Health Services Union v Bass Coast Regional Health
[2013] FWC 3478
•5 JULY 2013
[2013] FWC 3478 |
FAIR WORK COMMISSION |
DECISION |
Fair Work Act 2009
s.739—Dispute resolution
Health Services Union
v
Bass Coast Regional Health
(C2011/934)
Health and welfare services | |
DEPUTY PRESIDENT HAMILTON | MELBOURNE, 5 JULY 2013 |
Alleged dispute concerning the classification of nursing attendants as per Schedule D, Clause 2.57 and 7.5 of the 2009 Agreement.
On 27 October 2011 the Health Services Union (‘HSU’) filed an application under s.739 of the Fair Work Act 2009 (the Act) against Bass Coast Regional Health. As amended 1, the HSU sought an order that two employees, Mr.Koenig and Ms.Vaughan, are employed as Personal Care Worker Grade 3 under the current agreement, and were employed as such under an earlier agreement2. The employer currently classifies them as Nursing Attendants, at Skill Level 1, and they are currently paid $735 per week. Under the HSU application these workers would be classified as Personal Care Worker Grade 3, which is Skill Level 8, in an agreement with a maximum Skill Level of 11, and they would be paid $848.20. There are no intermediate classifications for this work; there is instead a large jump of over 15 per cent in wages and seven skill levels.
[1] The matter came before Jones C as she then was on 18 November 2011, 2 December 2012, and 19 July 2012 for conciliation. It was allocated to me in late May 2013. I set it down for hearing on 31 May 2013.
[2] Written submissions and witness statements were filed, and the following witnesses gave evidence in support of the application:
Mr Klaus Koenig
Ms Robyn Vaughan
[3] I have had regard to all the submissions and evidence.
[4] The employer made it clear on all occasions that both Mr.Koenig and Ms.Vaughan are valued employees. Both are clearly committed to the workplace and to the patients they care for.
Statutory Provisions
[5] Section 739 provides that I may exercise powers under the disputes settlement procedure of the current agreement in clause 19. The HSU submitted without contradiction that I have jurisdiction to arbitrate this application under the procedure 3.
Submissions
[6] The employer submitted that the employees are appropriately classified as ‘Nursing Attendants’. It submitted that:
• four agreements are relevant to the proceedings, namely the
1. Nurses (Victorian Public Sector) Multi-Employer Agreement 2000-2004 4
2. Health Services Union of Australia - Health and Allied Services - Victorian Public Sector - Multi Employer Certified Agreement 2002-2006 (No. 3) 5
3. Health Services Union of Australia - Health and Allied Services, Administrative Officers - Victorian Public Sector - Multi Employer Certified Agreement 2006-2009 6
4. Victorian Public Health Sector (Health Professionals, Health and Allied Services, Managers & Administrative Officers) Multiple Enterprise Agreement 2011-2015 7. This is the current agreement.
• I should take account of the classification definition, and the duty statements 8 attached to his submission, as well as evidence about the work performed by the employees;
• The skill levels in the agreement only go up to Level 11, and Level 8 is high in the ladder of classifications;
• Because the employees are supervised by a Division 2 nurse they cannot be the equivalent of a Division 2 nurse, contrary to what is said in their witness statements 9;
• ‘Because the level of autonomy that is required at Skill Level 8 is not the level of autonomy that they operate under. They are able to work independently in a very limited environment such as toileting residents who are ambulatory. When the moment comes to doing anything which requires any decision-making such as medication, wound care etc cetera they are not autonomous. They actually perform in a team. They have no level of autonomy at that stage.’ 10
• ‘Our submission as well is the fact that nothing has changed since the introduction of personal care workers. The role that Ms.Vaughan and Mr.Koenig were required to perform in 2002 is still the same role. Nothing has changed. They are still nursing attendants as they were then. There is nothing actually that has changed in the requirements of the role so we haven’t actually redesigned anything to actually come up with a personal care worker classification.’ 11
• The fact that the employees have long tenure does not affect the limited nature of the functions that they perform 12;
• that having regard to the duties, including the fact that the employees did not perform medication duties, the conclusion to be reached is that they are Nursing Attendants;
• the translation arrangements in 2003 are consistent with this, in that the VHIA provided guidance that Personal Care Workers Grade 3 do not count for the purposes of the nurse/patient ratios 13;
