Inspection on 24/05/05 for Birkdale

This inspection was carried out on 24th May 2005.

CSCI has not published a star rating for this report, though using similar criteria we estimate that the report is Adequate. The way we rate inspection reports is consistent for all houses, though please be aware that this may be different from an official CSCI judgement.

The inspector found there to be outstanding requirements from the previous inspection report but made no statutory requirements on the home.

Other inspections for this house

Birkdale 21/10/08

Birkdale 15/12/06

Birkdale 15/06/06

Birkdale 16/02/06

Birkdale 03/12/04

Birkdale 01/07/04

Birkdale 12/02/04

Similar services:

Maple Lodge

Heathlands

Aston Court Nursing Home

Breme

Ravenhurst

Bank House

Inspirations

Ashcroft Hollow Nursing Home

Extracts from inspection reports are licensed from CQC, this page was updated on 08/07/2008.

CARE HOMES FOR OLDER PEOPLE Birkdale Station Hill Oakengates Telford TF2 9AA Lead Inspector Joy Hoelzel Unannounced inspection 24 May 2005 10:00 The Commission for Social Care Inspection aims to: • • • • Put the people who use social care first Improve services and stamp out bad practice Be an expert voice on social care Practise what we preach in our own organisation Reader Information Document Purpose Author Audience Further copies from Copyright Inspection Report CSCI General Public 0870 240 7535 (telephone order line) This report is copyright Commission for Social Care Inspection (CSCI) and may only be used in its entirety. Extracts may not be used or reproduced without the express permission of CSCI www.csci.org.uk Internet address This is a report of an inspection to assess whether services are meeting the needs of people who use them. The legal basis for conducting inspections is the Care Standards Act 2000 and the relevant National Minimum Standards for this establishment are those for Care Homes for Older People. They can be found at www.dh.gov.uk or obtained from The Stationery Office (TSO) PO Box 29, St Crispins, Duke Street, Norwich, NR3 1GN. Tel: 0870 600 5522. Online ordering: www.tso.co.uk/bookshop This report is a public document. Extracts may not be used or reproduced without the prior permission of the Commission for Social Care Inspection. Birkdale E56 000049825 Birkdale V229454 UI 240505 Stage 4.doc Version 1.30 Page 3 SERVICE INFORMATION Name of service Birkdale Address Station Hill, Oakengates, Telford, TF2 9AA Telephone number Fax number Email address Name of registered provider(s)/company (if applicable) Name of registered manager (if applicable) Type of registration No. of places registered (if applicable) 01384 253560 The Keepings Ltd Claire Orrey Care Home 29 Category(ies) of Old Age (29) registration, with number of places Birkdale E56 000049825 Birkdale V229454 UI 240505 Stage 4.doc Version 1.30 Page 4 SERVICE INFORMATION Conditions of registration: 1) The home may accomodate 29 persons, whilst the person named on the attached schedule (not to be displayed) is resident. Date of last inspection 03/12/2004 Brief Description of the Service: Birkdale is a care home providing accommodation and personal care to twenty eight people over the age of sixty five. It is privately owned and is one of the two homes that are owned by The Keepings Ltd. The home is situated in the Oakengates area of Telford and is close to all local amenities. Birkdale is a large detached property and consists of a two storey building with single and twin bedded rooms, communal sitting and dining areas. There is a passenger lift to access the rooms on the first floor. Birkdale E56 000049825 Birkdale V229454 UI 240505 Stage 4.doc Version 1.30 Page 5 SUMMARY This is an overview of what the inspector found during the inspection. The unannounced inspection took place over four and a half hours on Tuesday 25th May 2005 and is the first of the statutory inspections for 2005/06. Twenty-eight people were resident at the time of inspection, staffing levels were seen to be low and not at the previously agreed levels. The inspection included discussions with ten residents, six members of staff and two visitors. Six care plans were examined in depth together with supporting documents and a tour of the home was conducted. What the service does well: What has improved since the last inspection? What they could do better: Staffing levels were observed to be low at the beginning of the inspection with only two care staff and the manager on duty, during the morning another care staff arrived. Staffing levels must remain at the agreed minimum levels for the full twenty four hour period, but must be determined by the lay out of the building and the dependency needs of service users, as dependencies change the levels and numbers of staff must reflect this. Staff were observed to be very busy endeavouring to attend to the residents needs. Visitors to the home stated that at times they thought and observed staff to be so busy that they had to rush to get their jobs done. Birkdale E56 000049825 