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Quality CRM - An HFG Working Paper

QUALITY CREW RESOURCE MANAGEMENT



A PAPER

BY

MEMBERS OF THE HUMAN FACTORS GROUP OF

THE ROYAL AERONAUTICAL SOCIETY



CONTENTS


1. Introduction
1.1 Background
1.2 Purpose of the paper
1.3 Objectives of CRM
1.4 Purpose of Regulatory involvement
2. Guiding principles
3. The CRM development process
4. Crew competence standards
5. Crew knowledge, skills and attitudes
6. Training methods and processes
7. CRM trainer competency standards
8. Trainer knowledge, skills and attitudes
9. Trainer selection, training and assessment
10. Evaluation
10.1 The benefits of CRM
10.2 The effectiveness of training methods
10.3 The performance of the individual
11. Confidentiality
12. Recommendations
13. Next Steps

Appendix A Crew competence standards
Appendix B Crew knowledge, skills and attitudes
Appendix C CRM training methods and processes
Appendix D Trainer competency standards
Appendix E Trainer knowledge, skills and attitudes
Appendix F Trainer selection and training

References


1. INTRODUCTION




1.1 Background

In 1993 the UK CAA introduced a requirement for UK public transport operators to provide their crews with Crew Resource Management Training (CRM). In 1995 a further requirement for formal recurrent training was added. The requirements were presented in Aeronautical Information Circulars (AIC) which expanded upon the CAP 360 means of compliance for Air Operator Certificate (AOC) holders engaged in public transport.

Although the criteria for procedural compliance was specified, course and LOFT exercise content were left largely to operators to permit the moulding of courses and training to suit their operational needs.

A number of initial CRM courses were approved by CAA for general consumption by other UK operators, whilst smaller operators were permitted to conduct tailored courses which were prohibited for use outside their organisations.

The Regulator, practitioners and trainees have observed that the standard of courses, recurrent training and the instructor/facilitators varies greatly. Although there is general support for CRM training, concern is widely shared that unaudited CRM training could permit undesirable practices to perpetuate, thus restricting the generally agreed potential of CRM to improve flight safety.

1.2 Purpose of the paper

The purpose of this paper is to present guidance and advice, on improving the quality of CRM training, to key personnel in the UK aviation industry, who are fully aware of CRM issues and are involved in the implementation of CRM programmes. The paper is not meant to be prescriptive; although it uses clear and practical examples to illustrate major points, which can be adopted directly by operators if they wish. It has been primarily developed by experienced practitioners rather than from academic research.

The paper has been based on a tried and tested structure from which all aspects of CRM training can be developed to the required detail. Essentially the paper will present guidance in practical terms so that operators can immediately begin to move forward with their CRM training programmes; it may thereafter be used to trigger further more academic and in-depth studies on specific items as required.

Appendices will expand upon the key areas to provide more specific reference material which could provide the basis for best practice in management and quality assurance of CRM programmes.

1.3 Objectives of CRM training

The objectives of CRM training are as follows:

a) To enhance crew and management awareness of human factors which could cause or exacerbate incidents which affect the safe conduct of air operations.

b) To enhance knowledge of human factors and develop CRM skills and attitudes which when applied appropriately could extricate an aircraft operation from incipient accidents and incidents whether perpetrated by technical or human factor failings.

c) To use CRM knowledge, skills and attitudes to conduct and manage aircraft operations, and fully integrate these techniques throughout every facet of the organisation culture, so as to prevent the onset of incidents and potential accidents.

d) To use these skills to integrate commercially efficient aircraft operations with safety.

e) To improve the working environment for crews and all those associated with aircraft operations.


1.4 The purpose of Regulatory involvement

The FAA have promulgated in depth advisory information on how and why CRM training should be conducted. This activity was initiated following funded research and air carrier investigation into the contributory causes of aircraft accidents and incidents, seventy per cent of which contained human factors elements which if corrected, had the potential beneficially to alter the outcome of the incident.
In the UK, however the Authority, after consultation mandated requirements in general terms following unsatisfactory training standards which were experienced during the last pilot recruiting expansion in 1989/1990. Examples of unsatisfactory standards were;

a) Lack of intermediate training to prepare pilots experienced only in light propeller driven aircraft for the higher speeds of turbine powered aircraft, consequentially pilots lacked situation awareness.

b) Lack of multi-crew co-operation training whereby those who operated mainly single crew continued to act in single crew style on large multi-crew transport aircraft, causing disruption to flight deck efficiency.

c) Lack of formalised training in Standard Operating Procedures (SOP) causing confusion between crew members and creating hazardous situations to arise, even for crews experienced in multi-crew operations.


