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Workplace Safety Inspection

By CHOW Lap Yan, Fenkins


September 2019
2766 7632

1
What are you going to work after graduation?

2
This is visual
machine
inspection, that can
be covered by This can be
workplace workplace safety
inspection. inspection

This is
testing and
measurement
, not just
visual
Inspection.
This is machine inspection
that needs to dismantle the
machine, which depends
whether you are m/c expert. 3
 Workplace Safety inspection = Safety Inspection covering Workplace
 But, it may have different means to cover different things in the workplace
and to different depth.
 And, it also depends on our competency.

 So, we need to define its terms of reference before conducting the expected
workplace inspection.
4
5
6
Hazard can be defined as
Inherent property or condition that
adversely affect the well-being or
health and safety of exposed persons.

Remarks:
• You can see or sometimes can even measure the
hazard.
• One hazard can bring more than 1 risk.

7
What is the hazard ( 危害 )? What is the risk( 風
險 )?
• Could you see the guy:
– “Working at height – at top of A-ladder”?
– This is a hazard.

• Could you see the guy:


– “Fall from height”?
– This is a risk.

• Risk presentation is the result of the evaluation of


hazard

• Some people cannot SEE the risk, so better to pre


sent the risk together with its source - hazard

Reference
Handout Topic: Workplace Safety Inspection Techniques and
Reporting, Sec. 4 8
Safety Risk or Risk

Outcome 1
Risk 1
Nothing

Outcome 2
Hazard Risk 2
(Source of Risks)
Nothing

Outcome 3
Risk 3
Nothing
9
Term Explanation: Risk or Safety Risk

“Safety risk. The predicted probability and severity of the


consequences or outcomes of a hazard.”

Remarks:
Risk intensity of an imagined
outcome
= Probability x Severity

• Risk is an evaluation of a
hazard
• It cannot be seen
• Its source is the hazard

Reference
International Civil Aviation Organization (ICAO), 2013, Safety Management Manual (SMM), p. xii 10
Complete description of Hazard & Risk
A man was found standing on the top of 10 feet tall
A-ladder, posing a risk of fatal falling case.

11
Risk Assessment :
3 Sequential Components

Reference
ISO 31000, 2018, Risk management – Principles and guidelines 12
Risk Assessment ( 風險評鑑 ):
1st Component: Risk identification ( 風險鑑
別)

Find, recognise and describe risks


尋找發現、認清認知及描述風險

Reference
ISO 31000, 2018, Risk management – Guidelines 13
Find
尋找發現

14
5.6.1 Identification of hazardous exposure or the risk of such
exposure to the workers

In order to identify hazards and assess their associated risks, … should in the
first place prepare a list of items covering premises, plant, people and
procedures, and gather information about them. The information required
should include: (a) tasks being carried out, their duration and frequency; (b)
location(s) where the work is carried out; (c) who normally/occasionally
carries out the tasks; (d) who may be affected by the work (e.g. visitors,
contractors, and the public); (e) training that personnel have received about
the tasks; (f) written systems of work and/or permit-to-work procedures
prepared for the tasks; (g) plant and machinery that may be used; (h)
powered hand tools that may be used; (i) manufacturers' or suppliers'
instructions for the operation and maintenance of plant, machinery and
powered hand tools; (j) size, shape, surface character and weight of materials
that may be handled; (k) distances and heights to which materials have to be
moved by hand; (l) services used (e.g. compressed air, power supply); (m)
substances used or encountered during work; (n) physical form of substances
used or encountered (fume, gas, vapour, liquid, dust/powder, solid); (o)
contents and recommendations of hazard data sheets relating to substances
used or encountered; (p) legal requirements and standards relevant to the
work, the plant and machinery used, and the substances used or
encountered; (q) control measures in place; (r) reactive monitoring data
(incidents, accidents and ill-health records associated with the work and the
equipment and substances used) from within and outside the organisation;
and (s) findings of any existing assessments relating to the work activity.
Details of risk assessment, evaluation and development of safety procedures
and risk control measures are described in Part 5.11.
15
What are the hazards in your classroom?

