Document e5BVYbdqBg1GZqGnDpXrkYd14

TO: Interoffice Communication FROM: DATE: SUBJ: Distribution XF: T. G. Grumbles February 12, 1991 VISTA REQUEST FOR COMMENTS OF DRAFT EMPLOYEE HEALTH AND SAFETY Attached is a draft of the Responsible CARE Employee Health and Safety Code. Please review the Code and provide me comments by March 20. I'll send collective comments to CMA. CMA has provided some specific questions to address (last 2 pages of attachment), but we also need comments on specific elements of the Code you have questions or concerns about. In general, you should consider whether the Code elements are understandable and clear in terms of what you would do to develop or improve programs in the element areas. At this point "wordsmithing" is also acceptable, but perhaps less important. We can discuss this briefly at the meeting on the 28th. T. G. Grumbles SAFETY DIRECTORS o-Aber, J. D. Harris-Balt, Harry Peirce-Blane, Kathy K. L. Fogg-LCCP, R. V. Gantz-LCLAB, G. M. Shirley-LCVCM, White-Okc, R. B. Martin-Austin, J. R. Drumwright, Rick Quy cc: PLANT MANAGERS R. W. Seymour-Aber, L. R. Bauer-Balt, G. D. Williams-Blane, J. Pavao-Hmd, J. Friend-LCCP, J. W. Ware-LCLAB, R. A. Conrad-LCVCM, H. D. Garrison-Okc, P. L. Foote-Prem, V. W. Weiss-Austin T. H. Huffman vvv 000011809 CHEMICAL MANUFACTURERS ASSOCIATION February 4, 1991 TO RESPONSIBLE CARE COORDINATORS Subject: Draft Employee Health and Safety Code of Management Practices and Member Self Evaluation Form Dear Responsible Care Coordinator: The draft Responsible Care Employee Health and Safety Code of Management Practices is enclosed for your Company's review. This code was developed by CMA's Health and Safety Committee through a code drafting group of occupational health and safety professionals representing a broad range of member companies (roster enclosed). Please review the draft code and provide your comments to CMA by April 1, 1991. A response form is enclosed for your convenience. Employee Health and Safety Code of Management Practices The goal of the Employe* Health and Safety (EHS) Code of Management Practices is to protect the health and safety of all persons working on or visiting the worksite. The EHS code complements the Process Safety Code of Management Practices to help ensure the safe operation of member company plants. The elements of the EHS code address identifying and assessing hazards, maintaining employee health, preventing unsafe acts and conditions, and communicating work practices and hazards to employees, contractors, and visitors to the worksite. Many of the code elements parallel requirements of regulations under the Occupational Safety and Health Act (OSHA). However, the scope of this code goes beyond OSHA requirements as follows: o The code requires that contractors have health and safety programs for their employees that are consistent with applicable sections of the code; o The code requires that companies develop mechanisms for determining trends in health and safety data; and o The code requires opportunities for employees to participate in the development, implementation, and review of health and safety programs. The code is an obligation of CMA membership and requires the commitment of all levels of management to the goal of providing a safe and healthful working environment. , 2501 M Street, NW, Washington, DC 20037 202-887-1100 Panafax 202-887-1237 Telex 89617 (CMA WSH) Responsible Care Coordinators February 4, 1991 Page 2 A proposed glossary of terms used in the code is also enclosed. All of the terms have not yet been defined, and suggestions from reviewers are welcome. The EHS code provides guidance to member companies on practices intended to achieve continuous improvement in employee health and safety. With this in mind, a proposed member self-evaluation form is also enclosed for your review. Earlier drafts of the EHS code were reviewed by the Responsible Care Public Advisory Panel. In addition, this draft of the EHS code reflects advice and comments from CMA's Responsible Care Coordinating Group, Health and Safety Committee, Engineering and Operations Committee, and other CMA task groups. March 7. 