Risk Management Guide for Student Organizations Purpose of

Risk Management Guide for Student Organizations Purpose of

Risk Management Guide for Student Organizations Purpose of Training Provide an overview of risk management. Familiarize leaders of student organizations with risk assessment and management concepts and tools as required by Education Code 51.9361 What Will I Learn From The Training Ability to define risk

management Use the risk matrix to identify and manage risk Identify risk in activities planned by an organization Develop methods to manage risk in activities planned by Risk Management Concepts and Tools What is Risk Management? Risk Management is the process of considering the potential and perceived risk involved in student activities. It

includes monitoring organization activities and taking both corrective action and proactive steps to minimize accidental injury and/or loss. High Risk Activities Alcohol and Illegal Drugs Hazing Sexual Abuse and Harassment Fire and Other Safety Issues Travel Behavior at Parties and Social Events

Others? Risk Types Physical Reputation Emotional Financial Facilities (This is used with permission from Student Risk Management at Arizona State University) Risk Management Concepts Identify risky behavior and activities Assess the probability of adverse outcomes Identify and implement controls to eliminate or reduce the risk Reassess the activity after the risks have been managed

Georgia Institute of Technology, 2002 Risk Management and Insurance Matrix RISK MANAGEMENT AND INSURANCE MATRIX Please feel free to speak to or consult with staff in Student Activities to assist in this risk assessment and insurance management process. Step One List all event activities or concerns. Step Two Identify risks associated with each activity. Step Three Use the Matrix to determine the level of risk before applying any Risk Management strategies Step Four Brainstorm methods to manage risks. See if you can reduce the probability that something will go wrong. Step Five Submit Risk Management & Insurance Matrix with Activity Proposal to Student Activities. NAME OF EVENT: LIST SPECIAL ACTIVITIES ASSOCIATED RISKS* SERIOUSNESS

PROBABILITY METHOD TO MANAGE RISKS** 1. 2. 3. 4. 1. 2. 3. 4. 1. 2. 3. 4. 1.

2. 3. 4. 1. 2. 3. 4. * Associated risks include: medical emergencies, food poisoning/allergic reactions, damage to University reputation, damage to University property and/or facilities, accidents, injury, and/or death. **Methods to manage risks may include: purchasing special event liability insurance, arranging for security through PVAMU PD, traveling with an advisor, rotating drivers, etc. SERIOUSNESS I May result in death. II May cause severe injury, major property damage, significant financial loss, and/or result in negative publicity for the organization and/or institution. III May cause minor injury, illness, property damage, financial loss, and/or could result in negative publicity for the organization and/or institution.

Probability Seriousness I II III IV A B C D PROBABILITY A Likely to occur immediately or in a short period of time, expected to occur frequently.

B Probably will come in time C May occur in time. D Unlikely to occur. IV Hazard presents a minimal threat to safety, health, and well-being of participants. If any special activity score is within the red or yellow the Office of Student Activities must review. The Risk Management & Insurance Matrix must be filed when an Activity Permit is submitted. The form has been provided as an educational tool to help student leaders to develop a process for identifying and discussing potential risk issues. It is intended for use as part of a larger event planning process, and should only serve as a starting point for your discussion on risk management. It is not designed to take the place of a careful review of applicable rules, policies, and laws, or discussion with your advisor. Completion of this form does not imply approval or authorization of your event by Prairie View A&M University. For more information on event planning, contact Student Activities in the Memorial Student Center, (936) 261-1340. Sample University Sample Event Sample University Outdoors April 2008 Sample University Outdoors is a fun, free event where children are taught about wildlife, plants, and the outdoors. Events include safety in archery and shooting, plant identification, arts and crafts, fishing, fire trucks, Smokey the Bear, birds of prey display, state park information, casting lessons, and many more booths.

Gates open at 9 am and close at 3pm. Children and parents are free to come any time during these hours. A free hotdog lunch is provided, along with drinks and chips. Step One: List all risk concerns for Sample University Outdoors NAME OF EVENT: PVAMU Outdoors LIST SPECIAL ACTIVITIES ASSOCIATED RISKS* SERIOUSNESS PROBABILITY METHOD TO MANAGE RISKS** 1. BB Gun Shooting 1. 1. 1.

1. 2. Climbing Wall 2. 2. 2. 2. 3. Archery 3. 3. 3.

