Attachment_I_Performance_Work_Statement.pdf

Attachment I TSA Hazardous Materials Management Program Support Performance Work Statement

Version 1.0

Transportation Security Administration TSA Hazardous Materials Management Program Support

Attachment I TSA Hazardous Materials Management Program Support

PART 1

INFORMATION

1.0 Detailed PWS Information

1.01 Background: Prior to passage of the Aviation and Transportation Security Act (ATSA), Pub.L. 107-71, the air carriers were responsible for the screening of commercial air carrier passengers. They also were responsible for the collection and disposition of all prohibited items, including hazardous materials. With the passage of ATSA, TSA became responsible for the screening of these passengers. 49 U.S.C. §44901(a).

As a result, TSA decided to accept prohibited and hazardous items abandoned by passengers at security checkpoints.

Having accepted the property, TSA is legally responsible for the disposition of abandoned or forfeited personal property.

Hazardous materials, if not otherwise donated per 41 CFR 101-42.304, must be disposed of in accordance with Federal and state laws and regulations. 42 U.S.C. §6901 et seq.

In 2003, TSA issued the National Voluntarily Abandoned Property and Hazardous Material Disposal Contract to assist with the management, disposition and disposal of the prohibited and hazardous items abandoned by passengers at security checkpoints. In April 2005, TSA added lighters to the prohibited item list as directed by Congress in the Intelligence Reform and Terrorism Prevention Act of 2004. Liquids, Gels, and Aerosols (LGA) were also added to the prohibited list in August 2006 while lighters were removed from the prohibited list in August 2007. As a result, the type and amount of hazardous items abandoned by passengers at security checkpoints have changed and increased in quantity since April 2005.

1.02 Objectives:

● Ensure that hazardous materials items abandoned by passengers at security checkpoints are disposed of in accordance with Federal and state laws and regulations.

● Maintaining Regulatory Compliance by way of audits, inspections, research, obtaining and maintaining any necessary licenses or permits, and complying with any applicable Federal, state and local laws, codes and regulations in connection with the performance of this statement of work.

● Providing an automated reporting system housing documents and records that allows TSA web access, on a near real-time basis, “Cradle to Grave” tracking of all hazardous materials.

1.03 Scope/High-level Description: Provide all personnel, equipment, tools, materials, vehicles, supervision, and other items and services necessary to perform hazard materials management and disposal for approximately 450 airport locations (and ancillary TSA offices when necessary) ( Technical Exhibit 2). The number of airports and airport locations is subject to change throughout the life of any resultant contract depending on privatization and Federalization decisions, new airports opening, the operation of seasonal airports or reorganizations that affect TSA operations).

Services shall be performed for all airports/collections areas. Perform to the standards meeting or exceeding all Federal, State, and local regulations. Historical contract data listed in Technical Exhibit 1.

1.04 Requirements:

A. Basic Services. Provide Hazardous Materials Management and Disposal Services to the Transportation Security Administration (TSA). These services will ensure the environmentally compliant management, collection, storage, packaging, transportation and disposal of hazardous materials voluntarily abandoned at airport security checkpoints and other TSA facilities, including other hazardous wastes generated by TSA.

Attachment I TSA Hazardous Materials Management Program Support

B. Administrative and Program Support. Provide a management team, qualified staff and resources to complete all Administrative and Program Support tasks to include:

1. All Contractor (including Contractor team partners and subcontractor) personnel shall have the required applicable and current Federal, state and local training for the handling, transporting and disposal of potential hazardous materials.

2. All Contractor (including Contractor team partners and subcontractors) personnel shall provide all equipment, tools, and personal protective equipment and any other items and services necessary to perform Federal, state and local compliant recycling or disposal of potential hazardous material.

3. Contractor shall provide a weekly status report to the TSA Office of Occupational Safety, Health, and Environment (OSHE).

4. Contractor shall provide a monthly summary report to OSHE.

5. Contractor shall provide a quarterly status report to OSHE and attend quarterly status meetings in the Washington DC metropolitan area, to be scheduled in conjunction with OSHE.

6. Contractor shall provide a non-emergency field contact phone number that is manned from 8:00am to 8:00pm EST from, Monday through Friday at the Contractor’s location.

7. Contractor shall provide an emergency phone number at the Contractor’s location that is manned 24 hours per day, seven (7) days per week, 365 days a year.

