Professional Designations, Professional Stamps and Permit Stamps -- A Guideline


FOREWORD

The reserved title and reserved practice provisions of The Engineering, Geological and Geophysical Professions Act require that the public have an effective means of identifying work that has been done under the supervision and control of APEGGA members. The emphasis in this Guideline, however, is on the use of the professional designation, professional stamp and permit stamp to indicate professional responsibility for documents which deal with technical and/or professional matters.

It is APEGGA's objective in publishing this Guideline to establish consistent methods of communicating the "professional responsibility and quality" message to the public. It is intended that formal confirmation of professional responsibility be a key step in the quality control procedures employed by any organization in which the professions are practiced.

The use of professional designations, professional stamps and permit stamps, as described in this Guideline, represents a standard of practice for all members. Variations in application can be made to accommodate special circumstances but should not detract from the intent. This guideline is not a legal document and is not intended to supersede or replace contractual arrangements designed to satisfy specific situations.


TABLE OF CONTENTS

SECTION 1-- RIGHTS AND OBLIGATIONS

1.1 Statutory Requirements -- EGGP Act
1.1.1 Professional Member
1.1.2 Permit Holder
1.1.3 Signature and Date
1.1.4 Custody and Control of Stamps
1.2 Civil Liability
1.2.1 Liability for Negligence
1.2.2 Professional Misrepresentation

SECTION 2 -- THE AUTHENTICATION OF PROFESSIONAL AUTHORSHIP AND QUALITY CONTROL

2.1 General
2.2 Methods of Authenticating Professional Authorship

2.2.1 Name, Professional Designation and Signature
2.2.2 Professional Stamp and Signature
2.2.3 Professional Stamp, Permit Stamp and Signatures
2.3 Organizational Considerations
2.3.1 Unincorporated Individual Proprietor
2.3.2 Permit Holder
2.3.3 Permit Holders and Unincorporated Individual
Proprietors

SECTION 3 -- PROFESSIONAL AND PERMIT STAMPS

3.1 General
3.2 Affixing Stamps to Documents

3.2.1 Drawings
3.2.2 Specifications
3.2.3 Design Notes
3.2.4 Reports
3.2.5 Manuals
3.2.6 Revisions
3.2.7 Reviewed Documents
3.2.8 Removal of Professional and Permit Stamps From a Document
3.2.9 Original Document Records

APPENDICES

APPENDIX A -- Definitions
APPENDIX B
-- Types of Stamps
APPENDIX C
-- Supervision and Control
APPENDIX D
-- Computer Generation of Professional Stamps for Documents


SECTION 1 -- RIGHTS AND OBLIGATIONS

1.1 Statutory Requirements -- EGGP Act

The Engineering, Geological and Geophysical Professions Act requires members of the Association to stamp all final plans, specifications, reports or documents before issuing them for use. The intent of this aspect of the Act is to provide clear identification for the public of all documents which have been prepared by or under the supervision and control of a professional member, including the name of the professional member assuming responsibility for them.

The intent of this aspect of the Act is to provide clear identification for the public of all documents which have been prepared by or under the supervision and control of a professional member, or in the case of work prepared by others, documents thoroughly reviewed and professional responsibility accepted by a professional members.

Following is a summary of references in the Act which describe its intent with respect to the authentication of professional authorship:

1.1.1 Professional Member

A professional member of APEGGA shall stamp only such documents that were prepared by the member or under the member's direct supervision and control, or in the case of work prepared by others, were thoroughly reviewed and professional responsibility accepted by the member. (Regulations, Section 51(1))

1.1.2 Permit Holder

When the practice of the professions is carried on by a firm, all plans, specifications, reports or documents shall:

a) be stamped with the professional stamp of the member who prepared them or directly supervised their preparation, or in the case of work prepared by others, thoroughly reviewed and accepted professional responsibility for them.

b) be stamped with the permit stamp of the Permit Holder under whose responsibility and control they were prepared. (Regulations, 50(2))

1.1.3 Signature and Date

a) The professional stamp shall be signed and dated by the member to whom it was issued. (Regulations, 51(3))

b) The permit stamp shall be signed and dated by a professional member who is a full time employee or member (director or shareholder) of the Permit Holder and who has been authorized in the Permit to Practice to assume responsibility for the practice engaged in by the Permit Holder. (Regulations, 50(1))

