Abstract
Football clubs in Scotland employ stewards to help to provide a safe and enjoyable matchday experience for spectators. However, stewarding at football matches in Scotland has recently been subject to criticism, particularly in regard to the professionalism of stewards. This article makes an original contribution to scholarship by exploring the role of stewards and private matchday security in Scottish football, drawing upon qualitative data from interviews with 35 participants who have a professional or personal interest in stewarding and the provision of safety and security at football events. The analysis traces the rise of stewarding in Scottish football, noting both challenges and improvements in event safety. Conceptually, we refract this rise, and the concomitant decline in policing resources, through the lens of plural policing, arguing that the policing of football events in Scotland represents a paradigm example of this shift within a reconfiguring field of policing provision and security governance.
Introduction
In October 2018, in advance of Scotland’s plans to host several high-profile Union of European Football Associations (UEFA) European Championship matches in 2020, it was announced that Police Scotland was to commission a report to examine the effectiveness of the force in the policing of football events.
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The report was published in January 2019 as An Independent Review of Football Policing. The author of this review, Mark Roberts, Deputy Chief Constable (DCC) of South Yorkshire Police and the National Police Chiefs’ Council lead for football policing, was tasked with identifying both good practice and areas for improvement. Roberts’ review was, at points, highly critical of the role of stewarding at football matches in Scotland: The questionable quality of some of the stewarding at matches observed will undoubtedly make it harder for Police Scotland to reduce its own resourcing on the footprint of stadiums. (Police Scotland, 2019: 18) Until stewards are adequately trained, supervised, and capable of properly discharging their functions, there will continue to be an overreliance on Police Scotland to use officers in stadia. (Police Scotland, 2019: 18)
This article traces the rise of stewarding in Scottish football as part of a set of safety arrangements influenced by successive stadium disasters, by football clubs seeking to reduce expenditure on matchday security, and by a desire in policing to reduce both the liability of police forces for football policing and to direct resources towards other policing priorities. It finds that the rise of stewarding has brought improvements in event safety at football grounds, but has also raised challenges. Our research highlights concerns about the quality of stewarding personnel in relation to matters such as communication skills and the searching of supporters upon stadium entry. Nevertheless, our research also notes positive aspects of stewarding, particularly as a result of the continuity of provision in comparison to policing arrangements and perceptions of recent improvements in training and professionalisation. Conceptually, we refract this rise of stewarding in Scottish football, and a concomitant decline and distancing of police resources, through the lens of plural policing. In doing so, we argue that the policing of football events in Scotland represents a typical example of plural policing within a reconfiguring field of policing provision and security governance. Overall, this article follows Martin Nøkleberg’s lead in shifting scholarship on plural policing from normative debate to empirical inquiry (Nøkleberg, 2020), and offers insights of relevance to both interested academics and practitioners in Scotland, the United Kingdom (UK), and further afield.
Research methods
This article is principally informed by data from semi-structured interviews with 35 participants conducted in Scotland in 2019 and 2020. The participants included front-line stewards and stewarding company personnel (including supervisors and company management), club safety officers, police officers, and a small number of football fans. Participants from across these populations were identified through a convenience sampling procedure drawing upon the existing networks of the authors, one of whom is actively employed in this field, supplemented where possible by snowball sampling to extend beyond these networks. 2 The semi-structured interview guide was principally informed by a review of available literature, including academic research, public reports and practitioner-focused policy documents, reports, and official regulatory guidance on the subject of stadium safety and security. This allowed the interview questions, which were designed to allow participants the opportunity to communicate their views on stewarding practice, and stadium safety and security, to be grouped and raised appropriately for each interview. In addition to the inherent flexibility of the semi-structured interview process, the interview schedule also included a section on emerging practice and future challenges, to assist in moving beyond existing knowledge. This overall approach helped to produce qualitative data that advance current debates and make new contributions to understanding the role of private matchday security in the plural policing of football events. These data were analysed thematically; a process that was facilitated through the use of NVivo qualitative data analysis software. As a result of this thematic analysis, this article presents its findings across two core themes – ‘the rise of stewarding in Scottish football’ and ‘professionalism and professionalisation’ – and a subsequent discussion that reflects contemporary practice back upon the concept of plural policing. Before doing so, however, it is necessary to provide a review of the relevant literature related to this topic.
