FORKLIFTS – Lease Vs Buy: What is Best for Your Business?

The decision whether to purchase, lease or rent forklifts depends on the particulars of the application and company preferences.

Forklifts are expensive. In fact, next to employees, they could be your largest expense. Your job is to look for ways to measure those costs accurately and reduce them.  With financial tools becoming more and more sophisticated and material handling equipment (forklifts) becoming increasingly complex it might be time to rethink the way you “purchase” your machines.  Is there a way to reduce the costs of your material handling equipment through leasing?

In a perfect world, if a forklift were idle the cost of it would be zero; if working, the cost of a forklift would be like paying an employee, e.g., $10/hour. Tie the COST to the WORK. Pay for USE. Essentially, that is what leasing or renting should do. Or at least it should get you closer to that ideal.  

Renting a forklift

Renting and leasing are almost the same. Rentals are usually short term, a few weeks or months. One advantage to renting is that you can experiment with a machine.  If you are not sure of the dealer’s response time to breakdowns, rent something for a few months and see how they respond to mechanical issues.  That experience can help you assess their capabilities.  Not sure if this “different” machine will be more productive?  Rent it for a few months and measure it against your existing forklifts.  Want to try a new method of picking?  Set up a temporary model and rent the appropriate equipment.  Use rentals to test your hypotheses.  

Peak periods are another reason to rent. Perhaps from September to December, you build up your business for the Christmas rush. To match this volume increase over this short term you may need to increase your fleet of forklifts. Return the rentals in December and save the cost of those machines for the next three-quarters of the year. Renting equipment increases your flexibility.

Renting is usually more expensive.  The extra cost of a unit pays for the machines that sit idle but available (in the dealer’s warehouse waiting to be rented).  Another reason rentals cost more is because the cost of maintenance is included in the monthly rental fee.  

The biggest difference between leasing and renting is that, when renting, you probably lose the option to purchase the machine.  A rental machine usually must be returned to the dealer.        

Leasing a forklift

Monthly leasing payments can vary from place to place. On an average, you may have to pay around $600 per month to have a forklift that cost around $25k. Monthly lease payment can be around $1100 for a forklift that costs around $50k. (That does not usually include the cost of maintenance.)

Positives Of Leasing

  • Lower Initial Costs: You can acquire an expensive machine without paying 100% of the cost upfront.
  • Increased Productivity: New machines every 3-5 years will ensure that downtime is reduced and the forklifts should be working at peak efficiency.  As labor is your highest cost it is important to get the most out of your employees. (Cost of labor is $10+/hour vs $1+/hour for your forklift).  Good tools should make more efficient workers.   
  • Cost Closely Matches Use: By spreading the cost out over 3-5 years the work done with the forklift matches the monthly lease and maintenance costs to get that work done.  It should help with budgeting.
  • Testing As You Purchase: Leasing allows you to test the machine without committing to a purchase.  Use the forklift for 3-5 years and, if it works reliably, and isn’t too well used, there is a provision to purchase it at the end of lease term.  Or return it.
  • Always Have The Latest Technology Updated Equipment:  With leasing, you get the opportunity to replace the forklift with the latest technology, updating your equipment at regular intervals. This is a strategy to keep technologically competitive in the marketplace and increase the performance of your business.
  • Tax-Advantage: In most states in the U.S. leasing is a 100% tax deductible operational expense. (Check your own state or provincial tax rules.)
  • Maintenance Cost Can Be Part Of Monthly Lease Price: It is common for the leasing company or dealer to offer maintenance packages to add to the lease payment.  This added cost will depend on the environment (e.g. cold storage maintenance costs are higher). The benefit is that you can account for it by paying one price per month.

Negatives of Leasing

  • Higher Long-term Cost: If you decide to exercise your option to purchase at the end of a term you may ultimately pay more than financing the initial purchase price of the machine. You are paying a premium (like an insurance policy) for the option of sending it back with no obligation. The dealer is taking on that risk.
  • Penalty for Over Use – the lease usually includes a clause to cover the number of hours that you intend to put on the machine. Like a car lease, if you go over that, there is a penalty. (Sometimes, if you stay with the manufacturer that penalty can be negotiated or covered in the new lease.)   
  • You Don’t Have An Asset: When you purchase a forklift outright, you can use it to borrow against, resell it, etc. But in the case of leasing, you can’t sell because you are not the owner of the machine.
  • The Possibility Of Poor Maintenance Service By The Leasing Company: As the maintenance is often up to the dealer/manufacturer or the leasing company, it may prove to be difficult to get things fixed in a timely manner. Before leasing, it is important to do your due diligence – understand the supplier’s capabilities and reputation, investigate references, etc. It may require you to include a spare machine in the contract to cover unintended downtime.

