Client’s Legal Entity Fire Exit Drills Policies and Procedures
Holiday Decorations in Client’s Buildings
Sample Computer Security Policy
Loss Control Inspection Protocol
Subject: Client’s Legal Entity Fire Exit Drills Policies and Procedures
1. Purpose
The purpose of fire exit drills is to ensure the efficient and safe use of the exit facilities available in the case of an emergency. Proper drills ensure orderly exit under control and prevent the panic that has been responsible for much of the loss of life in the major fire disasters of history. Order and control are the primary purposes of the drill. Speed in emptying buildings, while desirable, is not in itself an object, and should be made secondary to the maintenance of proper order and discipline.
2. Responsibility
Fire exit drills shall be designed and conducted according to the occupancies specified below and in cooperation with the authority having jurisdiction. Responsibility for the planning and conduct of drills shall be assigned by Client’s risk management and safety to competent persons qualified to exercise leadership. A written record of all drills conducted should be maintained including a critique of the event. This record should be maintained by the Client’s safety or security coordinator.
3. General Guidelines
Drills shall include suitable procedures to make sure that all persons in the building, or all persons subject to the drill, actually participate. If a fire exit drill is considered merely as a routine exercise from which some persons may be excused, there is a grave danger that in an actual fire, the drill will fail in its intended purpose.
All drills should be pre-planned and preannounced. Surprise drills tend to limit productive learning, breed apprehension, and cause passivity to future alarms. Any alarm not preceded by plan or announcement shall be treated as an actual fire condition. Fire exit drills shall be held with sufficient frequency to familiarize all occupants with the drill procedure and to have the conduct of the drill a matter of established routine.
Drills should be carefully planned to simulate actual fire conditions. Not only should they be held at varying times, but different means of exit should be used based upon an assumption that if some given stairway is unavailable by reason of fire or smoke, all the occupants must be led out by some other route. Fire exit drills should be designed to familiarize the occupants with all available means of exits, particularly emergency exits that are not habitually used during the normal occupancy of the building.
4. Fire Exit Signs
Adequate posting of fire exit signs is a responsibility which each Client’s division must address. A highly visible graphic design should be conspicuously posted with the following information:
* Evacuation routes
* Identification of "you are here" location
* Location of the pull stations
* Location of portable extinguisher
NOTE:
The term "fire exit drill" is used to avoid confusion between drills held for the purpose of rapid evacuation of buildings and drills of fire fighting practice that, from a technical viewpoint are correctly designated as "fire drill", although this term is by common usage applied to egress drills in companies, etc.
The usefulness of a fire exit drill and the extent to which it can be carried depends upon the character of the occupancy. Drills are most effective in occupancies such as classrooms, where the occupant load of the building is under discipline and subject to habitual control. In buildings where the occupant load is of a changing character and not under discipline such as Staff Unions, no regularly organized fire exit drill is possible.
In such cases, the fire exit drills must be limited to the regular employees, who can be thoroughly schooled in the proper procedure and can be trained to properly direct other occupants of the building in case of fire. In occupancies such as hospitals, regular employees can be rehearsed in the proper procedure in case of fire. Such training always is advisable in all occupancies whether or not regular fire exit drills can be held.
The following sections address some of the special fire exit drill details which should be observed for specific occupancy classes.
1. Educational (staff training) Occupancies — Classrooms, Lecture Halls, Laboratories, Administrative Buildings, Workshops
All Client’s educational (staff training) buildings must hold one fire exit drill per year, preferably during the first four weeks of the your. Client’s Administration and Staff shall work in cooperation with safety personnel in scheduling drills before the current year begins to allow for curriculum planning.
Evacuation instructions are to be conspicuously posted in each classroom, hallway, and stairwell to provide the necessary evacuation information and ensure orderly egress from the building. Signs should also specify that elevators must not be used to exit and should delineate alternative routes.
Classroom staff should be familiar with the easiest exit to be used in the fire drill and the alternative exits available. Client’s Administration and staff should close (not lock) doors and windows and take responsibility for checking facilities for complete evacuation. All personal belongings within reach should be taken from classrooms by staff.
Handicapped Staff should inform Client’s administration or staff at the start of the semester of any special requirements with respect to locations and procedures that will best facilitate those Staff’s egress from the building in an emergency. In general, wheelchair users should go to the stairwell, which is furthest from the fire and wait for help. Fire departments should be notified that stairwells be checked first. Other handicapped persons should be assisted by staff.