8. Provide an e-mail address, maintained on the Contractor’s mail server, for communication with TSA field elements. This e-mail address shall be housed on the Contractor’s system and made accessible to all necessary TSA employees. All e-mails sent to and from the address shall be retained indefinitely and made available to TSA upon request.

9. Contractor shall review, update, and distribute the TSA owned Standard Operating Procedures for Voluntarily Abandoned Property and Hazardous Materials Disposal, annually. A final draft shall be approved by a designated TSA representative(s). Distribution to TSA Federalized airports after TSA approval of the final draft.

10. Contractor shall establish and execute a quality control plan to ensure the quality of service, products and deliverables issued to or on behalf of TSA.

11. All Contractor and subcontractor personnel that perform contract support activities at TSA facilities shall successfully complete the TSA badge and credentialing vetting process.

12. All vetted Contractors and subcontractors shall successfully complete TSA designated training each performance period of the contract. Training is estimated to be 40 hours per year.

C. Regulatory Support. Responsible for obtaining and maintaining any necessary licenses or permits, and for complying with any applicable Federal, state and local laws, codes and regulations in connection with the performance of this statement of work. Included but not limited to:

Attachment I TSA Hazardous Materials Management Program Support

1. Acquiring any required permits or notifications of regulated waste activity, not already obtained by TSA.

2. Payment of one-time and annual fees that are necessary for the federalized airports listed in the contract.

3. Development and submittal of annual reports to Federal and state regulatory agencies, as required.

4. Monitoring, and changing if necessary, generator status.

5. Similar support for other TSA facilities will be upon request.

6. Upon request, perform regulatory research in support of TSA HQ.

7. Upon request, provide assistance to TSA airport operations and facilities to respond to regulatory inquiries.

8. Perform six (6) total compliance assistance visits to TSA Federalized airports as selected by OSHE each year. The purpose of these visits will be to review the hazardous material management practices at the airports and provide guidance and support to correct any deficiencies. All corrective actions shall be coordinated through and approved by OSHE:

Checklist of practices to be developed by Contractor and approved by TSA. For each visit, a trip report (in mutually acceptable Contractor format as developed under subparagraph 3 below) shall be submitted to TSA within the timeline specified in the Delivery Schedule of this PWS. Trip report format shall be developed by Contractor and approved by TSA no later than 30 calendar days after contract award.

9. Perform surveys of at least two (2) airports per week to collect information on the facilities waste management activities, quality of the service provided by the Contractor or its subcontractors, and to verify/update point of contact information. Survey template to be developed by Contractor and approved by TSA no later than 45 days after contract award.

Quarterly Summary of surveys to be provided to TSA during Quarterly Status meetings.

D. TSDF Audits. Contractor shall perform environmental audits of the Treatment Storage and Disposal Facilities (TSDF) that receive TSA wastes. TSA shall provide the format for all audits. Audits include:

1. Phase I: Annual document review

● TSDF financial status – Dun and Bradstreet and other similar financial data review sources

● TSDF regulatory status – Compliance history, notices of violation or non-compliance findings, resolution of notices of violation or non-compliance findings. Review of pending or current litigation

1a. Phase II: Site facility audits

Attachment I TSA Hazardous Materials Management Program Support

● Up to three facility audits per year – Lines of Inquiry (LOIs) for each site visit shall be developed from applicable checklist items included in EPA-305-B-98-006, Protocol for Conducting Environmental Compliance Audits of Treatment, Storage, and Disposal Facilities under the Resource Conservation and Recovery Act. Auditors may add or supplement these LOIs, as needed, during the planning and execution of audits to ensure that all applicable and relevant areas are fully addressed.

E. Documentation and Safe Record Keeping. Provide an automated reporting system that allows TSA web access, on a near real-time basis, “Cradle to Grave” tracking of all hazardous materials. This reporting system shall be housed on the Contractor’s system but be available via remote access to all necessary TSA employees. Access control to the system will be limited to those Contractor employees performing on the contract and those TSA employees designated by the agency as having a need for access to the information.

1. The reporting system shall be capable of securely storing and generating information on specific information, including but not limited to:

1a. Pickups requested, Scheduled pickups, pickups completed 1b. Copies of Manifests, Bills of Lading, or other shipping papers 1c. Copies of land disposal restrictions (LDR’s), packing lists, test results, or waste analysis results, waste profile sheets, manifest correction letters, licenses, permits, and certifications.

