Inspection on 23/01/06 for Ivy Cottage

This inspection was carried out on 23rd January 2006.

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. These are things the inspector asked to be changed, but found they had not done. The inspector also made 2 statutory requirements (actions the home must comply with) as a result of this inspection.

Other inspections for this house

Ivy Cottage 03/02/09

Ivy Cottage 11/10/06

Ivy Cottage 09/08/05

Ivy Cottage 08/11/04

Ivy Cottage 12/07/04

Ivy Cottage 02/03/04

Similar services:

Larch Avenue

Alderson Road 12

Cranworth Close Registered Care Home

The Cornerstone

John Street Nursing Home

Pennine Camphill

Whitwood House

Whitwood Hall

Extracts from inspection reports are licensed from CQC, this page was updated on 09/07/2008.

CARE HOME ADULTS 18-65 Ivy Cottage Ackton Lane Ackton Featherstone West Yorks WF7 6HP Lead Inspector Patricia Pedley Unannounced Inspection 23rd January 2006 10:40 Ivy Cottage DS0000006269.V279661.R01.S.doc Version 5.1 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 Ivy Cottage DS0000006269.V279661.R01.S.doc Version 5.1 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 Adults 18-65. 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. Ivy Cottage DS0000006269.V279661.R01.S.doc Version 5.1 Page 3 SERVICE INFORMATION Name of service Ivy Cottage Address Ackton Lane Ackton Featherstone West Yorks WF7 6HP 01977 701370 01977 795707 ivycottage1@tiscali.co.uk 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) Ivy Cottage (Ackton) Limited Care Home 10 Category(ies) of Learning disability (10) registration, with number of places Ivy Cottage DS0000006269.V279661.R01.S.doc Version 5.1 Page 4 SERVICE INFORMATION Conditions of registration: Date of last inspection 9th August 2005 Brief Description of the Service: Ivy Cottage is a care home providing personal care and accommodation for 10 younger adults who have a learning disability. Many of the service users present with complex needs including the management of challenging behaviour. The home is situated in Ackton, a small residential suburb of Featherstone, and is some distance from local amenities. It is privately owned and has two sister homes which also accommodate this category of service user. The premises, that are not purpose built, have service user accommodation arranged on two floors. All bedrooms are designed for single occupation and there is adequate communal space. The home has a small open garden to the front of the house and a pleasant secure courtyard to the rear along with car parking facilities. Ivy Cottage DS0000006269.V279661.R01.S.doc Version 5.1 Page 5 SUMMARY This is an overview of what the inspector found during the inspection. This was an unannounced inspection of the home carried out by two inspectors over a period of 4 hours. The inspectors spoke with the new manager and other staff, spoke with service users, examined records and looked around the home. The manager is not yet registered; her application for registration has been submitted to the Commission. The inspectors would like to thank service users and staff for their assistance and hospitality during this visit. What the service does well: What has improved since the last inspection? What they could do better: The requirement made at the last inspection to supply pedal bins and liquids soap where personal care is offered to service users is yet to be met. There are some environmental issues to be addressed in the body of this report, including re-decoration of some areas, mending furniture and risk assessing the need for radiator covers. Ivy Cottage DS0000006269.V279661.R01.S.doc Version 5.1 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. Ivy Cottage DS0000006269.V279661.R01.S.doc Version 5.1 Page 7 DETAILS OF INSPECTOR FINDINGS CONTENTS Choice of Home (Standards 1–5) Individual Needs and Choices (Standards 6-10) Lifestyle (Standards 11-17) Personal and Healthcare Support (Standards 18-21) Concerns, Complaints and Protection (Standards 22-23) Environment (Standards 24-30) Staffing (Standards 31-36) Conduct and Management of the Home (Standards 37 – 43) Scoring of Outcomes Statutory Requirements Identified During the Inspection Ivy Cottage DS0000006269.V279661.R01.S.doc Version 5.1 Page 8 Choice of Home The intended outcomes for Standards 1 – 5 are: 1. 2. 3. 4. 5. Prospective service users have the information they need to make an informed choice about where to live. Prospective users’ individual aspirations and needs are assessed. Prospective service users know that the home that they will choose will meet their needs and aspirations. Prospective service users have an opportunity to visit and to “test drive” the home. Each service user has an individual written contract or statement of terms and conditions with the home. The Commission consider Standard 2 the key standard to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 5 Arrangements for informing service users of what they might expect from living in the home are satisfactory. EVIDENCE: An examination of service user files showed that the service user or their designated representative had signed a copy of the terms and conditions of occupancy. Ivy Cottage DS0000006269.V279661.R01.S.doc Version 5.1 Page 9 Individual Needs and Choices The intended outcomes for Standards 6 – 10 are: 6. 7. 8. 9. 