Working time regulations in connection with offshore oil and gas operations

June 2016

Regulations on working time, including requirements on maximum weekly working time, daily rest periods, days off and night work.

This guideline concerns the Offshore Safety Act regulations on working time, rest and days off as well as the provisions in Executive Order no. 1204 of 15 December 2015 on Certain Aspects of the Organisation of Working Time in connection with Offshore Oil and Gas Operations etc. (Working Time Executive Order) regulating maximum weekly working time, daily rest periods, days off and night work.

The guideline concerns work performed by the employee at the enterprise with which the employee has established a contract of employment.

The guideline concerns offshore work, i.e. work performed at an installation, connected infrastructure or in connection with pipelines, transport time to and from such facilities, and work ashore performed in connection with transport to or from installations etc., which relates directly to the work offshore.

The guideline primarily addresses enterprises which have employment relationships with employees performing offshore work, but also operators and owners who have a duty to ensure that enterprises performing work for these operators and owners (contractors) comply with the regulations on the organisation of working time in connection with offshore oil and gas operations etc. Furthermore, the guideline addresses employees covered by the regulations.

The guideline does not include agreements on remuneration and may thus contain wording that vary from the wording used in such agreements.

The most important rules

Taking into account the duration of the offshore work period, including the daily working time, employees must be given reasonable opportunities for rest periods, days off and breaks, which are adjusted to the special conditions of the workplace and the employee, with a view to reducing the health and safety risks of the work to a level as low as reasonably practicable (ALARP), see section 51(3) of the Offshore Safety Act. Contents of the guideline:

1. Definitions
2. Scope
3. Duties
4. Main regulations
5. Exceptions to the main regulations where no agreement is required
6. Agreements on derogations from rest periods
7. Risk management
8. The role of the Danish WEA

1. Definitions

1.1. Working time

Any period during which the employee is at the employer's disposal, i.e. performs work. Time spent at an installation or connected infrastructure, when the employee is not performing work, is not considered working time, but a rest period.

1.2. Rest period

Any period which is not working time.

1.3 Day off

A rest period of 24 consecutive hours ashore. A day off is calculated from the end of the rest period immediately following the conclusion of the offshore work.

1.4. Night time

Any period of not less than seven hours which includes the period between midnight and 5:00 am. Night time runs from 10:00 pm to 5:00 am, unless another period has been agreed.

1.5. Night worker

An employee who

a) as a normal course works at least three hours of his daily working time during night time, or

b) works at least 300 hours during night time within a 12-month period.

1.6. Shift work

Any method of organising work in shifts whereby employees succeed each other at the same work stations according to a certain pattern, including a rotating pattern, and which may be continuous or discontinuous, entailing the need for employees to work at different times over a given period of days or weeks.

1.7. Shift worker

Any employee whose work schedule is part of shift work.

1.8. Offshore work

Work performed mainly on or from an installation, connected infrastructure or in connection with pipelines, and which directly or indirectly relates to offshore oil and gas operations.

Transport to and from the installation is considered offshore work, and is counted from the starting time, as scheduled by the employer, at the transport terminal (airport or waiting area for vessel) until arrival at the installation etc., or from departure from the installation etc. until the employee can leave the transport terminal.

Any time period in addition to this (typically ashore in Denmark, but also elsewhere) during which the employee is at the employer’s disposal for work related to work offshore is also considered offshore work if the employer has stipulated the location of the employee during the period.

The precondition for work ashore in Denmark or elsewhere to be considered offshore work is that such work has been commenced within 24 hours after the end of the daily rest period following the time at which the employee left the transport terminal. This means that work typically commenced within 11 hours (the rest period) + 24 hours after the employee left the transport terminal, is offshore work. If the period following the rest period exceeds 24 hours, this will be considered a day off, and the work performed following this period is not offshore work.

Time spent on completing statutory training to perform work at installations will also be considered offshore work. See WEA guideline 65.1.4 on training and competence.

Finally, time spent on completing other training/education activities will be considered offshore work if such activities are required by the employer.

Work performed for the employer ashore or abroad (onshore or offshore), which is not covered by the definition of offshore work, is not subject to the regulations in the Offshore Safety Act, but rather to the Working Environment Act and the Act on implementing parts of the Directive on working time, to the extent that this legislation applies.

