Engineering risk survey reports –
an insight for underwriters
Contents
Introduction ............................................................................................................................................
3
The purpose of a survey report
..........................................................................................................
3
Risk surveyor
...........................................................................................................................................
3
Where the underwriters is involved
in the choice of risk surveyor/risk engineer ............................. 3
Where the underwriter is not
involved in the appointment
.............................................................. 5
Instructions to surveyors
........................................................................................................................
6
Source of instructions
.........................................................................................................................
6
Time and money
.................................................................................................................................
7
Survey timing
......................................................................................................................................
7
The report
...............................................................................................................................................
8
“Reading between the lines”
..............................................................................................................
8
Co-operation
.......................................................................................................................................
8
Cultural and management style
issues
...............................................................................................
9
Language
...........................................................................................................................................
10
Facts and analysis
..............................................................................................................................
10
Photographs
......................................................................................................................................
11
What cannot be said
.........................................................................................................................
11
Recommendations
................................................................................................................................
12
After the report is issued
......................................................................................................................
14
Conclusions
...........................................................................................................................................
14
Introduction
When underwriting an engineering
risk, insurers rely on a variety of information most of which is factual. Judgment
is needed about the quality of the risk and this will be based on what the
underwriter knows from experience, intelligence about the risk and any survey
report. The aim of this paper is to help those who regularly read survey
reports to be aware of the circumstances and limitations surrounding the
creation of survey reports when interpreting what they read.
The purpose of a
survey report
Survey reports are intended to:
• set
a risk into a context of other similar risks
• evaluate
whether relevant specifications have been complied with
• identify
any unusual features which might influence an underwriter
• provide
more detail than an underwriting submission
• make
recommendations for risk improvements
A report which makes clear that a
risk is of poor quality can cause an underwriter to:
• refuse
to offer terms
• charge
a higher premium
• or
restrict cover
Surveys can also sometimes improve
the image of a risk.
Case history – For a number of years
after a major city suffered earthquake damage, underwriters in the
international markets believed that public structures such as schools and
hospitals (which had suffered extensive damage) were likely to perform poorly
in a future earthquake event. A broker-arranged survey showed that since the
earthquake extensive structural retrofitting had taken place and new buildings
were built to a much higher standard than before. As a result it was reasonable
to expect much improved structural performance in any future earthquake.
Underwriters should be prepared to
set aside an established view where fresh information allows them to quote a
very competitive premium or offer wider cover than others who are being asked
to quote.
Risk surveyor
Sometimes underwriters are involved
in the choice of a risk surveyor/risk engineer and sometimes they are simply
presented with a report.
Where the
underwriter is involved in the choice of risk surveyor/risk engineer
The underwriter needs to be
satisfied that the person who is to undertake a survey and produce a report:
• understands
what is to be surveyed
• has sufficient insurance knowledge
• is suitably qualified
•
has experience to produce
opinions which are credible and assess the risk against international best
practice standards
• is known in the insurance market
• has a good reputation
• carries professional indemnity
insurance, since it is an indicator of quality because a professional indemnity
underwriter has to be satisfied that the surveyor is competent and qualified to
undertake survey work
Case history: A surveyor
from a small survey company with no professional indemnity insurance reported
that there was no risk of explosion on a grain handling facility. The reason
for this was not explained. Such facilities are renowned to be susceptible to
grain dust explosions. No details were provided on the measures to avoid
explosions and a few months after the survey the facility was virtually
destroyed by a chain reaction of explosions.
Whilst the surveyor had been
negligent, in this case the underwriter should have questioned the surveyor’s
competence or impartiality. Had the underwriter identified the flaw in the
survey report, cover might have been denied, or a new survey commissioned
leading to improvements in the management of the dust explosion risk and thus
avoiding the loss. In the absence of professional indemnity insurance, the
pursuit of a recovery was judged in this case to have limited prospect of
success.
A surveyor with
knowledge and experience of a particular technology should be able to explain
it clearly and make insightful comments and recommendations. One who is
struggling may just re-state information they have been given or leave
technical jargon unexplained.
