Superannuation (Julia Farr Services Employees) Regulations 2003

The regulations introduce several key concepts that modify the Superannuation Act 1988.

“Contributor” is redefined in section 4(1) of the Act (as substituted by regulation 9(2)) to mean a person whose name appears in Schedule 1 of these regulations. That is a closed list of four natural persons. “Age of retirement” is fixed at 65 years (regulation 9(1)), overriding any different retirement age that might otherwise apply under the Act. “Plan” is defined as the Julia Farr Centre Staff Provident Plan - the predecessor arrangement of which these contributors were previously members.

The most important concept is “prescribed employment”, inserted into section 4(1) by regulation 9(3). It means employment, or notional employment, with Julia Farr Services, as determined by regulation 7. This is a fictional construct: a contributor who moves to another public sector job is treated as still employed by Julia Farr Services for superannuation purposes, provided there is no break of one month or more. “Public sector employee” is given the same meaning as in the Public Sector Act 2009 (regulation 7(3)). The concept of notional employment ensures that the benefit calculation (which uses salary at retirement) can take into account salary progression in the public sector, even though the contributor is no longer physically working at Julia Farr Services.

The benefit formulas rest on three variables. “FS” is the contributor’s actual or attributed salary immediately before retirement, termination, or death, expressed as an annual amount. The definition of “salary” in the modified Act is not reproduced in the regulations but is imported from the principal Act, subject to any modifications. “Pn” is a proportionality factor: 1 for a contributor who worked full-time for the whole period of employment with Julia Farr Services; otherwise, it is a fraction representing completed months of membership (in the Plan or as a contributor in prescribed employment) expressed as a proportion of full-time employment. This accounts for part-time or partial service.

“BM” is the sum of the RBM and ABM from Schedule 1. These multiples are fixed numbers, not indexed and not changed by further service. The RBM ranges from 4.95 to 7.30; ABM exists only for one contributor (0.66). The total BM (e.g., 7.30 + 0 = 7.30; or 6.53 + 0.66 = 7.19) effectively acts as a multiplier of final salary and the Pn factor. For a full-time contributor with a BM of 7.30, the lump sum at retirement at or after 65 is 7.30 times final annual salary.

The concept of “membership” for the early retirement formula uses “M” (actual completed months of membership in the Plan or as a contributor in prescribed employment) and “PM” (the months the contributor would have completed by age 65). The ratio M/PM reduces the lump sum for early leavers in a linear fashion. For example, a contributor who retires at 55 with twenty years of membership and would have completed thirty years by 65 receives a lump sum of (20/30) times the full benefit.

The disability pension concept is unique: it is a periodic payment (not a lump sum) at 75% of notional salary, but it has a three-month qualifying period and a two-year cap. The pension is not payable for periods where the contributor is entitled to sick leave, workers compensation, recreation leave or long service leave. “Notional salary” appears not to be defined in the regulations; it would likely be the salary the contributor would receive if working, but the source is silent on the precise derivation. The interaction between the disability pension and the invalidity lump sum is not addressed in the regulations. A contributor could potentially receive disability pension for up to two years and then, if terminated on invalidity, receive a lump sum under section 31. Whether the two payments are additive or whether the pension is deducted from the lump sum is not stated.

Finally, the concept of “preservation” under section 28 is automatic on resignation before 55. The contributor cannot elect otherwise. The preserved benefit is calculated using the early retirement formula (section 27(2)) and is held until the contributor reaches 55, unless earlier access is permitted on grounds of permanent incapacity (60% or more) or death. The Board is required to pay the benefit at 65 if no earlier election is made.

The regulations directly affect only the four named individuals in Schedule 1. No other employees of Julia Farr Services or any other entity can be added to the scheme. That makes this a personal, quasi-contractual superannuation arrangement embedded in the SA public sector superannuation legislation. The contributors are the only persons with rights to benefits under the modified Act. Their employers - initially Julia Farr Services, and subsequently any South Australian public sector agency that employs them - are indirectly affected through the continuity rule in regulation 7.

The South Australian Superannuation Board (the Board) is the administering body. It bears the obligation to calculate and pay benefits, to determine incapacity levels, to preserve benefits, and to manage the disability pension. The Board must develop administrative procedures to track the employment status of each contributor, particularly any breaks in public sector employment that could sever the notional continuation of prescribed employment.

