Assured Joint Integrity



Similar documents
JOINT INTEGRITY MANAGEMENT SOLUTIONS

The Pathway to ASME PCC Appendix A Compliance and why it s of Critical Importance

Owner-User Pressure Equipment Integrity Management Requirements

50t. Product training courses. 40t

Asset Integrity Services. A commitment to excellence in Non-Destructive Testing & Inspection.

Our Know-How. Your Peace of Mind. Innovative Sealing and Gasket Solutions

Powerful information management services and software for the oil, gas, and chemical industries

LIFECYCLE INTEGRITY PARTNER

JOHN HART GENERATING STATION REPLACEMENT PROJECT. Schedule 9. Quality Management

ABSTRACT. The Guidelines Section F is related to the Purchasing requirements of NSQ100 (Chapter 7.4). Summary

EDICATED TO ONTINUITY

Quality Management System

Engineered Solutions

Atlantic Maintenance Services

Specialties Manufacturing. Talladega Castings & Machine Co., Inc. ISO 9001:2008. Quality Manual

Copyright, Language, and Version Notice The official language of this [Certification Protocol] is English. The current version of the [Certification

MAXIMISING YOUR. Offshore wind assets ASSET OPERATION & MAINTENANCE SERVICES

CORPORATE QUALITY MANUAL

9. QUALITY CONTROL/QUALITY ASSURANCE

Industry Solutions Oil and Gas Engineering Document Control and Project Collaboration Solutions for Oil and Gas

WORLD CLASS CUSTOMER SERVICE

MBA Experience Overview

energy JLT Specialty Limited Demand Different

Asset and Lifecycle Management

SUPPORTING THE RAIL INDUSTRY UNIQUE SOLUTIONS FOR UNIQUE SITUATIONS

CQR-1 CONTRACTOR QUALITY REQUIREMENTS for CONSTRUCTION SERVICES

Certification of Materials and Components

The Asset Management Landscape

Asset Management Conformity Assessment Fitness for Service QHSE. Oil & Gas Services and Tools. For the benefit of business and people

MEDFORD FABRICATION CSC, INC. Quality System Manual. Date of issue: 03/25/2010 Revision : F

NON-DESTRUCTIVE TESTING FULL SCOPE OF INTEGRATED NDT SERVICES

API Q2 Specification for Quality Management System Requirements for Service Supply Organizations for the Petroleum and Natural Gas Industries

True Product Lifecycle Management Begins When Design Ends. strategy may dictate involvement in all or just a few implemented according to design

ISO/IEC QUALITY MANUAL

Quality Assurance Manual ISO 9001:2000. Uncontrolled copy

ISO 9001:2008 QUALITY MANUAL. Revision B

Evaluation of the Quality System Appraisal of Conformity

Reduce risk. Reduce cost. Raise performance.

C.A.T.S. Capabilities

Pressure Equipment Certification. Ensure the Conformity and Quality of Your Pressure Equipment. Worldwide.

FPO. Meeting and Exceeding API Standards: How Much Testing Do Pumps Really Need? White Paper

GLOBAL INSPECTION AND CERTIFICATION

ITSM Process Description

Capability Statement Global Technical Staffing. expertise at work. recruitment specialists

Operational Excellence Management System

Quality Systems Manual

SECTION A... 3 SECTION B... 7

BASE CONSTRUCTION INC

SERVICES. Designing, deploying and supporting world class communications solutions.

Quality Manual. This manual is proprietary and no part thereof shall be copied without written authorisation from the company. Ref: Quality Manual.

Your Software Quality is Our Business. INDEPENDENT VERIFICATION AND VALIDATION (IV&V) WHITE PAPER Prepared by Adnet, Inc.

EA-6/02 M: EA Guidelines on the Use of EN and ISO/IEC for Certification to EN ISO Publication Reference PURPOSE

Section 1. The title of Section of Subchapter A of Chapter 100 of Title 1 of the Rules of the City of New York is amended to read as follows:

TAKE CONTROL OF YOUR ASSETS. move your enterprise forward

Capabilities Overview

Vigilant Security Services UK Ltd Quality Manual

The Prophotonix (UK) Ltd Quality manual

ISO 9001 Quality Systems Manual

12 Tips for Successful Medical Equipment Outsourcing

FMC Technologies Measurement Solutions Inc.

