Top Banner
SECURITY BADGE HANDBOOK
26

SECURITY BADGE HANDBOOK. Table of Contents Your Role Working at Charlotte Douglas International Airport (CLT)3 Important Information About Violations,

Jan 20, 2016

Download

Documents

Job Harper
Welcome message from author
This document is posted to help you gain knowledge. Please leave a comment to let me know what you think about it! Share it to your friends and learn new things together.
Transcript
Page 1: SECURITY BADGE HANDBOOK. Table of Contents Your Role Working at Charlotte Douglas International Airport (CLT)3 Important Information About Violations,

SECURITY BADGE HANDBOOK

Page 2: SECURITY BADGE HANDBOOK. Table of Contents Your Role Working at Charlotte Douglas International Airport (CLT)3 Important Information About Violations,

Table of Contents•Your Role Working at Charlotte Douglas International Airport (CLT) 3•Important Information About Violations, Procedures and Penalties 4•Must Know Penalties 5•Piggybacking 6•Failure To Follow Stop And Wait Procedures 7•Leaving Security Door Unattended 8•Bypassing Access Control Measures 9•Failure to Properly Re-set an Alarm 10•Display Or Use Of An Invalid ID Badge 11•Violation of Authorized Signer Privileges 12•Violation Of Airport Escort Procedures 13•Leaving Prohibited Items Unattended in Secured Area 14•General Negligence with SIDA Badge 15•Failure To Display Proper ID 16•Challenging (Failure To Challenge Or Respond) 17•Refusal to Comply with Direction of a security officer, LEO, or TSA Personnel 18•Improper Signs On Vehicles 19•Loaning/Borrowing An ID Badge 20•Abuse Of Security Keys 20•Duplication/Reproduction Of CLT ID Media 20•Using Secured Doors for Bypassing Screening 20•How Do I Escort Individuals 21•How Do I Challenge 22•Loss of CLT ID Media 23•Appendix / Resources 24-25•Glossary Of Terms/Important Phone Numbers 26 2

Page 3: SECURITY BADGE HANDBOOK. Table of Contents Your Role Working at Charlotte Douglas International Airport (CLT)3 Important Information About Violations,

3

Working at CLT

As an employee of the airport community, you play an important role in assisting us with ensuring an environment that is safe and secure. CLT closely with the Transportation Security Administration (TSA) to implement and enforce security regulations.

It is IMPORTANT that you take the time to become familiar with the following security violations and the penalties associated with each. As a badge-holder at CLT, you will be held accountable for violations of security procedures and regulations. If you are unclear on a particular violation, please ask your SIDA trainer or your supervisor for clarification.

As a community working together to serve the customers at CLT, we depend on each other to be diligent in our jobs, be aware of our surroundings, and to report suspicious activity in our working environment.

Airport Operations thanks you in advance for your support of our efforts to ensure a safe and secure environment for all, employees and travelers alike.

Page 4: SECURITY BADGE HANDBOOK. Table of Contents Your Role Working at Charlotte Douglas International Airport (CLT)3 Important Information About Violations,

4

Important Information about Security ViolationsA combination of any three (3) or more security violations within two (2) years may result in permanent revocation of the offender’s ID badge. If the offender does not commit another offense within two (2) years, a future offense will be treated according to the rules as a first offense.

Security ViolationProcedures/Penalties

Violations of the following Airport Rules and Regulations may be cause for penalties. Upon receiving a written citation, offender has three days to appeal the citation in writing to the Airport Security Coordinator (ASC). The appeal will be reviewed by the ASC, and an appropriate suspension may be levied. A violation deemed severe by the ASC or designee is cause for permanent revocation of the offender’s ID badge. A citation and a letter from the ASC to the offender with a copy to the offender’s employer applies to all offenses. At any given time the penalties may be increased, or decreased depending on extenuating circumstances.

In all circumstances, CLT reserves the right to penalize companies conducting business at CLT for security infractions (example: knowingly encouraging employees to commit violations; not being responsible by not supporting the ViolationProgram) Penalties may be assessed and determined based on consultation and coordination with TSA.

Civil Penalties Assessed By The TSAPenalties assessed by the TSA for infractions/violations of applicable TSA regulations and/or the Airport Security Plan may be passed on to the airline/tenant involved.

