1. Justifying the unjustifiable
2. Seafarer vaccination lags behind
3. Carbon charterparty clauses
4. Seafarers deserve support
5. Water level detectors
6. Indian Register goes digital
7. Shell emissions court case
8. Supply chain security risk
9. Cargo dangers
10. Officer shortfall
11. Mission for Shipping
12. Ever Given case
13. ISU salvage statistics
14. All at Sea
Notices & Miscellany
Readersâ responses to our articles are very welcome and, where suitable, will be reproduced:
Write to: contactus@themaritimeadvocate.com
1. Justifying the unjustifiable
By Michael Grey
Nobody should be surprised that there has been something of a fight back by ship operators after the World Maritime Universityâs research earlier in the year showed up widespread âadjustmentâ in the recording of seafarersâ hours of work and rest (see A Culture of Adjustment). It was a shocking report, although it merely gave chapter and verse to what is reality aboard so many hard-pressed ships, with exhausted crews. But as reported in the Nautilus Telegraph, rather than looking constructively at the WMUâs recommendations to make seafaring more humane and 21st century, the shipownersâ representative at the Maritime Labour Convention Special Tripartite Committee sought to denigrate the report as unfounded. (https://www.nautilusint.org/en/news-insight/telegraph/fatigue-another-inconvenient-truth)
Adopting the time-honoured strategy of suggesting the research was suspect because of its sponsors and dubious methodology, the ownersâ representative went on to attack the university itself, doubtless provoked by the amount of publicity the report received in the media. You might suggest that such a response, of a lobby group that âdonât like it up âemâ, was entirely predictable, but a little humility would not have come amiss, rather than trying to bluff their way out of trouble. There were a whole host of serious points made in the research document, which surely deserved to be properly considered. I would be willing to bet that plenty of decent ship operators, rather than rubbishing the research, will have looked closely at the situation and are seeking to address some of the points made.
To take just one of the issues that the report highlighted, the idea that a 6/6 hour watch system can be operated legally is utterly laughable, but remains in place for a huge fleet of small ships. The UK, led by organisations like the Nautical Institute (hardly a trade union) has been trying to stop the practice for years. While the UK remained in the EU, every attempt to outlaw this practice was shot down in flames at the pre-IMO meetings insisted on by Brussels, where the antediluvian Dutch, German and Scandinavian views on âacceptable manning practicesâ predominate. It might be argued that such practices are economically necessary, but if they cannot be undertaken legally in a culture that never permits ships to lay by, they should stop pretending. It doesnât say much for the notion of âdecent workâ, when inadequate manning is allowed to become institutionalised and is defended by employers who like to emphasise their commitment to safety all the time.
Letâs face it, this is usually why short sea ships regularly run aground on their coastal passages, with tired people slumped in their chairs in their climate-controlled wheelhouses and no separate night lookout posted as this would interfere with the day work. It is why there are serious accidents, like the mooring fatality investigated recently by the Dutch authorities, where nobody aboard had been asleep for 17 hours and a cook and trainee were trying to handle the lines down aft.
Itâs all very well to suggest that adequately manning these ships and operating them with less of a rush would make them uneconomic against road haulage competition, but itâs basically the same argument that failed to prevail against the common humanity that ended the sweat shop and child labour in more civilised countries. The problems outlined by the WMU researchers wonât go away and itâs time that the industry took them on board.
Maybe it is the sort of cause that Frank Coles, formerly of Wallem, might take up in his latest role as a supporter of seafarersâ human rights. He surfaced last week in the e-journal Splash 247, with an excoriating attack on those who treat seafarers, especially during the pandemic, as people of little account â the âscum of the earthâ. It was explosive stuff, which will doubtless have plenty of industry folk stroking their chins, but welcome, as too many people who depend on the ships coming and going never give a thought to those who live aboard them. When somebody who has been one of the worldâs biggest ship managers says these things, they get noticed. See https://splash247.com/seafarers-scum-of-the-earth/
Michael Grey is former editor of Lloydâs List.
2. Seafarer vaccination lags behind
The Seafarer Covid-19 Welfare Survey announced recently by the Bahamas Maritime Authority has already garnered very high levels of support from maritime organisations and seafarers, however the initial responses received from seafarers are demonstrating that the vast majority, 87%, have still to receive a first vaccine.
