Orange County, Brea Police Department (2016-2018 inspection cycle)

July 18, 2018 Jack Conklin, Chief of Police Brea Police Department 1 Civic Center Circle Brea, CA 92821 2016-2018 BIENNIAL INSPECTION 6031 PC & 209 WIC Dear Chief Conklin: On April Board of State and Community Corrections (BSCC) staff conducted the biennial inspection of the Brea Police Department temporary holding facility pursuant to Penal Code Section 6031 for compliance with the Minimum Standards for Local Detention Facilities as outlined in Titles 15 and 24, California Code of Regulations. In addition, BSCC staff conducted compliance monitoring pursuant to the federal Juvenile Justice and Delinquency Prevention Act (JJDPA) for the secure detention of minors. The inspection was preceded by a desk audit of applicable policies and procedures governing the operation of the facility1, wherein policy content was reconciled against relevant regulations to ensure that each subject required by regulation was addressed in policy. The on-site inspection began with a review of documentation to verify that practices follow written procedures and regulation, and concluded with a walk-through of the physical plant. Detective Sergeant Tim Mercado& Jailer Josh Howey were present during the inspection and assisted by answering questions and clarifying procedural issues. Their involvement in the process was extremely valuable. The professionalism and courtesy extended during the inspection was appreciated. The complete BSCC inspection report is enclosed and consists of: This transmittal letter; Inspection Cycle Information sheet identifying the facility and listing any areas of non-compliance; The Procedures Checklist outlining applicable Title 15 sections; The Physical Plant Evaluation outlining Title 24 requirements for design;2 and, The Living Area Space Evaluation summarizing the detention facility’s physical plant configuration. Local Inspections In addition to a biennial inspection by the BSCC, inspections are also required annually by the County Health Officer and biennially by the State Fire Marshal or an authorized representative (Health and Safety 1 BSCC does not review all of your policies and procedures. We only review those policies related specifically to the applicable regulations included in Title 15, Minimum Standards for Local Detention Facilities for issues of non- compliance. We do not “approve” your policies nor do we review them for constitutional or legal issues. We recommend agencies seek policy review through their legal advisor, risk manager, and other persons deemed appropriate. 2 Facilities are assessed against Title 24 requirements in place at the time of design or significant remodel to the jail area. 3600 Brea PD City Jail THJ; 07/18/2018 Jack Conklin, Chief of Police Page 2 Code Sections 101045 and 13146.1). Please consider our report in conjunction with the reports from the County Health Officer and Brea City Fire Department for a comprehensive perspective of your facility. Fire Inspection: The Brea City Fire Department conducted the last fire/life safety inspection on March 14, 2018. No deficiencies affecting fire/life safety were noted and a fire clearance was granted. Health Inspections: The local health authority is required to conduct annual inspections of all detention facilities and includes evaluation of medical/mental health services and the environmental health standards. Nutritional requirements are not applicable for temporary holding facilities. The dates of the latest inspection, any issues of non-compliance, and corrective action taken are listed below: Health Corrective Date Non-Compliance Issues Inspection Action Environmental 10/19/2017 None Not applicable Medical/Mental 10/19/2017 None Not applicable Health We encourage the practice of maintaining a permanent file for historical copies of all inspections. This file should be the first point of reference when preparing for all future inspections. BSCC Inspection Physical Plant: Completed in 1981, the Brea Police Department temporary holding facility is evaluated using the 1980 Physical Plant Standards. No inmates were in-custody at the time of the inspection. The jail was clean and no issues of deferred maintenance were evident. No issues of non-compliance with applicable physical plant standards were identified. Policy, Procedures and Practice: BSCC reviewed a subset of the agency policy manual specific to the facility operations and reconciled the contents against relevant regulations to ensure that each subject required by regulation was addressed in policy.3 No issues of non-compliance were identified. We evaluated the department’s procedures and reconciled them against policy. Those evaluations included a review of documentation related to jail operations including daily inspection sheets, shift schedules, local inspection results, classification documents, incident reports and other records which gave insight to the facility’s operations. BSCC sought out evidence to ensure that practices matched written procedures and that written documents reflected actual events. 