[Pharmwaste] help
Kirshenberg, Seth D.
Seth.Kirshenberg at KutakRock.com
Mon Mar 26 17:53:23 EDT 2012
Please unsubscribe me from this list
-----Original Message-----
From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of pharmwaste-request at lists.dep.state.fl.us
Sent: Monday, March 26, 2012 5:46 PM
To: pharmwaste at lists.dep.state.fl.us
Subject: Pharmwaste Digest, Vol 77, Issue 14
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Today's Topics:
1. Re: Items Accepted at Permanent Collection
(Mark_Williams at deq.state.ms.us)
2. RE: Items Accepted at Permanent Collection (Fredrick L. Miller)
3. Re: Items Accepted at Permanent Collection (Rod Larson)
4. RE: Items Accepted at Permanent Collection (Lucy, Burke)
5. RE: Items Accepted at Permanent Collection (Fredrick L. Miller)
6. RE: Items Accepted at Permanent Collection (Audet, Adele (DPH))
7. RE: Items Accepted at Permanent Collection (Audet, Adele (DPH))
8. RE: [html][heur] [Pharmwaste] Items Accepted at Permanent
Collection (Pete Pasterz)
----------------------------------------------------------------------
Message: 1
Date: Mon, 26 Mar 2012 14:45:32 -0500
From: Mark_Williams at deq.state.ms.us
Subject: Re: [Pharmwaste] Items Accepted at Permanent Collection
To: Mbascom at harthosp.org
Cc: pharmwaste-bounces at lists.dep.state.fl.us,
pharmwaste at lists.dep.state.fl.us
Message-ID:
<OF8C6B9001.650E2A89-ON862579CD.006C7A82-862579CD.006C9631 at deq.state.ms.us>
Content-Type: text/plain; charset=US-ASCII
In many if not most states (ours included), the household exemption follows
the wastes through the end of life and the police station does not become
the generator of the wastes and the wastes do not lose the household
exemption. However, there are some states where HHW centers and other
facilities that handle household hazardous wastes could be regulated as a
TSD that would require a state permit. That would be a state specific
matter that you would have to check on with the RCRA programs in your
individual state. I believe that is the exception though and does not
apply to the majority of states.
Mark Williams, P.E., Administrator
Solid Waste Policy, Planning & Grants Branch
Mississippi Department of Environmental Quality
P.O. Box 2261
Jackson, MS 39225
Phone: 601-961-5304
Fax: 601-961-5785
From: "Maureen Bascom" <Mbascom at harthosp.org>
To: "ANGELA Deckers" <adeckers at cityofboise.org>,
<pharmwaste at lists.dep.state.fl.us>
Date: 03/26/2012 02:39 PM
Subject: Re: [Pharmwaste] Items Accepted at Permanent Collection
Sent by: pharmwaste-bounces at lists.dep.state.fl.us
I would be interested in knowing if any unused pharma from households, that
falls under RCRA, such as P or U listed wastes are being deposited in the
police collection containers. If so, does that now make the police
generators of hazardous wastes?
>>> "ANGELA Deckers" <adeckers at cityofboise.org> 3/26/2012 3:33 PM >>>
Greetings. I am hoping to get some feedback from other programs that have
established pharm collection containers at local law enforcement agencies.
In our program, the evidence room managers of the participating police
agencies are voicing frustration over the disposal of items in the
collection containers that are viewed, by the agencies, as outside the
realm of the intended use of the program. Examples would include vitamins,
over-the-counter meds etc...
As public works staff, I facilitated the implementation of the program,
come from the environmental side, and see the benefit of collecting some of
these products. The police staff are looking at controlling illegal use of
prescription meds. I would like them to collect these products but don't
wish to alienate them to the point that they consider backing out all
together.
Has anyone else run into this and what compromises were reached? Where
did your program draw the line?
Please respond to adeckers at cityofboise.org
Thanks. Your time in responding is much appreciated.
