NZ203036A

NZ203036A - Aqueous automatic dishwasher composition with thixotropic properties

Info

Publication number: NZ203036A
Application number: NZ20303683A
Authority: NZ
Inventors: M Julemont; M Marchal
Original assignee: Colgate Palmolive Co
Priority date: 1982-01-18
Filing date: 1983-01-14
Publication date: 1986-04-11
Also published as: GB2116199A; GB8301299D0; SE453834B; AU1036883A; DK158155C; DK158155B; DK18383D0; SE8300162L; DE3300243C2; FR2520004A1; CH654849A5; FR2520004B1; SE8300162D0; AU552294B2; GB2116199B; DK18383A; DE3300243A1

Description

<div class="application article clearfix" id="description"> New Zealand Paient Spedficaiion for Paient Number £03036 203036 Priority Date(s): /?.. 1. .?/.> . J.Q. J. , Complete Spccificattc" Filacl: )*4.. /. 'J&. Class: LJ 185 J (&/,..£! {f>t/00 Publication Dare: ... il,. P.O. JojmaI, fix Patents Form No. 5 Number PATENTS ACT 1953 Dated COMPLETE SPECIFICATION GEL-TYPE AUTOMATIC DISHWASHER COMPOSITIONS HAVING THIXOTROPIC PROPERTIES //We COLGATE-PALMOLIVE COMPANY, a corporation organised under the laws of the State of Delaware, United States of America of 300 Park Avenue, New York, New York 10022, Unites States of America do hereby declare the invention for which //we pray that a Patent may be granted to (HOCus. and the method by which it is to be performed, to be particularly described in and by the following statement 1 (followed by page la) 203036 The invention relates to automatic dishwashing detergent compositions having thixotropic properties, improved chemical and physical stability, and which are readily dispersible in the washing medium to provide effective cleaning of dishware, glassware, china j|nd the like. [] Commercially available household-machine dishwasher detergent i provided in powder form has several disadvantages, e.g., nonuniform composition; costly operations necessary in their manufacture; tendency to cake at high humidities, resulting in the II jformation of lumps difficult to disperse, and dustiness, a source of i! particular irritation to users who suffer allergies. Liquid forms i! ®f such compositions, moreover, generally cannot be used in automatic dishwashers due to high foam levels, unacceptably low Viscosities and exceedingly high alkalinity. 1 i ■ I Recent research and development activity has focussed on the ■fel or "thixotropic" form of Buch compositions, e.g., scouring I , Cleansers and automatic-dishwasher products characterized as thixo- ; 1 ■j^ropic pastes. Dishwasher products so provided are primarily Objectionable in that they are insufficiently viscous to remain :|'anchored" in the dispenser cup of the dishwasher, and moreover jjrield spotty residues on dishware, glassware, china and the like. ildeally, thixotropic cleansing compositions should be highly viscous |! jf.n a quiescent state, Bingham plastic in nature, and have relatively fjiigh yield values. When subjected to shear stresses, however, such [is being shaken in a container or squeezed through an orifice, they ihould quickly fluidize and, upon cessation of the applied shear stress, quickly revert to the high vis cosity/Bingham plastic state, stability is likewise of primary importance, i.e., there should be :io significant evidence of phase separation or leaking after long 3t anding. V +S V ^ \J The provision of automat ic-dishwuoher compositions in i;l<J form having the aforedescribed properties has thus far proved problematical, particularly as regards compositions for use in home dishwaoher machines. For effective use, it is generally recommended that the automatic dishwashing detergent, hereinafter also designated ADD, contain (l) sodium tripolyphosphate (NaTPP) to soften or tie up hard-water minerals and to emulsify and/or i peptize soil; (2) sodium silicate to supply the alkalinity i necessary for effective detergency and to provide protection for : I fine china glaze and pattern; (3) sodium carbonate, generally i considered to be optional, to enhance alkalinity; (k) a chlorine-releasing agent to aid in the elimination of soil specks which lead' 'to water spotting; and (5) defoamer/surfactant to reduce foam, = thereby enhancing machine efficiency and supply requisite deter- ; gency. See, for example, SDA Detergents in Depth, "Formulations Aspects of Machine Dishwashing," Thomas Oberle (197M. Cleansers I approximating the aforedescribed composition are mostly liquids or powders. Combining such ingredients in a gel form effective for home-machine use has proved difficult. Generally, such compositions omit hypochlorite bleach, since it tends to react with other | chemically active ingredients, particularly surfactant, thereby