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My guest today is Vicki Whitsitt, Scientific & Regulatory Affairs Manager for the Natural Products Association (NPA). We’ll be talking about the what defines a natural product, how natural products are labeled, what, if any, government regulations apply to them, and what the Natural Products Association is doing to identify products that meet their definition.Vicki works with the association’s self-regulatory quality assurance and regulatory education programs, and manages the NPA GMP Certification Program. In this capacity, she works closely with program advisors, third-party auditors and companies seeking NPA GMP certification.  She has been involved in the development and revisions of the NPA GMP Standard and related program materials and GMP education for the past 14 years.  Through her work, Ms. Whitsitt has developed competencies in dietary supplement law and regulation compliance. www.NPAinfo.org

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TOXIC FREE TALK RADIO
The Seal That Defines “Natural Product”

Host: Debra Lynn Dadd
Guest: Vicki Whatsitt

Date of Broadcast: October 17, 2013

DEBRA: Hi, I’m Debra Lynn Dadd, and this is Toxic Free Talk Radio—where we talk about how to thrive in a toxic world. And it’s necessary to do that because there are so many toxic chemicals all over the place—in the air we breathe, then the food we eat, the water we drink, in our homes, in consumer products, and even in our bodies that our bodies are carrying around toxic chemicals from past exposures, toxic chemicals that your body can’t process very well.

And so we talk about toxic chemicals, and we talk about their health effects, and we talk about what’s toxic and what’s not, and how we can live in a way that is healthy for us, and eliminate as many as toxic exposures as we can, and find the things that are not toxic.

Today is Thursday, October 17, 2013. I’m here in Clearwater, Florida, and it’s a little bit overcast today. We’re not having our usual sunshine that we were talking about yesterday when we were talking about sunscreen, and I just want to remind people that even if it’s cloudy, you still can get a sunburn, so watch out for that.

Today, my guest is Vicki Whitsitt. She’s the scientific and regulatory affairs manager for the Natural Products Association.

And we’re going to be talking today about what is a natural product. That term natural product is used very widely and has been used for a long time, but there actually is an organization—the Natural Products Association, who has set a standard and a definition, and certifies products as being natural. And we’re going to find out what that means today.

Hi, Vicki. Thanks for being with me.

VICKI WHITSITT: Thank you, Debra. It’s a pleasure to be here.

DEBRA: Thanks. Well, first, why don’t you tell us a little bit about yourself, what your interest is, and your background in, how you got to the Natural Products Association? And then tell us about the history of the Association.

VICKI WHITSITT: Well, my background is, of course, as a consumer, I’ve been interested in the whole natural industry approach, whatever you want to call it, since I was quite young. I won’t tell you how long ago that was. I raised my kids to eating what people would call naturals foods, and avoiding processed foods, avoiding a lot of refined sugars, that sort of thing.

Then I started actually with the Natural Products Association.

So I always had a personal interest.

And then I started working for the National Products Industry about 16 years ago. And now, I’m on the other side of it, meaning, not the consumer side, but now, I’m on the business side. And so, I’ll tell you a little bit about the organization—who we are, what we do.

So we were founded in 1936. That means we’re 77 years old. We’re the nation’s largest and oldest trade association dedicated to the natural products industry. And as a trade association, of course, a lot of what we do is advocate on Capitol Hill […] for the rights of consumers to have access to natural products, for the rights of retailers and suppliers so they can sell the products.

We have over 1900 members, and that accounts for over 10,000 retail, manufacturing and distribution locations throughout the U.S. We have companies in all 50 states, as a matter of fact.

And we are the only trade association that covers the entire spectrum—from the ingredient suppliers, the manufacturer to the retailer. And we believe that our membership diversity makes us strong. Our retailers are particularly important because they’re the gateway to the consumers, and they let us know at every turn about what’s important to consumers.

DEBRA: What happened in 1936 that made it necessary for this association to be founded?

VICKI WHITSITT: That is a great question. I don’t have any exact answer. I just know a long time ago, it wasn’t as broad a focus. And so trade associations are important because that’s people with common interest grouping together to talk to Capitol Hill, and to advocate for business opportunities, that sort of thing.

