A REPORT ON CONSUMER ASSOCIAION OF BANGLADESH AND ITS ROLE
Consumers Association of Bangladesh (CAB) a non-government and non-profit organization, established in 1978 at the initiative of a group of Dhakaits imbued with the idea of consumerism, a movement that already took shape in Europe and America. Since its inception, CAB has been trying to spread the essence of consumerism among poor and low-middle class consumers have attempted to organise activities for the promotion and protection of the rights and interests of the consumers.
The major objectives of CAB are to:
| a) | make consumers aware of their rights and responsibilities; |
| b) | promote consumer education, aiming at raising awareness of consumers against exploitation, and providing them with technical knowledge and support for real protection; |
| c) | focus on consumers’ problems and develop a spirit of mutual co-operation and understanding among different groups, associations, institutions, NGOs and government agencies functioning in the interests of the welfare of the people; |
| d) | exchange information and knowledge of various actions about consumer protection with national and international organizations; |
| e) | Organize and set-up consumers associations and groups at the districts and thana level; and |
| f) | undertake research studies on consumer issues and problems. |
CAB activities in consumer education include mainly the publication of a monthly bulletin in Bangla titled Consumers’ Voice to provide consumers with information of various consumer issues and problem. CAB also publishes a quarterly bulletin in English, which it distributes to different organisations at home and abroad. In addition, it occasionally publishes pamphlets, folders, and leaflets on various consumer issues and problems and regularly prepares features and press releases for dissemination through the mass media.
CAB regularly monitors the market prices of essential commodities and services to show the actual price situation in the market and keep prices within the purchasing power of general consumers. It runs a market monitoring cell, which regularly conducts market surveys and supplies relevant information to consumers through national dailies. CAB launched a ‘Dirty Dozen Campaign’ against 12 most harmful pesticides. Earlier, there were no guidelines on the marketing of pesticides and it is because of the pressure created by CAB that the government had to formulate guidelines on the marketing of pesticides and publish them through a gazette notification. CAB also carried out studies on household insecticides and labeling of pesticides on packets.
The organisation was very vocal and active in creating demand for formulating a National Drug Policy (NDP) and played an active role in the process of enactment of the NDP in 1982. Since then, CAB has been regularly monitoring the implementation of NDP and organizing promotional activities, especially relating to issues of inadequacy and poor services in the delivery of public health care. CAB started an anti-tobacco campaign in 1981. CAB is active in lobbying with the government for banning smoking in selected public places. CAB is also monitoring the implementation of the Breast Milk Substitute Ordinance enacted in 1984. CAB carries out campaigns in support of breastfeeding.
CAB activities include organization of seminars, workshops, and group meetings, street processions, distribution of posters and leaflets, and publication of features in newspapers on environmental pollution and degradation as well as on safe road and transport systems. A routine activity of CAB is the formation and development of consumer for expansion of consumer movement at the division, district, thana and peripheral levels. These groups keep liaison with the national level and deal with consumer education and motivation and handle local consumer problems and issues.
CAB runs a Complaint Centre to receive complaints from consumers and extends technical and legal support to them for redress. With a view to keeping the consumers informed about the daily market situation and other consumer issues and problems CAB runs a Consumer Information Centre, which has a small library attached to it. It conducts studies on important consumer issues such as commodity prices, use of BMS in hospitals and clinics, tobacco consumption, road accidents, violation of BMS ordinance, drug abuse and the like. It has been looking for the formulation of consumer protection laws in the country for a long time.
CAB now concentrates its activities in the districts of dhaka, chittagong, sylhet, mymensingh, gazipur, manikganj, bogra, khulna and barisal but has plans to expand the activities in other districts of the country, too. Some of the achievements of CAB are as follows:
The Milk Vita Company used to mix imported powder milk with cows milk and then market it as the cows milk. CAB exposed this malpractice, following which the company had to change its policy;
CAB created considerable awareness among the people about harmful and unnecessary drugs long before the enactment of the National Drug Policy, which after being formulated, was popularised by CAB through a vigorous campaign;
Since 1984, CAB has been conducting campaigns for the promotion and protection of breast feeding and has been an advocate for enactment and implementation of Bangladesh Breast Feeding Substitutes (marketing regulation) Ordinance, 1984;
CAB was instrumental in the declaration of the Code of Pesticide Marketing and assisted in the creation of a committee to evaluate price situation, in the re-organization of the Bangladesh Standard Institute and publication of lists for standard certificates, and in creation of a committee to assess the adulteration position in edible oils;
CAB was instrumental in the re-organization of the government’s Environmental Pollution Control Department.
