NOTICES
INDEPENDENT REGULATORY REVIEW COMMISSION
Notice of Comments Issued
[29 Pa.B. 3135] Section 5(g) of the Regulatory Review Act (71 P. S. § 745.5(g)) (act) provides that the designated standing committees may issue comments within 20 days of the close of the public comment period, and the Independent Regulatory Review Commission (Commission) may issue comments within 10 days of the close of the committee comment period. The Commission comments are based upon the criteria contained in section 5a(h) and (i) of the act (75 P. S. § 745.5a(h) and (i)).
The Commission has issued comments on the following proposed regulations. The agency must consider these comments in preparing the final-form regulations. The final-form regulations must be submitted by the dates indicated.
Final-Form Reg Submission No. Agency/Title Issued Deadline 30-51 Pennsylvania Emergency
Management Agency
Public Safety Emergency
Telephone Program6/3/99 5/3/01 29 Pa.B. 1719 (April 3, 1999) 30-52 Pennsylvania Emergency
Management Agency
Training and Certification
Standards for 9-1-1
Emergency Communications Personnel6/3/99 5/3/01 29 Pa.B. 1721 (April 3, 1999) 30-53 Pennsylvania Emergency
Management Agency
9-1-1 Performance Review
and Quality Assurance
Standards6/3/99 5/3/01 29 Pa.B. 1717 (April 3, 1999)
Pennsylvania Emergency Management Agency Regulation No. 30-51
Public Safety Emergency Telephone Program
June 3, 1999We have reviewed these proposed regulations from the Pennsylvania Emergency Management Agency (PEMA) and submit for consideration the following objections and recommendations. Subsections 5.1(h) and (i) of the Regulatory Review Act (71 P. S. §§ 745.5a(h) and (i)) specify the criteria the Commission must employ to determine whether a regulation is in the public interest. In applying these criteria, our Comments address issues that relate to fiscal impact, reasonableness and clarity. We recommend that these Comments be carefully considered as you prepare the final-form regulations.
1. Section 120b.104. Technical standards for plans--Consistency and Clarity.
The existing language of § 120b.104(b)(2)(xviii) reads as follows:
The 9-1-1 operators, dispatch personnel and supervisors shall receive a minimum of 40 hours classroom and hands on instruction. The APCO [Associated Public Safety Communicate Officers, Inc.] training course or a similar course that is used is subject to Council approval. In addition to minimum training requirements, a county may require additional training at its discretion.The 40-hour minimum classroom and hands on instruction is inconsistent with the training requirements in proposed Regulation #30-52. The current language of this subsection should be deleted and replaced with a reference to training requirements in Chapter 120c, which is in proposed Regulation #30-52.
2. Section 120b.106. Eligible costs--Consistency and Clarity.
Consistent with Act 17 of 1998, the proposed regulations adds training directly related to the provision of 9-1-1 services to the list of eligible recurring costs in § 120b.106(b)(2)(vii). Counties may use funds generated by contribution rates assessed by means of Act 17 to pay for training. However, existing language in § 120b.106(c)(5) identifies ''recruitment and training of dispatchers, call takers or telecommunication officers or operators'' as an ineligible cost for which funds from the contribution rate cannot be used. To be consistent with Act 17, PEMA should delete the words ''and training'' from § 120b.106(c)(5) in the final-form regulations.
3. Section 120b.113. Accuracy standards for 9-1-1 database systems--Reasonableness and Clarity.
PEMA needs to clarify that this section applies to enhanced 9-1-1 centers.
Subsection (b) requires the local exchange carrier (LEC) and the county to perform a database validation every 6 months. Commentators expressed concern with the reasonableness of requiring validation every 6 months and questioned the feasibility of this requirement. PEMA should justify why a 6-month interval for validation is both appropriate and practical.
Commentators have also questioned the feasibility of the minimum 95% requirement in subsection (b)(1). If they have to wait for LECs to reach 95% accuracy on their databases, some county 9-1-1 center may never receive the required data. PEMA should explain the need for and feasibility of the 95% rule.
In subsection (b)(2), the phrase ''the use of'' after the first comma is unnecessary and should be deleted.