 

Buying A Forklift

Depending on your requirements purchasing could make more sense than leasing/renting. If for example, you need a machine to work one hour a week, leasing might not make sense. Purchase a used machine. Likewise, purchasing might be the best option if: 

  • there is no intention of changing the use and a machine will last 20 years
  • you have the cash to purchase, or you need the asset on your books as capital equipment
  • your bank has this inexpensive line of credit for you to use
  • or your owner simply prefers to own all capital equipment.

 Each company has their own unique policies and ways of looking at this decision.

Final Decision: Rent, Lease or Buy

More and more companies, including the majority of the Fortune Five Hundred in North America, are leasing forklifts instead of purchasing. From a budgeting standpoint, it is important to match costs with revenues. From a productivity standpoint, turning over your fleet every five years means you have newer and, therefore, more reliable machines.   Bringing in rental equipment when the demand is temporary could make good economic sense.  Leasing gives you the opportunity to keep up with new technology.  In this rapidly changing world, sometimes there is a need to retract your business.  Leasing could accommodate that.  If there is a need to radically change the way you are doing things, leasing might accommodate that.  

Every company has different needs. However, if you are not leasing now, and you have a fleet of machines, I would encourage you to consider this option. Purchasing might still be your best option but to be sure work through the benefits of leasing.

At least that’s my two cents.

 

Dan Beer has consulted on material handling and warehouse equipment along with related safety programs for 30 + years, serving companies including  Amazon, Starbucks, and Best Buy, among others. Dan can be contacted at danwbeer@gmail.com.  

 

When Online Forklift Training Makes Sense and When It Doesn’t

Wikimedia Commons: Practical training: Senior Airman Marie Zieman, 403rd Civil Engineers Squadron emergency management specialist, guides Tech. Sgt. Emile Babin through a series of forklift operations during October 2011. (U.S. Air Force photo/Tech. Sgt. Ryan Labadens)

Online or e-learning for forklift training can be beneficial for the classroom portion of the instruction delivery. Here are pros and cons to consider.

According to OSHA requirements, a forklift operator must be at least 18 years old, as well as trained and certified in order to drive a forklift without the direct supervision of a qualified trainer. In addition, lift trucks can only be operated when authorized by your employer.

Forklift operators must be trained in forklift operation, general safety and equipment management procedures. Typically, employers arrange mandatory training for their employees either in their own facility, at a training provider location or online. Individuals interested in obtaining a forklift operator job may undertake training from a training provider on their own to improve their chance of being hired for a forklift operator position. 

It is important to note that OSHA makes the rules but it neither provides training nor certifies operators. Also, it does not approve or accredit training programs. There are many online forklift operator training programs available from which to choose.  When selecting a training option, one important question to ask is “When Does Online Forklift Training Make Sense?”

When Online Forklift Training Makes Sense

  1. When you are just talking about the classroom portion of the instruction. OSHA forklift training requirements include formal (classroom) instructions, practical training and finally the evaluation of operator’s performance. So, clearly, the second and third requirements can’t be fulfilled by an online course.  Formal instructions, however, can be effectively delivered through e-learning.
  2. When you can’t afford to spare a qualified operator to provide the training. When volume spikes or unplanned absenteeism get entered into the equation, all too often the scheduled trainees can report to work for training but be left without a trainer. Online instruction eliminates this risk of lost training hours. 
  3. When there is uncertainty as to when the time will be available to do the training. On demand e-learning courses can be undertaken as time permits. Training can be undertaken anytime.
  4. When the qualified operator who performs your practical training and evaluation isn’t comfortable providing classroom instruction. Some operators make excellent practical trainers but aren’t cut out for the formal instruction aspect.
  5. When there are available computer stations to accommodate trainees. Obviously, without terminals and an adequate Internet connection, e-learning is a poor idea.

