NHS Nottinghamshire County Primary Care Trust. Display Screen Equipment Procedure

Transcription

1 Nottinghamshire County NHS Nottinghamshire County Primary Care Trust Display Screen Equipment Procedure Reader information Reference NON-CLIN/13 Directorate Quality and Governance Document purpose To provide guidance on the requirements of Display Screen Equipment Procedures Version 2.0 Title Display Screen Equipment Procedure Author/Nominated Lead Jackie Betts Health and Safety Advisor Approval Date March 2011 Approving Committee Health and Safety Committee Review Date March 2013 Groups/staff Consulted Company Secretary, Corporate Risk Manager Target audience All staff Circulation list All staff Associated documents Health and Safety Policy, Procedure for the Reporting of Incidents and Near Misses, including Serious Untoward Incidents Superseded documents Display Screen Equipment Procedure 2007/2009 version 1.0 Sponsoring Director Director of Quality and Governance DSE Procedure Version 2.0 Page 1 of 22

2 Contents Page Number 1. Introduction 2.Procedure Statement 3 3. Roles and Responsibilities The PCT 3& Line Managers All Staff 4 4. Identification of Users 5 5. Information Instruction and Training 5 6. Eyesight Test 5&6 7. Equipment 6 8. Lighting 6 9. Ventilation and Humidity Noise Breaks away from the Display Screen Equipment Eye and Eyesight Effects Photosensitive Epilepsy Skin Complaints Musculoskeletal Problems Radiation and Pregnancy Reporting Accidents/incidents/Injuries Monitoring Compliance and Effectiveness, Auditing and Reviewing 8 Arrangements 18.1 Key Performance Indicators Equality and Diversity Statement Associated Policies 9 Appendix 1 Display Screen Equipment self assessment 10 Appendix 2 - Display Screen Equipment Risk Assessment 11 Appendix 3 -. Flowchart for Entitlement to Special Corrective Appliances 20 Appendix 4 Managers checklist 21 Appendix 5 Payment Memorandum 22 DSE Procedure Version 2.0 Page 2 of 22

3 1. Introduction European Directive 90/270/EEC was adopted on 29 h May 1990 and concerns the minimum health and safety requirements for work with display screen equipment. The requirements of the Directive are implemented in the UK in the Health and Safety (Display Screen Equipment) Regulations In brief, the Regulations require employers to assess and evaluate health and safety risks associated with work on display screen equipment and seek to minimise those risks. Members of staff have the right to information and training on health and safety matters relating to their workstations and to regular rest breaks. Staff classified as regular users are also entitled to vision or sight tests and employers are also liable for payment towards visual aids to correct vision defects connected with display screen work. 2 Procedure Statement Nottinghamshire County Primary Care Trust (the PCT) recognises its responsibility to ensure the health and safety of all employees using display screen equipment at work. The requirements of this Procedure are based on the Health and Safety (Display Screen Equipment) Regulations 1992 (as amended). The Regulations requires users and operators to be identified and a suitable and sufficient assessment made of all workstations with a view to reducing risk. Display Screen Equipment (DSE) covers computer screens and display screens for microfiche, televisions used as CCTV monitors and laptops. A workstation comprises all the equipment and furniture required for the job and includes environmental factors (eg lighting, temperature, humidity) and the immediate environment around the display screen equipment. This may be in a PCT office or at home or at another location where you are required to work The aims of the document are: To prevent health problems and to encourage effective design of equipment, the environment and the job To outline the self assessment process for Display Screen Equipment within the PCT To detail the roles and responsibilities of different staff groups under the procedure To detail the management arrangements for identifying users and for providing special corrective equipment To set out how the compliance and effectiveness of this procedure will be monitored 3 Roles and Responsibilities 3.1 The PCT Nottinghamshire County PCT (the PCT) has a responsibility to provide a safe and healthy working environment. However, this can only be fully achieved by educating staff and ensuring that they contribute to the maintenance and improvement of safe working practices. The regulations are designed to protect employees who are regular users of DSE. These are workers who habitually use display screen equipment or as a significant part of their DSE Procedure Version 2.0 Page 3 of 22

