PART C – DECISION UNDER APPEAL
The decision under appeal is the Ministry of Social Development and Poverty Reduction (ministry) reconsideration
decision dated 18 July 2018, which determined that the appellant was not eligible for persons with disabilities
designation (PWD) because he had not met all of the legislated criteria under section 2 the Employment and
Assistance for Persons with Disabilities Act. The ministry determined that the appellant had demonstrated that he
has reached 18 years of age. The ministry further determined that the appellant had not demonstrated: that his
impairment, in the opinion of a medical practitioner or nurse practitioner, is likely to continue for at least 2 years;
that he has a severe mental or physical impairment; that his severe mental or physical impairment, in the opinion of
a prescribed professional, directly and significantly restricts his ability to perform daily living activities (DLA) either
continuously or periodically for extended periods; and as a result of direct and significant restrictions, he requires
help to perform those activities.
PART D – RELEVANT LEGISLATION
Employment and Assistance for Persons with Disabilities Act (EAPWDA) – section 2
Employment and Assistance for Persons with Disabilities Regulation (EAPWDR) – section 2
PART E – SUMMARY OF FACTS
Evidence before the ministry at reconsideration consisted of the following:
1.
The appellant’s PWD Application
The Application contained:
•
A Medical Report (MR) dated 5 December 2017, completed by a general practitioner (GP) who has
seen the appellant 11 or more times in the past 12 months and known the appellant for more than 10
years. Section 2, Part E – Daily Living Activities was not completed in the initial MR (dated 5 December
2018). A completed Section 2, Part E – Daily Living Activities, dated 20 April 2018, was before the
ministry at the initial decision and at reconsideration.
•
An Assessor Report (AR) dated 14 June 2017, completed by a registered nurse (RN) who has seen
the appellant 1 time in the past 12 months and completed the AR at the first visit.
•
A 2-page typewritten Self Report (SR) dated 17 August 2017, signed by the appellant.
The panel will first summarize the evidence from the PWD Application as it relates to the PWD criteria at issue in
this appeal.
Duration
In the MR, the GP does not tick either ‘yes’ or ‘no’ in response to the question “Is the impairment likely to continue
for two years or more from today?”. The GP does not provide any comment in response to the question “What is
the estimated duration of the impairment and are there any treatments that may minimize or resolve the
impairment? Please explain.”
Diagnoses
In the MR, Part A – Diagnoses, the GP writes: There is no diagnosis that would fulfill a disability claim. Consultation
at UBC Neurovascular Disease Unit and Metabolic Consult and Genetic Workup support his ability to work.
Severity of mental impairment
MR:
The GP indicates that the appellant is fit to work and needs emotional support to gently reintegrate him back to
work and build up his confidence after many years on disability insurance.
The GP has ticked ‘no’ in response to whether there are difficulties with communication other than lack of fluency in
English.
The GP indicates that the appellant does not have significant deficits with cognitive and emotional functioning in the
areas of memory and emotional disturbance. No comments are provided.
AR:
The RN assesses the appellant’s cognitive and emotional functioning as having no impact in the areas of insight
and judgement, psychotic symptoms, other neuropsychological problems and other emotional or mental problems.
The RN assesses minimal impacts on daily functioning in the areas of attention/concentration and memory.
Moderate impacts on daily functioning are assessed in the areas of emotion, impulse control, executive and motor
activity. Major impacts are assessed in the areas of bodily functions, consciousness, motivation and language.
SR:
The appellant describes suffering from anxiety and depression due to being afraid to do anything. He indicates that
his home is messy because he has no motivation to clean it and this prevents him from socializing at home. He
expresses difficulty with both socializing and communication due to anxiety.
Severity of physical impairment
MR:
Under Health History, the GP writes: He had a catastrophic event in the distant past with rhabdomyolysis that
ended up in the ICU. Unfortunately he had been told to avoid work and exertion. This had resulting in many years
on a disability insurance claim. He is fit to work and needs emotion support to gently reintegrate him back to work
and build up his confidence.
For functional skills, the GP indicates that the appellant can walk 4+ blocks unaided, climb 5+ steps unaided, and
remain seated without limitation. Lift abilities have not been assessed.
The GP does not indicate whether the appellant requires any aids or prostheses.
