Good Shepherd Catholic Primary School Springfield Lakes Allergy Awareness and Management Policy

Transcription

1 Gd Shepherd Cathlic Primary Schl Springfield Lakes Allergy Awareness and Management Plicy Overview This plicy reflects Gd Shepherd s Missin Statement: by being pen and welcming, reaching ut t thers with justice and cmpassin. Therefre this plicy is cncerned with a whle schl apprach t the health care management f thse members f the schl cmmunity suffering frm specific allergies. Allergies are becming a mre frequent ccurrence within ur cmmunity. Cnsequently we must respnd t the needs f thse students, staff and vlunteers with identified allergies. Allergic reactins can vary frm mild discmfrt t severe reactins with the ptential t be fatal. Anaphylaxis is a severe and sudden allergic reactin. Cmmn allergens include but are nt limited t nuts, eggs, shellfish, wheat, pllens, dairy prducts, bee stings, hpper ant stings, pet hair etc. Gd Shepherd s psitin is guided by the Health Supprt Guidelines develped by The Australasian Sciety f Clinical Immunlgy and Allergy (ASCIA) which has infrmatin n the preventin f fd anaphylactic reactins in schls, available at PHILOSOPHICAL BASIS Gd Shepherd Cathlic Primary Schl adheres t the Health Supprt Guidelines develped by the Department f Educatin Queensland. Infrmatin regarding the management f Anaphylaxis is taken frm the publicatin, Anaphylaxis in educatin and children s services, the DECS website and the Australasian Sciety f Clinical Immunlgy and Allergy (ASCIA) website, (as abve). Current research and advice regarding Allergies and Anaphylaxis indicates that the practive apprach in managing allergies in the envirnment is t educate ur cmmunity abut the varius types and triggers t allergies, and develp safe practices t supprt cmmunity members with allergies. Risk minimisatin with regard t particular fds (peanuts and tree nuts) is indicated, hwever the implementatin f blanket fd bans r attempts t prhibit the entry f fd substances int schls are nt recmmended. Issues cnsidered in nt recmmending blanket fd bans were: the practicalities f such measures the issue that fr schl age children an essential step is t develp strategies fr avidance in the wider cmmunity as well as at schl the lack f evidence f the effectiveness f such measures ther guidelines and psitin statements and experts d nt recmmend such measures sme guidelines state that such a plicy shuld be "cnsidered" fr a specific fdstuff such as peanuts rather than recmmended fr all allergies fd bans at schls are nt recmmended by allergy cnsumer rganisatins the risk f cmplacency abut avidance strategies if a fd is banned (Australasian Sciety Clinical Immunlgy and Allergy (ASCIA) Psitin Paper/Guidelines fr Schls Preschls) Gd Shepherd Cathlic Primary Schl Springfield Lakes ALLERGY AWARENESS AND MANAGEMENT POLICY p. 1

2 Given the variety f allergy triggers, it is difficult t prtect members f the schl cmmunity frm expsure t ptential allergens. This Allergy Awareness Plicy is in place t minimise the risk f expsure t allergens and triggers t allergic reactins and ensure that staff are trained t prvide apprpriate first aid shuld a child r adult have an allergic reactin. AIMS T minimise risks t staff and students within Gd Shepherd Cathlic Primary Schl wh are identified as having the ptential fr anaphylaxis. T develp an understanding abut allergies and their triggers, and prmte educatin abut safe practice. T be aware f staff, students and vlunteers wh have allergies and their Health Care Plans OBJECTIVES Gd Shepherd Cathlic Primary Schl is cmmitted t taking 5 key steps t develp an Allergy Aware Envirnment. These are: 1. T btain medical infrmatin abut children at risk and develp a written care supprt plan devised in cnjunctin with a health prfessinal and the student s family. 2. T educate schl staff and relief staff and thers in the schl cmmunity respnsible fr the care f students, cncerning the risk f certain fds and envirnmental allergens. 3. T implement practical strategies t avid expsure t knwn triggers, where pssible. 4. With parents/caregivers, prvide age apprpriate educatin t students with severe allergies. 5. T regularly review and mnitr all health care plans. Definitins Allergy - A cnditin in which the bdy has an exaggerated respnse t a substance (e.g. fd and drug). Als knwn as hypersensitivity. Allergen - A nrmally harmless substance that triggers an allergic reactin in the immune system f a susceptible persn. Anaphylaxis - Anaphylaxis, r anaphylactic shck, is a sudden, severe and ptentially life-threatening allergic reactin t fd, stings, bites, r medicines. Epipen - Brand name fr syringe style device cntaining the drug Adrenalin which is ready fr immediate inter-muscular administratin. Minimized Risk Envirnment An envirnment where risk management practices (e.g. Risk assessment frms) have minimised the risk f (allergen) expsure. Health Management Plan A detailed dcument utlining an individual student s cnditin treatment, and actin plan fr lcatin f Epipen. Gd Shepherd Cathlic Primary Schl Springfield Lakes ALLERGY AWARENESS AND MANAGEMENT POLICY p. 2

