Extension of Heightened Safety Period Alert

MOM Extends Heightened Safety Period by Three Months with Additional Measures

1.  The Ministry of Manpower (MOM) will be extending the Heightened Safety Period (HSP) by three months from 1 March to 31 May 2023, with additional measures. The HSP was first introduced on 1 September 2022 for six months, with stronger measures1 to address the concerning rise in workplace fatalities. The annualised workplace fatality rate per 100,000 workers improved during the HSP, falling from 1.5 for January-August 2022, to 0.8 for September-December 2022. The full year fatality rate for 2022 was 1.3 per 100,000 workers.

2.  However, the annualised major injury rate per 100,000 workers increased from 16.8 to 18.7 in that same period. The impact of HSP was also uneven across sectors. While Construction showed the most improvement in terms of monthly average fatal and major injuries2, the Transportation & Storage sector’s monthly average fatalities3 did not improve and its major injuries4 worsened during HSP. This is of concern, as major injuries reflect persistent safety lapses at workplaces and most of these injuries have debilitating effects.

3.  Since the start of 2023, there have been four workplace fatalities. Furthermore, based on past trends, periods post-Chinese New Year have had higher workplace injury numbers as companies rush to compensate for workdays lost. Heightened alert and vigilance need to be maintained.

Additional Measures During Extended HSP

4. During the extended HSP, MOM will put in place the following additional measures, taking into account the recommendations of the International Advisory Panel last month, to complement existing ones (see Annex for existing measures):

• Require CEOs and Board of Directors to attend a mandatory half-day in-person WSH training course, for companies found to have serious WSH lapses following serious or fatal workplace accidents.
  
  
  • This is on top of existing HSP measures where companies may be barred from employing new foreign employees for up to three months. We will continue to require company leaders to personally account to MOM and take responsibility for WSH rectifications. These measures aim to strengthen WSH ownership and accountability among corporate senior leadership, and better equip them to meet their WSH responsibilities.
  • The course curriculum will be an enhanced version of the existing bizSAFE5 training for senior management. It will feature additional modules on the Approved Code of Practice for Chief Executives and Board of Directors’ WSH Duties, and root cause analysis of top incident types. MOM will notify companies whose senior leaders are required to attend this training.

• Increase maximum fines from $20,000 to $50,000 for breaches of WSH Act Subsidiary Legislation that could result in death or serious bodily injury, in order to enhance deterrence for WSH Act breaches.
  
  
• Empower workers by raising awareness of the various channels to report WSH concerns and providing protection for workers who speak up.
  
  
  • The WSH Council will launch a National WSH Campaign in April 2023, to encourage workers and members of the public to report unsafe practices at workplaces. Workers are encouraged to first report WSH concerns to their supervisors and companies for expedient resolution, before raising it to the authorities if no action is taken. This can be easily done through the SnapSAFE page on MOM’s website, and a QR code leading to the page is displayed at worksites. Workers and members of the public can also call MOM’s hotline at 6438 5122.
  • Migrant workers can also reach out to MOM through the FWMOMCare app, or reach the Migrant Workers’ Centre at 6536 2692. The Campaign will also heighten awareness of the types of protection available for workers who report or raise WSH issues.
    
    
• Introduce bite-sized versions of WSH guidance materials to better support all companies, in particular SMEs, in instilling a stronger safe operations culture. This is in addition to the earlier expansion of the StartSAFE programme to better support SMEs. The WSH Council will introduce these materials from May 2023. 

Longer-term Measures to Sustain WSH Standards

5.  Beyond the HSP and the above measures, MOM, together with the Multi-Agency Workplace Safety Taskforce (MAST)6, will consider further measures to strengthen WSH standards and practices. These include placing greater accountability on employers and senior management, enhancing safety training, reviewing incentives and penalties, and sectoral strategies.

6.  Said Senior Minister of State for Manpower, Mr Zaqy Mohamad: “We have made good progress following the HSP, with improvements seen in the annualised workplace fatality rates and within the Construction sector. This shows that tangible results in WSH performance is possible with concerted efforts from all stakeholders. However, we are still not where we want to be – which is why we remain cautious and have decided to extend the HSP with additional measures. Only with vigilance, greater ownership and continual training, can we get back on track to achieving our WSH 2028 goals of keeping our fatality rate at below 1.0 per 100,000 workers, and our major injury rates at below 12.0 per 100,000 workers.”

