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The Importance of a Quality Fit Testing Program

One of the simplest things managers can do to prepare employees to succeed in a hazardous environment is to provide access to the proper personal protective equipment.   The right equipment is important, and knowing how to put on that equipment is critical for the health and safety of the staff.

A good fit testing program follows OSHA standard and guidelines. Due to the fact that fit testing can be life saving, there are strict rules in place that should be followed when teaching the proper “donning and doffing” technique. Here are some questions we thought might help you prepare your staff for this critical training.

What exactly is “fit testing”?

Fit Testing is the test of the actual skin to mask fit to make sure no particles or contaminants are getting through your respirator. The goal is to make it air tight so you are breathing clean air.

 

Is it a one time test?

No. Individuals need to be tested annually. Interestingly, facial features are constantly changing. Therefore, the mask that fit you a year ago might not be the right fit this year. This is why when fit testing occurs, you are not allowed to have any facial hair. Other features like scars, plastic surgery, dentures, and certain oral surgeries are reasons to fit test again.

 

How does the process work?

There are seven steps when it comes to fit testing, each of which take about seven minutes to do. There is a sensitivity test, exercises, and the rainbow passage you must read after every yearly test. The rainbow passage is a passage used by OSHA that goes through all the movements and motions of your mouth. It is essentially a speech pathology passage. Exercises include jogging in place, bending over and moving your head side to side and up and down.

 

How do I choose a fit test company?

Fit Testing, while simple, is not something that should be shortchanged. Whomever is providing the testing protocol should plan on spending at least 15-30 minutes per person.  They should also provide proof that they follow the steps outlined in OSHA guidelines.  Having fit testers that also use equipment themselves is also good practice since they have personal experience using this equipment.

 

Are there different types of Fit Tests?

Yes. There are two types of fit tests: quantitative and qualitative. Qualitative fit testing relies on your sense of taste and smell. Qualitative tests do not measure the amount of the irritant sprayed, it only tests whether or not your mask is protecting you from leakage. Quantitative tests are normally used for half-mask respirators. They only cover your nose and mouth. During this test, a machine is used to measure the amount, if any, of leakage into the mask.

 

What if my staff is too busy to leave our location to receive their fit testing?

Emilcott can arrange to come onsite to fit test for larger numbers of employees. We even have a bus that can provide fit testing to employees in the field.

 

How do I sign up?

You can call and make an appointment with us at 973-538-1110 or contact us on our website with a question.


6 Indoor Air Quality Tips for Buildings at Risk of Having Poor Air Quality

Are your building occupants complaining of symptoms like itchy eyes, coughs, allergies and headaches? Have you noticed a persistent and unusual odor in your building lately? You’d be surprised at how common it is to have poor indoor air quality—and how often it is caused by a distinct source with an easy fix. In our 30 years of air quality testing, we’ve seen all kinds of problems due to poor air handling maintenance: from HVAC filters that haven’t been changed in years to pigeons roosting near the air intake and leaving feathers and droppings to forgotten insulation and trash inside the AHU after a contracting job. These problems are not unusual, and they’re not going away.

 

Air quality concerns and problems aren’t going away either. In fact, they seem to be on the rise, especially with growing reports of poor outdoor air quality across the globe.

 

To mitigate these growing concerns, we’ve compiled 6 important air quality tips that we recommend all property managers consider when building issues arise:

 

#1: Confirm adequate ventilation and air flow. When evaluating operations and activities in the building, are functions and spaces properly located and ventilated? For example, printers can often give off fire particulates and kitchenettes and bathroom exhausts can create unpleasant odors. Making sure adequate ventilation and air flow are present relative to the purpose of the space can go a long way toward staving off complaints.

 

#2: Revisit your building’s cleaning services. Are building cleaning schedules adequate? How frequently are you preventing dirt from entering the building at the doors and windows? Does the housekeeping schedule provide adequate removal of dust and particulates? Do they vacuum the carpets and dust the shelves with regularity? Simple spot checks on these services can often provide clues as to the efficacy of cleaning services.

 

#3: Create a water intrusion policy. Do you have a formal policy or procedure for responding to water intrusion? Timely and appropriate response (within 24-48 hours) can eliminate the potential for mold. Be specific in your plan and consider differences in policies, procedures and timing regarding the source of the water intrusion (e.g., rainwater vs. toilet backup.)

