CC BY
23
https://doi.org/10.29013/EJLPS-21-2-28-36
Ho Thi Huong Loan, Master, University of Fire Prevention and fighting, Vietnam
E-mail: [email protected]
FINISHING ADMINISTRATIVE PENALTIES IN FIRE PREVENTION AND FIRE FIGHTING IN VIETNAM - THEORETICAL AND PRACTICAL ISSUES OF APPLICATION
Abstract. Sanctions for administrative violations in general and administrative sanctions in the field of fire prevention and fighting are always concerned. The study of the above problem has a very important meaning in perfecting the theory as well as the legal basis for the application of sanctions. The article focuses on clarifying the theoretical and legal issues on sanctioning of administrative violations in the field of fire prevention and fighting; practical application of sanctions on administrative violations in the field of fire prevention and fighting, thereby drawing problems and shortcomings from the provisions of the law as well as from practical application, thereby proposing perfecting the provisions of the law on sanctioning of administrative violations in the field of fire prevention and fighting according to the competence of the fire prevention and fighting police force.
Keywords: Sanctions sanctioning administrative violations; fire prevention and fighting.
1. Place the problem To well implement the work of ensuring fire
In the current situation, when the country is ef- prevention and fighting safety, one of the impor-
fectively implementing the Party's renovation policy and the industrialization and modernization of the Party, our economy has grown strongly, and foreign investment has been continuously invested every year. increase. Along with that is the strong development of industrial parks, export processing zones, hightech zones, commercial centers, high-rise apartment buildings, gas stations, oil, ... Besides, daily residents Increasingly, especially in big cities and industrial provinces, there are many factors leading to the risk of fire and explosion as well as the warning ofviolations offire prevention and fighting regulations. big. According to the Fire and Rescue Police Department - Ministry of Public Security, in 2020, there will be 2,764 fires, killing 75 people, injuring 144 people, destroying property worth 932,023 billion dong. and 1,411.7 ha of forest; There were 33 explosions, killing 14 people and injuring 40 people. Compared to 2019, the number of fires decreased by 1,026 cases, down by 27.07%; the number ofexplosions increased by 053, up 17.81% [1].
tant solutions is to strengthen the inspection and sanctioning of administrative violations. However, the sanctioning of administrative violations in the field of fire prevention and fighting is facing many difficulties, partly due to the legal documents on sanctioning administrative violations in the field of fire prevention and fighting. still incomplete such as: There are unclear and specific regulations leading to inconsistent application; regulations on competence, measures to sanction administrative violations, the level of fines for some administrative violations are still unreasonable ...
2. Research results
2.1. Theoretical and legal basis for the sanctioning of administrative violations in the field offire prevention and fighting
Administrative violation is a type of law violation that is quite common in social life. Although its level of danger to society is lower than that of crime, an administrative violation is an act that causes damage or
threatens to cause damage to the interests of the State, the collective or the interests of individuals. The cause of crime arises in all areas of social life if it is not prevented and handled in time. The field of fire prevention and fighting is a field in social life related to the assurance of safety, life, health and property of citizens, agencies and organizations; related to security, order, environment. Accordingly, the administrative violation in the field of fire prevention and fighting is the faulty act committed by individuals or organizations, violating the provisions of the law on state management of fire prevention and fighting without having to is a crime and in accordance with the law must be sanctioned for administrative violations.
The sanctioning of administrative violations in the field of fire prevention and fighting is the coercive activity of state power in order to apply administrative sanctions, performed by the entities authorized by the State and performed against individuals. and organizations committing administrative violations in the field of fire prevention and fighting according to the order and procedures prescribed by law. The sanctioning of administrative violations in the field offire prevention and fighting has the following characteristics: applicable to individuals and organizations committing administrative violations in the field of fire prevention and fighting; conducted by authorized entities in accordance with the law; be conducted according to the principles and procedures prescribed by law; The results ofsanctioning administrative violations in the field of fire prevention and fighting are shown in decisions on administrative sanctions.
