Blog

23 Sep
Food Safety Consortium KTL
Food Safety Consortium: KTL Presentation on How to Respond to Recalls

The Food Safety Consortium Fall Edition is kicking off this October with five weekly sessions featuring critical thinking topics that have been developed for both industry veterans and knowledgeable newcomers. KTL will be a featured presenter during the Recalls: Trends and Analysis episode on Thursday, October 14:

How to Respond to Recalls
Thursday, October 14
1:10 pm – 1:55 pm ET (includes Q&A)
Presented by KTL Senior Consultant Roberto Bellavia

22 Sep
Sustainable Food Management
Creating Sustainable Impacts Part 3: Sustainable Food Management

Wasted food makes up the largest percentage—over 20%—of any one material sent to landfills and incinerators each year in the U.S. This large volume of disposed food is a main contributor to total U.S. methane emissions, a greenhouse gas (GHG) with 21 times the warming potential of carbon dioxide. Financially, wasted food costs America more than $100 billion annually from disposal costs of municipal waste management, over-purchasing costs, and cost of lost energy. And all this wasted food is happening when nearly 40 million Americans are food insecure.

In short, wasting food impacts the sustainability of our economy, our society, and the environment—also known as the triple bottom line of sustainability. But through sustainable food management, it is possible to help businesses and consumers save money, create outlets for those in our communities who do not have enough to eat, and conserve resources for future generations.

Wasted Food and Food Loss

The U.S. Environmental Protection Agency (EPA) uses the term wasted food instead of food waste to describe food that is not used for its intended purpose. This terminology conveys the notion that a valuable resource is being squandered. The U.S. Department of Agriculture’s (USDA) Economic Research Service (ERS) further defines food loss as the “edible amount of food, postharvest, that is available for human consumption but is not consumed for any reason.”

Food loss occurs at every stage of the supply chain—from farm to table. How that loss is managed plays a vital role in how it impacts our society. That is where sustainable food management comes to play.

What Is Sustainable Food Management?

According to EPA, sustainable management of food is “a systematic approach that seeks to reduce wasted food and its associated impacts over the entire lifecycle, starting with the use of natural resources, manufacturing, sales, and consumption, and ending with decisions on recovery of final disposal.”

Sustainable food management is essentially a subset of sustainable materials management (SMM). As with SMM, the best approach to reducing food loss and waste is to not create it in the first place. Source reduction is the most effective way of reducing the environmental and financial impacts of wasted food and packaging because it prevents unneeded materials from ever being created. To do so is a process that involves performing a food waste assessment—much like an SMM lifecycle analysis (LCA)—to identify what and how much food (and food packaging) is being wasted.

A thorough food and packaging assessment serves as the foundation for reduction efforts. Having this general understanding can help identify appropriate strategies to avoid waste, cut down on disposal costs, reduce over-purchasing and labor costs, reduce water and energy use associated with food production, and reduce GHG emissions.

Based on the outcomes of the food waste assessment, EPA suggests some common strategies for reducing wasted food and packaging, which may include the following:

  • Adjusting food purchasing policies to reduce excess food purchasing (i.e., use just-in-time purchasing, purchase items in bulkfood-recovery-hierarchy to reduce packaging).
  • Storing and organizing food properly to reduce spoilage.
  • Repurposing leftover food following food safety guidelines.
  • Reducing to-go/takeout item packaging and using compostable/recyclable packaging.
  • Reducing portion size of regularly wasted items.
  • Using a system to identify over-purchased food items and to track wasted food.
  • Continuously training staff on basic steps to minimize food waste (e.g., cooking and food preparing to reduce wasted food, plating practices).

If excess food is unavoidable—and sometimes it is—reusing leftover food is possible as long as food safety guidelines are followed. The food can also be recovered to donate to hunger relief organizations to feed people in need. Even inedible food can be recycled into other products such as animal feed, compost and worm castings, bioenergy, bioplastics, and clothing. EPA’s Food Recovery Hierarchy identifies and prioritizes the actions organizations can take to prevent and divert wasted food. The top levels of the hierarchy are the most desirable alternatives because they create the most benefits for the environment, society, and the economy.

Part 4 of KTL’s series on Creating Sustainable Impacts will dive into some of the incentives and drivers for participating in sustainable food management.