3 Allergy Awareness Prcedures Identificatin and Dcumentatin f Medical Infrmatin Obtain medical infrmatin regarding the allergy at the time f enrlment, emplyment r engagement and an annual update thereafter. When a student, staff member r vlunteer is diagnsed with an allergy, relevant dcumentatin is t be prvided by an authrised adult and medical practitiner in the frm f a Health Care Plan (Appendices 3,4,5,6,7). This Health Care Plan and any relevant medicatin will be held at the Schl Office. A cpy f the Anaphylaxis Actin Plan (Appendix 5) is als t be kept in a designated Teacher s flder and is t be taken with the relevant medicatin by the teacher, whenever the persn at risk leaves the grunds e.g. fr excursins, walks, etc. Where a student, staff member r vlunteer has an allergy, written cnsent (Appendix 4) fr infrmatin and phtgraph t be detailed n an at risk list which will be displayed in the Staff Rm in the apprpriate area, ie Playgrund Duty and in a cnfidential flder at the frnt desk. Phtgraphs f students with knwn allergens are t be kept with medicatin in the Wellbeing rm t minimise the pssibility f wrngly administering medicatin. Parents will be alerted t the benefits f using a Medical Alert Identificatin bracelet. The schl will update the Health Care Plan annually with the child/student s Dctr. Educatin Whle schl cmmunity t be educated abut the dangers f allergies. The schl cmmunity will be encuraged nt t bring fds that may trigger severe allergies t schl e.g. nuts r nut cntaining prducts. Educatin will be prvided thrugh newsletters, class ntes, the schl web site and parent infrmatin sessins. Staff undertaken Senir First Aid training cvering the recgnitin f the risks f allergies and understanding the steps that can be taken t minimise these risks. Allergy training is t be prvided by qualified prfessinals and reinfrced annually. Imprtant tpics t be addressed in training include: understanding f allergies and anaphylaxis; triggers fr allergy and anaphylaxis; preventin and recgnitin f anaphylaxis; actins required in the event f a severe allergic reactin and instructin in EpiPen use. Staff will have access t Schling and childcare - website: Staff wh have cntact with students with knwn allergies need t be aware f risk factrs fr that student. Staff in cntact with a student with a severe allergy will need t adhere t any special requirements put in place fr that class. Students with an allergy parents/caregivers, in cnsultatin with a medical practitiner, t educate the at risk student in the self-management f their allergy, e.g. what is safe and unsafe, strategies fr aviding expsure t allergens, symptms f allergic reactins, hw and when t tell an adult they may be having an allergy-related prblem, and hw t read labels. Where a severe fd allergy exists it may be recmmended that the at risk student nly cnsume fds, which have been prepared at hme. Gd Shepherd Cathlic Primary Schl Springfield Lakes ALLERGY AWARENESS AND MANAGEMENT POLICY p. 3

