Hatch Enterprises, Inc.

Plain-English summary

At a small limestone mine, production supervisor Dewayne Lambert began cutting metal with a torch without putting on available safety goggles. Judge Priscilla M. Rae found that the eye-protection standard was violated and that the condition was S&S because sparks and glare were likely to cause a serious eye injury during the planned cutting work. Lambert functioned as management by directing miners, running the mine when the owners were absent, conducting examinations, and handling citation abatement, so his conduct was attributable to Hatch Enterprises. The Judge rejected unwarrantable failure, however, because the act lasted only seconds, affected only Lambert, had no similar prior history, and was an isolated careless choice rather than a continuing management practice. She reduced negligence to moderate and assessed $350 instead of the proposed $2,000.

Decision snapshot

• Cited standard: 30 C.F.R. § 56.15007
• Outcome: The S&S violation was affirmed, unwarrantable failure was removed, negligence was reduced to moderate, and a $350 penalty was assessed.
• Key point: A lead worker's supervisory functions can make him an operator's agent, but a brief isolated PPE lapse does not automatically amount to aggravated conduct.

Full text (FMSHRC public release)

FMSHRC ALJ Decision

FEDERAL MINE SAFETY AND HEALTH REVIEW COMMISSION

OFFICE OF ADMINISTRATIVE LAW JUDGES

601 New Jersey Avenue, N.W., Suite 9500

Washington, DC 20001

March 5, 2012

SECRETARY OF LABOR,   

MINE SAFETY AND HEALTH    

ADMINISTRATION (MSHA),  

Petitioner, 

v.

HATCH ENTERPRISES, INC.,

Respondent. 

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Civil Penalty Proceeding

Docket No. SE 2010-341-M

A.C. No. 08-00088-205943-01

HATCH ENTERPRISES INC.

DECISION

Appearances:    Jonathan Hoffmeister, Esq., Office of the Solicitor, U.S. Department of  Labor, 61 Forsyth St., S.W., Room 7T10, Atlanta, GA 30303, for Petitioner;

W. Randolph Hatch, President, Hatch Enterprises, Inc., P.O. Box 238, Branford,  FL 32008, for Respondent                               

Before:            Judge Rae

This case is before me on a petition for assessment of civil penalty filed by the Secretary
of Labor, acting through the Mine Safety and Health Administration, against Hatch Enterprises,
Inc. pursuant to sections 105 and 110 of the Federal Mine Safety and Health Act of 1977, 30
U.S.C. §§ 815 and 820 (the “Mine Act” or “Act”).  

Prior to hearing, Petitioner filed a motion for leave to file the petition out of time. In
response, Respondent filed an objection thereto. On December 2, 2011, I granted Petitioner’s
motion. At issue for hearing was one section 104(d)(1) citation.

The proposed penalty is
$2000.00. The hearing was held on February 15, 2012 in Gainesville, FL. The parties presented
evidence and made arguments. The record was held open for ten days for Hatch to submit
financial information which was received on February 22, 2012.

I.         FINDINGS OF FACT AND CONCLUSIONS OF LAW

Hatch Enterprises, Inc. (“Hatch”) operates a family- run crushed limestone surface mine
in Suwannee County, FL. At the time of this inspection, the mine employed three miners who
worked one shift per day, five days per week. (Ex. S-7 at pg. 3.)The annual man hours worked
was 20,000 to 30,000. (Ex. S-10.)

On October 20, 2009, the mine was inspected by an MSHA certified inspector who issued
a number of citations and an oral imminent danger order. The following violation was
adjudicated at hearing.

The Violation

The narrative portion of the citation with the later amendment reads as follows:                         

A miner was observed using a cutting torch to cut a piece of metal without the use of proper eye protection. When observed, the employee had just started cutting the metal material. Eye protection is provided to employee’s (sic) by the operator  but was not being worn at this time. The miner in question was the operator’s leadman. Mr. Lambert, leadman, engaged in aggravated conduct  constituting more than ordinary negligence in that he knew that eye protection was required and needed, but failed to wear it. This is unwarrantable  failure to comply with a mandatory standard.

After review of information and the facts, it is determined that the leadman is an  agent of the operator, therefore, this citation is modified to a 104(d)(1) citation

(Ex. S-1.)