 Annex

Existing Initiatives for Heightened Safety Period 

Initiatives	Details
Tighter enforcement measures	Companies found to have serious WSH lapses following serious or fatal workplace accidents may be debarred from employing new foreign employees for up to three months. Chief Executives will also be required to personally account to MOM and take responsibility for rectifications.
Strengthened support for SMEs who need help to improve their WSH practices and processes, through the expansion of StartSAFE	Provide small and medium enterprises (SMEs) with more access to WSH consultants who can help them identify WSH risks and implement good WSH practices, as part of the existing StartSAFE programme. The costs of the WSH consultants are fully borne by MOM.
Targeted measures for the construction sector	A new harmonised set of disqualification criteria across all public sector construction tenders to align the evaluation criteria and temporarily disqualify contractors with poor WSH performance from participating in these tenders; A Revised Demerit Point System, where the threshold for issuing demerit points is lowered. This means that more demerit points will be issued for WSH Act breaches, and errant companies with consistently poor WSH performance will reach the penalty thresholds more quickly - after which they will be debarred from hiring foreign employees for up to 2 years.
Set up of Multi-Agency Workplace Safety Taskforce	Comprising representatives from key government agencies that oversee sectors where most fatal and major injuries occur, the Multi-Agency Workplace Safety Taskforce aims to: Identify sectoral-specific strategies that complement MOM’s cross-sectoral strategies, to contribute to a sustained reduction in workplace fatality and injury rates, and Strengthen sectoral engagements with companies to reinforce the importance of WSH.

 FOOTNOTE

See go.gov.sg/heightenedsafetyperiod

1. Monthly average number of fatalities for Construction fell from 1.6 pre-HSP to 0.3 during HSP. Similarly, monthly average number of major injuries fell from 8.3 pre-HSP to 7.3 during HSP for major injuries with higher risk of fatalities, and 5.5 pre-HSP to 4.5 during HSP for major injuries with lower risk of fatalities.
2. Monthly average number of fatalities for Transportation & Storage pre- and during HSP remained at 0.8.
3. Monthly average number of major injuries with lower risk of fatalities for Transportation & Storage worsened from 2.3 pre-HSP to 4.3 during HSP, and monthly average number of major injuries with higher risk of fatalities stayed about the same pre- and during HSP at 2.3 and 2.0 respectively.
4. bizSAFE is a nationally recognised capability building programme designed to help companies build workplace safety and health capabilities.
5. Set up on 12 October 2022, the MAST comprises representatives from Ministry of Manpower, Ministry of Sustainability and the Environment, Ministry of Transport, Ministry of National Development and Ministry of Trade and Industry.

WSH Case Studies -Falling From Heights

What is WSH Case Studies

WSH Case Studies is a free resources for various groups from management and safety professionals to supervisors and workers for improving WSH practices .

It offers insights to past  accidents that have taken place in Singapore. The case studies not only provide lessons learnt for the industry, but more importantly, they remind us to actively review our current practices and continually find ways to make our workplaces safer. Readers are encouraged to carefully think through each case, review its relevancy and context to specific workplace situations, and incorporate the lessons learnt where appropriate.

Here are accidents case studies -falling from height

Flammable Materials Dispensing Hazards

Hazards Associated With Dispensing Small Quantities of Flammable Materials

Many companies receive flammable liquids in metal drums or IBCs, and then fill smaller containers from them. While there are different types of small containers that can be used, the use of safety cans is recommended for safer handling of flammable liquids.

Using unsuitable containers such as open cans, buckets or pails is a dangerous practice as the escape of flammable vapours cannot be prevented. In general, the use of glass containers is not advised as these are easily breakable and will increase the chance of a serious spill.

The use of non-reusable glass or plastic containers is acceptable only in special cases where the required liquid purity (e.g., analytical reagent grade or higher) is affected by storage within a metal container, or if the liquid causes excessive corrosion of the metal container.

Metal Drum

Fully-filled metal drums can be very heavy and trying to move one by hand can be difficult, dangerous and bad for your back. Always use a mechanical aid (e.g., a specially designed drum cradle or trolley) for moving individual drums around. Note that drums used for storage of flammable liquids will require venting to relieve pressure build-up (e.g., due to exposure to heat) and prevent the creation of a vacuum (e.g., when liquid is being dispensed). As either pressure or vacuum can cause failure of the metal drum, the use of metal drums with automatic pressure- and vacuum-relief is essential.

