Inspection on 10/02/09 for Nethermoor House

This inspection was carried out on 10th February 2009.

CSCI found this care home to be providing an Adequate service.

The inspector found no outstanding requirements from the previous inspection report, but made 1 statutory requirements (actions the home must comply with) as a result of this inspection.

Other inspections for this house

Nethermoor House 07/02/08

Similar services:

Ravenhurst

Bank House

Inspirations

Ashcroft Hollow Nursing Home

Maple Lodge

Heathlands

Aston Court Nursing Home

Breme

Extracts from inspection reports are licensed from CQC, this page was updated on 19/06/2009.

Inspecting for better lives Key inspection report Care homes for older people Name: Address: Nethermoor House 131 Chaseley Road Etching Hill Rugeley Staffordshire WS15 2LQ     The quality rating for this care home is:   one star adequate service A quality rating is our assessment of how well a care home, agency or scheme is meeting the needs of the people who use it. We give a quality rating following a full assessment of the service. We call this a ‘key’ inspection. Lead inspector: Kathryn Marks     Date: 1 0 0 2 2 0 0 9 This is a report of an inspection where we looked at how well this care home is meeting the needs of people who use it. There is a summary of what we think this service does well, what they have improved on and, where it applies, what they need to do better. We use the national minimum standards to describe the outcomes that people should experience. National minimum standards are written by the Department of Health for each type of care service. After the summary there is more detail about our findings. The following table explains what you will see under each outcome area. Outcome area (for example Choice of home) These are the outcomes that people staying in care homes should experience. that people have said are important to them: They reflect the things This box tells you the outcomes that we will always inspect against when we do a key inspection. This box tells you any additional outcomes that we may inspect against when we do a key inspection. This is what people staying in this care home experience: Judgement: This box tells you our opinion of what we have looked at in this outcome area. We will say whether it is excellent, good, adequate or poor. Evidence: This box describes the information we used to come to our judgement. Copies of the National Minimum Standards – Care Homes for Older People can be found at www.dh.gov.uk or bought from The Stationery Office (TSO) PO Box 29, St Crispins, Duke Street, Norwich, NR3 1GN. Tel: 0870 600 5522. Online ordering from the Stationery Office is also available: www.tso.co.uk/bookshop 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 Our duty to regulate social care services is set out in the Care Standards Act 2000. Care Homes for Older People Page 2 of 29 Reader Information Document Purpose Author Audience Further copies from Copyright Inspection report CSCI General public 0870 240 7535 (telephone order line) Copyright © (2009) Commission for Social Care Inspection (CSCI). This publication may be reproduced in whole or in part, free of charge, in any format or medium provided that it is not used for commercial gain. This consent is subject to the material being reproduced accurately and on proviso that it is not used in a derogatory manner or misleading context. The material should be acknowledged as CSCI copyright, with the title and date of publication of the document specified. www.csci.org.uk Internet address Care Homes for Older People Page 3 of 29 Information about the care home Name of care home: Address: Nethermoor House 131 Chaseley Road Etching Hill Rugeley Staffordshire WS15 2LQ 01889584368 Telephone number: Fax number: Email address: Provider web address: Name of registered provider(s): Type of registration: Number of places registered: Conditions of registration: Category(ies) : Nethermoor House Care Ltd care home 19 Number of places (if applicable): Under 65 Over 65 6 19 dementia old age, not falling within any other category Additional conditions: 0 0 The maximum number of service users to be accommodated is 19. The registered person may provide personal care and accommodation for service users of both sexes whose primary care needs on admission tot the home are within the following categories: Old age not falling within any other category (OP) 19 Dementia over 65 years of age (DE)(E) 6 The two single rooms identified as being not fit for purpose, due to their small size, continu to be used only as long as the Service Users currently in occupation in these rooms remain there. Date of last inspection Brief description of the care home Nethermoor is located on the periphery of the town of Rugeley and the home overlooks part of Cannock Chase. Over the years the home has been extended to provide more resident accommodation. The original part of the home maintains a number of original features. The house is located within its own extensive grounds. There are no facilities in the Care Homes for Older People Page 4 of 29 Brief description of the care home immediate area that people using the service can walk to or use. The home is registered to offer accommodation to 19 older people, six of whom may have dementia. There is a large lounge adjoining the dining room, with another smaller quiet lounge, all on the ground floor. The communal areas are pleasant with a homely feel. There are single bedrooms on the ground floor, and a mixture of double and single upstairs. Some of the double rooms are being used as singles to allow more privacy for more people using the service. The first floor can be accessed via the shaft lift or stairs. Bathing and toilet facilities are located throughout the home. Nethermoor does not provide en-suite facilities. The parking space at the front of the home is laid