The standard provides: “Protective clothing or equipment and face shields, or goggles
shall be worn when welding, cutting, or working with molten metal.”30 C.F.R. §56.15007.

Billy Handshoe started his career with MSHA as a certified inspector in 2003 and
remained until 2008 when health issues prevented him from completing his duties. He then
worked for CEMEX as the safety and health supervisor where he conducted approximately 50 to
100 safety audits and accompanied MSHA inspectors on approximately 14 regular inspections in
the year he was there. In 2009, he returned to MSHA and worked in the Lexington, KY and
Barstow, FL offices until he became the field office supervisor in Knoxville in July 2011. He was
also a blaster for 12 years prior to joining MSHA.

Early in the morning of October 20, 2009, Handshoe met with Mr. Randy Hatch,
President of Hatch Enterprises, in the shop area. Shortly after meeting with Hatch, Hatch
departed and Dewayne Lambert escorted Inspector Handshoe on the inspection. (Tr. 16, 33-34.)
During the health and safety survey he conducted in the shop area, he observed a bench grinder
that was not equipped with a guard for which he issued a citation. (Tr. 17.)When Handshoe
issued the citation on the bench grinder, Lambert responded by commencing to cut a piece of
expanded metal from which to fabricate the guard. As he began to cut the metal with a torch,
Handshoe saw that Lambert was not wearing protective safety goggles (“PPE”) and he
immediately issued a verbal imminent danger order. (Tr. 17-18.) Handshoe then issued this
citation for the failure to wear proper safety equipment. (Tr. 18.)

Hatch poses several arguments in defense of this citation. They contend, Lambert had
only fired up the torch but had not yet begun to cut the metal, therefore the standard was not
violated. Further, it asserts that this grinder is 20 years old and had been in service before the
passage of the Mine Act. It came without a guard and has never been cited by an MSHA
inspector in all the years that it has been in use and therefore the inspector’s citing it was
arbitrary and unnecessary. (Tr. 28, 52.) It contends that Handshoe came to the mine with
something to prove as a new field office supervisor. According to Hatch and Lambert, Handshoe
made some sort of remark that he was going to write every citation he possibly could in order to
increase the penalties as much as possible. (Tr. 38, 63.) This cited violation was the result of the
inspector threatening to order the grinder be taken out of service if the guard was not constructed
immediately. (Tr. 53.) Laboring under the exigency of this situation created the unsafe
environment, not Lambert’s actions. (Tr. 55.) There has not been an accident at this mine in over
20 years and MSHA has acted arbitrarily in its assessment of this citation. (Tr. 55, 75-76.)
Hatch challenges the characterization of this violation as S&S, an unwarrantable failure or the
result of high negligence. Hatch asserts that Lambert has a standing practice of wearing his safety
goggles on his hat which he pulls down as soon as he needs them. (Tr. 76-77.) Had the inspector
not threatened to shut down production if the condition was not immediately abated, the proper
procedures would have been followed. This unsafe practice was essentially at the direction of the
inspector, not Hatch. (Tr. 55.) Further, they disagree with a finding that Lambert was a supervisor
of the company.

Despite Hatch’s attempts to establish that Lambert had not yet begun cutting when
Handshoe issued this citation, the evidence does not support this. Handshoe observed Lambert
cutting the expanded metal without putting on proper protective equipment to shield his eyes
from sparks. (Tr. 18-19, 70.) Lambert confirmed in his testimony that he had started cutting the
metal, and was not merely lighting the torch, when Handshoe issued his verbal order to cease
cutting. (Tr. 57, 70) At the Closeout Conference held between Randy Hatch and Handshoe,
Hatch stated that Lambert knew better than to use the torch without PPE. (Tr. 36.) Hatch has had
a discussion with him about it. Hatch also told Handshoe that he intended to conference the
negligence assessment but not the citation. (Ex. S-9.) The evidence establishes that Lambert
was, indeed, in the act of cutting the metal when Handshoe issued the order and the citation. I
note also that it would be a reasonable interpretation of the standard to require one to put on the
PPE before taking the preparatory step of lighting the torch. Once the torch is lit a flame is
present and so too is the danger of sparking.