degrading the suspending or thixotropic agent and impairing its effectiveness. Thus, U. S. Pat. No. U,115,308 discloses thixotropic automatic dishwasher pastes containing a suspending agent, e.g., CMC, synthetic clays or the like; inorganic salts including silicates, phosphates, polyphosphates, etc., a small amount of surfactant and a sud3 depressor. Bleach is not disclosed. U.S. Pat. No. 1+, 1^7 ,650 is similar and further includes a hypochlorite bleach. The product is described, however, as a detergent slurry. U.S. Pat. No. 3,985,668 describes abrasive scouring cleaners - 2 - ZUJUJb , of gel-like consistency containing (l) ouopending agent, jirel'cr-ably the smectite and attapulgite types of the colloid form in g clays; (2) abrasive, e.g., silica sand or perlite; and (3) filler comprising light density powdered polymers, expanded perlite and j the like, which has a buoyancy and thus stabili2ing effect on the j i composition in addition to serving as a bulking agent, thereby I i replacing water otherwise available for undesired supernatant ! layer formation due to leaking and phase destabilization . The j foregoing are the essential ingredients. Optionals include hypo- ! i chlorite bleach, bleach stable surfactant and buffer, e.g., silicates, carbonates, monophosphates, ertc. Builder such as NaTPP I can be included as a further optional to supply or supplement 'building function not provided by the buffer, the amount of such builder not exceeding 5% of the total composition, according to the patent. Maintenance of the desired >pH10 levels is enabled by the buffer/builder components. High pH is said to minimize decomposition of chlorine bleach and undesired interaction between surfactant and bleach. When present, NaTPP is limited to 5%, as I stated. Foam killer is not disclosed. In accordance with the invention, it has been discovered that improved detergent compositions particularly adapted for uue ! in automatic dishwashers, particularly those of the type found in the home, are provided having the properties desirably characterizing thixotropic, gel-type structure and including each of the various ingredients necessary for effective detergency within such automatic dishwasher. Thus, a primary object of the invention is to provide a detergent composition having thixotropic properties and benefici- , ally Gdapted for use in an automatic dishwasher. £03036 compouition liuvine good phyoical ulubility with no o ig nil" io an L s phaae separation being evident after prolonged periods of standing Another object of the invention is to provide such composition wherein problems associated with undesired interaction of chemically active ingredients are eliminated or at/least substanti ally mitigated. Yet another object of the invention i/s to provide such a composition having the aforementioned stability under the highly alkaline conditions necessary for effective detergent performance. Still another object of th*e invention is to provide such a composition having improved j/n eological ^properties exhibiting higher viscosities at low/shear rates and lower viscosities at high shear rates—thii? advantageously adapted for use in the dispenser cup of automatic dishwashing machines. Yet a further object of the invention is to provide such a composition^having low foam characteristics, improved deterger.cy and bei/ig readily dispersible in the washing machine. / Other objects and advantages of the invention will become ftp p ft r i? n t—herein—aft o-i*. This and other objects are attained in accordance with the invention which in its broader aspects provides a normally gellike aqueous automatic dishwasher-detergent composition having thixotropic properties comprising, by weight, from about: (a) 5 to ) 2>5% water-soluble alkali metal tripolyphosphate having an average degree of hydration of from about 1 to 5 ; (b) 2.5 to 20% " sodium silicate; (c) (3 to 9% water-soluble alkali metal carbonate; (d) .1 to 5% bleach stable, dispersible organic surfactant; (e) .1 to .5? mono-or di-( g-C^ ) alkylester* of phosphoric acid foam depressor; (f)3-20% NaOClslon-13% avail, ce; (ft) 1.5 to 1055 in-orRnnJc, c o I. l.oid-PorrninR clay thickcninr, riftont; and ( h ) :;u I' l'i o j en I. 203036 10 15 20 25 30 nuilJum -li/ci rpx I ill- to pruvido ;i )>ll J 0 . 5- 1 3 . 