Alternative solutions include enacting a number of recommendations related to the Administrative Battalion Chief (See Recommendation #2), elevate the Administrative Battalion Chief to assist with more of the duties assigned to the Deputy Fire Chief, and either hire/assign a civilian logistics manager or assign a full‐time training officer (Captain) to work under the Administrative Battalion Chief.
Recommendation #4:
Refine the Fire Prevention Inspection Program
The current staffing levels within the fire prevention bureau are adequate and efficientforthe size and complexity of the jurisdiction, however, the fire prevention bureau still has a few challenges. The main challenge falls underthe category of standardization between the three cities; a common theme throughout this report. The DMR, ENC, SOL FD has made great strides in standardizing many processes within the bureau, such as aligning fire codes and DMR, ENC, SOL Fire Departments Page 16 © Fitch & Associates, LLC Management/Administrative Assessment October 2021 their adoption cycle (currently the 2018 International Fire Code and 2019 California Fire Code), they have transitioned to a 100% electronic plan review system, aligned master fee schedules, etc. However, the bureau still has several facets of the program that are not yet aligned, such as; street and electric gate standards, how follow‐up code enforcement is carried out, some fire prevention staff members are dedicated to working solely within their “home” jurisdiction so there is limited flexibility in balancing workload between the three respective cities. These challenges hinder the ability of the bureau to carry out its mission effectively.
The recommended “refinement” of the fire prevention program essentially falls in two key areas. 1. Continue to seek standardization of codes, processes, systems, and practices (see Strategic Recommendation 9). 2. Refine the annual occupancy inspection process to better align resources to mitigation of risk to the communities served with the current staffing configuration.
Currently, the fire prevention bureau’s goal is to inspect 100% of “inspectable occupancies” annually. Due to the challenges mentioned prior, the bureau is capable of inspecting 100% of the California State Fire Marshal’s Office – mandated occupancies13, however, it is only able to inspect about 90% of the other occupancies within the three cities. This 10% gap is not currently triaged, so a high‐risk occupancy has the same chance of missing an annual inspection as a low‐risk occupancy. A missing inspection, in this case, is not necessarily completely missed, as it might be picked up within weeks or months of its planned inspection cycle, but the risk can be significantly different between a high‐risk and a low‐risk occupancy experiencing a delay in receiving a fire/life safety inspection. Therefore, it is recommended the fire prevention bureau assess all their inspectable occupancies, classify them into three categories and adopt the following sample criteria for inspection cycles:
Inspect 100% of high‐risk occupancies annually (California mandated occupancies, plus i.e., any building with a commercialfire protection system, assemblies, large or multi‐story commercial, industrial, etc.)
Inspect 100% of medium‐risk occupancies every two years (i.e., medium office buildings, strip malls, etc.)
Inspect 100% of low‐risk occupancies every three years (small office buildings, stand‐alone businesses, drive‐thru kiosks, etc.)
The proposal of these new inspection categories and cycles is to ensure that the highest risk occupancies are inspected annually and to avoid any “gaps” in the program since the lower risk occupancies are still inspected but at an interval that is within the capabilities of the
13 California Health & Safety Code – 13145 & 13146
DMR, ENC, SOL Fire Departments Page 17 © Fitch & Associates, LLC Management/Administrative Assessment October 2021 current staffing configuration of the bureau yet does not put the jurisdictions at any unreasonable risk. The proposed inspection categories are just an example. The fire prevention bureau can assess the risk of the different types of occupancies within the jurisdiction and modify as needed to provide the highest level of mitigation commensurate with staffing, capabilities, and community expectations.
Recommendation #5:
Conduct an assessment of the agency’s culture in regard to diversity, equity, and inclusivity in the workplace
There are many areas of the budget where substantial funding is being spent but the money has a nexus to an outcome. For example, fair pay and benefits might help attract and retain good employees, and those employees provide a service that results in a positive outcome for the community (rapid response, lower insurance rates, high cardiac survival rate, low urban blight, etc.). However, a few areas of risk create a tremendous draw on the budget with little to no value to the community, examples include but are not limited to: instances of bad employee behavior, investigations, discipline, grievances, lawsuits, and injury. An example of the legal exposure related to these examples can be illustrated with a few interesting facts.