When Online Forklift Training Does Not Make Sense

There are a number of situations, however, where online training might not be the best solution. These include:

  1. When your intent is to provide practical hands-on training and evaluation of operator performance. Online instruction is only permitted for formal instructions.
  2. When you believe it is more beneficial to have your practical trainer spend the additional time with trainees to get to know them better before they get aboard a forklift during the practical portion of training.
  3. When you are looking for opportunities for employee growth and development. Organizing and delivering the classroom forklift training content can provide a useful teaching and mentoring experience for the trainer.
  4. When you are looking for every opportunity to instill the company’s values. If the trainees are new hires, it can be worthwhile to have the formal training done by a trusted employee rather than an online service.
  5. When you are at risk of IT problems such as slow internet connection.
  6. When you cannot justify the expenditure on computer stations to allow online learning, or when the online training cannot be run without risk of interruptions while it is session due to the location of the computer stations.

Conclusion

Online forklift training can be a good option to cover the classroom requirements for forklift operation. Online courses from reputable providers are designed to be thorough and engaging. They may be visually appealing, and interactive. They provide the opportunity for the trainee to work at his or her own pace, and of course, the results of training are recorded to aid in your training recordkeeping. To reiterate, however, practical, hands-on training and evaluation of operator performance must take place in the operating environment and include instruction on dealing with site specific risks that would be beyond the scope of an online course.

Forklift Battery Handling And Maintenance Best Practices

Forklift batteries cost $1,500 to $5,000 a piece. So, not giving importance to the proper maintenance might result in great financial loss or higher operating expenses in your business. Nearly all lead-acid forklift batteries provide approximately 2,000 charge cycles. This means a battery normally lasts around 5 years. But to have the maximum service life of a forklift battery, you need to take proper care of it. Without proper maintenance, your forklift battery may not even last 5 years. You can expect to use a battery longer than 5 years if you strictly follow the forklift battery handling and maintenance best practices.

Following are some useful battery maintenance and handling best practices and tips that you should follow:

1. Charge the Battery the Proper Way

People tend to charge forklift batteries whenever they feel convenient, known as “opportunity charging.” But this is a poor practice as forklift batteries should be charged only to certain degrees and at certain times. You should charge the battery until it is full every time it dips below 30 percent charge. It is important to note that both undercharging and overcharging a forklift battery can considerably lessen its life span. The best way to charge is having a fixed charge cycle and not interrupting the cycle. Never charge a forklift battery twice a day as it can cut its service life in half.

2. Regularly Equalize the Batteries

You must regularly equalize wet or flooded cell batteries. When the battery acid gets more concentrated at the bottom of the battery, the equalizing process reverses the chemical stratification. Acid and water stratification make it harder for the battery to hold a charge. Proper equalizing eliminates sulfate crystals from the plates of the battery and rebalances the electrolyte concentration. Equalizing is possible only when a battery charger has an equalizing setting. While maintenance specifications can vary from battery to battery, most batteries require equalizing almost every 5 to 10 charging cycles. Make sure you check the specifications before initiating the equalization process.

3. Frequently Check Fluid Levels

To work properly, forklift batteries require the perfect amount of water. Every 5 charge cycles, open up the battery to check the fluid levels. Check 2 to 3 battery cells and make sure that there is sufficient fluid to cover up the plastic element of the battery. In case if you are not sure checking only 2-3 cells, check all the cells and be sure about the fluid level. If you find that there is not sufficient fluid, you need to add water.

4. Maintain Correct Water Levels

Roughly every 10 charge cycles, you need to check the water level and add water to maintain right water level. Just top off the fluid in the battery and add sufficient water to cover the plastic element protector of the battery.

Just like not adding water when needed is harmful, adding extra water can be equally harmful. It is important to note that maintenance-free batteries are required to be topped off. Make sure you top off the battery only when it is fully charged. Adding water before charging the battery is a common mistake. Between 5 and 7 on the pH scale is the recommended limits for impurities. Remember, putting impure water into the battery can lead to damage of the battery.

5. Keep Forklift Batteries at a Safe Temperature

The temperature not exceeding 45℃ (113℉) is regarded as safe temperature to keep forklift batteries. For optimal cooking, try to ensure enough air circulation in and around the battery compartment. Charging a battery in extreme heat or cold can damage the battery and its service life. If you want to be 100% sure about the perfect temperature to keep and charge the battery, contact the manufacturer because the temperature can vary from battery to battery and model to model.

