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Inspection on 17/08/06 for Elmhurst

Also see our care home review for Elmhurst for more information

This inspection was carried out on 17th August 2006.

CSCI has not published a star rating for this report, though using similar criteria we estimate that the report is Good. 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 made no statutory requirements on the home as a result of this inspection and there were no outstanding actions from the previous inspection report.

What follows are excerpts from this inspection report. For more information read the full report on the next tab.

What the care home does well

Elmhurst is a well managed home, that communicates effectively with residents and their relatives, through meetings, newsletters and individual conversation. The admission arrangements and information for prospective residents is good. Care plans are detailed, individual to each resident, and drawn up with the resident where possible. The provision of meals, snacks and drinks is good. Residents enjoy a freedom of choice in how and where to spend their time, and staff respect residents wishes.

What has improved since the last inspection?

Further to the last inspection of March 2006, no requirements or recommendations were made. Since then the home has formed a "League of Friends" made up of staff and visitors, who organise social events and activities for residents.

What the care home could do better:

As a result of this inspection three requirements and one good practice recommendation is made of the home. These requirements relate to staffing levels, the medicine records and first aid training. Handwritten medicine charts need to be signed by the author and verified by a checker, that they are correct. Night staffing levels need to be increased so that residents needs can be met in a safe and timely way. A good practice recommendation is made for the home to increase the number of care staff with an NVQ in care. The home has previously had a very stable staff team, but has recently been using a lot of agency staff, which is not conducive to providing consistent care to people with dementia. No recommendation is made on this at present, as recruitment of new staff had just taken place.

