ISO 45001:2018 Clause 5: Leadership and worker participation

CLAUSE 5 – Leadership and worker participation

Top management and their workers are required to have involvement in the input and operation of the OHSMS management system and must ensure that the requirements are integrated into the organization’s OHSMS processes and that the policy and objectives are compatible with the strategic direction of the organization. The top management must take overall responsibility and accountability for the prevention of work-related injury and ill health as well as the provision of safe and healthy workplaces and activities. This clause places requirements on top management to assign relevant responsibilities and support other relevant management roles to demonstrate their leadership as it applies to their areas of responsibility. Critical to the success of the OH&S management system is leadership and commitment from ‘Top Management’. The expectation of leaders within an organization is to become champions of the system and provide the necessary resources to protect workers from harm. This clause is the cornerstone for the success of the OH&S MS. In OHSAS 18001, top management was responsible for OH&S and was required to ‘appoint’ a member of top management with specific responsibility for OH&S. Top management in ISO 45001 is responsible and accountable for the prevention of work-related injury and ill health as well as the provision of safe and healthy workplaces (not simply providing support for a management system). This requires top management to be personally involved in order to develop, lead and promote a culture that supports OH&S. It should also be noted that leadership and culture are identified as a potential hazard later in the standard. It is also top management that has to ensure that a process for consultation and participation with workers is established. This may include establishing a health and safety committee. It is also top management’s responsibility to establish, implement and maintain the health and safety policy.
The required contents for the policy include elements such as a commitment to consultation and participation of workers. Importantly consultation with workers on the health and safety policy is included later in this clause. Consultation and participation of workers are significantly enhanced from OSHAS 18001 which was limited to participation in hazard identification and consultation on changes. In ISO 45001 consultations involve seeking views before making a decision with clear two-way communication, whilst participation is involved in decision-making. This must include non-managerial workers. The organization is now required to provide the mechanisms, time, training and resources for consultation and participation of workers. This includes removing any obstacles or barriers such as language, literacy or fear of reprisals.

Context 5.1: Leadership and commitment

Top management should demonstrate leadership and commitment with respect to the OH&S management system. Top management must be taking overall responsibility and accountability for the prevention of work-related injury and ill health as well as the provision of safe and healthy workplaces and activities. Top management must be ensuring that the OH&S policy and related OH&S objectives are established and are compatible with the strategic direction of the organization. The top management must be ensuring the integration of the OH&S management system requirements into the organization’s business processes. The top management must be ensuring that the resources needed to establish, implement, maintain and improve the OH&S management system are available. The top management must be communicating the importance of effective OH&S management and of conforming to the OH&S management system requirements. The top management must be ensuring that the OH&S management system achieves its intended outcome. The top management must be directing and supporting persons to contribute to the effectiveness of the OH&S management system. The top management should be ensuring and promoting continual improvement. The top management should be supporting other relevant management roles to demonstrate their leadership as it applies to their areas of responsibility. The top management should be developing, leading and promoting a culture in the organization that supports the intended outcomes of the OH&S management system. The top management should be protecting workers from reprisals when reporting incidents, hazards, risks, and opportunities. The top management should be ensuring the organization establishes and implements processes for consultation and participation of workers. The top management supporting the establishment and functioning of health and safety committees.

As per Annex A (Guidance on the use of ISO 45001:2018 standard) of ISO 45001:2018 standard it further explains:

Leadership and commitment, including awareness, responsiveness, active support, and feedback, from the organization’s top management, are critical for the success of the OH&S management system and achievement of its intended outcomes; therefore, top management has specific responsibilities for which they need to be personally involved or which they need to direct. A culture that supports an organization’s OH&S management system is largely determined by top management and is the product of individual and group values, attitudes, managerial practices, perceptions, competencies, and patterns of activities that determine the commitment to, and the style and proficiency of, its OH&S management system. It is characterized by, but not limited to, active participation of workers, cooperation and communications founded on mutual trust, shared perceptions of the importance of the OH&S management system by active involvement in the detection of OH&S opportunities and confidence in the effectiveness of preventive and protective measures. An important way top management demonstrates leadership is by encouraging workers to report incidents, hazards, risks, and opportunities and by protecting workers against reprisals, such as the threat of dismissal or disciplinary action, when they do so.