'j , UrtJil ooinpon i I I mi having a thixoLropy index ol' ubout 2.5 to 10. ADD compooitlono co formulated are low-foaming; otuble, both chemically and physically; are readily soluble in the washing medium and moot effective at pit valueo beat conducive to improved Cleaning performance, viz , pH 10.5-13.5- The compositions are normally of gel conolatency, i.e., a highly viscous, opaque Jelly-like material having Bingham plastic character and thus relatively high yield values. Accordingly a definite shear force is necessary to initiate or increase flow, such as would obtain within the agitated dispenser cup of an energized automatic dishwasher. Under such conditions, the composition is quickly fluidized and easily dispersed. When the shear force is discontinued, the fluid composition quickly reverts to a high viscosity, Bingham plastic i state, closely approximating its prior consistency. i Generally, ADD effectiveness is directly related to (a) available chlorine levels; (b) alkalinity; (c) solubility in washing medium; and (d) defoamer efficacy important herein that the I pH of the ADD composition be from about 10.5-13.5 and preferably at least about 11.5. The use of NaOH herein is thus essential, since without UaOH, the ADD pH is helow 10.5- At this pH, the ADD product is too viscous , i.e., solid-like, and thus not readily fluidized under the shear-force levels created within the dispenser cup under normal machine-operating conditions. In essence, i the composition loses much, if not all, of its thixotropic character. In that case, addition of NaOH is thus essential to increase i pH and flowabi.lity properties. The presence of carbonate is often n eeded herein, since it acts as a buffer enabling maintenance of the necessary pH level. Excess carbonate is to be avoided, however since it may cause the formation of needle-like crystals of carbonate, thereby impairing the stability and/or i - 5 - functlonalily of the ADD product, The caustic ooda oervco the further vital function of neutralizing the phosphoric acid enter foam deprensor. Other criteria governing ingredient selection herein and essential to providing a stable, effective ADD product having thixotropic properties are as follows: The NaTPP must toe free of heavy metal, since the latter tends to decompose the sodium hypochlorite. On average, the NaTPP contains about 5-155& by weight water, corresponding to an average degree of hydration of about 1 to 5. If only the hexahydrate is used, the detergent product is liquid and has little if any thixotropic character. If only the anhydrous NaTPP is used, the product"is too thick and therefore unsuitable. Effective compositions obtain, for example, using a 0.5:1 to 2:1 weight ratio of anhydrous to hexahydrated NaTPP, values of about 1:1 being particularly preferred. Foam depressor is essential to increase dishwasher-machine efficiency and to diminish destabilizing effects which might occur due to the presence of excess foam within the washer during use. Available chlorine levels are supplied herein by sodium hypochlorite rather than, for example, the dichloroisocyanurates used in current powder detergents. The ADD product exhibits improved rheological properties as evaluated by testing product viscosity as a function of shear rate. Investigation ^confirms the compositions to exhibit higher viscosity at a low shear rate and lower viscosity at a high shear rate the data indicating efficient fluidization and gellation well within the shear rates extant within the dishwasher machine. In practical terms, this means improved pouring and processing characteristics as well as less leaking in the machine dispenser-cup, compared to current liquid ADD products. For applied shear *UJ036i intcn torreepond fng to 3 to 30 rpm, viecqatties (BrQ<jk- j field) correspondingly range from about 15,000-30,000 "cps to about 3000-5000 ,cpa..,as measured at room temperature by means of an LVT Brookfield viscosimeter after 3 minutes using a ffk spindle. A shear rate of 7•^ sec~^ corresponds to a spindle rpm of about 3. An approximate ten-fold increase in shear rate produces a six- to seven-fold reduction in viscosity. With current ADD gels, the j corresponding reduction in viscosity is only about two-fold. Moreover, with such compositions, the initial viscosity taken at j about 3 rpm is only about 2500-2700 cps. The instant compositions j I thus exhibit threshold fluidizations at lower shear rates and of | I significantly greater extent in terms of"incremental increases in j shear rate vs. incremental decrease in viscosity. This property : of the instant ADD products is summarized in terms of a thixotropic index (Tl) which measures the ratio of (a) apparent viscosity at 3 rpm to (b) apparent viscosity at 30 rpm. The present composi- I tions have a TI of from about 2,5 to 10 and preferably 6 to 8. Each of the ADD compositions tested exhibited substantial and ' quick return to prior quiescent state consistency when the shear force is discontinued. In preparing