1d. Copies of Certificates of Recycling/Disposal to include method of disposal (e.g. T07 – incineration, D80 – Landfill) 1e. Record of one time payments and annual payments as well as original payment requests from Federal or State regulatory agencies.

1d. All disposal documentation will be submitted electronically via the web portal to TSA designated personnel and cross-reference the following:

● Name and address of generating activity

● Three (3) digit airport code

● EPA ID number

● Contract number, task order, and/or work order numbers

2. Sign, on behalf of TSA, all manifest, Bills of Lading, waste profile sheets and any other documentation that “requires generator’s signature.”

3. Ensure that all originals or hardcopies that are necessary for compliance be provided to the TSA generating location/facility within timeframes prescribed by law.

F. Emergency and Spill Response Support. (Make this a separate CLIN) Contractor shall provide emergency spill response and support in full compliance with 29 CFR 1910, 49 CFR and 40 CFR.

1. TSA Emergency and Spill Response Support. Contractor shall provide 24 hours per day, seven (7) days per week, 365 days a year Emergency and Spill Response assistance, including but not limited to:

1a. Operating a 24 hour emergency telephone hotline;

1b. Taking reports of leaks and spill from TSA locations;

1c. Reviewing emergency procedures with TSA field contact(s) to ensure every step of the procedure has been implemented;

1d. Evaluating EPA or state reportable quantities;

1e. Reporting, if necessary, on behalf of TSA all reportable spills to the National Response Center;

Attachment I TSA Hazardous Materials Management Program Support

1f. Providing regulatory information and guidance to on-site TSA personnel;

1g. Scheduling, if necessary, the pickup and disposal of the waste and the materials used to contain and clean up spill; and 1h. Reporting to designated TSA personnel within four hours, all received report(s) of leaks or spills with the following information:

1. Description of item spilled (including identity, quantity, etc.).

2. Whether amount spilled is EPA/state reportable, and if so, whether it was reported.

3. Time and location of spill including a description of the area involved.

4. Containment procedures initiated.

5. Summary of any communications Contractor has with Government officials other than the

Contracting Officer. Public comments or issue press releases without written consent from the Contracting Officer or the Contracting Officer’s designee are prohibited.

6. Description of clean-up procedures employed or to be employed at the site including disposal location of spill residue.

7. Estimated time of completion (if not already complete)

G. Contractor Emergency and Spill Response. Respond to all spills or leaks that occur as a result of Contractor sorting, packaging transportation, or treatment of hazardous materials.

1. Containment and clean up shall be performed for such spills or leaks in a manner that complies with applicable Federal, state, and local laws and regulations.

2. Report to TSA any spill or leak of TSA wastes that result in a call to the National Response Center within four hours of occurrence.

G. Training Support. Upon request from TSA, Contractor shall provide training, qualified training staff, and training materials, as required, to ensure that TSA personnel involved in the handling of potential hazardous materials and prohibited items obtain the expertise required to properly identify, log, handle, and store these materials. Training shall be funded separately by TSA and no training shall be conducted without a funded CLIN and authorization from the Contracting Officer’s Representative (COR). Training will primarily be for the TSA biannual workshop.

a. 1. Training materials (including handouts, CDs, slide presentations, badges, posters, informational cards, books, etc) shall be made available to class participants.

b. 2. Training may be in groups of approximately 20-25 individuals or as small as groups of 1-5 individuals.

c. 3. Training course may last one to three days.

d. 4. Training will be held at TSA designated locales.

e. 5. Maintain a list of those TSA employees it has trained and provide that listing as part of the

Quarterly Report

f. 6. Contractor shall coordinate all aspects, as required, for the training course including but not limited to:

6a. Maintenance of a list of potential course participants to be delivered at the quarterly status meetings.

6b. Registration and confirmation of course participants.

6c. Acquisition of conference room or suitable meeting room space for execution of training.

6d. Acquisition of hotel rooms for course participants when necessary. If rooms are not used due to the fault of the Government then the Government shall be responsible for any associated cancellation costs.

Attachment I TSA Hazardous Materials Management Program Support

H. Hazardous Material Management Support. Provide, on an as needed basis, the packaging, transport and disposal of hazardous materials generated at all TSA airport operations and facilities but focusing primarily on the airport operations.

