“SECRETARY OF LABOR,Complaint,v.LEWIS & LAMBERT METALCONTRACTORS, INC.,Respondent.DECISIONBefore:\u00a0\u00a0\u00a0 BUCKLEY, Chairman;CLEARY, Commissioner.BY THE COMMISSION:This case is before the Occupational Safety andHealth Review Commission under 29 U.S.C. ? 661(i), section 12(j) of the OccupationalSafety and Health Act of 1970, \u00a0 29 U.S.C. ?? 651-678 (\”the Act\”).\u00a0The Commission is an adjudicatory agency, independent of the Department of Labor and theOccupational Safety and Health Administration (\”OSHA\”).\u00a0 It was establishedto resolve disputes arising out of enforcement actions brought by the Secretary of Laborunder the Act an has no regulatory functions.\u00a0 See section 10(c) of the Act,29, U.S.C. ? 659(c).Lewis & Lambert Metal Contractors, Inc., asubcontractor at a building construction site in Fort Worth, Texas, was issued citationsalleging four violations of OSHA’s construction standards.\u00a0 The administrative lawjudge affirmed a citation item concerning an electrical violation because he found thatLewis & Lambert controlled the violative condition and should therefore have abatedit.We affirm this portion of the judge’sdecision.\u00a0 The judge affirmed three other citation items because he found that,although Lewis & Lambert did not create or control the violative conditions, it failedto take reasonable alternative measures to protect its employees.\u00a0 We reverse thejudge’s decision with respect to these citation items.Citation 2, Item 1:\u00a0 Ground-FaultProtection.Item 1 of citation 2 alleges that Lewis &Lambert violated 29 C.F.R. ? 1926.400(h)(1)[[1]] by failing to use either ground-faultcircuit interrupters or an assured equipment grounding conductor program to protect itsemployees on the site from electrical hazards.\u00a0 A compliance officer from OSHAdetermined that ground-fault circuit interrupters had not been installed and that anassured equipment grounding conductor program had not been instituted.\u00a0 The employeeswere using electric tools to perform their work.\u00a0 At the hearing, the employer did not contendthat it had complied with the standard. \u00a0 It instead argued that it neither creatednor controlled the non-complying condition.\u00a0 Lewis & Lambert relied on theSeventh Circuit’s decision in Anning-Johnson Co. v. OSHRC, 516 F.2d 1081 (7th Cir.1975), which held that subcontractors working at a multi-employer construction site maynot be cited for non-serious violations where the subcontractor did not create, control,or have responsibility for the hazardous conditions.\u00a0 Id. at 1091. Lewis &Lambert argued that Walker Construction Company–the project manager and primecontractor–was responsible for safe conditions in general on the project and that Lewis& Lambert lacked the expertise to comply. \u00a0 However, both the compliance officerand Lowry, Lewis & Lambert’s foreman, testified that Lewis & Lambert could haveunilaterally installed a portable, commercially available ground-fault circuitinterrupter.\u00a0 The employer did not show that such things as contractual obligationsor union jurisdictional concerns relieved it of responsibility for or prevented it fromliterally complying with section 1926.400(h)(1).\u00a0 On the basis of this evidence, thejudge properly concluded that Lewis & Lambert was responsible for the workingconditions and had the ability to comply with the standard.\u00a0 Accordingly, item 1 ofcitation 2 is affirmed.Citation 1, Item 1, and Citation 2, Item 2and 3:\u00a0 Guardrails.Item 1 of citation 1 alleges a violation ofsection 29 C.F.R. ? 1926.500(f)(1)(vi)(b)[[2]] in that a wire rope used as aguardrail around an open elevator shaft was too slack to provide protection againstfalling.\u00a0 The standards requires that guardrails have [a] strength to withstand atleast the minimum requirement of 200 pounds top rail pressure with a minim ofdeflection.\”\u00a0 The compliance officer observed two Lewis & Lambert employeesfabricating and installing sheet metal ductwork near an open elevator shaft on the thirdfloor of the new building.[[3]]\u00a0 One of the workers was working in a kneelingposition about three to six feet away from the edge of the open shaft. \u00a0 The flooropening for the shaft was 20 feet wide by 40 feet long, and was guarded by two wire ropesstrung between metal posts embedded in the concrete floor.\u00a0 The posts were about sixto eight feet apart.\u00a0 The top wire rope–which was equipped with a turnbuckle fortightening–sagged about eight inches between posts.