Call to Order
Chairperson Dick Stoffer called the meeting to order at 10:00 am with
a quorum present.
Presentation and Introductions
Chairman Stoffer presented Lynn Walding with a certificate recognizing
his twenty years of service to the State of Iowa.
Staff and guests introduced themselves.
Minutes of Previous Meeting
Mr. Stoffer asked for discussion of the April 19, 2001 Minutes. There
was no discussion.
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Motion: |
Bob Cramer moved the Minutes of April 19,
2001 stand approved as submitted. Shirley Daggett seconded the
motion, and it passed by unanimous vote. |
Sales Report
Total sales for fiscal year 2001 were $110.4 million, which is about
$4.9 million above last year’s mark. Sales exceeded $100 million
for the first time last year setting a new record. Preliminary figures
indicate a 4.6% increase in dollar sales for the year and approximately
1% in volume according to Jim Kuhlman.
Product Buyout Information
The total investment in the Buyout Program for fiscal year 2001 was
$9.8 million, a little less than the previous year. The percent of
rate of return was 8.6% with a dollar profit of $817,000 for the year.
Financial Report
Jim Kuhlman reported General Fund Transfers through April were $2.5
million ahead of last year due to strong sales and continued efficiencies
in the Division’s operations. Figures reflect the highest amount
of gallons sold since 1988.
Beer tax collections reflect a fairly constant rise the last several
years. Wine tax collections for this year show a slight decline.
Budget
The operating budget for fiscal 2001 was $1.6 million. The Legislature
slashed 6% from that budget resulting in a $96,000, or 6%, cut from
the FY2001 budget. The FY2002 operating budget is $1.5 million. Also,
there was a slight reduction in spendable receipts which is money
received by the Division for rent from the Lottery and some of the
Divisions of the Department of Commerce. In addition, through negotiations
with AFSCME, all state employees were awarded a 3% pay raise effective
July 1st; however, the Legislature only funded 78% of the salary increase.
The total cut from the operating funds is $119,000 or 7%.
In past years, the Division was allowed to keep fines levied against
licensees to expend for educational purposes in a Civil Penalty Fund.
A few years ago, the fund became a direct appropriation of $37,500
and was more recently reduced to a $25,000 appropriation earmarked
for licensee education. Those funds were used to conduct seminars
and to produce videos, produce the red book, Iowa’s Alcoholic
Beverage Laws and You, and last year the money was used for the Booze,
Butts and Bingo: Retail Compliance Training conducted in 12 cities
throughout the state. The Legislature completely cut those funds this
year. Although the money is not a significant amount, it reflects
a policy shift.
The Tobacco Enforcement budget was cut about $108,000. This was a
negotiated amount between the Department of Health and the Alcoholic
Beverages Division.
The bottom line of all budget cuts amounted to $228,000 or a total
of 7%. Mr. Kuhlman explained that one of the bureau chiefs, Dennis
Mitcham, retired in June and his position will remain vacant absorbing
a major part of the budget cuts. Mr. Kuhlman has assumed Mr. Mitcham’s
duties.
Warehouse Contract Transition
Mr. Kuhlman reported that the advantage of continuing the contract
with the J. A. Jones Management Services resulted in a smooth warehouse
contract transition. There were several changes in the contract:
- J. A. Jones Company will backhaul damaged merchandise found
by storeowners on a weekly basis providing improved customer service.
- The Jones Company will be responsible for some warehouse maintenance
including maintenance of the dock doors, dock ramps, levelers,
outdoor lights, etc.
- The new price of $1.85 per case will save the General Fund approximately
$90,000 this year. Over the course of the five-year term, the
savings will be close to $500,000 with increased services. The
previous per case price was $1.94.
Administrative Rule on Surety Bond Requirements
Judy Seib reported some of the current rules in Chapter 185 have typographical
and scrivener’s errors and the proposed Administrative Rule on
Surety Bond Requirements corrects these errors.
Item 1. Amend subrule 185-4.23(4) paragraph f. The rule will reinsert
the word no making the rule read no admission fees of any kind . .
. .This rule describes a private place for the purpose of a catering
privilege as opposed to a public place.
Item 2. Amend subrule 185-5.9(4) as described in the Commission booklet.