The requirements within this clause are generally self-explanatory. You will need to provide information on how top management ensure the OHSMS is compatible with the strategic direction as well as taking responsibility for promoting a safety culture to ensure that the management system achieves its intended outcome. In clause 5.1, 45001 uses the term ‘top management’ to refer a group or an individual at the highest level, controlling and directing the organization.  This sets out a list of things that top management must do, to demonstrate the commitment and leadership with respect to their health and safety management system. Three of these directly refer to the rights of workers:

  • To support establishing and the ongoing operation of health and safety committees, this clause specifically refers to the need to put emphasis on the participation of non-management workers in setting up these committees.
  • Ensuring that clause 5.4 is implemented.
  • Ensuring the protection of workers from any reprisals when they report hazards and risks.

The following are examples of how leadership can be demonstrated within the OH&S management system:

  • Take overall responsibility and accountability for the prevention of work-related injury / ill health, as well as the provision of a safe and healthy work environment
  • Facilitating positive culture and continual improvement
  • Ensure the OH&S system is integrated within the business processes
  • Promote communication internally and externally and at all levels (cascading from the top)
  • Protect workers from reprisal when reporting incidents,
    hazards, risk, and opportunities
  •  Provision and support for safety committees

For an external audit, the expectation is for senior leadership to be at the heart of the OH&S management system with a clear demonstration of understanding the system.

Clause 5.2: OH&S policy

Top management must establish, implement and maintain an OH&S policy. The policy must include a commitment to provide safe and healthy working conditions for the prevention of work-related injury and ill health and is appropriate to the purpose, size, and context of the organization and to the specific nature of its OH&S risks and OH&S opportunities. The policy should provide a framework for setting the OH&S objectives. The policy should include a commitment to fulfill legal requirements and other requirements. It should include a commitment to eliminate hazards and reduce OH&S risks. The policy should include a commitment to continual improvement of the OH&S management system. It should include a commitment to consultation and participation of workers, and, where they exist, workers’ representatives. The OH&S policy should be available as documented information. It should be communicated within the organization. It must be available to interested parties, as appropriate. It must be relevant and appropriate.

As per Annex A (Guidance on the use of ISO 45001:2018 standard) of ISO 45001:2018 standard it further explains:

The OH&S policy is a set of principles stated as commitments in which top management outlines the long-term direction of the organization to support and continually improve its OH&S performance. The OH&S policy provides an overall sense of direction, as well as a framework for the organization to set its objectives and take actions to achieve the intended outcomes of the OH&S management system. These commitments are then reflected in the processes an organization establishes to ensure a robust, credible and reliable OH&S management system (including addressing the specific requirements in this document). The term “minimize” is used in relation to OH&S risks to set out the organization’s aspirations for its OH&S management system. The term “reduce” is used to describe the process to achieve this. In developing its OH&S policy, an organization should consider its consistency and coordination with other policies.

Top management needs to establish, implement and maintain an OHSMS policy that includes a commitment to provide safe and healthy working conditions for the prevention of work-related injury and ill health and is appropriate to the purpose, size, and context of the organization and to the specific nature of its OHSMS risks and opportunities. The policy must be communicated, set out the framework for establishing measurable occupational health and safety objectives and targets, including a commitment to consultation and participation of workers or representatives and a commitment to eliminate hazards and fulfill legal requirements.

An OH&S Policy is a ‘Statement of Intent’ or ‘Mission Statement’ which sets out the framework to manage the Occupational Health and Safety Management System. The OH&S policy is approved by senior leadership and will drive the controls that are in place and the actions that are carried out to improve it. The standard specifically requires that the OH&S policy should include commitments to:

  • Provide a framework for setting objectives
  • Provide safe and healthy working conditions for the prevention of work-related injury and/or ill health
  • Eliminate hazards and reduce OH&S risks
  • Continual improvement of the OH&S system
  • Consultation and participation of workers and where they exist worker representatives
  • Fulfillment of legal and other requirements

Once the OH&S policy has been approved it must be communicated to stakeholders including workers. The policy must be available to interested parties, which will include customers and external providers on request. In addition, periodically the OH&S policy must be reviewed by senior leadership to ensure it remains applicable to the context of your organization.

Sample Occupational Health and Safety Policy

This policy will apply to __(Name of Business)_____ at all locations.

