Pattern 2

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Summary

Corporate Procedure

No. 505.31

Date issued

January 5, 2005

Subject

PRODUCT/SOLUTION LIFE CYCLE   MANAGEMENT

Replaces issue dated

June 3, 2003

Next review date

January 5, 2008

This Corporate Procedure (“Procedure”) shall   be followed by Nortel Networks Corporation (“NNC”) and its subsidiaries and   other controlled businesses globally, whether incorporated or unincorporated   (collectively, “Nortel”). 

1.0 Purpose

The   purpose of this Procedure is to provide the operating requirements and   functional responsibilities necessary to ensure the maximum effective use of   process discipline for Product Life Cycle Management. This Procedure serves as a key element for   implementation of Corporate Policy 700.02 – Product Design and Life Cycle   Management. 

2.0 Interpretation

The   General Manager(s) of each applicable Product portfolio are responsible for   implementing this Procedure in a consistent manner that fits the needs of   their business and adheres to Corporate Policy 500.04 – Quality and Customer   Satisfaction. 

3.0 Definitions

3.1 “Business Decision Point” is an event driven   evaluation used to set common expectations on market-based goals, evaluate   market performance, consider/ analyze Risks, make decisions on   project/Product content, direction, quality, funding, schedule, and resource   levels, and empower the project team to execute project plans in accordance   with the Nortel Corporate Policies, Procedures and Standards.

3.2 “Core Strategic Vision”   articulates market and customer focus, Product and Solution focus, life cycle   management considerations, and requisites for business success.

3.3 “Corporate Policy” is a   Nortel statement of a governing principle.

3.4 “Corporate Procedure”   is a Nortel document governing the implementation of a Corporate Policy and   related processes.

3.5 “Corporate Standard” is   a Nortel document used to define the requirements necessary to meet industry   standards and specific Nortel requirements. Corporate Standards shall be adhered to by Nortel, and where   applicable, by suppliers, contractors and sub-contractors (see Corporate   Policy 500.16 – Corporate Standards).

3.6 “DCA” means Delivery   Customer Assurance and is a process used to drive the delivery of Products   and services to meet or exceed the customer’s expectations and to preserve   margins.

3.7 “Executive Investment   Council” is a term used to describe the Nortel executive team that sets the   vision, mission, strategy, and Product roadmap for portfolio investments,   execution, and business results.

3.8 “Intellectual Property   Review” means review by a member of the IPT together with a member of the   Intellectual Property Law Group to identify any patentable inventions   associated with the project and to ensure that any appropriate invention   disclosure submissions have been made to the Intellectual Property Law Group.

3.9 “IPT” means Integrated   Project Team and is a term used to describe a cross-functional team, chaired   by a team leader, who is accountable for the success of the project to meet   customer/business needs, developing/implementing portfolio project plans, and   is accountable to the Portfolio Management Team throughout the duration of   the project.

3.10 “NPI” means New Product   Introduction and is the interval during which all ideas through deployment   phase activities are managed and completed for the design, test, and delivery   of a Product or Solution to all intended markets.

3.11 “Operational Support   Processes” includes processes for any or all of the following functions: order, configure, procure, manufacture,   integrate, and test; move, install, train, repair, and technical support.

3.12 “Out-of-Bounds” means   that the project parameters as originally defined will have a significant variance   and potentially alter or impact the intended project outcome.

3.13 “Portfolio Management   Team” is a decision making team, chaired by the portfolio lead (i.e. General   Manager or delegate), which is accountable for portfolio strategy, resource   allocation, and ongoing portfolio management/ decisions relative to market   timing, customer need, and business priorities. This appropriate cross-functional team is   accountable for the performance of all Products within the portfolio and to   ensure those Products are supported by an accountable IPT leader or Product   owner.

3.14 “Product” is a term used   to describe a single offering of hardware, software, documentation, services   or any combination thereof.

3.15 “Product Life Cycle   Management” is a term used to describe all Product introduction, Production,   and Retirement activities.

3.16 “Production” is the   interval during which all Production phase activities are managed and   completed to meet delivery commitments, achieve return on investment,   support/improve quality and performance, and meet/exceed targeted levels of   customer satisfaction.

3.17 “Retirement” is the   interval during which all Retirement phase activities are managed and   completed to stop Production, provide continued service and maintenance, and   eventually exit the market.

