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FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule...

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Purdue University Cooperative Extension Service is an equal access/equal opportunity institution. July 2016 Scott Monroe Food Safety Educator FSMA Produce Rule Basics and Purdue Food Safety Update
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Page 1: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

July 2016

Scott MonroeFood Safety Educator

FSMA Produce Rule Basics and Purdue Food Safety Update

Page 2: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

What have you heard???

Produce Food Safety

Page 3: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

CDC estimates that each year:• 48 million Americans sick from

foodborne illness• 1 in 6 people• 128,000 hospitalizations• 3,000 deaths

A significant proportion of foodborne illnesses have been

attributed to fresh produce

Source: http://www.cdc.gov/foodborneburden/

http://ww

w.cdc.gov/foodborneburden/attribution-im

age.html#foodborne-illnesses

Produce Food Safety

Page 4: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

•Americans buying more fresh produce•Range of consumer health (immuno-compromised)•Better detection and reporting systems•Microbes newly associated with produce

– (E. coli, Salmonella, Norovirus)

Produce Related Illnesses

Page 5: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Bacteria – Single-celled organisms that live independently.Parasites – Intestinal worms or microscopic protozoa that live in a host animal or human

Viruses – Small particles that live and can only replicate in a host

Microbial Causes of Illness

Page 6: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Three most common microbesSalmonella

E. coli O157:H7Listeria monocytogenes

24 Hours

1 Cell 17 Million CellsUnder ideal growing conditions

Microbial Causes of Illness

Page 7: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

SoilPeopleWaterManureLivestockPetsWildlife

On-Farm Microbial Sources

Page 8: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

E. coli on lettuce

Salmonella on muskmelon

Photo credits: E. Maynard, Peter Cooke, Stephen Ausmus, Scimat Science Photo Library, Institute of Food Technologists

Washing Safe

Page 9: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Potatoes Spinach Lettuce

Winter Squash Sweet Corn Cucumbers

Zucchini Beets Radish

Eggplant Kale Microgreens

Tomatoes

Apples

Berries

Garlic

Herbs

Onions

Cooked ?Both? Raw

Microbial ‘kill step’ Wash step

Cooked vs. Raw Consumption

Page 10: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Field Wash/Pack Cooling/Storage Transportation Market Consumer

Consider Farm to Fork Risks

Page 11: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

GAPs are the conditions, growing practices, and harvesting practices recommended for minimizing risk of microbial contamination to produce safe and wholesome fruits and vegetables.

National GAPs Programwww.gaps.cornell.edu

Using Good Agricultural Practices

Reduce on-farm Risks

Page 12: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

ALL growers who introduce produce into the public food supply should be concerned

about food safety!

Page 13: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Regulation of on-farm food safety

Federal Government (FDA)(FSMA)

Indiana State Department of Health (ISDH)

Industry

County Health Departments

Farmers’ Market Rules

Page 14: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

January 2011 - Signed into Law

November 2015 - Final Produce Rule Published

January 2016 – New Produce Rule Became Law

FSMA = Food Safety Modernization Act

https://en.wikipedia.org/wiki/FDA_Food_Safety_Modernization_Act

Food Safety Modernization Act

Page 15: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Seven rules in process by FDA

Preventive Controls for Human Foods (final)

Preventive Controls for Food for Animals (final)

Produce Safety (final)

Foreign Supplier Verification Programs (FSVP) for Importers of Food for Humans and Animals (final)

Accreditation of Third-party Auditors/Certification Bodies to Conduct Food Safety Audits and to Issue Certifications (final)

Sanitary Transportation of Human and Animal Food (final)

Focused Mitigation Strategies to Protect Food Against Intentional Adulteration (final)

Page 16: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

FSMA Terminology

Covered – One is held to and obligated to comply with the produce rule.

Exempt – One is not obligated to comply with the produce rule.

Qualified Exemption – One is exempt from the produce rule provided that certain conditions (qualifiers) are met.

