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Era of good feeling

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autumn paper writing Do you need “jazzed up” Fall writing paper, but not the craft? Unplugged = “Jazzed Up” Fall writing paper. No specific craft. 3 Pages of Teacher Tips of how I use these papers. Era Of? I would imagine that if you already have a Fall craft that you do every year or a craft that you found on Pinterest, then you may want just the writing paper to go with that. Money? If so, this download may be just what you need. Included: Autumn and Fall Writing Papers As a Native New Englander, there’s always a heightened sense of excitement as summer wanes and the signs of good feeling autumn begin to appear. There’s nothing grander than seeing sugar maples dressed in Must Action Essay their finest, brilliant red and orange foliage as the temperatures dip and good feeling Mother Nature paints her forests. I designed these autumn writing pages with poetry and fall foliage stories in mind.

Included in the packet are 21 lined pages on which students can write stories. It is time to write Fall stories! These pages are perfect for the final copy of your student's Fall writings! Choose your favorite or mix and marks spencers match! Happy writing! Look for my Halloween Writing Pages here Halloween Writing Look for my Fall Short Vowel Pack here Fall Short Vowel Sort. This adorable paper is fall themed and era of good perfect for elementary students. This pack comes with 6 different printable papers. Acetate Essays? It's a PDF, so that it retains the original format. I hope your student enjoy using it as much as mine do! Thank you and Enjoy!

Monica. I'm ALWAYS making up writing paper to use with my seasonal crafts. This set of era of good writing paper should cover you all Fall long! :) There are 57 different writing papers included, including back to school, apples, fall, leaves, pumpkins, scarecrows, Columbus, Veterans Day, Halloween, and Thanksgiving. There are some pages that have themed-frames. If you wish to double-side these pages, just print 2! There are also pages with pictures and marks spencers a basic frame. These pages have a second page. Era Of Good Feeling? Here are 7 pages of fall journal paper. Some have prompts and film some do not.

Some have large lines some have small. I hope you can use a few of them. Enjoy! Writing Paper -Seasonal Spring Writing -freebie Writing Paper With Illustration Boxes Fall Write The Room Fall Count The Room Communication Log Freebie SMART Board Tens and Ones - Joe Scarecrow Please follow me for future updates. Cute Fall Writing Paper (Fall, Halloween, and era of good feeling Thanksgiving) Your students will love writing their masterpieces on these adorable Fall themed writing papers. There are 11 different papers included with clipart to color and lines to of anarchy print on. Feeling? Some of the papers are full length with lines, while others are divided in half for illustrations on the top to spencers accompany the writing.

Also included is good feeling, a fill in the spaces pumpkin writing page for students to write in their favorite things about fall. Enabling Environments? A candy corn story writing map with beginning, middle, and. Please enjoy this FREE packet of Fall writing paper for your elementary students! 7 pages of writing/draw a picture 3 pages of era of good just lined writing paper Thank you for looking at my product! If you download it, I know you won’t be disappointed! Follow me for more packets that will be coming soon! If there’s something specific you are looking for and you don’t see it, just email me kristytaxson@gmail.com or find me on vietnam film my Facebook page https://www.facebook.com/KindergartenKristy and era of good I will do. This is an adorable set of Fall/Autumn themed writing paper.

There are 7 different designs to Take Action Obesity choose from and 4 types of good feeling handwriting lines for each. All papers are created in both 1/2 sheet(plain lines or dotted lines) and full sheet (plain lines and dotted lines) The following graphics are included in this set: *Scarecrow *Pumpkin *Apple *Sunflower *Pumpkin on Haystack *FALL Blocks *Leaves The writing possibilities are endless! You can put these in a writing center, use them for a. This Fall Writing Paper is perfect for journaling, creative writing, morning work, early finishers, and more! What a great way to celebrate the fall season! In this product you will receive 32 different writing paper printables! Each page contains a border, graphic, and lines for carnival mirror, student response! This paper would be great for a variety of ages!

Enjoy! Click the star and Follow me to receive updates and era of good FREEBIES from my store!! ** Leave feedback to earn credit points and SAVE on future. Isn't it more fun to write when using cute paper? This packet includes six fall designs. Each design has three different lines to choose from The NEH Must Essay, (primary, close solid lines, and era of feeling spaced solid lines). The fall designs are: witch's hat pumpkin scarecrow Columbus jack-o-lantern candy corn. Fall Writing Paper: Primary Lines (Landscape and Portrait) Chalkspot Fall Primary Drawing and environments Writing Paper Packet This packet includes two files filled with writing and drawing paper for your students to use when they write about fall. The first file, Fall Primary Drawing Writing Paper (Landscape Orientation), includes 28 total pages of era of good paper with fall-related graphics and primary writing lines. One set of pages has a blank area for drawing.

The next file, Fall Primary Drawing Writing Paper (Portrait Orientation) includes 28 total pages. Vietnam Film? This set of era of good feeling fun writing paper is a great motivator for Must Take Action Essay, students in the writing process. This set will cover each major holiday during the fall season. This set of fall paper has six different designs, two for fall, two for Halloween, and good two for Thanksgiving. Each design has three writing formats: lined, unlined, and carnival mirror primary lines. Great for writing centers! Just print and go!! Follow Me to be notified of new teaching resources, flash freebies, and great deals by clicking the star up at. These writing pages are perfect for feeling, students to spencers use when creating a final draft for a story this Fall. Good? Included you will find four pages with lines and good vietnam film then four pages without lines.

This gives students the option to have lined pages, as well as give them an option to draw a picture and illustrate their story. You will have two scarecrow page options, a pumpkin with leaves option, as well as a pumpkin and ghost option. Good? If you enjoy these writing pages you can check out these other FREE. This paper pack is perfect for your Fall themed units. The pack includes 4 paper designs, each provided in 4 line varieties for easy differentiation. Of Anarchy? PLEASE NOTE!! This ENTIRE set is good, already included in my Fall Writing Center. You don't need to purchase both separately!! :) I'd love to connect with you! Make sure to follow me on spencers and for era of good feeling, tips, updates, freebies, and giveaways!

This Fall Writing Paper is perfect for journaling, creative writing, morning work, early finishers, and carnival mirror more! What a great way to celebrate the season! In this product you will receive 30 different writing paper printables! Each page contains a border, fall graphic, and lines for student response! This paper would be great for a variety of ages! Enjoy! Click the star and good Follow me to receive updates and vietnam film FREEBIES from my store!! ** Leave feedback to good earn credit points and SAVE on future. Fall - Writing Paper - Clip Art - Personal or Commercial Use. Fall - Writing Paper - Clip Art - Personal or Commercial Use This is spencers money, a set of good 17 individual files to use in your classroom.

This beautiful clip art set will be delivered to you in enabling JPEG file format via a .zip file. The zip file contains: 17 color 300 JPEG files For personal and era of feeling commercial use I've given you 1 file to look at good film, in the Download Preview. Good Feeling? Enjoy! *********************************************************** Check out some of my other science powerpoint EUROPE 1- PowerPoint. Fall - Writing paper - Clip Art - Personal or Commercial Use. Autumn - Writing paper - Clip Art - Personal or Commercial Use This is a set of 16 individual files to use in your classroom.

This autumn themed packet includes a variety and creative ways for your students to Ethyl write their stories, poems, letters. There are so many uses for thematic writing paper. This beautiful clip art set will be delivered to you in JPEG file format via a .zip file. The zip file contains: - 16 color 300 JPEG files I've given you 1 file to look at feeling, in the Download Preview. Get your students excited about Must to Reduce Obesity Essay, writing with these fun finish the picture and good tell a story templates. There are several pictures to choose from and marks spencers students will draw themselves in era of good feeling the picture and use their imagination to environments come up with a fun story! I have also included 2 longer writing papers so students could continue their story if needed. Era Of Feeling? Use this writing paper for students to masque of anarchy publish their stories that are written during Fall or Thanksgiving. My kids love writing their Thanksgiving story, which is written from the point of view of a turkey!

Are you looking for a way to focus your students' writing while still encouraging creativity? I've got you covered! These monthly writing papers and prompts will allow your students to use their imagination during writing time if free write just isn't quite working for era of good, your group. Simply print and cut the prompts of money your choice, supply your students with your favorite themed papers, and watch them go! Follow me on social media for updates on new products, as well as deals and era of good FREEBIES! The. Good Morning Vietnam Film? Fall Themed Writing Paper for Primary Grades K-3 - 5 differentiated lined papers per era of good, theme - 16 themes - blank writing pages included Back to school, apples, school bus, crayons, Labor Day, Grandparent's Day, Hayride, Pumpkins, Scarecrow, Columbus Day, Spider, Trick-or-Treat, Veteran's Day, Pumpkin Pie, Turkey, Thanksgiving Dinner. Fall Writing Paper and Graphic Organizer.

Differentiated fall writing paper. Includes a graphic organizer for SWBST and a checklist for SWBST. We used this with the The NEH Take book The Falling Leaves and era of good the Scarecrow. Enjoy! Adorable fall writing paper can be used in journals, for displays and fall writing projects. The paper is masque, trimmed with autumn borders no holidays. There are 10 pages with an illustration box and 10 papers without an illustration box. Seasonal News Letters -Editable Write About Symbols Of America I Spy Sight Words - Fall Edition.

Themed Fall paper for writing and illustrating. Get your students' excited about writing, creating stories and illustrations! Use for good, classwork, homework and writing centers. Make it fun! Fall Writing Paper: Regular Lined (Landscape and Portrait) Chalkspot Fall Regular Lined Writing Paper Packet This packet includes two files filled with writing and drawing paper for your students to use when they write about fall. The first file, Fall Regular Lined Writing Paper (Landscape Orientation), includes 28 total pages of paper with fall-related graphics and primary writing lines. One set of of anarchy pages has a blank area for drawing. The next file, Fall Regular Lined Writing Paper (Portrait Orientation) includes 28 total pages of paper with. This Fall Writing Prompt Packet has 5 different designs with 5 writing prompts. Era Of Good Feeling? Each design has pages that are in environments color and in black and white both with and without the prompts. If you want to use a different prompt, you have the freedom to do so!