1991, Open Meeting in Atlanta The code drafting group will hold an open meeting on Thursday, March 7, 1991, from 8:00 a.m. to 5:00 p.m., at the Hyatt Atlanta Airport. This open meeting will give representatives of your company an opportunity to ask questions and raise any specific concerns you may have about the code. An agenda for the open meeting is enclosed. If you or a representative of your company is interested in attending this open meeting, please complete the enclosed registration form. A registration fee of $75 will be charged to each attendee to cover meeting expenses, including lunch and break refreshments. Please submit the registration form and fee by March 1, 1991. Written Comments To assure that all member companies have an opportunity to review the code before it is sent to CMA's Board of Directors.for approval in September 1991, please submit any comments your may have in writing. A response form is enclosed for your convenience. In completing the response form, please feel free to identify other areas of concern to your company, to suggest a more appropriate approach, or to provide glossary definitions. Please return the response form and any supplemental cements to Sandra L. Tirey, Associate Director, Health Programs, by April 1, 1991. Resource Needs for Implementation of the EHS Code Implementation of the EHS code as an obligation of membership under the Responsible Care Initiative will require the commitment of significant resources by CMA and its member companies. Implementation will be supported by both new and existing materials from CMA, as well as other appropriate sources. An implementation resource manual is currently under development by the code drafting group. With this in mind, please use the response form to identify resources your company would find helpful in implementing the code. WV 000011811 Responsible Care Coordinators February 4, 1991 Page 3 The Employee Health and Safety Code represents the continuing commitment of CMA and the chemical industry to the principles of Responsible Care. It reflects our concern for the health and safety of our employees and all others who work on or visit our worksites. Building public trust must begin with protecting the health and safety of our own employees. If you have any questions about the draft code, open meeting, or resource needs for implementation, please call Sandra L. Tirey at 202/887-1274 (or fax: 202/887-1237). Responsible Care Enclosures cc: Health and Safety Contacts Responsible Care Coordinating Group Health and Safety Committee Engineering and Operations Committee VVV 000011812 SAFE RESPONSIBLE CARE PLAN* OPERATIONS/EMPLOYEE HEALTH AND CODE OF MANAGEMENT PRACTICES CODE DRAFTING GROUP SAFETY GARY LOPEZ (Chairman of the Task Group) Manager, Safety and Health Programs ICI Americas Inc. Concord Pike and New Murphy Road Wilmington, DE 19897 302/886-7960 -5304 Work Group I: Administrative GAYLA MCCLUSKEY, C.I.H., C.S.P. Manager, Health and Safety Interchem, Inc. 9808 Bluegrass Parkway Louisville, KY 40299 (Chairman) DONALD CROWELL Labor Counsel Union Carbide Corporation 39 Old Ridgebury Road Section E3 Danbury, CT 06817 PATRICIA HUNT, R.N., B.S.N., M.N. Health Services Manager Department of Medicine and Health Sciences Monsanto Company 800 North Lindbergh Blvd. A3NB St. Louis, MO 63167 NEIL NETZEL Director, Health and Safety Velsicol Chemical Corporation 5600 North River Road Rosemont, IL 60018 BARRY OSTROFF, M.D. Regional Medical Director Olin Corporation P.0. Box 1355 Stamford, CT 06904-1355 502/499-4665 -4148 203/794-6755 -6269 -5382 314/694-8814 -8808 708/318-1144 698-9714 203/356-2563 -3524 Work Group II: Analysis RICHARD ALLEN, C.I.H. (Chairman) Industrial Hygiene Coordinator Exxon Chemical Americas 13501 Katy Freeway Houston, TX 77079 713/870-6885 -6661 VVV OCOOlW3 RONALD EGEDAHL, M.D., FRCPC Assistant Medical Director The Dow Chemical Company 1803 Building Midland, MI 48674 WAYNE LEDNAR, M.D., Ph.D. Corporate Epidemiologist Eastman Kodak Company Health and Environmental Lab Building 320 Kodak Park . Rochester, NY 14652-3615 RICHARD MATHERNE Supervisor, Corporate Industrial Hygiene Ethyl Corporation 451 Florida Street Baton Rouge, La 70801 CAROLYN PHILLIPS Manager, Industrial Hygiene Services Shell Oil Company P.0. Box 4320 Houston, TX 77210 JERRY REGNIER General Counsel 3M Company 3M Center 220-11E-03 St. Paul, MN 55133 Work Group III: Prevention/Control ROBERT HUNT (Chairman) Coordinator of Health and Safety Chevron Chemical Company 6001 Bollinger Canyon Road San Ramon, CA 94583 DAVID JOHNSON, C.S.P. Corporate Director, Occupational Health, Safety, and Industrial Hygiene Hoechst Celanese Corporation Route 202-206 P.0. Box 2500 Somerville, NJ 08876-1258 R.G. (BOB) LINK Director of Safety and Risk Management Union Carbide Chemicals and Plastics 39 Old Ridgebury Road, P-2, 599 Danbury, CT 06817 HOMER TURNER Area Manager, Safety E.I. du Pont de Nemours & Co., Deepwater, NJ 08023 Inc. 517/636-0008 -1875 716/588-5803 477-2863 504/388-7745 -7687 -7686 713/241-0020 -3325 612/733-5509 736-3257 415/842-5876 -3194 201/231-4488 -4458 203/794-2546 -5275 609/540-2310 -2991 VVV GQ0011dl4 Work Group