2. Scope

The guideline applies to work in connection with offshore oil and gas operations etc., i.e. all activities associated with an installation, connected infrastructure or pipelines, including design, planning, construction, installation offshore, as well as the operation, modification and decommissioning thereof, relating to exploration, production and pipeline transport of oil and gas as well as other substances and materials between an offshore installation and onshore installation, or between several offshore installations.

It makes no difference in which country a mobile installation is registered, or where the owner comes from. As long as the installation is operating in Danish territorial waters or continental shelf areas, the work will be covered by these regulations.

The guideline also applies to operations undertaken in connection with an installation or connected infrastructure if the activities are subject to the Act on the Use of the Danish Subsoil and where these operations carry safety or health risks. This may include activities such as storage of CO₂ or other substances from installations carrying out offshore oil and gas operations.

The working time regulations apply to all employees performing offshore work, regardless of whether they are employed, for instance, by the operator and the owner, respectively, or a contractor, unless the exception in section 2 of the Working Time Executive Order (managerial functions or work of an unusually independent nature, see sections 5.7 and 5.8) applies.

An example of this could be an employee who has an agreement with a construction company ashore, and who is requested to perform work at an installation where the operator and the owner, respectively, have the authority to give instructions to the employee and thus act as employers as described in the Offshore Safety Act. In this case, the construction company will be responsible for complying with the rules in the Working Time Executive Order.

3. Duties

The enterprise which has established a contract of employment with the employee must ensure that, as a minimum, the rights of the employee comply with the regulations of the Working Time Executive Order. Where a contract of employment is transferred to another enterprise, this enterprise must ensure the employee’s rights pursuant to the Working Time Executive Order in connection with organisation of the employee’s work.

The offshore installation manager must ensure that the installation is operated in accordance with current legislation, including the regulations in the Working Time Executive Order. The individual employers must ensure that any health and safety risks associated with the work have been identified, assessed and reduced to a level as low as reasonably practicable. This includes risks associated with working time, such as night work.

The offshore installation manager and the individual employer are both responsible for ensuring that the working time regulations concerning offshore work are observed, and that for each individual employee the number of working hours, including overtime, does not exceed 48 hours a week on average over a 12-month period. If the employee is performing offshore work ashore at the same time, e.g. course activities or administrative work which is immediately related to the work performed at the installation or connected infrastructure, the offshore installation manager and the individual employer at the installation must ensure that the total working time associated with the offshore work does not exceed 48 hours on average.

4. Main regulations

The main regulations for the organisation of work at offshore oil and gas operations are as follows.

4.1. Maximum weekly working time

The total working time per week, including overtime, calculated as an average over 12 months, cannot exceed 48 hours. The maximum number of working hours during any 12-month period is thus 47 x 48 hours = 2256 hours. Thus, the calendar year is not used as the basis for determining whether the requirement has been met. Going back 12 months from any given date must result in a total number of working hours of no more than 2256 hours during such period.

When calculating the working time, the total number of hours of work performed for an employer is included, i.e. the time during which offshore work has been performed, as well as the time during which the employee has been involved in other work activities for the same employer. Even though such other work activities are not subject to the regulations in the Working Time Executive Order, which only applies to offshore work, they must be taken into consideration in the calculation.

Holidays and extra days off as well as illness are not included in the calculation of the maximum number of working hours.

If the employee has been employed for less than 12 months, the reference period will be calculated from the time at which the employment relationship commenced.

4.2. Length of offshore work

The length of offshore work must not exceed 28 consecutive days. This means that the consecutive time period during which offshore work is performed, be it offshore or elsewhere, must not exceed 28 days.

4.3. Rest periods and days off

Working time must be organised so as to allow a rest period of at least 11 consecutive hours within every period of 24 hours.

This means that a rest period of 11 consecutive hours must be allowed during a period of 24 hours, calculated backwards from the time at which the calculation of the working time commences. In order to determine whether this requirement has been met, a timeline may be used on which a reference point during the working time is selected. During a period of 24 hours going back from this point, the employee must have been allowed 11 consecutive hours of rest.

The average weekly working time must be considered when determining the number of days off between periods of offshore work.

Following a period of offshore work and the subsequent rest period, the employee must be allowed at least three days off, consecutive as far as possible, for each 14 days of offshore work. The wording “as far as possible” means that it is acceptable that the employee breaks up the days off period, if this is deemed necessary in light of the operations of the enterprise or the employee’s own circumstances.