to gravel. This is not easy for an older person to negotiate. The home has an extensive enclosed garden area at the rear with raised flowerbeds, with the remaining area being well-maintained lawns. Care Homes for Older People Page 5 of 29 Summary This is an overview of what we found during the inspection. The quality rating for this care home is: Our judgement for each outcome: one star adequate service Choice of home Health and personal care Daily life and social activities Complaints and protection Environment Staffing Management and administration peterchart Poor Adequate Good Excellent How we did our inspection: The Overall quality rating for this service is 1 Star. This means that the people using the service experience adequate quality outcomes. This unannounced Key Inspection was carried out by two inspectors on Tuesday 10th February 2009 from 9.30 am to 3.15 pm. During this unannounced Key Inspection, the Care Manager was on duty with three care staff, cook, and handyperson. The Annual Quality Assurance Assessment (AQAA), had been returned to us by the service. Completion of the AQAA is a legal requirement and it enables the service to Care Homes for Older People Page 6 of 29 undertake a self assessment, which focuses on how well outcomes are met for people using the service. It was completed to a good standard and gave detailed information about the services offered. The Care Manager also provided written information regarding staffing, staff training, menu and dietary provision that was observed to be in the home. On arrival at Nethermoor House people were sitting in lounges having just completed breakfast. The district nurse visited to see one person using the service. We talked to people who use the service in both lounges, the visiting district nurse and three relatives. All made positive comments about the service and staff. Information received in surveys could be summarised as follows: Six people told us they always received the care and support they needed. Four people told us staff are always available when they need them and two said usually are. Six people told us they always receive the medical support they need. Six people told us they knew how to make a complaint. People were assisted by relatives to complete survey questionnaires. The inspection included examining the files of three people using the service. A sample of the homes documentation systems and procedures were also reviewed. As part of this inspection we checked five requirements that had been made previously. Of these, four had been completely met. The remaining requirement related to staff being employed in the home without the required POVA First checks. We found that one member of staff had worked in the home without these checks for some time, since our last inspection. We considered taking enforcement action against the home but since the situation is now rectified and the checks in place we decided against it. The Manager was made fully aware of the seriousness of this situation. What the care home does well: What has improved since the last inspection? What they could do better: Provide an alarm/buzzer to the first floor fire doors to alert staff if a person comes through the fire doors to the staircase. Staff records be more organised to avoid having to search for information. Second signature be obtained when dealing with peoples finances to ensure system is safe. When short stay people are admitted to the service, the home must ensure that monitored dosage systems for the administration of medication have been put up by the pharmacist. The management must make sure that the required checks are carried out on prospective staff before they work in the home. This will ensure that people are always supported safely. Care Homes for Older People Page 8 of 29 If you want to know what action the person responsible for this care home is taking following this report, you can contact them using the details set out on page 4. The report of this inspection is available from our website www.csci.org.uk. You can get printed copies from enquiries@csci.gsi.gov.uk or by telephoning our order line –0870 240 7535. Care Homes for Older People Page 9 of 29 Details of our 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) Outstanding statutory requirements Requirements and recommendations from this inspection Care Homes for Older People Page 10 of 29 Choice of home These are the outcomes that people staying in care homes should experience. They reflect the things that people have said are important to them: People are confident that the care home can support them. This is because there is an accurate assessment of their needs that they, or people close to them, have been involved in. This tells the home all about them and the support they need. People who stay at the home only for intermediate care, have a clear assessment that includes a plan on what they hope for and want to achieve when they return home. People can decide whether the care home can meet their support and accommodation needs. This is because they, or people close to them, have been able to visit the home and have got full, clear, accurate and up to date information about the home. If they decide to stay in the home they know about their rights and responsibilities because there is an easy to understand contract or statement of terms and conditions between them and the care home that includes how much they will pay and what the home provides for the money. This is what people staying in this care home experience: Judgement: People using this service experience good quality outcomes in this area. We have made this judgement using a range of evidence, including a visit to this service. People who wish to move into Nethermoor House receive the information they require, and they are assessed so that they can be assured the home can meet their needs. Evidence: The AQAA told