The Superannuation Fund is the source of benefit payments (regulation 6). The Fund’s resources are used to pay these defined benefits, which are not funded by current contributions from the contributors or their employers (since the contributors make no contributions). The cost is borne by the Fund’s other members and the State, effectively creating a cross-subsidy. Given the small number of contributors, the financial impact is negligible, but the principle is worth noting.

The South Australian Treasury is also affected, because the Act ordinarily provides that certain benefits are paid by the Treasurer; these regulations override that default. The Board, not the Treasurer, controls the payments from the Fund.

Julia Farr Services itself, or any successor entity, has an interest in ensuring it provides accurate information about periods of employment and any cessations, because that information determines when “prescribed employment” starts and stops. The Public Sector Act 2009 definition of public sector employee is imported, meaning that any entity that employs public sector employees (including most South Australian government agencies) is potentially involved if a contributor moves between roles.

The regulations do not affect the broader membership of the Superannuation Act 1988. They carve out a specific subclass of “new scheme contributors” with entirely different rules. No other employee at Julia Farr Services (if any remain) or any future employee can become a contributor under these regulations. The scheme is extinctive: it winds down as each contributor retires, dies, or ceases prescribed employment.

Family members of contributors are affected as dependants: spouses may receive death benefits, and the estate may also receive benefits if there is no surviving spouse. The disability pension does not appear to have a dependant component; it ceases on death or the two-year cap.

From a compliance and administrative perspective, the effect is minimal outside the Board and a few payroll officers. But for the four individuals, the regulations define their entire superannuation entitlement - a defined benefit that is significantly more generous than a typical accumulation account, because it is non-contributory and based on final salary multiplied by a fixed multiple.

The regulations impose few duties on contributors because the scheme is non-contributory. A contributor has no obligation to make contributions to the Treasurer (section 23). They have no obligation to elect preservation or to make investment choices. The scheme operates almost as a deferred annuity: the contributor works, and the benefit accrues by formula.

However, contributors have several rights. The right to a retirement lump sum arises at age 65 (or earlier retirement, with a reduced amount). The right to a disability pension arises if the contributor becomes incapacitated for work in prescribed employment, subject to the three-month waiting period and the exclusions for sick leave, workers compensation and leave entitlements. The right to apply for payment of preserved benefits is triggered at age 55, or earlier on proof of permanent incapacity (60% or more). The right to a death benefit flows to the spouse or estate.

Contributors also have the right to the continuity rule in regulation 7: ceasing employment with Julia Farr Services does not automatically break the benefit-accrual period, provided they move to another public sector job with no gap exceeding one month. This right is valuable because it preserves the link to “prescribed employment” and ensures that final salary can be updated.

The Board has the primary duty to administer the scheme and pay benefits correctly. It must determine whether a contributor has reached the age of retirement (65), whether incapacity meets the 60% threshold for invalidity termination or early access to preserved benefits, and whether the 60% threshold warrants payment of preserved benefits for incapacity under section 28(3). The Board must also determine when a contributor’s incapacity is temporary or permanent for the disability pension, and must ensure that the two-year aggregate cap is observed. The Board’s decisions on incapacity (especially the 60% threshold) involve medical evidence and may be subject to administrative review.

The employer Julia Farr Services (or any entity that employs a contributor in a public sector role) has a practical duty to notify the Board of any changes in employment status, including the start and end of employment, any breaks, and salary changes. This is not explicitly stated in the regulations but is necessary for the Board to administer the formulas.

Importantly, the regulations do not give the Board any discretion to alter the benefit formulas or the Schedule multiples. The benefits are mechanically determined. The Board must calculate A = FS × Pn × BM exactly as written. It cannot reduce or increase the multiple.

There is no duty on contributors to make elections, except that a contributor who resigns before 55 is “taken to have elected to preserve” (section 28(1)(b)). This is a deemed election, not a choice. The contributor cannot opt for an immediate cash-out. Similarly, when the contributor reaches 55, they may require payment, but if they do not, the Board pays at 65.

The regulations are silent on any right to transfer benefits to another superannuation fund. There is no portability provision. The only transfer mechanism is the notional continuation under regulation 7, which keeps the contributor within the SA Fund.

