Posts Tagged ‘country of origin labeling’

Congress Must Strengthen Buy America Act

Tuesday, June 4th, 2019

The Buy American Act was passed by Congress in 1933. It required the U.S. government to give preferential treatment to American producers in awarding of federal contracts. The Act restricted the purchase of supplies that are not domestic products. For manufactured products, the Buy American Act used a two-part test:  first, the article must be manufactured in the U.S., and second, the cost of domestic components must exceed 50 percent of the cost of all its components.

After the end of the Cold War and the end of the subsequent Gulf War in 1991, the provisions of the “Buy America Act” were eased to allow purchasing off the shelf commercial parts (COTS) from foreign countries by the Defense Department and other government agencies if they met the same fit and function of parts made to strict military specifications. Previously, parts, assemblies, and systems were required to be substantially made in the United States or in a NATO country, such as Great Britain, France, or Germany.

In the early 1990s, most commercial parts were still being made in the United States, with some outsourcing to the Philippines, Hong Kong, and Singapore, so this change was pretty safe. However, permitting commercial parts to replace Military Specification parts probably drove out of business the small companies that catered exclusively to the military and provided Traceability of Origin per Military Specifications for parts supplied to government agencies, military contractors, and subcontractors. This was all done in the name of cost savings.

Gradually over the last 26 years, the manufacturing of most commercial electronic components and microchips was transferred offshore, so that now they are fabricated in China, Vietnam, or South Korea. 

This is the root cause of counterfeit Chinese parts becoming part of the military/defense industrial supply chain.

The President has authority to waive the Act in response to the provision of reciprocal treatment to U.S. producers. Under the 1979 GATT Agreement on Government Procurement, the U.S.-Israel Free Trade Agreement, the U.S.-Canada Free Trade Agreement, the North American Free Trade Agreement, the Central American Free Trade Agreement, and the Korea Free Trade Agreement, access to government procurement is granted by certain U.S. agencies for goods from the partner countries to these agreements.

It was reported by Reuters in January 2014 that “The Pentagon repeatedly waived laws banning Chinese-built components on U.S. weapons in order to keep the $392 billion Lockheed Martin Corp F-35 fighter program on track in 2012 and 2013, even as U.S. officials were voicing concern about China’s espionage and military buildup.”

To address weaknesses in the defense supply chain and to promote the adoption of aggressive counterfeit avoidance practices by the Department of Defense and the defense industry, an amendment to the National Defense Authorization Act for Fiscal Year 2012  was adopted in the Senate and signed by President Obama.

Instead of implementing the requirements of the Act, it appears that DOD “entered a new phase… characterized by globalization of supply chains” according to Richard McCormack, publisher and producer of the Manufacturing & Technology News, May 20, 2015 edition.

McCormack reported on comments made by Bill Lynn, CEO of Finmeccanica North America and former Deputy Secretary of Defense from 2009 until 2011, at the April 29, 2015 meeting of the Center for Strategic and International Studies in Washington, D.C.

The defense sector and the U.S. military have “moved from being a net exporter of technology to a net importer,” Lynn stated, adding “When their R&D budgets are combined to total a scant $3 billion (or only 1.6 percent of revenue), the five biggest defense contractors — Boeing, Lockheed, Raytheon, L3 and Northrop — would not even make the list of the top 20 global companies that invest in R&D.”

Lynn told the meeting, “Those are things where the commercial industrial base is stronger than the defense industrial base and in many ways the key to maintaining our future [defense] technology edge is to be able to import those technologies into our defense industrial base… Since many of the underlying technologies now reside outside of the United States, DOD has to figure out how to deal with foreign corporations and state-owned enterprises that hold the keys to its success.”

McCormack noted, “The Department of Defense and its major contractors are now dependent on foreign manufacturers for many of the military’s most advanced weapons systems…The defense industry is a shadow of its former self, representing less than 3.5 percent of the U.S. economy, a position that continues to decline as defense budgets reach new lows with no chance of them growing faster than the economy.”

Lynn commented that “DOD is slowly catching up to the structural change caused by globalization of technology and supply chains. It is wrestling with the regulatory and procurement systems it has in place to monitor and conduct business with foreign suppliers, but it has little time to waste.”