The anti-tobacco campaign by CAB resulted in the introduction of warning against hazardous effects of smoking in cigarette advertisements; and
CAB has been recognized as representative of consumers in numerous committees (both government and non-government) formed on different issues and subjects.
CAB, however, faces a number of constraints such as inadequacy of funds, and a relatively slow response from communities and population groups that prevent consumer movement from gaining a solid ground, and a general weakness of consumers in terms of their awareness level and bargaining strength in purchases. CAB’s success, therefore, remains minimal as their programmes often go against the interest of the business community, who enjoys near monopoly and has the opportunity to organise syndicated trade. [Syed Rashedul Hasan]
Breastfeeding a common practice in Bangladesh, particularly in rural areas. Almost every new-born is breastfed for quite a long period. The practice of using wet nurse for breastfeeding the new-born among the middle class and upper class families is very rare in the country. The breastfeeding patterns in Bangladesh is largely governed by the cultural and religious beliefs on the one hand and socio-economic status on the other. Despite widespread campaigns at government and NGO levels to promote early initiation of breastfeeding (ie, feeding colostrums) to new-born, more than fifty percent are still given breast milk after the first six hours of their birth and the rest are put to breast milk after two days. This pattern of breastfeeding is mainly the outcome of the traditional belief that colostrums is not good for the new-born. In Bangladesh more than 90 percent of births are delivered at home and there is a general custom of feeding the baby a few drops of honey diluted with water shortly after birth. Even if the birth occurs in hospital and the initiation is not immediate (due to inability of the child to suckle or due to weakness or inability of mother), plain water or sugar cube diluted with water is given to the new-born until the mother is physically fit to feed the baby or it is strong enough to suckle the nipple. According to a recent study based on demographic and health survey data, Bangladeshi children are given supplemental food fairly early and cow’s milk and infant formula are the most common supplemental food.
Breastfeeding a new-born baby is considered a sacred duty of every mother. She is advised to offer breast milk to her baby for at least 30 months. A woman is forbidden to offer breast milk to her baby beyond the age of 30 months. The poor economic condition of the people however often forces mothers to continue breastfeeding for a longer period. As a large proportion of the people is poor, they cannot afford to buy supplementary food for the young. As a result, the child has to remain dependent on mother’s milk for a long time and the frequency of suckling is also high. This perhaps leads to a long duration of post-partum amenorrhea. The 1975 Bangladesh Fertility Survey reported a mean length of postpartum amenorrhea of 14.6 months. The 1989 Survey found the overall median length of post-partum amenorrhea to be 12 months. More recent research, however, has reported shorter lengths of PPA, with significant differentials evident by socio-economic status indicating that although the duration of breastfeeding has not changed much over the last two decades, the length of amenorrhea is showing a declining trend. A study in Matlab in early 1990s observed that the median duration of post-partum amenorrhea fluctuated around 13 months for the cohorts of births during the 1978-1983 period. The study also showed that the increased use of contraception may be one of the important contributing factors to the declining trend in postpartum amenorrhea in Bangladesh. According to the demographic and health survey of 1996-97, the mean length of post-partum amenorrhea is 11 months. [M Mazharul Islam]
Children boys and girls under 14, The UN Convention of the Rights of Children treats every human being below the age 18 years as a child. The convention allows every society to consider its own laws and customs. Children in Bangladesh are grouped in three categories: shishu – anybody under 5 years of age, balak or balika – a child of 6 to 10 years and kishor or kishori – a child of age between 11 and 14.
In 1997, Bangladesh had a total population of 124.3 million, of whom the number of children was 61.75 million. The population below 18 years constituted 49.6% of the total and below 14 years – 40.63% of the total.
The family system in Bangladesh is mostly patriarchal, except in some ethnic minority groups. The father is responsible under law for taking care of the children. But the children remain close to their mother, whose role in shaping their character is predominant. Generally, boys start getting away from their mothers in their kishor age, when they are guided by the father or other male guardians. Girls remain close to the mother or female relatives.
