COVID-19 Stress Online Discussion Group

By Jay Jarvis, CMCA, CCAM and Bruce Latta, CMCA

The Desert Cities HOA Council and CAI-CV’s Homeowners Leaders Committee online idea exchange for Coachella Valley Homeowner Association (HOA) Board members has gotten off to a successful start, although more participants are welcome. This is a valuable tool any time, but especially during challenging times such as these, when the COVID-19 virus makes it unsafe to meet face-to-face.

A recent discussion involved how HOA communities are dealing with the stress brought on by the COVID-19 virus.

One Homeowners’ Association (HOA) Board member wrote:

"The anxiety here has been with the pool closure/openings. Our pool areas have been open for weeks. We've used signage to place the responsibility for sanitation on those who enter the pool areas and locked up all the chairs and loungers. We didn't think people would heed the rules of social distancing and wiping down chairs."

That HOA Board member noted that they had presented a draft set of emergency rules, but other board members did not believe they were necessary. The individual also noted that there was a complaint to the board because “a vendor came on the property with no face covering.”

The Treasurer of another community wrote:

"We have not seen much anxiety among homeowners due to COVID-19. Nor are we having any video meetings other than board meetings and committee meetings. Other than regular issues it has been pretty quiet. Might be because so many people are gone for the season."

An HOA President wrote:

"We … have two pool/spas areas, but we are also in a community of five HOA's. All five presidents talk, to avoid conflicts between HOA's/Homeowners, especially when it came to the pools."

That President added:

"Our pool & spa areas have been open for a few weeks now, but with signage up to advise that all are to follow the County/City guidelines as to social distancing, masks, etc. and to take the responsibility for sanitation on themselves when they enter the pool areas, as to the gates, railings, furniture. …Again, about half our homeowners are gone for the summer now, so not that many left here use the pools."

The individual added that their association is using Freeconferencecall.com for meetings, because they don’t need video at this time.

A representative of a 55-and-over community noted that the homeowners have been “very good about staying at home.” However, the individual added: "We have a walking group of about 10 people that started out wearing masks but not the distancing and when Riverside County took the mask and distancing rules away so did they. A few still wear a mask every once in a while but never distancing."

To join the idea exchange, send an email to CAICV-HOALeadersForum+subscribe@groups.io. The subject line should state “Subscribe” (without the quotation marks). In the body of the email, include your name, the name of the HOA on whose board you serve, and your position on the board.

Bruce Latta, CMCA, is the Chairman of CAICV's Homeowner Leader Committee and is President of the Parc La Quinta Homeowners Association. He is the Project Manager for Indio Properties Land. He previously served as the manager of Jackson Monroe Owners Association. He has served as a fair and festival manager and is a Certified Fair Executive (CFE). He is a graduate of California State University Los Angeles and holds a certificate in Meetings and Events Planning from San Diego State. Bruce can be reached at 760-285-5617 or by email to plqhoablatta@gmail.com

E.J. (Jay) Jarvis II, CMCA, CCAM is community manager with HOA Office, Inc., Past President, Lafayette Village Homeowners Association, Past President and On-site manger of Portola Palms Homeowners Association. Jay can be reached at jay@HOAOffice.net.

Coronavirus and Community Association Insurance

Managing Expectations During the Pandemic

By Joel W. Meskin, Esq., CIRMS, CCAL , MLIS, EBP

My question, as someone who has been spending a great deal of time answering questions on the coronavirus and insurance coverage is: did any prior pandemic, epidemic or outbreak of a communicable disease lead to the myriad of insurance issues we are now being asked to respond with clear and immediate responses. Maybe our standard response should be “maybe” or “it depends” on many variables before an intelligible response can be provided. This conundrum provides numerous opportunities for creative coverage attorneys representing Insureds to boldly assert and plausibly argue to find coverage where no such coverage was intended to exist. To trigger coverage under the Insured(s) Association Property Policy requires the existence of the coronavirus in a common area constituting “property damage.” To satisfy the existence of property damage, most property policies require that there is a "Covered Cause of Loss" (i.e. is the coronavirus a covered cause of loss) that results in direct physical loss of or damage to the Insured(s) covered property? I presume, but do not assume, that these requirements will not be met to trigger coverage for direct physical

THE CORONAVIRUS PANDEMIC HAS FOUND MOST OF US WITH OUR ARMS UP IN THE AIR. THESE ARE DEFINITELY UNCHARTERED WATERS.

damage in the majority of jurisdictions. I also presume, but do not assume, that contingent damages arising or resulting from the alleged property damage will not be covered. These potential coverages include business interruption loss, loss of business income or loss of use.

