A summary of this committee meeting is not yet available.
SAFETY AND SECURITY PORTFOLIO COMMITTEE
23 August 2000
FIREARMS CONTROL BILL: PUBLIC HEARINGS
Chairperson: Mr M E George
Southern Africa Arms and Ammunition Collectors Association
Gun Free South Africa
The Professional Hunter's Association of South Africa
South African Human Rights Commission
Institute For Security Studies
Southern Africa Arms And Ammunition Collectors Association rejected the Bill as flawed and unworkable but it did make detailed suggestions as to proposed amendments. It also noted that despite being named by the Bill as one of the key entities with which consultation has taken place, SAAACA was only able to meet with the drafting team for two hours to elaborate on views expressed in their multiple submissions. This did not constitute meaningful consultation. They recommended the following: amend the existing Act after consultation with meaningful stakeholders; re-systemise the Central Firearms Registry; conduct an audit of all state and private firearms; improve control of State owned firearms and ammunition; declare a meaningful amnesty; empower the SAPS to enforce law; educate the public on responsible firearm habits.
Mr Denichaud, in his personal capacity, rejected the Bill as an inadequate means of combating crime. He complained about a lack of transparency and a lack of meaningful dialogue with firearm bodies in drafting the Bill. He claims that there is no research from Government to suggest that the Bill will reduce crime but much research exists to the contrary.
Gun Free South Africa believes that the ultimate solution to widespread gun violence in South Africa is the abolition of civilian firearm ownership. However, they support the Bill because it will make a contribution to reducing gun violence. Points made were that violent crime and domestic violence convictions should be criteria for exclusion from qualifying for a competency certificate. Greater attention is needed to the licensing and the training of police officers in the use of their firearms. There is a need for an independent firearms authority to monitoring the firearm legislation. A greater allocation of resources to the Central Firearms Register would facilitate better record keeping. They noted that there have been many objections to the powers given to the Minister under the new Bill but the Minister had even greater powers under the old Act. They critiqued the Lott study which has been used to bolster support for the idea that an increase in guns results in a decrease in crime. It is disappointed with the revisions made to the Bill on 24 May 2000 which will allow an individual to possibly own three firearms for self-defence as opposed to one. It supports the notion of amnesties, buy-backs and compensation seeing them all as measures to reduce firearm proliferation and violence.
The Professional Hunters Association of South Africa (PHASA) said that the Bill is unconstitutional because it gives the government unlimited power to take away the firearms of law-abiding citizens. They also noted that there is an important link between tourism and hunting and contend that this legislation will have a negative impact on the tourism industry.
The South African Human Rights Commission (SAHRC) expressed support for the proposed Bill. They described it as an ''urgent corrective measure'' for the high level of violent crime in South Africa. In spite of their support for the Bill they noted a few objections to the current draft.
Khuseleka expressed support for the Bill but were concerned that it does not address people living in informal settlements. In light of this they said that there should not be discrimination (on economic grounds) in respect of the allocation of firearms to the people of South Africa.
The Institute for Security Studies (ISS) expressed its support for the proposed Bill. They view the Bill as being in line with regional and international trends. They support the stiffer sentences that go with the privileges of owning a firearm. This includes provisions relating to competency testing, age restrictions, and more police powers.
Southern Africa Arms And Ammunition Collectors Association (SAAACA)
Mr Peter Wills, the Gauteng chairperson of this association, stated that SAAACA resists the Bill's introduction as it is flawed and unworkable but will suggest positive alternatives in the realisation that the Bill might be implemented. They will make an effort to have it amended into an effective piece of legislation especially with regard to both collectors and collecting.
It was said that SAAACA was accredited with the SAPS and that it represented over 1000 members that formed the majority of collectors in the country. The constitution of the association charges its members to preserve and protect arms, ammunition and related items as part of our National Heritage. This protection will seek to avoid the effects of legislation that could adversely affect the scientific hobby of Arms and Ammunition collecting for future generations.
SAAACA states that they are fully committed to reasonable attempts to eradicate or reduce crime and the criminal possession of firearms in this country. They point out that there is, however, no evidence to suggest that responsible collecting contributes in any way to crime in South Africa. They believe that collectors as a group are already well regulated and in most cases the cost of their chosen hobby prompts collectors to take steps in excess of those required by law to protect their collections against theft.