As for Hatch’s other arguments as to why the violation was improperly charged, they too
fail. Operators are subject to strict liability for a violation of this mandatory standard, thus the
fact that other inspectors did not cite the guard is not a defense to the violation. The
Respondent’s argument that the grinder was grandfathered in, therefore requiring the guard be
constructed immediately was arbitrary and caused this violation is disingenuous. It is the duty of
the inspector to enforce the provisions of the Mine Act which was enacted prior to putting this 20
year old grinder into service. Furthermore, the cited condition was a failure to don PPE when
using the torch cutter. There was nothing preventing Lambert from putting on his PPE before he
started cutting the metal. The Secretary has met her burden of proving the violation was properly
cited.

Significant and Substantial

A violation is significant and substantial (“S&S”) if the violation is “of such a nature as
could significantly and substantially contribute to the cause and effect of a coal or other mine
safety or health hazard.” 30 U.S.C. §814(d)(1). There must be “a reasonable likelihood that the
hazard contributed to will result in an injury or illness of a reasonably serious nature.” Cement
Div., Nat’l Gypsum Co., 3 FMSHRC 822, 825 (Apr. 1981). Under the National Gypsum
definition, “the Secretary of Labor must prove: (1) the underlying violation of a mandatory safety
standard; (2) a discrete safety hazard –that is, a measure of danger to safety – contributed to by
the violations; (3) a reasonable likelihood that the hazard contributed to will result in an injury;
and (4) a reasonable likelihood that the injury in question will be of a reasonably serious nature.”
Mathies Coal Co., 6 FMSHRC 1, 3-4 (Jan. 1984)(footnote omitted); see also, Buck Creek Coal,
Inc. v. MSHA, 52 F.3d 133, 135 (7th Cir. 1999); Austin Power, Inc. v. Secretary, 861 F.2d 99,
103-104 (5th Cir. 1988), aff’g Austin Power, Inc., 9 FMSHRC 2015, 2021 (De. 1987) (approving
Mathies criteria).

In order to meet the requirements of the third, and most difficult to establish, element of
the Mathies formula, the Commission has provided the following guidance:

We have explained further that the third element of the Mathies formula “requires that the
Secretary establish a reasonable likelihood that the hazard contributed to will result in an   event
in which there is an injury.” U.S. Steel Mining Co., Inc., 6FMSHRC 1834, 1836 (August 1984).
We have emphasized that, in accordance with the language of section 104(d)(1), it is the
contribution of a violation to the cause and effect of a hazard that must be significant and
substantial. U.S. Steel Mining Co., Inc. 6 FMSHRC 1866, 1868 (August 1984); U.S. Steel
Mining Co., Inc., 6 FMSHRC 1573- 1574 (July 1984).

This evaluation is made in consideration of the length of time that the condition in
violation existed prior to the citation and the time it would have existed if normal mining
operations had continued. Elk Run Coal Co., 27 FMSHRC 899, 905 (Dec. 2005); U.S. Steel
Mining Co., Inc., 6 FMSHRC at 1574. The question of whether a particular violation is S&S
depends upon the surrounding circumstances of the violation. Texasgulf, Inc, 10 FMSHRC 498
(Apr. 1988); Youghioghen & Ohio Coal Co., 9 FMSHRC 2007 (Dec. 1987).

Handshoe testified that he felt the S&S assessment was appropriate because Lambert
acted in reckless disregard for his health and safety in using a cutting torch without eye
protection. Based upon his observations, he believed that Lambert had intended to complete the
cutting task without PPE.(Tr. 15-16.). To construct the guard, it would have taken Lambert
approximately 5 minutes of cutting with the torch. (Tr. 23.)Under these circumstances, it would
be highly likely that the sparking of the torch, as well as the glare, could result in a reasonably
serious injury to his eyes of a permanently disabling nature. (Tr. 20-21.) He based his opinion on
his personal mining experience and as an MSHA inspector, as all mines have torches and welders
on site and he is very familiar with this standard. (Tr. 13-15.)

Hatch asserted that the sparks were more likely to hit Handshoe who was standing
approximately five feet away rather than Lambert because Lambert was kneeling over the metal
facing the floor. (Tr. 17-18.) I defer to the experience of Handshoe and find the violation was
S&S.