1. People? 人
Sub-contractors, trainees …
2. Plant? 機
Fixed equipment, portable equipment …
3. Premises? 物、環
Construction site, confined space …
4. Procedure? 法
Major activities, work flow…

16
P2 - Receiving
P2.1 - Unloading/palletiziting
P2.2 - Pallet putaway
P2.3 - ASN Update
P3 - Replenlishment
P3.1 - Run replishement report in WMS
P4 - Order Processing
P4.1 - Order wave in WMS
P5 - Order Despatch
P5.1 - Print Load Plan Packed Details Report in Brio
P6 - Item Disposal
P6.1 - Arrange disposal after receiving instruction from Client
P7 - Cycle Count

Initial
Potential Evaluation
Environmental Aspect / H&S Hazard Initial H&S Risk Assessment Objective, Targets
Environmental of
Impact Enviroment

Possible Severity Factor

Risk Factor (RF=SFxLF)


Initial EHS

Bulk Qty, Haz., Sensitive


Ref Env. Aspect: Consumption, Waste diposal, Wasterwater Existing Risk Control

Likelihood Factor
Risk

Land Contaminat ion


Resource Depletion
discharge, Emissions to air, Releases to water, Energy emitted

Env. Consequence
Applicable Legal
Water pollution

(LF)
H&S Hazard: Dangerous Part, Dangerous Equipment, Electrical Objective Target Program

(SF)
Possible Accident / Incident

LE

Register Ref.
Air pollution

Noise / Heat
Haz, Fire Haz, Explosion Haz, Working at height, Transport Haz,

material
Ergonomic Haz

MP
SA
G Electric Charger for Trucks - Chargers are placed above the floor by pallet x - Fire due to overheating 4 2 8 High To eliminate the fire due Re-locate the MHE charging Install some fire re
- Nearby with Installation of portable fire extinguisher - Truck hits the charger to overheating of areas board next to the B
- Demarcated and separated by metal sheet between the charging charger areas charging areas to
area and storage area fire spreaded to ca
P2 - Receiving
P2.1 - Unloading/palletiziting
A Fire hazard due to bulk storage of combustible wooden pallets - EHSOP001(DC / Warehouse Operations Daily Checking 0 0 Fire incident 4 1 4 Moderate To eliminate the fire Re-locate and dedicate areas - Separate and de
Procedres) accident due to bulk for bulk pallet storage for bulk pallet stora
- EHSOF001(Warehouse Basic Operations Standard Daily Check pallet storage. - Nearby with insta
Sheet) portable extinguish

B Fall of object hazard due to improper storage of wooden pallets - EHSOP001(DC / Warehouse Operations Daily Checking 0 0 Hit by falling object 3 2 6 Moderate To eliminate the fire Re-locate and dedicate areas - Separate and de
Procedres) accident due to bulk for bulk pallet storage for bulk pallet stora
- EHSOF001(Warehouse Basic Operations Standard Daily Check pallet storage. - Nearby with insta
Sheet) portable extinguish

Risk register based on operation flow17


環法
Types of Ha
zards
Reference 人法
Handout Topic: Workplace
Safety Inspection Techniques
and Reporting, Sec. 2

機法 Man

environMent 物法

m e
i
Machine Material /T
lo w
s F 空
e s 時
r oc 越
P 穿

18
• Confined spaces
Types of Ha • Unsafe behaviour


Extreme temp
Non-ionizing radiation
zards such as rule-violation
behaviour, rushing, unsafe


Biological hazard
Bad weather
method, incompetence, long
Reference • Tough environment
hour work
Handout Topic: Workplace
such as working at height,
Safety Inspection Techniques unprotected edge hazards
• Pollution
and Reporting, Sec. 2 Noise

• Slip, trip hazards
Hazard • Obstruction, projection
• Extreme
• Mechanical hazards such
Man • Fire / Explosion
temp
as the 9 types recommended hazard
under BSI, PD 5304:2014 • Transport hazard
• Ergonomic hazards • Obstruction /
• Electrical hazard environMent Chemical Hazards
• projection
• Dangerous equipment • such
Fireas the 7 categories
/ Explosion
such as LA, Abrasive under F&IU (Dangerous
Wheels, Forklift trucks
hazard
Substances) R
• Radiation • Radiation
Machine Material • Heavy object
me
i
• Lifting hazard • Overbalance of /T
• High pressure fluid stacked goods low
F
• High speed particle ess
• Dust hazard • Pollution hazards ro c
P 19
• Fire hazard • Transport hazard
Example hazard
from “Man”

Hazard:
A naked welder without clothes
Possible Risk:
The naked welder without clothes can expo
se himself to strong radiation from arc weldi
ng, resulting in skin-burnt.
Inaccurate expression:
The welder will get injured by welding.
20
When to say “no” in hazard description
• Such as no safety belt, no safety gear, no procedure
• Use “no”
• when something is expected to be there, but it is not
there.
• This “no” is called “omission”.
• This omission can either:
• directly cause accident to happen, or
• be not compiling with common norm / standard /
law.

