APPENDIX B PR950355 Download Word Document AUSTRALIAN INDUSTRIAL RELATIONS COMMISSION Workplace Relations Act 1996 s.113 application for variation The Australian Workers' Union (C2003/5979) OIL DRILLING RIG WORKERS (OFFSHORE PLATFORM DRILLING RIGS) CONSOLIDATED AWARD 1991 (ODN C No. 31 of 2000) [AW791880  J9179] Oil and gas industry COMMISSIONER LEWIN MELBOURNE, 2 AUGUST 2004 Application for increase to casual loading. DECISION [1] This decision concerns an application by the Australian Worker's Union (AWU) to vary the Oil Drilling Rig Workers (Offshore Platform Drilling Rigs) Consolidated Award 1991 [AW791880] (the Oil Drilling Award). The application refers to the award prior to review pursuant to Item 51 of the Workplace Relations and Other Legislation Amendment Act 1996 ; however, I will treat the application as an application to vary the AWU Oil Drilling Rig Workers (Offshore Platform Drilling Rigs) Award 2001 which is the simplified award made by order of Senior Deputy President Polites on 17 December 2001 in Print J9179. The application seeks to increase the casual loading prescribed by the award from 20% to 25%. The application is opposed by the Australian Mines and Metals Association (AMMA) and its member company International Sea Drilling Ltd (ISD). While AMMA contends that ISD is the only respondent to the award currently in operation the evidence on behalf of the AWU was that another company Imperial Snubbing Services (ISS) is also operating at present. [2] The relevant provisions of the award the subject of the application are in the following terms: "5.3 Casual employment 5.3.1 A casual employee is one engaged and paid as such. 5.3.2 An employee shall not be engaged as a casual employee for a continuous period of more than two work cycles except for the relief of permanent employees taking leave in accordance with clauses 15, 17, 18 and 20 of this Award. 5.3.3 A casual employee shall be paid on a daily basis at the rate of twice the daily rate plus 20%, in lieu of paid leave entitlements. 5.4 The employer may direct an employee to carry out such duties as are within the limits of the employee's skill, competence and training consistent with classification structures prescribed herein, provided that such duties are not designed to promote de-skilling." [3] The completion of the hearing of this matter was considerably delayed by various events which occurred during the scheduling of the matter to suit the convenience of the parties and also by the need to carefully evaluate the evidence and the award provisions concerning casual and full time employees to establish appropriate quantitative comparators. In the course of hearing the matter Mr John Hurley gave evidence for ISD and an affidavit by Mr Terry Lee, an AWU Organiser, was admitted as evidence. Extensive written submissions were filed by the AWU and by AMMA. I have taken that evidence into account for the purposes of my decision. [4] The AWU relies on a number of submissions in support of the application as follow: · A Full Bench of the Commission has recently reviewed the casual employment loading in the Metal Engineering and Associated Industries Award, 1998 Part 1 [AW789529] 1 . · The award operates in the context of a well defined industry in which employees work in close contact. · The industry context is regulated by a set of awards. · Those awards include the award the subject of this application. · In particular the AWU made reference to the operation of the Engineering (Oil Companies) Award 2000 [AW780050] and the Australian Workers' Union Construction and Maintenance Award 2002 [AW815828], the Metal, Engineering and Associated Industries Award 1998 and the National Metal and Engineering On-Site Construction Industry Award 2002 [AW816828]. · The AWU also referred to a Full Bench decision in relation to the Pastoral Industry Award 1998 [ PR930781 ] dealing with the subject of casual loading which it submits supports the granting of the application. · The AWU submitted that while there are some differences between the terms and conditions of the Metal Engineering and Associated Industries award and the Oil Drilling Award the fundamental and most relevant comparisons between the terms of those awards supported a conclusion that the Full Bench decision increasing the casual loading to 25% in the former award should be persuasive in this matter. [5] In reply AMMA submitted as follows: · The Oil Drilling Rig Award and the industry in which it operates are fundamentally different to the Metal, Engineering and Associated Industries Award 1998 and the Metal Industry respectively. · The Engineering (Oil Companies) Award applies to oil refineries and is a 38 hour week award, there is no comparison relevant for the purposes of the application. · When casual workers are engaged under the Oil Drilling Award they work a complete duty cycle of two weeks offshore as do permanent employees. · Casual workers are paid a day rate derived from an annualised salary plus 20% · The annualised salary aggregates allowances, annual leave loadings, and public holiday penalties. · Casual employees are already "double dipping" in respect of pubic holiday and annual leave loadings. · Casual employees are paid for sickness in some circumstances while offshore. · Some casual