2. Residential Occupancies — Dormitories, Lodges, Etc.
Residential facilities demonstrate the greatest need for adequate and effective fire exit awareness due to the potential loss of life in what often are high rise structures. Fire exit drills in dormitories must be performed once per year at a minimum. Because of the nature of the occupancy, it is usually the case that additional drills are performed due to false alarms.
A major concern in dormitory fire drills is the resistance of residents to evacuate the building in the event of a drill. This problem may be alleviated by contacting the city attorney to determine what type of citation may be applied (i.e., disorderly conduct). Citations may then be issued during the fire drill by the fire department or other official to achieve cooperation. Resident assistants and other employees must take responsibility for the complete and orderly evacuation of the building. Education and awareness are key components to an effective fire evacuation program. Directional signs in hallways and in each dorm room will help Staff to become more fully aware of their options.
Special consideration must be given to handicapped Staff with regard to fire safety in dormitories. To be most effective, handicapped Staff should be required to evacuate the building during a fire exit drill regardless of their location in the building. Preplanning is key for the handicapped person because his/her own familiarity with the buildings, exists, and the safest methods of egress is vital. First responders should preplan by having designated individuals assigned to evacuate handicapped persons requiring assistance. The handicapped person should also seek out buddies to assist in the evacuation and should explain all instructions beforehand. No-one should be left behind during a fire exit drill or fire condition.
To facilitate evacuation, handicapped persons should be assigned to rooms on ground or egress level whenever possible. Rooms should be identified on the outside of the building with a distinctly coded sign to advise the fire department without distinguishing the Staff. If evacuation of a handicapped person is not possible, he/she should return to the room, close the door or proceed to the nearest stairwell if possible and wait for the fire department rescue. For this reason, each dorm should have a list of all handicapped Staff and their room location on file with the fire department.
On each floor of the Client’s office, the resident staff should proceed down the hall knocking loudly on each door as he/she passes. Staff should not unlock each door as this is time consuming and may result in danger to the staff person.
3. Assembly Occupancies — Theaters, Auditoriums, Lecture Halls, Arenas, Staff Unions
Because actual fire drills are not practical for places of non continuous assembly where the Staff or public body changes with each program, employees or attendants of such places should be schooled in the duties they are to perform in case of fire in order to be of greatest service in effecting orderly exit of assemblages.
An adequate number of competent attendants must be on duty when assembly occupancy is used. Attendants should be instructed in the proper use of portable fire extinguishers and other manual fire suppression equipment if provided.
An audible announcement may be made prior to the start of each program to notify occupants of the location of the exits to be used in the case of emergency. Signs with directions for speedy and orderly egress should be posted at aisle ends and at all entrances and exits.
4. Health Care Occupancies
The administration of every health care facility shall be responsible for the development of a written plan for the protection of all persons in the event of a fire. A qualified person shall be appointed as the fire exit drill coordinator (safety director, security director, disaster committee member, etc.) and will conduct fire drills at least once per quarter on all three shifts including weekends.
Fire exit drills are to be pre-planned and pre-announced over the P.A. System, (e.g., "Attention please — a fire drill will be conducted at this time. All personnel return to your departments.") Patients should be advised by unit staff. Advanced planning will test the efficiency, knowledge, and response of personnel without disturbing patients.
Fire drills should be instructional in nature and include the following:
* Describing the hypothetical situation
* Sounding the alarm
* Removing personnel and patients from danger
* Confining the fire (close doors)
* Turn on all lights
* Extinguishing techniques (blankets, extinguisher, hose)
* Ventilating according to need (engineered smoke system)
Staff members should be assigned to evaluate the response to the drill in other areas of the hospital; for example:
* Person assigned to meet and escort fire department to fire area
* Sprinkler control valve person to locate appropriate valves and standby for instruction
* Fire pump observer to station
* Auxiliary generator observer to station
A written record of any drill conducted should be maintained by the fire drill coordinator including a critique of the event and recommendations to correct any deficiencies noted.
5. Day-Care Occupancies
In order to meet the requirements for certification, an approved fire evacuation plan shall be executed not less than once per month in Client’s day-care centers pending severe weather. Fire safety should be included in the curriculum of the day-care center taught by knowledgeable staff to ensure preparedness by children and staff.