The anticipated arguments, protracted litigation, attorney fees and costs, as well as the fees and costs of countless multidisciplinary experts will depend on specific policy wording, state laws, court interpretation, judges and creative attorneys. All these factors will ultimately determine coverage or no coverage. These coverage issues and related litigation will undoubtedly go on for years, or until the insureds can no longer afford the fight. If you would like to get a taste of what we can expect, just Google "Insurance Coverage Issues arising out of the World Trade Center Occurrence/Occurrences." On the other hand, insurers may choose to resolve such claims on a cost of business basis. This is less likely due to the nature and extent of the potential claims.

I do not believe that insurers ever intended for coverage to exist under these circumstances. There are potential cases where express language, endorsements or definitions providing coverage exist. I also confidently contend that actuaries did not consider these exposures in developing rating and other modeling they use to best anticipate acceptable loss ratios and underwriting criteria, necessary to properly price coverage for the intended exposure. Again, this is different where there is specifically crafted or included provisions creating coverage.

COMMUNITY ASSOCIATION INSURANCE FOR CORONAVIRUS

The following chart sets forth the basic community association insurance puzzle. It is anticipated that Insured(s) may seek coverage under the four highlighted policies below: General Liability, Directors and Officers Liability Coverage, Workers Compensation Coverage and Property Coverage.

Coronavirus and Community Association Insurance — Which policies may apply?

Purple = 3rd Party Liability

Red = first party coverage for the Insured(s) property Blue = package policy for Unit Owners

Green = Assn Package policy for both Property and Liability

Black = Association Self Insurance General Liability Coverage

Workser Compensation Coverage Earthquake Insurance

Special Event

Business Partner Professional Liability Policy

Directors & Officers Liability Coverage

Property Coverage

Wind Coverage

Master Policy Condo - Coop - SF HOA - Townhouse

Additional Insured Status on Contractor GL Policy

Employment Practices Liability

Fidelity Coverage

Flood Insurance

Homeowners Policy Single Family HOA

Bank Loan Umbrella Liability Auto Liability Coverage

Crime Insurance

Cyber Liability

Condo Unit Owner HO6 Policy Fiduciary Coverage

Data Breach Response Services

Coop Shareholder Policy

Association's Assets

Special Assessment

Joel W. Mcskin © 2018 InsurancePuzzle Community Association

The focus of the issues set forth below involves the “common elements, property and amenities” of a not-for-profit community association such as a Condo, Coop or HOA. In addition, the focus here is on the alleged consequences from the existence of the coronavirus existing in/on a common element. These may have issues that differ from an analysis of a business where direct financial loss will result from the closure of a business due to direct physical loss to the Insured’s property.

In order to analyze the existence of coverage under the various community association program, it is helpful to understand how to look and review an insurance policy. Notwithstanding the bad rap that insurance policies have for being filled with small print and legalese, there is a method to the madness. The carriers need to protect the intent they have behind an insurance product. Accordingly, if they do not cross every “t” and dot every “i”, they will be challenged on virtually every claim because without being this careful, the policy will be attacked as having language that is vague and ambiguous resulting in having the language being construed in favor of the Insured(s). FOR ALL INTENT AND PURPOSE, ALL PROPERTY AND CASUALTY POLICIES ARE BUILT THE SAME WAY. SPECIFICALLY, THEY ARE STRUCTURED AS FOLLOWS:

• Insuring Agreement – Gives you the world • Definitions – Defines the world • Exclusions – Takes away a part of the world • Covered under another policy • Would make the policy unaffordable if not excluded • Against public policy • Conditions – What Insured must do to trigger coverage • Endorsements and Amendments – change the basic form. • Issued with policy • Including State Amendatory endorsements • Added later

As the issues below are reviewed, the structure set forth above will help you understand why coverage is applicable to the potential coronavirus alleged claim for injury or damage.

Issue No. 1: Most property insurance policies require that the Insured(s) property suffer direct physical damage to Insured property resulting from a covered peril. Does the existence, or possible existence of coronavirus constitute direct physical loss or damage to Insured property?