Example: Three employees have worked offshore for 14 days and fly ashore at 9 am, just after breakfast at the installation on the 15th day. After they have checked out of the airport in Esbjerg at 11 am, they attend an obligatory course with a duration of 4.5 days, after which they start their day off. They go straight from the airport to the course, which starts with lunch at 12 noon and ends at 6 pm, after which they are off until the next day at 8 am. In this case, the rules on rest periods are complied with because the working day started at 9 am. The same goes for the remaining course days. The length of the offshore work (work at the installation, including transport to the installation (14 days), transport from the installation (0.5 days) and course activities (4.5 days)) totals 19 days, which means that the employees are entitled to four days off, consecutive as far as possible, starting on the day after the end of the course. In accordance with their agreement with the employer, the employees have 21 days off after the offshore work. As they were attending a course for some of these 21 days, the days must be counted as offshore work and not as days off. One of the employees then works another seven days for the enterprise following two days off. This work is not included in the previous offshore work. After this, the employee is off until going offshore again, i.e. after seven days. This last week’s work is thus subject to the regulations in the Working Environment Act as regards the daily rest period and weekly day off, but must be included in the calculation of the average weekly working time. In the example, the employee has been allowed four consecutive days off in accordance with the legislation, although not immediately following the offshore work.

4.4. Breaks

An employee with daily working time of more than six hours is entitled to breaks of a length appropriate to the purpose of the breaks. The purpose of the breaks is to counter the health and safety risks facing the employees depending on the nature of the work.

Collective agreements or agreements between the relevant employer and workers' organisation may stipulate more detailed provisions on the determination of breaks, including length and criteria for allocation. If the framework is laid down in an agreement between the individual employer and an employees’ organisation, the specific terms of the agreement may be decided locally at the installation.

If collective agreements or other agreements do not contain provisions on breaks, breaks will be scheduled according to the general guidelines for the organisation of working time. As part of the organisation of working time, the purpose of breaks must be taken into account.

4.5. Night work

Employers which employ night workers on a regular basis must notify the Danish WEA of this upon request.

Limitation of daily working time

Night workers whose work involves special hazards or heavy physical or mental strain are not allowed to work more than eight hours in any period of 24 hours during which they perform night work.

The eight hours are calculated as an average over a period of 14 days.

What type of work is deemed to involve special hazards or heavy physical or mental strain has to be determined in connection with the risk assessment of the installation.

Medical examinations

The employer must offer employees free occupational health examinations before they start working night shifts and, subsequently, within regular time intervals of no more than three years.

The occupational health examinations must be carried out by occupational health-care clinics or occupational health-care departments, including occupational health-care outpatient departments, or by other similarly qualified entities or persons. The examination can be carried out by the employee’s general practitioner or by a physician appointed by the employer, provided that the physician has sufficient experience in the area of occupational health.

“Free” means that the health check is carried out without any costs or loss of income for the employee. The employer must also ensure that the health check is carried out within working hours as far as possible.

The occupational health examinations offered are voluntary for the employee.

While the right to be offered health checks is governed by the Working Time Executive Order, the results of the assessment are covered by the Act on the use of health data, etc. on the labour market. This means, among other things, that the employer must inform the Danish WEA prior to the planned health check. See also WEA guideline D.7.5 with regard to health checks in connection with night work.

If employees incur health problems in relation to night work, they must be transferred whenever possible to day work to which they are suited. Such health problems must be documented by means of a statement from a physician, for instance the employee’s general practitioner, a specialist doctor or an occupational health-care clinic. As a general rule, a physician is not allowed to pass on information to the employer without the employee’s consent.

5. Exceptions to the main regulations where no agreement is required

Exceptions from the main regulations, see section 4, are described below, and can be specified by the employer alone without requiring any agreement between the parties, as opposed to the derogations in section 6.

5.1. Shift work

The daily rest period may be reduced from 11 hours to a minimum of eight consecutive hours for shift work, if the employee changes shift and cannot take a daily rest period of 11 hours between the end of one shift and the start of the next.

5.2. Special activities

The daily rest period may be reduced, however to no less than eight hours

1) in the case of operations involving several short periods of work split up over the day; or

2) in the case of operations involving the need for continuity of service or production, for instance work which cannot be interrupted on technical grounds.