Large uncomplicated signs should be strategically place and explained to children prior to a fire exit drill to help educate them in orderly egress. A fire exit drill coordinator shall be assigned to coordinate the fire drill efforts and to maintain written records of the drills and critiques thereof.
Staff shall be instructed to check each room for children and shall have responsibility for a specific group of children during a fire drill. Upon exiting a room, doors and windows should be closed but not locked. Roll call will be taken immediately after exiting building to ensure that all children have evacuated and are present. Area fire authorities should be consulted to confirm that fire exit drills are being executed in the safest and most efficient manner for a specific building.
6. Administrative Occupancies
Due to the stable nature of administrative buildings, fire exit drills should be held annually following the guidelines set forth in the section on educational occupancies above. Special consideration must be given to handicapped employees and non-employee guests in the building. Awareness by the occupying staff of the needs of these people will help to facilitate easy egress.
Subject: Holiday Decorations in Client’s Buildings
To set forth a Client’s policy regarding the safe use of natural and artificial holiday decorations in owned and leased Client’s buildings.
There have been questions regarding Client’s policy on holiday decorations in Client’s buildings. Because of the inconsistency between the current policies and their actual use, provisions have been updated to clarify where natural and artificial decorations may be used on Client’s Legal Entity, and how holiday decorations can be used safely.
Failure to maintain a safe environment in Client’s facilities could result in negligence on the part of the Client’s office, etc. should a loss occur. It is suggested that the physical plant personnel be involved in the installation and maintenance of holiday decorations whenever possible.
Client’s System Risk Management strongly recommends that holiday trees and wreaths not be placed in individual living quarters of any dormitory or residence halls due to the severe life safety hazard that these items present. Final adoption of this policy by each Client’s division rests with the director (chancellor). Artificial trees of flame retardant material or flame-proofed natural trees may be used in office areas, lobbies, and reception areas only if the following precautions are taken.
1.Trees
The most important factor in reducing the flammability of holiday trees is maintaining adequate moisture content. These guidelines may help reduce the fire hazard:
1. Before setting the tree up, be sure to cut the bottom of the tree at an angle at least three inches up from the original cut to facilitate water absorption.
2. Place the tree in a stand, which allows for at least two inches of standing water.
3. Designate an individual to monitor the water level in the tree stand and dryness of needles daily.
4. Place the tree away from heaters or air vents which accelerate the drying of the tree. Avoid placing the tree against the walls or ceiling, or in entry or exit ways as this may increase the fire hazard.
5. When needles become brittle or fall off the tree, remove the tree from the building.
6. Remove the tree from the building as soon as the holiday season ends, or from any building, which will be unoccupied for more than three consecutive days.
2. Lights
Only indoor lights may be used on indoor trees. These lights must bear Underwriter’s Laboratory approval. Lights should be inspected for shorts, and weak or cracked spots before using and should only be used during regular business hours when offices are occupied. Lights should be connected with a heavy duty extension cord and should be unplugged when unattended. Do not connect strings of different wattage together. Do not use lights on artificial metal trees. Avoid overloading electrical circuits by using power strips with their own circuit breaker. Candles should not be used.
3. Other
Decorations, including but not limited to, wreaths and tree skirts, may only be of non- flammable or flame-proofed materials and should not be attached to walls or around windows. Natural wreaths have the potential to become extremely flammable as they dry and should only be used for a short period of time.
Instruct area staff of location of the nearest fire extinguisher, how to use it, and how to report a fire.
4. Flame-Proofing Procedure:
A great deal of controversy exists over the effectiveness of flame-proofing holiday trees. Many States do not require flame-proofing of trees. Underwriters Laboratories, Inc. does not list any products for flame-proofing because the effectiveness is based primarily on how the product is applied. The National Fire Protection Association indicates that proper care of natural trees, such as recutting the trunk and keeping the tree in water is more effective than flame-proofing.
For these reasons we feel that maximum protection can be obtained by both flame-proofing the tree correctly (or having a knowledgeable person do it for you) and by maintaining a high moisture content as explained in guidelines 1-6 above.
One way of achieving compliance with this policy is to have owners bring trees to one location, possibly the safety office, where they are sprayed and then delivered to their respective location. This method increases control and awareness by the safety department as well as by tree users.
Flame-proofing sprays can be purchased from stores which sell trees, hardware stores, or possibly the local fire department.
