SFAIRP vs ALARP

Risk! Engineers Talk Governance
Episode 1, Season 1

In this episode of the podcast Risk! Engineers talk Governance, due diligence engineers Gaye Francis and Richard Robinson discuss the difference between SFAIRP & ALARP.

ALARP versus SFAIRP is still creating a lot of confusion within the risk industry and organisations, this discussion clarifies the difference and why organisations must work towards SFAIRP.

...the Act actually goes to some trouble and the precursor tool is the Victorian OHS Act 2004 has it in there… a particular clause or section that says you must achieve the highest level of precaution as is reasonably practicable.  So whilst it doesn't define SFAIRP, it does define reasonably practical. And then another portion of the Act says you've gotta achieve the highest level that you can and that's what the SFAIRP principle's all about.

Read the full transcript below.

Transcript

Megan (Producer) (00:02):

Hi & welcome to Risk! Engineers Talk Governance. My name's Megan and I work behind the scenes on the podcast, but also with hosts Richard Robinson and Gaye Francis on their businesses. R2A Due Diligence Engineers and also Apto PPE Women's and Maternity Workwear.Please enjoy this first episode of season one of the podcast, Richard and Gaye talk about SFAIRP and the difference between it and ALARP.If you enjoy the episode, please subscribe so you don't miss future episodes. Also, help us out and give us a rating if you do enjoy it so we can help other people find the podcast on this topic.The podcast is available on all podcast platforms. Please enjoy this episode and if you have any questions or any ideas or feedback, please let us know. Enjoy.

Gaye Francis (01:23):

I'm Gaye Francis, and with me today is Richard Robinson. We are both directors at R2A and today's topic is ALARP versus SFAIRP. I feel like we've talked about this a number of times, Richard, but welcome.

Richard Robinson (01:30):

And we've talked about for ever Gaye and welcome. And welcome Megan, who is our producer sitting in the sun over there and quite enjoying herself.

Gaye Francis (01:31):

On a beautiful Melbourne Autumn day. So I guess, where do we start for ALARP versus SFAIRP? There's so many conversations and people that say that there's no difference between the two.

Richard Robinson (01:43):

Well, interesting enough, and probably this might be the way to introduce it... I was giving a briefing on behalf of Rio Tinto for that national tailings dam conference, and they had a, he'd have to have been a criminal lawyer, giving advice. And one of the things he pointed out, because all the engineers were carefully saying, well, look, we're not lawyers - we don't interpret the legislation. But one of the things this lawyer pointed out was that so far as reasonably practical (SFAIRP) isn't defined in the WHS legislation, but reasonably practicable is. And we've been thinking about this for some time because obviously the legislation says you should eliminate hazards so far as reasonably practicable. And if you can't eliminate, (you) should reduce them so far as reasonably practice, which is the SFAIRP part. But if the legislation doesn't define SFAIRP, can you actually use the term?Now what we sort of realised was there's another aspect to the Act and the Act actually goes to some trouble

(02:34):

...and the precursor tool is the Victorian OHS Act 2004 has it in there even though we haven't adopted WHS legislation in Victoria. But this element is a particular clause or section that says you must achieve the highest level of precaution as is reasonably practicable.So whilst it doesn't define SFAIRP, it does define reasonably practical. And then another portion of the Act says you've gotta achieve the highest level that you can and that's what the SFAIRP principle's all about.So far as we can tell, the Act actually does (define SFAIRP), and I'd be particularly interested to see if there's any lawyers out there who could actually have an opinion about this because I think this is actually really quite important.

Gaye Francis (03:18):

So it really sets out what the intent of the legislation is and what the principle of SFAIRP is, rather than putting in the black letter of the law sort of stuff.

Richard Robinson (03:19):

Yes, that's correct. And the way legislation works, if you do get a case, the first thing the lawyers do is say go through the legislation and say what did the legislators intend? What did the parliaments intend when they put that clause in? And you're not always (or) all together clear. And when you listen to the lawyers and the judgements and so forth, they're basically interpreting the words from parliament. Now, again, it's a bit hard to know what parliament actually intended, but we've always assumed that it came from the common law. That's what Michael Toma says in his books, which we're willing to go with. And he's, uh, something of the guru in WHS legislation. And if it's coming from the common law, then it's coming from Lord Atkin, the Brisbane born English law lord from 1932 and Donahue versus Stevenson.

