MASTER OF SCIENCE OCCUPATIONAL SAFETY AND HEALTH MANAGEMENT OSH SEMESTER 1 – 2018 ASSIGNMENT NO 1 (GROUP ASSIGNMENT) Analyze the differences between the three(3) OSHMS, which are OHSAS 18001, ISO 45001 and MS 1722. 1 CONTENT SECTION 1.0 2.0 TITLE Introduction PAGE 3 Table 1.0 Comparison between OHSAS 18001, MS 1722 and ISO 45001 requirements and its differences Discussion on advantages of ISO 45001:2018 against OHSAS 18001:2007 and MS 1722 4 - 13 14-19 Table 2.0 Advantages of ISO 45001:2018 against OHSAS 18001:2007 and MS 1722 3.0 Discussions on matters in OHSAS 18001 or MS 1722 are better than ISO 45001. 20 4.0 Conclusion 21 5.0 References 22 2 1. Introduction OH&S management controls the conditions and factors that affect, or could affect, the health and safety of workers (including temporary workers and contractor personnel), visitors, or any other person in the workplace, to avoid their ill health and/or injury. ISO 45001: 2018 Occupational health and safety management systems Requirements with guidance for use is a standard that defines the requirements for a management system for OH&S management, as well as giving guidance on its use. ISO 45001, building upon OHSAS 18001:2007, adopts Annex SL, providing a shared framework with other ISO standards. The standard applies to all forms and sizes of organization, performing any types of activities. This standard is developed by Project Committee 283 in 2013 and published in March 2018. It provides a framework to establish OH&S management policies, objectives, processes and governance, and facilitates an organization's achievement of its strategic goals. ISO 45001 utilizes a structured, effective, and efficient process that drives continual improvement for an organization's OH&S performance. This standard focuses on the need for a management system, not the management of specific types of hazards and risks. This new standard has its origins in OHSAS 18001. OHSAS 18001 was first published in 1999 and revised in 2007 by the OHSAS Project Group, an international consortium of experts including representatives from various national standards bodies, academic institutions, and health and safety organisations. OHSAS was initially developed in 1999 by BSI and the 2007 version are compatible with ISO 14001:2004. MS 1722:2011 – Occupational Safety and Health Management Systems – Requirements is a Malaysian Standard that provides requirements on Occupational Safety and Health Management Systems (OSHMS) and basis for the development OSH system in an organisation. MS 1722:2011 is supported by Department of Occupational Safety and Health (DOSH) Guidelines on Occupational Safety and Health Management Systems which replaced the MS 1722: Part 2:2003 Occupational Safety and Health Management Systems - Guidelines standard which has been withdrawn by Standards Malaysia. The requirements of the standard are intended to address OHS for employees, temporary employees, contractors and other personnel on site rather than the safety of products and services. This assignment focuses on differences and advantages of ISO 45001 requirements on occupational health and safety management systems (referred to hereafter as ISO 45001) against OHSAS 18001:2007 and MS 1722:2011 which are the two OHSMS standards currently widely used OHSMS in Malaysia. 3 Table 1.0 Comparison between OHSAS 18001, MS 1722 and ISO 45001 requirements and its differences Clause OHSAS 18001:2007 1 Scope 2 Reference Publications Terms and Definitions 3 Clause MS 1722:2011 Clause ISO 45001:2018 3 OSHMS in the organisation 0.1-0.5 Introduction 1 Scope and purpose 1 Scope Similar Explain the background success factors, intended outcomes, PDCA concept and verbal forms used in the standards. In MS 1722, clause 3 includes the Figure 3.1 which describe the OSH element; POPEA. No significant changes 2 Normative references Terms and definitions New title This is ISO Annex SL format tittle. Enhanced Context of the organisations New title OHSAS 18001 has 23 terms; MS 1722 has 24 terms while ISO 45001 has 37 terms. In ISO 45001, many of the similar OHS terms in both OHSAS 18001 and MS 1722 are updated and enhanced to suit current OHS development and promotes suitability at international level. For example the term employee was changed to worker, the term injury and ill-health is used to describe the harm/risk instead of ill health and work related injuries, disabilities, ill-health and diseases in MS 1722. Risk and OHS risk has different definitions. There are new terms in ISO 45001 such as occupational health and safety opportunities, documented information, outsource and process. This is ISO Annex SL format tittle. 