Subject: Sample Computer Security Policy
This paper serves two purposes. First, it provides the Client’s safety and loss control personnel with a sample computer security policy from which they may develop their own. Second, it may provide Client’s personnel with the information necessary to protect their computer equipment and to reduce their loss in the event of a computer theft.
Client’s Risk Management has physically examined all Client’s Administration Buildings where valuable computer equipment exists due to concerns regarding the security of the equipment. Because computer theft has become more common and the Client’s divisions there is a need for special guidelines for computer security and the application of property insurance and deductibles in the event of a loss.
Currently, a $2500 deductible applies per occurrence when there is no evidence of forced entry, exit, or removal of equipment. When such evidence does exist, a $500 deductible applies for each occurrence. These deductible provisions can be avoided through the use of specific computer anchor pads, which may be purchased along with the computer. Theft of a computer, which is secured with an anchor pad according to contract specifications will be reimbursed directly from the anchor pad manufacturer for up to $5,000.
The following building specific guidelines have been proposed as Client’s Administration policy to enhance the probability and ease of having all computer equipment secured adequately from the date of purchase. With the cooperation of the system computer purchasing coordinator, anchor pads can be included with the purchase of computers where necessary. This will simplify and expedite the securing of new equipment. A variety of anchor pads are available with prices for the warranted systems ranging from $165 to $500. Consultation with the computer purchasing agent will aid in determining which anchor pad will best meet a specific situation.
Between 5:45am and 10:00pm a security guard is on duty and is situated near the front and also monitors side entrances. At 5:30pm the stairwells and back doors are locked, and a security system goes into operation. Anyone attempting to enter or exit via the rear doors will trigger an alarm. Anyone who enters or exits the front or side doors is visible to the guard and must sign in and out. Breaking any of the first floor windows will trip an alarm that rings at Police and Security. The loading dock door is bolted and an alarm is activated at 9:30pm. Between 10:00pm and 5:45am, no guard is present, however, the only access to the building is the side door which has a card access system which is hard wired to Police and Security. Any foul play with the system will trigger the alarm. The system also itemizes the names and time of those who have entered or exited the premises.
During the day a remote possibility exists for someone to walk out the back entrance with some equipment, however, proper documentation must be shown to the guard or the individual is detained.
Recommendation -In light of the current security and of the fact that no computer losses have occurred, it is recommended that Client continue with its current alarm and security system. Provided that the security systems continue to operate as described.
Recommendation � At some divisions when necessary the installation of Anchor Pads on all IBM, Apple and IBM compatible (including Zenith and new Wang PC’s) is recommended. The use of Anchor Pads is also encouraged on any laser printers. Rekeying the top floors would be costly and key control is difficult due to the traffic of many employees and cleaning staffs who may be careless at times.
Recommendation — At other officies it is recommended that offices with IBM, Apple and IBM compatible computers be rekeyed because this is more affordable than installing several anchor pads. Rekeying cost about $40 per door and has been shown to be effective in this building in the past.
For all financial offices — With only one entrance to the Budget Preparation and Analysis office and shaded glass windows to prevent passers-by from looking into the offices this building presents little theft exposure to System. In addition, there is minimal Staff traffic in this office. Overall it is felt that this office, due to its location and composition of equipment, does not present a potential problem.
Recommendation — We recommend that no action be taken unless more valuable equipment is acquired in which case the occupants may wish to use anchor pads at their discretion.
For a prime computer targets due to poor outdoor lighting, the ease of penetration of the outside/inside doors, and the quantity and mobility of the computer equipment.
Recommendation — It is recommended that an exterior security card access system be installed similar to the one. With such a system, the potential for theft would be greatly reduced and in most cases there would be evidence of either forced entry or exit and so a $250 deductible would be applicable. This system should be recommended to the buildings landlord for purchase.
Subject: Loss Control Inspection Protocol
This paper has been developed to provide a protocol for the Client’s divisions and Client’s risk management, environmental health and safety, and physical planning and development staff to use in preparation for, during, and in follow-up to the annual Client’s Legal Entity loss control inspections. Adherence to this guideline will help to improve the quality and results of the loss control inspection process as a whole.