4 normal work for continuous spells of an hour or more at a time and use it in this way more or less daily. 3.2 Line Managers In order to secure the health and safety of members of staff who are regular users of display screen equipment, in so far as is reasonably practicable, Managers must, Ensure full compliance with the Health and Safety (Display Screen Equipment) Regulations 1992 and associated legislation, including the provision of suitable equipment identified by assessment Identify users Encourage staff to undertake a self assessment of each workstation (Health and Safety Toolkit available on the Intranet /health--safety.aspx) following the assessment managers must o Ensure that all necessary measures are taken to remedy any risks found as a result of the assessment o Take steps to reorganise members of staff s activities to prevent intensive periods of on-screen activity o Review software to ensure that it is suitable for the task and is not unnecessarily complicated o Arrange for the Health and Safety Advisor to conduct an assessment on the workstation if required o Arrange for provision of a vision test or sight test at appropriate intervals and where a visual problem is experienced, the frequency of tests will vary according to individual factors (See section 6 Eyesight tests) Ensure that assessments are reviewed when required Encourage staff to raise any issues of concern relating to the use of display screen equipment 3.3 All Staff Users of display screen equipment will be requested to complete a self assessment checklist (see appendix 1) to assist the PCT in providing a safe and healthy working environment Where a problem arises in the use of display screen equipment the member of staff must: inform his / her supervisor / manager immediately; in the case of an adverse health or medical condition advise his / her supervisor / manager, who will inform Occupational Health. DSE Procedure Version 2.0 Page 4 of 22

5 4 Identification of users A user is an employee who habitually uses display screen equipment as a significant part of their working day for continuous spells of an hour or more at a time and uses it in this way more or less daily. Other requirements may need to be considered) eg the individual has no discretion as to the use or non-use of the display screen equipment. All workstations, even those not used by a regular user must meet the minimum requirements as outlined in the self assessment checklist. 5 Information Instruction and training The PCT will provide all employees with sufficient information regarding use of display screen equipment via the procedure and guidance on the intranet The PCT acknowledges that information for users is essential and will make available resources to support the self-assessments. (See Setting up your Workstation - Display Screen Equipment self-assessment guidelines, available on the PCT s Intranet under the Health and Safety section). 6 Eyesight test For regular users, all agreed costs of a vision or sight test will be met by the PCT provided that the testing has been arranged through the Manager and the necessary documentation completed. Where a member of staff obtains a test independently, and without the knowledge of his / her Manager then the employer will not be responsible for the costs incurred. Regular user status must be established and documented prior to any vision or sight test being undertaken by the Manager of the member of staff. (Appendix 3) All sight tests are required to be carried out by a registered Optomestrist / Ophthalmologist the cost of such test will be met by Nottinghamshire County PCT; Where it is confirmed in writing by the appointed optician that visual aids are necessary for the use of display screen equipment, The PCT will pay towards the cost of providing special corrective appliances (normally spectacles). The PCT will pay for The cost of the sight test The cost of the standard lenses, as per NHS Prescription charges, where required for correction (cost of additional lens features will be borne by the employee) The cost of a standard frame as per NHS Prescription charges (the additional expense of something more fashionable will be borne by the employee The employee will be permitted leave to attend the sight test with least disruption to service delivery as per the special leave policy section 9.3. Evidence of the purchase must be produced and a receipt must accompany the member of staff s claim for reimbursement. Employees must provide a quote for the standard costs where they have purchased additional features DSE Procedure Version 2.0 Page 5 of 22