2. GUIDING PRINCIPLES



a) Professional aircrew shall demonstrate high standards of Crew Resource Management.

b) Consistent with other aspects of aircrew performance, these standards should be well defined, objective and measurable.

c) The knowledge, skills and attitudes required to meet these standards should be equally well specified, so that they can be thoroughly and systematically integrated with other aspects of aircrew training and training standards.

d) CRM standards of performance have a bearing on flight safety and the efficiency of aircraft operations, and are essentially more explicit and refined versions of professional standards implicit in the common sense definition of 'airmanship'.

e) These knowledge, skills and attitudes have wide applicability and should be incorporated into basic training of all personnel and their respective managers who are involved in the operation and dispatch of aircraft.


3. THE CRM DEVELOPMENT PROCESS



In common with other aspects of flight crew performance, the achievement of high standards of CRM rests on a foundation that is several layers deep, and the successful achievement of each stage relies on the preceding stage.

In other words, crew performance will be determined by individuals behaving and operating to a set of standards; which will require them to have certain knowledge, skills and attitudes. Developing this knowledge, these skills and attitudes in individuals, will be dependent on trainers behaving and operating to certain standards, and likewise this will require them to have the commensurate knowledge, skills and attitudes.


Appendix A
Behavioural Markers / NVQs

Appendix B

Appendix C
Quality Assurance Group

Appendix D
Quality Assurance Group / NVQs

Appendix E

Appendix F



4. CREW COMPETENCY & STANDARDS (Appendix A)



Although this stage is the end result of the training process, it must be considered first because it sets out the standards of behaviour, that the industry and regulators will require aircrew to demonstrate during flying operations.

There are two issues in the specification of performance standards for CRM. The first is to identify and define the domains of behaviour and the second is to define the levels or standards of performance in each domain which distinguish competence from incompetence.

The standards are competency based and therefore can be assessed against specific performance criteria. Much work has been done worldwide on these subjects, and although there is not yet an internationally agreed set of reference points, there is obvious overlap among categories and standards defined in the documents referred to in Appendix A. This contains a selection of behavioural markers and competency standards currently used by various organisations.

It remains for the industry and regulators to compile what is available and agree the standards required.


5. CREW KNOWLEDGE, SKILLS AND ATTITUDES (Appendix B)



Appendix B lists the areas of knowledge, the skills, and attitudes, that individuals would need to acquire in order to demonstrate competency to the above behavioural standards. Clearly, the level of knowledge and skills required will be determined by the standards that are established.

Appendix B is meant to be relatively comprehensive; but it is acknowledged that, for instruction purposes, more work is required to expand upon the definitions and contents in each topic area.


6. TRAINING METHODS AND PROCESSES (Appendix C)



To maintain the integrity of the training process, training methods should be focused on objectives; rather than be activity driven, which tends to encourage a 'tick in the box' mentality. The objectives would be to ensure that participants develop the right knowledge, skills and attitudes. Whereas hitherto in the airline and other industries, training programmes have been constructed and assessed largely on the basis of their content, the more recent tendency is to assess programmes on the basis of the trainee outcomes they purport to achieve and the procedures they have in place to assess these outcomes.

This trend focuses the effort and investment in training on objectives which are defined in terms of measurable outcomes. It does not by any means render content obsolete, but recognises that content is only the means, not the end in itself, of training and education.

In behavioural training, where behavioural skills development and attitude changes are being encouraged, the interactive process of the actual training is what is of paramount importance. The following model in the field of training emphasizes the relationship in which knowledge, skills and attitudes stand to each other in the learning and development process. The essence of the model is that knowledge, ability and motivation are all necessary to effect enduring changes in behaviour.



CRM training is a long term development process that encompasses a varied barrage of training resources and media, which run from the traditional and passive to the highly interactive and experiential such as: self study; classroom awareness training; modelling, classroom skills training; continual skills practice both classroom and simulator; and practice or coaching during flying operations. A selection of programmes and methods that might be considered best practice is at Appendix C.

