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The following appeared in a memo from the Board of Directors of Butler Manufacturing. "During the past year, workers at Butler Manufacturing reported 30 percent more on-the-job accidents than workers at nearby Panoply Industries, where the work shifts are one hour shorter than ours. A recent government study reports that fatigue and sleep deprivation among workers are significant contributing factors in many on-the-job accidents. Therefore, we recommend that Butler Manufacturing shorten each of its work shifts by one hour. Shorter shifts will allow Butler to improve its safety record by ensuring that its employees are adequately rested."