6 Managers will then complete a manager s checklist (Appendix 4) and send a Payment Memorandum (Appendix 5) with the receipt attached to Finance to instruct reimbursement to the employee. The cost of providing special corrective appliances is funded from Directorate budgets The Regulations indicate that the maximum period between vision and / or sight tests should be at regular intervals. Nottinghamshire County PCT's approach will be to be guided by Occupational Health and / or opticians, the aim being to ensure that tests are carried out as and when appropriate. Where a member of staff is transferred to a job including regular use of display screen equipment he / she will also be offered the opportunity for a vision or sight test on induction. This also applies where display screen equipment has become a significant part of the work for a member of staff not previously considered a regular user. The member of staff will be personally responsible for the safekeeping of all special corrective appliances. These are supplied in accordance with a statutory requirement in the interest of health and safety. Members of staff are expected to show the same degree of care for glasses as for any other item of Nottinghamshire County PCT property 7 Equipment Many of the health problems associated with using DSE such as pains in the arms, shoulders or neck are attributed to poor machine or workstation design. Display screens and equipment that is used with them should be adaptable to individual needs, e.g. detachable keyboards, tilt / swivel facilities, chairs with variable height and back support. Members of staff are therefore encouraged to make appropriate adjustments before commencing work (guidance can be sought using the Setting up your Workstation - Display Screen Equipment self-assessment guidelines available on the PCT s Intranet under the Health and Safety section). Machines should be serviced regularly to ensure that a clear and stable image is maintained, as drifting or flickering can lead to eyestrain or headaches. All faults with equipment must be reported to the Helpdesk or managers as appropriate. 8 Lighting Inappropriate or inadequate lighting can lead to headaches and eye problems. Direct glare from windows or lights or reflections on the display screen can be a particular problem and should be eliminated or minimised by using curtains or blinds. Reflected glare can also be minimised by choosing equipment with features such as matt keyboard surrounds. When positioning equipment, the light sources within a room (both natural and artificial) should be taken into account and adjustments should be made accordingly. 9 Ventilation and Humidity Where a number of DSE are in operation within a work area, a certain amount of heat may be generated and attention should be given to humidity and ventilation in order to avoid drowsiness and soreness or dryness of eyes. DSE Procedure Version 2.0 Page 6 of 22

7 10 Noise Ideally DSE s should be almost silent. If this is not the case, employers may wish to refer the matter to the manufacturers, via the helpdesk, for investigation. Where possible, printers should be sited away from DSE operators or should be adequately soundproofed. 11 Breaks away from the display screen equipment The purpose of a break from display screen equipment is to prevent the onset of fatigue. Nottinghamshire County PCT will seek to incorporate changes of activity in the working day and users of display screens are encouraged through the planning of their activities to make opportunities to take breaks to perform alternative tasks. There is no prescribed frequency or duration of breaks from display screen work. Wherever possible, employees will be given the discretion to decide the timing and extent of off screen tasks. Fixed breaks should be avoided unless there is no alternative, as they reduce flexibility for both employers and employee. 12 Eye and Eyesight Effects Medical evidence shows that using screen equipment is not associated with damage to eyes or eyesight; nor does it make existing defects worse. But some workers may experience temporary visual fatigue, leading to a range of symptoms such as impaired visual performance, red or sore eyes and headaches, or the adoption of awkward posture which can cause further discomfort in the limbs. These may be caused by:- a) staying in the same position and concentrating for a long time; b) poor positioning of the display screen equipment; c) poor legibility of the screen or source documents; d) poor lighting, including glare and reflections; e) drifting or flickering images on screen. Like other visually demanding tasks, DSE work does not cause eye damage but it may make workers with pre-existing vision defects more aware of them. Such uncorrected defects can make work with a display screen more tiring or stressful than would otherwise be the case. 13 Photosensitive Epilepsy DSE work does not cause epilepsy and a person suffering from this complaint should not be prevented from undertaking DSE work. However, one type of epilepsy photosensitive epilepsy can make the sufferer susceptible to flickering lights or striped patterns. It is relatively rare, however, is very unlikely that someone of employable age would be unaware of the problem. Advice can be sought from Occupational Health if required 14 Skin Complaints There have been some reports of DSE users suffering from skin irritation or redness. Such problems may be due to the electrostatic field generated by the DSE and / or dry atmosphere. Filters, anti-static carpeting and humidity adjustments may alleviate any difficulties. In some cases, such symptoms may of course be quite unconnected with DSE work and a visit to your occupational health or General Practitioner is advisable if problems persist. DSE Procedure Version 2.0 Page 7 of 22