The birth of a child is a joyful event for the family. Muslims observe aqiqah, a religious festival. Cows or goats have to be sacrificed for the welfare of the newly born child. The Hindu’s social ritual for the occasion is annaprashana. The birthday of children in better-off families, especially in urban areas, are now observed in the western style. Parents love children and often give top priority to fulfilling their needs but traditionally, ignore their opinions, arguing that they understand little. In some cases, simple survival demands do not allow poor parents to take much care of their children.
Children in Bangladesh, especially in the rural areas and in conservative families, are often subject to gender discrimination. Many parents think that the male child represent heredity. The birth of a male child in a Muslim family is marked by Azan and in a Hindu family, by music from the holy shankha. In the Akika of a girl, a goat is sacrificed, but in that of a boy, a cow or two goats. A kishor (boy) enjoys more freedom than does a kishori (girl). The boy is allowed to go outside of the house more frequently than a girl, who is to remain with her mother or aunts to help in a household work or is to imply stay inside because of purda and ‘security’. From very early age, boys and girls in Bangladesh society wear different dresses. Boys wear pants, shirts, lungis, pidjamas, panjabis, etc. and girls wear salwar-kamijes, urnas, saris, etc. The girls are to keep long hair from their early age.
Traditionally, only the father or a senior male person in the family is the legal guardian of a family. Only the father’s name is put in the school register and elsewhere. Recently, however, the government has issued an administrative order to put the mother’s name along with the father’s in the school-register book. Child marriage, although officially banned, continues to take place in many parts of the country. Arranged marriage is still the prevalent feature and the opinion of the girl in question is largely ignored.
In Bangladesh, children have little scope for enjoying their childhood. Most village boys help their fathers in the fields from an early age. The girls are engaged in household work. Slum boys and girls have to earn own livelihood, most of the time, for themselves and often, for their families.
A large number of children are born with physical and mental handicaps. Such children are neglected within the family as well as in society. Although some schools and training centers have been established for these children, entry to these institutions is restricted to the privileged few.
Bangladesh was one of the first countries to sign and ratify the UN Convention of the Rights of the Child (CRC). In addition, the Constitution of Bangladesh ensures children’s rights by its various articles. For example, Article 14 of the Constitution prohibits all kinds of exploitations. Article 15(d) ensures the right of social security of people of all age groups. Article 17 provides for adopting effective measures for the purpose of establishing a uniform, mass-oriented and universal system of education for all children. Labour laws prohibit child labour in Bangladesh. Primary education is now free and compulsory. Girls enjoy special facilities and stipend in studies up to the secondary level. However, not all rights of children or of girls are ensured in practice.
Every year about two and a half million children are born in Bangladesh. About three-fourths of all children in the country live below the poverty line. Child mortality is very high. In the early 1990s, for every thousand children born alive 12 died within several hours of birth, 8 due to birth trauma and 4 due to prematurity. A further 23 died within a week, 16 due to prematurity and 7 as a result of neonatal tetanus. Poverty, inadequate housing, malnutrition, shortage of pure drinking water, sanitation, primary health care, immunization and inadequate knowledge of hygiene, teen-age motherhood, etc are causes of the high infant mortality. The infant mortality rate in rural areas is higher than in urban areas.
Child trafficking has become a regular phenomenon. Children are being smuggled to the Middle East and other countries for various exploitative and abusive purposes. Bangladeshi children are found in large number in brothels at home and abroad. Children are also being used as camel jockeys in the Gulf countries.
Bangladesh officially launched the education for all plan (EFA) in March 1992. But a large number of children still remain beyond coverage of primary education. 76% boys and 64% girls enroll in primary schools. Children of rich families in urban areas attend kindergarten, which are divided into two categories, English medium and Bengali medium. Children of lower classes of urban areas go to conventional primary schools. Rural children go to primary schools and to ebtedayee madrasahs. Solvent families in rural and urban areas employ private tutors for their children. In urban areas, coaching classes are organized, where children take extra lessons. The children of Muslim families learn the Holy quran at home and in mosques. Interested guardians in urban areas send children to music schools for lessons in music and dancing. In many towns there are specialized libraries for children to read books. In addition, there are organizations, which develop children’s literary and cultural faculties.
