publishing House 2020
Caroline Sy Hau – Tiempo Muerto, Ateneo 2019
Mae Respicio – How to Win a Slime War, Random House Kids 2021
Randy Ribay – Patron Saints of Nothing, Penguin 2020
Brian Ascalon Roley, Ambuscade: Poems, Finishing Line Press 2021
Ricco Siasoco – The Foley Artist, Gaudy Boy 2020
Lara Stapleton – The Ruin of Everything, Paloma, 2021
Engage with your favorite writers and discover your next read.
Filipino American Interest
Connect to engaging discussions and performances related to the Filipino American community.
This program is sponsored by Friends of the San Francisco Public Library.
Attending Programs
For questions about the program or help registering, contact sfplcpp@sfpl.org. All SFPL locations are wheelchair accessible. For accommodations (such as ASL or language interpretation), call (415) 557-4557 or contact accessibility@sfpl.org. Requesting at least 3 business days in advance will help ensure availability.
Public Notice and Disclaimer
This program uses a third-party website link. By clicking on the third-party website link, you will leave SFPL's website and enter a website not operated by SFPL. This service may collect personally identifying information about you, such as name, username, email address, and password. This service will treat the information it collects about you pursuant to its own privacy policy. We encourage you to review the privacy policies of each third-party website or service that you visit or use, including those third parties with whom you interact through our Library services. For more information about these third-party links, please see the section of SFPL's Privacy Policy describing Links to Other Sites.
The views and opinions expressed in programs presented by groups unaffiliated with SFPL do not necessarily reflect the official policy or position of SFPL or the City.
More Than a Month 2023
New Main Library 25th Anniversary
Golden Gate Park's 150th Birthday

redpajama_set_name: RedPajamaCommonCrawl


In our Mission Statement we commit to respecting each child as an individual and encouraging him/her to develop his/her full potential.
By rewarding each child for being the best that he/she can be we are encouraging our children to develop as well rounded individuals, socially, culturally, morally, spiritually, emotionally and physically.
Gold, silver or bronze medals for our Code of Behaviour "Discipline for Learning".
A plaque signifying "Player of the Week" for children learning tennis .
The "Nell Kenny Trophy" is presented to an exceptional overall student from 5th Class each year.
In 2009, Chloe Fowler was presented with the trophy.
Praise the young and they will flourish!


text:
Правда () — село в Польше, входит в гмину Жгув Восточно-Лодзинского повята Лодзинского воеводства.

География
Село располагается в 4 км от Жгува и в 17 км от Лодзи. Возле села протекает река Добжинка.

История
С 1975 по 1998 год село входило административно подчинялось тогдашнему Лодзинскому воеводству.

Хозяйство
В селе в основном располагаются сельскохозяйственные предприятия и несколько предприятий сферы услуг. Здания располагаются вдоль главной улицы.

Источник
 Miasto i Gmina Rzgów. Mapa Turystyczno-Krajoznawcza, wyd. I, Eko-Dent Anna Świć, 06-2006.

Ссылки
 Central Statistical Office (GUS) Population: Size and Structure by Administrative Division