2 Terms and definitions 3 4 4 Type of changes Description of Differences Claus e OHSAS 18001:2007 Claus e MS 1722:2011 Clause ISO 45001:2018 Type of changes Description of Differences 3.3.1 Initial Review 4.1 Understanding the organisations and its context Understanding the need and expectations of workers and other interested parties Determining the scope of the OHSMS New Requirement 4.4 OHS Management system Similar 5 Leader and worker participation Title Change 5.1 Leadership and commitment New Requirement 5.2 OHS Policy Enhanced This is a new requirement with the intent to identify the internal and external issues that will drive the OH&SMS. This is a new requirement to identify what the needs of workers and other interested parties are and to understand how those needs impact the OH&S Management System. Includes identifying the boundary of the scope and taking into consideration the external and internal issues, needs and expectations of interested parties and any planned or performed work-related activities. Add requirements to include the processes needed and the interactions for an OH&SMS. This is ISO Annex SL format tittle with addition of “worker participation” to emphasise OHS discipline requirement. Ensures leadership is involved in the OH&S Management system through several required commitments. Adds requirements to ensure it is available and communicated appropriately, both internally and externally. 4.2 4.3 3.3.1 4.4.1 4.4.3 4.4.6 4.2 Initial Review (partial) OH&S Policy 3.1.1 OSH Policy 5 New Requirement Enhanced Clause OHSAS 18001:2007 Clause MS 1722:2011 Clause ISO 45001:2018 Type of changes Description of Differences 4.4.1 Resources, roles, responsibility, accountability and authority 3.2.1 Responsibility, accountability and authority 5.3 Organizational roles, responsibilities, and authorities Enhanced Part of the OHSAS 18001 requirements was added to Section 5.1 in ISO 45001. Also, ISO 45001 adds more emphasis on workers taking on responsibility for the management system with top management being used as a communication tool. 4.4.3. 2 Participation and Consultation 3.1.2 Employee participation 5.4 Consultation and participation of workers Enhanced Emphasizes that the consultation and participation of non- managerial workers is intended to apply to persons carrying out the work activities, but is not intended to exclude, for example, managers who are impacted by work activities or other factors in the organization. 4.3 Planning 6 Planning Title This is ISO Annex SL format tittle. 6.1 Actions to address risks and opportunities New Requirement There is a new requirement to determine the risks and opportunities of the organization. 6 Clause OHSAS 18001:2007 Clause MS 1722:2011 Clause ISO 45001:2018 Type of changes Description of Differences 6.1.1 General New Requirement The Actions to address risks and opportunities requires the organization to consider the following issues: - Context of the Organization - Needs and expectations of interested parties - The Scope of the OH&S Management System These issues shall take into account its associated: - Hazards - OH&S Risks and Other Risks - OH&S Opportunities and other opportunities - Legal Requirements and Other Requirements Risks or undesired effects can include work-related injury and ill health, noncompliance with legal requirements and other requirements, or damage to reputation. OH&S opportunities address the identification of hazards, how they are communicated, and the analysis and mitigation of known hazards. Other opportunities address system improvement strategies. 7 Clause OHSAS 18001:2007 Clause MS 1722:2011 Clause 4.3.1 Hazard identification, risk assessment and determining controls 3.3.3 Hazard 6.1.2 identification, risk assessment and risk control 4.3.2 Legal and Other Requirements 6.1.3 6.1.4 6.2 ISO 45001:2018 Type of changes Hazard identification Enhanced and assessment of risks and hazards Determination of legal requirements and other requirements Planning action OH&S Objectives and Planning to Achieve Them 8 Description of Differences Adds requirements to identify and assess risks related to workers at a location not under the direct control of the organization, home-based workers or those who work alone. Have extensive requirement on hazard identification which include social factors, human factors, people within the vicinity etc. It also takes into consideration risks and opportunities that may arise from routine, non-routine and emergency situations. Similar Add new requirement related to how legal and other requirements can result in risks and opportunities. New Requirement The organization shall plan actions to: - address these risks and opportunities (see 6.1.2.2 and 6.1.2.3);2) - address legal requirements and other requirements (see 6.1.3); - prepare for and respond to emergency situations (see 8.2); This is ISO Annex SL format tittle. New Tittle Clause OHSAS 18001:2007 Clause MS 1722:2011 Clause ISO 45001:2018 Type of changes Description of Differences 4.3.3 Objectives and programme 