House of Commons - Work and Pensions

Select Committee on Work and Pensions Fourth Report

9 INSPECTION AND ENFORCEMENT

121. HSE inspectors have a range of tools at their disposal. They may offer advice, serve improvement and prohibition notices, withdraw approvals, vary licence conditions or exemptions, issue formal cautions and prosecute. HSE defines 'inspection' as the proactive mechanism used to assess the extent to which duty-holders have discharged their duties and to motivate them to do so.[200] It usually involves a visit to the workplace to look at how health and safety is managed. An 'investigation' is an inquiry into a set of circumstances, most usually those surrounding either an incident or a complaint. Inspectors are not just engaged in inspections. Those in the construction sector, for example, are involved in safety and health awareness days as well as in interacting with designers and clients.[201]

122. The term 'enforcement' has a wide meaning and applies to all dealings between enforcing authorities and those on whom the law places duties (employers, the self-employed, employees and others.) The principles HSC expects enforcing authorities to follow are set out in an Enforcement Policy Statement.[202] A consultation document on HSE's 'interventions strategy' is due to be published in September 2004.[203]

123. Since the Environment, Transport and Regional Affairs Committee reported on the issue in 2000[204], a number of measures have been introduced (such as a new enforcement policy statement) which it is considered should help to improve the quality, rigour and consistency of HSE's enforcement decisions.[205] A number of key issues emerged in the course of the current inquiry, including whether HSE has sufficient resources available for enforcement and the emphasis HSE places on the different aspects of its intervention strategy.

Inspector numbers

124. HSE employed the following number of inspectors in the years 1995 to 2004:[206]

Number of inspectors employed by HSE As at 1 April	Field Operations Directorate	Other	Total
1995			1,478
1996			1,466
1997	780	662	1,442
1998	783	654	1,437
1999	853	644	1,497
2000	898	609	1,507
2001	954	580	1,534
2002	955	670	1,625
2003	962	689	1,651
2004	901	704	1,605

125. According to Prospect, 540 of the 901 Field Operations Directorate staff employed in 2004 are grade 3 and 4 staff working in the front-line doing inspection and investigation work.[207] The remainder are managerial staff, or in policy or support roles. Some work on specific sectors, for example, acting as the main contact point for industry associations, providing industry specific training or trying to influence industry practice.

126. The Centre for Corporate Accountability and Prospect pointed to the direct relationship between resources, the number of inspectors HSE is able to employ and the enforcement activity it is able to carry out.[208] The Committee was told that inspector numbers rose during a period of increased financial resources (2001/02 - 2003/04) and fell in 2004 following a freeze on recruitment as a result of the 2002 Spending Review settlement.[209]

INSPECTORS' QUALITIES AND SKILLS

127. The quality of HSE staff was praised in much of the evidence to the inquiry.[210] A paper presented to the HSC on Becoming a Modern Regulator, raises the question as to whether inspectors should have responsibility for more than one regulatory area.[211] However, the importance of inspectors having expertise in their area was noted. Mr Gary Booton of EEF, the manufacturer's organisation, noted that, recently there had been concerns that a 'relatively inexperienced fieldforce' was relying 'on systems to reach decisions rather than using their discretion.'[212] Prospect, the union representing HSE professional staff, notes an inspection role requires trained and qualified staff:[213]

'Experience shows that even the seemingly most straightforward visit can turn into a complex situation when, for example, asbestos contamination is discovered, or there is a serious fire risk. These types of situations require training so that problems can be identified and dealt with.'

128. The Local Government Association told us that while the involvement of local authorities in enforcement provided an opportunity to use 'multi-functional inspectors',[214] in larger authorities there was almost invariably a health and safety specialist section and there has been a move away from generalist inspectors.[215]

Balance between inspection and information/advice

129. In written evidence, HSC/E told us that 'there is strong evidence to support the continuation of a balanced mix of advice (persuasion), enforcement and business incentives. Enforcement is an effective way of securing compliance. It creates an incentive for self-compliance and a fear of adverse business impacts, such as reputational damage in all sectors and sizes of organisations…There is some evidence that advice and information are less effective in the absence of the possibility of enforcement.'[216]

130. The appropriate balance of these activities emerged as an important question in the evidence to the inquiry. According to the National Audit Office, out of a net expenditure of £202 million in 2002/03, HSE spent £111 million on securing compliance with the law and a further £26 million on improving knowledge of and understanding of health and safety issues through the provision of information and advice.[217]