Населённые пункты Восточно-Лодзинского повета

redpajama_set_name: RedPajamaWikipedia


WASHINGTON, DC, April 04, 2018 /24-7PressRelease/ — The Coalition for Community Schools, an initiative of the Institute for Educational Leadership (IEL), is proud to present 10 leadership awards to community school leaders who have made explicit that only by working together and focusing on equity will all children learn and thrive. The Coalition will present national leadership awards to a youth, national partner, superintendent, initiative leader, coordinator, family and community advocates, and educators at the Community Schools National Forum on May 2-4, 2018 in Baltimore, Maryland. The Coalition will also honor a long-time community school supporter with the Joy Dryfoos Community School Lifetime Achievement Award.
In an era dominated by our divisions, the selected awardees have partnered to work across boundaries of race, class, religion, institutions, disciplines, and programs to advance youth by bringing a multitude of services into schools and their communities. The awardees have partnered with local agencies to increase graduation and decrease chronic absenteeism rates, developed crisis response protocols, and created grassroots efforts to increase equity and engage families. Most importantly, all awardees have played a powerful role in the growth of community schools with their commitment to excellence.
Descriptions of the awardees are below. To learn more please visit Community Schools Leadership Awards Page.
William S. White is chairman and chief executive officer of the Charles Stewart Mott Foundation. Since 1935, the Foundation has been a major funder of community schools – first in its home community of Flint, Michigan, and ultimately in communities around the world. Mr. White has been an advocate for and supporter of the community school movement and related organizations and projects, including – over the past 20 years – the Coalition for Community Schools.
The National League of Cities (NLC) is dedicated to helping city leaders build better communities, working in partnership with 49 state municipal leagues, and serving as a resource and advocate for the more than 19,000 cities, villages, and towns it represents. NLC's Institute for Youth, Education, and Families has committed to continuously advocating for the growth of community schools and worked diligently with mayors to support their community school implementation.
Matt Wayne is the Superintendent of Hayward Unified School District. Dr. Wayne works to create deeper learning experiences, focusing on the whole child and meeting the diverse needs of students and families through the community school strategy. His dedication to partnering has increased graduation rates and lowered chronic absenteeism rates across the district. He also led the charge to pass a Sanctuary Schools resolution.
Jill Pereira's leadership of the United Way of the Greater Lehigh Valley's community school initiative has led to a significant growth from two schools with a $100,000 investment to 24 schools with a $6 million investment. Her work has also helped advance grade level reading across 125+ schools.
Jitu Brown is the National Director for the Journey for Justice Alliance, a network of over 40 grassroots community-based organizations in 31 cities organizing for community-driven school improvement. Mr. Brown has consistently used his influence and dedication to equity to advocate for community schools as the vehicle for change and is one of the leaders who has helped to raise community schools visibility to a national level.
Comunidad de Luz y Esperanza is a group of mothers from East Austin College Prep (EAPrep), proud and committed to helping EAPrep families and the communities throughout East Austin. Part of the Good Neighbor initiative from Southwest Key Programs and in strong partnership with EAPrep, Comunidad de Luz y Esperanza's grassroots and culturally responsive methods to increase equity and engage families has empowered parents to increase student achievement and build bridges across their community.
Clifford Hong has been the Principal of Roosevelt Middle School since 2010. Through his leadership and commitment to the community school strategy, Mr. Hong created a strong alignment between the school's academic program and community school partnerships. As a result, Roosevelt Middle School has made progress on academic, social-emotional, and civic outcomes, including lowering chronic absenteeism rate to 6.5%, and decreasing suspensions.
Deanna Hron is an Elementary Teacher and President of the Deer River Education Association. A committed believer in the community schools strategy, Ms. Hron implements the whole child approach in her classroom and leads her school in social-emotional learning and data best practices. Ms. Hron has exemplified strong leadership in advocating for community schools, testifying before the Minnesota Senate Education Committee, and working with a small group of committed community members to pass a school referendum to build a building that houses a Boys and Girls Club, senior center, and early childhood center.
The Coalition for Community Schools, an initiative of the Institute for Educational Leadership (IEL), is an alliance of national, state and local organizations in education K-16, youth development, community planning and development, higher education, family support, health and human services, government, and philanthropy, as well as national, state, and local community school networks. The Coalition advocates for community schools as a strategy to leverage local resources and programs, changing the look and feel of the traditional school structure to best meet the needs of children and families in the 21st century.


text:
FFXV North American Box Art Released
Jul 10, 2016 Kris Kittie
These covers will be featured on the games for PS4 and Xbox One.
Final box art is reversible with a plainer version on the opposite side.
The final version of the North American box art for the game Final Fantasy XV has been revealed. Initially Square Enix showed a nearly finished draft, but there is no doubt now about the finality of the product that they have unveiled now. This box art will be featured on the covers of the games for Xbox One and PS4.
What is fascinating about this particular box art is that it is reversible, with the final design on the front, and the classic simple design on the back. Colors have been adjusted for a richer, more finished picture.
Final Fantasy XV has also recently released a trailer discussing elements of its new universe. The game itself is slated for a September 30th release for PS4 and Xbox One. Square Enix has also discussed how they have decided to improve the performance of their newest installment in the Final Fantasy series.
FFXV-5


text:
Q: Removing newlines from ob_get_clean() output ok i do have this following codes
<?php
ob_start();
?>
codepad is an
online compiler/interpreter,
and a simple collaboration tool.
Paste

your code below,
and codepad wi
ll run
it and give you a short
URL you can use to share
 it in chat or email
<?php
$str = str_replace('\r\n','',trim(ob_get_clean()));
echo $str;
?>

and you can see how it works here
http://codepad.org/DrOmyoY9
now what i want here is to remove the newlines from the stored output of the ob_get_clean().
I almost looked around the internet on how to remove newlines in the strings and that's the common and fastest method to remove the newlines aside from using the slowly preg_replace().
Why this happens? is this already a bug? or i just missed something?

A: \r\n is windows style, but if the user using linux or mac, it would be different . so best solution is:
$str = str_replace(array("\r","\n"),'',trim(ob_get_clean()));

A: I think u miss one thing, it should be :
$str = str_replace("\r\n",'',trim(ob_get_clean()));

using double quotes not single quotes


You are a devilishly handsome wizard, who enjoys long walks on the beach.
You are minding your own business in your quiet home village.
Without warning hell minions appear with the diabolical intention of poisoning the village water supply!