Of the respondents to date, 86% would be willing to have the vaccine if offered and 65% would feel safer if they had been vaccinated. Initial results also show that more than half of those who have been at sea during the pandemic have been impacted in terms of shore leave and ability to get on or off the vessel. These are very much based on first responses and researchers are receiving many more on a daily basis.
The aim of the survey is to accurately collect information from front-line seafarers (who will remain anonymous throughout), specifically focusing on their mental health needs before and during the pandemic. The data collected will be analysed and used to understand the challenges our seafarers experienced in order to develop effective solutions that raise awareness and guide international efforts to improve the livelihoods of those who choose to serve at sea.
The electronic survey itself is simple to complete and takes about 10 minutes. All results will be kept confidential at the University of Washington and respondents can choose not to answer any question with which they are uncomfortable. To maximise uptake, The BMA has approached a number of key industry bodies to support and raise awareness of the initiative, giving as many seafarers as possible the opportunity to participate and contribute towards this endeavour. For further details and a link to the survey go to the BMA website: www.bahamasmaritime.com/bma-news/87-of-seafarers-still-to-receive-a-first-vaccine-according-to-initial-results-of-bma-mental-health-survey/
3. Carbon charterparty clauses
As the industry prepares for the introduction of new carbon regulations due to come into force in 2023, BIMCO has been looking at preparing charterparty clauses to cover the new rules. An impact study by BIMCO and other market players has identified a number of hurdles and contractual challenges to be overcome and as charterparties are already under negotiation which extend beyond 2023, coming up with new clauses is top priority.
According to BIMCO: âThe main driver for this initiative is the amendments to chapter 4 of MARPOL Annex VI, due to come into force in 2023, which will tightly regulate the energy efficiency and carbon intensity of ships. The future regulatory framework is complex and challenging and may require shipowners to reduce engine power and speed to comply with the Energy Efficiency Existing Ship Index (EEXI). The carbon intensity index (CII) requirements may also see shipowners having to reduce cargo intake in addition to routeing and slow speeding measures. Compliance with the new regime may mean that shipowners are at risk of being in breach of their obligations in performing the voyage under standard charterparty terms.â
BIMCOâs impact study has indicated that the commercial implications of CII will be as equally challenging as the contractual issues. Another issue to be considered is whether the carbon levies should be seen as a tax.
For further information see https://www.bimco.org/news/priority-news/20210528-bimco-tackles-challenging-carbon-rules-with-new-charter-party-clauses.
4. Seafarers deserve support
BIMCO is launching âSeafarers Deserve Supportâ, the second in the series of films produced to raise awareness, this time calling on governments and decision-makers worldwide to step up and support the seafarers behind world trade.
On any given day, around one million seafarers are working on some 60,000 large cargo ships worldwide. It has been estimated that in September 2020, around 400,000 seafarers requiring repatriation were stranded at sea due to the Covid-19 pandemic, and in some instances, seafarers have not been able to go home for 18 months.
The pandemic has exposed a widespread lack of understanding about the crucial role of seafarers and with many countries fighting a third wave, the crew change crisis is far from over. Like its predecessor, âShips Make the World Goâ, the aim of âSeafarers Deserve Supportâ, is for the film to be shared as widely as possible to help raise awareness.
âNever have we faced more urgency to make sure our seafarers are given the support they need and the fairness they deserve. These are the people that keep the world supplied, the people behind world trade,â says BIMCOâs Secretary General, David Loosley.
âThe pandemic has demonstrated that too many outside the shipping community are unaware of the crucial role that seafarers play. The lack of action by governments needs to be addressed repeatedly so that our seafarers are protected and can go home safely after work,â Loosley says.
In addition to the lack of action in finding solutions that will allow crew change â including seafarer vaccination programmes â seafarers are exposed to other safety issues that urgently require the attention and action of governments. Globally, 135 crew were kidnapped from their vessels in 2020, with the Gulf or Guinea accounting for over 95%, a rise from 2019.
âNo seafarer deserves to risk being kidnapped while he or she is carrying out their job, and no seafarer deserves to be stuck at sea for 18 months while delivering everything that we need in our daily lives. It is time that governments step up in their support for seafarers,â says Loosley.