6. Have A Separate Battery Room

Having a designated area for charging the forklift battery is an OSHA-recommended best practice. Keep the room well ventilated. Make sure there is no open flame or smoking near batteries.

7. Move the Batteries the Right Away

As forklift batteries are quite heavy, do not allow a single person to move a forklift battery. Use special equipment such as walkie pallet jack equipped with a transfer carriage to move the battery.

8. Clean The Battery

At least once a month clean the battery with battery cleaner or warm water. Not cleaning the battery can cause faster self-discharge, voltage tracking, tray corrosion and even affect the electronics within the forklift. Some manufacturers waive the warranty if they find forklift batteries unclear.

9. Never Forget Worker Safety

It is recommended that the workers wear steel toe work boots to ensure their safety while handling a forklift battery. Having necessary arrangements for eye and hand washing nearby too are recommended to avoid health risks of the workers. Workers must wear chemical-resistant gears as well. Lead-acid battery cells contain a large volume of sulfuric acid, which can be the reason for serious chemical burns on human skin.

10. Miscellaneous

Never keep any metal objects on batteries as batteries are electrically live all the time. Metal objects can catch electricity and cause accidents. Always allow the battery enough time to cool before recharge or discharge. Never add acid or any other solutions to the battery. And never allow unauthorized representatives to service the battery. To prevent arcs and sparks, always turn off the charger before disconnecting the battery.

In a Class of Their Own: an Overview of Lift Truck Classification


A review of the 7 forklift classifications.

Class 4 forklift internal combustion

Wikimedia Commons

 

forklift history,history of lift truck

By 1927, forklifts had evolved to include back tilt. Source: Palletizer Magazine.

These days, forklift trucks are integral to material handling in manufacturing plants, distribution centers, and other operations. The first ever lift trucks were developed in the early 1900s. In fact, early models didn’t have forks at all. They had a single lift plate. As such, the earliest skids did not have a center stringer to accommodate the early lift truck. But forklifts have improved significantly over the years. Those in use today have evolved tremendously from those early beginnings.

Modern day forklifts have many different power options including electrical battery, liquid propane gas (LPG), compressed natural gas (CNG), gasoline, and diesel. There are many different types of lift trucks suited to different lift operations. The U.S. Occupational Safety and Health Administration (OSHA)  classifies lift trucks into 7 different types based on their power options and purpose of uses. Following are those 7 different classes of lift trucks:

Class I- Electric Motor Rider Trucks

Used in versatile applications, electric motor rider trucks are equipped with either pneumatic tires or cushions. The pneumatic-tired lift trucks are good fits for use in dry outdoor applications. On the other hand, the cushion-tired motor rider trucks are made for indoor use on smooth surfaces.

Powered by electric batteries, these lift trucks use transistor motor controllers to move and hoist functions. Air quality factors are important considerations when choosing an electric motor rider truck for indoor use. These lift vehicles are mostly used in storage facilities and loading docks.

Most of these lift trucks are counterbalanced rider type. Three Wheel Electric Trucks also fall under this category.

Class II – Narrow Aisle Electric Motor Trucks

Class 2 forklift

Wikipedia Commons

Made for use in narrow aisle operations, narrow aisle trucks allow operators to maximize their use of storage space. Because they can operate efficiently in narrow passageways, storage racks can be set closer together than they could be in a conventional facility, providing greater storage capacity. Reach type outriggers, order pickers, side loaders and turret trucks are examples of narrow aisle electric motor trucks.

Class III – Hand-Rider or Electric Motor Hand Trucks

These are comparatively smaller capacity lift trucks that run on industrial electric batteries. As the name suggests, this kind of truck is hand controlled. The lift controls of the truck are mounted on top of the tiller and the operator moves the tiller side to side to navigate the truck. They are frequently used for palletized loads both in low and high lift operations.  

Class IV – Cushion Tired Internal Combustion Engine Trucks

Used indoors on smooth dry surfaces, these lift trucks are used for transporting palletized loads. These forklifts are commonly used in storage and load areas. As cushion-tired lift trucks are lower to the ground than pneumatic-tired lift trucks, cushion tired internal combustion engine trucks are used mainly in low clearance applications.  