131. A discussion paper presented to an HSE board meeting on 3 September 2003, proposed putting more emphasis on the 'educate and influence' aspects of their work.'[218] It is said that this will mean using a smaller proportion of the total front line resource for inspection and enforcement. This reflects a belief that 'altering the balance in this way will help [HSE] to climb off the current plateau in safety performance and to tackle the increases in ill health.' However, it is acknowledged that at present the evaluation of the effectiveness of different approaches and techniques is not sufficiently well developed to allow it to be more than a belief. The Centre for Corporate Accountability (CCA), on the other hand, argued that the 'HSE's new evolving policy on enforcement - to move away from inspection, investigation and formal enforcement - contradicts overwhelming international and HSE evidence that it is inspection, investigation and formal enforcement that works best.' [219]

132. A literature review was conducted for HSC/E by way of building an evidence base for the current strategy.[220] This found that enforcement was an effective means of securing compliance, creating an incentive for self-compliance and a fear of adverse business impacts such as reputational damage in all sectors and sizes of organisations. The leadership role provided by HSE and local authorities was an important element in prompting major firms to manage health and safety. The literature review also found some evidence that advice and information is less effective in the absence of the possibility of enforcement.

133. Awareness raising, incentives and enforcement are important, mutually supportive and reinforcing aspects of HSE's work.[221] Awareness raising is particularly important for small and medium enterprises (who may have lower levels of awareness) and is a pre-requisite for compliance. However, as the study points out, awareness does not, in itself, necessarily lead to action in the absence of regulatory or other motives. Furthermore, education, advice and information activities were found to have most impact on those who were already receptive or proactive on health and safety and was less effective with 'reluctant' compliers. Face-to-face contact, in the form of seminars and direct contact by inspectors, is the most effective way of getting the message across.[222]

134. The literature review commented that the 'many organisations are not motivated by the business benefits to improve health and safety'.[223] The Ambulance Service Association told the Committee that making the business case is difficult 'when the objective evidence and data to support them are not readily available.'[224] Difficulties arise 'through the conflict of immediate demands on resources for operational services against investment in longer term control measures where the benefits are difficult to measure and may not be seen for some time, even years.' However, it was 'hoped that with the continuing integration of risk management systems and use of risk registers in the development of organisational strategies and business plans, that these priorities will come to the fore.'

135. In evidence to the inquiry, employers expressed varying views on the importance of the enforcement function. The NHS Confederation told us it played an important role in ensuring health and safety was prioritised:[225]

"Health and safety legislation is best understood by the professionals in the field. However, arguably, this understanding dilutes as one moves up through the managerial hierarchy. Regrettably, health and safety is still seen by some as a potentially expensive nuisance in balancing a range of conflicting resource demands…..There is no doubt that the use of improvement notices by the HSE is a powerful method of forcing an internal review of priorities and raising health & safety up the NHS Board agenda."

136. The Ambulance Service Association reported positive results from a comprehensive round of inspections undertaken by HSE over a period of some six years.[226] A committee had also been set up to lead a programme of improvement. It was felt that HSE representation on that committee had been of great benefit both in terms of helping ambulance services meet the requirements of health and safety legislation and in improving HSE's understanding of, and inspection processes for, ambulance services.

137. The Construction Confederation argued that more inspectors were needed to enable HSE to devote more time to sites where there is most risk of accidents happening.[227] The importance of enforcement action in the construction sector was highlighted, in the Committee's view, by the outcomes of inspection 'blitzes' carried out by HSE. These blitzes involved concentrating inspection effort by bringing resources together in one place at one time, to focus on one theme. Despite the fact that employers were notified of visits in advance, significant levels of non-compliance with health and safety legislation were revealed. For example, a blitz was carried out in May 2002 in Scotland and the North of England looking at falls from height, workplace transport and welfare. [228] 444 sites were visited, 259 notices issued and there were 10 possible prosecutions.