 

#4: Develop a procedure for complaints. Do you have a standard operating procedure for responding to complaints? When a complaint occurs from a building occupant or a visitor, do you have a standard operating procedure for investigating and responding to the complaint? Often when complaints are ignored, there can be the perception that building air quality has worsened because no one is actively managing it…so make sure that you are proactively managing it!

 

#5: Maintain your HVAC filters. Have the HVAC filters been regularly and properly maintained? Filters must be changed on an appropriate schedule. We have found that even filters that have been changed quarterly create the potential for dust-related allergies and/or bacterial and fungal growth, which can aggressively impact building occupants. And remember – not all filters are the same so it is important you use filters that are of good quality.

 

#6: Visit the air handler. When was the last time you visited the air handler? Beyond filters, consider checking that water and dust are not accumulating inside the air handler. The entire AHU from outdoor air intake to discharge into the building, supply ducts, and return ducts all warrant inspection to identify problems.

 

So what do you do if you find you have a more serious air quality problem? Indoor air quality should always be evaluated relative to outdoor air quality. If outdoor air quality is good, increasing ventilations may be sufficient. However, when outdoor air quality is an issue, active management of air inside the building envelope is critical.

 

In an age where air quality in increasingly challenging to manage, proactive measurement and maintenance of indoor air quality – as suggested in our 6 tips above – can be critical to maintaining employee health and wellness.


EPA Implements New Rules for Hazardous Waste Generators

EPA Implements New Rules for Hazardous Waste Generators

New Jersey and Pennsylvania have adopted the EPA’s Hazardous Waste Generator Improvements Rule. This revised rule for hazardous waste generators became effective May 30, 2017 for states that do not have an EPA authorized RCRA program (Iowa and Alaska) and for states (such as New Jersey and Pennsylvania) that have adopted the rule by reference.

  • Other Authorized States run the RCRA program in their state and, thus, will go through the state adoption & authorization process for this new RCRA rule. Authorized states will have to pick up the more stringent provisions, typically by July 1, 2018 (or July 1, 2019 if state law change is needed).

What Does This Mean to Your Site’s Operations?

  • The new rule allows for Very Small (formally “Conditionally Exempt Small”) and Small Quantity Generators (SQG) to have an episodic increase in hazardous waste production without resulting in a change in hazardous waste generator status. There are notification, marking, labeling, storage, and recordkeeping requirements associated with this provision.
  • Additional notification requirements are in effect for Small and Large Quantity Generators.
  • In addition to determining the type of waste that has been generated, hazardous waste generators will have to determine the physical and health hazards of the waste. Hazardous waste container marking requirements include identifying the physical and health hazards of the waste.

Key changes to the Hazardous Waste Generators requirements:

  • Reorganization of the regulatory requirements placing all of the generator requirements in 40 CFR Part 262. The regulation has been reorganized, and the rules are easier to find.
  • New for Small Quantity Generators
    • Conditionally Exempt Small Quantity Generator (CESQG) will now be designated as a Very Small Quantity Generator (VSQG).
    • Creation of the “episodic event” provision which allows SQG and VSQG to generate a volume of waste (that would have previously moved them to a higher-level generator category) with certain limitations. The generator category would not change as a result of an “episodic event”. Note: An increase in production resulting in an increase of waste generation does not qualify as an “episodic event”.
    • VSQG under the ownership of a Large Quantity Generator (LQG) may transport their waste to the LQG for disposal. Note – there are DOT requirements and NJDEP hazardous waste transporter requirements which are not considered as part of this ruling.
    • New rules require SQG’s to submit a notification to the EPA every 4 years beginning in 2021. The notification serves as verification that the SQG is still in operation.
  • New for Large Quantity Generators
    • LQG’s need to notify the EPA or their authorized state if the facility is closing.
    • LQG’s must create and submit a Contingency Plan quick reference guide for emergency responders. The content requirements are found in 40 CFR 260.262. Note: LQG’s with existing Contingency Plans do not need to create a quick reference guide until the next Contingency Plan revision.
  • Hazardous waste container markings requirements now include identification of the hazards of the contents (this can be accomplished with GHS markings and/or DOT markings) in addition to marking as “Hazardous Waste”.

