Inspection on 04/08/05 for Jordan Lodge

This inspection was carried out on 4th August 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

Jordan Lodge 08/11/07

Jordan Lodge 11/09/06

Jordan Lodge 08/12/05

Jordan Lodge 27/01/05

Jordan Lodge 15/07/04

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

CARE HOME ADULTS 18-65 Jordan Lodge 5 Warham Road South Croydon Surrey CR2 6LE Lead Inspector Margaret Lynes Unannounced 04 August 2005, 10.00 The Commission for Social Care Inspection aims to: • • • • Put the people who use social care first Improve services and stamp out bad practice Be an expert voice on social care Practise what we preach in our own organisation Reader Information Document Purpose Author Audience Further copies from Copyright Inspection Report CSCI General Public 0870 240 7535 (telephone order line) This report is copyright Commission for Social Care Inspection (CSCI) and may only be used in its entirety. Extracts may not be used or reproduced without the express permission of CSCI www.csci.org.uk Internet address This is a report of an inspection to assess whether services are meeting the needs of people who use them. The legal basis for conducting inspections is the Care Standards Act 2000 and the relevant National Minimum Standards for this establishment are those for Care Homes for Adults 18-65. They can be found at www.dh.gov.uk or obtained from The Stationary 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. Jordan Lodge G53 G53 S25803 jordanlodge V192361 040805 stage 4.doc Version 1.40 Page 3 SERVICE INFORMATION Name of service Jordan Lodge Address 5 Warham Road, South Croydon, Surrey, CR2 6LE 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) 020 8686 8801 Laurel Residential Homes Limited Mr Jeremy R Burrows Care Home 14 Category(ies) of Mental disorder(14) registration, with number of places Jordan Lodge G53 G53 S25803 jordanlodge V192361 040805 stage 4.doc Version 1.40 Page 4 SERVICE INFORMATION Conditions of registration: Date of last inspection 27/1/05 Brief Description of the Service: Jordan Lodge is a large detached building in South Croydon, well situated for access to the centre of Croydon and its many community based facilities, and good transport links. The property comprises of 2 day rooms (lounge and dining area) on the ground floor, and a small coffee/smoking room on the first. There are 14 single bedrooms, all fitted with hand basins but no other en-suite facilities. There are 3 WC’s, 3 bathrooms and 1 shower. Off-street parking is provided to the front of the house, while there is a large, pleasant garden at the rear. The stated aim of the home is to provide care for people with longterm mental health problems. Jordan Lodge G53 G53 S25803 jordanlodge V192361 040805 stage 4.doc Version 1.40 Page 5 SUMMARY This is an overview of what the inspector found during the inspection. This inspection was unannounced, and was conducted over one day. During that time a number of records were examined, a tour was made of the communal areas of the home, and time was spent talking with service users and staff. The last inspection report contained 15 requirements. Only five of these have now been met. This is disappointing. This visit resulted in a further nine requirements being made. All steps must be taken to ensure that these requirements are dealt with promptly, as in doing so the home will improve the overall quality of the service being provided, and improve the well-being of the service users. What the service does well: What has improved since the last inspection? What they could do better: Clearly, with ten unmet requirements from previous inspections, and an additional nine new requirements being made, there is room for improvement in the home. One of the most noticeable things about this visit was the lack of organised activities for service users. When asked, most said that they had no plans for the day, other than just sitting watching TV, or sitting in the garden. Although goals had been identified in the service user plans, and staff were aware of them, it appeared that staffing resources meant that they were unable to engage with the service users to assist them to meet these goals. Given that this is a home for younger adults, it was surprising to find so little emphasis on developing service user skills. Jordan Lodge G53 G53 S25803 jordanlodge V192361 040805 stage 4.doc Version 1.40 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. Jordan Lodge G53 G53 S25803 jordanlodge V192361 040805 stage 4.doc Version 1.40 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 Standards Statutory Requirements Identified During the Inspection Jordan Lodge G53 G53 S25803 jordanlodge V192361 040805 stage 4.doc Version 1.40 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 standard(s) 1 and 2 The home has met the previously made requirements regarding the Service User Guide and the Statement of Purpose, which means that prospective service users now have the information that they need to make an informed decision about where to live. Care should be taken however, to ensure that the revised documents are readily available and that staff are familiar with them. The Inspector was not satisfied that adequate assessments were being made of prospective service users. This means that service users cannot be assured that the home has taken into account their individual needs, and that it can meet them; and that the staff in the home will not be as familiar as they could be with new service users, or have a full understanding of what specific service they will need to provide. EVIDENCE: Prior to this inspection a copy of the revised Statement of Purpose and Service User Guide were sent to the local CSCI office. They now contain all of the information required in the Regulations. The files of the two newest service users were examined. One contained a needs assessment from the placing authority, along with a poorly completed in-house assessment. The other file did not contain a pre-admission assessment. Without