us that people are confident that the care home, can offer support to them within a comfortable and safe environment. The AQAA says that an individual assessment is carried out prior to admission, to assess the persons needs before offering a placement. We checked 3 peoples records and were able to confirm this. We observed a Service Users Guide in place that is provided to people using the service, the guide contained information about the home and fees charged. The guide also contained information about how the service would meet the special needs of people following assessment. Care Homes for Older People Page 11 of 29 Evidence: Two people we spoke to told us they had some information about the home before they lived there. One relative we spoke to confirmed this. Six people told us in surveys that they received enough information about the home before they moved in. Care Homes for Older People Page 12 of 29 Health and personal care These are the outcomes that people staying in care homes should experience. They reflect the things that people have said are important to them: People’s health, personal and social care needs are met. The home has a plan of care that the person, or someone close to them, has been involved in making. If they take medicine, they manage it themselves if they can. If they cannot manage their medicine, the care home supports them with it, in a safe way. People’s right to privacy is respected and the support they get from staff is given in a way that maintains their dignity. If people are approaching the end of their life, the care home will respect their choices and help them feel comfortable and secure. They, and people close to them, are reassured that their death will be handled with sensitivity, dignity and respect, and take account of their spiritual and cultural wishes. This is what people staying in this care home experience: Judgement: People using this service experience good quality outcomes in this area. We have made this judgement using a range of evidence, including a visit to this service. The home meets the personal, health and social needs of people using the service. Evidence: The Annual Quality Assurance Assessment we received prior to the inspection told us that people are registered with their own general practitioner. The home operates a policy on the receipt of medication, of the safe storing, handling, administration and disposal of medication. The service says that they encourage people to make their own decisions, and that all staff are trained to respect and maintain dignity, privacy, and quality of life of people using the service. We observed there to be individual plans of care for people using the service. We looked at care records for three people, and found them to be up to date. Care records contained admission details and assessment, daily records, day actions and night actions. They also had nutritional assessments, social work assessments, physical assessments, moving and handling assessments. Care Homes for Older People Page 13 of 29 Evidence: There are four people at the home with dementia, one person is currently being reassessed as the service feels they can no longer meet this persons needs. Some staff were signing up for dementia awareness training and starting induction. We spoke to a visiting health care professional who told us that she was satisfied that her instructions are carried out at the home, and that continence management is good. We were also told that staff contact health care professionals appropriately. Records indicate that there is good support for people and the home from general practitioners. Staff administering medication are trained to do so by the homes pharmacist on an annual basis. The manager of the home checks that staff are administering properly. A monitored dosage system is used for administering medication, this is given direct to the person and signed for as given. Medication Administration sheets were signed up to date. There are no controlled drugs in use at the time of this inspection visit. The medication is stored in a locked cupboard that is secured to the wall. When short stay people are admitted to the home the manager must check that medication has been put up by the pharmacist. We discussed medication with a member of staff who has been at the home for some time. This staff told us they felt well supported by the manager, If I want any training, I only have to ask the manager and she organises it for me, I am very happy here. Privacy and dignity of people generally was being promoted at the home. Staff however should be mindful of this when administering nose drops in the lounge, this is not appropriate. The service needs to look at staffing levels to ensure that people who may wish to bathe in the evening, are able to do so. In the surveys returned to us, six people using the service told us that they receive the care and support they need and that staff listen and act on what they say. Four people told us that staff are always available and two said usually. All six people completing surveys told us that they receive the medical support they need. Care Homes for Older People Page 14 of 29 Care Homes for Older People Page 15 of 29 Daily life and social activities These are the outcomes that people staying in care homes should experience. They reflect the things that people have said are important to them: Each person is treated as an individual and the care home is responsive to his or her race, culture, religion, age, disability, gender and sexual orientation. They are part of their local community. The care home supports people to follow personal interests and activities. People are able to keep in touch with family, friends and representatives. They are as independent as they can be, lead their chosen lifestyle and have the opportunity to make the most of their abilities. People have nutritious