dissenting:
EEOC Vice Chairman Ricky Silberman described the agency’s recently revised guidelines against sex harassment as “a logical extension of [Meritor Savings Bank v.] Vinson1 that will be used to maximize protection against sexual harassment.” She further observed, “sex harassment is about power and supervisors who use it are violating Title VII.” (emphasis added) BNA Labor Reporter Current Developments (Oct. 18, 1988).
Power cannot be exerted over employees unknowingly. “Harassment” and “power” are active nouns that embody an exercise of will. The principal question in this case *483is under what circumstances acts of coworkers, not supervisors, of the plaintiff, can render the employer liable for sex harassment and the noxious exercise of power that Title VII forbids. An equally important question is the extent to which sexual graffiti are probative of an employer’s knowledge of a hostile sexual environment. Because I disagree that Waltman has established a fact issue on the pivotal issue of employer liability, and because the majority’s dicta concerning actionable sexual harassment are overbroad, I respectfully dissent.
1. A Preface on Sexual Harassment.
Waltman’s claim, even viewed in its best light for summary judgment purposes,2 developed over two and a half years and consists of several isolated incidents of unwanted physical contact, an obscene statement made over the plant public address system, plus several remarks addressed to her. She also complains of sexual graffiti on the plant walls, most of which did not involve her or the female anatomy, and “girlie” pictures hanging in men’s lockers, as well as a calendar depicting bikini-clad women displayed on a shop wall. I would not suggest that any of the incidents she describes are inoffensive or that the male workers’ choice of graffiti or calendars was tasteful. But a hostile environment cause of action is comprised of more than one alleged offense, and I think several factors counsel against allowing a hostile environment claim to proceed in this case.
First, all but one of the specific incidents involved coworkers or non-employees of IPCO.3 Only one man was involved in more than one physical incident. The incidents were spaced well apart chronologically. Waltman began work at the plant in April 1982. She complained about supervisor Garrett’s behavior in October 1983 and, at her request, was immediately re-assigned to another shift. She admitted that 13 months elapsed until any other physical incident occurred. There is no pattern, conspiracy or consistency to the offensive physical incidents.4
Second, when she complained about particular unwelcome conduct, IPCO responded. The obscene comments over the P.A. system ceased as soon as she brought them to a supervisor’s attention. Dempsey Par-due placed her on a different shift — at her request — after she took issue with the atmosphere on the “A” shift. The calendars and photographs were removed from the men’s lockers. IPCO counselled her at several management levels and tried to resolve her January, 1985, complaints while avoiding undue emotional stress on her. She signed a letter requesting no formal investigation of her coworkers. IPCO, however, with her permission, informed Brown & Root of her charges against its employees. IPCO’s resident manager met with all exempt salaried personnel to reiterate the company policy against sex harassment, and at a crewshift meeting attended by Waltman just after she returned to work, the policy was also stressed.
*484Third, Waltman never complained of unwelcome sexual comments by her coworkers, which she allegedly heard almost weekly. As the majority acknowledge, Waltman never resorted to the company grievance procedure.
Not only do the majority overlook or minimize these circumstances, they go further, stating that graffiti not directed at Waltman “is relevant to her claim,” as they quote with approval from Vinson v. Taylor, 753 F.2d 141, 146 (D.C.Cir.1985), the D.C. Circuit’s predecessor decision to Meritor: “[ejven a woman who was never herself the object of harassment might have a Title VII claim if she were forced to work in an atmosphere in which such harassment was pervasive.”
The Supreme Court’s decision in Meritor superseded the discussion of the D.C. Circuit on this point. Meritor cannot be reconciled with the majority’s open-ended and gratuitous extension of an actionable claim to encompass harassment of which the plaintiff was not even a target. The Court adopted in Meritor the EEOC’s guideline that defines sexual harassment as “[ujnwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature.” 29 C.F.R. § 1604.11(a) (1988). Further, the guidelines provide that sexual misconduct constitutes prohibited sexual harassment, whether or not it is linked to an economic quid pro quo, where the conduct “has the purpose or effect of unreasonably interfering with an individual’s work performance or creating an intimidating, hostile or offensive working environment.” § 1604.11(a)(3). 477 U.S. at 65, 106 S.Ct. at 2405.
