In the old street scam of "find the pea," the crooked magician hides a pea or other small object under one of three walnut shells or other hemispherical covers. The object, of course, is for the victims to guess the location of the pea after the shells have been shuffled. It is impossible to guess correctly, because the pea has been hidden elsewhere during the shuffle.

Using similar sleight of hand, the Occupational Safety and Health Administration (an arm of the U.S. Department of Labor) issued a letter in November 1999 defining employers' responsibilities for the health and


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