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May 10, 2015

Compulsory Continuing Professional Development endangers the Public

By Abdul Mousa, Ph.D., P. Eng., Fellow IEEE A) Abstract

Several provincial engineering associations imposed compulsory Continuing Professional Development (CPD) in recent years, and some other BC professions, e.g. Certified General Accountants and Architects, did the same. Following the herd mentality, APEGBC is proposing to impose a CPD Bylaw that requires members to earn a certain number of Professional Development Hours (PDH) per year. The pressure to impose a CPD Bylaw increased following the 04/Aug/ 2014 failure of the tailings storage facility at Mount Polley, BC, even though it has been shown that the subject incident had nothing to do with CPD.

The claimed objective of the Bylaw is to maintain the competence of the members of APEGBC so as to protect the public. This document exposes the fallacy of that proposition by showing that:

1) Little or no competency will be gained from compulsory CPD because:

a) The PDH/CEU (Continuing Education Unit) is not a valid metric for assessing learning because CPD service providers arbitrarily assign such credits, use these as a marketing tool, and often grant credits for useless activities.

b) For many years, vendors have realized that their commercial propaganda, which often involves claims that are false and/or promote unsafe products, would be more potent if presented as educational material. Hence they have been using the seminars of CPD service providers, the technical presentations of professional conferences, and the technical articles in trade journals to deliver their commercial promotions.

c) In the case of engineering where the subject is complex, authoritative technical papers are few and second rate ones and those tainted by commercial interests abound, technical competence can only be gained by in-depth self-study of the literature, occasionally supplemented by courses from recognized universities and a few other reputable expert CPD providers. The record of such learning should be Certificates of Completion/Attendance rather than PDH/CEU credits.

d) Compulsory CPD detracts from the serious work that is needed to reach and maintain competence, and it instead converts professionals into PDH collectors chasing bits and pieces of superficial knowledge. In addition to missing the opportunity to reach and maintain competence, compulsory CPD makes them an easy prey to the ongoing attacks of the vendors that are described above.

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2) The public interest will be harmed when the PDH collectors subsequently attempt to apply the superficial and commercially tainted information which they have been fed, and that includes materials that is technically incorrect and/or promotes unsafe products. B) Introduction

1) When APEGBC issued its invitation for consultation meetings (copy enclosed), it offered a credit of one Professional Development Hour (PDH) for every participant who registered and paid the related $10 fee. Obviously, attending that event contributed nothing to the competence of the participants. Hence the related PDH credit was only intended to induce members to attend. In this connection, it should be noted that PDH credits are sometimes expressed as Continuing Education Units (CEUs).

2) The practice of APEGBC of offering PDH credits for activities that do not contribute to competence of its members is not new. For example, according to an announcement in July/August 2006 edition of Innovation Magazine (copy enclosed), the Association promised PDH credits for anyone who volunteered to help in processing a surge in membership applications which the Association then received. Needless to say, sifting through the documents of those applicants would not make the volunteer more competent.

3) In cases like the above, it is not clear whether the APEGBC administrators, who misused their power to grant PDH credits, did so because they did not know what “competence” meant in the context of professional engineering/geoscience, or knew but deliberately misused the system to serve their own objectives.

4) While the above conduct is scandalous because APEGBC claims that maintaining the competence of its members is the objective of its CPD program, the situation within the CPD industry at large is much worse. For the problem is not limited to granting PDH credits for worthless material. Rather, they allow vendors to present their false claims as educational material. The result is that the participants are dis-informed/brain washed, and hence they are worse off than if they did not attend. This can be dangerous in the case of a profession where its members do design work and/or advise the public regarding what products and systems to use. The incident which brought the above sad fact to the attention of the writer is presented hereafter. C) The PDH/CEU Credit Scam

1) The undersigned is a lightning protection expert who has published many papers on this subject starting in 1976 [1]. Lightning protection is accomplished by providing sacrificial “air terminals” (Franklin rods, masts or shield wires) to intercept the lightning strokes, then divert these safely to ground via a system of buried electrodes (ground rods, counterpoise, the metallic footings of structures, etc.) and “down wires”. The above constitutes the “conventional system” which is universally adopted in national and international standards.