Clarifications to the Hazardous Waste Generators requirements:

  • 3-day rule for moving waste in Satellite Accumulation Areas to a Central Accumulation Area has been clarified to mean 3 calendar days.
  • New rules clarify that a hazardous waste generator can only have one generator category per month. If an activity makes a generator a LQG at a given moment, they are a LQG for the entire month.
  • New rules clarify that solid and hazardous waste determinations must be made at the point of generation before any dilution, mixing, or other alteration of the waste occurs.
  • Storage areas for hazardous waste that do not meet the definition of satellite accumulation areas are called “central accumulation areas” (CAA). The new rules clarify that there can be more than on CAA and that “central” does not mean that it is in the center of the facility.
  • New rules clarify that SQGs and LQGs must identify the RCRA waste code(s) associated with their waste. Hazardous waste determination has always been a requirement for generators; however, many relied on disposal vendor to identify the waste code. The new rules clarify that this is a requirement of the hazardous waste generator.

HOW CAN EMILCOTT HELP?

Emilcott can assist with getting your operation aligned with the Hazardous Waste Generator Improvements Final Rule. Every day Emilcott’s experienced professionals help hazardous waste generators understand the new requirements, and how the rule affects their operations. This is your opportunity to learn more about what you can do to comply with the new rule.

Emilcott can provide a broad range of technical support related to RCRA Compliance:

  • Training: Client-needs specific training for site-wide RCRA Awareness for waste generators and shipment manifest signers.
  • Program Development: Update site programs and implementation methods to reflect new requirements.
  • Prepare RCRA Regulatory Submissions: Biennial Reports, Notifications, and Status Updates
  • Gap Assessments: Identify potential gaps in compliance related to program implementation or operational changes.

Please give us a call – we can help you meet your goals!


Mid-year Regulatory Submissions Reminder

Just as we all take a deep breath after getting the CRTK submissions on March 1 — now it is time to get started gathering the information for the next round of submissions.  We’ve pulled together our Spring and Summer submission list.  Similar to our 1Q2017 Regulatory Submission Reminder , we detail information about the regulations that require submissions from mid-April through July 2017 along with specific dates to help you ensure that everything is submitted on time! 

For more information and for a more comprehensive outline of each submission and what is required, including links to government pages, download our FREE ebook “ Spring/Summer Regulatory Submissions Reminder”.

Please feel free to call us at 973-538-1110 to speak to an EHS Consultant regarding any further questions you may have or for help with your regulatory submissions or safety compliance. 


UPDATED: When Dust Is Not Just Dust: New silica guidelines you need to know now

* UPDATE: The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) has now delayed enforcement of this new standard to begin on September 23, 2017 as opposed to the original date of June 23, 2017.  

Silica is the second most common mineral in the crust of the earth.  Silica can be found in materials like sand, concrete, brick, block, stone and mortar. Overexposure to dust that contains crystalline silica can cause scar tissue to form in the lungs, which reduces the lungs ability to function. The resulting disease is called Silicosis.  It is an incurable lung disease that sometimes causes bronchitis and puts victims at increased risk of tuberculosis, and may lead to lung cancer.

All this disease, from breathing in dust that is not just dust.

The hazards of breathing crystalline silica have been known by stone cutters and quarrymen for eons. In the 1700’s Bernardino Ramazzini (considered the father of occupational medicine) wrote about stone cutter “maladies” of cough, asthmatic afflictions, and consumption resulting from breathing in rough, sharp and jagged splinters of stone. 

In 1938, the US Secretary of Labor started the “Stop Silicosis” campaign after hundreds of workers died from silicosis while working on construction of the Gauley Bridge tunnel. 

In the 1990’s, the Department of Labor recognized that worker exposure to crystalline silica still caused a significant health hazard and once again rolled out a campaign to raise awareness and highlight safe work practices “It’s Just Not Dust”.  The source of exposure to airborne crystalline silica today is not predominately in tunnel construction, it occurs with the increased use of dry cutting, drilling and grinding of concrete and masonry material in construction along with the popularity of stone surfaces in residential and commercial buildings.