\u00a0 When the compliance officerleaned on the top wire rope, it sagged an additional 12 to 16 inches.Items 2 and 3 of citation 2 alleges respectivelythat Lewis & Lambert violated 29 C.F.R. ?? 1926.500(d)(1) and (e)(1)(ii).[[4]]\u00a0Section 1926.500(d)(1) requires that \”[e]very open-sided floor or platform 6 feet ormore above adjacent floor or ground level shall be guarded by a standard railing . . . onall open sides . . . .\” \u00a0 Section 1926.500(e)(1)(ii) requires that employersequip \”every flight of stairs having four or more risers . . . [with] at least onerailing on the open side . . . .\”\u00a0 The compliance officer observed that thestairway landings at four levels of the building were open on one side.\u00a0 the landingswere protected on two sides by I-beams and on a third side by the stairs themselves, butwere open on the fourth side. \u00a0 Conditions were identical on all four levels.\u00a0The potential fall distance was seven feet to the next lower level.\u00a0 The complianceofficer also observed that the stair flights did not have railings on their open sides.Lewis & Lambert contended that it did notcreate, control or have responsibility for the violative conditions.\u00a0 Lowry, Lewis& Lambert’s foreman at the worksite, testified that the wipe rope guardrail asoriginally installed by ironworkers employed by another contractor.\u00a0 Lowry statedthat sheet metal workers are not permitted to work on wire rope guardrails, and that ifthey had done so it would likely have caused a jurisdictional dispute.\u00a0 Snow, avice-president of Lewis & Lambert, testified that the company employed only sheetmetal workers on the project.\u00a0 Snow stated that under prevailing craft unionjurisdictional agreements in the region, sheet metal workers cannot erect or maintain wirerope guardrail, a jurisdictional dispute and possible a job shutdown would occur.\u00a0According to the project manual for the job, Walker was responsible for worker safety,including the responsibility for placing barriers and guardrails around flooropenings.\u00a0 In any event, Snow stated, Lewis & Lambert’s employees did not havethe tools or expertise to perform guardrail work around either the elevator shaft orstairway openings.\u00a0 Snow conceded that it would not have taken much physical effortto tighten the turnbuckle attached to the wire rope guardrail around the elevatorshaft.\u00a0 Forrester, the compliance officer, testifiedthat it would only have taken five minutes to tighten the turnbuckle on theguardrail.\u00a0 Forrester agreed that a jurisdictional dispute would likely result if aniron worker were to install or maintain a wooden guardrail.\u00a0 The compliance officerstated that during and following the inspection, workers employed by Walker corrected thenon-complying elevator shaft and stairway guardrail conditions by installing 2×4 woodenguardrails.Lewis & Lambert’s foreman, Lowry, complainedtwo or three times to the worksite representatives of Baldwin Construction Company andWalker about the lack of adequate elevator shaft and stairway guardrails.\u00a0 Walker’sworksite representative replied that he lacked jurisdiction to correct the safetyproblems.\u00a0 Lowry earlier had Baldwin’s representative write a letter to Walkercomplaining about safety problems at the site.\u00a0 The letter, dated June 5, 1980 (abouteight weeks before the OSHA inspection), mentioned a lack of stairways and referred to\”a number of other safety hazards that I haven’t brought to your attention but I knowyou are aware of . . . .The judge found that the inadequate railingsurrounding the elevator shaft and the lack of railings on the stairway violated the citedstandards and that the two Lewis & Lambert workers were exposed to fall hazards.\u00a0The judge found that Lewis & Lambert had established that it neither created norcontrolled these non-complying conditions.\u00a0 The judge concluded that Walker wascontractually responsible for general job safety–including installing and maintainingguardrails around the elevator shaft and stairway–and that craft union jurisdictionalagreements prevented Lewis & Lambert’s sheet metal workers from erecting ormaintaining wire rope or wooden guardrails without risking a jurisdictional dispute or jobshutdown.\u00a0 The judge also found that Lewis & Lambert was bound by the projectmanual for the job and by its contract with Baldwin, neither of which imposed theresponsibility for erecting guardrails.However, the judge held that Lewis & Lambertfailed to take reasonable alternative measures to protect its employees, citing theCommission’s decision in Anning-Johnson Co., 76 OSAHRC 54\/A2, 4BNA OSHC 1198,1975-76 CCH OSHD ? 