3.18 “Risk” is a term used to   describe the possibility of an impact or loss – typically in the form of   diminished Product quality, increased costs, project delays, and/or failure   to meet business objectives.

3.19 “Risk Management” is a   disciplined practice – supported by process, methods, and tools - used to   proactively and continually identify, assess, prioritize, and mitigate Risks   critical to project/business success.

3.20 “Solution” is a term   used to describe a combination of multiple Products – typically from multiple   portfolios (internal) and/or vendors (external) – designed to interoperate to   satisfy a customer need.

4.0 Responsibility

4.1 The General Manager for each Product   portfolio shall:

(a) Establish and hold a   Portfolio Management Team accountable for making strategic business decisions   that optimize Nortel’s investment in that portfolio.

(b) Develop and maintain a   Core Strategic Vision in conjunction with the Portfolio Management Team –   ensure alignment to and execution of the investment strategy and Product   roadmap as defined by the Executive Investment Council.

(c) Clearly distinguish   between higher level platforms and single point Products within the portfolio   and include other portfolio leaders in platform level business decisions that   may impact their Products, and ensure the required level of interoperability   is defined.

(d) As mandated by the   executive leadership team, ensure accountability to the responsibilities   outlined in this Procedure in support of Corporate Policy 700.02 - Product   Design and Life Cycle Management.

(e) Assume responsibility for achieving   targeted levels of customer satisfaction and all aspects of Product   performance. 

(f) Establish assurance programs,   including regular audits by an independent party, to ensure:

i. all Products in the portfolio are   supported by an appropriately staffed IPT or, as business/Product needs   dictate, at least a single, accountable Product owner;

ii. process discipline is   being applied across the entire portfolio through use of documented life   cycle management processes, inclusive of measurement of process   effectiveness, root cause analysis, applied best practices, and continual   process improvement as a result thereof;

iii. minimum requirements   for Business Decision Point content, documentation, approvals, storage, and   accessibility must be defined and consistently met;

iv. Product life cycles are being managed   to meet investment and/or business objectives;

v. Product quality plans and performance   targets are defined, progressive, consistently measured, and documented - in   the Business Decision Points for each Product - to demonstrate use of   documented design and life cycle management processes (reference the phase by   phase activities and exit criteria requirements of Corporate Procedure 505.32   - Product/Solution Design and Test);

vi. customer interaction   programs are established to regularly measure customer perceived quality and   track the top issues, by account, in collaboration with the key account   teams; and

vii. all aspects of Product design, delivery,   safety, maintenance, and potential Product recovery from customers meet   applicable legal, contractual, environmental and regulatory requirements - in   all applicable global markets - and intellectual property associated with   said Product(s) is adequately protected.

(g) On a regular basis,   report findings of assurance programs to Nortel’s executive leadership team.

4.2 The Portfolio   Management Team for each portfolio shall:

(a) Ensure alignment to the   Core Strategic Vision.

(b) Determine if business   and/or Product needs justify the formation and continuing support of IPTs for   all Products in the portfolio.

(c) Establish and hold   IPTs accountable for Product development, introduction, Production, and/or   Retirement to meet market, customer, and/or business needs.

(d) Ensure an accountable   team leader is assigned to each IPT.

(e) Ensure an accountable   Product owner is assigned to any Product in the portfolio not supported by an   IPT.

(f) Ensure the maximum   effective use of available resources across the entire portfolio.

(g) Ensure consistent   application and measurement of documented Product Life Cycle Management   processes (idea through Retirement) and implementation of root cause   analysis, best practices, and continuous process improvements as a result   thereof.

(h) Ensure that when a   Product introduction cycle is completed, ongoing Product management   responsibilities are clearly defined and remain with the same team or   transition to another IPT or transition to the Product owner.

(i) Review the applicable   criteria for each business decision in a Product’s life cycle, ensure the   minimum Business Decision Point requirements are documented - inclusive of   Product quality and performance, give approval to proceed, do not proceed,   redirect as appropriate based upon assessment of Risks in achieving business   objectives, and ensure the approval of all accountable functional primes is   captured and documented.

(j) Review all Out-of-Bounds   conditions, the associated Risk analysis, recommended actions plan, and   proceed/do not proceed/redirect as appropriate. General Manager approval required.