Children in Bangladesh do not have access to facilities in games and sports. Not all schools have adequate arrangements. Whatever little provisions are available, are created by communities. They consist of some open space in the village or town for boys to play football or traditional games like hadudu, dariabandha and kana machi bho bho. In rural areas, children also play within the house premises. But in urban areas, children do not have the opportunity simply because of the lack of space. Indoor games like table tennis, carom, chess and video games are the privileges of urban children only, but that too only for those having access to medium and large educational establishments. Girls are virtually excluded from the benefit of playing outdoor games. In villages they play with dolls and in urban areas, some of them play indoor games.
Despite the fact that existing labour laws prohibit child labour, a large number of children are employed in the formal and informal sectors, eg small industries, workshops, restaurants, sweetmeat shops, motor garages, bus and tempos, construction, tea plantations, agriculture, domestic work etc. Their employment however, is rarely secure. Sometimes they receive only subsistence rations for survival. And these, in many cases, are considered as favours. In some cases children are nearer to what can be called bond labour. Child labourers are often assigned tasks beyond their physical capacity. Many of them work in hazardous conditions among dangerous fumes, gases, asbestos, lead, sodium etc. As a result, they have to suffer from skin diseases, heart diseases, bronchial problems, etc. In domestic service the child, especially a girl child, has every possibility of being abused. A large number of children die from fire, accidents by machinery, toxic substances, injury and violence.
The most vulnerable category of children is known as street children or street urchins commonly known as tokais. These children survive by picking things from the street, dustbins and other places. Street children have no parents. Actually, they are born on the street, live on the street and die on it. Some of them have parents but have no contacts with them. Factors forcing children to the street are mainly poverty, broken family, running away from family, and sexual abuse. Nobody takes care of vagrant children. They live at stations, bus terminals, office premises and in parks, street sides etc, or under the open sky. [Abu Sayeed Khan]
Children policy The ministry of women and children affairs of the government formulated a National Children Policy in December 1994. This is divided into eight chapters. The first chapter states that it is essential to adopt an appropriate programmed of action for welfare of the children in the interest of the overall development of the country and that it is desirable that everyone should participate in the task of helping every child grow into an able citizen. To promote children’s welfare the government enacted a law in 1974 and established the Bangladesh Shishu Academy in 1976. Bangladesh was an early signatory to the UN Charter of Children’s Rights and has since been taking steps to implement its provisions.
Chapter two defines a child as one who has not crossed the age of 14. Chapter three explains that because of dearth of resources, underdevelopment and lack of employment, many children are deprived of their basic rights to education, health, nutrition and housing. Chapter four speaks of the objectives of the policy. To ensure a child’s right to live, it is necessary to provide him security of health, nutrition and person. To ensure his overall mental growth, it is necessary to educate him. Other objectives outlined in the policy are to help develop a child’s sense of moral, cultural and social values; to take necessary steps to help develop his family environment; to ensure special support for handicapped children; to adopt policies to ensure maximum protection of children’s rights at national, social, family and personal levels; and to ensure legal rights of children in national, social and family activities.
Chapter five describes of implementation of these objectives. The sixth chapter outlines the strategies to ensure implementation of the objectives. To ensure overall welfare of the children, it is necessary to give particular attention to management at family, group or social levels; to develop institutional management at village level and ensure people’s participation in the activities of the government’s social welfare institutions; to strengthen management of government institutions to ensure proper rehabilitation of homeless and helpless children; and, when necessary, to create new institutions and enlist support of organizations.
The seventh chapter describes the way a national children council is to be formed and its agenda. The children policy concludes with the declaration that it was the objective of the policy to ensure that all children of the country, irrespective of their caste, color, gender, language, religion or belief, social status, wealth, birth or any other status, enjoy all rights and opportunities equally. [Golam Kibria]
Milk a secretion of the mammary gland for the nourishment of the young. The amount of food value in milk varies from animal to animal and from region to region. The amount also varies according to nature of fodders of animals.
Cow milk and milk products form an important component of human diet. Children must have it for growth and health. Adults require it for health and invalids as well as old people must have it to prolong their longevity.
