Cover Story

Raising the Costa Concordia

Insurance foots the bill for the largest marine recovery project in history.
By: | September 1, 2013 • 13 min read
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The plan to raise the Costa Concordia — the largest and most expensive wreck removal operation in maritime history — is a marine engineering marvel. But a successful outcome is far from assured and the cost is approaching $1 billion.

When the massive Costa Concordia passenger ship ran aground on Jan. 13, 2012, claiming 32 lives, it entered the marine insurance record books.

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Hull insurance on the vessel, at more than $500 million, is now paid off by insurers, which include XL, Generali and RSA.

But the removal of the wreck of the Costa Concordia, the largest such project ever attempted, is driving costs onto additional insurers that could reach $1 billion. Those carriers include P&I (protection and indemnity) clubs, which are, in essence, marine mutual insurers owned by ship owners and related interests.

Those charged with righting the decaying ship and plucking it off the reef are in a bind. Each day on the reef weakens the ship’s hull. Magnifying the ship recovery risk is the size of the Costa Concordia. The ship measures about the length of three football fields and weighs 114,500 gross tons.

By far, the biggest complication is the fact that the ship is wrecked in the environmentally sensitive Tuscan Archipelago National Park, a protected coral reef as well as a popular tourist destination.

The wreck must be removed whole in order to avoid releasing a swamp of debris and pollutants into the waters. For this reason, the Italian government is paying close attention to the project.

The need to remove the wreck in one piece left only the most expensive recovery option open: parbuckling and re-floating. Parbuckling, which refers to the process of rolling the ship back up to an upright position, is not a new invention. After the bombing of Pearl Harbor in 1941, the U.S. military recovered the capsized USS Oklahoma in much the same way. For the Concordia though, the costs involved in such an undertaking would be extraordinary.

“The instructions are ‘Get it off [the reef] and we’ll worry about costs later,’ which is the worst thing for an underwriter to hear,” said Steven Weiss, vice president, Marine Engineering and Project Cargo with Liberty International Underwriters.

Just as troubling as the cost, the shadow hanging over the plan is that a parbuckling operation has never been attempted on a ship anywhere near the size of the Costa Concordia. Even now, some still have doubts about whether it can really be done.

Getting Ready To Roll

From the moment the Costa Concordia came to rest on the reef, the race was on to avoid an environmental catastrophe. The ship was still carrying 2,300 tons of diesel fuel.

Dutch salvor Smit Salvage was brought in to pump out Concordia’s 17 fuel tanks — not as straightforward a task as it might seem. Draining the tanks would shift the vessel’s equilibrium, likely causing it to topple off the reef and sink, hemorrhaging fuel in its wake.

Smit used a process called hot-tapping, a painstaking method of pumping hot water into the vessel at the exact same rate that fuel is being pumped out, in order to keep the weight constant.

The fuel removal process alone took a team of 100 experts from around the world, with the aid of 20 platforms, tugs, transport ships, crane barges, tankers and oil spill response vessels. However, the 31-day operation was just a warm-up for the work that would soon begin.

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The contract to remove the wreck was awarded to a team comprised of Florida-based salvor Titan Salvage and Italian marine engineer Micoperi. The Titan-Micoperi plan has engaged 450-plus crewmen and divers from 19 countries, working around the clock for more than a year, with a menagerie of least 25 marine vessels and crafts operating at any given time.

“The number of engineers and amount of computing time they’ve used on this was probably equivalent to the first moon landing,” said John Phillips, vice president, Marine Hull, Liability & Cargo, Liberty International Underwriters.

That’s probably not far from the mark — it took three supercomputers running for weeks to model the wreck removal plan.

Work on the project began in June 2012, but parbuckling remained a distant goal. Every day that the ship lay on its underwater perch, it remained in danger of sliding down the steep seabed and sinking into 230-foot deep water, likely breaking apart in the process. Divers spent months stabilizing the vessel, securing it with chains, cables and anchor blocks to prevent it from becoming dislodged prematurely.

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About 65 percent of the ship lies beneath the water, its interior almost completely flooded. Therefore, the ship can’t float on its own and it will need a stable floor to support it before it can be refloated. Titan and Micoperi constructed a six-part subsea platform, aligned precisely so that the Concordia will land squarely on it once its rotation is complete.