employees have been paid while training to meet necessary regulatory and other requirements. · There is no relationship between the Oil Drilling Award and the awards referred to by the AWU, nor do those awards apply offshore. · Additionally, the awards referred to are of a different nature, in particular in relation to hours and practices of work. · Some employees in the industry prefer casual employment. · Access to overtime is not denied to casual employees offshore. · Some casual employees in the industry have been paid redundancy benefits. · Using the table which appears at paragraph 197 of the Full Bench decision concerning the Metal Industry Award, in relation to various considerations identified in the course of that decision, the comparative outcome for the offshore drilling industry is different. By adjusting the table for various identified factors submitted as appropriate the table shows different outcomes for consideration in relation to the Oil Drilling award. [6] In relation to the engagement of casuals Mr Hurley's witness statement includes the following: "[8] The Company has a pool of casual employees who are usually available for offshore work with the Company. The pool numbers approximately 6-7 employees at any one time. [9] The Company's requirement for casual employees in terms of frequency and numbers of casuals required fluctuates considerably continent upon the rig activity. [10] Typically, the requirement ranges from 1 casual for one/two weeks (annual leave replacements), 1 casual for 3-4 days due to temporary absences (sick leave, compassionate leave etc) to 3-4 casuals for up to 14 days, during periods when rig is executing interplatform rig moves. [11] The casual employee forms an integral part of the offshore work team, and he/she works a full shift every day or night that the crew are on the facility/platform. In short, casual employees work just as hard and just as long as our permanent employees." 2 [7] Mr Lee's statement includes the following: "There are currently two respondents to the subject Award working Bass Strait, Imperial Snubbing Services and International Sea Drilling Ltd. Both companies by the nature of the industry employ casual labour. Both companies have a pool of casuals they call upon to fill positions on the rig created by sickness, annual leave and training commitments of their weekly hire employees and during times of increased workload such as rig moves" 3 . Consideration and conclusions [8] Having regard to the disagreement between the parties and the provisions of Principles 4 and 10 of the Statement of Principles of May 2004 Safety Net Review decision the matter has been referred to the President who has decided not to convene a Full Bench to hear this application. [9] The Full Bench decision in relation to the Metal Industry Award prescribing a 25% casual loading is not a test case standard for the purposes of this decision. [10] It is pertinent to note the specific nature of the industry of offshore drilling and the relevant differences between that industry and others in respect of which casual loadings have recently been considered by the Commission. It is also relevant to note the difference between the various awards which have been referred to in relation to the application. [11] Moreover, a number of highly significant distinctions between full time employment and casual employment remain in the industry and are provided for by the terms of the Oil Drilling Award. [12] In the Pastoral Industry Award Casuals case 4 the following was stated by a Full Bench of the Commission. "[63] The original submissions on behalf of the AWU appear, on one view, to place reliance on the Metal Industry Casuals Case as though it were a "test case". WAFFIA certainly interpreted the submissions in that fashion. However, the later submissions of the AWU expressly disavowed such an approach. The Metal Industry Casuals Case is not a "test case" in the sense in which that term is used in this jurisdiction. It provides no authority for the proposition that a casual loading of 25 per cent is now some sort of "community standard" which ought flow on to other awards. Indeed, in that case the Full Bench explicitly noted that applications to vary casual loadings would need to be considered on a sector by sector or industry by industry basis. The Full Bench was at pains to demonstrate that the increase from 20 per cent to 25 per cent sought in the application before it was justified upon an analysis of the value of the award benefits enjoyed by permanent employees that were not enjoyed by casual employees in the metal industry. The Metal Industry Casuals Case does provide authority in relation to the approach to be taken when considering applications for variation of a casual loading in an award" "[67] In our opinion, the relevance of the Metal Industry Casuals Case to the present matter is as authority for the proposition that if, upon analysis of the true value of award and other benefits enjoyed by permanent employees that are not enjoyed by casual employees and the disadvantages suffered by casual employees that are not suffered by permanent employees, it appears that the current casual loading is inadequate, then this can provide a proper basis for awarding an increase in a casual loading as