the ADD product, one should dissolve or disperse first all the inorganic salts, i.e., carbonate, silicate and tri-polyphosphate, in the aqueous medium. Thickening agent is added last. The phosphoric acid ester foam depressor is preliminarily i provided as an aqueous dispersion, as is the thickening agent. The ester dispersion, caustic soda and inorganic salts are first mixed at elevated temperatures in aqueous solution (doiouizcri water) and thereafter cooled, using agitation throughout. Bleach, surfactant and thickener dispersion at room temperature are thereafter added to the cooled (25-35°C.) solution. The i" 7 *■> I amount of water used is such as to provide an A.I. concentration I in the ADD product of from about 35-75%, a range of about 50-65% being preferred. The inorganic salts herein comprise, by weight of total |l product, about: (a) 5 to 35% and preferably about 20 to 30% NaTPP J (b) 2.5 to 203! and preferably about 10 to 15% sodium silicate hav- !l ing an Na^OrSiC^ ratio of about 0.3 to 0.5%, and (c) 0 to 9%, preferably about 4 to 7%, alkali metal carbonate, preferably sodium |j carbonate. These salts should provide a total salt concentration i| of about 20 to 50% and preferably about 35 to 45%. I I i, | Bleaching agent comprises sodium hypochlorite .'(NaoCl) soln o ^13% available Cl in 'amounts of about 3-20%, preferably about 7-12% j Caustic soda, as mentioned, should be sufficient to maintain I a pH of 10.5 to about 13.5 and preferably about 11.5 to about 12.7, ^Generally these amounts will be about 0.5 to 3%, and in any event |at least sufficient to neutralize the foam depressor phosphoric J |acid ester compound. The preferred foam depressor comprises mono- and-or di-C^-jCjg alkyl esters of phosphoric acid in a range of about 0.1 to ;0.5% and preferably about 0.15 to 0.3%, specific amounts depending 'in part on the quantity of surfactant present. Surfactants useful herein must be stable in the presence of I 1 [hypochlorite bleach and preferably comprise those of the anionic, |amine oxide, phosphine oxide, sulfoxide and betaine types, the , 'former being most preferred. They are used in amounts ranging i I from about 0.1 to 5% and preferably about 0.3 to 0.8%. To insure adequate foam suppression, it is generally advisable to maintain a surfactant: foam-depressor weight ratio of about 10.1 to 1:1 and preferably about 1.5:1 to 4:1. Particularly preferred surfactants herein are the linear or branched alkali metal mono-and/or di- Cg_i4 alkyl diphenyl oxide mono- and/or disulfonates, 2 03 03 6 45 50 5 5 commercially available for example as DOWFAX 3B-2 and DOWFAX 2A-1. | In general, the paraffin sulfonates tend to impair, if not destroy l| thi*otropy, having been found to unduly increase viscosity causing 35 ; severe shearing force problems. In addition, the surfactant .1 should be compatible with the other Ingredients of the composition. Other suitable surfactants include the primary alkyl-sulphates, a Iky Isulphonates , alkylaryIsulphonates and sec.-I alkyIsulphates. Examples are sodium C10 C18 alkyIsulphates such 40 j| as sodium dodecyIsulphate , sodium tallow alcoholsulphate, sodium I' al'Kf!nesulphcnatea , aach as | ■ sodium hexadecy1-1-sulphon ate; sodium alkyl- benzenesulphonates such as sodium dodecyIbenzeneeulphonate, and the corresponding potassium salts. As other suitable surfactants or detergents, the amine oxide surfactants are typically of the structure ^R^NO, in which each R is a lower alkyl group, for instance methyl, and is a long chain alkyl group having from 8 to 22 carbon atoms, for instance a lauryl, myristyl, palmityl or cetyl group. Instead of an amine oxide, a corresponding surfactant phosphine oxide R2R^P0 or sul-phoxide RR '"SO can be employed. Betaine surfactants are typically of the structure R2R*N+R"COO-, in which each R is a lower alkyl group, is a long chain alkyl group as above and R" is an alky-lene group having from 1 to 5 carbon atoms. Specific examples of these surfactants are laury1-dimethylamine oxide, myristydi- l| methylamine oxide, cocodimethylamine oxide, hardened tallow ! j dimethyl amine oxide, the corresponding phosphine oxides and 'I sulphoxides, and the corresponding betaines including dodecyldi- ij !j me thylammonium acetate, tetradecyl-diethylammonium pentanoate, , o0 jj hexadecyldimethylammonium hexanoate and the like. For biodegrad-Jj ability, the alkyls in these surfactants should be linear, and are preferred. 