Simultaneously, enormous airtight boxes called sponsons are being welded to the exposed side of the ship. The 15 sponsons, most around 10 stories high and weighing up to 500 tons, will be filled with seawater initially. They will act as a cantilever, adding weight and assisting in the rotation.

The main event — the parbuckle — will be a slow and tense operation, lasting at least two days. With a network of strong cables, the team must apply enough force to rotate the vessel, while being careful not to put too much stress on the hull.

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“There are a couple of big assumptions you’ve got to make,” explained Capt. Rich Habib, vice president and managing director of Titan Salvage.

“The amount of force you have to apply depends on the weight of the thing you’re going to rotate, where it’s going to pivot, and the center of gravity. It’s a simple physics problem if you knew all of the variables … but you don’t always know.”

The more force, the more risk. And for a ship that’s been languishing in the water this long, the risks are intensified. The Concordia’s hull is now covered in rust and is significantly weaker than it was 20 months ago.

“The water that it’s in is relatively warm temperature and that leads to more rapid corrosion,” said LIU’s Weiss. “The hull integrity of the vessel would become even more compromised.”

There’s no question that the parbuckling will be a nail-biter of an event. The ship is already in a stressed condition, lying in a position that the designers didn’t intend it for, said Habib.

“Now I’m going to add force to it. So I’m going to have a lot of distortions and things breaking and popping and so forth. It’s not a clean operation.”

After the ship has been rotated, most of it will be underwater. A matching set of 15 sponsons will be welded to the other side of the ship.

Hydraulic pumps will be used to force the seawater out of the sponsons and fill them with air, displacing water to create enough external buoyancy to lift the ship.

Slowly, the Costa Concordia will rise. But even then, a high degree of risk remains. The “what ifs” abound, said Michael Brown, area executive vice president, Marine, at Arthur J. Gallagher and Co.

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“The wreck could slide off the table while they try to pump air into the sponsons, or a sponson could fail or come loose, and it could sink.”

If that were to happen in deep water, some might consider it a blessing. But if it re-sank in shallow water, it would be a whole new ball game.

Either way, this operation is getting expensive, very expensive.

“With a lot of salvage events, the contract is bid with a [fixed] number. In a situation like this, it’s an open ended cost — there’s not an upper limit on it,” said Weiss.

“Because of the restrictions being placed by the government, the bottom line is they’ve got to remove the wreck. It doesn’t matter how much it costs, they’ve got to get it out of there.”

Salvors will continue to attempt the removal of the wreck until the limits of liability of the clubs is reached, said Brown.

And there’s the rub: “It’s an interesting fact that P&I clubs usually write vessels with unlimited liability except in the case of pollution,” said Brown. “So we’re talking mega potential loss. It could get worse or it could start all over again.”

The Titan-Micoperi plan has been vetted repeatedly, but challenges, or worse, surprises, may remain.

“We refloat things all the time, but we may not know the extent of the damage 100 percent beforehand so we have risk there too,” said Habib.

The team will have people and equipment in place “to ensure that once we float it, we can hold it.”

A Foundation That Flexes to Fit

Every salvage project, from a small capsized craft to a shipwrecked luxury cruise liner, carries its own unique circumstances and set of risks. Salvors need to rely on insurance programs that allow them to adapt to whatever comes their way.

Titan Salvage executives are keenly aware that their insurance program is the difference maker, giving the company the security it needs to operate in a risky industry. But it goes deeper than that. A dynamic insurance program gives salvors the freedom they need to be able to bid on any project quickly. It also becomes part of the overall value that the salvor has to offer its clients. Habib said the strength of the company’s insurance program helps set Titan apart.

“My insurance covers are not a cost to me; they’re a tool that I use to do my business. My underwriters are my partners,” said Habib.

Dwight Menard is vice president, risk management for Crowley Maritime Corp., the parent company of Titan Salvage.

“Crowley relies heavily on its core insurance program that is both well established, but also very flexible,” said Menard. “It has the ability to quickly respond to either a $1,000 job or a multimillion dollar job. Salvors’ insurance is a different animal — it’s unique and very specialized.”

Salvors’ protection and indemnity coverage must be broadly worded to cover regularly assigned employees as well as additional crew that may be hired for any given job. It also has to adapt to the intricacies of employment classifications.