The surveyor should
have international experience to be able to set the risk surveyed into
international best practice standards, and knowledge of engineering standards
that are applicable in different countries as well as familiarity with policy
clauses and codes, for example:
• European norms,
• British Standards,
• ASME1 standards,
• ASTM2 standards,
• FPA3 standards and codes including the
Joint Fire Code4,
• NFPA5 standards and codes,
• Tunnel Code of Practice6,
• FM7 standards,
·
Munich Re policy and
condition/endorsement wordings,
• Swiss Re policy and
condition/endorsement wordings,
A surveyor’s clients
may wish multiple aspects of a risk to be surveyed such as
• property exposure
• construction/erection all risks
• delay in start-up risks
• third party liability exposure
• business interruption risks
• contingent business interruption risks
Expertise is required
in each aspect, if risks are to be properly considered. Reports from technical
specialists with limited insurance understanding may focus too heavily on the
technology of what has been surveyed and insufficiently on the factors that
determine the quality of risk and what might be done to manage them better.
Large insurers,
reinsurers and brokers have teams of surveyors who usually work in a fairly
standardised way with defined routines and report formats including rules to
govern what goes into a report and how it is interpreted. An underwriter has to
decide if their in-house team has sufficient expertise or whether to appoint an
external specialist. In-house teams may be focused on the types of risk that
generate large numbers of surveys (and thus a predictable workload) and may not
have expertise on some types of risk.
They may not be
prepared or allowed to work in some territories where there are difficult
security situations. Both underwriters and the client may benefit from input of
an independent surveyor.
Underwriters also need
to consider the needs of the following market who may not have the opportunity
for informal conversations with the surveyor and may be unfamiliar with
reporting conventions and rating systems.
Swiss Re8 has provided
some useful guidance about the survey process in general. IMIA has analysed
risk management approaches in Construction and Erection projects9. The London
Engineering Group (LEG) has produced a standard for some types of risk survey
report10.
Where the underwriter
is not involved in the appointment
When the underwriter is not
involved in appointing the surveyor, it may be only when the survey report is
received that the underwriter will know who has produced it. The underwriter
should go through the same process as if they were being given a choice of
surveyor before the survey and decide on the weight they are prepared to give
to the opinion of the surveyor who has written the report.
The underwriter should
look at who has signed the report and who made the survey visit since reports
are sometimes countersigned by people who were not present during the survey.
Having a second person to review a report (the so-called “four eyes principle”)
is certainly desirable but the person making the survey inspections and
conducting the survey process also requires appropriate skills, experience and
knowledge in the discipline and technology of the risk. A report produced by a
senior person whose skills and experience are inappropriate should be viewed
with some scepticism.
When reviewing a risk
survey report, an underwriter needs to
• Consider whether the right person has
undertaken the survey and written the report
• Consider whether the surveyor was
briefed about the background to the survey, the history of the risk and areas
of particular concern. (see “instructions to surveyors” below)
• Satisfy themselves that the surveyor
highly values his/her professional reputation and was not influenced
inappropriately by commercial pressure. (see “source of instructions” below)
Instructions to
surveyors
Source of instructions
The source of
instructions for the surveyor is important, whether it be a broker, a cedant,
an insurer, a reinsurer or a company seeking insurance. Whilst a survey
requires objectivity, there will also be instances where subtle interpretations
of what has been surveyed are made. Interpretations can make a significant
difference to an underwriter’s impression of a risk. At their most basic they
can express where the risk should sit on the scale of good and bad.
Surveyors will want to
protect a source of regular instructions. An adverse survey report can make it
difficult for a broker or cedant to obtain cover. Of course no one is so crude
as to say to a surveyor they will only be paid if the report provides a positive
impression of the risk. Nevertheless a surveyor may be conscious that the fee
or future survey instructions may be at risk if brokers/cedants or the company
surveyed receive a negative survey. This can lead to the survey report being
nuanced.
In determining how much
faith they put in the survey report, underwriters should take into account any
pressures to which the surveyor may have been subject. If a surveyor has been
positive about a risk in a report without justification this can occasionally
lead an underwriter to insist on a second survey by a surveyor of underwriters’
choosing with instructions to be wary.
Surveyors may also have
been instructed as a result of commercial pressure on the underwriter. For
example, a broker or cedant may suggest to an underwriter that their own survey
team be used. Underwriters not wishing to upset someone who can be influential
in a competitive bid situation may agree.
Independent surveyors
work under contracts and care is required that the contractual terms governing
the survey do not have an adverse impact on what a surveyor can say. It is not
unusual for surveyors to sign confidentiality agreements, since they will be
shown locations and be given information which is commercially sensitive.