And so a small group of people, we were not very large, and we started when we were established. And one of the early activities that we did besides advocating was started trade shows. So our association started the first trade show in this industry—a place for business to come together, and retailers and business talk about what’s out there, what the consumers want, and interact.

So from the very beginning, we’ve been very involved with all aspects of the industry.

DEBRA: So now, I understand that there’s no legal definition of the word natural product.

VICKI WHITSITT: That’s true.

DEBRA: And I wanted to just give the URL of your business. It’s NPAInfo.org, Natural Products Association. NPAInfo.org.

And you have a lot of information on this site, and I’m hoping that my listeners will go there, and take a look. And when you get to the site, there are different tabs. It’s the top one. It says for consumers, for retailers and for suppliers.

And of course, you can look at all of them. But if you click on the for consumers tab, then there are various pieces of information there, including a store locator where you can type in your zip code, and find stores that sell products that have been certified.

So one of the things that you do at the Natural Products Association is that you certify natural products. So first, please tell me, what is your definition of a natural product.

VICKI WHITSITT: The definition is that products are made of ingredients that come from or are made from a renewable resource found in nature—fauna, flora, mineral. Absolutely no petroleum compound, and that the processing is used to make these are only those that are allowed under the standard.

Under the definition, it does allow, and the standard does allow for—it’s 95% truly natural, and then there’s a very limited amount of synthetic preservatives that can be used in products that will certify natural.

DEBRA: I’ve been researching this regarding about this subject for 30 years, so let me ask you some questions. So it sounds like when I first started, I thought the definition of natural was just as you said, that it would be a plant and animal, or a mineral, and it wouldn’t have any petroleum ingredients in it.

And then you said about processing that it needed to just be minimal processing.

And that’s what I thought too. So in that case, a natural product would be something that has, say, on the label, ingredients that we would recognize like—well, these are ingredients that would be in a product, but apples and lemons and coconut oil, and salt, and things like that. Am I on the right track here so far?

VICKI WHITSITT: Well, yes. And I mean, for a food that’s probably exactly what you would see on the label. It’s a little trickier with cosmetics, with personal care products because they use what’s called INCI Nomenclature. It’s very specific naming, convention for ingredients.

And so sometimes when you’re looking at a label, you see something that you can’t pronounce, but it really might be a natural ingredient, or there might be something, an extract, “Oh, yes. Lavender oil extract. I know what that is,” and you would assume that that’s natural.

But depending on how it was made, it might be what we consider natural under our definition—cold-pressed. But it also may have been extracted using a solvent—a petroleum-based solvent, which then would make that what we would call synthetic ingredient.

DEBRA: I exactly agree with you on that. So this is the question that I’m trying to ask is because you wouldn’t accept for certification if it was lavender oil, for example, that was extracted with a solvent. But you would accept it if it was cold-pressed.

VICKI WHITSITT: Yes, exactly. And that’s the value of a program like ours. All of our products and ingredients have gone through very vigorous third party reviews as part of the certification process.

DEBRA: We’re going to talk more about that when we come back. We need to go to break. This is Toxic Free Talk Radio.

I’m Debra Lynn Dadd, and my guest today is Vicki Whitsitt, and she’s from the Natural Products Association. They look with great scrutiny natural products and certify ones that are truly natural. And we’re going to find out more about what that means when we come back.

= COMMERCIAL BREAK =

DEBRA: You’re listening to Toxic Free Talk Radio. I’m Debra Lynn Dadd, and my guest today is Vicki Whitsitt from the Natural Products Association. And we’re talking about what makes a natural product.

Okay, so what we said before the break was that it needs to be a plant or animal or a mineral, and not a synthetic, petrochemical ingredient. Yet, let me ask you this. I’m going to ask you this question, but it’s not to be critical because I want to understand the logic of what you’re applying here.

So you wouldn’t certify a product that had lavender oil in it that was extracted with a solvent, but you allow some small percentage of preservatives and stuff that are synthetic?

VICKI WHITSITT: Yes, and that’s a really good question. And we’re often asked why we allow any synthetic ingredient under the natural standard. That’s a good question.

DEBRA: A lot of listeners are asking that question.

VICKI WHITSITT: These are temporarily allowed as the standard of a living document. It’s reviewed continually. We’ve already made some revisions that strengthen it.

For example, we now only allow natural fragrances under the standard. And that’s progress. That’s a tremendous progress.