3. 4. ATVs 4. 4. 4. 4. * Associated risks include: medical emergencies, food poisoning/allergic reactions, damage to University reputation, damage to University property and/or facilities, accidents, injury, and/or death. **Methods to manage risks may include: purchasing special event liability insurance, arranging for security through PVAMU PD, traveling with an advisor, rotating drivers, etc. SERIOUSNESS I May result in death. II May cause severe injury, major property damage, significant financial loss, and/or result in negative publicity

for the organization and/or institution. III May cause minor injury, illness, property damage, financial loss, and/or could result in negative publicity for the organization and/or institution. PROBABILITY Probability Seriousness I II III IV A B C

D A Likely to occur immediately or in a short period of time, expected to occur frequently. B Probably will come in time C May occur in time. D Unlikely to occur. IV Hazard presents a minimal threat to safety, health, and well-being of participants. If any special activity score is within the red or yellow the Office of Student Activities must review. The Risk Management & Insurance Matrix must be filed when an Activity Permit is submitted. The form has been provided as an educational tool to help student leaders to develop a process for identifying and discussing potential risk issues. It is intended for use as part of a larger event planning process, and should only serve as a starting point for your discussion on risk management. It is not designed to take the place of a careful review of applicable rules, policies, and laws, or discussion with your advisor. Completion of this form does not imply approval or authorization of your event by Prairie View A&M University. For more information on event planning, contact Student Activities in the Memorial Student Center (936) 261-1340. Step Two: Identify risk associated with each activity

Driving ATVs Other Vehicles Events BB Gun Shooting Climbing Wall Archery Physical Risks Insect Bites Slips, Trips, Falls Animal Concerns Financial

Liability Insurance Reputation What If ??? NAME OF EVENT: Tarleton Outdoors LIST SPECIAL ACTIVITIES ASSOCIATED RISKS* SERIOUSNESS PROBABILITY METHOD TO MANAGE RISKS** 1. BB Gun Shooting 1. Accident/Injury 1.

1. 1. 2. Climbing Wall 2. Accident/Injury 2. 2. 2. 3. Archery 3. Accident/Injury 3.

3. 3. 4. ATVs 4. Accident/Injury 4. 4. 4. * Associated risks include: medical emergencies, food poisoning/allergic reactions, damage to University reputation, damage to University property and/or facilities, accidents, injury, and/or death. **Methods to manage risks may include: purchasing special event liability insurance, arranging for security through PVAMU PD, traveling with an advisor, rotating drivers, etc. SERIOUSNESS OF RISK I May result in death.

II May cause severe injury, major property damage, significant financial loss, and/or result in negative publicity for the organization and/or institution. III May cause minor injury, illness, property damage, financial loss, and/or could result in negative publicity for the organization and/or institution. PROBABILITY Probability Seriousness I II III IV A B

C D A Likely to occur immediately or in a short period of time, expected to occur frequently. B Probably will come in time C May occur in time. D Unlikely to occur. IV Hazard presents a minimal threat to safety, health, and well-being of participants. If any special activity score is within the red or yellow the Office of Student Activities must review. The Risk Management & Insurance Matrix must be filed when an Activity Proposal is require. The form has been provided as an educational tool to help student leaders to develop a process for identifying and discussing potential risk issues. It is intended for use as part of a larger event planning process, and should only serve as a starting point for your discussion on risk management. It is not designed to take the place of a careful review of applicable rules, policies, and laws, or discussion with your advisor. Completion of this form does not imply approval or authorization of your event by Prairie View A&M University. For more information on event planning, contact Student Activities in the Memorial Student Center (936) 261-1340. Step Three: Use the matrix to determine the level of risk before applying any risk

management strategies NAME OF EVENT: PVAMU Outdoors LIST SPECIAL ACTIVITIES ASSOCIATED RISKS* SERIOUSNESS PROBABILITY METHOD TO MANAGE RISKS** 1. BB Gun Shooting 1. Accident/Injury 1. II 1.

1. 2. Climbing Wall 2. Accident/Injury 2. II 2. 2. 3. Archery 3. Accident/Injury 3. II 3.

3. 4. ATVs 4. Accident/Injury 4. II 4. 4. SERIOUSNESS I May result in death. II May cause severe injury, major property damage, significant financial loss, and/or result in negative publicity for the organization and/or institution. III May cause minor injury, illness, property damage, financial loss, and/or could result in negative publicity for the organization and/or institution. IV Hazard presents a minimal threat to safety, health, and well-being of participants.