Page 17: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

FSMA Produce Rule –

Am I Covered???

Page 18: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Page 19: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Am I a FARM or a FACILITY???

https://slowhappyliving.files.wordpress.com/2014/11/img_1784.jpg

Photo: J. Obermeyer

Page 20: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

FarmFSMA Produce Rule

Good Agricultural Practices (GAPs)

FacilityFSMA Preventive Controls Rule

Applies if required to register with FDAChopping, grinding, and pelletizing may constitute “manufacturing”

Mixed-type FacilityAn entity that engages in both farming and processing

https://slowhappyliving.files.w

ordpress.com/2014/11/im

g_1784.jpg

Page 21: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Photo: J. Obermeyer

FarmMinimal processing

DryingBalingVacuum packing

***No significant alterations

FacilityBeyond minimal processing

Pelletizing***Significant alterations

Page 22: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

FSMA Produce Ruledefinition of “farm”

• Farms are not required to register as a food facility merely because they pack or hold raw agricultural commodities grown on another farm under a different ownership.– Such activities are subject to the produce

safety rule rather than the preventive controls rule for human food.

– One can still pack for a neighbor!

Page 23: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Page 24: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

FSMA Produce Rule – Am I Covered???

Farms or farm mixed-type facilities with an average annual monetary value of produce

sales of $25,000 or less are not covered.

Page 25: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Page 26: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

AsparagusBeans

BlackGreat NorthernKidneyLimaNavyPinto

BeetsGarden (roots and tops)Sugar

CashewsSour CherriesChickpeasCocoa Beans

Coffee BeansCollardsSweet CornCranberriesDatesDill

SeedsWeed

EggplantsFigsHorseradishHazelnutsLentilsOkraPeanuts

PecansPeppermintPotatoesPumpkinsWinter SquashSweet PotatoesWater Chestnuts

Commodities Rarely Consumed Raw

Page 27: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Food Grains

Barley AmaranthCorn Quinoa

Dent BuckwheatFlint Oilseeds

Sorghum CottonOats FlaxRice RapeRye SoyWheat Sunflower

Page 28: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Page 29: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Page 30: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Processing crops receive a qualifiedexemption if:

A. They receive commercial processing that adequately reduces the presence of microorganisms of public health significance.

B. Accompanying documents disclose that the food is “not processed adequately to reduce the presence of microorganisms of public health significance”.

C. Written assurances from the buyer are obtained annually.

Page 31: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Page 32: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Page 33: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

If I’m exempt,does this really matter???

FSMA Produce Rule

Page 34: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Remember!!!While individuals may be exempt

from regulations,

One is NEVER exempt from liability!

Page 35: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Who Sales Time to ComplyFarms >$500,000 food sales/year 2 yearsSmall Farms $500,000 - $250,000 food sales/year 3 yearsVery Small Farms $250,000 - $25,000 food sales/year 4 years

In addition to compliance times, all will receive an additional two years to comply with water testing requirements.

Compliance Timeline

Page 36: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Agricultural Water “Water used in covered activities on covered produce where water is intended to, or is likely to, contact covered produce or food contact surfaces, including water used in growing activities (including irrigation water applied using direct water applicationmethods, water used for preparing crop sprays, and water used for growing sprouts) and in harvesting, packing, and holding activities (including water used for washing or cooling harvested produce and water used for preventing dehydration of covered produce).”FSMA Produce Rule – Section 112.3(c)

Page 37: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Direct Water Application Method“Using agricultural water in a manner whereby the water is intended to, or is likely to, contact covered produce or food contact surfaces

during use of the water.”

ProduceDefined, in part, as the harvestable part of a crop.