this information it is difficult to see how the home can be certain that the referral is suitable for it, and they suitable for the service user. Jordan Lodge G53 G53 S25803 jordanlodge V192361 040805 stage 4.doc Version 1.40 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 standard(s) 6, 7 and 9 It was not felt that the care plans adequately reflected how assessed needs and goals were to be met, or if they had been met. This means that it is difficult for the staff team to determine if progress is being made, and the feedback for service users may not be as positive as it could be. The service users spoken with all felt that they were enabled to make decisions about their lives, with as much input from staff as necessary. The Inspector could not be satisfied that all risks to service users had been fully assessed, or that the service users were being supported to take risks as part of an independent lifestyle. EVIDENCE: At the previous inspection a requirement was made regarding the need for more comprehensive documentation regarding how identified needs were being met. This visit indicated that recording in this area still needed to be improved. There was little to evidence what staff were doing to help the service users achieve their goals. This was discussed with various members of the staff team, who indicated that either they did follow a plan of care, but did not document their efforts, or, more worryingly, that they were not following a Jordan Lodge G53 G53 S25803 jordanlodge V192361 040805 stage 4.doc Version 1.40 Page 10 plan of care. The reason for this seemed simply to be due to resources – predominantly staff time. This will be given further consideration in Standard 33. There were no risk assessments in the files examined. It is important that each service user has a clear risk assessment, both for their protection and the protection of other residents, staff and the community at large. Jordan Lodge G53 G53 S25803 jordanlodge V192361 040805 stage 4.doc Version 1.40 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 standard(s) 12, 13, 15, 17 and 17 From discussion with service users and staff, and also from observation, the Inspector was not satisfied that service users were being given sufficient opportunity to participate in the local community or engage in appropriate activities. This means that they are not being provided with sufficient stimulation, which in turn may affect their overall well-being and their enjoyment of day to day life in the home. The level of contact with family and friends varies considerably. Many of the service users have little or no contact with friends/family or associates outside of the home. Nevertheless, contact with family and friends is supported and encouraged. The service users are offered a healthy diet, and all said that they enjoyed their meals albeit the quality of the cooking varied considerably, and they would like to be better consulted re the menu. EVIDENCE: The Inspector accepts that the time spent carrying out the Inspection was no more than 5 hours however during that period little was seen in the way of Jordan Lodge G53 G53 S25803 jordanlodge V192361 040805 stage 4.doc Version 1.40 Page 12 staff engaging the service users in activities or referring to their care plans to look at what identified goals were and taking steps to achieve them. The residents simply appeared to wander around the home with little to stimulate them apart from the television. It is appreciated that it can be difficult, with this client group, to get them to engage in an activity of any length, nevertheless the attempts must be made. To be fair to the staff team, it has to be said that there was not a lack of willingness to engage with service users, but rather a lack of time. At the time of this visit, there were no relative available to talk with however some of the service users discussed friends and family. Clearly they were encouraged to maintain these links. The home does not employ a cook and this has been a topic of debate for some time. At the previous inspection it was required that if the care staff were also expected to undertake catering duties, then the number of care staff on duty must be increased accordingly. From the rota provided this does not appear to be happening on a consistent basis. There is the added issue that staff are not particularly happy to also do the catering, and this must be taken into consideration. The service users commented that the quality of the meal varied depending on who was cooking. Again, this is an issue that must be considered, as residents should always be provided with good quality food. Jordan Lodge G53 G53 S25803 jordanlodge V192361 040805 stage 4.doc Version 1.40 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 standard(s) 18, 19 and 20 Service users commented that they felt that they received personal care and support in the manner that they wished. Staff ensure that each resident is able to access community based health facilities as and when required. The medication administration records were examined. Unfortunately a number of errors were noted. Clearly this is unacceptable, as any mistakes made in giving out medication can have serious consequences for the service users. EVIDENCE: The service users spoken with stated that they felt that they were well looked after, and were given the opportunity to be involved in their care and make decisions, including how they received personal support, for themselves. To the extent that community based health services are available for this client group, staff do all they can to enable the residents to access it. While inspecting some of the paperwork in the office it was noted that a pot with medication in it had been left on the desk top. This was not put safely away for quite some time. Additionally, gaps were found on some of the medication records, Tippex had been used, and one prescription had not been Jordan Lodge G53 G53 S25803 jordanlodge V192361 040805 stage 4.doc Version 1.40 Page 14 followed as