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2) During the 1970’s, an entrepreneur named Roy Carpenter suggested that it would be better to prevent lightning strokes from terminating on the protected object than letting them occur as usual, then intercept them and divert them to ground. He hence formed a company named Lightning Eliminators & Consultants (“LEC”) to manufacture and market his devices. After extensive investigation of his claims based on both field observations and theoretical studies, independent scientists concluded in 1975 that lightning cannot be eliminated and that the said devices do not work [2]. Since then, the above finding was confirmed by further investigations, including two papers by Mousa [3, 4] and a review paper by a CIGRE Working Group [5].

3) As part of their marketing campaigns, manufacturers are always willing to have their representatives visit the offices of companies that are potential users of their devices, so as to make promotional presentations about their products and the related technologies. Of course, such presentations by vendors are free of charge, and vendors are especially eager to provide such presentations when their claims have been criticized. In this connection, it should be noted that LEC offered to make a presentation to the staff of BC Hydro at the time when the undersigned was still working there. That offer was rejected based on my advice.

4) In view of the above, I was shocked when I received an ad from a CPD service provider named EUCI (Electric Utility Consultants Inc.) for two webinars on the lightning protection of oil & gas facilities, for which the instructors were two of the employees of LEC: Peter Carpenter and Joe Lanzoni, and the fee for each webinar was US $295. The webinars were scheduled for 24/May/2012 and 06/Jun/2012. The worst aspect, however, was that EUCI was offering CEU credits to the participants. A copy of the cover page of the brochure of EUCI is enclosed.

5) So here you have it: a CPD service provider offering credits for information which is commercial propaganda for a product that has been condemned by the scientific community. Further, it was charging fees to the participants for material which LEC has been willing to provide for free, by having one of its sales staff visit the premises of any interested company.

6) I initially thought that the staff of EUCI had been misled by LEC, and that they would back off and cancel the subject webinars if I made them aware of the invalidity of LEC’s lightning elimination claims. This I did, not just by providing my personal opinion as a lightning expert, but also by referring them to the material on the web site of the International Conference on Lightning Protection (www.iclp-centre.org). But EUCI refused to cancel those webinars. My conclusions were that:

a) They do not care about the technical validity of the content of their courses, which means that they are only interested in collecting fees;

b) It was obvious to me that LEC did not ask to be paid for the “services” of their salesmen, and they probably also paid EUCI to organize those webinars. This means that EUCI was making more profit from those webinars than it would make from offering

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credible courses where the instructors have to be paid. That extra profit must have been the driver behind the scandalous conduct of EUCI.

7) The brochure of EUCI stated that it was authorized to offer CEUs for its courses by IACET (International Association for Continuing Education and Training, McLean, Virginia, USA, www.iacet.org). Having got no satisfaction from EUCI, I complained to IACET regarding the misconduct of its certified CPD service provider. Their response was even more shocking: they refused to investigate my complaint and said that it was up to EUCI to decide the matter. That fact is documented in the 11/May/2012 reply of Mr. Khunteang Pa, who was then IACET’s Senior Director of Programs (copy enclosed).

8) IACET is the successor of a not-for-profit organization that was formed decades ago with the objective of “bringing quality, excellence and integrity to continuing education and training programs”. CPD service providers who join IACET, by paying its fees, become certified service providers and that entitles them to grant CEUs for their courses. The definition of the CEU was first introduced in 1970, and the process for assigning it is included in a document that is administered by IACET: ANSI/IACET 1-2013: Standard for Continuing Education and Training.

9) In connection with the above, it should be noted that the fees charged by IACET are as follows:

• $450 for the application form/package. • $3,250 for the application fee. • $835 annual fee

10) Same like ANSI, IACET is presently run by a board selected from among its constituent members, .i.e. it is a self-policing operation. Hence they have no real interest in enforcing IACET’s original objective of “bringing quality, excellence and integrity to continuing education and training programs”. Nevertheless, they still use that slogan so as to serve their business interests. As to the staff of IACET, they apparently want more CPD service providers to join so as to bring in more fees for use as salaries and benefits of themselves. Hence it would be contrary to their interest to kick out misbehaving members, which could turn out to be a majority of IACET’s members.

D) Discussion

1) Imposing compulsory CPD on the members of professional societies corners them into becoming “PDH collectors” rather than learners. That is not much different from being stamp collectors or comic book collectors!

