“\ufeff\t\tDocument\t\t\t\t p.hiddenParagraph { visibility:hidden } p { margin-top:0; margin-bottom:0; font-family:Times New Roman; color:WindowText; font-size:10pt; font-size:10pt; } p { font-family:Times New Roman; font-size:12pt; } p.style_Normal { } span.style_DefaultParagraphFont { } table.style_TableNormal { } span.X3AS7TOCHyperlink { color:#000000; text-decoration:none; } p.X3AS7TABSTYLE { } span.BulletSymbol { font-family:’Symbol’; } body { margin-left:0px;margin-top:0px;margin-bottom:0px;margin-right:0px;} div.basic { width:21.59cm;height:27.94cm;} p.hiddenParagraph { font-size:2pt; visibility:hidden; } \t\t\t\t\t\t\t\t\tvar useragent = navigator.userAgent;\t\t\t\t\t\t\tvar navigatorname;\t\t\t\t\t\t\tif (useragent.indexOf(‘MSIE’)!= -1)\t\t\t\t\t\t\t{\t\t\t\t\t\t\tnavigatorname=\”MSIE\”;\t\t\t\t\t\t\t}\t\t\t\t\t\t\telse if (useragent.indexOf(‘Gecko’)!= -1)\t\t\t\t\t\t\t{\t\t\t\t\t\t\tif (useragent.indexOf(‘Chrome’)!= -1)\t\t\t\t\t\t\tnavigatorname=\”Google Chrome\”;\t\t\t\t\t\t\telse\t\t\t\t\t\t\tnavigatorname=\”Mozilla\”;\t\t\t\t\t\t\t}\t\t\t\t\t\t\telse if (useragent.indexOf(‘Mozilla’)!= -1)\t\t\t\t\t\t\t{\t\t\t\t\t\t\tnavigatorname=\”old Netscape or Mozilla\”;\t\t\t\t\t\t\t}\t\t\t\t\t\t\telse if (useragent.indexOf(‘Opera’)!= -1)\t\t\t\t\t\t\t{\t\t\t\t\t\t\tnavigatorname=\”Opera\”;\t\t\t\t\t\t\t}\t\t\t\t\t\t\t\t\t\t\t\t\t\tfunction symbol(code1,code2)\t\t\t\t\t\t\t{\t\t\t\t\t\t\tif (navigatorname == ‘MSIE’)\t\t\t\t\t\t\t\tdocument.write(code1);\t\t\t\t\t\t\telse\t\t\t\t\t\t\t\tdocument.write(code2);\t\t\t\t\t\t\t}\t\t\t\t\t\t\t\t\t\t\t\t\t\u00a0\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\tUNITED STATES\t\t\t\t\t\tOF\t\t\t\t\t\tAMERICA\t\t\t\t\t\t\t\t\t\tOCCUPATIONAL SAFETY AND HEALTH REVIEW COMMISSION\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\tSECRETARY OF LABOR,\t\t\t\t\t\t\t\t\t\tComplainant,\t\t\t\t\t\t\t\t\t\tv.\t\t\t\t\t\tOSHRC DOCKET NO. 13064\t\t\t\t\t\t\t\t\t\tBELDON ROOFING & REMODELING CO.,\t\t\t\t\t\t\t\t\t\tRespondent.\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\tDECISION\t\t\t\t\t\t\t\t\t\tBEFORE BARNAKO, Chairman; MORAN and CLEARY, Commissioners.\t\t\t\t\t\t\t\t\t\tBY THE COMMISSION: A decision of Review Commission Judge J. Paul Brenton,\t\t\t\t\t\t\t\t\t\tdated October 14, 1975, is before this Commission for review pursuant to 29 U.S.C. \u00a7 661(i).\t\t\t\t\t\t\t\t\t\t1\t\t\t\t\t\t\t\t\t\tThat decision, which is attached hereto as Appendix A, affirmed a citation which alleged that\t\t\t\t\t\t\t\t\t\trespondent violated 29 U.S.C. \u00a7 654(a)(2) by failing to install perimeter guarding on a flat roof\t\t\t\t\t\t\t\t\t\tin contravention of 29 C.F.R. \u00a7 1926.500(d)(1).\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\tIn Secretary v. Central City Roofing Co., OSAHRC Docket No. 8173, June 4, 1976, a\t\t\t\t\t\t\t\t\t\tdivided Commission held that 29 C.F.R. \u00a7 1926.500(d)(1) does not apply to flat roofs. That\t\t\t\t\t\t\t\t\t\tdecision is dispositive of the charge in issue in the instant case.\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\tAccordingly, the citation and the penalty assessed therefor are vacated.\t\t\t\t\t\t\t\t\t\tFOR THE COMMISSION:\t\t\t\t\t\t\t\t\t\tWilliam S. McLaughlin\t\t\t\t\t\t\t\t\t\tExecutive Secretary\t\t\t\t\t\t\t\t\t\tDATED: OCT 13, 1976\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t1\t\t\t\t\t\t\t\t\t\tChairman Barnako does not agree to this attachment.\t\t\t\t\t\t\t\t\t\t\u00a0\t\t\t\t\t\t\t\t\t\t\u00a0\t\t\t\t\t\t\t\t\t\tUNITED STATES\t\t\t\t\t\tOF\t\t\t\t\t\tAMERICA\t\t\t\t\t\t\t\t\t\tOCCUPATIONAL SAFETY AND HEALTH REVIEW COMMISSION\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\tSECRETARY OF LABOR,\t\t\t\t\t\t\t\t\t\tComplainant,\t\t\t\t\t\t\t\t\t\tv.\t\t\t\t\t\tOSHRC DOCKET NO. 13064\t\t\t\t\t\t\t\t\t\tBELDON ROOFING & REMODELING CO.,\t\t\t\t\t\tDECISION AND ORDER\t\t\t\t\t\t\t\t\t\tRespondent.