The onus for operators and regulators rests upon specifying CRM training objectives that map onto the competency domains and standards which they require of their aircrew. Training contents and methods, and trainers themselves, need to accommodate the needs of the trainees in whatever ways, shapes and forms necessary to attain these ends, within the limits imposed by commercial and other practical considerations.


7. CRM TRAINER COMPETENCY STANDARDS (Appendix D)



To assure the consistency and the effectiveness of CRM training, and especially its reputation, competency standards for CRM trainers should be established. These competency standards can be applied in various degrees to any stage in the CRM development process.

Successfully achieving all the training objectives is the ultimate standard for assessing trainer competency, although other factors such as management support, continuation training, the motivation of the individual and the culture of the organisation could undermine even the best instruction.

A Quality Assurance Group that monitors these standards of instruction may be the most appropriate method for maintaining CRM trainer competency levels, a selection of which are listed in Appendix D.


8. TRAINER KNOWLEDGE, SKILLS AND ATTITUDES (Appendix E)



In order to deliver CRM training effectively, trainers would be required to develop the knowledge, skills and attitudes in Appendix E in addition to those in Appendix B. Because of the nature of CRM training it is of critical importance that trainers should be able to demonstrate and role model the basic crew skills and attitudes listed in Appendix B to an exceptionally high level.

Recognition has been made of a slight variation in the level of skill required in certain domains (the last four items in the skills list) for those trainers who would be solely involved with LOFT facilitation or line checking. In this area further work needs to be done to establish whether differing standards may be required for trainers involved in the wide range of CRM training and evaluation activities, as well as the environments in which they operate.

To be consistent with the achievement of high standards and in recognition that the CRM trainers' knowledge, skills and attitudes will underlie the whole process, the compilation of the list has been thorough; and a strong attempt has been made to avoid training jargon.

Any CRM assessment should be carried out by those with demonstrated relevant, full and in-depth knowledge, to ensure any statements made are sufficiently robust to withstand possible later challenge.


9. TRAINER SELECTION, TRAINING & ASSESSMENT (Appendix F)


Selecting trainers with as much of the knowledge, skills and attitudes that are required will minimise the use of training resources or the possibility of them not reaching the standards at all. Trainer selection is important to get right, because of the potential to create damage, such as using inappropriate methods which affect the credibility of CRM.

Individuals who can already demonstrate a high level of the basic skills and who have the appropriate attitudes, will more easily be able to acquire the knowledge and additional skills that will enable them to become competent trainers.

In practice, because competence in behavioural skills training requires considerable experience, demonstrating the basic skills (Appendix B) to a high standard would be a minimum requirement for trainer selection. Other criteria and methods for training trainers are listed in Appendix F.

In time the objective of teaching CRM as a discreet topic with an associated group of specialist trainers should be abandoned by incorporating its principles within trainer competency, and within all stages of training as an indistinguishable element of overall skills. However there may still be a need for specialist trainers to develop some of the basic communication, teamwork or decision making skills; as they may be far better qualified in these areas than technical trainers. Furthermore, this objective can only be met if trainers are properly and independently assessed as being fully competent.

However, there needs to be a transitional stage during which trainers are selected and developed for CRM training, in order that standards can be implemented quickly and consistently. The next step consists of training and development for Line, Route and Check trainers or their equivalents, to be competent in CRM instruction. Those who reached the standard would be most fully qualified, but those who were assessed as not yet competent would not automatically lose their appointment, although they would be restricted from instructing and assessing CRM competencies in others.


10. EVALUATION



The evaluation of training quality is a complex issue, but one which must be comprehensively addressed since a direct appreciation of the benefits of CRM training will be necessary to progress such training in the manner outlined. The assessment of benefit must take account of individual needs and values which underpin perceptions and judgements of quality. Most people will not be interested unless they are convinced of the benefits.

The solution is to link the quality of training directly to the needs of the customer. There are a number of customer groups whose views and reactions are important.
In the case of flight crew training, at least six kinds of customers matter: flight crew, flight management, the rest of the company, regulatory authorities (representing other aviation agencies and the population at large), shareholders and paying customers. The needs and values of these groups are different.

Evaluation can be divided into 3 levels for which there will be differing forms of measurement. The following table illustrates the levels and areas in which measurement is possible.


