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SQF is First 3rd-Party Assessment Program Requiring Unannounced Audits

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#1 Setanta

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Posted 06 January 2014 - 03:27 PM

SQF Becomes First Internationally Accredited Third-Party Assessment Program to Require Unannounced Audits


The Safe Quality Food Institute (SQFI), a division of the Food Marketing Institute, announced today the incorporation of an unannounced audit protocol to be included in the next revision of the SQF Code (SQF). With the support of its Technical Advisory Council, representing SQF stakeholders, SQF will become the first internationally accredited third-party assessment program to require unannounced audits. Robert Garfield, senior vice president, SQFI, issued the following statement:

“SQFI’s unannounced audit protocol will be introduced in February 2014 and implemented in July 2014, and will require that one out of every three SQF audits will be unannounced.

“We made the decision to enhance the rigor of the SQFI program after consulting with numerous stakeholders. We understand that the food industry must respond to and meet the nation’s food safety challenges more rapidly and effectively, which requires a more nimble approach to our program.

“Although many stakeholders, such as governments and consumer organizations, recognize the efficacy of the SQFI food safety management program, unannounced audits will elevate the SQF Program to the next level by providing a standard that will prepare SQF-Certified suppliers to be audit-ready at any time. We believe that each facility must be prepared every day for an assessment.”


Edited by Setanta, 06 January 2014 - 03:31 PM.

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#2 tadelong

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Posted 06 January 2014 - 05:43 PM

This appalls me. Our facility only has six employees, so a scheduled audit is taxing enough on our system. Realistically, to be able to afford to follow an auditor around all day on a normal workday would require an extra person that we don't have. Everyone already wears more than two hats, and there's a closet full of impatient fedoras waiting for their size 7 1/2 head.

 

Trouble is, if we let the auditor do their busy work by themselves(or only paid half-attention), then they'd take longer and have to come back another day, doubling the cost(over $1,000/day! where do these numbers even COME from?!). We can hardly afford to dump our pockets into that sieve, either.

 

A scheme like this doesn't work for us; all it does is make us look incompetent for trying to be efficient.


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#3 Myusername

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Posted 06 January 2014 - 09:54 PM

UGH, i agree with tadelong, sqf is making themselves less competitive for smaller companies. Who's paying for these unannounced audits, i bet you its not SQF.


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#4 Charles.C

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Posted 07 January 2014 - 05:37 AM

Dear All,

 

Does this mean that the SQF (apparently compulsory) format will no longer be compliant with GFSI benchmarking requirements ?

 

Either way, i would imagine that some competitor hand-rubbing is now underway. :smile:

 

Rgds Charles.C


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#5 esquef

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Posted 07 January 2014 - 02:58 PM

I think we need further clarification from SQF (which we won't see until the new edition comes out, supposedly next month). It says one of three audits will be unannounced, and I'll take a guess and say that the unannounced audit will take place +/- 30 days from the last announced audit date.

 

This is certainly no surprise to many in the industry; there's been a push for convergence with national regulatory and inspection bodies (ex. FDA in the U.S.) where virtually all audits are unannounced. Announced 3rd party audits have been under fire since the Peanut Corporation of America ordeal (500 illnesses and 9 deaths) where AIB scored PCA "excellent" year after year even though the FDA had data showing that results from an unannounced audit showed that the facility was in terrible condition.


Edited by esquef, 07 January 2014 - 02:59 PM.

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#6 Myusername

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Posted 07 January 2014 - 03:25 PM

I think we need further clarification from SQF (which we won't see until the new edition comes out, supposedly next month). It says one of three audits will be unannounced, and I'll take a guess and say that the unannounced audit will take place +/- 30 days from the last announced audit date.

 

This is certainly no surprise to many in the industry; there's been a push for convergence with national regulatory and inspection bodies (ex. FDA in the U.S.) where virtually all audits are unannounced. Announced 3rd party audits have been under fire since the Peanut Corporation of America ordeal (500 illnesses and 9 deaths) where AIB scored PCA "excellent" year after year even though the FDA had data showing that results from an unannounced audit showed that the facility was in terrible condition.