• employees including Ms.Vaughan and Mr.Koenig were offered ‘interest free loans ... to further their work qualifications and to ensure the future sustainability and development of the rural workforce...’ The qualifications obtained by both ‘would advantage their own personal growth and development, it would not provide any financial or professional benefit to their position.’ 14
[7] The Health Services Union (HSU) submitted that the two employees should be classified as ‘Personal Care Worker Grade 3’ within clause 7.5 of Schedule F of the 2011 Agreement. It submitted that:
• the employees performed the duties of a Personal Care Worker 3 as required by clause 7.5.1;
• the employees were required by the employer to hold a nationally accredited certificate at Australian Quality Framework Level IV, and despite this they continued to be classified and paid as a ‘Nursing Attendant’ 15;
• Personal Care Work Grade 3 employees are listed as ‘Skill Level ....8’ in Schedule B - Wage Rates for Health Professionals. Skill Level 8 provides a number of requirements;
• the duties of the employees fit within Skill Level 8. The duties of the employees as set out in their witness statements, and in for example Exhibit HSU 4, show a degree of autonomy and responsibility consistent with Skill Level 8, having regard also again to the requirement of the employer that they hold and use a nationally accredited certificate at Australian Quality Framework Level 3;
• medication duties had to be performed by medical staff given legal requirements, and this cannot count against the applicants because a Personal Care Work 3 would not perform medical duties because they lack nursing qualifications;
• this is a high care facility, and the approach to be taken is that the main differentiation between a Nursing Attendant and a PCW3 is the qualification of the employee, with a Nursing Attendant not requiring a formal qualification and a PCW3 requiring a qualification;
• the skill level is also relevant 16;
• the definitions of duties for the two competing classifications of ‘Nursing Attendant’ and ‘Personal Care Worker’ are broad and overlapping;
• Schedule D, Item 7.1 of the 2009 agreement expressly provides that the Personal Care Worker Classification ‘replaces the Nursing Attendant classification in low care/dual care residential aged care facilities’, although this is a high care facility;
• The main point of difference between a ‘Nursing Attendant’ and a ‘Personal Care Worker Grade 3’ is the qualification of the employee. A Nursing Attendant need possess no formal qualification, while a Personal Care Worker Grade 3 must hold a Level III certificate. Qualification rather than duties distinguishes the two classifications;
• The Skill Level at which each employee is working is also relevant, with Level 1 ‘no experience or training is required’ being entry level, and changes to the levels of responsibility;
• There are issues arising from the time of engagement, and under Schedule D item 7.5.2;
• The Personal Care Worker classification was introduced with the 2002 agreement;
• Although the express words of the Aged Care Award 2010 provide in clause 10.1 for an employee to be informed at the time of engagement whether they are employed on a full-time, part-time or casual basis, this in the context of the 2002 agreement may refer to 2003, when a Personal Care Worker classification was introduced. The fact that Mr.Koenig and Ms.Vaughan were employed as Nursing Attendants is not relevant. Properly construed both were required to hold a Level 3 certificate at the time of engagement, or alternatively Ms.Vaughan held such a certificate when engaged;
• The reference in Schedule D, clause 7.5.2 to a requirement in writing to obtain a Level 3 certificate is no more than a sensible administrative mechanism as to how a requirement may be made;
• Alternatively this is a translation dispute;
• Both Ms.Vaughan and Mr.Koenig gave evidence that they perform the duties of a Nurse Grade 2, and specified the duties they perform.
Authorities
[8] In Kucks v. CSR Ltd 17 Madgwick J said that:
‘It is trite that narrow or pedantic approaches to the interpretation of an award are misplaced. The search is for the meaning intended by the framer(s) of the document, bearing in mind that such framer(s) were likely of a practical bent of mind: they may well have been more concerned with expressing an intention in ways likely to have been understood in the context of the relevant industry and industrial relations environment than with legal niceties or jargon. Thus, for example, it is justifiable to read the award to give effect to its evident purposes, having regard to such context, despite mere inconsistencies or infelicities of expression which might tend to some other reading. An meanings which avoid inconvenience or injustice may reasonably be strained for. For reasons such as these, expressions which have been held in the case of other instruments to have been used to mean particular things may sensibly and properly be held to mean something else in the document at hand.’