10.1. Evaluating the benefits that achieving high standards of CRM performance brings to operators or the other customers listed above.

Possible benefits can be identified as improvements in flight safety, reputation, fuel management, punctuality, passenger comfort, job satisfaction and relationships with other aviation organisations, such as ATC and airfield operators; and reductions in maintenance costs, insurance premiums, wear and tear, stress, medical problems and environmental damage.

Flight management will evaluate how the training contributes to their ability to plan, organise and control the activities and people for whom they are responsible.

Resources will only be made available to complete the CRM Development Process satisfactorily if tangible or acceptable intangible benefits are perceived.


10.2. Evaluating the effectiveness of the training methods, processes and delivery.

This is focused on checking if the objectives have been achieved. The knowledge that has been gained, the skills that have been developed and the attitudes that have changed, balanced against the costs and use of resources.

Positive flight crew reactions to training are essential for training effectiveness. If the immediate customers are not paying attention or do not feel it is relevant, then they will not learn, will not remember and will not change. If their perceptions of quality are low, they are unlikely to benefit from the experience.

Most professionals, and flight crews are no exception, are influenced in their judgement of the quality of training by four factors:-

a. Immediate practical relevance. They have limited patience for training input that is not perceived to be directly linked to their jobs, which distracts their attention from factual matters.

b. Professional credibility. Flight crew, in particular, are continuously scrutinised for professional competence, and they demand high standards from those who would presume to teach them.

c. Amusement value. They can learn their most memorable lessons in busy, stimulating or potentially threatening environments. Such stimulation is essential as an antidote to highly factual training.

d. Self development. They are also keen to learn and improve their job skills, so they will judge training quality on this basis too.


10.3 Evaluating the individual.

Assessment of competency can only be done when the development process has matured. In other words when the competency levels have been established and agreed, when the trainer competency levels have been established and agreed and when trainers have the knowledge, skills and attitudes to deliver the CRM training effectively and properly.

Clearly, it would be impractical to assess competency against a long list of items as shown in Appendix B, so the assessment methodology would need to be categorised to enable trainers to evaluate individuals effectively. Furthermore, recognition must be given to the aircraft's operating environment when developing methods for evaluating individuals, as these will vary considerably across the aviation industry, even though industry wide standards should be maintained.

In addition an individual's response to the training can be evaluated in their health, commitment and motivation to the job .

There is no practical reason why assessment of CRM performance should be any different from existing flying competency assessments, and may in due course be integrated in such assessments.


11. CONFIDENTIALITY



Confidentiality must be maintained during training activities in the classroom or simulator where participants are practicing or experimenting in order to learn skills. However, there are boundaries of confidentiality, such as the display of inappropriate attitudes that would be hazardous to flight safety, and these must be established clearly.

Although the overall long term aim is for CRM to be fully integrated with existing flying standards and assessed as a complete operational package, the initial period of CRM training will benefit from not yet having this link. Therefore, during training exercises, confidentiality should only be applied to those areas not covered by the competence standards being assessed. So if CRM skills are being assessed then handling or technical errors would remain confidential. In any case it is without question that assessments themselves must always be fed back to individuals in their entirety.

Where a pilot is considered critically deficient in aspects of CRM, remedial training and appropriate counselling should be made available prior to any reassessment.



12. RECOMMENDATIONS



12.1. The industry adopt the CRM Development Process model as an overall framework and start working towards ensuring crews meet the competence standards.

12.2. Training systems are focused on achieving knowledge, skill or attitude objectives rather than carrying out a set of activities to a prescribed syllabus.

12.3 The industry begins to develop a comprehensive evaluation process for recording the tangible and intangible benefits to operators; and focuses on addressing today's problems rather than those in the past that may have already been significantly overcome.

12.4 Recurrent skills training is delivered in modular form, on a regular basis and over a period of time, so that the skills base is broadened and gradually improved. Thereafter it can be matched to the particular training needs in an individual's performance.

12.5 The industry considers the resources that will be required to ensure the highest CRM standards possible are achieved and makes provision for making them available; acknowledging that although this may take many years, a start must be made now.

12.6 Whilst the use of simulators for LOFT training and fully integrated CRM/Technical assessments is the ideal, operators can develop basic CRM skills in their crews to a high standard by using more cost effective methods.