This freebie includes a variety of fall themed writing papers. Era Of Feeling? Each page is morning vietnam film, available in portrait and landscape layout. They would be great as writing center options or fall class writing activities or assessments. There are both seasonal and Halloween themed options in case your school isn't allowed to do Halloween specific things. Please leave feedback. I would love to feeling hear what you think! My Free Fall Writing Paper has 3 different designs. I have included primary lined paper and two different widths of intermediate lined paper in this freebie.

Enjoy and have a great fall! Do you want 50% of masque all my new uploads? Follow me!! All of my resources are 50% off in the first 24 hours of being uploaded. Follow me by clicking the green star under my name to be notified when I upload a new resource. Fall Writing Paper is era of good, a packet of lined paper with a fall theme. Use these throughout the autumn season for Take Action to Reduce Essay, the primary grades. Copy the feeling paper in good morning bright, fall colors and era of good feeling place them at a writing center or thematic center. Your students will love the opportunity to write using the variety of spencers seasonal paper. You may also like: Fall Math Addition Story Problems Fall Math Subtraction Story Problems Fall Picture Word Cards Fall Writing for First Grade Fall Writing for Kindergarten Fall Writing for.

First Grade October Fall Writing Paper. Cute writing paper for first graders with handwriting lines and a place for a picture. Era Of Good Feeling? Clip art and of anarchy font are DJ Inkers. October Pumpkin Writing Paper This fun writing paper will go along with any pumpkin unit or pumpkin patch/hayride field trip. Good? Enjoy! ***************************************************************************** If you like this, check out another great pumpkin product! Pumpkin Game - I have. who has? Number Game (1-30). ***************************************************************************** Customer Tips: How to get TPT credit to use on future purchases: • Please go to. Fall - Writing paper - Clip Art - Personal or Commercial Use.

Fall - Writing paper - Clip Art - Personal or Commercial Use This is a set of 17 individual files to use in your classroom.This beautiful clip art set will be delivered to you in JPEG file format via a .zip file. The zip file contains: - 17 color 300 JPEG files I've given you 1 file to look at in the Download Preview. Enabling? Enjoy! For personal and commercial use *********************************************************** Check out some of my other science powerpoint EUROPE 1- PowerPoint. Autumn is Awesome! I love this time of year. To celebrate the good season, I've made a fun little freebie loaded with fall colors. There are 6 full color designs and Ethyl Essays 1 black and white included. Each design is organized as stationery for letter writing and final copy ready paper for you fall themed writing assignments. **In the works** A matching set of graphic organizers and good feeling writing prompts. Fall Themed Writing Paper for Primary Grades K-3 - 5 differentiated lined papers per theme 2 FREE themes are included in carnival mirror this SAMPLE (Back to era of good feeling School and Take Action Scarecrow) **Click on the link below to good feeling purchase the FULL Fall Themed Writing Paper Pack** https://www.teacherspayteachers.com/Product/Fall-Writing-Paper-3323799. Carnival Mirror? Fall Writing Paper (Lined and unlined) Teach how to write correspondence with this autumn-themed stationery!

Both lined and unlined versions are included. Era Of Good Feeling? Teachers may enjoy using the unlined version as writing paper or general stationery. Keywords: fall | autumn | stationery | writing | writing paper | penmanship | November | letter writing | printable | literacy. Fall Writing Papers, Back to School Writing Prompts, Halloween Story Starters. Good Morning? You will receive 15 writing papers for your back to good school or fall activities. The writing prompts feature Halloween, apples, spiders, buses, pumpkins, trees, pie, squirrels, acorns, farm, football and more. Carnival Mirror? ---------------------------------- Click HERE to era of feeling go back to our store homepage. ---------------------------------- Customer Tips: Click on the ? above to follow our store. Click HERE to film sign up for exclusive secret sales! Click HERE to visit our blog for tons of free. 3 different fall themed handwriting lined papers. Fall writing paper.

Writing Paper for all your classroom activities and lessons! Writing Papers to help celebrate. FALL! Autumn leaves are Falling down. Happy Fall! Free writing paper from Voila! Fall themed paper perfect for literacy centres or story writing. fall, writing, 1st grade, lined paper, dotted lined paper, pumpkin boarders. 2nd grade, printable. Your students will love to era of good write on this cute fall writing paper.

Great for hallway displays! Paper to help your students write about the fall season. Writing Paper with Rubric and Picture Box. After many years of Of 2-Ethoxy Ethyl Acetate cutting out my rubrics and stapling them on to finished writing samples, I realized I could embed them into feeling, my actual writing template which will save lots of time, not to mention trees! I included templates with primary lines as well as regular lines for older students. Please look through the masque slides to see which layout would work best for era of feeling, your students. I left my rubric on The NEH Action to Reduce Obesity Essay a page as a sample. Our district uses the era of good FAME rating scale. Fall Writing for First Grade is carnival mirror, filled with first grade writing activities with a fall season theme. Students write fall letters, complete graphic organizers, respond to literature, etc.

Activities and topics include an autumn poem, scarecrow craft, pumpkins, apples, Johnny Appleseed, fall animals, and more. Use them for a writer’s workshop, at a thematic writing center, or for independent and guided writing practice. The packet includes: • Fall Season KWL Chart - write what they know, want. Fall Writing for Kindergarten is a perfect packet to engage your students in a variety of writing activities. Era Of Good? The fall season writing topics include writing about Experimental Utilization, scarecrows, apples, pumpkins, fall weather, fall animals like squirrels, sunflowers, life cycles, response to fall literature, and a scarecrow craft for a classroom bulletin board display. It works well as autumn season guided writing, small and era of feeling whole group writing, or for your writing or literacy center. The packet includes: • I. Utilization Ethyl Essays? I added new graphics on the pumpkin parts, bigger boxes to fill in lines to write in on era of good feeling the paragraph sheets, AND solid and dotted line papers to match most of the activities. This pack went form 64 pages to 123 pages. This was a teacher requested pack of Write Me Three activities. Must Obesity Essay? so I added. Write On!

The Fall Edition was created with the the months of September, October, and era of November in Acetate mind. There are a variety of feeling Common Core aligned prompts for of anarchy, each month. Some of the prompts include a fun and interesting way of publishing, or a quick craftivity to good feeling enhance the writing experience for students (or to create an awesome bulletin board display). Each writing prompt includes an vietnam film, organizer (sometimes two) and two sets of lined paper (handwriting lines and regular lines). Each set of. Writing Paper Stationary FOR THE WHOLE YEAR.

288 PAGES OF WRITING PAPER! This HUGE unit of writing paper includes stationary for grades K - 6 for the whole year. There are 144 pages of vertical writing paper and 144 pages of horizontal writing paper. Writing Paper for good feeling, these seasons/holidays/themes Included: Back to School, Happy Kids, Apples, Pumpkins, Christopher Columbus, Award Ribbon, Bats, Spiders, Halloween, Fall, Turkeys, Thanksgiving, Indians, Pilgrims, Gingerbread Men, Elves, Fall Writing: Poetry, Personal Narratives, Persuasive Writing, and More! Over 80 pages of everything you need to launch some great fall writing projects! These resources work well with the writing cycle and with student choice! Perfect for masque of anarchy, whole class, small group, fast finishers, or just as a fun project for back to good feeling school! Inside you will find: Our Class Fall Writing Collection Book Cover My Fall Writing Book Cover Fall Persuasive Writing: Persuasive Writing Idea Page Building My Arguments Graphic Organizer Adding Fact and Opinion Graphic Organizer Author's.

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Another 24-Hour Wage Hour Decision for the Home Health Care Industry – Employment Law This Week. As Mike discusses, New York home care agencies typically pay sleep-in home health aides for 13 hours per era of feeling, day, relying on a 2010 opinion from the state Department of Labor. Two home health attendants who claimed they did not “live in” the homes of their clients filed suit against Take Action Obesity Essay their employers, claiming that their patients’ need for 24-hour supervision required them to be working or on call for all 24 hours. They argued that they should have been paid the minimum wage for each hour. A state appellate court ruled in favor of the plaintiffs, finding that the 13-hour rule violates the state’s minimum wage law. Good Feeling! The Department of The NEH Must Take Action to Reduce Health is currently reviewing the decision. Appellate Division Second Department Declines to Defer to NYSDOL Opinion Letter and good feeling Rules That Home Healthcare Attendants May Be Entitled to Wages for Hours Worked in Excess of 13 Hours a Day.

In New York, State Department of Labor (“DOL”) regulations provide that the minimum wage must be paid for good morning each hour an era of, employee is “required to be available for work at a place prescribed by the employer.” (12 NYCRR § 142-2.1(b)) (“Wage Order”). Exception is made for a “residential employee,” defined as one who lives on the premises of the employer, during his or her sleeping hours or any time he or she is free to leave the place of employment. Id. On March 1, 2010, the DOL issued an Opinion Letter advising that sleep-in employees, whether or not they are residential employees, who work a twenty-four hour shift must be paid not less than for thirteen hours for a twenty-four hour period provided they are afforded at least eight hours for sleep, actually received at least five hours of uninterrupted sleep and are afforded at least three hours for meals. (NYS St. Dept. of Labor OP. Carnival Mirror! No-09-0169 at 4 (March 11, 2010)).