Finally, the regulations do not provide a right to a pension (other than the temporary disability pension). The retirement benefit is a lump sum. The invalidity termination benefit is a lump sum. The death benefit is a lump sum. That distinguishes this scheme from those that offer lifetime pensions.

The regulations themselves contain no penalty provisions. There are no fines, infringement notices, or criminal offences created by the Superannuation (Julia Farr Services Employees) Regulations 2003. The absence of penalties is not unusual for a regulation that primarily modifies benefit entitlements; enforcement mechanisms would be found in the principal Act or in general law.

Under the Superannuation Act 1988 (as modified), the Board’s decisions on benefit eligibility, incapacity assessments, and the calculation of payments are likely subject to internal review and possibly to external review by the South Australian Ombudsman or the South Australian Civil and Administrative Tribunal (SACAT), depending on the applicable administrative law framework. However, the regulations do not specify review rights. A contributor who disputes a Board decision would rely on the general administrative law avenues available for public sector superannuation decisions in South Australia.

Civil enforcement is the primary mechanism for ensuring compliance. If the Board fails to pay a benefit when due, or pays an incorrect amount, the contributor (or their estate) could bring an action for debt or for breach of statutory duty. The courts would interpret the regulations and the modified Act to determine the correct benefit. Given that the benefit formulas are mechanical, disputes are likely to turn on factual issues such as salary, part-time proportion, date of retirement, or the level of incapacity.

The regulations impose no obligations on contributors that could be subject to penalty. Contributors do not contribute, do not elect, and do not file reports. Non-compliance by a contributor is not defined. The only potential breach by a contributor would be making a false claim (e.g., for disability pension when not incapacitated), but that would fall under general fraud or criminal law, not the regulations.

The Board has an obligation to ensure that disability pension payments are not made during periods when the contributor is entitled to sick leave, workers compensation, or other leave. If the Board pays incorrectly, it might attempt to recover overpayments, but the regulations do not provide a specific clawback mechanism. The Board would likely rely on common law restitution or statutory debt recovery provisions in the principal Act.

The only quasi-penalty provision in the regulations is the loss of the continuity rule if there is a break in public sector employment of one month or more (regulation 7(2)). That is not a penalty for wrongdoing; it is a factual trigger that ends the notional employment. But its effect can be severe: it crystallises the benefit as at the date of the break, preventing any further salary growth from affecting the lump sum. That functions as a de facto forfeiture of future accrual, but it is not a penalty in the legal sense.

Given the small number of contributors, enforcement is unlikely to be a major issue. The more significant risk is administrative error in applying the formulas or determining the Pn factor. The absence of a defined mechanism for administrative review in the regulations means that disputes would have to be resolved through standard judicial processes, which could be costly for the individual contributor relative to the size of their benefit.

These regulations operate as subordinate legislation under the Superannuation Act 1988 (SA). They expressly modify that Act in its application to the named contributors. The effect is that, for these individuals, many sections of the principal Act are replaced. The regulations do not repeal or amend the principal Act generally; they create a special regime by force of clause 1(1)(b) of Schedule 1A of the Act, which allows modifications for new scheme contributors.

The most significant interaction is with the Superannuation Act 1988 itself. The regulations delete and substitute sections 23, 24, 25, 27, 28, 28A, 28B, 28C, 29, 30, 31, 32, and repeal section 32A. That means the standard rules on contributions, retirement benefits, resignation, disability pensions, invalidity, and death benefits do not apply to these contributors. The regulations also amend the definitions of “age of retirement” and “contributor” and insert new definitions (Plan, prescribed employment, Schedule). These modifications are exhaustive: the contributors are governed solely by the substituted sections.

The regulations also intersect with the Public Sector Act 2009. Regulation 7(3) defines “public sector employee” by reference to that Act. Any change in that Act’s definition would automatically affect who counts as a public sector employee for the continuity rule. The 2010 amendment (Gazette 28 January 2010) varied regulation 7(3) to replace a reference to the Public Sector Management Act 1995 with the Public Sector Act 2009, illustrating this dependency.

The interaction with Commonwealth superannuation law is not addressed in the regulations. The Superannuation Industry (Supervision) Act 1993 (Cth) and the Superannuation Guarantee (Administration) Act 1992 (Cth) may apply to the Fund generally. However, because these contributors are part of a state public sector superannuation scheme that is a “regulated superannuation fund” under SIS, the payment of lump sums and preservation rules must comply with SIS regulations. The regulations (section 28) impose a preservation age of 55, which aligns with the general SIS preservation age for that period. However, the automatic preservation on resignation under 55 may or may not satisfy SIS requirements; the regulations are silent. Practitioners should verify that the Board’s preservation arrangements for these contributors comply with Commonwealth law.