Each year, in conjunction with the loss control efforts of the Department of Administration Bureau of UKGC Risk Management (BUKGCRM), the Client’s Office of Environmental Affairs, Safety, and Risk Management (EASRM) schedules a one-day loss control inspection at each of the divisions. These inspections have been performed by any selected by Client Services Loss Control Consultants for the past ten years and provide an integral part of the Client’s loss control effort by identifying the hazards that exist on Client’s divisions. These inspections result in a list of loss control recommendations compiled by the consultant based on the inspection and the comments of the inspection participants. As the Client’s loss control program continues to evolve it is vital that these annual inspections identify emerging areas of hazard assessment not recognized in the past.
In an attempt to integrate the annual inspection into a comprehensive loss control program, to achieve more consistency within the Client’s Legal Entity, and make more cost effective use of the expertise of the Services consultants, new inspection procedures have been developed. Increased cooperation between Client’s Risk Management and Environmental Health and Safety (EHS) will help to meet these goals and will allow for increased involvement by EHS staff in the Client’s inspections process.
1. Inspection Allotments: Annual Client’s Legal Entity inspections will continue to be performed by the Services Loss Control Consultants. All Client’s divisions will be allotted one day per year. Additional inspections may be purchased by EASRM or a Client’s division from Services as needed.
2. Inspection Participants: Participation in each loss control inspection will be comprised of a core group with one representative from the following offices:
Past inspections have indicated that when fewer individuals are involved, the inspection is usually smoother and less intimidating to the departments being surveyed. Conversely, it is beneficial to obtain the involvement of specific personnel in specific situations. One efficient way to achieve necessary input without developing a large inspection entourage is to provide a very specific agenda so that specific individuals may converge with the core group at any given point in the process.
3. Inspection Leader: Each inspection will be directed by a predetermined individual or "leader." This leader will either be someone from EASRM or from the Client’s division. It will be the responsibility of the leader to finalize and communicate the agenda to all other individuals in the group. In addition, the leader will make sure that the agenda is adhered to and the inspection remains on course throughout the day and will act as the decision maker when deviating from the agenda. In most cases it will be logical for the Client’s risk, safety or EHS personnel to take the role of leader because of their close affiliation with departmental personnel involved. The Client and EASRM participants will designate a leader in advance of the inspection day.
1. Inspection Area Determination:
In the past, BSRM and EASRM have suggested a few key areas for each year’s inspections based on recent loss experience and comments from the Client’s divisions. With the implementation of a risk management information system in the EASRM office, identification of inspection areas should become more significant.
At the start of each fiscal year, BSRM, EASRM, and Client’s Legal Entity risk and safety personnel will schedule the Client’s inspections for the year. Notice sent from BSRM or EASRM will indicate the key areas which will be targeted for the year. These areas will be chosen based on a Client’s evaluation of the exposure level of the area, claims experience, and past inspections. The Client should also include those areas, which are of particular concern to them.
2. Pre-inspection Procedures:
Upon scheduling of an inspection, the Client should do the following:
1. Choose an inspection leader or defer to EASRM.
2. Review previous inspections and discuss the areas of concern.
3. Develop a full agenda including an opening and closing meeting.
4. Inform the Assistant Chancellor of Business Affairs.
5. Communicate with departmental personnel the date, purpose, benefits and requirements of the inspection, and make any necessary arrangements to ensure that facilities can be inspected with ease.
6. Provide a detailed agenda to BSRM, EASRM, and the consultant one month prior to inspection.
7. Provide BSRM, EASRM, and Services consultant with a Client’s Legal Entity map and parking information.
3. Inspection Day Procedures:
0. Opening Meeting: Each inspection should include an opening meeting involving all members of the core inspection group, the Assistant Director (Chancellor) of Business Affairs, if possible, and any other Client’s personnel necessary. The purpose of the opening meeting is to introduce the consultant to the Client’s personnel, to discuss the status of recommendations from previous inspections, and to resolve any changes or uncertainty in the agenda. The Assistant Director (Chancellor) may present the Client’s position regarding loss control and its relationship to their physical planning and development initiatives.
1. Inspection Leader Responsibilities: As stated above, the inspection leader will be responsible for the direction of the inspection. As various departments/areas are inspected, it is helpful for one employee from the area to join the inspection to provide detailed information to the Services consultant. This participation, which is extremely helpful in pinpointing the source and solution of safety problems, should be prearranged between the Client’s risk or safety manager and the area employee. During the day, lunch time should be scheduled and facilitated so as to maximize the productivity of the day.
