Inspection on 28/06/05 for Down Lodge

This inspection was carried out on 28th June 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

Down Lodge 26/09/08

Down Lodge 06/09/06

Down Lodge 15/12/05

Down Lodge 18/01/05

Down Lodge 22/09/04

Down Lodge 16/03/04

Similar services:

St Vincents

The Cotswold Home

Newbeech House

Winton House

Rush Court

Hillyfield Rest Home

The Maypole Nursing Centre

The Briars

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

CARE HOMES FOR OLDER PEOPLE Down Lodge 11 Sturgess Road Wokingham Berkshire RG11 2HG Lead Inspector Amanda Longman Unannounced 28 June 2005 10:00hrs. th 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. Down Lodge H52-H01 S11397 Down Lodge V223563 280605 Stage 4.doc Version 1.40 Page 3 SERVICE INFORMATION Name of service Down Lodge Address 11 Sturgess Road Wokingham Berkshire RG11 2HG 118 978 6484 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) Mr G R Casseldon, Mrs. S R Taylor, Mr. M J Taylor Mrs S R Taylor Care Home 16 Category(ies) of Old age, not falling within any other category registration, with number OP 16 of places Down Lodge H52-H01 S11397 Down Lodge V223563 280605 Stage 4.doc Version 1.40 Page 4 SERVICE INFORMATION Conditions of registration: none Date of last inspection 18th January 2005 Brief Description of the Service: Down Lodge is a care home for 16 older peole. It is situated in a residential road close to Wokingham town centre. The home is situated over 2 floors with a stair lift providing access to the first floor. Fourteen rooms are single occupancy, with one room currently being shared. There is a communal lounge/dining room which provides access to an enclosed lawned garden. Down Lodge H52-H01 S11397 Down Lodge V223563 280605 Stage 4.doc Version 1.40 Page 5 SUMMARY This is an overview of what the inspector found during the inspection. The inspection was carried out during a daylong visit to Down Lodge. The inspector met with one of the proprietors, Mr. G. Casselden and one member of the management team (the Care Manager) Miss Eloise Taylor. A tour of the premises was undertaken. The inspector spoke with several residents and was able to take lunch with them. Staff members were spoken with and two service users relatives were interviewed. However because of the particular standards being examined on this occasion this was largely a records based inspection. The inspector reviewed five service user files in detail and assessed policies and procedures. Despite the number of requirements made this was largely a positive inspection. Down Lodge is a happy and homely establishment where service users feel supported and are encouraged to maximise their independence by committed and caring staff. However service user records, induction training, some health and safety issues and the management structure of the home all require attention. What the service does well: What has improved since the last inspection? A review of the requirements made following the last inspection showed improvements have been made to the records kept of meals consumed and Down Lodge H52-H01 S11397 Down Lodge V223563 280605 Stage 4.doc Version 1.40 Page 6 that risk assessments for unguarded radiators are now in place. There are plans to introduce a new form of care records but this was not yet in place. The inspector was informed that new versions of the Statement of Purpose and the Service User Guide had been prepared and that these would be forwarded to the inspector shortly. What they could do better: 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. Down Lodge H52-H01 S11397 Down Lodge V223563 280605 Stage 4.doc Version 1.40 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 Down Lodge H52-H01 S11397 Down Lodge V223563 280605 Stage 4.doc Version 1.40 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) 1 and 4 The documentation about the home, provided to potential service users was not available. All service users participate in a thorough pre-admission assessment which enables the home to decide and the service user to see, that their needs will be appropriately met. The content of a previous requirement made in relation to standard 4 is further discussed under standards 7 and 8. EVIDENCE: The proprietor explained that the Statement of Purpose and Service User Guide had recently been updated and were currently stored on one of the proprietor’s lap top computers and so were not available. An examination of five service user files showed thorough pre-admission assessments in place including a detailed questionnaire completed with or by the service user about their social history and their personal preferences for all aspects of their care. Down Lodge H52-H01 S11397 Down Lodge V223563 280605 Stage 4.doc Version 1.40 Page 9 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 and 9 Service users needs are set out in a service user plan that covers health, personal and social care needs together with risk assessments. These plans and associated risk assessments are reviewed monthly and a full reassessment is undertaken 6 monthly. Service users health care needs are met and service users are protected by the home’s policies and procedures for dealing with medication. However, service user files were not easy to follow. A previous requirement made in relation to standard 4 expressed the need for all care planning documentation to be completed in a consistent manner. This impacts on the score given for standard 7 in this inspection. Goals or outcomes of care for individual service users were not always specified. Diabetic service users were not enabled to access their