Agency/Unwarrantable Failure

Handshoe was initially told by Hatch and Lambert that Lambert was a supervisor when he
conducted the pre-inspection conference. As he started writing citations, he was then told that
Lambert was a lead man, or a rank-and-file miner. Later, Handshoe reviewed his notes and
consulted with the district and determined that Lambert was a supervisor. He then amended the
citation to a section 104(d) violation charging the company with unwarrantable failure by and
through its agent, Lambert. (Tr. 15-16, 26-29 and Ex. S-1.) In order for unwarrantable failure to
be imputed to Hatch, it must be established by the Secretary that Lambert was an agent of the
operator.

Section 3(e) of the Act defines “agent” as “[a]ny person charged with responsibility for
the operation of all or a part of a coal or other mine or the supervisor of the miners in a coal or
other mine.” 30 U.S.C. § 802(e). In considering whether an employee is an operator’s agent, the
Commission has relied, not upon the job title or the qualifications of the miner, but upon his
function, and whether it is crucial to the mine’s operation and involves a level of responsibility
normally delegated to management personnel. Martin Marietta Aggregates, 22 FMSHRC 633,
637-38 (May 2000); REB Enterprises. Inc., 20 FMSHRC at 211; Ambrosia Coal & Constr. Co., 18
FMSHRC 1552, 1560 (Sept. 1996); U.S. Coal Inc., 17 FMSHRC 1684, 1688 (Oct. 1995).

The Commission in Nelson Quarries, Inc., 31 FMSHRC 318 (Mar. 2009) looked to the
Ambrosia Coal query of whether the function of the miner was “crucial to the mine’s operations
and involved a level of responsibility normally delegated to management personnel.” Ambrosia
Coal at 1560. In Nelson, the Commission upheld the judge’s determination that three employees
were agents within the meaning of the Act based upon their functions at the mine. Specifically,
the Commission focused upon the fact that all three conducted all of the daily examinations, they
supervised and directed the work force assigned to them, they addressed problems the work force
brought to them in attempting to abate citations, the work force treated them and regarded them
as their supervisors, they held themselves out as foremen, and they were designated as the person
in charge of health and safety on the legal identity and start-up and closure reports required to be
filed with MSHA.

Lambert testified that he is the most experienced employee at the mine and can run
everything on site. (Tr. 48-49.) Mr. Hatch is at the mine site for only a short time each day so
Lambert takes over running the mine on a regular basis.(Tr. 50.) When Mr. Hatch does issue
work orders, he gives them to Lambert and Lambert then delegates the tasks to the proper
person(s) to carry them out. Lambert is the one the miners come to for their work assignments.
(Tr. 66-69.) His title is Production Supervisor but he stated when the Hatches are not there,
everything falls to him to run the business. Id. He holds himself out to the other miners as their
supervisor and expects them to comply with his orders. (Tr. 66.) The miners come to him first
with issues or questions which he will resolve without having to consult with the owners. (Tr.
68-69.) He accompanies the MSHA inspectors on regular inspections and is responsible for
ordering whatever work is needed to abate any issued citations.(Tr. 65.)He conducts the pre-shift
examination of the loaders and belts, opens up the office and prepares the paperwork. (Tr. 58-59.)When it has been necessary to shut down equipment, he has ordered it himself without
direction from the owner.(Tr. 70.)

Mr. Hatch testified that Lambert is his “right hand man” and referred to him as his
supervisor.(Tr. 81.) In fact, when Handshoe commenced his inspection, he asked Hatch who
from management would accompany him. Hatch responded that Lambert would and said that he
was a supervisor.(Tr 24-25.) Hatch had told Handshoe that he was running for political office at
the time of the inspection and was only at the mine for short periods of time. In fact, he was not
present for days at a time in some instances. When a member of the Hatch family was not there,
Lambert would take charge. (Tr. 29, 81.) Handshoe reviewed prior citations and notes taken at
the time and found that Lambert had regularly attended both pre-inspection and close-out
conferences and had been the company representative joining the MSHA inspector on the
inspections. (Tr. 33.)

The testimony of Lambert and Hatch leaves no question in my mind that Lambert is an
agent by deliberate designation by Hatch as well as by virtue of his daily functions at the mine
which involve a level of responsibility normally delegated to management personnel. Lambert’s
conduct is properly imputed to Hatch. The issue then is whether the level of negligence rises to
the level of unwarrantable failure.