Operations covered by number 1) could be logging or stimulation of wells, whereas activities covered by number 2) could be repair work after a sudden breakdown of equipment or similar, the functioning of which is required for continued production, and which cannot be attributed to the force majeure rule in section 5.4.

5.3. Night work

The regulations on limited working time for night workers performing hazardous work can be derogated from.

5.4. Unforeseeable events (force majeure)

Where the normal operation of an enterprise is being, or has been, disturbed by acts of nature, accidents or an imminent risk of accidents, breakdowns of machinery or similar unforeseeable events, the main regulations in sections 4.2-4.5 on maximum duration of offshore work, daily rest periods, number of days off between offshore work periods, breaks and night work may be deviated from, to the extent necessary, until normal operation has been restored.

The circumstances must be beyond the employer’s control as well as exceptional and unforeseeable. It is furthermore a condition that the consequences of the circumstances could not have been avoided despite the exercise of all due care. Illness among the employees is not usually considered force majeure.

Derogations must be recorded in a manner which is accessible to the Danish WEA. Registrations may be either on paper or in electronic form.

5.5. Offshore medics

For employees involved in the treatment and care of people, the main regulations in sections 4.2-4.4 concerning rest periods, the maximum length of offshore work and breaks may be derogated from to the extent necessary. At permanently manned installations, health services with offshore medics have been established. These medics are covered by the above derogation possibility.

Derogations must be recorded in a manner which is accessible to the Danish WEA. Registrations may be either on paper or in electronic form.

5.6. Compensatory rest period

When the rest period is reduced in the situations described in sections 5.1-5.5, compensatory rest periods must be provided which, as a general rule, must be scheduled immediately after the work period, or, where in exceptional circumstances and for objective reasons this is not possible, appropriate protection must be offered.

Appropriate protection may be in the form of extraordinary safety measures, administrative measures or measures related to the organisation of work, including breaks and periods of less straining work.

5.7. Managers

The principles in section 4.1-4.3 concerning weekly working time, the length of offshore work, rest periods and days off do not apply to certain supervisors.

This exception is conditional on the supervisors in question having the powers to make independent decisions in situations in which, due to the special nature of the work performed, the duration of the working time is not measured or determined in advance, or in situations in which they can determine their own working time. As a consequence of this, the supervisors are not obliged to monitor the work of the people they are supervising, or follow a predetermined rotating pattern.

The installation manager (platform supervisor or OIM) at an installation is deemed to satisfy this criterion automatically.

Supervisors such as foremen and others who are directly supervising and in contact with the employees in a certain field of work are covered by the general regulations on daily rest periods, since they are not included in the condition for exception.

5.8. Exemption of certain other employees

Other employees who have the powers to make independent decisions in situations in which, due to the special nature of the work performed, the duration of the working time is not measured or determined in advance, or in situations in which the employees can determine their own working time, are not covered by sections 4.1-4.3 on the length of offshore work, rest periods, maximum weekly working time and days off.

Examples include persons called out to an installation to perform special tasks characterized by short-term but intensive work, e.g. repair work on broken-down equipment, or persons performing logging of wells.

5.9. Exemptions

The Danish WEA may, in exceptional circumstances, when deemed reasonable and justifiable from a health and safety perspective, grant exemptions from the provisions of the Executive Order, provided that doing so is commensurate with the Working Time Directive.

6. Agreements on derogations from rest periods

6.1.General

The daily rest period of 11 hours may, to a limited extent, be reduced to eight hours through an agreement between the employers' organisation and the workers' organisation (collective agreements). When making such agreements, the health and safety risks resulting from the reduction must be taken into account. For offshore work, an agreement can only involve a reduction, but not a postponement of the daily rest period.

An employer who is covered by the collective agreement and an employee who is not covered by the collective agreement can make an agreement on reducing the daily working time to the same extent and under the same conditions as stipulated in the collective agreement. The precondition is that the reduction of the rest period is necessary in order to follow the same working time as the employees covered by the agreement. Examples of such employees are supervisors or consultants.

The agreements must be in writing.

6.2. Limited extent

The rest period may only be reduced to a “limited extent”.