entitlement to free chiropody services. EVIDENCE: Five service user files were examined in detail. All contained a service user plan which addressed health needs, personal and social care needs. However because there was no standard index or order for keeping records the service files were difficult to navigate. It is understood from the proprietor that a new record keeping system is being purchased. Evidence was seen regarding eye tests, hearing tests and chiropody but information was not ordered in all of the files. For one service user it was not Down Lodge H52-H01 S11397 Down Lodge V223563 280605 Stage 4.doc Version 1.40 Page 10 evident until half way through the file that she was registered blind and the relevant risk assessments did not reflect this. The Care Manager stated she was not aware that diabetic service users were entitled to free chiropody. The policies and procedures relating to medication were seen to be appropriate and adhered to. The drugs cupboards were suitable and locked. Down Lodge H52-H01 S11397 Down Lodge V223563 280605 Stage 4.doc Version 1.40 Page 11 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 and 15 (part) Service users are enabled to maintain contact with family, friends and representatives from the local community. They are encouraged to go out and receive visitors and are enabled to treat Down Lodge as their own home. Service users receive a wholesome appealing balanced diet in pleasing surroundings, at times convenient to them. EVIDENCE: The pre admission assessment undertaken with each service user by the home, records many details about family relationships and friendships, past times and pleasures. One service user was witnessed being taken out by his son on the day of the inspection and one was witnessed being brought back from an outing by her family. The inspector observed the interactions between service users’ families and the management and staff at Down Lodge. The relatives were welcomed in to the home (including a young great grandson) in a warm and friendly manner. The conversation was familiar, whilst respectful. The inspector spoke with both relatives who stated the home provided very good care and enabled their mother/father to maintain as much independence as possible. One of the relatives spoken with stated that his father was well looked after and liked to walk in to Wokingham town centre most days. The encouragement for people to go out, have visitors and maintain contacts was Down Lodge H52-H01 S11397 Down Lodge V223563 280605 Stage 4.doc Version 1.40 Page 12 further evident in conversations with two other service users and general conversations with staff. The inspector viewed the kitchen, spoke with the cook, examined records of meals taken and sat with the service users to sample lunch. The kitchen was clean and tidy, food was stored appropriately and records of fridge temperatures are kept. These temperatures had been slightly high on occasions. The cook was aware of this. The cook was observed working and checked the temperature of cooked food appropriately. Records of menus were seen, and of what individuals actually had eaten. A cooked meal is provided every lunchtime. The cook demonstrated good knowledge of service users likes and dislikes, and their dietary needs. Alternatives are offered as required. Lunch on the day was shepherds pie with cauliflower and runner beans. The presentation and taste were very good. Some service users opted to have lunch served on a tray in their rooms. The dining area was comfortably furnished in a homely style and the atmosphere during lunch was warm and pleasant. The staff served lunch in a friendly and pleasant manner and provided appropriate unobtrusive assistance when required. Having attempted to encourage one reluctant service user to sample the cooked lunch, her choice of a sandwich was then provided. During lunch the inspector chatted with a service user who was very pleased with all aspects of the home and described it as very comfortable. Down Lodge H52-H01 S11397 Down Lodge V223563 280605 Stage 4.doc Version 1.40 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 and 18 Service users comments and complaints are encouraged and acted upon. The general ethos of the home seeks to protect service users from abuse and procedures covering abuse of vulnerable adults and whistle blowing are in place. It is recommended that the home reviews its policies in this area to satisfy themselves that the correct policies and procedures are in place. EVIDENCE: The complaints procedures were examined and found to be appropriate. A copy of the complaints procedure, containing contact details for The Commission for Social Care was on display in the entrance hall. No complaints were recorded since November 2004. The procedures document relating to adult protection in the processes file was dated April 2004 and out of date. This needs reviewing by the home. A more up to date policy, including Whistle Blowing, which included the Local Authority Inter Agency Guidelines for handling abuse was found in the Health and Safety file. Although evidence was also seen that some staff have attended external courses, discussions with the Care Manager revealed that she was not familiar with the local authority guidelines. The inspector was able to satisfactorily clarify with the Care Manager the role of the local authority lead officer for vulnerable adults. Down Lodge H52-H01 S11397 Down Lodge V223563 280605 Stage 4.doc Version 1.40 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, 24, 25 and 26 Down Lodge is a safe, comfortable home which is well