The disability pension (section 30) interacts with workers compensation law. The pension is not payable for a period where the contributor is entitled to weekly payments of workers compensation. That is an anti-overlap provision. It does not require the contributor to claim workers compensation first; it simply suspends the pension while the entitlement exists. Similarly, the pension does not pay for periods of sick leave, recreation leave or long service leave. That means a contributor who is incapacitated but has accrued sick leave must exhaust that leave before the disability pension can commence (subject to the three-month qualifying period). The effective waiting period could be longer than three months if the contributor has substantial sick leave.

The regulations also override section 20B of the Act (regulation 6), which would otherwise direct that certain benefits be paid by the Treasurer. Instead, all benefits under the modified Act must be paid out of the Fund. That shifts the financial liability from the State’s consolidated revenue to the Superannuation Fund, which is likely already funded by employer and employee contributions from other members.

Finally, no interaction with taxation legislation is mentioned. The lump sum payments and disability pension may have tax consequences under the Income Tax Assessment Act 1997 (Cth) and the Superannuation Industry (Supervision) Regulations 1994 (Cth). The regulations do not set out the tax treatment; the Board would need to apply the usual tax rules for superannuation benefits.

The regulations were originally made on 25 September 2003 (Gazette p3644) and commenced on 1 October 2003. Since then, they have been amended four times, as recorded in the legislative history.

The 2005 variation (Gazette 13 January 2005, No 2) is the first amendment. It deleted regulation 2 (commencement) under the Legislation Revision and Publication Act 2002, which is a standard housekeeping amendment. More substantively, it varied regulations 11 and 13. Regulation 11 is the substitution of sections 27, 28, 28A-28C and 29; regulation 13 is the substitution of sections 31 and 32. The variation likely refined the benefit formulas or clarified the preservation provisions. The exact changes are not specified in the source, but they were effective 13 January 2005.

The 2007 amendment (Gazette 28 June 2007, No 177) was more extensive. It deleted regulation 4 (which had not been provided in the original text, but likely dealt with some transitional matter). It substituted and varied regulation 7 (the continuity rule) in several respects: regulation 7(1) was substituted (the rule that a contributor who continues public sector employment is taken to continue employment with Julia Farr Services), regulation 7(2) was varied, and regulation 7(3) was substituted (the definition of public sector employee). It also deleted regulation 7(4). This suggests the continuity rule was restructured to better align with changes in the public sector employment framework. Regulation 9(3) (the definition of prescribed employment) was also varied, likely as a consequential change. Regulations 11 and 13 were varied again, probably to adjust the formulas or cross-references. Most importantly, Schedule 1 was substituted in its entirety, with new benefit multiples. The 2007 version is the current Schedule. The substitution removed any previous contributors and established the four names now listed.

The 2010 variation (Gazette 28 January 2010, No 11) was confined to regulation 7(3). It varied that provision to replace the reference to the Public Sector Management Act 1995 with the Public Sector Act 2009. This was a straightforward updating amendment following the enactment of the new Public Sector Act. It commenced on 1 February 2010.

No further amendments appear on the legislative history table. The regulations have been stable since 2010.

The historical versions listed are 13 January 2005 and 28 June 2007, meaning that the original 2003 version is not separately preserved as a snapshot, but the 2005 and 2007 versions can be consulted. For practitioners, the current version is the one with all amendments consolidated.

The regulations have never been repealed or replaced. They remain in force for the four named contributors. As each contributor dies or retires, the regulations will eventually become spent, but they will remain on the statute book until formally repealed. No sunset or review clause appears in the text.

The source document includes no references to any court or tribunal cases involving these regulations. The legislative history table contains no entries for litigation; it only records legislative amendments.

Given the limited scope of the regulations - four individuals, a small defined benefit scheme, and mechanical formulas - there has likely been no reported litigation. The types of disputes that could arise (contested salary figures, disagreement over the Pn factor, challenges to the Board’s assessment of 60% incapacity, or disputes about the continuity of prescribed employment) are fact-specific and would likely be resolved internally or through administrative tribunals rather than superior courts. Even if a dispute reached the Supreme Court of South Australia, it would probably not be reported unless it raised a question of general principle.