20,690 (No. 3694 & 4409, 1976).\u00a0 The judge found that theoral complaints to Walker and Baldwin by Lewis & Lambert’s foreman–coupled with theJune 6, 1980, letter–were not a reasonable alternative measure.\u00a0 In the judge’sview, it should have been evident to Lowry that his complaints to Walker’s on-siterepresentative were not going to be acted upon. \u00a0 The judge therefore concluded thatLowry’s complaints lacked sufficient forcefulness, and that Lowry should have contacted ahigher authority within Walker or had an appropriate officer of Lewis & Lambert doso.\u00a0 In the alternative, the judge held that Lewis & Lambert could havephysically protected its workers by instructing them to wear safety belts tied off to thewire rope guardrail or by providing \u00a0 ladders for them\u00a0 to gain access to theirwork stations.Lewis & Lambert disputes the judge’s findingthat it failed to take reasonable measures to protect its employees.\u00a0 The employerargues that its efforts were realistic and reasonable, and that \”[to] require morespecific measures . . . would be beyond the policy of the Act . . . .\”The Secretary takes issue with the judge’sfinding that Lewis & Lambert did not control the elevator shaft guardrailviolation.\u00a0 The Secretary argues that it would have required no particular effort orexpertise to tighten the guardrail turnbuckle. \u00a0 The Secretary also contends that theemployer was bound under the guidelines of the Sheet Metal Air Conditioning NationalAssociation to replace any guardrails it might have to remove in order to perform itscontract.The Secretary also urges affirmance of thejudge’s conclusion that the employer failed to take reasonable alternative measures.\u00a0The Secretary argues that the letter to Walker was written 55 days before the inspection,\”an unreasonably long time period during which . . . employees were exposed tohazards.\”\u00a0 The Secretary also notes that the letter fails to mention any of thecited hazards and does not indicate that Lewis & Lambert is the complainant.\u00a0 TheSecretary contends that any conversations with Walker that took place before the letterwas written should not be considered because some of the cited conditions did not thenexist.We agree with the judge that Lewis & Lambertdid not create or control the elevator shaft or stairway guardrail violations, largely forthe reasons he assigned.\u00a0 The Commission has recognized that an employer may beprevented from abating a hazardous working condition due to union jurisdictionalrules.\u00a0 See\u00a0 McLean-Behm Steel Erectors, Inc.,\u00a0 78 OSAHRC54\/A2, 6 BNA OSHC 1712, 1715, 1978 CCH OSHD ? 22,812, p. 27571 (No. 76-2390, 1978).\u00a0The record establishes here that Lewis & Lambert employed only sheet metal workers atthe worksite, and that craft jurisdictional agreements prevented those workers fromworking on or building guardrails.\u00a0 Despite the apparent ease with which the elevatorshaft guardrail could have been tightened, Lewis & Lambert’s workers could not haveabated the hazard without risking a jurisdictional dispute and a job shutdown.\u00a0Furthermore, such workers did not have the expertise or materials\u00a0 to fabricateguardrails for the stairs.\u00a0 Under our case law these facts establish that Lewis &Lambert did not create or control the cited guardrail hazards.However, we disagree with the judge’s conclusionthat Lewis & Lambert failed to take reasonable alternative measures.\u00a0 Thealternative efforts a subcontractor is required to make were first discussed in GrossmanSteel & Aluminum, Corp., 76 OSAHRC 54\/D9, 4 BNA OSHC 1185, 1189, 1975-76 CCH OSHD? 20,691, p. 24,791 (No. 12775, 1976)(footnote omitted):[An employer] can . . . attempt to have thegeneral contractor correct the condition, attempt to persuade the employer responsible forthe condition to correct it, instruct its employees to avoid the area where the hazardexists if this alternative is practical, or in some instances provide an alternative meansof protection against the hazard.\u00a0 We therefore expect every employer to make areasonable effort to detect violations of standards not created by it but to which itsemployees have access and, when it detects such violations, to exert reasonable efforts tohave them abated or take such other steps as the circumstances may dictate to protect itsemployees.In a later decision, the Commission stated thatthe steps that must be taken depend upon what is realistic under the circumstances.