According to Ms. Seib, the surety bond cancellation language was in
the dram shop translation rule and the dram shop cancellation rule
was in the surety bond language. The proposed amendment puts the items
in the proper section.
Mr. Cramer asked if other alternatives were proposed such as a letter
of credit or an escrow of funds. He would like to give the licensees
another option for the well-managed place of business to have the
coverage without wasting the money. Daryl Henze commented that it
would be cheaper for a business to post an escrow account or a letter
of credit as opposed to the surety bond. Ms. Seib responded a letter
of credit or an escrow of funds would take a statutory change for
Class E’s but it wouldn’t for the bars. Several years ago,
according to Seib, every bar in the state of Iowa had to have a $500
surety bond because they paid a 15% licensee tax on liquor purchased
from state liquor stores. That tax was rescinded and removed from
the Code years ago; however, the language in the rule was not updated.
The surety bond language is mandatory because Class E licensees buy
liquor from the state.
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Bob Cramer moved the two proposed amendments
be filed Notice of Intended Action. Daryl Henze seconded the
motion and it passed by unanimous vote. |
Mr. Walding stated the division would explore options.
State Tobacco Initiative
Lynn Walding complimented Gary Marker, Nicole Watson and others who
worked on the tobacco program the first year.
Gary Marker announced that the division is close to signing a new
contract with the Department of Health for tobacco enforcement in
FY2002. The division will continue to work with the current 202 law
enforcement partners as well as expand to other areas. Approximately
8,000 tobacco compliance checks were conducted in the past six months
with 100% coverage of the state. The Iowa State Patrol conducted checks
in areas where there was no law enforcement partnership coverage.
Many local law enforcement officials notify retailers that they are
partnering with the Alcoholic Beverages Division and that they will
be checking. Mr. Walding sent letters to all permittees in December
stating checks would be conducted.
There are approximately 5,000 tobacco retailers statewide, all of
whom were checked at least once and many were checked a second time.
The division is seeking voluntary compliance; however, the law has
stiff penalties for those who do sell. The division has a sub-agreement
with the Attorney General’s Office and Assistant Attorney General
Kevin McCarthy has been working with city and county attorneys to
enforce the laws. In the past, there were no consequences when licensees
were not in compliance.
In FY02 the division will supply information to the Department of
Health on the federally required SYNAR checks. If 28% or more of the
retailers are noncompliant in FY02, Iowa will loose 40% (approximately
$5,000,000) of the Substance Abuse Block Grant administered by the
federal agency.
The second component of the State Tobacco Initiative is education.
The first six months of the program was spent primarily on educational
efforts. The tobacco advisory committee (ITACom) indicated they would
like to have a calendar at the cash register to help them determine
proper age to purchase. The division put together a tear-away calendar
for June – December 2001 and a 2002 calendar showing the age
an individual must be to purchase either tobacco or alcohol on this
date. Break room posters, a 5-step ID process and other training materials
have been produced and distributed to retailers.
Nicole Watson gave preliminary reports for FY01. The overall noncompliance
rate for the state is 18%. In the past, this has been as high as 30%.
In FY01, the State had to have a noncompliance rate of 31%; for FY02
- 28%; FY03 – 20%. The agency’s goal is single digit noncompliance.
Unfortunately, convenience stores and grocery stores, which have the
greatest proportion of tobacco retailers in Iowa, have the lowest
compliance rate. Mr. Marker said it was discouraging to note that
57% of clerks who asked for identification sold to a minor which indicates
the clerk did not know how to properly evaluate the ID.
The first round of all retailers checked resulted in 80% compliance,
the second round resulted in 87% compliance which shows that active
enforcement of tobacco laws is having an effect on sales to minors.
Mr. Marker reported on the pilot program of Cops in Shops in 50 cities
where police officers posed as clerks in retail establishments. Over
one-half of the tickets written were to adults buying tobacco for
kids in the parking lot. The young adult was cited for buying for
the juvenile and the juvenile was cited for possession. Publicity
surrounding the program was excellent.
Counsel’s Report
Mr. Lundquist stated the large number of complaints listed in the
Commission packet is an indication of the educational efforts done
by the state to educate law enforcement officers on how to do liquor
compliance checks. There is more awareness among law enforcement officers
and licensees about what constitutes a violation and more communities
are interested in prosecuting administratively these types of violations.