Literature review
The literature on policing has posited, for some time now, that the state-centric system of policing that characterised many contemporary societies across much of the 19th and 20th centuries does not monopolise policing practice. Towards the end of the 20th century David Bayley and Clifford Shearing (1996) argued that policing systems in developed economies were undergoing radical change. They argued that policing had moved through and increasingly beyond the police; entering a new historical phase characterised by the pluralisation of the policing landscape, with multiple security providers now operating in this space, and a concomitant search by the traditional ‘public’ police for identity, role and function in this re-configuring field. Bayley and Shearing’s thesis has been subject to criticism in the period since, both from within the Anglosphere (Jones and Newburn, 2002) and beyond (Nøkleberg, 2019, 2020), but the fundamental premise of plural change in policing has become orthodox. Such critiques are important nevertheless, not just because they subject existing sensibilities to a form of critical scrutiny that is rooted in empirical effort, but also because they draw attention to the importance of understanding the way in which changes in policing systems are experienced and expressed at the micro level. This is important for our exploration of the role of private matchday security in the plural policing of Scottish football events, and we return to this in our concluding discussion.
Given that we consider the policing of football events as an important site of plural policing in practice, it is necessary to trace plural policing in more depth before presenting our findings. In 2016, Dominique Boels and Antoinette Verhage published a systematic review on this topic. Following their lead we adhere to the definition of plural policing elucidated at the turn of the millennium by Ian Loader: What we might call a shift from police to policing has seen the sovereign state – hitherto considered focal to both provision and accountability in this field – reconfigured as but one node of a broader, more diverse ‘network of power’…Sure enough, this network continues to encompass the direct provision and supervision of policing by institutions of national and local government. But it now also extends – as we shall see – to private policing forms secured through government; to transnational police arrangements taking place above government; to markets in policing and security services unfolding beyond government; and to policing activities engaged in by citizens below government. We inhabit a world of plural, networked policing. (Loader, 2000: 323–324)
Boels and Verhage’s systematic review (2016) also provides a useful starting point from which to appraise the literature on plural policing. This systematic review, which examined relevant literature from 2000 to 2015, located and analysed 31 empirical studies of plural policing. The authors identified common themes across the literature, which they grouped under two over-arching categories: ‘the dangers of blurring boundaries’ and ‘the effects of plural policing on the core tasks of the public police’. In relation to the first category, they considered the potential dangers of plural policing, including: lack of cooperation between agencies; issues around regulatory frameworks, training, professionalisation and misconduct; conflicting expectations and responsibilities between policing agents; and issues related to accountability structures and other negative consequences, such as the introduction of a tiered policing system based on ‘affordability’. They also further highlighted: the focus of the literature on conflicts of interest between public and private interests; issues around delineation of roles (and potential mission creep amongst policing agents); and disagreements around particular responsibilities where the public police and other agents co-deliver policing services. In relation to the second category, Boels and Verhage noted: how plural policing emerges as a result of new agents filling a void left by the absence of public police; that the presence of new policing agents, particularly at football events, frees up capacity of the public police to focus on other core tasks; and how some non-public police agents may assist the public police in carrying out their core tasks.