 

21 Sep
sqf amendments
Amendments to SQF V9: Effective October 4, 2021

In October 2020, the Safe Quality Food Institute (SQFI) published SQF Codes Edition 9 (SQF V9) as the most recent edition of the SQF Food Safety Codes. SQF V9 is comprised of 13 industry-specific codes that provide step-by-step instruction for production and manufacturing sites to become SQF certified. This certification is recognized by the Global Food Safety Initiative (GFSI) and showcases certified sites’ commitment to a culture of food safety and operational excellence in food safety management. Implementation of SQF V9 is effective as of May 24, 2021.

In August 2021, SQFI introduced four code amendments to this most recent edition. These amendments are required to be implemented along with applicable SQF V9 codes by October 4, 2021, and will be audited accordingly. A summary of the amendments is included below:

AreaDescriptionApplicability
Medical ScreeningRequires a medical screening procedure for all employees, visitors, and contractors who handle exposed product or food contact surfaces.Personnel Hygiene and Welfare, 3.3.1.1; 9.3.1.1; 10.4.1.1; 11.3.1.1; 12.4.1.1; 13.3.1.1; 17.3.1.1
Approved SuppliersRequires all approved and emergency suppliers to be registered and all registers to be complete, including supplier contact details.2.3.3 in the Primary Food Safety codes; 2.3.4 in all other codes except Storage and Distribution
Multi-site ProgramRequires sub-sites within an SQF multi-site program to operate in only the following food sector categories: 1, 2, 3, 4, 5 (primary) and 26 (storage and distribution).Appendix 4
Application of Agricultural ChemicalsRequires the code apply to the person applying chemicals, as well as the person making decisions on chemical application.7.7.3.2, 5.7.3.2, 8.7.3.2, 18.8.4.2

SQFI has a number of resources and guidance documents available to help ensure compliance with these amendments and the other requirements of SQF V9.

23 Aug
EPA Enforcement: Ammonia Refrigeration

Over the past several months, we have seen an uptick in Environmental Protection Agency (EPA) enforcement actions and large penalties for violations related to anhydrous ammonia storage, risk management, and chemical accident prevention planning. These include the following recent penalties:

Many of these violations have been uncovered as part of a National Compliance Initiative (NCI), which focuses on reducing risk to human health and the environment by decreasing the likelihood of accidental releases at facilities. According to EPA, there are approximately 150 catastrophic accidents each year at facilities that make, use, or store extremely hazardous substances (EHS). With ammonia refrigeration making up approximately 40% of the facilities with EHS regulated under the EPA’s Risk Management Program, these facilities have become a clear target for EPA.

Chemical Accident Prevention Program

Anhydrous ammonia is classified as an EHS that presents a significant health hazard if accidentally released. Anhydrous ammonia is corrosive to skin, eyes, and lungs. Exposure to 300 ppm is immediately dangerous to life and health. It is also flammable at concentrations of about 15-28% by volume in air.

To help refrigeration facilities comply with Clean Air Act (CAA) requirements and prevent accidents that could result in these significant hazards, EPA’s NCI is working to enforce the following regulatory aspects of the CAA’s Chemical Accident Prevention Program:

  • Risk Management Plan (RMP) regulations (40 CFR Part 68)
  • General Duty Clause (GDC) (CAA Section 112(r))
  • Emergency Planning and Community Right-to-Know Act (EPCRA) (CAA Section 312)
  • Process Safety Management (PSM) regulations (29 CFR 1910.119)

Risk Management Plan (RMP)

EPA’s RMP regulations require facilities that have more than a threshold quantity of certain regulated chemicals in a process (e.g., use or storage) to develop a Risk Management Program. CAA designates anhydrous ammonia as a regulated substance under RMP with a threshold quantity of 10,000 lbs.

Recent cases have demonstrated that refrigeration facilities may not be fully implementing RMPs, despite requirements. Facilities subject to RMP must:

  • Analyze the worst-case release scenario to determine the potential effects of a release.
  • Implement a prevention program that includes safety precautions, as well as maintenance, monitoring, and employee training.
  • Complete a five-year accident history.
  • Coordinate response actions with the local emergency response agencies through an Emergency Response Program.
  • Submit to EPA a written RMP that summarizes the Risk Management Program.