The sanctioning of administrative violations in the field of fire prevention and fighting is done on the basis of general provisions on sanctioning of administrative violations and legal provisions on sanctioning of administrative violations in the field of fire prevention. and fire fighting. Including: Law on handling of administrative violations in 2012; Decree No.81/2013/ ND-CP dated July 19, 2013 of the Government detailing a number of articles and measures to implement the Law on Handling of Administrative Violations;
Decree No.97/2017/ND-CP dated August 18, 2017 of the Government amending and supplementing a number of articles of the Government's Decree No. 81/2013 / ND-CP dated July 19, 2013 on details a number of articles and measures to implement the Law on Handling of Administrative Violations; Law on Fire Prevention and Fighting in 2001; Law amending and supplementing a number of articles of the Law on Fire Prevention and Fighting in 2013; Decree No.167/2013/ND-CP dated 12/11/2013 of the Government stipulating the sanction of administrative violations in the field of social security, order and safety; Prevention of social evils; fire prevention and fighting; domestic violence prevention, combat; Standards and standards in the field of fire prevention and fighting such as: QCVN06: 2020/BXD National technical regulation on fire safety for houses and buildings; TCVN5738: 2001 Automatic fire alarm system - Technical requirements; ...
Acts of administrative violation in the field of fire prevention and fighting are specified in Decree No. 167/2013/ND-CP, divided into 22 groups as groups of violations in the promulgation of regulations. change and organize the implementation of regulations and rules on fire prevention and fighting; group of violations of regulations on inspection of fire prevention and fighting safety; group of violations on the records of management of the safety of fire prevention and fighting; .
Also according to Decree No.167/2013/ND-CP on sanctioning of administrative violations in the field of fire, the forms of administrative sanctions include: Main sanctions and additional sanctions. For each administrative violation, the violating individual or organization shall be subject to a main sanctioning form; The main form of penalty may be associated with one or several additional forms of sanctions. The main form of punishment includes 2 forms: warning and fine. Additional sanctioning forms are: Confiscation of material evidences of administrative violations and means used in committing administrative violations; expulsion.
In many cases, in addition to the application of administrative sanctions, organizations and individuals committing administrative violations in the field of fire prevention and fighting may also be subject to remedial measures due to administrative violations caused such as: Forcible preservation, arrangement, arrangement, reduction of quantity, volume, types of substances, goods at risk of fire and explosion according to regulations; forcible movement of dangerous inflammables and explosives caused by administrative violations to warehouses or locations according to regulations; forced restore to the original state; forced overcoming conditions to ensure safety for fire prevention and fighting; ...
2.2. Practical application of sanctions against administrative violations in the field of fire prevention and fighting
According to the Government's report, from 2014 to 2018, the authorities issued a decision to sanction 98,384 violations of fire prevention and fighting, with the total amount paid to the state budget of206 billion VND; suspended 1,956 cases, temporarily suspended 2,720 cases and fined more than 2,035 cases [2]. As such, the frequently applied sanctioning decision is a fine decision. The reason is that the procedure for applying the fine form is quick and easy to implement, the form of the fine has a direct impact on the economic interests of the violator, so it is highly educational and deterrent. Most administrative violations of fire prevention and fighting are carried out by organizations such as markets, trade centers, supermarkets; high-rise buildings; schools; industrial zones, industrial clusters, cottage industry clusters; business establishments with premises for rent; service establishments (bars, karaoke, discos, clubs, ...). The group ofviolations that happened a lot was the group ofvio-lations regarding the equipment, preservation and use of fire prevention and fighting means; group of acts of violating regulations on fire prevention and fighting in design, installation, management and use of electricity and group of acts ofviolation of regulations on formulation and practice of fire-fighting plans.