And it took several years of ingredient companies working to make sure that there were commercially available natural fragrances, so that we could move to that step.

It’s important for natural products to be effective and properly preserved for consumers to choose them over the alternative, and for them to come back and buy them. You take it home, but if it doesn’t work, or it doesn’t hold up, if it’s not shelf-stable at home, you’re not going to want to buy it again.

And so the allowed synthetics, you’ll notice it’s limited to a very specific short list, most of which are there because they provide preservation activity to ensure that the products are shelf-stable in the store and also in the consumer’s home.

Like I said, we’re evolving, adjusting the science technological advancements. We’re always looking for natural alternatives.

So this is reviewed every year to determine if there are viable alternatives commercially available. And as they come available, these things will be dropped from the standard.

And our goal, of course, is 100%. And by the way, we think that being 95% of the way there is much better than where we were a few years ago. And many of our products are able to be formulated not using any synthetics.

But we feel it’s important, especially the preservation activity, that there needs to be those alternatives out there for ingredients that need the preservative in them to be stable, and not to go rancid, to stay a [viable] product for the consumer.

That’s why we have these limited lists.

So just to be clear—it doesn’t mean any synthetic. The only synthetics that are allowed are those on that very limited list.

DEBRA: That’s very clear. Thank you for clearing that up. So if you have a seal, it says Natural Products Association certified, it has—I see two of them here. I’m thinking one is for personal care, and one is for household products […]?

And so if I see that on the label, as a consumer, that means that that it’s 100% natural, it may be 100% natural, but it may also have some of these other ingredients that are allowed.

VICKI WHITSITT: Yes. And our standard does require that all ingredients are listed, so a consumer can see exactly what’s in the product.

Any of these products that might be using a very—and normally, we’re talking 1% or less, but they will be listed on the label because they also are…

DEBRA: And I just want to say because I know that there are some people listening, and sometimes including myself, that want everything to be 100% natural. And so they say, “Well, how do I identify what are the ingredients that are not natural?”

So in this case, you really need to learn what those ingredients are. The ones that are allowed are listed on the website. And I want to say that it’s a tremendous, tremendous step in the right direction that these products are certified have moved away from even more toxic things that could be in products. They’re so much better than the really toxic products that are on the market.

And so to have these very small amounts of synthetics in them, well, you’d have to not walk outside and breathe the air. It really is that […], wouldn’t you say?

VICKI WHITSITT: Yes. And we appreciate that. We don’t feel that we’re doing the consumer any good if we have a standard that companies can’t meet, first of all, because they’re not going to put out a product that is unsafe or stable. Then you’re not going to have the products.

And number two, again, we want everybody—consumers, and I’m a consumer as well, I want that product to last when I open it up more than a day or two.

And again, one of the strengths is that this is a constantly evolving standard and definition. And we have very great technical expertise involved in this that they really understand. They’ve got their finger on the pulse of the ingredient industry.

And so we are able to evaluate when we can move a synthetic off of the list.

DEBRA: That’s great that you’re doing that.

Now, I know some of my listeners are wondering, well, what about—are all the ingredients organic, or do they have pesticide residues? I’m asking a lot of hard questions, I know…

VICKI WHITSITT: Well, that’s a good question. Organic might be natural. Natural is not necessarily organic. So there are companies that use the organic ingredients, but it’s not a requirement under our standard.

One of the things we also do—no, this is good. These are good questions, is that part of the documentation companies submit is they do have to submit […] that lists contaminants as well, so that we do look for issues, but we’re not an organic standard.

DEBRA: Okay, good. We need to take another break. And we’ll be back with more hard questions.

VICKI WHITSITT: Okay. I love them. Thank you.

DEBRA: I’m just trying to make it clear what you’re doing, so that people know what it is when they see your seal, that they know what it represents.

I’m Debra Lynn Dadd. You’re listening to Toxic Free Talk Radio, and my guest is Vicki Whitsitt. She’s with the Natural Products Association, and they certify natural products.

We’ll be right back.

= COMMERCIAL BREAK =

DEBRA: You’re listening to Toxic Free Talk Radio. I’m Debra Lynn Dadd, and my guest today is Vicki Whitsitt. She’s with the Natural Products Association. And we’re talking about what makes a natural product, and about what kind of products they certify, and why.