1.1.4 Custody and Control of Stamps

a) A stamp issued to a professional member, licensee or restricted practitioner shall at all times remain under the member's direct control. (Regulations, 51(1))

b) A stamp issued to a Permit Holder shall at all time be under the control of a professional member authorized in its Permit to Practice to assume responsibility for the professional practice in which the Permit Holder engages. (Regulations, 50(1))

c) All professional and permit stamps or seals are the property of APEGGA, and shall be returned when the person or entity ceases to be a member of the Association. (By-Laws, 35)

The APEGGA Code of Ethics state that the absence of a seal or stamp does not necessarily indicate that the document has not been reviewed by a professional member, nor does it relieve the member from professional or legal responsibility if it can be shown that the member was involved with the work (refer to the Manual of Professional Practice Under the Code of Ethics.)


1.2 CIVIL LIABILITY

1.2.1 Liability for Negligence

The statutory requirement for stamping and signing documents does not affect the exposure of the professional member to civil liability. Liability for negligence is based on fact and it is not generally possible to contract out of liability for negligence or failure to exercise due care. A professional member may be liable for the documents prepared or directly supervised, whether or not the member stamped and signed them.

1.2.2 Professional Misrepresentation

A professional member who stamps and signs documents that were not prepared by the member or under the member's direct supervision, or in the case of documents prepared by others, were not thoroughly reviewed and professional responsibility accepted by the member, is:

a) in breach of the Code of Ethics

b) open to charges of fraud, and

c) open to charges of negligence if the misrepresentation results in damages.

The basis for the liability is that the professional member fraudulently misrepresented that the member prepared the documents or supervised and controlled their preparation, or thoroughly reviewed and accepted professional responsibility for the documents.

The member or permit holder should endeavour to retain custody and control of all original documents relating to a finished project. This will protect and defend against misrepresentation through unauthorized changes to the document. If a client or authority requires the original documents, the responsible member and permit holder should maintain a duplicate record of the documents transferred.



SECTION 2 -- THE AUTHENTICATION OF PROFESSIONAL AUTHORSHIP AND QUALITY CONTROL

2.1 General

The basic purpose of professional designations, professional stamps and permit stamps is to identify documents which involve work that has been performed by, or under the direct supervision of a professional member, or in the case of work prepared by others, were thoroughly reviewed and professional responsibility accepted by a professional member. As instruments for quality control the use of professional designations is as applicable to documents produced for use by a member's employer as it is to documents produced for an outside client.

The employer or client of a professional member has a right to expect competent and careful professional advice or service. The affixing of professional and permit stamps to documents is designed to emphasize the care and responsibility associated with their preparation prior to release for use.

Any document generated through the use of professional practice and considered to be the final issue for the scope of that project must show professional authorship. For example, drawings issued as part of a feasibility study would show professional authorship if professional practice was employed.


2.2 Methods of Authenticating Professional Authorship

In general, the professional authorship of all formal letters, instructions, drawings, specifications, reports and manuals prepared by, or under the direct supervision of, a professional member, or in the case of documents prepared by others, acceptance of professional responsibility following thorough review of the documents, must be authenticated before they are issued for use.

There are three ways to authenticate professional authorship:

a) Name, professional designation and signature

b) Professional stamp and signature

c) Professional stamp, permit stamp with signature on each.

In accordance with Regulations, 51(3), a stamp or seal shall be accompanied by the signature of the professional member or licensee, and the date on which it is applied.

It is a matter of individual judgement which form should be used in a specific situation or the circumstances in which it is not required. The method should, in all circumstances, complement the significance of the document. The simplest form is recommended in all routine communications. Stamping is required for all issued documents involving professional judgement or advice.

Following is a brief description of the type of documents on which each of the above methods of authentication is normally used.

2.2.1 Name, Professional Designation and Signature

This is the simplest form of professional authentication. It involves the signature of the professional member over the members' name and professional designation.

It is used for all written communications to communicate to the public the professional status of the author of the document.

2.2.2 Professional Stamp and Signature

This form of professional authentication is used for documents which contain information involving professional judgement or advice and which are to be issued by:

a) a member practicing as an unincorporated individual proprietor, or

b) a member practicing as an employee of a government organization which is excluded from the Permit to Practice requirements of the Act and Regulations.