IV: Training and Communications STEPHEN KEMP (Chairman) Manager, Industrial Hygiene Occidental Chemical Corporation 360 Rainbow Boulevard South P.0. Box 728 Niagra Falls, NY 14302 HARRY ESCHENBACH Director, Health & Safety & Toxicology Grace Specialty Chemicals Company 55 Hayden Avenue Lexington, MA 02173 RICHARD HACKMAN, CIH Senior Industrial Hygienist The Procter and Gamble Company Ivorydale Technical Center 5299 Spring Grove Avenue Cincinnati, OH 45217-1087 ALAN HAY, M.D. Assistant Corporate Medical Director E.I. du Pont de Nemours & Co., Inc. N-11400-ERD 1007 Market Street Wilmington, DE 19898 Liaisons HENRY (HANK) GUDRIAN (Communications) Director, Communications Quantum Chemical Corporation 11500 Northlake Drive P.0. Box 429550 Cincinnati, OH 45249 PHILIP RASCH (Process Safety Code Drafting Group) Manager, Safety Loss Prevention and Process Safety Hoechst Celanese Corporation 26 Main Street Chatham, NJ 07928 JOHN WILLETT (Health & Safety Committee) Manager, Plans & Integration Chemical Division Shell Oil Company P.0. Box 4320 Houston, TX 77210 Current as of February 1, 1991 716/286-3357 -3099 617/861-6600 x2213 862-3869 513/627-7688 302/774-4866 -7321 513/530-6239 -6119 201/635-3917 -4122 713/241-6958 -4043 -4044 oaooiim February 1, 1991 DRAFT EMPLOYEE HEALTH AND SAFETY CODE OF MANAGEMENT PRACTICES Purpose The goal of the Employee Health and Safety Code of Management Practices is to protect the health and safety of all persons working on or visiting the worksite. The purpose of the Code is to provide guidance to member companies on practices intended to achieve continuous improvement in employee health and safety. These multi-disciplinary programs are provided to identify and assess hazards, maintain employee health, prevent unsafe acts and conditions, and communicate work practices and hazards. Implementation of the Employee Health and Safety Code, together with other codes of management practices, can enable member companies to operate in a manner that protects the health and safety of employees, contractors, the public, and the environment. Relationship to Guiding Principles Implementation ofthe Code helps achieve several ofthe Responsible Care Guiding Principles: To recognize and respond to community concerns about chemicals and our operations. To make health, safety, and environmental considerations a priority in our planning for all existing and new products and process. To operate our plants and facilities in a manner that protects the environment and the health and safety of our employees and the public. To extend knowledge by conducting or supporting research on the health, safety, and environmental effects of our products, processes, and waste materials. VVV 000011816 Employee Health and Safety Code of Management Practices February 1, 1991 -- Page 2 DRAFT MANAGEMENT PRACTICES Each member company shall have an ongoing employee health and safety program that includes: Program Management 1. Commitment by all levels of management to the goal of safe and healthful working con ditions for employees through a published policies, assignment of specific responsibility and accountability for policy implementation, and provision of sufficient resources, in cluding qualified health and safety personnel. 2. Written programs and procedures to implement policy that are maintained current and that take into account occupational health and safety practices appropriate to each facility and regulatory requirements. 3. Systems, including regular audits, to monitor the effectiveness of health and safety programs. 4. Maintenance of records to support and improve health and safety programs, in addition to meeting regulatory requirements. 5. Provisions, including selection criteria and regular verification, that on-site contractors either have programs for their own employees consistent with applicable sections of this Code or are included in the member company's program, or some combination ofthe two. Identification and Evaluation 6. Methods to identify and prioritize potential occupational health and safety hazards in existing and planned facilities. 7. Exposure assessments and safety analyses of job tasks to evaluate and communicate risks to employees from potentially hazardous chemical, physical or biological agents, processes, or workplace conditions. 8. Occupational medical surveillance programs to evaluate employee health and to com municate results to participating employees. 