Subsection (b)(3) provides the following:
Thereafter, additional validation processes shall be implemented by a county and the LEC or LECs to eliminate, insofar as possible, any substantive mismatches between the county's MSAG and the LEC's customer database.This subsection is confusing for two reasons. First, it is not clear what time reference is meant by ''Thereafter.'' PEMA should use a specific time reference in place of ''thereafter'' to describe when additional validation processes should be implemented.
Second, it is not clear what is meant by ''additional validation processes.'' Does this mean a different technology must be used to validate information or a different method for validation? PEMA should clarify its intent on what it means by additional validation processes.
Pennsylvania Emergency Management Agency Regulation No. 30-52
Training and Certification Standards for 9-1-1 Emergency Communications Personnel
June 3, 1999We have reviewed these proposed regulations from the Pennsylvania Emergency Management Agency (PEMA) and submit for consideration the following objections and recommendations. Subsections 5.1(h) and (i) of the Regulatory Review Act (71 P. S. §§ 745.5a(h) and (i)) specify the criteria the Commission must employ to determine whether a regulation is in the public interest. In applying these criteria, our Comments address issues that relate to consistency, statutory authority implementation procedures, reasonableness, need and clarity. We recommend that these Comments be carefully considered as you prepare the final-form regulations.
1. Section 120c.101. Purpose and definitions--Consistency, Need and Clarity.
Section 120c.101(a) describes the purpose of these proposed regulations ''to implement section 3(a)(6)'' of the Public Safety Emergency Telephone Act (Act 17). The subsection's single sentence also states that section 3(a)(6) of Act 17 ''was added by section 3(a)(6) of the act of February 12, 1998 (P. L. 64, No. 17) to provide for the training and certification of call takers, emergency dispatchers and supervisors who work for 9-1-1 emergency communications centers in this Commonwealth.''
The subsection is lengthy and inconsistent with Act 17. First, it is not necessary to include a detailed reference to Act 17. The citation for Act 17 in the proposed regulations' definition of the term ''act'' is sufficient. The date and pamphlet citation should be deleted from § 120c.101(a).
Second, the subsection does not match the actual statutory language of section 3(a)(6) of Act 17. This statute gives PEMA the power and duty ''to establish minimum training and certification standards for emergency dispatchers, call takers and supervisors.'' § 120c.101(a) should simply state that the purpose of these proposed regulations is to establish minimum standards for the training and certification of 9-1-1 personnel.
2. Sections 120c.102--120c.104. Call taker; emergency dispatcher; and 9-1-1 center supervisor certification--Consistency, Implementation Procedures, Reasonableness, Need and Clarity.
Sections 120c.102, 120c.103 and 120c.104 set forth certification, training and examination procedures and requirements for the positions of call taker, emergency dispatcher and 9-1-1 center supervisor respectively. The structure and content of these three sections are very similar. County 9-1-1 centers and other commentators have expressed concern and raised questions related to features that appear in all three sections. Because the subsections of §§ 120c.102, 120c.103 and 120c.104 are comparable, the following paragraphs discuss issues related to specific subsections and provisions in all three sections.
Subsection (b)(1)(i) Certification--Application forms
Subsection (b)(1)(i) of §§ 120c.102, 120c.103 and 120c.104 requires an applicant for certification to complete ''an application on a form prescribed by the Agency [PEMA].'' However, the regulation do not inform potential applicants how to obtain the appropriate forms. Sections 120c.102--120c.104 should contain this information.
Subsection (b)(1)(ii) Certification--Minimum age requirements
In §§ 120c.102, 120c.103 and 120c.104, subsection (b)(1)(ii) contains a minimum age requirement for each of the three positions. Why is this provision necessary? This regulation should provide the counties and local entities with sufficient latitude to hire people with the ability to do the job. PEMA should explain the need for and purpose of the minimum age requirements.
Subsections 120c.102(b)(1)(iii), 120c.103(b)(1)(iv) and 120c.102(b)(1)(v) Certification--Training requirement
These subsections require that applicants complete training courses approved or prescribed by PEMA to qualify for certification. However, neither these subsections nor any other part of this regulation contain any information concerning the content or length of these courses. In another chapter, existing language at § 120b.104(b)(2)(xviii) requires that 9-1-1 personnel ''receive a minimum of 40 hours classroom and hands on instruction.''
The details of the minimum standards for training should be set forth in this regulation. Counties and applicants for certification as 9-1-1 personnel, as well as the public at large, should be provided an opportunity to review the minimum training requirements for 9-1-1 staff. PEMA should establish the minimum number of hours and subject areas required of call takers, emergency dispatchers and 9-1-1 center supervisors in this regulation.