138. EEF, the manufacturers' organisation, said it was unclear whether there was a correlation between increased enforcement and improved health and safety performance.[229] It also considered that increased enforcement action in recent years may have had a negative impact on the way employers view inspectors.[230]

139. In oral evidence, the Minister confirmed the Government's view was that the emphasis on advice and information, rather than inspection and enforcement, needed to increase:[231]

"I think the Health and Safety Executive would share the view that it is engaging industry and business in safety, getting them to recognise the importance of safety, that brings them a greater degree of success than straight enforcement of a set of regulations. It is about winning hearts and minds, it is about persuading people of the importance of safety."

140. In its memorandum to the Inquiry, HSC/E argued that work being done by the National Audit Office (NAO) might 'provide an insight into the HSE's wider regulatory approach and achievements.'[232] In the event, the NAO report concluded that HSE needed more evidence on the effectiveness of its various interventions and recommended a programme of evaluation.[233] The Committee wrote to Mr Bill Callaghan, Chair of the HSC, asking on what basis they had decided that occupational health communications should be a higher priority for extra resources than inspection. In response, Mr Callaghan said that they believed there was sufficient evidence to carry forward pilots in these areas, although 'we accept it is not hard or unequivocal.'[234] A number of points were made regarding the work on communication. For example, the 'Good Health is Good Business' campaign and safety and awareness days had been found to have some positive effects. The Food Standards Agency's campaign to promote action on healthy food and diet was considered to have triggered the kind of national debate and awareness likely to foster changes in behaviour.

141. An either/or choice as to whether to emphasise guidance or enforcement in policies for achieving compliance is too simplistic a decision to make about what works best and quite clearly, they both have their place. Equally, it is important that innovative approaches to achieving better compliance and, in the words of the HSC, 'winning hearts and minds', are developed. The real challenge would seem to be to find ways to achieve this, without developing one strategy at the expense of reducing the role of the other.

142. The evidence supports the view that it is inspection, backed by enforcement, that is most effective in motivating duty holders to comply with their responsibilities under health and safety law. We therefore recommend that the HSE should not proceed with the proposal to shift resources from inspection and enforcement to fund an increase in education, information and advice.

Inspections versus investigations

143. HSC/E's primary aim is prevention. Its memorandum explains that this approach was endorsed in an inquiry into the work of HSE by the Environment, Transport and Regional Affairs Committee in 2000, which also urged HSE to increase investigation and prosecution rates. [235] The Government accepted the recommendation and HSE undertook to increase the number of investigations by 50% from 6.8% in 1999/00 to 10% in 2001/02. The number of incidents investigated peaked at 9.4% in 2000/01 and has since fallen to 5.6%.[236] HSE considers that achieving this change has 'created conflict with the intention to maintain a largely preventive focus'. The ratio of time on proactive and reactive work, which had been 70:30 in 1997/98, fell to 50:50 in 2002/03. HSE explains that this was not felt to be the best balance taking the time devoted to each activity as an approximation for the best mix of the two activities in terms of preventive impact.' Accordingly, it has taken steps to streamline and improve investigation procedures through revised accident selection criteria with the aim of re-establishing a 60:40 time ratio of proactive to reactive work.

144. HSC investigates all fatal injuries.[237] In 2003/04, it investigated 11.4 per cent of major injuries (see Appendix 2).[238] This is higher than it was in 1997/8 (6.4 per cent), but a considerable reduction compared to 15.1% in 2001/02. 5.6 per cent of all incidents reported under RIDDOR were investigated, compared to 8.1% in 2001/02. This figure also has to be seen in the context of underreporting under RIDDOR (see paragraph 11). The Centre for Corporate Accountability (CCA) and Unison estimate that on average, a registered premise will receive an inspection once every 20 years.[239] HSC/E figures show that 6.4 per cent of workplaces falling within the jurisdiction of the Field Operations Directorate were inspected in 2003/04, up from 5.8 per cent in 2001/02.

145. Analysis by the CCA indicates the serious nature of some of the incidents HSE is unable to investigate. It points out that the 80% of major injuries not investigated in 2000/01, included '16 out of 62 amputations to either hands, arms, feet or legs and 69 out of 178 major injuries involving electricity'. [240] It considers that constrained resources are leading to a 'misleading debate about 'inspections' versus 'investigations' and said that 'it is difficult to see how the 'balance has gone too far towards investigations when, despite the shift, so many serious incidents were still not being investigated.'[241]