9. Programs to conduct job-specific health assessments to determine employee medical fit ness for work. 10. Timely investigation and communication ofworkplace illnesses, injuries, and incidents. vvv 00001181? Employee HeaJth and Safety Code of Management Practices February 1, 1991 - Page 3 DRAFT 11. Systems for analyses of employee health and safety data to determine trends. Prevention and Control 12. Inherent safe design of facilities and job tasks through the use of sound engineering practices, appropriate standards and codes, past experience, and consideration of human factors. 13. Prevention or control of identified hazards by giving primary consideration to the sub stitution of a less hazardous material or process or the use of engineering controls. 14. Administrative controls, including current standard operating procedures for safe and consistent operations, special hazard procedures, and a means to verify that actual prac tices are consistent with procedures. 15. Corrective action plans to prevent the recurrence of illnesses, injuries, and incidents and methods for evaluating the effectiveness of corrective actions taken. 16. Systems to select, inspect, test, maintain, and use health and safety equipment. 17. Preventive maintenance and housekeeping programs to provide facilities, tools, and equipment that are safe to use. 18. Security procedures and systems that prevent unauthorized entry of personnel and materials into the facility. 19. Emergency response plans and procedures that reflect the Community Awareness and Emergency Response (CAER) Code of Management Practices and that provide for emergency medical assistance for employees. Training and Communications 20. Communicating specific facility hazards to employees, contractors, and visitors, 21. Formal programs for, and documentation of, initial, refresher, remedial, and upgrade health and safety training to achieve and maintain proficiency in work practices and skills. 22. Programs that keep awareness of safety and health at a high level, both on and off the job. 23. Opportunities for employee participation in the development, implementation, and re view of health and safety programs in a way that addresses employee concerns about hazardous conditions and safety incidents. ooooiia18 vW Employee Health and Safety Code of Management Practices February 1, 1991 -* Page 4 DRAFT 24. Systems to evaluate the effectiveness of training and communications programs. RELATIONSHIP TO OTHER CODES OF MANAGEMENT PRACTICES This code complements, and should be implemented in conjunction with, current and future code of management practices. ooaoii019 VMM February 1, 1991 DRAFT CHEMICAL MANUFACTURERS ASSOCIATION MEMBER SELF-EVALUATION FORM EMPLOYEE HEALTH AND SAFETY CODE OF MANAGEMENT PRACTICES Member Company Name:_______________________ Responsible Care Coordinator Name:_______________________ Address:_____________________ Telephone (_____ )___________________ Number of Facilities Subject to Code. yvv 000011820 Member Self-Evaluation Form February 1, 1991 - Page 2 DRAFT EMPLOYEE HEALTH AND SAFETY CODE OF MANAGEMENT PRACTICES 1. Under the Responsible Care Initiative, each member company will submit a SelfEvaluation form annually to CMA. To establish the industry baseline, each member company should complete this Self-Evaluation form and send it to Dr. Edward J. Heiden, Heiden Associates, Inc., 1815 H. Street, N.W., Suite 501, Washington, D.C. 20006. 2. Indicate on the cover page the number ofmember company facilities subject to the Code. Each company must report the implementation stage for all facilities subject to the Code on this form. 3. For each Management Practice on the following four pages, indicate the number of facilities that have attained each implementation stage. Each facility should appear in only one milestone stage per Management Practice. The total number offacilities subject to the Code should equal the number offacilities across all six implementation stages for each Management Practice. 4. Only subject facilities owned or operated as of the reporting gate should be included. 5. The implementation stages are: Stage I Stage II Stage III Stage IV Stage V Stage VI No action Evaluating company practices against Code practice. Developing action plan to implement Code practice. Implementing action plan. Code management practice in place. Implementation reviewed and reaffirmed this year WV 00OOUS21 Member Self-Evaluation Form February 1, 1991 -- Page 3 DRAFT Management Practices Each member company shall have an ongoing employee health and safety program that includes: I II III iv v vi Program Management 1. Commitment by all levels of management to the goal of safe and healthful working condi tions for employees through a published policy, assignment of specific responsibility and ac countability for policy implementation, and provision of sufficient resources, including qualified health and safety personnel. 