4 Other students teachers will teach students abut the cmmn triggers and signs f allergic reactins, and t reprt immediately any suspected symptms. They will als educate students regarding strategies which culd be emplyed in the event f an attack when an adult is nt present. N sharing r trading f fd, drinks, cntainers and utensils t be allwed. Students t be encuraged t wash hands bth befre and after eating, and after cntact with knwn allergens t minimise the risk f accidental transference. Parents/Caregivers/Vlunteers A partnership mdel is prpsed where assistance will be required and sught in educating students abut allergies and their triggers; the symptms f an allergy attack and pssible respnses. If vlunteering in a class where there is a student with a severe allergy, the vlunteer will need t read and adhere t any special requirements put in place fr that class and student. Implementatin f Practical Strategies Envirnment: Whle schl Our aim is fr the whle schl t be aware f the ptential dangers f allergies in identified students. This includes envirnmental allergens such as insects, bees, grasses and chemicals. While fd prducts that may cause allergies will nt be banned frm the schl, it will be schl plicy t encurage parents and caregivers t cnsider alternatives fr their student s healthy lunches and snacks. Similarly all adult grups invlved in schl will be reminded f schl plicy and asked nt t bring these prducts n site due t the risk f transference. Special attentin will be given t nuts and nut prducts given the severity f reactins at minimal expsure levels. In additin t this, risk assessments will need t be cmpleted n all prducts and freign bjects, including animals, brught int the schl envirnment during an incursin which may be triggers fr a child with an allergy. Classrm Expsure t Fd Substances where a student in a particular class gruping is identified as having a fd allergy, and expsure t that fd, even withut ingestin will put that student at risk; additinal precautins will need t be put in place within that classrm. In such circumstances a nte will be sent hme t parents ntifying them f the situatin and requesting that fds which may cause a prblem nt be sent t schl (appendix 1). Shuld fds cntaining knwn allergens be brught t schl, the child wh has brught them will be directed t mve t a designated space, t cnsume them t minimise risk f transference within the classrm. In sme cases it may be necessary t create allergen free areas at which students may eat their lunch and snacks. The Schl cmmunity will regularly be reminded t assist the schl in develping an Allergy Aware cmmunity. Gd Shepherd Cathlic Primary Schl Springfield Lakes ALLERGY AWARENESS AND MANAGEMENT POLICY p. 4

5 Birthday Treats parents t be encuraged t speak t the classrm teacher regarding apprpriate birthday treats and t cnsider alternate ways f celebrating a birthday that des nt require fd. If fd is t be prvided the safest alternative is pre-packaged fd which can be left in the fridge in the Administratin Wellbeing rm. Shared Lunch- where a shared lunch is rganised, classrm teachers are t use a standardised frm utlining unsuitable fd. (Appendix 7) Parents/caregivers f at risk students will be advised t prvide safe treats t be given during birthday celebratins and t prvide alternatives fr shared lunches. All students will be encuraged t wash their hands befre and after eating, at first and especially secnd break after play and prir t eating. Regarding ther allergens, precautins need t be taken t minimise the expsure risk t identified staff, students r vlunteers. This is t take the frm f risk assessments and mnitring what cmes int the classrm, e.g. pets if there is a severe allergy t pet hair; flwers if there is an allergy t pllen; cleaning prducts - if there is an allergy t certain chemicals. Classrm teachers need t als be aware f risks during science experiments, excursins, schl camps and physical educatin activities. Lunch Orders The Family and Cmmunity Engagement Netwrk (FACE) mrning tea and lunch makers will nt stck r sell nuts, nut prducts, r items knwn t cntain nuts as an ingredient, as these can cause severe reactins. This ban des nt apply t fds labelled may cntain traces f nuts. Other fds sld may cntain prducts which culd trigger allergic reactins, eg gluten and eggs. Infrmatin will be available t enable students and their families t identify thse fds which may be triggers fr particular children. OSHC Fr a student with anaphylaxis attending Centacare OSHC, the OSHC Crdinatr will negtiate with the family regarding fd cnsumptin in-line with Centacare s plicies and prcedures. In sme cases the family may prefer t prvide a meal frm hme. If it is decided t prvide meals t a student at risk, then the meal prepared shuld nt cntain the ingredients t which the student is knwn t be allergic. Students wh are identified as at risk may require utensils, which are easily identifiable (e.g. a different clur) t minimise risk f expsure via transference. All students shuld wash hands bth befre and after eating t minimise accidental transference f allergens t ther surfaces. Due t the ptential severity f the reactin, meals prepared with ingredients which May cntain traces f nuts written n the label, shuld nt be given t students with nut allergies. Gd Shepherd Cathlic Primary Schl Springfield Lakes ALLERGY AWARENESS AND MANAGEMENT POLICY p. 5