Time and money
Sufficient time and money needs to
be allowed if a survey report of suitable quality is to be produced. With
unrestricted access but limited time, the choice of what should be inspected
can be guided by what the surveyor considers important. If poor choices are
made an unbalanced view of the risk may result. Some risk features require
particular attention, for example the tunnel sections on a long motorway
construction project. Surveys are often commissioned by underwriters with a
view to a particular aspect of the risk being scrutinized. Just because this is
in the forefront of the underwriter’s mind does not mean that it will be
obvious to the surveyor. If an underwriter wishes the survey to concentrate on
something specific then it is important to say so.
Adequate time needs to be allowed
for:
• Preparations including making advanced
requests for information, setting an agenda, agreeing a survey program,
obtaining a visa and/or security clearance.
• Travel, since risks may be spread over
hundreds of kilometers (such as a road, railway or pipeline) and a company’s
head office can be in a different location to the risk.
• Physical inspections
• Meetings with key personnel
• Reviewing information
• Report
writing
Companies offering survey services
operate in a competitive market. Whilst no one wants to waste money, an
unrealistic price or time allowance (and the two are often linked) may result
in a superficial or patchy survey report or the survey being conducted by
someone without the required knowledge and experience.
For some construction projects it
is not feasible to survey the whole project in a single visit. A risk
engineering programme therefore may need to review a proportion of the project
on one survey and the remainder on the next11 12. If insufficient time and
money has been allowed reports may be qualified to explain the limitations on
the work that could be undertaken.
Survey timing
If an underwriter wishes to have
the benefit of a recent survey report when making decisions about renewal or to
use renewal negotiations to push for risk improvements or changes in coverage,
sufficient time needs to be allowed for the survey to be undertaken and the
report delivered.
Some risks also look very different
at different times of the year because of weather conditions. For example a
road construction project can be a long dry hard dusty strip in the dry seasons
and a partially flooded mud bath with unstable slopes in the wet season. The
impression gained from two reports of the same risk at different seasons can
vary considerably.
The report
“Reading between
the lines13”
Before reading the technical part
of any report, an underwriter should check the preliminary statements since
sometimes they can give a valuable insight into problems that have arisen with
the survey process. If the underwriter is concerned they should ask the
surveyor about them.
For example, if a surveyor says in
a report “time was not available to visit the………”, the underwriter needs to
consider why? Was there insufficient money available for the survey? Did the
company being surveyed conceal something? Does it matter?
During a survey there is the danger
that risk owners may guide the surveyor towards locations which look good and
away from those that give a poor impression. This may not be in a conscious
attempt to deceive insurers but out of concern by a local manager that a survey
report will be seen by a wide audience including senior management. An
experienced surveyor, aware of such dangers, will look to avoid being too
obviously guided about what is inspected but there can be a limit as to how far
a surveyor can push to see something which a determined manager wishes to
conceal. Most companies being surveyed will be aware of the importance of not
being seen to deliberately conceal things from a surveyor but this will not
stop some from using subtle ways to try to guide a surveyor. Such tactics can
backfire if a detrimental aspect of a risk is uncovered. This can lead a
surveyor to question the credibility of both the information being provided and
the managers who they are meeting, thus raising concerns that a positive and
open attitude to risk management and safety is absent and instead there exists
a culture of concealment.
Co-operation
Survey reports should also contain
a statement about the level of co-operation, openness and willingness to engage
in the process demonstrated by the company being surveyed since it is an
important factor in gaining a positive impression of a risk. A lack of
co-operation can suggest:
• The company being surveyed has
something to hide
• The company does not understand the
importance of the survey report for future insurance cover
• Risk management is seen as a
peripheral activity to be managed in a narrow way by a safety officer rather
than by senior management
• Senior
management is overloaded to the extent that they do not have time to respond
properly
Poor co-operation can also come
about because of poor communication between insurer, broker, cedant, surveyor
and insured leaving managers no time to prepare properly because information
was not passed to them in time.
Occasionally problems
do arise with the survey process when access is denied or becomes impossible
for security reasons (such as when there is a sudden deterioration in the
security situation because of terrorist action). In such circumstances a
logical justification can be provided for a survey to be repeated.