What suprises me is that even tho PCA's audit indicated "excellent"  yet the FDA who i would believe is the governing body over this facility did nothing even though the had evidence the facility was in terrible condition. Im not familiar enough with the situation to give fact so im going to throw out some hypotheticals.

 

An audit for the most part is a verification activity of the Food safety system, the CB cannot tell the plant to stop production, only withdraw certification, if the plant is up to standard that day and the paperwork is in line what more can the CB do other than give the plant its certification, its not their job to do compliance Inspections only enforce thier standard, "Inspections" are what the regulatory body is for. From what i do know this auditor who work for PCA had several situations like this and was obviously too "easy" or incompetant, but yet the regulatory body who's job it should be to say yea or nae on this plant did not do their job and shut this plant down.

 

In my opinion there is a serious problem with the FDA or the american government if they could not have stopped this from happening with the observations and evidence they had.


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#7 esquef

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Posted 07 January 2014 - 04:47 PM

I agree that if the FDA had evidence that PCA was not fit to process peanuts it should have done something about the situation, even if it was to share their findings with PCA's self designated 3rd party auditor, AIB. But I think the whole thing needs to be put in perspective in that the PCA recall was voluntary. In the pre-FSMA days the FDA's powers to force a recall were much more limited than post-FSMA, and injunctions where a facility was closed until corrective actions were imlemented then verified for effectiveness with a followup FDA inspection (paid for by the company) were virtually unheard of.

 

An unannounced audit is simply a snapshot of a facility and as the PCA saga proves doesn't prevent a filthy facility from sprucing everything up for an announced audit. Believe me, as a Food Safety Manager I realize that to make sure that my employer is "audit ready at any time" makes my job way more stressful, but like I said earlier, this has been coming for a long time, and IMO is a good thing for the consumer.


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#8 Snookie

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Posted 07 January 2014 - 05:43 PM

Interestingly enough I got to meet one of the FDA agents who participated in the PCA situation and he talked at great length about the difficulty of getting positive samples and how many they had to take to get a positive result. 

 

However that being said, the reality is that audits are only a snapshot and too many plants don't "live" their system and really only pull it together just before the audit.  Many auditors don't have the time and/or the expertise to really pull out serious issues.  There are not enough government agencies or third party auditors to fix the system.  Auditing will never get us to where we need to be.  Somewhere along the line the companies need to figure out that doing it right the first time and continuing to do it the right way is ultimately cheaper, and better in the long run and provide the tools and support for that.  

 

Coming from pharmaceutical we rarely had an announced audit and we had to  be audit ready every minute.  In food we should strive to do the same.  That being said, don't think this will warrant big changes.  Only one audit in three is unannounced and my guess is that  as Esquef pointed out, there will be a window for the audit.  In the end I don't see dramatic improvements or results from this just some irritating situations as you know the unannounced will happen on the day when staff or missing, equipment is misbehaving etc. But then audit days are always tough and Murphy's law seems to be in full play anyway.  It will be interesting to see the protocol in February to see how they have structured this requirement.   


Edited by Snookie, 07 January 2014 - 05:47 PM.

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#9 Simon

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Posted 07 January 2014 - 07:05 PM

Announced or unannounced a poor auditor is a poor auditor and that's a different issue that certainly needs fixing.  I'm personally for unannounced audits and I think one out of three is a reasonable transition to what will no doubt become the norm across all GFSI standards.


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#10 bacon

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Posted 07 January 2014 - 08:27 PM

I agree with Simon, this is where the industry is going and leadership in the food manufacturing industry are beginning to realize it, the only way to reduce retail exposure. BRC already offers it as an option (with incentives) on issue 6. 

 

As an aside on the PCA debacle: the 1st thing on my 1st BRC audit was for the auditor asking for the last 2 years of other audit records (FDA, Military, Costumer, USDC, State). That would have been an easy catch for AIB if the auditor had asked for that (granted if PCA was not obfuscating these documents). I take that to be standard protocol (even if the auditor does not ask for them; their loss of having other "snap shot" samples).


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#11 Charles.C

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Posted 08 January 2014 - 04:54 AM

Dear All,

 

A few comments.

.

I applaud the respect being paid to the concept of  maximising consumer safety in many of the previous threads.

