SAFETY POLICY Revised: December 30, 2013
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1 SAFETY POLICY Revised: December 30, 2013 OVERVIEW It shall be the policy of the College of the Desert Public Safety Academy (COD PSA) to conduct all training in such a manner in order to promote an attitude of safety among Instructors and Students alike. Safety must be the primary concern of everyone involved in training at the COD-PSA, and related sites, so the risk of injury is significantly minimized. The efforts of all personnel involved in training shall be directed toward ensuring a safe atmosphere within which maximum training benefits can be realized. I. Staff/Administrative Responsibilities A. The training staff shall provide advance notice to prospective trainees and their agencies regarding anticipated physical demands and/or physical performance expectations. B. Instructors shall be provided with a copy of the POST Safety Guidelines and COD-PSA Safety Policy and shall be responsible for their implementation, within their area of instruction. C. The training staff shall ensure emergency communications are accessible at all training sites. D. At least one member of the instructional staff, either directly involved in the training activity or immediately available at the training site, shall be trained in first aid and CPR. E. Student emergency notification information shall be maintained for the duration of the course. F. When planning a training event, the training staff shall identify which medical facilities and emergency services are available or to be notified in the event of an emergency or injury. II. Instructional Staff-To-Student Ratios A. Recommendations for instructional staff to student ratios for each psychomotor skill area have been established. Implementation for the ratios shall be based on the following criteria: 1. The intensity or pace of the training experience. 2. Student familiarity with the material. 3. Characteristics of the training site. 4. Potential of injury. 5. Active versus passive participation. COD-PSA: Safety Policy Revised 8/01/13 1
2 6. Discretion of the Instructor. B. For the purpose of establishing an instructional staff to student ratio, the following personnel titles and descriptions are viewed by COD-PSA as exerting functional supervision over students in training: 1. Primary/lead/principle Instructor 2. Assistant Instructor(s) 3. Course Coordinator 4. Safety Officer(s) 5. Others as designed by the Director, COD PSA. C. Specific ratios are established by COD-PSA in collaboration with the POST Safety Guidelines, approved by the Director, COD-PSA, and incorporated into the COD-PSA Safety Policy. D. Reassessment of the student-to-instructor ratios will be initiated when curriculum changes are proposed or when course instruction is otherwise modified. III. Instructor Responsibilities A. The primary Instructor, or designee, shall be responsible for conducting safety inspections of students and facilities used for training. B. The Instructor(s) should be aware of environmental factors, such as weather conditions and/or air quality, and adjust the training as necessary to maximize safety. C. The primary Instructor, or designee, shall verbally review specific safety rules with the students. D. Specific safety rules shall be incorporated into the lesson plans. Copies of safety rules shall be posted, distributed, or otherwise provided to students as part of the course orientation or handouts. E. Instructors shall adhere to the Expanded Course Outline, as submitted to POST, and the lesson plans approved by the Division Dean. F. Instructors shall advise the students of their responsibility to report unsafe conditions and/or stop unsafe actions during training. Instructors shall have the authority to separate students from the training class who fail to comply with these safety requirements. G. Instructors shall display an attitude of safety and professional demeanor at all times. IV. Student Responsibilities A. Students shall immediately notify an Instructor of any pre-existing medical condition which is likely to be aggravated, or be adversely affected during training. COD-PSA: Safety Policy Revised 8/01/13 2
3 B. Students shall be required to provide evidence of medical and/or physical fitness for training if the Instructor questions their ability to safely perform any aspect of training. C. Any student, who sustains an injury or becomes aware of an injury to another student during training, shall immediately notify a member of the training staff. D. Students are responsible for adhering to all safety requirements of individual course. V. Response to Injuries A. In the event of an injury, the following actions shall be taken, as necessary: 1. Render first aid utilizing a COD-PSA first aid kit. If the injury occurs on the grounds of the Academy, the first aid kit is located in PSA Room 18. At the range, the Safety Officer will possess the first aid kit. Additionally, a COD-PSA first aid kit and Safety Policy is issued and carried by a student in each module. 2. Obtain appropriate medical assistance. In all cases where a student loses consciousness an evaluation shall be sought from a competent medical authority before the student is allowed to return to training. 3. Notify the appropriate Administrator. 