(k) Manufacture discontinue   and/or end all projects/Products that do not meet business objectives, are no   longer profitable, have been replaced by a better alternative, and/or have   reached the end of their intended life. All projects/Product data and information shall be securely stored and   labeled in accordance with documented Product Life Cycle Management   processes.

4.3 The IPT leader or   Product owner for each Product shall:

(a) Team Leader - Ensure   that an IPT is formed and remains appropriately staffed - including, but not   limited to design, delivery, and service representation - to meet all Product   Life Cycle Management objectives. Escalate resource issues to the Portfolio Management Team.

(b) Product Owner -   Identify business and/or Product needs to the Portfolio Management Team that   justify formation of an IPT.

(c) Ensure that the   documented Product Life Cycle Management process is followed, including root   cause analysis and the use of documented best practices. Identify areas for continuous process   improvements to the Portfolio Management Team.

(d) Coordinate, document,   and present business decision recommendations to the Portfolio Management   Team for each phase in a Product’s life cycle – ensure alignment and   successful completion of the applicable design and test phases (reference   Corporate Procedure 505.32 – Product/Solution Design and Test).

(e) Ensure Risk Management   practices are continuously and effectively utilized throughout a Product’s   life cycle.

(f) Ensure all known   Product applications are identified and the accountable IPT leaders and/or   Product owners are informed of decisions that may impact another Product or   Solution.

(g) Identify Out-of-Bounds   project/Product conditions. Research   and deliver Risk analysis and recommendations to the Portfolio Management   Team for approval to proceed/do not proceed/redirect.

(h) Ensure Portfolio   Management Team decisions, as captured and documented for each Business   Decision Point, are effectively implemented.

(i) Ensure all project/Product data is securely   stored and labeled in accordance with documented data management processes.

5.0 Process

5.1 To achieve a basic   level of process consistency, the following phases and key activities shall   be included in the supporting Product Life Cycle Management process   documentation.

Phases

Primary Phase Objective

Key Phase Activities

Phase 1 - Idea

Approve project concept

(a) Identify     and scope the market opportunity.

(b) Develop     preliminary Product concept, Solution, and/or alternatives.

(c) Develop     a rough business case and strategic rationale.

(d) Initial Intellectual Property Review.

(e) Business Decision Point to assess     strategic readiness.

Phase 2 - Opportunity

Approve Product concept     and initial project schedule

(a) Evaluate     the global market opportunity and ability to service proposed geographies.

(b) Confirm     strategic fit and assess business capabilities.

(c) Capture     customer and functional requirements (reference Customer Requirements     Analysis Phase of Corporate Procedure 505.32 – Product/Solution Design and     Test).

(d) Define     system architecture – include administrative and maintenance requirements     (reference Design Phase 0 of Corporate Procedure 505.32 – Product/Solution     Design and Test).

(e) Identify     commercial (sellable Products, models, services, and associated pricing)     and operational (order, configure, procure, manufacture, integrate, and     test; move, install, train, repair, and technical support) requirements.

(f) Identify     legal, contractual, environmental, and regulatory requirements - give     special consideration to security and export controls.

(g) State     the Product concept and project boundaries - include interoperability     requirements with other Nortel and 3rd party Products.

(h) Identify     strategy for Product quality, performance, and associated release over     release improvements – include in business case.

(i) Identify     strategy for Product/ Solution delivery – see Corporate Procedure 505.33 –     Product/ Solution Delivery. 

(j) Identify     any Products being replaced.

(k) Define     the business case and plan definition phase needs – include estimated project     and R&D costs, resources, capital, Product cost, margins, return on     investment targets, and revenue potential.

(l) Review     and consider lessons learned from previous projects/Products.

(m) Conduct     Intellectual Property Review.

(n) Ensure     all conditions are met for customer requirements analysis and completion of     Design Phase 0 as outlined in Corporate Procedure 505.32 – Product/Solution     Design and Test.

(o) Business     Decision Point to assess market readiness.

Phase 3 - Definition

Approve final Product definition     and project plan

(a) Clearly     define the Product based on global customer needs.

(b) Clearly     define all markets, the rollout strategy, and associated legal,     contractual, environmental, and regulatory requirements - give special     consideration to security and export controls.

(c) Capture     commercial requirements (sellable Products, models, services, and     associated pricing).