Page 1 of 7 Effective Date: 12/18/03 Software Supplier Process Requirements

EU F-Gas Regulation Guidance Information Sheet 15: Fire Protection System Contractors

6 Reasons Why Outsourcing Equipment Maintenance Is Your Best Hedge In A Down Economy

Title: Rio Tinto management system

DOCUMENT CS/1: SCHEME DESCRIPTION AND BENEFITS

Analytical Products and Solutions. Complete service and maintenance solutions for your analytical equipment. usa.siemens.com/analyticalproducts

Integrity Management Software Solution - Managing your daily activities By Sebastian Ruik Beyhaut

Essentials Welding QA/QC Plan Sample

RTP s NUCLEAR QUALITY ASSURANCE PROGRAM

CERTIFIED MAINTENANCE Total Maintenance Management (TMM)

A Leading Provider of Engineering Information Management Solutions and Services. Facilitating multi-office, multi-contractor execution strategies

QUALITY MANUAL ISO Quality Management System

Fire and Gas Solutions. Improving Safety and Business Performance

Life Cycle Solutions. Lowering Equipment Cost Increasing Plant Output

Quality Manual Printed copy valid for 24 hours from time of printing unless stamped CONTROLLED COPY in red. Page

Turnaround and Maintenance Services

Industry Solutions Process Manufacturing Flexible and Agile Engineering Document Control for Efficient, Safe and Compliant Plants

Training and Competency in a High Hazard Environment

CHECKLIST ISO/IEC 17021:2011 Conformity Assessment Requirements for Bodies Providing Audit and Certification of Management Systems

Quality Management System Manual

GENERAL WELDING & FABRICATING, INC. 991 Maple Road Elma, New York 14059

The vision of the Ham Baker Group is to be the partner of

THE DELTON GROUP MANPOWER TRAINING CONSULTANCY SHORT COURSE PROGRAMME TOPICS LISTING

Maturity Model. March Version 1.0. P2MM Version 1.0 The OGC logo is a Registered Trade Mark of the Office of Government Commerce

For the Design, Installation, Commissioning & Maintenance of Fixed Gaseous Fire Suppression Systems

Operational Business Intelligence in Manufacturing

CENTRIS CONSULTING. Quality Control Manual

1 RCNY CHAPTER 100

YOuR SuppLIER for InnOvaTIvE and ERp-IndEpEndEnT finance SOLuTIOnS. perfection In detail.

Safer food supply chains why assessments are great news for your business

Emergency Power System Services Industrial UPS, Batteries, Chargers, Inverters and Static Switches

NORWEGIAN PROJECT MANAGEMENT PRINCIPLES APPLIED IN THE JURONG ROCK CAVERN PROJECT

UNCONTROLLED COPY FOR REFERENCE ONLY

Item: 16 Page: Purpose

Title V Compliance Verification Process

Aftermarket Technical Service Solutions for Pumping Technologies

Managed Services. New Vibrations. Contents. Key Articles

INTERTEK S ASSET INTEGRITY MANAGEMENT PROGRAM (AIM)

NOT PROTECTIVELY MARKED

Transcription:

Assured Joint Integrity

All leaks cost Loss of containment can have catastrophic results and negatively impact brand image, facilities, employees, and the environment. Unplanned shutdowns at hydrocarbon processing facilities regularly feature in the news; and globally, reports of major fires exceed, on average, one a week. It is unquestionably true that all leaks cost the industry but it is also true that all leaks are preventable. All leaks from bolted joints can be avoided This is a true statement that Hydratight emphatically believes in and drives our people and our processes all leaks from bolted joints can be avoided. No matter where the leak occurs, the media type released, or the volume that escapes, the resultant leak will have a cost to the facility. According to ASME, bolted joint leakage contributes to a loss of life and costs industry $100m in any given year. Hydratight s assured Joint Integrity programs are designed to make sure facilities operate with the safest bolted connections possible preventing leakage during commissioning and operation. A proven approach to preventing leaks Our joint integrity process stems from industry best guidelines and parallels the regional legislative frameworks our customers operate with. Hydratight s proven Joint Integrity approach ensures assets and installations have the safest bolted joints possible. Our philosophy is to prevent leaks. A one-of-akind, holistic approach ensures leak-free start-ups and operations. Only Hydratight provides: Joint Integrity Assurance for bolted flange joints via the provision of: - Technical Consultancy - On Site Compliance, QA and QC Joint Integrity Execution for bolted flange joints, via the provision of: - On-site controlled bolting, on-site machining, and flange management services - Bolting and machining equipment for rental or sale Industry pioneer in Joint Integrity Technical authority on bolted joints A holistic approach to safety, time & costs Hydratight s Assured Joint Integrity ST Our people underpin the Hydratight Joint Integrity approach. Everyone, from our field service personnel, to our technical and engineering support teams, to our operations and sales staff, possesses levels of training, competency, skills and experience unrivaled in this highly specialized safety conscious industry. Assurance Service Decommissioning FEED Assured Joint Integrity Turnarounds Sales Construction Commissioning Rental 2 hydratight.com