 

However I think it is is also necessary, and I fear unavoidable, to remember that we are discussing “business” activities here. Including auditing. And sometimes an absolute separation between black / white is not readily defined. This is not to excuse  obvious blunders, or worse, of course.

 

As one posssible worst case scenario, maybe have a look at some of the UK threads here bemoaning the QA time spent dealing with the barrage of external audits. And potentially to the detriment of overseeing their own internal safety situation. Now consider the result if they were all unannounced as may be a final trend.

 

Ideally, as per HACCP, preventive food safety activities should obviously be pro-active. We have all seen that in practice this is often simply not the case. For a variety of reasons such as basic lack of knowledge (general or local), faulty implementation, fraud / security issues. And  this again unfortunately includes auditing.

 

I would like to see some evidence that (apart from the intuitive "independent" attraction) un-announced audits are more efficient than the opposite at benefitting consumer safety. Having experienced / undertaken both, I am so far unconvinced.

 

GFSI’s position ?

 

Rgds / Charles.C


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#12 tadelong

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Posted 08 January 2014 - 07:39 PM

I don't worry about our readiness; the CFIA roll in every month, not every six months. They do their inspections, and give us our grade, any admonitions we deserve, and so long as we're up to snuff we're golden. We can be down two people and the CFIA inspector is nearly just as quick. The problem for us is all logistics. 

 

Ugh.


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#13 Mr. Incognito

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Posted 08 January 2014 - 08:04 PM

I'm with Simon on this but with SQF's inspection tier system I think they should make it part of level 3 rather than all of their inspections.

 

It's well known that level 3 is a higher level inspection so place it there instead.  (I know the real breakdown is safety vs quality and safety but still)

 

Yes it will be within 30 days of the previous audit so you already know the window of when they'll come (unless they change that with their update).

 

It won't make them non-compliant with GFSI because their requirement will be more stringent than GFSI's not less stringent.

 

I like unannounced audits.  It forces you to actually be doing the right thing not making it look like your doing the right thing.


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#14 Douglas NIcoll

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Posted 09 January 2014 - 01:06 AM

Interesting development. The bar has been raised. As a USDA plant we are used to having our systems and facility checked on a regular basis. We all like to put our best foot forward for announced visits but regularly have to deal with the unexpected. I do expect other audit systems to follow suit. It will benefit both industry and consumers with safer products.


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#15 Tony-C

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Posted 09 January 2014 - 03:00 AM

I see this as progress and should provide greater confidence in certification. It should reduce the situation where audits are 'stage managed' and there isn't a complete buy in to maintaining an effective food safety management system.

 

Regards,

 

Tony


Edited by Tony-C, 09 January 2014 - 03:00 AM.

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#16 oronogirl

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Posted 09 January 2014 - 03:00 PM

Speaking for our industry - primary packaging - this is an utter shock to our culture.  Food safety is still a shock to our culture.  We (as an organization) have only been doing this for two years involving one certification audit and one re-certification audit.

We do not have food inspection audits by the CFIA because ... yes, that's right, I'm saying it [even though I have had to argue for the other side of this point for two years!!] ... WE DON'T PRODUCE FOOD!

 

I like the thought process from another member that Level 3 SQF participants would be required to have 1 out of 3 audits unannounced; not Level 2 participants. 

 

For our facility, one of our concerns is what allowances are going to be made for access to records due to employees who are on vacation/sick/travelling on business or what if there is some other critical customer visit/concern that is the priority at that moment?  What kind of guidance are the SQF auditors going to be given to address situations these situations?

 

Here's hoping someone at SQFI is a member of IFSQN and taking notes from this board!

 

MaryK


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#17 Simon

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Posted 09 January 2014 - 09:33 PM

For our facility, one of our concerns is what allowances are going to be made for access to records due to employees who are on vacation/sick/travelling on business or what if there is some other critical customer visit/concern that is the priority at that moment? 

