Trade Adjustment Assistance

Document Sample
Trade Adjustment Assistance Powered By Docstoc
					Classroom Training                                                                                  Page 1 of 11

                                       Trade Adjustment Assistance
                                  Washington State Operational Procedures

This document has been formatted for use on this web site. It contains hyperlinks that enable the
user to jump directly to specific areas within the document or to related documents.

EFFECTIVE DATE:                            April 17, 2007
TAA PROCEDURE NUMBER:                      OP-3045
SUBJECT:                                   Classroom Training Procedures

These procedures explain the actions and forms necessary for workers eligible for Trade Adjustment
Assistance (TAA) to enter and complete a classroom training program. Refer to TAA Classroom
Training Policy #3045.


              Background | Determination of Entitlement Form 57 | Initial Needs Assessment
                Waiver from Training | Revocation of Waiver | Comprehensive Assessment
                     Training Research | Approval of Training Checklist | Remedial Education
                       Individual Training Plan (CT3) | Request for Training Approval (858)
                            Authorization to Release Information | Exception to Cost
                      Funding Resource Map | Books and Supplies | Tools and Equipment
              Issuing, Inventorying, & Storing Tools/Equipment | Participant Responsibilities
            Transportation, Subsistence or TRA Allowance Responsibility Attendance Forms
      Revision Checklist | Leave of Absence | Denial of Training Allowances | Training Checklist
      SKIES Revocation of Waiver | SKIES Entries | SKIES Deobligating | Supersedes | Inquiries


   Classroom Training Checklist | Determination of Entitlement Form 57 | Training Research (CT1)
          Approval of Training Checklist | Request for Training Approval and Allowances (858)
            Individual Training Plan (CT3) | Weekly Attendance and Benefits Request (858A)
                          Monthly Attendance | Waiver from Training Guidelines (CT15)
                      Authorization to Release Information (CT4) | Exception to Cost (CT5)
                      Funding Resource Map (CT6) | Books and Supplies Agreement (CT7)
         Tools and/or Equipment Agreement (CT8) | Classroom Training Responsibilities (CT9)
           Transportation, Subsistence or TRA Allowance (CT10) | Revision Checklist (CT11)
                     Leave of Absence (CT12) | A-19 Transmittal | Initial Needs Assessment
                       Comprehensive Needs Assessment | SKIES Training Service Plan
                          SKIES Revocation of Waiver | Eligible Training Provider’s List
Classroom Training                                                                                      Page 2 of 11

There are several steps that must occur before a worker can enter training approved by a TAA
Service Provider. Refer to Classroom Training Checklist.

Only one training program can be approved under a specific Trade Act certification. When approving
training, remember the participant must be “job ready” upon completion of the training program.
Before training is approved each participant’s SKIES Service Plan must clearly identify the
occupation they will be trained in.

A participant who withdraws from training to return to work for a new employer or for their trade
affected employer will not be allowed to return to TAA funded training.

If they return to permanent full-time work which pays 80% of their prior wage and requires skill levels
equal to or higher than their Trade affected employment they are no longer eligible to receive TAA

Classroom training for workers eligible for Trade Act is based on the availability of federal funds.

The forms necessary for a participant to commence, remain in and conclude TAA approved training
are listed in order of priority of use within these procedures.

Make certain participant is entitled to TAA by obtaining a copy of the participant’s Determination of
Entitlement Form 57.

If the worker has an out-of-state petition, fax it to the state TAA coordinator (360 438-4777 or 360
902-9790) when completing a SKIES Program Enrollment.

See TAA Assessment Policy #3020 and Assessment Procedures #OP-3020 . The needs
assessment must take into consideration local labor market conditions, transferable skills, barriers to
employment such as obsolete skills, excess supply of skills in the labor market, or limited English
proficiency; as well as employment history, desired employment and education history. The Initial
Needs Assessment form is for the participant to complete to obtain basic information about the
participant relevant for TAA purposes and builds on the WorkSource Assessment.

Workers certified for Trade Act must be enrolled in training or have a Waiver from Training issued
within strict timelines to access Basic TRA. The Waiver from Training preserves the right to Basic
TRA. An initial assessment must be conducted before issuing a waiver. The waiver must be issued
by the last day of the 16th week after the most recent total qualifying separation or by the last day of
the 8th week of the petition certification covering the worker, whichever is later. See Waiver from
Training Guidelines (CT15).