Underwriters should
check on the list of attendees set out in the report showing who was and who
was not involved in the survey. If only the safety officer and the head of the
fire service are listed, why were senior managers and directors not involved? (There
can, of course be legitimate business reasons why senior managers were not
available.) Was there a lack of interest in risk management? A safety officer
is unlikely to be able to talk authoritatively about design, engineering,
quality, maintenance, operations etc.
Most reports will
include disclaimers to protect the surveyor and these need to be worded
acceptably.
Cultural and management
style issues
Cultural and language
issues can have a significant impact on how good a report can be produced. Risk
surveys and risk engineering are not common in some areas of the world and may
be regarded with suspicion or puzzlement. Senior managers of some organizations
may have little experience and understanding of insurance and risk management.
They may be feel that a surveyor is trying to tell them how to do their job or
to find fault. Others may be receptive but find it difficult to accept the
advice in the relatively open forum of a large meeting with a subsequent
report.
Case history: A survey of a power
plant construction project was undertaken with the close involvement of the
project manager. At the wrap up meeting at the end of the survey, the surveyor
set out the recommendations for improvement that he was proposing to include in
the survey report some of which required a carefully considered response. After
each recommendation was explained, the project manager picked up the telephone
to one or other members of his team and shouted at them. He concluded the
meeting by asking whether anything else needed to be changed? This indicated to
the surveyor that the project manager felt that deficiencies had been solved by
shouting at staff. For cultural reasons the surveyor felt it would not be wise
to say in the survey report that a different style of management was needed but
raised the issue with the underwriter at a subsequent meeting.
Where a difficult
cultural issue arises which is adversely affecting the quality of risk
management, it may be difficult to put it into a survey report which an insured
will see. When an underwriter is informed of such an issue he/she has various
options including:
• adjusting his/her rating of the risk
• advising the following market that
there is an issue that is not covered by the report
• contacting the broker to suggest that
the insured company could benefit from some management training for its senior
managers
• asking to see a written plan of action
for tackling the issues raised in the recommendations rather than waiting for
the next survey to take place to see if improvements have been made
Language
Holding meetings in more than one
language slows the surveyor’s ability to obtain information and obviously
increases the potential for time consuming and occasionally awkward
misunderstandings. Even meetings in one language (particularly in English which
is very widely spoken but by people with very different vocabularies) can
create difficulties if the level of language skills varies significantly
between the surveyor and those being surveyed. In such circumstances surveyors
need to be careful not to use overly complicated language or jargon since
misunderstandings can be caused by the use of a single key word which is not
understood. It can difficult for non-native English speakers to admit that they
do not understand something. Help for native English speakers in appreciating
the problem can be obtained by reviewing the “Globish14” website. Reports
should always be written in language that makes them easy to understand but
this is particularly important where those working for the company that has been
surveyed do not have English as their first language. Much of the survey report
(and particularly the recommendations) will have been written for their
benefit. Ambiguous or unspecific terms should be avoided and all acronyms and
abbreviations should be explained.
Facts and analysis
Reports, even lengthy ones, may
contain only factual descriptions of the location visited or the business that
was surveyed and not focus on issues relevant to the decisions that the
underwriter has to make, for example:
• Is
the risk better or worse than required to achieve an international best
practice level?
• What
changes need to be made to improve the risk and how should these be undertaken?
Whilst facts may be of interest to
the underwriter, it is important that reports also present conclusions and
explanations about the quality of the risk. A discussion with the surveyor may
clarify why aspects that the underwriter was particularly interested in or
worried about have been omitted.
It is good practice for the
surveyor to provide a draft copy of a survey report to the company that has
been surveyed so they can check it for factual accuracy and make comments on
the analysis it contains before the report is finalized. They may not agree
with the views expressed in the report and if issues are raised it may be
appropriate for the surveyor to record that the company surveyed has a
different view and explain why.
Underwriters should be aware that
survey reports are often not checked in detail by insured’s even when drafts
are supplied. Insureds tend to concentrate on executive summaries and
recommendations. Errors may only come to light on subsequent surveys or when an
issue arises and a particular statement becomes the focus of attention.
Underwriters are expected to be able to identify through their knowledge of an
industry, a particular technology or experience when a report clearly contains
a significant error.