Each drum vent should also be fitted with a flame arrester for protection against flashback from external ignition sources.

Dispensing from Metal Drum to Safety Can

A flammable liquid transfer pump with antistatic flexible hose may be used to facilitate safe transfer from a metal drum to a safety can. As static build-up can occur during the transfer of flammable materials from one metal container to another, bonding and grounding (earthing) is necessary before transferring to prevent the generation of electrostatic sparks and possible vapour ignition. The use of antistatic flexible cables/ wires and spring-loaded clamps may be used to achieve an effective onsite bonding and grounding solution.

Bonding both containers and grounding one of them basically “drains off” static charges and prevents the discharge of sparks. All grounding and bonding connections must be from bare metal to bare metal. It is therefore critical that all dirt, paint, rust or corrosion is removed from every electrical contact point.

Safety Can

Portable safety cans are recommended for carrying, storing and dispensing small quantities of flammable liquids. They are available in different shapes and in capacities ranging from 0.5 to 25 litres. Safety cans are usually made of metal or very low conductivity plastic.

The special feature of safety cans is that they have spring-loaded self-closing spout caps. These caps automatically open when the vapour pressure builds up inside, allowing vapours to escape and preventing rupture of the can (e.g., when exposed to fire).

The cap-operating mechanism of a safety can also cause the spout cap to automatically close once pouring is complete, or if the can is dropped. This instant cut-off capability allows onehanded control for safer dispensing without spills. Flexible metal safety hoses can be threaded into the spout cap of the safety can for added control.

Safety cans also typically house a wire mesh flame arrester screen inside its cap spout. These serve to prevent a flashback (from an external ignition source) from reaching the flammable liquid inside the cans.

Note that while this is a safety feature, it could create a hazard under some conditions. Do not store a safety can in a warm, enclosed space (such as in a vehicle) as vapours venting from a safety can may accumulate to within the flammable range and all it would take is a spark to cause a fire. For transporting small amounts of flammable liquid, use a pressure-resistant and non-venting container instead of a safety can.

Never use any safety can that is damaged. If repairs using approved replacement parts cannot restore the damaged can to a safe condition, it should be discarded once it has been properly cleaned.

Health Considerations

As flammable materials may also be toxic (i.e., harmful to human health), it is important to also take the necessary precautionary measures to minimise exposure and protect one’s health when working with a flammable material.

Check out Workplace Safety and Health (WSH) Guidelines on flammable materials which provide practical guidance on risk control measures that can be implemented to ensure the safety and health of workers who work with flammable materials daily. This Guidelines covers all industry sectors where flammable materials are used in smaller quantities.

Storage of Flammable Materials

Proper storage is essential to protect flammable materials from ignition sources. Through proper storage, fires can be prevented and better controlled (to minimise fire spread) should it occur.

This blog post focuses on fire safety measures for minor storage (involving a small cluster) of flammable materials.

As per Singapore Standard SS 532: 2007 Code of Practice for The Storage of Flammable Liquids, “minor storage” refers to the storage of flammable liquids, in various locations, in small  quantities no larger than the set quantities specified in the standard.

In general, minor storage refers to any storage of flammable liquid (i) less than or equal to 50 litres or 2.0 litres/m2, and 

(ii) not more than 200 litres per minor storage area. The criteria forclassification as minor storage, however, varies with the location of storage (e.g., in a residential building, in a commercial building, in a storage warehouse, in a laboratory, in a factory, etc) as well as the degree of flammability of the liquid being stored (e.g., extremely flammable versus highly flammable). Details of the classification criteria can be found in Table 2 of SS 532: 2007.

Note that storage of petroleum and flammable materials (P&FM) is regulated by SCDF and a P&FM storage licence may be required (depending on storage quantity) prior to bringing such materials onto your premises. More information on fire safety and P&FM licensing may be found on SCDF website (www.scdf.gov.sg).

Specific guidance on the storage of flammable gases can be found in NFPA 55: 2013 Compressed Gases and Cryogenic Fluids Code and NFPA 58: 2014 Liquefied Petroleum Gas Code. Suggested references for specific storage situations (namely, hazardous material warehouses, LPG cylinder installations and laboratories handling chemicals) are provided in the References section of this Guidelines.