Gaye Francis (04:02):

Which is all about due diligence.

Richard Robinson (05:01):

It's all about due diligence and it was all about the principal reciprocity.I think I mentioned to you, I just found fairly recently an article by a Canadian law professor, which was a bit of a surprise to me cause I forget why I was tracking through looking for something, because I'd come to the view that Atkin was actually talking about the parable of Good Samaritan when he asked the question and who, in law, is your neighbour?And I didn't realise this, but the, well, certainly the high court judges or the House of Lords in the UK when they're doing a judgment, they actually write notes out, in case, I guess, one of them gets sick and another judge has to take over for some reason they've got this case study of what they've done and how they've done it and what they've discovered, and all these sorts of things. And this Canadian law professor's going through Atkins notes about this particular case. And he is absolutely crystal clear. He was given the reading on the Parable of the Good Samaritan. And quite literally that was why he concluded in the formulation of his neighbor principal.

Gaye Francis (05:03):

So the intent was clear.

Richard Robinson (05:38):

The intent was clear and the way he said it was clear.How did he put it? "The rule that you ought to love your neighbor becomes a law, you must not injure your neighbor". And the lawyers' question, "who is my neighbor?", that's the lawyers' question that's asked in the 2000 year old question. These lawyers have always been with us. You know, we're not gonna escape them in our lifetime. The lawyers' question, who's my neighbor receives a restricted reply. And the restricted reply is along the lines that you must take reasonable care to affect anybody you know, knowingly or unknowingly, that you should have thought about. And that's what the Parable of Good Samaritan's actually about. So it's just a principle that shows up everywhere.

Gaye Francis (05:43):

So we've gone sort of a little bit off tangent just a little bit, but that's not unlike us, Richard!So if we go back to SFAIRP versus ALARP, there is clearly a difference. And they're defined by different people.

Richard Robinson (05:59):

Well, Andrew Hopkins from ANU, he basically goes on about it to some length too. Uh, I didn't realize he's now an emeritus professor and according Ravi Nijjer, he's actually in high demand overseas at speaking engagements making the same point that there's no nothing in law, the ALARP principle just doesn't exist. And your duty's to achieve the highest level you reasonably can.

Gaye Francis (06:23):

So ALARPs been used in the risk business for a long time now, 30 years plus. And it really just talks about the hazard doesn't it; the level of hazard, the level of risk.

Richard Robinson (06:35):

And...

Gaye Francis (06:37):

Is it acceptable or tolerable; it's measurable in some way. And as we've said many, many times, it's a human construct of what people think the likelihood of those things are.

Richard Robinson (06:51):

Well, I think it goes a bit further. I think what they were trying to do, and I've gotta say a hidden history, I was probably guilty of this too, but what they were trying to do was make it a scientific concept, you know, the laws of nature so that there was something you could physically measure. But has been pointed out by lots of people, one of my former partners, Derek Viner, pointed it out too. You send two risk experts out there to go and assess the risk associated with a circumstance or situation. If it was truly a scientific concept, they'd all come up with the same answer.

Gaye Francis (07:17):

They do not.

Richard Robinson (07:19):

They never do. Unless you use an identical process, in which case you've just done the same thing twice. And everybody would know that because when you're sitting around a risk workshop doing risk assessments, nobody agrees.

Gaye Francis (07:49):

No, it's very, very hard to get consensus from the group. Everyone has a different perspective on what that is, especially when you're talking about what the likelihood is. So, I mean, for us, the SFAIRP principle is all about the precaution, the level of controls, the level of precautions and mitigations that are in place. So it's all about what needs to be done to manage the particular hazard rather than the level of risk.

Richard Robinson (07:52):

Correct. And the legislation's quite clear. You've gotta achieve the highest level of control you can.

Gaye Francis (07:59):

So for us, there is a clear difference. And I think some of the confusion comes out in that people are trying to define ALARP and define SFAIRP in a way that sort of matches their processes.

Richard Robinson (08:14):

Well, frustration of all this all came around because of the tolerability risk study by was it to Frank Layfield, I think it was, in the UK. And he tried to make risk into a scientific concept, and that was because he was listening to scientists, rather than talking to engineers, I think.Because the engineers always tried to meld the two. The scientists look at the laws of nature. The lawyers look at the laws of man. But the people who live in the sandwich in the middle are always the engineers. And I, for some reason, haven't quite understood, that engineers don't quite understand that they're the meat in the sandwich.