AR:
In the AR, the RN has responded to the question “What are the applicant’s mental or physical impairments that
impact his/her ability to manage Daily Living Activities?” as follows: Rhabdomylosis – pain flare up. [Left] shoulder
frozen. Hypertension. Only has one kidney. Tremors in hands. Nocturia 2-3 hours. Client is seeing a geneticist for
further testing.
The RN indicates that the appellant requires periodic assistance from another person with all areas of mobility and
physical ability, including: walking indoors and outdoors, climbing stairs standing lifting and carrying and holding. As
well, the RN indicates that the appellant takes significantly longer (10x) with walking indoors and outdoors and
climbing stairs and significantly longer (3x) with carrying and holding. The RN comments: Pain, weakness in body
(rhabdomyolysis) with exertion.
SR:
The appellant states that he suffers from rhabdomyolysis, which can be fatal, and is at risk of kidney failure. He
explains his physical limitations, fear of exertion due to an inability to know his limitations, and difficulty with DLA,
including dressing, bathing, carrying groceries, making his bed, cooking, laundry and housekeeping.
Ability to perform DLA
MR:
The GP indicates that the appellant has not been prescribed medication that interferes with his ability to perform
DLA.
The GP indicates that the appellant is not restricted in relation to: personal care, meal preparation, management of
medications, basic housework, daily shopping, mobility inside and outside of the home, use of transportation and
management of finances. The GP indicates that the appellant is restricted periodically with social functioning.
In explaining ‘periodic’ the GP comments: avoidant of anxiety provoking situations such as job interviews. He
manages well when he feels safe with friends and people whom he knows and trusts.
The GP provides the following additional comments in relation to the degree of restriction: has avoidance of job
interviews due to the fear of failure and embarrassment, has resulted in unemployment.
In relation to assistance needed with DLA, the GP comments: Coaching and confidence building. Teaching of
communication skills and teaching that anxiety symptoms will not hurt him but the avoidance and not facing the
anxiety gently and gradually will strengthen his self doubt.
AR:
The RN indicates that the appellant is independent in the personal care activities of dressing and transfers in/out of
bed and on/off chair; the shopping activities of reading prices and labels, making appropriate choices and paying
for purchases; the meals activity of safe storage; the pay rent and bills activities of banking and paying rent and
bills; the medications activity of safe storage; and the transportation activities of getting in/out of a vehicle and using
public transit.
The RN indicates that the appellant requires periodic assistance with the personal care activities of grooming,
bathing, and feeding self; and the shopping activity of carrying purchases home.
The RN indicates that the appellant requires continuous assistance for basic housekeeping; shopping activity of
going to and from stores; the meals activities of meal planning, food preparation and cooking; the pay rent and bills
activity of budgeting; the medications activities of filling/refilling prescriptions and taking as directed; and the
transportation activity of using transit schedules and arranging transportation.
Section 2(1)(b) DLA
The following DLA are applicable to a person who has a severe mental impairment:
Make decisions about personal activities, care or finances
MR:
The GP indicates that the appellant is not restricted in his ability to manage personal self care, meal preparation,
medications and finances.
AR:
The RN indicates that the appellant is independent with shopping activities of reading labels, making appropriate
choices, and paying for purchases; the meals activities of safe storage; the pay rent and bills, of banking and bill
payment; the medications DLA of safe storage.
The RN indicates that the appellant requires assistance with meal planning (continuous), budgeting (continuous),
filling/refilling prescriptions and taking as directed (continuous) and the transportation DLA of using transit
schedules and arranging transportation (continuous).
Relate to, communicate or interact with others effectively
MR:
The GP indicates that the appellant has no difficulties with communication and is periodically restricted in relation to
social functioning.
AR:
The RN assesses the appellant’s ability to communicate as satisfactory in the areas of reading, writing and hearing
and poor in the area of speaking with the comment: speech impediment.
In assessing social functioning activities, the RN indicates that the appellant requires periodic assistance with
appropriate social decisions and continuous support/supervision with developing and maintaining relationships,
interacting appropriately with others, dealing appropriately with unexpected demands and securing assistance from
others. The RN indicates that the appellant has marginal functioning in his immediate (social phobia, seclusion) and
extended social networks (isolates, polite if engaged).
In response to help required the RN comments: mental health supports for anxiety, depression and isolation.
Help required
MR:
The GP does not indicate whether the appellant needs help.
