Mr Matt Bell v MSS Strategic Medical and Rescue Pty Ltd

[2015] FWC 6230

[2015] FWC 6230

FAIR WORK COMMISSION

DECISION

Fair Work Act 2009
s.394 - Application for unfair dismissal remedy

Mr Matt Bell
v
MSS Strategic Medical and Rescue Pty Ltd
(U2015/306)

COMMISSIONER CLOGHAN PERTH, 10 SEPTEMBER 2015

Application for relief from unfair dismissal - jurisdiction - not dismissed - resigned.

[1] This is an application by Mr Matt Bell (Mr Bell or Applicant) seeking a remedy for alleged unfair dismissal from his former employer, MSS Strategic Medical and Rescue Pty Ltd (MSS SMR or Employer).

[2] The application is made pursuant to s.394 of the Fair Work Act 2009 (FW Act).

[3] In response to the application, the Employer asserts that Mr Bell was not dismissed and that he resigned from his employment on 13 January 2015.

[4] The Employer’s response to the application is essentially that the Commission has no power to deal with the application. Mr Bell has not been dismissed pursuant to s.386(1) of the FW Act and consequently, the Commission can only deal with an application, if Mr Bell was dismissed.

[5] I advised the parties that I would deal with the Employer’s jurisdictional objection by way of written submissions. Subsequent to receiving the written material, I conducted a conference of the parties in compliance with s.397 of the FW Act.

[6] This is my decision and reasons for decision regarding the Employer’s jurisdictional objection that Mr Bell has not been dismissed.

RELEVANT LEGISLATIVE FRAMEWORK

[7] Section 385 of the FW Act sets out the meaning of unfair dismissal as follows:

“385 What is an unfair dismissal


A person has been unfairly dismissed if the FWC is satisfied that:

(a) the person has been dismissed; and


(b) the dismissal was harsh, unjust or unreasonable; and


(c) ...


(d) ...”

“386 Meaning of dismissed

(1) A person has been dismissed if:

(a) the person’s employment with his or her employer has been terminated on the employer’s initiative; or

(b) the person has resigned from his or her employment, but was forced to do so because of conduct, or a course of conduct, engaged in by his or her employer.

...”

QUESTION FOR DETERMINATION

[8] On 13 January 2015, Mr Bell forwarded to Mr S Scott-Higgins correspondence entitled “Employment Issue”. The relevant parts are as follows:

“I refer to your letter of the 9th January 2015, our meeting of the 7th January 2015 and my previous statement about the BBQ held on the night of 14th December 2014.

I wish to state clearly that I deny the allegations of misconduct and therefore challenge your decision to issue me with a first and final warning letter dated the 9^th January 2015 and the findings contained in that letter.
…
Overall then none of your findings can amount to misconduct. You therefore had no basis for issuing me with a first and final warning.

More importantly you had no basis for preventing me from working on BHP site as stated at the meeting and in your letter.

Attached to your letter of the 9^th January 2015 were conditions under which you propose to redeploy me as an ESO to the NT GROOTE EYLANDT.

This will be on a FIFO basis from Darwin/Cairns. I am required to find my own way at my own cost from my home in Western Australia to Darwin or Cairns Airport Finally I note that my rate of pay proposed is $46.94 per hour being $15.37 reduction from my current rate of $62.31 per hour.

I cannot accept the substantially changed conditions proposed.

I cannot accept that your conduct towards me in subjecting me to a disciplinary process and issuing a first and final warning and preventing me from working on a BHP site is reasonable management action in all the circumstances.

The probable and likely outcome of the company’s conduct towards me is to force me to resign.
…
The company has forced me into a situation where I have no choice but to resign. I therefore resign from my employment effective immediately.”

[9] The Employer eventually accepted Mr Bell’s resignation on 16 January 2015.

[10] The jurisdictional question for determination is not whether Mr Bell resigned, because he did. The question is whether he was forced to resign because of conduct or a course of conduct engaged in by MSS SMR.

RELEVANT BACKGROUND

Employment

[11] Mr Bell commenced employment with MSS SMR as a Casual Emergency Services Officer (ESO) on or about 4 September 2013.

[12] MSS Security provides security services to clients throughout Australia and is part of the MSS Group of Companies.

[13] MSS Security has a contract with BHP Billiton Iron Ore (BHPBIO) in the Pilbara region of Western Australia.