Gaye Francis (08:48):

They've gotta make it all work.

Richard Robinson (08:49):

We've gotta make it all work. And the problem with being an engineer is you're attached to the laws of nature.I mean, if you just talk about a financial problem, you can always argue about it in court after the event, whether you were reasonable or not. Because you haven't killed or maimed anybody. You might have damaged them commercially, but it wasn't a death matter. Whereas when you're dealing with a structure or a fire that failed to be controlled or something like that, people die. So you've gotta manage the laws of nature and get it right. Nobody's gonna forgive you for it if you get it wrong.I mean one of the things that really put me off, I think I just mentioned to you, I was, for some reason looking up the Registration of Engineers in Victoria and the person who signs off on the Code of Ethics and the interpretation of the Code of Ethics that they were opposing on registered engineers in Victoria.

(09:31):

The first point it says it is know the law. And then it goes on to speak about the Wrongs Act. Now I learned about the Wrongs Act 30 years ago when I was doing some expert witness thing. And a lawyer mentioned it to me, I didn't know anything about it. Anyway, it contains a thing called the Occupiers Liability Act, which shows the duty of care you have towards somebody who comes into your premises like a shopping center or something like that. And it's the common law duty of care. And it actually lists the principles that defined in pretty much the WHS legislation what constitutes reasonable practicability. It lists consequence, likelihood, and all these other factors. You know, it's a degree which you've got control and so forth.Now I've always quoted the Occupiers Liability Act and the consolidated version of the Wrongs Act.

(10:11):

In all the cases you would recall that I've done this. And you used to look at me and say, "Why is Richard including that?" And the answer was because the lawyers told me to. Um, and yet this lawyer is saying the first principal, the Code of Ethics is know the law. You can already see that somebody who spent a fair bit of time fiddling around with getting advice from lawyers. The legal opinion you're getting varies quite substantially. How on earth are the engineers meant to know about all this legal stuff? And yet that's the first duty as a registered engineer in Victoria. That is a stupendous. Let alone all the technical standards and things like that, that you have to consider.

Gaye Francis (10:47):

I think they're trying to make it so complicated with that sort of stuff. I mean, for us, SFAIRP is a governance principle in that it wants everybody that has the ability to control the hazard to work together to get the highest level of protection. I, for me, it's just some of the legislation and the standards and all of that stuff around it, which we will cover in another podcast, I'm sure...

(11:13):

They're trying to make it so complex. But if you look at it from a top-down governance viewpoint, it's about getting all of the parties in the room, all of the key stakeholders in the room that has the ability to control this hazard to agree on what the highest level of precaution is. It's not allocating blame somewhere that it's a single person's responsibility. It's everybody's responsibility.

Richard Robinson (11:37):

Well, it actually knocks the issue of a confident person around a bit, which has been a particular popular thing to put in legislation because if you need the collective wisdom rather than just one person signing off, how do you do it? And as that Professor Sidney Dekker points out from Brisbane University, he's an airline pilot turned psychologist, there are so many rules out there now and that's one of the problems with standards. I mean, there's so many, so much stuff out there. It is not possible one person to know at all anymore. It just isn't possible. And the problem with that is if you're coming bottom up and you're expected to know it all, well you can't. And that's the same thing with that first question, the regulator on the Code of Ethics Victoria or Code of Practice for registration of engineers; it is not possible for an engineer to know all the law that this, obviously lawyer, was speaking to.

Gaye Francis (12:25):

So I mean, from our viewpoint, there is a difference between ALARP and SFAIRP. ALARP is hazard focus and if you've seen any of our presentations we go through that in quite a bit of detail of why that's the case. And the SFAIRP principle is really about looking at the controls that can be put in place to make sure that the hazards are managed appropriately.

Richard Robinson (12:46):

It's all about the controls. And that was the other point. Remember how we demonstrate that we like single-line line threat barrier diagrams as a way to construct an argument that'll go from the workers and the people actually doing things, to the board and all the lawyers, and everybody else in between that gets hold of things. But one of the things we do with our threat barrier diagrams now is we put in precautions that are the responsibility of others in a different color so that you can see that the sequence of control is going through the hierarchy. The hierarchy in the legislation is eliminate and then reduce. And the hierarchy in the common law is eliminate, prevent and then mitigate. And most of the regulators are completely confused cause they've got four or more, generally up to six, which just leaves everybody in a state of confusion.