21
Example hazard
from
“Machine” + “Man”

Hazard:
Machine: Exposed powered mixer
Machine+Man: Operating the mixer with loose
clothing

Possible Risk:
Loose clothing closed to exposed running mixer may
result in entanglement injury.
22
Example hazard
from “Material”
+ “Man”
Hazard:
Material: Very hazardous chemical of HF
Machine+Man: Very hazardous chemical
without prominent warning label
Possible Risk:
Inadequate chemical
warning label may
result in lack of
safety awareness. 23
Example hazard
from
“environMent”
+ “Man”
Hazard:
Env: Hot outdoor
Env+Man: Hot outdoor work

Possible Risk:
Hot outdoor work may result in
heat stroke or heat disease.
24
Example hazard
from “Material”
+ “environMent”
+ “Man”

Hazard:
Material: Goods
Material+Env+Man: Exit #2 blocked by
goods.
Escape way, exit signage, etc.
are often overlooked
要看得通透
25
Go through it

26
Get alarm de-activating key .. and go thro
ugh

27
Ask before you open

28
Example hazard
from “Material”
+ “environMent”
+ “Man”

Hazard:
Material: Goods
Material+Env+Man: Exit #2 blocked by
goods.
Possible Risk:
Exit #2 for fire escape was blocked.
29
Example hazard
from “Machine”
+“Material”+“Man”
Hazard:
Machine: Compressed air gun
Material: Metal dust and swarf
M/C+Mat+Man: Eye may be exposed to metal dust / swarf

Possible Risk:
Eye may catch the metal dust blown up by the air gun.
Inaccurate expression:
Dust will cause eye injury. Or, machine will cause injury.
30
Example hazard
from
“Machine”+“Mat”
+“Env”+ “Man”
Hazard:
Machine: Unfenced truck
Material: Unsecured goods
M/C+Mat+Env+Man: Unsecured goods transported
on slope

Possible Risk:
Unfenced truck may allow unsecured goods slipping
away.
31
What are the hazards?

• Man: who to maintain, who to operat


e
• Machine: a machine controlled by la
w / exposed abrasive wheel, any too
l rest, gap, stability
• Material: disk crack?
• environMent: whether suitable for ou
tdoor (waterproof), whether to use it
at night (lighting)
• Machine / Material: what type of mat
erial can be grinded by the machine

32
Risk Assessment ( 風險評鑑 ):
1st Component: Risk identification ( 風險鑑
別)

Find, recognise and describe risks


尋找發現、認清認知及描述風險

33
Recognise: A Matching Game

34
35
What is the hazard? What is the risk?

36
References for the Risk

增廣見聞
• Past OHS cases
• Good, bad and minimum practices
• Risk assessment reports
• Safety audit reports

37
References for the Risk

Co. OHS
records Statistics

Googling /
Court
YouTubin
cases
g
Cases

38
Co. OHS
records Statistics
Useful search
Googling / Court
YouTubing cases
• Hong Kong Judiciary to search for
Cases
case: http://legalref.judiciary.gov.hk

• Keywords considered: Prosecution Cases:


site:gov, site:org, accident, 事故 , ha • Magistracy Appeal, HCMA
zard • Final Appeal (Criminal), FACC,
• Google Translate the term “grinder acc FAMC
ident” into Japanese “ グラインダー事
故” and then by image, then you will Civil Cases:
find the following sites • Employee’s Compensation
Case, DCEC
http://diytool.biz/disk_grinder_how_to_use • Personal Injuries Action, HCPI
• Civil Action, HCA
https://youtu.be/R32o3zJU1lU • Civil Appeal, CACV
• Final Appeal (Civil), FACV,
FAMV
39
Co. OHS
records
records Statistics
Statistics