AR:
The RN indicates that the appellant receives assistance from health authority professionals, community service
agencies and friends and provides the comment: friends may assist with these ADLs when available and if the
client asks – however client has difficulty asking for help.
In response to the prompt to specify what help is required but there is none available, the RN writes: housekeeping,
laundry, cooking, budgeting, transportation, shopping, social interaction, counselling for depression, dietary
assistance, genetic testing, speech therapy, memory prompts, blister pack medication kidney care – urology
consult.
The RN does not indicate that the appellant uses assistive devices. The RN responds to the prompt for equipment
needed but not being used with the comment: blister pack medication. OT assessment for assistive devices
needed.
The RN indicates that the appellant does not receive assistance from assistance animals.
2.
A 4-page advocate’s letter dated 16 January 2018, arguing that the appellant meets all PWD criteria.
3.
A 1-page letter dated 5 May 2018, written by a geneticist, indicating that the appellant has a “micro deletion
which is a susceptibility locus for neurodevelopmental disorders.”
4.
A 3-page letter, dated 29 March 2017, written by a geneticist, indicating that the appellant’s rhabdomyolysis
with relatively minor exercise suggests a metabolic disorder but the panel conducted has largely eliminated
the known possibilities. The letter indicates that it seems likely that he might suffer similar episodes with
significant exercise and it is difficult to know how much activity to advise or how to monitor it.
5.
Request for Reconsideration
In the appellant’s signed Request for Reconsideration, dated 18 June 2018, the following reasons for the request
are provided: {Appellant] disagrees with the assessment. The adjudicator appears to place more weight on the
physician’s portion. Employment and Assistance for Person with Disabilities Legislation must be interpreted with a
benevolent purpose in mind. There is no statutory requirement that both the physician and assessor must confirm
the impairment – it is either.
Included with the Request for Reconsideration is a 6-page advocate’s letter, in which it is argued that the appellant
meets all PWD criteria set out it in the legislation and that the information provided by the RN should be preferred
over the information provided by the GP.
Additional information before the panel on appeal consisted of the following:
Notice of Appeal
In the Notice of Appeal dated 26 July 2018, the following reasons for appeal are provided [Appellant] disagrees with
the weight given to the physician’s portion given the evident bias and the ministry’s decision makes reference to the
assessor not being a nurse practitioner.
Appeal Submissions
At the hearing, the appellant, with assistance from an advocate, argued that the ministry erred in its weighing of the
evidence as it preferred the information provided by the GP over the information provided by the RN. In addition,
the appellant argued that there is no statutory requirement for confirmation of the appellant’s eligibility from both the
RN and GP. The appellant’s position is that the right approach is to consider the scales of probability, and erring on
the side of caution with a benevolent purpose in mind to resolve any ambiguities in favour of the appellant. As well,
the appellant urged the panel to consider that 3 advocates, the RN and appellant all attest to the appellant’s
eligibility. As well, the appellant argued that the GP has displayed inherent bias, as it is evident that the GP has a
concern with clients on disability.
The ministry relied on the reconsideration decision.
Admissibility
The panel finds that the information provided in the appellant’s Notice of Appeal and at the hearing consists of
argument, which does not require an admissibility determination in accordance with section 22 (4)(b) of the
Employment and Assistance Act.
PART F – REASONS FOR PANEL DECISION
The issue in this appeal is whether the ministry decision that determined that the appellant did not meet four of the
five statutory requirements of Section 2 of the EAPWDA for PWD designation is reasonably supported by the
evidence or is a reasonable application of the legislation in the circumstances of the appellant. Specifically, the
ministry determined that the information provided did not establish that:
•
the appellant has a severe mental or severe physical impairment;
•
that the appellant’s severe mental or physical impairment, in the opinion of a medical practitioner or nurse
practitioner, is likely to continue for at least 2 years;
•
that the appellant’s severe mental or physical impairment, in the opinion of a prescribed professional,
directly and significantly restricts his ability to perform daily living activities (DLA) either continuously or
periodically for extended periods; and
•
as a result of those restrictions, he requires help to perform those activities.
The following section of the EAPWDA applies to this appeal:
Persons with disabilities
2 (1) In this section:
"assistive device" means a device designed to enable a person to perform a daily living activity that, because of a
severe mental or physical impairment, the person is unable to perform;
"daily living activity" has the prescribed meaning;
"prescribed professional" has the prescribed meaning.