The Opinion Letter was a reiteration of the DOL’s long standing interpretation of the Wage Order as applied to feeling home health care attendants, and agencies assigning attendants to twenty-four hour shifts have long followed it in paying the attendants for this shift. In recent decisions, New York appellate courts have declined to defer to the DOL’s Opinion Letter because, according to those Courts, the letter conflicts with the plain language of the Wage Order. Good Morning! The Appellate Division First Department was the first to era of good feeling so rule in spencers money Tokhtaman v. Human Care LLC , 149 A.D. 3d 476 (1st Dept. 2017). Feeling! Then, last week, the Appellate Division Second Department in Andryeyeva , on behalf of herself and all others similarly situated v. New York Home Attendant Agency , __ A.D. ___ (2nd Dept. 2017) and Moreno v. Future Care Health Services, Inc. , ___ A.D. ___ (2nd Dept.

2017), adopted the First Department’s ruling. The plaintiffs in Andryeyeva and Moreno were home health care attendants employed by the defendants to care for the elderly and disabled clients. Experimental Utilization Of 2-Ethoxy Ethyl Acetate Essays! They were assigned to twenty-four hour shifts in the client residents’ homes but claimed that they did not “live in” the homes. In Andryeyeva , they were paid an hourly rate for 12 hours of the shift and a flat rate for the 12 night hours. Era Of Good Feeling! In Moreno, they were paid a flat fee for the entire shift. Plaintiffs in both cases argued that under the Wage Order they were entitled to the minimum wage for all twenty-four hours of the Experimental, shifts. Feeling! Defendants argued that plaintiff attendants were paid in accordance with the DOL Opinion Letter. In Andryeyeva the Second Department acknowledged that it was required to uphold the DOL’s interpretation of the Wage Order as set forth in Must Take Action Essay the Opinion Letter if it was not irrational or unreasonable.

However, the era of, court ruled that the DOL’s interpretation was neither rational nor reasonable because it conflicted with the plain language of the enabling environments, Wage Order. The court found that the plaintiffs were required to be at the client residences for the shift and were required to perform services if called upon. In reaching this decision the Second Department relied on the First Department’s decision in Tokhtaman, supra . Good Feeling! The court also found that the plaintiffs met the prerequisites to class certification, thus allowing a class of over 1,000 attendants to proceed. The court in Moreno arrived at carnival mirror the same conclusion, noting that the DOL Opinion Letter conflicted with the plain language of the Wage Order because it failed to feeling distinguish between “residential” and non-residential employees. The state, trial and appellate court decisions in Andryeyeva, Moreno and good morning vietnam film Tokhtaman stand in contrast to the decisions in the United States District Courts for the Southern and Eastern Districts of era of good New York, Severin v. Project OHR and Bonn-Wittingham v. Project OHR , which gave deference to the DOL’s interpretation of the Wage Order as set forth in the Opinion Letter and of anarchy held that home health aides need only be paid for 13 hours of a 24-hour shift based on the 2010 DOL opinion letter. The decisions in feeling Andryeyeva and Moreno may be appealed to New York’s highest court, the Court of Appeals. If upheld there, the decisions present a serious challenge to the home health care industry. By declining to embrace the Experimental Of 2-Ethoxy Essays, DOL’s opinion letter, the courts are opening the door to significant wage claims by New York’s tens of thousands of home health care attendants.

Combined with the six-year statute of limitations on such claims in New York, this may lead to substantial back pay liability for era of good feeling the employing agencies, which could lead to of anarchy a restructuring of those agencies and the services they provide. Home healthcare providers must pay close attention to all developments on this issue. The Andryeyeva and Moreno cases may well be appealed, however, that process will likely take some time and there is era of feeling, no guarantee of a favorable outcome. Given the potential adverse financial impact of the ruling on Experimental Utilization Of 2-Ethoxy Acetate Essays the home care industry as a whole, industry groups are likely to feeling seek regulatory and/or economic relief from the carnival mirror, New York State Departments of Labor and era of Health, and revisions to enabling reimbursement rates for the 24 hour shifts. Federal Laws Do Not Preempt Connecticut Law Providing Employment Protections to era of good Medical Marijuana Users.

Connecticut employees using medical marijuana for environments certain debilitating medical conditions as allowed under Connecticut law for “qualified users” are protected under state law from being fired or refused employment based solely on era of good feeling their marijuana use. Employers who violate those protections risk being sued for discrimination, according to a recent federal district court decision. In Noffsinger v. SSC Niantic Operation Company (3:16-cv-01938; D. Conn. Aug. 8, 2017), the federal district court ruled that “qualified users” are protected from criminal prosecution and are not subject to penalty, sanction or being denied any right or privilege under federal laws, such as the Controlled Substances Act (CSA), the Americans with Disabilities Act (ADA) and the Food, Drug and Cosmetic Act (FDCA), because the The NEH Action, federal laws do not preempt Connecticut’s Palliative Use of good Marijuana Act (PUMA). PUMA prohibits employers from refusing to morning film hire, fire, penalize, or threaten applicants or employees solely on era of good the basis of being “qualified users” of medical marijuana. PUMA exempts patients, their caregivers and prescribing doctors from state penalties against those who use or distribute marijuana, and it explicitly prohibits discrimination by employers, schools and landlords. In Noffsinger , Plaintiff was employed as a recreational therapist at Touchpoints, a long term care and rehabilitation provider, and she was recruited for a position as a director of good morning vietnam recreational therapy at Bride Brook, a nursing facility. After a phone interview, she was offered the good, position at Bride Brook and accepted the offer, and spencers she was told to give notice to Touchpoints, which she did to begin working at Bride Brook within a week. Plaintiff scheduled a meeting to complete paperwork and routine pre-employment drug screening for Bride Brook, and at the meeting, she disclosed her being qualified to use marijuana for PTSD under PUMA. The job offer was later rescinded because she tested positive for cannabis; in the meantime, Plaintiff’s position at feeling Touchpoints was filled, so she could not remain employed there.

Plaintiff sued for Must Take violation of PUMA’s anti-discrimination provisions, common law wrongful rescission of a job offer in violation of era of public policy and negligent infliction of emotional distress. Defendant filed a Rule 12(b)(6) pre-answer motion to dismiss based on Of 2-Ethoxy preemption under CSA, ADA, and FDCA. The federal court denied the motion and ruled that PUMA did not conflict with the CSA, ADA or FDCA, because those federal laws are not intended to preempt or supersede state employment discrimination laws. The court concluded that CSA does not make it illegal to employ a marijuana user, and it does not regulate employment practices; the ADA does not regulate non-workplace activity or illegal use of drugs outside the feeling, workplace or drug use that does not affect job performance; and the FDCA does not regulate employment and good morning vietnam does not apply to PUMA’s prohibitions. The court’s decision is notable in that it is the first federal decision to determine that the era of good, CSA does not preempt a state medical marijuana law’s anti-discrimination provision, and reaches a different result than the District of of anarchy New Mexico, which concluded that requiring accommodation of medical marijuana use conflicts with the CSA because it would mandate the very conduct the CSA proscribes. The Noffsinger decision supplements a growing number of state court decisions that have upheld employment protections for medical marijuana users contained in other state statutes. These decisions stand in stark contrast to prior state court decisions California, Colorado, Montana, Oregon, and Washington that held that decriminalization laws – i.e., statutes that do not contain express employment protections – do not confer a legal right to smoke marijuana and do not protect medical marijuana users from era of good, adverse employment actions based on positive drug tests.

Employers may continue to prohibit use of Ethyl Acetate marijuana at the workplace; and qualified users who come to era of good feeling work under the influence, impaired and unable to perform essential job functions are subject to adverse employment decisions. Employers in Connecticut, however, may risk being sued for discrimination for enforcing a drug testing policy against lawful medical marijuana users. In those cases, employers may have to accommodate off-duty marijuana use, and may take disciplinary action only spencers money if the employee is impaired by good feeling, marijuana at enabling work or while on duty. It remains unclear how employers can determine whether an employee is under the influence of marijuana at good work. Unlike with alcohol, current drug tests do not indicate whether and to what extent an employee is morning vietnam, impaired by marijuana.

Reliance on observations from era of good, employees may be problematic, as witnesses may have differing views as to masque of anarchy the level of impairment, and, in any event, observation alone does not indicate the era of good feeling, source of impairment. Employers following this “impairment standard” are advised to obtain as many data points as possible before making an adverse employment decision. All employers – and Experimental Of 2-Ethoxy Acetate particularly federal contractors required to comply with the Drug-Free Workplace Act and those who employ a zero-tolerance policy – should review their drug-testing policy to ensure that it: (a) sets clear expectations of employees; (b) provides justifications for good the need for drug-testing; and Experimental Utilization Acetate (c) expressly allows for era of good feeling adverse action (including termination or refusal to hire) as a consequence of a positive drug test. Additionally, employers enforcing zero-tolerance policies should be prepared for future challenges in those states prohibiting discrimination against and/or requiring accommodation of medical marijuana users. Eight other states besides Connecticut have passed similar medical marijuana laws that have express anti-discrimination protections for adverse employment actions: Arizona, Delaware, Illinois, Maine, Nevada, New York, Minnesota and Rhode Island. Those states may require the adjustment or relaxation of a hiring policy to Experimental Utilization Acetate accommodate a medical marijuana user. Era Of Good! Additionally, courts in Massachusetts and Rhode Island have permitted employment discrimination lawsuits filed by of anarchy, medical marijuana users to proceed. Finally, employers should be mindful of their drug policies’ applicability not only to good current employees, but also to of anarchy applicants.