Here are the recommended Practice for Minor Storage of Flammable Materials

•Keep the amount of flammable materials in storage as small as possible.

•Keep storage areas away from any heat and ignition source.

•Ensure that storage areas are well-ventilated so that flammable vapour concentrations (e.g., due to spillage or leaks) can be kept low (below the LFL).

•Store flammable materials in a cool (e.g., under a shelter or under temperature-controlled environments if necessary) and dry (to prevent metal container corrosion as well as workplace slips, trips and falls) location.

•Store flammable materials in areas accessible by emergency response teams. Ground floor storage is recommended as this will provide for easier access during an emergency.

•Store flammable materials separately, away from process and production areas and other combustible materials. This separation will reduce the spread of any fire originating from the flammables storage area. The separation will also protect the stored flammable material from exposure to fires in neighbouring areas, as well as accidental contact with incompatible materials (e.g., oxidizers).

•Store flammable liquids with flash points lower than room temperature under appropriate conditions (e.g., under refrigerated conditions). Do not store flammable liquids in a standard refrigerator meant for household use as they are not designed to be free of ignition sources. Store small quantities of flammables only in a laboratory-safe or explosion-proof refrigerator. The refrigerator’s temperature needs to be set lower than the flash point of the most readily ignitable substance stored in the refrigerator.

•Do not store flammable materials in areas that may jeopardise escape in the event of fire. In particular, make sure that storage containers do not block fire lifts, fire exits, stairwells and any aisles leading to exits.

•Store flammable materials in separate minor storage clusters separated by a suitable safety distance (see Table 16 for guidance on minimum separation distance) or fire-resistant walls.

•Store larger quantities in metal drums placed on spill control pallets or within a dike. Smaller quantities may be stored in a fire-rated (minimum 1 hour) storage cabinet designed to protect its contents from the heat and flames of an external fire.

•Do not use plastic or glass containers for storing flammable liquids unless storage in metal containers affects the purity of the liquid or if the liquid causes excessive corrosion of the metal container.

•Inspect all incoming containers to ensure that they are not damaged. Do not accept delivery of defective containers.

•Affix all flammable material storage containers with GHS labels and keep them closed when not in use.

•Practice good housekeeping and immediately clean up any spills that occur in the storage area.

•Allow only trained, authorised personnel into storage areas.

•Inspect storage areas regularly for any deficiencies such as damaged or leaking containers, poor ventilation or non-approved equipment. Correct all deficiencies as soon as possible.

•Provide storage areas with adequate firefighting and spill clean-up equipment.

Separation Distance for Minor Storage

The following guidance on minimum separation distance is based on Singapore Standard SS 532: 2007 Code of Practice for The Storage of Flammable Liquids:

Handling of Flammable Materials

Flammable materials present a fire hazard in any workplace as they are readily ignitable, easily causing a fire. Users of flammable materials are advised to consult this chapter prior to attempting any work involving a flammable material.

Recommended Practice for Safe Handling of Flammable Materials

•Consult the SDS for each material you work with, identify those that are flammable and understand their flammability characteristics. The other hazards of the material may need to be addressed such as health toxicity and reactivity, and general guidance can be found on the SDS.

•For each material identified as flammable, ensure that its container is correctly labelled (see the GHS labelling) to indicate the hazardous nature of its contents.

•Check each container to ensure that it is not damaged and that its safety features (e.g., relief vent, flame arrester, any spring-loaded mechanism) are in good condition and working properly.

•Obtain the completed risk assessment form for the work activity to be performed. Identify the existing risk controls already in place and the additional control measures that need to be taken to further bring down the risk level associated with the work activity.

•Practice good housekeeping and check that your work area is free from combustible materials.

•Familiarise with the fire emergency response plan for your specific work area.

•Inspect your work environment and confirm that there are no ignition sources (e.g., open flames, sparks, hot surfaces) in your work area.

•Put on the appropriate PPE (e.g., safety goggles, fire-retardant coveralls and gloves) prior to any work activity involving flammables. Be familiar with the correct PPE for day-to-day operations, as well as for emergencies.

•Work behind a splash guard or face shield when working with a machine or process that ejects flammable or combustible liquids.