Response No. 1: Probably not.

Property Damage: Is there coverage for Property Damage under the Association Property and or Master Policy Property Coverage Part?

Does Coronavirus = "Property Damage?"

To trigger coverage under the Insured(s) Property Coverage Policy is that the existence of the coronavirus in a common area constitutes "property damage."

Property Damage Direct Physical Loss

To satisfy the existence of property damage, most property policies require that there is a "Covered Cause of Loss" (the coronavirus) that results in direct physical loss of or damage to the Insured(s) covered property.

Coronavirus does not equal Direct Physical Loss or Damage to the Insured(s) Common Elements.

Insured(s) will try and assert that the coronavirus introduced into the common elements constitutes direct physical loss or damage. Policy interpretation is subject to state law. Courts in some states have opined that contamination and other incidents that render property uninhabitable or otherwise unfit for its intended use constitutes a "physical loss." I believe that this is the minority opinion. Moreover, this argument would not be to the coronavirus. The coronavirus issue in community associations is not really the existence of contaminated property as a result of the virus. One study concluded as follows:

“The researchers behind the new study tested the virus' life span in a 71-degree-Fahrenheit room at 65% relative humidity. After three hours, the virus had disappeared from printing and tissue paper. It took two days for it to leave wood and cloth fabric. After four days, it was no longer detectable on glass or paper money. It lasted the longest, seven days, on stainless steel and plastic.” (Business Insider, April 7, 2020 - https://www.businessinsider.com/ coronavirus-lifespan-on-surfaces-graphic-2020-3)

The coronavirus issue in community associations is arising out of the closing of non-essential common elements to prevent social gathering and the spread of the virus. An association not heeding governmental orders or the recommendation of virtually all health care providers is what the association should be concerned with.

The coronavirus as is discussed each day all day in the news has an extremely short life. By the time the property can be tested for any contamination by coronavirus, or the governmental orders are lifted, the existence of the coronavirus would be moot. The coronavirus would no longer exist.

How long the new coronavirus can live on surfaces

Paper and tissue paper** Copper* Cardboard*

Wood**

Cloth**

Stainless steel*

Polypropylene plastic* Glass** 3 HOURS

4 HOURS

24 HOURS

2 DAYS

2 DAYS

2-3 DAYS

3 DAYS

4 DAYS

Paper money** 4 DAYS

Outside of surgical mask** 7 DAYS

*At 69.8 to 73.4ºF (21 to 23 ºC) and 40% relative humidity Source: New England Journal of Medicine*; The Lancet Microbe** ** At 71ºF and 65% relative humidity BUSINESS INSIDER

The physical nature and life of the coronavirus is different than that of asbestos and mold where there are much stronger arguments that they constitute contamination of actual property damage and will not go away without remedial measures. Coronavirus will self-eliminate.

Issue No. 2: Is there coverage for testing and or remediating costs?

Response No. 2: Probably not.

There is no coverage for testing or remediation costs, again if there is no direct physical damage or loss. The discussion to this response is the same as Response No. 1.

Issue No. 3: In the unlikely event that the coronavirus is considered “property damage,” will there be any other impediment to coverage?

Response No. 3:

A. Yes. Even if the property damage is established, there are numerous exclusions that would apply. These exclusions further support that insurers had no intent to provide coverage.

B. No. Coverage may exist where a policy may have a specific endorsement. This is not likely for community associations, however, because of extremely prohibitive costs. This is more likely in an industry such as restaurants and the hospitality industry where the significant cost can be included in the cost of doing business. These supplemental coverages in the normal course will not include the direct physical loss of damage requirement.

Accordingly, the mental gymnastics of whether there is property damage or not is avoided.

Consequential Damages

To trigger Consequential Property Damages coverage under the Insured(s) Property Policy (aka Master Policy,) there must be the existence of the coronavirus in a common area constituting "property damage."

Consequential Property Damage Requires:

Direct Physical Loss to the Insured Property Beware of State Legislators

There are currently seven states where legislators are trying to put the onus on insurance carriers for the damages regardless of there being no coverage. such as Business Interruption, Loss of Income or Loss of Use? Response No. 4: No.

For these coverages for consequential damages, the damage must again result from Direct Physical damage or loss to The Insured(s) property. Accordingly, the same discussion in Response No. 1 above will apply here.