\u00a0 MayfairConstruction Co., 77 OSAHRC 178\/A14, 5 BNA OSHC 1877, 1977-78 CCH OSHD ? 22,214 (No.2171, 1977).\u00a0 In determining whether an employer has made reasonable efforts to abatea condition, the Commission will examine the employer’s overall conduct rather than anysingle act.\u00a0 See Weisblatt Electric Co., 82 OSAHRC 28\/B3, 10 BNA OSHC 1667,1982 CCH OSHD ? 26,058 (No.79-2537, 1982).\u00a0 At a minimum the subcontractor shouldrequest the general contractor to provide the necessary protection.We conclude that Lewis & Lambert’s effortsto have the guardrail conditions corrected were reasonable and satisfy our Anning-Johnsontest.\u00a0 Lewis & Lambert several times attempted to have the general contractorscorrect the non-complying guardrail conditions.\u00a0 Its foreman had Baldwin’s siterepresentative write a letter to the Walker representative complaining about worksitehazards.\u00a0 The foreman personally raised these issues with Walker’s representativeseveral times before ad after the letter as written.[[5]]\u00a0 As we stated in DutchessMechanical Corp., 78 OSAHRC 59\/B14, 6 BNA OSHC 1795, 1796, 1978 CCH OSHD ? 22,876, p.27,679 (No. 16256, 1978), \”[the employer’s attempts to have the general contractorsremedy hazardous conditions on the worksite through both oral and written communicationsindicate a concern for employee safety and health that is consonant with the goals of theAct.\”\u00a0 In judging the reasonableness of Lewis & Lambert’s conduct, it bearsemphasis that complaints to a general contractor about conditions such as these can nearlyalways be expected to be effective.\u00a0 General contractors have, under Commissionprecedent, been held responsible for such conditions by reason of their generalsupervisory authority and central position on a multiple-employer construction site.\u00a0See, e.g., Olson Construction Co., 77 OSAHRC 176\/A2, 5 BNA OSHC 1857,1859-60, 1977-78 CCH OSHD ? 22,197, p. 26,710 (No. 14683, 1977).\u00a0 We thereforereverse the judge’s ruling that Lewis & Lambert failed to take reasonable alternativemeasures to protect its employees. See Novak & Co., 84 OSAHRC _____, 11BNA OSHC 1763, 1766, 1984 CCH OSHD ? 26,766, p. 34,235 (No. 80-7335, 1984).[[6]]We also reject the judge’s alternative findingthat the Lewis & Lambert employees could have ascended ladders to their work stationsand tied off with safety belts once they reached their work stations.\u00a0 First, becausethe stairways here were unguarded only on the one side adjacent to the interior of thebuilding and a fall would be to the next lower level, it is reasonable to conclude thatclimbing the unguarded stairway was safer than ascending a ladder, especially when toolsand materials were to be transported to work stations.\u00a0 For this reason, the use ofladders would not constitute a reasonable alternative measure.\u00a0 Second, the use ofsafety belts and lanyards was not mentioned a the hearing by either party or the judge asan alternative means of protection.\u00a0 We therefore could not adopt the judge’s findingthat such measures were \”reasonable.\”\u00a0 In any event, the Anning-Johnsondefense does not require an employer to establish that it explored every conceivablemeasure in order to protect its workers from non-complying conditions that it did notcreate or control. \u00a0 It requires only that the employer \”make a reasonableeffort to detect violations . . . [and] exert reasonable efforts to have abated . . ..\”\u00a0 Grossman Steel & Aluminum, 4 BNA OSHC at 1189, 1975-76 CCH OSHDat p. 24,791.\u00a0 The record reflects that Lewis & Lambert has done so here.Accordingly, the judge’s decision is affirmed inpart and reversed in part.\u00a0 Item 1 of citation 1 and items 2 and 3 of citation 2 arevacated.\u00a0 Item 1 of citation 2 is affirmed, without penalty.FOR THE COMMISSIONRAY H. DARLING, JR..\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0EXECUTIVE SECRETARYDATED:\u00a0 OCTOBER 2, 1984FOOTNOTES:[[1]] The standard provides in part: ? 1926.400General requirements. (h) Ground-fault protection–(1) General. . . . [T]heemployer shall use either ground-fault circuit interrupters as specified in paragraph(h)(2) of this section or an assured equipment grounding conductor program as specified inparagraph (h)(3) of this section, to protect employees on construction sites. . . . [[2]] The standard provides:\u00a0 ? 