•Use only the minimum amount of flammable material for your work. It is good practice to keep no more than a day’s supply of flammable material in your immediate work area. Return any leftover material to the proper storage area or cabinet at the end of each work day.

•Bond and ground metal containers before transferring flammable liquids (or powders). •Where practicable, carry out the transfer of flammable materials under local exhaust ventilation or via closed system transfer (e.g., through fixed piping systems) so as to avoid the creation of flammable vapour concentrations in the atmosphere. If this is not possible, ensure that the work environment is well-ventilated before dispensing or using a flammable material.

•When transferring a flammable material, work in an area where a fixed gas detector has been installed or use a portable gas detector to continuously monitor the work environment. Programme the detector to raise an alarm before dangerous concentrations are reached.

•Always keep containers of flammable material closed when not in use in order to minimise the escape of flammable vapours.

Bulk Handling of Flammable Materials

ISO tank containers (i.e., tank containers built to standards set by the International Organisation for Standardisation) are commonly used for the bulk transportation of chemicals (including flammable materials) within Singapore via the use of prime movers and trailers. ISO tank containers are made of stainless steel and come in a variety of sizes ranging from 27,000 to 40,000 litres

For transporting smaller bulk quantities of chemicals, Intermediate Bulk Containers (IBCs; size ranging from 1,000 to 1,250 litres per IBC) and cylindrical metal drums (200 litres per drum) are typically used.

Other types of containers used for carrying flammable materials include tube trailers (e.g., for transporting compressed hydrogen) and gas cylinders (e.g., for transporting liquefied petroleum gas).

For work involving bulk loading/ unloading of a flammable material, it is important to ensure that the following are made available on-site at the loading/ unloading facility prior to work commencement:

•automatic water sprinkler system

•fire extinguisher(s)

•emergency stop button

•eye wash and safety shower

•first aid box

•spill control kit

Loading/ Unloading of ISO Tank Containers

An ISO tank container can be loaded or unloaded from its top or bottom. On a standard tank container, there is a manhole and at least one valve at its top, and another at its bottom. Loading and unloading is achieved by connecting hoses from the loading/ unloading facility to the valves of the tank container. Loading or unloading is then carried out by gravity, pressurisation or pumping. 

For safe loading/ unloading of a flammable material to/ from a tank container, it is critical to prevent static build-up through electrical bonding and grounding. Grounding (earthing)connections are typically provided at the bottom front and rear of each ISO container to prevent differences in electrical potential arising between the tank container, the body of the vehicle, the piping used and the ground during the loading/ unloading operation.

Proper bonding and grounding (earthing) will prevent the formation of electrostatic sparks which can ignite the vapours of the material being transferred.

Further guidance on the safe handling of chemicals in logistics operations is available in SCIC’s Guidebook on Transport & Handling of Dangerous Goods.

Loading/ Unloading of Intermediate Bulk Containers and Pallets of Metal Drums

IBCs are reusable industrial containers designed for the transport and storage of bulk liquid and granulated materials. The most common IBC is the single-use plastic composite IBC – a white/ translucent cube-shaped plastic container (typically made of polyethylene) housed within a tubular galvanized iron cage. For flammable materials, the use of metal IBCs (fitted with a venting device) is recommended for enhanced fire resistance. IBCs are designed to be stackable and moved with a forklift or a pallet jack.

An alternative to the use of IBCs is the use of palletised metal drums (typically 4 to 6 drums per pallet). Each pallet of drums (also known as barrels; typically made of steel) is also stackable and can be moved with a forklift or a pallet jack.

When loading/ unloading an IBC or a pallet of drums from the back of a lorry/ truck or when moving it with a forklift within the work area, extra care must be taken not to puncture or drop the containers as this will cause a spill resulting in the formation of a flammable vapour cloud.

When filling an IBC or drum with a flammable liquid, proper bonding and grounding is again necessary to prevent the formation of electrostatic sparks during the transfer. Specially designed drum funnels, fitted with a flame arrester, may be used to affect the safe transfer of flammable liquids. A large diameter funnel will also help to minimise the risk of spills. 

Safe Handling of Flammable Materials

 SAFE HANDLING OF FLAMMABLE MATERIALS

There were two separate incidents involving flammable materials in the first two weeks of March 2023. 