3 BSCC does not review all of your policies and procedures. We only review those policies related specifically to the applicable regulations included in Title 15, Minimum Standards for Local Detention Facilities for issues of non-compliance. We do not “approve” your policies nor do we review them for Constitutional or legal issues. We recommend agencies seek policy review through their legal advisor, risk manager, and other persons deemed appropriate. 3600 Brea PD City Jail THJ; 07/18/2018 TEMPORARY HOLDING FACILITIES Board of State and Community Corrections PROCEDURES1 BSCC Code: 3600 FACILITY NAME: Brea Police Department City Jail FACILITY TYPE: THJ PERSON(S) INTERVIEWED: Detective Sergeant Tim Mercado & Jailer Josh Howey FIELD REPRESENTATIVE: Michael J. Bush DATE: 04/03/2018 TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS 1024 COURT HOLDING AND TEMPORARY 900.1.1 HOLDING FACILITY TRAINING 1 – Jailer only. When not available officers will All personnel who are responsible for supervising inmates, book prisoners. All have gone through the and supervisors with custodial responsibilities, complete required training. the eight hours of specialized training outlined in this X regulation within six (6) months of assignment. Successful completion of training, pursuant to Section 1020 of these regulations, may be substituted for the initial eight hours of training. Eight hours of refresher training is completed every two Department is currently going through a years. Successful completion of training, pursuant to refresher course. Section 1025 of these regulations, may be substituted for X the eight hour refresher. 1027 NUMBER OF PERSONNEL In addition to the implementation and operation of all programs and activities required by the regulations, another predicator for compliance There are sufficient personnel on duty at all times with this section is the availability of staff to (whenever there is an inmate in custody) to ensure the complete and document at least hourly safety implementation and operation of all programs and activities checks. required by these regulations. X Few inmates are placed in rated cells. Most are briefly detained in one of two non-rated booking enclosures. Staff is present at all times when arrestees are in the enclosures. Safety check documentation that was available for review was found compliant with policy and regulation. There is a written plan that includes the documentation of 900.9 hourly safety checks. Safety checks are required hourly with X documentation on the Jail Housing and Classification Log. 1 This document is intended for use as a tool during the inspection process; this worksheet may not contain each Title 15 regulation that is required. Additionally, many regulations on this worksheet are SUMMARIES of the regulation; the text on this worksheet may not contain the entire text of the actual regulation. Please refer to the complete California Code of Regulations, Title 15, Minimum Standards for Local Facilities, Division 1, Chapter 1, Subchapter 4 for the complete list and text of regulations. The findings herein, as related to policy, do not constitute an “approval” for content, constitutional, or legal issues. We recommend agencies seek policy review through their legal advisor, risk manager, and other persons deemed appropriate. 3600 Brea PD City Jail THJ PRO.docx; 04/03/2018 - 1 - A352 TH PRO eff. 9/12.dot TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS There is at least one employee on duty at all times, who 900.1.2 shall be immediately available and accessible with the X ability to respond to any inmate in the event of an emergency. Whenever one or more female inmates are in custody, there 900.1.1 is at least one female employee immediately available and X accessible. Will call outside agency when there are no Note: Reference PC § 4021. trained female staff available. A staffing plan is available which indicates personnel 900.2.1 X assigned and their duties. 