2) The above created a demand in the market place that led to the rise of hundreds of profit-driven CPD service providers. Those entities administer the provision of CPD services by seeking instructors, advertising the offerings of those instructors, collecting fees from the participants, paying the instructors, and keeping the balance to cover their administration costs

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and provide a profit. In doing the above, most CPD service providers have no way of assessing the worth of their offerings and, the way things are, they do not care! This similarly applies to many not-for-profit CPD service providers as their administrators seek to grow their business so as to generate bigger salaries and benefits for themselves.

3) Vendors have long realized that advertising would be more potent if their commercial propaganda was disguised as educational material. With the CPD industry being mostly profit-driven and the profit margin being larger in offering such material, the system has been badly corrupted and the attendees cannot tell whether their PDH collection activities are making them any wiser.

4) In addition to the EUCI webinars mentioned above, the staff of LEC directly delivered technical presentations at conferences. Examples of these are listed in [6] - [9]. According to the proposed rules of APEGBC, a member would earn PDH credits if he/she attended such presentations.

5) The conduct of EUCI is like the case of magazines that disguise vendors’ promotional material as technical articles, and charge the vendors for the publication space at the same rate as ads or even higher. By the way, there is also a firm named Power PR (www.PowerPR.com) which specializes in writing such articles on behalf of vendors, then getting these published in several magazines to make the subject commercial propaganda more potent in misleading the readers. I learned of that company because LEC also used its services. Power PR sometimes listed the names and affiliation of its technical writers, perhaps to get some publicity for itself: [10] – [15]. In other cases, the author of the article was not identified: [16] – [18].

6) Some of the commercial propaganda that is included in CPD course materials involves exaggerated claims regarding the performance of products and systems that seek to give one vendor an unearned advantage over its competitors. The PDH collectors who attend those “educational activities” become involuntary participants in anti-competition activities that harm their employers and/or clients. Other PDH collectors cause much bigger harm because the course materials which they received involved promotion of dangerous products. That is especially serious in the case of engineers because the crux of their mission is ensuring safety of the public.

7) As an example of the above, a vendor succeeded in corrupting the IEEE Standard on the Shielding of Substations against Direct Lightning Strokes, by introducing an invalid design method that promotes the type of devices which it sells [19]. During the related debate, it was argued that the subject design method should not be in a standard because it has not been previously applied to the design of substations. The supporters of the vendor within the IEEE Working Group responded by holding a seminar to teach that invalid design method to engineers. Since the improper design of a substation can cause blackouts that would affect the safety, comfort and economic interests of hundreds of thousands of people, this is a gross example of the damage that can result from the quest to collect PDH credits.

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8) Engineering is a complex subject in which expertise and competence can only be gained by in-depth studies of the literature over many years, coupled with engagement in its application to actual situations. Forcing members of these professions to run around to collect PDH credits, and to waste more time in documenting and reporting compliance, can only be counterproductive as it detracts from the in-depth studies that produce competence.

9) The above in-depth studies can of course be supplemented by courses from credible educational institutions and/or participation in technical conferences. This should be occasionally done when resources are available and the person is keen on the subject. Such participation should only be documented by “Certificates of Completion or Attendance”, and not by award of PDH credits, as there is no way of measuring the resulting learning in such cases. Self-respecting institutions only provide such certificates.

10) As an example of the above, I was granted a Completion Certificate in 1976 when I attended the seminar on Optimized Transmission Line Design that was then organized by the Power Systems Engineering Department of General Electric Company. More recently, the 2012 International Conference on Lightning Protection provided Attendance Certificates to the participants, including myself. Copies of the certificates of the above two great learning events are enclosed, and neither of them speaks of PDHs nor CEUs credits. In contrast to the above, I received a CEU credit in 1979 (certificate enclosed) for attending a seminar on lightning protection that was organized by PDS (Professional Development Services). I found that seminar to be week and I think that the related CEUs was intended as a consolation for the failure of PDS to provide a good seminar.

11) As shown above, the system of accrediting CPD service providers is a sham as IASET in effect only seeks to collect fees from CPD service providers, and they are free to do whatever they wish after getting registered. That includes packaging the exaggerated and false claims of vendors as educational material.

E) Closing Remarks

1) While some courses of study help advance the competence of the participants, the CPD industry has been corrupted, the user has no way of telling whether he/she will be informed or dis-informed, and the related PDH/CEU awards are mostly meaningless. This invalidates the metric upon which the proposed bylaw of APEGBC is based.

