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A MANAGER’S GUIDE TO

PROCESS SAFETY MANAGEMENT

The Industrial Refrigeration Consortium


Do you have direct or oversight responsibility for one or more plants that
use anhydrous ammonia as a refrigerant? If yes, then this guide is for you!

In this guide, you will find factual information in a question and answer
format explaining one of the more significant OSHA standards released
within the last 20 years – the Process Safety Management (PSM) Standard.

About the IRC The Industrial Refrigeration Consortium (IRC) is a collaborative effort between the
University of Wisconsin-Madison and industry. Together, our mission is to
improve the safety, efficiency, and productivity of industrial refrigeration systems
and technologies.

The IRC offers a unique combination of complementary resources that include


academic qualifications, technical expertise, and practical experience. We provide
objective information that is not biased by an affiliation with any particular
organization.

These services provide substantial benefits to our members and to the entire
refrigeration industry. The knowledge that we create and distribute helps to
improve the capabilities of individuals at all levels. Increased knowledge can help
improve safety, reduce operating costs, increase productivity, and make your
organization more competitive.

The IRC is wholly funded by external funds.

Contact Information Industrial Refrigeration Consortium


1415 Engineering Drive
Suite 2342
Madison, WI 53706

Toll-free: 866-635-4721
Local: 608-262-8220
Fax: 608-262-6209

Douglas T. Reindl, Director

www.irc.wisc.edu

© 2006 All Rights Reserved


What is PSM? PSM or Process Safety Management refers to an OSHA regulation that went into
effect on May 26, 1992. It is codified in the Federal Register under Title 29
(Department of Labor) in part 1910 (Occupational Safety and Health Standards)
and subpart H (Hazardous Substances). It is also referred to by its numerical
reference within Title 29 as “1910.119.”

Is my plant covered under The PSM standard applies to processes that use or store hazardous or flammable
this standard? substances. The standard lists 137 different hazardous chemicals and threshold
quantities (TQ) above which employers are required to develop and implement
PSM programs. Examples of three common chemicals are shown below.

Chemical Threshold Quantity Typical Uses/Sources


Anhydrous ammonia 10,000 lb industrial refrigeration
Chlorine 1,500 lb water treatment, biocide
Hydrogen sulfide 1,500 lb byproduct of organic matter breakdown

The PSM standard also applies to processes that use or store more than 10,000 lb of
flammables (such as methane or natural gas and propane).

Are there exceptions or Yes. The following are exemptions related to flammables: (1) hydrocarbon fuels
exemptions from coverage used solely for workplace consumption as a fuel (e.g., propane used for comfort
under this standard? heating, gasoline for vehicle refueling) if the fuels are not a part of a process
containing another highly hazardous chemical covered by the standard, and (2)
flammable liquids stored in atmospheric tanks or transferred which are kept below
their normal boiling point without benefit of chilling or refrigeration. Also exempt
from the provisions of the PSM standard are retail facilities, oil/gas well drilling
operations, and unoccupied remote facilities.

Can you summarize the The core of the PSM standard is embodied in 14 interrelated elements. Part (a) of
PSM standard? the standard covers applicability and part (b) definitions. The heart of the PSM
standard begins with part (c) and continues through part (p). The table on the
following page provides a brief summary of the PSM elements in 1910.119.

The elements of PSM keep Consider the simplest scenario where a company owns and operates a plant that
referring to “employer”, houses a process covered by the PSM standard. In this case, the “employer” is the
who is the “employer”? company that owns and operates the plant. Other cases that arise can be more
complicated when multiple employers are connected with a work location that
houses a covered process. Ultimately, the host employer that potentially exposes
his employees to a hazardous chemical is responsible for insuring that a PSM
program is developed an implemented. The host employer cannot parlay this
responsibility off to a third party even when a third party contractor may be
operating the covered process.

If my plant is not covered No. Because you are an employer, you have a general duty responsibility to
under PSM, I don’t have to provide a workplace free from recognized hazards. As such, both OSHA and EPA
do anything - correct? have the ability to apply their “General Duty Clause” which requires that you
operate your facilities (including those systems that may have less than threshold
quantities of hazardous chemicals or flammables) consistent with industry-
recognized good practice. At a minimum under the general duty clause, you need
to identify and assess hazards of releases of hazardous substances and/or
flammables; design and maintain a safe facility to prevent those releases; and
minimize the consequences of releases that may occur.