Why is Joint Integrity so important? Irrespective of location or whether onshore or offshore, studies show that the majority of flange leaks are attributable to procedural, process or operational failings. Surprisingly, few are due to technical reasons. Fundamentally, it s people and their competencies that prevent leaks. These fundamentals are the heart of Hydratight s joint integrity services. Environmentally responsible and safety focused installations commonly record leaks and report leak size and frequency as a metric. The intent is to demonstrate improvement both to stakeholders and legislative bodies, and ultimately eliminate leaks completely. Hydratight understands these leak investigations and the need to demonstrate year after year leak reductions. Our process is wholly compliant; we meet the requirements for safety and environmental management systems, ageing and life extension provisions; and provide permanent databases with traceable and easily retrieved joint data. Joint Integrity allows organizations to fully meet the demanding safety, environmental, and external compliance standards. Only Hydratight has a proven track record for delivering assured joint integrity. Nearly all process plants depend on either welded or bolted joints. A welded joint must comply with numerous mandated procedures and competency requirements to assure quality. But a bolted flange joint has historically had few such requirements, even though it serves the same purpose pressurized process containment. Welded Joint Bolted Joint Material Control Coded Welder Material Control Competent Personnel Documented Procedure NDT Verification Documented Procedure Hydro-tested Hydro-tested Integrity Tested Records Records Only Hydratight treats the bolted joint like a weld Hydratight s Joint Integrity approach is dedicated to ensuring the design, assembly, tightening, inspection, and management of a bolted flange joint meets the same quality control and assurance requirements as a welded joint. hydratight.com 3

Essentials of assured Joint Integrity A Joint Integrity program based on these essentials will deliver a leak-free startup and operation, provide long term assurance, and ensure that any organization operates Joint Integrity best in class procedures. Our joint integrity process stems from industry best guidelines and parallels the regional legislative frameworks our customers operate with. Ownership, Support and Structure A defined Joint Integrity owner should be appointed. This provides an unambiguous reporting structure, aids in solving issues and ensures that the Joint Integrity program is effectively communicated to all levels of an organization. Management Process and Strategy An overall Joint Integrity strategy should be in place to drive leak-free intent, integrate seamlessly, and ensure the Joint Integrity philosophy is embedded throughout the organization. Technology and Best Practice Procedures and technical standards should represent best practice, providing a single source of truth, minimizing delays and avoiding rework. Criticality Assessment Define and implement a joint criticality assessment policy to ensure resources allocated to each joint are balanced with risk. Vendor Packages A system should be in place to ensure that vendor suppliers work to mandated client procedures. These essentials are based on industry best practice, including: ASME Guidelines for Pressure Boundary Bolted Flange Joint Assembly (PCC-1-2013) European Standard Design Rules for Gasketed Circular Flange Connections (EN1591-4-2013) UK Energy Institutes Guidelines for the Management of Integrity of Bolted Joints in Pressurised Systems (2007) Step Change in Safety Mechanical Joint Integrity Route to Competence Guidance Engineering Construction Industry Training Board (ECITB) Mechanical Joint Integrity Standards Training and Competence Management All field service personnel should have a proven level of competency, ensuring work is executed Right First Time, providing long term integrity of bolted joints. Joint Identification, Status Control and Tagging Implement joint identification protocols, format, and technology to provide permanent records and minimize ambiguity. Records and Data Management Implement a Data Management system to provide a permanent, comprehensive, and searchable record of every joint. Inspection and Compliance Implement a program of on-site inspection and compliance to ensure procedures are followed, verify workmanship, drive down operational costs, and avoid unplanned shutdowns. Management of Leaks Establish a robust leak investigation process to ensure leaks are addressed, resolved, eliminated, and lessons learned. Reporting, Analysis and KPI s Clear reporting structure and metrics should be in place, providing visibility on progress and performance, and demonstrating that schedule are being met. 4 hydratight.com