Case history: A print works
containing large quantities of combustible material was surveyed. The entire
works were located in a single building with no fire compartment and poor
detection/protection systems. The surveyor recommended an EML of 50% of the
value at risk which the reinsurer adopted. Shortly afterwards a fire caused a
total loss. The reinsurer sought an opinion about suing the surveyor for
negligent advice on the EML. The reinsurer was advised that a knowledgeable and
experienced underwriter should not have simply accepted the recommended EML
when it was obvious from the description of the premises in the report that a
figure of 100% should have been used.
Where a report contains
a loss calculation, rather than simply accept it, an underwriter should
consider whether the calculation is credible. If he/she has doubts, these
should be raised with the surveyor or a second opinion obtained from another
surveyor.
Photographs
Photographs are
particularly useful for recording conditions during the survey and help to
avoid arguments about the presence of shortcomings. If the underwriter has
doubts about an issue it may be possible to probe this by comparing what
photographs show with the words in the survey report.
It is not always
possible to take photographs during a survey. Some installations are
strategically important and some companies feel that photographs may threaten
their commercial secrets. Occasionally photographs may be removed from a report
before it is given to an underwriter.
If there is no reason
why photographs could not be taken but there are none, then an underwriter
should check the contents list to see if they have received the complete
report. Removing the photographs (or attachment and appendices) from a report
must raise a suspicion that an attempt is being made to conceal the truth.
Sometimes reports are poorly reproduced which degrades the photographs and this
can be almost as bad as having none since the evidence shown in the photographs
can be obscured.
What cannot be said
There are some things
that a surveyor generally will not include in a survey report such as:
• Something a surveyor has been told by
those he/she meets but on condition that this information is not revealed
• Unauthorized/illegal activity which
the surveyor suspects is taking place but if mentioned in a report without
substantiation could result in the surveyor being sued.
• Personal opinions about individuals
encountered during a survey or comments that would be culturally unacceptable.
Case history: During a survey of an
industrial complex a surveyor became detached from the group undertaking the
site inspection and was for a short time just in the company of a department
manager.
When away from the complex’s
owners, the manager told the surveyor on a confidential basis that he was
struggling to run part of the complex safely because insufficient funds were
being made available for parts and maintenance. The surveyor was however advised
during the main survey meetings by the plant’s owners that all maintenance
tasks were fully up to date and there was no shortage of funding for spares.
The surveyor found it impossible to report in writing the conversation with the
manager but instead advised the underwriter in a phone call what he had been
told.
If an underwriter
becomes aware that an insured company is deliberately deceiving a surveyor, it
is reasonable to question whether they can rely on the doctrine of utmost good
faith. Faced with such a concern, an underwriter should call a meeting with the
surveyor and the broker to discuss whether the coverage can continue and if so
what actions are needed to address the situation. The broker is likely to have
to play the lead role in determining whether the relationship between
underwriter and insured has been damaged beyond repair or can be salvaged.
Recommendations
It is the
recommendations in a report that will normally receive the most attention. Many
recommendations involve minimal cost since they are about modifying behaviour.
They can also be controversial since complying with them can be costly or
require considerable effort over a prolonged period. In such cases underwriters
should be looking for a positive response to a recommendation including
acceptance of the deficiency and a sustained willingness to commit resources to
make necessary changes.
Case history. During a first risk
engineering survey of a major construction project the surveyor observed a very
poor site safety culture and recommended a series of steps to improve it.
Although the project’s managers accepted the need for changes, many months of work
were needed to change the attitudes of a large work force which had been using
poor practices for years. Several subsequent risk engineering survey reports
sustained the recommendation until eventually a marked improvement was
observed.
Underwriters should
evaluate the quality of each recommendation to make sure that it:
• is specific
• is achievable
• is proportionate
• provides sufficient information to
explain the problem
• provides technical details of how it
can be implemented
• cites references which explain that it
is good practice, If possible
A company that is
surveyed should understand the benefit of the various recommendations and
ideally agree with the need but this does not always happen. Wherever possible,
recommendations should be discussed during or at the end of the survey so that
the company has an opportunity to comment, to challenge or to suggest
alternative solutions.
Recommendations are not
conditions of policy coverage, although there are rare cases of warranties
being applied to onshore recommendations. Warranties are a more common feature
offshore.
Ultimately the decision
as to how much weight they are given with respect to the insurance coverage
rests with the underwriter.