NAME OF EVENT: PVAMU Outdoors LIST SPECIAL ACTIVITIES ASSOCIATED RISKS* SERIOUSNESS PROBABILITY METHOD TO MANAGE RISKS** 1. BB Gun Shooting 1. Accident/Injury 1. II 1. B

1. 2. Climbing Wall 2. Accident/Injury 2. II 2.B 2. 3. Archery 3. Accident/Injury 3. II 3. B

3. 4. ATVs 4. Accident/Injury 4. II 4. B 4. PROBABILITY A Likely to occur immediately or in a short period of time, expected to occur frequently. B Probably will come in time C May occur in time. D Unlikely to occur.

NAME OF EVENT: Tarleton Outdoors LIST SPECIAL ACTIVITIES ASSOCIATED RISKS* SERIOUSNESS PROBABILITY METHOD TO MANAGE RISKS** 1. BB Gun Shooting 1. Accident/Injury 1. II 1. B 1.

2. Climbing Wall 2. Accident/Injury 2. II 2.B 2. 3. Archery 3. Accident/Injury 3. II 3. B 3.

4. ATVs 4. Accident/Injury 4. II 4. B 4. Probability Seriousness I II III IV A

B C D Step Four: Brainstorm Methods to Manage Risk Find strategies you can apply to reduce the severity of the risk and probability that something will go wrong Procure Summer Camp insurance for participants providing coverage that included accident, medical and general liability. Provide medical station to treat minor issues such as insect bites, sun exposure, sprains, etc.

Request ATVs to be provided by vendor in lieu of utilizing personal vehicles. Implement registration process to monitor participants. Monitor food preparation process for potential food safety concerns. NAME OF EVENT: PVAMU Outdoors LIST SPECIAL ACTIVITIES ASSOCIATED RISKS* SERIOUSNESS PROBABILITY METHOD TO MANAGE RISKS** 1. BB Gun Shooting 1. Accident/Injury

1. II 1. B 2. Climbing Wall 2. Accident/Injury 2. II 1.B 3. Archery 3. Accident/Injury 3. II 3. B

4. ATVs 4. Accident/Injury 4. II 4. B 1. Proper one on one Instruction/Supervision 2. One on one Instruction/Participation Vendor certified supervision 3. One on One Instruction/Supervision 4. Restricting use to Advisor/Organization not participants. Provide orientation for use limitations and routes. Use vendor ATVs instead of personal units.

* Associated risks include: medical emergencies, food poisoning/allergic reactions, damage to University reputation, damage to University property and/or facilities, accidents, injury, and/or death. **Methods to manage risks may include: purchasing special event liability insurance, arranging for security through PVAMU PD, traveling with an advisor, rotating drivers, etc. SERIOUSNESS I May result in death. II May cause severe injury, major property damage, significant financial loss, and/or result in negative publicity for the organization and/or institution. III May cause minor injury, illness, property damage, financial loss, and/or could result in negative publicity for the organization and/or institution. PROBABILITY Probability Seriousness I II III IV

A B C D A Likely to occur immediately or in a short period of time, expected to occur frequently. B Probably will come in time C May occur in time. D Unlikely to occur. IV Hazard presents a minimal threat to safety, health, and well-being of participants. If any special activity score is within the red or yellow the Office of Student Activities must review. The Risk Management & Insurance Matrix must be filed when an Activity Permit is submitted. The form has been provided as an educational tool to help student leaders to develop a process for identifying and discussing potential risk issues. It is intended for use as part of a larger event planning process, and should only serve as a starting point for your discussion on risk management. It is not designed to take the place of a careful review of applicable rules, policies, and laws, or discussion with your advisor. Completion

of this form does not imply approval or authorization of your event by Prairie View A&M University. For more information on event planning, contact Student Activities in the Memorial Student Center (936) 261-1340. Step Five: Determine if you have reached an acceptable level of risk by applying risk management strategies Consider modifying or eliminating activities that have unreasonable risk associated with them. Remember to consider how the activities relate to the mission and purpose or your organization. Additional Resources

The Risk Management & Insurance Matrix is available on the Texas A&M University System website at http://www.tamus.edu and www.pvamu/studentactivities Alcohol, Illegal Drugs and Penalties Alcohol, Illegal Drugs and Penalties Public intoxication - Occurs when a person appears in public while intoxicated to the degree that the person may endanger himself/herself or others due to the impairment of mental or physical faculties. The officer is not required to give you a breath test or a field sobriety test to show that you are intoxicated. Generally you get to sober up in jail, unless there is a responsible sober adult that is willing to accept responsibility for you and the officer deems it not necessary for a trip to jail.