10. Service users know their assessed and changing needs and personal goals are reflected in their individual Plan. Service users make decisions about their lives with assistance as needed. Service users are consulted on, and participate in, all aspects of life in the home. Service users are supported to take risks as part of an independent lifestyle. Service users know that information about them is handled appropriately, and that their confidences are kept. The Commission considers Standards 6, 7 and 9 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 6, 7, 8, 9 & 10 Care planning and risk assessment processes are maintained to a good standard demonstrating that staff have a good understanding of service user’s individual support needs. EVIDENCE: Four service user files were sampled. The manager said that all care plans are being updated. Care plans were found to be of a good standard demonstrating that there had been service user involvement and where possible these had been signed by the service user. The manager said that changes were taking place so that a regular review of care plans took place with full involvement from the service user. Staff had found that care reviews specifically for the service user were best undertaken in a more informal setting and had booked a room at a local public house for discussing change and then had stayed on for lunch afterwards. The manager said that confidentiality was assured since the room was booked on a private basis before the pub opened to the public. The manager said that other changes planned to care plans would be undertaken within a person centred approach and that staff have recently been introduced to person centred planning during recent value based training. Ivy Cottage DS0000006269.V279661.R01.S.doc Version 5.1 Page 10 Risk assessments were found to have been prepared which link strongly with individualised care plans. The manager said that these are also discussed fully with service users. Recorded evidence also shows that human right issues are taken into account in regards to personal freedom and choice whilst recognising individual needs and abilities. The minutes of service user meetings show that these take place regularly and that issues important to service users are discussed with them and action taken. From examining records, talking with staff and service users and observations made during the inspection, it was found that service users are encouraged to be independent where possible such as making drinks or using public transport. One member of staff said that some service users are able to use public transport independently but prefer to be supported by staff. From observation, it was seen that service users files are kept locked away in accordance with data protection principles. An examination of quality assurance systems showed that staff had been sent a questionnaire regarding their understanding of confidentiality issues. The resulting report showed that they had given a good response to the questions raised and any recommendations were highlighted for action. Ivy Cottage DS0000006269.V279661.R01.S.doc Version 5.1 Page 11 Lifestyle The intended outcomes for Standards 11 - 17 are: 11. 12. 13. 14. 15. 16. 17. Service users have opportunities for personal development. Service users are able to take part in age, peer and culturally appropriate activities. Service users are part of the local community. Service users engage in appropriate leisure activities. Service users have appropriate personal, family and sexual relationships. Service users’ rights are respected and responsibilities recognised in their daily lives. Service users are offered a healthy diet and enjoy their meals and mealtimes. The Commission considers Standards 12, 13, 15, 16 and 17 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 13, 14, 15, 16 & 17 Service users are encouraged to follow their own interests and take part in activities within the local community with appropriate support from staff. EVIDENCE: Upon first arriving at the care home some service users were at home whilst others had gone out for the morning. Some had gone to Temple Newsam Farm. Those service users who were in were listening to music, taking part in a craft activity and one was helping bake buns for the coffee morning the following day. Service users had decided they would like to have the coffee morning to fundraise for another local charitable service. Local residents had been invited to attend as well as friends and family members. A pool table is available in the main lounge and there is a well-equipped activity room, which has good storage, a music centre and a computer. Some of the service users work was displayed on the wall. Ivy Cottage DS0000006269.V279661.R01.S.doc Version 5.1 Page 12 An examination of records in care plans, including the records of daily journals, weekly or monthly reviews gave a good indication that service users are supported to take part in a number of activities including day services, college, voluntary work or other leisure pursuits. Three service users have their own bicycles and are supported by staff to use nearby cycle paths. One service user said that he was looking forward to seeing his family in a few days time and the manager later confirmed that several service users had family contact. A payphone is available in the dining room and a member of staff said that a few service users had their own mobile phone. A member of staff said that service users were encouraged to use the telephone before 6pm as this number also acts as the fax number. Service users are provided with a key to their room and staff said they do not enter without the service user’s permission. Staff were seen interacting with service users, taking