CARE HOMES FOR OLDER PEOPLE Elmhurst Priory Road Ulverston Cumbria LA12 9HU Lead Inspector Jenny Donnelly Unannounced Inspection 17th August 2006 8:15 X10015.doc Version 1.40 Page 1 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 Elmhurst DS0000036576.V291304.R01.S.doc Version 5.2 Page 2 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. Elmhurst DS0000036576.V291304.R01.S.doc Version 5.2 Page 3 SERVICE INFORMATION Name of service Elmhurst Address Priory Road Ulverston Cumbria LA12 9HU Telephone number Fax number Email address Provider Web address Name of registered provider(s)/company (if applicable) Name of registered manager (if applicable) Type of registration No. of places registered (if applicable) 01229 894115 www.cumbriacare.org.uk Cumbria Care Mrs Jayne Allonby Care Home 40 Category(ies) of Dementia - over 65 years of age (32), Old age, registration, with number not falling within any other category (40) of places Elmhurst DS0000036576.V291304.R01.S.doc Version 5.2 Page 4 SERVICE INFORMATION Conditions of registration: 1. 2. The service must at all times employ a suitably qualified and experienced manager who is registered with the Commission for Social Care Inspection. The home is registered for a maximum of 40 service users to include: up to 40 service users in the category of OP (Old age, not falling within any other category) up to 32 service users in the category of DE(E) (Dementia over 65 years of age) When single rooms of less than 12 sqm usable floor space become available they must not be used to accommodate wheelchair users, and where existing wheelchair users are in bedrooms of less than 12 sqm they must be given the opportunity to move to a larger room when one becomes available. 9th March 2006 3. Date of last inspection Brief Description of the Service: Elmhurst is a purpose built locally authority care home. Cumbria County Council own the home, which is operated by Cumbria Care. Mrs Jayne Allonby is the registered manager. Elmhurst is a single storey building situated 15 minutes walk from the centre of Ulverston town. It is divided into four units of 10 bedrooms. Each unit has its’ own dining lounge, two bathrooms and a toilet. There are four bedrooms with an en-suite bathroom, and two with adjoining doors for married couples or siblings. Three of the units cater for people with dementia, and the other unit is for the physically frail. The three-dementia care units have open access within the home, but no free external access. Elmhurst has a small smoking room, and a pleasant secure garden. The weekly fees ranged from £363.00 to £422.00 according to residents’ dependency needs. The home had information for prospective residents and their families in the form of a statement of purpose and service users guide. A copy of the latest inspection report was also available from the home. Elmhurst DS0000036576.V291304.R01.S.doc Version 5.2 Page 5 SUMMARY This is an overview of what the inspector found during the inspection. This inspection comprised of two unannounced visits to the home, one on 17th August from 20.15 to 22.30 hours, and another on 21st August from 10.00 to 12.30 hours. In the months preceding these visits, written information had been gathered from the home manager, and comment cards had been collected from the residents. During the visits to the home, I spoke with residents and staff, observed the general running of the shift, looked at residents’ care and medication records, and inspected staff files. The manager was on leave at the time of these visits. What the service does well: What has improved since the last inspection? What they could do better: As a result of this inspection three requirements and one good practice recommendation is made of the home. These requirements relate to staffing levels, the medicine records and first aid training. Handwritten medicine charts need to be signed by the author and verified by a checker, that they are correct. Night staffing levels need to be increased so that residents needs can be met in a safe and timely way. A good practice recommendation is made for the home to increase the number of care staff with an NVQ in care. The home has previously had a very stable staff team, but has recently been using a lot of agency staff, which is not conducive to providing consistent care to people with dementia. No recommendation is made on this at present, as recruitment of new staff had just taken place. Elmhurst DS0000036576.V291304.R01.S.doc Version 5.2 Page 6 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. Elmhurst DS0000036576.V291304.R01.S.doc Version 5.2 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 Outcomes Statutory Requirements Identified During the Inspection Elmhurst DS0000036576.V291304.R01.S.doc Version 5.2 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 the following standard(s): 1 and 3 Quality in this outcome area is good. This judgement has been made using the evidence available including a visit to the service. The home had good information for prospective residents and their families, about the services on offer at Elmhurst. All new residents had their needs thoroughly assessed before being offered a place in the home, this ensured Elmhurst would be able to meet their health and social care needs. EVIDENCE: The home had good information for prospective residents and their relatives. This was in the form of a statement of purpose and service user guide. Preadmission assessments were undertaken of prospective residents, before they were offered a place in the home. This was to ensure that Elmhurst would be a suitable placement, and be able to meet the persons’ health and social care needs. Information was also gathered, where relevant, from the persons’ social worker, community nurse and/or the hospital. This was used in conjunction with the homes’ assessment to build a picture of the persons’ needs and preferences. The home does not provide intermediate care. Elmhurst DS0000036576.V291304.R01.S.doc Version 5.2 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 the following standard(s): 7, 8, 9 and 10 Quality in this outcome area is good. This judgement has been made using the evidence available including a visit to the service. The home was meeting residents’ personal care needs well throughout the day, although this was less so at night due to low staffing levels. The management of health care and medicines was generally good, and benefited residents general wellbeing. Staff respected and helped to maintain residents’ privacy and dignity. EVIDENCE: The care plans of three residents were inspected, these included one shortterm respite, one resident new to the home and someone who had lived at Elmhurst for a long time. Each care plan was laid out following a set format, using standard documentation. The plans were detailed, up to date and very informative about each resident’s needs and wishes. These included long term and short care plans, and risk assessments for maintaining residents safety. There was evidence of good healthcare input for those residents that needed it. Consultations with the doctor, community nurse and psycho-geriatrician were recorded, with any new care instructions made clear for staff. Where appropriate, residents had signed their agreement