4. Initiate other appropriate notifications or actions as required by College of the Desert. 5. Investigate and complete the appropriate forms as required by the College of the Desert. 6. Students who sustain an injury which requires treatment by a physician must obtain medical release before they will be allowed to resume training. VI. Course-Specific Safety Rules A. Specific safety rules and procedures for individual subject areas are found in the respective course documents. These rules vary due to differences in subject matter, tasks to be performed and the particular training environment or site. B. Reference has been made to the following resources in developing this policy 1. POST Guidelines, 2. POST Administrative Manual, and 3. College of the Desert Policy. COD-PSA: Safety Policy Revised 8/01/13 3
4 DRIVER TRAINING POLICY Note: All Driver Training (EVOC) will be conducted by the Regional POST Certified Trainer: San Bernardino Sheriff Department The San Bernardino Sheriff s Department has an approved safety policy in place and students adhere to and obey the SBSD safety policy. COD-PSA: Safety Policy Revised 8/01/13 4
5 I. Facility Guidelines College of the Desert - Public Safety Academy FIREARMS SAFETY POLICY A. General safety rules, policies and procedures unique to COD-PSA have been developed, reduced to writing, and shall be communicated to students prior to the training session. B. The intent of this policy is to promote student and staff safety awareness in areas involving psychomotor skills training and to reduce the potential risk for injuries. C. Students are unfamiliar with the facility and shall be made aware of local rules and conditions. D. Rules of the firing range are clearly posted at the range. E. The range shall have an adequate bullet impact area to provide a reasonable margin of safety from all aimed, strayed, and ricocheted shots. F. The range shall have a reasonably contained perimeter designated by means of warning signs, fencing, and an earth berm to prevent unauthorized entry. G. It is important that all persons in the vicinity of the firing range be aware of the activities which occur there. Signs shall be conspicuously posted and far enough away from the shooting area to provide for a wide margin of safety. H. Safe areas are designated to accommodate persons who are not directly engaged in shooting, including areas for cleaning, unloading and reloading with duty ammunition. I. Safe areas are to be clearly identifiable to the student. Sand barrels or other appropriate devices for the safe loading and unloading of firearms will be available. J. The range shall have a communications system capable of clearly transmitting instructions to all persons on the range. The system/process shall be sufficient to stop action and ensure that verbal commands are clearly understood by shooters on the firing line. Cease Fire and/or the sound of the whistle shall signify the STOP ACTION command and will be used in emergencies. K. The range facilities and bullet impact areas shall be inspected at least daily for apparent hazards. L. Adequate emergency lighting shall be provided at the site of any night-time firearms training. M. Weather conditions shall be considered with regard to the need to provide shaded areas, shelter, or protective clothing. COD-PSA: Safety Policy Revised 8/01/13 5
6 N. A first aid kit shall be readily accessible at the range and shall have trauma supplies to allow for treating gunshot wounds. O. Reactive targets shall be constructed in such a manner as to minimize the danger of ricochets. P. Props and sets used in the tactical shooting course shall be constructed to minimize the danger created by ricochet. Q. Only red guns shall be used for training purposes outside of the range area. No real firearms or live ammunitions shall be used for training purposes outside of the range area. II. Student-to-Instructor Ratio A. The student-to-instructor ratio for static line courses of fire shall minimally be 5:1. III. Equipment Guidelines A. Every student shall be required to wear eye and ear protection while engaged in shooting or while in the immediate vicinity of the firing line. B. Every student shall be required to wear soft body armor while on the range. C. Each handgun shooter shall use a holster that is compatible with the type of handgun that will be used on the range. D. Each weapon shall be subject to a basic safety inspection and approved for use by the instructional staff prior to use on the range. E. A safety check of weapons shall be initiated following any break in training or whenever students have been allowed to leave the training site. F. Clothing and footwear appropriate to the course of fire and terrain of the range is required. IV. Instructor Qualifications A. Instructors and/or Range masters in firearms courses shall have successfully completed a POST certified firearms instructor s course or its equivalent. B. Instructors and/or Range masters are encouraged to participate in periodic firearms instructor update courses. C. Instructors and/or Range masters shall have received previous training in the particular weapon or weapons used in the training. COD-PSA: Safety Policy Revised 8/01/13 6