2. Written programs and procedures to imple ment policy that are maintained current and that take into account occupational health and safety practices appropriate to each facility and regulatory requirements. 3. Systems, including regular audits, to moni tor the effectiveness of health and safety programs. 4. Maintenance of records to support and im prove health and safety programs, in addi tion to meeting regulatory requirements. 5. Provisions, including selection criteria and regular verification, that on-site contractors either have programs for their own employ ees consistent with applicable sections ofthis Code or are included in the member com pany's program, or some combination of the two. Identification and Evaluation 6. Methods to identify and prioritize potential occupational health and safety hazards in existing and planned facilities. 7. Exposure assessments and safety analyses of job tasks to evaluate and communicate risks to employees from potentially hazard ous chemical, physical or biological agents, processes, or workplace conditions. 8. Occupational medical surveillance programs to evaluate employee health and to commu nicate results to participating employees. vv v 0000 tia 22 _________ 1 _________ 1___________ Member Self-Evaluation Form February 1, 1991 -- Page 4 DRAFT 9. Programs to conduct job-specific health as sessments to determine employee medical fitness for work. 10. Timely investigation and communication of workplace illnesses, injuries, and incidents. 11. Systems for analyses ofemployee health and safety data to determine trends. I Prevention and Control 12. Inherent safe design of facilities and job tasks through the use of sound engineering practices, appropriate standards and codes, past experience, and consideration ofhuman factors. 13. Prevention or control of identified hazards by giving primary consideration to the sub stitution of a less hazardous material or process or the use of engineering controls. 14. Administrative controls, including current standard operating procedures for safe and consistent operations, special hazard proce dures , and a means to verify that actual prac tices are consistent with procedures. 15. Corrective action plans to prevent the recur rence ofillnesses, injuries, and incidents and methods for evaluating the effectiveness of corrective actions taken. 16. Systems to select, inspect, test, maintain, and use health and safety equipment. 17. Preventive maintenance and housekeeping programs to provide facilities, tools, and equipment that are safe to use. 18. Security procedures and systems that pre vent unauthorized entry of personnel and materials into the facility. 19. Emergency response plans and procedures that reflect the Community Awareness and Emergency Response (CAER) Code of Man agement Practices and that provide for emergency medical assistance for employ ees. CO r-t Hoooo >> II III IV V VI V Member Self-Evaluation Form February 1, 1991 -- Page 5 DRAFT Training and Communications 20. Communicating specific facility hazards to employees, contractors, and visitors. 21. Formal programs for, and documentation of, initial, refresher, remedial, and upgrade health and safety training to achieve and maintain proficiency in work practices and skills. 22. Programs that keep awareness ofsafety and health at a high level, both on and offthe job. 23. Opportunities for employee participation in the development, implementation, and re view of health and safety programs in a way that addresses employee concerns about hazardous conditions and safety incidents. 24. Systems to evaluate the effectiveness of training and communications programs. i ii in iv v vi tv 000( 11824 DRAFT January 14, 1991 EMPLOYEE HEALTH AND SAFETY CODE OF MANAGEMENT PRACTICES Glossary This Code uses key terms in a context that may be broader than their associated regulatory definitions. However, adherence to this Code does not relieve a company of its obligations to meet Federal, state, and local regulatory requirements. (The number after a term indicates the code element where the term is first used.) Administrative controls - (14) Limiting exposure to harmful physical or chemical hazards through the use of procedures and work practices Audits - (3) Documentation - (22) Employee - (1) a member company's workers. Employee participation - (24) Engineering controls - (14) elements in the physical design of facilities that reduce or eliminate exposure to harmful physical or chemical hazards. Exposure - (8) the potential dose, i.e., ambient air concentration or the amount that