Keep in mind that Business Interruption insurance is intended to protect businesses against income losses sustained as a result of disruptions to their operations. Contingent business interruption coverage similarly provides insurance for financial losses resulting from disruptions to a business's customers or suppliers, usually requiring that the underlying cause of damage to the customer or supplier be of a type covered with respect to the business's own property.

In the community association context, the interruption of operations may be argued to be the unit owner members’

inability to pay fees and assessments. This is not the result of coronavirus in the community association, but the result of the impact on their business or employment. This is too attenuated from the community association. With respect to the association’s inability to pay business partners such as landscapers, pool services or the like, the potential issue would not be a property policy issue. The potential risk will a claim or suit against the association for breach of contract. As a breach of contract issue, there may be a defense pursuant to a Force Majeure provision in the contract (unforeseeable circumstances that prevent someone from fulfilling a contract).

Issue No. 5 If the board opens common elements such as pools, clubhouses and gyms, will any insurance policy defend or indemnify the board?

Response No. 5: No.

Board Decisions: If the board opens common elements such as pools, clubhouses and gyms, will any insurance policy defend or indemnify the board? What if the board closes common elements?

Issue No. 4: Is there coverage for consequential damages

Director and Officers Liability Coverage

1. Claim

Written Demand for $ or non $ Relief open common element or close common element.

2. Insured(s)

Wrongfully opened or wrongfully closed.

3. Wrongful Act

Wrongfully opened or wrongfully closed.

4. Timely Reported to Insurer

If 1+2+2+3+4 is missing then no coverage - Stop

If 1+2+2+3+4 exist see if any Exclusions apply

5. Exclusions

Bodily Injury, Property Damage, Pollution a. Bodily Injury Exclusion Includes Death, Emotional

Distress and Sickness or Disease b. Property Damage c. Pollution Exclusion

If a, b or c no coverage. If no a, b and c then coverage.

if a unit owner or guest got sick with negligently maintained the common elements that could not be closed (i.e. elevators, entry doors or stairways)? Sickness: Would there be coverage if a unit owner or guest got sick with CORVID-19 alleging the association negligently maintained the common elements that could not be closed (i.e. elevators, entry doors or stairways)?

General Liability Coverage

Insuring Agreement

We will pay those sums that the insured becomes legally obligated to pay as damages because of "bodily injury" or

"property damage" to which this insurance applies. Duty to Defend

We will have the right and duty to defend the insured against any "suit" seeking those damages. Personal Injury and Advertising Injury.

Occurrence

An accident, including continuous or repeated exposure to substantially the same general harmful conditions [only applicable to BI and PD, not PI or AI]. Intended and Expected Exclusion

Pollution Exclusion

Sudden & accidental requirement. Definition of Pollutant: an irritant or contaminant, whether in solid, liquid, or gaseous form, including—when they can be regarded as an irritant or contaminant—

smoke, vapor, soot, fumes, acids, alkalis, chemicals, and waste. Communicable Disease Exclusion

"Bodily injury" or "property damage" arising out of the actual

Issue No. 6: Would there be coverage CORVID-19 alleging the association or alleged transmission of a communicable disease. Response No. 6: Probably Not.

Issue No. 7:

policy? Is the CORVID-19 disease covered under a workers compensation

Response No.7: No.

Workers' Compensation: Is the CORVID-19 disease covered under a workers' compensation policy?

Workers' Compensation

Workers' Compensation

Statutory Requirement No Fault Employers are required to pay compensation and medical for employees injured in the course of employment.

Workers' compensation insurance is meant to cover illness or injury "arising out of or in the course of employment."

Will workers' compensation cover CORVID-19 as a result to show that the exposure to coronavirus it is work-related rather than an ordinary disease of life to the public.

Probable Exception:

Is if the exposure to coronavirus as a natural consequence of their jobs.

CONCLUSION:

In going through analysis of each issue above, it should be clear under which portion of the policy structure it falls. (1) Does the alleged claim meet the elements of the insuring agreement? (2) If one is satisfied, does one of the definitions work to defeat coverage? (3) If there are no definitions to defeat coverage, are there any exclusions that apply and is the exclusion preclude defense and indemnity, or just indemnity still requiring the carrier pay for the defense? (4) Is there an applicable condition that has not been made, such as the time in which a claim must be reported to the carrier? And, (5) Is there an endorsement that changes any terms or conditions or removes an exclusion or condition? I always make it a practice to review the endorsements first and be prepared to know if something I review in the actual policy has been changed.