\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\tAppearances:\t\t\t\t\t\t\t\t\t\tWilliam E. Everheart, Esq., of Dallas, Texas, for the Secretary of Labor\t\t\t\t\t\t\t\t\t\tMr. Michael Beldon, of San Antonio, Texas, for the Respondent\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\tSTATEMENT OF THE CASE\t\t\t\t\t\t\t\t\t\tJ. Paul Brenton, Judge, OSAHRC\t\t\t\t\t\t\t\t\t\tThis is a proceeding pursuant to section 10 of the Occupational Safety and Health Act of\t\t\t\t\t\t\t\t\t\t1970 (29 USC 651 et seq., hereafter called the Act) contesting a citation issued by the\t\t\t\t\t\t\t\t\t\tcomplainant against the respondent under the authority vested in complainant by section 9(a) of\t\t\t\t\t\t\t\t\t\tthat Act.\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\tThe citation alleges that as the result of the inspection of a workplace under the\t\t\t\t\t\t\t\t\t\townership, operation or control of the respondent, located at 1810 S. Laredo, San Antonio,\t\t\t\t\t\t\t\t\t\tTexas, and described as follows: \u2018Roofing\u2019, the respondent has violated section 5(a)(2) of the Act\t\t\t\t\t\t\t\t\t\tby failing to comply with certain occupational safety and health standards promulgated by the\t\t\t\t\t\t\t\t\t\tSecretary of Labor pursuant to section 6 thereof.\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\tThe citation, which was issued on April 3, 1975, alleges that a serious violation resulted\t\t\t\t\t\t\t\t\t\tfrom a failure to comply with a standard promulgated by the Secretary by publication in the\t\t\t\t\t\t\t\t\t\tFederal Register, and codified in 29 CFR 1962.\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\tThe description of the alleged serious violation contained on said citation states:\t\t\t\t\t\t\t\t\t\tItem 1 \u201829 CFR 1926.500(d)(1) Open sided floor 6 feet or more above the\t\t\t\t\t\t\t\t\t\tadjacent floor or ground level was not guarded by standard railings or the\t\t\t\t\t\t\t\t\t\tequivalent: a. East side of the building.\u2019\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\tThe standard as promulgated by the Secretary provides as follows:\t\t\t\t\t\t\t\t\t\t\u00a0\t\t\t\t\t\t\t\t\t\t\u00a0\t\t\t\t\t\t\t\t\t\tItem 1 \u2018Section 1926.500\u2014Guardrails, Handrails, and Covers\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t(d) Guarding of open-sided floors, platforms, and runways\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t(1) Every opensided floor or platform 6 feet or more above adjacent floor or\t\t\t\t\t\t\t\t\t\tground level shall be guarded by a standard railing, or the equivalent, as specified\t\t\t\t\t\t\t\t\t\tin paragraph (f)(i) of this section, on all open sides, except where there is entrance\t\t\t\t\t\t\t\t\t\tto a ramp, stairway, or fixed ladder. The railing shall be provided with a standard\t\t\t\t\t\t\t\t\t\ttoeboard wherever, beneath the open sides, persons can pass, or there is moving\t\t\t\t\t\t\t\t\t\tmachinery, or there is equipment with which falling materials could create a\t\t\t\t\t\t\t\t\t\thazard.\u2019\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\tPursuant to the enforcement procedure set forth in section 10(a) of the Act, the\t\t\t\t\t\t\t\t\t\trespondent was notified by letter dated April 3, 1975, from Herbert M. Kurtz, Area Director of\t\t\t\t\t\t\t\t\t\tthe San Antonio, Texas, area, Occupational Safety and Health Administration, U. S. Department\t\t\t\t\t\t\t\t\t\tof Labor proposed to assess a penalty for the serious violation alleged in the amount of $500.00.\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\tAfter respondent contested this enforcement action, and a complaint and an answer had\t\t\t\t\t\t\t\t\t\tbeen filed by the parties, the case came on for hearing at San Antonio, Texas, on July 14, 1975.