Angela Deckers
Hazardous Materials Coordinator
Boise Public Works
adeckers at cityofboise.org
208.384.3983
208.433.5650 fax
---
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------------------------------
Message: 2
Date: Mon, 26 Mar 2012 13:09:13 -0700
From: "Fredrick L. Miller" <millerfl at tricity.wsu.edu>
Subject: RE: [Pharmwaste] Items Accepted at Permanent Collection
To: <pharmwaste at lists.dep.state.fl.us>
Message-ID:
<0394FB32A1ECFB41A7BA0F55586C4A7701728134 at lotus.tricity.wsu.edu>
Content-Type: text/plain; charset="us-ascii"
It's a slippery slope they're on. They can maintain their HHW exemption
so long as they are fastidious about their recordkeeping and never mix
one drop/gram of non-traceable waste. That means they can't
legitimately claim the household exemption if they allow anonymous or
unattended drop-offs. They lose control of the process and open the
door to commercial source wastes (e.g. pharmacy/clinical) dumping.
Also, they have to be careful never to mix their own wastes with the
household wastes or they turn the whole lot into RCRA regulated
materials.
Then there's the issue of legacy and nuclear meds. How do they keep
things like "seeds" out of their waste? How about old stuff laden with
mercury and barium? While the HHW exemption may apply to them as a
generator, those issues can still bite disposal facilities where the
waste is accepted and all it takes is one "oops" to kill the entire
process for one and all. Nothing spreads in the disposal business like
the news of getting burnt and once burnt, industry reacts far more
quickly and in far more draconian fashion than regulators ever could.
They simply start saying "no" to any and all comers who look like the
party that started the problem.
In my opinion, pharmacists are the only folks out there with the
education and familiarity sufficient to get the job done. Unfortunately
their time is usually far too precious to spend on such programs. Until
industry, USEPA, and DEA get their act together and sing a little
harmony this problem will remain with us.
Fred Miller
USTUR
Board Member, College and University Hazardous Waste Conference
-----Original Message-----
From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Maureen
Bascom
Sent: Monday, March 26, 2012 12:39 PM
To: ANGELA Deckers; pharmwaste at lists.dep.state.fl.us
Subject: Re: [Pharmwaste] Items Accepted at Permanent Collection
I would be interested in knowing if any unused pharma from households,
that falls under RCRA, such as P or U listed wastes are being deposited
in the police collection containers. If so, does that now make the
police generators of hazardous wastes?
------------------------------
Message: 3
Date: Mon, 26 Mar 2012 16:53:24 -0400
From: Rod Larson <larsonr at husson.edu>
Subject: Re: [Pharmwaste] Items Accepted at Permanent Collection
To: "Fredrick L. Miller" <millerfl at tricity.wsu.edu>,
<pharmwaste at lists.dep.state.fl.us>
Message-ID: <CB964F84.126E4%larsonr at husson.edu>
Content-Type: text/plain; charset="US-ASCII"
I agree that pharmacists have the training and familiarity to get the job
done. However, having the public return their unused medications to
pharmacies is a very bad idea in my opinion.
Pharmacy has a very good tracking system in place for the ordering, storing,
dispensing, and returning of medications. Even with this, however, there is
a problem with employee diversion at each step.
Adding a steady stream of unknown medications into this system would likely
result in some of these medications getting back into the legitimate
pipeline to be dispensed again (which is illegal). Or they will be diverted
into the illicit pipeline, ending up at high school and college parties.
This latter diversion would be much easier than it is now, since the
diverter wouldn't have to circumvent a relatively tight tracking system for
controlled substances. The high costs of medications are just to tempting
for this not to occur.
I was at a recent presentation by the DEA agent who stated that the new
regulations will have a heavy pharmacy component to them, since many of the
public comments gathered recommended this. This scares me a great deal.
Rod Larson
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
Rodney A. Larson, Ph.D., R.Ph.
Founding Dean
Husson University School of Pharmacy
On 3/26/12 4:09 PM, "Fredrick L. Miller" <millerfl at tricity.wsu.edu> wrote:
> It's a slippery slope they're on. They can maintain their HHW exemption
> so long as they are fastidious about their recordkeeping and never mix
> one drop/gram of non-traceable waste. That means they can't
> legitimately claim the household exemption if they allow anonymous or
> unattended drop-offs. They lose control of the process and open the
> door to commercial source wastes (e.g. pharmacy/clinical) dumping.