7 D. The instructional staff shall be easily identifiable and shall wear an approved red Firearms Instructor Staff polo shirt, or windbreaker and wear body armor. V. Presentation Guidelines A. General range safety rules shall be re-emphasized to students immediately prior to range training. B. Procedures for handling weapon malfunctions, ammunition failures and other unusual occurrences shall be reviewed immediately before live-fire training. C. Students shall be instructed to keep their fingers outside of the firearm s trigger guard until a target is available for shooting and they decide to fire. D. Students shall be given a general orientation to any tactical shooting course where live fire will be used prior to application phase of training. E. An instructor shall be designated as the Safety Officer, possess a first aid kit, and shall be responsible for the overall safety of the training, including ensuring nonparticipatory students are monitored by an instructor. F. Students shall be instructed to wash their hands and face thoroughly after shooting to remove any lead particles or other debris deposited as a result of the weapon s discharge. COD-PSA: Safety Policy Revised 8/01/13 7
8 I. Facility Guidelines College of the Desert - Public Safety Academy CHEMICAL AGENTS POLICY A. General safety rules, policies and procedures unique to COD-PSA have been developed, reduced to writing, and shall be communicated to students prior to the training session. B. The intent of this policy is to promote student and staff safety awareness in areas involving psychomotor skills training and to reduce the potential risk for injuries. C. All chemical agents training should be conducted at the Riverside Sheriff Department Firing Range at Lake Cahuilla. However, the COD-PSA, or other suitable location, may be used if deemed safe by the lead Chemical Agent Instructor and/or COD-PSA Director. D. Students who are unfamiliar with the facility shall be made aware of local rules and conditions. E. Weather conditions shall be considered with regard to the need to provide shaded areas, shelter, or protective clothing F. A first aid kit shall be readily accessible at the range and shall have trauma supplies to allow for treating chemical agent injuries. G. No real firearms or live ammunitions shall be used for training purposes during the chemical agent training. H. The Chemical Agent Training area shall have adequate lighting, proper ventilation, with minimum potential hazard to the public and shall have an easily accessible first aid kit (possessed by the Safety Officer) and fire extinguisher. I. Chemical Agents shall be handled only by Chemical Agent Instructors. J. Should a Chemical Agent not function properly, students shall be moved away from the defective chemical agent a safe distance (a minimum of 100 feet), and a reasonable time (at least 15 minutes) shall elapse before any action is taken by the Instructor. The Instructor, using protective gear, shall remove the defective chemical agent with a shovel or other appropriate tool, to a safe location. K. Students shall be instructed in the proper use and fitting of a gas mask. L. At least one instructor shall escort and accompany students into the area of the released chemical agent and remain with the students during the exposure to the chemical agent. Once exposed, the student is escorted to water for rinsing and monitored by a group of roving instructors. M. There will be a sufficient water supply for decontamination of students after exposure. COD-PSA: Safety Policy Revised 8/01/13 8
9 II. Student-to-Instructor Ratio College of the Desert - Public Safety Academy A. The Student-to-Instructor ratio for chemical agent use on students shall be 1:1. B. All other chemical agent training, such as during the deployment of CS/CN Gas, shall be 6:1 III. Equipment Guidelines A. Clothing and footwear appropriate for chemical agent training is required. IV. Instructor Qualifications A. Chemical Agent Instructors shall have successfully completed a POST certified Chemical Agent Instructor Course or its equivalent. B. Chemical Agent Instructors are encouraged to participate in periodic chemical agent instructor update courses. C. Chemical Agent Instructors shall have received previous training in the particular chemical agent training to be utilized. D. The instructional staff shall be easily identifiable and shall wear an approved red Instructor Staff polo shirt or windbreaker. V. Presentation Guidelines A. General safety rules shall be re-emphasized to students immediately prior to chemical agent training. B. Procedures for handling chemical malfunctions, failures and other unusual occurrences shall be reviewed immediately before chemical agents are used in training. C. An instructor shall be designated as the Safety Officer, possess a first aid kit, and shall be responsible for the overall safety of the training, including ensuring nonparticipatory students are monitored by an instructor. D. Students shall be instructed to wash their hands and face thoroughly after chemical agent training. COD-PSA: Safety Policy Revised 8/01/13 9