Class V- Pneumatic Tired Internal Combustion Engine Trucks

Most commonly used in warehouses, these lift trucks are used both indoors and outdoors for many different types of applications ranging from a single unit load to a 40-foot container. These lift trucks are available for use with compressed natural gas, diesel, gasoline and LPG as well.

Class VI- Internal Combustion and Electric Engine Combo Tractors

Very versatile in operations, these lift trucks have options to power using both internal combustion and electric engines. For indoor use, electric power is preferred. For outdoor use, the powerful internal combustion engine is used.

Class VII- Rough Terrain Forklift Trucks

These are quite large lift trucks with huge floatation type tires. These trucks are capable of working on difficult outdoor surfaces. They are quite frequently used in large construction sites for lifting building materials. Auto recyclers and lumber years too frequently use rough terrain forklift trucks.

 

Should I Buy New Or Used Forklifts?


When deciding to buy either a new or used forklift, there are several factors to weigh.

Wikipedia Commons. Photo by Patsy Lynch/FEMA

Forklifts are expensive machines, so do your homework before you make a buying decision. Given an unlimited budget, everyone would like to have a shiny, new forklift with the latest technology, but for a lot of operations, the decision of whether to go with new or used mobile equipment is a difficult one. There is no easy and straightforward answer to the question of whether to buy new or procure a used unit. Take the time to assess the pros and cons of both options before you make a final decision.

The Cost Difference between New and Used Forklifts

Unfortunately, budgets are often constrained, and people look for ways to cut the cost. Going for a used forklift can offer significant price savings may turn out to be an ill-advised move if you end up paying too much for maintenance and a machine that is only going to have a short remaining service life. Let’s have a look at the price difference:

An electric warehouse forklift with standard capacity like 5000 pounds will cost you $15K-$25K. You need to spend another $2k to $5k for a battery and its charger. A brand new internal combustion (IC) forklift with similar capacity can cost as much as $30k. A high-end forklift that can handle even 35,000 pounds at a time can cost more than $100k.  

On the other hand, a used but well refurbished used electric forklift with 3000-pound capacity will cost $5k-$10k. A similar capacity IC forklift will cost $10k-$15k. So, going for a used forklift, you can expect to have 30% to 50% cost savings. But cost saving should not be the only factor when deciding whether to buy new or used forklifts.

Pros And Cons Of Buying A New Forklift

Pros

  • Buying a new forklift allows you to have the newest and latest model in the market.
  • You pay the listed price with no need for bargaining.
  • A new forklift should last longer and handle long hours at an efficient pace under proper maintenance.
  • Higher overhead.
  • All the parts of the forklift will be brand new contrary to used forklifts.  
  • You get precisely what you want.
  • You get a 12-36 months warranty.

Cons

  • Very expensive.
  • Financing, purchasing can involve lengthy paperwork

Pros And Cons Of Buying A Used Forklift

Pros

  • Huge cost saving (30%-50% less than brand new forklifts).
  • Quicker purchasing process.
  • Quicker delivery.

Cons

  • You normally don’t get a forklift as per your desired specifications and forgo some features.
  • You don’t get the newest model in the market.
  • The price valuation of the used forklift is important. If you do it wrong, you might lose big in the bargaining.
  • Less overhead.
  • Won’t work as efficiently as a new one.
  • Higher maintenance cost.
  • No or very limited warranty.

When To Buy Used Forklifts

According to experts, buying a used forklift is a good idea if the required daily use of the forklift is less than 4 hours. If you plan on using a forklift for more than 4 hours a day, it might not perform well for long enough. Still, the used forklift needs to be in good condition. It requires exceptional valuation and negotiation skills to buy a used forklift. Again, there remains the risk of buying from an uncertified seller. Buying a forklift from an individual is always risky. So, consider finding a certified dealer before you proceed. Availability of used and refurbished forklifts is another important consideration.

When To Buy New Forklifts

As mentioned before, when the required daily use of the forklift is more than 4 hours, you consider a new forklift. The 12-36 month warranty is a very important advantage that is money well spent for such heavy use.  

 

Walk This Way: Pedestrian Safety In Forklift Operations

Forklift warning lights

Every year, more than 68,400 forklift accidents take place in the United States. Far too many of them injure pedestrians. The National Institute for Occupational Safety and Health (NIOSH) report reveals that nearly 20 percent of all forklift accidents involve pedestrians being struck by the forklifts. With proper awareness and pedestrian training, the rate of accidents can be significantly reduced.

