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On the other hand, if you're insisting that employees have to go outside to smoke, building a smoking shelter or allowing them access to a balcony is likely to be a welcome gesture

Call as soon as the area is safe to enter

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The MUTPA makes it unlawful to use "[u]nfair methods of competition and unfair or deceptive acts or practices in the conduct of any trade or commerce." 65 To determine whether the respondents' claims under the MUTPA were preempted by the FCLAA, the Court used the "predicate-duty" test it developed in Cipollone