On 7 March, an explosion in a room caused a section of the building wall to collapse. Preliminary investigations revealed the explosion was caused by the accumulation of flammable vapours from a waste oil tank placed in a lift motor room. 

On 13 March, a large fire occurred at an industrial chemical blending and storage warehouse. Preliminary investigations revealed the fire started from an adhesive dispensing unit containing flammable solvents. The fire eventually engulfed the warehouse and its connecting production areas. 

While no one was badly injured, both incidents highlight the need for workplaces to better manage flammable materials as workplace fires can lead to mass casualties and cause extensive damage to assets. 

As we are still in the midst of the Heightened Safety Period, the WSH Council calls on all companies storing or handling flammable materials, including flammable waste, to undertake an urgent assessment of their safety measures. Examples of flammable materials include petroleum products, volatile organic solvents, and all substances listed in the Fourth Schedule of the Fire Safety (Petroleum and Flammable Materials) Regulations. Workplaces storing or handling flammable materials should ensure the effective implementation of the following measures: 

Risk assessment 

• Use Safety Data Sheet (SDS) information as input to risk assessments.
 • Look out for advice and precautions on storage, handling, and disposal in the SDS. 

Training and awareness 

• Place the control of flammable materials under a competent person and allow only authorised workers who have been trained on the hazards and precautions to take, to handle flammable materials. 

• Provide readily accessible copies of Safety Data Sheets to persons using or handling flammable materials. 

Storage 

• Ensure that storage areas are well-ventilated to prevent flammable vapour accumulation. Flammable storage must be segregated from heat and ignition sources e.g. open flames, hot work, sparks, hot surfaces). Examples include fire-rated or flammable storage cabinets, and dedicated storage areas with fire protection provisions.
• Optimise the quantity of flammable materials stored on site to as low as reasonably practicable, considering the required quantities for use during production.
• Use spill control pallets or build dikes/curbs with adequate drainage to contain potential spills.
• Affix GHS labels for flammable raw material and product storage containers.
• Provide flammable material storage areas with adequate firefighting equipment. 

Handling
• Ensure risk control measures are implemented to address hazards associated with flammable materials, including:

•  Implementing effective control of ignition sources; 
• Bonding and grounding of metal containers to prevent ignition by electrostatic discharge during flammable liquid transfers; 
•  Transferring flammable materials under local exhaust ventilation to prevent accumulation of flammable vapours; 
• Keeping containers of flammable material closed when not in use to minimise fugitive emissions of flammable vapours; and 
• Installing gas detectors or using portable gas detectors to continuously monitor the work environment where practicable. • Ensure workers put on personal protective equipment (e.g. fire-retardant clothing, face shield, respirator, gloves and safety boots) when working with flammable materials.

• Plan and implement an effective emergency response plan. 

Disposal
• Label flammable waste containers according to the SS 603: 2021 Code of Practice for Hazardous Waste Management.
• Dispose flammable materials separately from general waste.
• Check for chemical compatibility before disposing waste into collection tanks. Never mix waste with another type of waste unless the constituents in both waste sources are known. If necessary, conduct laboratory tests to ascertain hazardous substances before combining waste from different sources.
• Treat mixtures of flammable liquids with other less flammable liquids, as flammable. For example, if waste kerosene is mixed with more flammable naphtha, the mixture should be stored and disposed as a flammable liquid.
• Monitor flammable material waste for prompt collections by Toxic Industrial Waste Collectors to minimise on-site waste inventory. 

For more information, refer to the WSH (Risk Management) Regulations, Fire Safety (Petroleum and Flammable Materials) Regulations, Environmental Public Health (Toxic Industrial Waste) Regulations, SS 532: 2016 Code of Practice for the Storage of Flammable Liquids, SS 603: 2021 Code of Practice for Hazardous Waste Management, and the WSH Council's Code of Practice on WSH Risk Management, WSH Guidelines on Management of Hazardous Chemicals Programme, and WSH Guidelines on Flammable Materials.  

Below are safe practices when handling flammable liquids

Charging in flammable liquids into blending vessel.

Use only explosion-proof portable air-operated pump.

Bond the flammable storage drums of raw material before charging.

Bond one of the raw material drums to the grounded explosion-proof portable air-operated pump before charging.

Ground the explosion-proof portable air-operated pump by earth wire with clamp to the fixed-grounding point.