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PSM PROGRAM SUMMARY

Element Requirement

(c) Employee
Requires employee involvement in developing PSM program, particularly in the area of hazard evaluation.
Participation

(d) Process Safety Requires the employer to compile information relating to the nature of the chemical (or flammable)
Information hazards involved, process technology, and process equipment.

Requires the employer to conduct a careful analysis of hazards involved with the process. Using one of
(e) Process Hazard
several formal hazard analysis techniques, a team identifies, evaluates, and recommends measures to
Analysis
eliminate, mitigate, or control hazards.

(f) Operating Requires the employer to develop and implement written operating procedures for the covered process
Procedures over all phases of its operation including safe work practices.

Requires employers to train all involved (including contractors) in operating the covered process on the
(g) Training hazards, operating procedures (normal & emergency), and safe work practices. The training is required
for each person before they begin operating a covered process.

For all contractors involved directly and in areas adjacent to covered processes, employers need to
evaluate the contractor’s capabilities and safety history to assess their suitability for safe performance. In
(h) Contractors
addition, all contractors expected to become involved in operating the covered process must receive
training prior to their involvement in the operation.

Requires that employers perform a detailed review of a new or modified (changed) system to insure the
(i) Pre-Startup
design is appropriate, construction adheres to design specifications, operating procedures are available,
Safety Review
training is complete, process hazard analysis is complete, and all process safety information is current.

Requires that employers develop and implement a methodical program for performing appropriate
(j) Mechanical
maintenance and equipment inspection/testing at proper frequencies to uncover equipment deficiencies
Integrity
before they fail.

Requires that employers develop a formal program to prevent fire and explosions from occurring while
(k) Hot Work
conducting hot work (welding, cutting, brazing, grinding, etc.) in and around the covered process.

Documented procedures aimed at insuring safe system operation as changes to the system occur. The
(l) Management
management of change process guides updates or development to process safety information, process
of Change
hazard analyses, operating procedures, and training to insure all elements of the PSM program are current.

Requires that employers investigate actual incidents or near-misses to understand the factors that
(m) Incident
contributed to the incident and to develop/resolve recommendations aimed at preventing their future
Investigation
occurrence. A formal incident investigation needs to begin with 48 hrs of an incident.

Requires that employers conduct pre-planning for emergencies that may arise at the facility. At a
(n) Emergency
minimum, the emergency planning needs to include notification procedures, escape routes, alarm systems,
Planning and
and plant-wide training. More intensive efforts are required for situations where employees are expected
Response
to actively become involved in mitigating incidents.

Involves critically evaluating a PSM program and the extent of its implementation at least every 3 years.
(o) Audits The audit must certify the plant is in compliance with the standard or identify areas of non-compliance that
the plant needs to address to bring the program back into compliance.

(p) Trade Secrets Allows employers to protect those aspects of their covered process considered a trade secret.

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What steps are involved in The first step to creating a successful PSM program is committing the necessary
establishing a PSM resources to create and implement a program. Often the first internal resource
program? applied to this effort is the appointment of a lead person called a “PSM Leader” or
“PSM Coordinator” that will have primary responsibility for program development.
This responsible and detailed-oriented individual then begins the process of
involving other employees to establish the program elements. Some organizations
have successfully engaged outside consultants to advise or contribute to some
aspects of program development but consultants cannot replace internal resources
as the primary developer in their program. Although OSHA does not require the
designation of a specific individual with this responsibility, EPA does.

What is required for initial The initial development of a PSM program can be quite resource intensive. The
PSM program actual staffing requirements will vary widely depending on the size of the plant and
development? the state of documentation for the covered process (e.g. refrigeration system).
When it promulgated the PSM standard, OSHA provided estimates of financial
impacts to organizations covered by the scope of the standard. OSHA estimated
that for the first five years of compliance, “the worst-case profit impacts would
average 1.1 percent for large establishments and 3.2 percent for small
establishments” (OSHA PSM Preamble). Organizations comprised of multiple
locations with covered processes, can effectively leverage costs by developing a
“model program” for all plants. That model program is then refined based on site-
specific processes, equipment, and practices.