146. In order to achieve the shift towards proactive work, HSE is piloting new criteria to reduce the number of incidents investigated.[242] Under the new criteria, for example, scalpings are not to be investigated and amputations of digit(s) past the first joint only 'where the incident involved potential for more than one finger or for hand/arm amputation.'[243] Inspectors currently have discretion to investigate an incident where, for example, they consider there may have been a serious breach of the law. This will no longer be the case. In oral evidence, Mr Steve Kay of Prospect gave us an example of the sort of accident that would not be investigated under the new criteria[244]:

"A few years ago I investigated an accident to a man whose hand was caught in the platens of an injection moulding machine, a heated injection moulding machine because it cures the rubber at very high temperatures. The guards on this machine were defective; he touched it and it closed on his hand so he could not get his hand out and it was effectively cooking his hand at oven sorts of temperatures. He could not get his hand out and his work-mates had to prize the moulds open using bars, so his hand was in there for a period of minutes. Under the new selection criteria that will not be investigated because burns to less than 10% of the body are not to be investigated, and that is of serious concern to us….If an employer has breached the law in such a blatant way and there is a serious outcome as a result, that should be investigated as a moral issue."

147. A paper to a meeting of the HSE Board noted that the revised criteria had reduced the number selected for investigation 'by more that was initially intended' and that amended criteria were to be piloted until the end of June 2004 before consulting with the Commission on how to proceed.[245]

148. Asked about the proportion of major accidents investigated, Mr Timothy Walker, Director General of the HSE said[246]:

"We would not agree that it is too low a number. Not all accidents will benefit from an HSE investigation and we think we need to concentrate our investigation skills and experience both on those cases that are likely to lead to prosecution or where there is considerable learning involved either for that company or for other companies."

149. However, this begs the question as to how, in the absence of an investigation, HSE can be confident that a case is unlikely to lead to prosecution or to have considerable learning involved.

150. The number of proactive inspections is also low. HSC/E told us that 6.4% of premises within the remit of HSE's Field Operations Directorate were inspected in 2003/04[247]. Ms Mary Boughton of the Federation of Small Businesses told us that 'the majority of small businesses never have an inspection.'[248] Dr Janet Asherson, of the CBI told us that 'statistically, enforcement and inspection across the piece of all British business is a rare event.'[249] The Committee is concerned both at the low level of incidents investigated and at the low level of proactive inspections and recommends that resources for both are increased (see paragraph 82).

TARGETING RESOURCES

151. One of the 'key drivers for change' in HSC's recently published strategy document is to target HSE and local authority resources where they can have most impact.[250] This means 'discouraging HSE and local authorities from putting resources into issues where the risks are of low significance, well understood and properly managed.' A recent internal discussion document issued by the HSE indicates that this may be difficult to achieve in practice.[251] One option is for HSE not to intervene in particular employment sectors or in particular activities or processes such as office work or light assembly. However, it is noted that this 'would make no allowance for variation in duty holder performance and it is difficult to see how 'proper management' of risk could be ensured.' Deciding not to cover particular hazards would have the same drawback, although to an extent it already operates through the concentration on priority programme areas. A further option is to allow specific duty holders 'earned autonomy' to manage health and safety risks without routine intervention from enforcement agencies. Such a programme has been operated in the US in the form of a 'Voluntary Protection Programme.' The paper comments that this system appears to be complex and bureaucratic.

152. The idea of putting higher performers 'on trust' was supported by organisations such as the Institution of Occupational Safety and Health and the Royal Society for the Prevention of Accidents.[252] The TUC, however, was concerned that employers might respond by putting a lot of effort into reducing accident reporting.[253] Prospect pointed out that HSE already use a risk targeting approach and good employers are not inspected anywhere near as often as those with poor health and safety records.[254]

153. The Committee believes that before adopting a policy of reduced inspection for employers with an established record of good practice, there is a need for clear and thorough evidence-based analysis to ensure that the reduction does not lead to negative outcomes such as improper pressures to achieve a reduction in accident reporting.