10 I. Facility Guidelines College of the Desert - Public Safety Academy USE OF FORCE POLICY Arrest and Control A. Specific policies, procedures and general safety rules unique to COD-PSA have been developed, reduced to writing, and shall be communicated to the student prior to the training session. B. Use of Force Training shall occur in a suitable location. Comment: Risk of student injury increases dramatically when training occurs in inappropriate locations. An appropriate mat room or similar type of are, either permanent or temporary, is recommended. C. The size of the facility shall be adequate for the number of students to be trained. Comment: Adequate space between students is fundamental to minimizing the chance of injury. Baton training, for example, should occur in an area of sufficient size which allows for the full unobstructed swing of a standard baton. D. Environmental factors shall be considered when selecting a safe training location. Comment: Indoor training facilities used for Use of Force instruction should have adequate lighting and proper ventilation to accommodate strenuous physical activity. Adequate cooling capabilities, for example, are necessary to prevent heat related illness. E. The training site shall be reasonably free from outside distractions. F. Only RED GUNS shall be used for training purposes outside of the range area, including all Arrest and Control training. No real firearms or live ammunitions shall be used for training purposes outside of the range area. II. Equipment Guidelines A. Students training in Use of Force shall be required to meet the clothing and footwear standards established by COD-PSA. These requirements equal the uniform required for the cadets in the basic academy. Comment: Clothing worn for physical training will allow for flexibility of movement. Students wearing glasses should use shatter-resistant lenses and eyeglass retainers B. The instructional staff shall conduct a pre-training inspection. COD-PSA: Safety Policy Revised 8/01/13 10
11 Comment: A pre-training inspection ensures that students have brought the correct clothing and personal equipment. It provides the opportunity to check for the presence of watches, rings, necklaces, earrings, and other jewelry which may cause injury to the individual or other students. C. Equipment used in use of force training shall be cleaned regularly. Comment: Mats and the surfaces of all equipment which students come in contact with should be cleaned regularly. Cleanliness plays an important part in the health of all involved. D. The instructional staff shall conduct periodic equipment inspections to ensure their safety and suitability. Comment: Split bamboo batons, for example, require frequent replacement. Mat surfaces prone to tearing shall be repaired professionally. Mat attachment systems also require frequent examination. E. COD-PSA shall provide or require specific safety equipment for any high intensity or full-contact training. F. Use of Force instructors are encouraged to participate in periodic instructor update courses. Comment: Networking of instructors is encouraged. III. Student-to-Instructor Ratios A. The Student-to-Instructor ratio for Use of Force should minimally be 6:1 for the handson component. The ratio shall allow the instructional staff to adequately observe takedown, application of pain compliance holds or other activities which present a potential for student injury. IV. Presentation Guidelines A. Instructors shall maintain an appropriate level of discipline over students at all times. Comment: Instructors shall consistently maintain a professional atmosphere during training and ensure that students abide by all published rules of conduct. B. Instructors shall be aware of physical fatigue factors which affect the ability of the student to safely perform any given task. Comment: Use of Force techniques are inherently tiring. Instructors shall be aware that long periods of training, environmental conditions, or other factors can unduly fatigue students and increase potential injury. Extreme high temperatures, for example should suggest a reduction in physical intensity. COD-PSA: Safety Policy Revised 8/01/13 11
12 C. An instructor shall be designated as the Safety Officer, possess a first aid kit, and shall be responsible for the overall safety of the training, including ensuring nonparticipatory students are monitored by an instructor. IV. Specific Safety Rules A. Minimum conditioning guidelines for in-service training shall be considered whenever Use of Force training is included. Comment: In-Service students may be in poor physical condition at the time of training. Their potential for injury particularly muscle strains and joint irritations, shall be considered. Advance notice shall be sent to agency heads and students of specifics course expectations. B. Trainees attending instructor level courses shall be given a list of specific physical requirements, fitness expectations, and testing standards well before initiation of the course. Comment: Instructor-level training in Use of Force training is more intensive and requires a higher degree of physical fitness. Inadequate preparation for this training may substantially increase an attendee s potential for injury. C. A systematic physical warm-up procedure shall be initiated prior to commencement of any Use of Force training. Comment: Injuries are less likely if students engage in appropriate warm-up stretching activities before beginning training. Specific attention should be given to the particular muscle and joint group involved. Instruction on the takedown to a carotid restraint, for example, suggests a concentrated warm-up of the neck and shoulder muscles. D. A systematic procedure for cooling-down shall be initiated at the conclusion of any Use of Force training. Comment: An appropriate cool down will also help to reduce muscle pain after exercising. COD-PSA: Safety Policy Revised 8/01/13 12