__(Name of Business)______________ is committed to providing a healthy and safe work environment for its workers and preventing occupational illness and injury. To express that commitment, we issue the following policy on occupational health and safety.
As the employer, (Name of Business) is responsible for the health and safety of its workers. __(Name of Business)______________ will make every effort to provide a healthy and safe work environment. We are dedicated to the objective of eliminating the possibility of injury and illness.
As _(CEO/Owner/etc.)______________ I give you my personal promise to take all reasonable precautions to prevent harm to workers.
Supervisors will be trained and held responsible for ensuring that the workers, under their supervision, follow this policy. They are accountable for ensuring that workers use safe work practices and receive training to protect their health and safety.
Supervisors also have general responsibility for ensuring the safety of equipment and facility.
__(Name of Business)__________________ through all levels of management, will cooperate with the Joint Occupational Safety and Health (JOSH) Committee or the Health & Safety Representative and workers to create a healthy and safe work environment. Cooperation should also be extended to others such as contractors, owners, officers, and so on.
The workers of (Name of Business) will be required to support this organization’s health and safety initiative and to cooperate with the JOSH Committee or Health & Safety Representative and with others exercising authority under the applicable laws. It is the duty of each worker to report to the supervisor or manager, as soon as possible, any hazardous conditions, injury, accident, or illness related to the workplace. Also, workers must protect their health and safety by complying with applicable Acts and Regulations and following policies, procedures, rules and, instructions as prescribed by
__(Name of Business)______________.
_(Name of Business)______________ will, where possible, eliminate hazards and, thus, the need for personal protective equipment. If that is not possible, and where there is a requirement, workers will be required to use safety equipment, clothing, devices, and materials for personal protection.
__(Name of Business)________ recognizes the worker’s duty to identify hazards, and supports and encourages workers to play an active role in identifying hazards and to offer suggestions or ideas to improve the health and safety program.
Signed:
Title:
This policy has been developed in cooperation with the  Committee, Health & Safety Representative, or workers.

—————————End of example—————————————

Clause 5.3: Organizational roles, responsibilities, and authorities

Top management must ensure that the responsibilities and authorities for relevant roles within the OH&S management system are assigned and communicated at all levels within the organization and maintained as documented information. Workers at each level of the organization must assume responsibility for those aspects of OH&S management system over which they have control. While responsibility and authority can be assigned, ultimately top management is still accountable for the functioning of the OH&S management system. Top management must assign the responsibility and authority for ensuring that the OH&S management system conforms to the requirements of this document. There must be reporting on the performance of the OH&S management system to top management.

As per Annex A (Guidance on the use of ISO 45001:2018 standard) of ISO 45001:2018 standard it further explains:

Those involved in the organization’s OH&S management system should have a clear understanding of their role, responsibilities, and authorities for achieving the intended outcomes of the OH&S management system. While top management has overall responsibility and authority for the OH&S management system, every person in the workplace needs to take account not only of their own health and safety but also the health and safety of others. Top management being accountable means being answerable for decisions and activities to the organization’s governing bodies, legal authorities and, more broadly, its interested parties. It means having ultimate responsibility and relates to the person who is held to account if something is not done, is not done properly, does not work or fails to achieve its objective. Workers should be enabled to report about hazardous situations so that action can be taken. They should be able to report concerns to responsible authorities as required without the threat of dismissal, disciplinary action or other such reprisals. The specific roles and responsibilities identified in 5.3 may be assigned to an individual, shared by several individuals, or assigned to a member of top management.

Top management needs to ensure that the responsibilities and authorities for relevant roles are assigned, communicated and understood throughout the organization. The scope and boundaries of the OH&S Management System must now be thoroughly examined and defined considering the aforementioned interested parties and their needs, plus resulting compliance obligations. Also requiring consideration are the OH&S Management System functions and physical boundaries, and all products, services, and activities, including the organization’s ability to exert control on external factors, with the results of the whole definition included in the OH&S Management System and kept critically as “documented information.”It requires the organization to define clear roles, responsibilities, and authorities throughout the organization.
It is recognized that overall responsibility for the OH&S management system falls to ‘Top Management’ however individuals must take account of their own health and safety and that of others. Consider documenting roles, responsibilities, and authorities within high-level and localized organizational charts. Individual policies and work instructions may also include responsibility and authority however competence must be considered. Top management is ultimately responsible for the OH&S management system, even if the day-to-day decisions related to occupational health and safety are delegated to others. What is delegated and to whom should be clearly and unambiguously communicated so that everybody understands who is responsible for what. Top management should assign responsibility and authority for:

  • Ensuring that the OH&S management system conforms to the requirements of ISO 45001;
  • Reporting on the performance of the OH&S management system to top management.