Lack of transparency was complained about by SAAACA with regards the stages between the policy document being drawn up by the Institute for Strategic Studies (ISS) and its approval by the Minister of the time, Sydney Mufamadi. SAAACA stated that at numerous stages access to the policy document was denied to them. SAAACA believes that the document should have been available for public scrutiny before it became the basis for the drafting of the current Bill.
Despite being named by the Bill as one of the key entities with which consultation has taken place, SAAACA was only able to meet with the ISS for two hours to elaborate on views expressed in their multiple submissions. It is the belief of SAAACA that this situation did not constitute meaningful consultation as their specialist input was only given at the drafted Bill stage and not at the policy formulation stage.
Principle Problems with the Bill
- The Bill assumes that the majority of illegal firearms used in criminal activities originate from the theft or loss of privately owned arms. SAAACA maintains that many arms such as the AK type assault rifles, R4/5 rifles and 9mm semi-automatic pistols originate from either neighbouring countries or from SAPS/SANDF armouries or members. The SANDF admits to having lost 200 000 firearms alone. They assert that to focus legislation on law-abiding private firearm owners rather than on the criminal is not likely to have an effect on crime prevention. The view of the organisation is that only if the Bill is backed by an equally serious commitment to law enforcement and apprehension of criminals will crime be reduced.
- The impact of the Bill can only be assessed in conjunction with the Regulations that the Minister/Registrar will be able to issue. As these Regulations have not been published it is impossible to judge this. The costs of licensing and re-licensing of firearms for multiple-firearm owners may be severe. Until the relevant Regulations are drafted this will remain a concern.
- Regarding Chapter 15 Presumption of Possession of Arms and Ammunition, SAAACA understands the problems this chapter is trying to combat but it raises concern for circumstances where this presumption can be wrongly made with devastating consequences for the individual.
Other points raised:
- The definition of 'antique firearm' does not cover all arms that SAAACA believe could be de-regulated. It suggests that the cutoff date of 1870 be changed to 1900 to ensure that all muzzle-loading arms are included.
- SAAACA understands the need to outlaw guns that have had their serial numbers removed but notes that some collectible arms have had numbers changed due to accepted practices at the time. It requests that an amendment be made to avoid the automatic prohibition of such firearms. They would expect all serial numbers to be recorded on a new database.
- 'Devices not firearms for the purposes of this Act' does not mention flare guns and projectors. They should be exempted due to their widespread use as part of safety equipment. There is no record of them being used in criminal activity and are widely available.
- The sections dealing with licenses to deal with collections of firearms and ammunition are unworkable in rural areas as every firearm or ammunition would have to be inspected by an accredited collectors association official. SAAACA suggested that proof that a member is a registered member as required by the current act is more practical.
- The Bill provides for Competency Certificates to lapse two years after the date of issue. SAAACA would recommend that this lapse for collectors, hunters and sportspersons after 10 years. This action would consolidate the re-licensing and competency checks into a single event every 10 years.
- The section dealing with the destruction of firearms by the State mentions that the State 'may retain' any firearm or ammunition which the Registrar deems to be of 'special value'. This is a positive aspect of the Bill as it enables the preservation of any items of Historic or National interest and it suggests 'may retain' be changed to 'must retain'.
- It recommended that Section 62 (a) be amended to read 'repair, alter or improve any firearm for which he or she would does not possess a license'. This would allow a firearm owner to perform maintenance on his/her own firearms only and not as a business.
- It also made suggestions with regard to the section dealing with restrictions on the possession of firearm parts.
- The Bill does not differentiate between collectors on the basis of what they collect and it is recommended that the various categories be incorporated into the regulations.
Envisaged problems with the Bill if it were accepted included:
- The vast majority of the population would not understand the Bill.
- SAPS resources that should be employed against crime would be taken up by the monitoring required by the Bill.
- It will be unenforceable leading to large-scale non-compliance through ignorance.
- The introduction of Firearm Free Zones will result in those areas becoming crime hot-spots.
- Illegal trafficking in firearms and ammunition will not be curtailed
- The costs of implementation may well exceed benefits gained.
The Arms and Ammunition Act of 1969 (as amended) provides adequate mechanisms and with proper enforcement would be effective. It has been ineffective due to:
- The inability of SAPS and the courts to adequately deal with offenders
- Problems with the existing firearms registry
- The historically ineffective control over State-owned firearms and ammunition.