Many of the common themes identified in Boels and Verhage’s review are pertinent, either directly or indirectly, to our analysis and discussion of football stewarding. In their systematic review, Boels and Verhage (2016) concluded that there is a strong need for more empirical research on this subject, and especially through qualitative methods. The literature on plural policing published since 2015 addresses, at least in part, this issue. Nøkleberg’s research (2019, 2020) contributes to a recent empirical base that includes research elsewhere in Europe (Brown, 2017; de Maillard and Zagrodzki, 2017; Devroe, 2017; O’Neill, 2017; Terpstra, 2017; van Steden, 2017) and beyond (van Stokkom and Terpstra, 2018). 3
In contrast to plural policing, which has been well traversed in the literature, the topic of private stewarding has been subject to comparatively less academic interest, especially as it relates to football events. Nevertheless, beginning more broadly, and linked to the aforementioned vibrant study of pluralisation, there is an extensive literature on the role of private security in this reconfiguring and increasingly marketised space of security provision. Contributing to this literature on the role and function of private security Phillip Hadfield (2008) in particular has focused upon nightclub security personnel in the UK – ‘bouncers’, in British parlance – as a hitherto hidden element of the private governance of ‘security’ and the wider network of ‘nodes’ that govern the night-time economy. Hadfield’s account here draws together seams from his previous collaborative research (see Hobbs et al., 2002, 2003; Hobbs, Lister et al., 2005; Hobbs, Winlow et al., 2005; Lister et al., 2001; Winlow et al., 2001); a collective body of work that has inspired and informed similar work in the UK (Calvey, 2019; Monaghan, 2004; O’Brien et al., 2008) and in other jurisdictions (see Kupka et al., 2018; Mbhele and Singh, 2019; Roberts, 2007, 2009; Søgaard, 2014); opening up a new and vibrant seam in criminological research. Yet whilst ‘bouncer ethnography’ has found a place within the study of private security, the parallel role of event security, and particularly the role of matchday stewards in providing security at football events, has received comparatively less academic attention. As Megan O’Neill succinctly stated in Policing Football in 2005, There has not been much specifically written about stewarding at football matches. (O’Neill, 2005: 175) Stewards’ training remains important, but clubs and stewards will be judged on how that training is delivered in practice. (Frosdick and Chalmers, 2005: 161) From the commercial perspective, there have been cost savings – stewards are substantially cheaper than paying for police officers…On the downside, too many clubs look to cut costs beyond what is acceptable. (Frosdick and Chalmers, 2005: 167)
Chalmers and Frosdick’s follow-up book More Safety and Security at Sports Grounds (2011) updates their overview and also usefully recounts Frosdick’s work decoupling and balancing ‘safety’ and ‘security’; with the former beginning with stadium design and structural maintenance, and incorporating the safe entry, accommodation and egress of patrons, and the latter more policing-oriented tasks of crime prevention and detection, alongside counter-terrorism and public order tasks. Frosdick is correct to state here that the matchday steward is responsible, in large part, for both safety and security at football events. 4 The academic literature in this area also recognises that stewards have become a common feature of crowd management and control, but that this can be a challenging role that requires careful staff selection, and standards of stewarding can thus vary considerably (Warne, 1999). Moreover, as Hamilton-Smith and McArdle (2013) noted in their research in Scotland, only a small minority of stewards are professionally trained and the majority are employed on a casual basis and may be reluctant to confront challenging situations. Such accounts of the limitations of stewarding resonate with the concerns expressed in An Independent Review of Football Policing in Scotland (Police Scotland, 2019).
The relative paucity of attention given to matchday stewarding is interesting when considering, in the UK at least, the unique regulatory regime around the provision of security at football events. In 2001, the UK government introduced the Private Security Industry Act. This Act outlined a system for the statutory regulation of the private security industry in the UK, and established the Security Industry Authority (SIA) as the independent body to provide this oversight (see White, 2015). Unlike door supervision in the night-time economy, where private security personnel are required to hold a relevant license in order to conduct their duties, the licensing of matchday stewards at football events is less clear cut. Mark Button (2011) has characterised this partial regulation, with several areas of the private security industry subject to no or limited control, as ‘the security management gap’. The 2001 Act was amended in 2006 to provide an exemption from licensing requirements to in-house employees carrying out duties in connection with their employer’s use of a certified sports ground (or certified sports stand) where there is a valid safety certificate in place.