In 2019, there was 27 career firefighter line‐of‐duty deaths in the U.S.14; however, there were literally hundreds of agencies thrust into litigation due to employee behaviors, unprofessional interactions, and/or lack of meaningful preventative training.15 In terms of cost to the agencies involved, it is difficult to fully measure the impacts, but a key indicator is the comparison between firefighter line‐of‐duty deaths and instances of firefighter malfeasance. The trend for firefighter line‐of‐duty deaths has stayed fairly steady over the past decade but impacts due to firefighter malfeasance and subsequent litigation continues to grow at an alarming rate. When we look at the amount of funding that fire agencies dedicate to firefighter training for operational hazards, then compare that to the funding dedicated to shielding the agency from a multi‐million‐dollar legal challenge (usually caused by a disconnect between the agency’s policies and a culture of indifference within the workplace) we see the disproportionate funding and the unfortunate results that follow.
The assessment of the Del Mar, Encinitas, and Solana Beach Fire Departments did not reveal any explicit or above‐average problem in the area of culture. In fact, fire administration has probably addressed this better than most agencies as they have invested in agency‐wide
14 U.S. Fire Administration – Career firefighter fatalities for 2019 15 Career Survival Group – www.careersurvivalgroup.com DMR, ENC, SOL Fire Departments Page 18 © Fitch & Associates, LLC Management/Administrative Assessment October 2021 training above and beyond the traditional default method of assigning online computer‐based training to meet the bare minimum of requirements. However, the best practice today is to assess the culture so that blind spots can be revealed and addressed over time. There are some recognized benchmark measurements that can be incorporated as objective measurements for this type of program. They are usually incorporated into the strategic planning process (See Specific Recommendation 7) to ensure transparency and accountability. The bottom line is the process is designed to ensure ongoing public trust.
Itis,therefore,recommended the DMR, ENC, SOL FD conduct an assessment ofthe workplace culture in regard to diversity, equity and inclusivity. Such assessments can be completed by any number of subject matter experts that specialize in this field. Typical assessments for any agency similar to DMR, ENC, SOL FD might cost between $10,000 and $20,000. Findings can be directed by and to the agency’s legal representative to ensure confidentiality. The Fire Chief and administrative staff can then use the findings to refine their training and other resources to address the areas of concern over time, thus reducing the risk of litigation to the agency and the contract cities. This strategy can also be valuable in demonstrating to the employees, elected officials, and the community‐at‐large the DMR, ENC, SOL FD is taking actionable steps to ensure the workplace culture is open and fair to all.
Recommendation #6:
Develop an expanded/more efficient internal communication strategy from the Fire Chief’s office
A lack of meaningful communication within the organization is a common issue brought up by various respondents, but also one of the most commonly cited problems in almost every organization. It is not unique to the DMR, ENC, SOL FD but is nonetheless an area that can be improved with a healthy return on investment once implemented. It is a basic function of human nature to want to know the future and employees will carry this expectation into the workplace. The Fire Chief and the Deputy Fire Chief carry the most influence and weight because they provide information that has not been filtered through multiple layers of the organization, and there is a perception they have a greater level of accountability for the accuracy of the information provided (no plausible deniability).
However, communication can also be one of the biggest consumers of time for the chiefs when they take time to "make the rounds" to each station/crew/shift, craft memos, or send out email updates. However, there is likely no better system in place than face‐to‐face interaction, so the best answer seems to be a balance between the different systems of DMR, ENC, SOL Fire Departments Page 19 © Fitch & Associates, LLC Management/Administrative Assessment October 2021 communication to leverage as much information as possible without overtaxing the chief officers.
The chiefs already make a concerted effort to get "face time" with the crews. The process can now be followed up with the expanded use of the agency’s current video conferencing system (Zoom). One of the positive aspects of the recent pandemic is most people are now very well versed in video conferencing and is now more widely accepted.
Therefore, it is recommended the Fire Chief and/or Deputy Fire Chief provide a video update to the organization on a scheduled basis. This would replace some, but not all, of the time and effort put into station rounds, thus leveraging some additional time back to the chiefs.
Many agencies use this format for getting critical information out quickly while also providing a method to get feedback from the crews so the information can be further refined to ensure the message is clear for everyone.