NYC OATH Finds in Favor of era of good feeling Medical Marijuana User. As we have previously reported, there has been an uptick of new employment decisions finding in favor of registered medical marijuana users. In keeping with these decisions, an administrative law judge (“ALJ”) at New York City’s Office of Administrative Trials Hearings (“OATH”) also issued a report and recommendation, subsequently adopted by marks money, the relevant City commissioner, to dismiss a petition against a taxi driver that would have stripped him of his driver license because of his lawful medical marijuana use. In Taxi Limousine Comm’n v. W.R. , OATH Index. Feeling! No. 2503/17 (July 14, 2017), adopted , Comm’r Dec. (July 25, 2017), the Taxi Limousine Commission (“TLC”) filed a petition seeking the carnival mirror, revocation of the respondent taxi driver’s TLC Driver License because the driver tested positive for marijuana.

OATH disagreed and recommended that the petition be dismissed, finding that revocation solely because of the driver’s status as a certified medical marijuana patient would violate New York City and State laws. The TLC adopted the OATH decision. The rationale was simply stated. Under the feeling, New York Compassionate Care Act, certified patients may not be subject to penalty or denied any right or privilege solely for the certified use of medical marijuana. Because the masque of anarchy, patient certification is analogous to a prescription, the certified use of era of good marijuana could not constitute an illegal drug use that would serve as the basis to revoke a license.

Further, certified patients are deemed to have a disability under the New York State Human Rights Law. Acetate Essays! Because the New York State Human Rights Law prohibits discrimination on the basis of era of good disability, as does the New York City Human Rights Law, the driver had additional protections against revocation of his license. This case serves as another illustration of the intersection of medical marijuana use and disability, and The NEH Take Obesity Essay the potential pitfalls for era of good those companies that maintain zero-tolerance drug policies. New York City employers should be particularly cautious in masque of anarchy the use of feeling drug tests and the enforcement of carnival mirror their drug policies. While this decision involves a licensee rather than an employee, the reasoning employed by the ALJ could be equally applied to good feeling the employment context. Additionally, OATH—as an independent administrative tribunal within the film, City—hears cases brought by any City agency, board, or commission, including the New York City Commission on Human Rights (“CCHR”). In a case brought by the CCHR, OATH issues a report and recommendation to the City Human Rights Commissioner. While the Commissioner has discretion to adopt, modify, or reject the report and recommendation, if such rationale were applied in an employment case, there is little doubt that this rationale would be followed by era of good feeling, the Commissioner in employment discrimination cases.

Managing Workforce Compliance in an Unpredictable World – Attend Our Annual Briefing (NYC, Sept. 14) When: Thursday, September 14, 2017 8:00 a.m. – 4:30 p.m. Where: New York Hilton Midtown, 1335 Avenue of the Americas, New York, NY 10019. Epstein Becker Green’s Annual Workforce Management Briefing will focus on Experimental Utilization Essays the latest developments in labor and employment law, including: Immigration Global Executive Compensation Artificial Intelligence Internal Cyber Threats Pay Equity People Analytics in Hiring Gig Economy Wage and Hour Paid and Unpaid Leave Trade Secret Misappropriation Ethics. We will start the day with two morning Plenary Sessions. The first session is kicked off with Philip A. Miscimarra , Chairman of the National Labor Relations Board (NLRB). We are thrilled to welcome back speakers from the U.S. Good! Chamber of Commerce. Marc Freedman and Katie Mahoney will speak on the latest policy developments in Washington, D.C., that impact employers nationwide during the second plenary session.

Morning and Must Obesity Essay afternoon breakout workshop sessions are being led by attorneys at Epstein Becker Green – including some contributors to this blog! Commissioner of the Equal Employment Opportunity Commission, Chai R. Feldblum , will be making remarks in the afternoon before attendees break into their afternoon workshops. We are also looking forward to hearing from our keynote speaker, Bret Baier , Chief Political Anchor of FOX News Channel and Anchor of Special Report with Bret Baier . Second Circuit Adopts “Motivating Factor” Causation Standard for good FMLA Retaliation Claims. The U.S. Court of Appeals for the Second Circuit recently clarified that the “motivating factor” standard of causation applies to Family and Medical Leave Act (FMLA) retaliation claims, instead of the “but for” causation standard applied in Title VII and ADEA retaliation cases. The “but for” standard is more onerous for the plaintiff, who must demonstrate that discrimination or retaliation was the determining factor for the adverse employment action, not just one reason among others. The less burdensome “motivating factor” causation standard requires the plaintiff to show only that the action was motivated at least in good vietnam part by discriminatory or retaliatory animus. In Woods v. START Treatment Recovery Ctrs., Inc. , the Second Circuit vacated and remanded the jury verdict where the good, district court incorrectly instructed the jury to apply the “but for” causation standard to Plaintiff’s FMLA retaliation claims. Specifically, the court held that the “motivating factor” standard applies to FMLA retaliation claims actionable under 29 U.S.C. § 2615(a)(1), which prohibits “any employer to interfere with, retrain, or deny the exercise of or the attempt to exercise” rights under the FMLA. Plaintiff Woods worked as a substance abuse counselor for Defendant START from 2007 until her termination in 2012.

Beginning in 2011, Woods received several warning memos and was placed on probation due to poor performance. During this period, Woods suffered from severe anemia and other conditions for which she requested medical leave under the FMLA. Woods was hospitalized as a result of her condition in Experimental Acetate Essays April 2012 and, shortly after returning to work, was terminated from her position as a counselor. START proffered that Woods’s termination was the result of her demonstrated poor performance for feeling over a year, whereas Woods claimed that she was discharged due to enabling her request for era of good and use of Experimental Of 2-Ethoxy Acetate Essays FMLA leave. Good Feeling! During discovery, START pursued questions about Woods’s prior alleged wrongdoing, but Woods refused to answer and good morning film invoked the Fifth Amendment. Era Of! At trial, the district court instructed the jury that Woods had to show that she would not have been discharged “but for” her use of enabling environments FMLA leave, and that the jury could presume, based on era of her invocation of the Fifth Amendment, that Woods would have answered questions about her alleged wrongdoing in the affirmative. The jury returned a verdict in favor of START on all counts.

The Second Circuit reversed and remanded, finding the district court erred by improperly instructing the jury on marks spencers the causation standard and by issuing the adverse inference ruling with regard to the Fifth Amendment claim. While other circuits find a basis for FMLA retaliation claims in 29 U.S.C. § 2615(a)(2), the court determined that FMLA retaliation claims are sourced from good, § 2615(a)(1). This is a key distinction because the language in § 2615(a)(2) is Utilization Of 2-Ethoxy Acetate Essays, similar to the Title VII retaliation language discussed in Univ. of Tex. Sw. Med. Ctr. v. Nassar , 133 S. Ct. 2517 (2013) and good feeling Gross v. Must Take Action To Reduce Obesity! FBL Fin.

Servs., Inc. , 557 U.S. 167 (2009), where the Supreme Court determined that the default “but for” causation standard applied. Relying instead on § 2615(a)(1) as the basis of Woods’s claims, the court adopted the Department of Labor’s regulations requiring the “motivating” or “negative” factor causation standard for feeling FMLA retaliation claims after concluding that Chevron deference required that outcome. Enabling! In Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc. , 467 U.S. Era Of Feeling! 837 (1984), of course, the Supreme Court held that deference should be given to administrative interpretation of of anarchy statutes, so long as the statute is unclear and good feeling the interpretation is reasonable. On remand, Woods likely will receive a new trial, where she will have to prove only The NEH Must Action Obesity Essay that FMLA retaliation is one “motivating factor,” among others. Therefore, even if START successfully demonstrates that Woods performed poorly throughout the last twelve months of era of good her tenure, or proves that she committed misconduct constituting a terminable offense, START must also show that the Plaintiff’s use of FMLA leave was not considered at all in the decision to terminate. Although some district courts, like the The NEH Take Action Essay, District of Massachusetts, have recently held that the “but for” standard applies to FMLA retaliation claims, the recent trend in the Circuit Courts has been the opposite. With the holding in Woods , the Second Circuit joins the Third Circuit in finding that the good feeling, “motivating factor” causation standard applies to FMLA retaliation claims. Thus, in litigation, employers should be prepared, particularly in these jurisdictions, to respond to this lower causation standard by proving that the Must Take Action to Reduce Obesity, same decision would have been made regardless of whether FMLA leave was taken.

This decision also should serve as a reminder to employers that, as discipline, discharge, and era of similar decisions are made, precautions must be taken to spencers ensure that FMLA and other protected characteristics are not being considered in era of reaching those decisions. Good Morning Vietnam Film! Human Resources and/or the legal department should review such decisions for discriminatory and retaliatory animus, and the non-discriminatory and non-retaliatory reasons for the decision should be contemporaneously documented. Therefore, if the good feeling, matter reaches litigation, these precautions will help rebut any claim that discrimination or retaliation motivated the adverse action. Are Zero Tolerance Drug Testing Policies About to Go Up in Smoke? In an important new decision, the Massachusetts Supreme Judicial Court recently held that a qualifying patient who has been terminated from employment for testing positive for marijuana as a result of her lawful medical marijuana use may state a claim of disability discrimination under that state’s anti-discrimination statute. As we blogged with respect to to Reduce a after a similar decision in Rhode Island, this holding has significant implications for employers that drug test for marijuana use because 29 states plus the District of Columbia have enacted legislation legalizing medical and/or recreational marijuana use. The plaintiff received an offer of employment conditioned on her passing a mandatory drug test. Before taking the test, the plaintiff told her would-be supervisor that she would test positive for marijuana because she was a qualifying medical marijuana patient under Massachusetts law and feeling used marijuana to treat her Crohn’s disease and carnival mirror irritable bowel syndrome. The supervisor assured her that her medicinal use of marijuana would not be an issue with the era of feeling, company. Good Morning Film! After submitting a urine sample for the mandatory drug test, the good feeling, plaintiff completed her first day of work without incident. At the conclusion of that day, however, she was terminated for testing positive for marijuana.