General Duty Clause (GDC)

The GDC requires that owners and operators of facilities with regulated substances and other EHS in any quantity ensure those chemicals are managed safely. Unlike RMP, GDC applies to many chemicals and applies facility-wide, regardless of the amount of chemical stored. Facilities are responsible for:

  • Identifying the hazards posed by chemicals and assessing impacts of possible releases.
  • Designing and maintaining a safe facility to prevent accidental release.
  • Minimizing the consequences of accidental releases that do occur.

The EPA NCI focuses specifically on the “identifying hazards” component of GDC, particularly at ammonia refrigeration facilities using 1,000 lbs. to 10,000 lbs. of anhydrous ammonia (i.e., those that fall below the RMP threshold).

Emergency Planning and Community Right-to-Know (EPCRA)

Section 312 of EPCRA requires facilities to report the presence of certain chemicals, including anhydrous ammonia, to Local Emergency Planning Committees (LEPCs) and response agencies. The purpose is to ensure emergency responders know what chemicals are onsite should they need to respond to an incident.

Any facility that is required to maintain Safety Data Sheets (SDS) for hazardous chemicals stored or used onsite must submit an annual Tier II inventory report for those chemicals. Tier II forms require basic facility identification information, employee contact information (emergency and non-emergency), information about chemicals stored/used at the facility, and additional data elements that would be useful to LEPCs and first responders.

Process Safety Management (PSM)

PSM regulations require facilities to prevent or minimize the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals. While PSM is not an EPA regulation, the Occupational Health and Safety Administration’s (OSHA) program is closely related to EPA’s RMP program. RMP is intended to protect the environment and the community; PSM is an occupational health program intended to protect workers. Applicability thresholds differ for RMP and PSM for some chemicals; however, the PSM and RMP thresholds for anhydrous ammonia are the same—10,000 lbs.

PSM establishes a comprehensive management program made up of 14 elements. The process hazard analysis is the key provision of the standard, as it is intended to identify, evaluate, and control the hazards involved in the process.

Additional Enforcement Focused on Process Startup

In February 2021, EPA issued a new Enforcement Alert, “Risk of Chemical Accidents During Process Startup.” According to the alert, the U.S. Chemical Safety and Hazard Investigation Board (CSB) has noted that a disproportionate number of accidents occur during startup or other nonroutine operations.

Given this recent Alert, EPA cites that the following provisions of the RMP regulations are particularly important to prevent accidents during process startup:

  • Operating procedures that provide clear instructions for safely conducting activities involved in each covered process.
  • Training so each employee involved in operating a process is familiar with operating procedures, safety and health hazards, emergency operations, and safe work practices.
  • Pre-startup review to ensure construction and equipment is functioning according to design specifications and that safety, operating, maintenance, and emergency procedures are in and place and adequate.

Avoiding Enforcement: Hazard Analysis

As part of the NCI, EPA has been sending Information Requests to select facilities that it believes may be out of compliance with GDC. Again, the primary focus of those Information Requests includes those facilities with 1,000 lbs. to 10,000 lbs. of anhydrous ammonia onsite. Facilities are required to answer four questions about their ammonia refrigeration systems, including whether they have performed a process hazard review.

EPA is focusing heavily on the first duty of the GDC (i.e., hazard review) as it evaluates facilities for violations. An EPA Enforcement Alert on anhydrous ammonia at refrigeration facilities from February 2015 reinforces that identifying the hazards of a facility’s refrigeration systems is crucial to accident prevention and compliance. This involves identifying and inventorying every chemical onsite, understanding the associated hazards of each chemical, and making sure employees and local responders know what to do in case of an accident. Part of this analysis should also include addressing potential gaps between new industry codes and standards and the standards to which the facility was built (e.g., facility upgrades).

If your facility uses anhydrous ammonia and you have not conducted a hazard analysis, you are at significant risk of incurring enforcement actions of fines. It is important you invest the time and resources required to:

  • Understand the hazards posed by chemicals at the facility.
  • Assess the impacts of a potential release.
  • Design and maintain a safe facility to prevent accidental releases.
  • Coordinate with local emergency responders.
  • Minimize the consequences of accidental releases that do occur.