The Waiver from Training is created and stored in SKIES. Once issued a waiver must be reviewed
every 30 days. Each waiver review is recorded in SKIES. See SKIES Waiver from Training. See
Trade Readjustment Allowance Policy #3040.

Revoke the waiver if the conditions for waiver no longer exist. Provide a brief reason for the
revocation in the comment section. The effective date of the revocation is required. There are two
reasons for revocation of a training waiver: 1) the participant enrolls in a TAA approved training
Classroom Training                                                                                       Page 3 of 11

funded by either TAA or a partner program or 2) the participant has not complied with Work Search
Directive requirements. See SKIES Revocation of Waiver.

Refer to TAA Assessment Policy #3020 and TAA Assessment Procedures #OP-3020. The
Comprehensive Needs Assessment must expand upon the initial assessment regarding a
participant’s skills, aptitudes, and abilities (including reading and math levels).

A comprehensive assessment should determine the participant’s interests as they relate to
employment opportunities in demand either in the commuting area or, where there is no reasonable
expectation of securing employment in the commuting area and the worker is interested in relocation
to other areas, outside the commute area.

Give the Comprehensive Assessment form to the participant to complete and return. TAA Federal
Regulations state a participant must be qualified to undertake and complete training. Evaluation of
the participant’s personal qualifications must include physical and mental capabilities, educational
background, work experience and financial resources as adequate to undertake and complete the
specific training program being considered. The sections of the Comprehensive Assessment form
meet all of these training approval requirements.

Only one training program is allowed under a specific Trade Act certification. Therefore it is
paramount for a participant to complete thorough research to match available training to the
participant’s skills, aptitudes and abilities. All participants wanting to enter training must be instructed
to complete the Training Research packet. Participants co-enrolled in the WIA Dislocated Worker
program who have completed similar research and are enrolled in training paid by WIA are not
required to complete another Training Research packet. However, if a participant is in WIA paid
training, the training must meet the six conditions for TAA approval of training for TAA funding. The
six conditions for TAA approval of training must be met for the participant to access available TRA.
Refer Approval of Training Policy #3000 and Approval of Training Procedures #OP-3000.

The Training Research packet consists of seven pages.
Page 1, informs the participant of research requirements and when to return their research packet.

Page 2, provides the opportunity for a participant to interview two different schools. A participant
must contact at least two schools if there is more than one in the local area. A participant may
contact additional schools if other schools are available in the local area. Refer to the Eligible
Training Provider’s List. Training shall only be approved from an institution and program published
on the Statewide ETPL and meets the performance criteria established by the Workforce Training
and Education Coordinating Board (WTECB).

Pages 3 – 5, are provided for employer informational interviews. Each participant must interview at
least three employers who would hire individuals who possess the occupational skills they are
researching. A participant may interview an employer on a school’s Vocational Advisory Committee
or an employer who accepts interns through the proposed training program. This is to give the
participant an idea of the skills needed for the occupation as well as the likelihood of obtaining
employment upon completion of training.

Page 6, the Vocational Plan section is provided to obtain the participant’s reason for selecting the
training program and preferred school. The Labor Market Information section offers a place to
compile the data gained from the employer informational interviews. The Financial Resources
section is for the participant to consider any disparity between the length of training and how long
their weekly income support benefits will last.
Classroom Training                                                                                    Page 4 of 11

Page 7, the participant may need your help with the Weekly Benefits (UI/TRA) Calendar in
determining the balances, the beginning and the ending dates of the various sources of income
support from regular unemployment benefits, TRA Basic, TRA Additional and state training benefits
(TB). It must be made clear to the participant that the Weekly Benefits Calendar will contain
approximate dates and balances and is to be used as a guide only.

Refer to Approval of Training Policy #3000 and Approval of Training Procedures #OP3000. The
training requested by a participant must meet the six conditions for approval. The Approval of
Training Checklist covers each of the six conditions and can be completed following the Initial
Assessment and Comprehensive Assessment.

The selection of a training or provider and location must be prioritized as follows:

    1)   Local community colleges, vocational technical schools or state universities
    2)   A private school within the commute area
    3)   Community college or vocational school outside the normal commute area
    4)   A private school outside the normal commute area

If a private institution is selected over a public institution enter the reason why in SKIES case notes.