2.2.3 Professional Stamp, Permit Stamp and Signatures

This form of professional authentication is used for documents which contain information involving professional judgement or advice and which are to be issued by a Permit Holder.

a) the professional stamp identifies the individual professional member or members under whose direct supervision and responsibility the various disciplines or phases of a project were prepared, or in the case of work prepared by others, identifies the individual professional member or members that thoroughly reviewed and accept professional responsibility for the work, and

b) the permit stamp identifies the Permit Holder organization which, as the employer of the professional member or members, is responsible for the quality and integrity of the total project.


2.3 Organizational Considerations

2.3.1 Unincorporated Individual Proprietor

As indicated in 2.2.2 above, documents prepared by or under the direct supervision and control of, or documents thoroughly reviewed and professional responsibility accepted by a professional member practicing as an unincorporated individual proprietor require only the professional stamp signed and dated by the professional member.

2.3.2 Permit Holder

Documents prepared by or under the direct supervision and control of, or documents thoroughly reviewed and professional responsibility accepted by, one or more professional members practicing as employees of a Permit Holder, require both the professional stamps and permit stamp, each appropriately signed and dated.

In an organization where professional members practice under the direct supervision of other professional members, the decision as to who should stamp specific documents should be made at the beginning of the project. This decision must take into account the experience and competence of the individuals involved and should establish responsibility for consultation and final review prior to stamping. It should also reflect corporate policy respecting any jurisdictional constraints on the professional members who are authorized in the Permit to Practice to direct the practice or practices of the permit holder.

When more than one professional member is responsible for specific parts of a document, the format of the document should be such that the professional stamps clearly indicate the boundaries of responsibility of the individual members.

2.3.3 Permit Holders and Unincorporated Individual Proprietors

If a document is prepared by or under the direct supervision and control of, or in the case of work prepared by others, is thoroughly reviewed and professional responsibility accepted by, professional members practicing as employees of more than one Permit Holder and one or more unincorporated individual proprietors, both professional stamps and permit stamps are required.

a) The Permit Holder employee members and unincorporated individual proprietors will affix, sign and date their respective professional stamps to the components of the document for which they are individually responsible.

b) The members authorized in the Permits to Practice to assume responsibility for each Permit Holder will affix, sign and date permit stamps to the components of the document for which they are respectively responsible.



SECTION 3 -- PROFESSIONAL AND PERMIT STAMPS

3.1 General

A professional stamp, when affixed to a document, is intended to indicate to the public that the document has been produced by, or under the supervision and control of, or in the case of work prepared by others, was thoroughly reviewed and professional responsibility accepted by a professional member of the Association, who is fully qualified by virtue of training and experience, in the field of the profession contained in the document, to take professional responsibility for its contents. The stamp indicates the document is the result of skilled practice of the profession, and that the work was done in a professional manner in accordance with the Code of Ethics established pursuant to section 18(1)(H) of the Engineering, Geological and Geophysical Professions Act. The professional member, when applying the professional member's stamp, indicates the work in the document was checked for technical accuracy, and that sufficient quality control was in effect to preclude errors or omissions in the technical content, resulting in a complete and accurate document. Professional stamps must therefore be affixed, signed and dated only after the responsible professional members are satisfied that the document, or component for which they are professionally responsible is complete and ready for issue.

A permit stamp indicates corporate professional responsibility for the integrity of one or more professionally stamped documents comprising the total project. The permit stamp means the corporation has put in place an organization which enables skilled, professional practice to be carried out. It indicates that, in the judgement of the permit holder, the work was carried out by skilled professionals, qualified by virtue of training and experience, to practice in the field of the profession contained in the document. It indicates that the business of the corporation is carried out in accordance with the Code of Ethics. It indicates that sufficient quality control procedures are in place to preclude errors or omissions in the technical content, resulting in a complete and accurate document. The members signing the permit to practice are not indicating that they are personally responsible for the technical content the same as the member applying the Professional Members Stamp, or that they personally checked the technical work or directly provided any quality control for the practice of the profession contained in the work, but only that sufficient quality control procedures are in effect.

The permit stamp is applied after the individual professional stamps have been affixed and is signed and dated by one of the professional members so authorized in the Permit Holder's Permit to Practice. The permit stamp should not be affixed, signed and dated until all applicable professional stamps have been affixed, signed and dated. In the case where two Permit Holders produce different components of the same document, both permit stamps are required. The Permit Holder responsible for the integrity of the total document should be the last to stamp and sign.