written. These errors were brought to the attention of the senior member of staff on duty. Jordan Lodge G53 G53 S25803 jordanlodge V192361 040805 stage 4.doc Version 1.40 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 standard(s) 22 and 23 It was not possible to determine if the home had satisfactory procedures re complaints and adult protection, as the relevant procedures were not found in the main policy/procedure manual. There was a need for staff to attend training in adult protection. A lack of such training means that service users will not be as well protected from abuse as they might be. EVIDENCE: One complaint had been made since the last inspection visit. The service user who made the complaint stated that they were happy that it had been appropriately dealt with. At the time of this visit, the complaints log did not contain details of written complaints. It will be recommended that the log be amended so that it shows all complaints. There were no adult protection issues at the time of this visit; nevertheless it is important that all staff receive training in the prevention of abuse. It was surprising to find that the staff policy and procedure handbook did not contain either a complaints procedure or a procedure re adult protection. It may be that they had been removed for revision, however if this was the case it would have been helpful for staff if this had been indicated in the manual. Jordan Lodge G53 G53 S25803 jordanlodge V192361 040805 stage 4.doc Version 1.40 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 standard(s) 24, 26, 27 and 30 A tour was made of the areas of the home that had been previously identified as needing attention. A number of the requirements made have yet to be actioned. Once they have been, the home will fully meet the need to provide a safe and well-maintained environment. EVIDENCE: Three requirements that were made at the last inspection have yet to be met. These relate to the need to replace the flooring in the first floor bathroom, the first floor hallway and to ensure that the bath hot water temperature is of a satisfactory temperature. The hot water temperature in three bathrooms was measured, and was found to vary between 20°C and 36°C. Several new issues were identified – the need to install a cover for the fluorescent lighting on the first floor landing and the need to replace the carpet in the lounge/dining area. It will also be recommended that new sofas are purchased and that some garden furniture is provided. Jordan Lodge G53 G53 S25803 jordanlodge V192361 040805 stage 4.doc Version 1.40 Page 17 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 35 the key standard to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for standard(s) 33 and 35 The Inspector was not satisfied that the staffing levels were always adequate, which means that service users needs cannot always be met, and they will not always be provided with the support that they need. While a number of training courses have been made available to staff during the past year, the lack of training in adult protection issues means that there is the possibility that service users individual and joint needs may not always be met. EVIDENCE: At the time of the last inspection it was required that staffing levels be increased if staff were to be expected to cover the catering duties. The rota provided on this visit evidenced that this requirement was not being met with any consistency. On a number of shifts there were only two staff on duty. With one spending a notable amount of time in the kitchen preparing the main meal of the day, it meant that there was only one member of staff to support the service users. This impacts upon the quality of care that staff are able to give. The Inspector felt that the staff team were more than willing to engage in much more depth with the residents, but were often prevented from doing so because there were simply not enough of them to assist service users to carry out some of the goals identified on their plans. Jordan Lodge G53 G53 S25803 jordanlodge V192361 040805 stage 4.doc Version 1.40 Page 18 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 39, and 42 the key standards to be inspected at least once during a 12 month period. JUDGEMENT – we looked at outcomes for standard(s) 39, 40, 41 and 42 The Inspector was not fully satisfied that the home was being run in the best interests of the service users as the quality assurance system had not yet been implemented, albeit it was now in place. The home’s policies and procedures were regularly updated however neither the procedure relating to complaints or the adult protection procedure could be found. Furthermore, due to errors in the medication records and the absence of a visitor’s book it was not felt that the welfare of the service users was being promoted as well as it could be. Continuing gaps in the weekly testing of fire alarms and a number of other issues regarding health and safety indicated that the home was not being maintained to an appropriate level of safety, thus putting service users at risk. Jordan Lodge G53 G53 S25803 jordanlodge V192361 040805 stage 4.doc Version 1.40 Page 19 EVIDENCE: The home has now put in place a quality assurance system, which, when fully operational, will enable the management to identify any areas where the service is sub-standard and then, hopefully, take action to improve it. Ultimately this will mean that the home is run in the best interests of the service users as the process will include regular consultation, regarding quality, with the service users. The main policy and procedure manual did not contain either a complaints procedure or a procedure re adult protection. This, coupled with the inaccurate/absent records means that Standards 40 and 41 could not be said to be have been met. Following the last inspection it was required that the fire alarms be tested on a weekly basis. It was disappointing on this visit to find that this was still not being done. Additional concerns were found with