LOW LEVELS OF ENFORCEMENT OF CERTAIN ASPECTS OF THE LEGISLATION

154. There is concern that certain important aspects of the legislation are not enforced. Mr Hugh Robertson of the TUC told us that the 'two twin pillars' of health and safety culture - involvement of the workforce and risk assessment - are 'not there at the moment.'[255] These fundamental aspects of the legislation are rarely enforced. For example, there was concern from trade unions at the lack of enforcement action on the regulations dealing with consultation with employees and safety representatives (see Chapter 14).[256] Levels of enforcement of the regulations requiring employers to conduct risk assessments are also very low. In 2002/03, there were only 109 informations laid (leading to 66 convictions) under regulation 3 of the Management of Health and Safety at Work Regulations 1999. Given the lack of awareness of these regulations (some 43% of employers[257]), this seems a very low level. (See Appendix 3)

155. The issue around whether an employer was using competent persons to assist them in complying with their duties under health and safety law was another area in which more enforcement is said to be needed.[258] Figures from HSC/E show that in 2002/03, there were one conviction and 81 improvement notices issued under the relevant regulation (regulation 7 of the Management of Health and Safety at Work Regulations 1999.)

156. The Royal Society for the Prevention of Accidents told the Committee that [259]:

"Very importantly, HSE need to prioritise their enforcement effort towards the rectification of underlying health and safety management weaknesses such as the absence of professional advice, absence of appropriate management and skill [in] H&S training, absence of risk assessment, absence of active and reactive monitoring, absence of consultation and performance review etc"

157. Given that risk assessment, the use of competent persons to assist with health and safety requirements and worker participation is crucial to implementing European health and safety legislation, the Committee believes that HSE should increase the visibility of its enforcement action in those areas.

PUBLIC SAFETY

158. This is not an issue into which the Committee was able to enquire in detail during the inquiry. However, we note that employers have a duty to conduct their undertaking so as not to expose the public to health and safety risks[260]. In 2003/04, HSE investigated 6.9 per cent of injuries to the public reportable under RIDDOR.[261] This is an increase compared to 1997/98, when only 2.4% were investigated but is a reduction compared to 9.1 per cent in 2001/02.

159. HSC/E has announced its intention to 'determinedly move away from intervening in those areas of public safety that are better regulated by others or by other means.'[262] The Centre for Corporate Accountability (CCA), however, argued that no other body has the power to enforce section 3 of the Health and Safety at Work Act. A death in custody, may, for example, be a result of inadequate working practices or training and such organisational matters would not be considered by the police.[263] CCA has obtained a legal opinion on the question as to whether the policy is in breach of HSE's duty to 'make adequate arrangements for the enforcement of these duties.'[264] This concluded that the policy was ultra vires and was extremely likely to lead to unlawful decisions that would be amenable to legal challenge. If this is the case, HSE may not be able to rely on withdrawing from areas of public safety as a means of freeing up resources for other activities.

Does HSE need more inspectors?

160. The Committee received evidence on enforcement activity in two of HSE's priority programme areas - construction and the health service. In the context of the construction industry, the National Audit Office (NAO) found that there was one HSE inspector for every 3,333 construction sites.[265] The NAO described the strategic approach taken by HSE to maximise the effectiveness of its work in the construction industry. Steps taken included working with other stakeholders in the supply chain (such as clients and designers), supplementing its usual site inspections with blitzes concentrating on particular risks, and initiatives targeted at workers, such as Safety and Health Awareness Days. Nonetheless, both employers and unions in the sector told the Committee they considered HSE to be under-resourced in terms of being able to carry out the level of inspections needed in the industry, The Construction Confederation, for example, told us that HSE only had sufficient resources to be reactive after the event and needed another 50 inspectors to be able to devote more time to those sites where there was the highest risk of accidents happening.[266]

161. The NHS Confederation told us that it did not feel HSE was sufficiently well resourced to meet its objectives within the NHS.[267] In 2003/04, HSE had carried out 201 inspections within the health service, where nearly 1.3 million staff are employed in many thousands of workplaces. Concerns about lack of resources for enforcement were echoed by the Royal College of Nursing and Unison.[268]

162. Evidence also suggested that HSE inspectors were under considerable pressure. Mr Gary Booton of EEF told us that inspectors appeared to be 'under time pressures not to dig into what has happened…but simply to say, 'Right, there is one more job, one more to tick off.' [269] Mr Steve Kay of Prospect said that in order to be able to focus limited resources on priority areas, inspectors were being told to ignore other areas unless they became matters of evident concern.[270] This pressure on inspectors' time has been recognised by the head of the Field Operations Directorate (FOD), who has noted that increasing the contact time inspectors have with duty holders was a continuing concern in FOD.[271]