To address the backlog of cases and concerns regarding lag time between
the complaint and the case actually being heard, field staff has been
working in the office helping prepare cases.
The tied house litigation with regard to Game Works continues. There
has not been a transfer in ownership at this time.
Mr. Walding stated the complaint against the Union Bar in Iowa City
has been settled. The Union Bar paid a $2,000 civil fine and is currently
serving a 21-day suspension.
Organizational Chart
The revised organizational chart reflects restructuring based on legislative
budget cuts for FY02. The Products/Customer Service Bureau has been
merged into the Operations Management Bureau reducing the number of
bureaus from four to three.
Mary Strait, Licensing Specialist, took disability and her position
in Licensing has not been filled. Annie Carroll has temporarily transferred
from Order Entry to Licensing. In addition, the regulatory staff is
working in Licensing on a regular basis.
Dram Shop Insurance
According to Lynn Walding, a tragic accident last summer involving
the death of a five-year-old child by a drunken driver brought to
the forefront the issue of what should be the proper amount of dram
shop insurance. Iowa law currently requires every on-premises licensed
establishment to provide dram shop insurance. The legislature, in
123.92, determines that the Alcoholic Beverages Division is best suited
to determine that rate. Administrative Rule 185, Iowa Administrative
Code 5.8, sets the limits of liability. Under current Iowa law, an
insurance company writes a 10/20/5 policy providing $10,000 for bodily
injury or harm in one instance; $20,000 in the aggregate sense of
bodily injury; and $5,000 for loss and means of support. There is
nothing explicitly written about property and the $25,000 is all that
one person can receive which is very low in comparison to most other
jurisdictions.
Nick Podsiadly, with the assistance of Judy Seib and John Lundquist,
worked extensively on this issue. The rate has not been increased
since the rule was initially put into place in the late 60’s
or early 70’s. The statute has been on record since shortly after
Prohibition.
The attorney for the parents of the little girl killed has indicated
the family is supportive of an increase in dram shop insurance. Other
attorneys representing families who lost loved ones as a result of
a drunk driver accident have contacted Mr. Walding arguing that rates
should be higher.
In drafting the rule, the division worked in coordination with the
Insurance Commission to determine the impact on the Alcoholic Beverages
Division and what it means with regard to insurance premiums. The
final implication will not be clear until after the rule is submitted.
The state of Iowa is substantially below the amounts required in many
other states.
There are many companies that write dram. There is little competition
in the market because the rates are so low; therefore, the companies
who do offer dram shop coverage command a fairly high premium. Mr.
Podsiadly submitted a draft proposal raising the rates about 3 times
the current rate.
The Wisconsin law review article provides justification for states
having dram shop. Part of the argument is to provide insurance coverage
for victims of drunk driving accidents so they do not feel the economic
impact alone. A second reason is that oftentimes the driver does not
have adequate coverage and the economic impact falls on the victim.
The article talks about putting the responsibility on the licensee
class because dram shop insurance is available providing specific
insurance for these types of accidents. Another argument is that the
licensee class is best able to regulate and control consumption through
sales, and that licensees will be more likely to do retail training
if they have responsibility and liability.
Mr. Stan Walk, a licensee from the St. Ansgar area, sent a letter
to Mr. Walding and the Commissioners in response to an article in
the Des Moines Register. He made the following points:
- The driver should not be allowed to recover damages.
- Insurance carriers settle claims because it is only $10,000
rather than pay the cost of litigation.
- People file frivolous claims.
In response to a question by Mr. Cramer regarding contiguous states,
Mr. Podsiadly responded:
- South Dakota and Nebraska do not have dram shop insurance.
- Wisconsin has host liability only.
- Missouri does not have dram shop insurance following the interpretation
of their Supreme Court Rule.
- Minnesota has dram shop insurance.
- Illinois has a capital limit set by their county so their county
can impose a stiffer dram limitation. The information was not
available by county; however, they are capped on average about
$40,000 - $50,000 across the state of Illinois.
In reply to a request for examples of rates in other states, Mr.