> Also, they have to be careful never to mix their own wastes with the
> household wastes or they turn the whole lot into RCRA regulated
> materials.
>
> Then there's the issue of legacy and nuclear meds. How do they keep
> things like "seeds" out of their waste? How about old stuff laden with
> mercury and barium? While the HHW exemption may apply to them as a
> generator, those issues can still bite disposal facilities where the
> waste is accepted and all it takes is one "oops" to kill the entire
> process for one and all. Nothing spreads in the disposal business like
> the news of getting burnt and once burnt, industry reacts far more
> quickly and in far more draconian fashion than regulators ever could.
> They simply start saying "no" to any and all comers who look like the
> party that started the problem.
>
> In my opinion, pharmacists are the only folks out there with the
> education and familiarity sufficient to get the job done. Unfortunately
> their time is usually far too precious to spend on such programs. Until
> industry, USEPA, and DEA get their act together and sing a little
> harmony this problem will remain with us.
>
> Fred Miller
> USTUR
> Board Member, College and University Hazardous Waste Conference
>
>
> -----Original Message-----
> From: pharmwaste-bounces at lists.dep.state.fl.us
> [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Maureen
> Bascom
> Sent: Monday, March 26, 2012 12:39 PM
> To: ANGELA Deckers; pharmwaste at lists.dep.state.fl.us
> Subject: Re: [Pharmwaste] Items Accepted at Permanent Collection
>
> I would be interested in knowing if any unused pharma from households,
> that falls under RCRA, such as P or U listed wastes are being deposited
> in the police collection containers. If so, does that now make the
> police generators of hazardous wastes?
> ---
> Note: As a courtesy to other listserv subscribers, please post messages to the
> listserv in plain text format to avoid the garbling of messages received by
> digest recipients.
> ---
> TO SUBSCRIBE, go to:
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> TO UNSUBSCRIBE, DO NOT REPLY TO THE LISTSERV. Please send an e-mail to
> pharmwaste-unsubscribe at lists.dep.state.fl.us -- the subject line and body of
> the e-mail should be blank.
> If you believe you may be subscribed with a different email address, please
> visit the subscriber listing at
> http://lists.dep.state.fl.us/cgi-bin/mailman/roster/pharmwaste
> FOR PROBLEMS: Contact List Administrator Laurie.Tenace at dep.state.fl.us
> SEND MAIL to the list server at: pharmwaste at lists.dep.state.fl.us
------------------------------
Message: 4
Date: Mon, 26 Mar 2012 21:17:24 +0000
From: "Lucy, Burke" <Burke.Lucy at CalRecycle.ca.gov>
Subject: RE: [Pharmwaste] Items Accepted at Permanent Collection
To: "pharmwaste at lists.dep.state.fl.us"
<pharmwaste at lists.dep.state.fl.us>
Message-ID:
<77A4B84FA266494B9DCBC529A5233B13A4BCEC at DR3MAIL1.itservices.network>
Content-Type: text/plain; charset="us-ascii"
Regardless of whether a state exempts household waste through the end of life, haulers still have to follow U.S. DOT standards. So that's one of the benefits of using a law enforcement collection program since they have their own transport process. The U.S. DOT does not exempt household waste from regulation if it's "consolidated shipments of household hazardous materials transported from collection centers" (CFR, Title 49, Section 171.8). If the new DEA regulations provide more flexibility for collecting controlled substances at pharmacies, the hauling process could still be a sticking point.