and attractive meals and snacks, at a time and place to suit them. There are no additional outcomes. This is what people staying in this care home experience: Judgement: People using this service experience good quality outcomes in this area. We have made this judgement using a range of evidence, including a visit to this service. The people using the service are given opportunities to make choices about their lifestyle. Evidence: The AQAA we received prior to the inspection told us that daily living is as flexible as possible. The service encourages people to become involved with the activities of daily life of running the home. For example contributing to the menu. The service recognises the importance of personal relationships and respects peoples privacy. Peoples relatives can visit at anytime and have a meal in the home if they wish. We observed from looking at peoples records and talking to individuals, that outings take place with relatives. Venues such as garden centres and relatives homes are visited. The notice board in the hallway displays information about activities, a visiting singer during our inspection and a Valentine party was organised for Valentine day. One Care Homes for Older People Page 16 of 29 Evidence: person remained in the small lounge, they told us they did not want to join in with the sing a long. There was a friendly relaxed atmosphere in the home, relatives were in and out of the home throughout this visit. The people we spoke to told us they were happy with the care received by their relative, one person said she felt safe leaving mum at the home. There is a refreshment trolley in the dining room for relatives to make a drink. We discussed diet and menu with the cook, she confirmed that quantity and quality of food is good. We saw lunch being prepared with a choice available. Food provided was, bacon, cheese and broccoli pie, omelette, cheese and potato pie, salad, soup. Dessert was a choice of fresh fruit, rice pudding, diabetic dessert. There is a choice at breakfast of a cooked breakfast or, cereals, juice and toast. Nutritional screening takes place, special diets are catered for. People told us after lunch that they had enjoyed their meal. Four people told us in surveys that they usually liked the food at the home, two people told us they always liked the food. Two people said there are always activities arranged, two said sometimes, and two said usually. Care Homes for Older People Page 17 of 29 Complaints and protection These are the outcomes that people staying in care homes should experience. They reflect the things that people have said are important to them: If people have concerns with their care, they or people close to them know how to complain. Any concern is looked into and action taken to put things right. The care home safeguards people from abuse and neglect and takes action to follow up any allegations. People’s legal rights are protected, including being able to vote in elections. This is what people staying in this care home experience: Judgement: People using this service experience adequate quality outcomes in this area. We have made this judgement using a range of evidence, including a visit to this service. People using the service and their relatives need to know that their complaints will be taken seriously, investigated properly and that the systems in the home are completely safe. Evidence: The AQAA we received prior to the inspection told us people understand that, if they make a complaint, they would be fully supported by staff. All complaints are recorded showing the complaint, how it was investigated, and the action taken. The AQAA told us people are treated as individuals, and that the home assumes they have the capacity to make all their own decisions unless proved otherwise. The home says that it operates a no tolerance of abuse. We saw the complaints procedure displayed in the hallway, and contained in the service users guide. Two people we asked told us they knew how to make a complaint, and identified the manager and staff as people they would talk to. There were no complaints recorded in the complaints book since the last inspection. However, we received a complaint which we asked the manager to investigate. The person making the complaint was not happy with the response and we agreed it lacked sensitivity and sufficient detail of the related accident. We asked the manager to respond again and provide the person making the complaint with more detail. Care Homes for Older People Page 18 of 29 Evidence: The six people who completed surveys told us they knew how to make a complaint. There is an abuse policy in place that is discussed with staff during induction and staff members we spoke to were aware of areas of abuse. However there is no formal training and the care manager was advised to contact Staffordshire Social Care Workforce Partnership (SSCWP) to arrange safeguarding training. The manager also needs to ensure that the recruitment procedures protect the people using the service at all times. Care Homes for Older People Page 19 of 29 Environment These are the outcomes that people staying in care homes should experience. They reflect the things that people have said are important to them: People stay in a safe and well-maintained home that is homely, clean, pleasant and hygienic. People stay in a home that has enough space and facilities for them to lead the life they choose and to meet their needs. The home makes sure they have the right specialist equipment that encourages and promotes their independence. Their room feels like their own, it is comfortable and they feel safe when they use it. This is what people staying in this care home experience: Judgement: People using this service experience adequate quality outcomes in this area. We have made this judgement using a range of evidence, including a visit to this service. The physical