part an award safety net of fair minimum wages and conditions. The various components that contribute to an assessment of a casual loading may vary from award to award. Some components are relevant to all awards. In relation to those components, the approach adopted in the Metal Industry Casuals Case in respect of those components ought be applied unless there is some clear distinguishing circumstance." [13] Moreover, in the Car Parking Industry Award case 5 a Full Bench said as follows: "[55] As the extracts set out above show, to warrant an increase in a casual loading it must be demonstrated that the existing loading does not adequately compensate casual employees for the benefits they do not enjoy vis-à-vis weekly hire employees. This requires, in contested proceedings at least, some analysis of the value of the award benefits enjoyed by weekly employees that are not applicable to casual employees in the award in question. The approach taken in the Metal Industry Casuals case is clearly relevant in this regard and ought to be followed. But that case does not establish a 25 per cent casual loading as a test case standard." [14] There are a number of the provisions of the award which either explicitly or effectively distinguish the rights and entitlements of casual employees which may be weighed according to their terms and the nature of their effects having regard to the nature of casual employment and other terms of the award 6 generally and in light of the evidence. While there are matters peculiar to this industry which may be perceived as constituting other relevant considerations such as the effects of the annualisation of remuneration and the inclusion of some amounts in respect of allowances and overtime I consider that on balance the award's exclusion of casual employees from various award entitlements applicable to full time employees and the nature of its operation in the relevant industrial circumstances weighs in favour of the application. [15] Moreover, it is necessary to refer to the table of calculations at paragraph 197 of the Metal Industry Award decision in order to deal with the submissions made by AMMA in this particular respect. The table set out in the Full Bench decision is attached as Appendix A and comparative tabular calculations relied on by AMMA in this matter are reproduced as Appendices B and C to this decision. The tables produced by AMMA and shown in the appendices are for periods of three and six months employment respectively. [16] It is important to note what was said by the Full Bench in the Metal Industry case when referring to that table at paragraph 198 of the decision in that matter which, is reproduced below. "[198] That form of calculation is but one of a number which might be used to demonstrate points and costing effects or estimates. For the reasons we have given, we are not persuaded that an exact or precise quantification of different components should be welded on to the determination of the casual rate loading. We are satisfied that the existing loading is substantially exhausted in compensating for the potential liability for paid leave entitlements applicable to other relevant types of employment . The changed access to some forms of personal leave since the last adjustment in 1974, and the substantially differential access to notice of termination for weekly (now full-time) employees in conjunction with the reintroduction of an employment by the hour effect for casual employees, justify some additional loading. Our view in that respect is reinforced by what we have broadly categorised as the notice of termination and employment by the hour effects. Even a minimal quantification of an addition to the loading for that component would be sufficient to make out a relatively compelling case for an increase to the existing level of the loading." (emphasis added) [17] Before further consideration of the tabular comparisons relied upon by AMMA it is useful to recall at this point the terms of clause 5.3.2 of the Oil Drilling Award. The terms of the award are that the existing casual loading is " in lieu of paid leave entitlements ". Strictly speaking any compensation for other comparative incidents of casual and full time employment, in accordance with the terms of the award, it would seem, are not provided for by the loading. [18] Had the tabular comparisons referred to by AMMA been the single fulcrum of the decision in this matter I would question some of the considerations which AMMA has relied upon, in some detail. In particular the construction of the nature of the comparisons with the table produced in the Metal Industry Award decision and the calculations involved. However, it is clear that exact or precise quantification of different components of the calculation undertaken by the Full Bench in the Metal Industry Award case are not appropriate to be " welded onto the determination of the casual rate loading " 7 . [19] Nevertheless some observations can be made in relation to those matters. In my view, Mr Hurley and Mr Lee's evidence concerning sick leave would lead me to conclude that it would not be appropriate to assume a substantial employer practice of gratuitously allowing a sick leave entitlement in respect of casual employees within the calculations. The incidence