(2) The minister may designate a person who has reached 18 years of age as a person with disabilities for the
purposes of this Act if the minister is satisfied that the person is in a prescribed class of persons or that the person
has a severe mental or physical impairment that
(a) in the opinion of a medical practitioner or nurse practitioner is likely to continue for at least 2 years, and
(b) in the opinion of a prescribed professional
(i) directly and significantly restricts the person's ability to perform daily living activities either
(A) continuously, or
(B) periodically for extended periods, and
(ii) as a result of those restrictions, the person requires help to perform those activities.
(3) For the purposes of subsection (2),
(a) a person who has a severe mental impairment includes a person with a mental disorder, and
(b) a person requires help in relation to a daily living activity if, in order to perform it, the person
requires
(i) an assistive device,
(ii) the significant help or supervision of another person, or
(iii) the services of an assistance animal.
(4) The minister may rescind a designation under subsection (2).
The following section of the EAPWDR applies to this appeal:
2 (1) For the purposes of the Act and this regulation, "daily living activities",
(a) in relation to a person who has a severe physical impairment or a severe mental impairment, means the
following activities:
(i) prepare own meals;
(ii) manage personal finances;
(iii) shop for personal needs;
(iv) use public or personal transportation facilities;
(v) perform housework to maintain the person's place of residence in acceptable sanitary condition;
(vi) move about indoors and outdoors;
(vii) perform personal hygiene and self care;
(viii) manage personal medication, and
(b) in relation to a person who has a severe mental impairment, includes the following activities:
(i) make decisions about personal activities, care or finances;
(ii) relate to, communicate or interact with others effectively.
(2) For the purposes of the Act, "prescribed professional" means a person who is
(a) authorized under an enactment to practise the profession of
(i) medical practitioner,
(ii) registered psychologist,
(iii) registered nurse or registered psychiatric nurse,
(iv) occupational therapist,
(v) physical therapist,
(vi) social worker,
(vii) chiropractor, or
(viii) nurse practitioner, or
(b) acting in the course of the person's employment as a school psychologist by
(i) an authority, as that term is defined in section 1 (1) of the Independent School Act, or
(ii) a board or a francophone education authority, as those terms are defined in section 1 (1) of the School
Act,
if qualifications in psychology are a condition of such employment.
Duration
The legislation requires that for PWD designation, an opinion from either a medical practitioner or nurse practitioner
is required to determine that the person’s severe impairment is likely to continue for at least two years.
In the reconsideration decision, the ministry noted that the GP’s assessment in the MR does not indicate or speak
to the expected duration of the appellant’s impairment. The ministry also noted that the assessor who completed
the AR is a RN, not a nurse practitioner. The ministry considered the March 29 geneticist’s letter, noting that it
spoke to the possibility of recurring episodes rather than the duration of impairment. The ministry concluded that it
could not be established that the appellant’s impairment, in the opinion of a nurse practitioner or medical
practitioner, is likely to continue for two years.
At the hearing, the appellant argued that the RN is technically qualified to complete the PWD application, according
to the BC government website. As well, the appellant argued that the supplemental information, specifically the
geneticist’s March 29 letter does speak to duration of impairment.
The panel finds that the legislation clearly states that the opinion of a medical practitioner or nurse practitioner is
required for duration. As a result, the panel finds that information provided by a Registered Nurse is not “the opinion
of a medical practitioner or nurse practitioner”. In addition, the panel finds that the geneticist’s statement that It does
seem likely that he may night suffer similar episodes with significant exercise, so it is difficult to know how much
activity to advise, or indeed how to monitor it does not speak to duration. The panel finds the ministry’s conclusion
that this statement speaks to the likelihood of recurring episodes rather than expected duration is a reasonable
application of the legislation. The panel concludes that the ministry’s determination that the duration requirement
has not been established is reasonably supported by the evidence and a reasonable application of the legislation.
Severity of impairment
The legislation requires that for PWD designation, the minister must be “satisfied” that the person has a severe
mental or physical impairment. The legislation makes it clear that the determination of severity is at the discretion of
the minister, considering all the evidence, including that of the appellant. Diagnosis of a serious medical condition
or the identification of mental or physical deficits does not in itself determine severity of impairment.