12.7 CRM training begins to be fully integrated with existing flying training and current monitoring processes; for example using Line Operated Evaluation (LOE) as an assessment methodology.

12.8 Incorporate the recommendations above in one single fleet vertically and in depth, so that the results of this approach can be evaluated, benefits perceived and hence resources are made more readily available.

12.9 The Regulatory Authority should establish a widely representative CRM quality assurance group to monitor quality standards of trainers and training programmes, and adjudicate complaints.

12.10 CRM related competencies and standards become mandatory for all new training appointment holders as soon as it is practical to set up a training standardisation process to define and supervise their implementation.

12.11 Consideration be given to establishing different sets of standards and training strategies to recognise the practical problems facing smaller or diverse operators and the conditions in which they operate.

12.12 There should be no aspect of the CRM agenda which is in principle not attainable by existing licence holders through training and experience.


13. NEXT STEPS



13.1 Demonstrate the benefits of high standards of CRM to all the customers groups in the industry and obtain commitment and support, demonstrated by the provision of adequate resources.

13.2 Establish agreed crew behavioural competence standards.

13.3 Establish agreed knowledge, skills and attitude standards.

13.4 Develop measurement methodologies and techniques.

13.5 Develop recommended training methods for all stages.

13.6 Establish agreed trainer competency standards.

13.7 Establish agreed trainer knowledge, skills and attitude standards.

13.8 Develop recommended trainer training methods.

13.9 Develop evaluation methods and techniques.

13.10 Communicate structure effectively to industry.


May 1996

Appendix A

CREW COMPETENCE STANDARDS

Below are selected extracts from typical behavioural markers / competency standards that various organisations are currently using. They are shown here to illustrate the levels involved.

FAA Advisory Circular 120-51A 1993

* Briefings are interactive and emphasize the importance of questions, critique, and the offering of information.

* Crew members speak up and state their information with appropriate persistence until there is some clear resolution.

* Critique is accepted objectively and non-defensively.

* The effects of stress and fatigue on performance are recognised.

British Airways behavioural markers:

* Tone of flight deck is friendly, relaxed, supportive.

* Crews adapt to other members personalities.

* Crews act decisively when situation requires.

NASA /UT LOS Checklist

* When conflicts arise, the crew remain focused on the problem or situation at hand. Crew members listen actively to ideas and opinions and admit mistakes when wrong, conflict issues are identified and resolved.

* Crew members verbalize and acknowledge entries to automated systems parameters.

* Cabin crew are included as part of team in briefings, as appropriate, and guidelines are established for coordination between flight deck and cabin.

Britannia Airways behavioural markers (Helmreich based):

* Avoids complacency.

* Prioritises tasks and manages time for effective accomplishment.

* Remains calm and positive under pressures.

Northwest Airlines behavioural markers:

* Clearly communicates decisions about operation of flight.

* Involves entire crew in the decision making process.

* Adapts to crew interpersonal differences.

Management Charter Initiative Level 4 Competency Standards:

* Individuals are encouraged to offer ideas and views and due recognition of these is given.

* Information about problems is clear, accurate and provided with an appropriate degree of urgency.

* Potential and actual conflicts are identified and actions promptly taken to deal with them.

* Inadequacies in information are identified and alternative sources are sought.


CRM NVQ Level 4 Competency standards:

* Flight deck crew are encouraged to offer opinions, express concerns, and exchange information in an open manner so as to promote trust, mutual support, and effective working and decision making.

* Breakdowns in communication are recognised, assessed, and action taken to improve immediate and long term situation.

* Information is presented to, and sought from, cabin crew in such a manner so as to promote mutual support, and effective communications.

* Essential activities are maintained whilst collecting information.

* Conflicts of opinion are clearly elicited, stated, assessed and resolved via reasoned argument and appropriate evidence.

* Effects of any action are constructively reviewed and used to inform the continuous decision making process and FDM loop.


Appendix B

CREW KNOWLEDGE, SKILLS AND ATTITUDES

Knowledge

Skills
Communications

Effective Teamwork
Task Management Attitudes (Values and beliefs which influence people to select a set behaviour)

Appendix C

CRM TRAINING METHODS AND PROCESSES

The following training programmes would be considered best practice in ensuring that the required training objectives are met.

Phase One - Awareness training - 2 days classroom (residential or non-residential).