What are the minimum The minimum requirements for compliance are for a plant to develop, implement,
requirements? and maintain all 14 elements as defined in the PSM standard!

Can I “buy” a PSM Since the PSM Standard came into effect, there have been organizations that have
program? offered “canned” PSM programs. These canned programs, in and of themselves,
are generally not acceptable since they are not customized to a specific covered
process or operation within a plant. If your organization chooses to purchase a
canned PSM program, consider it only as a template upon which to build your own
PSM program. Be sure the elements are customized for your own plant’s covered
process and reflect your own plant’s operation. Also remember that the first
element of the PSM standard is “employee participation.” As such, make sure your
employees are truly involved with the development of the PSM program.

Can I use a finished PSM Some organizations with multiple plants have created a single model PSM program.
program at another facility The model program creates a degree of uniformity and consistency across
within the company? individual plant’s programs but still needs to be customized each plant.

How long does it take to Often, companies view PSM as another initiative to be completed within a
complete a PSM program? reasonable time horizon. Unfortunately, this viewpoint is not congruent with both
the spirit and requirements of PSM. PSM needs to be viewed as a living program
to be maintained as long as the plant is operating the covered process(es).

What are typical resource As with development, the on-going human-resource requirements to maintain a
requirements for on-going PSM program will vary widely. If a plant or facility undergoes significant changes
maintenance of PSM? due to expansion, remodeling, or retrofit, the level of effort required to keep a
program current can be considerable. If a facility is “mature” and undergoes
change infrequently, the resource requirements are much less intensive. The size of
the facility will also drive resource needs. Larger facilities tend to have more staff
required to effectively manage and maintain the plant’s PSM program. Ideally,
much of what is involved with PSM should be assimilated into the plant’s normal
culture of operation. Once rooted, maintaining PSM becomes considerably simpler
since the resource requirement does not lie within one or a small group of
individuals.

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What are the on-going Since many plants are not static, the costs associated with the on-going
costs to maintain the PSM maintenance of a PSM program are highly variable. Plants that grow or change
program? process equipment frequently will have higher on-going resource requirements for
PSM as compared to plants that are built and never change.

What are the on-going Once a PSM program is initially developed and implemented, there are a number of
activities of a PSM activities within the scope of the standard that require on-going support.
program?
PSM Element On-going Requirement Frequency
(c) Employee Participation Employees involved Continuous
(e) Process Hazard Analysis Update and re-validate 5 yrs
(f) Operating Procedures Certified current 1 yr
(g) Training Refresher training 3 yrs
(h) Contractors Evaluate contractor performance Periodically1
(j) Mechanical Integrity Inspections and tests Periodically2
(l) Management of Change Update program during plant changes As-needed
(m) Incident Investigation Investigate and develop recommendations As-needed
(o) Compliance Audit Audit PSM program 3 yrs
1
No prescriptive requirement in PSM regulation – an annual evaluation is recommended.
2
The frequency of inspections and tests shall be consistent with manufacturers' recommendations,
good engineering practices, and more frequently if necessary by prior operating experience.

What are typical costs for The typical costs associated with fines for non-compliance with OSHA standards
compliance vs. costs for are small. Based on a cost-analysis of OSHA fines for PSM infractions, the
non-compliance? average summation of violations is approximately $18,000. This is at least two
orders of magnitude smaller than the potential losses associated with plant facilities,
equipment, productivity, and employees. Don’t make “fine avoidance” a primary
goal of your plant’s PSM program!