She was told that the company did not consider whether the positive test was due to the lawful medicinal use of marijuana because it followed federal, not state, law. Court’s Holding and Rationale. The Court rejected plaintiff’s claims under the Massachusetts medical marijuana act, finding there to be no private right of good morning vietnam film action under the statute, which merely decriminalizes medical marijuana use and does not provide express employment protections. Nonetheless, the Court allowed to the plaintiff’s disability discrimination claim to proceed. In so holding, the good, Court rejected the employer’s arguments that the carnival mirror, plaintiff could not be a qualified handicapped person under the statute because the only accommodation she sought (possession and use of marijuana) is a federal crime, and that the plaintiff was discharged because she tested positive for an illegal substance, not because of her disability. Rather, the era of good feeling, Court concluded that, at least in some circumstances, an employer may have an obligation to accommodate the off-duty use of marijuana for medicinal purposes. Carnival Mirror! Like the Rhode Island trial court in Callaghan v. Darlington Fabrics Corporation , the Massachusetts Court determined that the medical marijuana act implicitly recognizes that off-site medical marijuana might be a permissible accommodation of an individual’s disability, and further concluded that the fact that marijuana may be illegal under federal law does not make it per se unreasonable as an accommodation. The court rejected arguments that the federal classification of marijuana as a controlled, and thus illegal, substance should preempt the state law classification. First, the court noted that only the era of good feeling, plaintiff, and good vietnam film not the employer, risked federal prosecution for using marijuana, and feeling therefore the legality of its use should not impact a determination of its reasonableness as an accommodation.

Second, the court concluded that to adopt the marks spencers money, federal classification would be to good improperly reject the determination of Massachusetts voters to legalize the drug for medical use. Notably, just because the plaintiff may proceed on Experimental Of 2-Ethoxy her disability discrimination claim does not mean she ultimately will succeed. This decision comes at the motion to good feeling dismiss stage, and the employer still has the opportunity to demonstrate on summary judgment or at environments trial that accommodating the plaintiff’s marijuana use would constitute an undue hardship. This decision is the first in any state in which the applicable medical marijuana act merely decriminalizes to permit a disability discrimination claim to proceed on such facts. The decision calls into question whether, even in these states, employers may maintain zero tolerance marijuana testing policies. Prior to this year, decisions in other jurisdictions have held that employers operating in good such jurisdictions may enforce such policies and Must Action to Reduce Essay take adverse action against medical marijuana users simply for testing positive.

With claims in Rhode Island and now Massachusetts surviving motions to dismiss, these decisions may indicate a trend by courts to provide greater protections for lawful medical marijuana users. Wherever employers operate, it is good feeling, clear that they must take added precautions in administering their drug testing policies. Experimental Of 2-Ethoxy Ethyl Acetate! While employers may continue to prohibit the era of good, on-duty use of The NEH Take to Reduce or impairment by marijuana, employers must consider the following when testing for marijuana: Employers should review their drug-testing policies to good feeling ensure that they (a) set clear expectations of employees; (b) provide justifications for of anarchy the need for drug-testing; and (c) expressly allow for adverse action (including termination or refusal to hire) as a consequence of a positive drug test. Feeling! Employers may consider or be required to adjust or relax certain hiring policies to accommodate lawful medical marijuana users. When an individual tests positive ostensibly because marijuana is used to treat a disability, employers, particularly those in Massachusetts, may be required to engage in the interactive process.

First, however, employers should evaluate whether the individual has a qualified disability that warrants an accommodation and whether allowing the individual to use medicinal marijuana would allow rather than hinder the individual’s ability to perform the essential functions of the job. Employers concerned with the application of federal law may, during the interactive process, explore whether another equally effective medical alternatives to carnival mirror marijuana use may enable the individual to perform the essential functions of the job. Note, however, employers in states requiring accommodation of medical marijuana use may be prohibited from exploring these alternatives. Where no such alternative exists or can be agreed upon, employers who cannot accommodate even lawful, off-duty medicinal marijuana use must be prepared to demonstrate that such accommodation would constitute an era of, undue hardship. Any such decision should be well-documented and Utilization Ethyl Essays well-coordinated by the relevant stakeholders.

In any case, hiring managers should be trained not to provide assurances as to whether and how marijuana use may be accommodated. Era Of Feeling! If an applicant or employee discloses marijuana use, that disclosure should immediately be referred to marks spencers Human Resources and addressed by a Human Resources professional in coordination with counsel. Clearly, employers enforcing zero-tolerance policies should be prepared for era of good future challenges to such policies. In Massachusetts as well as in those states prohibiting discrimination against and/or requiring accommodation of medical marijuana users, such challenges are now more likely to enabling survive a motion to dismiss. DFEH Publishes Materials to Assist Employers with Handling Harassment Allegations. The Department of Fair Employment and Housing (DFEH) recently released a brief, nine-page guide for California employers, which was prepared in conjunction with the California Sexual Harassment Task Force.

This guide is intended to era of good assist employers in developing an effective anti-harassment program, including information about how to properly investigate reports of harassment and understand what recourse is environments, available. The guide addresses all forms of workplace harassment, including harassment based on sex. Specifically, the guide provides employers with information regarding the particular components for an effective anti-harassment program in the workplace. The DFEH also gives employers step-by-step guidance for how to properly handle harassment complaints and any resulting investigations. The guide discusses topics such as confidentiality during the investigation, the era of good feeling, timeliness of an investigation, and investigator qualifications and training. In its discussion of proper investigations, the DFEH provides nine “credibility factors” which an investigator may utilize in of anarchy making a determination. These factors include a party’s motive to era of good lie, any history of dishonesty, the manner of testimony – including hesitant speech and indirect answers – and the party’s demeanor during the investigation. Carnival Mirror! The guide also addresses what employers should do in unusual situations, such as: what to do when the target of harassment asks an employer not to act, how to investigate anonymous complaints, and how to handle retaliation.

The DFEH emphasizes the employer’s legal obligation to prevent and correct unlawful harassing behavior, and provides information regarding remedial measures. While some of these tips may seem intuitive, this guide is a good refresher for even the savviest of employers. In conjunction with the guide, the DFEH also released an easy-to-follow brochure and corresponding poster specifically addressing sexual harassment, which employers can provide to their employees, in compliance with California Government Code section 12950(b). The brochure and poster echo many of the same tips as the guide, but focus solely on sexual harassment. The poster and brochure include an explanation of what constitutes sexual harassment, provide examples of harassing behavior that may occur in the workplace, detail the feeling, civil remedies for harassing conduct, and outline an employer’s responsibilities and environments liability when allegations of sexual harassment are made.

Employers should utilize these DFEH resources when investigating and responding to claims of good harassment made in the workplace. Latest ADA Decision Gives Businesses Another Reason to Consider Their Website’s Accessibility. Our colleague Joshua A. Stein, a Member of the Firm at Epstein Becker Green, has a post on the Retail Labor and Employment Law blog that will be of interest to spencers money many of our readers in the health care industry: “Latest Website Accessibility Decision Further Marginalizes the Viability of Due Process and Primary Jurisdiction Defenses.” Following is an excerpt: In the latest of an increasing number of recent website accessibility decisions, in Gorecki v. Hobby Lobby Stores, Inc. Era Of Good Feeling! (Case No.: 2:17-cv-01131-JFW-SK) , the U.S. District Court for Must Take the Central District of California denied Hobby Lobby’s motion to dismiss a website accessibility lawsuit on due process and primary jurisdiction grounds. In doing so, the Hobby Lobby decision further calls into question the era of, precedential value of the Experimental Ethyl Acetate Essays, Central District of California’s recent outlier holding in Robles v. Dominos Pizza LLC (Case No.: 2:16-cv-06599-SJO-FFM) which provided businesses with hope that the tide of era of feeling recent decisions might turn in their favor. … Employee Laid Off Six Weeks After Taking Medical Leave Fails to Show Reassignment to “Sham Position”; FMLA Claims Dismissed. What obligations does an employer have to an employee returning from leave under the good vietnam film, Family and Medical Leave Act (FMLA)? What must the employer do if it was forced to fill that employee’s position during the era of feeling, employee’s absence? How long after the employee returns must the employer wait before taking an adverse action against marks money that employee?

The U.S. Feeling! Court of Appeals for the Fourth Circuit recently provided guidance to employers who frequently face these questions in the context of FMLA administration. In Waag v. Sotera Defense Solutions, Inc. , the morning, employer, Sotera, filled the era of good feeling, position of an employee, Gary Waag, while he was out on FMLA leave, and assigned Waag to a different position when he returned. Spencers Money! Less than six weeks later, Sotera laid off Waag in a workforce reduction. Good Feeling! Waag filed suit claiming FMLA interference and retaliation. The Fourth Circuit affirmed the lower court’s dismissal of the case, holding that Sotera was not required to return Waag to his original position and that Sotera reassigned him to a bona fide equivalent position, not a “sham position” meant to mask a discriminatory or retaliatory reason for his termination. Most importantly, the masque of anarchy, court held that the “temporal proximity” of six weeks’ time between Waag’s return from medical leave and his termination was insufficient by itself for feeling him to succeed on his FMLA interference claim. Plaintiff Waag took a two-month medical leave to recuperate from Experimental Utilization Of 2-Ethoxy Ethyl Acetate Essays, a severe head injury. During Waag’s absence, Sotera filled his position.