How we can work with you While we would always recommend a bundled package of services, our approach is designed to be highly flexible, and we offer a number of different contracting models at different stages of a projects lifecycle to meet any client requirements. All of our services fall within three broad contracting models, linked to our Business Model. Engineering and Technical Consultancy During the preparation and planning of any construction or maintenance activity, we provide technical consultancy to assist with the development of a best practice Joint Integrity program. This includes the review and development of procedures, troubleshooting and engineering support, and expert guidance on Joint Integrity related issues, drawing on our position as an industry leading technical authority. We perform Technical Consultancy at any phase of a projects lifecycle from initial FEED to Turnaround planning during operations. On-site QA/QC Compliance During any on site construction or maintenance activities, we perform a full QA/QC service of any Joint Integrity activities. Teams of specialist Joint Integrity personnel drive and monitor the implementation of a client s Joint Integrity program, ensuring compliance, and providing full traceability that clients mandated procedures and standards have been met. On site compliance is provided as a distinct service to the direct execution of any controlled bolting, helping to avoid conflicts of interest, or can be bundled with a broader package of Joint Integrity services to meet any client requirements. On-site Execution: Service/Sale/Rental We supply skilled field service personnel to directly execute any controlled bolting, on site machining, or flange management activity. Hydratight is an original equipment manufacturer (OEM) and provides a comprehensive range of in-house manufactured equipment, either for sale or rental. Where standard tools are unsuitable, Hydratight is able to design and manufacture special tooling to order. We also offer a centralized tool trailer for rental to ensure tools are calibrated properly for safe and accurate use, reducing rental cost and the amount of duplication. Consultancy Compliance Execution Assist with the development of a best practice Joint Integrity program Assure that correct processes, procedures, and standards are being met Provide skilled personnel and high quality equipment for flange management Assured Joint Integrity hydratight.com 5

Services we offer Our Joint Integrity offer is made up of a number of distinct services, which can be provided standalone or as a package of services combined within the different contracting models we offer. Hydratight Offer Gap Analysis Procedure Development Engineering Support Description Technical Authority review (at client offices or on site) of all existing Joint Integrity procedures, processes, and management systems, benchmarking against industry best practice, and producing a detailed reporting identifying 'gaps' and recommendations for improvement. Remote review and development of any client technical or operational procedures, whether task, control, or management based. Ongoing access to Hydratight's global team of Technical Authorities to provide expert guidance, troubleshooting, and support on any Joint Integrity related technical or engineering issue. Flange Management Software Bespoke Integrity Data Management System (idms) for any asset / plant / site to record data, plan, manage, and provide a project delivery tool for the on site execution of any Joint Integrity workscope. Bolt Load Calculations Informate bolt load calculation engine, which provides optimized bolt load values and torque/tension values for any joint application, whether coded or not. Informate contains an extensive range of joint types, flanges, gaskets, lubricants, and bolting materials. Joint Integrity Engineers (On Site) management of any Joint Integrity program, providing supervision, technical resource, training, and management reporting, coordinating the introduction of Flange Management Software, and ensuring full compliance with a clients Joint Integrity program by any personnel involved in Joint Integrity activity. Joint Integrity Inspectors Perform (on site) flange joint inspection, along with supervision and witness of joint assembly and tightening, providing full and traceable QA/QC documentation, and ensuring mandated procedures are followed by all involved in controlled bolting activity. Training & Compliance Management Supply training and compliance management to any client, contractor, or sub contractor involved in controlled bolting, onsite machining, or flange management activity. Field Service Technicians Supply uniquely qualified field service technicians to client sites to directly perform any controlled bolting, on site machining, or flange management activity. Equipment Rental & Sale Bolt Load Verification and Assurance Equipment Modification & Design Engineering Supply of a comprehensive range of in-house calibrated hydraulic bolt tightening, on site machining, and associated ancillary equipment to support the execution of controlled bolting, on site machining, or flange management workscopes. Measure, adjust and record the bolt load induced by the chosen bolt tightening methodology. Follow up with periodic non-invasive bolt load checks. Where standard tooling is unsuitable, tool modification and bespoke equipment solutions can be provided by Hydratight's global team of Design Engineers, from one of our global technical centers of excellence. 6 hydratight.com