3.3.2 OSH Objectives 6.2.1 6.2.2 Similar No Significant Changes 4.4 Implementation and Operation 3.2 Organising 7 OH&S Objectives Planning to achieve OH&S objectives Support New Title This is ISO Annex SL format tittle. Resources Similar Requirement pulled into its own section Competence ISO 45001:2018 Awareness Similar Type of changes Enhanced Requirement pulled into its own section Description of Differences Adds awareness requirements that workers shall be made aware of, such as: - incidents and the outcomes of investigations that are relevant to them; - hazards, OH&S risks and actions determined that are relevant to them; - the ability to remove themselves from work situations that they consider present an imminent and serious danger to their life or health, as well as the arrangements for protecting them from undue consequences for doing so. 4.4.1 Resources, roles, 3.2.1. responsibility, 4 accountability and authority 4.4.2 Competence, 3.2.2 and Clause Clause training OHSAS 18001:2007 awareness. The employer 7.1 shall provide appropriate resources Competence, 7.2 Training and Clause MS 1722:2011 Awareness 7.3 9 Clause OHSAS 18001:2007 Clause MS 1722:2011 Clause ISO 45001:2018 Type of changes Description of Differences 4.4.3 3.2.4 Communication 7.4 Communication Title Change 7.4.1 General Enhanced 7.4.2 Internal Communication Enhanced 7.4.3 External Communication Enhanced 7.5 Documented information General Title Change This is ISO Annex SL format tittle. Participation and consultation has been pulled out and moved into its own section (5.4). Expanded to include consideration of diversity aspects, views of external interested parties and responding to external communication. Adds requirement to ensure its communication process(es) enables workers to contribute to continual improvement. External communication shall consider its legal requirements and other requirements This is ISO Annex SL format tittle. 4.4.4 Communication, Participation and Consultation Documentation 3.2.3 OSHMS Documentation 7.5.1 4.4 Implementation and Operation 3.3 Planning and Implementation 7.5.2 Creating Updating 7.5.2 Control Documented Information Operation 8 10 Similar and Similar of Similar Title Change Allows for documentation media outside of the traditional word, excel and pdf formats, such as software programs. No significant changes Requires documentation and record retention requirements be identified. This is ISO Annex SL format tittle. Clause OHSAS 18001:2007 Clause MS 1722:2011 Clause ISO 45001:2018 Type of changes 4.4 Implementation and Operation Operational Control 3.3 Planning and Implementation 8.1 Operational Planning and control General Title Only Hazard identification, risk assessment and determining controls 3.3.3 Hazard identification, risk assessment and risk control 8.1.2 Eliminating hazards and reducing OH&S risks New sub clause 3.3.5 Management of change 8.1.3 Management of change New requirement (only when compare with OHSAS 18001) 3.3.6 Procurement 8.1.4 Procurement New title 8.1.4.1 General New requirement 4.4.6 4.3.1 8.1.1 11 Enhanced Description of Differences Adds operational requirements, such as adapting work to workers. At multiemployer workplaces, the organization shall coordinate its OH&S management system with the other organizations. Separates the hierarchy of controls requirements into its own section. There is a new control option parallel with engineering control named as “reorganization of works” which addressed controls for physiological and psychological hazards. The organization shall establish a process (es) for the implementation and control of planned temporary and permanent changes that impact OH&S performance. The term “unintended consequences” is used. The organization shall establish, implement and maintain a process(es) to control the procurement of products and services to ensure their conformity to its OH&S management system. Clause OHSAS 18001:2007 Clause MS 1722:2011 Clause ISO 45001:2018 Type of changes Description of Differences 3.3.7 Contracting 8.1.4.2 Contractors New requirement 8.1.4.3 Outsourcing New requirement 8.2 Emergency preparedness and response Similar The organization shall coordinate its procurement process(es) with its contractors, to identify hazards and to assess and control the OH&S risks Adds requirement to ensure that outsourced functions and processes are controlled. No significant changes 9 9.1 Performance Monitoring, measurement, analysis and performance evaluation General Title Change Title Only This is ISO Annex SL format tittle. Enhanced Evaluation of compliance Internal audit General Internal audit programme Similar Increased focus on the overall performance of the OH&S management system and ensuring results are analyzed, evaluated and communicated. No significant changes Title Only Similar Similar No significant changes No significant changes 4.4.7 Emergency preparedness and response 3.3.4 4.5 4.5.1 Checking 3.4 Performance 3.4.1 measurement and monitoring Emergency prevention, preparedness and responses Evaluation Performance monitoring and measurement 9.1.1 4.5.2 4.5.5 Evaluation of compliance Internal audit 9.1.2 3.4.3 Audit 9.2 9.2.1 9.2.2 12 Clause OHSAS 18001:2007 Clause MS 1722:2011 Clause ISO 45001:2018 Type of changes Description of Differences 4.6 3.4.4 Management review 9.3 Management review Enhanced Added agenda items to match the new requirements in the ISO 45001 standard. Also require additional outputs to be evaluated and documented. 