What are the implications Identified areas of non-compliance are grounds for citations issued against the
of non-compliance? employer. Citations for areas of non-compliance are categorized by OSHA:
Violation Description Fine
Other-than- A violation directly related to job safety and health, but Up to $7,000
Serious likely not to cause death or serious physical harm. per violation
A violation where there is substantial probability that
Up to $7,000
Serious death or serious physical harm and that the employer
per violation
knew, or should have known, of the hazard.
A violation involves an employer intentionally and Up to $70,000
knowingly committing or a violation that the employer per violation,
commits with plain indifference to the law. The with a
Willful
employer either knows what they are doing constitutes a minimum of
violation, or is aware that a hazardous condition existed $5,000 per
and made no reasonable effort to eliminate it. violation
A violation where OSHA finds a substantially similar Up to $70,000
Repeated
violation during a re-inspection. for each repeat
Failure to Employer failing to correct a previously cited violation Up to $7,000
Abate beyond the prescribed abatement date. per day

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Can I be personally liable In addition to OSHA citations and penalties, the U.S. Department of Justice may
for non-compliance? bring a criminal action against an employer whose willful violation of a standard
leads to the death of an employee. If a court convicts such an employer, the offense
is punishable by a court-imposed fine or imprisonment for up to six months, or
both. The court may impose a fine for a criminal conviction of up to $250,000 for
an individual or $500,000 for a corporation.

Are there benefits to my Apart from significant reductions in unplanned equipment break-downs and failures
business operations which lead to improved operating reliability, is improved system operating
beyond just “complying efficiency. Successful PSM programs involve close attention to the details. It is
with the standard?” that shift in mindset that carries over into other aspects of the operation that allow
staff to extend their knowledge, skills, and capability to improve the overall
efficiency of the systems they operate. Here are other dimensions to the benefits
from developing and maintaining strong PSM programs.

• Protection of an Investment: look at PSM as a tool that will help you protect
your investment in plant property, equipment, buildings, and other
infrastructure. Keep in mind that these physical assets are all essential to your
plant's ability to produce products. What value do you assign to avoiding a
significant business interruption or infrastructure loss? An effective PSM
program will help you avoid unplanned production interruptions and protect
your investment in plant infrastructure!
• Protection of plant employees: Without employees, it is difficult to
manufacture products. Your organization has made a considerable investment
in many of its employees (especially skilled trades and professional staff) -
What is the value of their loss? What is their "replacement" value? An
effective PSM program aids in protecting your investment in people!
• Protection of market share: If your plant experiences a catastrophe incident
with a subsequent disruption in your plant operations, it could lead to erosion
or loss of your corporation's market share. What value do you place on
protecting your market share? An effective PSM program will help you not
only protect market share but meet the demands of a growing market share.
• Community stewardship: Incidents at your plant that allow the release of
hazardous chemicals beyond its boundaries can adversely impact the local
community. What is the value of avoiding such mishaps and being a good
steward of the local community? An effective PSM program will minimize the
likelihood of large scale incidents that impact the surrounding community.
• Improvement of workplace: “quality of life”: Employees greatly appreciate a
workplace where risks to their health and safety are eliminated or minimized.
An effective PSM program will help you avoid the real loss in productivity that
occurs with a life-changing catastrophic event that can occur in a PSM-
complacent plant. Some anecdotal evidence has suggested that improved
workplace quality of life attributable to sound PSM programs has anchored
productivity gains. Boosted productivity contributes directly to the bottom line!
• Insurance and insurability: Increasingly, insurers are looking for plants to
have functional PSM programs to protect assets they insure. Without PSM,
your plant and the value of stored products may not be insurable. With a
healthy PSM program working in your plant, you are a better insurance risk –
ask your provider for a commensurate premium reduction.
• Goodwill: Most corporations have a considerable value in their “goodwill.”
Although goodwill is difficult to quantify, it is real. Incidents, accidents, and
regulatory action (fines) can erode goodwill. An effective PSM program will
help protect your organization’s goodwill.

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What indicators suggest • Purchasing excessive quantities of ammonia
poor PSM performance or • High employee turn-over
non-compliance? • Poor employee acceptance of the company and/or employee participation
• Increasing or high number of ammonia releases or near misses
• Increasing or high system downtime, particularly unplanned downtime

Are there other related There are a number of other related OSHA standards that intersect with PSM.
standards I should know These include: lockout/tagout (1910.147), respiratory protection (1910.134),
of? emergency action plans (1910.38(a)), emergency planning and response
(1910.120(q)), and others. Contact your organization’s safety director for further
information on other related standards. The related EPA regulation that
complements PSM is 40 CFR Part 68, “Accidental Release Prevention
Requirements: Risk Management Programs” under the Clean Air Act, 112(r)(7).