Birkdale V229454 UI 240505 Stage 4.doc Version 1.30 Page 6 The privacy and dignity of people living at the home must be enhanced with the provision of suitable locks to bathrooms, toilets and private bedrooms. The recommendations of the local fire service must be complied with to ensure the health and safety of service users. Please contact the provider for advice of actions taken in response to this inspection. The report of this inspection is available from enquiries@csci.gsi.gov.uk or by contacting your local CSCI office. Birkdale E56 000049825 Birkdale V229454 UI 240505 Stage 4.doc Version 1.30 Page 7 DETAILS OF INSPECTOR FINDINGS CONTENTS Choice of Home (Standards 1–6) Health and Personal Care (Standards 7-11) Daily Life and Social Activities (Standards 12-15) Complaints and Protection (Standards 16-18) Environment (Standards 19-26) Staffing (Standards 27-30) Management and Administration (Standards 31-38) Scoring of Standards Statutory Requirements Identified During the Inspection Birkdale E56 000049825 Birkdale V229454 UI 240505 Stage 4.doc Version 1.30 Page 8 Choice of Home The intended outcomes for Standards 1 – 6 are: 1. 2. 3. 4. 5. 6. Prospective service users have the information they need to make an informed choice about where to live. Each service user has a written contract/ statement of terms and conditions with the home. No service user moves into the home without having had his/her needs assessed and been assured that these will be met. Service users and their representatives know that the home they enter will meet their needs. Prospective service users and their relatives and friends have an opportunity to visit and assess the quality, facilities and suitability of the home. Service users assessed and referred solely for intermediate care are helped to maximise their independence and return home. The Commission considers Standards 3 and 6 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for standard(s) 2,3,6 Service users needs are assessed before moving into the home. EVIDENCE: Contracts and terms of conditions between the home and the resident are available, the registered manager explained the problems and difficulties experienced with getting them signed by the resident/ representative due to cognitive difficulties of the resident or unavailability of representative or relative. Through the case tracking process it was evident that two residents had not been issued with contracts/terms and conditions although they had been resident at the home since 2004. It was a requirement from the previous inspection that each resident is provided with a contract/terms and conditions at the point of admission; this is now outstanding and must be seen as a priority requirement. The care plan of the most recent resident into the home included a full pre admission assessment of need supplied from the local primary care trust. This information was then used to generate a plan of care for daily living. Birkdale E56 000049825 Birkdale V229454 UI 240505 Stage 4.doc Version 1.30 Page 9 The care plans for other residents included information from previous placements and social history details. The home does not provide an intermediate care service. Birkdale E56 000049825 Birkdale V229454 UI 240505 Stage 4.doc Version 1.30 Page 10 Health and Personal Care The intended outcomes for Standards 7 – 11 are: 7. 8. 9. 10. 11. The service user’s health, personal and social care needs are set out in an individual plan of care. Service users’ health care needs are fully met. Service users, where appropriate, are responsible for their own medication, and are protected by the home’s policies and procedures for dealing with medicines. Service users feel they are treated with respect and their right to privacy is upheld. Service users are assured that at the time of their death, staff will treat them and their family with care, sensitivity and respect. The Commission considers Standards 7, 8, 9 and 10 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for standard(s) 7,8,9,11 The care planning system is basic and would greatly benefit from being more comprehensive and concise. There is little evidence to suggest that residents are being consulted and involved in the planning of their care. EVIDENCE: Six randomly selected care plans were examined and identified a basic plan of care based on the activities of daily living. The nutritional screening assessment included in the care plan of the most recently admitted resident to the home had not been completed. One of the care plans sampled had not been reviewed monthly and there is no evidence in all six plans that the resident has been included in the planning process or that it has been discussed with them or their relatives. Risk assessment for the use of bedrails is very basic and does not include all aspects of their use or continuation of use. Consent of use of bedrails has not been sought. The manager and owner explained that all the documentation for care planning is under review with a revised system to be