Walding gave the following: > > Alabama has $100,000
- Arkansas has $200,000
- Colorado has $150,000
- Connecticut has $20,000
- Maine has $250,000
- Michigan has $50,000
- Minnesota has $100,000
- New Mexico has $50,000
- North Carolina has $500,000
- Oregon has $300,000
- Utah has $500,000
Mr. Podsiadly pointed out that any changes to the way the law is
written must be done statutorily. The statutory language requires
that every licensed liquor establishment that sells on premises
must have three areas of coverage: personal injury or death of a
party, loss and means of support and property damage. The rule implements
statutory language. The current rule skirts the issue on the limits;
the new rule will address each of the separate areas. The idea behind
the change in the rule is to update it in a fashion that is relevant
to the inflationary rates of insurance policies. The second reason
is to address the actual statutory language and correct it to be
in tune with what was codified.
Mr. Cramer stated he believes an establishment who pours more should
pay more for insurance. Mr. Podsiadly replied that insurance companies
use a rate multiplier that goes up or down depending on the number
of claims against the establishment, whether server training is
offered, the number of liquor sales versus number of food sales
and a number of other issues. The insurance company establishes
a base rate for the level of coverage. The more violations an establishment
has, the rate multiplier will go up exponentially. Establishments
with live music four nights a week might draw a different crowd
and the insurance companies adjust their rates accordingly. The
type of business does play a factor in the insurance premium. The
limits set a responsible limit for minimum insurance coverage so
that everybody in the state has to have a uniform requirement; however,
the type of establishment determines the amount of risk.
Mr. Podsiadly commented that in addition to raising the rates of
the inherent coverage, there were some clarifications expanding
the coverage currently written. There are a number of loopholes
that insurance companies currently use to reduce coverage while
maintaining the lowest rate. These companies commonly put in exclusions
for continuous coverage during licensee suspension periods. The
new rule will have requirements maintaining that they must have
insurance even during suspension periods to make sure the coverage
is in effect at all times.
The amended rule also addresses comments and changes requested by
the Iowa Insurance Division. Under 5.8(3) Permitted Policies, a
distinction is made between the Claims Made Policies and Occurrence
Policies. Some policies are being written whereby the coverage is
tied to the number of claims made against the license. When the
maximum insurance coverage for a year is reached, the licensee no
longer has dram shop insurance for the rest of the year. This rule
will guarantee coverage throughout the year.
Mr. Walding clarified that under Iowa law, there is dram shop liability.
If there is an accident causing $1,000,000 in damages, the bar owner
is liable for the $1,000,000 damage. Many bars are incorporated
which creates the corporate shield from that liability which is
why the state requires liability insurance up to certain rates.
The Alcoholic Beverages Division determines what that rate is.
Mr. Walding stated that the division is sensitive to what the rate
does to premiums; there is no intent to drive people out of the
business. The CEO of Merchants Bonding Company has contacted Mr.
Walding and offered to review the proposed rule and give an estimate
of what this action would do with regard to setting premiums for
the dram shop insurance.
This proposed administrative rule would not go into effect immediately.
The Notice of Intended Action will be published August 8, 2001.
The hearing will be held August 28, 2001 in the Board Room of the
Alcoholic Beverages Division. The earliest date the rule can take
effect is January 1, 2002. After the effective date, applicants
for new licenses will have the expanded coverage at the new rate.
Current license holders will be required to have the expanded coverage
at the time of their renewal.
In response to a comment by Mr. Cramer that the definition of sales
should include cover charges as part of total sales, Mr. Walding
stated it is a risk assessment determined by the insurance companies.
Mr. Podsiadly said policies are established by the Insurance Division
in the Department of Commerce and the Alcoholic Beverages Division
works within those guidelines in dealing with the industry. Alcoholic
Beverages Division’s role is to make sure the coverage is there
and to establish a limit per statutory law. Any changes in the industry
would have to be handled by the Insurance Division.
Mr. Walding commented members of the Iowa Hospitality Association
and some legislators expressed concerns regarding dram shop insurance
at a meeting last fall in Cedar Rapids. The Iowa Hospitality Association
helped introduce HSB 133 last year to limit the dram to not include
persons whose intoxication contributed to the injury. The bill did
not get out of committee; it is a live round for next year. The
Association also argued that off premises license holders should
have to carry dram shop insurance – it should not be limited
to on-premises license holders. From the agency’s perspective,
those are legislative issues and the division is simply reacting
to the legislative requirement that now exists.
Craig Tweet, Tweeters, Okaboji
Mr. Tweet stated he would like to see rates based on purchases which
would level the playing field. In addition, he would like to see dram
shop requirements for everybody who sells.