In addition to the above results, the practical application of sanctions for administrative violations in the field of fire prevention and fighting still has shortcomings and limitations. Some legal regulations on sanctioning administrative violations in the field of fire prevention and fighting are incomplete, unclear and specific, making it difficult for the selection and application process in sanctioning administrative violations with the cases, detail:
- Regarding the regulations on authorization, delegation of powers and absence in the 2012 Law on Handling of Administrative Violations, it is unclear and difficult to apply. Specifically, the 2012 Law on Handling ofAdministrative Violations stipulates the delegation of sanctioning rights to deputies, but there is no regulation or guidance for deputies to be authorized to apply preventive measures and ensure the sanctioning of administrative violations; as well as there is no specific guidance on what is the case of the "absentee" case of the head (Article 87), making it difficult to apply in practice;
- Clause 2 and Clause 3 Article 61 of the Law on handling of administrative violations in 2012 have the same provisions on the explanation for administrative violations, but there are two ways to specify the time limit according to "days" and "working days". The above provisions lead to many difficulties in calculating dates, especially in the case of making minutes of violation and making decisions coinciding with holidays, New Year holidays;
- According to Clause 1, Article 61 of the Law on handling of administrative violations in 2012, if individuals, organizations are subject to confiscation of material evidences, means of administrative violations or means used in administrative violations will not having the right to explain is unreasonable, affecting the rights and interests of the subjects subject to the measure of confiscation of material evidences and means of administrative violations. Because in many cases, even many exhibits and means are worth many times higher than the fined amount of 15 million dong or 30 million dong;
- Clause 3, Article 61 of the Law on handling of administrative violations in 2012 stipulates: "In case of direct explanation, violating individuals and organizations must send written requests to be explained directly to competent persons. sanction administrative violations within 02 working days from the date of making the record of administrative violation ". Meanwhile, Clause 2, Article 61 stipulates: "In case of written explanation, violating individuals or organizations must send written explanations to the persons with competence to sanction administrative violations during the period. within 05 days from the date of making the record of administrative violation ". Thus, in the minutes of administrative violations, the time limit for submitting the request for explanation of individuals or organizations is 2 working days or 5 days. If inserting 05 days but the individual or organization requests direct explanation, then the inscription of the time limit as above will be contrary to Clause 3 Article 61. If inserting 02 working days, when the time limit expires, the individual or organization If you want to be explained in writing but have not yet sent your written explanation, how will it be handled?
- In Clause 1, Article 66 of the Law on handling of administrative violations in 2012 states: "In the case of a particularly serious case, with many complicated details and subject to explanation as prescribed in paragraph 2, Clause 2 and Clause 2. 3 Article 61 of this Law, if it takes more time to verify and collect evidence, the competent person who is handling the case must report in writing to his/her direct head to apply for an extension; The extension must be in writing, the extension must not exceed 30 days ". But the Law does not specify and unify what is "a particularly serious case with many complicated details" or "an authorized person handling the case" according to Clause 1, Article 66 above;
- Article 3 of Decree No.81/2013/ND-CP stipulates "The time limit for deprivation of the right to use licenses, practice certificates for administrative violations must be specified in a specific time frame,
the distance between the minimum and maximum stripping time is not too great ". However, at present, there are no legal documents guiding how to determine the time limit for deprivation of the right to use a specific license or practice certificate for a violation, so in practice, is there any less difficulty;
- Clause 4, Article 30 of Decree No.167/2013/ ND-CP stipulates: "A fine of between VND15,000,000 and 25,000,000 for acts of illegally storing substances or goods at risk of fire and explosion". However, at present, there is no specific regulation on storing how many kg, illegally storing substances, goods at risk of fire and explosion; especially in the gasoline and oil sector;
- Clause 1, Article 47 of Decree No.167/2013/ ND-CP on violations of regulations on fire and explosion prevention and fighting in households that stipulate: "A fine of between VND300,000 and 500,000 for acts of unintentionally violating the regulations on safety of fire prevention and fighting so that a fire or explosion occurs without causing damage or causing less than 25,000,000 VND ". In fact, there are still many shortcomings and obstacles in dealing with the acts to cause fire and explosion without causing damage or causing damage below 25,000,000 VND. As households, small business households, because this object is mostly households, when a fire occurs, it often leads to problems related to people's lives and emotions. Therefore, it is very difficult to deal with these objects' behavior to cause fire, almost impossible. In addition, there are fires and explosions that cannot be sanctioned for administrative violations, especially fires and explosions that occur in mountainous areas, economically difficult areas or households that When a fire happened, the fire destroyed all the property.