Since resources can be limited, opportunities should be sought out to integrate OH&S responsibilities within existing functions of the organization, such as manufacturing, facilities management, purchasing, and human resources. If other management systems are already in places, such as quality, environment, energy or food safety, synergies may exist where there are similar roles and responsibilities. This will enhance ownership of OH&S management across the organization and potentially create efficiencies. ISO 45001 requires that the responsibilities and authority of all persons who perform duties that are part of the OH&S management system be documented. These can be described and included in:

  • OH&S management system procedures;
  • Operational procedures and process maps;
  • Project and/or task descriptions;
  • Job descriptions;
  • Induction training packages.

Such documentation can, among others, be required for the following personnel:

  • Management at all levels in the organization, including top management;
  • Safety committees/safety teams;
  • Process operators and the general workforce;
  • Those managing contractors;
  • Those responsible for OH&S training;
  • Those responsible for equipment operation and maintenance;
  • Those responsible for facilities management;
  • Employees with OH&S qualifications, or other OH&S specialists, within the organization;

Care should be taken with the clarification of responsibilities at the interfaces between different functions (e.g. between departments, between different levels of management, between workers, between the organization and contractors and between the organization and its neighbors).

Some examples of Roles, responsibility, authority, and accountability 

1.) Managing Director:

  • Overall responsibility for the performance of the Organization
  • Overall responsibility & accountability for the OHS System, directly or through a nominated executive
  • Chair and Management Review Meeting
  • Define the OHS Policy
  • Review and approve the OHS System manual and its amendments
  • Ensures adequate resources are available for effective implementation
  • Appoint Management Representative
  • Approval of Purchase Orders for capital items
  • Overall accountable for continual improvement of the OHS Management system

2.) Cross-Functional Team:

  • Preparation of objectives and targets in consultation with Top Management
  • Conducting departmental reviews
  • Coordinate in providing resources for departmental elements of OHS.
  • Providing direction to the department on the design, implementation, and maintenance of OHS
  • Resolving corrective action issues
  • The MR is accountable for the effective implementation of OHS MS
  • Identify training needs for personnel directly reporting.

3) Legal Team:

  • Identify applicable legislation and other requirements.
  • Evaluate Legal compliance
  • Communicate the legal non-compliances
  • Hold review meetings on legal requirement.
  • Update with latest legislations / amendments.
  • DGM-HR is accountable for compliance with OHS legal & other requirements.

4) Audit Team:

  • Conduct Internal audits as per the audit schedule
  • Generate audit reports
  • Verify the audit closure
  • MR is accountable for conducting audit & NC closure

5) Emergency Response Team:

  • Review emergency response & preparedness manual
  • Train the people for emergency response
  • Conduct the role during the mock drill
  • To see the entry of unauthorized persons is restricted to areas.
  • To check whether Fire Extinguishers are provided at appropriate places and are tested periodically.
  • To check persons working are using proper PPE’s
  • To train the personnel over the safety & to identify key areas where safety is necessary
  • To identify safe assembly area
  • Impart safety awareness to all employees through in-house training as per the needs identified.
  • To check whether safety instructions have been prepared and displayed at relevant places through Operation control Instruction for use of Safety Personal Protective Equipment.
  • To see all the effectiveness of the emergency preparedness
  • An emergency response team has been constituted with Personnel from all departments to review / initiate actions for identified potential Emergency situations identify through the significant Study.
  • To co-ordinate with respective Functions head for identifying different types of emergency situations and prepares an “onsite emergency plan” which briefly describes the action to be taken by the employees during identified emergency situation internally.
  • To prepare an evacuation plan & to describe the plan for evacuation from the emergency area and to identify the gathering point.
  • To prepare mitigation actions after the emergency.
  • To organize Mock drills or Mock exercise, to test the Onsite emergency plan for the different identified emergency situations.
  • To make sure the Mock Drill records are maintained by the Safety Officer. To decide the possible changes needed in the emergency plans.
  • The safety officer is accountable for compliance with Emergency preparedness and response

6) First Aid Team

  • The team should regularly monitor medicine availability in the box.
  • The First Aid personnel shall take care of the injured persons and in case of an emergency condition.
  • The First Aid persons should take care that the injured persons are shifted to the hospital in time.
  • Admin Officer is accountable for maintaining adequate first aid medicines, providing first aid to injured personnel.