Milk from cows consists of water, organic substances, and mineral salts. Average composition of milk is 87.6 percent water, 3.7 percent fat, 3.2 percent protein, 4.8 percent lactose and 0.72 percent ash. Whole milk is an excellent source of calcium, phosphorus, riboflavin, protein and vitamin A. One hundred ml of milk may furnish 65.3 calories. Total milk production in Bangladesh, however, is much lower than the national demand. Hence a considerable quantity of milk powder is imported. Local milk consumption in liquid form in 1993-94 was 4,62,000 metric tons. This includes milk from cows, buffalo and goats. The milk product made from imported milk was about 19,000 metric tons. A large part of the available milk is used to make different types of milk products.
Liquid milk may be consumed as skim milk, that is to say, milk from which sufficient milk-fat has been removed to reduce its fat content to below 0.50 per cent. It is however, rich in water-soluble vitamins and minerals. Skim milk is not widely used in Bangladesh.
In several cities pasteurized milk is available. Pasteurization is done by heating the milk to at least 63BAC and holding it continuously at or above this temperature for at least 30 minutes, or to at least 72BAC, and holding it continuously at or above this temperature for at least 15 seconds, to ensure the destruction of all pathogenic microorganisms. This is followed by immediate cooling of the milk to 4.4BAC or less. Most milk is consumed in Bangladesh by boiling it for not less than 20 minutes.
Often ‘toned milk’ is made by adding water and non-fat dry milk to fresh whole milk. Whole buffalo milk is usually admixed with reconstituted spray dried skim milk from production. It should contain 1.0 to 3.0 percent fat and 8.5 to 10.5 percent solids to make 11.5 percent total solids. Such milk is useful for low-income groups. [AKM Abdul Mannan]
Milk a secretion of the mammary gland for the nourishment of the young. The amount of food value in milk varies from animal to animal and from region to region. The amount also varies according to nature of fodders of animals.
Cow milk and milk products form an important component of human diet. Children must have it for growth and health. Adults require it for health and invalids as well as old people must have it to prolong their longevity.
Milk from cows consists of water, organic substances, and mineral salts. Average composition of milk is 87.6 percent water, 3.7 percent fat, 3.2 percent protein, 4.8 percent lactose and 0.72 percent ash. Whole milk is an excellent source of calcium, phosphorus, riboflavin, protein and vitamin A. One hundred ml of milk may furnish 65.3 calories. Total milk production in Bangladesh, however, is much lower than the national demand. Hence a considerable quantity of milk powder is imported. Local milk consumption in liquid form in 1993-94 was 4,62,000 metric tons. This includes milk from cows, buffalo and goats. The milk product made from imported milk was about 19,000 metric tons. A large part of the available milk is used to make different types of milk products.
Liquid milk may be consumed as skim milk, that is to say, milk from which sufficient milk-fat has been removed to reduce its fat content to below 0.50 per cent. It is however, rich in water-soluble vitamins and minerals. Skim milk is not widely used in Bangladesh.
In several cities pasteurized milk is available. Pasteurization is done by heating the milk to at least 63BAC and holding it continuously at or above this temperature for at least 30 minutes, or to at least 72BAC, and holding it continuously at or above this temperature for at least 15 seconds, to ensure the destruction of all pathogenic microorganisms. This is followed by immediate cooling of the milk to 4.4BAC or less. Most milk is consumed in Bangladesh by boiling it for not less than 20 minutes.
Often ‘toned milk’ is made by adding water and non-fat dry milk to fresh whole milk. Whole buffalo milk is usually admixed with reconstituted spray dried skim milk from production. It should contain 1.0 to 3.0 percent fat and 8.5 to 10.5 percent solids to make 11.5 percent total solids. Such milk is useful for low-income groups. [AKM Abdul Mannan]
What we generally observe in our country is that consumers are treated negligently. While consumerism has become a strong movement and consumer organizations are highly powerful in the developed as well as in many of the developing countries including our neighbours, a great majority of the consumers in our country are still in the dark about their basic rights and obligations as consumers. Due to mass illiteracy, particularly the poor and the disadvantaged section, the consumers are not aware and conscious of their rights and responsibilities as consumers. In fact, consumerism is still a new concept in Bangladesh and the very term Consumer Rights is not known even to the great majority of those whom we are literate.