3.2 Affixing Stamps to Documents

The professional stamp affixed to a document should only be that of the professional member who prepared it or directly supervised its preparation, or in the case of work prepared by others, thoroughly reviewed the document and accepted professional responsibility for it. The permit stamp affixed should be signed by the appropriate member authorized in the Permit to Practice to assume responsibility for the specific practice or organizational area under whose jurisdiction the document was prepared.

The use of computer generated professional stamp and permit stamp images is permissible and should meet the following criteria:

a) The signature and date must not be part of any computer generated stamp image.

b) The computer generated stamp images must not be part of the document database.

c) Custody of the computer generated stamp must remain in the control of the professional member, in accordance with Regulation 51(3). A computer generated stamp image shall at all times be under the control of the professional member.

Members or permit holders must ensure, if they use computer generated stamp images, that a procedure is in place to ensure the computer generated stamp images remains under the direct control of the professional member responsible. An example of a formal procedure for the generation and use of computer generated stamp images is included in Appendix D.

Following are guidelines for the application of professional stamps and permit stamps to various types of documents.

3.2.1 Drawings

Final drawings which clearly indicate their intended use should be stamped as follows:

a) Professional Stamp -- Each sheet in a set of drawings should be stamped.

b) Permit Stamp -- The permit stamp should be affixed to each sheet.

Where documents are formally issued at various stages of a project, care should be taken to ensure that their restricted purpose is clearly indicated on the stamped copies of the documents.

3.2.2 Specifications

When specifications are bound separately they should be clearly identified with the project drawings and stamped as described below:

a) Each discipline or project component of the document should be stamped with:

i) the professional stamp of the member directly responsible, and

ii) a permit stamp.

b) The specification document, as a whole, should be stamped with the permit stamp.

3.2.3 Design Notes

Design notes should be prepared in a format which records the names of the responsible professional, designers and checkers including the dates on which their work was performed. The cover sheet of the design notes should be stamped, signed and dated if they are issued for review or use by a client, employer or other consultant.

3.2.4 Reports

Reports of all sizes and formats should be stamped as described below:

a) Reports involving one professional author should be stamped with:

i) a professional stamp and
ii) a permit stamp.

b) Reports which involve more than one discipline or expertise should be stamped by each professional member assuming direct responsibility for the work as follows:

i) Each distinctly separate section should be stamped by:

• a professional stamp and
• a permit stamp.

ii) The complete report should be stamped with the permit stamp.

3.2.5 Manuals

Manuals prepared for direction and guidance of others in technical and public safety areas should be stamped using the same principles of quality control and professional responsibility as described for specifications and reports.

3.2.6 Revisions

a) Revisions to a document issued by, or under the direct supervision and control of, the same professional member(s) responsible for the original document should be clearly identified as revisions to the original document. The original professional stamp(s) and permit stamp should be re-dated to indicate the date of the revision and initialed by the respective professional member(s).

b) When revisions to a document are made by someone other than the professional member(s) responsible for the content of the original document, the revisions only, including all elements of the document which are affected by the revisions, should be stamped, signed and dated by the professional member(s) under whose direct supervision and control the revisions were made. Care should be taken in documenting the revisions to clearly identify the boundary of professional responsibility between the original and revised documents.

In these circumstances the professional member(s) assuming responsibility for the revisions should:

i) stamp, sign and date separate drawings or documents which comprehensively describe the revisions including all elements of the original document affected by the revisions;

OR

ii) stamp, sign and date the revisions shown clearly on the original drawings or documents as revisions to them and for which professional responsibility is restricted to the revisions and all elements affected by them.

In either case the documents should be stamped with the permit stamp.

c) With computer generated documents, revisions to a document issued by or under the direct supervision and control of the same professional member(s) responsible for the original document, should be clearly identified as revisions to the original document. The new computer generated professional stamp image(s) and permit stamp image should be dated to indicate the date of the revisions and each should be initialled by the appropriate professional member(s). The new computer generated stamp images will replace those of the previous issue. The document database must include a dated record of who stamped which document issue.

d) When revisions to a computer generated document are made by someone other than the professional member(s) responsible for the content of the original document, the revisions only, including all elements of the document which are affected by the revisions, shall bear new computer generated stamp images, and be signed and dated by the professional member(s) under whose direct supervision and control the revisions were made. The new stamp images replace those of the previous issue. The document database must include a dated record of who stamped which document issue. Care should be taken in documenting the revisions to clearly identify the boundary of professional responsibility between the original and revised documents.