I opine that there is not going to be coverage under any of these policies for any of the issues presented. However, that does not preclude the possibility that attorneys will not challenge the basic policy forms. Insureds will have to do a cost benefit analysis in the event there is a possibility to challenge a policy provision.

(Copyright© 2020 Joel W. Meskin) THIS ARTICLE IS NOT A LEGAL OPINION, IS NOT THE POSITION OF ANY SPECIFIC INSURER OR THE MCGOWAN COMPANIES. THESE ARE THE BEST THOUGHTS OF THE AUTHOR.

Joel W. Meskin, Esq is the Managing Director Community Association Products for McGowan Program Administrators. He is also a Fellow, in CAI’s College of Community Association Lawyers ("CCAL") and holds his CAI Community Insurance and Risk Management Specialist ("CIRMS") designation He also holds the Management Liability Insurance Specialist ("MLIS") designation and the National Community Association Institute Educated Business Partner Distinction (“EBP”). He is a Founding Member of the Foundation for Community Association Research (“FCAR”) Think Tank, a member of the National Community Association Institute Board of Trustees (2017- 18); (2019-20) and Chair of the National Community Association Institute Business Partner Council (2018), and a CAI National Corporate Member. Joel can be reached at (800) 545-1538 or by email to Jmeskin@mcgowanins.com.

Duck, Duck, Turtle — Antibiotic Immunity Transmission to Algae

By Patrick Simmsgeiger, CLM

During these uncertain times related to COVID-19, there are still things we can do to prepare our businesses and properties for the new norm which is certainly around the corner. Although this piece may initially add to your list of concerns, hope springs eternal that knowledge can be acted upon, and good stewards can make difficult decisions to protect all stake holders.

I remember my mother refusing to get a turtle for me as a pet. She understood that turtles transmitted salmonella, but she probably had no idea baby turtles also transmitted hepatitis-B. She told me not to touch the ducks in the neighborhood lake. She probably heard they hosted alpha-herpes virus, which caused high mortality rates in ducks, geese and swans. This disease first appeared in Long Island in 1967, transmitted from European flocks. In the last 50 years, these health threats have spread worldwide and normalized in the public mind. There is emerging evidence that turtles, ducks and geese, adapted to the diseases they carry, spread antibiotic-resistant bacteria. As an aquatic expert, what keeps me awake some nights is the possibility these bacterial strains could transfer their resistance to water algae. Ducks and turtles are as ubiquitous to water environments as shells on a beach. These water species excrete waste with bacterium, which settles into soil already laced with antibiotic runoff from

human activity. This long-term buildup becomes a habitat for new generations of bacteria. In a scientific study of a meat duck farm conducted in 2017, the data indicated that the deeper the excrement layers, and the longer these layers went without removal, the more numerous the antibiotic-resistant bacterial species, plus the greater number of antibiotics to which these species showed resistance. These bacteria also evolved resistance

to zinc, copper and cadmium. Copper is the primary element used to control algae and cyanobacteria in water. A Harmful Algal Bloom (HAB) is the result of runaway algae and cyanobacteria growth when heat and nutrient loading are abundant, and eco-diversity is low. HABs can be extremely toxic.

Could algae learn antibiotic and copper resistance from bacteria? Algae are in every environment on the Earth, having emerged as a simpler species about 1.7 billion years ago. Bacteria existed a couple billion years before that. Cyanobacteria preceded these by about 1 billion years, being the first life on this planet. Clearly these species learned or stole abilities from each other, then continued to evolve to the present day. It would be very unlikely that this adaptive behavior has suddenly come to a stop. More likely, these microorganisms are reacting to human activity, feeding on modern waste, adapting to our chemicals, while they continue to compete and learn from one another. Microorganisms comprise the vast majority of biomass, which has always been true and will probably always be true; humans are a recent experiment.