Besides, through the survey, the shortcomings and limitations also stem from the practice of sanctioning administrative violations in the field of fire prevention and fighting. In fact, the implementation of the provisions of the law on handling of administrative violations in the field of fire prevention and fighting has had certain effects, contributing to
deterrent, prevent and limit administrative violations offire prevention and fighting. However, the current sanction of administrative violations in the field of fire prevention and fighting still faces difficulties and problems that need to be removed such as:
- Article 70 of the 2012 Law on handling of administrative violations stipulates the time limit for sending decisions to sanction administrative violations within 2 days, this provision is difficult to implement due to the huge volume of decisions to sanction administrative violations. Many violators do not have stable residence or have little presence in the locality or the address stated in papers is different from the actual residence address;
- The postponement of the execution of the decision on sanctioning the administrative violation in fire prevention and fighting has not been stipulated for the organization. Article 76 of the Law on handling of administrative violations in 2012 stipulates that only individuals are allowed to postpone execution of the fine decision, but in reality, many enterprises that are sanctioned for administrative violations also have financial difficulties, losing business. so the fine cannot be paid on time;
- Some organizations and individuals do not cooperate with the fire prevention and fighting safety inspection force; intentionally evading the inspection team, making it difficult for the Fire department when determining the administrative violation in fire prevention and fighting. Multi-family houses (miniapartments) at the time of construction with the intended use are residential houses (separate houses), but during the operation, the owners voluntarily sell or lease out apartment; In a number of mini-apartments, the head of the household has sold out all the apartments, is not present at the facility and does not send a representative to work, so the inspection is facing many difficulties;
- The force directly engaged in the task of instructing and inspecting the safety of fire prevention and fighting is still thin, does not ensure the quantity as prescribed, while the establishment is under the
management of many, large areas; Inspection officers in charge of many facilities have led to a situation in which the management of the area and facility is not closely involved, and has not promptly detected the violations of the facility as well as the current situation of fire prevention and fighting. local authorities to promptly advise leaders, at all levels, especially local authorities, to work out appropriate leadership and direction methods;
- The identification of the object that is sanctioned for an administrative violation in fire prevention and fighting has a number of unknown points, making it difficult for the analysis and assessment of the administrative violation in fire prevention and fighting. Specifically, in Clause 10, Article 2 of the Law on handling of administrative violations in 2012 stipulates "Organizations are state agencies, political organizations, socio-political organizations, socio-political professional organizations, organizations. social organizations, professional social organizations, economic organizations, people's armed forces units and other organizations established in accordance with the law ". However, in practice, for the case of an individual business household, it is difficult to identify as an organization or an individual when committing an administrative violation. According to Article 66 of the Government's Decree No.78/2015/ND-CP dated September 14, 2015 on enterprise registration, "A business household is made up of an individual or a group of individuals. Vietnamese citizens who are full 18 years old, have full civil capacity, or one household owner, are only allowed to register for business in one location, employ less than ten employees and bear full responsibility Your assets over your business. ". These signs indicate that business households can be divided into three categories: Household businesses owned by one individual; A household business is owned by a household and a household business is owned by a group of people. Therefore, individual business households can be understood as individuals or organizations. In Decree No.185/2013/ND-CP dated
November 15, 2013 of the Government stipulating the sanctioning of administrative violations in commercial activities, production and trading of counterfeit goods, banned goods and protection of the interests of people. Consumers identify households as individuals but only apply within this Decree, while in Decree No.167/2013/ND-CP, business households are not defined as individuals or organizations. This makes it difficult to identify the subject of administrative sanctions;
- The enforcement of enforcement of a decision on sanctioning of administrative violations still faces many difficulties because the sanctions specified in the Law and Decree are not strong enough, leading to the situation that many individuals and organizations shirk not to accept and execute the decision. or delayed execution of the decision. Some individuals with small businesses with unstable business locations, mainly renting space for business, often show signs of evasion when executing the sanctioning decision. In reality, there are establishments and households that, when fires and explosions occur, they must be sanctioned for administrative violations according to regulations, but due to lack of economic conditions and difficult circumstances, they cannot execute sanctioning decisions. . Some families with meritorious services to the revolution, war invalids, sick soldiers, policy families, ... the promulgation or enforcement of sanctioning decisions of the authorities also faced many difficulties;