To be sure, the Court’s reliance on the “unwelcomeness” of sexual verbal or physical conduct lends a subjective component to the definition.5 However, sexual harassment is not actionable, the Court cautions, unless it is so “severe or pervasive ” as “to alter the conditions of the victim’s employment and create an abusive working environment.” 477 U.S. at 67, 106 S.Ct. at 2406 (emphasis added). These qualifications, it seems to me, are intended to set an objective floor on allegations of sexual harassment. Such language does not, for instance, suggest that whenever a victim feels abused, she has a cause of action under Title VII. This conclusion seems not only logical but necessary. We have so little social consensus in sexual mores nowadays that, short of incidents involving unwanted physical contact, it is impossible generally to categorize unacceptable sexual etiquette.6 It is likewise impossible to eradicate sexual conduct from the workplace — without unthinkable intrusiveness. Compare Vinson v. Taylor, 760 F.2d 1330, 1331 n. 3 (Bork, J., dissenting from the denial of en banc rehearing).7 Thus, the law is properly attuned to severe, pervasive and abusive conduct and results.
This case may present a fact issue concerning whether Waltman suffered so many severe and pervasive insults to her personal integrity as to result in an abusive working environment. Waltman alleges that she required hospitalization as a result of her experiences. It does not raise any question whether a woman who was not the target of unwanted physical contact or obscene remarks or graffiti might assert a Title VII claim. To render such a claim actionable, as the majority does, not only contravenes Meritor but also creates the unpalatable possibility that a woman might sue her employer for consensual conduct that others undertook among themselves. Surely, such invasions of privacy cannot have been the object of banning sexual harassment in the workplace.
*4852. Employer’s Liability.
The majority also stray far afield in finding that fact issues exist in the last element of the Jones8 test: whether IPCO knew or should have known of the harassment and took prompt remedial action.
Meritor, most of the federal court cases to date, and the EEOC guidelines9 assume that actionable sex harassment is perpetrated by supervisors, who exert control over an employee’s working conditions. In such cases, the Supreme Court seemed to conclude that under agency principles, an employer is liable for a supervisor’s conduct that it knew or should have known about. The Court unequivocally cautioned, however, that “the Court of Appeals erred in concluding that employers are always automatically liable for sexual harassment by their supervisors.” 477 U.S. at 71, 106 S.Ct. at 2408. The majority’s decision in this case virtually imposes strict liability on employers, contrary to Meritor, for two reasons: the offensive conduct here was undertaken, with one minor exception, by Waltman’s coworkers, not supervisors; and the “knowledge” of the “pervasiveness” of coworkers’ actions is imputed to IPCO only because of the existence of sexual graffiti in the plant and because management was advised of her complaints on three occasions spaced over two and a half years.
Sexual harassment differs from other types of employee torts for which an employer may become liable because it is never carried out to further the employer’s business. Quid pro quo harassment, for instance, usually occurs fortuitously and solely for the gratification of the individual who made sexual advances. Thus, in Meritor, the Supreme Court recognized that Title VII “surely evinces an intent to place some limits on the acts of employees for which employers ... are to be held responsible.” Id. Agency principles fulfill this role with regard to supervisors, because of their responsibility for and power over the working environment. Coworkers, by contrast, may influence the working environment, but they have no authority over each other. It stands to reason, then, that coworkers are not “agents” of the employer in the same sense as supervisors if they make unwelcome sexual advances, and employer liability consequently must turn on the employer’s knowledge of coworker behavior and its failure to afford prompt remedial action. The availability of a formal grievance procedure to address coworkers’ offensive behavior should be counted more strongly in the employer’s favor, because, contrary to the situation of a grievance against a supervisor, there is no disincentive to its being used against a coworker. Compare Meritor, 477 U.S. at 71-74, 106 S.Ct. at 2408-09 (grievance procedure does not necessarily exonerate employer from liability for supervisor’s harassment).
Waltman received prompt remedial action from IPCO every time she complained about an offensive action: the public address system remarks were stopped; she was transferred, at her request, from “A” shift to “D” shift, and the “A” shift employees were instructed to remove sexual calendars from their lockers; Brown & Root was asked to investigate its employees; and management followed her request, acknowledged in the January 25 letter, as to how to redress her complaints about her coworkers.