[14] MSS Security subcontracts to MSS SMR, specifically for the provision of ESOs.

[15] BHPBIO is MSS SMR’s largest client in Western Australia and represents a vast majority of its work in the State.

[16] On commencement of employment, Mr Bell was residing in Queensland and was employed on a fly-in-fly-out (FIFO) basis from Brisbane.

[17] On 2 October 2013, Mr Bell advised the Employer that he had relocated to Perth.

[18] In February 2014, Mr Bell, of his own volition, transferred from a casual ESO to a permanent employment contract. As a consequence, Mr Bell’s employment conditions, particularly the hourly rate of pay, changed.

[19] In May 2014, the Employer received notification from BHPBIO of contractual changes which would result in a reduction in the Employer’s positions as part of its contract with BHPBIO. MSS SMR began a communication and consultation process with the employees affected.

[20] On 28 May 2014, the Applicant was informed that he would not be retained on the BHPBIO contract. Mr Bell would be reassigned to another role based in Queensland and required to be a FIFO worker from Brisbane.

[21] At the same time, the Employer entered into discussions with the Applicant regarding transferring to MSS Security and working on the BHPBIO contract as a permanent Security Emergency Officer (SEO).

[22] Rather than elect to remain as a permanent ESO based in Brisbane or transfer to MSS Security as a permanent SEO in Western Australia, Mr Bell sought to revert to a casual ESO position working on the BHPBIO contract in the Pilbara.

[23] On 17 June 2014, the Applicant accepted an offer of employment with accompanying conditions of employment as a casual ESO.

[24] The Applicant concedes that, as part of accepting the offer of employment as a casual ESO working pursuant to the BHPBIO contract, his conditions of employment were site specific. Further, that these conditions of employment ceased if he was transferred to another contract due to “variation in services or operational requirements, client request or performance issues” (my emphasis).

[25] In addition, Mr Bell concedes that he was aware that as a casual ESO, work was on an ad hoc basis and no guarantee of on-going work or hours of employment.

BBQ incident and subsequent events

[26] On or about 15 December 2014, the Employer became aware of an incident at a BBQ involving Mr Bell on 14 December 2014.

[27] On 16 December 2014, Mr Bell was required to leave site and was not rostered for further shifts of work.

[28] On 19 December 2014, the Employer provided to Mr Bell a “Letter of Allegation”. The allegations, put shortly, are:

• Mr Bell drove a BHPBIO vehicle (medical buggy) with passengers aboard after having consumed alcohol; and



• Mr Bell was not wearing personal protective equipment (PPE) while operating the medical buggy.

[29] The Employer alleged that the conduct was contrary to its own Standing Instructions and BHPBIO’s Charter Values, Code of Conduct and site safety rules.

[30] For clarity, it should be noted that Mr Bell was not on duty at the time, had not organised the BBQ, and the food and drink was supplied by BHPBIO. The incident came to the attention of BHPBIO by way of a Facebook post.

[31] In a statement dated 15 December 2014, Mr Bell agreed that he drove the medical buggy. Secondly, there were passengers aboard at both the beginning (one) and at the end of the BBQ (three). Mr Bell concedes that he “had a couple of light alcoholic beverages” during the BBQ which went from 6:20 pm to 10:50 pm.

[32] Mr Bell apologised for his actions and stated that he would ensure it never happened again.

[33] Mr Bell and his representative met with the Employer’s representatives on 7 January 2015. Mr Bell alleged that his actions were custom and practice, and that if it wasn’t for the Facebook post, the practice would have continued.

[34] The Employer concluded, on the basis of its investigation and Mr Bell’s admissions, that the allegations were proven. In response, the Employer issued Mr Bell with a first and final warning and advised him that he would not be returning to work on a BHPBIO contract site in the Pilbara.

[35] The Employer’s decision to issue a first and final warning was reduced to writing on 9 January 2015, together with the offer to redeploy Mr Bell into another role.

[36] Mr Bell was advised that alternative work available for him was as a casual ESO in the Gulf of Carpentaria as a FIFO worker from either Darwin or Cairns. The Applicant was informed of the hourly rate of pay and the requirement for him to make his own way to Cairns or Darwin.