- Long and inadequately controlled borders facilitating arms smuggling
As an alternative to the adoption of the Bill SAAACA suggests the following:
- Reject the Bill in its entirety
- Publish the Policy Document for scrutiny and modification
- Amend the existing Act after consultation with meaningful stakeholders
- Re-systemise the Central Firearms Registry
- Conduct an audit of all firearms (state and private)
- Improve control of State owned firearms and ammunition
- Declare a meaningful amnesty to allow surrender or license firearms and ammunition
- Empower the SAPS and legislature to enforce law
- Educate the public on responsible firearm habits.
SAAACA believe these measures will be supported by major stakeholders and will result in less burden on human resources and the tax-payer.
The Chairperson questioned Mr Wills as to the use of the word 'Southern' in the title of their organisation. Mr Wills responded saying that when the organisation was founded it was the intention of the members to establish links with similar associations in neighbouring states. He went on to say that they had made contacts with collectors in Zimbabwe and Namibia but are still a South African organisation.
Advocate Swart (DP) raised a question about the definition of black powder to which Mr Wills responded that greater care would have to be taken as regards the wording.
General Viljoen (FF) expressed concern over what exactly constituted a collectors item. Mr Wills replied that collecting is a scientific pursuit and more meaningful consultation with stakeholders that possess the expertise would have meant a better Bill.
The Chairperson raised the issue of firearm free zones and whether people therein would prove soft targets for criminals. Mr Wills provided the example of a person carrying wages who enters a firearm free zone exposing themselves to risks they ordinarily they would not have face.
Mr Bayard Denichaud
Mr Denichaud appeared in his personal capacity to voice his concern and reject the Bill as an inadequate means of combating crime. Mr Denichaud complained about a lack of transparency and a lack of meaningful dialogue with firearm bodies. He claims that there is no research from Government to suggest that the Bill will reduce crime but much research exists to the contrary. Another complaint centered around the difficulty Mr Denichaud had experienced in corresponding with the Committee.
Mr Denichaud particularly highlighted Section 15 (2)(b). He asking if he wasn't granted a license for a firearm and his family were killed because he could not defend them, would he then be able to sue the State? He also raised the question as to how he would be considered more dangerous if he possessed two firearms?
In conclusion, Mr Denichaud asked why Government wanted to disarm civilians and called for further discussions with the relevant stakeholders.
Mr Geldenhuys (NNP) asked Mr Denichaud about an assertion that only 4000 people in South Africa owned more than four guns. Mr Denichaud denied having made such a statement in his submission to which others concurred.
Mr Maziya (ANC) inquired into the allegations by Mr Denichaud that he was not given the opportunity to enter his submission at an earlier stage. Mr Maziya asserted that submissions were taken from February.
Mr Denichaud faced a number of complaints as to the political nature of his submission from individuals in the Committee. Mr Denichaud stated that he had no political motivation and complained that he had written four letters to the Committee without a response.
Gun Free South Africa
Adele Kirsten, GFSA Director, said that GFSA believes that the ultimate solution to widespread gun violence in South Africa is the abolition of civilian firearm ownership. However, they support the Bill because it will make a significant contribution to reducing gun crime and violence in our country. Mr Joseph Dube, GFSA's National Organiser, noted that they have been developing firearm free zones and that there are currently 64.
Points made were:
- Violent crime and domestic violence convictions should be criteria for exclusion from qualifying for a competency certificate.
- Parliamentary oversight of the Minister is an important principle of democracy.
- Greater attention to the licensing and the training of police officers in the use of their firearms is needed.
- The need for an independent firearms authority to allow for civilian involvement in monitoring new firearm legislation, maintain accountability of the SAPS and provide the SAPS with a partnership with skilled experts in the field.
- A greater allocation of resources to the Central Firearms Register (CFR) would facilitate better record keeping.
- The Bill cannot by itself get rid of violent crime in South Africa. Other efforts to deal with the flow of illegal weapons, police training, educating gun owners and regional co-operation with neighbouring countries were also needed to curb violent crime.
The Arms and Ammunitions Act is out of date, not working and has too many loopholes.