Minor in Possession - A person who is a minor (under 21 years of age) who is found to be in possession on an alcoholic beverage of any kind is in violation. Minor in Consumption - Minor in consumption is just that! Just taking a sip of one beer violates the law. The only exception to this is if your parent or spouse is with you and giving you the alcohol to consume. Fine $250.00 Plus suspension of Drivers license Alcohol, Illegal Drugs and Penalties Purchase / Furnish Alcohol to a Minor

Fines: Up to $4,000.00 and Up to 1 yr. in Jail Furnishing alcohol to a minor or providing a place for a minor to consume alcohol is a serious Class A misdemeanor and is under the jurisdiction of the County Court. A Class A misdemeanor is one step below a felony. Remember if you are having a party at your house or apartment, you are responsible. If one minor is found drinking at your party you are in violation. Alcohol, Illegal Drugs and Penalties Driving While Intoxicated A person is Driving While Intoxicated when having a blood alcohol concentration of

0.08 or more while operating a motor vehicle. The 1st offense is a Class B misdemeanor Fines: Confinement in jail for up to 180 days, a fine up to $2,000 and drivers license suspension 90 days to 1 year The 2nd offense is a Class A misdemeanor Fines: Confinement in jail a minimum of 30 days & up to one year, a fine not to exceed $4,000 and drivers license suspension 180 days to 2 years The 3rd offense is a third degree felony Fines: 2 to 10 years in prison, a fine not to exceed $10,000, an drivers license suspension 180 days to 2 years (Fines do not include court cost and lawyer fees) Alcohol, Illegal Drugs and Penalties Possession of Drugs The possession of a usable

quantity of Marijuana (2 oz. or less) is an offense under state law. This offense is a Class B Misdemeanor Fine: Confinement in jail for up to 180 days and a fine up to $2,000 Heroin, Cocaine, Methamphetamine, Methadone, Psilocin (Mushrooms), Mescaline, and The Opiates Dangerous Drugs such as the above are those types of drugs that have no medicinal value. Possession of these major drugs carries varied punishments and even the possession of only a single usable amount still carries a State Jail Felony punishment.

Fines: Up to two years in jail and a fine of up to $10,000 Punishments for possession over a usable amount can be as high as: 15-99 years or life and up to $250,000 fine Alcohol, Illegal Drugs and Penalties Methods of Control Check IDs at the door and use a unique way of

identifying those over the legal drinking age, such as with bracelets. Hire professional security to work the door and check IDs. Serve non-alcoholic beverages and food. Set a starting time and ending time for the party and stick with them, limit party to four hours. Do not permit drinking games Maintain control of all alcoholic beverages present. Do not allow bottles. Parties with Alcohol Parties on campus that serve alcohol to students are prohibited. Alcohol, Illegal Drugs and Penalties What Should You Do?

Know the Law Minor in possession Stop the drinking Take the appropriate action to deal with the minor in a safe manner Illegal drugs Notify authorities for removal of the individual Ensure the person who is under the influence is properly cared for Impaired Attendee Do not allow the person to drive Seek medical assistance as needed Do not leave the person alone

Sample University Alcohol, Illegal Drugs and Penalties Scenario (Baby Dome party where participant comes visibly intoxicated) Hazing Hazing Hazing is defined as any intentional or reckless act occurring on or off the campus of an educational institution, by one person alone or acting with others, directed against a student that endangers the mental or physical health or safety of that student for the purpose of pledging, being initiated into, affiliating with, holding

office in, or maintaining membership in any organization whose members are students at an educational institution. Hazing Hazing Does Not Help you to assimilate better into the group/organization Help you build inner strength Take into account the psychological state of an individual Have boundaries or follow safe-guards that govern actions, or activities Have to be illegal, and/or involve ingesting something Represent the only creative alternative bond activity Hazing