[37] In his letter of resignation of 13 January 2015, Mr Bell sets out his “consistent position” with respect to the BBQ incident. Further, “overall then none of your findings can amount to misconduct. You therefore had no basis for issuing me with a first and final warning. More importantly, you had no basis for preventing me from working on BHP sites as stated at the meeting and in your letter”.

[38] Mr Bell concluded his correspondence of 13 January 2015 by tendering his resignation.

[39] Instead of accepting Mr Bell’s resignation immediately, the Employer, in correspondence dated 14 January 2015, held off and gave the Applicant “an opportunity to think about and reconsider your decision [to resign]”. The Employer stated that it disagreed with Mr Bell’s contention that he had been forced to resign.

[40] Mr Bell was given to mid-day on 16 January 2015 to reconsider his resignation decision.

[41] On 15 January 2015, at 10:59 am, Mr Bell responded to the Employer with the words, “nothing you have said changes my decision”.

[42] On 16 January 2015, the Employer accepted Mr Bell’s resignation.

CONSIDERATION

[43] The Applicant submits that the principles in Mohazab and Rheinberger should guide the Commission in determining this matter.

[44] The Applicant also refers to P O’Meara v Stanley Works Pty Ltd.

[45] The Employer agrees that the Commission should consider Mohazab, Rheinberger and P O’Meara v Stanley Works Pty Ltd but also the statements of the Full Bench in ABB Engineering and Australian Hearing v L Peary.

[46] In my consideration of this matter, I intend to commence with the relevant paragraphs in the Fair Work Bill 2008, Explanatory Memorandum (EM)which are as follows:

“1529. Paragraph 386(1)(b) provides that a person has been dismissed if they resigned from their employment but were forced to do so because of conduct, or a course of conduct, engaged in by their employer. Conduct includes both an act and a failure to act (see the definition in clause 12).

1530. Paragraph 386(1)(b) is intended to reflect the common law concept of constructive dismissal, and allow for a finding that an employee was dismissed in the following situations:

• where the employee is effectively instructed to resign by the employer in the face of a threatened or impending dismissal; or



• where the employee quits their job in response to conduct by the employer which gives them no reasonable choice but to resign.”

[47] As I apprehend the Applicant’s submission, it is generally that he was not provided a “fair go”. The Applicant states he was not given a “fair go” for the following reasons:

• the Employer came to the wrong conclusion regarding his conduct during the BBQ incident;



• in any event, his conduct during the BBQ incident could not be characterised as misconduct;



• as a consequence, the disciplinary outcome of a first and final warning was extremely excessive;



• the Employer chose to exclude him from BHPBIO sites to keep its client “happy”; and



• exclusion from the BHPBIO sites was “economically crippling”.

[48] For the above reasons, the Applicant submits that the conduct of the Employer if, “viewed objectively could only result in the applicant leaving employment. Even if the respondent did not intend the outcome…”

BBQ incident

[49] Largely, the facts regarding the BBQ incident are not in dispute.

[50] The Applicant states that the facts are compatible with past practice – in his words, “a cultural norm”. Mr Bell contends that:

• there was no rule or direction that the driver of the medical buggy had to abstain from alcohol during the BBQ;



• no alcohol test was carried out by the Employer or BHPBIO; and



• he behaved properly at the BBQ and on the drive back.

[51] It is true that no blood/alcohol reading was carried out by the Employer or BHPBIO. However, this is because the incident was only brought to their attention after the event by a Facebook post. Secondly, the only material I have regarding whether the Applicant behaved properly at the BBQ and on the drive back is the Facebook post. The Facebook post is not determinative of the Applicant’s contention that he behaved properly, except to say that all present in the medical buggy appear to be having “fun” as described in the Facebook post.

[52] With respect to the “designated driver” abstaining from alcohol, the Applicant disputes that there was a rule or direction. On the material provided, I am not able to make a finding that there was no rule or direction to abstain from alcohol during the BBQ. However, it would seem common sense that such a “rule” would be self-evident.

[53] BHPBIO does not dispute that the BBQ is part of regular “team building” exercise. However, the event does not exclude the requirement to wear PPE and the necessity of a driver, not to consume alcohol.