[9] In AMWU v. Thales Australia Limited 18a Full Bench of the tribunal determined an appeal from a single member decision about the appropriate classification level of a Radiography Coordinator under an agreement by considering the particular terms of the classification provisions in the agreement and the evidence. It said:
‘If Mr.Liddington was being required to perform at Level 3 and/or the position itself could only be performed at Level 3, then it would not be left to the discretion of the Respondent to accept or reject the performance, as Mr.Liddington would need to be reclassified pursuant to subclause 10.6.1.5 of the Agreement.
...
We add that we were not taken to any evidence that Mr.Liddington had been directed to perform duties at Level 3 or that there was a pattern of conduct on the part of the Respondent that indicated, or from which an inference reasonably could be drawn, that it placed expectations on Mr.Liddington to perform duties that were appropriately classified at Level 3.
...
It was open to the Commissioner, in our view, to conclude as he did that the work that is required to be performed, and that which is actually performed by Mr.Liddington, is appropriately classified at Level 5.’
[10] Other decisions in which applications for reclassification of employees under an agreement are determined include AMACSU v. Gold Coast City Council 19, City of Wanneroo20, HSU v. Austin Health21, and Mackay Sugar Limited v. AWU22. In each of these cases the specific classification provisions are considered and interpreted, and applied on the evidence before the tribunal of the work performed by the employees sought to be reclassified, and/or required to be performed by the employer, and any other matter that may be relevant such as formal qualifications.
Agreement Definitions of Nursing Attendant and Personal Care Worker Grade 3
[11] I have referred to the terms of the current agreement in most cases, and in so doing intend to refer where relevant to the same term in the earlier 2009 agreement. In this case the classification definition for a Personal Care Worker 3 are set out in clause 7.5.1:
‘7.5 Personal Care Worker Grade 3
7.5.1 Means a person employed in an aged care service or like service (but not including dedicated disability services or establishments respondent to the Residential and Support Services –Victoria – Award 1999) to provide personal care for disabled or aged persons in a high care residential aged care facility. Such a person is required to undertake the duties of a Personal Care Worker Grade 1; and
7.5.2 A Personal Care Worker Grade 3 holds, at the time of engagement, a nationally accredited certificate at Australian Quality Framework Level 3 (or equivalent) awarded by a Registered Training Organisation; or is required by the organisation to obtain such a certificate as a condition of employment. An Employee shall be advised of such a requirement in writing prior to undertaking the course, or by a verbal request that is subsequently reduced to writing.’
[12] Personal Care Work Grade 3 employees are listed as ‘Skill Level ....8’ in Schedule B - Wage Rates for Health Professionals. Skill Level 8 provides:
‘1.8 Level 8
1.8.1 An Employee at this level:
(a) is capable of functioning semi autonomously, and prioritising his or her own work within established policies, guidelines and procedures;
(b) is responsible for work performed with a substantial level of accountability;
(c) works either individually or in a team;
(d) may require basic computer knowledge or be required to use a computer on a regular basis;
(e) possesses administrative skills and problem solving abilities;
(f) possesses well developed communication, interpersonal and/or arithmetic skills; and
(g) requires substantial on-the-job training, may require formal qualifications at trade or certificate level and/or relevant skills training or experience.’
[13] The classification definition for a Nursing Attendant is set out in clause 2.57:
‘2.57 Nursing Attendant
2.57.1 Means a person employed in attending to the comforts and needs of sick, disabled, aged or infirm persons
2.57.2 The Nursing Attendant does not apply to work performed in low care/dual care residential aged care facilities.’
[14] Nursing Attendants were listed as ‘Skill Level ....1’ in ‘Schedule B - Wage Rates for Health Professionals’. Skill Level 1 in ‘Part 3 - Health and Allied Services Employees Classification Structure’ provides:
‘1.1 Level 1
1.1.1 An Employee at this level:
(a) [sic]
(b) works within established routines, methods and procedures;
(c) has minimal responsibility, accountability or discretion;
(d) works under direct or routine supervision, either individually or in a team; and
(e) no previous experience or training is required.