The key is to provide a steady source of reliable information on potentially the hottest topics in a timely manner. This will stifle rumors and produce an increased level of trust due to the extra transparency. This must be all be done with the recognition that the consumers of the information will never stop consuming, and the Fire Chief and Deputy Fire Chief need to be spending time on strategic matters, as well, to keep the organization safe.
Recommendation #7:
Develop a Community‐Driven Strategic Plan
The most progressive fire agencies have several things in common, one of them is the use of strategic planning to make sure current activities and resource allocations are all done in alignment with longer‐term goals and objectives. The DMR, ENC, SOL FD is among one of the more professional and progressive fire agencies in the nation as it has chosen to develop a standards of cover, it’s asking for a third‐party review of its administrative programs, and its exploring fire service accreditation; however, an updated strategic plan is one of the core elements of a professional and progressive fire agency that is still pending.
The best practice is to develop a select group of community stakeholders to help provide inputinto the strategic planning process from the perspective ofthe customer. To emphasize the importance of this strategy to the fire service as a whole, the United States Fire Administration has recently adopted a “people‐centered” focus as the first step in their As Fire Service
Leaders we are
in the "People
Business."
People Centered
People Focused
People Committed
- G. Keith Bryant
DMR, ENC, SOL Fire Departments Page 20 © Fitch & Associates, LLC Management/Administrative Assessment October 2021 decision‐making16 model, which means the industry is embracing its responsibility to ask the customerfirst before they determine any levels of service they may be assuming the customer wants.
Granted, the council form of local government provides a level of citizen oversight, but with only a select few councilmembers, their capacity to gain meaningful feedback may not truly reflect that of the community‐at‐large. Councilmembers are also trying to balance many different city priorities and might not always be able to dedicate the time to participate in an in‐depth exploration of the agency’s capabilities and needs. One solution that has gained considerable credibility in local government oversite of their public safety functions is the use of community stakeholders to fill the gap.
The community stakeholder group should include a number of major segments of the community including representatives from various demographic groups, business leaders, influential citizens, perhaps a member of the media, homeowner groups, etc. This group should be ideally ten (10) to twenty (20) representatives of the community; a number that is not too large to coordinate but large enough to provide a broad array of feedback from the customer’s perspective.
The community stakeholder group should be able to commit the time necessary to complete the whole process that could be as little as one day or several multi‐hour sessions over several days. Some sessions could be in a classroom, or even virtual, and consist of presentations and some workshop activities. Other sessions could include field trips to see agency facilities and equipment, meet firefighters in their work environments, and perhaps even some carefully supervised hands‐on activities allowing for experiencing first‐hand some of the challenges faced by firefighters.
Ideally, the coordination of the citizen stakeholder group activities would include the members ofthe agency’s strategic planning group (fire administration, various members from the rank and file, as well as labor). The goal is to educate the community stakeholders to a degree higher than the average citizen so they can make informed decisions. Then, through a facilitated process, the stakeholders would provide feedback on the levels of service they want, the scope of services valued, what items are most important to them, what items are least important to them, etc.
16 U.S. Fire Administration – Strategic Plan Fiscal Years 2019‐2023 DMR, ENC, SOL Fire Departments Page 21 © Fitch & Associates, LLC Management/Administrative Assessment October 2021 Strategic plans that are developed without customer input put agencies in danger of losing touch with what the end‐user wants, which could have negative political ramifications later on. This recommendation provides the critical elements to the strategic planning process, along with a few additional side benefits. 1. The agency will have a group of strong advocates educating their friends and family on their inside‐view of their fire agency. 2. The agency will have a model process to screen issues from a customer’s perspective to ensure they are maintaining public trust. 3. The process can be designed in such a way as to comply with the Commission on Fire Accreditation International if the agency decides to pursue fire service accreditation (see Strategic Recommendation 8).
The fire administrative staff currently utilize a “Divisional Task List” to track assignments. The list does not necessarily reflect the priority of the task but is a simple and effective method of tracking a project and the date it is due to be completed. Aligning the use of the divisional task list along with the priorities derived from the strategic planning process might not increase the completion rate of tasks but should improve the return on investment in terms of outcomes that are of the most value to the community and the efficiency of the staff.