So I have another ingredient question for you, Vicki. We were talking about lavender oil that’s cold-pressed versus lavender oil with a solvent—that you wouldn’t certify something that had solvent extract of lavender oil

What about ingredients—a lot of ingredients that are in, what are considered to be products in the natural products industry, are products that have as their source material a renewable or mineral product, like coconut oil, for example. But then that coconut oil goes through an industrial process, and gets turned into something like sodium lauryl sulfate.

So are those kinds of ingredients that are industrially processed also included?

VICKI WHITSITT: No.

DEBRA: So it explain to us more about that.

VICKI WHITSITT: They’re included on the prohibited list, if that’s what you’re asking. So if you’ve been looking on our website, and you looked at our standard, you’ll see that within the standard itself, we have prohibited ingredients, and we also have a separate illustrative list.

So we describe prohibited ingredients by class or type, and then we also have called out some specific ingredients that are prohibited and why, and one of the things that part of this vigorous, third party review, when companies want to get a product certified or an ingredient certified, they have to include documentation that tells us the source because something like glycerin, or there are other ingredients that can come from a natural source or a synthetic source.

So we have to go all the way back to the source, we have to look at how it’s processed, and we don’t allow, even if it was processed using a solvent that’s not in the final product, our standard doesn’t allow it even in the processing.

DEBRA: That’s excellent.

VICKI WHITSITT: So we do a really vigorous ingredient review, as well as product review. And also, any of our certified ingredients, no synthetics are allowed in the finished ingredient, or in the processing of the ingredient. So those are 100% natural.

You have a company that wants to make a natural product, and they are searching for sources for their ingredients. They can go to our website, look at our list, and those are ingredients that have already been through the review process and qualified—well, qualified under our standard.

Our illustrative list, I think what you brought up is a really good point, if anybody is listening, that is a formulator, understand that the list—again, we use the lavender oil. If you have to look at the source, you have to look at how it’s made because just simply being on that list doesn’t mean it’s automatically going to qualify under the standard.

DEBRA: I’m glad you pointed that out. I wanted to tell you how happy I was to see that list because one of the things that’s happening right now, and whether it was just some progress about this in the last couple of days, is that you may or may not know that there is an organization that is asking top 10 retailers to take certain chemicals, products with certain chemicals off their shelves.

And this past week, Target was one of those on the list, and they were not doing it, and not doing it, and not doing it. And they finally agreed to do it.

And so I’m having been looking at products and evaluating products for myself as a consumer advocate for more than 30 years, I’m asking myself, as good an idea as this is, to ask retailers to do this, how are they supposed to evaluate the products that are on their shelves if they don’t have any kind of background in this subject?

But that same question comes up in terms of consumers too. I know what I know because—I didn’t take chemistry in school, but I certainly studied toxicology books and chemistry books, and all of these things. And it seems like that right now, we’re at a point where there’s a lot of pressure from different directions for retailers and manufacturers to identify their toxic ingredients, to reduce their toxic ingredients, and yet, everybody seems to have to start at square one, and look at an ingredient, and learn how to evaluate it, and go look it up in a toxicology book.

And what you’ve done is that you put together a list that says these are the acceptable ingredients.

And this is what we need on a much larger scale. This is my opinion. We need to have lists of the toxic ingredients that are not acceptable, like you’ve made, and we need to have lists of ingredients that are acceptable, like you’ve made.

I’m in complete agreement with your process, and I wish this would be done more, so that consumers can then say, “Well, we know what to look for now.” And I wish that there would be more information on the labels, so that it can say lavender oil cold-pressed, and that would be the standard, so that those of us who want to take a look at it can.

I think you’re doing everything exactly on the right track.

VICKI WHITSITT: Well, thank you. With that in mind—you’re right. Consumers probably are not going to have access to all of the information, obviously, that we have, when a company submits ingredients. But a consumer can go to our standard, for example, and look where we have ingredients that are prohibited.

And even if you just started with our initial list where we talk about parabens, or the SOS, or petroleum, mineral oil, paraffin, glycols, phthalates, some of those things—it’s surprising how many products with the term natural in their name have these ingredients in them.