Burke
Mr. Burke Lucy
Integrated Waste Management Specialist
Department of Resources Recycling and Recovery (CalRecycle)
1001 I Street, PO Box 4025
Sacramento, CA 95812
Burke.Lucy at CalRecycle.ca.gov
916.341.6592
-----Original Message-----
From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Mark_Williams at deq.state.ms.us
Sent: Monday, March 26, 2012 12:46 PM
To: Mbascom at harthosp.org
Cc: pharmwaste-bounces at lists.dep.state.fl.us; pharmwaste at lists.dep.state.fl.us
Subject: Re: [Pharmwaste] Items Accepted at Permanent Collection
In many if not most states (ours included), the household exemption follows the wastes through the end of life and the police station does not become the generator of the wastes and the wastes do not lose the household exemption. However, there are some states where HHW centers and other facilities that handle household hazardous wastes could be regulated as a TSD that would require a state permit. That would be a state specific matter that you would have to check on with the RCRA programs in your individual state. I believe that is the exception though and does not apply to the majority of states.
Mark Williams, P.E., Administrator
Solid Waste Policy, Planning & Grants Branch Mississippi Department of Environmental Quality P.O. Box 2261 Jackson, MS 39225
Phone: 601-961-5304
Fax: 601-961-5785
From: "Maureen Bascom" <Mbascom at harthosp.org>
To: "ANGELA Deckers" <adeckers at cityofboise.org>,
<pharmwaste at lists.dep.state.fl.us>
Date: 03/26/2012 02:39 PM
Subject: Re: [Pharmwaste] Items Accepted at Permanent Collection
Sent by: pharmwaste-bounces at lists.dep.state.fl.us
I would be interested in knowing if any unused pharma from households, that falls under RCRA, such as P or U listed wastes are being deposited in the police collection containers. If so, does that now make the police generators of hazardous wastes?
>>> "ANGELA Deckers" <adeckers at cityofboise.org> 3/26/2012 3:33 PM >>>
Greetings. I am hoping to get some feedback from other programs that have established pharm collection containers at local law enforcement agencies.
In our program, the evidence room managers of the participating police agencies are voicing frustration over the disposal of items in the collection containers that are viewed, by the agencies, as outside the realm of the intended use of the program. Examples would include vitamins, over-the-counter meds etc...
As public works staff, I facilitated the implementation of the program, come from the environmental side, and see the benefit of collecting some of these products. The police staff are looking at controlling illegal use of prescription meds. I would like them to collect these products but don't wish to alienate them to the point that they consider backing out all together.
Has anyone else run into this and what compromises were reached? Where
did your program draw the line?
Please respond to adeckers at cityofboise.org
Thanks. Your time in responding is much appreciated.
Angela Deckers
Hazardous Materials Coordinator
Boise Public Works
adeckers at cityofboise.org
208.384.3983
208.433.5650 fax
---
Note: As a courtesy to other listserv subscribers, please post messages to the listserv in plain text format to avoid the garbling of messages received by digest recipients.
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------------------------------
Message: 5
Date: Mon, 26 Mar 2012 14:39:35 -0700
From: "Fredrick L. Miller" <millerfl at tricity.wsu.edu>
Subject: RE: [Pharmwaste] Items Accepted at Permanent Collection
To: <pharmwaste at lists.dep.state.fl.us>
Message-ID:
<0394FB32A1ECFB41A7BA0F55586C4A7701728158 at lotus.tricity.wsu.edu>
Content-Type: text/plain; charset="us-ascii"
Burke brings up another good point. Transportation will be an issue.
Unless LE is going to transport their collections all the way to the end
disposal facility they're going to end up using commercial transporters
at some point and at that moment the stuff becomes fully regulated with
no exceptions or exemptions. All it takes is for a transporter to get
caught with something in the load that isn't manifested correctly for
the whole shebang to come to a screeching halt. It is unlikely the
agencies involved have the people on staff at every location with the
education, experience, and training necessary to fully comply with 49
CFR. It's even more unlikely they're aware of the magnitude of the
penalties involved for typical 49 CFR violations. If they knew the
financial liability they're contemplating taking on they'd be running
away at full speed.