2 0 3 0 j 6 6 5 70 75 80 85 9 0 Ij Surfactants of the foregoing type, all well known in the 1 i 1 •art are described, for example, in U.S. Patents 3,985,668 and j 4,271,030. j Thickening or suspending agents useful herein generally ' jlcompriue the inorganic, co11oid-forming clays of smectite and/or i! lattapulgite types, the former being preferred. These materials i I 'affect the Theological properties of the composition and are ; i used in amounts of from about 2.5 to 42, the amount selected being i in any event sufficient to confer the desired Bingham plastic i; '■character. Smectite clays include montmorlllonite (bentonite), I'the preferred species, hectorite, saponite, and the like. Mater-'!ials of this type are available under trade names such as Thixogel No. 1 and Gelwhite GP from Georgia Kaolin Company (both being iLontmorillonites). Attapulgite clays include the materials com-j!mercially available under the trade name Attagel, i.e., Attagel 40, iAttagel 50 and Attagel 150 from Engelhard Minerals and Chemicals Corporation. Mixtures of smectite and attapulgite in weight ratios of 4:1 to 1:5 are useful herein. Suspending agents of the foregoing type are well known in : j 'the art, being described, for example, in the referenced U.S. rPatent No. 3,985,668. Other ingredients useful in the instant ADD compositions linclude dyestuffs to provide a pleasantly colored composition, ilParticularly preferred are the chlorinated phthalocyanines and j|po lysis If ides of aluminosilicate which provide green and blue tints jrespectively. 11 j: The following examples are for illustration only, and are !! not to be considered as limiting the invention. Percentages herein are by weight and based on total product unless otherwise indicated, 10- 203036 Example I A preliminary dispersion of foam suppressor, comprising a 2:1 mixture of mono- and di-(C^-C^g) alkyl ester of phosphoric acid, 0.16g, in 6g water is prepared by mixing at 60°C. for 30 minutes using a disk impeller. This dispersion is designated Part I. A preliminary dispersion of GELWHITE GP (hydration) thickener, 3g in 17g water, is prepared by mixing at 70°C. for 10 minutes using a Z-Blade ralxer. This dispersion is designated .Part 2 . i i The following ingredients are mixed in a Giusti mixer at •50 - 60°C: : z AIX j Deionized water 16. 9 j Part I 6. 16 0. 16 J Caustic soda sol.ti, 4 9 X NaOH 2 . 40 1.2 1 Sodium carbonate i 7. 00 7.0 Sodium silicate (l:2.4)sol a-47.5% solids 13. 74 6.5 Sodium TPP (substantially anhydrous)* 12. 00 11.54 Sodium TPP (hexahydrate) 12. 00 - 9.36 The mixture is cooled to 25-30°C., maintaining agitation throughout, and the following ingredients at room temperature are -dded thereto: v Sodium hypochlorite s oln-13% a'va il ab le chlorine 7. 615 1.0 Part 2 (dispersed with highspeed turbine) 20. 00 3.0 Dowfax 3B-2** 0. 80 0. 36 *i.e., containing Or-5%, specially 3%, moisture **sodium monodecyl/didecyl disulfonated diphenyl oxide, 45% AI -11- 203036 An opaque composition (about 4 AI) having a gel-like consistency is obtained. The composition is determined to have a TI of about 7, according to the procedure hereinbefore described based upon apparent viscosity values of 28,000 cps and 4,000 cps at 3 rpm and 30 rpm respectively. When tested in an automatic dishwasher apparatus provided with a dispenser cup, the above composition provides excellent cleaning performance and is easily and quickly dispensed. The composition is observed to be satisfactorily nonfoaming. Little or no phase separation is observed after prolonged standing in a closed container. The pH of the composition, measured as a IS! solution in water, is 11.6. When conducting the shear-test evaluations, it is observed that the composition quickly reverts to its prior quiescent state consistency, suggesting no appreciable loss of yield value when tested within the limits hereinbefore described, i.e., within shear-force limiting values at least approximating those extant within an energized automatic dishwasher. No discernible difference obtains when dispensing the ADD product by squeeze tube rather than dispenser cup. Example 1, illustrating a combined polyphosphate carbonate silicate concentration of about 37% is repeated, but varying the total concentration of such salts within the limits previously given. Best results obtain at a combined-salt concentration o£ at least about 30% and particularly when the sodium tripolyphos-phate concentration is at least about 20%. Higher silicate concentrations,desirable to protect china glaze and patterns, also impart higher alkalinity which can be compensated for by appropriately reducing the caustic soda concentration and/or adjusting the sodium carbonate (buffer) concentration. The composition appears to be most sensitive, resultwise, to variations in the ^JaTPP concentration (the higher concentration range is more </div>