1028 1028 FIRE AND LIFE SAFETY STAFF 900.1.2 Whenever there is an inmate in custody, there is at least Temporary Holding Facility Training X one person on duty at all times who meets the BSCC Agency self-certifies that all applicable staff are training standards for general fire and life safety. current in required training, which includes fire and life safety training. There is at least one person on duty who trained in fire and Each officer receives facility specific training life safety procedures that relate specifically to the facility. X during orientation. 1029 POLICY AND PROCEDURES MANUAL 2 Agency uses Lexipol. There is a published manual of policies and procedures for X the facility that addresses applicable regulations and includes: Table of organization, including channels of 900.2 X communications; Inspections and operations reviews by the facility 900.2 & 900.6.3 X administrator/manager; Use of force; X 900.6.4 Defers to Department Policy Use of restraint equipment, including the restraint of 900.3.1& 900.6.4 pregnant inmates; X Note: Reference PC § 6030(f); Screening newly received inmates for release 900.6.5 X Note: Reference PC § 849(b)(2) and 853.6 Security and control, including: 900.7 X Physical counts of inmates; Searches of the facility; X 900.7 Searches of inmates; X 900.7 & 900.15 Contraband control; and, X 900.7 Key control. X 900.7 At least annually, the facility administrator reviews, 900.2 evaluates and documents internal and external security X measures. Emergency procedures, including: X Escape; X 900.7.1 Disturbances; X 900.7.1 Taking of hostages; X 900.7.1 Civil disturbance; X 900.7.1 Natural disasters; X 900.7.1 Periodic testing of emergency equipment; X Included on monthly inspection form. 2 Procedures related to security and emergency response may be in a separate manual to ensure confidentiality by limiting general access. 3600 Brea PD City Jail THJ PRO.docx; 04/03/2018 - 2 - A352 TH PRO eff. 9/12.dot TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS Storage, issue and use of weapons, ammunition, 900.7.1 X chemical agents; and, Storage, issue and use of security devices. X 900.7.1 Suicide prevention; and, X 900.7.2 Segregation of inmates. X 900.8.2 The manual is available to all employees. X Hard copies in various locations and intranet. The manual is comprehensively reviewed and updated at least every two years. X 1032 FIRE SUPPRESSION PREPLANNING 900.7.1 There is a fire suppression pre-plan that has been developed X in consultation with the responsible fire authority and includes: Note: Reference PC § 6031.1 Monthly fire and life safety inspections by facility staff Completed monthly as a portion of a X with a two-year retention of the inspection record; comprehensive inspection form. Verified. Fire prevention inspections at least once every two Conducted 03/14/2018by the City of Brea Fire years; Prevention. No deficiency-fire clearance X Note: Reference Health and Safety Code Section granted. 13146.1(a) and (b); An evacuation plan; and, X 900.7.1 A plan for the emergency housing of inmates in the The Orange County Jail would be used in this event of a fire. X event. 1044 INCIDENT REPORTS 900.3.2 There are written policies and procedures for the maintenance of written records of all incidents that result in X physical harm, or serious threat of physical harm, to an employee, inmate or other person. Such records include names of persons involved, a description of the incident, actions taken, and date and time of the occurrence. Written record is prepared by appropriate staff and submitted within 24 hours of the incident. X 1046 DEATH IN CUSTODY 900.18 X Written policy and procedures assure that there is a review of each in-custody death. When a minor dies in a facility, the administrator of the 324.7.5 facility provides the Board of State and Community Corrections with a copy of the death in custody report that is submitted to the Attorney General under Government Code X Section 12525, within 10 days after the death. Note: Reference Government Code § 12525 1050 CLASSIFICATION PLAN 900.8.2 X The facility has a written classification plan designed to properly assign inmates to housing units and activities. 3600 Brea PD City Jail THJ PRO.docx; 04/03/2018 - 3 - A352 TH PRO eff. 9/12.dot TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS Includes receiving screening performed at intake by trained Agency self-certifies verifies that all applicable personnel. X staff is current in initial and biannual training requirements. Includes maintenance of a record of each inmate's classification level, housing restrictions and housing X assignments. 