(d) Select     Product technology, complete high level design (including strategy for     administration, maintenance, environmental compliance, and release over     release improvements), and commit to design reliability and delivery     (reference Design Phase 1 of Corporate Procedure 505.32 – Product/Solution     Design and Test).

(e) Clearly     identify interoperability requirements with other Nortel and applicable 3rd     party Products.

(f) Capture     operational requirements (order, configure, procure, manufacture,     integrate, and test; move, install, train, repair, and technical support).

(g) Identify     intervals for Production and Retirement - ensure contract alignment.

(h) Identify     strategy for Product recovery and recycle.

(i) Identify     the phase out strategy for Products being replaced.

(j) Establish     plan for Product life cycle quality and performance – include consideration     of release over release improvements and update business case as required.

(k) Ensure     all customer and functional requirements have been accepted and included in     the commitment to design delivery – identify exceptions.

(l) Fully     plan the remainder of the project for NPI - include customer commitments; Product release management requirements     (reference Corporate Procedure 505.34 – Product Release Management);     commercial/ operational requirements for Product sales, supply, and     support; and the associated Product design, test, and delivery schedule     (reference Corporate Procedure 505.32 – Product/Solution Design and Test) –     identify critical project Risks and Risk Management plan.

(m) Refine     and validate the business case – include updates – as required – to all     project and R&D costs, resources, capital, Product cost, margins,     return on investment targets, and revenue potential.

(n) Review     and consider lessons learned from previous projects/Products.

(o) Conduct     Intellectual Property Review.

(p) Ensure     all conditions are met for completion of Design Phase 1 as outlined in     Corporate Procedure 505.32 – Product/Solution Design and Test.

(q) Business     Decision Point to assess business readiness.

Phase 4 -Implementation

Complete Product/process     validation and approve formal release of Product

(a) Complete hardware and software design and test (reference     Design Phase 2 of Corporate Procedure 505.32 – Product/Solution Design and     Test).

(b) Complete hardware and software design integration testing     (reference Design Phase 3 of Corporate Procedure 505.32 – Product/Solution     Design and Test).

(c) Complete Product verification and system validation testing,     including large system overload limits and interoperability (reference     System Test Phases 1 and 2 of Corporate Procedure 505.32 – Product/Solution     Design and Test).

(d) Finalize documentation, ensure alignment to the commercial     requirements (sellable Products, models, services, and associated pricing),     and formally release the hardware and software design (reference System     Test Phase 2 of Corporate Procedure 505.32 – Product/Solution Design and     Test).

(e) Develop and/or update the Operational Support Processes –     validate through initial implementation and execution thereof.

(f) Ensure legal, contractual, environmental, regulatory, and     export requirements have been satisfied for deployment phase markets and     applications.

(g) Ensure customer and functional requirements have been satisfied     for deployment phase markets and applications.

(h) Prepare plans for Product introduction, deployment, validation,     and support in each intended market - consider unique requirements and     relationships needed to satisfy key customers.

(i) Identify and begin execution of the DCA process for any     applicable customer order (reference Corporate Procedure 506.01 – Delivery     Customer Assurance (“DCA”) Process).

(j) Update the business case – include updates – as required – to     all project and R&D costs, resources, capital, Product cost, margins,     return on investment targets, and revenue potential.

(k) Conduct Intellectual Property Review.

(l) Ensure all conditions are met for completion of Design Phases     2 and 3 and System Test Phases 1 and 2 as outlined in Corporate Procedure     505.32 – Product/Solution Design and Test.

(m) Ensure Product vintage and release controls are established.

(n) Capture and document the parameters for managing the initial     Product release – identify critical deployment Risks and Risk Management     plan - gain approval and communicate to operational support primes     (reference Corporate Procedure 505.34 – Product Release Management).

(o) Business     Decision Point to assess customer readiness.

Phase 5 - Deployment

Approve volume Production     and deployment

(a) Validate the formally released Product in a live customer     environment - ensure that each new feature is validated (test coverage) and     the in-service (soak time) target is met (reference System Test Phase 3 of     Corporate Procedure 505.32 – Product/Solution Design and Test).

(b) Ensure the Operational Support Processes can fulfill the     commercial requirements (sellable Products, models, services, and     associated pricing).

(c) Update - as needed - and implement the Operational Support     Processes for volume Production - ensure consideration for the planned     Production phase interval and associated supply/customer contracts.