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In practice, this means that stewarding at many football events is often provided ‘in-house’ by football clubs themselves, supplemented by personnel from external security companies where deemed necessary for particular fixtures. Personnel from these external companies are often, but not always, SIA licensed. This regularly results in a set of staffing arrangements for stewarding at football events that is characterised by the deployment of both licensed and non-licensed staff. This mode of stewarding provision is not universal, and other football events may use only in-house staff or rely exclusively on external companies. In any event, the Guide to Safety at Sports Grounds, published by the Sports Grounds Safety Authority and more commonly known as the Green Guide, defines a steward as follows: A steward is a person who has successfully completed a training programme that has been mapped against the relevant National Occupational Standards, and whose occupational competency has been successfully assessed under those standards, or, a person who is undergoing training and assessment towards the meeting of such standards. (Sports Ground Safety Authority, 2018: 67)
The rise of stewarding in Scottish football
The provision of an appropriate regime to ensure the safety of football fans, players and staff, as well the overall security of the event, has become an integral feature of Scottish football. The evolution of safety management and stewarding at football grounds in the UK has been influenced by successive stadium disasters. In fact, the first edition of the Green Guide was published as a result of the Wheatley Report into the Ibrox disaster in 1971, where a crush at the stadium of Scottish football club Rangers FC resulted the deaths of 66 people, with injuries sustained by over 200 more. Developments in sports ground safety management in the period since, and especially following the Hillsborough disaster in 1989 – where 96 Liverpool FC fans died as a result of a crushing incident at a football ground in Sheffield, England – have focused on areas such as legislation, stadium design, and the development of regulation and advisory body the Sports Grounds Safety Authority. However, up until this period the provision of safety and security at football events was very much a police role. As Richard, a police officer, summarised in our research, [In the late 1980s/early 1990s] The police had primacy in the ground over everything, and that was just the culture of the time. The organisation of everything was a police role, so the turnstiles, the outside duties [too]…Every element of it seemed to be experienced officers who knew how things ran…Very much it was a police operation from start to finish. (Richard, police officer) The general responsibility for safety began to be assumed by the club whilst the police role shifted to concentrate on crime, public order and emergency management. (Frosdick et al., 1999: 211)
Data from participants in our study highlighted the ‘typical’ provision for stewarding at a Scottish football event, and the rationale for such stewarding provision. An ordinary arrangement for stewarding on a matchday was outlined by Barry, a club safety officer, I look for a model of both in-house and sub-contract[ed] stewards. To get the minimum amount of stewards [requires that] we bring in contract stewards. We have our core company, which is a [club] owned company…and at the same time we bring in contract stewards. The stewarding qualifications are based on the Green Guide edition six, the requirements of stewards. (Barry, club safety officer) From a cost point of view, stewards represent better value-for-money, because an efficient stewarding operation will see a reduction in policing costs. Of course that’s a win–win for the police as well as for the clubs. (Barry, club safety officer) Ultimately, if we go ‘police free’ [stewarding only]…there’s a big saving to be made there [for the football club], and that saving can be pumped back into buying players, improving the ground, improving the spectator experience. So [mentions football club] are keyed into that. (Kyle, police officer) At [mentions fixture] I have reduced the detail [number of police officers deployed] by about a third…They [the host club] are delighted because you are bringing down the cost, but it’s not just about the cost, it’s about, as an area commander say I need my town centre covered, so why am I taking cops away from the day-to-day stuff to stand at the football? (Alexander, police officer) The benefit a football club has [from stewarding] is that they [stewards] have familiarity with the venue, a knowledge of the contingencies of that venue and subtle nuances that a police officer might not be able to understand if deployed there from a different part of the country. (David, police officer) We have the same stewarding company, which is owned by the club. Same people and management. Makes life pretty constant and standard. It means that the people in charge have experience of the stadium. (Simon, club safety officer) You get what you pay for, but they work at that ground every week. So they know the people sitting in the seats and they know the problematic people. They also know how to get people out of the ground quickly…I think generally they are pretty good though. (Kyle, police officer) You just try and avoid getting in bother, especially at the end of the match when you are Baltic [very cold] and hungry and you need a pee! (Ciaran, police officer)