text:
From heart wipe to HD, follow the evolution of production switchers and find one that's best for you.
JOHN LUFF
Movies usually portray the glamour of television with a shot of a large control room (usually at a New York network studio) with a passel of production people sweating over a newscast or awards show. A shot of the production switcher always makes the final cut because it epitomizes the glitzy, high-tech look the audience associates with television production. In fact, a close-up shot of a Grass Valley Group Model 100 production switcher actually appeared in one movie as the controls of a nuclear power plant.
Most live broadcasts involving more than a camera or two must use some kind of production switcher. Whether the studio is a location production truck that can accommodate only two people or a control room with 20 chairs in it, the production switcher is an essential element.
Those who want to upgrade to digital switching without replacing their old analog control panel may benefit from a solution like the Ross Video frame shown above.
A switcher has a number of inputs ranging from four to 80, which can be combined into a number of outputs, ranging from one to 50 or so. In a digital mixer, the software that mixes the inputs allows the usual range of cuts, wipes, dissolves, keys, effects, moves and fades in at least one, and as many as four, complex mix-effects banks. (This article focuses on digital switchers because few analog production switchers are sold new today.)
The first analog production switcher was a GVG device that predated 1966. At that time, Ampex, CDL, GVG. RCA and Vital all sold switchers. Today, GVG has been reborn for the third time, and the rest have disappeared, replaced by Echolab, Ikegami, Panasonic, Parkervision, Pinnacle, Ross, Thomson Grass Valley, Snell & Wilcox, Sony, Videotek and others. The number of models of switchers available from these companies and the range of options they offer is mind-blowing, producing results no one dreamed of in the mid-70s when Vital brought out the Sqeezoom (along with the highly valuable and still-available heart wipe).
With the introduction of digital switching based on software, the days of manual switcher setups have passed. (You might remember the literally hundreds of interacting pots in an Ampex AVC-4100 switcher. It was quite an art tweaking one up to high standards.) The capability of every basic switcher today is light years ahead of the most sophisticated switchers made a decade ago. Take the venerable GVG Model 100 as a base point and you will find many similar-looking digital switchers today. Compared to the original, each of these modern Model 100 look-alikes provides more functionality, the same or better reliability, and superior performance. And, in deflated dollars, they even cost less.
But all these choices present a problem: How do you select the switcher that's right for you? A good way to begin is by looking for the number of inputs you feel you need. Be sure to count key signals because most modern switchers don't segregate key inputs from primary video inputs. There are switchers as small as four inputs (for ENG applications), and as large as 80 inputs (available from Sony and Thomson Grass Valley). Effects systems range from simple key and dissolve effects in some ENG products to a full range of mix, wipe, key and DVE effects in one to four mix-effects (M/E) configurations.
If your facility has several control rooms, large and small, you should consider systems that allow you to standardize an operator interface (control panel design). This will allow your personnel to move easily from one room to another without retraining. Thomson Grass Valley offers the Zodiak and Kalypso series, and Sony has the MVS-8000/DVS-9000 series based on similar technology. Ross Video (Synergy one to four) and others provide a similar range of scalable products.
At one time, digital video effects were defined by a statement like, "What kind of ADO do you have?" Well, ADO is gone. But in its place is a range of digital effects systems integrated into the production switcher, and this trend has really caught fire. Not long ago, a four-channel DVE was considered huge. Pinnacle Systems' PDS 9000 has nine DVEs, Thomson Grass Valley has six dual video/video or video/key channels, and Ross has eight channels.
Still stores have also become a necessity in switchers. Some have capacities that make separate still stores unnecessary in many applications, with storage for literally thousands of uncompressed frames. This is a blessing for the budget, but a curse for the TD who has to operate it. Fortunately, some manufacturers provide a separate control panel that offers limited functionality for a second operator. If you have lot of stills and change them often, consider an outboard still store in addition to the very useful internal units.
GVG invented effects memory with EMEM a long time ago. Since then, every manufacturer has been able to come up with its own similar system while avoiding the patent attorneys. With a complex switcher, pay particular attention to how those setups are stored and recalled, and stored offline as well. Floppies are convenient, but a zip disk might allow you to off-load stills and save them with the rest of the setup for a program. In the sports-production business, many clients bring the setup for their entire show in on removable media so that the TD does not have to reprogram each effect in each truck.
HD and beyond
Technology does matter, and the evolution of technology leaves old products in the dust altogether too often. HD production switchers have been available for many years. Full-featured units have been available from Sony, Snell & Wilcox, Philips (Thomson Grass Valley) and others since the late '90s. A new crop of switchers that can handle a full range of standard definition and multistandard HDTV is now on the market. They provide the ability to use a studio to produce an HD program now and switch back to SD production at will. This may well be a key to getting wide acceptance for the cost of HDTV-capable systems.
Lastly, it would be unfair not to mention that Parkervision has innovated production with a system that includes a video switcher. The switcher can be timeline-driven using a technical script that includes not only the production-switcher events, but also the character-generator pages, script and teleprompter, and audio console. The era of automated news is here and, for many stations, the appeal of lower labor costs is irresistible.
John Luff is senior vice president of business development at AZCAR. To reach him, visitwww.azcar.com.
Send questions and comments to:john_luff@primediabusiness.com
It is interesting to note that video switchers are not sold as digital switchers anymore. Today, it's assumed that all switchers are digital, but of course
The coolest-looking item in any broadcast or large video facility is the production switcher. John Luff reviews the technology under the panels of these 100-button behemoths
Adding 3G and 3-D capability today is a smart investment for the future
Today's complex switchers have the functionality of entire control rooms.
It is clearly valuable to many stations and production studios to have hardware that can adapt to a 525 shoot today and a 1080 shoot tomorrow.
Digital production switchers have been on the market for many years now.
Over time, most technologies evolve to support the changing needs of the marketplace they serve. Television, in all of its incarnations, is no different.
Video routing is still the hub of all broadcast and production centers. An examination of multi-format, HD and SDI routing techniques and technology