 

Records should be accessible irrespective of who's in or out of the business and you should also have cover (able deputies) for all positions critical to food safety and quality and these should be documented in your system.  There is a parallel thread running on the forums on how and where to document cover.  This will be an area to develop in your system that should in part help you to overcome the logistical difficulties of unannounced audits.  I agree if you have another important visit at the same time it will be very difficult, especially as in many businesses human resources are limited and we all wear many hats.  It’s tough


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#18 bacon

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Posted 09 January 2014 - 10:04 PM

FYI, just out: http://www.ifs-newsl...=bece5d8542&p=1

 

Details about unannounced IFS Food Checks  

The aim of the unannounced IFS Food Checks is to verify whether a food producing company complies in daily operations with the processes which were audited during the IFS Food audit, thus ensuring food safety and quality continuously. The IFS Food Check is carried out without notice and takes a maximum of one audit day.

Basis of the unannounced IFS Food Checks is a checklist of 90 criteria, which have been selected from the IFS Food version 6 standard. This checklist serves as a guideline for the auditor. The focus is placed on the review of the IFS Food standard requirements, in particular the requirements relating to the implementation of HACCP and to the ensurance of the general health and pest preventions. The document review will be limited to the most essential.


The participation in the IFS program "unannounced IFS Food Checks" is voluntary. The necessary pre-condition is that the company either holds a valid IFS Food certificate or has applied simultaneously for the unannounced IFS Food Checks and for an IFS Food audit at a certification body.

A successfully completed IFS Food Check allows companies to demonstrate their continuous fulfillment of the IFS Food standard requirements in their daily production routine.


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#19 Charles.C

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Posted 10 January 2014 - 02:59 AM

Dear baron,

 

So now as far as "mandatory" is concerned, it's 2 against (probably?) one. :smile:

 

i suspect a business opportunity has been sniffed.

 

Rgds / Charles.C


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#20 Kellio

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Posted 14 January 2014 - 11:08 PM

To all Food Safety Warriors out there,

 

SQF just announced the implementation of unannounced audits or "surprise audits".  Starting February 2014 and full implementation by July 2014.  Now in SQF, out of 3 Audits, one will be unannounced.  Just passing information along to SQF Practitioners.

 

Talk to you soon,

 

Kelio


Edited by Charles.C, 18 January 2014 - 05:38 AM.
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#21 Tony-C

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Posted 15 January 2014 - 05:33 AM

Thank you for the post Kelio. Setanta beat you to this last week. You can see members comments here:

 

http://www.ifsqn.com...nounced-audits/

 

Regards,

 

Tony


Edited by Charles.C, 18 January 2014 - 05:39 AM.
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#22 Kellio

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Posted 17 January 2014 - 09:10 PM

To all,

Here below are the guidelines to follow this new unannounced SQF Audits. (Just received)

I hope this helps.

I wonder if the other Audit Schemes in GFSI will be doing the same thing.

It will be very interesting.

Talk to you soon,

Kelio

 

 

Unannounced Audit FAQ

Proposed Unannounced Audit Protocol (subject to revision by the SQFI Technical Advisory Committee) to be published February 3, 2014.

 

Effective date: July 1, 2014.

 

Within three (3) certification cycles the certification body shall conduct one (1) unannounced recertification audit of the supplier.  The unannounced audit shall occur in the supplier’s facility within the sixty (60) day recertification window (i.e., the anniversary date of the initial certification audit +/- thirty (30) days).   Currently certified SQF suppliers shall be required to undertake one (1) unannounced audit within the three (3) year certification cycle.

  1. The supplier’s certification cycle begins with the initial certification audit date. Unannounced recertification audits occur once in every three (3) certification cycles.
  2. Unannounced audits shall not be conducted on the initial certification audit or on a surveillance audit.
  3. If a supplier changes certification bodies the supplier’s unannounced recertification audit schedule shall not change.
  4. The unannounced recertification audit shall follow the protocol under the SQF Code, Part A, section 4.3 and 4.4. 
  5. Multi-site suppliers are exempted from unannounced audits.
  6. The date of the unannounced audit shall be determined by the certification body within the 60 day recertification audit window.
  7. A defined blackout period shall be established through negotiation between the supplier and their certification body that prevents the unannounced recertification audit from occurring out of season or when the operation is not operating for legitimate business reasons.
  8. Immediate suspension of the supplier certificate will occur in facilities that refuse entry to the auditor during an unannounced audit.