to their care plan. Other healthcare services, such as chiropody and dentistry, were arranged either privately or through the NHS as the residents preferred. During my visit to the Elmhurst DS0000036576.V291304.R01.S.doc Version 5.2 Page 10 home I met some visiting professionals, who spoke well of the care home, the manager and staff. Residents appeared cared for, and said they felt “well looked after” at Elmhurst. Bathing and personal care had been taking place, both during the evening and morning visit, with residents assisted to dress as they chose. There was evidence that the low staffing levels at night reduced the quality of care offered at this time, meaning residents were less well supervised and had to wait for attention. This is commented on further under “Staffing”. Staff had received instruction on treating residents with dignity and respect, and protecting personal privacy. Those residents, who were able, confirmed that personal care was carried out in private. I observed bathroom and toilet door locks being used, and staff knocking on bedroom doors before entering. The management of medicines was inspected and found to be safe. There were good systems for recording all medicines in the home, including records of receipt, administration and the return of any unwanted/wasted medicines. Staff who dealt with the medicines, had undergone training in the safe management of medicines. The medicine administration charts were mostly printed, although some were handwritten, where additional medicines had been prescribed, or new residents were not yet on the printed system. These handwritten charts were said to be checked by two staff, but there was no evidence of this. Where staff handwrite medicine charts, these should be signed to confirm who copied it out, and who double-checked that the prescription was copied out correctly. This is subject to a requirement. Elmhurst DS0000036576.V291304.R01.S.doc Version 5.2 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 the following standard(s): 12, 13, 14 and 15 Quality in this outcome area is good. This judgement has been made using the evidence available including a visit to the service. There were good opportunities for residents to join in activities and events as they wished, and there was no restriction on movement around the home. The provision of meals was good, and allowed choice and variety. EVIDENCE: The home operated a varied programme of activities led by care staff. There was a two-week programme on display in the entrance hall, showing which staff would be leading each activity. I observed staff on one unit organising an exercise session using different sizes and shapes of soft balls. The staff member was qualified in armchair exercises for the elderly. Residents clearly enjoyed this activity, and participated with enthusiasm. The home had a lovely information board, showing photographs of residents, staff and visitors enjoying a summer event in the grounds. The home had a new “League of Friends” made up of staff and relatives, who arranged special events such as the summer fair. Any money raised at these events was put into the residents amenity fund for future activities/events. Residents were observed moving freely around the home, and spending time on other units as they wished. Those residents, who chose to wander, were able to do so and appeared content in their activity. Residents confirmed they Elmhurst DS0000036576.V291304.R01.S.doc Version 5.2 Page 12 went to bed at a time that suited them, and most people chose to stay up quite late. The home operated open visiting, although no family visitors were seen on this occasion. Residents enjoyed the meals at Elmhurst, saying the “cook is very good”. The home has been using a lot of agency cooks to cover staff absences, but this did not appear to reduce the quality of meals for residents. There was a menu system in operation, and staff asked residents each morning what they would like from the menu. This information was then relayed to the kitchen along with any special orders for alternatives. Lunch on the day of my morning visit was corned beef hash or chicken and leek pie, with vegetables, followed by upside down pudding or egg custard. Meals were served from hot trolleys in each unit, with residents helping to lay tables, and clear away, if they wished. During the evening staff were seen making frequent hot drinks for residents, and offering them biscuits and toast before bed. Elmhurst DS0000036576.V291304.R01.S.doc Version 5.2 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 the following standard(s): 16 and 18 Quality in this outcome area is good. This judgement has been made using the evidence available including a visit to the service. There were sound systems through which residents or relatives could raise concerns, and be listened to. The home had procedures in place to protect vulnerable adults from abuse, and staff understood these. EVIDENCE: The home had a complaints procedure in place, which was clear, and told people how and who to complaint to. No complaints had been made to the home since the last inspection, and none had been made directly to the inspector. There were policies and procedures for staff on protecting vulnerable adults, and information on what to do in the event of a suspected abuse. Staff confirmed that they had received training on adult protection as part of their induction, and foundation training, as well as it being covered periodically during their individual supervision sessions. Residents said they felt “safe” in the home. Elmhurst DS0000036576.V291304.R01.S.doc Version 5.2 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 the following standard(s): 19, 23, 24 and 26 Quality in this outcome area is good. This judgement has been made using the evidence available including a visit to the service. Residents were living in a purpose built, well maintained, clean and comfortable home. EVIDENCE: The home is purpose built, and all on one level. There are four ten bedded units, each with its’ own dining lounge and two bathrooms. Three of the units catered for people with dementia, with the fourth being for the physically frail. All bedrooms were single although two had adjoining doors, for use by siblings or married couples. Residents had brought personal items into Elmhurst and made their bedrooms homely and personalised. Residents had free access around the home, except for the physically frail unit, which had keypad locks, to prevent the residents with dementia entering. There were also keypad locks on external doors; the home is sited on a busy road. The residents on the physically frail unit knew how to operate to keypad locks if they wished to go out. My evening visit took place on a very wet and thundery night, and the home was warm, welcoming and cosy throughout. There was a stale smell in the main corridor area that evening, which had gone by the next visit. Apart Elmhurst DS0000036576.V291304.R01.S.doc Version 5.2 Page 15 from that the home appeared clean and fresh throughout, and domestic staff were seen going about their duties. The supervisors were responsible for maintenance checks, including water temperature, fire alarm and fire equipment checks. These were up to date. External contractors were used