The limitation in how often and to what extent the rest period may be reduced must be determined under the conditions

– that the reductions are generally justifiable from a health and safety perspective,

– that there is ”room for” the additional overtime causing the reduction in the rest period within the maximum average weekly working time of 48 hours.

The limitation in how often and to what extent the rest period may be reduced must be determined by the collective agreements mentioned in section 6.1 in consideration of the above conditions.

When assessing whether a reduction in rest periods has a limited extent, the Danish WEA will base its judgment on the following calculation examples. The calculation examples are based on the assumption that offshore work is performed on or from an installation, connected infrastructure or in connection with pipelines. If the employee is performing offshore work ashore, e.g. course activities or actual work, the offshore installation manager and the individual employers at the installation must ensure that the total working time associated with the offshore work does not exceed the number of hours agreed between the enterprise at which the employee is employed and the operator and the owner, respectively.

The calculation examples may be derogated from in cases where the Danish WEA assesses that specifically agreed reductions meet the above conditions. The examples are based on a working time of 12 hours followed by 12 hours of rest for each 24 hour period.

If the transport time to and from the installation is not included in the periods mentioned in the examples below, this must be taken into account when calculating excess time for reduction of rest periods and offshore work ashore.

Under different circumstances, on the basis of a specific assessment, other figures may be used in the calculations.

a) 14 days of offshore work - one person works for two weeks and then takes three weeks off:

In this case, the employee normally works 14 times 12 hours = 168 hours. In one year, there are 52/(2 + 3) = 10.4 periods of offshore work, resulting in 1,747.2 hours of work during a 12-month period.

This means that additionally a person can perform a maximum of 2,256 minus 1,747.2 hours = 508.8 hours of offshore work during a 12-month period, which corresponds to 48.9 additional hours during one period of offshore work.

If a person works 13 hours per day, thus still observing the 11-hour rule, the person works 14 times 13 hours = 182 hours, which corresponds to 1,892.8 hours during a 12-month period.

This means that additionally a person can perform a maximum of 2,256 minus 1,892.8 hours = 363.2 hours of offshore work during a 12-month period, which corresponds to 34.9 additional hours during one period of offshore work.

The rest period cannot be reduced to less than eight hours.

To make sure it is justifiable, a reduction in the daily rest period to eight hours should not take place more than two-three times during the period where offshore work is performed.

Reductions to nine or ten hours may be agreed four or more times during the offshore work period, however not every day.

All reductions must be distributed evenly over the 14 days of offshore work.

b) 14 days of offshore work - one person works for two weeks and then takes four weeks off:

In this case, the employee normally works 14 times 12 hours = 168 hours. In one year, there are 52/(2 + 4) = 8 2/3 periods of offshore work, resulting in 1,456 hours of work during a 12-month period.

This means that additionally a person can perform a maximum of 2,256 minus 1.456 hours = 800 hours of offshore work during a 12-month period, which corresponds to 92.3 additional hours during one period of offshore work.

If a person works 13 hours per day, thus still observing the 11-hour rule, the person works 14 times 13 hours = 182 hours, which corresponds to 1,577.3 hours during a 12-month period.

This means that additionally a person can perform a maximum of 2,256 minus 1,577.3 hours = 678.7 hours of offshore work during a 12-month period, which corresponds to 78.3 additional hours during one period of offshore work.

The rest period cannot be reduced to less than eight hours.

To make sure it is justifiable, a reduction of the daily rest period to eight hours should not take place more than two-three times during a period of offshore work.

Reductions to nine or ten hours may be agreed four or more times during the offshore work period, however not every day.

All reductions must be distributed evenly over the 14-day period.

c) 21 days of offshore work - one person works for three weeks and then takes three weeks off:

In this case, the employee normally works 21 times 12 hours = 252 hours. In one year, there are 52/(3 + 3) = 8.7 periods of offshore work, resulting in 2,184 hours of work during a 12-month period.

This means that additionally a person can perform a maximum of 2,256 minus 2,184 hours = 72 hours of offshore work during a 12-month period, which corresponds to 8.3 hours during one period of offshore work.

The rest period cannot be reduced to less than eight hours.

In order to observe the maximum average weekly working time of 48 hours, a reduction of the daily rest period to eight hours cannot take place more than 18 times during a calendar year. This corresponds to a maximum of two times during a period of offshore work. On the remaining days, the rest period is assumed to be 12 hours.