Concerning subject areas for training, the Pennsylvania Chapter of the American College of Emergency Physicians recommended that 9-1-1 staff receive training in emergency medical dispatch (EMD) standards. Training in EMD standards includes medical call-taking, triage and dispatch of resources, and pre-arrival patient care instruction. PEMA staff indicated that EMD standards would be a part of an approved training program. If so, this core requirement should be listed in this regulation.
Subsections 120c.102(b)(1)(iv), 120c.103(b)(1)(v) and 120c.102(b)(1)(v) Certification--Written examination
These subsections require the applicant to pass a written examination prescribed by PEMA. However, there is no indication who will administer the examinations, when they will be available or the examination's content or length. If PEMA plans to develop, administer and grade the examinations, then the regulation should articulate this plan. It should also indicate when and where applicants can take the examinations.
Subsections 120c.102(b)(1)(v), 120c.103(b)(1)(vi) and 120c.102(b)(1)(vi) Certification--Practical test
These subsections state that the applicant must pass a practical test related to the respective position skill requirements. The tests will be prescribed by PEMA. As indicated above with written examinations, PEMA should set forth minimum standards and requirements outlining the content, length and administration of these tests in the regulation.
Subsection (c) Recertification
Recertification is required every 3 years for call takers and emergency dispatchers, and every 4 years for 9-1-1 center supervisors. Each applicant for recertification is required to pass a written examination prescribed by PEMA. In addition, call takers and emergency dispatchers are required by § 120c.106 to complete refresher training. Commentators questioned the need for both recertification examinations and continuing education through refresher training.
PEMA should explain the need for both refresher training and recertification examinations. If a certified employee has worked in the 9-1-1 system for 3 years and has fulfilled the refresher training requirements, why does he or she need to pass another examination? The licensure boards for several professions in health care and other occupations have continuing education requirements. For many of these licensure boards, documentation of continuing education is the only requirement for licensure renewal.
If an employee has not worked in the 9-1-1 system for an extended period, an examination for recertification may be more appropriate. If PEMA opts to require recertification of former 9-1-1 system employees, it should quantify the length of absence that would trigger the recertification requirement in this regulation. This subsection should also include information concerning the recertification examination's contents, administration and availability.
Missing ''grandfather'' provision--Testing and training of current personnel
A few commentators expressed concern with imposition of the new training requirements on current employees. Many 9-1-1 centers already have training programs in place. Many of these programs go beyond the minimum standards that PEMA is contemplating. In addition, these existing training programs include courses approved by the National Emergency Numbers Association and other professional organizations with training standards that are identical or comparable to those PEMA plans to use.
Commentators stated that there is no need to compel current employees to enroll in duplicative courses of instruction. We agree. One resolution of this concern is to allow current employees to take the PEMA examinations without additional training. PEMA indicated that it was considering this approach. However, there is nothing in the regulation that provides an exception for current employees.
Will PEMA allow current employees to document previous training experience? If so, the regulation should require current employees to document their training experiences. After PEMA determines that current employees' previous training meets or exceeds its standards, these employees should be allowed to qualify for certification just by passing the examination without having to complete additional or duplicative training courses.
3. Section 120c.105. Certification curriculum and instructors--Reasonableness and Clarity.
This section states that PEMA ''will review and approve certification curriculums, materials, schedules, examinations, fees, recordkeeping and other related matters that are necessary to implement the certification standards.'' In addition, the section states that PEMA will approve instructors. As stated earlier, several counties already have comprehensive training programs in place for their 9-1-1 personnel. Because the regulation do not provide what PEMA's requirements will be, these counties indicate that they are uncertain whether their training programs will meet PEMA's standards.
It is our understanding that PEMA will allow counties to continue to run their own training programs. If this is true, the regulation should set forth the details of an application process whereby counties may submit information on their training programs and instructors for review and approval by PEMA. This is another reason why this regulation should include information on the minimum hour and course content requirements for training courses. Without specific standards, counties cannot determine whether their training courses will meet PEMA's standards.