Googling
Googling // Court
Court
YouTubing
YouTubing cases
cases
Case
s

40
41
The 3 largest no. o
f industrial acciden
2
1 ts in HK in 2016

3
42
43
References for the Risk

Legal Rules /
requirement Machine
s Instructions

Codes of
practice /
Site tours
standards /
guidelines

Trade
Googling / experience
YouTubing Practices from mgt &
worker

44
Rules /
Legal Machine
Instruction
requirements s
Codes of Search technique
practice /
Site tours
standards /
guidelines

Trade
Googling / experience
YouTubing Practices from mgt &
worker

• Keyword search plus 1 of the following:


site:gov, site:org, safety, best, pdf
• Department of Justice:
https://www.elegislation.gov.hk

45
Rules /
Legal
requirements Machine
Instructions

Codes of
practice /
Site tours
standards /
guidelines

Trade
Googling / experience
YouTubing Practices from mgt &
worker

46
46
Legal Rules /
Machine
requirement Instruction
s s
Codes of
practice /
standards / Site tours
guidelines

Trade
Googling / experience
YouTubing Practices from mgt &
worker

47
Useful references for local safety inspection

48
Useful references for fire safety

49
Types of Findings

1st: Risk

Example finding:
A man was found operating the band-saw
with his hand coming very close to the
exposed saw, posing a risk of cutting injury
50
Types of Findings

2nd: Possible non-compliance with legal


requirements

Example finding:
Material was found stacked beyond the edge of
a receptacle, which was hung up by a tower
crane. This “fall of object” risk may breach Cap.
59I, Reg. 49 (Protection from falling materials)
51
Types of Findings

3rd: Non-compliance with organisational standard

Example finding:
A trainee was found wearing
shorts when working in workshop,
against the in-house safety rule of
putting on long trousers
52
Role of Safety Inspection
in Management Cycle

Safety Inspection is a “management functio


n and process of examining and evaluating
the extent to which specific goals, standard
s, policies, tasks or procedures have been
met.”

D
Pl

o
na
Culture

C
Ac

he
t

ck
y
Polic

Reference

CCH International, 1992, CCH Occupational Health & Safety Glossary 53


Types of Findings

4th: Other observations

Example finding:
PPE were left around on floor,
showing lack of housekeeping or
maintenance
54
Types of Findings

5th: Repeated substandard finding


Example finding:
The hydraulic test of a gas
cylinder was done in 2007.
It is illegal to use a gas
cylinder which has not been
hydraulic tested in the
previous 5 years.
Similar finding happened in
the inspection done in a
year ago.

55
Types of Findings

6th: Good practices observed

Example finding:
A drill press was found well
maintained with a properly
Is this OK? fixed telescopic guard.
This good practice could be
Could we have better? extended to the missing
telescopic part of the guard
found in the nearby drill
press. 56
Inspection / Test / Examination Forms under Ca
p. 59J, F&IU(LALG)R
Form Description Sec. No.
Form 1 Weekly inspections of lifting appliances (by Competent Person) 7A

Form 2 Test and examination of anchoring or ballasting of cranes after 7E, 7G(2)
installation or bad weather affecting stability (by RPE)

Form 3 Test and examination of cranes, crabs and winches before first 5(3), 5(5)
use or every 4 years or after major repair (by RPE)

Form 5 Examination of lifting appliance every 12 months (by RPE) 5(1)

Form 4 Test and examination of lifting appliances (except cranes, 5(2), 5(4)
crabs, winches) before first use or after major repair (by RPE)

Form 6 Test and Examination of chains, ropes and lifting gear (except 18(1)(d)
fibre rope) before first use (by RPE)

Form 7 Examination of chains, ropes and lifting gear every 6 months 18(1)(e)
(by RPE)

Reference
http://www.info.gov.hk/cgi-bin/forms/elogframe.cgi?formnoinput=&keywordinput=&deptinput=LABD&format=&dept=Searc
h 57
Test forms under Cap. 56, B&PVO
Form Description Sec. No.
Form 1 Certificate of fitness for a steam boiler 27
Form 2 Certificate of fitness for a pressure vessel / air receiver (every 26 months 27
by appointed examiner)