2) Compulsory CPD rests on the premise that it serves the public interest by advancing the competence of the participants. As shown herein, that premise is absolutely false as compulsory CPD would make the participants less competent, it is contrary to the public interest, and it would actually endanger the public in some cases.

3) The analysis herein was based on examples on the subject of lightning protection in which the writer is an expert. However, the conclusions apply to all engineering fields as this analysis reveals that the CPD industry has been corrupted.

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4) Unlike most other professions, engineering deals with the use of goods, services and systems where the exaggerated and false claims of the suppliers abound. For decades, the selling tactics of the vendors have included presenting their claims as educational material. Hence the success of CPD in other fields, if any, is not relevant to engineering.

5) The public has no clue regarding the real implications of compulsory CPD. Hence, even if they were valid, public opinion surveys on this subject are worthless and only serve the agenda of the CPD promoters who paid for those surveys.

6) Even if we ignore the corruption of the CPD industry, the benefits of compulsory CPD are disputable while its costs are not. Whether a net benefit exists is best established by the position of the regulator when it is required to pay for the time off work plus the expenses related to compulsory CPD. That is the case where the regulation of the teaching profession in BC is concerned as it is done by the Ministry of Education, which also pays the teachers’ salaries. The fact that compulsory CPD does not apply to teachers shows the real position of the BC government where the decision is based on proper examination of the facts. Hence I reject the vague and unsupported claim that the BC government really wants APEGBC to adopt compulsory CPD.

7) The above suggests that compulsory CPD is either driven by parties who stand to gain from it, or by persons who do not know what it takes to be competent as an engineer. This means that they are acting outside their scope of competence and/or in violation of the Code of Ethics.

8) There is a famous saying from the Wizard of Oz movie: “You do not need a brain, you need a certificate”! The CPD industry, as well as the regulators who have been brain washed by its propaganda, are in effect saying: “You do not need to be competent, you only need to collect PDH/CEU credits”!

REFERENCES

[1] A.M. Mousa. (1976). “Shielding of High-Voltage and Extra-High-Voltage Substations”, IEEE Trans., Vol. PAS-95, No. 4, pp. 1303-1310.

[2] J. Hughes (Editor). (January 1977). Review of Lightning Protection Technology of Tall Structures, Proceeding of a conference organized by the US Office of Naval Research, Arlington, Virginia, held 06/Nov/1975.

[3] A.M. Mousa. (1998). “The Applicability of Lightning Elimination Devices to Substations and Power Lines”, IEEE Trans. on Power Delivery, Vol. 13, No. 4, pp. 1120-1127.

[4] A.M. Mousa. (July 2003). “Validity of the Lightning Elimination Claim”, Proceedings of the IEEE-PES Annual Meeting, Toronto, Ontario.

[5] CIGRE WG C4.405. (October 2011). “Lightning Interception – Non Conventional Lightning Protection Systems”, Electra No. 258, pp. 36-41.

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[6] R.B. Carpenter, L. Marsh and R.L. Auer. (1993). “A Lightning Prevention System for Industrial Applications”, Proceedings of Industrial & Commercial Power Systems Technical Conference, pp. 33-40, 187.

[7] R.B. Carpenter. (June 1995). “Lightning Protection Systems for Automated Cement Plants”, Proceedings of Cement Industry Technical Conference, pp. 75-80.

[8] R.B. Carpenter and G. Yeh. (June 1996). “Lightning Protection for Pulp and Paper Industry”, Proceedings of Pulp and Paper Industry Technical Conference, pp. 140-156.

[9] R.B. Carpenter, Mark Drabkin and Edward Bazelyan. (29-30 May 2002). “Status of Charge Transfer Technology”, ERA Technology Conference, Paper #13, Keresley, Coventry, Britain, 13 pp.

[10] Jason Mino, Power PR. (October 2000). “Lightning Dissipation System offers Better Protection”, Northwest Public Power Association Bulletin, pp. 22-24.

[11] Jason Mino, Power PR. (May 2001). “Lightning Prevention Specialist saves Auburndale Power $100,000 a Year”, Northwest Public Power Association Bulletin, pp. 25-27.