functioning by the end of August 2005. Birkdale E56 000049825 Birkdale V229454 UI 240505 Stage 4.doc Version 1.30 Page 11 The home operates a weekly monitored dose system of medication administration. The medication is stored in a locked cabinet, with surplus medication stored in a locked room. The medication administration record sheets were seen to be correctly completed, it is recommended that a sample of the administrator’s signature is obtained and is kept with the medication administration records. A fridge for the storage of medications is available in the treatment room. It is recommended that a maximum/minimum thermometer be purchased for the accurate recording of the required temperature of the fridge. The care plan did not include the information required as to the residents’ wishes concerning terminal care and the arrangements following death. Birkdale E56 000049825 Birkdale V229454 UI 240505 Stage 4.doc Version 1.30 Page 12 Daily Life and Social Activities The intended outcomes for Standards 12 - 15 are: 12. 13. 14. 15. Service users find the lifestyle experienced in the home matches their expectations and preferences, and satisfies their social, cultural, religious and recreational interests and needs. Service users maintain contact with family/ friends/ representatives and the local community as they wish. Service users are helped to exercise choice and control over their lives. Service users receive a wholesome appealing balanced diet in pleasing surroundings at times convenient to them. The Commission considers all of the above key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for standard(s) 13,14,15 The meals provided are of a good homely type offering both choice and variety; however, some organisation in menu planning would be beneficial. EVIDENCE: Visitors at the home stated that they are able to visit at times suitable to their relative. Residents’ personal possessions were very much in evidence in the bedrooms with all rooms containing small treasured items. Information has been given to all residents and their representatives on accessing their personal records; a copy of the signed information is included in the care plan. Residents commented that the food provided was good, enjoyable and that they are offered a choice of menu. One resident stated that she liked to have breakfast in her bedroom as then she was able to get up and dressed in her own time. A new cook has recently been appointed and as such is reviewing the menu; at the time of the inspection no menu programme was in operation. Birkdale E56 000049825 Birkdale V229454 UI 240505 Stage 4.doc Version 1.30 Page 13 Complaints and Protection The intended outcomes for Standards 16 - 18 are: 16. 17. 18. Service users and their relatives and friends are confident that their complaints will be listened to, taken seriously and acted upon. Service users’ legal rights are protected. Service users are protected from abuse. The Commission considers Standards 16 and 18 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for standard(s) 16,18 The complaints procedure is adequate however; systems must be in place for recording the complaint, the investigation and any action that may be required. EVIDENCE: The complaints file has not been updated; the last recorded complaint is dated at 2002. Two complaints have been received since the last inspection. One was investigated using the home’s complaint procedure, the other has been referred to the vulnerable adults procedure for investigation. Visitors at the home explained that they had cause to complain to the owner and manager about the care provided to their relative. They had received an explanation and apology from the management of the home but stated they still had reservations. This was discussed with the owner and manager during the inspection. The vulnerable adults procedure investigation is ongoing. The owner stated that all staff have received abuse awareness training and it is included in the induction training. Birkdale E56 000049825 Birkdale V229454 UI 240505 Stage 4.doc Version 1.30 Page 14 Environment The intended outcomes for Standards 19 – 26 are: 19. 20. 21. 22. 23. 24. 25. 26. Service users live in a safe, well-maintained environment. Service users have access to safe and comfortable indoor and outdoor communal facilities. Service users have sufficient and suitable lavatories and washing facilities. Service users have the specialist equipment they require to maximise their independence. Service users’ own rooms suit their needs. Service users live in safe, comfortable bedrooms with their own possessions around them. Service users live in safe, comfortable surroundings. The home is clean, pleasant and hygienic. The Commission considers Standards 19 and 26 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for standard(s) 19,20,21,22,24,26 Recent investment has significantly improved the appearance of the home however, the use of door wedges, lack of maintenance checks and the risk of contamination and cross infection