Mr Bell’s conduct during BBQ and return drive, could not be described as misconduct

[54] With the exception of consuming alcohol, there is nothing to suggest that Mr Bell’s conduct at the BBQ was untoward. With or without a rule regarding the consumption of alcohol, the Employer came to the view that Mr Bell’s consumption of alcohol and driving its client’s vehicle, was an act of misconduct – in my view, such a conclusion was reasonably open to it. The not wearing of PPE on the return journey may seem like a minor infraction but the Employer has the right to enforce, with its employees, the client’s safety policies.

Was a first and final warning “extremely excessive”?

[55] It is not my role in these proceedings, to consider the reasonableness of the Employer’s response to Mr Bell’s actions. The fact is that Mr Bell was given a first and final warning.

[56] Mr Scott-Higgins’ witness statement states that Mr Keating, Superintendent of Emergency Services, BHPBIO, had indicated to the Employer that if it had been a BHPBIO direct employee, in similar circumstances, the person may have lost their job or, if it was a first offence, a first and final warning.

Applicant’s exclusion from BHPBIO sites to keep client “happy”

[57] The Applicant does not make this assertion in his witness statement, however, it is contained in his submission.

[58] I have received excerpts from BHPBIO’s investigation into the BBQ incident. The investigation report was received by the Employer on 19 December 2014. The Recommended Outcome reads as follows:

“MSS Strategic Medical be informed that the incident involving Matt Bell has been investigated and under the BHP Charter Values & Code Of Conduct be requested that he remains off site & not be allowed back on any BHP site.”

[59] The Applicant may conceive that the Employer by following the above recommendation was making BHPBIO “happy”. However, it is a generalisation which the Applicant has a strong commitment to believing. Even if the Applicant’s contention is correct (and I am not suggesting it is) that does not detract from the reasonableness of the Employer complying with BHPBIO’s request.

[60] I now turn to the case law.

Case law

[61] Mr Mullally set out, for the Applicant, the often quoted statement in Mohazab 1 by the Full Court of the Federal Court of Australia:

“In these proceedings it is unnecessary and undesirable to endeavour to formulate an exhaustive description of what is termination at the initiative of the employer but plainly an important feature is that the act of the employer results directly or consequentially in the termination of the employment and the employment relationship is not voluntarily left by the employee. That is, had the employer not taken the action it did, the employee would have remained in the employment relationship…

and the Court when referring to APESMA v David Graphics Pty Ltd, His Honour Wilcox CJ described the circumstances of that case as:

‘…a termination of employment at the instance [of] the employer rather than of the employee.’

And further,

‘I agree with the proposition that termination may involve more than one action. But I think it is necessary to ask oneself what was the critical action, or what were the critical actions, that constituted a termination of the employment.’”

[62] Mr Mullally also acknowledged that in O’Meara v Stanley Works Pty Ltd 2, a Full Bench of the Australian Industrial Relations Commission felt it necessary to state:

“In our view the full statement of reasons in Mohazab which we have set out together with the further explanation by Moore J in Rheinberger and the decisions of Full Benches of this Commission in Pawel and ABB Engineering require that there to be some action on the part of the employer which is either intended to bring the employment to an end or has the probable result of bringing the employment relationship to an end. It is not simply a question of whether “the act of the employer [resulted] directly or consequentially in the termination of the employment.” Decisions which adopt the shorter formulation of the reasons for decision should be treated with some caution as they may not give full weight to the decision in Mohazab. In determining whether a termination was at the initiative of the employer an objective analysis of the employer’s conduct is required to determine whether it was of such a nature that resignation was the probable result or that the appellant had no effective or real choice but to resign.”

[63] While Mr Mullally urged the Commission to adopt the above summary of the principles in determining whether Mr Bell was forced to resign; I only partly agree. In O’Meara v Stanley Works Pty Ltd, the Full Bench went further and stated:

“[20] Moore J, one of the members of the Full Court in Mohazab, addressed the question further in Rheinberger v Huxley Marketing Pty Limited (Rheinberger). His Honour said, after referring to extracts from Mohazab:

“However it is plain from these passages that it is not sufficient to demonstrate that the employee did not voluntarily leave his or her employment to establish that there had been a termination of the employment at the initiative of the employer. Such a termination must result from some action on the part of the employer intended to bring the employment to an end and perhaps action which would, on any reasonable view, probably have that effect. I leave open the question of whether a termination of employment at the initiative of the employer requires the employer to intend by its action that the employment will conclude. I am prepared to assume, for present purposes, that there can be a termination at the initiative of the employer if the cessation of the employment relationship is the probable result of the employer's conduct.”