1051 COMMUNICABLE DISEASES 900.8.2 There are written policies and procedures, which require X that all inmates with suspected communicable diseases are segregated until a medical evaluation can be completed. In absence of medically trained personnel at the time of 900.11 intake into the facility, an inquiry is made to determine if the inmate has or has had any communicable diseases, or Agency uses a standardized Orange County has observable symptoms of communicable diseases, X medical screening questionnaire, completed by including but not limited to tuberculosis or other airborne trained staff. diseases, or other special medical problems identified by the health authority. Inmate's response is noted on booking form and/or Responses entered and maintained in I-Leads screening device. X 1052 MENTALLY DISORDERED INMATES 900.1.3 (c) Non-Detainable Prisoners There are written policies and procedures for the X identification and evaluation of all mentally disordered inmates. An evaluation by health care staff occurs within 24 hours of identification or at the next daily sick call, whichever is X earliest. Segregation may be used if necessary to protect the safety X of the inmate or others. 1053 ADMINISTRATIVE SEGREGATION 900.8.2 & 900.1.3 (d) References Section 1053 as Non-Detainable There are written policies and procedures, which provide Prisoners for administrative segregation of inmates who are X determined to be prone to: escape; assault staff or other inmates; disrupt operations of the jail; or, are likely to need protection from other inmates. The administrative segregation consists of separate and secure housing with no deprivation of privileges other than those necessary to obtain the objective of protecting X inmates and staff. 1055 USE OF SAFETY CELL No Safety Cell The balance of this regulation has been deleted. The safety cell, specified in Title 24, Part II, Section 1231 X 2.5, is used only to hold inmates who display behavior that results in the destruction of property or reveals an intent to cause physical harm to self or others. 3600 Brea PD City Jail THJ PRO.docx; 04/03/2018 - 4 - A352 TH PRO eff. 9/12.dot TITLE 15 SECTION YES NO N/A P/P REFERENCE - COMMENTS 1056 USE OF SOBERING CELL 900.1.9 The sobering cell, specified in Title 24, Part II, Section No sobering cells. The balance of this regulation 1231 2.4 is used only for holding inmates who are a threat X has been deleted. to their own safety or the safety of others due to their state of intoxication and pursuant to written policies and procedures. 1057 DEVELOPMENTALLY DISABLED 900.1.3 (g) INMATES X References Section 1057 as Non-Detainable There are written procedures for identification and Prisoners evaluation of all developmentally disabled inmates. A contact to the regional center occurs within 24 hours when an inmate is suspected or confirmed to be X developmentally disabled. 1058 USE OF RESTRAINT DEVICES 900.6.4 There are written polices and procedures for the use of Restraints are not used, the remainder of the text restraint devices that include: of this regulation has been deleted. 1067 ACCESS TO TELEPHONE 900.16 There are written policies and procedures that allow X reasonable access to a telephone beyond those telephone calls required by Section 851.5 PC. 1068 ACCESS TO COURTS 900.1.5 There are written policies and procedures that ensure the X inmate's right to confidential consultation with attorneys. 1081 PLAN FOR INMATE DISCIPLINE (WA) 900.9.2 & 900.9.6 There are written policies and procedures for inmate No discipline is administered in the facility. discipline. (This may be waived by written policy Waived stating that discipline is not administered in the facility. If discipline is administered, Sections 1080, 1082, 1083 and 1084 Title 15, CCR, apply.) DETENTION OF MINORS YES NO N/A Are minors held in this facility? Facility reported that minors will not be held in secure detention. If YES, then the core requirements of the Juvenile Justice and Delinquency Prevention Act (JJDPA) and the X provisions of Title 15, Article 9, Minors in Detention in a Law Enforcement Facility apply and will be inspected for. JUVENILE JUSTICE AND DELINQUENCY VIOLATION N/A P/P/REFERENCE - COMMENTS PREVENTION ACT MONITORING NO YES 3600 Brea PD City Jail THJ PRO.docx; 04/03/2018 - 5 - A352 TH PRO eff. 9/12.dot 42 USC 5633 SECTION 223(a)(11) DEINSTITUTIONALIZATION OF STATUS OFFENDERS Status offenders, non-offenders, alien juveniles, civil-type N/A juveniles are not to be held in secure detention. Number of violations: 0 Reference: WIC 206 & 207 42 USC 5633 SECTION 223(a)(12) SEPARATION Juveniles may not be confined or detained in any