Page 5: SECURITY BADGE HANDBOOK. Table of Contents Your Role Working at Charlotte Douglas International Airport (CLT)3 Important Information About Violations,

5

Pay attention to the following PENALTIES identified in this booklet—they can have a major impact on your employment at CLT

1) Loaning/Borrowing an ID Badge: Permanent revocation of your ID badge on 1st offense.

2) Abuse of Security Key Privilege (loaning/borrowing keys to/from others): Permanent revocation of your ID badge on 1st offense.

3) Duplication/Reproduction of CLT Media: Permanent revocation of ID badge on 1st offense.

4) Using Secured Doors to Bypass Screening: Permanent revocation of ID badge on 1st offense.

5) Leaving a Security Door Unattended: Permanent revocation of ID badge on 3rd offense.

6) Piggybacking: Permanent revocation of ID badge on 3rd offense.

7) Violation of Escort Procedures: Permanent revocation of ID badge on 3rd offense.

8) Bypassing Access Control Measures: Permanent revocation of ID badge on 3rd offense.

9) Display or Use of an Invalid ID Badge (lost, stolen, deactivated, expired): Permanent revocation of your ID badge on 3rd offense.

Penalties that will impact your employment

Page 6: SECURITY BADGE HANDBOOK. Table of Contents Your Role Working at Charlotte Douglas International Airport (CLT)3 Important Information About Violations,

6

Offense: Piggybacking occurs when someone follows through an access point without using one’s own ID badge or security key except when under escort.

If a person knowingly allows someone through an access point without the other person using their own ID badge/security key, both persons will be cited for piggybacking.

If a person follows someone through an access point without using one’s own ID badge or security key and without the other person’s knowledge, the individual following is cited for piggybacking and the other person is cited for failure to follow stop and wait procedures.

Example: You are running late for work. You must get to the job site on time because you have been warned by your supervisor not to be late again. As you rush towards the secured door, an individual has swiped and cleared entry to the area, you run towards the door to grab it before it closes. You made it to work on time, but have now incurred an infraction against your record. The 3rd offense permanently revokes you ID badge.

The individual who opened the door will be cited for failure to follow the stop and wait procedures and you will be cited for piggybacking.

First Offense: Confiscation of ID badge for 3 days. Retake SIDA training. Badge reactivation fee $25.-Second Offense: Confiscation of ID badge for 7 days. Retake SIDA training with manager/supervisor. Badge reactivation fee $50.-Third Offense: Permanent revocation of ID badge.

Piggybacking

Page 7: SECURITY BADGE HANDBOOK. Table of Contents Your Role Working at Charlotte Douglas International Airport (CLT)3 Important Information About Violations,

7

Offense: Failing to ensure a door or gate has completely secured behind or allowing unauthorized access.

First Offense: Confiscation of ID badge for 3 days. Retake SIDA training. Badge reactivation fee $25.-Second Offense: Confiscation of ID badge for 7 days. Retake SIDA training with manager/supervisor. Badge reactivation fee $50.-Third Offense: Permanent revocation of ID badge.

Failure to Follow Stop and Wait Procedures at Vehicles Gates, Pedestrian Gates, or Secured Doors

Example: You need to access the airfield via vehicle gate. You swipe your badge and the vehicle gate opens to allow you access.

You proceed through the gate and continue driving to your job site.STOP! Someone is following through the open gate behind you. Have they swiped a badge?—Do they have access? Are they AUTHORIZED?

You are responsible to ensure the vehicle/persons entering behind you do not do so.

Once you have entered the secured side, STOP, WAIT, then proceed.

Page 8: SECURITY BADGE HANDBOOK. Table of Contents Your Role Working at Charlotte Douglas International Airport (CLT)3 Important Information About Violations,

8

Offense: Leaving area, where there is an unsecured access point, unattended.

Example: You report to work and are assigned to jetway door E11. You are the gate agent responsible for boarding passenger for the next flight out. You placed the door into timed override by swiping your badge and propping the door open. You need to leave the area for just a few minutes. Is this what you should do? No you should remain at the door or secure it.

First Offense: Confiscation of ID badge for 3 days. Retake SIDA training. Badge reactivation fee $25.-Second Offense: Confiscation of ID badge for 7 days. Retake SIDA training with manager/supervisor. Badge reactivation fee $50.-Third Offense: Permanent revocation of ID badge.