1.1.2 Indicative tasks performed and indicative classifications at this level are:
Classification Group | Indicative Tasks Performed and Indicative Classifications |
Food Services | Basic Food Preparation; the cooking of basic meals; cleaning of food preparation and consumption areas and cooking equipment and utensils and the serving and delivery of meals. - Food and domestic services assistant - Other cook |
General Services | Cleaning; attending to a lift, car park or incinerator; basic laundry work and the sorting and packing of linen. Assisting a gardener; basic maintenance work; basic sewing; General Orderly/Porterage/Courier functions in hospitals or other health services. - Laundryhand - Incinerator Attendant - Carpark Attendant - Sorter/Packer of Linen - Lift Attendant - Orderly or Cleaner - Seamsperson - Assistant Gardener - Maintenance/Handyperson (Unqualified) - All other Employees not elsewhere provided for |
Technical, Clinical and Personal Care | The operation of automatic photographic processing machines; the cleaning, washing and preparation of equipment and chemicals within a laboratory and the cleaning and washing of surgical equipment within a Central or Theatre Sterilising Unit; the feeding and basic care of animals within animal houses; direct assistance with technical, clinical and personal care duties under supervision and direction; a recording technician operating an ECG/EEG or similar recording equipment; the handling, transporting of client/patients and the preparation of beds; communication and liaison with clients/patients and directly assisting social workers/welfare workers; an Orthotic Technician involved in the manufacture and fitting of orthotic devices in his or her first year of employment as such. - CSSD Attendant - Laboratory Assistant Grade 1 - Darkroom Processor - Animal House Attendant - Orthotic Technician 1 - Nursing Attendant - Theatre Attendant - Recording Attendant (including EEG & ECG) - Social Work/Welfare Aide |
Decision
[15] The definition of a Personal Care Worker Grade 3 in clause 7.5 is very limited in its scope. Skill Level 8 provides more explanation of the classification, and it is agreed that the agreement specifically provides that it is relevant in applying the classification definition 23. This is in any event the only sensible approach to determining classification issues under this agreement, and from the beginning of the new classifications with the 2002 agreement the Skill Levels were expressly linked in the same way with the Nursing Attendant and Personal Care Worker classifications24. Any other approach leaves the Skill Level definitions with little or no work to do, and ignores the specific incorporation of them by Schedule B - Wage Levels, and the limitations of clause 7.5.
Clause 7.5
[16] Turning to deal firstly with the classification definition for a Personal Care Worker Grade 3 in clause 7.5, in this case both Ms.Vaughan and Mr.Koenig on all submissions meet the requirements of clause 7.5.1.
[17] In relation to clause 7.5.2, Mr.Koenig gave evidence that he was told to obtain an AQF III qualification and then an AQF IV qualification 25. Ms.Vaughan gave similar evidence26, although she already had an AQF III qualification on engagement. She says she thinks the job advertisement required qualifications. It appears from the grievance lodged by Mr.Koenig and Ms.Vaughan that the ‘requirement’ that both achieve AQF IV qualifications was allegedly made orally, and was not made in writing27. The earlier Position Description for the ‘Nursing Attendant’ of January 2000 required a Personal Care Attendant (PCA) and Patient Service Assistant (PSA) holding current certificate, and the current Position Description for the Nursing Attendant position of June 2011 ‘required’ a Certificate III or IV28. It appears to be a condition of employment that the AQF III qualification be obtained, but not the AQF IV qualification.
Skill Level 8
[18] Agreements may provide for classification or reclassification simply on achievement of a qualification, but this agreement does not do this. The classification definition in clause 7.5 requires an AQF Level 3 qualification, and then in Skill Level 8 additional requirements are listed relating to the work performed and capability. I also note that Skill Level 8 provides that formal qualifications ‘may’ be required and/or experience, which again is inconsistent with an approach of reclassification based on achievement of a qualification. Again the issue of the work itself is emphasised. It is of course also agreed that we need to look at the work actually performed by the employees and the requirements of Skill Level 8 29. I have had regard to the content of the AQF courses achieved by the two employees.
[19] Turning to deal with evidence, Ms.Vaughan described her work in the following terms:
‘MR WEST: You appear to give the impression in your statement at paragraph 13 that you’re the equivalent of a division 2 nurse. In fact you say:
It is my observation that there are no significant differences between the work performed by a division 2 nurse and myself.