Contracting Model Benefits Engineering Consultancy On-site QA/QC Compliance On-site Execution Independent assurance that all client processes, procedures, and management systems represent industry best practice. Yes Yes Optional Client can remain in line with industry best practices through the development of a proper joint integrity program. Yes Yes Optional Expert support wherever and whenever the client needs it. Yes As Required As Required Provides a permanent, searchable record of every joint s history, along with a means to manage, track and control the status of every bolted joint during the planning / execution of a bolting workscope, helping to avoid errors, improve efficiency, and ensure a client s procedures are being correctly applied. Yes Yes Yes Ensures access to a source of bolt load calculations that is controlled, independently verified, and is in line with industry best practice. Yes Yes Yes Provides independent assurance that a client s Joint Integrity processes, procedures, and mandated mechanical engineering standards are being correctly implemented. Optional Yes Yes Reduce re-work costs, remove rework delays, eliminate the risk of needing second tests, and significantly reduce operational issues in relation to bolted joints, along with providing independent assurance of compliance to a client's Joint Integrity program. Bolting is a specialized skill where training is not a guarantee of competency. Controlling the competence of personnel involved in the assembly and controlled tightening of joints has consistently been proven to be a key factor in preventing leaks. No Yes Optional No No Yes The use of specialized bolting personnel minimizes rework, with all bolting executed 'right first time'. No 'search & repair'. No 'leak & fix'. No No Yes The use of high quality, calibrated bolting equipment is a key means by which control is applied to the process of bolting, ensuring the correct bolt load, and hence Joint Integrity is achieved. Verify the correct bolt load has been achieved within the specified tolerance. Prevent subsequent joint failure due to vibration, material yielding, cyclic load. Optional Optional Yes Optional Optional Optional The ability to customize allows for needed flexibility and assurance in difficult conditions. Optional As Required As Required hydratight.com 7

Our key strengths We offer a number of different services to assist clients with the development and implementation of a best practice Joint Integrity program. This specialized approach is underpinned by the training, competency, skills, and experience of our people, combined with our technical and engineering expertise. Our Training and Competency All field service personnel pass through our IMPACT (Integrity, Management, Process, Assurance, Competence, Training) program, implemented via a global network of Joint Integrity Colleges. The IMPACT program enables us to provide qualified bolted flange joint assembly personnel in accordance with renowned global regulations and guidelines. We are proud to be the only organization to make that claim. And our focus on our people is not just limited to our field service staff; all employees have the opportunity to attend modules at our Joint Integrity College. Our Technical Leadership Hydratight s Technical Authorities have long term involvement with the professional organizations that drive global standards in Joint Integrity, and we also work closely with major Operators, Contractors and OEM s to develop procedures that meet industry best practices. As a measure of our technical credibility, Hydratight became the world s only ASME PCC-1: Appendix A qualifying organization, certified by Lloyd s Register Energy (LRE) in September 2014. This confirms that our operational procedures, and Joint Integrity Assurance Manual meet ASME PCC-1: Appendix A, a benchmark industry guideline. Our technical expertise is further demonstrated in the development of our two market leading software packages: Informate Bolt Load Calculation Engine and Integrity Data Management System (idms). Informate provides optimized bolt load values and torque/tension values for any joint application, whether coded or not. It contains an extensive range of joint types, flanges, gaskets, lubricants and bolting materials. idms can build a database of flange joints and joint data needs using a project or plant s 3D model, drawings, piping specifications and bolting manual. Databases can range from a few hundred joints, to complex oil and gas projects in excess of 100,000 joints. Our unique combination of capabilities equipment manufacturer, training and competence assessor, field service provider, and industry technical authority are unique within our specialized industry and unrivalled by our peers. Hydratight is the world s first ASME PCC-1-2013 qualifying organization, following an independent audit by Lloyd s Register Energy in 2014. 8 hydratight.com