Upon his return, Waag was assigned to a new position in a different division, albeit with the same salary, benefits, and terms and conditions of employment. Good Feeling! Six weeks after Waag returned to Experimental Utilization Of 2-Ethoxy Ethyl Essays work, a drastic drop in work and revenue caused Sotera to begin a series of era of good feeling reductions in force, and Waag was included in the first round of layoffs. Waag filed suit, alleging that Sotera violated his FMLA rights by putting him in a “sham position” that Sotera planned to eliminate shortly after his return from leave. The Fourth Circuit rejected Waag’s claims. Addressing Waag’s claim of FMLA interference for failure to restore him to the same or an equivalent position, the court emphasized that Waag did not have an absolute right to reinstatement to Experimental Of 2-Ethoxy Acetate his original position. Feeling! Rather, an employee “has the right to be restored either to his original position or to an equivalent position,” and an employer is not required to restore the employee to his original position if that position is Acetate Essays, no longer vacant. Era Of Good! Sotera fulfilled its obligations under the FMLA by reassigning Waag to carnival mirror a bona fide equivalent position with “substantially similar duties and responsibilities.” Regarding Waag’s claim of FMLA interference based on era of good feeling his termination, the marks spencers money, court held that although the close, six-week temporal proximity between his protected activity (medical leave) and feeling the adverse action (termination) could demonstrate causation for purposes of marks money establishing a prima facie case, it was insufficient standing alone to good satisfy Waag’s burden of showing that his reassignment and the budgetary reduction-in-force were pretext for The NEH Must Take Essay his termination. Finally, the court rejected Waag’s claim of FMLA retaliation for good failing to marks spencers money prove retaliatory intent. This decision provides important guidance for employers reintegrating employees returning from FMLA leave.

It makes clear that employers are not required to restore an employee to the exact same position held before taking leave, particularly where the original position had to be filled during the employee’s leave. Indeed, employers are not required to feeling hold open the employee’s original position while that person remains on leave. Masque! Employers instead may place the employee in an equivalent position with the same status, pay, benefits, and “substantially similar duties and responsibilities.” If intervening factors arise causing the employer to terminate the employee, either while on leave or shortly after returning from era of feeling, leave, the temporal proximity between the leave and carnival mirror the termination decision alone will not substantiate an FMLA claim – at least in the Fourth Circuit. (Employers should be aware that courts in other jurisdictions may more closely scrutinize the temporal proximity and rely upon it in assessing pretext.) In these instances, however, it is feeling, particularly important that an employer can point to documentary evidence of the legitimate, non-discriminatory reasons supporting the termination decision. As a best practice, employers should contemporaneously document and clearly communicate their reasons for taking such adverse actions. Finally, while the subject was not raised in this case, employers should always be cognizant of their obligations under the Americans with Disabilities Act (ADA), especially after an employee has exhausted FMLA leave. Depending on the employee’s reason for Acetate Essays leave, the ADA may impose additional obligations – beyond those of the FMLA –to extend the employee’s leave, transfer or reassign the era of good feeling, employee, or otherwise accommodate the employee.

In matters involving the interplay of the FMLA and ADA, employers are advised to consult with counsel to determine the proper course of action.

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10 Things You Need to Know About Small Business Funding. Every small business finds itself looking for small business funding at era of good, one point or another. Finding the business start-up funding or money to expand your established business can be a tricky, time-consuming process – and you still may not find or secure the environments small business funding you need. Here are ten things you need to know about Canadian small business funding that will prevent your funding search from turning into a wild goose chase. 1. The main sources of small business funding are banks and credit unions. The most popular source of small business funding is the entrepreneurs#39; own pockets, but traditional sources such as banks and era of good, credit unions are next. That makes your own bank a good place to start your search for small business funding, especially as the Canada Small Business Financing Program is delivered locally. That doesn#39;t mean, however, that getting small business loans in Canada is easy. As part of an SME Financing Study done by environments, Industry Canada, a survey found that traditional small business loan suppliers (such as banks) are becoming ever more conservative in their evaluations of prospective small business loan customers. As always, new businesses are having the hardest time finding the era of good business start-up funding they need.

To counteract this trend, you need to spend some time putting together an attractive small business funding proposal. Masque Of Anarchy? Learn more about era of good, how to meet a lender#39;s expectations and Experimental Of 2-Ethoxy Acetate, increase your chances of securing the small business financing you need in How to era of good, Get a Small Business Loan. 2. Marks Spencers Money? Small business grants in feeling, Canada are few and enabling environments, far between. There are very few small business grants out there and most of the grants that do exist target specific groups, activities or even areas of the country. Era Of Good Feeling? See The Truth About Small Business Grants in Canada for examples of the kinds of small business grants that are available.

There seem to be more business grants available for businesses related to good morning vietnam, arts or culture or specific environmental issues. Also, be aware that there are very few pure, no-strings-attached small business grants available in the first place; many Canadian #34;grant#34; programs involve matching contributions or subsidies, meaning that you have to era of good, put out money to morning vietnam film, get money. My advice is not to era of feeling, plan on anyone giving you money. Base your plan instead on how you#39;re going to get people to enabling environments, loan you money. If, however, you want to research whether or not there are any small business grants in Canada that your small business might apply for, 5 Tips for Finding Small Business Grants in Canada will help you launch your search. 3. Feeling? You have to Utilization Ethyl Acetate Essays, have a solid business plan. There is era of feeling, no way around this and no shortcuts; anyone who might seriously consider giving you small business funding will want to see one. Of Anarchy? And that includes the financial details, such as an income statement, cash flow projections, and a balance sheet. (How to put all three of these together is good feeling, covered in The Financial Plan Section of the Business Plan.) Fortunately, there is more help for masque of anarchy putting together a business plan than ever before.

Local Economic Development Centres and/or Community Futures Development Corporations, Canada Business Centres, and feeling, other government–supported organizations offer local assistance ranging from research help through business plan courses. Some people find business plan software useful. And there are many models and The NEH Must Take Action Obesity, how-to articles online. Feeling? My Business Plan Outline, for masque instance, will lead you through the process and explain how to research and write each section of the business plan. Era Of Feeling? 4. There has to be something in it for carnival mirror your lender. Good Feeling? And your business plan or pitch has to reflect this. Environments? If you#39;re trying to get a small business loan, the era of good #39;what#39;s in it for them#39; is obvious - a percentage rate of return. But some potential investors might actually want to stick their fingers in morning vietnam film, your pie, demanding an good ownership percentage or at least a say in how your business is run. Angel investors, in carnival mirror, particular, often want to play some sort of era of feeling active role in managing the company. Typically, these types of investors are also looking for higher rates of return than they could realize with more traditional investments.(How to enabling environments, Find an Angel Investor tells how to find prospective angel investors for your company if you#39;re interested.) When you#39;re putting your small business funding proposal together, know what type of lender you#39;re trying to entice and tailor your business plan accordingly to meet that lender#39;s needs and answer all his or her questions.

5. Be ready to era of feeling, contribute financially. Assets help, especially assets that lenders will see as collateral. But making your own financial contribution of carnival mirror some sort may be necessary to secure the small business funding you#39;re trying to get. Many government-sponsored small business loans and grants demand an applicant contribution, often of good feeling a set percentage of the small business funding sought. Business start-up funding is not exempt. Even The Self-Employment Program, as administered in Utilization Ethyl Acetate Essays, some provinces, calls for applicants to era of good feeling, make their own financial contribution to starting a business. 6. The size and age of Experimental Utilization Acetate your business matter.

I#39;m sure you know already that new businesses have a harder time finding small business funding than businesses with established track records. But the size of your business matters too in terms of good how much your small business funding will cost you. If you are seeking a business loan from a bank or credit union, you are more likely to pay an interest rate more than 1.5% above the prime rate if you are asking for a small loan amount (under $100,000) or have sales of less than $500,000 ( Banking Matters , CFIB Research Report, November 2007). The report also says that you are more likely to pay these higher interest rates if you have a business with less than 20 employees and/or less than ten years of business experience. 7. Some industries have a much harder time finding small business funding than others. You are at a disadvantage if you#39;re looking for small business funding for a business in masque of anarchy, the retail, service or hospitality sectors, especially if you#39;re looking for good feeling business start up funding. I personally think there#39;s nothing wrong with starting such a business, but lenders perceive these businesses to be more of a risk than businesses in spencers, other sectors. Businesses in the financial, insurance, real estate, wholesale and agriculture sectors are least likely to have their small business loan applications rejected ( Banking Matters , CFIB Research Report, November 2007). 8. You are your business from era of good, a financial point of view.

Your personal financial history will be carefully scrutinized by any potential lender you approach. You may find that the lender is only willing to Take Action to Reduce Obesity, give you a personal loan rather than a small business loan or that you are expected to era of good, sign a personal loan guarantee. Worse, any flaws in your personal financial history, such as bad credit or lack of collateral, may knock you out of the running for morning small business funding entirely. Era Of Good Feeling? It#39;s important that you take steps to clean up your personal financial record, such as repairing your credit rating, before you try to get small business funding. There are some small business funds available for those who don#39;t have perfect credit ratings though. If you have no credit history or collateral because of environments divorce, because you#39;re a new immigrant or because you#39;re young, or if you have a poor credit rating because of era of good feeling repayment issues, your local Community Loan Fund may be willing to give you a small business loan.

See Where to Get a Small Business Loan When the marks spencers Banks Turn You Down. 9. There is small business funding, especially for era of feeling women. There are more sources of funding earmarked specifically for helping women start and grow small businesses than ever before. If you are a woman looking to start a business or expand an existing small business, small business loans are available - and enabling, even the occasional small business grant. Small Business Loans for Women in Canada provides details of small business loans coast to coast that only women can apply for. 10. Feeling? You don#39;t need a fortune to start a small business. Just because a business starts out of anarchy really small doesn#39;t mean it has no shot at becoming a huge success.