facility in which they have contact with adult prisoners. N/A Reference: WIC 208 Number of violations: 0 42 USC 5633 SECTION 223(a)(13) JAIL REMOVAL (SIX-HOUR HOLD EXCEPTION) During the previous calendar year, minors are securely detained for a period not to exceed six hours. N/a Number of violations: 0 Reference: WIC 207.1(d)1(B) TITLE 15 SECTION YES NO N/A P/P/REFERENCE - COMMENTS 1142 WRITTEN POLICIES AND PROCEDURES 324 Written policies and procedures concerning minors held in X temporary custody address: suicide risk and prevention; X 324.7.2 use of restraints; X 324.7.3 emergency medical assistance and services; and, X 324.7.1 prohibiting use of discipline. X 324.7.4 1143 CARE OF MINORS IN TEMPORARY 324.3.1 CUSTODY The following are made available to all minors held in X temporary custody: access to toilets and washing facilities; one snack upon request during term of temporary custody if the minor has not eaten within the past (4) X hours or is otherwise in need of nourishment; access to drinking water; and, X privacy during consultations with family, guardian, or X lawyer. Minors placed in locked rooms are: 324.4.7 provided blankets and clothing, as necessary, to assure X the comfort of the minor; and, permitted to retain and wear his or her personal clothing unless the clothing is inadequate, presents a health or safety problem, or is required to be utilized as evidence X of an offense. 3600 Brea PD City Jail THJ PRO.docx; 04/03/2018 - 6 - A352 TH PRO eff. 9/12.dot TITLE 15 SECTION YES NO N/A P/P/REFERENCE - COMMENTS 1144 CONTACT BETWEEN MINORS AND 324.3.2 ADULT PRISONERS Policies and procedures ensure that there is no physical or sustained sight or sound contact between juveniles in X detention and incarcerated adults. Reference: WIC 208 In situations where brief or accidental contact may occur, such as booking or facility movement, facility staff (trained in the supervision of inmates) shall maintain a constant, X side-by-side presence with the minor or the adult to prevent sustained contact. 1145 DECISION ON SECURE DETENTION 324.4.2 Minors are held in secure detention in a law enforcement Minors are not held in secure detention. facility only if the minor is in custody for an offense described by WIC § 602, is at least 14 years of age, and X presents a serious security risk of harm to self or others. Reference: WIC 207.1 (d) 1 Factors to be considered when determining if the minor presents a serious security risk to self or others are: age, maturity and delinquent history; severity of offense for which taken into custody; minor’s behavior; availability of X staff to provide adequate supervision or protection of the minor; and, age, type and number of other individuals detained at the facility. 1146 CONDITIONS OF SECURE DETENTION 324.4.3 While in secure detention, a minor may be locked in a room Minors are not held in secure detention. or other secure enclosure, secured to a cuffing rail, or X otherwise reasonably restrained as necessary to prevent escape and protect the minor and others from harm. 1147 SUPERVISION OF MINORS HELD INSIDE 324.4.3 A LOCKED ENCLOSURE Minors are not held in secure detention. Minors must receive adequate supervision which includes: X Constant auditory access to staff by the minor; and, documented, safety checks are conducted by staff at No secure detentions have occurred during the least once every 30 minutes. inspection period. X Reference: WIC 207.1(d)1(E) Males and females are not placed in the same locked room unless they are under constant direct visual X observation by staff of the law enforcement facility. 1148 SUPERVISION OF MINORS IN SECURE 324.4.3 DETENTION OUTSIDE OF A LOCKED ENCLOSURE X Minors held in secure detention outside of a locked enclosure are not secured to a stationary object for more than 60 minutes unless no locked enclosure is available. 3600 Brea PD City Jail THJ PRO.docx; 04/03/2018 - 7 - A352 TH PRO eff. 9/12.dot TITLE 15 SECTION YES NO N/A P/P/REFERENCE - COMMENTS A staff person from the facility is present at all times to assure the minor’s safety while secured to a stationary X object. Securing minors to a stationary object for longer than 60 minutes, and every 30 minutes thereafter is approved by a X supervisor and documented. The decision to secure a minor to a stationary object for longer than 60 minutes and every 30 minutes thereafter is X based on the best interests of the minor. 