Having formal forklift training is an OSHA requirement. While OSHA does not specially address forklift pedestrian training, the OSHA General Duty Clause instructs companies to take all the precautionary steps to protect all employees. This includes ensuring that workers who are exposed to forklifts and lift trucks in operation receive the instruction necessary to preserve their safety on the job.

Very often, warehouse managers do not realize the significance of training pedestrians exposed to any kind of lifting operation. When the pedestrian is ignorant of basic safety precautions around lift trucks, the chances of an accident involving the forklift and pedestrian increase.

Common Forklift/Pedestrian Accident Situations

Following are two common situations accidents involving pedestrians and forklifts take place:
Pedestrian Came Too Close To Lift Trucks  There is no way a collision involving a pedestrian can take place if the pedestrian does not come within a close proximity of a forklift. Maintaining at least a 4-foot safety zone is highly recommended when the forklift is running. This precaution can lessen the risk of the lift truck driving over the pedestrian’s foot.

But the actual safety zone can be much longer than just 4 feet. In the employee or pedestrian awareness programs, companies should let the pedestrians know that the back end of lift trucks can swing very quickly to the side. Normally, forklifts that comes with elevated forks necessitate proportionately higher safety clearance. The horizontal length of a load is another important consideration. A long load like a 20-foot long lumber package will need a proper safety clearance especially when the lift truck turns.
Pedestrian Did Not Notice The Lift Truck In Operation  In many cases, pedestrians don’t see the lift truck in operation. Blind corners and varying degrees of intersections can be reasons for not seeing the lift truck. So, pedestrians should be aware of those to be safe from accidents. Pedestrians may not hear the lift truck in operation as different power sources of forklifts determine the sound generated in operation. For instance, electric battery powered lift trucks can be very quiet, the internal combustion lift trucks can be very loud. So, if not well-aware of different sounds generated by different forklifts, a pedestrian might equate a lack of noise with the absence of a lift truck in operation.

Ways To Increase Pedestrian Safety In Forklift Operations

The frequency of forklift accidents involving pedestrians can be significantly reduced by providing awareness training, using right safety equipment and better traffic management.

Training and Awareness for Pedestrians  Proper pedestrian awareness and training should not take much time and effort. First of all, pedestrians need to be aware of the fact that lift trucks can suddenly appear around the blind corners. The training can work as a reminder to the pedestrian to stop, listen and look carefully when working or staying around the blind corners. Pedestrians should always expect a sudden appearance of a lift truck.

Before crossing a forklift’s path, a pedestrian must maintain eye contact with the forklift driver. When the eye contact is not possible or difficult like when crossing the path behind the forklift, giving the driver a verbal alert is mandatory. Alertness and communication are crucial. When crossing behind a forklift that may back up, be sure to make verbal communication with the operator before crossing, or to wait at a safe distance until it has finished backing up.

Other important safety rules that need to be included in pedestrian training and awareness programs include never riding on a forklift truck unless the vehicle is specially designed to accommodate a passenger, keeping clear of a forklift and loading swing radius. Never walk under a load.

Traffic Management  Safety professionals recommend the creation of separate routes for pedestrians made easily noticeable through painted lines and signage. Having physical barriers to keep forklifts from entering pedestrian-only routes can be a very effective solution. If having physical barriers is difficult or not possible, avoiding forklift use in areas with high levels of pedestrian activity can be a good solution. Having and maintaining safety rules for both pedestrians and lift trucks are very important.

Safety Equipment  Safety best practices dictate that pedestrians should wear a highly visible vest step for improving visibility. Having and using forklift truck horns, adding warning lights, or travel alarms are good measures as well. The use of convex mirrors at intersections can improve pedestrian safety by providing the pedestrians with better chances of seeing the forklifts in operation.

Conclusion

While the training of forklift operators is mandatory, facility operators are also required to protect the safety of pedestrians who traverse in proximity to material handling equipment. Take care to consider the safety of pedestrians who might not be obvious such as sales, maintenance or clerical personnel, supplier representatives or contractors working at the site.

Note: The information provided above is intended only to provide general guidance. For specific regulatory requirements in your jurisdiction, please contact a local safety professional or appropriate compliance professional.