have the potential for placing residents and staff at risk. EVIDENCE: The home offers single and double accommodation to 28 older people. Service users spoken with commented that they are very happy living at the home, and that their bedroom ‘is very comfortable’. It was observed that wedges are used to prop open doors. If it is inconvenient for doors to remain closed, or indeed a residents personal preference, then a ‘swing free’ self closer should be fitted to the doors and wired into the fire alarm system, so as to close when the alarm is triggered. Residents must have the choice of having their bedroom doors open whenever they wish but their safety must not be compromised with the use of wedges. The communal rooms have recently been redecorated and refurbished, one resident stated that she was very comfortable and liked the new chairs. Birkdale E56 000049825 Birkdale V229454 UI 240505 Stage 4.doc Version 1.30 Page 15 Most of the toilet and bathroom doors do not have a suitable locking facility fitted. All toilets and bathrooms must have suitable locking facility to ensure that privacy and dignity is upheld. Staff use an override device only as indicated by a risk assessment. Bedrails were seen on be used on some beds, records of regular maintenance checks were not available. Wheelchairs and other equipment, not in use, were observed to be stored in all areas of the home giving a very untidy impression. The agreement of the offer of a lockable facility on resident’s private rooms has been included in the care plan. The door locking facility must be available on all private bedrooms so as to offer a true choice to each resident of having their door locked or not. The provision of a lockable storage space in the bedrooms has not been fully complied with. The manager stated that this is outstanding in six bedrooms. This was a requirement from the previous inspection and must be seen as priority. The hot water temperature at the wash hand basin in the first floor toilet was recorded at 60 degrees centigrade, and as this is used by residents, presents a great risk of scalding. This toilet was taken out of use immediately until the appropriate fail-safe valve can be fitted. The registered manager stated and the tour of the premises evidenced that commodes are used at night time. Consideration must be given to the installation of automatic sluicing disinfectors for the safe disposal of bodily waste, they will enhance the working conditions for staff and reduce the risk of contamination, splash back accidents and cross infection. All areas where personal care is undertaken by staff must be provided with hand washing facilities to include liquid soap and paper towels. Birkdale E56 000049825 Birkdale V229454 UI 240505 Stage 4.doc Version 1.30 Page 16 Staffing The intended outcomes for Standards 27 – 30 are: 27. 28. 29. 30. Service users needs are met by the numbers and skill mix of staff. Service users are in safe hands at all times. Service users are supported and protected by the home’s recruitment policy and practices. Staff are trained and competent to do their jobs. The Commission considers Standards 27, 29, and 30 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for standard(s) 27,30 The present arrangements for maintaining staffing levels are not adequate and have the potential for placing residents and staff at risk. EVIDENCE: Care staffing levels were well below the minimum requirements during the morning of the inspection with the manager and two care staff on duty, two staff were on leave and two had called in sick that morning. Usual staffing levels being one manager and four care staff. The manager stated that she did not have the authority to contact the staffing agencies for extra staff when required. She had contacted a member of staff due to be on duty during the afternoon that agreed to start her shift early. The two care staff and manager were observed to be very busy attending to the needs of residents. Visitors at the home stated that at times the staff were very ‘pushed’ and ‘appeared not to have sufficient time that is needed when dealing with older people’. The manager explained that recruitment is ongoing for waking night staff but explained that the person would only be ‘waking’ at peak periods during the night and early morning. As the home is operating at maximum capacity and the lay out of the home is wide spread, three staff must be on night duty and awake at all times. A kitchen assistant was cooking the lunchtime meal (the cook was on a day off) that had been prepared by the recently appointed cook; arrangements must be made to adequately cover for allocated days off etc. Birkdale E56 000049825 Birkdale V229454 UI 240505 Stage 4.doc Version 1.30 Page 17 The kitchen assistant stated that she has not received any training in food hygiene. A revised system for induction and foundation training is soon to be implemented with new documentation. The requirement made at the last inspection relating to staff files will be fully inspected at the next inspection; this was agreed with the owner. Birkdale E56 000049825 Birkdale V229454 UI 240505 Stage 4.doc Version 1.30 Page 18 Management and Administration The intended outcomes for Standards 31 – 38 are: 31. 