- The acts of administrative violation of fire prevention and fighting in investment and construction of high-rise apartment buildings, commercial centers, ..., the fine level is still low, not enough to discourage. The Investor, due to the timely request of the project, has accelerated the hand-over of the project while still not ensuring the safety of fire prevention and fighting. Home buyers want to have a place to live early, so they still stay in even though the project is not safe in terms of fire prevention and fighting. The sanction level for administrative violations for this act according to Decree No.167/2013/ND-CP
is from VND30,000,000 to VND50,000,000, and the cost for completing the fire prevention and fighting system. burning up to billions of dong. Therefore, many investors have chosen to accept the penalty;
- In some provinces, cities, many apartment buildings violate regulations on fire prevention and fighting but slow to remedy the violations. Among them, the resettlement apartments with slow recovery have a significant number. These are the apartment buildings that were put into use more than a decade ago, so the basic infrastructure cannot meet the requirements of fire prevention and fighting; fire prevention and fighting equipment has been severely degraded, containing a high risk of fire and explosion. Although there is a decision to require the facilities to overcome shortcomings of fire prevention and fighting, the progress of the treatment is slow because there are works related to the structure and use of the utility, and requires a large investment;
- The application of administrative sanctions for social welfare establishments such as hospitals, schools, markets, commercial centers or houses for living in combination with business is common. many difficulties are almost impossible to implement because it directly affects the rights and life of the people;
- Some regulations of the law on fire prevention and fighting are overlapping with other provisions of the law such as: Regulations on the application of standards and regulations on fire prevention and fighting, according to the provisions of the Law. Fire prevention and fighting, fire prevention and fighting standards are compulsory standards to be applied. However, according to the Law on Standards and Technical Regulations, standards are only encouraged to apply, which has caused many difficulties for the application of the law;
- Some administrative violations in the field of fire prevention and fighting specified in Decree No. 167/2013/ND-CP have a low fine level, not enough to discourage, leading to the willingness of the establishment. committing a number of acts
to bring economic benefits compared to having to comply with the requirements of fire prevention and fighting standards and standards, most commonly the acts related to safety distance. solutions for fire prevention, escape and transportation of substances and goods at risk of fire and explosion; Some behaviors with low penalties lead to the establishment's willingness to pay the fine, but not remedy because the economic efficiency calculation between the fine payment and the remediation of the violation will be many times larger than the amount of the fine;
- Clause 1, Article 33 of Decree No.167/2013/ ND-CP on the violation of regulations on fire prevention and fighting in the use offire sources, heat sources, fire-generating equipment and tools, stipulates: "Fine warning or a fine of from 100,000 VND to 300,000 VND for acts of using matches, lighters, cell phones in places where regulations are prohibited ". Point a, Clause 3, Article 33 of Decree No.167/2013/ND-CP on the violation of regulations on fire prevention and fighting in the use of fire sources, heat sources, fire-generating equipment and tools, stipulates: " A fine ranging from VND2,000,000 to VND5,000,000 shall be imposed for using fire sources, electronic equipment or other devices and tools that generate fire or heat in places where prohibited by regulations ". The above provisions are still confusing, ambiguous and the feasibility is not high because the term "electronic device" here is too wide, almost any type of machine can now be listed in electronic equipment such as cameras. digital, television, ... In fact, at the gas station, many people still use cell phones indifferently, while the functional forces are thin, unable to be on duty to punish, if they want to punish them. It's not easy either.
2.3. Supplement and complete the legal basis for the sanctioning of administrative violations in the field of fire prevention and fighting
Accordingly, it is necessary to study amending and supplementing the legal provisions on handling of administrative violations in the 2012 Law on Handling of Administrative Violations, Decree No.81/2013/ ND-CP, Decree No.97/2017/ND-CP:
- On the assignment of powers: Article 54, Article 87, Article of administrative violation The Law on handling of administrative violations in 2012 stipulates the assignment of the right to sanction to the deputies. However, the Law should have specific regulations and instructions to avoid understanding and different application of deputies authorized to apply measures to prevent and ensure the sanction of administrative violations.