them out for the morning or encouraging them to take part in an activity. There appeared to be an easy banter between service users and staff. From observations made service users are able to choose whether they wish to join in events. Some service users went to spend time in their room whilst the inspection was taking place. One service user said that she was looking forward to her birthday as she was going out with staff and was also looking forward to a holiday later in the year. When the inspectors arrived some home made soup was being made. A number of menus were seen which showed that a balanced diet was on offer. These were not dated. The manager said that service users could choose an alternative meal if they wished. A record of service user’s dietary likes and dislikes were seen on their individual file. Ivy Cottage DS0000006269.V279661.R01.S.doc Version 5.1 Page 13 Personal and Healthcare Support The intended outcomes for Standards 18 - 21 are: 18. 19. 20. 21. Service users receive personal support in the way they prefer and require. Service users’ physical and emotional health needs are met. Service users retain, administer and control their own medication where appropriate, and are protected by the home’s policies and procedures for dealing with medicines. The ageing, illness and death of a service user are handled with respect and as the individual would wish. The Commission considers Standards 18, 19, and 20 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 & 20 There is good evidence that healthcare needs are met. The arrangements for the safekeeping, administration and recording of medication are generally good and protects service users. A requirement has been made to store insulin properly. EVIDENCE: An examination of service user files shows that healthcare needs are met. Discussion with the manager demonstrated that professional healthcare support is obtained where needed. A member of staff responsible for dealing with medication said that the home now uses blister pack medication and that the pharmacist was planned to come and carry out some staff training because of the change. A copy of the training pack was seen. A copy of the medication procedure was available in the medication storage area and the senior on duty holds the medication keys. A risk assessment is in place for any service user who chooses to self medicate. An examination of the medication administration sheet showed that the record was correct against the drugs stored. It was recommended during the inspection that the sharps box be moved into a better position for moving and handling purposes. Action was taken to address this straight away. Ivy Cottage DS0000006269.V279661.R01.S.doc Version 5.1 Page 14 It was seen that insulin was kept in the fridge upstairs. This was not being kept in an insulated container but kept in the boxes supplied by the home’s pharmacist. A member of staff said that staff have been trained as competent by the district nurse. She also said that staff are regularly offered updated training. The home also receives good support from the diabetic clinic. Ivy Cottage DS0000006269.V279661.R01.S.doc Version 5.1 Page 15 Concerns, Complaints and Protection The intended outcomes for Standards 22 – 23 are: 22. 23. Service users feel their views are listened to and acted on. Service users are protected from abuse, neglect and self-harm. The Commission considers Standards 22, and 23 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 22 & 23 There are satisfactory arrangements for dealing with complaints and ensuring that service users are adequately protected through good practice in providing staff training and proper policies and procedures. EVIDENCE: The record of complaints in the book by the front door showed no complaints had been made recently. However, complaint forms showed that there had been two complaints since the last inspection, which had been dealt with properly. Since a number of service users have complex needs including the display of challenging behaviour the records of physical intervention and staff training was examined. The manager said the deputy manager is trained as a trainer in non-crisis intervention and takes responsibility for staff training. The responsible person also receives updated training. Any incident is `satisfactorily recorded. The manager said that staff receive internal training from a senior manager on adult abuse and this was confirmed through examining staff training records. . The local authority adult abuse procedure is available to staff. A member of staff was asked how she would deal with an allegation of abuse from a service user. She was able to provide a satisfactory response. Ivy Cottage DS0000006269.V279661.R01.S.doc Version 5.1 Page 16 Environment The intended outcomes for Standards 24 – 30 are: 24. 25. 26. 27. 28. 29. 