Leaving a Security Access Point Unattended

Page 9: SECURITY BADGE HANDBOOK. Table of Contents Your Role Working at Charlotte Douglas International Airport (CLT)3 Important Information About Violations,

9

Offense: Pushing a secured door or gate open without proper access permissions and/or without utilization of authorized ID badge or security key and/or failure to immediately notify Airport Operations of the incident. Pushing a secured door or gate open instead of using an ID badge or security key.

Example: You have come into the concourse from the ramp to get something to eat. You only have a few minutes to get back to work and you need to hurry. You remember that there is a stair tower that is closer to you that you could use, but you don’t have an intellikey to open the door. You think you will just hit the panic bar to open the door. WRONG! If you do not have access through use of a security key or ID Badge, DO NOT ENTER!

First Offense: Confiscation of ID badge for 3 days. Retake SIDA training. Badge reactivation fee $25.-Second Offense: Confiscation of ID badge for 7 days. Retake SIDA training with manager/supervisor. Badge reactivation fee $50.-Third Offense: Permanent revocation of ID badge.

Bypassing Access Control Measures

Page 10: SECURITY BADGE HANDBOOK. Table of Contents Your Role Working at Charlotte Douglas International Airport (CLT)3 Important Information About Violations,

Offense: Failure to check the ramp and secured areas for intruders when resetting a door alarm.

Example: When resetting an alarm, you are required to make sure that nobody unauthorized entered the secured areas. When you silence the alarm, inspect the ramp, stair towers and other areas for intruders.Call Airport Operations at 704-359-4012 with your findings are resolution of the alarm.

First Offense: Confiscation of ID badge for 3 days. Retake SIDA training. Badge reactivation fee $25.-Second Offense: Confiscation of ID badge for 7 days. Retake SIDA training with manager/supervisor. Badge reactivation fee $50.-Third Offense: Permanent revocation of ID badge.

Failure to Properly Re-set an Alarm

10

Page 11: SECURITY BADGE HANDBOOK. Table of Contents Your Role Working at Charlotte Douglas International Airport (CLT)3 Important Information About Violations,

11

Offense: Displaying and/or using an ID badge that has been reported lost or stolen, has been deactivated, or has expired.

Example: You report to work and swipe your ID badge at Door 9 and it does not work. You try it a second time and a third and the reader does not validate your entry. You have to get to work and are very frustrated.

There is a problem with your ID badge. You should go to the Airport Credentialing and Compliance office located in baggage claim zone E, or call 704-359-4903. After hours contact Airport Operations at 704-359-4012. Even if your badge is not expired there could be other reasons why your ID badge is not working. Under no circumstance should you enter a restricted area if the card reader has not validated your ID badge.

First Offense: Confiscation of ID badge for 3 days. Retake SIDA training. Badge reactivation fee $25.-Second Offense: Confiscation of ID badge for 7 days. Retake SIDA training with manager/supervisor.Badge reactivation fee $50.-Third Offense: Permanent revocation of ID badge.

Display or Use of an Invalid ID Badge (Lost, Stolen, Deactivated, Expired)

Page 12: SECURITY BADGE HANDBOOK. Table of Contents Your Role Working at Charlotte Douglas International Airport (CLT)3 Important Information About Violations,

12

Offense: Any willful or gross negligence of authorized signer responsibilities. Examples include application falsification, forgery, and negligent acts pertaining to audits and recordkeeping, failure to immediately de-activate a badge by a phone call, or in person.

Example 1: An employee presents a badge request form with another authorized signer’s name printed in the authorized signer field, so you sign that person’s name in the signature field. Stop! You are forging another signer’s signature, which is a serious violation.

Example 2: You have terminated, or suspended an employee. You must call Airport Credentialing and Compliance office at 704-359-4010 , or Airport Operations at 704-359-4012, when the Credentialing office is closed, to de-activate the ID. Follow this request up with an email referencing, who you spoke with on the phone.

First Offense: Confiscation of ID badge for 5 days and loss of Authorized Signer privileges for 60 days. Retake SIDA and Authorized Signer training. Badge reactivation fee $25.-Second Offense: Confiscation of ID badge for 10 days and loss of Authorized Signer privileges for 90 days. Retake SIDA and Authorized Signer training with manager/supervisor. Badge reactivation fee $50.-Third Offense: Permanent revocation of ID badge.