The categorisation process is integral to the overall shape of security and safety provision at Scottish football events. Scotland operates an identical system of categorisation to England and Wales, with categories ranging from CS (club security only, essentially ‘police free’), through Category A (low risk of disorder), Category B (medium risk of disorder), Category C (high risk of disorder), and Category C-IR (Category C with increased risk of disorder) (Police Scotland, 2018). The categorisation of each match in Scotland is effectively a result of a process of discussion between the police service and the club; each of which has its own objectives to advance and interests to protect. James, a senior police officer, reflected upon this process of dialogue, The debate all happens before the season starts and that’s where the discussion place about the number of cops in each stand, and as you go through the seasons that’s how many cops will be put in and charged for by the police…The clubs need to do their financial planning, so before of the season they’ll know they’ve got so many Cat C games, so many Cat B games and they can project their financial impact at the start of the season. But there is always that debate and discussion. Football clubs are businesses and need to maximise their margin, but we as an organisation need to make sure that that event is safe. And if my professional judgement is that that event needs 40 cops, then that is where the discussion starts. And it might end up that we say ‘well if you pay for an extra 20 stewards I’ll reduce the number of cops’, so you [the football club] might still need to pay some money but it’s stewards as opposed to cops. That discussion often takes place and it happens every year.” (James, police officer) It [club safety officers being ex-police officers] helps because they understand our rationale, very occasionally some of them forget they aren’t in the polis [police service] anymore! But for the most part it’s a definite benefit…I talked about the categorisation at the start of the season, we then do it game-by-game as the games approach and we get an intel [intelligence] document for that and based on that intel document we then say what the categorisation is. Sometimes we have a disagreement with the club where they say ‘we think you’ve over-assessed this’ and we’ll debate it and we’ll talk through it and usually come to an agreement. (Tom, police officer) The club can fight back [against categorisation] and say maybe they’ll mitigate that risk. So they’ll employ an extra 30, 40 stewards, on minimum wage. And a lot of the clubs, the stewards are fans and they are there on a temporary part-time basis because they want to be there, so their role is diluted. Are they feeding intelligence on the risk support, who potentially could be their pals? Are they feeding that into the risk assessment? And that can have an impact on the intelligence picture from a policing point of view for future games. (Stuart, police officer)
Professionalism and practice
A central critique of An Independent Review of Football Policing in Scotland (Police Scotland, 2019) related to the professionalism of stewarding staff. The review noted that until appropriate training and supervision was in place in relation to stewarding, football events would continue to overly rely on the police to ensure that matches were safe and secure. The criticism of DCC Roberts in his review is not a solitary voice: police officers, fans and even some club’s own safety officers in our research expressed concerns about the quality of stewarding in Scottish football. Ross, a police officer at the front line of football policing, offered a forthright assessment when asked about his view of stewards, They’re shite. They cause more problems than they sort. (Ross, police officer) You get told to ‘let the stewards do their job’ but eventually you have to search people and you are fishing out bottles of Buckfast [tonic wine, from football fan’s pockets]. (Ciaran, police officer) There’s now far more stewards but its empty jackets. I feel sorry for them. They arrive early, stay longer, are on maybe a tenth of the money [than a police officer], on a zero hours contract. A lot of them are maybe foreign students who have a loose grasp of [local] language…Stewarding numbers have increased but it’s hollow yellow jackets walking around who can’t do anything, and I wouldn’t expect them to. (Ciaran, police officer). [The stewards were] A lot of guys who just wanted a free season ticket or [were] foreign students who didn’t speak great English. There was no training, you just put on a yellow jacket and if there was a problem, [you would] call the supervisor! We were doing it for minimum wage. Saturday night drinking money. You do get some though that will make a career out of it, [also] doing retail security or whatever, and become supervisors and progress. And you can spot them a mile off because they are the only ones who are interested in actually doing anything or being helpful in any way. (Rory, police officer)
Despite such forthright views it is important to recognise that there were also counter-perspectives on the effectiveness of stewards. Contrary to the reductive characterisations of stewards expressed by some police officers, the typical profile of stewards as ‘students and old timers’ was considered by others as a positive. For example Robert, a club safety officer, remarked positively on the diversity of the stewarding cohort and the increasing professionalisation of the role. Some positive perspectives were also given by police officers. David, for example, also noted moves towards a more professional approach to stewarding, I think for me that the levels of expertise and professionalism that we find within stewarding is far higher than it may ever have been in the past…yeah there has definitely been a shift in professionalisation of stewards. (David, police officer) So through that lengthy process of doing their character references and doing their work vet [vetting] checks as well as making sure if they want to work towards and SIA or NVQ [National Vocational Qualification], we cover that for them as well…It is lengthy training process. (Jeff, security firm manager) Probably more recently there has been a slight change in profile of the stewards in so far as they have become more specialist in some areas. We have always had standard stewards, safety stewards we call them, they are not security but they are safety primarily, so that’s the core. Then we have fire stewards which are not particularly new, but they would be people who would probably come from a fire and rescue background, either serving or retired, and their job is fire safety around the stadium. Now we have access stewards, who look to take care of disabled fans coming into the stadium, and more recently in the last few years we have safeguarding stewards, trained and qualified to look after children and young people and vulnerable adults. So in amongst the stewarding base now there is some specialisms for the matchday operations. (Robert, club safety officer)