What are the additional A facility covered under RMP must conduct a hazard assessment, including an off-
requirements for the site consequence analysis (OCA) of accidents called the “worst-case and alternative
related EPA Accidental release scenarios”, provide a management program to ensure the program is
Release Prevention maintained, and submit a certified Risk Management Plan to the USEPA at least
Program? every 5 years. The prevention program elements essentially mirror the applicable
elements of the PSM program. However, the emergency response plan must
address proper first aid and medical treatment necessary to treat accidental human
exposure, procedures and use of emergency response equipment, and updating the
plan and training for all employees as appropriate. The plan must be coordinated
with the community emergency response plan developed by the Local Emergency
Planning Committee (LEPC) and first responders (fire department, emergency
medical services, police department, etc.).

Are there any state- Yes. Let’s first start with California. The California Accidental Release Prevention
specific PSM or RMP Program (CalARP) is a merging of the federal and state regulations for the
program requirements prevention of accidental releases of regulated toxic and flammable substances. The
(e.g., California, Delaware, California version of PSM is under Title 8, Section 5189 as “Process Safety
and New Jersey)? Management of Acutely Hazardous Materials.” The California version of the
standard includes some additional requirements beyond the Federal OSHA PSM
standard 1910.119. The California Accidental Release Prevention (CalARP)
Program includes the federal Accidental Release Prevention Program (RMP under
Title 40 Part 68) with certain additions specific to the state pursuant to Article 2,
Chapter 6.95, of the Health and Safety Code (HSC). There are also specific
Seismic Hazard Assessment requirements in designated earthquake areas.
For Delaware, potentially hazardous substances are regulated under the state’s
Accidental Release Prevention Regulation found in Title 7 Chapter 77 based upon
release rates which in some cases are lower than EPA threshold quantities and
includes reactive/explosive chemicals and some toxic and flammables not listed in
40 CFR 68. A facility is subject to the Federal RMP first (Section 5 of the State of
Delaware’s Accidental Release Prevention Regulation) first. If the substance and
process are not regulated by the EPA, the facility must check to see if Section 6 of
the Accidental Release Prevention Regulation is applicable. A facility can only be
subject to one program - first the federal and if not the federal program then the
‘Delaware Only’ program may be applicable. The owner or operator of a facility
that has substances or processes regulated under Section 6 must implement the
appropriate risk management program and register the appropriate risk management
plan with the State of Delaware Department of Natural Resources and
Environmental Control (DNREC).

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Are there any state-specific The New Jersey Toxic Catastrophe Prevention Act (TCPA) regulation insures that
PSM or RMP program owners or operators of covered facilities comply with provisions of both the state
requirements (e.g., and federal accidental release prevention (ARP) requirements. The NJ Toxic
California, Delaware, and Catastrophe Prevention Act, (N.J.S.A. 13:1K-19 et seq.) requires owners and
New Jersey)? operators of these facilities to have a Department of Environmental Protection
(DEP)-approved risk management program if they handle, use, manufacture, store
or have the capability of generating an extraordinarily hazardous substance (EHS)
at certain specified quantities. The threshold quantity for ammonia in NJ is 5,200
lb. In addition, NJ has more extensive operator training requirements for covered
processes using hazardous chemicals including ammonia.
Recognize that states can adopt more restrictive requirements than established by
federal law. Be sure to check your own state’s requirements.

Are there other related Yes. OSHA has Voluntary Protection Programs (VPP) designed to recognize and
OSHA programs that promote effective safety and health management. In VPP, management, labor, and
recognize exemplary safety OSHA team together to establish a cooperative relationship at a workplace that has
programs? implemented and demonstrated a strong program. In VPP, management agrees to
operate and sustain an effective program that meets established criteria, employees
agree to participate in the program and work with management to assure a safe and
healthy workplace, and OSHA initially verifies that the program meets the VPP
criteria. OSHA then publicly recognizes the site's exemplary program and removes
the site from routine scheduled inspection lists.