8 15 Musculoskeletal Problems Where DSE operators complain of discomfort in the neck, shoulders or arms, adjustments to their workstation, environment, work pattern, posture or technique will usually provide the answer. It is likely that a combination of factors may contribute to such discomfort. Prolonged static posture of the back, neck and head are known to cause musculoskeletal problems. Awkward positioning of the hands and wrist (e.g., as result of poor working technique or inappropriate work height) are further likely factors. Outbreaks of soft tissue disorders among keyboard workers have often been associated with high workloads combined with tight deadlines. The research does suggest that for a number of people, these problems can develop into a chronic and persistent condition. Such conditions have until recently fallen under the general heading of Repetitive Strain Injury (RSI) and involve recurrent or persistent pain, disability or loss of function in any part of the body, but mainly in the upper limbs and neck. They are now more commonly known as Work Related Upper Limb Disorders (WRULDS). Any member of staff experiencing persistent problems in this area should report them to their manager and consult with their occupational health department and General Practitioner for a proper diagnosis and advice. Good equipment and workstation design, linked with training in the health and safety aspects of working with DSE should help to prevent these problems. 16 Radiation and Pregnancy Scientific research has concluded that there is no risk from radiation emitted by DSE. There is no evidence to suggest that it causes miscarriages, and pregnant women should therefore be advised accordingly and encouraged to continue working with DSE. However, it is clear that a pregnant woman should avoid anxiety and stress and so members of staff who are concerned about adverse reports should be given the opportunity to discuss the matter with a suitably qualified person. However, a risk assessment must still be undertaken as pregnancy may affect posture, etc. 17 Reporting Incidents/Injuries All accident/incidents/injuries however minor must be reported (in accordance with the PCT s Incident Reporting Policy), using the standard incident form. It is the responsibility of the employee to complete the incident form as soon as possible after the incident/injury has occurred. Where the injured person is unable to complete the incident form the manager where relevant, should enter details on their behalf. Where an incident/injury results in admittance to hospital or inability to continue work the relevant manager must be informed immediately. 18 Monitoring Compliance and Effectiveness, Auditing and Reviewing Arrangements Self assessment completed for each DSE user and reviewed annually or in light of material changes (as required) DSE Procedure Version 2.0 Page 8 of 22

9 18.1 Key Performance Indicators. The KPI s for this procedure are Self assessment completed for each DSE user (as above) 19. Equality and Diversity statement The organisation aims to design and implement services, policies and measures that meet the diverse needs of our service, population and workforce, ensuring that none are placed at a disadvantage over others. All policies and procedures should be developed in line with the PCT s Equality and diversity policies and need to take into account the diverse needs of the community that is served. The Equality Impact Assessment tool is designed to help consider the needs and assess the impact of the procedure being developed. An Equality and Diversity Assessment has been completed for this procedure. 20. Associated Policies Health & Safety Policy Procedure for the Reporting of Incidents and Near Misses including Serious Incidents DSE Procedure Version 2.0 Page 9 of 22

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11 Nottinghamshire County Appendix 2 - DSE WORKSTATION RISK ASSESSMENT Workstation location and number (if applicable):... User:. Checklist completed by:. Assessment checked by:... Date of assessment:. Any further action needed? YES / NO Follow-up action completed on: This checklist should be completed by the workstation assessor and can be used as an aid to risk assessment and to help comply with the Schedule to the Health and Safety (Display Screen Equipment) Regulations. Work through the checklist, ticking either the yes or no column against each risk factor: Yes answers require no further action; No answers will require investigation and / or remedial action by the workstation assessor. They should record their decisions in the Action to take column. Assessors should check later that actions have been taken and have resolved the problem. Remember that the checklist only covers the workstation and work environment. You also need to make sure that risks from other aspects of the work are avoided, for example, by giving users health and safety training and providing for breaks or changes of activity. Advice on these is given in the main text of the guidance. DSE Procedure Version 2.0 Page 11 of 22

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13 DSE WORKSTATION Risk assessment Nottinghamshire County RISK FACTORS Tick Answer THINGS TO CONSIDER ACTION TO TAKE Yes No 1. DISPLAY SCREENS Are the characters clear and readable? Is the text size comfortable to read? Is the image stable, ie, free of flicker and jitter? Is the screen s specification suitable for its intended use? Are the brightness and / or contrast adjustable? Does the screen swivel and tilt? Make sure the screen is clear and cleaning materials are made available. Check that text and background colours work well together. Software settings may need adjusting to change text size. Try using different screen colours to reduce flicker, e.g. darker background and lighter text. If problems still exist, get the set-up checked, e.g. by the equipment supplier. For example intensive graphic work or work requiring fine attention to small details may require large display screens. Separate adjustment controls are not essential, provided the user can read the screen easily at all times. Swivel and tilt need not be built in; you can add a swivel and tilt mechanism. However, you may need to replace the screen if:- swivel / tilt is absent or unsatisfactory; work is intensive and / or; the user has problems getting the screen to a comfortable position. DSE Procedure Version 2.0 Page 13 of 22