Lynn stated “that changing perceptions about foreign involvement in the defense industry are similar to what happened in the U. S. auto sector…Americans and their representatives in Congress were skeptical about foreign nameplates. But as foreign auto companies started building technologies in the United States and hiring American workers, the tide turned… “

It is incomprehensible to me to compare what happened to the U. S. auto industry to what is happening to the U. S. defense industry. The whole purpose of the defense industry is to protect our national sovereignty and national security. How can anyone in their right mind want to make our defense supply chain vulnerable to the foreign country, namely China, that has a written plan to replace the U.S. as the world’s super power? The Chinese have stolen our technology to build up their own military power as evidenced by the uncanny similarity of China’s stealth fighter, the J-31and the Chengdu J-20 fighter jet to the F-35 Lightning II advanced fighter jet. 

Does anyone believe that we will get the parts and assemblies needed by our defense industry when China has decided we are so weak that we cannot stop their aggression in Asia? We are not even safe to have parts sourced in Taiwan, South Korea, the Philippines, Malaysia, Indonesia, or Vietnam. These countries would all be targets for takeover by China once the Chinese lose their fear and respect for U. S. naval and air power.

Four of the last five sessions of Congress attempted to address this problem, but the following bills to strengthen the Buy American Act introduced in Congress failed to be enacted: 

H.R. 4553 (111th), introduced February 2, 2010

S. 2391 (113th), introduced May 22, 2014

S. 2167 (114th), introduced October 8, 2015.

At least, President Trump issued an Executive Order on Buy American and Hire American onApril 18, 2017, which set forth a policy to “maximize …use of goods, products and materials produced in the United States” through federal procurements.

This was followed by the introduction of the 21st Century Buy American Act (S.2196) on Dec. 6, 2017 by Sen. Chris Murphy, D-CN, and a similar bill, H.R. 4812 introduced in the House by Representative David Cicilline. D-RI.  Both bills aimed to strengthen existing Buy American standards, but after considerable support, both failed to be enacted. The legislation focused on five change areas.

  1. The cost of components test for non-commercial-off-the-shelf items would be modified to require that an item’s U.S. component costs exceed 60% of the item’s total costs for the item to be deemed “domestic.” From the current 50%
  2. The so-called “overseas exemption” regarding items procured for use outside the United States would be limited significantly.
  3. Agencies would not be permitted to apply a public interest exception unless it considers the short-term and long-term effects of applying such exception on employment within the U.S.
  4. A program to make or guarantee loans would be created for contractors seeking to manufacture certain items that are not currently manufactured in the U.S.
  5. Actions would be taken to increase transparency related to the use of exceptions

On May 2, 2019, Congressmen Dan Lipinski (IL-3) and Mike Bost (IL-12) “reintroduced the BuyAmerican.gov Act, which helps ensure that federal agencies adhere to Buy American laws and prioritize the purchase of American-made goods. The legislation, H.R. 2472, directs the General Services Administration to establish a website, BuyAmerican.gov, to collect and display information about each request by a federal agency to bypass ‘Buy American’ laws and purchase foreign-made products.  Once the law is approved, manufacturers and others will be able to use the site to identify contract opportunities and challenge pending ‘Buy American’ waivers sought by federal agencies.”

The press release stated, “In the last five years, federal agencies have spent $34 billion on goods manufactured by foreign firms.  The Department of Defense, the largest purchaser of manufactured goods in the world, has spent almost $200 billion on manufactured goods made by foreign companies since 2007.…This bill applies “Buy American” requirements to federal spending programs that are not covered under current law and closes loopholes in “Buy American” programs.

Under current law, federal agencies are exempt from following Buy American laws if American-made goods are unavailable or cost-prohibitive. Unfortunately, federal agencies are too often abusing this waiver authority and there’s no way to hold them accountable,” Lipinski said.”

Senators Rob Portman (R-OH), Chris Murphy (D-CT), Lindsey Graham (R-SC), and Sherrod Brown (D-OH) introduced companion legislation the same day in the Senate.

This bill increases transparency related to waivers and exemptions to the Buy American Act, but it doesn’t address the other four issues that previous bills addressed.

Congress must act to strengthen the Buy American Act, not weaken it, eliminate the incentives for offshoring, and provide incentives for bringing manufacturing back to America. We must protect the supply chain for defense and military products and systems, so that the Defense Department can fulfill its primary mission of defending our country.