Hazing Does Create a cycle of abusive behavior Create a false sense of power and control Display an absence of constraints or boundaries Humiliate, degrade, and embarrass Hazing Prevent Hazing Recognition of hazing Follow the Student Handbook, Charter and/or National Policy Stand-up for what is right even if it is against traditions

Secret = Hazing Groupthink Addition to Hazing Prevention Each member and prospective member must attend mandatory Membership Intake Process (MIP) meeting. Hazing Scenario (Incident where water was thrown on prospective member and she slipped and hit her head) Sexual Abuse Sexual Harassment Sexual Abuse-Sexual Harassment Sexual

Harassment is unwelcome conduct of a sexual nature[and]can include unwelcome sexual advances, request for sexual favors, and other verbal, nonverbal, or physical conduct of a sexual nature. Federal law prohibits sexual harassment of college students whether the harasser is an employee or another student. Sexual Abuse includes a wide range of unwanted sexual behaviors, including: sexual assault/murder, aggravated sexual assault, sexual assault, which can be forced contact or coercive in nature, indecent exposure, obscene phone calls, sexual harassment, voyeurism, frottage, peeping, etc. HB 2639 utilizes the term sexual abuse in an effort to encompass all of the above behaviors. However, for this risk management training sexual

Sexual Abuse-Sexual Harassment 20 to 25 percent of college women are sexually assaulted during their college career (The American Association of University Women, 2004) In 2003, one in every 10 sexual assault victims were male (US Dept of Justice, 2003) In 2005, about seven in ten female rape or sexual assault victims stated the offender was an intimate, other relative, a friend or an acquaintance (Natl Crime Victimization Survey),

Alcohol continues to be the number one drug used to facilitate a sexual assault (US Dept of Sexual Abuse-Sexual Harassment How to Reduce the Risk of Sexual Assault Educate Yourself Look out for your friends Stay in Groups Never be alone with someone you dont know Never leave your beverage unattended Decide what your limits are and communicate them clearly Learn to be assertive Do not assume anything TRUST YOUR INSTINCTS

Sexual Abuse-Sexual Harassment If you have been Sexually Assaulted Find a safe environment Preserve evidence of the attack Report the attack as soon as possible Seek medical attention Find out about your resources Office of Equal Opportunity A.I. Thomas Building, Suite 102 Sexual Abuse-Sexual Harassment Helping Victims Let victims make decisions Listen with patience

Active Listening Provide victims with information and referrals Sexual Abuse-Harassment Scenario A male teacher offers to give a female student an A if she'll kiss him. A female guidance counselor tells a male student that she won't help him with his college applications unless he goes out on a date with her. A male soccer coach suggests to a male student that he'll have a better chance of making the team if he has sex with him.

Fire and Life Safety Fire and Life Safety Events may have inherent physical risks that require contingency plans including: Fire Safety Inclement Weather Campus Emergency Fire and Life Safety General Fire/Life Safety Guidelines Organizations should have Emergency contact numbers for Fire, Police, & Ambulance posted near common phones. Prior to any event plan & provide for all facilities used for event:

Evacuation routes Shelter Must know specific location description to direct emergency services. The possession of firearms or explosive devices of any kind is forbidden. Fire and Life Safety General Fire/Life Safety Guidelines Be sure to call authorities to notify them of the emergency. Most locations have 9-1-1 service Verify emergency contact number before event First priority is to ensure safety of attendees Have some method of accounting for attendees location Initiate appropriate actions in response to the emergency PVAMU Fire Safety Numbers Campus Police: 1375 Emergency: 4911

Emergency from cell phone: 936.261.4911 (recommend programming in cell phone) Safety Fire Safety Fire evacuate building; Do not allow anyone to re-enter a building until cleared by the proper authority There are several common causes of accidental college fires: Careless smoking Unattended candles, incense, perfume burners Cooking Overloaded extension cords and power outlets Leaves and debris located near buildings Unattended cooking grills Improper use of surge protectors Fire and Life Safety Life Safety Tips

Report to administration, landlord, etc. defective or inoperable fire protection equipment. Do not tamper with fire protection equipment. Know your evacuation routes in apartments, houses, hotels, conference centers, etc. Keep egress hallways and exits clear of obstructions. If you observe a fire: Activate the fire alarm system to notify building occupants of the emergency Notify the University Police or the City of Prairie View Fire Department of the fire Evacuate the building Remain outside until notified by the fire department the building is safe to re-enter Safety Inclement Weather If City Tornado Siren sounds travel to the interior of the structure.