Fred
-----Original Message-----
From: pharmwaste-bounces at lists.dep.state.fl.us
[mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of Lucy,
Burke
Sent: Monday, March 26, 2012 2:17 PM
To: pharmwaste at lists.dep.state.fl.us
Subject: RE: [Pharmwaste] Items Accepted at Permanent Collection
Regardless of whether a state exempts household waste through the end of
life, haulers still have to follow U.S. DOT standards. So that's one of
the benefits of using a law enforcement collection program since they
have their own transport process. The U.S. DOT does not exempt
household waste from regulation if it's "consolidated shipments of
household hazardous materials transported from collection centers" (CFR,
Title 49, Section 171.8). If the new DEA regulations provide more
flexibility for collecting controlled substances at pharmacies, the
hauling process could still be a sticking point.
Burke
Mr. Burke Lucy
Integrated Waste Management Specialist
Department of Resources Recycling and Recovery (CalRecycle)
1001 I Street, PO Box 4025
Sacramento, CA 95812
Burke.Lucy at CalRecycle.ca.gov
916.341.6592
------------------------------
Message: 6
Date: Mon, 26 Mar 2012 17:38:44 -0400
From: "Audet, Adele (DPH)" <adele.audet at state.ma.us>
Subject: RE: [Pharmwaste] Items Accepted at Permanent Collection
To: ANGELA Deckers <adeckers at cityofboise.org>,
"pharmwaste at lists.dep.state.fl.us" <pharmwaste at lists.dep.state.fl.us>
Message-ID:
<911EE1A8306B2D468591223E65BC0A688475F246C2 at ES-MSG-EMB-002.es.govt.state.ma.us>
Content-Type: text/plain; charset="us-ascii"
If the departments are responsible for the fees associated with incineration then there may be a legitimate reason to be frustrated. Most local and state agencies have very tight budgets. If a local LE is willing to include prescription drugs in their destruction of evidence then why fault them for not taking on OTCs and vitamins?
Adele D. Audet, R. Ph.
Assistant Director, Drug Control Program
MA DPH
305 South Street
Jamaica Plain MA 02130
Phone 617-983-6712
FAX 617-524-8062
________________________________
From: ANGELA Deckers [mailto:adeckers at cityofboise.org]
Sent: Monday, March 26, 2012 3:33 PM
To: pharmwaste at lists.dep.state.fl.us
Subject: [Pharmwaste] Items Accepted at Permanent Collection
Greetings. I am hoping to get some feedback from other programs that have established pharm collection containers at local law enforcement agencies.
In our program, the evidence room managers of the participating police agencies are voicing frustration over the disposal of items in the collection containers that are viewed, by the agencies, as outside the realm of the intended use of the program. Examples would include vitamins, over-the-counter meds etc...
As public works staff, I facilitated the implementation of the program, come from the environmental side, and see the benefit of collecting some of these products. The police staff are looking at controlling illegal use of prescription meds. I would like them to collect these products but don't wish to alienate them to the point that they consider backing out all together.
Has anyone else run into this and what compromises were reached? Where did your program draw the line?
Please respond to adeckers at cityofboise.org<mailto:adeckers at cityofboise.org>
Thanks. Your time in responding is much appreciated.
Angela Deckers
Hazardous Materials Coordinator
Boise Public Works
adeckers at cityofboise.org<mailto:adeckers at cityofboise.org>
208.384.3983
208.433.5650 fax
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Message: 7
Date: Mon, 26 Mar 2012 17:40:05 -0400
From: "Audet, Adele (DPH)" <adele.audet at state.ma.us>
Subject: RE: [Pharmwaste] Items Accepted at Permanent Collection
To: Maureen Bascom <Mbascom at harthosp.org>, ANGELA Deckers
<adeckers at cityofboise.org>, "pharmwaste at lists.dep.state.fl.us"
<pharmwaste at lists.dep.state.fl.us>
Message-ID:
<911EE1A8306B2D468591223E65BC0A688475F246C3 at ES-MSG-EMB-002.es.govt.state.ma.us>
Content-Type: text/plain; charset="us-ascii"
Interesting since I was told that at a collection site, Selsun Blue would become a hazardous waste.
Adele D. Audet, R. Ph.