(d) Ensure compliance to all applicable export control regulations.

(e) Ramp up Production to support unique requirements by market.

(f) Identify and execute the DCA process for any applicable     customer order (reference Corporate Procedure 506.01 – Delivery Customer     Assurance (“DCA”) Process).

(g) Maintain Product vintage and release controls – update as     needed.

(h) Ensure changes to previously documented     Product release management requirements are captured, approved, and     communicated as needed – consider new Product     applications, markets, customers, applicable Risks and management thereof     (reference Corporate Procedure 505.34 – Product Release Management).

(i) Finalize training and certification programs - ensure     alignment to and validation of engineering rules and associated     documentation.

(j) Ensure legal, contractual, environmental, regulatory, and     export requirements have been satisfied for general Product availability. 

(k) Ensure customer and functional requirements have been satisfied     for general Product availability.

(l) Ensure final Product design and quality meet requirements for     general availability – validate quality plan and release over release     improvements - update plan as needed.

(m) Identify and assess Risks that may impact Product performance,     customer perception, and/or overall business objectives – establish Risk     Management plan and include for consideration in the parameters defined and     approved for Product release management (reference Corporate Procedure     505.34 – Product Release Management).

(n) Ensure plans are in place for Product recovery and recycle.

(o) Ensure the phase out plan is in place for Products being     replaced.

(p) Validate business case – include project cost summary and any     updates to targets for Product cost, support cost, margins, return on     investment, and life cycle revenue.

(q) Capture lessons learned and process upgrades.

(r) Conduct final Intellectual Property Review.

(s) Ensure all conditions are met for completion of System Test     Phase 3 as outlined in Corporate Procedure 505.32 – Product/Solution Design     and Test.

(t) Capture and document Product release management requirements     for the Production phase – identify any restrictions specific to Product     application, market, and/or customer – gain approval and communicate to     operational support primes (reference Corporate Procedure 505.34 – Product     Release Management).

(u) Business Decision Point to assess channel     readiness.

Phase 6 - Production

Achieve return on     investment and approve plan to stop Production

(a) Transition on-going business management to an accountable team     or owner.

(b) Begin and effectively manage volume Production to meet market     demand.

(c) Identify and execute the DCA process for any applicable     customer order (reference Corporate Procedure 506.01 – Delivery Customer     Assurance (“DCA”) Process).

(d) Monitor market performance against the business case (examples     include Product reliability, cost performance, market penetration/share,     revenue, return on investment, and customer satisfaction).

(e) Identify any Product offering inconsistent with commercial and/     or design intent (i.e. Out-of- Bounds) take appropriate action to     address/resolve issues and any associated Risks.

(f) Changes to the previously defined parameters for Product     release must be documented, approved, and communicated (reference Corporate     Procedure 505.34 – Product Release Management).

(g) Maintain Product vintage and release controls – update as     needed.

(h) Execute plans for Product recovery and recycle as needed.

(i) Monitor quality plan - improve Product design, quality,     performance, and/or cost as business/customer needs dictate.

(j) Capture and analyze requirements to stop Production -     including legal, contractual, environmental, and regulatory considerations     - ensure consideration for the planned Retirement phase interval.

(k) Establish plan to transition customer to the next generation     alternative(s).

(l) Define business requirements for Retirement phase support –     include costs and potential for new and/or continued service revenue.

(m) Business     Decision Point to assess end of life readiness.

Phase 7 -Retirement

Execute plan to stop     Production. Monitor/support     installed base and approve plan to exit the market

(a) Execute manufacture discontinue plans and ensure all activities     have been completed to inform customers and stop Production.

(b) Monitor installed base, Product quality, and service     performance against the original manufacture discontinue plan.

(c) Execute plans for Product recovery and recycle as needed.

(d) Changes to the previously approved parameters for Product     release and support (i.e. market and/or application) must be documented,     approved, and communicated (reference Corporate Procedure 505.34 – Product     Release Management).

(e) Capture and analyze requirements to stop Product service and     support – include business considerations and impact.

(f) Business Decision Point to end the     Product life and all future service and support.

(g) Communicate with customers and execute market exit plans.

(h) Archive Intellectual Property.

(i) Support     customers/channels through transition/migration – continue Product     recovery/recycle as required.