Severity of physical impairment
In the reconsideration decision, the ministry determined that a severe impairment of physical functioning had not
been established. In making this determination, the ministry considered the functional skills assessment by the GP
noting that the appellant is able to walk 4+ blocks unaided, climb 5+ steps unaided, limitations in lifting are not
indicated and the appellant has no limitation with remaining seated. The ministry argued that while the RN states in
the AR that the appellant suffers from a number of medical conditions and flare-ups, the GP does not describe
these conditions in the MR. As well, the ministry argued that while the RN has indicated in the AR that the appellant
suffers from flare-ups, she has not described the frequency of such flare-ups. The ministry noted that the RN had
met the appellant for the first time when completing the AR, while the GP has known the appellant for more than 10
years and has seen him 11+ times in the past 12 months. The ministry indicated its inclination to put more weight
on the assessment of the GP. The ministry’s conclusion on this criterion was that a severe impairment of the
appellant’s physical functioning had not been established.
The panel finds that the ministry’s determination was reasonable. The panel notes that the assessments of the
appellant’s functional capacity and mobility and physical ability assessments in the MR and AR are not consistent
with one another and do not provide a clear picture of the appellant’s ability to function independently. The
argument provided by the appellant is that the information in the AR is to be preferred because the GP is biased
and the information he has provided does not accurately reflect the appellant’s situation. However, the panel finds
that despite assertions of bias by the appellant’s advocates, the physician’s statements in the MR do not reflect a
severe physical impairment. The appellant also argued that any ambiguities should be resolved in favour of the
appellant. However, the panel finds that, when faced with conflicting information in the MR and AR, the ministry’s
decision to prefer the information from the prescribed professional who has known the appellant for more than 10
years over the information provided by the prescribed professional who had met him one time is reasonable. The
panel finds that the information provided in the assessments, and the additional medical letters from the two
geneticists, does not provide a clear, consistent and detailed account of the impacts of the appellant’s limitations.
The panel finds that the ministry’s determination, that a severe physical impairment has not been established, is
reasonably supported by the evidence.
Severity of mental impairment
In the reconsideration decision, the ministry found that the appellant does not have a severe mental impairment.
The ministry noted that the GP’s assessment in the MR did not indicate that the appellant has difficulties with
communication. The ministry considered that in the MR the GP indicates no deficits in the areas of emotional
disturbance and memory and in the AR the RN assesses a number of major, moderate and minor impacts.
As well, the ministry considered the GP’s assessment of the appellant’s social functioning abilities. In this
consideration, the ministry took note of the GP’s MR assessment of periodic restrictions with social functioning and
noted the absence of information relating to frequency or duration restrictions. The ministry noted that the RN has
indicated impacts to communication, while the GP indicates no difficulties. As well, the ministry noted that the RN
has indicated that the appellant has significant deficits with cognitive and emotional functioning, while the GP has
indicated no significant deficits. The ministry indicated its inclination to put more weight on the assessment of the
GP because the RN had met the appellant for the first time when completing the AR, while the GP has known the
appellant for more than 10 years and has seen him 11+ times in the past 12 months. As well, the ministry
considered that the RN indicated a need for continuous assistance with 4 of the 5 listed area of social functioning,
while the GP indicated periodic restrictions to social functioning. The ministry concluded that the information
provided had not established a severe impairment in mental functioning.
The panel finds that the ministry’s determination that a severe mental impairment has not been established was
reasonable. The panel notes the presence of a number of inconsistencies between the MR and AR. Again the
panel finds that, when faced with conflicting information in the MR and AR, the ministry’s decision to prefer the
information from the prescribed professional who has known the appellant for more than 10 years over the
information provided by the prescribed professional who had met him one time is reasonable. As well, the panel
also notes that both the RN’s and GP’s assessments relating to decision-making indicate that the appellant is
independent in most of these areas. The panel finds that the ministry’s conclusion that the information provided
does not establish a severe mental impairment and that this criterion was not met is reasonably supported by the
evidence.
Direct and significant restrictions in the ability to perform DLA
The legislation specifies that the minister assess direct and significant restrictions in the ability to perform DLA in
consideration of the opinion of a prescribed professional, in this case the GP and RN. At issue in this assessment is
the degree of restriction in the appellant's ability to perform the DLA listed in section 2(1)(a) and (b) of the
EAPWDR applicable to a person with a severe mental or physical impairment.