What industry resources • OSHA (www.osha.gov): The OSHA website includes all of its standards,
and guidance documents interpretations to all of its standards, and a wealth of other information. D not
are available? forget that OSHA does have a consultation program completely separate from
its enforcement arm. Through its consultation program, OSHA provides
support to businesses for developing and improving their safety programs.
• EPA (www.epa.gov): EPA provides a number of guidance documents and
software tools for developing and implementing Risk Management Plans
(RMP). Much of EPA’s information is developed and disseminated through
their Chemical Emergency Preparedness and Prevention Office (CEPPO).
• IRC (www.irc.wisc.edu): The Industrial Refrigeration Consortium offers a
range of options available for supporting your organization. The IRC has
developed safety-related publications as well as web-based tools for inventory
determination, engineering analysis of safety systems, and compliance audits.
The IRC can also lend assistance as your staff navigate the waters of program
development and implementation.
• CCPS (www.aiche.org/ccps): The Center for Chemical Process Safety has
published a number of textbooks and guidance documents on all aspects of
safety and process safety management.
• IIAR (www.iiar.org): The International Institute of Ammonia Refrigeration
has developed a Guide to the Implementation of Process Safety Management
(PSM) for Ammonia Refrigeration and Risk Management Program Guidelines
(RMP) for Ammonia Refrigeration. These documents provide a framework
with which to develop or refine your own PSM and RMP programs. IIAR is
also developing an Ammonia Refrigeration Management (ARM) program
aimed at guiding smaller facilities that would be under the general-duty clause.
• ASTI (www.ammoniasafety.com): The Ammonia Safety and Training Institute
has published guidance documents on safety and emergency response to
ammonia releases, including coordination between facility staff and local first
responders.

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TEN QUESTIONS EVERY MANAGER SHOULD ASK
Here are ten questions you should ask your staff who are responsible for PSM. If your staff can answer these
questions “correctly” without researching the answers, you can most likely feel confident that the PSM program is in
good hands. If not, you should be concerned and begin to further probe on the health state of your organization’s
PSM program.

1. When was our last compliance audit?


(Should be 3 years or less)

2. Can you show me the closeout of recommendations from the last compliance audit?
(Documentation must be available that shows all recommendations have been dealt with in a timely manner.)

3. Can you provide me a copy of the most recent incident report and documentation that shows how we closed out
recommendations from the incident report?
(Expect there to be more than one incident report from the last five years. At a minimum, the incident report
should include: date of incident, date the investigation began, listing of the incident investigation team,
description of the incident that occurred, factors contributing to the incident, recommendations for preventing
future similar incidents. There should be documentation that describes changes made in response to the incident
report recommendations.)

4. When was our last Process Hazard Analysis (PHA) conducted and can you show me documentation that closes
out the recommendations from the last PHA?
(PHA should have been conducted and/or re-validated in a period no later than five years. There should be
documentation that describes changes made in response to the recommendations that arose from the PHA.)

5. How often do we certify our plant’s written operating procedures for the covered process?
(First, your plant must have written operating procedures for the covered process. Next, the written operating
procedures must be certified that they are current and accurate annually.)

6. What training program do we have for our operators and what are the means used to verify they have understood
the training?
(At an absolute minimum, the initial training must include an overview of the chemicals being used and the
process. The training program must also cover plant-specific written operating procedures. Look for credible
means to verify understanding: testing, demonstration, etc. Also, make sure that operators have had refresher
training at least every three years.)

7. How often do we do refresher training?


(The PSM standard requires refresher training on an interval not to exceed 3 years.)

8. Based on our plant’s mechanical integrity program, what is the next piece of equipment scheduled for retirement
and when is it scheduled to come out of service?
(Although they may have to look this up, they should have a firm answer and you should not get a blank stare
when you ask the question.)

9. What criteria do we use to evaluate contractors that work on our covered process?
(There should be established criteria that may include: Experience Modification Rating (EMR), lost work injury
or recordable cases, industry experience, etc.)

10. What was the last change made to our system and can you show me the documentation for that change?
(There should be a “Management of Change” that was initiated before the change was implemented, all
recommendations addressed and a Pre-Startup Safety Review completed before startup of the change, and the
MOC approved and signed off by those responsible for various PSM elements.)

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