A history of establishing standards Hydratight has long been involved with the professional organizations that drive global standards in Joint Integrity, including the Engineering Construction Industry Training Board (ECITB), City and Guilds, OLF, the Energy Institute, and Step Change in Safety. 2014 Launched a Hydratight Joint Integrity College to deliver training and qualification that meets or exceeds the requirements of ASME PCC-1-2013 guidance to our own technicians, engineers and managers. Hydratight becomes the world s first ASME PCC-1-2013 qualifying organization, following an independent audit by Lloyds Register Energy. 2013 Hydratight involved in the publication of CEN republished EN1591, Flanges and their Joints - Part 4: Qualification of Personnel Competency in the Assembly of the Bolted Connections of Critical Service Pressurized Systems. 2011 Hydratight worked with the ECITB and Step Change in Safety to establish an approved route to technical competence in Mechanical Joint Integrity. 2007 Hydratight a key member of the working party which reviewed the UKOOA Guidelines and produced the UK Energy Institute s Guidelines for the Management of Integrity of Bolted Joints in Pressurised Systems (2007). 2002 Hydratight a key member of the working party which established the UK Offshore Operators Association (UKOOA) Guidelines for the Management of Integrity of Bolted Pipe Joints (2002). 2000 Hydratight pioneered the Joint Integrity Management Service and flange management software system. 1994 Hydratight worked with the UK Engineering Construction Industry Training Board (ECITB) to establish an industry benchmark training program for bolting technicians. hydratight.com 9

Our Results 200,000+ joints, flawlessly executed Joint Integrity program on world scale, multi-site, LNG construction project 30,000+ joints, flawlessly executed Joint Integrity program on major USA refinery construction Hydratight leak-free guarantee Hydratight has been tracking the outcome of implementing Assured Joint Integrity since 2000. The data collected demonstrates that obtaining a leak free start-up is very achievable provided that the joint integrity work-scope is competently executed and fully assured. To stand by our Joint Integrity Assurance program, current processes, procedures, and people, Hydratight offers a Leak Free Guarantee for every joint assigned to Hydratight under an assemble and tighten and/or Assurance Services contract. We guarantee, subject to the mutually agreed upon terms and conditions, that every joint will pass its respective integrity test the first time. The Guarantee is valid for new construction, repair or maintenance contracts, and is equally applicable to very small and extremely large work-scopes. Any joint type can be guaranteed, subject to a review by one of our global Subject Matter Experts. It is an industry expectation that Bolted Flange Joint Assemblies (BFJA s) must pass integrity tests the first time; it is no longer acceptable that joints are subject to repeated testing. Repeated tests add cost, threaten schedules, raise concerns about workmanship quality, and create doubt among those charged with managing the plant once in service. With Hydratight s Joint Integrity program, plant start-ups can occur with the confidence that assured joint integrity is no longer a wish, but a reality. No leak and fix, rework or second tests. Just right the first time, every time. Guaranteed. Refer to the Hydratight general terms & conditions at hydratight.com for more details about the Leak Free Guarantee. 10 hydratight.com

It has to be Hydratight A century after developing the technology behind hydraulic bolt tightening, Hydratight is at the forefront of bolted flange joint safety with our Joint Integrity approach. It is the cornerstone of a leak-free operation, flawless startups and cost savings. We are able to support clients worldwide through our extensive network of global locations. Work with Hydratight and you can take advantage of the industry s most qualified support and highly trained competent people. Our proven, comprehensive Joint Integrity approach is critical to a safe, productive, and profitable process operation. Our comprehensive Joint Integrity approach provides the following benefits: Create a flawless startup Achieve planned schedules Improved plant and personnel safety Provide long term assurance Identify problems in joints/materials Provide fully traceable records Realize cost savings Comply with industry best practice Only Hydratight combines the benefits of an industry technical authority, expert service provider and equipment manufacturer. Offering manufacturing facilities on two continents, offices in 35 countries and an extensive network of agents, we can provide the local support you need. Hydratight s Joint Integrity offering is not a single product or service line, it is the combination of everything we do. Contact your local Hydratight representative today, email us at jointintegrityenquiries@ hydratight.com, or visit hydratight.com for more information. hydratight.com 11

Our global network means that you can rely on the right people, products, and services wherever you are in the world. Email us at: jointintegrityenquiries@hydratight.com Or find your local representative at: hydratight.com/contact Hydratight provides support through service centers ( ) and authorized representatives ( ) HT_BR_012_0615_US