In 2016 OSHA published a detailed new standard for OSHA’s new standard for Crystalline Silica. And now compliance dates are approaching with June 23, 2017 for the Construction Industry and most of General Industry scheduled for June 23, 2018.

How are you set for June 23, 2017 compliance with the Construction Industry requirements your business must follow in order to protect your employees against the effects of crystalline silica.

Here are six questions to ask:

  1. Are your site work protocols and equipment aligned with the new “Safe Methods for Working with Silica” issued by OSHA?
  2. Are you confident any recently performed a worker exposure to crystalline silica measurements reflect the new exposure control methods issued by OSHA in regulation §1926.1153 Respirable crystalline silica.
  3. Do you have a respirator program for your employees wearing respirators (even dust masks?)
  4. Have your employees wearing respirators been medically cleared to wear these respirators?
  5. Are your employees receiving training about the dangers of crystalline silica?
  6. Do you have records of your training?

If you answered no to any of these question and your employees are potentially exposed to crystalline silica, you may not be in compliance the latest OSHA standards.  Contact Emilcott today or check out our full compliance checklist.  We offer comprehensive solutions to:

  • Write programs customized to your business that comply with the OSHA standard
  • Provide training on using the methods recommended by OSHA in specified exposure control methods
  • Help you meet the requirements on communicating the hazards of silica to be in compliance with OSHA hazard communication regulations
  • Train your employees at their work site on your schedule
  • Provide on site exposure assessments for silica.

7 considerations for your next site-specific health and safety plan

(OSHA 29 CFR: 1926.21, 1925.65, 1910.120)

1. Do you have the right programs, processes and defensible data to prove you are actively guarding the health and safety of your workers?   

Under the exclusive remedy provision of workers compensation laws, most workers do not sue their employers.  This worker compensation protection, however, does not cover third parties who then become the targets of plaintiff attorneys’ looking to claim damages. 

2. Are you comfortable with the level of liability you would assume in the event that a worker was injured on a construction site?

Have you reviewed your professional liability coverage?  Certain locations (e.g., New York City) have experienced significant increases in claims for worker injuries on construction sites.  As a result, many insurance companies have dropped or limited their professional liability coverage for those companies that directly or indirectly manage or provide oversite of health and safety activities on a construction project.  Even if you feel you have no responsibility, liability exposure may be significant if you are sued as a third party.

3. Are your employees apprised of their obligation under OSHA’s multi-employer workplace policy?

In the event a worker is injured or killed on the site because he or she failed to take proper precautions, the first liability is with the company who employed the worker.  However, OSHA has redefined the definition of employer to include other companies or agencies that are also working on the construction project.  For example, OSHA has identified engineering firms as a Controlling Employer because of their oversite role on a project.  This not only exposes an engineering firm to OSHA citations but lays the groundwork for being named as a contributing third party in the accident.  This OSHA policy is complicated and requires a prescriptive company procedure to manage the conduct of employees working on a construction site.  It is critical to proactively prepare your staff for situations like this and others is step one in managing your liability on the site. 

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=28265

4. Is the construction site in proximity to high density populations? 
Residences, roadways, shopping areas, pubic venues?

With certain contaminants and toxins, weather conditions can carry dusts, vapors and gases up to 2 miles away from the site of origination.  Even if a smell or toxin is not considered harmful at the concentration levels at which it is sensed, it can cause alarm and create public unrest that has the potential to disrupt operations unnecessarily.  Having a means to collect data to measure potential contaminants potentially emitted from a construction site, provides strong defensible position that people are not being harmed from construction activities.

5. Is the construction site in proximity to vulnerable populations like schools or hospitals?

Routine operations such as excavation and site preparation create dust.  While not all dust is harmful, air quality continues to be a major concern for vulnerable populations (sensitive receptors).  Proactively monitoring dust in the air continuously and maintaining transparency with the public can prevent complaints and claims of disease coming from toxic exposures.

6. Are you comfortable with the level of liability you would assume in the event that an outside group claimed they had been exposed to a toxin from your site?

Lawsuits pertaining to public exposure to toxins require the defendant (the company) to prove a negative.  In other words, you must show that the plaintiff was not exposed or that their injury did not result from toxic exposure originating from your construction site.  Proving a negative is extremely difficult unless you have sufficient environmental data covering the specific timeframe when the plaintiff claims exposure.  Real-time monitoring provides that level of data necessary to guard against this type of claim.  Furthermore, real time data allows you ensure that any toxic release is identified immediately, managed, and documented as such before it reaches toxic levels.