Affordable, flexible and easy to use.
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Have you ever been in that situation when, during a board meeting, you are trying to present your idea but nobody seems to understand you? It is in those times that one of the best solutions to the issue would be to have a drawing board with which you can really show the concept in a way that allows other meeting participants to get a clear picture (literally) of what you're trying to present. We're not just talking about product concepts. It could be anything, from an idea for the next line of hair gel to an accounting concept that could secure the financial future of the company.
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Have questions? Ready to order? Contact Projector SuperStore today!


So sad to hear of Jean's passing, but rejoice in the fact that she's with her Heavenly Father, pain free. One of the sweetest people ever. She will be missed. We will be praying for peace and comfort for the family in the days to come. God Bless You.


I ordered an Odyssey battery for my UTV from autoplicity and I must say the price is by far the lowest from anywhere on the web. Great service and fast shipping!! They keep you updated throughout the whole process. Autoplicity will definately be my first stop for things here on out.


text:
JetBlue Foundation
Our future will be built by you: the brightest and most diverse students of today.
The JetBlue Foundation is committed to championing diversity in STEM education and creating career pathways for the next generation in aviation.
We invest in students from diverse backgrounds to create a lifelong interest in STEM.
We partner with organizations and communities to provide access to STEM programs.
We create equal opportunities for all students to spark a passion for STEM.
We build a more diverse talent pipeline for the aviation industry.
Learn more about what we do
Education Isn't Always Top of Mind After Natural Disasters, But It Should Be
When natural disasters strike, people and corporations are generous, donating millions of dollars worth of food, medicines and other needed supplies. But often, in the urgency to address immediate life-threatening realities, the long-term needs of rebuilding communities are overlooked. JetBlue and the JetBlue Foundation have invested in science, technology, engineering and math (STEM) education programs on the island for many years, as part of their focus on building a more diverse pipeline for the aviation industry.
Read More Link opens an external site and may not conform to the same accessibility policies as JetBlue.
Aviation High School Host "Sky Blue" Day
In a separate event related to National STEM Day, Aviation High School hosted a "Sky Blue" day with eight Crewmember volunteers from Tech Ops and JetBlue Foundation Ambassadors, who spoke at a student-led career panel in collaboration with Women In Aviation's Aviation H.S. Chapter. More than 40 students participated, and JetBlue volunteers toured the school after the panel, to check out the facilities and meet with students in various experiential shop classes.
Celebrating National STEM Day with Our Grantees!
November 8 was National STEM Day, a day focused on inspiring young people to explore and pursue careers in the fields of science, technology, engineering and math—and the JetBlue Foundation participated in a fantastic event with its grantee partners to commemorate the day.
At LSC, JetBlue hosted 18 students and two professors from the InterAmerican University of Puerto Rico Bayamón for a day-long program in which Crewmembers presented talks on different aspects of our operation. There were discussions about revenue management, air traffic control and fuel planning; a tour of the SOC; lunch and more.
Diversifying the Aviation Industry Through STEM Partnerships
The JetBlue Foundation say they're leading the charge to build a more diverse talent pipeline for the aviation industry, in partnership with groups like the Organization of Black Aerospace Professionals (OBAP). The JetBlue Foundation and OBAP hosted seven ACE Academy programs last summer. Many previous ACE alumni have gone on to land coveted internships with JetBlue and other corporate partners, some of which led to full-time careers.
The JetBlue Foundation Aims to Inspire Girls to Pursue Aviation Careers
Less than 3% of aircraft technicians and 7% of airline pilots are women, but we're out to change those numbers for good. We invited young girls to our 'Fly Like a Girl' event in BOS to learn about some of the many exciting careers in aviation. Our Female pilots, mechanics, and flight attendants greeted more than 40 girls ages 6-17 with a first-class glance at what it's like to be a woman in aviation.
Driving Interest in STEM
The JetBlue Foundation are key mentoring partners. Hundreds of JetBlue crew members are alumni of Aviation High School, and now they're paying it forward by regularly volunteering as student mentors and sponsoring field trips to New York airports


As a CEO of my business I sometimes think about "Mastery" and what this means.
How does one define Mastery?
How does one reach Mastery?
How can I hire people who have reached the level of Mastery?
How can I train or support training to help employees reach Mastery?
What kind of training does it take to reach Mastery?
How important is mastery and why the hell does this even matter?


The materials below reflect an effort to document the development of Sunoikisis. Grant proposals, meeting agendas, evaluation studies, and other materials continue to be added.
The Associated Colleges of the South ("ACS") receives $1.15 million grant from the Andrew W. Mellon Foundation for "Enhancing the Learning Environment Through the Use of Technology." It includes a proposal for a pilot project in classics.