Alternatively, minor reductions of the daily rest period, e.g. reductions to nine or ten hours, may take place no more 24 or 36 times respectively during a calendar year. This corresponds to a maximum of three-four times during a period of offshore work. On the remaining days, the rest period is assumed to be 12 hours.

Alternatively, a daily rest period of 11 hours can take place no more than 72 times during a calendar year, which corresponds to approx. eight times during a period of offshore work. On the remaining days, the rest period is assumed to be 12 hours.

All reductions of the rest period must be distributed evenly over the period of offshore work.

Observing the rule of a maximum average weekly working time of 48 hours thus requires accurate monitoring of the working time.

d) 28 days of offshore work - one person works for four weeks and then takes four weeks off:

In this case, the employee works 28 times 12 hours = 336 hours. In one year, there are 52/(4 + 4) = 6.5 periods of offshore work, resulting in 2,184 hours of work during a 12-month period.

This means that additionally a person can perform a maximum of 2,256 minus 2,184 hours = 72 hours of offshore work during a 12-month period, which corresponds to 8.3 hours during one period of offshore work.

The rest period cannot be reduced to less than eight hours.

In order to observe the maximum average weekly working time of 48 hours, a reduction of the daily rest period to eight hours cannot take place more than 18 times during a calendar year. This corresponds to a maximum of three times during a period of offshore work. On the remaining days, the rest period is assumed to be 12 hours.

Alternatively, minor reductions of the daily rest period, e.g. reductions to nine or ten hours, may take place no more than 24 or 36 times respectively during a calendar year. This corresponds to a maximum of four-six times during a period of offshore work. On the remaining days, the rest period is assumed to be 12 hours.

Alternatively, a daily rest period of 11 hours may take place no more than 72 times during a calendar year, which corresponds to approx. 11 times during a period of offshore work. On the remaining days, the rest period is assumed to be 12 hours.

All reductions of the rest period must be distributed evenly over the period of offshore work.

Observing the rule of a maximum average weekly working time of 48 hours thus requires accurate monitoring of the working time.

6.3. Compensatory rest period

Appropriate protection may be in the form of extraordinary safety measures, administrative measures or measures related to the organisation of work, including breaks and periods of less straining work.

7. Risk management

The physical framework and the offshore work must be organised so as to allow the employee access to breaks, undisturbed rest, restitution and rest periods. Furthermore, the nature of the tasks performed by the employee during working hours as well as any impacts of the work, e.g. noise, must be taken into account when organising the working time.

To reduce the health and safety risks of the work to a level as low as reasonably practicable (ALARP), the risk assessment must include an assessment of the special health and safety risks associated with night work, work organised according to a specific work rate, or a reduction of the daily rest period. Appropriate measures must be taken to reduce these risks to a level as low as reasonably practicable. With regard to work organised according to a specific work rate, the measures must take special consideration of the general principle of adapting work to the worker, with a view, in particular, to alleviating monotonous work and work at a predetermined work-rate. The measures must generally be adapted to the specific nature of the work, in particular by considering additional breaks during working time and their length.

It should be emphasised that supervisors and others who are exempt from the regulations on length of offshore work, rest periods, breaks, maximum weekly working time and days off are still entitled to rest periods, days off periods and breaks, which are determined on the basis of a specific risk assessment in accordance with the ALARP principle.

The operator and the owner, respectively, must establish and maintain a management system for health and safety and prevention of major environmental incidents in connection with offshore oil and gas operations, ensuring and documenting compliance with the legislation.

Consequently, the management systems of the operator and the owner, respectively, must include procedures, or similar, which ensure and document compliance with the Working Time Executive Order, including the possibilities for derogation following from this guideline, and that health and safety risks and risks of major environmental incidents are reduced in accordance with the ALARP principle.

For example, it must appear from the management system how the working time has been organised for individual groups of employees, and where and by whom any deviations are registered.

Furthermore, the management system must ensure and document observance of regulations on health checks offered to employees, to the extent that the operator and the owner, respectively, have established a contract of employment with the employee. In other cases, the enterprise with which the employee has established a contract of employment is responsible for offering health checks.

8.The role of the Danish WEA

The Danish WEA will not approve or allow deviations from the main regulations in section 4, but may grant exemptions. In addition, the Danish WEA supervises the observance of the regulations.