In these circumstances the professional member(s) assuming responsibility for the revisions should:

i) stamp, sign and date separate drawings or documents which comprehensively describe the revisions including all elements of the original document affected by the revisions;

OR

ii) stamp, sign and date the revisions shown clearly on the original drawings or documents as revisions to them and for which professional responsibility is restricted to the revisions and all elements affected by them.

In either case the documents should bear the permit stamp image.

e) When a stamped document is added to the computer database through electronic scanning, the original signed and dated stamp images must not be removed. Revisions to such documents would require additional computer generated stamp images. The document should include a clear indication that it is an electronically scanned reproduction.

3.2.7 Reviewed Documents

Documents prepared by others and thoroughly reviewed by a professional member or members, should be stamped with the professional stamp of the reviewing member or members and the permit stamp. The stamps should only be applied after the documents have been thoroughly reviewed and professional responsibility for the documents is accepted by the professional member or members.

The thorough review must include sufficient research, calculations and other engineering work so that the reviewer is satisfied that the works described in the documents being stamped are safe and meet the engineering standards in place in Alberta. The reviewer must do enough work so that he can stand behind the works described in the documents being stamped, as if the reviewer were the designer. A thorough review does not necessarily imply a complete redesign. The test to be applied is "Is it safe and does it meet the applicable standards?", not "Is this the way that I, the reviewer, would have designed it?". Fees for the review work should be commensurate with this level of effort.

3.2.8 Removal of Professional and Permit Stamps From a Document

Professional stamps or permit stamps should not be removed from a document except by the professional members who stamped, signed and dated them originally. When stamps are removed, the member or members responsible for their removal have a professional duty to inform those who may be affected and also to withdraw the documents from public use.

3.2.9 Original Document Records

Permit Holders and unincorporated individual proprietors should maintain a stamped, signed and dated record copy of all documents that have been issued. The record copy should bear a note to the effect that "This copy or print is for record purposes and shall not be revised".


Appendix -- DEFINITIONS

1. AUTHENTICATING PROFESSIONAL AUTHORSHIP

The communication through professional designations, professional stamps and permit stamps, of professional responsibility for documents prepared under the direct supervision and control of APEGGA members.

2. PROFESSIONAL STAMP

A stamp or seal engraved in a form prescribed by the Council of the Association showing the professional category of a registered member as Professional Engineer, Geologist or Geophysicist.

3. PERMIT STAMP

A stamp engraved in a form prescribed by the council of the Association showing the name of the corporation, partnership or other entity which has been registered as a Permit Holder and is authorized by Council to engage in the practice of one or more of the engineering, geology or geophysics professions.

4. PERMIT HOLDER

A corporation, partnership or other entity that holds a Permit to Practice pursuant to the EGGP Act.

5. CODE OF ETHICS

A series of statements published by the Council of the Association establishing standards of conduct of its members and the basis on which the dignity and honour of the professions is maintained.

6. PUBLIC

All persons who may be affected by the safety or cost/benefits of the work prepared by, or under the direct supervision and control of, a professional member.

7. PERMIT TO PRACTICE

The authority to engage in the practice of engineering, geology or geophysics in the Province of Alberta as represented by a permit certificate and stamp issued by the Council of the Association to a corporation, partnership or other entity.

8. UNINCORPORATED INDIVIDUAL PROPRIETOR

A self-employed professional member of APEGGA who practices as an individual offering professional services to clients for a fee.


Appendix B -- TYPES OF STAMPS

Stamps are issued by APEGGA according to variations in member status in the Association. Following is a description of those in current use:

1. MEMBER PROFESSIONAL STAMP

This stamp is issued to professional members of the Association following acceptance by the Board of Examiners of their academic and experience qualifications.

2. LICENSEE PROFESSIONAL STAMP

This stamp is issued to professional licensees of the Association. Licensees differ from members in that they are not landed immigrants or Canadian citizens. They meet the same academic and experience qualifications as other professional members.

3. RESTRICTED PRACTITIONER PROFESSIONAL STAMP

This stamp is issued to members of the Alberta Association of Architects following acceptance by the Joint Board of Practice of their experience qualifications to engage in restricted engineering practice.