âSeafarers Deserve Supportâ serves as a valuable tool to help raise awareness, educate and increase the support for seafarers. The film can be viewed and shared via this link: https://www.bimco.org/SeafarersDeserveSupport
5. Water level detectors
At its meeting last month, the International Maritime Organizationâs Maritime Safety Committee (MSC) adopted a new regulation, entering into force on 1 January 2024, requiring new multiple hold cargo ships to be fitted with water level detectors in each cargo hold.
The water level detectors will give an audible and visual alarm at the navigation bridge when the water level reaches a height of 0.3m above the bottom of the cargo hold, and again when the water level reaches a height of 15% of the depth of the cargo hold.
The new regulation harmonizes the requirements for bulk carriers and non-bulk carriers, and will not apply to tankers, liquid holds, and tanks entirely above the freeboard deck.
Meanwhile an IMO working group has agreed a set of draft guidelines to support mandatory measures to cut the carbon intensity of all ships.
The proposed mandatory measures have already been approved by IMOâs Marine Environment Protection Committee (MEPC) and are expected to be adopted when the MEPC meets for its 76th session from 10-17 June, 2021.
6. Indian Register goes digital
Classification society, Indian Register of Shipping (IRClass), has announced major initiatives towards digitalisation and offering its services through a unified digital platform.
IRClass has initiated the creation of a separate department âIRClass Digitalâ, a dedicated team under the aegis of its Executive Chairmanâs office. It will focus on connected ship and smart infrastructure, online information and access management, automated immersive design simulation and validation, smart emergency response system, use of Digital Twin concept, and real time condition monitoring.
The âIRClass Digitalâ initiative aims to build a world class digital framework based on 4 key pillars â technology, people, processes, and open innovation. Through this digital platform, IRClass plans to offer remote vessel and fleet monitoring, performance and voyage optimisation, remote maintenance assistance, predictive maintenance, condition monitoring and a slew of other services.
IRClass has signed a Memorandum of Agreement with Smart Ship© Hub (www.smartshiphub.com); a multi-tenant on demand digital platform and one stop solution provider to ship owners to customize as per their specific requirements, to collaboratively grow ‘IRClass Digitalâ and to offer best-in-class solutions for the maritime community.
Arun Sharma, executive chairman of IRClass said: âWe believe that a collaborative approach to digitalisation in shipping is a proactive way forward for the maritime community. As technological adoption in shipping is progressing rapidly, IRClass is well-positioned to offer value added services. This tie-up with Smart Ship© Hub to develop âIRClass-Digitalâ allows us to offer fully integrated and technology enabled service offerings to our customers and stakeholders.â
7. Shell emissions court case
A Netherlands court ordered oil major Shell to reduce its carbon emissions by 45% by 2030, with the company set to appeal the judgment. The case was brought by charity Friends of the Earthâs Dutch chapter. The charity says the ruling from the court in The Hague will have major ramifications internationally.
Sara Shaw, from Friends of the Earth International, said: “This is a landslide victory for climate justice. Our hope is that this verdict will trigger a wave of climate litigation against big polluters, to force them to stop extracting and burning fossil fuels. This result is a win for communities everywhere who face devastating climate impacts now.â
Responding to the judgment Shell said âUrgent action is needed on climate change which is why we have accelerated our efforts to become a net-zero emissions energy company by 2050, in step with society, with short-term targets to track our progress.”
âWe are investing billions of dollars in low-carbon energy, including electric vehicle charging, hydrogen, renewables and biofuels. We want to grow demand for these products and scale up our new energy businesses even more quickly.
âWe will continue to focus on these efforts and fully expect to appeal todayâs disappointing court decision.â
8. Supply chain security risk
The risk of loss or damage to goods in the global supply chain has never been more evident. In combating the dangers, international freight insurance specialist, TT Club has launched a second series of its podcasts to draw attention to the variable and complex nature of these risks and offer increased guidance on loss prevention.
Mike Yarwood, TTâs managing director, loss prevention, hosts the podcasts and comments, âThe current freight transport environment features higher than normal volumes of cargo movement across all modes on land, sea and air, as well as significant disruption to well-established routings and methods of transport.â In addition, he says, there are increased inventories of certain goods at many locations and more sub-contracting activity, potentially employing less reliable entities. All these factors allow well-organised criminal organisations to exploit security weaknesses along the supply chain.