unlabelled, open food in the fridge, a lack of daily fridge/freezer temperature readings, a condemned fire extinguisher still on its bracket in the hallway, and the need to ensure that windows above ground floor level had appropriate restrictors fitted. This latter issue was raised at the last inspection and, although steps were taken to meet it, the problem has reoccurred. A file had been put together which conveniently contained the relevant maintenance documents for the home. The gas safety certificate and evidence that the water tank had been treated re Legionnaires Disease could not be found however. The home had been recently visited by the Environmental Health Department – the manager must ensure that the home complies with the requirements/recommendations that arose from that visit. Jordan Lodge G53 G53 S25803 jordanlodge V192361 040805 stage 4.doc Version 1.40 Page 20 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 CONCERNS AND COMPLAINTS Standard No 1 2 3 4 5 Score 3 2 x x x Standard No 22 23 ENVIRONMENT Score 2 2 INDIVIDUAL NEEDS AND CHOICES Standard No 6 7 8 9 10 LIFESTYLES Score 2 3 x 2 x Score Standard No 24 25 26 27 28 29 30 STAFFING Score 2 x 3 2 x x x Standard No 11 12 13 14 15 16 17 x 2 2 2 3 x 3 Standard No 31 32 33 34 35 36 Score x x 1 x 2 x CONDUCT AND MANAGEMENT OF THE HOME PERSONAL AND HEALTHCARE SUPPORT Standard No 18 19 20 21 Jordan Lodge Score 3 3 1 x Standard No 37 38 39 40 41 42 43 Score x x 2 2 2 1 x G53 G53 S25803 jordanlodge V192361 040805 stage 4.doc Version 1.40 Page 21 yes Are there any outstanding requirements from the last inspection? STATUTORY REQUIREMENTS This section sets out the actions which must be taken so that the registered person/s meets the Care Standards Act 2000, Care Homes Regulations 2001 and the National Minimum Standards. The Registered Provider(s) must comply with the given timescales. No. 1. Standard 2 Regulation 14 Requirement All new service users must undergo a pre-admission assessment before becoming resident in the home. The staff team needs to better evidence how the services being provided are meeting the assessed needs and goals of the service users (as identified in the service user plans). The previously set timescale has not been met. Risk assessments must be carried out for all service users. These should be documented and regularly reviewed. The manager must ensure that service users are able to engage in appropriate activities and community based pursuits with support from staff as required. The manager must ensure that the medication administration records are accurately maintained at all times. The staff team must undergo training in the protection of vulnerable adults. The flooring on the first floor hallway is heavily marked and should be replaced. The G53 G53 S25803 jordanlodge V192361 040805 stage 4.doc Timescale for action 4/8/05 2. 6 12 30/9/05 3. 9 13 30/9/05 4. 12, 13, 14 16 30/9/05 5. 20 13 4/8/05 6. 7. 23, 35 24 13 23 30/10/05 30/9/05 Jordan Lodge Version 1.40 Page 22 8. 9. 24 24 23 23 10. 27 23 11. 33 18 12. 38 23 13. 39 24 14. 22, 23, 40 18 15. 41 17, 26 16. 42 13 previously set timescale has not been met. A diffuser must be fitted to the fluorescent light on the first floor landing. The floor covering on the first floor WC/ bathroom requires replacement. The previously set timescale has not been met. It was again evidenced that the bath hot water temperature was unacceptable. On this visit it was found to vary between 20°C and 36°C. The previously set timescale has not been met. The rota provided indicated that the home was not consistently ensuring that there were enough staff on duty to cover catering duties. The previously set timescale has not been met. The manager must ensure that all fire extinguishers are replaced if they fail to meet the approved standard. An appropriate quality assurance system must be implemented in the home, which seeks service users views and measures the success of the home in meeting the aims and objectives laid out in the Statement of Purpose. A system has been devised but has yet to be implemented. The previously set timescale has not been met. The home must ensure that it has in place all of the required policies and procedures. The previously set timescale has not been met. The home must ensure that all of the required records are maintained. The previously set timescale has not been met. The manager must ensure that window restrictors are fitted where necessary. This was 30/9/05 30/9/05 4/9/05 4/8/05 31/8/05 30/9/05 30/9/05 30/9/05 30/9/05 Jordan Lodge G53 G53 S25803 jordanlodge V192361 040805 stage 4.doc Version 1.40 Page 23 17. 18. 42 42 23 13, 23 19. 42 16 previously required and although met the same issue has reoccurred. Fire alarms must be tested on a weekly basis. The previously set timescale has not been met. The home must be able to evidence that all necessary maintenance checks have been carried out in a timely fashion. Staff must ensure that fridge/ freezer temperatures are checked and recorded daily. 4/8/05 30/9/05 4/8/05 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. 4. 5. 6. Refer to Standard 1 17 23 24 24 42 Good Practice Recommendations The manager should ensure that the most up to date version of the homes Statement of Purpose and Service User Guide are freely available. Service users should be enabled to become more involved in the planning of menus. It would be good practice to ensure that the complaints log contained details of all complaints, regardless of how they are made. It would improve the premises if new sofas were provided. The garden area would be enhanced by the provision of garden furniture, including sun shades. It would be good practice if staff could access the health and safety risk assessments for the home. Jordan Lodge G53 G53 S25803 jordanlodge V192361 040805 stage 4.doc Version 1.40 Page 24 Commission for Social Care Inspection 8th Floor, Grosvenor House 125 High Street Croydon CR0 9XP 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. 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