6 As in classrms, additinal precautins may need t be taken t minimise risk f expsure t ther allergens fr identified staff, students r vlunteers this culd take the frm f risk assessments and mnitring f what cmes int OSHC, eg pets if there is a severe allergy t pet hair; flwers if there is an allergy t pllen; cleaning prducts - if there is an allergy t certain chemicals. Regular review and mnitring f all plans Gd Shepherd Cathlic Primary Schl tgether with Centacare will update the Health Care Plan annually with reference t already mentined websites. REFERENCES: Australian Sciety f Clinical Immunlgy and Allergy Inc Queensland Gvernment Australian Sciety f Clinical Immunlgy and Allergy Inc at Australasian Sciety f Clinical Immunlgy and Allergy Infrmatin n the preventin f fd anaphylactic reactins in schls, available at Schling and childcare: APPENDICES Appendix 1 Parent Letter infrming that as an Allergy Aware Schl, infrming that a student in their child s class has an allergy Prcedures Appendix 2 Letter re shared lunch and class celebratins prcedures Appendix 3 Cnfidential infrmatin Principal and family Appendix 4 Parent/Legal Guardian Permissin At Risk List - Agreement Appendix 5 Health Care Plan Appendix 6 Anaphylaxis (severe allergy) Care Plan Health Supprt Plan Appendix 7 Parent Actin Plan fr children wh have had a previus acute severe allergic reactin Appendix 8 Infrmatin fr Families pamphlet re Children living with Anaphylaxis Gd Shepherd Cathlic Primary Schl Springfield Lakes ALLERGY AWARENESS AND MANAGEMENT POLICY p. 6

7 Appendix 1 Letter t parents Date: Dear Parents/Caregivers in Year This letter is t infrm yu that ur schl is an ALLERGY AWARE SCHOOL. A student in ur class has been identified as having an allergy t As an ALLERGY AWARE SCHOOL we are trying t Educate staff, students and families abut hw can cause an allergic reactin fr sme peple; Build awareness abut hw staff, students and families can ensure safety at schl fr students with allergies by being cautius and aware f the dangers f. Fr this student expsure t r prducts knwn t cntain may cause a life threatening allergic reactin (anaphylaxis) requiring emergency medical interventin. T reduce the chance f this ccurring we ask that yu D nt send r prducts t schl; Check the labels f fd being brught t the schl; Remind yur child t NOT share any fd with ther student - this is nt being unkind - this is being sensible; When sending fd fr class parties be aware f the ingredients; If yur child has been in cntact with befre cming t schl ensure that yur student s face, hands and muth have been thrughly washed befre entering the schl; If yu are vlunteering at the schl we ask that yu als limit any ptential expsure the allergen Please d nt send anything which may cntain fr sharing. We appreciate yur supprt with these prcedures. Please cntact me at schl if yu require further infrmatin. Sincerely Judith Anne Seery Principal Gd Shepherd Cathlic Primary Schl Springfield Lakes ALLERGY AWARENESS AND MANAGEMENT POLICY p. 7

8 Appendix 2 Shared Lunches and Class Celebratins Dear Parents/Caregivers We are having a shared lunch/class celebratin n at We have students in ur class wh are allergic t peanuts ther nuts eggs shellfish Please be aware f this when preparing fd and d nt send any fd items cntaining these prducts. If yur child has a severe fd allergy yu may prefer t prvide fd that has been prepared at hme. Thank yu fr yur c-peratin, Classrm Teacher/s Gd Shepherd Cathlic Primary Schl Springfield Lakes ALLERGY AWARENESS AND MANAGEMENT POLICY p. 8

9 APPENDIX 3 CONFIDENTIAL T be cmpleted by the PRINCIPAL with the FAMILY and OTHERS as indicated belw, fr a staff/student/client wh requires individual plan in schl. This plan shuld be based n written health care advice frm a health prfessinal. It will invlve risk assessment fr staff in planning fr the student. This infrmatin is cnfidential and will be available nly t supervising staff and emergency medical persnnel. Schl Name: Gd Shepherd Cathlic Primary Schl 58 Opperman Drive Springfield Lakes QLD 4300 Or Name f place f Excursin/ Camp etc Name f staff/student/client: Date f birth: Family name (please print): First name (please print): Date f this plan: Date fr next review: Cmplex/invasive health supprt Des the child/student/client have cmplex/invasive health care needs? Yes* N (eg gastrstmy r ther tube feeding, pstural drainage, rutine xygen, trachestmy care, catheter/stma management) Yes N *Refer t attached ntes t assist in the cmpletin f this Health supprt plan First Aid Is there any individual first aid requirement, ther than basic first aid respnse? Yes* N (eg in relatin t asthma; anaphylaxis (including administratin f prescribed adrenalin via an Epi-pen; administratin f prescribed intranasal midazlam fr seizure management; management f anxiety) *Refer t attached ntes t assist in the cmpletin f this Health supprt plan Gd Shepherd Cathlic Primary Schl Springfield Lakes ALLERGY AWARENESS AND MANAGEMENT POLICY p. 9