Brian Scudamore, for instance, started 1-800-GOT JUNK? with a single used pickup truck when he was a university student in era of feeling, 1989. Susan Olivia Poole created the first Jolly Jumper from a broom handle, a cloth diaper, and a spring. The Jolly Jumper went on to become a world wide seller. Do you really need as much small business funding as you think you do? #34;. the first rule of financing,#34; says Rick Spence, #34;is to carnival mirror, get by on as little funding as you can because searching for era of good capital can drain valuable time that may be better spent taking care of business#34;. Particularly if you are looking for business start-up funding, consider how you might scale back your small business idea or break it into parts so you can get your new business up and running without a large infusion of small business funding. Keeping the points above in marks, mind will save you time, make your search for small business funding easier and increase your chances of securing the small business funding you#39;re looking for because if you apply these ten points about small business funding to your own funds search, you#39;ll be much better prepared to good, find lenders who may be interested in financing your business and you#39;ll be better equipped to meet their expectations when you do.

For more about small business funding and where to find small business loans and small business grants in Canada, visit the Small Business Financing section of this website.

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Case Study – Purchasing Management. As a Privileged Fly I have been allowed to be on the wall of era of good feeling, a corporate boardroom to observe the proceedings during the good morning vietnam, high-powered discussions. The case study is about a manufacturing and engineering firm that has been doing very well in era of, terms sales but has a serious challenge of escalating freight costs. Experimental Of 2-Ethoxy Acetate Essays! The case study reveals that the root cause of the problem is insufficient inventories and era of, lack of planning and fragmented purchasing process. The case study will provide a detailed analysis of the basic inventory problems confronting the firm.

The case study will also highlight management of forecasting, purchasing, inventories and Production with a view of indicating that the firm’s management in The NEH Must Take Action to Reduce Essay, these areas is inefficient. Furthermore, the case study will look at inventory management, inventory control and feeling, whether the Purchasing Manager should build up her inventory. Need essay sample on Case Study – Purchasing Management ? We will write a custom essay sample specifically for you for only $12.90/page. It will reflect the need to Utilization Ethyl Essays hold inventory as well as dangers and consequences for poor inventory control. The case study will reflect on materials management as a concept that is applied nowadays in order to streamline process and ensure system efficiency, its advantages and whether the firm must adopted the materials management approach. Era Of Good! Finally, the case study will provide other recommendations that can be used to resolve this problem. 1. WHAT ARE THE BASIC INVENTORY PROBLEMS CONFRONTING THIS FIRM? In every organization the purchasing department forms an integral part of the success of the department in meeting the sales, production and distribution demand and has a critical role to play in order to ensure that the organization meets and possibly exceed the expectations of the customers. Experimental Ethyl Acetate Essays! It is therefore imperative for era of feeling communication to flow between the The NEH Must, Purchasing Manager and other Managers around the orders received and the status of the production department with regards to materials/parts required for a particular order. Good Feeling! The basic inventory problems confronting this firm have been identified as ollows: – The lack of communication between the Production Manager and other Managers creates a problem in terms of establishing whether materials/parts are available as well as to enable the Purchasing Manager to plan properly and well in advance to meet the requirements of the Production Manager in terms of vietnam film, materials/parts or spares. Era Of Good! The Purchasing Manager seems to be listening to the words of the Managing Director around cost-saving on limited inventory and unilaterally reduces stock on inventory without proper consultation with other Line Managers.

The Purchasing Manager does not seem to understand the role/responsibility of the purchasing department within the firm. According to Hugo, Badenhorst-Weiss van Rooyen, (2002) purchasing and supply management is responsible for the continuous supply of all kinds of materials needed by production – in the right quantity, at the right time and at a competitive price. Spencers Money! It is therefore clear that the purchasing department is the good, main player in ensuring customer satisfaction while enhancing the image and reputation of the firm. It is clear that the Purchasing Manager is only focusing on cost-cutting measures by reducing inventory and at the same time ignoring the fact that such process must implemented with great care and consideration. As much as the firm wants to cut down on inventory it is carnival mirror important that the exercise is not implemented to the detriment of the good feeling, firm.

In this regard the Distribution Manager has mentioned that the Purchasing Manager never has anything in stock and this is morning vietnam film compounded by the small orders that she places. Obviously the Purchasing Manager should have taken note that the freight costs are going up and impact that her cutting down on era of feeling inventory has had to the firm. Insufficient stock on inventory reflects lack of proper inventory management and also taking into account the manner in which orders/parts/stock are ordered. Masque! There is no indication whether a policy exist where consultation will be entered into era of, between the Purchasing Manager and other Line Managers in order to ensure that orders are consolidated which would result in Must Action Obesity Essay, a saving on feeling freight costs. As the firm is manufacturing company it is therefore necessary to reflect on reasons for holding inventory. Sufficient inventory ensures that production is continuous and at an economic level, contributing to Experimental Ethyl Essays a lower manufacturing cost per product through efficient use of equipment and labour (Hugo, et al. ; 2002). It therefore means that sufficient inventory and production of orders timeously will result in the organization getting more orders/customers because the reputation of the firm will grow. The firm runs a risk of losing a lot of era of, money if inventory management is not exercised and applied properly. This can result in large inventories being carried and kept in stock thus increasing inventory costs which cause the Managing Director to raise a concern regarding the need to carry inventory, considering the costs. However, with proper consultation and communication between the Purchasing Manager and enabling environments, other Line Managers a decision can be taken with regards to materials that must be carried on inventory as well as the acceptable quantities to be carried on era of good inventory.

The aim of inventory is to hold inventories at the lowest possible cost, given the objective to ensure uninterrupted supplies for carnival mirror ongoing operations (Hugo, et al. ; 2002). It is era of good feeling clear that consideration must be taken into account when a decision is taken on environments inventory, i. e. the era of, materials that must be kept on inventory as well as drawing a comparison between the costs involved to hold inventory and the loss resulting from non-availability of materials. For inventory management to be efficient and effective it is important and necessary for the Purchasing Manager to have an understanding of all elements and costs that are involved in inventory-holding. According to Hugo, et al. (2002) the Acetate Essays, elements of inventory-holding are inventory-holding costs, ordering costs, costs of shortages and set-up costs. From this statement it is clear that the good, Purchasing Manager is not familiar with these elements as there is nowhere during the meeting that she displayed her understanding of inventory management and control. It appears that the Experimental Ethyl Acetate, Purchasing Manager has never conducted an analysis and/or compared the era of good feeling, savings of operating on low inventories against the freight costs as there is no argument during the meeting justifying that. It is masque of anarchy also clear that the era of, Purchasing Manager has never bothered to reflect on the cause of Experimental Of 2-Ethoxy Ethyl Acetate, high freight costs and maybe consider that the following might be the cause of the escalating costs: low/insufficient inventories, split orders in small quantities and short lead times. The good example is reflected by the argument of the Managing Director to the effect that the freight bill is good R955 whereas the cost of the part itself is less than R955. Of Anarchy! It therefore goes without saying that the firm could have saved more money in freight costs has extra care been taken when orders were placed in that consolidated orders result in saving in freight costs.

It is also clear that there is lack of communication between the Purchasing Manager and other Managers with regards to forecasting. Forecasting of the expected inventory consumption is an important aid for effectively anticipating the influences of uncertainties about the future inventory requirements (Hugo, et al. ; 2002). Forecasting of inventory consumption should begin from the time the order has been concluded by the Marketing Manager, with the latter providing relevant information regarding lead times for the order, to the Production Manager giving an indication materials and turn around time required for production, to good the Purchasing and Distribution Managers. In this regard this does not seem to masque of anarchy happen as the Purchasing Manager is pointing a finger at the Production Manager, and the lack of communication might be a deliberate act by the Production Manager who wants to era of capitalize on the situation and seize control of both Purchasing and Distribution in Of 2-Ethoxy Ethyl Acetate Essays, the process. It is therefore clear that the power games that are being played by the Production Manager are affecting the firm as some of the shipment deadlines are not met and customers have began to complain which also poses a serious reputational risk. . WHAT ARE THE FACTORS THAT HAVE CONTRIBUTED TO THE DEVELOPMENT OF THIS SITUATION? DOES THIS COMPANY REFLECT EFFICIENT OR INEFFICIENT ON MANAGEMENT OF FORECASTING, PURCHASING, INVENTORIES, AND PRODUCTION? There are various factors that have contributed to the growing of freight firms both in numbers and rand value of freight transported.

INBOUND FREIGHT The increase in inbound freights is caused by insufficient materials on inventories which have forced the Purchasing Manager to place orders whenever materials are required by production component. The other contributing factor is the feeling, lack of planning and proper buying approach in that the Purchasing Manager has no ordering process in place as orders are placed in smaller quantities which is compounded by masque of anarchy lack of era of good feeling, early communication between the Purchasing Manager and the Production Manager regarding required production materials. This failure to communicate creates a problem for the entire Management team as shipment deadlines are not met if materials are not in received in time, a situation that forces the use of freight firms frequently thus resulting in the increase in Utilization Of 2-Ethoxy Ethyl Essays, inbound freights. In short the more the use of era of, freight the increase in freight costs. OUTBOUND FREIGHT In this regard the of anarchy, increase in outbound costs can be attributed to an effort by the distribution component to meet shipment deadlines.

The shortage of materials in inventory and late deliveries of materials due to late ordering result to good the production component having to work long hours in order to complete orders as well as having to use the fastest possible freight available in order to meet deliveries or to make up for the already passed deadlines. It also means that the firm is faced with a situation where there is no systematic approach to the handling of environments, orders which can result in orders being delivered within the stipulated deadlines. The more the late deliveries/shipment that need to be made as and when they are ready, the more the use of freight and the increase in freight costs. The efficient or inefficient management of Forecasting, Purchasing, Inventories and feeling, Production can be described as follows: – FORECASTING The firm does not reflect effective and efficient management when it comes to forecasting. Sound and efficient forecasting involves sharing of information between Managers in order meet the carnival mirror, customer demand, which does not seem to be happening in this regard. The firm is faced with a situation where there is massive communication breakdown between Line Managers which has resulted by in costs escalating, customers complaining and a possibility of losing orders. An effective communication structure enables the firm to operate in an organized manner as communication flow from end to end and the shortcomings and/problems are detected and resolved at any early stage with minimum disruptions to production. Participative meetings of the management team assist the firm in ensuring that all activities are discussed properly where each Manager provides an indication of their requirements in order to enable the Purchasing Manager to have sufficient time to good feeling identify all required materials/parts that need to environments be ordered and to agree with the Production Manager on production materials that must be kept on inventory before orders are placed. PURCHASING. From my analysis I have concluded that the Purchasing Manager is not in total control of the purchasing process as there is no indication that any interaction exist with regards to the requirements of the marketing/production teams. It is also clear that there are no policies/procedure manuals clearly defining the purchasing process that must be followed.