1926.500 Guardrails,handrails and covers. (f) Standard specifications. (1) A standard railing shallconsist of top rail, intermediate rail, toeboard, and posts, and shall have a verticalheight of approximately 42 inches from upper surface of top rail to floor, platform,runway, or ramp level. \u00a0 The top rail shall be smooth-surfaced throughout the lengthof the railing. \u00a0 The intermediate rail shall be halfway between the top rail and thefloor, platform, runway, or ramp.\u00a0 The ends of the rails shall not overhang theterminal posts except where such overhang does not constitute a projection hazard.\u00a0Minimum requirements for standard railings under various types of construction arespecified in the following paragraphs:(vi) Other types, sizes, and arrangements ofrailing construction are acceptable, provided they meet the following conditions:(b) A strength to withstand at least theminimum requirement of 200 pounds top rail pressure with a minimum of deflection[.] [[3]] Lewis & Lambert had contracted withBaldwin Construction Company to fabricate and install portions of the new building’s airhandling system.\u00a0 Lewis & Lambert’s vice-president \”presumed\” thatBaldwin was itself a subcontractor of the prime contractor and project manager WalkerConstruction Company.[[4]] The standards provide:\u00a0 ? 1926.500 Guardrails,handrails, and covers. (d) Guarding of open-sided floors, platforms, and runways.\u00a0(1) Every open-sided floor or platform 6 feet or more above adjacent floor or ground levelshall be guarded by a standard railing, or the equivalent, as specified in paragraph(f)(1)(i) of this section, on all open sides, except where there is entrance to a ramp,stairway, or fixed ladder.\u00a0 The railing shall be provided with a standard toeboardwherever, beneath the open sides, persons can pass, or there is moving machinery, or thereis equipment with which falling materials could create a hazard.(e) Stairway railings and guards. (1)Every flight of stairs having four or more risers shall e equipped with standard stairrailings or standard handrails as specified below, the width of the stair to be measuredclear of all obstructions except handrails:(ii) On stairways less than 44 inches widehaving one side open, at least one stair railing on the open side. . . .\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0[[5]]We disagree with the judge’s conclusionthat Lowry should have complained to a more senior representative of Walker.\u00a0 Nothingin Gotham Electric Co., 78 OSAHRC 1\/A14, 6 BNA OSHC 1265, 1266, 1977-78 CCH OSHD ?22,479, P. 27,095 (No. 16155, 1977)–on which the judge relied for the proposition thatrequests made to the general contractor must be definite and forceful–mandates adifferent result.\u00a0 In that case, the record was not clear as to the nature and extentof requests made to the general contractor to correct certain hazards.\u00a0 6 BNA OSHC at1266, 1977-78 CCH OSHD at p. 27,095.\u00a0 Here , by contrast, the record demonstrates acontinued effort by Lewis & Lambert to have the safety conditions at the worksiteimproved.[[6]]Because Chairman Buckley concludes thatLewis & Lambert established that it took reasonable alternative measures as requiredunder existing Commission precedent, the Chairman does not decide in this case whetherCommission precedent correctly holds that an employer that did not create, control, orotherwise have responsibility for a hazardous condition must further show that it tookreasonable alternative measures.\u00a0 Following the Seventh Circuit decision in Anning-JohnsonCo. v. OSHRC, the Commission reconsidered its own case law on the subject.\u00a0 In Anning-Johnson,supra, and Grossman Steel and Aluminum, supra, the Commission accepted the SeventhCircuit rationale that a non-creating and non-controlling subcontractor is nor liable fornoncomplying working conditions.\u00a0 However, the Commission decided that the employerwho did not have actual or constructive notice of the hazardousness of the conditions.\u00a0 See Anning-Johnson Co., 4 BNA OSHC at 1198, 1975-76 CCH OSHD at pp.24,783-84.\u00a0 The Commission apparently concluded that the duty to take realisticalternative measures followed from the duty stated in section 5(a)(2) of the Act, 29U.S.C. ? 654(a)(2), to comply with standards.\u00a0 However, because section 5(a)(2) ofthe Act mandates employer compliance with specific standards, it is not clear that thisprovision can be the source of an employer’s obligation to take \”alternativemeasures\” beyond or different from what is required by specific standards.\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0\u00a0″