An interior restroom provides better protection for most buildings. Know the Areas of Refuge in each building on-campus www.pvamu.edu/Include/EHS/Student%20Safety%20protocols.doc Review Prairie View University Inclement Weather Policy www.pvamu.edu/Include/EHS/Student%20Safety%20protocols.doc Emergency Notification Text System http://panthertracks.pvamu.edu/ Fire Safety Additions Panther

Alert System and/or PVAMU website http://panthertracks.pvamu.edu/ Link to emergency procedures www.pvamu.edu/Include/EHS/Emergency%20Preparedness/ Emergency%20Operations%20Plan%202008.doc Fire and Life Safety Campus Emergency Review and know the following procedures if any of the following occur:

Terrorist/Shooter follow directions of emergency personnel through Panther Tracks. Bomb Threat review guidance contained in the University Emergency Guide. www.pvamu.edu/Include/EHS/Student%20Safety%20protocols.doc Injury Accident know basic First Aid protocol www.pvamu.edu/Include/EHS/Student%20Safety%20protocols.doc Fire and Life Safety Scenario Two students are smoking in a room and they throw the cigarette butt in the trashcan. The cigarette has not been fully extinguished and the contents of the trash can now rapidly catch fire

Travel Current Travel Policy http://www.pvamu.edu/pages/1355.asp These procedures are considered to be minimum standards; departments may mandate additional procedures. Failure to comply with these procedures may result in the suspension of student travel for the director/department responsible for arranging the trip. The University President or his designated representative (the Vice President for University Operations) may authorize exceptions to these procedures on a case-by-case basis. Travel General Requirements No

student will be authorized to drive a Universityowned or leased vehicle to transport students off campus on any University authorized and/or funded trip. Must be at least 18 years of age Prefer rental vehicles be used if possible Must have personal automobile insurance and registration as required by state law if personal vehicle to be used Travel Things to Think About Consider alternative methods of transportation Anticipate or prepare for emergency expenses associated with travel Transportation in open beds of trucks should be avoided Arrangements for transporting impaired individuals

Plan to take a 15 minute break for every two hours of driving Travel More Things to Think About When assigning someone to perform a task involving driving, consider their physical and mental state Length of trip and number of available drivers Does your location provide easy ingress and egress Emergency vehicle access Stranding during bad weather Travel Scenario It is Saturday night. The basketball teams and supporters have been in Houston for a big game

against TSU. Student Activities has promoted the event and offered a free bus ride to the game for university students, faculty and staff. The weather has been very cold and a front is predicted to bring freezing rain and icing conditions on Sunday. After the two buses leave for Houston, there is a concern from some weather forecasters that the front may pick up speed and arrive late Saturday night or early Sunday morning. Behavior at Parties and Social Events Behavior at Parties Can Our Organization Be Held Responsible for an Individuals Behavior? YES!

It can depend on number of members attending BUT most importantly You assume responsibility if the activity is related to the organization Behavior at Parties Organizations may be held responsible when acts of individual members are directly related to the student organization's activities member is violating local, state, or federal law or University regulations and other members present fail to discourage such activity

Remember in addition to the group being held responsible, members, officers, and even advisors may be held individually responsible for an individual members actions. Behavior at Parties Prevent Potential Problems Communicate organizational and University expectations to members BEFORE there is a problem Know the law Use good judgment when

Choosing to attend the party/event Posing for pictures which could be posted to social networking sites Staying at the party/event if you detect illegal/risky behavior Behavior and Parties Scenario (Individual was at a baby dome party wearing his organizations uniform. He got drunk and passed out in the bathroom) Questions? Risk Management Training Next Steps Within 45 days following completion training, the officers or advisors receiving the training must: Report the program content at a meeting of the full membership of

the recognized student organization Submit to the Office of Student Activities and Leadership a signed statement saying the report was made Submit to the Office of Student Activities and Leadership a copy of the meeting agenda or a flyer detailing the topics covered at the meeting Adopt a risk management policy for the organization Attendance and Documentation Requirements Must

Take Attendance at the Presentation Must impose reasonable sanctions on a person who is required to attend and fails to attend Must maintain for three years record of attendance

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