5.2 In   association with the key phase activities and associated critical path for   completion of each phase, Business Decision Point dates shall be established,   captured, and tracked as a plan of record for Product Life Cycle   Management. Performance to these dates   – specifically the Customer and Channel Readiness Business Decision Points -   shall be consistently reported as a key measure of process effectiveness and   continuous improvement. BDP data   capture, updates, and overall plan of record performance shall be the   responsibility of the IPT Leader and/or Product Owner. 

5.3 Utilization   of this Procedure in conjunction with aforementioned documented process   requirements and the referenced documents listed below will be considered the   “Nortel Product Life Cycle Model” as required by customer requirements, ISO   9001 and TL 9000.

6.0 Approvals

In   addition to the Senior Executives listed on the title page of this Procedure,   Senior Executives of the following operating entities have also approved and   agreed to adopt this Procedure for implementation across the Product   portfolios for which they are accountable:

President   – Carrier Networks

President   – Enterprise Networks

7.0 Reference Documents

Corporate   Policy 100.05 – Direct Government Financial Assistance

Corporate   Policy 100.07 – Federal Government Relations

Corporate   Policy 100.22 – Disclosure of Material Information

Corporate   Policy 200.05 – Corporate and Systems Security

Corporate Policy 200.17 – Collection and Retention of Competitive   Information

Corporate   Policy 200.18 – Intellectual Property Protection

Corporate   Policy 300.01 – Risk Management

Corporate Policy 400.02 – Handling Unsolicited Disclosure of Ideas   from Third Parties

Corporate   Policy 400.03 – Protection of Proprietary Software

Corporate   Policy 400.04 – Export Control and Trade Compliance

Corporate   Policy 400.06 – External Publication of Technology Information

Corporate   Policy 500.04 - Quality and Customer   Satisfaction

Corporate   Policy 500.16 – Corporate Standards

Corporate   Policy 500.17 – Protection and Enhancement of the Environment

Corporate   Policy 500.22 – Acquisition of Goods and Services

Corporate Policy 500.25 – Sales and Delivery Life Cycle Margin   Preservation and Customer Delivery Assurance

Corporate   Policy 700.01 – Research and Development Investment

Corporate   Policy 700.02 – Product Design and Life Cycle Management

Corporate Procedure 205.04 – Protection of Confidential Information

Corporate Procedure 252.05 – Review and Approval of the Collection and   Retention of Competitive Information

Corporate Procedure 401.02 – Review and Approval Process for External   Publication or Presentation of Technology Information

Corporate Procedure 401.03 – Handling Unsolicited Disclosure of Ideas   from Third Parties

Corporate Procedure 402.01 – Export Control and Trade Compliance   Procedure

Corporate Procedure 501.02 – Intellectual Property

Corporate Procedure 505.01 – Nortel Networks Quality Management System   (“NNQMS”)

Corporate Procedure 505.32 – Product/Solution Design and Test

Corporate Procedure 505.33 – Product/Solution Delivery

Corporate Procedure 505.34 – Product Release Management

Corporate Procedure 506.01 – Delivery Customer Assurance (“DCA”)   Process

Corporate Procedure 601.01 – Research and Development Program

Corporate Procedure 712.03 – Competitive Purchasing

Corporate Procedure 712.05 – Purchase Requisitions

Corporate Procedure 712.12 – Single and Sole Source Suppliers

Corporate Procedure 712.17 – Environmental Procurement

Corporate Standard 1505.00 – Contract Manufacturers Products   Introduction Process

Corporate Standard 1509.00 – Dependability Program

Corporate Standard 1509.01 – Dependability Program Supplemental   Documentation

Nortel Corporate Policies and Procedures are available on the Nortel intranet: Services @ Work - Corporate   Policies & Procedures

Nortel Corporate Standards are available on the Nortel intranet: 

Global Web   - Global Quality-Corporate Standards

Life Cycle Management information and templates are available on the   Nortel intranet:

http://lcm.ca.nortel.com

Intellectual   Property Law information is available on the Nortel intranet:

http://navigate.us.nortel.com/imds?pg=/law/ip

8.0 Review

This   Procedure shall be reviewed every three years, or earlier, as required.

9.0 Revision History

June 3, 2003

September 13, 2002

End of   Document

Issued by:

Sue Spradley

Approved by:

Brian McFadden

President, Global Operations

Chief Technology Officer