The ministry was not satisfied that the appellant has a severe impairment that, in the opinion of a prescribed
professional, directly and significantly restricts his ability to perform DLA. In reaching this conclusion, the ministry
noted that the appellant has not been prescribed medication that impacts his ability to perform DLA. The ministry
considered the GP’s assessment that the appellant is not restricted with any DLA except for social function. The
ministry considered that the RN’s AR assessment indicates that the appellant is restricted with some areas of
personal care, basic housekeeping, shopping, meals, paying rent/bills, medications, and transportation but the GP
has indicated no restrictions in all of these areas. The ministry indicated its inclination to put more weight on the
assessment of the GP because the RN had met the appellant for the first time when completing the AR, while the
GP has known the appellant for more than 10 years and has seen him 11+ times in the past 12 months. The
ministry concluded that the assessments provided did not provide enough evidence to confirm that the appellant
has a severe impairment that significantly restricts his ability to perform DLA continuously or periodically for
extended periods.
The panel finds that the ministry’s determination that the assessments provided do not establish that a severe
impairment significantly restricts the appellant’s ability to perform DLA continuously or periodically for extended
periods was reasonable. The panel notes that the legislation specifies that direct and significant restrictions to DLA
must be in the opinion of a prescribed professional. The panel finds that, in relation to the areas where some
periodic restriction is assessed, neither the RN nor GP has provided sufficient information in relation to the nature,
degree and duration of the assistance required by the appellant to establish that there are significant restrictions for
extended periods in the appellant’s ability to perform DLA. As well, the panel finds that the only area in which the
GP and RN seem to agree that there are restrictions is social function. The panel finds that the appellant is
restricted with respect to social functioning. There is disagreement between the MR and AR with respect to all other
areas, with the RN indicating some level of restriction in many areas and the GP indicating no restrictions in any
areas. The panel notes that the appellant has argued that the GP’s information is biased and inaccurate. However,
the panel finds that the ministry’s approach to addressing the conflicting information in the MR and AR is
reasonable. Given the limitations in the information before the ministry, the panel concludes that the ministry’s
determination that this criterion has not been met is reasonably supported by the evidence.
Help required
The legislation requires that, as a result of being directly and significantly restricted in the ability to perform DLA
either continuously or periodically for extended periods, a person must also require help to perform those activities.
The establishment of direct and significant restrictions under section 2(2)(b)(i) is a precondition of meeting the need
for help criterion. Help is defined in subsection (3) as the requirement for an assistive device, significant help or
supervision of another person, or the services of an assistance animal in order to perform a DLA.
In the reconsideration decision, the ministry determined that as it had not been established that appellant’s ability to
perform DLA were significantly restricted, it cannot be determined that significant help is required. While the
information provided indicates that the appellant does receive assistance from other people, and that he requires
more assistance and/or supervision than he is currently receiving, the panel has concluded that the ministry
reasonably determined that direct and significant restrictions in the appellant’s ability to perform DLA have not been
established. As such, the panel finds that the ministry reasonably concluded that under section 2(2)(b)(ii) of the
EAPWDA it cannot be determined that the appellant requires help to perform DLA.
Conclusion
The panel finds that the ministry’s reconsideration decision, determining that the appellant had not met all of the
legislated criteria for PWD designation, was a reasonable application of the legislation in the circumstances of the
appellant and reasonably supported by the evidence. The panel confirms the ministry’s reconsideration decision.
The appellant is not successful on appeal.
PART G – ORDER
THE PANEL DECISION IS: (Check one)
UNANIMOUS
BY MAJORITY
THE PANEL
CONFIRMS THE MINISTRY DECISION
RESCINDS THE MINISTRY DECISION
If the ministry decision is rescinded, is the panel decision referred back to the Minister
for a decision as to amount?
Yes
No
LEGISLATIVE AUTHORITY FOR THE DECISION:
Employment and Assistance Act
Section 24(1)(a)
or Section 24(1)(b)
and
Section 24(2)(a)
or Section 24(2)(b)
PART H – SIGNATURES
PRINT NAME
Jennifer Smith
SIGNATURE OF CHAIR
DATE (YEAR/MONTH/DAY)
2018/08/16
PRINT NAME
Glenn Prior
SIGNATURE OF MEMBER
DATE (YEAR/MONTH/DAY)
2018/08/16
PRINT NAME
Donald Stedeford
SIGNATURE OF MEMBER
DATE (YEAR/MONTH/DAY)
2018/08/16
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