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Coalition for a Prosperous America’s California Chapter Celebrates the Outlook for the Future

Tuesday, December 17th, 2013

The California Chapter of the Coalition for a Prosperous America (CPA) held their annual dinner in San Diego on January 11th at the Del Mar Hilton to look back on this year’s work and ahead to the coming year, as well as honor those who have helped make that work successful. Nearly 80 attendees joined me in showing our appreciation to Senator Mark Wyland for being the co-host of the well-attended “Manufacturing in the Golden State–Making California Thrive” economic summit last February. Unfortunately, co-host Assemblymember Toni Atkins was unable to be present. Assemblyman Tim Donnelly and County Supervisor Dave Roberts attended along with staff representing Congresswoman Susan Davis, Congressman Darrell Issa, Assemblyman Brian Jones, and Assemblyman Rocky Chavez.

I shared how I became involved with CPA, which is a non-profit, non-partisan membership organization established in 2007 as a coalition of manufacturing, farming, ranching, and labor to fix the U.S. trade deficit and the economy. CPA uniquely joins these distinct groups and focuses on both grass roots and Washington, D. C. lobbying efforts. CPA educates business, organization and political leaders about the economic harm caused by the trade deficit, methods to correct the deficit, and the need to develop and implement a national strategy to produce more in the U.S. so jobs and the taxes they create stay in the U. S.

When I was researching and writing the chapter “What is being done now to save American manufacturing?” for the first edition of my book in 2008, I found many trade and professional organizations that were focused on a particular issue important to their industry or profession, but there didn’t seem to be any collaboration between the organizations to support or oppose issues that affected American manufacturers. The two most powerful organizations, the National Association of Manufacturers and the U. S. Chamber of Congress seemed to be controlled by the large multinational corporations whose position on various issues were at odds with those of smaller American-only manufacturing corporations.

After my book was published in 2009, I met Ian Fletcher, author of Free Trade Doesn’t Work:  What should replace it and why, and he introduced me to CPA when he became their Sr. Economist in early 2011. I realized this was just the kind of organization I had been looking for and started participating in their member-at-large monthly conference calls to share what we were each doing to work on issues adversely affecting American manufacturing.

I volunteered to help CPA put on a Smart Trade Conference on March 28, 2012, and one of the people that attended was Donna Cleary, Field Rep for State Senator Mark Wyland. She asked CPA to facilitate putting on a manufacturing summit in the fall. Because of the national election, we postponed the summit to February 2013, which gave us more time to solicit partners and sponsors. Our partner list became the “who’s who” of organizations in San Diego, and the summit was very successful. In addition to being a bi-partisan event, what made it different was that we broke into small groups after the main presentations and conducted “pair wise” voting on issues to come up with the top two issues: California regulations and the need for a national manufacturing strategy.

We formed a Manufacturing Task Force and produced a report that we disseminated to all of the attendees and subsequently presented to our Congressional delegation. We also presented CPA position papers on the trade deficit, currency manipulation, County of Origin labeling, Border Adjustable Taxes, and “Fast Track” Authority for the proposed Trans-Pacific Partnership Agreement (a trade and global governance agreement being negotiated by the U.S. with eleven Pacific Rim nations).

We sponsored a viewing of the film “Death by China” in September, which clearly shows that we are in a trade war with China that we are losing, and American companies aren’t competing against Chinese companies, but the Chinese government itself.

The next speaker was Mike Dolan, Legislative Representative for the Teamsters, who said, “If CPA didn’t exist, we’d have to invent it.” His basic point was that, based on his long experience working on the Hill and in the field for Fair Trade (fighting expansion of the flawed and failed NAFTA/WTO model), we can win the current battles of the Trans-Pacific Partnership and Fast Track if and only if we build and maintain a strong bipartisan mobilization. He called the TPP “NAFTA on steroids.” He doesn’t see a path to victory next year on sensible trade policy without the Coalition for a Prosperous America and the constituencies it represents — small business, particularly in industries that are sensitive to trade fluctuations, family farmers and ranchers, working families and “trade patriot” activists including the Tea Party cadres.