3.5 Action for improvement 10 Improvement New Title This is ISO Annex SL format tittle. 10.1 General New requirement Requires identification and implementation of opportunities for improvement. 4.5.3 4.5.3. 1 Management Review Incident investigation, nonconformity, corrective action and preventive action Incident investigation 3.5.1 Preventive and 10.2 corrective action Incident, nonconformity and corrective action Similar No significant changes 3.4.2 Incident Investigation 10.2 Similar No significant changes 3.5.2 Continual improvement 10.3 Incident, nonconformity and corrective action Continual improvement New requirement Requires demonstrated continual improvement of not only the OH&S management system, but with the OH&S as a whole. 13 2. Discussion on advantages of ISO 45001:2018 against OHSAS 18001:2007 and MS 1722 Table 2.0 Advantages of ISO 45001:2018 against OHSAS 18001:2007 and MS 1722 Acceptance MS 1722:2011 Only recognised in Malaysia because this a national standard Update Less accurate and relevant because it was reviewed and updated in 2011 (8 years ago) Concept Using POPEA cycle, i.e. Policy Organising – Planning & Implementation – Evaluation – Action for Improvement OHSAS 18001 Although it’s a national standard developed by British Standards Institute, it is recognised at international level. Less accurate and relevant because it was reviewed and updated in 2007 ((11 years ago) OHSAS 18001 used to be similar in arrangement when compared to ISI 14001:2004. Although use Plan-DoCheck-Act cycle, the clauses arrangement is not easing for Not easy for business to merge with implementing integrated management ISO 9001 and ISO 14001 system, especially after ISO 14001 is updated in 2015. However, those with a good OHSAS 18001 systems will find the route to implementation less difficult and will find a lot of common ground, as risk-based thinking should already be a core activity. 14 ISO 45011: 2018 Recognised at international level and will be replacing many national OHS standards More accurate and relevant with current OSH practices in industry. Provides clarity on OHSMS issues especially on the current risk reduction concept, performance based monitoring etc. Although the PC 283 keeps the Plan-DoCheck-Act cycle, ISO 45001 follows the Annex SL framework used for ISO 9001, ISO 14001, ISO 23001 etc. This means that organisations with multiple management systems who wish to integrate or align them, should find this to be an easier task. MS 1722:2011 OHSAS 18001 Integration of No specific requirement to support Not explicitly detailed the OHSMS into integration the business processes of the organization Risk based thinking No considered Process approach versus procedure approach Both standards are procedure-approach. 15 ISO 45011: 2018 ISO 45001 promotes and supports business in ensuring their strategic business action is consistent with their OHS performance The need to ensure integration of the requirements into business processes should mean that the “silo” approach of some organisations, whose OH&S management systems are totally independent, is a thing of the past. Risk-based thinking for the OHSMS, as well as for OH&S risks. This means there is no reference to preventive action. The organisation must show that they have determined, considered and, where necessary, taken action to address any risks and opportunities that may affect (either positively or negatively) their OH&S management system’s ability to deliver its intended outcomes. While ISO 9001:2008 promoted the adoption of a process approach and OHSAS 18001 was based on “plan, do, check, act” (PDCA), there is recognition of both approaches in this document. Clause 4.4 requires the processes and their interactions to be determined within the OH&S management system. Wellness and Wellbeing Content MS 1722:2011 MS 1722 did not mention at all employee wellbeing/wellness programmes. OHSAS 18001 OHSAS 18001 is not intended to address other health and safety areas such as employee wellbeing/wellness programmes. ISO 45011: 2018 ISO 45001 enables an organization, through its OH&S management system, to integrate other aspects of health and safety, such as worker wellness/wellbeing. Lack details and requirements Lack details and requirements Have more details and requirements 1. Guidance in implementing 1. Guidance in implementing the 1. Guidance to implement the the requirement are in requirement are in separate requirements is on the same separate document document – ISO 18002 and ISO document developed by DOSH 18004 2. Clearer guidance on requirement – 2. No requirement on 2. No requirement on leadership refer annex leadership 3. Only focus on employee 3. Leadership is a key factor in the 3. Only focus on employee participation, consultation PDCA concept and is a requirement participation requirement is very limited. 