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Linda Zhang '13 Receives Fulbright ETA T...
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Linda Zhang '13 Receives Fulbright ETA To Russia
Holly Foster May 7, 2013
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Linda Zhang '13 has been awarded a Fulbright English Teaching Assistantship to Russia. A Russian studies and comparative literature major, she spent the 2011 summer and fall semesters studying at Bard-Smolny College of Liberal Arts and Sciences in St. Petersburg and Yaroslavl' Pedagogical State University.
At Hamilton she is a SHINE English Tutor for refugees in Utica; president of the Russian Club; a Hamilton College Slow Food E-board Member and events coordinator; and a Community Farm member.
Zhang spent last summer at MYBlock in New York City as a film production intern.
The daughter of Yi Mei Huang of Brooklyn and Fan Zhang of Niagara Falls, she graduated from Stuyvesant High School.
Upon her return to the U.S., Zhang plans to pursue graduate study in comparative literature and Russian Studies and continue to teach and tutor English to immigrants and refugees.
The Fulbright ETA Program, an element of the Fulbright U.S. Student Program, places U.S. students as English teaching assistants in schools or universities overseas, thus improving foreign students' English language abilities and knowledge of the United States while increasing their own language skills and knowledge of the host country. ETAs may also pursue individual study/research plans in addition to their teaching responsibilities.
Sponsored by the U.S. Department of State, the Fulbright program is the largest U.S. international exchange program offering opportunities for students, scholars, and professionals to undertake international graduate study, advanced research, university teaching, and teaching in elementary and secondary schools worldwide.
315-859-4680 pr@hamilton.edu Working with Us
Former "Jans" Provide Advice Because Hamiltonians Sauté: Emma Laperruque '14 Former Hamilton President Honored


Annie is approximately 19 Inches. She is handcrafted of muslin, stained and baked in coffee. Her facial features are hand painted with love. She comes with her little gray kitty ornie and a primitive hang tag with a kitty on it. She has 100% raggedy red wool hair which is sewn on. Lots of hand stitching --- see the love that went into this one. She can sit unassisted or she can be hung. Signed and dated on her tummy.


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Who is the Greatest? Laver v Agassi
Readers of The Tennis Space have the opportunity to vote on who they believe to be the greatest male tennis player of all time. In the second of the semi-finals, Rod Laver plays Andre Agassi, with the winner to go through to play Roger Federer. This semi-final will finish at 5.30pm (London time) on Friday. NOTE: this is now closed with Laver going through with 62 per cent of the vote.
We selected eight greats to play in the quarter-finals of Who is The Greatest? In alphabetical order, they are: Agassi, Borg, Djokovic, Federer, Laver, McEnroe, Nadal, Sampras. What happened in the quarter-finals.
Rafael Nadal v Pete Sampras – Nadal went through into the next round, with 56 per cent of the vote.
John McEnroe v Roger Federer Federer went through into the next round, with 90 per cent of the vote.
Bjorn Borg v Rod Laver Laver went through into the next round, with 63 per cent of the vote.
Andre Agassi v Novak Djokovic Agassi went through into the next round, with 66 per cent of the vote.
In the first semi-final, Roger Federer 'beat' Rafael Nadal with 89 per cent of the vote.
Readers can vote in the poll on the right-hand side of this page and all other pages on The Tennis Space. The player with the greater percentage of votes will go through to the next round, to the final.
Taking into consideration the differences in equipment, opponents, and overall physicality of the game, I would say that Andre Agassi was the better "player". But then again, Rod Laver did accomplish some pretty lofty milestones that will probably still be around long after all of us are dust.