30. Service users live in a homely, comfortable and safe environment. Service users’ bedrooms suit their needs and lifestyles. Service users’ bedrooms promote their independence. Service users’ toilets and bathrooms provide sufficient privacy and meet their individual needs. Shared spaces complement and supplement service users’ individual rooms. Service users have the specialist equipment they require to maximise their independence. The home is clean and hygienic. The Commission considers Standards 24, and 30 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 24, 26, 27, 28 & 29 In general the home is kept safe and well maintained. This can be enhanced further by carrying out any minor redecoration and repair highlighted during this inspection and ensuring the safety of service users from contact with hot radiators. EVIDENCE: A tour of most of the home was carried out although some bedrooms could not be accessed since some service users were out and therefore permission to look around their room could not be granted. Generally, the home is well maintained. A record of maintenance was seen. Staff record any work that is needed and once done, the work is signed off as having been completed. The quiet room was sparsely furnished. A member of staff said that the torn chair cover was to be recovered. Two doors had been damaged but were down for replacement in the maintenance book. There were no curtains up and the member of staff said these are regularly taken down by one of the service users. She said that they were considering putting film on the window to offer a degree of privacy since this window faced the main road. The lounge and dining room were in good order. Ivy Cottage DS0000006269.V279661.R01.S.doc Version 5.1 Page 17 An examination of some bedrooms found that there were some in very good decorative order with lots of personal possessions about. Others needed redecoration and had fewer personal possessions about. However, from discussion with staff, this was generally found to be because of the individual needs and behaviours of service users and staff explained how individual needs were met, they said that any broken furniture would be replaced or alternative arrangements made. Some bedrooms are fitted with non-slip flooring rather than carpet in order to meet personal care needs although staff said some needs had changed and they were hoping that carpet could be refitted to two rooms. Some corridors and other communal areas were seen to be in need of repainting. The manager said that the owners were keen to ensure that the home was kept in good order and had recently funded new tiling in the kitchen and to the exterior fascias. The home employs a maintenance person. He was busy re-varnishing the garden furniture during the inspection. Smokers are encouraged to smoke in the rear courtyard. The home also employs a gardener. The courtyard and front garden were well tended. Al radiators seen were unguarded by radiator covers. Some radiators were turned off. The member of staff said that some service user’s preferred cool rooms. Two radiators, one in a bathroom and another in a service user’s bedroom were felt to be extremely hot. The last inspection report required that liquid soap and pedal bins were provided. These were not available in every toilet and bathroom. Staff said that service users might have moved them. The seal in the shower was rather mouldy and needed attention. The shower door did not close properly. The floor in the second shower room was seen to be uneven. The extractor fan in one toilet was heard to be very noisy. From visiting the toilet and listening to staff comments it appears that the water pressure for filling all of the home’s toilet cisterns and flushing them properly takes a great deal of time. This may be because the water pressure in the home is limited. The manager said this has been checked in the past. The home employs a cleaner for 10 hours a week and at other times care staff assist service users keep the rest of the home, including their bedrooms clean and tidy. The home was found to be clean and fresh during this visit. Ivy Cottage DS0000006269.V279661.R01.S.doc Version 5.1 Page 18 Staffing The intended outcomes for Standards 31 – 36 are: 31. 32. 33. 34. 35. 36. Service users benefit from clarity of staff roles and responsibilities. Service users are supported by competent and qualified staff. Service users are supported by an effective staff team. Service users are supported and protected by the home’s recruitment policy and practices. Service users’ individual and joint needs are met by appropriately trained staff. Service users benefit from well supported and supervised staff. The Commission considers Standards 32, 34 and 35 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 32, 33, 34, 35 & 36 Staffing arrangements ensure that service users needs are met and that their interests and welfare is safeguarded. EVIDENCE: The manager said that there are good staffing levels. During the week there are 5 staff on morning and afternoon/evening duty not including the home’s activity organiser. The manager said that she is supernumerary to the rota and that the deputy manager is supernumerary for two days a week. At a weekend the home runs on 4 in a morning and 4 in the afternoon and evening. Two waking night staff are always on duty and there is a managerial “on call” system. An examination of a few staff files showed that these contained the information required by regulation. A record of staff interviews is kept. Staff training files showed that staff receive mandatory training including basic food hygiene, moving and handling, first aid and health and safety. Other training recorded included diabetes, autism and epilepsy awareness, dealing with challenging behaviour and bereavement training. A newer member of staff said that she had received induction and had attended the Learning Disability Award Framework training. She said she is due to start the NVQ level 2 training soon. The manager said that most staff have been trained in NVQ and Ivy Cottage DS0000006269.V279661.R01.S.doc Version 5.1 Page 19 those who had not were due to start their training very soon. Senior staff were either trained or were to be trained to NVQ level 3 standard. The records of staff supervision showed that the national minimum standard is met. Ivy Cottage DS0000006269.V279661.R01.S.doc Version 5.1 Page 20 Conduct and Management of the Home The intended outcomes for Standards 37 – 43 are: 37. 