Claims

<div class="application article clearfix printTableText" id="claims"> effective) as well as its degree of hydration. Variations in surfactant concentration generally require corresponding and direct variations in foam-suppressor concentration to achieve the desired low-foam levels. Decrease of the composition pH below about 10.5 is accompanied by significant decrease in composition effectiveness, as well as corresponding decrease of flowability. Similar results are obtained when the procedure of Example 1 is repeated, but replacing corresponding ingredients with alkyl sulfate surfactant, e.g., sodium coconut alkyl sulfate, attapulgite clay, e.g., Attagel 50; and 2:1 mixture of mont roorillonite and Attagel 50. The addition of small amounts, e.g. , 0.003-0.05% of chlorinated phthalocyanine and aluminosilicate dyes respectively to the Example 1 composition (included with the preliminary thickener dispersion or post-added to the cooled solution) produces pleasantly colored green and blue compositions respect ively. This invention has been disclosed with respect to preferred embodiments, and it will be understood that modifications and variation thereof obvious to those skilled in the art are to be included within the spirit and purview of this application and the scope of the appended claims. 24 JAN 198' RE CP' "13" WHAT WE CLAIM IS

1. An aqueous automatic dishwasher composition comprising substantially, by weight : (a) 5 to 35% water-soluble alkali metal tripolyphosphate having an average degree of hydration of 1 to 5; (b) 2.5 to 20% sodium silicate; (c) 0 to 9% water-soluble alkali metal carbonate; (d) 0.1 to 5% bleach stable, water-dispersible organic surfactant; (e) 0.1 to 0.5% mono- and/'or di- (C.,-C10) lb I o alkyl ester of phosphoric acid foam suppressor; (f) 3-20% NaOCI solution having 13% available chlorine; (g) 1.5 to 10% inorganic, colloid-forming clay thickener and (h) sufficient sodium hydroxide to provide a pH of 10.5 to 13.5, the amount of phosphoric acid ester being sufficient to provide low-foaming characteristics, the amount of sodium hydroxide being at least sufficient to neutralize said phosphoric acid ester, and the composition having thixotropy index of 2.5 to 10.

2. A composition according to Claim 1 wherein the weight ratio of surfactant to foam suppressor is 10 to 1 to 1 to 1.

3. A composition according to Claim 1 wherein the total concentration of tripolyphosphate, silicate and carbonate is at least 20%.

4. A composition according to Claim 3 wherein the concentration of tripolyphosphate is 22.5 to 30%.

5. A composition according to Claim 1 wherein the tripolyphosphate comprises a mixture of the substantially anhydrous and hexahydrate forms thereof in a corresponding weight ratio of 1:2 to 2:1.

6. A composition according to Claim 5 wherein said weight ratio is about 1:1.

7. A composition according to Claim 1 further containing a tinting amount of dyestuff.

8. A composition according to Claim 1, wherein said thickener is a smectite and/or attapulgite clay.

9. A composition according to Claim 1 wherein said surfactant is an alkali metal CQ to C^4 alkyl diphenyl oxide sulfonate .

10. A composition according to Claim 1 wherein said tripolyphosphate is a sodium tripolyphosphate; said carbonate is sodium carbonate; said surfactant is a mixture of mono- and di- (Cg to alkyl) diphenyl oxide disul- fonates and said thickening agent is bentonite.

11. A composition according to Claim 10 having a pH of 10.5 to 13.5.

12. A composition according to Claim 10 having a pH of 11.5 to 12.7.

13. A composition according to Claim 10 having a thixotropy index of 6 to 8. WEST-WALKER McCABE per: \ ATTORNEYS FOTT^THE APPLICANT </div>