1. Containers Upon request, provide compliant storage containers (in compliance with National Fire Protection Association standards) for hazardous materials storage to any federalized airport operations or other TSA facilities in order to allow TSA personnel to perform the primary segregation of potential hazardous materials into the following hazards classes:

The estimated number of new containers per year will be 400. Containers will be for newly Federalized airports or replacement for existing containers at airports or other TSA locations. Containers shall remain the property of TSA at the end of the contract.

2. Sorting, Removal and Shipping 2a. Ensure all hazardous materials are segregated and packaged in a DOT shippable container for the purpose of transportation as a hazardous waste, in accordance with all applicable Federal, state and local laws and regulations.

2b. Contractor shall mark and label shipping containers required by EPA and DOT hazardous waste and transportation regulations.

2c. Contractor shall remove all collected items on a regular basis as defined by airport or facility operations (larger airports having more frequent pick-ups and smaller having less frequent).

2d. Contractor shall ship all hazardous waste to a licensed and permitted recycler or treatment storage and disposal facility.

I. Final Treatment/Disposal

1. Contractor final treatment and disposal of collected hazardous materials shall be accomplished at facilities that are appropriately licensed, permitted, approved, and/or registered by Federal state and local agencies to accept for recycling, destruction or disposal of identified materials.

2. Sell or donate materials collected in the performance of this contract is prohibited.

A. Special Hazardous Materials – Ammunition

A1. Contractor shall support TSA airport operations and facilities with finding an acceptable public body that will accept the ammunition for the purposes of disposal (e.g., police, sheriffs, Alcohol, Tobacco, and Firearms, etc.)A2. At the direction of designated TSA headquarters personnel, pickup and dispose of ammunition.

● Pickups are estimated to be less than a total of 5 for all airports and other TSA facilities combined, per year.

● Pickup and disposal shall be performed in accordance with applicable law and regulations.

B. Special Hazardous Materials – Fireworks

1. Contractor shall support TSA airport operations and facilities with finding an acceptable public body that will accept the fireworks for the purposes of disposal (fire departments, local police, county sheriff, etc.)

2. At the direction of designated TSA headquarters personnel, pickup and dispose of fireworks.

Attachment I TSA Hazardous Materials Management Program Support

● Pickups are estimated to be less than a total of 10 for all airports and other TSA facilities combined, per year.

● Pickup and disposal shall be performed in accordance with applicable law and regulations.

C. Special Hazardous Materials – Sharps and Needles

C1. Contractor shall support TSA airport operations and facilities that have existing sharps mail back programs C2. Contractor shall support, upon request by TSA, airport operations and facilities, by implementing a sharps mail back program.

● Mail back programs exist at approximately 168 TSA airport operations

I. Non-Hazardous Voluntarily Abandoned Property. Upon request from TSA airport operations and facilities, coordinate with state and local agencies for the donation of non-hazardous abandoned voluntarily in accordance with Federal Property Regulations.

At the direction of designated TSA Headquarters personnel, pickup and dispose of non-hazardous voluntarily abandoned property.

1. Pickups are estimated to be less than 100 total CONUS and OCONUS per performance period.

2. When materials cannot be donated to a state or local agency, materials shall be sent for recycling where practicable.

3. All materials not recycled or donated, shall be destroyed so as to render the item useless and without market value. Materials shall not be sold by the Contractor.

J. Indemnification. The Contractor agrees to indemnify and hold harmless the Transportation Security Administration, the Department of Homeland Security, the United States of America and any component of the aforesaid governmental entities, together with the officers and employees thereof, from all civil and administrative liabilities related to the Contractor’s acquisition, possession, maintenance, treatment, and disposition, including transferring of the waste to others for their use, of hazardous and other waste under this contract.

This indemnification and hold harmless obligation applies to administrative and civil litigation brought by non-governmental third parties only.

1. The Contractor will not seek indemnification against the TSA, the Department of Homeland Security, the United States of America and any component of the aforesaid governmental entities, together with the officers and employees thereof, for all administrative, civil and criminal liabilities with their associated attorney’s fees and costs, imposed against the Contractor by any private or public entity related to the Contractor’s acquisition, possession, maintenance, treatment, and disposition, including transferring of the waste to others for their use, of hazardous and other waste under this contract.