KTL has experience working with a broad cross-section of industries impacted by PSM, RMP, GDC, and EPCRA, particularly chemical and food processing companies. We have created RMP and GDC audit protocols, conducted audits, and implemented investigation/improvement programs following significant release events. In addition, our team provides Tier II and TRI reporting, writes plans for OSHA and Emergency Response, and routinely works with LEPCs to coordinate emergency response efforts and exercises to keep communities informed and safe. Our team has helped many companies keep operations safe and compliant—and avoid EPA enforcement.

 

28 Jul
Food Supply Chain
FDA’s Focus on Food Traceability

According to the Centers for Disease Control and Prevention (CDC), approximately 48 million Americans—about one in six—get sick with a foodborne illness every year. Of that number, CDC estimates 128,000 end up hospitalized and 3,000 will die from a foodborne disease. Correspondingly, consumers rank safety higher than anything else (e.g., affordability, healthful eating) when selecting a restaurant. Consumers want—and need—to know more about their food. 

It is not surprising, given this information, that improving food traceability is a key objective for the U.S. Food & Drug Administration (FDA). Food traceability is the ability to track any food through all stages of the supply chain—production, processing, distribution—to ensure food safety and operational efficiency. Over the past year, the Agency has launched three major initiatives to create safer and more traceable food supply chain.  

Read KTL’s recent article in Food Safety Magazine about these initiatives and FDA’s focus on food traceability.

19 May
remote food safety audit
Food Safety Magazine Article: Food Remote Audits

Audits provide an essential tool for improving and verifying compliance performance. Audits may be used to capture regulatory compliance status (e.g., FDA, USDA); certification system conformance (e.g., FSSC 22000, SQF, IFS, BRC); and adequacy of internal controls, potential risks, and best practices.

Most regulations, standards, and certification programs require audits to be conducted with some established frequency. For many food companies, figuring out how to meet these audit requirements amongst travel restrictions, new company safety protocol, and government quarantines related to COVID-19 has presented a significant challenge.

The Online Alternative

Fortunately, the Global Food Safety Initiative (GFSI) and the benchmarked certification schemes have responded to this challenge, recognizing that online/remote/virtual audits can offer a viable alternative to onsite audits—even when companies are not operating in a pandemic.

Read KTL’s recent article in Food Safety Magazine about remote food safety auditing and best practices for doing it right.

19 Apr
Demonstrating Compliance in a Socially Distanced World

Don’t miss this free American Bar Association event on April 22, 2021 — Demonstrating Compliance in a Socially Distanced World: Virtual Auditing.

In the time of COVID-19, virtual auditing has become increasingly necessary and valuable to organizations as they seek to achieve environmental compliance while facing worldwide travel restrictions and remote work policies that have disrupted routine in-person audits. With this shift, comes the need for both regulated entities and regulators to develop new approaches and procedures to ensure the effectiveness of audits conducted remotely. Practitioners, including auditors and legal counsel, must consider new dynamics related to security, data protection, and audit integrity-on top of the usual audit considerations. This session will highlight some of these new challenges and provide real-world solutions to aid attendees form new practice skills to apply in the (virtual) field.

Panelists–including KTL’s Sarah Burton–will explore the new world of remote auditing, focusing on real-world solutions to the challenges that virtual auditing presents.

Register online.

05 Apr
Food CMS
Food Safety Tech Article: Integrated Food CMS

Managing the complexities of a management system is challenging for any food and beverage company, particularly for the team tasked with implementing the system throughout the organization. That is because every regulatory agency (e.g., FDA, USDA, OSHA, EPA) and voluntary certification (e.g., GFSI-benchmarked standards, gluten-free, organic, ISO) calls for companies to fulfill compliance requirements—many of which overlap. Supply chain and internal requirements can create further complications and confusion.

In today’s “New Era of Smarter Food Safety,” having a common system to organize, manage and track compliance offers an ideal solution. Dynamic tools are becoming available—systems that can manage employee training, pest control, laboratory testing, supply chain management tools, regulatory compliance and certification requirements, etc.

Unfortunately, these systems are often not set up to “talk” to each other, leaving company representatives to navigate many systems, databases, folders, and documents housed in many different locations.

The Solution: Compliance Management Systems

An integrated compliance management system (CMS) is intended to bring all these tools together to create one system that effectively manages compliance requirements, enables staff to carry out daily tasks and manage operations, and supports operational decision making by tracking and trending data that is collected daily by the team charged with implementation.