 

  1. How will facilities be chosen for an unannounced recertification audit? 

Any currently SQF certified facility is eligible for an unannounced audit. Multi-site operations, initial certification audits and surveillance audits are automatically exempt from unannounced audits.

 

  1. What if the facility is not in operation on the day the auditor shows up for the unannounced audit?

The facility will pre-establish with their certification body any “blackout dates” based on production and seasonal schedules.

 

  1. Does the facility have the option to decline the unannounced audit? 

No. Because the unannounced audit is a valid, recertification audit the facility will not have the option to decline an unannounced audit.

 

  1. What are the ramifications for a facility who refuses the unannounced audit?

Refusal of the unannounced audit will result in immediate suspension of the certificate. The certificate will be reinstated upon successful passing of an audit.

 

  1. After a site has undergone an unannounced audit, when does the unannounced audit period “reset?”

The site will receive one unannounced audit with three (3) audit cycles.  Therefore, the unannounced audit period resets after the completion of three (3) certification cycles. For example, if 2014 is the first year of the supplier’s audit cycle, then one (1) unannounced audit will be conducted within the time period between 2014 and 2017. The next time period in which an unannounced audit would occur for this site is from 2018-2021.

 

  1. Can the CB “cancel” an announced audit and convert it into an unannounced audit?

Yes. The unannounced audit will need to take place within the supplier’s sixty (60) day recertification window and outside the pre-determined black-out days. This should be made clear to the supplier during scheduling.

 

  1. Suppliers may experience limited staff resources on the day of an unannounced audit for such activities as escorting the auditor, pulling documents for review, etc., potentially causing substantial delays and impacting the audit duration.  What are SQFI’s expectations in this situation?

SQFI, the certification bodies and auditors understand that the audit duration may be impacted during an unannounced audit. However in discussing this with the CBs and auditors, there was no significant concern for substantial delays. Because of the expectation for the site to be “audit ready” at all times and since the supplier’s recertification window remains as sixty (60) days (thirty (30) days on either side of their anniversary date) this should provide sufficient time to prepare for an audit, announced or unannounced.

 

  1. Some facilities may store records off-site and may need extra time to access and present those for review.  How will these situations be address during the unannounced audit?

The SQF Code indicates in element 2.2.2.3 that documents are to be readily accessible and retrievable. The required documents must be available and accessible during the unannounced audit.

 

  1. Can I make suggestions for change to the unannounced audit protocol?

SQFI has discussed the protocol at length with their Technical Advisory Committee and certification bodies and have taken into account their advice regarding particular scenarios and situations. The protocol will become final once published in the Code in February, 2014. After that time, SQFI will provide clarification and expectations for the CBs, auditors, suppliers and other stakeholders.  Questions and comments can be sent to SQF at info@sqfi.com.


Edited by Charles.C, 18 January 2014 - 05:39 AM.
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#23 Charles.C

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Posted 18 January 2014 - 04:20 AM

Dear Kellio / All,

 

Thks for the above.

 

Not my direct concern but not looking so good for the "external practitioner" industry perhaps ??

 

I predict that the Draconian Note 8 will be the first one to be revised. :smile:

 

Rgds / Charles.C


Edited by Charles.C, 18 January 2014 - 05:51 AM.
moved from parallel thread

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Kind Regards,

 

Charles.C


#24 Mr. Incognito

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Posted 20 January 2014 - 12:45 PM

So now SQF and IFS... I wonder how long until all FSSC and the other GFSI standards move to this to stay competitive in the "We have safer food" mentality.


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#25 Tony-C

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Posted 20 January 2014 - 05:07 PM

So now SQF and IFS... I wonder how long until all FSSC and the other GFSI standards move to this to stay competitive in the "We have safer food" mentality.

 

It is inevitable that all food safety standards will go this way. After all they are in competition with each other!

 

It is probable that gaining certification to a standard with unannounced audits will mean that retailers will reduce their own audits (although some will continue to do their own audits, sometimes for commercial reasons). If retailers do accept certification to a standard with unannounced audits there are likely to be big savings for both the supplier and the retailer.

 

Regards,

 

Tony


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