I've been into photography for a while now and lately motion time lapse has had my interest. Check out Timescapes.org for some awesome examples of what I'm talking about. Trouble is to get some of those amazing motion shoots requires motorized tracks and motorized pan/tilt heads all working together through software and it gets a little pricey.
Lately though some cool stuff is coming out to put those kinda shots into the reach of amateur guys like me. I posted earlier about the CineMoco motorized track system. With that you can build some great dolly movement into your shot. Now there's the Radian motorized pan and tilt system.
I found this on Kickstarter (my new favorite site, ha ha). And it's a really affordable, well thought out, pan and tilt system. All the little details are on the Kickstarter page and their page.
Basically you can get one unit, for only $150, and that's it, you can start to capture panning time lapse photography or video. Spend a little more and get a second unit and now you can pan and tilt. This modular approach allows you to just get what you want and save some cash. Down the road if you decide to upgrade just buy another unit and put them together, pretty sweet.
A sucker for gadgets I ordered a pair with the L brackets so I can do pan and tilt movements. Since they use standard tripod mounts I'll be able to combine this with the CineMoco track for full pan, tilt, and dolly movement. It's gonna be awesome!
So that's it, one way of getting some nice movement into your shot without breaking the bank. I guess the only bummer is that now I have to wait for the production run. I should have my hands on them January 2013. My CineMoco track will ship next month so I'll get some time to play with that before the Radians show up. Keep an eye out for some footage!
Got an on site demo of the new Yamaha CL5 today. We have a couple of M7CL's and LS9's and we have liked those. We were curious how the CL5 improved on the other consoles.
First impression is that the console is very similar to the M7CL consoles, just less faders on the surface. Almost the same center section with the knobs and touchscreen. You gain some extra knobs to the right of the screen and some buttons above the knobs on the left to make navigating a little easier.
The faders are all new and feel pretty nice. We did notice that a couple of the fader caps seemed too low and felt like they were rubbing the surface but this is a early production desk. Above the faders are digital channel labels and colored bars that you can customize to help organize things. Lastly there's a knob above each fader that can be gain, pan, or a customized setting.
We were playing with the CL5 which is the largest console in the new CL series. This has 16 input faders to the left, 8 input or bus faders in the middle, 8 bus faders to the right of the center section, a stereo fader and a mono fader.
The layout is pretty nice with lots of options. The input faders on the left can access all 72 inputs plus there's a couple of custom layers. The custom layers let you arrange inputs any way you want on one layer.
The center section can access all 72 input channels and all of the output busses. So you could have the left faders on inputs 1-16 and the center section on inputs 65-72 (or whatever). You don't have to switch layers on the entire desk at once, each section is switched individually. This lets you work how you want to work and keep what's important in front you all the time.
The right section is for output busses and VCA's, like the center section on an M7. Lastly the stereo and mono master faders are at the very end. Since the masters can be accessed though the other bus sections these can actually be changed to input faders if you want. For example you could have the Pastor's wireless mic and the backup podium mic always available on those faders. Then you always have quick access to those channels.
Sonically we didn't really get to put it through it's paces but it seems that Yamaha has done their homework. The head end consists of all new mic pres and the digital snake is handled by a Dante audio network. We were told that the built in dynamics and EQ on the channels are the same as the M7.
You get tons of graphic EQ's, factory plugins, and "premium" plugins that can be inserted all over. Graphics can be stereo 31 band or dual mono 15 band. The standard plugin rack has effects, eq's, and dynamics plugins that can be inserted. The "premium" rack has some Rupert Neve endorsed plugins that model classic EQ's and compressors. According to Yamaha they're the only console plugins that Rupert Neve will be officially endorsing. You can have up to 16 stereo 31 band graphics or 32 mono 15 band graphics, 8 standard plugins, and 8 premium plugins. A couple of the premium plugins take 2 spaces in the virtual rack due to the processing power needed.
Overall that's a lot of stuff built into the box that's all standard. The premium rack doesn't cost extra to unlock or anything like that. If that's not enough you can get cards and extra hardware for Waves plugins, Dan Dugan automatic gain control, and Lake processing. It's a pretty versatile desk and I like the fact that Yamaha makes it easy for their products to work with other 3rd party products.
Price wise it's very competitive. I didn't get any real quotes but the rep said that it's not a huge jump up from the M7, about 20% more. In that case it's kind of a no brainer considering the number of features that you gain. The only real drawback would be less physical faders on the surface. This means working with layers instead of having everything on the surface.
Overall we liked the console, it's got a lot going for it and it's a nice step up from the M7. Our Yamaha consoles have proven to be very easy to use and have rock solid reliability. They seemed to have spent a lot of effort addressing the audio quality which could be one of the few arrows to shoot at the M7 or LS9. If you're in the market for a new console in this price range it's definitely worth a look.
Cinetics launched their CineSkates about a year ago and now they have a new Kickstarter campaign. The CineMoco system is their new product line built around a dolly track system. What interests me is the Cinemoco device itself which can control the motorized wheels and the camera. Controlling these together can allow for some cool motion time lapse stuff.
The system looks pretty comprehensive, seems like they have done their homework. Price wise it seems pretty good compared to other motorized systems I've look at. Definitely worth checking out!
Update: I was wondering what the minimum step is on their motor system. I wrote them and they answered right away. They said their system can take steps as small as 0.1mm. So ultra-smooth time lapses shouldn't be a problem. I also noticed that you can purchase additional lengths of the SkateTracks for more moment if you want. I actually just pledged to pick up a system, ha ha, couldn't resist! They say I should have the system in October so keep an eye out for a hands on review!