So maybe a consumer won’t know where that lavender oil, or exactly how it was processed, but they could use our standard and familiarize themselves with some of the more commonly used synthetics, and look for products that avoid those, or they can buy some things that have our seal on it, and they’ll know that NPA’s done the hard for them.

DEBRA: And also, anyone can go to your website. And again, I’ll give it. It’s NPAInfor.org. And if you click on the “for consumers” tab, one of the things is right there on that page. Look for the headline that says “certified natural products.”

And then there’s a list of personal care products, there’s a list of homecare products, and you can just click on either one of those, and it tells you the exact brand names.

Then you can just go to the store and choose those, and know that they meet the standards.

And I really do think—you have put together some great information that anyone who’s interested in natural products to go and look your standard, go look at your list of products, and they can start to learn what are the ingredients to look for that are good, and which to avoid.

We’re going to talk more about this after the break. You’re listening to Toxic Free Talk Radio. I’m Debra Lynn Dadd, and my guest today is Vicki Whitsitt. She’s from the Natural Products Association. And we’ll learn more about natural products after this.

= COMMERCIAL BREAK =

DEBRA: You’re listening to Toxic Free Talk Radio. I’m Debra Lynn Dadd, and my guest today is Vicki Whitsitt, from the Natural Products Association, and they certify products to be natural. They have the standard, and when a product meets their standard, then they can display the seal.

Vicki, could you just tell us, step by step, what a product needs to go through in order to get the seal?

VICKI WHITSITT: Well, sure. For a company that has a product that they want to put through the process, the first thing that they have to do is ensure that at least 60% of their product line needs to the NPA standard. That’s to qualify. They don’t have to certify all of those, but our program is intended to be more than a green washing program.

So we want a company that has a real commitment to natural, and part of the way they demonstrate that is having at least 60% of their product line qualify.

So then we recommend, the next step is they read our standard, become familiar with what’s allowed, what’s prohibited, there’s an application process, and they will have to provide how it works, and detailed information about each of the ingredients, as well as the manufacturing process that they’ve used to make the product.

It sounds very simple. It can be very complicated because we do ask a lot of information. But we need that to be able to verify that their ingredients qualify under the standard.

And the cost for certification is $500.00 per product for NPA members, and $1250 per product for non-members—the flat fee that covers all the administrative work on our end, the cost of the audit, and the use of the seal for two years. If they use NPA-certified ingredients—

DEBRA: I think that’s a reasonable…

VICKI WHITSITT: Yes. It really is. It’s a bargain, isn’t it?

DEBRA: It is. It is. Yes. So I’ve seen on your website that you have some articles about labeling. So let’s talk about labeling for a little bit. There was one about GMO labeling. What’s your position on that?

VICKI WHITSITT: NPA’s position is that we support the consumer’s right to know in a nutshell.

DEBRA: Good!

VICKI WHITSITT: So there you go. But when we’re looking at it from a legislative point of view, we want to be sure that that’s really the goal of it. That’s something that NPA just grappled with this past year. We spent a lot of time discussing it. But we have always, for quite a long time, NPA’s position has been supporting the consumer’s right to know what’s in a product.

DEBRA: I agree with that. And I think that I probably more than most people in the world want to see everything. I know some consumers say, “But I don’t even know what that means if I see it on the label.”

But I want to know everything.

And also, you have something about caffeine labeling. Do you think that caffeinated beverages and food should be labeled?

VICKI WHITSITT: Yes. We did a voluntary standard, and it’s not about restricting. It’s really, again, consumer’s right to know. And so we did come out in support of voluntary labeling caffeine standard.

DEBRA: Good. So that’s a standard that you’re having that can be a part of your standard.

Now, you particularly work in the NPA GMP Certification Program. Now, what does GMP mean?

VICKI WHITSITT: Well, it means Good Manufacturing Practices.

DEBRA: Good Manufacturing Practices. I knew it must have meant something standard like that […]

VICKI WHITSITT: The companies that are certified say it means—yes. So it has to do with the systems that you use to make sure that your product meets the established specification, so you’re producing quality products.

DEBRA: What products does that apply to?

VICKI WHITSITT: Well, in NPA Certification Program, it’s specific to dietary supplements. There are good manufacturing practices for foods, there are voluntary guidelines for cosmetics, for example. But NPA Certification Program is specific to dietary supplement. That would include vitamins, minerals, herbal products—they all fall under the regulatory definition of dietary supplement.