for bigger maintenance and repair jobs. The standard of décor and general repair around the building was good. Elmhurst DS0000036576.V291304.R01.S.doc Version 5.2 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 consider all the above are key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 27, 28, 29 and 30 Quality in this outcome area is adequate. This judgement has been made using the evidence available including a visit to the service. Throughout the day staffing levels were sufficient to meet the needs of residents. During the night there were not enough staff to meet residents’ needs in a timely manner. Staff recruitment procedures were sound and served to protect residents, although the team had undergone some changes and there was a heavy reliance on agency staff. Staff training was good, although more staff should have an NVQ in care. EVIDENCE: Staffing levels throughout the day generally comprise of a supervisor plus 8 care staff, called support workers. The dementia units each have 2 staff, there is one staff on the physically frail unit, the 8th staff and supervisor work across the home, doing medications and helping out as required. The night shift begins at 10pm and consists of two staff. With the home being arranged in four units, it is not possible for staff to be present on each unit. Night staff start their shift working from one end of the building, making drinks and settling residents to bed (if they wish to go). This means that by the time staff reach the fourth unit, residents have been unsupervised and unassisted for a long period of time. On my evening visit there were 23 residents up in the lounges when the night staff came on duty. Other residents were also up, but sitting in their bedrooms. With over 50 of residents choosing to go to bed later, the home needs to increase the night staffing levels accordingly, and this is subject to a requirement. Staff stated that at least 6 residents were Elmhurst DS0000036576.V291304.R01.S.doc Version 5.2 Page 17 regularly awake and wandering throughout the night, going into other residents’ bedrooms. This was confirmed as a minimum by the psychogeriatrician who visits the home. Information supplied by the manager said that 16 residents needed the help of two staff during the night. The night staff did receive some help from night “home care” staff who were based at Elmhurst between calls. This help varied between nothing and a few hours, when home care staff would help with the laundry, including ironing, which night staff are expected to complete. A review of staff files showed the home had thorough recruitment procedures, which the manager adhered to. The home had been reliant on a lot of agency care staff, as a well as agency cooks. During April and May, 50 care staff shifts had been covered by agency workers. This is not conducive to providing a consistent level of care to people with dementia, who have limited communication. However, several new care staff had been recently appointed and were due to start work once all necessary checks were completed. Staff training was well organised within the home, although only 30 of care staff had an NVQ in care, it is recommended 50 of staff hold this qualification. Staff confirmed that they had good access to training, through the homes’ formal induction and foundation training programmes, plus updates through supervision sessions. Staff spoken to had attended fire safety, moving and handling, dementia awareness and adult protection training. The manager and two of the supervisors were qualified dementia trainers, and had training sessions on this planned for later in the year. Elmhurst DS0000036576.V291304.R01.S.doc Version 5.2 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 31, 33, 35 and 38 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 31, 33, 35, 36 and 38 Quality in this outcome area is good. This judgement has been made using the evidence available including a visit to the service. The manager and staff ran the home in the best interests of residents, and promoted their health, safety and wellbeing. EVIDENCE: The registered manager is suitably qualified and competent to run the home. She was on annual leave at the time of these inspection visits, leaving her seniors in charge of the day-to-day running of the home. There was external management support in the form of an Operations Manager, who overseas a number of Cumbria Care homes in the area. Residents and staff confirmed that they saw the manager frequently and she was accessible if they needed to discuss anything with her. For quality assurance purposes the manager sent out satisfaction surveys at regular intervals to residents and relatives. The results of these were used as the basis for any forward planning, or changes in the home. There were other forums, including meetings and a Elmhurst DS0000036576.V291304.R01.S.doc Version 5.2 Page 19 newsletter, through which residents and relatives could comment on the service, and keep updated with any changes. There were also regular staff meetings, and all staff received regular one to one supervision meetings, of which records were kept. The homes policies and procedures were discussed in rotation, during supervision meetings. The home held spending money on behalf of some residents, and this was being safely managed. Separate record books and money wallets were held for each resident, and these were audited weekly. The records and money of two residents were checked, and correct. The health and safety of residents, visitors and staff was promoted through the regular maintenance and safety checks in the home. Staff had received training in safe moving and handling, fire safety and food hygiene. Elmhurst DS0000036576.V291304.R01.S.doc Version 5.2 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 Standard No Score 1 2 3 4 5 6 ENVIRONMENT Standard No Score 19 20 21 22 23 24 25 26 3 X 3 X X X HEALTH AND PERSONAL CARE Standard No Score 7 4 8 3 9 2 10 3 11 X DAILY LIFE AND SOCIAL ACTIVITIES Standard No Score 12 3 13 3 14 3 15 3 COMPLAINTS AND PROTECTION Standard No Score 16 3 17 X 18 3 3 X X X 3 3 X 3 STAFFING Standard No Score 27 2 28 2 29 3 30 3 MANAGEMENT AND ADMINISTRATION Standard No 31 32 33 34 35 36 37 38 Score 3 X 3 X 3 3 X 3 Elmhurst DS0000036576.V291304.R01.S.doc Version 5.2 Page 21 Are there any outstanding requirements from the last inspection? No 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 OP9 Regulation 13(2) Requirement Timescale for action 01/10/06 2 OP27 18(1) Handwritten medicine administration charts must be checked as correct and signed to confirm this. The home must provide 01/10/06 sufficient staff at night to meet the needs of residents in a timely way. 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 Refer to Standard OP28 Good Practice Recommendations At least 50 of the care staff should have an NVQ in care at level 2 or above. Elmhurst DS0000036576.V291304.R01.S.doc Version 5.2 Page 22 Commission for Social Care Inspection Eamont House Penrith 40 Business Park Gillan Way Penrith Cumbria CA11 9BP 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 Elmhurst DS0000036576.V291304.R01.S.doc Version 5.2 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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