13 Lifetime Fitness Safety Policy I. Application A. This General Safety Policy applies to all COD-PSA sponsored Fitness Training courses. The intent of this policy is to promote student and staff safety awareness in areas involving psychomotor skills training and to reduce the potential risk for injuries. Each training presenter/coordinator shall be furnished with a copy of this policy. B. All instructors and instructional staff shall be responsible for adhering to all applicable safety policies and approved course outlines and lesson plans. II. Facility Guidelines A. General safety rules, policies, and procedures unique to COD-PSA have been developed, reduced to writing, and shall be communicated to students prior to the training session. B. The intent of this policy is to promote student and staff safety awareness in areas involving psychomotor skills training and to reduce the potential risk for injuries. C. All physical training shall be conducted at the COD-PSA. 1. Classroom 2. Mat Room 3. Weight Room 4. Work Sample Test Battery (WSTB) Field D. Students who are unfamiliar with the facility shall be made aware of local rules and conditions. E. Weather conditions shall be considered with regard to the need to provide shaded areas, shelter, or protective clothing. F. A first aid kit shall be readily accessible and shall have trauma supplies to allow for treating injuries. G. Environmental factors shall be considered when selecting a safe training location. Indoor training facilities used for Physical Training instruction shall have adequate lighting and proper ventilation to accommodate physical activity. Adequate cooling capabilities, for example, are necessary to prevent heat related illness. III. Instructional Staff-To-Student Ratios A. A minimum of one (1) instructor per eight (8) students is required for warm-up, mobility, stability, corrective exercise, acceleration, agility drills, core, and recover exercise COD-PSA: Safety Policy Revised 8/01/13 13
14 technique practice. The 1:8 instructor to student ratio is also required for interval training workouts. B. A minimum of one (1) instructor per thirty (30) students is required for classroom lecture, and classroom learning activities. C. Students not engaged in group activities must be supervised by instructional staff. IV. Equipment Guidelines A. Students shall be instructed to bring: 1. Note taking material 2. Appropriate exercise clothing, which shall allow for flexibility of movement. 3. Water bottle 4. Gym bag to store athletic gear B. Exercise equipment shall be inspected for: 1. Loose collars 2. Unstable power racks 3. Tripping hazards and slippery or uneven surfaces 4. Frayed cables on weight machines V. Instructor Qualifications A. Instructors must have completed a POST-certified Physical Training Instructor Course or an equivalent instructor course or a certification exam from a recognized physical training organization (i.e. American College of Sports Medicine or National Strength and Conditioning Association. B. Instructors must have training and/or experience related to their specific teaching assignment. VI. Instructor Responsibilities A. Instructors shall review the course safety policy before each class. B. Instructors shall adhere to the approved lesson plan. C. Instructors who lead physical activity portions of the course shall review all PERQ forms and medical clearance statements before the beginning of any physical activity. They must identify students with activity restrictions and ensure that these students do not participate in restricted activities. COD-PSA: Safety Policy Revised 8/01/13 14
15 D. Instructors shall be responsible for conducting safety inspections or otherwise assessing the safety of the equipment and facilities used for training. E. All instructors shall be trained and have knowledge of the signs and the symptoms related to, but not limited to, the following medical conditions: Heat illness, cardiac arrest, dehydration, and other medical emergencies. F. Instructors shall be aware of environmental factors, such as weather or air quality, and adjust activities as necessary. G. Instructors shall advise all students of their responsibility to report any unsafe actions, equipment, or facilities during training. H. Instructors shall advise students of their responsibility to report any injury or illness. I. At least one instructor shall carry a cell phone for emergency purposes. VII. Presentation Policy A. Equipment, facilities, and activity set-ups shall be inspected for hazards before use. B. Instructors shall emphasize correct exercise techniques at all times. C. In hot, or warm and humid weather, activities shall be scheduled to reduce risk of heat illness. D. Water and water breaks shall be provided. Students shall be required to bring and permitted to carry water bottles. E. During extreme weather conditions, activities shall be moved indoors or rescheduled. F. A warm-up period shall be completed before every activity. G. At the conclusion of every physical training session which causes the students to break a sweat, there shall be a cool-down period. H. Instructors shall follow student-centered skill training principles while conducting exercise technique instruction and practice. I. Instructors shall emphasize proper application of correct technique and safety over competitive performance. (Many injuries occur as result of overzealous competition among trainees.) J. Appropriate lighting shall be provided during night-time activities. COD-PSA: Safety Policy Revised 8/01/13 15