[12] Del Williams, Power PR. (April/May 2002). “Dissipation Array System Technology offers Protection Against Lightning”, Remote Site & Equipment Management, pp. 23-24.

[13] Del Williams, Power PR. (July/August/September 2006). “Should your Plant rely on 250-year-old Lightning Rod Technology”, Electrical Source, pp. 26-28.

[14] Del Williams, Power PR. (April 2008). “Solving the Lightning Problem”, Electricity Today, pp. 64-66.

[15] Del Williams, Power PR. (30/Apr/2013). “Solving the Lightning Strike Problem at Nuclear Power Plant”, EngineerLive.com/content/21086, 3 pp.

[16] Anonymous. (May-June/ 2003). “Avoid Lightning”. Southern African Wireless Communications, pp. 28-29.

[17] Anonymous. (August 2004). Ion Plasma Generator Reduves Wind Turbine Lightning Strikes”, Power Engineering, 3 pp.

[18] Anonymous. (06/Feb/2006). “Protection Zones leave Upstream Facilities Lightning Strike-free”, International Oil & Gas Engineer, 3 pp.

[19] A.M. Mousa. (November 21, 2014). “Flaws of the Standard-Making Process of the IEEE and Related Impact on Lightning Protection Standards”, a presentation to the International Conference on Lightning Protection that was held in Shanghai, China, October 2014, a PowerPoint presentation, 52 pp., copy posted at: http://tech.groups.yahoo.com/group/LightningProtection/message/2700

Encl.

18 February2015

As part of APEGBC's consultation process, we are seeking feedback from the membership about the proposed CPD bylaw and legislative amendments. Members are strongly encouraged to attend and to share their thoughts and comments on these important issues.

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Home Events BN2FEB15

Member Consultation: Proposed CPD Bylaw and Legislative Amendments

Status: Seats are Available

Date: February 18, 2015

Time: 6:00 - 8:15 pm

Location: Burnaby BC Hydro Edmonds Auditorium, 6911 Southpoint Drive, Burnaby, BC Please see description for parking instructions.

Presenter:

PresidentJohn Clague, P.Geo., PhD, FGC

Dr. Clague is a geologist who serves as the Canada Research Chair in Natural Hazard Research and a Shrum Professor of Science at Simon Fraser University. Dr. Clague has also worked as a Research Scientist with the Geological Survey of Canada for 23 years. His other roles related to the professions include serving as Director of the SFU Centre for

Natural Hazard Research, Adjunct Professor of Environmental Engineering at the University of British Columbia and offering services as a consultant for private-sector firms and government agencies. In addition to this, Dr. Clague has also sat as President of the International Union for Quaternary Research, the Geological Association of Canada and the Canadian Geoscience Education Network.

Dr. Clague served as APEGBC Vice President for the 2013/2014 term, and has been a Councillor for five years.  He is a Director of the APEG Foundation, Director of Geoscientists Canada, and a member of the Audit and Geoscience Committees.

Dr. Clague received his Bachelors in Geology from the Occidental College in Los Angeles in 1967 and his Masters in Geology at the University of California in Berkeley in 1969. He went on to earn his PhD from the University of British Columbia in 1973. Dr. Clague has received a number of awards and honours including the J. Willis Ambrose Medal and the Logan Medal from the Geological Association of Canada, the Bancroft Award from the Royal Society of Canada and the Christopher J. Westerman Memorial Award from APEGBC.

Credit: 1 Informal Professional Development Hours (PDH)

Cost: $10 (includes pizza dinner and drinks).

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RE: EUCI Webinar on Lightning Elimination Devices & IACET Standard

From: Khunteang Pa (kpa@iacet.org) Sent: May-11-12 12:38:08 PM To: 'Abdul Mousa' (abdul_mousa@hotmail.com) Cc: aa-e-p@vip.cybercity.dk (aa-e-p@vip.cybercity.dk)

Hello Mr. Mousa,

Thank you for your email. Unfortunately, IACET is not able to take any action against EUCI. We, as a continuing education and training accrediting organization, review and approve an organization’s continuing education systems (i.e. the organization’s policies, procedures and processes for development and delivery of training) and we do not review content. My recommendation would be to submit your complaint directly to the organization.

I apologize for not being able to assist with your complaint any further.