2. Spontaneous and Follow-up Inspections: When time permits on the day of the inspection, the group may perform spontaneous inspections of areas which have posed a specific problem to Client’s personnel but which were not included in the agenda. A quick look at such situations may provide an easy remedy. Additionally, there are times when a recommendation from past inspections has not been acted upon due to financial constraints of the Client’s division. Follow-up recommendations are helpful in justifying the cost of loss control to the Client’s Legal Entity and his System Administration.
3. Inspection Participants Questions, Comments, and Suggestions: Before, during and after the Client’s divisions inspection, all inspection participants should communicate any questions, comments, and suggestions to the Services consultant. This communication will help the consultant to focus on the concerns of the Client’s divisions. Participation by the group is meant to enhance the thoroughness of the inspection.
The Services consultants are professionals in the field of general safety. Group members should inform and question the consultant on any safety issues which come to mind. When questions or concerns fall outside of the consultant’s expertise, the Client will have to decide whether additional expertise should be consulted. In particular, participation of the Client’s EHS staff in the inspections may raise questions which require an occupational health professional. The Services inspections should be used as a forum for discovery and initial evaluation of these types of concerns.
The Services consultant can help in the development of a more comprehensive loss control program for the Client through evaluation of the training and education of employees. Therefore, a copy of the department safety and training procedures should be provided for the consultant. The Services consultant may use this information in developing the final recommendations for the Client.
4. Closing Meeting: The closing meeting should involve all members of the core inspection group and the Assistant Director (Chancellor) of Business Affairs. It is designed to give the Services consultant the chance to highlight the general findings of the inspection, pointing out specifically those areas that need immediate attention, and initiating conversations regarding long-term planning and project development between UKGC and the Client’s divisions. Additional questions and comments of participants should be submitted and discussed at this time so that they may be addressed in the consultant’s final written list of recommendations.
4. Post-Inspection Procedures:
0. Additional Suggestions for Consultant: In the past, suggestions that were overlooked or only briefly discussed during the inspection have been brought up by the Client’s risk manager in the days and weeks following an inspection. If the Client desires inclusion of such topics in the consultant’s final report to bring the concern to the attention of other parties, these topics should be communicated to the Services consultant via the inspection leader. Some time constraint exists as the consultants usually release their report one month after the inspection.
1. Recommendations from Services Consultants: Shortly after the physical inspection of the Client’s divisions, the Services consultant will issue a final report, which consists of a brief overview of the inspection along with a detailed listing of specific loss control recommendations. If a recommendation is not acceptable to the Client, EASRM or BSRM, further discussion between the inspection participants will be necessary. Acceptance of the recommendations will obligate the Client to comply with them according to the set guidelines. The inspection recommendations should be distributed to BSRM, EASRM, the Client’s Assistant Director (Chancellor) of Business Affairs, and the Client’s risk manager.
2. Recommendation Compliance: Upon receipt of the recommendations from Services Consultants, the Client’s EHS and RM personnel should meet with Client’s planners and other appropriate staff to discuss approaches to compliance. At the same time, System EASRM will meet with the System architect and engineering team for the Client to determine what approach should be taken to rectify any problems. The Client should take immediate action on those recommendations which are minor and which can be solved without additional funding. The A/E team will consult with the Client to develop joint recommendations for resolution of the identified problems. For projects which require special funding the following sources should be considered:
1. Client’s Discretionary Funds
2. Building Commission All-Agency Funds
3. State or Federal Grant Funds
4. BSRM Loss Control Funds: emergency funding for projects which need immediate attention. This funding source is contingent upon repayment in the next fiscal year.
Requests for funding should be submitted as soon as possible after the completion of the inspection.
3. Written Recommendation Follow-up: Sixty days after the receipt of the inspection report from Services Consultants the Client should respond to the recommendations in writing. This response should address each recommendation in the order listed with the status of the recommendation correction. These should be sent to BSRM and EASRM. Because some projects cannot be completed in the 60-day time period, this report should provide an estimated completion date for incomplete projects with final completion reported by the Client to BSRM and EASRM.
4. Fiscal Year Evaluation of Process: At the end of each fiscal year BSRM, EASRM, and Client’s personnel will evaluate the inspection process in light of the years experience. Clarification and modification of this procedure will be made based on this evaluation.