Violation of Authorized Signer Responsibilities

Page 13: SECURITY BADGE HANDBOOK. Table of Contents Your Role Working at Charlotte Douglas International Airport (CLT)3 Important Information About Violations,

13

Offense: Escorting someone into a SIDA area and not following the procedures related to proper identification and the requirement to remain with the individual being escorted.

Example: You escort a new employee who is currently in the process of receiving their ID badge. It is imperative that you remain with the escorted individual at all times. You can only pass the person off to another individual with escort privileges. This is indicated by an ES on the ID badge.

First Offense: Confiscation of ID badge for 3 days. Retake SIDA training. Employee will also lose their escort privileges for minimum of six months. Badge reactivation fee $25.-Second Offense: Confiscation of ID badge for 7 days. Retake SIDA training with manager/supervisor. Employee will also lose their escort privileges for minimum of one year. Badge reactivation fee $50.-Third Offense: Permanent revocation of ID badge.

Violation of Airport Escort Procedures

Page 14: SECURITY BADGE HANDBOOK. Table of Contents Your Role Working at Charlotte Douglas International Airport (CLT)3 Important Information About Violations,

14

When tools or other equipment are brought into a secured, sterile area, or SIDA, control must be maintained 100% of the time. If the items are left in an area, that area MUST be locked and secured OR responsible personnel MUST be within sight of the items. If you are not sure if the area will be secured with a lock, or if there is a possibility that someone may gain unauthorized access, take any prohibited items with you. Only prohibited items allowed in the Secured, Sterile, or SIDA Areas are items that are necessary for performance of the job.

If you are unsure as to which items are “prohibited” see the list at the appendix or refer to the TSA website at: www.tsa.gov . Go to “Our Travelers”/ “Air Travel”/”Prohibited Items”

First Offense: Confiscation of ID badge for 3 days. Retake SIDA training. Badge reactivation fee $25.-Second Offense: Confiscation of ID badge for 7 days. Retake SIDA training with manager/supervisor. Badge reactivation fee $50.-Third Offense: Permanent revocation of ID badge.

Leaving Prohibited Items Unattended in a Restricted Area.

Page 15: SECURITY BADGE HANDBOOK. Table of Contents Your Role Working at Charlotte Douglas International Airport (CLT)3 Important Information About Violations,

15

Offense: Treating the badge in a negligent manner and opening a possibility of a breach.

First Offense: Confiscation of ID badge for 3 day. Retake SIDA training Badge reactivation fee $25.-Second Offense: Confiscation of ID badge for 7 days. Offender and manager/supervisor retake SIDA

training. Badge reactivation fee $50.-Third Offense: Permanent revocation of SIDA privileges

Example 1: You let a friend borrow your jacket, and your badge is inside. Your friend can come to the airport and decide to use your badge to get into areas they are not authorized to be in. It is your responsibility that they got hold of your badge

Remember: You are responsible for your SIDA badge. Make sure you always know its whereabouts. Always call Airport Credentialing office at 704-359-4010 or Airport Operations 704-359-4012 as soon as you realize you cannot find your badge, so it can be de-activated. Do not expose the airport to a possibility of a breach, even

unknowingly.

General Negligence with SIDA Badge

Page 16: SECURITY BADGE HANDBOOK. Table of Contents Your Role Working at Charlotte Douglas International Airport (CLT)3 Important Information About Violations,

16

Offense: ID badge not displayed and/or ID badge does not meet the requirements of valid identification and does not fit into any other violation category.

First Offense: Confiscation of ID badge for 3 day. Retake SIDA training. Badge reactivation fee $25.-Second Offense: Confiscation of ID badge for 7 days. Offender and manager/supervisor Retake SIDA

training. Badge reactivation fee $50.-Third Offense: Permanent revocation of SIDA privileges

Remember: ID badges must be displayed above the waist and on the outermost garment. It is required that the identification be displayed above the waist and below the neck .

Failure to Display Proper Identification

Page 17: SECURITY BADGE HANDBOOK. Table of Contents Your Role Working at Charlotte Douglas International Airport (CLT)3 Important Information About Violations,

17

Offense: Failing to challenge someone in a restricted area who is not displaying an ID badge or who is piggybacking. Failing to show ID when challenged.