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Furubotn, Eirik G.
FURUBOTN, Eirik G. American, b. 1923. Genres: Economics. Career: Rice Institute (now Rice University), Houston, TX, instructor in economics, 1949-51; Wesleyan University, Middletown, CT, instructor in economics, 1953-55; Rensselaer Polytechnic Institute, Troy, NY, instructor in economics, 1955-58; Lafayette College, Easton, PA, assistant professor of economics, 1958-60; Emory University, Atlanta, GA, associate professor of economics, 1960-63; State University of New York at Binghamton, professor of economics, 1963-67, chair of department, 1966-67; Texas A&M University, College Station, professor of economics, 1967-82, Private Enterprise Research Center, research fellow, 1996-; University of Texas at Arlington, visiting professor, 1981-82, James L. West Professor of Economics, 1982-96; visiting professor at universities worldwide. Publications: (with R.B. Ekelund and W.P. Gramm) The Evolution of Modern Demand Theory (essays), 1972; (with R. Richter) Institutions and Economic Theory, 1997. EDITOR & CONTRIBUTOR: (with S.A. Pejovich) The Economics of Property Rights, 1974; (with R. Richter) Some Views on Hospital Finance, 1988; (with R. Richter) The Economics and Law of Banking Regulation, 1990; (with R. Richter) The New Institutional Economics: A Collection of Articles from the Journal of Institutional and Theoretical Economics, 1991. Contributor to economic journals. Address: 750 N Rosemary Dr, Bryan, TX 77802, U.S.A.
Writers Directory 2005
"Furubotn, Eirik G. ." Writers Directory 2005. . Encyclopedia.com. 24 Jan. 2022 <https://www.encyclopedia.com>.
"Furubotn, Eirik G. ." Writers Directory 2005. . Encyclopedia.com. (January 24, 2022). https://www.encyclopedia.com/arts/culture-magazines/furubotn-eirik-g
"Furubotn, Eirik G. ." Writers Directory 2005. . Retrieved January 24, 2022 from Encyclopedia.com: https://www.encyclopedia.com/arts/culture-magazines/furubotn-eirik-g
Institutionalism , Institutionalism THE TEXAS SCHOOL OUT WITH THE OLD, IN WITH THE NEW THE IMPACT OF INSTITUTIONALISM BIBLIOGRAPHY The institutional approach to the eco… Institutionalism , Institutionalism The institutional approach to the economy had its genesis in the work of Thorstein Veblen, whose The Theory of the Leisure Class (18… Paul Anthony Samuelson , Samuelson, Paul A. 1915- BIBLIOGRAPHY If one could do a mental time-and-motion study of a modern economic theorist at work, a large fraction of what… Cliometrics , From a purely etymological standpoint, the term cliometrics should have a very broad meaning. After all, Clio was the muse of history in ancient Gree… economic , ec·o·nom·ic / ˌekəˈnämik; ˌēkə-/ • adj. of or relating to economics or the economy: the government's economic policy. ∎ justified in terms of profita… Sir John Harold Clapham , Sir John Harold Clapham The English economic historian Sir John Harold Clapham (1873-1946) established economic history as a significant and independ…
Fishback, Price V(anmeter)
HODGSON, Geoffrey M.
HANDS, D. Wade
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LINDBECK, (K.) Assar (E.)
DAWSON, George Glenn
Landsburg, Steven E(lliot)
Furtwängler, Adolf
Furtunǎ, Enric
Furttenbach, Josef
Furtseva, Ekaterina (1910–1974)
Furtsch, Evelyn (1911–)
Furthman, Jules
furthest
furthermost
furtherer
furtherance
Further Adventures of the Wilderness Family, Part 2
Furth, George 1932–
Furth, George 1932-2008 (George Scheinfurth)
Furth, George
Furtado, Juliana (1967–)
Furtado, Juli
Furtado, Celso (Monteiro) 1920-2004
Furtado, Celso (1920–2004)
Furtado, Abraham
Fürstner
Furstinger, Nancy
Furuhjelm, Annie (1854–1937)
Furuhjelm, Erik Gustaf
Furukawa, Makiko (1947–)
Furukawa, Masaaki
furuncle
furunculosis
furunculous
Furutani, Dale
Furutani, Dale 1946-
Fürüzan
Fürüzan (1935–)
furvous
Fury 1936
Fury and Hecla Strait
Fury on Wheels
Fury to Freedom: The Life Story of Raul Ries
Fury, David (A.) 1950-
Furyk, Jim
Furyū monji
furzy
fus.
Fusan
Fusar-Poli, Barbara (1972–)