The regulations do not name any particular cases, nor do they amend or purport to overturn any judicial interpretation of the Superannuation Act 1988. The modifications are self-contained.

That said, the principal Superannuation Act 1988 has likely been litigated in South Australia on general issues such as contribution obligations, interpretation of benefit formulas, and the Board’s powers. But those cases would not be directly relevant to the regulations, because the regulations displace the standard provisions for these contributors. A court interpreting the substituted sections would be dealing with a bespoke text, not the standard Act.

The absence of litigation history is not surprising. The regulations create a closed, non-contributory, defined benefit scheme with clear formulas. The multiples are fixed; salary can usually be verified; the continuity rule is factual. The only subjective element is the Board’s assessment of incapacity for invalidity termination or early access to preserved benefits (60% or more permanent incapacity). Disagreements over that assessment could lead to administrative review, but the regulations do not provide a specific review mechanism, so any challenge would be under the general law. There is no record in the source of such challenges.

Practitioners advising the Board or the contributors should still be prepared for potential disputes, but there is no precedent to rely on. Any litigation would break new ground. The small financial stakes per contributor (given the modest multiples) may also discourage expensive litigation.

Several traps await the unwary.

First, the continuity rule in regulation 7 is easily broken. A contributor who leaves Julia Farr Services and cannot secure a public sector job within one month loses the notional continuation of employment with Julia Farr Services. Once the break exceeds one month, the period of prescribed employment is taken to have ceased. This may crystallise the benefit as at that earlier date, meaning future salary increases in the public sector will not count. The lump sum will be calculated using salary at the time of cessation, not at the eventual retirement date. A one-month gap in public sector employment could destroy tens of thousands of dollars in benefit value if the contributor works for many more years. There is no safety valve for redundancy or involuntary loss of employment.

Second, the disability pension contains multiple overlapping exclusions. It is not payable for periods where the contributor is entitled to sick leave or weekly workers compensation payments. But “entitled to” is a legal concept: if the contributor has not claimed workers compensation but could claim, the Board might argue the period is excluded. Similarly, if sick leave is exhausted, the pension can start, but only after three months of absence. The three-month period runs from the start of the incapacity, not the start of any benefit period. So a contributor who uses sick leave for the first month must still wait an additional two months after sick leave ends before the pension begins. The two-year aggregate cap is also a trap: if incapacity recurs, the total days paid cannot exceed two years. There is no provision for resetting the cap for a new, unrelated incapacity.

Third, the early retirement formula uses “M” (completed months of membership) and “PM” (months to age of retirement). The formula reduces the benefit proportionally. But “membership” includes membership of the Plan and of prescribed employment. If a contributor had a break in service before the regulations commenced, that may have been Plan membership only. The Pn factor also depends on completed months as a proportion of full-time employment. For a contributor who worked part-time at some times, calculating Pn requires converting all service to an equivalent full-time basis. The method for treating periods of part-time work or unpaid leave is not specified beyond the formula. Disputes over the correct Pn could significantly change the lump sum.

Fourth, the benefit formula for retirement at or over 65 uses the full BM. But the “age of retirement” is fixed at 65. That means a contributor who retires at 66 still uses the same formula - there is no enhancement for delayed retirement. There is also no actuarial increase. The contributor is not penalised for working longer, but nor does the benefit increase (except through salary growth). If salary has not increased, there is no advantage in delaying retirement.

Fifth, the death benefit goes to the spouse first, then the estate. But the definition of “spouse” is not provided in the regulations. The principal Act’s definition would apply, which may exclude de facto or same-sex partners depending on the version of the Act. Practitioners should verify the current definition.

Sixth, there is no provision for commutation of the lump sum or for directing part of it to a reversionary beneficiary. The death benefit is a lump sum to the spouse; if the spouse predeceases the contributor, the contributor cannot nominate a different beneficiary. The estate is the default.

Seventh, the regulations do not specify what happens if a contributor’s prescribed employment ends before they have reached age 55 (e.g., if they quit the public sector and take a private sector job). They would be deemed to have resigned, and section 28 would apply: preservation until 55. But the benefit would be calculated using salary at that earlier date, potentially locking in a lower amount. There is no ability to transfer the benefit to a new employer’s fund.