contacts the skin or eyes. Exposure assessment - (8) the determination or estimation (quantitative or qualitative) of the magnitude, frequency, duration, and route of exposure Facility - (21) Hazard - (7) a chemical substance or activity that is a source of risk to human health when actuated by exposure. Health and safety equipment - (17) Health and safety training - (22) Human factors - (13) the study of the interaction between humans and the work environment. Inherent safe design - (13) a design that minimizes the exposure to hazardous situations. Safety analysis - (8) VVV 000011825 DRAFT January 14, 1991 Page 2 Medical fitness for work - (10) Occupational health and safety practices - (2) management practices designed to protect the health and safety of employees. Occupational health monitoring - (9) Occupational medical surveillance ~ (9) On-site contractor - (6) Operating practices - (17) actions that are actually taken to operate a process. Preventive maintenance - (18) repairing equipment before breakdown based on inspection or expected life. Qualified health and safety personnel - (1) Risk - (8) the probability of injury or harm. Sound engineering practices - (13) Special hazard procedures - (15) procedures for recurring hazardous situations such as confined space entry, complex maintenance, etc. Standard operating procedures - (14) Written descriptions of required operating practices including startup and shutdown. Substitution - (13) Elimination or reduction of a hazard with a nonor less hazardous alternative. Systems - (3) oooou826 RESPONSIBLE CARE EMPLOYEE HEALTH AND SAFETY CODE OF MANAGEMENT PRACTICES Open Meeting Hyatt Atlanta Airport Thursday, March 7, 1991 8:00 a.m. to 5:00 p.m. 7:30 - 8:00 a.m. 8:00 - 8:10 8:10 - 8:30 8:30 - 9:00 9:00 - 9:30 9:30 - 9:45 9:45 - 11:00 11:00 - 12:15 p.m. 12:15 - 1:30 1:30 - 2:45 2:45 - 3:00 3:00 - 4:15 4:15 - 5:00 Tentative Agenda Registration Welcome -Overview of Open Meeting Agenda -Objectives of Meeting Update on Responsible Care Initiative Overview of Responsible Care Employee Health and Safety Code of Management Practices Process Safety Code -Overview of Code -Update on Implementation -Harmonization of Process Safety Code with Employee Health and Safety Code BREAK Breakout Session I -Feedback on Code Elements -Identify Implementation needs Breakout Session II LUNCH Breakout Session III BREAK Breakout Session IV Wrap-up -Major points made by participants -Implementation needs identified -Next steps/timetable for Employee Health and Safety Code -Questions and Answers VVV 000011827 CHEMICAL MANUFACTURERS ASSOCIATION RESPONSIBLE CARE EMPLOYEE HEALTH AND SAFETY COOE OF MANAGEMENT PRACTICES OPEN MEETING Yes, I will be attending the Employee Health and Safety Code of Management Practices Open Meeting on March 7, 1991. NAME: TITLE: COMPANY: ADDRESS: PHONE: FAX: The deadline for registration is Friday, March 1. Please return this registration form, along with a check for $75 payable to CMA, to: Vicki McLaughlin Chemical Manufacturers Association 2501 M Street, NW Washinton, DC 20037 (202) 887-1279 Fax (202) 887-1237 Please complete a separate form for each registrant. Delta Airlines offers a special fare (40% off regular coach and 5% off lowest fare). Call 800-221-1212, refer to file number T-11861 and give the date and the city of the meeting. This meeting will be held at the Hyatt Atlanta Airport (404-991-1234). Registrants are responsible for making their own room reservations. Please note that the cut off date for the special meeting rate of $105 per night is Friday, February 15. 1991. VVV 000011Q28 Chemical Manufacturers Association RESPONSIBLE CARE EMPLOYEE HEALTH AND SAFETY CODE OF MANAGEMENT PRACTICES Response Form 1. We have reviewed the Employee Health and Safety Code Management Practices and have no comments. (Check only if no other comments are provided). 2. Will the practices outlined in this draft satisfy the goals of the Code described in the purpose section? YES __________________________ NO If no, what changes would you recommend? 3. Are any practices redundant or unclear? YES __________________________ NO If yes, please explain why and offer solutions.__ 4. Are any important issues left out of the code? If yes, please explain. YES _________________________V_VNVO0000X1829 5. What kinds of resources "will you find helpful in implementing this Code? 6. Additional Comments... Your Name: ___ Company: ___ Address: ____ Phone: ( ) PLEASE RETURN BY APRIL 1, 1991 TO: Sandra L. Tirey Associate Director, Health Programs Chemical Manufacturers Association 2501 M Street, NW Washington, DC 20037 ...OR FAX IT (202) 887-1237 VVV 000011830