Reference
http://www.info.gov.hk/cgi-bin/forms/elogframe.cgi?formnoinput=&keywordinput=&deptinput=LABD&format=&dept=Searc
h 58
Other Inspection / Test / Exam Forms
F&IU (Suspended Working Platforms) Regulations, Cap. 59AC
19(1) Weekly inspections of SWP (by competent person) SWP - F1
20(1) Examination of SWP every 6 months before use (by RPE) SWP - F2
20(2) & (3) Test and examination of SWP every 12 months before use or after major repair/ bad weather affecting SWP - F3
stability (by RPE)
Construction Site (Safety) Regulations, Cap. 59I
5(2) Weekly inspections of Hoists (by competent person) CSSR - F1
35(1) Test and examination of Hoist before use or after alteration or repair (by RPE) CSSR - F2
35(3) Six-monthly examinations of Hoists (by competent examiner) CSSR - F3
39(2) Weekly examinations of excavations over 1.2 meters or likely to cause danger (by competent person) CSSR - F4
38F(1) Inspection of scaffolds (every fortnight before use or bad weather) (by competent person) CSSR - F5

F&IU (Safety Officers & Safety Supervisors) Regulations, Cap. 59Z


17(2) Weekly report of daily inspection to be prepared by safety supervisor employed on construction sites SOSS - 3A
17(2) Weekly report of daily inspection to be prepared by safety supervisor employed in shipyards / container SOSS - 3B
handling workplaces

Reference
http://www.info.gov.hk/cgi-bin/forms/elogframe.cgi? 59
Risk Assessment ( 風險評鑑 ):
1st Component: Risk identification ( 風險鑑
別)

Find, recognise and describe risks


尋找發現、認清認知及描述風險

60
How to describe
描述

61
Poor example of finding (1/10)

62
Poor example of finding (2/10)

• What’s wrong with this finding:


– Band saw without guard

63
Poor example of finding (3/10)

• What’s wrong with this finding:


– A push-stick should be provided

64
Poor example of finding (4/10)

• What’s wrong with this finding:


– Not wearing anti-cut gloves

65
Poor example of finding (5/10)

• What’s wrong with this finding:


– The band-saw was found with crushing hazard

66
Poor example of finding (6/10)

• What’s wrong with this finding:


– The band-saw was found with cutting hazard

67
Poor example of finding (7/10)

• What’s wrong with this finding:


– Breach of Cap. 509

68
Poor example of finding (8/10)

• What’s wrong with this finding:


– Poor(P)

69
Poor example of finding (9/10)

• What’s wrong with this finding:


– Not up to standard

70
Poor example of finding (10/10)

“There is a machinery hazard in the Machinery Workshop”.

Comment:
• Even with the photo above, the hazard has not been explain
ed. Machinery, of course, will give machinery hazard.
• The finding cannot be specifically supported. There would b
e many machines in the workshop. Does this mean only one m
achine or some machines?

71
Better example of finding (1/2)

• Example finding:

In Room W402, a colleague was found operating the band-sa


w with his hand coming very close to the exposed saw, posin
g a risk of cutting injury.

• Example recommendation:

Push stick and guide can be provided to help feeding the sma
ll workpiece.

72
Other Engineering Control: Guides + Guard

73
Better example of finding (2/2)
• Example finding:
A man was found standing on top of A-ladder,
posing a risk of falling.

• If prominent breach of law observed, better to


express the related possible breach – to show
your professional competency:

• More professional example:


A man was found standing on top of A-ladder
on construction site, posing a risk of falling of
more than 2 meters. Construction Sites (Safe
ty) Regulations (Cap. 59I), Reg. 38B “Prevent
ion of falls”, requires physical control on this t
ype of work.

74
Finding should
• be supported by evidence, such as photo;
• be explained (evidence cannot tell by itself);
• give warning if there is possible non-compliance;
• be organised and prioritized if there are many; can be prioritise
d against order of risks / different types of findings

75
Risk Treatment ( 風險處理 ):

Reference
ISO 31000, 2018, Risk management – Guidelines 76
Designated factories and industrial undertakings with 50 or more workers or
construction contractors with construction work with a contract value of HK$100
million or more shall have a safety management system which contains the
element of “a programme of inspection to identify hazardous conditions and for
the rectification of any such conditions at regular intervals or as appropriate"
(Cap. 59AF, Sch. 4). 