1150 SUPERVISION OF MINORS IN NON- 324.4.1 SECURE CUSTODY Minors held in non-secure custody receive constant direct X visual observation by staff of the law enforcement facility. Monitoring a minor using audio, video, or other electronic X devices does not replace direct visual observation. Entry and release times are documented and available for Non-secure detention logs were available for review. X review. 1151 INTOXICATED AND SUBSTANCE 324.8 ABUSING MINORS Facility administrators shall develop policies and X procedures providing that a medical clearance shall be obtained for minors who are intoxicated by any substance, to the extent that they are unable to care for themselves. Supervision includes safety checks no less than once every 15 minutes until resolution of the intoxicated state, with the X actual time of each personal observation documented. 1047 SERIOUS ILLNESS OR INJURY OF A 324.7.1 MINOR IN AN ADULT DETENTION FACILITY There are policies and procedures for notifying the court and X the parent, guardian or person standing in loco parentis, in the event of a suicide attempt, serious illness, injury or death or a minor in custody. 3600 Brea PD City Jail THJ PRO.docx; 04/03/2018 - 8 - A352 TH PRO eff. 9/12.dot PHYSICAL PLANT EVALUATION BOARD OF STATE AND COMMUNITY CORRECTIONS- BIENNIAL INSPECTION ADULT COURT AND TEMPORARY HOLDING FACILITIES APPLICABLE REGULATIONS: 1/78 Title 24, California Code of Regulations (CCR) BSCC Code: 3600 FACILITY NAME: Brea Police Department FACILITY TYPE: THJ APPLICABLE REGULATIONS (Check All That Apply): 1/78: OTHER: 1980 FIELD REPRESENTATIVE: Michael J. Bush DATE: 04/03/2018 ARTICLE/SECTION YES NO N/A COMMENTS Temporary Holding Cells (2.2) X Contain 10 square feet of floor per inmate Limited to no more than 16 inmates X No smaller than 40 square feet X Contain sufficient seating to accommodate all inmates X Toilet accessible X Wash basin accessible X Drinking fountain accessible X Provide for adequate visual supervision of inmates X Bunk provided to inmates held between hours of 2400 and In cells A – E, when used for sleeping RC is one 0600 (Later, less restrictive 1994 standards only require a per cell. When used as holding, RC is four per cell. X bunk if inmates are held longer than 12 hours) Each cell contains a 76” bench that doubles as a bunk. Weapons Locker (3.12) External to the security area and equipped with individual X compartments, locks and keys Sobering Cells (WA) (2.4) Remove sober cell (2014) X Limited to no more than 8 inmates Safety Cells (WA) (2.5) No safety cell in this facility. Remainder of regulation deleted from checklist. X Contain 48 square feet with one floor dimension at least 6 feet Shower-Delousing Room (3.4) X Available Secure Vault or Storage Space (2.1) X Available for inmate valuables Telephone (2.1) X Available for inmate use per Penal Code § 851.5 Audio Monitoring (2.22) Video monitoring in each cell, audio is monitored by dispatch. X For facilities planned or constructed after 8-86 3600 Brea PD CityJail THJ PD PHY.docx; 04/03/2018 - 1 - A370 PHY CH-TH 1-78.dot (9/98) ARTICLE/SECTION YES NO N/A COMMENTS Janitor Closet (2.20) X Available Storage Rooms (WA) (2.21) X Available Emergency Power (2.24) Alarms go to dispatch. Available to maintain fire and life safety, security, X communications and alarm systems Attorney Interview Space (2.26) X Available 3600 Brea PD CityJail THJ PD PHY.docx; 04/03/2018 - 2 - A370 PHY CH-TH 1-78.dot (9/98) BOARD OF STATE AND COMMUNITY CORRECTIONS - BIENNIAL INSPECTION ADULT DETENTION FACILITY LIVING AREA SPACE EVALUATION BSCC Code: 3600 FACILITY: Brea Police Department TYPE: THJ RC: 0 FIELD REPRESENTATIVE: Michael J. Bush DATE: 04/03/2018 ROOMS EACH ROOM Cell Applicable # EACH CELL Total DIMENSIONS FIXTURES* Location Type Standards Cells # Beds RC RC (L x W x H) T U W F S Booking 2001 1 Not Measured 1 - 1 1 - enclosure Booking 2001 1 Not Measured 1 - 1 1 - enclosure Notes: One holding cell was eliminated in 2001 to construct the two booking enclosures. The enclosures are non-rated space due to size and fixtures. A – E Holding 1980 5 1 4 (20) 7’ x 7’ 1 - 1 1 * Notes: Each cell is equipped with 76” bunk. When used for sleeping, capacity is one per cell. When used for holding, capacity is four per cell. There is one shower in the area for the cells. Sobering 1980 1 - 4 (4) 8’ x 10’ 1 - 1 1 - Sobering cell removed during the remolding of locker room 2014 MJB *T = Toilets; U = Urinals; W = Wash Basins; F = Fountains; S = Showers in unit; If "Total RC" appears in brackets ( ), it is not part of the facility's rated capacity. "+" indicates that capacity includes prorated air space from adjacent areas. P:\Adult..\Cycle\Living..\3600 Brea PD City Jail THJ LAS.docx ; 02/16/2016 - 1 - A360 LAS Adult.dot (9/98)