Mr. Cramer commented he would like to see categories that take into
consideration each situation. Mr. Cramer believes rates based on purchases
versus sales would be a good idea because of cover charges that allow
licensees to substantially reduce the price that is being charged
for a drink.
Lewis Cassen from Maxwell’s Beach Café
Mr. Cassen stated restaurant and bar-owners act as police and as insurers,
and as far as he is concerned, it is because legislative bodies around
the country refuse to take the notion of drunk driving seriously.
Legislators talk about stiff fines, suspension of licenses, and going
from 1.0 to .8 but these are very modest efforts. In other parts of
the civilized world, BAC levels go as low as .4. In Queensland, Australia,
anyone stopped by a policeman, regardless of the time of day, must
take a sobriety test. Mr. Cassen said that restaurant and bar-owners
do their best to run a good business and the 18-year-old kids get
fake IDs to beat the system. The business pays the penalty and the
kid gets a slap on the hand. Mr. Cassen believes penalties should
be stiff if society really wants to stop underage drinking and keep
drunk drivers off the road. He advocates taking a drivers license
for 3 years, not six months.
Mr. Cramer commented the Commissioners are looking at all avenues
and trying to make the playing field level. It is the Commissioners
job to address the problems business owners must deal with and make
recommendations. The legislature will have to deal with it in their
normal course.
Mr. Walding commented many states, including Iowa, have dram coverage
for minors under host liability. Iowa also has it for adults and this
rule affects adults as well as minors.
Craig Foss from Outback
Mr. Foss believes the fine should be the same amount to the person
breaking the law as it is to the business owner. If an underage person
tries to buy a drink and the business owner and the server each get
fined $1500, then the minor and maybe the minor’s parents should
also receive $1500 fines.
Ms. Seib said the fine for a minor is $100 or $200 depending on the
number of prior violations he/she has. There is also the loss of driving
privilege that puts the individual on SR22 and increases the insurance
rate.
Mr. Walding reminded the owners that as a licensee they have the right
to confiscate false ID’s and turn them over to law enforcement.
He commented again that the issue is dram shop and serving people
to a point of intoxication. Under Iowa law, a bartender or server
can serve an intoxicated person, its whether the bartender or server
knew or should have known the person was intoxicated.
Mr. Tweet commented it is sometimes very difficult to identify an
intoxicated person because some people hold their liquor better than
others. Mr. Cassen added that a person might look and act sober even
though he has already consumed drinks prior to entering an establishment.
The one drink served at the bar or restaurant may be enough to tip
him over the edge to intoxication.
Betsy Tonsfeldt — TIPS
Several establishments have taken advantage of the TIPS training through
Iowa Lakes Community College according to Ms. Tonsfeldt. The TIPS
training provides ways to identify intoxicated people and helps servers
to implement some positive training intervention techniques to keep
an intoxicated person from getting in a car and driving. The training
also teaches how to slow down the service and help reduce the intoxication
by not over-serving the person to the point where they become intoxicated.
This summer through a grant from the Dickinson County Board of Health,
all establishment owners in the county were sent a card and encouraged
to send their potential servers to attend free training. The Board
of Health was convinced that if training was provided for bartenders,
managers and their staff that they could help reduce some of the problems
experienced in the area. About 35 people took advantage of the training.
Of the participants who participated in the free training, 54% of
the servers were over the age of 21.
As a result of the training:
- 84% said they would feel comfortable intervening (checking IDs
for the birth date as well as for the year, calling their manager,
or perhaps calling the police or offering alternate transportation
to keep that person off the road).
- 100% of the participants felt the training met their goal as
to what they would want to get out of the training.
- 47% said their biggest problem results from over-serving, serving
to the point of visible intoxication.
- Their second biggest problem was an intoxicated walk-in.
- The third biggest problem was underage.
- 92% felt the training should be mandatory for any servers.
- 96% said they thought the beverage industry should be involved
in the training or in support of the training.
The cost for the TIPS training is $45 because the book is expensive
even though Miller and Anheisuer Bush underwrite it. The Board of
Health hopes to provide free training again next summer for servers
in Dickinson County to get as many servers involved in the training
as possible.