design and layout of the home, provides accommodation in a homely setting for people using the service. Evidence: The AQAA we received prior to the inspection told us the home provides a safe and secure environment. Communal space is available within the home for all people to access. The home has a large accessible garden. Staff have received mandatory fire training and the home complies with all regulations. The home is adapted within for those people with limited mobility, for example grab rails. Nethermoor House is set in its own grounds, and is reached via a long drive. There is parking to the front of the house and, the rear garden is enclosed to ensure the safety of people living at the home. The older part of the house has retained many original features. We observed the home to be warm, and people told us they were comfortable in their surroundings. Bedrooms we visited were clean and personalised. There are single bedrooms on the ground floor, and both single and double on the first floor. The first floor is accessed via a shaft lift or two staircases. Care Homes for Older People Page 20 of 29 Evidence: It will be a recommendation of this report that consideration be given to fitting a buzzer to the first floor fire doors. This will alert staff to people who come through fire doors to the staircase. The home currently has four people with dementia. The care manager is going to try signage on bathroom and toilet doors to assist them. The environment is well maintained and clean. Policies and procedures are in place for the control of infection. Staff have received infection control training, this is due to be updated this year. Environmental Health have visited the home, no issues have been identified. Care Homes for Older People Page 21 of 29 Staffing These are the outcomes that people staying in care homes should experience. They reflect the things that people have said are important to them: People have safe and appropriate support as there are enough competent staff on duty at all times. They have confidence in the staff at the home because checks have been done to make sure that they are suitable to care for them. Their needs are met and they are cared for by staff who get the relevant training and support from their managers. There are no additional outcomes. This is what people staying in this care home experience: Judgement: People using this service experience adequate quality outcomes in this area. We have made this judgement using a range of evidence, including a visit to this service. There is a caring staff team who support people using the service. Evidence: The AQAA we received prior to the inspection, told us the service operates an equal opportunities policy and recruits from all cultures and backgrounds. Staff are trained to respect peoples privacy and dignity, and they promote peoples independence. Staff go through an induction programme with ongoing, continuous training. The service have a high percentage of staff qualified to National Vocational Qualification level 2. Two staff are presently doing level 3. There were three care workers, the care manager, cook and handy person on duty on the morning of our unannounced inspection. The rota identified three staff on duty until 6pm, and two staff from 6pm to 9pm. The cook works 7.30 am to 2pm and a care worker does tea. There are two waking night staff. There are three people on call identified on a list in the hallway with telephone numbers to contact them. Staff training takes place, senior staff are trained in the administration of medication, the pharmacist checks medication. Care Homes for Older People Page 22 of 29 Evidence: The Environmental Health are to give a talk to staff on minimising risks and environmental issues. Three staff training records were reviewed and mandatory training is carried out. As previously identified in this report safeguarding training has been discussed. The care manager told us she is going to arrange formal safeguarding training for staff. Three staff files were reviewed, we found that one member of staff had worked in the home without the required POVA First check. We discussed this with the care manager and confirmed to her, that all staff must have a POVA 1st before commencing employment and whilst waiting for their CRB. This had already been a requirement of the last inspection and we considered taking enforcement action. Since the situation is now rectified and the appropriate check in place we decided against it, but made the manager fully aware of the seriousness. All staff have or are doing National Vocational Qualification. Two staff have completed level 3, and two staff are currently completing level 3. Staff were registering today to start dementia care training. Staff records were in various folders and envelopes, information had to be searched for. It would be beneficial to formalise staff files to make information and training records more easily accessible. We have received surveys from five members of staff, that gave us the following information. Five staff told us they are usually given up to date information about the needs of people they care for. One staff told us they always are. Five staff told us appropriate pre employment checks were carried out before they were employed. Five staff told us they received training relevant to their role. Two staff told us there are usually enough staff on duty. One staff said sometimes. Care Homes for Older People Page 23 of 29 Management and administration These are the outcomes that people staying in care homes should experience. They reflect the things that people have said are important to them: People have confidence in the care home because it is led and managed appropriately. People control their own money and choose how they spend it. If they or someone close to them cannot manage their money, it is managed by the care home in their