of payment for any duration of sick leave on my view of the evidence would be extremely limited and of very short duration in any particular instance. It would be confined largely to the time taken to arrange helicopter transport for the employee to the land. More importantly however, the award does not prescribe an entitlement to sick leave in respect of casual employment. [20] I would also question the basis upon which the exclusion of consideration of an appropriate Ratio E in the tables submitted by AMMA is appropriate for the purposes of the comparison. While I accept that casual employees will sometimes work a full roster when engaged this is a limited observation concerning the pattern of casual engagements. It cannot, in my view, of itself suggest that over a year all casuals will be engaged for the same number of hours as full time employees. Having regard to what is before me I think it more probable than not that casual employees in the industry will be employed for less than full time hours over a year. Indeed the evidence indicates that only some and certainly not all casuals would, at the most, work for between five and six months of the year. Having regard to the provisions of clause 5.3.2 of the Award there is some cogency in assuming that casual employees are unlikely, on average, to work much more than 2 cycles in three. This was supported to some extent by the evidence of Mr Hurley under cross examination 8 . It seems to me that the consideration of the subject of paid hours differential cannot be avoided. [21] It will be noted that on AMMA's calculations, taken at face value, the comparisons with the table in the Metal Industry Award decision for Ratio E is apparently as follows: Print T4991 AMMA 1 AMMA 2 125.88% 123.04% 121.04% Table 1 Table 2 Table 3 I say apparently, because the operation of the relevant calculations in the AMMA tables seem not to explicitly acknowledge the Ratio E conclusion. [22] It will be noted that Ratios D and E in the tabular analysis contained in the Metal Industry decision are posed as alternatives. [23] In my view, the evidence in this matter concerning the paid hour differential giving rise to Ratio E in the methodology of the Full Bench in the Metal Industry Award decision would lead to a different conclusion than was used in the Metal Industry Award table referred to. [24] The evidence of Mr Hurley, in my view, leads to a conclusion that the paid hours differential under the operation of the award on average is likely to be greater than 5%. Even assuming what I consider to be a conservative estimate that evidence would support an extrapolation of a 10% differential or greater. [25] It will be noted that there are variations between all of the ratios in the tables relied upon by AMMA and the tables set out at paragraph 197 of the Metal Industry Award decision. [26] I should at this point observe that I consider that the most relevant considerations for the purposes of this decision are not so much the tabular comparison or the applicability of the various other awards relied upon by the AWU, and disputed by AMMA, but rather the generic and fundamental differences between full time and casual employment. Particularly when considered having regard to the Full Bench decision in the Metal Industry case and the terms of the Oil Drilling award. The Metal Industry Award decision has been cited with authority in a number of decisions by members of the Commission 9 . In my judgement, that decision is relevant and persuasive in this matter although not conclusive. [27] Additionally, while the incidence of casual loadings in other awards of the Commission is a consideration, variation between casual loadings provided by awards of the Commission has been a long standing feature of the award system 10 . [28] Where there is no agreement on what constitutes an established test case standard an application for a variation of an award in relation to a term and condition of employment must be determined on the merits of the particular case. A Full Bench decision made after an exhaustive enquiry and debate in relation to the relevant issue is highly persuasive. Comity alone would suggest that the broad rationale of the Full Bench decision in the Metal Industry Case should be followed unless good reason exists not to do so. [29] As for the various industry and other circumstances relied upon by the parties these are relevant but do not, in this case, displace the rationale provided for by the Full Bench decision where arbitration of the appropriate casual loading is necessary. [30] For example, that some employees may prefer casual employment, as submitted by AMMA, is not an entirely implausible proposition. However, I am unable to know what the nature, and/or extent, of that preference is or why it should lead to a loading of 20% rather than 25% in a safety net award or perhaps no loading at all in light of the preference. [31] Likewise, if employers have paid redundancy benefits to casual employees pursuant to agreements or as a gratuity, in my view, this cannot be taken into account. First because of the safety net nature of the award and the distinction between awards and agreements within the scheme of the Act and secondly because the incidence of this occurrence and the relevant