Bill Bullard, CEO of R-CALF USA (Ranchers-Cattlemen Action Legal Fund, United Stockgrowers of America) was the next speaker. He said they joined the Coalition because their industry was being unfavorably impacted by current U. S. trade policies and unfair trade practices by our trading partners. He said, “The number of privately owned cattle and sheep ranches has been going down dramatically since 1994 when NAFTA went into effect and accelerated after China became part of the World Trade Organization (WTO) in 2000. The size of the beef and sheep herd has been decreasing every year, while imports of beef, lamb, and mutton have been increasing.” Shockingly, he revealed that fast food restaurants are not required to disclose the origins of their beef and even when restaurants say the beef is “U.S. Inspected,” it is as likely as not to be imported. Their industry especially needs the government to provide consumer package labeling to show where meat and livestock was born, raised and slaughtered and to reverse the current policy of lowering U.S. health and safety standards just to facilitate more imported meat.

CPA President Michael Stumo presentation was “A Prosperity Strategy for America,” in which he stated:  “We are convincing Congress that we need “net exports,” not merely more exports, to be a successful trading and producing nation. In 2011, our trade deficit shaved an astounding 4% from overall U. S. GDP. We should have a national goal to grow manufacturing back up to 20% of GDP rather than 11%.

Supply chains are the lifeblood of our economy, and all tiers of suppliers to the OEMs are important. They produce the jobs, the job multipliers, the wealth, the innovation, and the intellectual property of a successful developed economy. Those in Washington who are pushing “global supply chains” are really pushing offshoring of our supply chain. We need a strategy of acquiring, keeping, and growing “domestic supply chains” for a strong America.

We need to stop offshoring our manufacturing jobs and the taxes they create to safeguard our economic strength, our democracy and our constitutional republic. The globalization agreements like the Trans-Pacific Partnership are only 15% about tariffs and quotas and 85% about non-trade topics. These other topics include financial regulation, taxes, food and product safety, product labeling, government procurement of domestic supplies, and other matters. These globalization deals transfer the authority of Congress and states over these domestic policy issues to unelected international tribunals of foreign trade lawyers.

The old way of manufacturing and labor working separately for their interests no longer works. These issues are a macro problem for our country and affect all Americans. That’s why manufacturers, farmers, ranchers and workers must work together.

It is working. A large part of Congress signed a letter opposing Fast Track trade authority because of sovereignty and economic issues. Leadership on important committees is talking about net exports rather gross exports. A majority of the House and Senate signed a letter calling for effective protections against foreign currency manipulation in future international agreements. We need to win. Vince Lombardi said ‘winning isn’t everything… it’s the only thing.’ We can win these issues by expanding our membership of individuals, companies, and organizations and expanding from eight state chapters to at least 25 chapters.”

In the wrap-up presentation, Dave Frengel, Director of Government Relations, Penn United Technologies, a precision tool making company, said, “We have 600 employees today, but if our government had been standing up for us against China’s unfair trade practices, we would have 1200 employees, most in family-sustaining jobs with good benefits. Unfair trade affects the entire U.S. supply-chain, not just our company. Our government has been turning its back on production of food and manufactured goods. Our precision tooling and manufacturing industry, which is critical to America’s industrial economy, is a third of what it was before this era of bad U.S. trade policy began. The resulting loss of jobs is huge.”

He continued, “When I was asked by my boss to “fix trade” 11 years ago, we tried working within the National Association of Manufacturers, but our voice and that of other American-only manufactures was ignored. We realized that we needed to join not only with manufacturers and concerned citizens, but with farmers, ranchers and workers to win. We realized that the mission would not be accomplished through existing organizations – we needed a new organization to get the job done. That is why we were a founding member of CPA.

For nearly seven years now, CPA has been holding events all over the nation to raise awareness and mobilize local leaders around trade reform issues. CPA members and staff made over 200 legislative visits this past year. The credibility and influence of CPA is growing and our trade reform message is becoming more convincing as we continue to have crucial conversations with a growing circle of trade policy leaders in Washington, D. C.

We are opening new doors with trade negotiators inside the Obama Administration, the House Ways and Means Committee, and the Senate Finance Committee. Our efforts helped gain massive Congressional opposition to Fast Track trade authority and in support of our constitution. Our efforts helped gain a majority of Senate and House support for effective currency manipulation provisions in all future trade deals.