In the absence of appropriate and adequate protective laws, standards and effective implementation of existing laws consumers in our country are helplessly being cheated and exploited by some dishonest businessman and vested interest groups. The innocent, simple and illiterate consumers are revolving in a vicious circle of food and commodity adulteration, cheating in weighing & measures, hoarding and artificial price-hike. In the service sectors, the consumers are deprived of their legitimate services even after paying increased costs. The physicians are not sincere in their duties and responsibilities and do not adhere to minimum ethics in their professional practices. Incidence of death due to wrong treatment or intakes of adulterated and counterfeit drugs are often published in the newspapers. Surprisingly the drug administration is silent.
The transport sectors are more dangerous and horrifying. No one can be assured of safe-return home. In the absence of good road transport system and due to lack of effective implementation of existing traffic laws, road accidents have been increasing at an alarming rate causing heavy tolls of lives and damage to property. Defective bus, minibus, auto-rickshaw and rickshaws are plying on the road with excessive passengers and often causing accidents resulting in death and damage to lives of innocent passengers. In case of water way every year we see the overloaded launches capsizing and killing hundreds of people.
In the name of open market economy foods and commodities are being imported freely. But how much do we know about the standards and quality of these imported commodities? Are we sure that these imported products have undergone any safety and standards tests by any appropriate authority in the testing laboratories? Consumers Association of Bangladesh (CAB) conducted a survey on packaged biscuits of 66 brands (both imported & locally produced) made of 33 companies in July 2003. The survey revealed that 76% did not have BSTI certification marks and proper labelling, 86% had no expiry date on the label, in 83% cases weight was not mentioned and in 83% cases the sellers are taking more price.
CAB conducted another survey in August- September 2002 on 51 brands of Jams and Jelly of 31 companies and it was found that 52% of Jams and Jelly did not have BSTI certification marks, 13.72% did not mention ingredients, 23.52% did not mention date of production and date of expiry and in 54.90% cases retail price was not mentioned on the label.
Bangladesh Standard and Testing Institute (BSTI) is beset with numerous problems. It is not well equipped with modern facilities for testing products and commodities. The efficiency and integrity of the officials of BSTI are often questioned by the general consumers. Services of BTTB, DESA, WASA, Bangladesh Biman, BRTC, BTV and Bangladesh Betar hardly meet consumer’s expectation. Rights are being abused in day to day life. Still they keep mum.
In the developed countries there are adequate laws to protect the consumers against violation of their rights and interests. There are separate consumer courts in those countries to deal with cases of violation of consumers’ rights and interests. In India, Consumer Protection Law was enacted in 1986 with subsequent modification in 1992. Under this law consumer courts were established all over the country to try cases instituted by the consumers for violation of their rights involved in the purchase and use of commodities and services. Instances are there that physicians had to compensate the patients for medical negligence and wrong treatment, trades and businessmen had to redress the grievances of the consumers by replacing or refunding money to the buyers for defective goods and commodities.
In Malaysia, Srilanka and even in Nepal consumer protection laws are in prevalence and being effectively implemented for protection of the rights and interests of the consumers of those countries.
But unfortunately in Bangladesh we do not have Consumer Protection Law as such even after prolonged advocacy and lobbying with the government and policy makers during the last one decade. But very recently the draft Consumer Protection law has almost been finalised in a meeting under the chairmanship of additional secretary, commerce Mr. B. R. Khan and hopefully it will go to the cabinet for final approval very shortly. However, there are some conventional laws in existence in the country, but these laws are so outdated that little or no protection is provided to the consumers. These laws are also inadequate and do not meet the present needs.
The most prominent amongst these laws are:
1. Bangladesh Food Ordinance, 1959
2. Bangladesh Pure Food Rules, 1967
3. Bangladesh Essential commodity Act, 1978
4. Bangladesh Drug Control Ordinance, 1982
5. Bangladesh Standard and Testing Institute Ordinance 1984
6. The Breast Milk Substitute (Regulation of Marketing ) Ordinance, 1984
CONCLUSION:
Among rules and ordinances BSTI ordinance 1984 has been amended will be implemented soon. The most interesting features of these laws are that aggrieved consumers can not sue the violators themselves. It is only the designated government officials empowered under these laws, who can initiate and sue the violators. Besides, provision of penalty or punishment is so negligible that nobody cares to abide by the rules under these laws and as such there is no effective implementation of the laws. As a result the consumers in Bangladesh are completely dependant upon the mercy of the business houses, the professionals and the vested interest groups. Thus at present it is not much satisfactory and the government must come up with better effective and efficient rules to redress consumer grievances.