38. 39. 40. 41. 42. 43. Service users benefit from a well run home. Service users benefit from the ethos, leadership and management approach of the home. Service users are confident their views underpin all self-monitoring, review and development by the home. Service users’ rights and best interests are safeguarded by the home’s policies and procedures. 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 are promoted and protected. Service users benefit from competent and accountable management of the service. The Commission considers Standards 37, 39, and 42 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for the following standard(s): 37, 38, 39, 41 & 42. This is an organised and well-managed service. The standard of record keeping and consultation with service users is good. There are good arrangements for health and safety which only needs minor attention to ensure safety of service users, staff and visitors. EVIDENCE: The manager is not yet registered as she has only been at the home for a few months. From discussion with the manager it was ascertained that she has had a lot of experience with this service user group. The Commission is currently processing her application for registration. She said that she receives good support from the senior management team and the providers all of whom visit the home regularly. The records of minutes of meetings for managers, senior staff and staff were seen. Staff who cannot attend the meetings are provided with a copy of the minutes. The manager said that staff are good at keeping themselves up to date with what is happening in the home. Ivy Cottage DS0000006269.V279661.R01.S.doc Version 5.1 Page 21 The records of accidental injury were found to be satisfactory. Records showed that portable appliances were tested annually. An examination of the fire safety records demonstrated that staff read and sign to say they have understood the home’s fire safety procedure. The record of fire alarm, emergency lighting and fire drills were up to date. Water safety records were found to be satisfactory. There are automatic air fresheners around the home. Unfortunately, one of these dispensed as the inspectors were stood nearby and one was accidentally squirted in the eye causing swelling and irritation. Due to this accidental injury their position needs to be reviewed to ensure safety. All records examined at the time of inspection were kept in a satisfactory manner. The results of quality questionnaires sent to staff regarding confidentiality issues were seen and for service users and their representatives, in regards to dignity. Both reports showed satisfactory results and recommendations for action by the manager and other staff were noted. Ivy Cottage DS0000006269.V279661.R01.S.doc Version 5.1 Page 22 SCORING OF OUTCOMES This page summarises the assessment of the extent to which the National Minimum Standards for Care Homes for Adults 18-65 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 X 2 X 3 X 4 X 5 3 INDIVIDUAL NEEDS AND CHOICES Standard No 6 7 8 9 10 Score CONCERNS AND COMPLAINTS Standard No Score 22 3 23 3 ENVIRONMENT Standard No Score 24 2 25 X 26 2 27 2 28 3 29 3 30 1 STAFFING Standard No Score 31 X 32 3 33 3 34 3 35 3 36 3 CONDUCT AND MANAGEMENT OF THE HOME Standard No 37 38 39 40 41 42 43 Score 3 3 3 3 3 LIFESTYLES Standard No Score 11 X 12 X 13 3 14 3 15 3 16 3 17 2 PERSONAL AND HEALTHCARE SUPPORT Standard No 18 19 20 21 Score X 3 1 X 3 3 3 X 3 2 X Ivy Cottage DS0000006269.V279661.R01.S.doc Version 5.1 Page 23 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 YA30 Regulation 13(3) Requirement The registered person must make suitable arrangements for the prevention of the spread of infection by the provision of liquid soap, disposable towels and foot operated disposal bins in all areas where residents are supported with their personal or intimate care. The storage of insulin must be reviewed. Timescale for action 28/02/06 2 YA20 13(2) 23/01/06 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 Refer to Standard YA17 YA24YA27 Good Practice Recommendations The record of menus needs to be dated. The curtains in the quiet room should be replaced. Some of the home, including some communal areas and bedrooms would benefit from being redecorated. The fan in the toilet should be repaired. Ivy Cottage DS0000006269.V279661.R01.S.doc Version 5.1 Page 24 The seal in the shower room should receive attention, as should the shower door. The floor in the second shower room should be levelled. Water pressure should be checked to ensure that toilet cisterns both fill and empty properly. It would be useful to carry out risk assessments on radiators and if identified, radiator covers should be fitted. Radiators should be checked to ensure that they are kept at a safe temperature. The position of the air freshener dispensers should be reviewed to ensure safety. 3 YA26 4 YA42 Ivy Cottage DS0000006269.V279661.R01.S.doc Version 5.1 Page 25 Commission for Social Care Inspection Brighouse Area Office Park View House Woodvale Office Park Woodvale Road Brighouse HD6 4AB 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 Ivy Cottage DS0000006269.V279661.R01.S.doc Version 5.1 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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