The majority minimize each of these actions, suggesting that the offenders should have been formally reprimanded or disciplined in each case or that, even though Waltman’s doctor and her superiors were concerned about her fragile psychological state in January 1985, a complete investigation of the coworkers’ actions was required.10 It is beside the point whether, in *486hindsight, management should have done more each time Waltman complained, because each time they responded exactly as she requested.11 Each time, management’s action appears to have been successful, because Waltman never experienced difficulty with that person again. The majority argue a non sequitur in suggesting that a reprimand to the man who remarked about Waltman over the P.A. system in April 1982 would have prevented Garrett from playfully putting his hand in her back pocket eighteen months later — unless, of course, all reprimands for sexual harassment, unlike every other type of employee discipline, are to be publicly displayed.
The majority’s conclusion forecasts that no matter what remedial action an employer takes when faced with a complaint of sexual harassment by a coworker, any further incident of alleged harassment by any other coworker lays the predicate for a Title VII violation. Moreover, the employee’s utter failure to employ the prescribed company grievance procedure — even without a showing that it would be ineffectual —has no legally adverse impact on her claim.
The breadth of this rule is compounded by the majority’s holding that the existence of sexual graffiti throughout the plant put IPCO management “on notice” of a sexually degrading work environment. From Waltman’s testimony, it appears that most of the graffiti had nothing to do with her personally.12 The graffiti was arguably non-discriminatory because it included male and female references.13 Using evidence of generalized sexual graffiti to bolster an otherwise non-actionable complaint against an employer highlights the subjectivity of the majority’s holding. As I observed earlier, sexual mores in our society are in rapid flux. Depictions that were only recently regarded as taboo in movies and television are now de rigeur for programs that even children will watch. The public use of lewd and suggestive language is as commonplace on the playground as in the workplace. Against such trends, it is quaint but also naive to rule that employers are legally required to eradicate all sexual graffiti from their establishments. The EEOC guidelines and policy statement never go so far. This case, moreover, is distinguishable from Bennett v. Corroon & Black Corp., 845 F.2d 104 (5th Cir.1988), in which the employee was viciously satirized and suffered emotional injury solely because of the graffiti about her. Here, the graffiti are a mere addendum to Walt-man’s other claims. Similar graffiti probably appear on workplace walls everywhere. It is incredible to contemplate the majority’s implication that the existence of sexual graffiti is sufficient to avoid summary judgment on a plaintiff’s claim that her employer knew that sexual conduct was so pervasive as to alter the terms of her employment and create an abusive working environment.
Because I believe that IPCO did not have actual or constructive notice that Waltman was subjected to a pervasively abusive and *487hostile work environment, and because I believe IPCO responded promptly to each complaint that she made, I dissent from the reversal of summary judgment on Wait-man’s Title YII claim.14
. Meritor Sav. Bank v. Vinson, 477 U.S. 57, 106 S.Ct. 2399, 2406, 91 L.Ed.2d 49 (1986).
. There is evidence in the record conflicting with Waltman’s assertions, but we may not consider it at this stage of the case. I assume, for instance, that the “touching" incidents she relates are sexual in nature.
. It is difficult to see how IPCO could under any circumstances be liable for the incident involving Brown & Root employees. Brown & Root reprimanded its employees after being informed of the "tonguing” incident.
. See Scott v. Sears, Roebuck & Co., 798 F.2d 210, 214 (7th Cir.1986) (coworkers’ offensive conduct and comments were "too isolated and lacking the repetitive and debilitating effect necessary to maintain a hostile environment claim’’); Moylan v. Maries County, 792 F.2d 746, 749-50 (8th Cir.1986) ("a single incident or isolated incidents generally will not be sufficient;” the harassment must be "sustained and nontrivial’’); Downes v. Federal Aviation Admin., 775 F.2d 288, 293-94 (D.C.Cir.1985) (not every crude joke or sexually explicit remark is actionable; conduct must be "routine” to "become a ‘condition’ of anyone’s employment"); Sapp v. City of Warner-Robins, 655 F.Supp. 1043, 1049 (M.D.Ga.1987); Freedman v. American Standard, 41 FEP Cases 471, 476, 1986 WL 7825 (D.N.J.1986) (“an obscene message sent on one occasion, rudeness ..., an accepted refusal of a date do not equate to ‘sexual harassment which creates a hostile or offensive environment’ ”); Hollis v. Fleetguard, Inc., 668 F.Supp. 631 (M.D.Tn.1987); see also EEOC Policy Guidance § C(2).