[21] In this Commission the concepts have been addressed on numerous occasions and by a number of Full Benches. In Pawel v Advanced Precast Pty Ltd (Pawel) a Full Bench said:

“[13] It is plain that the Full Court in Mohazab considered that an important feature in the question of whether termination is at the initiative of the employer is whether the act of an employer results directly or consequentially in the termination of the employment and that the employment relationship is not voluntarily left by the employee. However, it is to be noted that the Full Court described it as an important feature. It plainly cannot be the only feature. An example will serve to illustrate this point. Suppose an employee wants a pay rise and makes such a request of his or her employer. If the employer declines and the employee, feeling dissatisfied resigns, can the resignation be said to be a termination at the initiative of the employer? We do not think it can and yet it can be said that the act of the employer i.e. refusing the pay rise, has at least consequentially resulted in the termination of the employment. This situation may be contrasted with the position where an employee is told to resign or he or she will be terminated. We think that all of the circumstances and not only the act of the employer must be examined. These in our view, will include the circumstances giving rise to the termination, the seriousness of the issues involved and the respective conduct of the employer and the employee…” (my emphasis)

[22] In the Full Bench decision of ABB Engineering Construction Pty Ltd v Doumit (ABB Engineering) it was said:

“Often it will only be a narrow line that distinguishes conduct that leaves an employee no real choice but to resign employment, from conduct that cannot be held to cause a resultant resignation to be a termination at the initiative of the employer. But narrow though it be, it is important that that line be closely drawn and rigorously observed. Otherwise, the remedy against unfair termination of employment at the initiative of the employer may be too readily invoked in circumstances where it is the discretion of a resigning employee, rather than that of the employer, that gives rise to the termination. The remedies provided in the Act are directed to the provision of remedies against unlawful termination of employment. Where it is the immediate action of the employee that causes the employment relationship to cease, it is necessary to ensure that the employer’s conduct, said to have been the principal contributing factor in the resultant termination of employment, is weighed objectively. The employer’s conduct may be shown to be a sufficiently operative factor in the resignation for it to be tantamount to a reason for dismissal. In such circumstances, a resignation may fairly readily be conceived to be a termination at the initiative of the employer. The validity of any associated reason for the termination by resignation is tested. Where the conduct of the employer is ambiguous, and the bearing it has on the decision to resign is based largely on the perceptions and subjective response of the employee made unilaterally, considerable caution should be exercised in treating the resignation as other than voluntary.”

[64] Ultimately, the Full Bench came to the conclusion in O’Meara v Stanley Works Pty Ltd:

“In our view the full statement of reasons in Mohazab which we have set out together with the further explanation by Moore J in Rheinberger and the decisions of Full Benches of this Commission in Pawel and ABB Engineering require that there to be some action on the part of the employer which is either intended to bring the employment to an end or has the probable result of bringing the employment relationship to an end. It is not simply a question of whether “the act of the employer [resulted] directly or consequentially in the termination of the employment.” Decisions which adopt the shorter formulation of the reasons for decision should be treated with some caution as they may not give full weight to the decision in Mohazab. In determining whether a termination was at the initiative of the employer an objective analysis of the employer’s conduct is required to determine whether it was of such a nature that resignation was the probable result or that the appellant had no effective or real choice but to resign.” (my emphasis)

[65] In my view, the Full Bench in O’Meara v Stanley Works Pty Ltd summarised the principles to be adopted in cases where an employee alleges that he or she was forced to resign because of the conduct or a course of conduct engaged in by the employer.

[66] The legislation is framed in such a way that if an employee resigns because of the employer’s antecedent behaviour, it may be a case of termination of employment at the initiative of the employer. It is not a case of an employee who has resigned concluding that he or she must have been forced to resign because of the conduct of the employer.

[67] In this case, the antecedent behaviour was not “caused” by the Employer, but by Mr Bell. The actions of BHPBIO and the Employer were consequential to the conduct of Mr Bell.

[68] The truth of the situation is that because Mr Bell was given a first and final warning and excluded from BHP sites, he asserts that he had to resign.

[69] It is not a necessary condition that because an employee resigns, he or she must have been forced to resign.