In addition to professionalisation through training, a clear benefit of using stewards at football events was seen as their tailored experiences of specific stadiums and fans, and the subsequent expertise they can accrue if deployed consistently. Recognising the importance of consistency in stewarding personnel at stadiums a club safety officer noted, In the main it’s the same faces, so they know the stadium. And [we] will deploy them to the same areas of the stadium that they are familiar with. (Josh, club safety officer) You know who the people [supporters] were and could suss them out…you got to know a few of them. (Jack, football event steward) They had one or two individuals who were experienced in stewarding, and then they really had a cohort of the same people [stewards] coming every week, building up stadium knowledge. So even today, it’s the same fire officer, the same guy in charge of the main stand et cetera…I think the police didn’t trust that the stewards knew what they’re doing and therefore that would be a risk…But then once you see the same faces every week, at pre-ops meetings, there was a sense of ‘they know what they are doing’. (James, police officer)
Discussion and concluding remarks
This article has traced the rise of stewarding in Scottish football as part of a panoply of safety arrangements influenced by successive stadium disasters, efforts by football clubs to decrease expenditure on event security, and a desire in policing to both reduce the liability of police forces for football policing and to direct resources towards other policing priorities. The findings highlight how the rise of stewarding has brought improvements in event safety at football grounds, particularly as a result of continuity in safety and security provision. The familiarity and experience that comes from such continuity is more difficult to achieve through policing arrangements, where the personnel deployed can vary considerably from week-to-week. Additionally, moves towards improvements in training provision for stewards and an increasing number of specialisms within stewarding have also improved safety in stadiums, as well as offering enhanced career prospects for stewards in the broader field of private security. Yet it is also important to highlight that the rise of stewarding has resulted in challenges, some of which are acute. These include a lack of confidence of some police officers in the effectiveness of stewarding and the communication skills of stewards more generally, a reliance on police officers when stewards are faced with particularly challenging situations, and the unwillingness or inability of stewards to inform an intelligence-led policing approach to the policing of football fans. We have argued that such developments, considered together, represent a paradigm example of plural policing.
Boels and Verhage (2016) astutely highlighted that the literature on plural policing discloses a desire in public policing to withdraw provision around particular tasks. However, our analysis also notes a pressure from outside the public police to withdraw public policing functions and responsibilities, and to replace them with private security. The plural policing of football events is thus driven by the desire of the police service to reduce the police officer footprint at football events and to deploy officers in other community contexts where there is significant demand, but also the desire from football clubs to reduce expenditure on event safety and security. The promotion of new plural policing arrangements thus presents an interesting insight into both power and agency in a reconfiguring field of policing provision and aligned security governance. Our research indicated that the police service in Scotland is increasingly inclined to divest the ‘rowing’ function of football policing – particularly the ‘in-stadium’ aspects of safety – to football clubs, and a concomitant but still emergent shift away from the responsibility of ‘steering’ safety and security in stadiums. Such shifts intensify existing trends highlighted previously in the literature on the safety and security of football stadiums and events in the post-Hillsborough landscape (see Frosdick and Chalmers, 2005). Moreover, however, the retreat of the public police and the rise of stewarding and private security in the policing of football also raises issues of accountability, particularly in a Scottish context where policing tactics and the criminalisation of football fans in recent times have been of significant public and political concern (see Atkinson et al., 2020; McBride, 2017). The rise of stewarding and subtle shifts in security governance can thus be understood as part of a wider process of re-configuration in the plural policing of Scottish football; a process that presents both challenges and opportunities.
The issues experienced in the plural policing of Scottish football events resonate with many of those themes identified in the existing literature: from issues around training and professionalism to the effects of private security provision on the capacity of the public police. In relation to the latter in particular, our research highlights how the interests of public police and private actors can converge, and consensus can emerge on the retreat of the public police from particular policing tasks in order to re-focus police resources on ‘core’ tasks and concurrently reduce the expenditure of those private actors. Overall, this article has followed Nøkleberg’s (2020) lead in shifting scholarship on plural policing from normative debate to empirical inquiry. In doing so, it has offered empirical insights of relevance to both interested academics and practitioners in Scotland, the UK, and further afield, as well as critical reflection on the nature and development of plural policing.
Footnotes
Declaration of conflicting interests
The author(s) declared no potential conflicts of interest with respect to the research, authorship, and/or publication of this article.
Funding
The author(s) received no financial support for the research, authorship, and/or publication of this article.