Read KTL’s recent article and case study in Food Safety Tech about how a  CMS can be used to coordinate, organize, control, analyze, and visualize information to help organizations remain in compliance and operate efficiently.

18 Mar
Now Hiring: Food Safety Specialist
Now Hiring: Food Safety Specialist

Location: Chicago, Illinois

KTL is seeking a Food Safety Specialist with 5-7 years of professional food safety consulting or relevant food industry experience to join our team. This individual will work under the direction of KTL Project Managers and Senior Consultants to manage and execute tasks for KTL’s food safety projects and meet client expectations. The Food Safety Specialist must have working knowledge of FDA, USDA, and GFSI requirements as they apply to food/food packaging manufacturing, processing, and distribution, and experience implementing/maintaining food safety documents and plans.  

Responsibilities and tasks include the following: 

  • Providing HACCP, SOPand SSOP development and implementation support 
  • Conducting gap assessments to FDA, USDA, and GFSI (i.e., IFS, BRC, FSSC22000, SQF) requirements 
  • Conducting relevant food safety training for clients  
  • Researching FDA, USDA, and GFSI regulatory requirements and maintaining standards updates 
  • Researching labeling regulatory review 
  • Interpreting thirdparty regulatory audits 
  • Reviewing, recommending, and coordinating efforts for environmental contaminants and pathogen testing program 
  • Working with clients and KTL senior staff to identify Food Safety Management System (FSMS) and program gaps and implement solutions for continuous improvement  
  • Maintaining and updating documents to ensure conformance and compliance consistency 
  • Participating in the development and management of KTL’s SharePoint® tools  
  • Assisting in growing clients and other business development efforts, as requested 

Requirements

  • B.S. degree in food science, biology, chemistry,  technology, microbiology, or other related life science  
  • 5-7 years of related food industry experience in Quality Assurance/Control; experience in cooking, processing, manufacturing dairy, low-acid canned food, meat, or seafood preferred 
  • Excellent communication and presentation skills  
  • Excellent research, analytical, writing, and organizational skills 

 Preferred

  • Microsoft SharePoint® and information management systems experience 
  • Highrisk food or ingredients experience  
  • Understanding of food safety in food packaging 

How to Apply

Forward a resume to recruiting@kestreltellevate.com.


Company Description

KTL is a management consulting firm providing EHS, sustainability, food safety, and quality consulting services to a wide range of industry, municipal, university, and government clients. Our focus is to build strong, long-term client partnerships and provide value-added solutions that simplify management systems, improve compliance, and establish more sustainable operations. KTL specializes in developing and implementing strategies, processes, and tools that complement our clients’ investments in existing programs and resources. Our highly qualified personnel have an in-depth knowledge of U.S. federal, state, and international EHS requirements; global food safety compliance; ISO management systems; and information management toolsOur consultants possess the education, work experience, and professional registrations necessary to provide value-adding consulting services to our clients. 

25 Feb
food safety culture
IFS Food V7: Creating a Food Safety Culture

The International Featured Standards (IFS) are “uniform food, product, and service standards that ensure certified companies produce a product or provide a service that complies with customer specifications, while continually working on process improvement.”

There are currently six standards under IFS, including the most recent IFS Food Standard Version 7 (IFS Food V7), which was issued in October 2020. Recognized by the Global Food Safety Initiative (GFSI) as a benchmarked standard for auditing food manufacturers, IFS Food focuses on ensuring food safety and quality.

V7 Changes

The new IFS Food V7 reduces the number of requirements by 15% and provides additional clarity for auditors when performing an IFS assessment through the following changes:

  • Risk-based and less prescriptive approach that allows for customized solutions for company-specific risks and hazards
  • New wording that changes “audit” to “assessment” to create consistency with ISO/IEC 17065
  • New structure that emphasizes onsite evaluation over documentation
  • Better defined scoring system and a more clearly structured assessment report
  • Unannounced assessments (every third certification)
  • Checklist that aligns with the GFSI Benchmarking Requirements Version 2020, Food Safety Modernization Act (FSMA), and European Union (EU) regulations
  • Incorporation of food safety culture into assessments

IFS Food V7 is scheduled for implementation with audits beginning March 1, 2021 and will become mandatory for all certified companies on July 1, 2021.