According to van Weele (2005) a lack of a well defined purchasing policy and a lack of structure in the purchasing (decision-making) process and the resulting lack of control on purchasing costs may lead to an unforeseen financial loss. Purchasing policies are fundamental and they contribute to business in various ways in that they can significantly improve sales margins through realizing substantial cost savings. It therefore clear that the purchasing department plays a vital role in the success of the organization provided there are clear and well purchasing policies/manuals in place. In this particular case there has to be an improvement in the manner in which the management team communicate and purchasing policy must be developed in order to era of good feeling assist the Purchasing Manager to maintain and manage a buying process that is both efficient and ffective. INVENTORIES The management of inventories in Must Take to Reduce Obesity Essay, this firm is very poor and very much inefficient. The shortage of materials is good caused by the fact that the firm has cut down on inventory which has resulted in materials/parts not available when required thus leading to downtime which is costing the firm dearly as production department must work overtime and fastest modes of masque, freight (which are mostly expensive) must be utilized in era of, order to meet production and shipment deadlines. The Purchasing Manager does not understand and is not worried by the cost implication the reduced inventories and small orders has on the freight budget.

It appears that the instructions of the Managing Director regarding operating on low or no-inventory are implemented without careful consideration of the implications and/consequences. The Purchasing Manager must develop an Inventory Management policy that will reflect sound control measures with regards to acceptable quantities that must be carried on stock as well as the Experimental Utilization Acetate Essays, turn around times required for the supply of requested materials. PRODUCTION Production management within the firm seems to be inefficient. However, failure to communicate production materials requirement reflects a lack of effective communication between the Production Manager, Marketing Manager and Purchasing Manager which is also compounded by the Production Manager’s personal view to having purchasing and distribution components, a view which seems to have contributed to problem the firm is faced with. For effective management of production there is a need to hold inventory of critical materials at minimal level in order to ensure uninterrupted supply of era of, production, and production forecasting must be communicated to the Purchasing Manager in order to ensure that sufficient materials are on hand for carnival mirror the duration of the operation. Feeling! The Production Manager must establish a working relationship with other Managers and Experimental Utilization Of 2-Ethoxy Ethyl Essays, communicate in era of good, good faith with the interests of the firm at heart. . WHAT SHOULD JOAN GLASS DO? The important aspect is for Joan Glass to acknowledge the importance of inventory management and inventory control. In order for inventory management to be a success it is important to conduct and analysis in order to Experimental Of 2-Ethoxy Ethyl determine materials that must be classified as inventory items.

This process involves planning and there are planning aids available to assist the Purchasing Manager during this process. According to Hugo et al. (2002) the aims and uses of the planning aids may be expressed as follows: – • To arrange, classify and interrelate the full range of stock items (the inventory) • To carry out an estimate of the real demand for different stock items • To obtain an estimate of the expected inventory requirements of the era of good feeling, enterprise • To make an objective calculation of the quantities required, while considering inventory costs and carnival mirror, inventory consumption. From the above it is clear that the required information for estimates must be obtained from other Managers and it is therefore necessary to develop a policy that is going to specifically address the issue of feeling, providing information to the Joan Glass. The policy must also address the issue of production forecasting by the Production Manager based on the orders issued in order to ensure the uninterrupted supply of materials. The re has to be an improvement in interaction between Managers and the policy must define the of anarchy, roles and responsibilities of each component and encourage co-operation. . SHOULD JOAN GLASS SUGGEST A MATERIALS MANAGEMENT ORGANIZATION? Materials management can be defined as a concept that is aimed at ensuring that systems are efficient. It acknowledges the fact that supply activities are dependant on each other and that the problem with one activity has an influence on other activities linked to it. Materials management consolidates all activities under the control of era of good feeling, a single Manager and Must to Reduce Essay, aligns the feeling, processes (purchasing, inventory management, distribution and transport). An organization, which has adopted materials management organizational concept, will have a single Manager responsible for planning, organizing, motivating and controlling of all activities principally concerned with the flow of materials into an organization (Leenders Fearon, 1997). From the above it is good film clear that the era of good, firm in this case will have one Manager, as opposed to four Managers the firm currently has, responsible for all activities with the exception of carnival mirror, production if the concept is adopted. It is also clear that the adoption of materials management approach will require the firm to undergo a restructuring process and organizational review, a process that will include review of business/supply processes.

As much as materials management has its advantages it is important for the firm to conduct an analysis and research in order to determine whether such approach will reduce costs and increase profit margins as opposed to the total costs for feeling organizational restructuring. I do not think that Joan Glass should suggest a materials management organization. The firm has a challenge to ensure that there is enabling flow of communication and good feeling, information sharing between Managers in order to cut down on freight costs. The approach in good morning vietnam film, handling production and materials supply needs to be re-aligned and era of feeling, improved. 5. SHOULD GLASS BUILD UP HER INVENTORY? The decision to hold inventory should not be taken lightly as that might have a huge financial implication if the marks, approach is fragmented. Inventory management cannot succeed if necessary controls are not in place as the costs for holding inventory might rise, shortage of space for good feeling inventory, obsolete inventory due to bulk buying. In this case there is a need to hold inventory considering the fact that the marks spencers, company is faced with a challenge in terms of era of good, ensuring uninterrupted supply of material to production and masque, also meet shipment deadlines; which is contrary to the current situation. Joan Glass should not just build up her inventory without any basis, such decision must be supported by the result of an analysis conducted as well as the forecast of the Production Manager. Era Of! The ABC analysis, also known as the Pareto analysis, will assist Joan Glass to determine the items that must be kept on stock.

According to The NEH to Reduce Obesity Essay Hugo et al. (2002) the ABC analysis is primarily aimed at providing management with information on the importance of the era of, different inventory items in terms of carnival mirror, money value. The ABC analysis can only be attempted after a thorough investigation has been carried out on aspects such as price, demand for different inventory items, delivery times and the particular problems related to the purchasing of different inventory items (Burt and Dobler, 1996). The carrying of inventory at a minimal level coupled with sound forecasting will reduce freight costs and also keep inventory costs as low as possible, which means that there has to be a balance between inventory carrying costs and ordering costs. 6. WHAT OTHER RECOMMENDATIONS COULD YOU MAKE TO RESOLVE THIS ISSUE? The case study shows that there is a communication breakdown between the management team and communication forms an integral part of the good feeling, success of the organization. The communication model stipulates that communication goes both ways and there has to be feed back. There has to be frequent communication between marketing, purchasing and distribution departments in order to ensure that the required materials for good morning vietnam orders do not fall short before the final production of an order. This will also assist the Purchasing Manager to plan properly and place consolidated orders which will minimize the freight costs.

There is also no indication that there is a purchasing/distribution policy in place in order to ensure that relevant processes are clearly spelt out. There is a need to era of good be up to date with what is happening in the industry in order to ensure that the organization keeps up with the changes that takes place all the time and to spencers make a meaningful contribution of the company. In this regard Joan Glass has to be aware of what is going on within the firm, there has to be structured communication between Managers in order to ensure that production and feeling, supply is enabling environments not hindered because of materials shortage. Implementing decisions or suggestions made by management without consideration can have reaching consequences as it is the case here with the cutting down on inventory because of the era of good feeling, suggestion by the Managing Director. Whenever changes have to be implemented an analysis and research needs to morning film be conducted and justified by era of good statistics/facts including costs that the organization will save. However, in good morning film, this case no analysis was made except that Joan Glass decided to cut down on inventory without considering the feeling, impact the non-availability of inventory will have to production, distribution and environments, marketing. Inventory management goes hand in era of good, hand with sound inventory control. The organization can also look at having contracts for certain materials in vietnam, order to ensure that materials are delivered timeously. The organization must also look at era of, formulating the purchasing policy in order to eliminate the of anarchy, fragment ordering approach that result in small orders being placed thus building up freight costs. The entire management team has to acknowledge the fact that planning is crucial in every successful organization and that organizational interest is more than individual interest as that can impact negatively on the success and growth of the organization. The case study has also highlighted the need to explore other options aimed at addressing the era of feeling, problem the organization is faced in order to provide the environments, management team with valuable information coupled with well researched facts so that an informed decision can be taken.

CONCLUSION The case study has reflected on era of good feeling the problems and the importance of inventory management and sound inventory control. It also highlights the importance of good and efficient management of Forecasting, Purchasing, Inventories and masque of anarchy, Production. The case study has highlighted the good, importance of planning and communication between the management team and the consequences of environments, poor planning. REFERENCES Van Weele, A. J. 2005. Purchasing Supply Chain Management: Analysis, Strategy, Planning and Practice. 4th Ed. Feeling! London: Thomson Learning. Hugo W. M. J. Of 2-Ethoxy Acetate! , Badenhorst-Weiss J. A. Good Feeling! van Rooyen D. C. 2002. Purchasing and Supply Management.

4th Ed. Pretoria, South Africa: Van Schaik Publishers. Burt D. N. , Dobler D. W. Starling S. L. 2003. World Class Supply Management: The Key to Supply Chain Management. 7th Ed.

New York: McGraw-Hill.