circumstances are not evidenced in a way which would allow proper consideration for the purposes of this matter. [32] That casual employees may be trained with pay in order to meet the requirements of relevant regulations, so that they can perform the work covered by the award, is of limited weight for the purposes of this decision, so too must full time employees. This is a different consideration than access to training for development and the opportunity to achieve higher income, for example. [33] The operation of the award in respect of public holidays and annual leave is noted. Some consideration of this is reflected in Tables 2 and 3 to which my earlier comments about the utilisation of the tables and the comparative ratios apply. [34] Using the assumptions made in the Metal Industry award decision is problematic in relation to the application before me. Indeed the tables produced by AMMA demonstrate this. Having regard to the annualised rates of remuneration and its inclusions gives rise to issues of appropriate comparative calculations and the assumptions to be made in relation thereto. There are also differing levels of entitlements provided by the two awards in some respects, which raises other issues in relation to such calculations. [35] It is also important to note the purpose of the table used in the Metal Industry Award case. In essence the comparison is between the circumstances of three notional employees employed consistently over a year based on a survey of employers in the industry. The table identifies that comparison in relation to a Full Time, Fixed Term and a Casual employee on a continuous weekly basis for a year. [36] In view of the evidence before me, I wonder if the table is easily extrapolated to the circumstances of the oil drilling industry. This is so particularly having regard to the different structure of the terms and conditions of employment in the award and the different working patterns in the industry. [37] While the evidence and submissions of AMMA seek to align the circumstances having regard to the differences and make assumptions for this purpose I am not sure that this approach is conclusive. [38] Offshore working and working patterns are clearly very different to those in the metal manufacturing and heavy engineering industries. Having regard to the terms of the award the existing loading is exhausted by the leave entitlement applicable to full time employees. In the circumstances of this case I consider that to be the starting point for consideration 11 . Clearly the particular circumstances of this industry and the structure of award regulation have given rise to that aspect of the award's expression in relation to the quantum of casual loading. Therefore the question becomes; are there other considerations which warrant additional amounts of loading? [39] I think the answer to this question is yes. The first consideration is what might be described as the standby nature of the employment. The second is the nature of the paid hour differential in this industry. It is clear that, while some casual employees may enjoy substantial expectations of employment, the terms of clause 5.3.2 of the award and the incidence of illness, recreation leave, absenteeism and labour turnover will all combine to create a level of uncertainty in relation to the number of paid hours which will be available to casuals in the industry. In this respect the evidence of Mr Hurley and Mr Lee is apt. [40] In this respect I have taken the evidence into account having regard to what is said in the Metal Industry Award decision between paragraphs 184 and 192. [41] I also consider that the comments of the Full Bench in the Metal Industry decision between paragraphs 175 and 183 are also particularly pertinent. In that passage of the decision in that matter the significance of the lack of termination and severance entitlements applicable to casual employees was identified as an important consideration in the determination of an appropriate casual loading. [42] All of the matters referred to above were of considerable significance in the reasoning of the Full Bench in the Metal Industry Award decision and in my view are applicable in this case. They find only limited expression in the table shown at paragraph 197 of that decision. [43] Weighing all of the above considerations I am persuaded that for the reasons set out at paragraph 198 of the Full Bench decision in the Metal Industry decision the casual loading prescribed by the award should be increased to 25%. I am satisfied that, having regard to the terms and conditions of employment prescribed by the award regulating casual and full time employment, the nature of the working arrangements in the industry, and the other considerations referred to by the Full Bench in the Metal and Pastoral Industries an increase to the loading is justified. There is compelling logic in adopting a loading consistent with the decision in those matters. An order will be issued accordingly. The order will come into force from the first pay period commencing on or after today's date and remain in force for a period of twelve months. Printed by authority of the Commonwealth Government Printer <Price code C> APPENDIX A TABLE 1 Working Days Paid Comparison 12 Component Days Full-Time Fixed