7. Does your firm have a core competency in health and safety that can continuously manage both worker health and public health with technology?

Leading environmental and engineering firms have begun to bundle health and safety with engineering and construction management for a comprehensive, turnkey approach to public and worker health and safety.  Ensuring your staff has the technology and the training necessary to deploy equipment, oversee multi-employer safety, and monitor toxins in real time can not only create efficiencies but also provide third party credibility and even outsource liability in certain cases.

If you have specific questions or concerns about these issues, please feel free to reach out to discuss your specific needs at info@emilcott.com.


Checking the list… Annual Regulatory Reporting Checklist

2016 has been full of surprises but it is never good to be surprised when it comes to annual regulatory reporting! There are many things that we can do to minimize surprises and last minute scrambling.  The time to start the process is in the beginning of January 2017.

First – identify the regulatory submissions required for your organization and the deadlines for filing. These include submissions of the EPA Community Right to Know (CRTK) Survey and the Hazardous Waste Biennial Report (or Annual for some states) which are due March 1st. Also on the horizon are the EPA Toxics Release Inventory (TRI) and the New Jersey Release and Pollution Prevention Report (RPPR) both due July 1st.

The compilation and reporting process is less stressful and yields better results if it is started early and a strategy is developed with deadlines in mind.  Waiting until the last minute not only increases the potential for making mistakes, it is sometimes hard to get the submission through due to high volume of users on the same electronic filing system.

Here is my personal January 1st kick-off list that should make the time-consuming process of CRTK and TRI reporting easier to handle….

Download the checklist e-book here!

1)      Start requesting and gathering all the information needed for these submittals.

  1. 2016 purchasing records of the chemicals you are reporting
  2. 2016 production logs where these chemicals are used
  3. 2016 waste information
  4. 2016 recycling information for any reported chemicals that were recycled
  5. 2016 air emission inventory

2)      Develop and write down a comprehensive set of due dates so that you have time to review information as it comes in. If the requested data is late, have a plan to follow up or find another source because the deadline is not going to change!

3)      Review the rules early to avoid unpleasant surprises.

4)      Allow time for anomalies and additional fact-finding. Reported amounts from different sources may not match. If you find that is the case, it is your job to figure out why and that always adds more time to the already challenging process.

Emilcott’s clients depend on our environmental knowledge and organizational capabilities to gather the required information on time and give them fair warning if there is trouble ahead.  My best advice for successful reporting-don’t wait until the last minute.  Much like filing your income taxes on April 15th, waiting until February to gather the information for the CRTK or starting in June for the TRI will be stressful and could result in costly errors. So, what am I doing today?  Like Santa, I’m checking my own list twice!

Have you been meeting the CRTK and TRI deadline? If yes, can you offer additional advice or do you have particular steps that you take to get the submission process rolling?


Portable Space Heater Safety in the Workplace

There are no federal workplace safety rules that prohibit portable electric space heaters in the workplace and statistics regarding commercial property damage caused by space heaters are not readily available. However, the U.S. Consumer Product Safety Commission estimates that more than 25,000 residential fires every year are associated with the use of space heaters—resulting in more than 300 deaths. In addition, an estimated 6,000 people every year receive emergency room care for burn injuries associated with contacting the hot surfaces of room heaters, mostly in non-fire situations.

 

So, as the cold weather sets in, employers may be considering if they should permit portable space heaters or actually discourage their use—even outright ban them. However, some work areas can just be cold. This is a frequent problem with older buildings or those areas near entries or doors.  Adding to the challenge, there are many employees with medical conditions that require extra warmth above what is normally considered comfortable and a space heater can fulfill that accommodation without heating up everyone else’s work space.

 

The good news—like so many other hazards, portable space heaters can be used safely if proper care and precautions are implemented. Any employer permitting the use of portable space heaters should highly consider a written policy to spell out exactly what is proper care and sufficient precautions. It could possibly prevent fires, injuries and even death.