Yet in paragraph 12 and 57 you state both times that you are under the supervision of a division 2 nurse. Which is correct?---I am usually under the supervision of my NUM or my div 2 as they have the medical experience. But if I’m told to do, I just do what I am told to do usually by my one or my two so whatever they say I have to do, I have to do otherwise I’ll be reprimanded.’ 30
[20] This evidence is somewhat in contrast to the evidence given in witness statements, which was that they perform nearly all of the duties undertaken by Division 2 nurses other than certain medical procedures 31, although they are under supervision by Division 2 nurses regarding certain medical work, mainly basic wound care and dressing. During cross examination it was put without disagreement that these employees do not count for the purposes of the nurse/patient ratio32. It was also put in cross examination that the employees are under the supervision of a Division 2 nurse, and therefore they cannot be equivalent to Division 2 nurses33.
[21] Ms.Vaughan gave evidence that she worked in pairs with nurses or another personal care attendant such as herself, and performed duties together. She gave evidence that there are five people involved in a shift, a supervising Division 1 nurse, and two teams of two people. Those two teams are composed of nurses and sometimes personal care attendants. The two teams ‘take half of the facility each’ in a 30 bed facility. Working on a team with a nurse, Ms.Vaughan said that if they had a problem she thought it through with the nurse 34.
[22] Ms.Vaughan also gave evidence about the use of computers, for example she enters ‘WECARE’ information into the computer system, and she performs administrative tasks to some degree 35.
[23] A statement of duties of personal care attendants 36 prepared by the employer suggests that the work performed by Mr.Koenig and Ms.Vaughan is of a somewhat routine nature not requiring autonomous or semi-autonomous decision making, communication and work. For example, ‘resident care’ refers to specific tasks such as showering and bathing, and dressing. Tasks that would involve some degree of autonomous decision making and work would include tasks such as ‘basic wound care and dressings’, but this work is supervised by a Division 2 nurse.
[24] Some limited criticism of the statement of duties is made by Mr.Koenig and Ms.Vaughan 37. Both Mr.Koenig and Ms.Vaughan gave evidence about the work they do38. Mr.Koenig said that he worked with ‘limited supervision’, has often been required to perform handover duties, attends to resident care such as showering and bathing and colostomy bags, documentation including reporting on the WECARE and RISKMANN systems, duties regarding the resident of the day, and other key responsibilities. Similar evidence was given by Ms.Vaughan. Ms.Vaughan said that she did not give handover to the next shift, undertake medications work, conduct medications audits, or some other work39. Both said in the same words that ‘The Division 1 Nurses often approach me for guidance and advice on the current status of patients ....’40
[25] Attached to Ms.Vaughans’s witness statement are her 30 October 2000 letter of appointment, a payslip, a grievance she and Mr.Koenig lodged, and details of her AQF qualifications. Attached to Mr.Koenig’s witness statement are a payslip, the grievance, details of his AQF qualifications, a statement from a nurse manager, a roster which records Mr.Koenig as ‘PCW’.
[26] The duty statements require the employees to act ‘under the direction of the Nurse Unit Manager’, and other matters 41.
[27] Having regard to all the evidence, both Mr.Koenig and Ms.Vaughan operate under a high degree of supervision, with limited or very limited autonomy, decision making, or independent reporting, accountability and responsibility. They may make suggestions and may contribute but others make key decisions about the work. Medication is an important issue in a high care aged residential facility. The decisions regarding medication are made by nurses. Decisions about other medical questions are also made by nurses. This would in any event be a legal requirement. Medical issues would on occasion involve questions of great difficulty and be demanding of the skills of medical staff. Many of the remaining duties would be mainly routine in nature, and even these are organised by others.
[28] Turing to deal with the requirements of clause 1.8.1, each of the requirements in paragraphs (a) to (g) of clause 1.8.1, Skill Level 8, must be met. They are not alternatives. In this case the degree of autonomy that Ms.Vaughan and Mr.Koenig have is limited, and I am not satisfied that either are capable of functioning ‘semi autonomously’ within clause 1.8.1(a). This is a skill or ability which an employee at this level must have. Nor am I satisfied that they are capable of prioritising their own work as required by that clause. They work in teams, and if anything key decisions are taken by others although they may contribute and make suggestions.