“Salvage jobs may occur anywhere in the world, so you could have jurisdictional issues — are salvage workers seamen? Are they considered longshore and harbor workers? Or do they fall under a foreign employment scheme for injuries on the job? The P&I coverage for the salvage crew is extremely broad and allows the flexibility to cover any of those scenarios should an injury occur on a salvage job. It’s a very unique but absolutely essential type of cover for us.”

Salvors’ liability covers the operations of the salvor while undertaking the salvage project. In a situation like the Costa Concordia’s, where the vessel has already been declared a constructive total loss, the issue of damage to the vessel is moot. But a salvor still requires cover for damage to third parties, or any legal damages that may occur as a result of the operations of removing the wreck.

“Usually those types of covers are obtained at relatively low limits — low levels being $5 million — for a primary layer,” explained Menard. “So, in addition we have a very well structured bumbershoot and excess liability program to conceivably respond to much larger exposures and liabilities.”

Large scale salvage projects tend to be equipment intensive, but it’s not always possible to have equipment readily available when incidents occur in isolated parts of the world. That’s why some salvors find it more prudent to lease equipment locally, which typically means the salvor will have to provide cover for any physical damage to the equipment — some of it highly specialized as well as high priced.

Menard said that Crowley uses a captive to manage much of its equipment exposure.

“That’s included in the type of risk that we either self insure in the captive, or else cover through reinsurance for values in excess of aggregate deductibles. If it’s an extraordinarily high risk or an unusual piece of equipment, then specialized cover might be the best method of dealing with it. But for the most part, we’re able to cover these exposures through our captive and reinsurance program.”

Size in Perspective

The meter is still running on the financial toll of the Concordia wreck.

The ship’s safe removal remains the concern of The Standard Club and The Steamship Mutual, the lead P&I insurers for the ship, and the rest of the clubs in the International Group of P&I Clubs.

The vessel is reinsured through the International Group’s pooling system and reinsurance program with the London and international reinsurance markets. Costs from intense governmental oversight and the engineering required to safely remove the ship from the reef have pushed the P&I loss reserve to $1.17 billion.

Such eye-popping numbers for the wreck of a single ship have left some questioning whether marine vessels are simply getting too big — big enough for underwriters to start asking at what point a vessel is too risky to insure.

The Costa Concordia, put in service in 2006, was the first of five Concordia-class vessels, built for $570 million and measuring in at 114,500 GT (gross tonnage). But the Concordia’s sister ships are no longer the biggest behemoths afloat. Costa launched the Carnival Dream in 2009, a $741 million, 128,000 GT vessel. There are three Dream-class vessels currently in service, and a fourth 132,500 GT vessel being built.

But of course, the bigger they are, the harder they fall. Or sink, as the case may be.

It seems logical to ask if there might be a tipping point — the point at which the size of the vessel would make a salvage operation so expensive that insuring it would become too big a risk.

“It’s a valid question,” said Tim Donney, global head of Allianz Risk Consulting, Marine. “The truth is the international maritime salvage industry may not be able to keep up with the requirements of disasters such as the Costa Concordia.”

But Titan’s Habib is circumspect on the subject. Contrary to what the perception may be about the Concordia, he said, the project is actually moving at a brisk pace.

“Here, you have the largest passenger vessel in history, by weight — the largest salvage job ever accomplished, and we’re ready to parbuckle it in 14 months. I could name 10 projects that went on for two years or more — five years in one case — and you wouldn’t know one of those names if I rattled them off. There’s this perception that these large vessels are vastly more complex in the way that they have to be done. But it’s still a salvage job and it still has all the risks and variables of floating a 600-foot tanker.”

Bigger doesn’t necessarily change the equation, said Habib. Projects are more expensive for a variety of reasons — and they’re not all related to size.

“The salvor’s tool bag hasn’t changed much over the years,” he said. “What we’re doing on [the Concordia] is bigger than what’s been done before, but we’re using standard techniques. It’s really the requirements being placed on us from the outside that are driving the costs up.

“There’s a spotlight on the job, and that brings to bear all kinds of complications. The bigger the job, the more that’s perceived to be at stake, the more the underwriters and the consultants and the authorities want certainty. That drives the price up exponentially. Certainty comes at a pretty high price in salvage.”

Barring unforeseen disruptions, the Concordia will be parbuckled in late September. Any delay at this point could hurt the odds of a successful removal.