The Chinese will negotiate forever without changing their predatory trade strategies. We need protection from those who cheat us, which requires strong enforcement of international trade rules by our government. We can compete against foreign companies, but not against foreign governments that rig markets to cheat us out of our share of markets. The Coalition for a Prosperous America works for trade reform that delivers prosperity and security to America, its citizens, factories, farms, and working people. The solutions that CPA focuses on will benefit those who make and grow things here.”

In conclusion, he stated, “We are gaining more GOP support, more Democrat support, more Tea Party support, more citizen support, and more producer support. This year, we’re starting to win – because of the growth in size and influence of the Coalition for a Prosperous America. We need to get stronger. We need you to consider joining CPA as an individual or a company member or to make a tax deductible donation to the CPA Education Fund.”

Bad U. S. trade policy is a major cause of California’s economic crisis. Offshoring has cost California hundreds of thousands of its manufacturing jobs. Family members lost good jobs; communities declined; property values plummeted. We Californians know that we need a smarter U.S. trade strategy.

As a fledgling chapter, we are already influencing the trade policy positions of San Diego’s Congressional delegation, but need to grow to influence the other 48 Representatives and our two Senators to support better trade deals that will grow our economy. This is not a Republican issue nor a Democratic issue, but an American issue, and they must vote right to properly represent California. We need to get stronger and grow to accomplish our goals. We need your involvement and financial support to make a difference. Please contact me at michele@savingusmanufacturing.com to participate in the California Chapter.

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Why it is Important to Know Where Products are Manufactured

Tuesday, September 3rd, 2013

At a time when more consumers are paying attention to where products are made and expressing greater interest in buying “Made in USA” products even if they cost more, there are changes proposed that could impact consumers being able to make decisions on the products they buy.

The first reason we need to know where products are manufactured is to have a clear picture of whether the nearly six million manufacturing jobs we have lost since 2000 have been mainly the result of technologic advances and higher productivity in the U. S. or whether outsourcing to foreign countries like China has been the main cause.

For decades, there have been companies referred to as manufacturers that I called “virtual manufacturers.” in my book. These companies have no manufacturing capability in-house. Sometimes they don’t even have the personnel to design the product. The founders of the company may have a concept of the new product they wish to develop and market, but they don’t have the technical expertise to do the design and development themselves. They hire outside consultants to design and develop the product or subcontract the design, development, and prototyping to a company specializing in these services. At the extreme end, they subcontract out everything from start to finish, including engineering design, procurement of parts and materials, assembly, test, inspection, and shipping to the end customer. They may handle marketing and customer service themselves, but sometimes they even subcontract these functions to marketing and customer service firms. There was no real impact on U. S. manufacturing data as long as these U. S. companies outsourced their manufacturing to other domestic manufacturers.

However, in the past 20 years, these virtual manufacturers have increasingly outsourced most or all of their manufacturing offshore. This resulted in U. S. federal agencies involved in economic data labeling them as “factoryless goods producers” and classifying them as “wholesale traders,” if they didn’t do any domestic manufacturing themselves. Apple, Nike, and Cisco are some of the more well known “factoryless goods producers” because of having their manufacturing outsourced offshore.

Now, U.S. federal agencies involved in economic data want to change the way they classify companies that have outsourced their U.S. production to foreign manufacturing companies. They are proposing to reclassify these “wholesale traders” as “domestic manufacturers.” This means that their sales would be counted as U.S. production and their products that are made offshore and imported into the U. S. for sale would no longer be counted as imports.

As reported in the August 20th issue of Manufacturing & Technology News, the purpose of this change is supposedly “to determine how much products are been offshored and to pinpoint the number of American companies that are linked to manufacturing, even though they don’t make the products they design and sell.”

For the past decade, “U.S. statistical agencies found that the North American Industry Classification System (NAICS) did not provide a clear definition of companies that outsourced their production overseas, but that still owned the design and controlled the production and sale of goods from that foreign production.” A Manufacturing Transformation Outsourcing Subcommittee was formed in 2008 by the Economic Classification Policy Committee “to define outsourcing and identify “characteristics of establishments that outsource manufacturing transformation activities.” The committee was made up of representatives from the Bureau of Economic Analysis, the Bureau of Labor Statistics, the Census Bureau and the White House Office of Management and Budget.

“The committee decided that all factoryless goods producers should be classified in manufacturing, the specific industry classification based on the transformation production process used by the contractor”  and recommended that the classification changes be implemented in the 2017 North America Industry Classification System.