10 Appendix 4 AGREEMENT *This plan has been develped fr the fllwing: Schl/educatin Outings/camps/excursins/aquatics Hme Transprt Other (please specify) When will this child/student cmmence attending schl? If nt immediately, detail actins and timelines t enable attendance, and any interim prvisins Principal Signature Date Staff/cntact persn (if relevant) Signature Date Wh, apart frm the family and thse listed abve, will have a cpy f this plan? 1. Rle Signature Date 2. Rle Signature Date 3. Rle Signature Date Authrisatin I have read, understd and agreed with this plan and any attachments indicated abve. I supprt use f this plan by supervising staff. Parent/guardian r adult student/client Signature Date Child/student Signature Date I have read, understd and agreed with this plan and any attachments indicated abve. I apprve the release f this infrmatin t supervising staff and emergency medical persnnel. Parent/guardian Gd Shepherd Cathlic Primary Schl Springfield Lakes ALLERGY AWARENESS AND MANAGEMENT POLICY p. 10

11 Signature Date This infrmatin is cnfidential and will be available nly t supervising staff and emergency medical persnnel. Name f child/student/client Date f birth Date fr next review Descriptin f the cnditin Pssible bservable signs and symptms: Presence f knwn allergen Repeated vmiting Difficulty swallwing Swelling f lips, face r bdy Difficulty talking Lss f cnsciusness Generalised skin rash Cugh Difficulty with nisy breathing(wheeze r stridr) Knwn and suspected triggers First Aid If a child/student shws any f the abve bservable signs and symptms, staff will call 000 and then administer first aid in accrdance with Basic First Aid and including, as relevant, administratin f prescribed adrenalin via EpiPen. If yu anticipate this persn will require anything ther than this standard first aid respnse, please prvide detailed written recmmendatins. Staff will use this plan t discuss with families hw supprt can be prvided in line with the capacities f their service. Additinal infrmatin attached t this care plan Authrisatin and Release Health prfessinal Prfessinal rle Address Telephne Gd Shepherd Cathlic Primary Schl Springfield Lakes ALLERGY AWARENESS AND MANAGEMENT POLICY p. 11

12 Appendix 5 Health Care Plan CONFIDENTIAL T be cmpleted by the PRINCIPAL with the FAMILY and OTHERS as indicated belw, fr a child/student/client wh requires individual health and persnal care supprt in schl, preschl r child care. This plan shuld be based n written health care advice frm a health prfessinal. It will invlve risk assessment fr staff in planning fr the child/student/client. Schl name: This infrmatin is cnfidential and will be available nly t supervising staff and emergency medical persnnel. Name f child/student/client: Date f birth: Family name (please print): First name (please print): Date f this plan Date fr next review: Cmplex/invasive health supprt Des the child/student/client have cmplex/invasive health care needs? Yes* N (eg gastrstmy r ther tube feeding, pstural drainage, rutine xygen, trachestmy care, catheter/stma management) *Refer t attached ntes t assist in the cmpletin f this Health supprt plan First Aid Is there any individual first aid requirement, ther than basic first aid respnse? Yes* N (eg in relatin t asthma; anaphylaxis (including administratin f prescribed adrenalin via an Epi-pen; administratin f prescribed intranasal midazlam fr seizure management; management f anxiety) *Refer t attached ntes t assist in the cmpletin f this Health supprt plan Gd Shepherd Cathlic Primary Schl Springfield Lakes ALLERGY AWARENESS AND MANAGEMENT POLICY p. 12

13 Rutine supervisin fr health care-related safety Is there a knwn recmmendatin fr additinal supervisin fr health care-related safety? Yes* N (eg a medicatin authrity fr administratin during times when the child/student is in the care f staff; identified risk f self-harm r suicidal thughts and behaviurs; illness-related prblems) *Refer t attached ntes t assist in the cmpletin f this Health supprt plan Gd Shepherd Cathlic Primary Schl Springfield Lakes ALLERGY AWARENESS AND MANAGEMENT POLICY p. 13