First Offense: Confiscation of ID badge for 3 day. Retake SIDA training. Badge reactivation fee $25.-Second Offense: Confiscation of ID badge for 7 days. Offender and manager/supervisor retake SIDA training. Badge reactivation fee $50.-Third Offense: Permanent revocation of SIDA privileges

Example 1: You are performing your assigned job duties on the ramp. While you are loading baggage onto an aircraft, you observe an individual who doesn’t look comfortable/familiar with their surroundings even though they are in uniform. What do you do? Approach the individual and ask to see their ID badge, and make sure the badge belongs to them, is not expired and authorizes them to be in the area.

Example 2: You report to work, approach the secured door, swipe your ID badge, and gain access to your work site. After entering the area, you observe an individual who enters behind you, but didn’t appear to swipe for access. STOP! Ask to see their ID badge. If they can’t produce one, or produce an ID not belonging to them, inform them they are not authorized to enter the area.

Challenging – Failure to Challenge or Failure to Respond to a Challenge

If you feel threatened, immediately call Airport Police at 704-359-4911.

Page 18: SECURITY BADGE HANDBOOK. Table of Contents Your Role Working at Charlotte Douglas International Airport (CLT)3 Important Information About Violations,

18

Offense: Refusing to comply with directives of airport personnel, law enforcement, or TSA personnel in the conduct of their official duties. Includes all Airport property.

First Offense: Confiscation of ID badge for 3 days. Retake SIDA training. Badge reactivation fee $25.-Second Offense: Confiscation of ID badge for 7 days. Offender and manager/supervisor retake SIDA training. Badge reactivation fee $50.-Third Offense: Permanent revocation of SIDA privileges.

Examples: 1. You are picking someone up on the upper level and a traffic control officer asks you to move. You refuse to do so, since it will be just a minute till your party comes out. You are in violation, since

the Traffic Guard is carrying out provisions of the Airport Security Program. 2. A bus driver from the employee parking lot gives you a directive, you are required to

comply with it, otherwise you are in violation.

Refusal to comply with the directives of airport security, law enforcement or TSA personnel

Page 19: SECURITY BADGE HANDBOOK. Table of Contents Your Role Working at Charlotte Douglas International Airport (CLT)3 Important Information About Violations,

19

Vehicles must meet sign requirements. Signs must be of commercial design on both sides of the vehicle, company names must appear in letters a minimum of three inches high.

First Offense: Vehicle removed from AOA. Confiscation of ID badge for 1 day. Retake SIDA training. Badge reactivation fee $25.-Second Offense: Vehicle removed from AOA. Confiscation of ID badge for 3 days. Offender and manager/supervisor Retake SIDA training. Badge reactivation fee $50.-Third Offense: Vehicle removed from AOA. Confiscation of ID badge for 7 days. Offender and manager/supervisor Retake SIDA training. Badge reactivation fee $75.-

Improper Signs on Vehicles

Example: You are required to operate a vehicle on the AOA for your company. Your manager/ supervisor tells you to use another vehicle due to the fact your regular vehicle is in the shop for repairs.

You are responsible to ensure that the vehicle you are operating meets the requirements of proper signage (commercial design with a minimum of 3-inch lettering). If it doesn’t, bring it to the attention of your manager/supervisor.

Page 20: SECURITY BADGE HANDBOOK. Table of Contents Your Role Working at Charlotte Douglas International Airport (CLT)3 Important Information About Violations,

20

1.) Intentional and Willing Loaning/Borrowing an ID Badge to/from Another Person . ( Revocation of both parties badge)

Offenses that result in immediate and permanent revocation of ID Badge.

Example: You are ending your shift. Your co-worker reporting to work realizes he has forgotten his ID at home. He asks if he can use your badge for the day. You agree to let him borrow it as long as you get it back by the time you report to work the next day. You report to work, to find out you are no longer granted the privilege to hold an ID badge.

2.) Intentional and Willing Loaning/Borrowing Security Keys to/from Another Person. ( Revocation of both parties badge)

3.) Duplication/Reproduction of CLT ID Media. A person knowingly, willingly, intentionally using materials, data, etc. to duplicate or

reproduce CLT approved official ID media.

4.) Using Secured Doors to Bypass ScreeningUsing the door when travelling, in order to bypass screening. Also includes causing an

unscreened item to be placed on the aircraft.