Gaye Francis (13:31):

It does.

(13:35):

So that brings us to the end of our podcast for today. If you'd like any more information about ALARP versus SFAIRP, we do cover it in our Criminal Manslaughter booklet, which is available on our website (www.r2a.com.au). Thank you for joining us and we hope you can join us next time.

Richard Robinson (13:53):

Thanks Gaye. Thanks Megan.

Introducing Risk! Engineers Talk Governance

Risk Engineers Talk GOvernance
Special episode

In this special introduction episode of Risk! Engineers Talk Governance, meet your hosts Gaye Francis and Richard Robinson who outline their due diligence engineering experience and why they are starting the podcast .

Transcript

Gaye Francis (00:00):

Good morning and welcome to our podcast Risk! Engineers Talk Governance. I'm Gaye Francis and Richard Robinson's here and is my business partner.

(00:09):

How you going this morning, Richard?

Richard Robinson (00:10):

I'm particularly well Gaye, although it is a bit chilly.

Gaye Francis (00:12):

It is a bit chilly here in Melbourne. Winter has definitely arrived.

(00:18):

So this first podcast is really an introduction to what we're going to do. We'll introduce ourselves, what we do, what we hope to cover during the first season of the podcast, and some of the episodes that we'll cover, and just a little bit of chat so you get to know Richard and me.

(00:36):

We're not particularly good at introducing ourselves. So I'm gonna have a go at introducing Richard and then he'll have a go at introducing me. Richard's a career risk and due diligence engineer. He's been in the business for over 40 years. He works across a whole lot of industries, Rail, Road, Marine, Chemical, Water, Gas, Electricity... you name it. He's been there and done that. So Richard's really seen as one of the world leaders risk and due diligence business.

(01:07):

I've been working with Richard at R2A for over 25 years and started as a grad engineer. So we've worked together a lot. Richard also does a lot of courses through Engineering Education Australia, as well as in-house courses of our own on risk and due diligence and project due diligence and governance. And we also have a couple of booklets that we've co-authored together- Criminal Manslaughter, Engineering Due Diligence, and our new one Project Governance.

(01:34):

So, Richard Richard's been in the industry for a long time. He does have a little bit of a warped sense of humor and you need to get to know him a little bit better. My sister actually worked with us many years ago and she said he reminded her of Mr. Bean and some of his tall lankiness and his jokes.

(01:54):

So, that was a pretty nice introduction, Richard. So I'm hoping for the same.

Richard Robinson (01:59):

Well, good morning everyone. <laugh>. This is Gaye Francis, my business partner, now of about 20 years, although we've been working together for close to 30 years as she pointed out. In that time she got married and had two kids, Charlotte and Amelia. And I've gotta say at this point, the husband got displaced abruptly on her phone by the kids when they arrived!

(02:22):

Just to give you an idea, one of the first things I said to her when we first met, she was asking what this risk business was about and I said, well, think about it. There are three key terms, they are eek, e and oops. And she said, well, yes, I can add a fourth term to that. And that is grrr, which mostly happens when you're working with older males. So she's had a few life experiences like that, I understand <laugh>.

(02:46):

Possibly the other thing which I found most entertaining about her is that she actually trained as a chemical engineer. And when she went into industry, and I had personal experience with this 'cos I was there, she discovered she was actually allergic to chemicals, which is, and I have to point out actually never gets old <laugh>.

Gaye Francis (03:03):

It's a bit embarrassing, but I, I must admit, some of the things that I've done at R2A has got me outta my comfort zone and challenged me, no end. I'm actually scared of heights and I've climbed up the side of the ship, a side of a ship out in the strait and in Tasmania and many other places around Australia. I've also climbed up onto the top of the stadium here in Melbourne to look at some roofing issues. I got the phone call to go and do that at site inspection. Richard was actually interstate and he said, can you go and do this site inspection for me? And I said, I'm wearing a skirt dress today. So raced down at lunchtime to buy pants and went and did this site inspection in the afternoon on the top of, um, yeah, a stadium roof.

Richard Robinson (03:43):

You never mentioned that you actually bought pants, you just complained that there was a problem.