Recommendations can be
seen by the underwriter as vital if they address a serious shortcoming. The
underwriter and broker can occasionally act as negotiators about whether
recommendations need to be followed or how they might be modified to establish
a compromise between an ideal situation that the surveyor might recommend, and
achieving enough of an improvement, at perhaps a lower cost, for an underwriter
to accept. It is possible for a surveyor to recommend measures to reduce a risk
to an unreasonable degree.
Underwriters should pay
greater attention to what has been recommended than simply to the number of
recommendations. Risks can appear to have improved significantly if a large
number of easy to implement recommendations have been complied with but this may
leave the more important ones outstanding.
There may be a
temptation to deal with risk problems outside the survey report. Indeed, if a
problem can be eliminated quickly then there is nothing wrong with the survey
report setting out what was wrong and how the situation has been improved since
it was identified. But it would be inappropriate for the surveyor to leave out
mention of the original problem and only report on the improved situation or to
report that a problem has been solved simply because a company expresses an
intention to make improvements.
Often a surveyor’s
actions will be sufficient to motivate an insured to make necessary
improvements in risk management. The underwriter can however reinforce
recommendations by expressing concern (often through the broker), by drawing an
insured’s attention to a specific and relevant policy condition which might be
breached if action is not taken or by reminding an insured of their general
duty to take reasonable care to avoid losses.
Case history: During a survey of a
railway construction project the risk engineering surveyor recommended that
fire protection systems be active when systems were energized during testing
and commissioning in the coming months. The project advised that this was
already planned. At the next risk engineering survey, some months later,
energised systems were observed under testing with no active fire protection
systems and the previous recommendation had to be repeated with its category
increased to a priority level. The underwriter also raised the prospect that
this omission risked breaching a policy condition.
Underwriters should be
aware that a survey report may not get to staff at the location surveyed but
may instead be retained by the company’s insurance team where action on
recommendations will not necessarily follow. If details of the actions taken in
response to a recommendation are supplied this gives the best indication that
the survey process is being taken seriously.
Survey reports should contain
information on the status of recommendations made in previous reports. If
recommendations have been ignored, it is a sign of a poor attitude to risk
management or insufficient attention to the risk survey process. Occasionally a
situation may deteriorate requiring the emphasis and priority given to the
recommendation to be increased. A surveyor can only comment on previous
recommendations if they are made available. A report should say if they have
been requested but not supplied or that no previous survey has taken place and
there are no previous recommendations.
After the report is
issued
Occasionally a survey
will reveal something which the underwriter considers unacceptable. If this
leads him/her to conclude that the risk is different from what he/she had
expected to such a degree that the risk would not have been underwritten had
the facts been known, then this is likely to be taken up with the broker. In
extreme circumstances this may lead an underwriter to withdraw cover. More
frequently an underwriter may insist that a change is made or a recommendation
is followed within a limited time period indicating that, if action is not
taken, this may have a detrimental impact on coverage for any claim associated
with the shortcoming that has been identified.
Case history: During a
survey of a project to convert an operational simple cycle gas fired power
plant to combined cycle, it became apparent that in the operational area of the
plant, gas was being vented which was drifting into the construction area where
hot work was taking place. A recommendation was made to stop gas venting or
install continuous gas monitoring.
Where there is a very
poorly managed and unsafe situation with the potential for a large loss
underwriters are justified in acting decisively. In this case, after
considering the situation, the underwriter advised the insured that damage
caused by an explosion resulting from ignition of vented gas would not be
viewed as an unforeseen event and any resulting claim would be repudiated.
Whilst the risk
surveyor has no authority to make any decision that has an impact on policy
coverage, the underwriter does have that power if there is a breach of a policy
condition.
Conclusions
In an ideal world it
should be possible to take what is said in a risk survey report at face value.
In reality, the circumstances in which reports are commissioned and surveys are
carried out are not consistent and quality varies. Underwriters need to be
aware of the subtle ways in which a report’s contents might be manipulated to
make a risk look good without telling a lie. Underwriters need to know when to
ask questions, when to challenge a conclusion and when there is a serious
problem requiring action that may strain commercial relationships.
Armed with the
guidelines provided in this paper, a skilled and experienced underwriter should
be able to work out what limitations apply to a report and decide whether
he/she can live with them.
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