\t\t\t\t\t\t\t\t\t\tFINDINGS OF FACT\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t1. Respondent engages in the business of roofing and remodeling. In so doing it uses\t\t\t\t\t\t\t\t\t\tmaterials shipped into the State of Texas which are manufactured elsewhere.\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t2. Respondent was engaged in reroofing a building at the time the alleged violation\t\t\t\t\t\t\t\t\t\toccurred. It employed six to seven workmen at this work site.\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t3. In order to carry hot tar to the work area a pipe, connected with a pump, was erected\t\t\t\t\t\t\t\t\t\tleading from the tar kettle on the ground up over the roof top at the corner of an offset portion of\t\t\t\t\t\t\t\t\t\tthe building, the pipe being bent over and downward to form a down spout and nozzle over and\t\t\t\t\t\t\t\t\t\tabove this corner of the roof. (Exhibit C\u20131)\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t4. One employee was engaged in carrying the tar to its destination after causing it to be\t\t\t\t\t\t\t\t\t\tpumped into a bucket through the pipe.\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t5. Filling the tar bucket brought this employee no closer to the roof\u2019s edge than three feet.\t\t\t\t\t\t\t\t\t\tUpon filling the bucket he took off over the roof carrying it to the upper portion of the building\t\t\t\t\t\t\t\t\t\twhere the reroofing operation was in process.\t\t\t\t\t\t\t\t\t\t6. A metal rain spout was attached to the roof\u2019s edge. At one side at this corner was a\t\t\t\t\t\t\t\t\t\tutility pole and an adjacent ladder which extended from a loading dock below and used by all\t\t\t\t\t\t\t\t\t\trespondent\u2019s employees in going to and from the ground and the work areas on top. On the other\t\t\t\t\t\t\t\t\t\t\u00a0\t\t\t\t\t\t\t\t\t\t\u00a0\t\t\t\t\t\t\t\t\t\tside was the ground consisting of dirt, grass, and gravel. Also on this side there existed a railroad\t\t\t\t\t\t\t\t\t\ttrack the ties of which had long before settled into the earth\u2019s surface or became covered with\t\t\t\t\t\t\t\t\t\tearth. The nearest rail, which was three inches wide, was six feet four inch from the side of the\t\t\t\t\t\t\t\t\t\tbuilding. The tar machine or kettle was situated on the ground at the corner of the building about\t\t\t\t\t\t\t\t\t\teven with the utility pole.\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t7. The distance from the ground to the roof top at this corner was 15 feet nine inches. The\t\t\t\t\t\t\t\t\t\tdistance from the loading dock, which was concrete, to the roof top is unknown. It may only be\t\t\t\t\t\t\t\t\t\tinferred that it is less than 15 feet nine inches because it would have to be elevated above ground\t\t\t\t\t\t\t\t\t\tlevel to be a dock.\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t8. The corner at this roofs edge was not guarded with a standard railing.\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t9. The reroofing job commenced on March 24, 1975 and was completed on April 3,\t\t\t\t\t\t\t\t\t\t1975.\t\t\t\t\t\t\t\t\t\tISSUES\t\t\t\t\t\t\t\t\t\tWhether the facts and circumstances make a case for a serious violation of the standard\t\t\t\t\t\t\t\t\t\talleged.\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\tWhat amount, if any, should be assessed as a penalty for the violation.\t\t\t\t\t\t\t\t\t\tTYPE OF VIOLATION\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\tCrucial to respondent is the issue of whether a rational conclusion may be adjudged from\t\t\t\t\t\t\t\t\t\tthe evidence that there did in fact exist a substantial probability that death or serious physical\t\t\t\t\t\t\t\t\t\tharm could result from a 15 feet nine inch fall at this location. In order words is the violation\t\t\t\t\t\t\t\t\t\there a section 17(k) of the Act violation. Respondent did not raise as an issue that it did not know\t\t\t\t\t\t\t\t\t\tof the presence of the violation. In fact it tried the case on the proposition that it was completely\t\t\t\t\t\t\t\t\t\taware of the violation.