Both the training program and training provider must be on the Eligible Training Provider List (ETPL)
for TAA approval.

A participant’s need for remedial education must be documented through the comprehensive
assessment. Copies of the assessment along with the placement test from the school showing the
need for remedial education must be included in the participant file. Enter case notes in SKIES
reflecting the need for remedial education as well.

In a case where a participant lacks basic skills or has limited English proficiency, job readiness may
be achieved through on of the following:

A contextualized training program - this is a training strategy in which occupations skills are
developed in conjunction with Basic Skills or English As A Second Language (ESL) in a integrated
curriculum; or

A combination of remedial education (Basic Skills or ESL) and occupational skill training; or

A remedial education program alone, for individuals with marketable job skills may be approved if a
comprehensive assessment indicates that participant possess marketable skills and would be job
ready with remedial education, such as Basic or ESL Skills, to gain employment. Documentation of
the assessment, including labor market information showing the occupation is in demand and a copy
of the placement test form the school, must be included in the participant file. College pre-requisite
classes are not remedial education.

Remedial education can be approved for up to 26 weeks.

The Individual Training Plan is a contract between three parties, the school, the participant and
Employment Security Department. The CT3 must be signed and dated by all parties before a
participant begins training.

If a participant will be attending more than one school a CT3 must be completed for each school.
Classroom Training                                                                                    Page 5 of 11

Complete the Participant Information and TAA Program Information sections. In the Training
Program Information section enter the Occupation Goal and corresponding ONET code. Check the
box to identify whether the training provider is public or private. Enter the training provider’s full
name and mailing address.
The school will complete the remainder of the Training Program Information. If you know the start
and end dates of the training and the number of instruction hours, hours per week and total weeks of
instruction for remedial and/or occupational training for that particular training program you may
enter that information.

The school will also complete the Training Schedule Summary and Training Cost Inform ation
sections. Bring in person or send the CT3 to the school by email or United States Postal Service for
completion and signature. The participant may take the CT3 to the school also.

The established reasonable cost limit for TAA paid training is $16,000.00. If training costs exceed
this amount complete an Exception to Cost Limit providing justification for the cost of the training and
why it should be approved by TAA. Only the cost for training that TAA is responsible for must be
entered on the CT3. When sources are combined to fund training use the Funding Resource Map to
show the funding sources and the period of time the funding sources will cover.

As soon as the CT3 is approved (Signed by Service Provider Supervisor or Manger.) enter the
amount for remedial training, if required and Occupational Training in SKIES on the New Obligation
screen. See SKIES Entries for obligation of TAA funds for training costs. If a private institution is
selected over a public institution enter the reason why in SKIES case notes.

Request for Training Approval and Allowances (858) must be completed prior to the start of training.
Enter information in the first section. The training information can be found on the Individual Training
Account (CT3).

Section A: Participant Request
Occupational Skills Training – Enter the training program, training provider name and address. Enter
the start and end dates of training, then compute the total number of instruction weeks. If
occupational skills training will be completed at more than one provider show that provider name,
address, start and end dates and total instruction weeks on the second page.

Remedial – If the comprehensive assessment shows a need for remedial training enter that
information including the start and end dates for remedial training. Enter the number of weeks
needed for remedial training and the total instruction weeks for both occupational and remedial

Transportation – If the training facility is outside the normal commute area for the local labor market
the participant may be granted a transportation allowance. Check the box for Transportation
following the participant request statement.

Subsistence – When a participant will attend approved training outside the commuting area and
must maintain two separate households a subsistence allowance may be granted. Check the box for
Subsistence following the participant request statement.

Advance – If an advance in Transportation or Subsistence is necessary for the participant to begin
training check the appropriate box. The amount of an advance is determined upon individual need.
Contact the TRA Unit (360) 902-9505 for guidance on an advance.

The participant is to read the certification statement and sign the request.
Classroom Training                                                                                    Page 6 of 11

Section B: Agency Approval of Training Request
Enter the start and end dates for Transportation or Subsistence. Enter the mileage on line provided.
Use MapQuest to determine the distance from the participant’s place of
residence to the training facility.