14 Appendix 6 Anaphylaxis (severe allergy) care plan CONFIDENTIAL T be cmpleted by the DOCTOR and the PARENT/GUARDIAN and CHILD/STUDENT. This infrmatin is cnfidential and will be available nly t supervising staff and emergency medical persnnel. Name f child/student Date f birth Medic Alert Number (if relevant) Date fr next review Descriptin f the cnditin Pssible bservable signs and symptms: Presence f knwn allergen Repeated vmiting Difficulty swallwing Swelling f lips, face r bdy Difficulty talking Lss f cnsciusness Generalised skin rash Cugh Difficulty with nisy breathing(wheeze r stridr) Knwn and suspected triggers First Aid If a child/student/client shws any f the abve bservable signs and symptms, staff will administer first aid in accrdance with Basic Emergency Life Supprt and including, as relevant, administratin f prescribed adrenalin via EpiPen If yu anticipate this persn will require anything ther than this standard first aid respnse, please prvide detailed written recmmendatins. Staff will use this plan t discuss with families hw supprt can be prvided in line with the capacities f their service. Medicatin authrity (if medicatin is ther than the adrenalin via EpiPen) Individual first aid plan (Australasian Sciety f Clinical Immunlgy and Allergy [ASCIA] Actin Plan) General infrmatin abut this persn s cnditin Other (please specify) Schl/educatin Outings/camps/hlidays/aquatics Transprt Other (please specify) Gd Shepherd Cathlic Primary Schl Springfield Lakes ALLERGY AWARENESS AND MANAGEMENT POLICY p. 14

15 Authrisatin and Release Health prfessinal Prfessinal rle Address Telephne Signature Date I have read, understd and agreed with this plan and any attachments indicated abve. I apprve the release f this infrmatin t supervising staff and emergency medical persnnel. Parent/guardian r adult student/client Signature Date Gd Shepherd Cathlic Primary Schl Springfield Lakes ALLERGY AWARENESS AND MANAGEMENT POLICY p. 15

16 Appendix 7 ACTION PLAN FOR CHILDREN WHO HAVE HAD A PREVIOUS ACUTE SEVERE ALLERGIC REACTION (ANAPHYLAXIS) Name Prescribed by Date f Plan Emergency Cntacts Allergic trigger (s) Expsure r suspected expsure t trigger Seek emergency medical treatment Call 000 fr Ambulance Or if unavailable take child t nearest medical centre Observe fr the fllwing symptms and institute actin ACTION N signs r symptms cmpletely well Watch fr further symptms Give prescribed medicine... Skin rash which is red raised and itchy Swelling f the lips, face r bdy child therwise cmpletely well Or ACTION Watch fr further symptms Give prescribed medicine... Or Gd Shepherd Cathlic Primary Schl Springfield Lakes ALLERGY AWARENESS AND MANAGEMENT POLICY p. 16

17 Cugh ACTION Nisy breathing (wheeze r stridr) Watch fr further symptms Harse vice Give the EpiPen Difficulty breathing Difficulty talking Lss f cnsciusness Symptms may present with r withut skin rash Remve EpiPenfrm cntainer Remve grey cap Hld black end t frnt f uter thigh Push dwn hard The device will activate with a lud click Hld in place fr 10 secnds Remve EpiPen with care Or Lss f cnsciusness ACTION N breathing N cartid pulse Symptms may be present with r withut ther symptms Watch fr further symptms Give the EpiPen Fllw Australian Resuscitative Cuncil Prcedures Airway Breathing Circulatin Await emergency medical treatment If signs f anaphylaxis persist and adrenaline is available this can be repeated Apprved by: Issuing Grup: Judith Seery Principal Gd Shepherd Cmmunity Implementatin date: August 2014 Supersedes date: Nil. New schl Gd Shepherd Cntact: Principal Gd Shepherd Cathlic Primary Schl Springfield Lakes ALLERGY AWARENESS AND MANAGEMENT POLICY p. 17

18 Gd Shepherd Cathlic Primary Schl Springfield Lakes ALLERGY AWARENESS AND MANAGEMENT POLICY p. 18