\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\tRespondent aptly argues with authority that complainant is inconsistent in his\t\t\t\t\t\t\t\t\t\tdetermination to classify the violation here as serious, because in most previous cases for the\t\t\t\t\t\t\t\t\t\tsame or similar violation of the same standard he has determined each to be nonserious. In fact in\t\t\t\t\t\t\t\t\t\tmost non-serious cases the height of the fall potential was even greater 36 feet in Secretary v.\t\t\t\t\t\t\t\t\t\tPsaty & Fuhrman, Inc., 9 OSAHRC 447. 25 feet in Secretary v. S. D. Mullins Co., Inc., 4\t\t\t\t\t\t\t\t\t\tOSAHRC 1415. 20 feet in Secretary v. L. I. Dumont, Inc., 11 OSAHRC 158; Secretary v.\t\t\t\t\t\t\t\t\t\tLanger Roofing & Sheet Metal, Inc., 9 OSAHRC 403; and Secretary v. J. F. Probst & Co., Inc.,\t\t\t\t\t\t\t\t\t\t\u00a0\t\t\t\t\t\t\t\t\t\t\u00a0\t\t\t\t\t\t\t\t\t\t11 OSAHRC 373. 30 feet in Secretary v. Heyse Sheet Metal & Roofing Co., 4 OSAHRC 1395.\t\t\t\t\t\t\t\t\t\t18 feet in Secretary v. Moser Keating & Roofing Co., Inc., 6 OSAHRC 77.\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\tAnd in Secretary v. A. B. Hall, d\/b\/a Dixie Roofing & Metal Co., 15 OSAHRC 247, the\t\t\t\t\t\t\t\t\t\tissue was met squarely and forthrightly. There alleged serious violations of 29 CFR\t\t\t\t\t\t\t\t\t\t1926.500(b)(1), unguarded roof openings 166\u2018 above concrete floor below, and 29 CFR\t\t\t\t\t\t\t\t\t\t1926.500(d)(1), unguarded perimeter of flat roof 156\u2018 to 166\u2018 above dirt surface below, were\t\t\t\t\t\t\t\t\t\tmodified by the Administrative Law Judge so that each reflected a non-serious violation.\t\t\t\t\t\t\t\t\t\tMoreover, upon review of this decision the Secretary of Labor, the complainant in the instant\t\t\t\t\t\t\t\t\t\tcase, filed a memorandum therein concluding that the Judge\u2019s decision and order was supported\t\t\t\t\t\t\t\t\t\tby a preponderance of the evidence. Furthermore, the Review Commission unanimously\t\t\t\t\t\t\t\t\t\taffirmed the disposition of the Judge.\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\tApparently under the facts and circumstances of the instant case, an accidental fall was\t\t\t\t\t\t\t\t\t\talways possible although extremely unlikely. Thus, the degree of probable injury in the event of\t\t\t\t\t\t\t\t\t\ta fall is the yard-stick by which a serious from a non-serious violation may be distinguished.\t\t\t\t\t\t\t\t\t\tInquiry must therefore be made with respect to the kind of injury that is reasonably likely to\t\t\t\t\t\t\t\t\t\toccur. Here one surface area of exposure to a fall was composed mostly of grass or sod, and\t\t\t\t\t\t\t\t\t\tsome dirt with a mixture of loose gravel. This certainly is not significantly different than plain\t\t\t\t\t\t\t\t\t\tdirt. True there existed a three inch railroad rail parallel to the roof in this area but the chance of\t\t\t\t\t\t\t\t\t\ta fall thereon in a manner resulting in death or a permanent impairing injury is mere speculation.\t\t\t\t\t\t\t\t\t\tThe other surface exposed to a fall was concrete, however, the length of fall here is unknown\t\t\t\t\t\t\t\t\t\texcept that it is something less than 159\u2018.\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\tAccordingly, it must be concluded, in either situation, the most likely result of an\t\t\t\t\t\t\t\t\t\temployee fall is that he may suffer bruises, concussion, breaks of bones, and similar injuries\t\t\t\t\t\t\t\t\t\twhich are a type of injuries not classified as serious in nature. This conclusion comports with the\t\t\t\t\t\t\t\t\t\treasoning in Dixie Roofing & Metal Co., supra.