Many aquatic companies that treat algae promise to eradicate the problem. The fact is, algae colonies cannot be completely eliminated, only limited in

size and reproduction by using proper tools and procedures. Not only are there immense varieties of algae and bacteria adapted to every environment, but each cell of a species has the capability to create a daughter with new characteristics. If human teenage girls are tough, they have nothing on microorganisms. According to a recent estimate, there are about one trillion species of microbes on Earth, and 99.99 % of them have yet to be classified. Clearly, microorganisms have no problem evolving through adaption, with the newer species adapted to consume the most abundant form of nutrients, while resisting threats that limited their mother cells.

Once we accept the possibility of an inter-species exchange of resistance, what is the possibility this new algae strain would move out of its home pond? The same bird groups that excrete large amounts of waste also move from lake to lake. Birds visit all the water features in their territory but have a favorite spot; turtles have a capacity to travel as well. The wind plays a large role in transporting bacteria and other microorganisms over long distances. Empirically, the entire Earth is covered by microorganisms well-suited to each set of conditions.

"Survival of the fittest" is the rule, so there is every reason to believe that once a species can resist local defenses, it will find a way to spread to every nutrient source available.

Aquatic experts rely on a limited number of products to control algae, ultimately using copper as the active control ingredient, when more subtle treatments fail. Although antibiotic resistance is a problem all its own, it is algae’s resistance to copper that presents global concerns. But what can be done; is this an inevitable response of Nature to human activity? The most obvious step is to reduce human runoff into streams and lakes, which is a solution beyond the scope of aquatic managers. Next is the cleaning of muck layers from lakes and ponds, which is effective and doable, but not cheap. This step is commonly delayed for years, even decades, for budget and permit reasons. The last solution is the control of bird and turtle populations, which is an easy action to consider, but socially and politically difficult to carry out.

Reducing bird and turtle populations first runs into regulatory issues. These restrictions have nothing to do with The Endangered Species Act of 1973, but rather stem from public opinion. A complicated permit process, adding costs and delays, plus public relation issues are the bane of property managers and municipalities. Restrictions on turtle, bird and fish removal are commonly the final straw that defeats even a permitted plan. There is a San Francisco property that requires humane fish e ut h a n i z i n g ,

beginning with a gentle capture, then freezing, and finally a chemical softwash. After many years they are still looking for a contractor. Most water features in the United States are decades beyond their life span for muck removal. This delay in cleaning exacerbates and encourages the biologic risks, while also limiting water health overall.

Being alarmist in no way benefits a professional discussion, or any form of governance. Water management experts think in terms of years at a property, drawing on decades of experience. Yet recent events have demonstrated how quickly the status quo can change, how our assumptions about safety can become obsolete. In 1967, Avian Infectious Bronchitis Virus was studied as a crossover vector for human bronchitis. Interestingly, this was the same year flocks were found dead in Long Island from a European infection. Today, we may be ignoring signs of a larger problem, where algae could learn antibiotic and copper resistance from bacteria, vectored through birds and turtles, which densely populate neighborhood water features. Even if we recognize the signs, our hands remain effectively tied by sentiment for these adorable creatures, many of which we encourage to live in our underserved lakes.

Pat Simmsgeiger is the President of DWI, a Certified Lake Management company and manufacturer of aquatic products for 35 years and counting. Being a vital industry supplier, DWI is maintaining service to clients and consumers during the COVID-19 event with modified work practices and procedures.

Patrick Simmsgeiger is President of DWI and is a Certified Lake Manager in California. He has been maintaining lakes since age 14. He manufactures and distributes products for bodies of water, maps water features, offers fish stocking, organic sediment removal, and provides daily care year-round for many clients in California and Arizona. REFERENCES:

https://www.ncbi.nlm.nih. gov/pubmed/27744296

Accumulation of antibiotics and heavy metals in meat duck deep litter and their role in persistence of antibiotic-resistant Escherichia coli in different flocks on one duck farm. - 2017 https://www.hindawi. com/journals/ijmicro/2017/5798161/

Antibiotic Resistant Bacterial Isolates from Captive Green Turtles and In Vitro Sensitivity to Bacteriophages – 2017 https://www.worldwildlife.org/ pages/the-us-endangered-species-act

The US Endangered Species Act of 1973 https://www.ncbi.nlm.nih. gov/pmc/articles/PMC375381/ pdf/jvirol00329-0177.pdf

Morphogenesis of Avian Infectious Bronchitis Virus and a Related Human Virus (Strain 229E) - 1967