Accompanying Yarwood on the podcasts is David Thompson of Signum Services, the in-house investigative arm of TTâs managers, Thomas Miller. His career has spanned 30 years as a detective with Londonâs Metropolitan Police and a further eight as an investigator with Signum. âOrganised crime has never been so organised,â says Thompson. âMuch cargo crime is perpetrated by well-oiled business-like machines that target goods that are in market demand and easily converted into cash. They are well-informed and adapt quickly to new transport trends, spotting opportunities with intelligence and resource.â
Among identified trends apparent during the recent lockdowns has been a move away from the theft of higher value, more easily traced goods, such as electronics and domestic appliances, to food and drink commodities that have a ready market. Thieves have also noted and exploited the congestion in the supply chain that has increased the use of temporary warehousing and storage sites that are not always as secure as established premises. The second series of TTâs podcasts addresses these along with a range of other risk pinch points.
Keeping ahead of, or more often, up with the variable methods that criminal organisations employ, and combating the threats to cargo assets they enable, are major tasks and are the challenges that TT Clubâs loss prevention resources are ready to face through increased awareness and guidance on protective action.
9. Cargo dangers
The X-Press Pearl fire and the ongoing situation surrounding the casualty has highlighted the duty of care required in shipping hazardous cargoes the TT Club has warned.
âThe appalling events still unfolding at an anchorage off Colombo serve once more to underline the continuing problem of ship fires caused by the mishandling of dangerous goods. TT Club again urges all those involved in the movement of such cargoes to step up to their responsibilities and to act with transparency and diligence in matters of safety in transport.â
According to the club, the X-Press Pearl casualty is the latest in a disappointing recent and persistent catalogue of container ship fires of varying degrees of severity, which occur on an almost weekly basis. âThe vast majority of these are initiated by a cargo of a hazardous nature. One estimate puts the number of mis- or undeclared dangerous cargoes in excess of 150,000 containers a year â each of which has disastrous potential. While still to be fully investigated, the catalyst for the inferno on the X-Press Pearl has been asserted to be a leakage of nitric acid, which was correctly declared but apparently incorrectly packaged or packed.â
TT Club has been campaigning for some time on the issue, including promoting awareness and wider use of the IMO/ILO/UNECE Code of Practice for Packing of Cargo Transport Units â the CTU Code – and seeking changes in regulatory requirements to improve the clarity, application, implementation and enforcement of mandatory regulations, including the International Maritime Dangerous Goods (IMDG) Code.
TT Club organised a series of three webinars earlier this year covering all aspects of container ship fires, which looked at the whole gamut of issues from ensuring that cargo packing, declaration and stowage are right; how the ship and its crew are able to respond to incidents when they arise – specifically in terms of firefighting capability; to the aspects of forensic investigation and legal work leading to the probable litigation after the event.
All three videos can be accessed HERE
10. Officer shortfall
The diminishing attraction of a career at sea, coupled with rising man-berth ratios and continued fleet growth will lead to the highest shortfall of officers to crew the worldâs merchant fleet in over a decade by 2026, with important implications for both hiring and future manning cost inflation, according to the latest Manning Annual Review and Forecast report published by global shipping consultancy Drewry.
The current officer supply shortfall is estimated to equate to around 3% of the global pool, which is broadly manageable and is not noticeably impacting hiring, but is to some extent masked by the temporary idling of vessels in certain sectors such as cruise, due to the Covid-19 pandemic, Drewry suggests. Ratings supply is much more elastic due to lower entry requirements and shorter training periods.
However, looking ahead to 2026 the supply / demand gap is expected to widen to a deficit equating to over 5% of the global officer pool and the highest level since 2013. The principal reason for this is the slowdown in officer supply as the attraction of a career at sea is diminishing. In the five years to 2016 the supply of seafarers available to crew the global merchant fleet was growing at an average annual rate of 2.7%, according to Drewry estimates. However, over the last five years this growth rate has shrunk to just 0.5% annually.
âWith the ongoing negative effects of life at sea brought about by the Covid-19 pandemic, some seafarers may bring retirement plans forward, while others may look for work ashore,â said Drewryâs head of manning research Rhett Harris. âIt has been the case for a number of years that quality officers have been difficult to recruit and retain. This situation is expected to get worse as the growth in supply fails to keep pace with an expanding world fleet.â
Despite these trends, underlying aggregate manning costs, excluding the impact of Covid-19, are expected to rise moderately in 2021, according to Drewry estimates, increasing just 0.4% over the year, a similar pace to 2020. Looking further ahead, tightening labour market conditions and better affordability will drive up crewing costs, but increases will remain below the prevailing rate of consumer price inflation.