An additional benefit of completing a strategic plan is the advantage it would provide fire administrative staff in developing annual reports. The basis of the strategic plan is to determine the outcomes the community desires. Once outcome measurements are established, the agency can more succinctly report performance the community desires and in a way they can better understand. The agency’s annual reports contain very important information but can be somewhat confusing to the average citizen as to what it all means to them. Community‐driven strategic plans can answer the following questions with 5 to 7 simple graphs or charts:
How likely is my life, or the lives of my family, going to be saved? How much of my property will be saved (value, capabilities, can my business still operate, etc.)?
What will be my quality of life after an event (or if the event is prevented)? How much is it going to cost me to support, or don’t support, the fire department recommended strategies?
STRATEGIC RECOMMENDATIONS
Recommendation #8:
Explore Accreditation through the Commission on Fire Accreditation International (CFAI) DMR, ENC, SOL Fire Departments Page 22 © Fitch & Associates, LLC Management/Administrative Assessment October 2021 The modern fire service continues to see a growing sense of scrutiny for how it uses the resources it receives from the community. Efficiency and transparency will be the driving forces over the next decade. The Fire Chief is aware of this and has expressed his interest in pursuing Accreditation through the Commission on Fire Accreditation International (CFAI).
The CFAI process was originally developed in the early 1990s as a joint effort between the International Association of Fire Chiefs (IAFC) and the International City/County Managers Association (ICMA). The IAFC's and ICMA's purpose was to develop a system by which fire agencies could be evaluated using a standard set of criteria common to all fire agencies. Since then, the partnership has extended to the International Association of Fire Fighters and the Department of Defense.
The process starts with self‐assessment17, whereby the agency looks at all its internal processes and procedures to make sure they are meeting community expectations (11 categories with 250 performance indicators). Then the system is evaluated using peer‐ assessors (on a five‐year cycle) to verify and validate the agency’s performance. The process is modeled after other accreditation processes such as that for hospitals, law enforcement agencies, and educational institutions.
There were a few issues of concern brought up by various members of the agency during the interviews that did not necessarily meet the scope of this study. However, the accreditation process, if pursued, would be a process that will continually look at all areas of concern and make sure they are addressed systematically, following best practices as generally adopted by a joint International City/County Managers Association, International Association of Fire Fighters and the International Association of Fire Chiefs panel of commissioners. It is universally recognized by all these professional associations that every organization has “blind spots”, and the successful ones will develop a system to routinely look into all areas to ensure they are making incremental improvements. However, it is important to note that many ofthe improvement processes outline by the accreditation process does not necessarily require the agency to achieve recognition through the accreditation governing body (CFAI).
For all intents and purposes, the DMR, ENC, SOL FD can follow the best practices and implement them internally without full recognition of the commission. The main reason for an agency seeking recognition is to give the community it serves proof from a 3rd party perspective that their best interests are being prioritized within the agency.
17 Fire and Emergency Service Self‐Assessment Manual, 9th Ed. – Center for Public Safety Excellence DMR, ENC, SOL Fire Departments Page 23 © Fitch & Associates, LLC Management/Administrative Assessment October 2021 Therefore, it is recommended the DMR, ENC, SOL FD explore accreditation through the Commission on Fire Accreditation International. Once the DMR, ENC, SOL FD understands the key components to the process, a decision can be made in terms of how much of the model they wish to follow and assess the potential return on investment.
Recommendation #9:
Implement strategies to standardize administrative processes between the three agencies
Just as it was described in the background section and within the various recommendations, navigating the diverse administrative processes between the three cities is highly time‐ consuming, especially under the current administrative staffing configuration. It should be recognized thatitis unlikely to align all processes, procedures, codes, standards, and practices but a concerted effort to align as much as possible will leverage additional time and provide a measurable return on investment where the agency can be successful. The balance should be between efficiency and resiliency. The current configuration might have value in terms of cost efficiency for DMR and SOL but may not in terms of overall efficiency, nor resiliency for all three communities. This recommendation would dovetail nicely into Specific Recommendation 7 – Develop a Community‐Driven Strategic Plan. An updated strategic plan would include an analysis of items that can be aligned and prioritized accordingly into the agency’s Divisional Task List.
Examples of items identified by staff that would benefit the agency if aligned:
Purchasing procedures
Supply ordering
Apparatus design and standardization
Facilities repair and maintenance
Code enforcement follow‐up processes
Gate access standards
Street width standards
Agenda report standardization
Routing of agreements, agenda reports, etc.