14 Nottinghamshire County RISK FACTORS Tick Answer THINGS TO CONSIDER ACTION TO TAKE Yes No Is the screen free from glare and reflections? Use a mirror placed in front of the screen to check where reflections are coming from. You might need to move the screen or even the desk and / or shield the screen Are adjustable window coverings provided and in adequate condition? from the source of reflections. Screens that use dark characters on a light background are less prone to glare and reflections. Check that blinds work. Blinds with vertical slats can be more suitable than horizontal ones. If these measures do not work, consider anti-glare screen filters as a last resort and seek specialist help. 2. KEYBOARDS Is the keyboard separate from the screen? This is a requirement, unless the task makes it impracticable (e.g., where there is a need to use a portable). Does the keyboard tilt? Is it possible to find a comfortable keying position? Tilt need not be built in. Try pushing the display screen further back to create more room for the keyboard, hands and wrists. Users of thick, raised keyboards may need a wrist rest. DSE Procedure Version 2.0 Page 14 of 22

15 Nottinghamshire County RISK FACTORS Tick Answer THINGS TO CONSIDER ACTION TO TAKE Yes No Does the user have good keyboard Training can be used to prevent:- technique? hands bent up at wrist; hitting the keys too hard; overstretching the fingers. Are the characters on the keys easily readable? Keyboards should be kept clean. If characters still can t be read, the keyboard may need modifying or replacing. Use a keyboard with a matt finish to reduce glare and / or reflection. 3. MOUSE, TRACKBALL, ETC, Is the device suitable for the tasks it is used for? If the user is having problems, try a different device. The mouse and trackball are general purpose devices suitable for many tasks, and available in a variety of shapes and sizes. Alternative devices such as touchscreens may be better for some tasks (but can be worse for others). Is the device positioned close to the user? Most devices are best placed as close as possible, e.g. right beside the keyboard. Training may be needed to: prevent arm overreaching; tell users not to leave their hand on the device when it is not being used; encourage a relaxed arm and straight risk. Is there support for the device user s Support can be gained from, for example, the desk surface or arm of a chair. If wrist and forearm? not, a separate supporting device might help. Does the device work smoothly at a speed that suits the user? See if cleaning is required (e.g., of mouse ball and rollers). Check the work surface is suitable. A mouse mat may be needed. RISK FACTORS Tick Answer THINGS TO CONSIDER ACTION TO TAKE DSE Procedure Version 2.0 Page 15 of 22

16 Can the user easily adjust software settings for speed and accuracy of pointer? 4. SOFTWARE Yes No Users may need training in how to adjust device settings. Nottinghamshire County Is the software suitable for the task? 5. FURNITURE Is the work surface large enough for all the necessary equipment, papers, etc? Can the user comfortably reach all the equipment and papers they need to use? Any surfaces free from glare and reflection? Software should help the user carry out the task, minimise stress and be userfriendly. Check users have had appropriate training in using the software. Software should respond quickly and clearly to user input, with adequate feedback, such as clear help messages. Create more room by moving printers, reference materials, etc, elsewhere. If necessary, consider providing new power and telecoms sockets, so equipment can be moved. There should be some scope for flexible rearrangement. Rearrange equipment, papers, etc, to bring frequently used things within each reach. A document holder may be needed, positioned to minimise uncomfortable head and eye movements. Consider mats or blotters to reduce reflections and glare. DSE Procedure Version 2.0 Page 16 of 22

17 Nottinghamshire County RISK FACTORS Tick Answer THINGS TO CONSIDER ACTION TO TAKE Yes No Is the chair suitable? The chair may need repairing or replacing if the user is uncomfortable, or cannot use the adjustment mechanisms? Is the chair stable? Does the chair have a working:- seat back height and tilt adjustment? Seat height adjustment? Swivel mechanism? Castors or glides? Is the chair adjusted correctly? Is the small of the back supported by the chair s backrest? Are forearms horizontal and eyes at roughly the same height as the top of the VDU? The user should be able to carry out their work sitting comfortably. Consider training the user in how to adopt suitable postures while working. The arms of chairs can stop the user getting close enough to use the equipment comfortably. Move any obstructions from under the desk. The user should have a straight back, supported by the chair, with relaxed shoulders. Adjust the chair height to get the user s arms in the right position, then adjust the VDU height, if necessary. DSE Procedure Version 2.0 Page 17 of 22