Gaye Francis (03:47):

I wasn't gonna go into a site inspection like that! So yes, I've been taken out of my comfort zone a number of times.

(03:54):

So as we have said, we're business partners and we've been working at R2A for 30 years, and are career risk and due diligence engineers. We stayed in the industry and been boutique consultants, I guess, for that time. In that, I think we like to help people to solve their problems. You know, the risk business industry has become very complex. And there's a lot of resources going into it, and I'm not sure that organizations are getting bang for buck for what they're putting into it.

Richard Robinson (04:26):

That's completely the case. I mean, basically so far as we can tell, the OHS business in particular has turned into an industry, that that's sort of got a life of its own that's just quite independent of all corporate objectives and things like that. Which so far as we can tell is costing an awful lot of organizations an awful lot of money for very little result.

Gaye Francis (04:44):

And I guess our point of difference is that we come from the common law viewpoint of what would be expected to be done in the event that something happens. Which is very, very different from just applying the risk management standard, for example. So we sort of combine those two, come with a due diligence process to make organizations look at what their risk issues are and more importantly, what they have to have in place to, to manage these things.

Richard Robinson (05:12):

Yeah. It actually goes a bit further than that because one of the curious things about us, and I know a number of people have been very surprised by this about us, is that if we to figure out that we're not achieving things because, perhaps sometimes the O H S faction has particularly well entrenched and we haven't been able to get the lawyers to actually correct matters, we simply walk away. It doesn't matter, people paying us good money, if we can't achieve anything worthwhile, then we won't keep doing it. And we've walked away from major regulators in both major jurisdictions and in federal regulators who so far as we can tell, weren't applying due diligence out as expressed in the common law, which is what turned up in the WHS legislation.

Gaye Francis (05:50):

So yes, we're a little bit different in that way, but we love what we do and we really do feel that we make a difference with the people that we work with.

(05:59):

So why this podcast? So we, we've done a number of webinars, but we get asked interesting questions all throughout our work. And so we thought this podcast might be a format to be able to explore some of those issues that people ask us questions about consistently. So some of the things that we've got as our hot topics to talk about in this first season are ALARP versus SFAIRP, which is still creating a lot of confusion within the industry and organizations.

Richard Robinson (06:34):

Perhaps what confuses us the most, I mean, it all sort of popped up in 2004 in Victoria after Maxwell QC reviewed the WHS Act in Victoria, and then it got transferred into the whs legislation in most jurisdictions in 2011, 2012. But it's still causing grief and difficulty and it's generally with the technical parties, not the legal side of things; lawyers understand it quite well.

Gaye Francis (06:55):

And they're trying to align the two and there are key differences between the two terms, but people are saying that they equate to the same thing. Many industries are saying that they're equating to the same thing.

Richard Robinson (07:07):

Well, it is true, a rose by any other name. And a lot of people have been basically defining ALARP as SFAIRP, but we don't understand why you bother to do that. You might as well make it clear there was a difference and that you've changed and effectively moved to the right place.

Gaye Francis (07:21):

Mm-hmm. <affirmative>. So another (topic), we get a lot of discussion points on is standards and how standards are used. And they're really backwards looking; they're written retrospectively and they're not forward looking.

Richard Robinson (07:35):

And the way Australia's been using standards lately, we are actually going backwards. Because under the whs legislation for example, it's quite clear you've got to achieve things 'so far it's reasonably practical'. That is, if you can do better than the standard, than you've gotta get there. So the standards are merely the starting point, if you're talking about a technical standard, you can't design by standards and have useful innovation. And so we, as far as we can tell, innovation is being suppressed in way by the use of standards

Gaye Francis (08:03):

And the comment of a lot of organizations "we've always done it that way" doesn't roll anymore. No, you can't do that. You've gotta always look forward. What else can we do?

Richard Robinson (08:13):

To the extent that you have control, you have to demonstrate that you've done the best that you can.

Gaye Francis (08:19):

And that's for all parties involved in the process, not just, you know, a single party.

(08:25):

Code of practice in the ISO 31000, there's a mismatch of ideas there and that's unfortunate.

Richard Robinson (08:33):

ISO 31000 has done a lot of damage to Australian industry in the last 20 years. And since it's now inconsistent with the legislation, we don't understand why people are still basically designing to it. An awful lot of governments trying to do it too. And this just doesn't make sense anymore.