32. 33. 34. 35. 36. 37. 38. Service users live in a home which is run and managed by a person who is fit to be in charge, of good character and able to discharge his or her responsibilities fully. Service users benefit from the ethos, leadership and management approach of the home. The home is run in the best interests of service users. Service users are safeguarded by the accounting and financial procedures of the home. Service users’ financial interests are safeguarded. Staff are appropriately supervised. Service users’ rights and best interests are safeguarded by the home’s record keeping, policies and procedures. The health, safety and welfare of service users and staff are promoted and protected. The Commission considers Standards 33, 35 and 38 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for standard(s) 31,35,38 The manager has a good understanding of the areas of the day-to-day running of the home which need improvement; nevertheless, she must now exercise the responsibilities and control the delivery of care by using the systems in place. Resident’s finances are handled appropriately by designated senior staff only The health, safety and welfare of residents and staff are being compromised by the systems currently in place in regard to the correct storage and preparation of food. EVIDENCE: The registered manager has a nurse qualification and is nearing completion of the Registered Managers Award. She demonstrated a good knowledge of the resident group and conditions and diseases associated with ageing. The owner stated that the manager has been given supernumery time to deal with the managerial duties. It was observed that the manager is very ‘hands Birkdale E56 000049825 Birkdale V229454 UI 240505 Stage 4.doc Version 1.30 Page 19 on’ and enjoys the practical aspects of her role, however, adequate time must be taken to successfully implement the changes that are required and to manage the home on a day-to- day basis. The owner stated that recruitment is beginning shortly for the position of a deputy manager; this will greatly assist the manager to undertake the managerial responsibilities. The procedure for dealing with residents’ personal money was observed to be robust. Individual wallets and recording sheets are used, with two signatures obtained for each transaction. The amount of cash and the amount stated on the sheet satisfactorily cross-referenced. Open jars of jam and marmalade were seen to be stored in the kitchen cupboards. For the safe storage of food all opened jars etc must have the date of opening and stored in the fridge. The brown plastic trolley stored in the main kitchen must be replaced, as it is very marked and scratched. The freezer was in need of defrosting, the drawers inside are broken and have sharp edges. No cleaning rota for the kitchen was evident, with the whole area in need of a thorough clean. The manager explained that a refit and decoration of the kitchen is imminent together with the purchase of a new freezer. All hot water outlets accessible to residents must be maintained at a temperature close to 43 degrees centigrade, checks to be made and the recordings kept. Birkdale E56 000049825 Birkdale V229454 UI 240505 Stage 4.doc Version 1.30 Page 20 SCORING OF OUTCOMES This page summarises the assessment of the extent to which the National Minimum Standards for Care Homes for Older People have been met and uses the following scale. The scale ranges from: 4 Standard Exceeded 2 Standard Almost Met (Commendable) (Minor Shortfalls) 3 Standard Met 1 Standard Not Met (No Shortfalls) (Major Shortfalls) “X” in the standard met box denotes standard not assessed on this occasion “N/A” in the standard met box denotes standard not applicable CHOICE OF HOME ENVIRONMENT Standard No 1 2 3 4 5 6 Score Standard No 19 20 21 22 23 24 25 26 Score x 2 3 x x N/A HEALTH AND PERSONAL CARE Standard No Score 7 2 8 2 9 3 10 x 11 2 DAILY LIFE AND SOCIAL ACTIVITIES Standard No Score 12 x 13 3 14 x 15 2 COMPLAINTS AND PROTECTION 2 3 2 2 x 2 2 2 STAFFING Standard No Score 27 2 28 x 29 1 30 2 MANAGEMENT AND ADMINISTRATION Standard No 31 32 33 34 35 36 37 38 Score Standard No 16 17 18 Score 2 x 3 3 x x x 3 x x 2 Birkdale E56 000049825 Birkdale V229454 UI 240505 Stage 4.doc Version 1.30 Page 21 yes Are there any outstanding requirements from the last inspection? STATUTORY REQUIREMENTS This section sets out the actions which must be taken so that the registered person/s meets the Care Standards Act 2000, Care Homes Regulations 2001 and the National Minimum Standards. The Registered Provider(s) must comply with the given timescales. No. 1. Standard 2 Regulation 5(1) Requirement Each resident is provided with a contract/terms and conditions at the point of admission This is outstanding previous inspections and must be given priority attention The service users care plan must be drawn up with the involvement of the service user, recorded in a style accessible to the service user, agreed and signed by the service users whenever possible and/or representative. Nutritional screening must be undertaken at the point of admission Timescale for action With immediate effect 2. 