7) Safety Committee:

  • Safety Committee shall meet as often as necessary but at least once in three months. The minutes of the meeting shall be recorded
  • Safety Committee shall have the right to be adequately and suitably informed
  • Functions and duties of the safety committee shall include-
  • Dealing with all matters concerning health, safety, and environment, and to arrive at practical solutions to problems encountered.
  • Creating safety awareness among all the workers.
  • Undertaking educational, training and promotional activities.
  • Discussing reports on safety, environmental and occupational health surveys, safety audits, risk assessments, emergency and disaster management plans and implementation of the recommendations made in the reports.
  • Carrying out health and safety surveys and identifying the cause of accidents.
  • Looking into any complaint made on the likelihood of imminent danger to the safety and health of the workers and suggesting corrective measures and
  • Reviewing the implementation of the recommendations made by it.
  • Incident investigation results & review of the effectiveness of the action taken.
  • Safety Officer is accountable for conducting safety committee meeting.

The activity wise responsibilities are as shown below

S. No Activity

Responsibility

1 Appointing a Management Representative Managing Director
2 Selection of CFT Members MR
3 Review and approval of Policy Prepared by MR, Reviewed &  approved MD
4 Conducting Initial Review & Significant Impact / Risk Assessment CFT
5 Setting up objectives and targets  MR & CFT
6 Establishing Management Program MR & CFT
7 Approval of Management Program Managing Director
8 Identification of Legal and Other Requirements Legal Team
9 Providing resources for Implementation Managing Director
10 Identifying training needs CFT
11 Organising Training  HR Department
12 Internal Communication As per defined Procedure
13 External Communication
14 Document Control  MR
15 Operational Control Measurement & Monitoring CFT
16 Emergency preparedness and response Safety Officer & ERT Members
17 Review of Procedures after emergency ERT
18 Calibration of Instruments QA Deputy Manager
19 Handling and Investigating NC’s  MR & CFT
20 Initiating Corrective and Preventive action MR & Resp Dept HOD’s
21 Maintaining Records CFT
22 Conducting Audit Trained Internal Auditors
23 Conducting Management Review Managing Director

—————————End of example—————————————

 

Clause 5.4: Consultation and participation of workers

The organization must establish, implement and maintain processes for consultation and participation of workers at all applicable levels and functions, and, where they exist, workers’ representatives, in the development, planning, implementation, performance evaluation and actions for improvement of the OH&S management system. The organization must provide mechanisms, time, training and resources necessary for consultation and participation. Worker representation can be a mechanism for consultation and participation. The organization must provide timely access to clear, understandable and relevant information about the OH&S management system. It must determine and remove obstacles or barriers to participation and minimize those that cannot be removed. Obstacles and barriers can include failure to respond to worker inputs or suggestions, language or literacy barriers, reprisals or threats of reprisals and policies or practices that discourage or penalize worker participation. The organization must emphasize the consultation of non-managerial workers while determining the needs and expectations of interested parties and establishing the OH&S policy. The organization must emphasize the consultation of non-managerial workers while assigning organizational roles, responsibilities, and authorities as applicable. The organization must emphasize the consultation of non-managerial workers while determining how to fulfill legal requirements and other requirements. The organization must emphasize the consultation of non-managerial workers while establishing OH&S objectives and planning to achieve them. The organization must emphasize the consultation of non-managerial workers while determining applicable controls for outsourcing, procurement, and contractors. The organization must emphasize the consultation of non-managerial workers while determining what needs to be monitored, measured and evaluated. The organization must emphasize the consultation of non-managerial workers while planning, establishing, implementing and maintaining an audit program. The organization must emphasize the consultation of non-managerial workers while ensuring continual improvement. The organization must emphasize the participation of non-managerial workers while determining the mechanisms for their consultation and participation. The organization must emphasize the participation of non-managerial workers while identifying hazards and assessing risks and opportunities. The organization must emphasize the participation of non-managerial workers while determining actions to eliminate hazards and reduce OH&S risks. The organization must emphasize the participation of non-managerial workers while determining competence requirements, training needs, training and evaluating training. The organization must emphasize the participation of non-managerial workers while determining what needs to be communicated and how this will be done. The organization must emphasize the participation of non-managerial workers while determining control measures and their effective implementation and use. The organization must emphasize the participation of non-managerial workers while investigating incidents and nonconformities and determining corrective actions. Emphasizing the consultation and participation of non-managerial workers is intended to apply to persons carrying out the work activities but is not intended to exclude, for example, managers who are impacted by work activities or other factors in the organization. It is recognized that the provision of training at no cost to workers and the provision of training during working hours, where possible, can remove significant barriers to worker participation.