Term Casual Total working days: 260 260 260 260 Less days not worked: public holidays: (10) 250 Less days sick/personal: leave average use (6) (a) 244 RATIO A 106.5% Vested entitlements payable on completion of 260 days Leave: (20) 280 280 244 Leave loading: (3.5) 283.5 283.5 244 RATIO B 116.6% Vested contingent benefits Accrued personal leave: (4) (b) 287.5 283.5 Long service leave (4.3) (c) 291.8 283.5 RATIO C 119.6% Notice of termination and employment by the hour effects: Contingent benefit applicable to employment terminated on last day of work (1 week notice or payment in lieu) 296.8 283.5 244 RATIO D 121.6% OR Short time worked or paid hours differential determent: Norm for casual working hours in industry = 36.1 hours per week i.e. 95% of 38 hour standard (d) 291.8 283.5 231.8 RATIO E 125.88% (a) Commonwealth submission Exhibit COM3 at pp. 77-78 and Attachment D, and Exhibit COM4 at p. 77 for calculation of estimated average use of personal leave annually. (b) Note calculation is for four days accumulated whereas in first year of service, the remainder from the seven days entitlement would be one day. (c) See Section 13.2 paragraph 173 above: component covers also an estimated value for award based or related benefits not quantifiable as days paid including static classification as casual factors; training access; different superannuation and award process effects. (d) See paragraphs 189-190. APPENDIX B TABLE 2 WORKING DAYS PAID COMPARISON - OIL DRILLING RIG WORKERS (OFFSHORE PLATFORM DRILLING RIGS) CONSOLIDATED AWARD 1991 CASUAL WORKER ENGAGED TO WORK 3 COMPLETE MONTHS OVER A FULL YEAR Component Days Full-Time Casual Total working days: 260 260 260 Less days not worked: public holidays: (10) (7.5) Less days sick/personal: leave average use (6) (4.5) 248 RATIO A 104.8% Vested entitlements payable on completion of 260 days Leave: (20) 280 248 Leave loading: (3.5) (0.875) 283.5 248.9 RATIO B 113.9% Vested contingent benefits Accrued personal leave: (4) 287.5 Long service leave (4.3) 291.8 253.75 RATIO C 117.2% Notice of termination and employment by the hour effects: Contingent benefit applicable to employment terminated on last day of work (1 week notice or payment in lieu) 296.8 248.9 119.2% RATIO D 291.8 236.5 123.4% Assumptions / Notes 1. Only one quarter of the 6 days personal carer's/sick leave counted. 2. Only one quarter of the 10 public holidays counted - note also that the full value of the [forgone] public holidays for full time workers is aggregated into the annual salary, which is used as the basis for payment of casuals. 3. Note also that when offshore, casual workers in this industry are paid at twice the daily rate plus the casual loading, so the net values ascribed to the personal carer's / sick leave and public holidays should really be doubled 4. No account has been given to the short time worked or paid time differential as between permanent and casual workers, because in the oil and gas industry casual workers, once engaged to work offshore, work the same hours as do permanent workers. APPENDIX C TABLE 3 WORKING DAYS PAID COMPARISON - OIL DRILLING RIG WORKERS (OFFSHORE PLATFORM DRILLING RIGS) CONSOLIDATED AWARD 1991 CASUAL WORKER ENGAGED TO WORK 6 COMPLETE MONTHS OVER A FULL YEAR Component Days Full-Time Casual Total working days: 260 260 260 Less days not worked: public holidays: (10) (5) Less days sick/personal: leave average use (6) (3) 252 RATIO A 103.2% Vested entitlements payable on completion of 260 days Leave: (20) 280 252 Leave loading: (3.5) (1.75) 283.5 253.75 RATIO B 111.7% Vested contingent benefits Accrued personal leave: (4) 287.5 Long service leave (4.3) 291.8 253.75 RATIO C 115.0% Notice of termination and employment by the hour effects: Contingent benefit applicable to employment terminated on last day of work (1 week notice or payment in lieu) 296.8 253.75 116.9% RATIO D 291.8 241.06 121.04% Assumptions / Notes 5. Only one half of the 6 days personal carer's/sick leave counted. 6. Only one half of the 10 public holidays counted - note also that the full value of the [forgone] public holidays for full time workers is aggregated into the annual salary, which is used as the basis for payment of casuals. 7. Note also that when offshore, casual workers in this industry are paid at twice the daily rate plus the casual loading, so the net values ascribed to the personal carer's / sick leave and public holidays should really be doubled 8. No account has been given to the short time worked or paid time differential as between permanent and casual workers, because in the oil and gas industry casual workers, once engaged to work offshore, work the same hours as do permanent workers. 1 AIRC Print T4991, 29 December 2000 2 Exhibit H11 Affidavit of John Hurley. 3 Exhibit A1 Statement of Terrence John Lee paragraph 2 4 (2003) 123 IR 184 5 PR948947 6 clause 5.3 (in particular 5.3.2, 5.3.3); clause 6.1 (in particular 6.1.1, 6.1.2, 6.1.3, 6.1.4); clause 7 (in particular 7.1); clause 9.2; 9.2.1, 9.2.2; clause 12.4; clause 15; clause 17. 7 AIRC Print T4991 8 Transcript PN307 - PN309 9 AIRC Prints PR913088, PR915664, PR922373, PR928815, PR930631, PR930782, PR9358981, PR936006, PR946135 and PR946137. 10 AIRC Print PR948947 paragraph 48 11 Print T4991 paragraph 198 12 AIRC Print T4991 paragraph 197