maintained, clean, pleasant and generally hygienic. Service users enjoy indoor and outdoor communal facilities and benefit from comfortable bedrooms with their own possessions around them. Risks posed by uncovered radiators have been assessed, but surface temperatures of these need to be monitored to ensure they do not exceed 43 degrees Celsius and used to inform the risk assessments. Whilst the stair lift is not ideal, the potential risks posed by it are well managed by the staff. This situation will need monitoring as the risks may increase should any of the home’s residents become more dependent. The proprietor needs to ensure the suppliers of the new hot water system return promptly to rectify the problem of the water temperatures becoming too hot on occasions. The laundry requires the addition of hand washing facilities and an impermeable floor. EVIDENCE: Down Lodge H52-H01 S11397 Down Lodge V223563 280605 Stage 4.doc Version 1.40 Page 15 The garden of the home was seen to be tidy, safe and accessible and evidence from conversations with staff and service users showed it is well used for eating out, sitting out or for social gatherings. A tour of the home revealed it to be clean, pleasantly furnished and comfortable. On the day of the inspection the hairdresser was visiting. Unfortunately the lack of a separate hairdressing room meant that this was undertaken at the back of the sitting room, but this was seen to be done as unobtrusively as possible. The first floor is reached by a single staircase that also contains a stair lift. This is not an ideal arrangement as it makes the usable staircase narrower and limits the use of the outer handrail. However the inspector witnessed staff supervising service users using the staircase and all staff and service users observed were currently able to use the staircase safely. In addition to the internal staircase there are external fire escapes at each end of the first floor. Records for fire drills and monthly fire safety checks were seen and were all up to date. As were all the records of self-tests of equipment. A monthly health and safety check list of all rooms was seen to be done regularly and actioned appropriately, e.g. lights, call bells, electrical sockets, taps, carpets etc. The proprietor provided information that a new hot water system had been installed within the last three to four weeks. However it is currently causing some problems with water temperatures being too high. The proprietor informed the inspector that the supplying company are due to return to check the thermometers. Records of routine maintenance of the home were seen as was the last food safety inspection (July 2002). All recommendations from which were seen to have implemented, including insect blinds at the kitchen windows. Five service users bedrooms were seen: all were clean and comfortable and furnished to varying degrees with the service user’s own furniture and possessions. A previous requirement had been made to undertake risk assessments of all uncovered radiators in service users bedrooms and communal areas. These had been undertaken and the risk of scolding from radiators had been minimised by the re-arranging of furniture wherever possible. Some radiators had been replaced, but not with cool to touch surfaces. A tour of the home revealed it to be clean, hygienic and free from any offensive odours. The laundry is located in a room on the first floor. However it does not provide hand washing facilities and the floor needs to be finished in an impermeable covering. The inspector observed mop heads stored in buckets and clarified with the proprietor that these need to be washed and dried daily to limit the spread of infection. Down Lodge H52-H01 S11397 Down Lodge V223563 280605 Stage 4.doc Version 1.40 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, 28 and 30 Service users’ needs are currently met by the numbers and skill mix of staff on duty, but this would need to be reviewed should the dependency level of any service users increase. Service users are in safe hands. The induction process for new staff needs to be documented in line with TOPSS (The National Training Organisation for Social Care) requirements. EVIDENCE: The staff rotas were examined and discussed with the Care Manager. The home currently deploys two care workers to each daytime shift and one at night. The home uses a rostered standby system to ensure there is staff cover in the event of sickness or additional requirements and a senior member of staff is on call at night. Evidence was seen that 50 of staff are currently qualified to NVQ level 2 or above and 4 further staff are currently studying (2 for level 2 and 2 for level 4). The staff training programme was reviewed which showed evidence of all training undertaken in the last two years and that programmed for this year. Topics included infection control, dementia, food hygiene, medication and first aid. The induction training process was discussed with the acting manager but this process needs to be documented and management need to ensure it meets the laid down “TOPSS” criteria. Down Lodge H52-H01 S11397 Down Lodge V223563 280605 Stage 4.doc Version 1.40 Page 17 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, 33, 35 and 38 The registered manager no longer works full time at the home and the home is primarily managed by the Care Manager who was present at this inspection. Whilst it is acknowledged that this does not appear to have a detrimental impact on service users, it contravenes the regulations and needs to be resolved. A previous requirement asking the home to review its management