Assistant Director, Drug Control Program
MA DPH
305 South Street
Jamaica Plain MA 02130
Phone 617-983-6712
FAX 617-524-8062
-----Original Message-----
From: Maureen Bascom [mailto:Mbascom at harthosp.org]
Sent: Monday, March 26, 2012 3:39 PM
To: ANGELA Deckers; pharmwaste at lists.dep.state.fl.us
Subject: Re: [Pharmwaste] Items Accepted at Permanent Collection
I would be interested in knowing if any unused pharma from households, that falls under RCRA, such as P or U listed wastes are being deposited in the police collection containers. If so, does that now make the police generators of hazardous wastes?
>>> "ANGELA Deckers" <adeckers at cityofboise.org> 3/26/2012 3:33 PM >>>
Greetings. I am hoping to get some feedback from other programs that have established pharm collection containers at local law enforcement agencies.
In our program, the evidence room managers of the participating police agencies are voicing frustration over the disposal of items in the collection containers that are viewed, by the agencies, as outside the realm of the intended use of the program. Examples would include vitamins, over-the-counter meds etc...
As public works staff, I facilitated the implementation of the program, come from the environmental side, and see the benefit of collecting some of these products. The police staff are looking at controlling illegal use of prescription meds. I would like them to collect these products but don't wish to alienate them to the point that they consider backing out all together.
Has anyone else run into this and what compromises were reached? Where did your program draw the line?
Please respond to adeckers at cityofboise.org
Thanks. Your time in responding is much appreciated.
Angela Deckers
Hazardous Materials Coordinator
Boise Public Works
adeckers at cityofboise.org
208.384.3983
208.433.5650 fax
------------------------------
Message: 8
Date: Mon, 26 Mar 2012 21:44:30 +0000
From: Pete Pasterz <PAPasterz at cabarruscounty.us>
Subject: RE: [html][heur] [Pharmwaste] Items Accepted at Permanent
Collection
To: ANGELA Deckers <adeckers at cityofboise.org>
Cc: "pharmwaste at lists.dep.state.fl.us"
<pharmwaste at lists.dep.state.fl.us>
Message-ID:
<02C461E2EBA00F43B97C57B9230A2FE215E7B567 at Dash1.cabarrus.local>
Content-Type: text/plain; charset="iso-8859-1"
Angela-
Back to your original question, why are the Police objecting to the variety of the pills deposited? Is this a time issue (more frequent emptying)? A disposal cost issue (does the PD pay)?
Maybe it will help to educate them that the best way to facilitate collection of the illicit drugs is to collect all of them...the general public generally can't distinguish narcotics from antibiotics or supplements.
? Pete Pasterz, NCQRP SCTSOS
Cabarrus County Waste Reduction
PO BOX 707
Concord, NC 28026
704-920-3280
www.cabarruscounty.us/waste<http://www.cabarruscounty.us/waste>
If you're not for ZERO Waste, how much Waste ARE you for?
From: pharmwaste-bounces at lists.dep.state.fl.us [mailto:pharmwaste-bounces at lists.dep.state.fl.us] On Behalf Of ANGELA Deckers
Sent: Monday, March 26, 2012 3:33 PM
To: pharmwaste at lists.dep.state.fl.us
Subject: [html][heur] [Pharmwaste] Items Accepted at Permanent Collection
Greetings. I am hoping to get some feedback from other programs that have established pharm collection containers at local law enforcement agencies.
In our program, the evidence room managers of the participating police agencies are voicing frustration over the disposal of items in the collection containers that are viewed, by the agencies, as outside the realm of the intended use of the program. Examples would include vitamins, over-the-counter meds etc...
As public works staff, I facilitated the implementation of the program, come from the environmental side, and see the benefit of collecting some of these products. The police staff are looking at controlling illegal use of prescription meds. I would like them to collect these products but don't wish to alienate them to the point that they consider backing out all together.
Has anyone else run into this and what compromises were reached? Where did your program draw the line?
Please respond to adeckers at cityofboise.org<mailto:adeckers at cityofboise.org>
Thanks. Your time in responding is much appreciated.
Angela Deckers
Hazardous Materials Coordinator
Boise Public Works
adeckers at cityofboise.org<mailto:adeckers at cityofboise.org>
208.384.3983
208.433.5650 fax
________________________________
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties.
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