Many have objected to the powers given to the Minister under the new Bill but as can be evidenced by Section 33 (2) of the Act the Minister had even greater powers to declare a ban on guns or any such similar prohibition. GFSA welcomes the new limitations on the Minister. The new Bill is a vast improvement on the old Act in terms of simplicity.
Three reasons were given by GFSA that not all gun owners are responsible. Firstly, submissions have shown that not all gun owners are properly trained. Secondly, GFSA has data that points to a 70% inaccuracy in CFR records. Thirdly, some gun owners allow their gun to get into the hands of others such as children.
GFSA noted the threats of non-compliance with the new Bill if it is accepted and called upon the gun fraternity to educate their members as to the purpose and intent of the Bill. Much experience on this issue has been taken from Canada and New Zealand.
The Lott study has been extensively used to bolster support for the idea that an increase in guns results in a decrease in crime. The Lott study deals with 'conceal carry weapons' (CCW) in the USA and states that, as criminals will not know who is carrying a gun, they will be less likely to attempt any criminal behaviour. If this were so in our country then South Africa would have one of the lowest crime rates - which does not hold. The Lott study also failed to address other factors that affect crime that would have acted in conjunction with the CCW laws in the USA.
GFSA has heard allegations as to its role in the drafting of the current Bill. In June 1997 the team made its final presentation to the Minister and has not been involved in any way with the formal process of drafting the Bill.
- Licensing the firearm and the owner will allow this information to be readily accessed by authorised people such as police personnel.
- The competency certificate, a cornerstone of the Bill, and regular renewal of licenses will ensure the new Register will have integrity.
- GFSA supports the increase of the age limit for gun possession to 25 years.
- It is disappointed with the revisions made to the Bill on 24 May 2000 which will allow an individual to possibly own three firearms for self-defence as opposed to one. It recommends that Section 15 (3) be changed to read 'a person may not hold more than one self-defence firearms license'.
- Schedule 1, Item 11 (3) should be deleted and that every firearm owner complete prescribed training for the handling of a firearm including those granted licenses before the Act.
- Administrative transgressions should be separated from criminal offences which would have the following advantages: frees overburdened criminal justice system from less serious violations, the administrative process is faster and less expensive, administrative transgressions can hold great punitive power.
- More research is needed as to the estimated cost of gun violence in South Africa. In a 1993 study it was estimated that the treatment of gun violence at Groote Schuur Hospital cost nearly 4 million Rand. In order to make national calculations, it needs to be known how many people firearms injure. One way to achieve this is to make it mandatory for medical institutions to report injuries resulting from firearms to the police.
- GFSA supports the notion of amnesties, buy-backs and compensation seeing them all as measures to reduce firearm proliferation and violence.
- GFSA urges the Committee to take all stakeholders into account during the Regulation phase particularly concerning the safe storage of firearms.
- It supports the call for an Independent Firearms Authority although this is not mentioned in the Bill.
- It supports giving the Minister the power to declare 'premises or categories of premises' firearm free zones.
In conclusion, GFSA believes the costs of implementation have to be weighed against the cost of gun crime and violence in South Africa.
Advocate Swart (DP) commented on the use of the word 'responsible' in their submission and asked about the legal implication of firearm free zones when it comes to leaving your firearm with security. Ms Kirsten said that the inclusion of the word 'responsible' was deliberate as that was the way gun owners used the term. [The answer regarding the legality of firearm free zones was not directly answered].
General Viljoen (FF) inquired into the implications of knives and sticks in firearm free zones. He went on to recommend that GFSA withdraw the last paragraph of its submission as regards a recent survey showing overwhelming support for stricter gun control. GFSA consented to the removal of the final paragraph from their submission. [An answer regarding the first inquiry was not forthcoming].
Other issues such as ministerial powers and mandatory reporting of injuries were raised by Mr Geldenhuys (NNP).
Mr Goniwe (ANC) alluded to the theory that gun control disarmed law abiding citizens and said that it had originated in the USA.
The chairperson asked for further clarification as to an Independent Firearms Authority to which the response came from Adele Kirsten that this was not police business and that they should outsource.
Professional Hunters Association of South Africa (PHASA)
Specific objections raised
- PHASA described firearms as being ''the tools of [their] trade''. As such they object to the limitation on owning rifles because such a limitation will have a negative impact on their business. They reject the requirement that a hunter must prove to the Registrar that he needs a firearm. This effectively gives the government unlimited power to take away the firearms of law-abiding citizens.