arrangements by April 2005 has not been met. Improvements need to be made to the quality assurance policies and procedures to be able to demonstrate that the home is run in the best interest of its service users. Service users financial interests are safeguarded. The health, safety and welfare of service users and staff are promoted, but further work is required in this area to fully meet this standard. EVIDENCE: Examination of the staff rotas and discussion with the Care Manager revealed that the current registered manager now only works at the home two or three Down Lodge H52-H01 S11397 Down Lodge V223563 280605 Stage 4.doc Version 1.40 Page 18 nights each week although the inspector was informed the registered manager does call in at other times. The Care Manager undertakes many of the management functions and is currently studying for her NVQ level 4 qualification. The situation is further complicated by evidence seen of the role of a further deputy called the assistant matron who also undertakes some supervisory functions. The quality assurance survey undertaken for 2004 was examined. The individual responses for this survey were very positive but the responses had not been collated into a report form so no evidence was available as to how the home measured its success in meeting the aims, objectives and statement of purpose, nor how it provided feedback on these areas to service users. Procedures and mechanisms for dealing with service users money were seen to be in place and appropriately followed. Elements of health and safety have been touched on in other parts of this report. See standards 25 and 26. Records were seen to show that training is provided to staff in health and safety, including infection control and manual handling; but as previously covered the induction training needs to be reviewed to bring it in line with TOPSS (see standard 30). Requirements relating to these standards need to be addressed before standard 38 can be fully met. Down Lodge H52-H01 S11397 Down Lodge V223563 280605 Stage 4.doc Version 1.40 Page 19 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 2 x x 3 x x HEALTH AND PERSONAL CARE Standard No Score 7 2 8 2 9 3 10 x 11 x DAILY LIFE AND SOCIAL ACTIVITIES Standard No Score 12 x 13 3 14 x 15 3 COMPLAINTS AND PROTECTION 3 3 x x x 3 2 2 STAFFING Standard No Score 27 3 28 3 29 x 30 2 MANAGEMENT AND ADMINISTRATION Standard No 31 32 33 34 35 36 37 38 Score Standard No 16 17 18 Score 3 x 3 2 x 2 x 3 x x 2 Down Lodge H52-H01 S11397 Down Lodge V223563 280605 Stage 4.doc Version 1.40 Page 20 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 1 Regulation 4 and 5 Requirement Up to date copies of The Statement of Purpose and Service User Guide must be available at all times and issued to all service users. This requirement is outstanding from the previous inspection Service user files need to be consistently completed and ordered and specify the outcomes to be achieved Proper provision for the treatment of diabetic service users feet must be made by enabling them to access free chiropody services Surface temperatures of unguarded radiators must be monitored and used to inform the risk assessments relating to these radiators The proprietor must ensure the suppliers of the new hot water system return promptly to rectify the problem of the water temperatures becoming too hot on occasions. Timescale for action 23 September 2005 2. 7 15 and 17 23 October 2005 23 September 2005 23 September 2005 23 August 2005 3. 8 13 (1) (b) 4. 25 13 (4) (a) 5. 26 13 (4) 6. 26 16 (2) (j) The laundry requires the addition 23 of hand washing facilities and an November impermeable floor. 2005 Version 1.40 Page 21 Down Lodge H52-H01 S11397 Down Lodge V223563 280605 Stage 4.doc 7. 8. 9. 10. 26 30 31 33 Mop heads must be washed and dried thoroughly after use 18 ( c ) (i) The induction process for new staff must be documented 8 and 18 The review of the management of the home must be completed 4 16 (2) (j) 11. 36 13, 16 and 18 A quality assurance process must be put in place which enables service users views to be collected and collated in such a way that feedback can be provided to service users to demonstrate that the home is run in the best interest of its service users and is meeting its aims and objectives. The requirements relating to 23 standards 25, 26 and 30 must be November met before this standard is met 2005 23 August 2005 23 October 2005 23 September 2005 23 November 2005 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 18 25 30 Good Practice Recommendations It is recommended that the home reviews its policies relating to vulnerable adults to satisfy themselves that the correct policies and procedures are in place. It is recommended that surface temperatures of unguarded radiators should not exceed 43 degrees celcius It is recommended that the induction process for new staff should be documented. in line with TOPSS (The National Training Organisation for Social Care) requirements. Down Lodge H52-H01 S11397 Down Lodge V223563 280605 Stage 4.doc Version 1.40 Page 22 Commission for Social Care Inspection 2nd Floor, 1015 Arlington Business Park Theale Berkshire RG7 4SA 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 Down Lodge H52-H01 S11397 Down Lodge V223563 280605 Stage 4.doc Version 1.40 Page 23 - 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. Discrete codes and changes have been inserted throughout the textual data shown on the site that will provide incontrovertable proof of copying in the event this information is re-published on other websites. 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