.It could be argued, for instance, that the existence of sexual graffiti or lewd language alone, where unwelcome to a plaintiffs eye or ear, are prohibited by Title VII. Determining such a violation would become intensely subjective. That the EEOC guidelines explicitly exempt incidental uses of offensive language and do not refer to graffiti at all suggest to me that these matters may not be so severe or pervasive as to constitute actionable sexual harassment.
. The majority suggests, for instance, that Walt-man “arguably suffered more harassment than the plaintiff1 in Henson v. City of Dundee, 682 F.2d 897 (11th Cir.1982), who was repeatedly propositioned by her boss. This comparison is itself highly subjective.
. The EEOC guidelines recognize this also.
. Jones v. Flagship International, 793 F.2d 714, 719-20 (5th Cir.1986), cert. denied, 479 U.S. 1065, 107 S.Ct. 952, 93 L.Ed.2d 1001 (1987).
. Meritor, 477 U.S. at 68, 106 S.Ct. at 2407-08; Henson v. City of Dundee, 682 F.2d at 905; Jones v. Flagship Internat., 793 F.2d at 718-20; Downes, 775 F.2d at 294 n. 5; Scott, 798 F.2d at 214; Sapp, 655 F.Supp. at 1049; Hollis, 668 F.Supp. at 636 n. 12; EEOC Policy Guidance § D.
.I assume the majority would not advocate disciplining the coworkers without any prior investigation. If such an investigation had occurred, confidentiality was impossible. Walt-*486man would have been drawn into its vortex because she was the only woman working in her area.
. Compare Dornhecker v. Malibu Grand Prix Corp., 828 F.2d 307 (5th Cir.1987) (no constructive discharge where employer responded promptly to sex harassment complaint). Other courts have rejected employer liability on hostile environment Title VII claims after finding that the employer’s prompt remedial action caused incidents to cease. Steele v. Offshore Shipbuilding, Inc., 867 F.2d 1311 (11th Cir.1989); Swentek v. U.S. Air, Inc., 830 F.2d 552 (4th Cir.1987).
. With the exception of a phrase scratched in paint on one wall, Waltman simply wiped away graffiti she found offensive. She had no idea who wrote the graffiti. The plant employed over 350 people.
.The majority suggests that our decision in Bennett v. Corroon & Black, 845 F.2d 104, 106 (5th Cir.1988) holds that graffiti depicting both sexes somehow supports a woman’s claim of a hostile environment. This implication is doubly wrong. Bennett dealt with the legal consequences of offensive cartoons of a particular woman employee, as the majority here inferentially acknowledge later in their opinion. More significantly, Bennett’s suggestion that such cartoons alone raise a Title VII claim is pure dicta, as the court ultimately held that the “record presents meager proof of the conditions required by Meritor ...” and denied the plaintiff relief on another ground. 845 F.2d at 106.
. I also disagree with the majority’s holding that Waltman may prove a continuing violation of Title VII so as to avoid its 180-day limitations period. The impact in this case is not significant, because one or two physical incidents involving her occurred within the 180-day period. If her claims are actionable, no limitations bar exists. The majority’s holding, however, points up a serious inconsistency in Waltman’s claim. How can she have been so unaware that her environment at IPCO was pervasively and severely hostile, that a continuing violation occurred? Unlike Abrams v. Baylor College of Medicine, 805 F.2d 528 (5th Cir.1986), and cases where the discriminatory conduct is hidden from the plaintiff, Waltman had to know that she was being psychologically abused. If she did not, the credibility of her claim diminishes.
Finally, I disagree with the majority’s reversal of her discriminatory promotion claim. There is no evidence that she was denied a promotion because of her sex.