[29] They are not ‘responsible for work performed with a substantial level of accountability’ within clause 1.8.1(b). They work under the direction of a Division 1 and 2 nurse, and the nurses are accountable. They both work within a team within clause 1.8.1(c). They have computer knowledge within clause 1.8.1(d). There is limited evidence about their administrative skills and problem solving abilities within clause 1.8.1(e). I am not satisfied that they have sufficient problem solving skills, having regard to my observations above. On the issue of the level of their communication, interpersonal and/or arithmetic skills within clause 1.8.1(f), I heard the witnesses giving evidence, and am not satisfied that Ms.Vaughan or Mr.Koenig possessed well developed communication skills.
[30] I also note that having regard to the skill levels for other categories of employment in the agreement Skill Level 8 again is too high for the work performed by Ms.Vaughan and Mr.Koenig. One clear difficulty with the case put by the applicants is the very high skill level of Personal Care Workers Grade 3, in an agreement which has the highest Skill Level at Skill Level 11 42.
Conclusion
[31] I have had regard to the submissions and evidence before me and am unable to determine that Mr.Koenig and Ms.Vaughan meet the requirements of the Personal Care Worker 3 classification in the current agreement, or the 2009 agreement. I dismiss the application for an order that they be classified and paid at that level. However, they meet all the requirements of the Nursing Attendant classification. An order dismissing the application is contained in PR538401.
[32] In addition, clause 19 permits the Commission to ‘exercise any method of dispute resolution permitted by the Act it considers appropriate to ensure the settlement of the dispute’, which includes a non-binding recommendation. What the employer calls the ‘huge’ gap between classifications 43 could be met by the employer paying an over-award payment, of up to but less than the wage rates set for the Personal Care Worker Grade 1 position. However, that is entirely a matter for the employer, which has made it clear that it is in financial difficulties which could preclude this. My recommendation is that this be given consideration, and no more.
DEPUTY PRESIDENT
Appearances:
Mr M Champion, barrister, and Ms Ismail, lawyer, for the applicant
Mr T West of the respondent
Hearing details:
Melbourne
2013
31 May
1 PN467-474
2 the Victorian Public Health Sector (Health Professionals, Health and Allied Services, Managers & Administrative Officers) Multiple Enterprise Agreement 2011-2015 (the 2011 agreement) AE896737 PR528918; and the Health Services Union of Australia - Health and Allied Services, Administrative Officers - Victorian Public Sector - Multi Employer Certified Agreement 2006-2009 (the 2009 Agreement) AG848611 PR971684.
3 Exhibit HSU1, paragraphs 11-13
4 AG822685 PR929172
5 AG827418 PR936817
6 AG848611 PR971684
7 AE896737 PR528918
8 Attachments DT16 and DT5 to Exhibit B1
9 PN524
10 PN817
11 PN818
12 PN865
13 Exhibit B1, attachment DT11
14 Exhibit B1, attachment DT19
15 Exhibit HSU1, paragraphs 20-35
16 Exhibit HSU1 paragraphs 57-62
17 (1996) 66 IR 182 at 184. See also AMIEU v. Coles per Northrop J (1998) 80 IR 208 at 212
18 [2011] FWAB 8246 at paragraphs 29-34
19 [2007] AIRC 1058, Spencer C
20 [2012] FWA 366, Cloghan C
21 [2011] FWA 6004, Cribb C
22 [2011] FWA 5304, Spencer C
23 PN230-258
24 ‘Personal Care Worker Grade 3 Wage/Skill Group 8’, clause 26.2 of the 2002 agreement.
25 Exhibit HSU2, paragraphs 26-31
26 Exhibit HSU3, paragraphs 23-29
27 Exhibit HSU2, attachment B
28 Exhibit B1, Attachment DT5 and DT16
29 HSU PN222-224
30 PN521-523
31 Exhibit HSU2, paragraphs 12-14; Exhibit HSU 3 paragraphs 12-13.
32 PN512
33 PN521-524
34 PN563-583
35 Exhibit HSU4
36 Exhibit HSU4
37 Exhibit HSU2, paragraphs 54-60; Exhibit HSU3, paragraphs 52-58.
38 Exhibit HSU2, paragraphs 61-88; Exhibit HSU3, paragraphs 59-82
39 Exhibit HSU3, paragraph 56
40 Exhibit HSU2 paragraph 85; Exhibit HSU3, paragraph 83
41 Exhibit B1, DT5 and DT16
42 HSU, PN78
43 PN849-858
Printed by authority of the Commonwealth Government Printer
<Price code C, AE896737 PR537439>
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