âWhile ratings supply has slowed, availability is relatively elastic and wage levels will remain driven by collective bargaining arrangements,â explained Harris. âBy contrast, officer remuneration is more market driven but the widening shortage of officers is expected to affect the quality more than the quantity available for service. Drewry therefore expects employers currently paying low-wages will be more affected by fallout from the Covid-19 pandemic, as disgruntled seafarers are enticed to better paying owners or different roles ashore.â
11. Mission for Shipping
The International Chamber of Shipping (ICS) has welcomed the launch of Mission Innovationâs Mission for Shipping. Announced at the beginning of this month, it aims to enable 5% of the global deep-sea fleet to run on zero-emission fuels by 2030. Mission Innovation was launched five yearsâ ago at the time of the Paris agreement, with country members committed to accelerating clean energy initiatives aimed at combatting climate change.
The Mission for Shipping aims to support public-private cooperation and the increase in R&D expenditure that will be needed for oceangoing ships to transition to zero-carbon fuels and propulsion systems, at the pace required for the industry to decarbonise completely, in line with the goals of the Paris agreement on climate change.
It provides important and timely recognition of the urgent and critical need to accelerate R&D of zero-carbon technologies from both public and private sectors, which will be vital to achieve the ambitious CO2 reduction targets which have already been agreed for the global shipping sector at the UN International Maritime Organization (IMO), the ICS says. âThe $5 billion IMO Maritime Research Fund is the ideal vehicle for this public private partnership, which is advocated by a broad coalition of governments with the full support of the global shipping industry.â
With the support of Mission Innovation governments, the IMO Maritime Research Fund can be in place by 2023, funded solely by R&D contributions from ship operators. This will come at no financial cost to governments whilst complementing and supporting their own efforts towards the goal of decarbonisation.
Guy Platten, ICSâs Secretary General, commented: âWe welcome this timely recognition by Mission Innovation of the urgent need to accelerate R&D of zero-carbon technologies in shipping. This will be vital to achieve the ambitious CO2 reduction targets, already agreed at the UN IMO, to which both governments and industry are committed.
âThis firmly aligns with the goals of the $5 billion of guaranteed R&D funding which the IMO Maritime Research Fund will provide.â
âThe IMRF will make it possible to provide at least 50 per cent of the funding towards a specific government supported R&D project â potentially far more for smaller projects or if the project is undertaken by a developing country. This would contribute much needed R&D funding in line with the announcements made today by Mission Innovation governments. But this requires the support of these same governments at the critical IMO meeting next week.â
12. Ever Given case
Fallout from the recent grounding of the Ever Given in the Suez Canal continues with an announcement by the Ismailia first instance economic court that the case has been adjourned to 20th June, a press conference by the Suez Canal Authority alleging the ship was going too fast through the canal and a statement by insurers the UK Club. The Suez Canal Authority announced last month that it had reduced the amount of its claim following the incident from $916m to $550m (see the SCA website https://www.suezcanal.gov.eg).
The UK Club meanwhile has issued a media statement (https://tinyurl.com/55bbyzcy) expressing its concern about SCA comments saying the owners of the Ever Given and their P&I and hull and machinery insurers âlook forward to responding to these allegations within the Egyptian court proceedings. Critically it is important to clarify that whilst the master is ultimately responsible for the vessel, navigation in the Canal transit within a convoy is controlled by the Suez Canal pilots and SCA vessel traffic management services. Such controls include the speed of the transit and the availability of escort tugs.â
13. ISU salvage statistics
The International Salvage Union has just released its statistics for 2020 showing significantly weaker revenues with a dramatic fall in wreck removal income and services.
Gross revenue for ISU members amounted to US$ 301 million compared to US$ 482 million in 2019. Some 182 services were provided, against 216 services the previous year. Lloydâs Open Form (LOF) was used in 40 cases, up from 35 the previous year. LOF revenue was up at US$ 60 million (2019, US$ 49 million). Wreck removal income was significantly down at US$ 98 million from 52 services (2019, US$ 284 million from 101 services).