4. Consultation with workers is a 4. Only emphasise on 4. Didn’t promote integration of requirement, in addition with employers responsibilities OH&S requirement in other participation 5. No requirement on item 7.3 business processes in the 5. In ISO 45001, the clause 5.3 (b) organisation emphasise on OSH responsibilities 6. Didn’t promote integration of workers and top management of OH&S requirement in accountabilities. other business processes in 6. Provide workers with ability to the organisation make decision without referring to manager when the work is too dangerous. The employer shall make arrangement to protect workers when they not do the dangerous work. 16 Involvement of workers especially nonmanagerial workers Leadership and commitment MS 1722:2011 The word use in “Employee participation”, but the requirement said “consulted”. There is inconsistency. OHSAS 18001 Limited requirement on consultation and participation ISO 45011: 2018 Have detailed and consistent requirements regarding consultation and participation. Not explicitly detailed Limited requirement Top management are required to demonstrate that they engage in key OH&S management system activities. They are required to develop, lead and promote a culture of safety at work, and protect workers from reprisals when reporting incidents. This means that there is a need for top management to be actively involved, and demonstrate their commitment. In the case of those adopting ISO 45001, all managers will need to be able to demonstrate their commitment to OH&S. ISO 45001 is not just about accidents in the workplace, and managers would do well to remember that issues such as stress can affect all parts of the organisation. This is not something the nominated management representative can necessarily take on board. 17 Supporting guidance document MS 1722:2011 Supporting guidelines prepared by DOSH is limited on explanation and examples of demonstration of each requirement. OHSAS 18001 Supporting guidelines prepared by BSI provide better guidance on the requirements; namely OHSAS 18002 – Guidelines for implementation of OHSAS 18001:2007 and BS 18004:2008 Guide to achieving occupational health and safety performance. Auditing 18 ISO 45011: 2018 Supporting guidelines for ISO 45001 prepared by BSI are extensive such as follows: - BS 45002-0:2018 Occupational health and safety management systems. General guidelines for the application of ISO 45001 - BS 45002-1:2018 Occupational health and safety management systems. General guidelines for the application of ISO 45001. Guidance on managing occupational health - BS 45002-3:2018 Occupational health and safety management systems. General guidelines for the application of ISO 45001. Guidance on incident investigation - BS 45002-2. Occupational health and safety management systems. General guidelines for the application of ISO 45001. Part 2. Risks and opportunities At ISO TC 283 level, works are also in progress to develop additional guidelines to support ISO 45001 such as For management system auditors, the adoption of Annex SL means that in a combined audit, there is a generic set of requirements that can be audited simultaneously, irrespective of the disciplines within the audit scope. This will make the auditor life easier. 19 3. Discussions on matters in OHSAS 18001 or MS 1722 are better than ISO 45001. The following can be perceived as matters where OHSAS 18001 or MS 1722 are better than ISO 45001. i. The synergy of OHSAS 18001 clauses are easy for understanding and implementation compare to the synergy and dynamic of ISO 45001 clauses. ii. The term “worker” used in ISO 45001 may cause confusion and will take time for organisation to be able to really understand that everyone is worker, including top management. iii. The role of “management representative” has been removed, although it is a legal requirement in many countries including the UK. This role is explicitly mentioned in MS 1722 and OHSAS 18001 which many organisation considered as a useful position to have albeit it may not be effective in improving OH&S performance at the strategic level. iv. The requirements in MS 1722 are written in simple sentences which have been perceived by user as easier to be implemented. v. Those with a good OHSAS 18001 systems will find the route to implementation less difficult and will find a lot of common ground, as riskbased thinking should already be a core activity. vi. Auditing MS 1722 and OHSAS 18001 is easier. Due to the process approach in ISO 45001, the management system auditor may find auditing ISO 45001 is difficult and requires extensive technical and industry-specific competence. 