Terry Yarns — Remingtons
Mr. Yarns said from an economic standpoint, raising the insurance
levels is going to cost the licensees more money. He also commented
that he believed in the TIPS training, but from an economic standpoint,
he receives no break on his insurance premium. He would like to see
a financial incentive on the insurance premium for business people
who take the TIPS training.
Ms. Tonsfeldt said she understood that four insurance companies do
recognize the TIPS program.
In response to a question by Mr. Cramer whether the businesses had
servers under the age of 21 and if they thought it would be beneficial
to them to hire only servers over 21, Mr. Cassen replied he thought
it would be an absolute disaster. It would deprive a lot of college
kids the ability to make money to go to college. Mr. Cassen has waitresses
that make $10,000 - $12,000 a season that pays for their college.
In addition, it would be difficult to find help to work the nights
and weekend shifts.
Mr. Cramer asked if the business people would agree that servers and
bartenders under 21 are subject to intimidation and peer pressures.
The response was that the business owners watch their employees closely
and if there are a lot of young people in the restaurant or bar, they
are watched more closely because they know they are friends of the
server. Mr. Cassen said usually the bartender is not under 21; it’s
the servers and wait staff that tend to be under 21.
Julie Fillenwarth — Fillenwarth Resorts
Ms. Fillenwarth said she doesn’t think it is an issue with 18,
19 and 20 year-old-servers. Fillenwarth Resorts has very responsible
18, 19 and 20 year-old-servers and Ms. Fillenwarth knows it is her
responsibility to make sure the people that she hires to serve are
responsible.
Mr. Walding reiterated that many of the issues raised pertain to legislative
issues that the Commission has no authority to act upon. Mr. Stoffer
added that the Commission’s duty is to listen to the publics
concerns and voice them to the legislature or to the Governor.
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Shirley Daggett moved the proposed Dram Shop
Administrative Rule be filed Notice of Intended Action. Daryl
Henze seconded the motion. The rule will be published in the
Iowa Administrative Bulletin. Comments regarding the rule may
be presented in writing via mail, e-mail, or fax and in person
at the public hearing which will be held in the Board Room of
the Alcoholic Beverages Division, 1918 S.E. Hulsizer Rd., Ankeny,
Iowa at 2:00 p.m. on August 28, 2001. Motion carried unanimously. |
Binge Drinking on College Campuses
The Commission has held public forums in Iowa City and in Ames exploring
whether a statewide law would be in order, and if so, would it have
price restrictions or limit happy hours. Currently, local jurisdictions
have authority to do that. Iowa City has just enacted a law restricting
certain sales tactics. Licensees in Iowa City weren’t opposed
to certain price restrictions as long as everybody played by the same
set of rules. The question is whether price specials or certain type
of price structuring promotes responsible or irresponsible drinking
habits and if it does, should the law reflect that. The Commission
has no legislative authority, but can make a recommendation to the
Governor and the legislative body.
In response to a question by Ms. Daggett, Mr. Lundquist said that
Iowa City is still not restricting access to bars between the ages
of 18 and 21. Local communities may, if they choose to, pass local
ordinances to bar access to drinking establishments to those who are
under age. Most communities in the state don’t.
There was no comment from the public regarding the binge drinking
issue. Mr. Stoffer commented it is important that the Commissioners
narrow their focus on the binge drinking issue and reach a consensus
for recommendations to the Governor and the legislative body.
Election of Officers
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Shirley Daggett nominated Bob Cramer as chairman.
Daryl Henze 2nd the motion. The motion carried with Bob Cramer
abstaining from the vote.
Shirley Daggett nominated Daryl Henze as vice-chairman. Bob
Cramer 2nd the motion. The motion carried.
Shirley Daggett nominated Gayle Collins as secretary. Daryl
Henze seconded the motion. The motion carried unanimously. |
Meetings
Suggestions for the next meeting site were Cedar Falls, Cedar Rapids
or Davenport. Commissioners will be notified of the date and time.
In closing, Mr. Walding recognized Nick Podsiadly who started as an
intern and currently is an administrative assistant in the office.
Mr. Podsiadly has done an excellent job working on the Administrative
Rules as well as on the tobacco program. He will be leaving soon to
attend law school.
Adjournment
Commissioner Stoffer thanked the speakers for their input. Deliberations
on the issues will continue at the next meeting.
The meeting adjourned at 11:45 a.m.
DARYL K. HENZE, Secretary
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