4. Section 120c.106. Refresher training--Clarity.
This section states that call takers and dispatchers will receive ''annual refresher training of sufficient content and duration to maintain their competencies.'' As stated earlier, the regulation should specifically state the minimum number of hours to be required for continuing education. It should also indicate the subject areas that qualify as continuing education or establish a process whereby counties, training providers or 9-1-1 personnel can submit continuing education proposals to PEMA for review and approval.
5. Certification, Training, Recertification and Refresher training--Fiscal Impact and Clarity.
The actual costs of implementing this regulation are uncertain. In the Regulatory Analysis Form for this regulation, PEMA indicates that the costs of this regulation should be minimal. Many counties have training programs in place and PEMA plans to require that these programs comply with its minimum standards. Because the regulation does not contain PEMA's minimum standards, no one can ascertain whether the costs will be minimal. Hence, the fiscal impact of this regulation is unclear. This concern applies to training costs as well as the additional costs for examinations, refresher training and recertification outlined in the regulation. The cost is a significant unknown amount for counties that do not already have training programs.
Act 17 identifies training expenses as eligible expenditures for funding by means of the 9-1-1 fees. However, revenues from 9-1-1 fees generated by the statutory contribution rates are a limited resource. PEMA should establish the minimum standards and estimate the potential economic impact of mandating compliance with its standards.
6. Section 120c.108. Right to enter and inspect--Reasonableness and Clarity.
This section states that PEMA has the right to enter any 9-1-1 center during regular and usual business hours to inspect employment records, county plans, protocols and equipment. It also states that PEMA reserves the right to enter at other times upon any complaint or PEMA's reasonable belief that violations of this regulation or Chapter 120b exist. The question arises as to what PEMA would or could do if it found a problem. Act 17, existing regulations and this proposed regulation do not provide penalties for violations. PEMA's enforcement role in the 9-1-1 system is unclear. PEMA should explain its intent for this provision and its role in working with 9-1-1 centers, counties and local governments to advance the 9-1-1 systems.
7. Training and certification standards and remote dispatch points--Statutory Authority, Fiscal Impact, Implementation Procedure and Clarity.
A commentator questioned whether this regulation will apply to the staffs of remote dispatch points (RDPs). RDPs include local police units, private ambulance services or local fire companies. PEMA staff stated that RDPs will be expected to comply with this regulation because they are part of the 9-1-1 system. However, they indicated that they may need to amend the regulation to include RDP personnel.
RDPs and 9-1-1 centers have a vital relationship. Calls to a 9-1-1 center for emergency assistance can be transferred to RDPs where a dispatcher determines the appropriate response and dispatches equipment and personnel. Dispatchers at RDPs are not necessarily employees of a 9-1-1 center. It is unclear whether the certification and training requirements and other provisions of this regulation apply to dispatchers or other personnel at RDPs.
Act 17 gives PEMA broad authority and discretion in the development and operation of the 9-1-1 system. Section 2 of Act 17 (35 P. S. § 7012) contains definitions for ''911 emergency communication system'' or ''911 system'' and ''public safety answering point.'' However, the words ''remote dispatch point'' do not appear in Act 17. PEMA's goal is to improve 9-1-1 systems and the response of police, fire, ambulance and medical services to emergencies. This goal is understandable and worthwhile. Nonetheless, PEMA should explain its statutory authority to require certification and training of dispatchers and other personnel at RDPs.
Comments from the Pennsylvania State Association of Township Supervisors dated May 28, 1999, and the Berks County Communication Center also raise a number of other important questions concerning the application of this regulation to RDPs. Will the provision concerning PEMA's inspections of 9-1-1 centers apply to RDPs? How will RDP staffs pay for training? RDPs training may be eligible for funding by means of the county 9-1-1 plans but only at the discretion of the counties. How many RDPs are currently included in county 9-1-1 plans?
PEMA should review these questions and explain its positions for inclusion with the final-form regulations. Including representatives of local governments and RDPs in the discussions along with 9-1-1 centers would probably improve the final-form regulations.
Pennsylvania Emergency Management Agency Regulation No. 30-53
9-1-1 Performance Review and Quality Assurance Standards
June 3, 1999 We have reviewed these proposed regulations from the Pennsylvania Emergency Management Agency (PEMA) and submit for consideration the following objections and recommendations. Subsections 5.1(h) and (i) of the Regulatory Review Act (71 P. S. §§ 745.5a(h) and (i)) specify the criteria the Commission must employ to determine whether a regulation is in the public interest. In applying these criteria, our Comments address issues that relate to statutory authority, fiscal impact, reasonableness and clarity. We recommend that these Comments be carefully considered as you prepare the final-form regulations.