“The longer the job goes on, the greater the risk,” said Habib. “Time is our enemy. Always is, always has been, always will be.”

Michelle Kerr is associate editor of Risk & Insurance. She can be reached at mkerr@lrp.com
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Workers' Comp

Putting a Cap on Physician Dispensing

States are increasing regulation to limit physician distributed prescriptions.
By: | September 1, 2013 • 9 min read
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“If someone told you, as a physician, you could earn an extra $75,000 to $200,000 per year without having to see any additional patients, work more hours or increase your overhead, wouldn’t you like to know how?”

So begins an ad from MedX Sales Ltd., designed to create interest in MedX’s prescription repackaging and workers’ comp medical dispensing program. The four-minute ad goes on to state that some physicians handling workers’ compensation who sell MedX’s prepackaged generic and name brand medications to patients directly have “literally doubled their income” as a result.

Sound seductive? It is.

And yet, these sorts of promises from prescription drug repackagers are like most things that sound too good to be true, according to industry experts representing workers’ compensation payers including insurers, self-insured employers, TPAs and state workers’ compensation funds.

They fail to explain that when physicians sell prescription drugs to comp claimants directly, employers, insurers and other payers can expect to receive bills that are 100 percent to 700 percent more than invoices for identical medications dispensed by retail pharmacies like Walgreens and CVS. So said Joe Paduda, president of CompPharma, LLC, a consortium of the nation’s leading pharmacy benefit managers that are active in workers’ compensation, headquartered in Madison, Conn.

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In total, Paduda estimated that physician dispensing adds a billion dollars to employers’ workers’ comp premiums annually.

The issue is most pronounced in workers’ compensation, since “workers’ comp is basically dealing with pain, inflammation and so on,” with physicians often dispensing simple and inexpensive drugs like ibuprofen — possibly dispensing them at a factor of three to 10 times the price of over the counter, said Jacob Lazarovic, M.D., senior vice president and chief medical officer with Broadspire, a TPA to employers and insurers, based in Sunrise, Fla.

“The dispensing physicians can have a very small menu of 10 to 15 drugs including generally less potent opioids including the generic versions of Vicodin and Percocet, and that’s all they need to dispense drugs to all their compensation patients so it’s a very simple process,” said Lazarovic.

To address these kinds of problems — as well as safety issues that have emerged when doctors take on the role of pharmacists without the same kinds of information about patient histories and drug interactions — many states have adopted rules restricting or banning physician-dispensed medications.

PBM Map

California, for instance, first amended its fee schedule regarding physician-dispensed drugs in March 2007. The guidelines in question required that the relevant fee schedule for physician-dispensed drugs be based on the original manufacturer National Drug Code (NDC) for the drug — the very same rule that applies to pharmacies. Such rules override a loophole in national regulations set by the Federal Drug Administration, wherein a repackager is a manufacturer able to set its own NDC code and can price prescription drugs at the average wholesale price of its choosing.

The results have been staggering. Alex Swedlow, president of the California Workers’ Compensation Institute (CWCI), observed in a February 2013 report that from 2002 though 2006 — prior to the reform — physician-dispensed repackaged drugs climbed to nearly 60 percent of California’s total workers’ compensation prescription drug payments.

Today, the figure is less than 2 percent, Swedlow said. In the past, “it was not unusual to see a 1,000 percent difference for the same prescription” sold directly by doctors versus pharmacies, but today that extreme profit incentive no longer exists, he emphasized.

So far, states that have followed California’s lead in equalizing reimbursement rates include Arizona (October 2009), Georgia (April 2011), South Carolina (December 2011) and Tennessee (August 2012).

In California, meanwhile, the Swedlow study found that during the pre-reform period, when physician-repackaged drugs represented more than half of all drugs prescribed in California workers’ compensation, paid medical benefits on physician-dispensed repackaged drugs averaged $5,524, or 16.4 percent more than the $4,747 average for claims without them. Even after the March 2007 reforms, paid medical benefits on claims involving physician-repackaged drugs averaged $7,297 — 37.3 percent more than the $5,316 average for claims without these drugs.

In addition, the study found that comp claims with physician-dispensed repackaged drugs had a higher average number of paid temporary disability (TD) days. “Combining the pre- and post-reform results shows that from 2002 through 2011, claims with repackaged drugs averaged 44.1 paid TD days; 8.9 percent more than the average of 40.5 days for claims without repackaged drugs.