Eighth, the Schedule includes only RBM and ABM. There is no column for early retirement reductions or indexing. The multiples are fixed in dollar amounts? Actually they are numbers, not dollar amounts. The formula multiplies salary by the multiple. So a multiple of 7.30 produces a lump sum of 7.30 times salary. That is a high crediting rate compared to typical defined benefit schemes (which often use years of service times a percentage). The multiples appear generous, but they reflect the specific history of the Plan.

Finally, the regulations are not automatically updated for changes in the principal Act. The modification in Part 3 is static. If the Superannuation Act 1988 is amended in ways that affect provisions not covered by the modifications, the contributors may be inadvertently affected or benefit from unintended gaps.

Compliance obligations under these regulations fall primarily on the Board and secondarily on the employer.

For the Board, the first step is to identify the current contributors using Schedule 1. As of the last substitution in 2007, that means Byerley, Johnson, Klose and Rougasche. The Board must maintain accurate records of each contributor’s salary history, employment status, periods of part-time work, and any breaks in public sector employment. It should calculate and retain the Pn factor using the completed months of membership. The Pn factor should be recalculated each time there is a change in employment pattern.

When a contributor approaches retirement, the Board must verify the actual or attributed salary immediately before retirement. “Attributed salary” may require an imputation if the contributor is on leave or has variable pay. The Board should document the basis for FS. It must then apply the correct formula - either the full formula for retirement at or over 65, or the reduced formula for early retirement. For death, the same full formula applies.

For resignation before 55, the Board must calculate the benefit using the early retirement formula and then preserve it. The Board should notify the contributor of the amount and the preservation rules. It must track the contributor’s age and pay the benefit at 55 (if requested) or at 65 automatically. If the contributor claims premature access for incapacity, the Board must assess whether the incapacity for all kinds of work is 60% or more and likely permanent. That requires medical evidence and a standardised assessment process. The Board should develop written criteria for making that assessment.

For invalidity termination, the Board must again assess the 60% threshold. The lump sum formula is identical to the full retirement formula; there is no reduction for early age. That means invalidity termination is potentially more valuable than early retirement. The Board must ensure it does not pay both a disability pension and an invalidity lump sum for the same incapacity without an offset mechanism, though the regulations do not prohibit both. Prudent administration would establish a policy that the disability pension is paid only while the contributor remains employed and incapacitated, and that termination on invalidity then triggers the lump sum, with the pension ceasing.

The disability pension requires careful tracking. The Board must not pay for the first three months of absence. It must check if the contributor is entitled to sick leave, workers compensation, or other leave. If the contributor is on sick leave with pay, the three-month waiting period still runs, but the pension does not start until the entitlement to sick leave ends and the three months have elapsed. The Board should maintain a calendar for each contributor. The two-year aggregate cap must be monitored; the Board should record every day or part-day paid as disability pension. If the same incapacity recurs, the cap applies cumulatively.

Regulation 6 requires all benefits to be paid out of the Fund, not from appropriations. The Board must ensure its payment systems direct these benefits to the Fund’s account, not the Treasury’s.

For the employer (Julia Farr Services or any public sector agency), compliance is simpler but important. The employer must notify the Board promptly when a contributor starts or ends employment, and report any break of one month or more. If a contributor ceases Julia Farr Services employment but immediately starts a new public sector role, the employer (the new agency) should confirm the start date to avoid a gap exceeding one month. The employer should also provide salary data, including any variations in hours.

For the contributors, compliance is largely passive. They do not need to make contributions or elections. However, they should be aware of the importance of the one-month break rule. If they contemplate a gap in public sector employment, they should seek to keep it under 30 days. If they resign from the public sector entirely, they should obtain a statement of their preserved benefit from the Board.

The regulations do not require contributors to provide medical evidence unless they claim disability pension or invalidity termination. In those cases, the Board will request appropriate medical reports. Contributors should cooperate.

Finally, the Board should maintain a register of all communications with contributors, including notices of preserved benefits and decisions on incapacity. Given the lack of review provisions in the regulations, the Board should voluntarily adopt an internal review process to minimise the risk of litigation. Regular audits of the benefit calculations - especially for part-time Pn factors and the M/PM ratio - would prevent costly errors.