The unwarrantable failure terminology is taken from section 104(d) of the Act, 30 U.S.C.
§ 814(d), and refers to more serious conduct by an operator in connection with a violation. In
Emery Mining Corp., 9 FMSHRC 1997 (Dec. 1987), the Commission determined that
unwarrantable failure is aggravated conduct constituting more than ordinary negligence. Id. at
2001. Unwarrantable failure is characterized by such conduct as "reckless disregard,"
"intentional misconduct," "indifference," or a "serious lack of reasonable care." Id. at 2003-04;
Rochester & Pittsburgh Coal Co., 13 FMSHRC 189, 194 (Feb. 1991) (“R&P”); [see also Buck
Creek Coal, Inc. v. FMSHRC, 52 F.3d 133, 136 (7th Cir. 1995)] (approving Commission's
unwarrantable failure test).

Whether conduct is “aggravated” in the context of unwarrantable failure is determined by
looking at all the facts and circumstances of each case to see if any aggravating factors exist,
such as the length of time that the violation has existed, the extent of the violative condition,
whether the operator has been placed on notice that greater efforts are necessary for compliance,
the operator’s efforts in abating the violative condition, whether the violation is obvious or poses
a high degree of danger, and the operator’s knowledge of the existence of the violation. See
Consolidation Coal Co., 22 FMSHRC 340, 353 (Mar. 2000) . . . ; Cyprus Emerald Res. Corp.,
20 FMSHRC 790, 813 (Aug. 1998), rev’d on other grounds, 195 F.3d 42 (D.C. Cir. 1999);
Midwest Material Co., 19 FMSHRC 30, 34 (Jan. 1997); Mullins & Sons Coal Co., 16 FMSHRC
192, 195 (Feb. 1994); Peabody Coal Co., 14 FMSHRC 1258, 1261 (Aug. 1992); BethEnergy
Mines, Inc., 14 FMSHRC 1232, 1243-44 (Aug. 1992); Quinland Coal, Inc., 10 FMSHRC 705,
709 (June 1988). All of the relevant facts and circumstances of each case must be examined to
determine if an actor’s conduct is aggravated, or whether mitigating circumstances exist. Consol,
22 FMSHRC at 353. Because supervisors are held to a high standard of care, another important
factor supporting an unwarrantable failure determination is the involvement of a supervisor in the
violation. REB., 20 FMSHRC 203, 225 (Mar. 1998).

Handshoe testified that he assessed the violation as unwarrantable failure because
Lambert acted recklessly in cutting with a torch without first donning his PPE. Handshoe was
certain that although he had only been cutting for about 10 to 15 seconds when told to stop,
Lambert would have finished the cutting job, which would have taken about 5 minutes, without
wearing goggles. (Tr. 18-19.) The danger posed by his negligence was obvious as sparks were
flying a distance of three to five feet from the torch and Lambert was in a kneeling position
facing the torch about 18” away from the flame.(Tr. 18-21.) An injury could have occurred
instantaneously had a spark hit him in the eye.(Tr. 22.) Handshoe testified that Hatch had proper
PPE on hand in the shop but he felt the fact that Lambert commenced cutting the expanded metal
without eye protection with Hatch and Handshoe present indicated to him that this was a
common practice. (Tr. 36.) He designated the citation as affecting only Lambert.(Ex. S-1.)

I have taken cognizance of Respondent’s argument that in order to abate the citation
issued for the grinder, Lambert felt compelled to fabricate the guard immediately. There was
testimony that normally, this job would have been given to the welder but he was not present at
the time. (Tr. 69-70.) The choice for Lambert was either to tag out the grinder or do the cutting
himself then and there. I do not give any credence to the contention that Handshoe directed that
the guards be fabricated immediately or that he insisted that the grinder be removed from the
premises. I also consider the fact that Hatch and Lambert both testified that there has not been an
injury resulting in lost workdays at the mine in over 20 years. (Tr. 64, 75-76.) I have also
considered the fact that no one else was exposed to the hazard created by the violation and there
appear to be no prior citations for similar violations or any indication that the grinder had ever
been cited before putting Respondent on notice of a need for greater efforts at compliance. The
lack of injuries at the mine for a substantially long period of time seems to bear out the fact that
Hatch has made efforts in employing safe work practices.