Best,

Khunteang Pa

Senior Director of Programs

IACET

1760 Old Meadow Road, Suite 500 | McLean, VA 22102

703.506.3275 l 703.506.3266 l kpa@iacet.org

www.iacet.org

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Come Stop by IACET’s Booth #2706 at the SHRM Conference in Atlanta, GA June 24­26!

From: Abdul Mousa [mailto:abdul_mousa@hotmail.com] Sent: Friday, May 11, 2012 12:07 PMTo: Khunteang PaCc: aa-e-p@vip.cybercity.dkSubject: EUCI Webinar on Lightning Elimination Devices & IACET Standard

Dear Mr. Pa,

Many thanks for sending me the draft IACET standard. I will be sumitting my comments in due course.

I am a fellow of the IEEE (Institute of Electrical & Electronics Engineers), and served as a Specialist Engineer in the electrical power industry for about 35 years prior to retirement. I specialize in lightning protection and act as co-moderator of the Yahoo Lightning Prpotection forum, which has about 3,100 members worldwide.

My interest in the IACET standard arose from discovering that EUCI (Electric Utility Consultants Inc., of Denver, Colrado) is a member of IACET, and that EUCI is hence authorized to grant CEUs (education credits) for its seminars. EUCI's seminars cover a wide range of non-specialized subjects, and most of those seminars are probably worthwhile. However, they have just decided to delve into the very specialized subject of lightning protection, which they should have abstained from getting into, as they have no way of ascertaining the value of the material being offered, thus violating the promise of quality which is implied in the IACET authorization to grant CEUs.

The problem at hand is much worse than just poor quality. A vendor of the so-called lightning elimination devices offered to do a seminar for EUCI and they apparently accepted without any investigation regarding credibility of the instructors, nor validity of the theory for which would-be students would pay money and receive CEUs. On the other hand, the subject lightning elimination claims have been repeatedly condemened by the scientific community since the related gadgets were first marketed in the 1970's. Actually, the manufacturer (Lightning Eliminators & Consultants Inc.) has usually been more than willing to offer free "seminars" about its commercial propoganda, and some informed parties declined that offer. That is why I was shocked that EUCI is asking people to pay to be brain-washed with invalid commercial propaganda, and offers them CEUs for being misled!. A copy of the announcement about the subject webinar is enclosed. This is planned to be run on May 24 and June 6, 2012.

In addition to commenting on the IACET standard which governed the granting of status to EUCI, I wish to know to whom to complain about the inexcusable mistake which EUCI initiated, and will apparently proceed with unless they are given a wake-up call. Hence I would appreciate it if you provide me with name of the person to whom my complaint should be submitted.

Thank you.

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Abdul M. Mousa, Ph.D., P. Eng., Fellow IEEELightning protection consultantVancouver, Canadaabdul_mousa@hotmail.com

From: kpa@iacet.orgTo: abdul_mousa@hotmail.comSubject: RE: Requesting copy of draft standardDate: Fri, 11 May 2012 14:57:13 +0000

Hello,

Attached please find a zip file containing the Draft Standard and IACET Comments Template.

Khunteang Pa

Senior Director of Programs

IACET

1760 Old Meadow Road, Suite 500 | McLean, VA 22102

703.506.3275 l 703.506.3266 l kpa@iacet.org

www.iacet.org

Come Stop by IACET’s Booth #2706 at the SHRM Conference in Atlanta, GA June 24­26!

From: Abdul Mousa [mailto:abdul_mousa@hotmail.com]Sent: Friday, May 11, 2012 10:44 AMTo: Khunteang PaSubject: Requesting copy of draft standard

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From: kpa@iacet.orgTo: abdul_mousa@hotmail.comSubject: RE: Requesting copy of draft standardDate: Fri, 11 May 2012 13:40:53 +0000

Hello,

Please review, sign and return IACET's Draft Standard Revision Document Release Agreement.

Thank you.

Khunteang Pa

Senior Director of Programs

IACET

1760 Old Meadow Road, Suite 500 | McLean, VA 22102

703.506.3275 l 703.506.3266 l kpa@iacet.org

www.iacet.org

Come Stop by IACET’s Booth #2706 at the SHRM Conference in Atlanta, GA June 24­26!

From: Abdul Mousa [mailto:abdul_mousa@hotmail.com]Sent: Friday, May 11, 2012 1:57 AMTo: Khunteang PaSubject: Requesting copy of draft standard

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