The Law on handling of administrative violations should be amended and supplemented in the direction that the heads are empowered by deputies in all decisions about handling administrative violations in general and decisions on sanctioning administrative violations. Particularly, not limited to 03 cases specified in Article 54, Clause 2 Article 87 and Clause 2 Article of administrative violation:
- The Law on handling of administrative violations in 2012 and the guiding documents need to have specific instructions on how to identify the case of a "absent" head (Article 87), to avoid causing embarrassment in the application. in practice;
- Regarding the transfer of dossiers of violations with criminal signs for criminal prosecution: The Law needs to clearly state that when transferred to investigation agencies, material evidences and means of administrative violations will be temporarily seized by the agencies. How to manage, who will pay for it, how to deal with custody procedures in this case;
- It is necessary to study and clarify how to calculate time, time limit, statute of limitations in the direction of unifying time by working day to remove difficulties in practical application;
- Clause 1, Article 61 of the Law on handling of administrative violations needs additional regulations on the right to explain in case violators are subject to the measure of confiscation of material evidences, means of administrative violation or means used in the administrative violation is to suit the practice and the rights and interests of the violator, because in many cases, many material evidences and
means of violation have a value many times higher than the number of violators. fine money;
- Regarding the postponement of execution of decisions on sanctioning of administrative violations The Law should supplement regulations applicable to organizations. According to Article 76 of the Law on handling of administrative violations in 2012, only individuals are allowed to postpone execution of the fine decision, but in reality, many enterprises that are sanctioned for administrative violations also have financial and business difficulties. losing money so the fine cannot be paid on time;
- There should be unified guidance on how to determine the time of deprivation of the right to use a specific license or practice certificate for an administrative violation.
In addition, it is necessary to study amending and supplementing the legal regulations on handling of administrative violations in Decree No. 167/2013 / ND-CP:
- It is necessary to have a document specifying how many kilograms of stock are stored, which means illegal storage of substances or goods at risk of fire and explosion; especially in the field of petrol and oil, the provisions in Clause 4, Article 30 of Decree No.167/2013/ND-CP are: "A fine of between VND15,000,000 and 25,000,000 for acts of stockpiling illegal substances and goods in danger of fire and explosion";
- It is necessary to study to amend to suit the form of sanctions for violations of regulations on fire and explosion prevention and fighting in households in Article 47 of Decree No.167/2013/ND-CP because when a fire occurs, Damaged property, household has no fine to pay; on the contrary, the larger the property damage, the higher the fine, making it difficult for the household;
- In Article 32 of Decree No.167/2013/ND-CP on violations ofregulations on transporting substances or goods at risk of fire and explosion, stipulating the application of remedial measures specified at Point a, Clause 7, The Decree is not accurate because there is
no Point a Clause 2, which is proposed to be revised as "Forcible rearrangement of substances or goods at risk of fire and explosion in accordance with the provisions of the act specified in Clause 2 of this Article";
- The Law on handling of administrative violations stipulates that the maximum fine level in the field of fire prevention and fighting remains low (maximum VND50,000,000 for individuals; VND100,000,000 for organizations), not yet guaranteed. deterrence, corresponding to the nature and level of the actual violation. Therefore, it is necessary to propose an increase in the level of sanctions to ensure deterrence, commensurate with the nature and level of the actual violation. Regarding this content, the Ministry of Public Security has submitted a petition to the Ministry ofJustice; On the other hand, it is necessary to propose to the competent authorities when amending and supplementing Decree No.167/2013/ND-CP to supplement the violations and sanctions for violations in the field of rescue. rescue to create a uniform legal basis for application.
3. Conclusion
The application of sanctions for administrative violations in all fields of social life in general and in the field of fire prevention and fighting in particular has important implications. The rational and feasible provisions of sanctions in administrative sanctions on fire prevention and fighting not only have the effect of preventing acts of violating the regulations on fire prevention and fighting but also have a deterrent effect. threaten and punish individuals and organizations that fail to strictly comply with the law provisions on fire prevention and fighting. The above article has outlined the theoretical and legal issues about the sanction as well as the practice of applying the sanctions against administrative violations in the field of fire prevention and fighting over the past time. issuing, supplementing and perfecting laws to remove difficulties, problems and shortcomings in the implementation process, thereby contributing to improving the efficiency and effectiveness of state management on fire prevention and fighting in the next time.
References:
1. Government of the Socialist Republic ofVietnam (2019). Report No.33/BC-CP dated May 23, 2019 of the Government on the implementation of policies and laws on fire prevention and fighting the period 2014-2018.
2. Department of Fire Prevention, Fighting and Rescue - Ministry of Public Security (2014), System of legal documents on fire prevention, fighting and rescue and rescue.
3. The Department of Fire Prevention, Fighting and Rescue and Rescue (2020), Report on summary of work in 2020, Hanoi.
4. National Assembly (2013). Law on Fire Prevention and Fighting in 2001 and Law amending and supplementing a number of articles of Law on Fire Prevention and Fighting in 2013.
5. National Assembly of the Socialist Republic of Vietnam (2012). Law on Handling of Administrative Violations.