Transportation – When training is outside the normal commute area and is has been determined to
be necessary the actual payment may not exceed the lesser of:

Actual cost for travel by the least expensive means of transportation reasonably available between
the participant’s residence and the training facility (for example, public transportation such as a bus,
if feasible) or;

The cost per mile at the prevailing federal mileage rate except that the daily rate cannot exceed the
per diem rate for subsistence.

Enter the round trip miles in #Miles R/T. Enter the current federal mileage rate in X Mileage Rate
found at Click on Travel Desk; multiply the daily round trip mileage times
the federal mileage rate enter this in = Daily Allowance. Enter the average number of days per week
the participant will be attending training in the X Days per week in training. Multiply the Days per
week in training by the number of training weeks and enter the product in Transportation Cost.
[Round trip miles X Federal mileage rate = Daily allowance X Average days per week in training X
Number of training weeks = Transportation cost]. Key this as a service in SKIES. Obligate the funds
to pay transportation on the SKIES Obligation screen. See SKIES Entries.

Subsistence – When a subsistence allowance has been determined necessary, the actual payments
may not exceed the lesser of:

The actual daily cost for a temporary residence in the area of training or:

50 percent of the prevailing federal per diem rate for lodging and meals for the location of the training

Enter the per diem rate for the location of the training provider. Multiply the per diem rate by the
average number of days the participant will attend school each week. Multiply the product in Days in
school per week by the number of training weeks and enter the product in Subsistence Cost. [Per
Diem rate X Average days in school per week X Number of training weeks = Subsistence Cost]

Retain in the participant file proof that a primary residence is being maintained in the form of rent or
mortgage receipts, canceled checks or other proof of payment.

Key the subsistence allowance as a service in SKIES. Obligate the funds to pay subsistence on the
SKIES Obligation screen. See SKIES Entries.

Section C: Agency Denial of Training Request
In serving participants it is necessary to work with them to be able to approve a training program
based on their comprehensive assessment, work interests, work values and abilities. Should an
occasion arise where a participant insists on requesting training that cannot be approved the training
must be formally denied. See Denial of Adjustment Assistance Policy #3025.
Classroom Training                                                                                   Page 7 of 11

This form is used to obtain or exchange information between service providers. For example a
participant in TAA approved training has not provided grades or class registration; you can request
those from the school with a copy of the authorization.

Have the participant sign and date the Authorization to Release Information at the same time the
Request for Training Approval 858 is signed.

Complete an Exception to Cost Limit when TAA training costs exceed the $16,000.00 limit on either
a new contract (CT3) or when revising an established CT3. If this is a revision check the box in the
TAA Program Information field indicating Revision on the CT3. Enter the revision cost information in
the Revision column on the second page of the CT3 and enter the total of revision funds on the
Revision Total Costs line. Do not add the Total TAA Training Costs and Revision Total Costs

It is advised that you complete it electronically then forward in an email to the State TAA Specialist.
The TAA specialist will respond by email. You may also fax your request to the State TAA Specialist
but please send an email or phone to inform of the fax. (360) 438-4777.

Retain the approved Exception to Cost form and the new or revised CT3 in the participant file.

If your request for exception is approved, adjust the obligation screen in SKIES.

The Funding Resource Map is used when combining different funding sources to pay the cost of
training for a participant. It outlines the amount of the funding commitment from the various sources
and the dates those funding sources will cover.

The Resource Map with supporting documents such as a WIA ITA and the completed CT3 are
submitted to the Service Provider Supervisor or Manager for approval. Only after the TAA Service
Provider Supervisor or Manager has signed the CT3 may the participant begin training. If approved,
Trade Act will pay for the portion of training identified on the Resource Map and the amount
obligated by the CT3. Retain in participant file and enter information in SKIES case notes that a
Resource Map was completed.

The Books and Supplies Agreement is provided to inform a participant of the limitations on supply
purchases and items the TAA program will not pay for. Review the form with the participant prior to
the start of training. The participant must sign the Books and Supplies Agreement indicating they
understand the policy. Make a copy of this form for the participant. Retain the original in the
participant file.