FSMA Produce Rule – Section 112.3(c)

Page 38: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

1. Is my farm covered by the produce rule?

2. Is this particular crop covered by the produce rule?

3. Will I be applying water, as irrigation or crop sprays, to the harvestable part of the crop?

Water Questions to Ask

Page 39: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Surface water applied directly to harvestable part during growing20 samples within two years to establish a baseline5 samples per year thereafter

Underground water applied directly to harvestable part during growing4 samples in the first year1 sample thereafter

Sources: http://www.fda.gov/Food/GuidanceRegulation/FSMA/ucm415226.htm#water and PSA Curriculum Resources

Produce RuleAgricultural Water Standards

Page 40: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Produce RuleAgricultural Water Standards

(con’t)

For all water sources:Geometric Mean <126 CFU generic E. coli /100 mlStatistical Threshold Value <410 CFU generic E. coli / 100 ml

Sources: http://www.fda.gov/Food/GuidanceRegulation/FSMA/ucm415226.htm#water and PSA Curriculum Resources

Page 41: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Produce Rule Training Requirement

One person from each covered farm must complete training in the APPROVED GAPs curriculum.

The approved curriculum is the Produce Safety Alliance Curriculum

The training and registrations will be managed by the Association of Food and Drug Officials (AFDO)

Page 42: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Purdue ExtensionFood Safety Activities and Programming

Produce Safety Alliance (PSA) curriculum team8 individuals certified as trainers in approved curriculumTeam is currently seeking “lead trainer” certification.

Training sponsored by NC SARE

Produce Food Safety for Direct Marketers2 hour program for produce direct marketers.

Presented at Small Farms Conference, statewide webinar, and various countiesPresented program in over 30 counties

Program supported by USDA Specialty Crops Block Grant through ISDA

Produce Food Safety Website Developed through USDA Specialty Crops Block Grant through ISDA

Includes GAPs resources, blog, and event calendarhttps://ag.purdue.edu/hla/foodsafety

Food Safety Plan Writing Series4 session series delivered over internet (June/July 2015)

Supported by USDA Specialty Crops Block Grant through ISDA

Page 43: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Food Safety Activities and Programming (con’t)

Continue work with Cantaloupe IndustryPre-harvest workshops

ECGA unannounced audits (2014/2015)

Mock AuditingProvide mock audits for vegetable growers in advance of 3rd party audits

Staff Development Programs2 day GAPs training program for educators conducted December 2015

ResearchSummer/Fall 2015 Rapid Response Flood Project supported by Center for Produce Safety, et. al.

Testing of novel sanitizer productsWorking toward manure project in 2016/17

Page 44: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Flood Research (2015)

Page 45: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

How soon can I replant???

What can be done to speed the process???

Page 46: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Answering flood-related questions

AND

Making lemonade out of lemons

SWPAC Flood Remediation Project

Funded by the Center for Produce Safety et. al.

Page 47: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Randomized Complete Block Design6 Treatments

ControlTillageCover CropBrassicaClear Plastic MulchBlack Plastic Mulch

4 Replications

Page 48: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Soil Samples are periodically taken from plots

Samples are then analyzed for microbial populations

Page 49: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

To estimate the rate of microbial die-off after a flood event

And

To determine if treatments significantly alter microbial die-off rates

Goals of the Flood Remediation Study

Page 50: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Results –Data from this work

suggested that doing nothing was best

Page 51: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Extension Food Safety Personnel

Scott MonroeFood Safety Educator

Amanda DeeringClinical Assistant ProfessorFresh Produce Food Safety

Amanda’s Picture Here

Page 52: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Amanda DeeringClinical Assistant Professor

Department of Food Science

Email: [email protected]: 765-494-0512

Page 53: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Scott MonroeFood Safety Educator

Purdue Extension

Southwest Purdue Agricultural Center4369 N. Purdue Rd.

Vincennes, IN 47591(812)886-0198 (Office)(765)427-9910 (Cell)

[email protected]://ag.purdue.edu/hla/foodsafety

Page 54: FSMA Produce Rule Basics and Purdue Food Safety Update...November 2015 - Final Produce Rule Published. January 2016 – New Produce ... Preventive Controls for Human Foods (final)

Purdue University Cooperative Extension Service is an equal access/equal opportunity institution.

Questions???


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