- Further, once a person has been granted a licence to own a firearm there should be no restrictions on the quantity of ammunition (particularly for professional hunters) that he is allowed to possess.
- They object to the requirement that their members must relicence their firearms every two years.
- They are strongly opposed to the requirement that the visiting hunting clients should satisfy the Registrar that they are ''fit and proper'' to hold an import permit for the firearms (and ammunition) which they wish to bring into SA for safari purposes.
PHASA noted that there is an important link between tourism and hunting. According to them the most important tourists to visit SA are international hunting guests. One reason for the importance of these guests is the fact that they spend up to 30 times more than the average tourist. They contend that this legislation will ''effectively close down the safari industry''. Thus the impact on the tourism industry will be negative.
- In conclusion PHASA said that the law must balance the interests of those governing and those being governed. They will support a workable, sensible system of firearm regulations that will curb criminal use and abuse of firearms.
In response to a question, the presenter replied that licencing should be applied from the age of 21. However an apprenticeship should start at the age of 18 years for aspiring professional hunters.
South African Human Rights Commission (SAHRC)
In light of the present levels of violent crime in South Africa, the SAHRC supports this Bill. The Bill was described as an urgent corrective measure. In spite of their support for the Bill, they noted a few objections to the current draft:
- Clause 99 - employees of official institutions are exempted from obtaining competency certificates. SAHRC does not support this exclusion.
- Clauses 11(n), (o) and clause 101(8)(b) require that all firearm owners complete a written test on their knowledge of the Act and a practical test on the safe handling of a firearm. The SAHRC raised concerns in respect of the public's access to the Act. Steps must be taken to make the Act available to the public in plain language (summary form).
The proposed tests should be regulated and monitored to avoid corruption, abuse and regressive deterioration of standards.
- They support firearm free zones but noted practical difficulties which this may pose. For example, people cannot be expected to leave firearms at home (as they may have to travel through dangerous areas before getting to the firearm free zone). If the zone provides a firearm safekeeping facility this might carry an appeal for the criminal element. There will also be a cost involved in managing these zones. They asked the drafters to apply their minds to these practical problems.
They proposed that the establishment of firearms free zones be incorporated into the cost of purchasing firearms. [Thus firearm buyers will subsidise the creation of firearm free zones.]
- There are no provisions to lay down ground rules for the Registrar. They suggest that the Registrar must be subjected to public oversight by an independent organ of civil society.
- The Bill only gives the legal framework of the proposed new system. The successful implementation of the Act will depend largely on the content of the regulations. Public participation in drafting the regulations is important. Therefore the draft regulations should be published for comment and public hearings before the Act comes into force.
- They noted that they support the redraft of clause 125(2) (administrative fines). The clause now gives effect to the constitutional right to ''access to courts''. Perpetrators have the right to elect an administrative fine or a criminal trial.
Dr Geldenhuys (NNP) asked the presenter to comment on the fact that the purpose of the Bill was to fight crime.
The presenter replied that the Bill is not aimed at reducing general crime but it is aimed specifically at reducing firearm-related crimes. The Bill should be seen as one of the measures to reduce crime.
Advocate Swart (DP) asked how this Bill would address the illegal smuggling of firearms.
The presenter replied that the illegal smuggling of firearms should be seen as a function of the police and not a function of the proposed Bill.
Mr Zondo (ANC) asked the presenter who from civil society could play the oversight role which was suggested in the presentation.
The presenter suggested the Public Protector or a Gender Commissioner.
This organisation is involved in the construction of safe buildings in informal settlements in order to house firearms. They support the need for accountability and called on all citizens to support the Bill and not merely to rely on the police. They pointed out that the question of licences should be addressed within the context of the current backlog in the issuing of licences and relicencing. The organisation proposed that the issuing of firearms licences be linked with the auditing of firearms.
Khuseleka supported the amnesty notion without prosecution. They said that a friendly approach should be applied to encourage people to submit their firearms. They proposed that a course consistent with the type of weapons bought from the market should be introduced. The course should be presented in a person's mother tongue and should suit both literate and illiterate people.
Khuseleka proposed that security facilities be installed in firearm free zones to protect ordinary citizens. They raised concern around the implementation of the Bill. They also noted concerned that the Bill does not address people living in informal settlements. In light of this they said that there should not be discrimination (on economic grounds) in respect of the allocation of firearms to the people of South Africa.