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Ryan Giggs: I don't understand Marcus Rashford speculation
Posted by Steven Tan | Source from Manchester Evening News
Manchester United great Ryan Giggs admits he does not understand why there is any speculation around Marcus Rashford's future and believes he is at the right club to succeed.
Having impressed for England during the recent international break pundits and former players suggested Rashford should look to play his football elsewhere over fears he would not be given the opportunity at United.
Jose Mourinho gave an impassioned speech defending Rashford's playing time ahead of United's win against Watford in the Premier League and Giggs can't understand why there has been any discussion.
"He's a Manchester United player, he's from Manchester and he plays a lot of games so I don't see why there is speculation," Giggs told MEN Sport.
"He scored a couple of goals for England, but that doesn't mean anything. He's at the right club, United have a rich history of playing young players, so I'm not sure why all these people are debating whether he should leave."
Giggs was still working at the club when Rashford was handed his first team debut against Midtylland in 2016 and explained why the 20-year-old is a great person to have at the club.
"I'm a United fan and Marcus is someone who I love going and watching. I was at the club when he first got his debut and not only is he a great player but he's also a great character as well," he added.
And it's not just Rashford there's been speculation about since the start of the season. With United losing two of their opening three games there were reports of a crisis and mounting speculation that Jose Mourinho should leave, but Giggs believes there is no better man for the job.
"He is the right man for the job," Giggs said. "He's got good players and he's a good manager so I don't see where United would go after him.
"There's always going to be speculation about who can come in and who can replace but as far as I'm concerned they need stability."
And after back to back wins against Burnley and Watford the Wales manager is hopeful United can push on for the next part of the season.
"They've had two really good away wins at Burnley and at Watford and I expect them to climb up the table, because they've got an easy run of three of four games now and then all that sort of pressure will go away," Giggs said.
"It wasn't a great start but I expect us to go on a pretty good run now and the questions that are being asked to stop."
Giggs was talking to MEN Sport as he prepared to cycle 55km for Vimto to raise funds for Warrington Youth Club to celebrate their 110th brithday.
Giggs was joined by former Class of 92 team mate Gary Neville and 110 cyclists in Cheshire to tackle the challenge which raised £110,000.
"It's been a fantastic day and great to see Vimto's commitment to the local community, just as they support development of young football talent at the Salford City FC academy," Giggs said.
Related keywords: Marcus Rashford, Manchester United, Ryan Giggs, Jose Mourinho


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COVID-19 Vaccine May Not Work on Obese People
Even with COVID vaccines, people who are obese may still be a population who are highly vulnerable to COVID-19.
It has been reported that obesity is linked with risk factors for severe COVID-19 symptoms. Since March 2020, studies after studies have poured in from countries around the world reaching the same conclusion. People who are obese are more likely to die from COVID-19 than are those of normal weight, even when factors such as diabetes and hypertension are taken into account.
According to Nature Research Journal vaccines might not be as effective in people who are obese, a population already highly vulnerable to COVID-19.
About 42% of Americans are obese, which poses quite a challenge for the effectiveness of the long and dearly waited for COVID-19 vaccination. Around the globe, a general expectation is when we have the vaccine we will have a strong shield against COVID-19. For the obese, the bad news is vaccine may not be as good of a shield for as it is for non-obese people. It is already established that for people with underlying conditions COVID-19 could manifest complications. Obesity is linked with diabetes, heart disease and other risk factors for severe COVID-19 symptoms, so it is not just obesity but the conditions and diseases that generally go along with it.
Obesity is also linked to less-diverse populations of microbes in the gut, nose and lung; with altered compositions and metabolic functions compared with those in lean individuals. Those gut microbes can influence the immune responses to pathogens and to vaccines. This hypothesis is backed by studies of vaccines against influenza, Hepatitis B and rabies, which have show reduced responses in people who are obese compared with people who are lean.
However some researchers are still unconvinced that obesity will blunt the efficacy of vaccines because those studies on influenza vaccines were relatively small. Even if that is true, there might be ways to compensate for the vaccine shortcomings. One possibility is to give obese people extra doses of vaccine, maybe two or three injections instead of one.
There are currently three leading candidate vaccines currently being tested in large clinical trials. Unfortunately, the trials might not have samples that will allow it to determine whether obesity affects the vaccine response because it depends on who volunteers for the trial. It also depends on how well trial sponsors are at recruiting individuals from under-represented minority groups. In the end the world will still need to wait for data from clinical studies to draw conclusions. However, with the current studies showing an association between the severity of COVID-19 symptoms and obesity, hopefully it can push some governments and their health-care systems to tackle the growing obesity problems in their countries.
If you are at higher risk of COVID 19 complications due to obesity, it is never too late to start a weight loss journey. SureFiz will help you with our intelligent system and program that are all made based on proven studies around obesity. Give it a try now. SureFiz currently offers a limited promotion: subscribe for a 1-year plan and get a life-long plan and a FREE smart scale. Take advantage of it. Subscribe now. Start your weight loss journey and achieve your goals.
Source: Nature 586, 488-489 (2020)
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Charles Houchin (né le  à Lake Forest dans l'État de l'Illinois) est un nageur américain en activité, spécialiste des épreuves de nage libre.

Biographie

Palmarès

Jeux olympiques
 Jeux olympiques de 2012 à Londres (Royaume-Uni) :
  Médaille d'or au titre du relais  nage libre.

Championnats du monde
 Grand bassin

 Championnats du monde 2013 à Barcelone (Espagne) :
  Médaille d'or au titre du relais  nage libre.

 Petit bassin
 Championnats du monde 2010 à Dubaï (Émirats arabes unis) :
  Médaille d'argent au titre du relais  nage libre.

Jeux panaméricains

 Jeux panaméricains de 2011 à Guadalajara (Mexique) :
  Médaille d'or au titre du relais  nage libre.
  Médaille d'or au titre du relais  nage libre.

Records

Records personnels

Liens externes

Nageur américain
Nageur de nage libre
Champion olympique américain
Champion olympique de natation
Champion du monde de natation
Nageur aux Jeux olympiques d'été de 2012
Étudiant de l'université du Michigan
Naissance à Lake Forest (Illinois)
Naissance en novembre 1987