I find, with the regard to the aggravating factors enumerated by the Commission,
that:(1)the length of time the violation existed was very short – 10-15 seconds;(2) the extent of
the violation was minor as it was one discreet action performed by Lambert and affected only
him and would have continued for at most, five minutes if not stopped by Handshoe;(3) there are
no alleged prior violations or notice of the need for greater compliance with the use of PPE at the
mine;(4) the operator had PPE on site which Lambert donned once told to Handshoe to do so;(5)
the violation was dangerous to Lambert but not obvious to anyone that he would have
commenced cutting without goggles, and; (5) the violation is not of the nature that the operator
could have known Lambert would engage in such conduct. As Handshoe described the events, it
happened very suddenly and unexpectedly. Otherwise, it would be safe to assume, Handshoe
would have forewarned Lambert to use the eye protection if he had any indication that Lambert
did not intend to do so. Handshoe testified that for Lambert to have neglected to put on his
glasses in the presence of Hatch and an MSHA inspector, it must be a commonly accepted
company practice. I find this alone is insufficient evidence to establish a reckless or indifferent
pattern of behavior for unwarrantable failure purposes.

Overall, this violation is dissimilar to those considered by the Commission and its ALJs
as examples of unwarrantable failure. It was not a continuing situation that management left
unabated which posed a danger to miners such as dismantling pumps allowing water to
accumulate in travelways in a mine, failing repeatedly to ensure the use of fall protection when
working at heights, knowingly allowing unsafe access to workplaces to exist, failing to provide
proper training to new miners, etc. Instead, this was stupid and careless conduct by one person
that could not have been predicted or prevented in advance. It does not rise above ordinary
negligence. It is a serious violation and it is the result of moderate negligence taking into
consideration the mitigating factors discussed herein.

II.        PENALTIES

The Mine Act delegates the duty of proposing penalties to the Secretary. 30 U.S.C.
§§815(a) and 820(a). When an operator challenges the Secretary’s proposed penalties, the
Secretary petitions the Commission to assess them. 29 C.F.R. §2700.28. Once petitioned to
assess the penalties, the Commission delegates to the administrative law judges the authority to
assess civil penalties de novo for violations under the Act. Section 110(i), 30 U.S.C. §820(i).
The administrative law judge is required by the Act to consider the following six statutory
criteria in her assessment of the appropriate penalty:

(1) the operator’s history of previous violations, (2) the appropriateness of such penalty to the size of the business of the operator charged, (3) whether the operator was negligent, (4) the effect on the operator’s ability to continue in business, (5) the gravity of the  violation, and (6)the demonstrated good faith of the person charged in attempting to           achieve rapid compliance after notification of a violation. 30 U.S.C. §820(I).

The penalty assessment for a particular violation is within the sound discretion of the
administrative law judge so long as the six statutory criteria and the deterrent purpose of the Act
are given due consideration. Sellersburg Stone Co., 5 FMSHRC 287, 294 (Mar. 1983), aff’d,
736 F.2d 1147 (7th Cir. 1984); Cantera Green, 22 FMSHRC 616, 620 (May 2000).

I have discussed the gravity and negligence involved in the citation above. I have given
the additional statutory criteria consideration as well as the deterrent purpose of the Act in
assessing the penalties below.

Respondent has asserted that the proposed penalty of $2000.00 will affect his ability to
remain in business. He was provided ten days post-hearing in which to provide financial
information to support his position. I have received Ex. R-1 which is a statement of assets and
liabilities and a review of expenses for income tax purposes dated December 2011. Although the
document is not certified from an accountant, I have considered the information. However,
based upon the modification of the citation as set forth above, I find the penalty assessed herein
will not affect the Respondent’s ability to remain in business.

Having considered the six statutory criteria and the stipulated facts, I assess a penalty of
$350.00.

III.       ORDER

Based on the criteria in section 110(i) of the Mine Act, 30 U.S.C. §820(i), I have
modified the citation to a non-unwarrantable failure and have reduced the negligence to moderate
and assess a penalty of $350.00.00. Hatch Enterprises Inc., is ORDERED TO PAY the
Secretary of Labor the sum of $350.00 within 30 days of the date of this decision.

/s/ Priscilla M. Rae

Priscilla M. Rae

Administrative Law Judge

Distribution List:

Jonathan J. Hoffmeister, Esq., Office of the Solicitor, U.S. Department of Labor, 61 Forsyth
Street, SW, Room 7T10, Atlanta, GA 30303

W. Randolph Hatch, President, Hatch Enterprises, Inc., P.O. Box 238, Branford, FL 32008