163. One of HSE's responses to this has been to pilot new approaches, using visiting administrative staff working alongside inspectors in frontline roles, to deliver key health and safety messages.[272] There are now some 60-70 such administrative staff and their work enables inspectors to spend more time targeting the duty-holders most in need of HSE attention. Prospect, the union representing HSE professional staff, was, however concerned at untrained and unqualified staff having a 'quasi-inspection role when what is needed is a trained and qualified person to exercise their judgement.[273]

164. Mr Bill Callaghan, Chair of the HSC, did tell the Committee that HSC had put a 'strong case to ministers for more resources' in respect of occupational health support and communications but was more equivocal when asked whether HSE needed more inspectors.[274] Mr Gareth Williams of the Department for Work and Pensions said[275]:

"if you ask the HSE, as you did, had they more resources, where would they put them, the answer would not be inspectors, it would be around the advice and communication and prevention upfront. Even if you sought to improve that ratio with the additional funding to that order of magnitude, you still would not cover every company, you would still only inspect them on a limited number of occasions and the advice would depend on the day you turned up."

165. However, the fact that even if the number of inspectors increased, you would not cover every company, is not an argument for not increasing the number of inspectors. The recent literature review on the effectiveness of HSE's interventions found some evidence that higher levels of enforcement would prompt organisations to make further health and safety improvements.[276] Furthermore, evidence shows that face to face contact is the most effective way of providing information and advice, particularly for small firms[277] and inspectors are ideally placed to do this.

166. The Committee believes that the number of inspectors needs to be increased in order that HSE can increase the number of incidents investigated and the number of proactive inspections. A further question is what level of increase HSE should be aiming at. EEF, the manufacturers organisation, argued that[278]:

"We simply do not know whether the appointment of say 50 more health and safety inspectors would lead to improvement x in health and safety performance and therefore secure saving y for all concerned."

167. A number of other organisations provided us with suggestions as to the level of increase HSE should aim at. Prospect argued that the number of inspectors should be doubled so that each workplace can be inspected at least every five years and so that each new workplace is inspected in its first year of operation.[279] It estimates that the cost of an additional 700 inspectors in the Field Operations Directorate 'would rise to something like £48 million after 6 to 7 years.'[280] The Institution of Occupational Safety and Health suggested that as the majority of existing inspectors was focused on safety, additional inspectors were needed to concentrate on health issues.[281] It proposes doubling the number of inspectors in HSE (at an eventual cost of some £77.3 million a year) and employing an additional 150 full-time investigators to concentrate on work-related road safety (at an estimated cost of £7.25 million pa.)

168. The Centre for Corporate Accountability suggested that HSE should have sufficient resources to[282]:

Adequately enforce section 3 of the Health and Safety at Work Act, in relation to responsibility of employers not to expose the public to health and safety risks;
Investigate all major injuries falling into certain categories, all dangerous occurrences, all cases of industrial disease reported to it;
Inspect all workplaces in certain hazardous industries (manufacturing, agricultural workplaces, for example) at least once a year and all workplaces at least once every five years;
Investigate all deaths in a prompt manner;
Introduce independent legal oversight for prosecutions;
Employ a number of family liaison officers to work with families at the time of death; and
Increase resources available for monitoring local authority enforcement activity.

169. As previously stated, the Committee believes that a substantial increase in resources is needed for inspection (see paragraph 82).

200 http://www.hse.gov.uk/aboutus/hse/meetings/2003/030903/item7.pdf Back

201 Volume II (Ev132, Q514); Oral Evidence session with Public Accounts Committee. Monday 24 May 2004, HC 639-I Q122 Back

202 HSC (2002), Enforcement policy statement. www.hse.gov.uk Back

203 HSE, Discussion paper for views on 'areas where HSE and LAs will not be proactive' Back

204 Environment, Transport and Regional Affairs Committee, The Work of the Health and Safety Executive, Fourth Report. Session 1999-2000. Volume 1. HC 31-1 Back

205 Volume III (No. 41) Back

206 Adapted from Official Report, 17 May 2004, col 734W. 'Other' includes, for example, the Nuclear Safety Directorate and Hazards Installations Directorate Back

207 Volume III (No. 30) Back

208 Volume III (Nos. 30 and 41) Back

209 Volume III (Nos. 30 and 41); Volume II (Ev 34 Q118) Back

210 See, for example, Volume III (Nos. 5, 20, 26 and 35) Back