best interests. The environment is safe for people and staff because appropriate health and safety practices are carried out. People get the right support from the care home because the manager runs it appropriately with an open approach that makes them feel valued and respected. The people staying at the home are safeguarded because it follows clear financial and accounting procedures, keeps records appropriately and ensures their staff understand the way things should be done. They get the right care because the staff are supervised and supported by their managers. This is what people staying in this care home experience: Judgement: People using this service experience adequate quality outcomes in this area. We have made this judgement using a range of evidence, including a visit to this service. Management systems do not fully protect the people using the service. Evidence: The AQAA we received prior to the inspection told us that the Registered Manager has seventeen and half years experience. All staff receive induction training, ongoing supervision, and annual appraisals. Any changes implemented, are assessed and monitored at regular intervals. People and their relatives, are made aware that they can access their care records if they choose to do so. The Care Manager has National Vocational Qualification level 4 in care and management and has received training in dementia care, first aid, all mandatory training, and continues to take part in training to update her skills. We discussed the above with the Care Manager, who confirmed her experience and qualifications. Care Homes for Older People Page 24 of 29 Evidence: The Care Manager told us she runs the home in the best interest of people using the service, that she tries to look at the overall picture. We found, as identified previously, that the management of a serious complaint left the people concerned unreassured. An accident had occurred by which a person coming through a fire door had been found at the bottom of two stairs. We believe following discussion with the manager that this was an unfortunate accident, however the manager should have evaluated the risk and taken action to make sure this could not happen again. We have recommended that an alarm be fitted to the upstairs fire doors and suggest that the manager may wish to consult with the fire safety officer. Monies kept at the home for people has been left mainly by relatives, for hairdressing and chiropody. To ensure the safeguarding of peoples finances, it is recommended that two signatures be obtained when receiving or paying out monies. All finances that we checked, cash balanced with records kept. Staff told us that they felt supported by the manager and we observed her supervision of them. There is lots of health and safety information posted around the home. Staff spoken to including the cook were aware of health and safety and hazardous substances are locked in cupboards or stored in the cellar. Care Homes for Older People Page 25 of 29 Are there any outstanding requirements from the last inspection? Yes £ No R Outstanding statutory requirements These are requirements that were set at the previous inspection, but have still not been met. They say what the registered person had to do to meet the Care Standards Act 2000, Care Homes Regulations 2001 and the National Minimum Standards. No. Standard Regulation Requirement Timescale for action Care Homes for Older People Page 26 of 29 Requirements and recommendations from this inspection: Immediate requirements: These are immediate requirements that were set on the day we visited this care home. The registered person had to meet these within 48 hours. No. Standard Regulation Requirement Timescale for action Statutory requirements These requirements set out what the registered person must do to meet the Care Standards Act 2000, Care Homes Regulations 2001 and the National Minimum Standards. The registered person(s) must do this within the timescales we have set. No. Standard Regulation Requirement Timescale for action 1 38 13 Risks to the Health and Safety of people using the service must be evaluated and identified and action taken to eliminate them as far as possible A system should be in place to ensure the safety of people using the stairs 01/04/2009 Recommendations These recommendations are taken from the best practice described in the National Minimum Standards and the registered person(s) should consider them as a way of improving their service. No. Refer to Standard Good Practice Recommendations 1 2 18 19 As discussed with us at inspection the Care Manager accesses safeguarding training to update staff. Consideration be given to fitting an alarm to the fire doors on the first floor, to alert staff when a person comes through the fire door to the stairs. Signage be fitted to bathroom and toilet doors to assist people with dementia. Staff records would benefit from being condensed into one file, to make information and training records more accessible. 3 4 19 27 Care Homes for Older People Page 27 of 29 5 35 Two signatures be obtained when paying out or receiving peoples monies. Care Homes for Older People Page 28 of 29 Helpline: Telephone: 0845 015 0120 or 0191 233 3323 Textphone: 0845 015 2255 or 0191 233 3588 Email: enquiries@csci.gsi.gov.uk Web: www.csci.org.uk We want people to be able to access this information. If you would like a summary in a different format or language please contact our helpline or go to our website. Copyright © (2009) Commission for Social Care Inspection (CSCI). This publication may be reproduced in whole or in part, free of charge, in any format or medium provided that it is not used for commercial gain. This consent is subject to the material being reproduced accurately and on proviso that it is not used in a derogatory manner or misleading context. 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