Recommendation #10:
Explore the use of fire prevention inspection fees to encourage efficiency in enforcement and financial sustainability for the program DMR, ENC, SOL Fire Departments Page 24 © Fitch & Associates, LLC Management/Administrative Assessment October 2021 The fire prevention bureau’s primary mission is to enforce the jurisdictional fire and life safety codes. Many communities lose sight that fire and life safety codes are laws and not just best practices or guidelines. As such, it is often challenging for all fire prevention programs to balance the rule of law with the unique needs and accommodations of the local community.
Added to this, because most fire prevention programs generate different types of revenue from sources such as plan check fees, development impact fees, community facility district fees, inspection fees, inspection fines, etc., they are often pressured to bring in sufficient revenue to be cost‐neutral. However, anytime new fees are proposed, there is the chance of experiencing resistance from the community since they might see it as the fire prevention codes are being overly enforced to ensure a sufficient amount of revenue is generated.
The best practice is to design and adopt an inspection program that encourages safety compliance over revenue so that fees (or fines) are only implemented when the property owner refuses to comply and unnecessarily draws fire prevention resources away from other priority activities. In short, fees or fines are only used to incentivize compliance with the law, however, fines and fees should be sufficiently high enough to adequately cover the cost of engaging in drawn‐out compliance cases, so the program is essentially funded by the non‐ compliant versus the compliant property owner. The benefit of this type of inspection methodology is it incentivizes compliance so that staffing levels can remain as low and efficient as possible.
A proposed inspection process might adopt the following methodology:
DMR, ENC, SOL Fire Departments Page 25 © Fitch & Associates, LLC Management/Administrative Assessment October 2021 Figure 2 – Sample Inspection Process Flow Chart
The use of any fees should be established using a recognized methodology to ensure compliance with California state law18 and that fines are commensurate with the increased level of risk the property owner is imposing on the rest of the community. The three cities currently have adopted masterfee schedules that are routinely validated by a 3rd party. Future master fee schedule updates could incorporate this programming into its validation process.
It is also important to note that considerable investment should be made in community outreach before such a process is proposed to the respective governing bodies. There are many fire agencies in California with similar models, but most would also recommend a methodical approach to avoid unnecessary community misunderstandings.
Recommendation #11:
Explore the feasibility of assigning all DMR and SOL fire apparatus repairs and maintenance to the ENC repair facility
A review of the current fire apparatus repair and maintenance program stands out as a markedly time‐consuming process for administrative staff to coordinate and potentially inefficient in terms of cost to the cooperating cities of DMR and SOL. Depending on the apparatus, nature of the problem, or time of day, there might be four different points of contact to get the unit repaired. Then, depending on the estimated cost of the repair for a
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DMR, ENC, SOL Fire Departments Page 26 © Fitch & Associates, LLC Management/Administrative Assessment October 2021 DMR or SOL fire apparatus repair, the administrative staff need to coordinate with various staff members from the respective city to approve the expense. In addition, the preventative maintenance schedule is considerably different between the three cities. Over time, units receiving less preventative maintenance will naturally require more extensive repairs and longer “out of service” time.
A preliminary review of the ENC fleet maintenance program appears to be a viable solution.
The ENC fleet maintenance program already handles 70% of the combined fleet, has a robust preventative maintenance program that limits apparatus “out of service” times, is well‐ experienced in how to schedule preventative maintenance and routine repairs around field‐ level operational and training needs, and has a labor rate approximately 50% lower than the private vendors ($48 per hour versus $108 or $118). Additional analysis would need to be done to ensure the enhanced preventative maintenance routine would not exceed the anticipated savings, however, the unified coordination by the ENC fleet maintenance division alone could provide substantial time savings for the administrative staff that would need to be allocated a value in the analysis.
Therefore, it is recommended the agency explore the feasibility of assigning all DMR and SOL fire apparatus repairs and maintenance to the ENC repair facility. The analysis should include, but not be limited to, the various hourly labor rates, the transport cost for apparatus that cannot be repaired while at a fire station, the administrative staff time needed to coordinate repairs, the value of standardization of repairs, parts, use of the resource pool, and the amount of “out of service” time.