\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\tMoreover, this tribunal is attracted to the guidelines and the rationale therefor in\t\t\t\t\t\t\t\t\t\tSecretary v. Brown & Kerr, Inc., 13 OSAHRC 221, where it is established that a fall of 20 feet or\t\t\t\t\t\t\t\t\t\tmore on a soil surface and over 15 feet on a concrete surface is an exposure to the possibility of a\t\t\t\t\t\t\t\t\t\tserious injury within the meaning of section 17(k) of the Act. These guidelines are definitive and\t\t\t\t\t\t\t\t\t\tthey hereby are approved and are herein followed.\t\t\t\t\t\t\t\t\t\t\u00a0\t\t\t\t\t\t\t\t\t\t\u00a0\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\tThe violation in this case is therefore determined to be non-serious, consequently the\t\t\t\t\t\t\t\t\t\tcitation should be modified.\t\t\t\t\t\t\t\t\t\tPENALTY\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\tThe $500.00 proposed penalty is inappropriate. Of course it was proposed on the basis of\t\t\t\t\t\t\t\t\t\ta serious violation. Regardless, however, of whether the violation is serious or non-serious the\t\t\t\t\t\t\t\t\t\tsame factors must be considered in assessing a civil penalty in keeping with the commands of\t\t\t\t\t\t\t\t\t\tsection 17(j) of the Act.\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\tRespondent had no history of previous violations, its good faith is apparently good and\t\t\t\t\t\t\t\t\t\tthere were only seven employees on the job site. More importantly, just one employee was\t\t\t\t\t\t\t\t\t\texposed intermittently to the possibility of falling off this roof over a period of about eight days.\t\t\t\t\t\t\t\t\t\tMost significantly the facts and circumstances show that the degree of probability of occurrence\t\t\t\t\t\t\t\t\t\tof an injury is so minimal that it is practically non-existent. Therefore, the gravity of the\t\t\t\t\t\t\t\t\t\tviolation is moderate to the point of being exceedingly low. A penalty in the amount of $50.00 is\t\t\t\t\t\t\t\t\t\ttherefore deemed appropriate and the notification of penalty to be assessed should be modified\t\t\t\t\t\t\t\t\t\taccordingly.\t\t\t\t\t\t\t\t\t\tCONCLUSIONS OF LAW\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t1. The Review Commission has jurisdiction to hear and decide this case.\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t2. The kind of injury to be reasonably expected upon exposure to a hazard is measured by\t\t\t\t\t\t\t\t\t\tthe facts and circumstances surrounding the situation then and there existing in making a\t\t\t\t\t\t\t\t\t\tdistinction between a non-serious and serious violation.\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t3. An exposure to a fall of less than 20 feet upon a soil surface below ordinarily will be\t\t\t\t\t\t\t\t\t\tdeemed a non-serious violation. If 20 feet or more it ordinarily will be deemed a serious\t\t\t\t\t\t\t\t\t\tviolation.\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t4. An exposure to a fall in excess of 15 feet upon a concrete surface below ordinarily will\t\t\t\t\t\t\t\t\t\tbe deemed a serious violation. If 15 feet or less it ordinarily will be deemed a non-serious\t\t\t\t\t\t\t\t\t\tviolation.\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t5. An appropriate penalty for the violation is $50.00.\t\t\t\t\t\t\t\t\t\tORDER\t\t\t\t\t\t\t\t\t\tWherefore, it is Ordered that:\t\t\t\t\t\t\t\t\t\tThe citation be and it hereby is, modified by deleting therefrom the serious violation as\t\t\t\t\t\t\t\t\t\tcharged, substituting therefor a non-serious violation, and affirmed as modified.\t\t\t\t\t\t\t\t\t\t\u00a0\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\tThe notification of $500.00 proposed penalty to be assessed be and it hereby is, modified\t\t\t\t\t\t\t\t\t\tby reducing it by the sum of $450.00 for a total of $50.00 to be assessed as the penalty for the\t\t\t\t\t\t\t\t\t\tviolation.\t\t\t\t\t\t\t\t\t\tIt is so ordered at Dallas, Texas.\t\t\t\t\t\t\t\t\t\tJ. Paul Brenton,\t\t\t\t\t\t\t\t\t\tJudge\t\t\t\t\t\t\t\t\t\tDate: October 14, 1975\t\t\t\t\t\t\t\t\t\t\t\t\t”