[70] In the circumstances of this application, Mr Bell could have chosen to take the option of redeployment proposed by the Employer.

[71] Mr Bell cannot have it both ways. He cannot say the employer’s conduct forced him to resign, and at the same time, deny he was offered deployment elsewhere – he was in a position to adopt a course of action other than resignation.

[72] I consider the essence of the Applicant’s argument is that having been given a first and final warning, and excluded from BHP sites, unless an alternative deployment proposal was to his satisfaction, then he was forced to resign. In my view, this is a different proposition to that set out in the FW Act.

[73] In Mohazab, the Court made a finding of fact that the employer directed Mr Mohazab to resign or have the police called in. The Court found that the employer’s ultimatum was designed to “induce him into resigning” with the unstated consequence of the employer not having to undertake a disciplinary investigation and allowing the employee to explain himself. Finally, the Court concluded that the employer wanted, and it made it clear, that it no longer wanted to employ Mr Mohazab. Given the facts, the Court came to the conclusion that it really was the employer who terminated the employment relationship – employment was terminated at the initiative of the employer.

[74] To use the words of the Judgement in Mohazab, the “critical action” was the ultimatum issued by the employer. The circumstances of this application are not comparable to Mohazab.

[75] The facts of Mr Bell’s dismissal do not set out any ultimatum by the Employer. The facts demonstrate that the Employer did not make a decision to dismiss Mr Bell because of his misconduct - the penalty meant that he would remain in employment. Secondly, although he would not be able to work on BHP sites, it did not preclude him from working on other sites. Thirdly, the Employer actively sought and made available to Mr Bell alternative employment elsewhere. Finally, even when he resigned, the Employer actively encouraged him to reconsider his decision and did not accept his resignation immediately.

[76] In my view, none of these actions are demonstrative of the Employer desiring to end the employment relationship.

[77] Whether a dismissal is a constructive dismissal will very much turn on an objective analysis of the parties’ conduct. In this case, I am not satisfied that the Employer’s actions, either directly or probably, would have resulted in Mr Bell’s resignation. In making such a statement, it is necessary to consider the one remaining factor which is that the offer of employment was “economically crippling”.

[78] With the exception of the reduction in the hourly rate of pay, I have no economic evidence that the Employer’s proposed deployment options would be “crippling”. There is no dispute that the deployment option provided a lesser hourly rate of pay. However, Mr Bell was aware, and agreed, that the hourly rate of pay he received when employed as a casual ESO was site specific and in the context of an uncertain supply of working hours. Further, Mr Bell deliberately put himself in this position when he transferred from permanent employment as an ESO to a casual.

[79] While the Commission acknowledges the lesser hourly rate of pay, should Mr Bell have accepted deployment, and the necessary expenses associated with relocating to Darwin or Cairns, such expenses alone cannot be described objectively as “economically crippling”.

CONCLUSION

[80] In conclusion, I return to the Explanatory Memorandum (paragraph 1528) in which the legislation at paragraph 386(1)(b) of the FW Act is intended to capture the case law in Mohazab relating to the meaning of “termination at the initiative of the employer”.

[81] In Mohazab, the facts demonstrated that Mr Mohazab had no choice but to resign – it was self-evident.

[82] Mohazab is not authority for a judgement by applicants themselves, as to whether he or she was forced to resign because of the conduct of the employer. Mohazab and later decisions are authority for the necessity to objectively examine the facts of both the conduct of the employee and the employer.

[83] Further, it is not a matter of rephrasing the legislation to read that if an employee resigns, he or she was forced to resign because of the conduct of the employer.

[84] Finally, an employee is not forced to resign because he or she, of itself, does not like the alternatives if they are to remain in employment.

[85] Having objectively examined the facts surrounding the circumstances of Mr Bell’s resignation, I am satisfied that he was not forced to resign as a result of a course of conduct or conduct of the Employer.

[86] For the above reasons, I find that Mr Bell was not dismissed pursuant to s.386(1) of the FW Act, and consistent with s.385(a) of the FW Act, cannot have been unfairly dismissed. Accordingly, the application has not been properly made and must be dismissed. An Order to this effect is attached to this Decision.

COMMISSIONER

 1   Mohazab v Dick Smith Electronics Pty Ltd (No 2) (1995) 62 IR 200

 2   O’Meara v Stanley Works Pty Ltd PR973462

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