Page 21: SECURITY BADGE HANDBOOK. Table of Contents Your Role Working at Charlotte Douglas International Airport (CLT)3 Important Information About Violations,

21

How Do I Escort Individuals?

Any person with CLT issued ID badge with an “ES” designation, may escort any person(s) who meet the following conditions:

1.) Not currently badged.2.) Has not been denied a badge due to disqualifying convictions, or any other reason.3.) Not previously badged (only exception is by approval of the ASC, or his/her designee.)4.) The escorted individual is continuously accompanied, monitored, and under the control of the escort while in the SIDA and sterile area in a manner sufficient to identify whether the individual is engaged in activities other than those for which escorted access was granted.5.) The escorted individual is immediately removed from the SIDA or sterile area if they attempt to engage in activities other than those for which escorted access was granted.6.) The Airport is notified immediately through Airport Operations if the escorted individual:

- engages in activities other than those for which escorted access was granted, or - at any time, is removed from the control of the escort.

CLT airport-issued identification/access badges are for official business use only. Any exceptions must be authorized by the ASC, or his/her designee.The number of individuals should be limited to a reasonable number depending on circumstances and ensuring positive control is maintained at all times. For groups of two or more individuals, at least two escorts are required.

If you release the person you are escorting to another badge holder with escort privileges within your company, you must acknowledge to the other that you are placing the escort under theirauthority and control.

Page 22: SECURITY BADGE HANDBOOK. Table of Contents Your Role Working at Charlotte Douglas International Airport (CLT)3 Important Information About Violations,

22

How Do I Challenge?

Challenging is being observant of others in your working environment. If you observe someone entering your work area (a designated SIDA or AOA area), you are encouraged to approach the individual if they are not displaying an ID badge which is visible to you.

If someone enters a restricted area behind you, and they do not display an ID badge or appear to have gained access by not entering their PIN on an access card reader, CHALLENGE!

When challenging, make sure the ID badge belongs to the person, is still valid and the person is allowed to be in the area (i. e. a CLT-South badge, would not be permitted on the main terminal ramp).

If at any time you feel threatened by the individual or afraid to approach them, immediately notify Airport Operations while keeping the individual in your sight if possible.

On a consistent basis, testing is conducted by TSA Officials, Airport Officials, and other government authorities on the detection of persons not displaying or entering an area with proper ID badge or access methods.

We ask for your cooperation in assisting CLT by being observant of your working environment and helping to promote a safe and secure environment and helping to promote a safe and secure environment for all of us.

Page 23: SECURITY BADGE HANDBOOK. Table of Contents Your Role Working at Charlotte Douglas International Airport (CLT)3 Important Information About Violations,

23

Lost/Stolen CLT ID Badge

First Offense: $50 Fine.

Second Offense: (24) hour waiting period in hopes of finding badge and $100 Fine.

Third Offense: (48) hour waiting period in hopes of finding badge and $150 Fine

Lost/Stolen ID badges must be immediately reported to Airport Credentialing office, or Airport Operations by phone, or in person. Failure to do so could result in permanent revocation of ID badge.

In order to receive a replacement badge you must complete the badge request form signed by an authorized signature and pay a monetary fine as listed below. You can go to cltairport.com/operations to fill out a new badge request form.

Page 24: SECURITY BADGE HANDBOOK. Table of Contents Your Role Working at Charlotte Douglas International Airport (CLT)3 Important Information About Violations,

24

Appendix/Resources

Page 25: SECURITY BADGE HANDBOOK. Table of Contents Your Role Working at Charlotte Douglas International Airport (CLT)3 Important Information About Violations,

25

Appendix/Resources

Page 26: SECURITY BADGE HANDBOOK. Table of Contents Your Role Working at Charlotte Douglas International Airport (CLT)3 Important Information About Violations,

26

Appendix/ResourcesGlossary of Terms:

SIDA Security Identification Display Area

AOA Air Operations Area

CLT Charlotte Douglas International Airport

TSA Transportation Security Administration

ASC Airport Security Coordinator

ASP Airport Security PlanImportant Phone Numbers

Airport Police - Emergencies 704-359-4911

Airport Credentialing and Compliance Office 704-359-4910

Airport Operations 704-359-4012

Airport Security Coordinator 704-359-4844

Revised 5 Nov ‘15