77
After the described risk, how to correct?

• Based on the written finding,


• give the written recommendation for
• corrective action reference

78
E

C
A

Emergency
Preparedness

Reference
Adapted from CDC, U.S.A, at https://www.cdc.gov/features/celebrate-engineers/infographic.html
79
Recommendation should be

• Reasonably practicable
• Shown supported by the corresponding
finding

80
80
Example of well supported recomendation

81
Recommendation should be

• specific and not too general


– e.g. the local law about proper working platform is specific
– e.g. the local law about prevention of falling object is too general
– If the related law states specific measures, you can borrow them. But,
not all laws include such specific measures. The following is e.g.

orr ow
ral to b
gene
Too

82
Recommendation should be
• resulting from discussion with the workplace-in-charge, who is
the ultimate action-in-charge
• with reasonable timeframe for action to be taken
• so arranged to be closed with record of action, completion dat
e and action-in-charge
Laboratory Particulars of non-compliance Risk Rectification Particulars of rectification Date of
Location Level* a.s.a.p., must be completion
completed by

W401 Liquid was found leaked from a 3 15-Jun-2012 All were tidied as follows. 23 May 2012
severe rusting tin. Please clean up by T.L. Yip
the liquid and replace the tin with
another proper container.

Besides, there were no hazard sign


labels for some chemical bottles.
Please affix proper hazard sign
labels onto the chemical bottles.
 
 

83
Best recommendation can link strength & weakness

84
Common means of recording inspection - Checklist

PROPER Checklist can help …


• More systematic way of checking
• Avoid overlooking
• Efficient means of recording and reporting
• Record for follow-up

Drawbacks:
• May have excessive items
• May not address current issue

Reference

Handout Topic: Workplace Safety Inspection Techniques and Reporting, Sec. 5


85
Form 3A,
Cap. 59Z

86
Form 3A,
Cap. 59Z

87
Form 3A,
What is the major difference between
“Dangerous Goods” and “Dangerous
Cap. 59Z
Substances”?

88
Form 3A,
Cap. 59Z

89
What is “A”?

What is “C”?

What is “B”?

What is “D”?

90
90
Sample: Completed Form 3A

Suspended Working Platform

Floor Edges/Openings
Lift Shafts/Openings

91
Sample: Completed Form 3A

This is a finding.
1. What is this type of finding?
3. What is this?
2. Where is the corr. record?

Hoistway

4. Where is the corr. record?


Note: This is an Yes/No item; should be
filled in by either “Yes” or “No”.

5. What item was missed in the “Recommendations”?

92
Form 3B,
Cap. 59Z

93
Form 3B,
Cap. 59Z

94
Form 3B,
Cap. 59Z

95
Form 3B,
Cap. 59Z

96
Inspection process

97
Before inspection

• Review previous accident / inspection / action record


s
• Determine scope of inspection
• Prepare the checklist
• Inform relevant parties (This is not necessary if the concer
ned parties have known such arrangement.)
• Let inspectee know the standard of inspection
• Better to take pictures, but get consent first.
• Plan for any measuring equipment or PPE

98
During inspection

• Put on appropriate PPE to set good example 以身作則


• Don’t perform unsafe act yourself
• Request for accompaniment 結伴同遊
• Communicate your intention 互信互諒
– e.g. What’s wrong with this conversation: Show your green card.
• TALK with key people in the workplace, to get a quick understanding of the wo
rkplace hazards, but not a means to confirm risk
• Point out any immediate risk 開誠布公
• Seek consensus on recommendation 尋求共識
• Record both BAD and GOOD 巨細毋遺、懂得欣賞
• Don’t just paying attention to all the forms, neglecting the related physical cond
ition 坐言起行

99
After inspection

• Send a duplicated inspection record to related workplace-in-c


harge ASAP
• Summarise the findings and recommendations to overseeing
body in a report covering:
– Terms of reference (purpose and scope of inspection [such as when, w
here were inspected and by whom)
– Summary of findings and recommendations (NOT the reproduction of
the checklist, as it includes many non-finding items. If the findings are
many, organised / prioritised grouping under headings can help to dra
w immediate focus.)
– Appendices incl. completed checklist

100
Formal Safety Inspection Report
Other Suggestions

• Records kept for not less than 3 years


• Result to senior management
• Remedial action taken and monitored by s
enior management or safety committee

Reference

Code of Practice on Safety Management, Sec 5.5.4


101

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