When a training program requires the purchase of tools or equipment the Tools and Equipment
Agreement form must be completed. Review the form with the participant prior to the start of training.
The participant must sign then receives a copy of this form. See Issuing, Inventorying, and Storing
Tools and Equipment for instructions on how to proceed when providing tools or equipment for a
participant in TAA approved training. Retain the original in the participant file.
Classroom Training                                                                                        Page 8 of 11

1. All tools must be inventoried when issued to a participant for training.

2. If it becomes necessary for a participant to return tools you must complete another inventory and
record this information on the Participant Tool Log. Upon completion of the inventory secure (lock,
seal, tie or tape) the tool box/chest or other container holding tools and attach copies of the Tool Log
and the participant Tool Agreement. Once inventoried do not remove any portion of the contents.
Your office is now responsible for the tools.
Store them in a locked area. Notify either Randy Bachman or the state Technical Specialist that you
have them. An advisory notice will be sent to the field that these tools are available for reissue.

3. Your office will keep the tools for six months, if during that time you are unable to reissue the tools
to a TAA participant the tools may be issued to a WIA program participant only after contacting the
state TAA Technical Specialist for further instruction. If you reissue the tools or equipment a full
inventory must be taken and the transaction logged in SKIES case notes and on the Tool Log. If you
are unable to reissue the tools to another participant within the six months you may contact the
warehouse to have the tools picked up and stored until they can be reissued to another participant.

4. Only hand or power tools/equipment can be sent to the warehouse for storage. No clothing such
as uniforms, scrubs, lab coats, capes for cosmetology, or pants/jackets for culinary arts; no welding
jackets, gloves, no boots or shoes purchased for a particular participant are to be sent to the
warehouse. Your participants may be allowed to keep these things because they cannot be
reissued for hygienic concerns.

5. No items that have been used on other people such as those for cosmetology (brushes, combs,
curlers, clips, scissors, clippers, etc.) can be sent to the warehouse. These items cannot be reissued
to other participants for hygienic reasons so your participants may be allowed to keep them.

6. Only power tools, equipment or complete sets of tools (sockets, wrenches, screwdrivers, punch
and chisel sets, pliers sets, etc.) enclosed and sealed in a container (toolbox/chest or cardboard box,
etc.) can be sent to the warehouse for storage. The warehouse will track these items as they enter
and leave the warehouse.

The Classroom Training Responsibilities lists expectations of a participant in TAA approved training.
Review the form with the participant prior to the start of training. The participant will sign then receive
a copy of this form retain the original in the participant file.

The Transportation, Subsistence or TRA Allowance Responsibilities lists expectations of a
participant in TAA approved training when receiving these allowances. Review the form with the
participant prior to the start of training. The participant will sign then receive a copy of this form.

A participant in TAA funded training must submit attendance forms regularly. While claiming
unemployment benefits, either regular benefits or state training benefits, a participant must submit at
a minimum Monthly Attendance forms. The Weekly Attendance and Benefits Request (858A) form is
to be used when a participant, in TAA approved training, is claiming TRA. TRA weekly benefits are
paid to the participant from the Weekly Attendance and Benefit Request form. This form is also used
to pay Subsistence or Transportation when these allowances have been approved by the TAA
Service Provider.
Classroom Training                                                                                     Page 9 of 11

Trade Act service providers and supervisors will be responsible for the approval or denial of requests
to revise existing TAA training plans. Please note this type of revision does not include the request
of a participant to change from one training program to another. Under TAA regulations an individual
shall be approved for one training program per certification. Requests having to do with a change in
training programs will continue to be forwarded to Central Office for a determination.

When a participant requests a revision of their training plan the TAA service provider must obtain the
information needed to justify the approval and complete the Revision Checklist.

The service provider will work with the local supervisor who is responsible for reviewing the request
and providing concurrence of the approval. As part of the approval process, both the TAA
supervisor and service provider must initial the revised CT-3 and sign the Revision Checklist.

If a service provider is unable to approve a revision request, the service provider must follow the
Denial of Adjustment Assistance Policy #3025.

Additional classes or items being requested must be required for the participant’s training program.
The following requirements must be met for local approval of a revision request:

    ▪    The total number of instructional weeks cannot exceed 104. (Training must be completed
         within 104 instructional weeks.)

    ▪    Training costs must be within the established cost limits of $16,000. If not, a request for an
         Exception to Cost Limit must be approved by Central Office prior to the revision approval.

Good cause must be established for a participant to be granted up to a one quarter leave of absence
from training. The approval for a leave of absence will be made on a case by case basis.