14. All at Sea
Those of you looking for something enjoyable to read, a common problem when spending more time at home, should check out All At Sea, a memoir by Alan Loynd, who many readers will know. Loynd, whose career included six years in the Royal Fleet Auxiliary, before joining the Swire Group, has many a tale to tell of life in the fast lane of marine salvage.
Covered are some high profile salvage operations with Hongkong Salvage and Towage including the successful recovery of a Boeing 747 completed in the full glare of publicity â the first time this had ever been achieved. Also described is the delicate separation of the Inchcon Glory and Europa following a collision â one of four jobs on Lloydâs Open Form completed in a very short space of time â an impressive figure compared to how salvage work might apportioned in todayâs environment.
Loynd writes about his experiences in a way that a wide audience will appreciate â irrespective of their knowledge of complex salvage operations – and with a good deal of humour. Copies of the book, first published by Proverse Hong Kong are to be found on Amazon among other outlets, including Waterstones.
Notices & Miscellany
BIMCO changes
Sabrina Chao is set to take over as the 45th president of BIMCO, the fifth president to be based in Asia and the third to be based in Hong Kong. She takes over from Şadan Kaptanoğlu, managing director of Kaptanoglu Shipping, who has completed her two-year term.
âI am honoured to be offered this opportunity by an organisation that is trusted world-wide with a membership representing over half of the world cargo fleet,â says Chao.âOver the next two years, one of my key priorities is to use this opportunity to help increase awareness of our industry and our seafarers. The pandemic has exposed the lack of knowledge by policymakers about the important role we play in society, causing inaction when it comes to solving urgent issues including the crew change crisis and piracy. We need to keep raising our voice outside of our industry,â Chao says.
Meanwhile Documentary Committee Chairman Francis Sarre of CMB has, after six years in the driverâs seat, handed over the reins of BIMCOâs contracts and clauses approval body to Nick Fell of BW Group. âThe shipping industry is heavily reliant on BIMCOâs contracts and clauses and I will do my utmost to ensure that the Documentary Committee continues to act in a timely and quality-oriented fashion, developing pragmatic and commercially sound solutions,â says Fell who is Executive Vice President, Corporate Services and General Counsel at BW Group in Singapore.
Cyber awareness course
The Nautical Institute has introduced a new online course â Maritime Cyber Awareness for Seafarers â powered by HudsonCyber. The course will help crew members identify and report cyber risks, as defined in the companyâs safety management systems (SMS), policies and procedures.
The Instituteâs course provides valuable evidence that crew members have received training to address cyber risks under new IMO requirements introduced this year. These requirements call on shipping companies to address cyber risks in their SMS and their introduction has focused the minds of many on how cyber security onboard can be improved.
The Maritime Cyber Awareness for Seafarers course is offered in a three-hour module comprising video content, supplementary reading material and a 20 question self-test. Module 1 is now available, delivering training in baseline cyber security awareness. It is suitable for all crew members and has been developed specifically to assist shipping companies in meeting the new IMO cyber requirements.
https://www.nautinst.org/career-development/ni-academy/maritime-cyber-awareness-for-seafarers.html
Tsavliris view
Continuing our theme of salvage, All About Shipping has an interview with Claire Tsavliris, the third generation of this well-known family firm. Check it out at https://allaboutshipping.co.uk/2021/05/20/claire-n-tsavliris-reaffirms-strong-commitment-to-the-role-of-salvage-towage-and-wreck-removal-in-safety-and-in-safeguarding-the-environment/
Ince appointments
International legal and professional services firm, Ince has announced the appointment of a specialist and highly experienced shipping team to its Bristol office. Daniel Crockford and Alex Penberthy will join Ince as partners, adding their extensive shipping dispute resolution, yacht, superyacht and personal injury expertise.
Please notify the Editor of your appointments, promotions, new office openings and other important happenings: contactus@themaritimeadvocate.com
And finally,
A cowboy went to buy an insurance policy and the agent asked, “Have you ever had an accident?”
“Nope,” replied the cowboy, “but last summer, a bronco kicked in two of my ribs… and a couple of years ago, a rattlesnake bit me on the ankle.”
“Wouldn’t you call those accidents?” quizzed the puzzled agent.
“Naw,” the cowboy replied. “They did it on purpose!”
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