DEBRA: And what kind of practices might not be good practices? Why would a company need to get certified, or want to get certified to show that they’re not doing what?

VICKI WHITSITT: Well, it’s not about what they’re not doing. It’s about what they are doing. Did they have appropriate procedures in place? Are they documenting their work like they should? Do they have—you might call it a recipe and a cookbook, but do they have a master manufacturing record that describes how everything is going to be done, so that no steps are left out, that the right amount of the ingredients get in?

Have they set appropriate specifications for their ingredients to ensure that they have the correct strength, and that they don’t have any contaminants in them?

So it’s about setting up a strong, quality system that puts controls in place from the raw material stage, all the way through the manufacturing, all your verification testing, and even your distribution practices.

So it really is creating a very strong quality system. And the reason you would be certified is because, again, you have undergone a very rigorous third party review to evaluate if you meet that level of compliance.

And so by law, everybody has to meet the FDA GMP’s for dietary supplements. But there’s other variance as to how companies do it, and how strong their systems really are. So certification is the way you can show your customers, their businesses, your retailers that, in fact, you have strong quality systems in place.

DEBRA: That’s actually very interesting to hear you describe all of this because I’m mostly looking at ingredients. I’m wanting to get the most natural ingredients that I can and avoid the ones that are synthetic and toxic. But I hadn’t really thought about the quality of the manufacturing.

And while you were talking, I was thinking about how I, as a homemaker, am manufacturing things that I make in my home, such as dinner. I was thinking about you saying, did they have it written down how much to put in, this and that, and the other thing.

And as consumers, we want to know that if we buy a product that it needs certain standards of quality. But we don’t quite know what those quality standards are. And we also want to know that if we buy a product once, and it has a certain standard that we can expect that it’s going to have that standard again.

But I honestly can’t tell you […] going to do the same for me from one night to the next.

VICKI WHITSITT: But the cooking at home, making your famous chicken soup is different. And like you said, that’s where variances are okay. But you don’t want variances in your dietary supplements. You want them to be consistent from bottle to bottle.

DEBRA: But it makes sense to me that—I know my skills at cooking, I know the skill of other people as cooks, and I know that there’s a big difference. It’s just human beings, people like you and I, who are working in these manufacturing companies, and they have different degrees of skill as to how well they’re going to do, put these quality assurance things into place.

So it makes sense to me that there would be a certification that would just look at the quality of how the product is being produced.

And I also thought that I should say that I know I’ve talked to a lot of different organizations that have different kinds of certification programs. And I know from my past experience that just because a product doesn’t have a certification doesn’t meant that it’s a bad product, that there’s a lot of reasons why people don’t get certifications.

That doesn’t mean that they don’t meet the standard, for example. They just aren’t certified.

VICKI WHITSITT: We agree with you. That certification is a way to demonstrate to others that our programs are based on third party assessments. But you’re right. A company choosing not to go through it should not necessarily be seen as a negative—more these programs are a positive. They are a way for you to demonstrate to others that third party assessment demonstration that a lot of consumers are looking for.

Because most of us don’t—I mean, I can’t think of any consumer that has access to a manufacturing plant, for example. It just doesn’t happen.

And so if you’re concerned, or if you’re looking for a way to have more confidence, that’s what it’s about.

And also GMP certification is valuable business to business. And so there’s another level there why companies participate, not only for the consumer, but it’s also their businesses where they are—the retailers, or companies that manufacture, but don’t sell their own product, they manufacture for others.

Those people buying, they’re having their products made by them, want some level of assurance, some qualified assessment of the systems in place.

DEBRA: Well, our time is just about up. Thank you so much for being with me today, Vicki. And I do understand a lot better now what your organization does. And I’ll take a look for that seal when I know what it means now when I see it.

VICKI WHITSITT: Well, it was a pleasure. Thank you very much for having me on your show. We appreciate you reaching out to NPA about our natural standard and certification programs. We love to get the word out about what we have to offer, and let consumers know about where to look for, what to look for, and that they can come to our website to find even more…

DEBRA: Sorry. There’s the music. You’re listening to Toxic Free Talk Radio. I am Debra Lynn Dadd.

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