There is disagreement on whether this change would be beneficial as it would impact a dozen major government statistical series, such as industrial production, producer price indexes, and industrial productivity.

In my opinion this change would result in data that is misleading and wouldn’t be giving a true picture of American manufacturing. We would not be able to know how much is actually being produced in the United States if we count imports from offshore as if they are domestic production. This change could radically increase U.S. production statistics and reduce our import statistics making our trade balance artificially look better.

A better way to find the answer to this question has been provided by San Diego entrepreneur and businessman, Alan Uke in his book, Buying America Back:  A Real-Deal Blueprint for Restoring American Prosperity. Mr. Uke writes, “Our future as a nation and as individuals is being threatened. Since our spending habits as consumers have contributed to this situation, we can change our spending habits to reverse it… in order for a change to happen, consumers must demand to be more honestly and completely informed about what they are buying and where their money goes. To this end, we are starting a consumer movement to bring this to the attention of Congress…The goal of this movement and of this book are to encourage people to change their buying habits toward purchasing things that help the U. S. economy and job situation.”

He points out that the current information provided on country of origin labels is “misleading, incomplete, inaccessible, or all of these…In order to support our economy and American industries, we must have easily accessible, clearly communicated, and truthful information about a product’s entire origins.”

Mr. Uke recommends that consumers be provided the country of origin information they need at the point of sale whether at a store or online and presents a proposal for the U. S. government to require detailed country-of-origin labels for all manufactured products similar to the nutritional information labels now required on packaged food products. He feels that it is important for consumers to “see the last place where the product was manufactured” and “to discern what portion of its components came from other places” by use of what he calls a “Transparent Label.” It would include the cost by country of origin by both percentage and trade ratio, as well as the location of the company’s headquarters. The percentage is the total cost of the product that is produced or transformed in a particular country. The trade ratio describes the amount of exports vs. imports for a country in relation to the United States. This label would enable consumers to make better decisions when they buy manufactured goods.

The second reason we need to know where products are manufactured is to protect ourselves from unsafe, defective, toxic, and counterfeit products. The U. S. Consumer Protection Safety Commission’s website provides a monthly list of products that have been recalled, and month after month, more than 90% are made in China.

A label similar to Mr. Uke’s recommendation would help companies comply with the new product safety standard (ISO 10377) recently released by the International Standards Organization (ISO):  The “Consumer Product Safety — Guidelines for Suppliers” standard (ISO 10377). The summary written by Dr. Elizabeth Nielsen, Chair of ISO/PC 243, Consumer product safety and a Canadian government Scientist, Regulator and Policy Analyst, states, “Regardless of company structure and organization, ISO 10377 will affect all suppliers irrespective of their role in the supply chain and all types of products whatever the origin.”

“Products should be traceable and carry a unique identifier that is labelled, marked or tagged at the source. This also goes for raw materials, components and subassemblies. Suppliers should insist on properly identified products from vendors and be able to trace products back to their direct source and identify the next direct recipient of the product in the supply chain.”

This standard has a different purpose for labeling than Mr. Uke’s label:  to protect consumers from unsafe, defective, toxic, and counterfeit products. “Products are safer when they carry documentation about the product, its design, its production and its management in the market…Suppliers should be able to recognize a product’s development through its documentation and trace its design, risk assessment, hazard analysis and testing decisions back to its conception.”

ISO 10377 is “aimed at small and medium sized enterprises (SMEs) as well as larger firms and offers risk assessment and management techniques for safer consumer products. This standard will allow retailers and OEMs to trace every part and component of a product through the supply chain to determine exactly where a defect or a counterfeit has occurred.” The standard is divided into four main sections outlining general principles that promote a product safety culture in a company, safety in design, safety in production and safety in the retail marketplace.

Either Mr. Uke’s “Transparent Label” or the label required by ISO 10377 would satisfy both reasons for wanting to know where products are manufactured. This type of label would provide protection for consumers from unsafe, defective, toxic, and counterfeit products and would help us to recognize the main cause of the loss of manufacturing jobs in the United States. We need to face up to the true cause of the loss of manufacturing jobs before we can get any consensus of what to do about it by means of our national policies. We need to oppose reclassifying “wholesale traders” as domestic manufacturers and support “country of origin” labeling by contacting our Congressional representatives.

 

 

 

 

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