20 4. Conclusion The new standard adopts in full the text of Annex SL, with very minor modifications to suit its OHS discipline requirements such hazards, consultation and participation, hierarchy of controls and incident investigations. Therefore, it aligns with ISO 9001 and ISO 14001: with the same structure, same terms and definitions, and same generic text. Organisations will now have a model that integrates OH&S into the strategy and decision-making processes at all levels, and contributes to their business sustainability. Top management will be much more involved in OH&S matters and will be challenged to demonstrate their leadership and commitment in OHSMS. Workers will benefit from enhanced care of their OH&S needs but will also be challenged to participate in many instances of the OHSMS development, planning and operation. In another perspective on certification, internal and external OHSMS auditors will need the competence to audit top management more rigorously, competent in the sector that there are auditing including having knowledge and understanding on the issues that maybe affect the organisation in relations to OHS. These auditors also must be able to evaluate and compare evidence related to demonstration of conformity to ISO 45001 to the organisation’s business strategies. In this assignment, it has been shown that ISO 45001, OHSAS 18001:2007 and MS 1722:2011 requirements have some level of correspondence, similarities however the depth of OHS technical requirements have been expanded in ISO 45001. The main differences between these standards are application of term of workers, risks and opportunities, taking into account context, integration to business processes, extensive requirement on hazard identification, risk based thinking and process approach may posed a challenged to organisation who are have existing OHSMS based on OHSAS 18001 and MS 1722 . OH&S professionals such SHO and SSS will welcome these changes in all technical and operational OH&S-related issues as this will support OHS commitment and accountability at all levels and functions in their organisation. This will pose opportunity to the OHS professional to be able to interact with top management and to assist top management to discharge their duties and responsibilities. However, ISO 45001 requirements may be intimidating to SME and organisation that didn’t have strong and mature existing OHSMS. As this assignment is only able to compare obvious differences in main clauses and its sub clauses of these three standards, there is a need for future study to conduct compare effective implementation of these standards in organisations. 21 5. References a. Malaysian Standard ISO 45001:2018, Occupational Health and Safety Management System – Requirements with Guidance for use b. BS OHSAS 18001:2007, Occupational Health and Safety Management System – Requirements c. BS OHSAS 18002 – Guidelines for implementation of OHSAS 18001:2007 d. BS 18004:2008 Guide to achieving occupational e. MS 1722:2011 Occupational Safety and Health Management System f. Department of Occupational Safety and Health Malaysia, Guidelines on Occupational Safety and Health Management System, 2011, g. ISO/TC 283 Occupational health and safety management, https://www.iso.org/committee/4857129.html h. ISO/TC 283 Occupational health and safety management home website, https://committee.iso.org/home/tc283 i. Popular Standards - MS 1722:2011 & OHSAS 18001:2007 - Occupational Health and Safety Management Systems (OHSMS), http://www.jsm.gov.my/ms-1722#.W_Aa6rhx3IU, j. OHSAS Project Group, Implementation Guidance for migrating from OHSAS 18001:2007 to ISO 45001:2018, https://committee.iso.org/home/tc283 k. Abidin, E,Z., Irniza, R.(2015) Occupational Safety and Health Management System in Malaysia : Comparisons between OHSAS 18002:2007 and MS 1722:2011, International Journal of Public Health and Clinical Sciences, Vol.2 No 3 l. Kleinove, R., Szaryszova, P., (2016) The new Health and Safety Standard ISO 45001:2016 and its planned changes. INTERNATIONAL JOURNAL OF INTERDISCIPLINARITY IN THEORY AND PRACTICE. itpb.eu/pdf/2014-1/9%20klejnova,%20szaryszova.pdf m. Chartered Quality Institute, ISO 45001:2018, Understanding the International Standard. n. IAF’s Mandatory Document IAF MD 21: Requirements on the Migration to ISO 45001:2018 from OHSAS 18001:2007 (see: http://www.iaf.nu/upFiles/IAFMD21MigrationtoISO450012018Pub.pdf) 22