7 15(1) 31st August 2005 3. 8 14 4. 8 12(1) The home states this has been completed Consent for the use of bedrails The home must be obtained recorded in the states this care plan and reveiwed at has been regular intervals. completed The information required as to the residents’ wishes concerning terminal care and the arrangements following death must where ever possible be recorded in the care plan. There must be a planned menu(changed regularly) The home states this has been completed The home states this Page 22 5. 11 12(2) 6. Birkdale 15 12(2)(3) E56 000049825 Birkdale V229454 UI 240505 Stage 4.doc Version 1.30 7. 16 17(2) Schedule 4 23(4) offering a choice, in written or other formats to suit the capabilities of all residents. A record must be kept of all complaints and includes details of the investigation and any action taken. Door wedges must not be used to prop open doors to communal or private areas of the home. has been completed The home states this has been completed The home states this has been completed 31st August 2005 The home states this has been completed The home states this has been completed The home states this has been completed The home states this has been completed The home states this has been completed The home states this has been completed Page 23 8. 19 9. 21 10. 22 11. 24 12. 24 13. 25 14. 26 All toilets and bathrooms must have suitable locking facility to ensure that privacy and dignity is upheld. 12(1) All equipment used in the home, including bed rails must have regular maintenance checks to ensure the safety of service users. 12(4) Doors to service users private accommodation must be fitted with locks suited to service users capabilities and accessible to staff in emergencies 12(4)(a) Lockable stroage facilities must be provided in all bedrooms. This is outstanding from previous inspections and must be given priority attention. 13(4)(a)(c All hot water outlets accessible ) to residents must be maintained at a temperature close to 43 degrees centigrade, checks to be made and the recordings kept 13(3) Hand washing facilities to include liquid soap and paper towels must be available in all areas where personal care is undertaken. 18(1)(a) The registered manager must ensure that adequate numbers of staff are on duty and awake at all times. 12(4) 15. 27 Birkdale E56 000049825 Birkdale V229454 UI 240505 Stage 4.doc Version 1.30 16. 17. 30 29 18(1) 19(4) Schedule 2 18. 38 16(2) All staff handling food must have an accredited food hygiene certificate. Staff files must contain all of the elements as laid out in Schedule 2 of the Care Homes Regulations 2001 This is outstanding previous inspections but was agreed with the owner that this area will be fully inspected at the next inspection. For the safe storage of food all opened jars etc must have the date of opening and stored in the fridge The brown plastic trolley stored in the main kitchen must be replaced, as it is very marked and scratched. The freezer must be repaired or repaced. 31st August 2005 31st August 2005 The home states this has been completed 4th Jluy 2005 The home states this has been completed 19. 38 13(3) 20. 38 13(3) 21. 22. RECOMMENDATIONS These recommendations relate to National Minimum Standards and are seen as good practice for the Registered Provider/s to consider carrying out. No. 1. 2. 3. Refer to Standard 9 9 26 Good Practice Recommendations It is recommended that a sample of the medication administrator’s signature is obtained and is kept with the medication administration records. It is recommended that a maximum/minimum thermometer be purchased for the accurate recording of the required temperature of the fridge. It is highly recommended that consideration be given to the installation of automatic sluicing disinfectors for the safe disposal of bodily waste E56 000049825 Birkdale V229454 UI 240505 Stage 4.doc Version 1.30 Page 24 Birkdale 4. Birkdale E56 000049825 Birkdale V229454 UI 240505 Stage 4.doc Version 1.30 Page 25 Commission for Social Care Inspection 2nd Floor St Davids Court Union Street Wolverhampton WV1 3JE National Enquiry Line: 0845 015 0120 Email: enquiries@csci.gsi.gov.uk Web: www.csci.org.uk © This report is copyright Commission for Social Care Inspection (CSCI) and may only be used in its entirety. Extracts may not be used or reproduced without the express permission of CSCI Birkdale E56 000049825 Birkdale V229454 UI 240505 Stage 4.doc Version 1.30 Page 26 - Please note that this information is included on www.bestcarehome.co.uk under license from the regulator. Re-publishing this information is in breach of the terms of use of that website. 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