This finding challenges a critical statement often heard from repackagers — that the convenience of obtaining prescriptions from doctors should reduce the cost of medical care and facilitate quicker return to work.

“We found the opposite,” said Swedlow.

Reforms Reduce Opioid Use

Another state that has set its own standard as far as prescription drug repackaging is concerned is Florida. The state’s ban on physician dispensing of certain “stronger opioids” went into effect July 1, 2011. A study from the Workers’ Compensation Research Institute (WCRI) released this past July found that the Florida law reduced the overall use of opioids prescribed for injured workers in the state.

Apparently, the average Florida physician-dispenser continued to dispense pain medications after the ban, but increased the use of less addictive pain medications like ibuprofen and tramadol.

“The physician-dispensers could have continued to prescribe the stronger opioids (e.g., hydrocodone-acetaminophen), but would have been required to send the patients to pharmacies,” WCRI stated when it released the findings. The study reported no material change in the percentage of patients who received stronger opioids from pharmacies.

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Paduda observed that before the Florida changes, 5.7 percent of the prescriptions dispensed by doctors were opioids that fell under the ban. “After? 0.6 percent, and almost all of those were dispensed by docs outside of Florida for Florida claimants. Moreover, there was no appreciable increase in the volume of opioids dispensed by retail pharmacies, implying that the physicians who were prescribing and dispensing strong opioids stopped doing so when they could no longer dispense the medications from their own offices.”

A serious concern with drug repackaging and direct sales by physicians is the risk it poses for patient safety and potential drug interactions.

“Many times prescribing physicians will ask patients, ‘Are you taking other medications?’ and patients don’t know exactly what drugs they are taking,” said Robert Bonner, M.D., vice president of medical practices and medical director with The Hartford.

“The pharmacist has an automated system to check for potential drug interactions,” Bonner observed, whereas individual doctors do not.

One problem, he said, concerns patients who receive “second or third line drugs” that were once popularly prescribed but are no longer the drug of choice for a particular condition.

For example, a muscle relaxer known as Carisoprodol, marketed under the name Soma, and first developed in the 1950s, “is not used much anymore but is fairly common with physician dispensing,” said Bonner.

Often the process of drug repackaging and physician sales leads to patients receiving questionable medications, one source suggested. A 2006 study by CWCI found that acid blocker Ranitidine (the generic version of Zantac) also had one of the highest mark-ups when dispensed by physicians at the time, at $2.97 per pill when pharmacies were paid 18 cents — a 1,700 percent differential. Ranitidine was the most physician-dispensed drug at the time of the report.

“Usually, physicians would prescribe this drug for patients if they had trouble tolerating ibuprofen or aspirin,” said Bonner. But some doctors were automatically dispensing Ranitidine, prompting questions of whether the drug was medically indicated or precipitated by a profit motive.

Fighting Back

Paduda of CompPharma pointed to a few remedies being used for the repackaged drug problem:

* A number of payers are directing injured workers to go to physicians who don’t dispense their own drugs. This has been happening in California, Florida and Connecticut.
* Where critics are questioning the medical necessity of a particular drug a physician is dispensing, utilization review regulations may be used to contest the use of the dispensed medication.
* In many states, insurers are declining to pay bills where doctors are dispensing medications, requiring physicians who wish to contest the practice to take their complaint to an administrative law judge.

Broadspire has begun a pilot program, contacting physicians in Georgia and Pennsylvania who are dispensing drugs and telling them why the practice is questionable, said Lazarovic. Aiding Broadspire with the effort is HealthCare Solutions, Broadspire’s PBM.

“The preliminary result after one quarter’s worth of data is that physician-dispensed drug costs have declined by 9 percent” among those doctors who were part of the pilot, Lazarovic said.

Janet Aschkenasy is a freelance financial writer based in New York. She can be reached at riskletters@lrp.com.
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Sponsored: Liberty International Underwriters

Making the Marine Industry SAFE

A new initiative to help marine clients address safety risks leverages a customized, expertised approach.
By: | May 8, 2015 • 5 min read
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When it comes to marine based businesses there is no one-size-fits-all safety approach. The challenges faced by operators are much more complex than land based businesses.

The most successful marine operators understand that success is dependent on developing custom safety programs and then continually monitoring, training and adapting.