Focus on Food Safety Culture

One notable change with IFS Food V7 is the incorporation of food safety culture into requirements. This is in line with the addition of food safety culture into GFSI Benchmarking Requirements Version 2020. It also relates directly to one of the core elements of the U.S. Food & Drug Administration’s (FDA) New Era of Smarter Food Safety, which promotes food safety culture throughout the food system.

Per IFS, “Food safety culture refers to shared values, beliefs, and norms that affect mindset and behaviour toward food safety in, across, and throughout an organization.”

Informally, food safety culture can be thought of as “the way we do things around here” when it comes to food safety practices. An organization’s food safety culture is ultimately reflected in the way food safety is managed in the workplace. A strong food safety culture creates an atmosphere where everyone in the organization is aware of and helps to prevent any process and/or operational issues and deviations that my impact the safety and/or quality of their products.

Characteristics of a Strong Food Safety Culture

Per IFS Food V7, food safety culture should be driven by four primary elements:

  • Communication about food safety policies and responsibilities
  • Training
  • Employee feedback
  • Performance measurement

Best-in-class food safety cultures have robust systems in place to ensure that each of these elements, among others, is well-functioning and fully ingrained into the standard practices of the organization. KTL has found that organizations with strong food safety cultures typically exhibit many of the following attributes:

  • Communication. Communication is most effective when it comprises a combination of top-down and bottom-up interaction. All levels of management (senior, middle, supervisory) are responsible for clearly communicating to the workers who carry out the company’s mission. It is equally important that workers provide feedback on a practical level about what’s working and what’s not.
  • Commitment. When it comes to food safety, actions truly speak louder than words. A lack of commitment, as demonstrated by action (or lack thereof), comes across loud and clear to staff.
  • Caring. Caring involves showing concern for the personal safety of individuals (employees and consumers), not just making a commitment to the overall idea of food safety.
  • Cooperation.  Cooperation means working together to develop a strong food safety program. It means management seeks feedback from workers about food safety issues—and uses that feedback to make improvements.
  • Coaching. Coaching each other—peer to peer, supervisor to employee, even employee to management—is an important way to keep everyone on track, generate constructive criticism, and foster a truly collaborative atmosphere regarding food safety.
  • Procedures. There should be documented, clear procedures for every task. This not only prevents disagreement about what is required, it also shows commitment when things are put in writing.
  • Training. Training is a more formal, documented process for ensuring that employees follow food safety processes and procedures and feel prepared to do their jobs.
  • Tools. All equipment and tools should be in good repair and functioning as designed. Inadequate equipment/tools directly impact food safety/protection and indirectly impact perception of management commitment.
  • Personnel. There must be enough qualified workers to perform each task. The company must not sacrifice food safety or quality because of being understaffed (i.e., requiring shortcuts/overtime to meet production goals).
  • Trust. Trust in the food safety program, in senior management, and in each other is built when each of these characteristics is present and treated as a company-wide priority.

Planning for Change

For companies that are IFS-certified, now is the ideal time to assess current IFS Food program elements; identify improvements that are internally desirable and required by the new standard; and implement those updates that will create a strong food safety culture and make the IFS Food program more useful to the business. This can be done through a series of phases to ensure adoption throughout the organization.

  • Phase 1: IFS Food Internal Assessment – Review existing IFS food programs, processes, and procedures; document management systems; and employee training tools and programs to identify those need areas in need of updates, development, and/or implementation to meet the requirements of IFS Food V7.
  • Phase 2: IFS Food Program Updates – Based on the assessment, develop a plan for updating the IFS Food certification program, including major activities, key milestones, and expected outcomes. This may include updating/developing IFS Food programs, processes, procedures, and training with missing V7 requirements and incorporating new food safety culture requirements.
  • Phase 3: Training – To ensure staff are prepared to implement and sustain the updated IFS Food V7 program, staff must be trained on applicable requirements; specific plans, procedures, and GMPs developed to achieve compliance; and the certification roadmap to prepare for future assessments.

Following this plan now will help companies ensure they maintain their IFS Food certification when assessments begin under IFS Food V7 in March 2021.

Resources

The IFS website has several comprehensive resources available to assist facilities and auditors in understanding the IFS Food V7 changes and requirements, including:

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