Gaye Francis (08:47):

Regulations and license to trade. One of the interesting things there is the requirements of the regulators are often or, or can be, um,

Richard Robinson (08:57):

Inconsistent.

Gaye Francis (08:58):

Inconsistent. Thank you Richard. With the, the legislation. So, some organizations are actually having to do two processes to get one for a license to trade and then to meet their statutory obligations.

Richard Robinson (09:12):

Yes. Particularly when the regulators got it wrong. Um, it's one of these things, if you want the license to trade, you got to satisfy the regulator. If you want to satisfy the legislation you often have to do something different. And that's when we often have to walk away from a regulator when they don't recognize that.

Gaye Francis (09:25):

So many of these topics and some of our regular listeners to our webinars and (other resources) will have heard us say this and we've sort of tiptoed around some of these subjects over the last 10 years as to, not to offend anyone, but I think as we go further and further in this legislation, as Richard says it's been in Victoria since 2004 and in most of the rest of Australia since 2012, we're now 10 years down the track plus and we're still facing some of the issues that you would expect to see in the first couple of years of this legislation.

(10:04):

A couple of other interesting topics that we have on the cards is risk appetite and zero harm and organizations trying to relate those two ideas of risks. They're actually two different risk models.

Richard Robinson (10:16):

Yeah. And the confusion is mostly at board level. I don't think the troops have the confusion. It's mostly at board level. And we've briefed a number of boards lately where they simply didn't understand. And so far as we can tell, they've been taking their advice exclusively from management consultants. Um, and that's

Gaye Francis (10:33):

Not the technical view

Richard Robinson (10:34):

And there's been no technical view. And when you live in advanced technological society, that doesn't make a lot of sense.

Gaye Francis (10:39):

<affirmative>. And the language of risk and the complexity of it and how people are actually using some of the words.

Richard Robinson (10:47):

Well, just risk alone, it's a mess. I mean, the insurance world talks about it as the now, and most technical people think of it's likely and consequence simultaneously, but when you're in court and it's all gone wrong, and the facts are certain it's a particular instance, and you really talk about the likelihood of that particular instance occurring. And so when people use the word risk, everyone's confused.

Gaye Francis (11:07):

Mm-hmm. <affirmative>.

(11:08):

So they're some of the hot topics that have been our standout items and concern I guess over the last 10 years and what people have ome to us and said 'we'd like to know more about this'. But we really want this podcast to be a timely, interesting session. So if any of our listeners have got any ideas and things that they'd like to discuss

Richard Robinson (11:29):

Well, people that they'd like us to interview. Probably in the second season we expect to be actually interviewing various people in various (organisations) who've had particular frustrations, particularly when somebody's, for example, adapted the mismanagement standard to the septe process. That's crime prevention through design. There's some weird things going on out there that make no sense.

Gaye Francis (11:49):

<affirmative> and even industry specific things. So the topics that we've sort of outlined go across the industries, but there are some issues of concern and issues facing specific industries that are relevant there as well.

Richard Robinson (12:02):

Probably particularly important. So just people understand. Uh, I mean, um, just before Covid, R2A together with the Victorian Bar sponsored the professor and law and public policy out of Cambridge, David Howth, and the reason why we're interested in him is he's got a book of out of law and engineering, and the point that he makes on his presentations is that what the lawyers are actually doing, at least the big UK and US firms, is that they're actually adopting and deliberately studying the engineering design process. Because basically the point he makes is if you're a lawyer, and it's what happens with engineers, and somebody turns up with a problem or something they want to do, and then basically what you're saying is in the circumstances, these are the options, and which one in all your circumstances is the best and that's the best way forward.

(12:44):

And that's just the base act in engineering design process, um, and which the engineers have been doing now for a very long time. But which seems to be sort of a 10 year transition for the for the lawyers. We certainly came across this long time ago with a lawyer from Baker Mackenzie, and he made the point, there are two types of lawyers out there: those who will tell you what the law is, and those who say, in the circumstances, what are your options and which is the best? So certainly a lot of lawyers in Australia have been thinking about it, although we haven't necessarily seen all the law firms adopting it.

Gaye Francis (13:15):

<affirmative>. So that's sort of an overview of our podcast season one. We hope you can join us the next couple of episodes. And as we have both said, if you'd like us to talk about anything in particular, we'd love to for you to drop us a line. So have a great day and we hope to see you next time.