After all, it’s not just dollars at stake but the lives of dedicated crew and employees.

The LIU SAFE Program: Flexible, Pragmatic and Results Driven

Given these high stakes, LIU Marine is launching a new initiative to help clients proactively identify and address potential safety risks. The LIU SAFE Program is offered to clients as a value added service.

Richard Falcinelli, vice president, LIU Marine Risk Engineering

Richard Falcinelli, vice president, LIU Marine Risk Engineering

“The LIU SAFE program goes beyond traditional loss control. Using specialized risk assessment tools, our risk engineers function as consultants who gather and analyze information to identify potential opportunities for improvement. We then make recommendations customized for the client’s business but that also leverage our knowledge of industry best practices,” said Richard Falcinelli, vice president, LIU Marine Risk Engineering.

It’s the combination of deep expertise, extensive industry knowledge and a global perspective that enables LIU Marine to uniquely address their client’s safety challenges. Long experience has shown the LIU Risk Engineering team that a rigid process will not be successful. The wide variety of operations and safety challenges faced by marine companies simply cannot be addressed with a one-size-fits-all approach.

Therefore, the LIU SAFE program is defined by five core principles that form the basis of each project.

“Our underwriters, risk engineers and claims professionals leverage their years spent as master mariners, surveyors and attorneys to utilize the best project approach to address each client’s unique challenges,” said Falcinelli.

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The LIU SAFE Program in Action

When your primary business is transporting dry and liquid bulk cargo throughout the nation’s complex inland river system, safety is always a top concern.

The risks to crew, vessels and cargo are myriad and constantly changing due to weather, water conditions and many other factors.

SCF Marine, a St. Louis-based inland river tug and barge transportation company and part of the Inland River Services business unit of SEACOR Holdings Inc., understands what it takes to operate successfully in these conditions. The company strives for a zero incident operating environment and invests significant time and money in pursuit of that goal.

SponsoredContent_LIUBut when it comes to marine safety, all experienced mariners know that no one person or company has all the answers. So in an effort to continually find ways to improve, SCF management approached McGriff, Seibels & Williams, its marine broker, to see if LIU Marine would be willing to provide their input through an operational review and risk assessment.

The goal of the engagement was clear: SCF wanted to confirm that it was getting the best return possible on its significant investment in safety management.

Using the LIU SAFE framework, LIU’s Risk Engineers began by sending SCF a detailed document request. The requested information covered many aspects of the SCF operation, including recruiting and hiring practices, navigation standards, watch standing procedures, vessel maintenance standards and more.

Following several weeks of document review the LIU team drafted its preliminary report. Next, LIU organized a collaborative meeting at SCF’s headquarters with all of the latter’s senior staff, along with McGriff brokers and LIU underwriters. Each SCF manager gave an overview of their area of responsibility and LIU’s preliminary findings were reviewed in depth. The day ended with a site visit and vessel tour.

“We sent our follow-up report after the meeting and McGriff let us know that it was well received by SCF,” Falcinelli said. “SCF is so focused on safety; we are confident that they will use the information gained from this exercise to further benefit their employees and stakeholders.”

“It was probably one of the most comprehensive efforts that I’ve ever seen undertaken by a carrier’s loss control team,” said Baxter Southern, executive vice president at McGriff, which also is based in St. Louis. “Through the collaborative efforts of all three parties, it was determined that SCF had the right approach and implementation. The process generated some excellent new concepts for implementation as the company grows.”

In addition to the benefits of these new concepts, LIU gained a much deeper understanding of SCF’s operations and is better positioned to provide ongoing loss control support.

“Effective safety management is about being focused and continuously improving, which requires complete commitment from top management,” Falcinelli added. “SCF obviously is on a quest for safety excellence with zero incidents as the goal, and has passed that philosophy down to its entire workforce.”

“SCF’s commitment to the process along with LIU’s expertise was certainly impressive and a key reason for the successful outcome,” Southern concluded.

There are many other ways that the SAFE program can help clients address safety risks. To learn more about how your company could benefit, contact your broker or LIU Marine.

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This article was produced by the R&I Brand Studio, a unit of the advertising department of Risk & Insurance, in collaboration with Liberty International Underwriters. The editorial staff of Risk & Insurance had no role in its preparation.




LIU is part of the Global Specialty Division of Liberty Mutual Insurance.
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