1. Section120d.104. Standards and procedures for performance review--Fiscal Impact, Reasonableness and Clarity.
Quality assurance review
In § 120d.102, the term ''quality assurance review'' is defined. However, PEMA uses the term ''audit'' when referencing a quality assurance review in § 120d.104. For consistency and clarity, the term ''quality assurance review'' should be used in place of ''audit.''
The use of the word ''standard'' in the title of this section is unclear. This section does not indicate what standards or performance criteria are to be used in the quality assurance reviews. The regulation should include specific performance criteria that the quality assurance reviewer will use when examining other employees' work. If the reviewer is to use the criteria or standards in § 120d.105, then § 120d.104 should reference § 120d.105.
Content requirements or recommendations for quality assurance reviews
The last sentence in subsection (a) provides, ''It is also recommended that all incidents involving catastrophic loss be included in the review process.'' The phrase ''It is also recommended'' is inappropriate regulatory language because it does not convey a definitive standard. If incidents related to catastrophic loss will be required to be part of the review, this phrase should be removed from the regulation. If it will not be a requirement, the whole sentence should be deleted.
Dispatching
Subsection (b) requires dispatching the appropriate police, fire or emergency medical services within the prescribed time frame (usually within 90 seconds of obtaining pertinent information, 90% of the time). This provision, for several reasons, is problematic as to how it will be used for the quality assurance review.
First, the phrase ''usually within 90 seconds'' is not a definitive standard. PEMA should delete the term ''usually.''
Second, it is not clear what the prescribed time frame is for dispatching the appropriate personnel. Will it be 90 seconds or will it be another time frame? The regulation should clearly define the standard.
Finally, the City of Philadelphia observed, when the volume of calls dictates, they dispatch personnel on a priority basis. If dispatching calls on a priority basis is appropriate, PEMA should amend the regulation to allow such flexibility.
Frequency of call taking audits
Subsection (b) begins by requiring call taking audits to be completed weekly. The subsection later provides that ''Although it is recommended that audits be performed on a weekly basis, the quality assurance review process may assume a monthly configuration to accommodate 9-1-1 centers that have personnel or scheduling constraints.'' The language ''Although it is recommended'' is inappropriate and creates confusion as to whether call taking audits should be done weekly. If PEMA is intending to establish an exception to the weekly call taking audit requirement, it should expressly state when the exception will be applicable.
Quality assurance reviewer
Subsection (d) requires the director of each 9-1-1 center to create a quality assurance reviewer position. The quality assurance reviewer is a full-time position and depending upon the size of a 9-1-1 center, there may be more than one at each facility. PEMA did not identify the potential economic impact/cost of mandating this new full-time position or how the establishment of this position is the most cost-effective measure to ensure quality assurance. PEMA should conduct this analysis to ensure the creation and use of a quality assurance reviewer is cost effective.
The second sentence in subsection (d) provides that ''It is recommended that the reviewer be a supervisory level with a minimum of 3 years experience in the field of emergency telecommunications.'' Again, the phrase ''It is recommended'' does not convey a definitive standard. The regulation should specify the minimum qualifications for a quality assurance reviewer.
Retention of audit reviews
Subsection (e) requires audit reviews to be kept for 3 years at the 9-1-1 center. Commentators expressed concern that recorded 9-1-1 calls will be included as part of the audit review and thus subject to Pennsylvania's Right To Know Law. PEMA's proposed Regulation #30-51 includes a new § 120b.103(11). The new subsection states that a county plan will be considered a public record under the provisions of the act known as the Right to Know Law (65 P. S. §§ 66.1--66.4).
Commentators express concern that recorded 9-1-1 calls may be included in audits conducted for performance reviews. The commentators believe that the audits may be included in the plan, resulting in the recorded 9-1-1 calls becoming part of a public record.
It is our understanding that PEMA does not intend to require recorded phone calls to be part of the audit review. In addition, the Pennsylvania Supreme Court issued a decision on this issue earlier this year. In North Hills News Record v. Town of McCandless, 722 A.2nd 1037 (1998), the Supreme Court ruled that tapes of 9-1-1 calls are not public records under the provisions of the Right to Know Law. To insure consistency with this recent ruling of the Supreme Court, PEMA should state that transcripts or recordings of 9-1-1 calls are not public records under the Right to Know Law.