18 Nottinghamshire County RISK FACTORS Tick Answer THINGS TO CONSIDER ACTION TO TAKE Yes No Are feet flat on the floor, without too If not, a footrest may be needed. much pressure from the seat on the backs of the legs? 6. ENVIRONMENT Is there enough room to change Space is needed to move, stretch and fidget. position and vary movement? Consider reorganising the office layout and check for obstructions. Cables should be tidy and not a trip or snag hazard. Is the lighting suitable, e.g. not too Users should be able to control light levels, e.g. by adjusting window blinds or bright or too dim to work light switches. comfortably? Consider shading or repositioning light sources or providing local lighting, e.g. desk lamps (but make sure lights don t cause glare by reflecting off walls or other surfaces). Does the air feel comfortable? VDUs and other equipment may dry the air. Circulate fresh air if possible. Plants may help. Consider a humidifier if discomfort is severe. Are levels of heat comfortable? Can heating be better controlled? More ventilation or air-conditioning may be required if there is a lot of electronic equipment in the room. Or, can users be moved away from the heat source? Are levels of noise comfortable? Consider moving sources of noise, e.g. printers, away from the user. If not, consider soundproofing. DSE Procedure Version 2.0 Page 18 of 22

19 Nottinghamshire County RISK FACTORS Tick Answer THINGS TO CONSIDER ACTION TO TAKE Yes No 7. FINAL QUESTIONS TO USERS Ask if the checklist has covered all the problems they may have working with their VDU. Ask if they have experienced any discomfort or other symptoms, which they attribute to working with their VDU. Ask if the user has been advised of their entitlement to eye and eyesight testing. Ask if the user takes regular breaks working away from VDUs. Write the details of any problems here:- DSE Procedure Version 2.0 Page 19 of 22

20 Appendix 3 - Flowchart for Entitlement to Special Corrective Appliances STAFF MEMBER USING DSE WORKSTATION ASSESSMENT USER STATUS CONFIRMED BY MANAGER NO NO FURTHER ACTION YES ARRANGEMENTS MADE FOR VISION TEST IF REQUESTED BY USER SIGHT TEST UNDERTAKEN BY OPTHALMIC OPTICIAN / MEDICAL PRACTITIONER REQUEST FOR REIMBURSEMENT SENT TO MANAGER INCLUDING: A) Confirmation from optician / medical practitioner of need for corrective appliance; B) Receipt for costs incurred. detailing Cost of test Cost of standard corrective appliance Cost incurred by employee(actual cost paid) Employee can claim cost of test plus required lenses and standard frame additional costs will be the employee s responsibility Manager completes a Manager s Checklist and Payment Memo for finance for reimbursement to the employee of cost of test, required lenses plus standard frame DSE Procedure Version 2.0 Page 20 of 22 Jackie Betts January 201i

21 Appendix 4 - Managers checklist HEALTH & SAFETY (DISPLAY SCREEN EQUIPMENT) REGS 1992 (as amended) Employee s Name. Job Title.. 1) Has a comprehensive documented workstation risk assessment been undertaken? Yes No 2) Does the worker conform to the Regular User status Yes No 3) Has the user made a request to his / her Manager for a vision or sight test? Yes No 4) On what date was the test undertaken? 5) Does the User require corrective appliances to enable use of the DSE? Yes No 6) Attached invoice from Optician clearly stating corrective appliances required for DSE work? 7) Request for reimbursement Vision and / or sight test Corrective Appliances Yes No Signed Manager Print Name. Employee Print Name. Directorate. Please attach a copy to the Payment Memo and send to the Finance Department for reimbursement (finance will advise budget code) Please keep a copy in your personnel file DSE Procedure Version 2.0 Page 21 of 22 Jackie Betts January 201i

22 Appendix 5 Payment Memo Nottinghamshire County MEMORANDUM From To Date Creditors Payments Department Subject: PAYMENT REQUEST Please will you raise a cheque to be made payable to.. for reimbursement of an eyesight test carried out on.., as per the attached receipt. Value Payee Address..... Code 70. Thanks Name of Authorising Person.. Tel No of Authorising Person.. DSE Procedure Version 2.0 Page 22 of 22 Jackie Betts January 201i