Objectives:

Knowledge:
Skills:

Nil

Attitudes:

Motivated to observe situations, others' and own behaviour in future.
Belief in the value of developing CRM skills.

Activities:


Phase Two - Basic Skills training - 3/4 days classroom residential

Objectives:

Knowledge:


Skills:

See Appendix B

Attitudes

See Appendix B

Activities:


Phase Three - Skill development training - (1-2 day) Modular - Classroom, CPT or simulator

Objectives:

Development of knowledge, skills and attitudes to required competency standards.

Activities:
Practicing one or more skills on a regular basis under instruction in either the classroom, mock up/ CPT facility or full simulator LOFT sessions. Also considered valuable would be coaching by experienced crews during actual flying operations.

Appendix D

TRAINER COMPETENCY STANDARDS


The overriding competency standard is the ability of the trainer to achieve the training objectives; given that trainees have been appropriately selected. Notwithstanding this these are a selection of trainer competency standards that are currently being used.


FAA Advisory Circular 120-51A 1993 (LOFT debriefing performance indicators)

* Ensures that all crew members participate in the discussion, and effectively draws out quiet or hostile crew members.

* Is patient, and is constructive in probing into areas where improvement is needed.

* Provides a clear summary of key learning points.

British Airways

* Trainers should deliver training in a manner that is respectful, participative, open.

* Develops new approaches and improved products services without being constrained by past experience or current practice.

* Demonstrates approachability, calmness and self-control.


Management Training in other industries

* Can demonstrate and role model an assertive communications style.

* Challenges and draws out individual feelings and opinions.

* Is able to give and receive constructive criticism.

* Is able to distinguish between process and content.


Delta AQP

* Demonstrates effective communication and interpersonal skills.

* Encourages open and interactive discussions.


North West Airlines AQP

* Demonstrate excellent interpersonal and organizational skills.

* Demonstrate ability to observe students, and determine if there is confusion, or lack of understanding.


Appendix E

TRAINER KNOWLEDGE, SKILLS AND ATTITUDES

Knowledge As per Crew to a high standard plus:-

Skills Role modelling Crew Skills to a high standard plus:-

Attitudes As per Crew Attitudes plus:-

Appendix F

TRAINER SELECTION & TRAINING

The following is an example of some of the criteria that an organisation might use for the selection of potential trainers and focuses on criteria that may not be cost effectively trainable. It is not intended to be either complete or representing best practice; each organisation can select anyone they wish, as long as they can demonstrate they have the knowledge, skills and attitudes in Appendix D and can reach the competence standards in Appendix E following their training.

Essential Criteria:


Desirable Criteria: (To be ranked in order of importance for selection purposes):
P

TRAINING THE TRAINER PROCESS: (Minimum recommended programme)
1. Trainer attends CRM skills programme as a participant - 3 days (See Appendix C).

2. Trainer attends facilitator course to develop facilitation skills and the ability to manage difficult situations - 4/5 days.

Activities:


3. Trainer shadows experienced trainer on skills course - 3 days.

4. Trainer facilitates skills course with support from experienced trainer - 3 days.

5. Trainer is assessed as competent to facilitate either LOFT sessions only or full skills courses.

References:

Civil Aviation Authority AIC 126/1993
Carey Edwards and Lydia Malone - LMQ Research, Surrey, UK
Rosanne Beal - British Airways Flight Operations Training, Heathrow Airport
Dr. Philip Smith - Opus Consulting Ltd, Bristol, UK
Capt. George Robertson - Britannia Airways Crew Management Training, Luton Airport
Dr. Guy Smith - North West Airlines Human Factors Practices, MN, USA
Capt. T Carver - CAA Flight Operations Inspectorate, Gatwick Airport
Capt. David Harrison - Technical Chairman BALPA
FAA Advisory Circular 120-51A 1993
NASA/UT LINE/LOS Checklist, Version 4 - 08/01/94
Prof. R L Helmreich - Theory Underlying CRM training, NASA Conference 1987
ICAO Circular 217-AN/132, 1989
Management Charter Initiative Level 4 Competency Standards, London
UK National Vocational Qualifications for Air Transport Pilots - Aviation Training Association
Delta Airlines Advanced Qualification Programme, Atlanta, USA
North West Airlines Advanced Qualification Programme 1994 (Draft), MN, USA
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