Mr Booi (ANC) asked Khuseleka how much it costs to install a safe in an informal settlement.
Khuseleka replied that the cost was between R120 to R150. This included the cost of the cement.
Mr George (ANC) asked Khuseleka whether owning firearms is a priority for people living in an informal settlement. Dr Geldenhys (NNP) asked whether it is possible for people in the lower income groups to own firearms.
Khuseleka replied that buying firearms is not a priority but people want to protect themselves as the need arises.
Dr Geldenhys asked Khuseleka whether they would vote in favour of the Bill if they were members of the committee.
Khuseleka responded that they would vote for the Bill because they support the need for legislation that would reduce violence, particularly firearm-related violence.
Mr Blom (ANC) asked for a comment about the time frames for people to hand over their illegal firearms and the age limit for a person to own a firearm.
Khuseleka replied that the granting of amnesty should be an ongoing process that is subject to evaluation. This evaluation will inform the future approach on the issue.
In respect of the age limit they replied that the system should be such that a person qualifies to own a firearm rather than basing ownership on age. They noted that young people can be employed as policemen and at eighteen they can vote.
Institute for Security Studies (ISS)
The ISS representatives come from academic, legal, research and police backgrounds. They told the committee that each proposition that they make is backed by some form of research. They noted that the Bill will make a positive contribution to human security in South Africa and also toward meeting international standards.
They referred to international initiatives such as the Vienna Firearms Protocol and the United Nations 2001 process. The ISS told the committee that an international process to tighten the circulation of illegal arms will be concluded this coming December.
They also referred to developments on the African continent such as developments made by the Organisation for African Unity (OAU) and some initiatives in the SADC region. They mentioned a recent meeting of various police chiefs and commissioners of Southern African member states discussing issues ranging from competency tests, control and storage of firearms.
They view the Bill as being in line with trends and requirements in our region and internationally. They support the stiffer sentences that go with the privileges of owning a firearm. This includes provisions relating to competency testing, age restrictions, and more police powers.
Mr Blom (ANC) asked whether they view the Bill as constitutional.
The ISS replied that when it was introduced in December 1999 they felt that it would not pass the constitutional test. However, as it stands now it would pass the constitutionality test.
Mr Matsila (ANC) asked the ISS how it views the question of sportspersons and hunters. Are they seen as a threat or not?
The ISS replied that they are not a threat to society. The policy that guided the formulation of the Bill has accommodated the occasional hunters and those engaged in sport.
Mr Ndlovu (IFP) asked which age restriction the ISS is talking about in terms of firearm ownership. Do they think it should be the burden of the Registrar or the firearm owner to renew the licence? Do they think the search and seizure provisions should be changed?
The ISS replied that:
- they believe that 18 years of age is the correct one.
- on the renewal of licences, the danger is the administrative cost of taking a person to court.
- those search and seizure provisions in the Act have already been tested and are in line with our Constitution and no changes can be expected.
Dr Geldenhys (NNP) asked the ISS to comment on whether they were funded by a Foreign Ministry or by South Africa to draft the Bill.
The ISS replied that at the beginning of 1999 they were approached by the Department of Safety and Security to draft a firearms law. They were not funded by the government but welcomed the government's offer to assist in raising funds for them. The ISS made a research proposal to the British Department for International Development with an attached letter from the government and it agreed to fund them.
Gen Viljoen (FF) asked who funds the ISS. He also asked whether it is it right to start with the firearms rather than the criminals?
The ISS replied that having a long list of funders assists in an organisation. In this way it is not easily influenced by any particular funder.
In the Southern African region there are two levels of existing stock that results in the illegal smuggling of firearms. The legally owned weapons in SA are being circulated illegally either through negligence or because they are being stolen. This Bill is addressing this problem.
In response to a question by Adv. Swart (DP) the ISS replied that:
- it is difficult for every citizen to known the pending law. The correct way to deal with this is to put regulations that can easily be understood by the citizens.
- The Bill is not meant to fight illegal firearms. This is the responsibility of the police. Many laws are in place to fight crime in SA. The objective of this Bill is to ensure that firearm crime in SA is addressed. In light of this purpose, the Bill is adequate.
The Chair thanked the ISS for having contributed to this process. The meeting was adjourned.
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