4. PERMIT STAMP

This stamp is issued to corporate members of the Association following approval of an application for a Permit to Practice Engineering, Geology or Geophysics. Approval is conditional on there being one or more professional members of APEGGA who, as full time employees or shareholders of the corporate entity, undertake to provide technical and organizational direction to the practice of each of the professions in which the entity is engaged.

A permit stamp is not issued to a professional member operating as an unincorporated proprietor consultant.


Appendix C -- SUPERVISION AND CONTROL

The reserved practice provisions of the Engineering, Geological and Geophysical Professions Act requires that the practice of those three professions in Alberta be restricted to professional members of APEGGA or to persons who are under their direct supervision and control.

For the purpose of this guideline, an adequate supervision and control system is defined as a system which permits an APEGGA member to properly accept professional responsibility to both the public and APEGGA, for the results of the engineering, geological or geophysical tasks performed by others working under a professional members' supervision and control.

Judging the adequacy of a supervisory and control system is an exercise in risk management. No system will guarantee perfect results. However the following factors, if properly considered, will reduce the probability of deficient work to a minimum.

1. The training and experience (knowledge) of the supervisor.

2. The training and experience (knowledge) of the persons performing the tasks.

3. The reliability of the persons performing the tasks.

4. The degree of technological novelty of the tasks.

5. The degree of complexity of the tasks.

6. The number of discrete tasks being controlled.

7. The physical distance between the supervisor and the persons performing the tasks.

8. The communication system between the supervisor and the persons performing the tasks.

9. The formality of the approval process.

10. The schedule within which the tasks must be accomplished.

The ultimate criteria for judging the adequacy of a supervision and control system is the quality of the completed work as represented by the final documents.


Appendix D -- COMPUTER GENERATION OF PROFESSIONAL STAMPS FOR DOCUMENTS

1. PREAMBLE

When using computer generated professional stamps for documents, each permit holder and practicing member is responsible for developing standards and procedures which meet the requirements of the Act, Regulations and Bylaws.

This is an example of a procedure for dealing with computer generation of professional stamps for documents that may be applicable to a medium sized Engineering firm. This procedure meets these requirements, but other procedures could be formulated which likewise meet all the same requirements. Not all aspects of this example would necessarily apply to other permit holders or practicing members. Other procedures or practices would be acceptable as long as they meet the requirements of the Act, Regulations and Bylaws, and conform to the guideline, particularly in the area of direct control and custody of the stamps or stamp images.

2. GENERAL

Only the stamp image (no signatures or dates) will be put in a computer stamp image database. All professional and permit stamp images will be kept in a dedicated, secure directory on the drafting file server. Access to this directory will be restricted to those individuals in the drafting "CAD Leader" group.

The computer generated stamp image will be inserted in the drawing database immediately prior to plotting the drawing, and will be removed from the drawing database immediately after plotting. The computer generated images on the plotted hardcopy document must be signed and dated by hand.

Each professional member will be individually responsible for the addition or removal of their stamp image from the computer stamp image database as required.

3. PROCEDURES

The senior professional member responsible for the document will complete the "Professional Stamp Authorization" form and pass it on to the CAD leader for immediate execution. The form will identify which stamp images are required for which drawings, and each professional member will initial this form where the member's stamp is identified.

Only those personnel in the "CAD Leader" group are authorized to insert professional stamp images into the drawing database. All requests will be submitted to a "CAD Leader" for execution.

The date of insertion and the authorizing initials of those authorizing use of the stamp will be recorded and maintained in the drawing database in a "Stamping Record Table". This information shall not be plotted or deleted. The "CAD Leader" completing the insertion will be responsible for updating this table and will add their own initials to the record.

The "CAD Leader" inserting the images will then initial the "Professional Stamp Authorization" form as complete, and return the form to the initiator for filing in that project's files.


SAMPLE FORM

To: _______________________________


From: _____________________________

Date: __________________________


PROFESSIONAL STAMP IMAGE USE AUTHORIZATION

Affix the following stamp images:

STAMP DESCRIPTION

JURISDICTION

OWNER

INITIALS













to the following documents

___________________________________________________________________

___________________________________________________________________

___________________________________________________________________

AUTHORIZATION

COMPLETION

_________________________

_________________________




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