 

Firstly, OSHA rules do require that electrical equipment must be used according to manufacturer specifications on the unit’s label and in the user manual. Therefore, only employer-purchased and issued space heaters with adequate safety features should be used.  Generally, regardless of the types of space heaters, the following applies:

 

  • Choose only thermostatically controlled heaters to avoid wasting energy or overheating
  • Most heaters come with a general sizing table, so select heaters of varying sizes to fit the size of the areas that needs heating
  • Position heaters on a level surface away from foot traffic
  • All space heaters must be kept away from any combustible material
  • Heaters should have a tip-over automatic shut down feature and a grounded three-pronged plug
  • Require that space heaters always be turned off when the area is not occupied—possibly unplugged at night
  • Plug heaters directly into a wall outlet and in plain sight
  • Remind employees that nothing should ever be placed on top of or touching the space heater
  • Heaters missing guards, control knobs, feet, frayed cords, or otherwise damaged must be taken out of service
  • Discontinue use of the heater if the heater causes the electrical circuit breaker to trip

 

It is not recommended that unvented combustion space heaters, such as those fueled by propane, natural gas, and kerosene, be used for heating inside areas. They introduce unwanted combustion products into the environment—including nitrogen oxides, carbon monoxide, and water vapor—and deplete air in the space. Check for local regulations banning unvented kerosene and natural gas heaters.

 

Office Safety is covered under the OSHA General Duty Clause. Good office “housekeeping” and safety policies can prevent injuries. If you have questions about office safety policy, Emilcott can help.


On the road with Emilcott…

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This week we paid a visit to the 101st Annual NJ League of Municipalities Conference in Atlantic City. We’ve had a terrific week, meeting new friends, partners, and customers, as well as reconnecting with old ones!  This was our first attempt to drive our state-of-the-art fit testing van into a convention hall, and we are proud to announce it went off without a hitch.

In celebration of our successful week, we are sharing our free Respiratory Protection e-book with an inspection, donning & doffing checklist.

Click here to download.

Thank you to everyone who stopped by our booth this week, and if you didn’t get a chance to visit our van at the convention center, we’d be happy to drive to your place next!  Just call us.

1-800-886-3645.


Does Your Facility Need to File an Annual Community Right to Know Survey?

Community Right to Know (CRTK) Surveys must be completed and submitted by March 1 of each year by all industries with a listed NAICS code. A listing of applicable NAICS codes can be found at the following url: http://www.nj.gov/dep/enforcement/opppc/rtknaics.pdf.

The New Jersey Department of Environmental Protection (NJDEP) is initiating an enforcement effort against all entities that have not filed their 2015 CRTK Survey and did not receive an exemption from filing. If your company has not filed a CRTK Survey for 2015 and has not received an exemption, the NJDEP is encouraging entities to file. Filing before being forced to do so by the NJDEP may reduce the risk of a monetary fine.

If you are unsure whether you should file a survey or file for an exemption, here are the basics:

Requirements for Filing a CRTK Survey

1. Your facility is in a regulated NAICS Code

2. Your facility stored reportable quantities of regulated substances as listed in:

http://www.nj.gov/dep/enforcement/opppc/crtk/ehsalpha.pdf and

http://www.nj.gov/dep/enforcement/opppc/crtk/ehscasno.pdf

For an Exemption:

You must submit a CRTK Reporting Exemption Form which you can find at: http://www.nj.gov/dep/opppc/crtk/crtkrptexemptfm.html , if your facility meets one of the following criteria:

1. Your facility is in a regulated NAICS Code however NO environmental hazardous substances (as

listed in:) were present in 2015

2. Listed substances were present but below the applicable reporting thresholds;

3. Your facility is in a regulated NAICS Code and you meet the definition of an unstaffed site

(“Unstaffed site” means a remotely operated site, not contiguous to any other staffed sites and at which no full-time or part-time employees are assigned at any time except for maintenance or emergency repair – N.J.A.C. 7:1G1.2 (h)); or

4. If you determine that your facilities are in a regulated NAICS Code and ALL FACILITIES YOU OWN IN NJ conduct administrative office functions only.

Emilcott professionals are here to help if you determine that your facility needs to file a 2015 CRTK Survey or file for an exemption. Emilcott can also act as a liaison between your organization and the New Jersey Department of Environmental Protection.


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