2. The Contractor agrees to cooperate fully with the TSA, the Department of Homeland Security, the United States of America and any component of the aforesaid governmental entities, in defending against any liabilities, whether administrative, civil or criminal, related to the Contractor’s acquisition, possession, maintenance, treatment, and disposition, including transferring of the waste to others for their use, of hazardous and other waste under this contract.

3. The Contractor recognizes that the TSA has contracted with it for the acquisition, possession, maintenance, treatment and disposal, including transferring of the waste to others for their use, of hazardous and other waste

Attachment I TSA Hazardous Materials Management Program Support because of its lack of expertise in such matters and in recognition of Contractor’s substantial expertise and the Contractor further recognizes that the TSA’s reliance upon its substantial expertise is reasonable and warranted.

4. The Contractor represents that it possesses sufficient and continuous insurance against the liabilities referenced above and in accordance with the laws of the states within which it operates under this contract.

Upon request, the Contractor will supply copies of said insurance agreements and any related risk management devices to the contracting officer

K. Transition. During the Transition Period, all employees must be vetted, IT Platform must be fully developed and ready for implementation, and scheduling and plans must be created. The pickup, transportation, and disposal of hazardous materials/waste will be the sole contractual obligation not included in the transition period. Also, at this time, all data, records, and program specific documentation will be transitioned.

TECHNICAL EXHIBIT 1

PERFORMANCE REQUIREMENT SUMMARY

The contractor service requirements are summarized into performance objectives that relate directly to mission essential items. The performance threshold briefly describes the minimum acceptable levels of service required for each requirement. These thresholds are critical to mission success.

Performance Objective PWS Section

Acceptable Quality Level (AQL) Method of Surveillance

Collection and disposition of non-hazardous and hazardous waste from TSA Facilities and Federal Airports.

H 90% completed on time Customer Survey

Provide automated reporting system that allows TSA to track all hazardous materials

E

99% system availability and IT Security compliance

Field Survey and Random Sampling

Audits of Treatment Storage and Disposal facilities indicate compliance with environmental & hazardous materials rules, regulations, security and safety requirements.

D

Audits conducted are compliant, complete and accurate 95% of the time.

Periodic sampling of output items as determined necessary to assure a sufficient evaluation of contractor’s performance.

Perform HAZMAT Emergency and Spill Response Support F 100% Response Rate 100% Inspection

Provides all required reports and records in a timely manner. B

Reports received are complete and accurate

90% of the time Random Sampling

1.05 Deliverables:

Attachment I TSA Hazardous Materials Management Program Support

Deliverable Frequency # of Copies Medium/Format

Weekly Status Report Weekly: Friday by COB One copy to COR, One copy to Program Manager

Electronic

Monthly Summary Report

Monthly: By COB the last Friday of the month

One copy to COR, One copy to Program Manager

Electronic

Quarterly Status Report At Quarterly Status Meeting One copy to COR, One copy to Program Manager

Electronic

Non-emergency Field Contact Phone Number Fifteen (15) days after contract award N/A

N/A

E-mail Address Fifteen (15) days after contract award N/A N/A

Updated Standard Operating procedures Annually on the first Monday in May TBD

Electronic Program Support Materials Upon request TBD

TBD

Quality Control Plan Thirty (30) days after contract award One copy to COR, One copy to Program Manager Electronic

Compliance Assistance Trip Report Check List Thirty (30) days after contract award One copy to COR, One copy to Program Manager Electronic

Compliance Assistance Trip Report Ten (10) days after completion of trip One copy to COR, One copy to Program Manager Electronic

Compliance Assistance Trip Report Format

Thirty (30) days after contract award

One copy to COR, One copy to Program Manager Electronic

Survey Template Forty-five (45) days after contract award

One copy to COR, One copy

Attachment I TSA Hazardous Materials Management Program Support

Quarterly Survey Report At Quarterly Summary Meeting One copy to COR, One copy to Program Manager Electronic

TSDF Audit Phase I Report TBD One copy to COR, One copy to Program Manager Electronic

TSDF Audit Phase II Report TBD One copy to COR, One copy to Program Manager Electronic

Web access to the automated reporting and tracking system

11-Nov-16 List of applicable federal employees to have access to be supplied by government