As per Annex A (Guidance on the use of ISO 45001:2018 standard) of ISO 45001:2018 standard it further explains:

The consultation and participation of workers, and, where they exist, workers’ representatives, can be key factors of success for an OH&S management system and should be encouraged through the processes established by the organization. Consultation implies a two-way communication involving dialogue and exchanges. Consultation involves the timely provision of the information necessary for workers, and, where they exist, workers’ representatives, to give informed feedback to be considered by the organization before making a decision. Participation enables workers to contribute to decision-making processes on OH&S performance measures and proposed changes. Feedback on the OH&S management system is dependent upon worker participation. The organization should ensure workers at all levels are encouraged to report hazardous situations so that preventive measures can be put in place and corrective action is taken. The receipt of suggestions will be more effective if workers do not fear the threat of dismissal, disciplinary action or other such reprisals when making them.

The organization must establish, implement and maintain processes for consultation and participation of workers at all applicable levels and functions, and, where they exist, workers representatives, to continually improve the OHSMS. These clauses require engagement with work health and safety committees and existing workers representatives. The essence of any health and safety management system is for an organization to proactively and systematically engage with its workers, at all levels, to collaboratively prevent: incidents, injury, and disease. There is considerable evidence that the effective participation of workers and the representation of their interests in OHS are crucial elements in improving health and safety performance at the workplace. This representation occurs through the use of health and safety representatives (HSRs). Clause 5.4 requires an organization to set up a health and safety management system process or processes to ensure the consultation and participation of all workers, including the representatives of workers. 45001 also states that organizations are to support the establishment of health and safety committees. So that workers have an ongoing role in improving the organization’s health and safety management system and its outcomes, by:
• Developing
• Planning
• Implementing and
• Evaluating the organization’s health and safety management system and its outcomes.
So as then to proactively and systematically improve the organization’s health and safety management system and its outcomes in reducing injury, illnesses, disease, and fatalities. 45001 also requires that the organization provides the necessary resources, training and time through its mechanisms for consultation and participation. When an organization decides to develop, plan, implement, performance evaluate, or improve their health and safety management system. Clause 5.4 also calls for the organization to give emphasis to the participation of workers who are not managers in the following:

  • Setting up processes for their consultation and participation
  • Hazard identification, risk assessment and opportunities for improving health and safety outcomes
  • Working on how to eliminate hazards and if not possible, then reducing remaining health and safety risks
  • Deciding health and safety risk controls and how to implement these effectively
  • Establishing: training needs, competence levels and the evaluation of training
  • Deciding the health and safety communication measures and the manner in which they are done
  • The investigation of health and safety incidents, including near misses and other types of exposures to hazards and their risks, including nonconformities with the health and safety management system, and decisions over actions to correct these.

Clause 5.4 specifically refers to giving emphasis to consulting workers who are not managers in the following;

  • Drawing up the work health and safety policy.
  • Working out who has what health and safety roles,
  • The determination of the organization’s fulfillment of their legal and other requirements.
  • Designing the health and safety objectives for the organization including plans for their achievement.
  • Working out risk management processes in the use of outsourcing, contractors, and procurement.
  • Decisions over implementing, monitoring, measuring and evaluating elements of the organization’s health and safety management system.
  • Decisions over applying the audit process, including the audit plan and its establishment, implementation and maintenance.

workers

Advertisements

Leave a Reply

Fill in your details below or click an icon to log in:

WordPress.com Logo

You are commenting using your WordPress.com account. Log Out /  Change )

Google photo

You are commenting using your Google account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s