We also question the need for the 9-1-1 center to retain the audits for 3 years. PEMA should provide justification for this retention period or reduce it.
Quality assurance actions
Subsection (h) provides that quality assurance actions that are initiated in response to the results of an audit review will be documented and included as part of the audit. PEMA should define what ''quality assurance actions'' are, who is responsible for initiating the actions, and when the actions will be imposed.
2. Section 120d.105. Types of quality assurance reviews--Statutory Authority and Clarity.
Call taker performance review
Subsection (a)(8) requires the quality assurance reviewer to consider the professional demeanor of the call taker. The term ''professional demeanor'' lacks objectivity. Other standards listed in this subsection are also very subjective and provide a reviewer with a great deal of discretion in evaluating performance. PEMA should consider including more objective criteria to be used by the quality assurance reviewer to determine if the call taker is acting in a professional manner. This comment also applies to subsection (b)(8) for dispatchers.
Federal Communication Commission rules
Subsection (b)(8) provides that the telecommunicator shall abide by applicable Federal Communications Commission (FCC) rules and regulations. Instead of the general reference, specific citations to FCC regulations should be included.
Emergency medical dispatch program
Subsection (c) requires the Department of Health to approve the emergency medical dispatch program as a requisite to its use by the 9-1-1 emergency communications center. There is no current requirement for the Department of Health to review this program. Furthermore, PEMA lacks the authority to impose such a mandate on another administrative agency. Accordingly, this provision should be deleted.
PEMA itself has the authority to approve medical dispatch programs for 9-1-1 centers. If it decides that standards are needed, it can develop its own or can reference standards developed or approved by organizations with the appropriate expertise or qualifications.
3. Quality assurance reviews and remote dispatch points--Statutory Authority, Fiscal Impact, Implementation Procedures and Clarity.
A commentator questioned whether this regulation will apply to the staffs of remote dispatch points (RDPs). RDPs include local police units, private ambulance services or local fire companies. PEMA staff stated that RDPs will be expected to comply with this regulation because they are part of the 9-1-1 system. However, they indicated that they may need to amend the regulation to include RDP personnel.
RDPs and 9-1-1 centers have a vital relationship. Calls to a 9-1-1 center for emergency assistance can be transferred to RDPs where a dispatcher determines the appropriate response and dispatches equipment and personnel. Dispatchers at RDPs are not necessarily employees of a 9-1-1 center. The relationship between 9-1-1 centers' quality assurance review programs and RDP employees is unclear.
Act 17 gives PEMA broad authority and discretion in the development and operation of the 9-1-1 system. Section 2 of Act 17 (35 P. S. § 7012) contains definitions for ''911 emergency communication system'' or ''911 system'' and ''public safety answering point.'' However, the words ''remote dispatch point'' do not appear in Act 17. PEMA's goal is to improve 9-1-1 systems and the response of police, fire, ambulance and medical services to emergencies. This goal is understandable and worthwhile. However, PEMA should explain its statutory authority in implementing quality assurance standards for RDP employees who are not employed by 9-1-1 centers and are not included in county 9-1-1 plans.
Comments from the Pennsylvania State Association of Township Supervisors dated May 28, 1999, and the Berks County Communication Center also raise a number of other important questions concerning the application of this regulation to RDPs. What is the responsibility of 9-1-1 centers in auditing or performing quality assurance reviews of RDPs employees' performance? Will 9-1-1 center quality assurance reviewers have access to tape recordings of RDPs' calls and dispatches? RDPs may be eligible for funding by means of the county 9-1-1 plans but only at the discretion of the counties. How many RDPs are currently included in county 9-1-1 plans?
PEMA should review these questions and explain its positions for inclusion with the final-form regulations. Including representatives of local governments and RDPs in the discussion along with 911 centers would probably improve the final-form regulations.
JOHN R. MCGINLEY, Jr.,
Chairperson
[Pa.B. Doc. No. 99-982. Filed for public inspection June 18, 1999, 9:00 a.m.]
No part of the information on this site may be reproduced for profit or sold for profit.This material has been drawn directly from the official Pennsylvania Bulletin full text database. Due to the limitations of HTML or differences in display capabilities of different browsers, this version may differ slightly from the official printed version.