To approve a Leave of Absence the following must occur:

    ▪    The participant must have established good cause due to medical or health reasons for the
         participant or a family member. Documentation supporting the leave, such as a doctor’s note,
         must be included in the participant file.

    ▪    The training provider must approve the leave of absence and documentation must also be
         included in the file.

    ▪    If possible, arrangements must be made with the training institution for the participant to
         make up the time missed.

    ▪    Leave status must be reviewed every thirty (30) days.

TAA is able to pay for classes one time only for a participant. If a participant has to retake any
classes they will need to find other funding resources to pay for them.

A participant must be informed that a leave of absence from training can affect their weekly income
support whether it is Trade Readjustment Allowances or state Training Benefits. The TAA Service
Provider must coordinate the temporary leave with the TRA Unit.
Classroom Training                                                                                    Page 10 of 11

If it becomes necessary to deny training, follow the Denial of Adjustment Assistance Policy #3025.

This form provides an organized detail for the progression necessary to complete the Classroom
Training service and to verify these steps have been taken. The Classroom Training Checklist lists
all of the steps and forms necessary in assisting a participant in beginning, continuing and
completing a classroom training program.


Refer to SKIES Revocation of Waiver.

Refer to SKIES Training Service Plan. Close Basic Readjustment Service when entering a training

New Obligation Screen – When training begins, enter type of training (Training Service) as Provider
Service and the start date in the SKIES Service Plan. Close out the BRS status. You will not be
able to obligate funding without having the provider service in the SKIES Service Plan. See SKIES
Training Service Plan

When training has been completed enter the actual end date. Change the service from Occupational
Skills Training to next activity, i.e. Job Search Assistance (Core Services). Monitor services no less
than monthly.

Transportation or Subsistence allowances must be entered as services (Training Service). The
actual start date is the date they start receiving these services. Most likely this would be the date
when Occupational Skills Training begins. The planned end date would be the date the services are
expected to discontinue, which would be the same as the planned end date of the Occupational
Skills Training service.

When the participant is no longer receiving transportation or subsistence enter an actual end date.

New Voucher Tab – A voucher can exceed the total amount of the section as long as the voucher
does not exceed the remaining total amount of the CT-3 obligation. Example: If section one has
$2000 obligated out of $10,000 and the bill totals $2050, the voucher can still be paid out of section
one without obligating an additional $50. It will pull from the total amount of $10,000 leaving a
balance of $7950. The balance will pull up or down the sections as needed until the last payment is
made. If a balance is showing after all the vouchers have been remitted, de-obligate the amount
using the De-obligate the Unpaid Balance button. If additional funding, but still under the limit of
$16,000 for training, is required for the last section or the end date has changed and another section
needs to be added, the service provider will need to complete a Revision Checklist and fax to the
TRA Unit. This form is not used to request an exception to cost exceeding the $16,000 limit.
The voucher must be signed by the preparer and approving authority. If either signature is missing,
the A-19 will be automatically returned. Vendors are not required to sign the A-19.
Submit the original voucher with original receipts to the Budget/Financial Unit using an A-19
Transmittal. If the original receipt is lost, the service provider must sign and date the copy and write
“original lost” on the copy of the receipt.
Classroom Training                                                                                 Page 11 of 11

    Employment Security Department
    Budget/Financial Unit
    P.O. Box 9046, Mail Stop 6000
    Olympia, WA 98507-9046

SKIES DEOBLIGATING - Deobligate training, transportation and subsistence balances after all
vouchers have been submitted and paid. On the SKIES Job Seeker tab, click
Obligation/Voucher/Payment, click on Obligation Detail pertaining to the specific service, click on De-
obligate Unpaid Balance.

Repeat for all services with unpaid balances needing to be de-obligated.

If it becomes necessary to change either a training provider (school) or ONET code funds from the
first obligation, the first obligation must be de-obligated in SKIES. An obligation for the second
training provider or changed ONET code must be entered in SKIES as a new obligation.

The service provider does not need to notify the TRA unit when funds have been de-obligated unless
notification has been requested.

This communication cancels and supersedes all prior procedures for the classroom training
component of the TAA program.

Susan Jackson
Employment Security Department
WorkSource Operations Division
P.O. Box 9046, Mail Stop, MS 6000
Olympia, WA 98507-9046
Telephone: (360) 438-4703
FAX: (360) 438-4777

                                                                                        Revised 09/08/08