City of Fort Myers Beach, FL Page 19 © Fitch & Associates, LLC Standards of Cover Study 29 March 2018
APPENDIX A
Functional
Responsibility
Functional Responsibilities
Updated September 21, 2021
Fire Chief Directors’ meetings
Council meetings Governance Board North Zone Fire Chiefs County Chiefs Supervises Deputy Chief Fire Prevention Supervisor Marine Safety Supervisor Administrative Services
Division
Deputy Chief
Operations
Budgeting (3 agencies) Personnel (HR, Risk) Facilities Maintenance Apparatus Maintenance Equipment Maintenance CSA-17 Operations Zone OPs Chiefs liaison Battalion Chiefs Supervisor Career Development Promotional Testing (Administration)
Recruitment, Testing and Hiring
(Administration)
EMS/Paramedic Coordinator Swift Water Incident PIO Administrative Battalion
Chief
Training and Coordination Promotional Testing (Operations) New Hire exams New Hire Academy Coord. Training scheduling North Zone Training Group North Zone Operations secondary Apparatus specs/design Safety/Wellness Emergency Preparedness CERT Training Battalion Chief
A-Division
CICCS
FMZ Coordinator Pre-Fire Plans and IAP's Mapping/GIS Hazardous Materials Coordinator Uniform Committee Chair Battalion Chief
B-Division
RCS and VHF Radios
MDCs CAD/Response plans/Premise Hist. Station Alerting North Zone Communications Group North Zone Technical User Group Battalion Chief
C-Division
Telestaff Policy/Procedures RMS/CFIRS/NFIRS Tableau CERT Coordinator Pagers Knox B/C’s - ALL SHIFTS Emergency Response
Shift Supervisor Morning Briefing Operational Readiness of stations/daily activities
Communicate daily activities with
each station
Operations Chief/Duty Chief and
disseminate critical information as needed
Meet with company officers in
each station to explain new orders, answer any questions, discuss policies and procedures; ensure proper awareness of new standards Relay and receive information,
deliver interdepartmental mail if emergent
Assist the Operation Chief
with Company Officers' evaluations
Assist Company Officers with
counseling and coaching of subordinates when there is a performance or personnel problem if necessary Participate in training activities
and observes companies as they participate in drills
Preliminary investigations and/or
citizen complaints
Analyzes information gained and
handles when appropriate; or formulates report and passes through chain of command Keeps records and reviews RMS
reports per developed program
Participate in agency
scheduled Captains’ meetings when on duty
Participate in agency scheduled
shift or staff meeting
Attend/present at council and
commissions meetings
Incident analysis Telestaff Payroll
EMS Services Division
EMS Coordinator
LEMSIS EMT/PM licensing Continuing Education AED/Defibrillators EMS equipment Controlled Drugs CSA-17 Vaccinations Infection Control QA/QI Marine Safety Division Marine Safety Captain
Liaison to City Offices Liaison to Fire Chief Attend Council Meetings Public Safety Commission Rep State Park Collab Mtgs. Rep SDRALERT, CMSCA,
CLSA/USLA
Operations Budgeting Personnel (HR, Risk) Liaison Supervisor Lt/Sgt’s JG Program Oversight Code Enforcement Supervisor Career Development Promotional Testing Recruit, Hiring, Contracts Special Permits Review Marine Safety PIO Fire Prevention Division
Fire Marshal
Code Enforcement Plan Review Inspection Permitting Fire Protection Planning Public Information Officer Code/Law Review Weed Abatement Wildfire Planning and Mitigation Company Inspections Planning/Traffic Commission Support
Public Education Fire Investigations
Management Services
Division
Senior Management Analyst
Budget Development
and Monitoring
Cost Recovery Grant Writing and
Administration
Data Analysis Policy Review and
Development
Agenda Reports Contracts and RFPs NIMS Compliance City Emergency Mgmt. and Mitigation Planning
UDC Alternate
Management Analyst
Budget Development &
Monitoring
Cost Recovery Grant Writing and
Administration
Data Analysis Policy Review and
Development
Agenda Reports Contracts and RFPs NIMS Compliance City Emergency Mgmt. and Mitigation Planning
UDC Alternate
Admin. Support Coordinator
Training/Certificate
Reimbursements
Travel Expense Claims Invoice/Purchase Order Processing Cal Card Statements Office Supplies Annual Report Records Management Public Education Scheduling Updating Phone Lists DMR, ENC, SOL Fire Departments Page 29
© Fitch& Associates, LLC
Management/Administrative Assessment October 2021