24 Hour Emergency Hotline Number Fifteen (15) days after contract award N/A

N/A

Emergency and Spill Response Reports

No later than four (4) hours after receipt of field notification

One copy to COR, One copy to Program Manager

Electronic

Contractor Emergency and Spill Report

No later than eight (8) hours after spill occurs

One copy to COR, One copy to Program Manager

Electronic

Training Materials Two (2) weeks prior to training class TBD

TBD

Training Course Participants List

Thirty (30) thirty days prior to course date

One copy to COR, One copy to Program Manager

Electronic

Training Result and List of Actual Attendees

Five (5) business days after course completion of training

One copy to COR, One copy

1.07 Special Qualifications:

The systems supported under this task are Low. Contractor must follow applicable IT security related policies, e.g.

FISMA. The TSA Information Assurance (IA) Handbook contains applicable IA and IT security information and can be provided to the vendor as reference once the contract has been awarded.

Attachment I TSA Hazardous Materials Management Program Support

1.1 General PWS Information

1.11 Post Award Conference/Periodic Progress Meetings: Offeror shall be responsible for attending (at a minimum) the quarterly status and annual Team meetings. The contractor agrees to attend any post award conference convened by the contracting activity or contract administration office in accordance with Federal Acquisition Regulation Subpart 42.5.

The Contracting Officer, Contracting Officer’s Representative (COR), Task Manager (TM), and other Government personnel, as appropriate, may meet periodically with the contractor to review the contractor's performance. At these meetings the Contracting Officer will apprise the contractor of how the government views the contractor's performance and the contractor will apprise the Government of problems, if any, being experienced. Appropriate action shall be taken to resolve outstanding issues. These meetings shall be at no additional cost to the government.

1.12 Processing and Identification of Contractor Employees: Prior to commencing work under this contract, submit or have their employee submit the required security forms to the TSA PerSec Office for vetting and a number of copies as informed by the Task Manager. The contractor, when notified that the Government rejected the suitability assessment forms shall either have the rejected forms corrected and resubmitted or withdraw the employee from consideration from working under this contract.

1.13 Quality Assurance: Ensure quality assurance in accordance with the approved QAP as applicable to the services performed in accordance with this PWS. Develop and implement procedures specific to this requirement to identify, prevent, and ensure non-recurrence of defective services. The contractor’s quality assurance program is the means by which he assures himself that his work complies with the requirement of the task order. At a minimum, develop quality assurance procedures that address the areas identified in Technical Exhibit 1, “Performance Requirements Summary.”

Quality Assurance Surveillance: The government shall evaluate the contractor’s performance under this task order in accordance with the Quality Assurance Surveillance Plan. This plan is primarily focused on what the Government must do to ensure that the contractor has performed in accordance with the performance standards. It defines how the performance standards will be applied, the frequency of surveillance, and the minimum acceptable defect rate(s).

Government Remedies: The contracting officer shall pursue remedies for the contractor’s failure to perform satisfactory services or failure to correct non-conforming services in accordance with the terms and conditions of the contract.

Attachment I TSA Hazardous Materials Management Program Support

PART 2

DEFINITIONS & ACRONYMS

● PWS – Performance Work Statement

● Contracting Officer’s Representative (COR): A representative from the requiring activity assigned by the

Contracting Officer to perform surveillance and to act as liaison to the contractor.

● Defective Service. A service output that does not meet the standard of performance associated with it in the Performance Work Statement.

● Quality Assurance Surveillance Plan (QASP). An organized written document specifying the surveillance methodology to be used for surveillance of contractor performance to assure services meets the requirements of the Performance Work Statement.

● Quality Assurance. Those actions taken by a contractor to control the performance of services so that they meet the requirements of the PWS.

PART 3

GOVERNMENT FURNISHED PROPERTY, EQUIPMENT, AND SERVICES

3.01 General: The government shall provide, the facilities, equipment, materials, and/or utilities listed below.

3.011 Facilities: None

3.012 Equipment: The Government will provide: one laptop to the contractors Program Manager and one laptop to the assigned ISSO charged with managing the recordkeeping system.

3.03 Utilities: None

PART 4

CONTRACTOR FURNISHED ITEMS AND SERVICES

4.01 General: Except for those items specifically stated to be government furnished in Part 3, furnish everything required to perform this PWS.