16 K. Cleanliness is vital to the health of all involved. Therefore, the Academy Coordinator shall oversee regular cleaning and maintenance of exercise mats and equipment. Exercise mats, surfaces, and shared safety equipment shall be cleaned with a disinfectant solution after each training session and use. Instructors and staff with conduct regular equipment inspections to ensure safety and training suitability. Damage to equipment and requests for repair and/or equipment replacement shall be directed to the Academy Coordinator. VIII. Student Responsibilities A. Students shall provide a completed Physical Exercise Readiness Questionnaire (PERQ) form and medical clearance with activity restrictions, if indicated prior to engaging in any physical training or activity. B. Students shall immediately notify the course instructor of any known pre-existing medical condition, which may be aggravated during training or shall affect performance during assessment testing or exercise technique practice. C. If the instructor questions a student s ability to perform any physical training activity for a health related issue, the student shall be required to provide evidence of a medical clearance to engage in the physical training or activity. D. Students shall immediately notify the course instructor of any injury sustained during training. IX. Specific Safety Rules A. Students must bring to class a completed Physical Exercise Readiness Questionnaire (PERQ) form and medical clearance with activity restrictions, if indicated. B. Emergency notification information for each student shall be collected and made available at all training locations for the duration of the class. C. Instructors who lead physical activity portions of the course shall review all PERQ forms and medical clearance statements before the beginning of any physical activity. They must identify students with activity restrictions and ensure those students do not participate in restricted activities. D. All training and skills practice shall be completed on grounds of the COD-PSA. No offcampus activities are permitted. E. If a student is injured and requires medical care during the training, a medical release form from a physician shall be required prior to allowing the student to participate in any physical activity. COD-PSA: Safety Policy Revised 8/01/13 16
17 F. Students are not allowed to leave the training locations, e.g. classroom, gym, etc. without permission. ILLNESS OR INJURY POLICY I. Students Shall Report Illness and Injuries Immediately A. LIFE-THREATENING INJURY or ILLNESS REQUIRING EMERGENCY RESPONSE 1. COD-PSA staff shall provide immediate evaluation and first aid within the scope of their training. 2. DIAL 911 to ACTIVATE EMS or to report an Emergency via classroom or cellular telephone. Advise operator of building name, number or location of the injured person(s). All instructors 3. Notification of incident: * Director, COD-PSA: (Cell (760) ) * Security Department: (Director cell (760) ) * Administration (President's Office: (760) * Riverside County Sheriff's Department: (760) Complete and file Incident Report as soon as possible, or within 72 hours. B. IMMEDIATE, NON LIFE-THREATENING ILLNESS OR INJURY: URGENT RESPONSE 1. COD-PSA staff shall provide immediate evaluation and first aid within the scope of their training. 2. Advise, or if necessary, ensure the student is transported of the nearest Urgent Care facility. Transportation of the student will be based on the severity of the injury and in any event, the student shall not be transported by COD-PSA Staff. 3. Inform student, if sponsored by an agency, regarding instructions for seeking care and treatment. COD-PSA: Safety Policy Revised 8/01/13 17
18 a. Inform student of need to utilize employee health benefits or file Workers' Compensation claim with employer. 4. Complete and file Incident Report as soon as possible, within 72 hours. C. MINOR ILLNESS OR INJURY: ROUTINE RESPONSE 1. COD-PSA staff shall provide immediate evaluation and First Aid. 2. Complete and file Incident Report as soon as possible, or within 72 hours. II. COD-PSA Employees Work Related Injuries A. In the event that a COD-PSA employee experiences a work-related injury or illness, the guidelines outlined can be followed. Workers' Compensation claims are initiated by contacting Human Resources. The Director, COD-PSA, shall be immediately contacted. III. Hospital Information A. Eisenhower Medical Center Bob Hope Drive Rancho Mirage, California B. JFK Hospital Monroe Indio, California COD-PSA: Safety Policy Revised 8/01/13 18
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