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What should an asbestos register contain?

taken from my construction training notes when I use to instruct with L5/6 Dip Level and CITB L1 through to 4 & Supervisor levelenjoy:What is an asbestos risk register? The asbestos risk register is a key component of the required plan on how you will manage any asbestos found, or presumed to be, in your buildings. This management plan must contain current information about the presence and condition of any asbestos in the building.What should an asbestos management plan contain?The Asbestos Management Plan should be a simple, understandable document that addresses:who is responsible for managing asbestos;the asbestos register (the asbestos survey information) you have just made;plans for work on asbestos materials (if any);the schedule for monitoring the asbestos materials' condition;Asbestos Management PlanThe Control of Asbestos Regulations 2012 require every non-domestic property to have an Asbestos Management Plan. This document is intended to explain how the person responsible for the building, the Duty Holder, intends to manage the asbestos present to prevent persons being exposed to the asbestos.Unfortunately this is not a one-off job for it will be required for as long as you have asbestos-containing materials present in your buildings.The Asbestos Management Plan should be a simple, understandable document that addresses:who is responsible for managing asbestos;the asbestos register (the asbestos survey information) you have just made;plans for work on asbestos materials (if any);the schedule for monitoring the asbestos materials' condition; andtelling people who might disturb the asbestos about your decisions.Duty to Manage Asbestos“Asbestos is the single greatest cause of work-related deaths in the UK ” - Health and Safety Executive.The Duty to Manage Asbestos is contained in Regulation 4 of the Control of Asbestos Regulations 2012. It applies to non-domestic premises.Its effect is to ascribe duties to persons in control of non-domestic properties in order to achieve two basic goals:Persons working in a property or visiting that property will not be exposed to asbestos.Persons required to do work upon the property will be advised of the presence of asbestos so that they can avoid it or, if adequately trained, work on it appropriately.There will always be a Duty Holder in a non-domestic property, be that the Owner, the Manager of a company renting the property or a Head Teacher in a school. The Duty Holder is the person who has control of work upon the fabric of the building.What we do for the Duty Holder:Provide the Asbestos Survey so that an Asbestos Register can be compiledWrite the Asbestos Management Plan that describes how it will be managedAdvise on remediation where required and provide Asbestos Removal Project Management servicesProvide Asbestos TrainingProvide on-going advice as requiredControl of Asbestos Regulations 2012The Control of Asbestos Regulations (CAR) 2012 apply to all work with asbestos in the UK. The accompanying Approved Code of Practice L143 describes in detail how such work should be carried out. The Regulations state that whilst work with asbestos is a licensed activity, certain low risk work can be undertaken without a licence, although some of that work still requires a notification to be made.The most important point that the Regulations require is appropriate asbestos training for the type of work anticipated. If you or your employees are going to undertake work with asbestos you must have appropriate recent training. If you are going to employee someone to work on your asbestos you need to determine that they have such training.Even if persons are not intending to work with asbestos but are going to work on the fabric of your building then they should have UKATA Asbestos Awareness Training to help them recognise possible asbestos and to know how to respond if they accidentally disturb what maybe asbestos.The Control of Asbestos Regulations 2012 require that every non-domestic property should have an Asbestos Management Plan that details how the person responsible for the maintenance of a building, the Duty Holder, will proceed to ensure that persons are not exposed to asbestos.How often do asbestos registers need to be updated?All asbestos registers must also be reviewed and revised at least every five years, even if there have been no changes.Asbestos registers - AsbestosAsbestos in Victoria › in-the-workplace › information-about-asbestos-re...Search for: How often do asbestos registers need to be updated?5. Inspect your buildingThis is known as a 'management survey'. The aim is to produce an 'asbestos register' which says where asbestos is located or where there might be asbestos.For small premiseseg workshop, trading estate unit, office, shop.If you follow these steps correctly, your own inspection is normally sufficient to make an asbestos register.For larger premiseseg more than 25 employees, more than a few workrooms, or if you are unsure.You may decide to employ a competent asbestos surveyor. (See link on right)Inspecting your buildingNB. See 'Further information' (below) and 'Related links' (right) to help you complete thisCopy or draw a plan of the building.Example site plan [78KB] PDFWalk round and look.Get some help - a second pair of eyes is always useful.Mark on the plan what contains, or might contain asbestos.Checklist - Places and materials that can contain asbestosList of product brands containing asbestosSee also - related links on rightPrint a blank asbestos register.Blank asbestos register to print out [51KB] PDFBlank asbestos register to save - MS Word version [51KB] Word documentNote down each material that might contain asbestos. Note how much there is and its condition (good/poor)Where you can't get access, eg a roof void, wall cavity, presume that this contains asbestos. Note this down in the register.When your inspection has finished, complete your asbestos register.Add the date and sign it.Example of a completed asbestos register [68KB] PDFKey pointDo not disturb any material that might contain asbestos.SummaryIf a building contains asbestos, a management plan must be in place to ensure that everyone using the building is protected against exposure to it. To assess such risks the asbestos must be located and its condition identified so that anyone who may have to work on, or near, the asbestos can understand where it is. The record of the asbestos present on the site is called the asbestos register.This topic outlines how to develop and maintain this legally required information, including what information is required, how it should be formatted so that it is easy to understand by those who need access to it and how to ensure it is kept up to date.Employers' DutiesEmployers have a general duty to ensure, so far as is reasonably practicable, the health, safety and welfare at work of all employees under the Health and Safety at Work, etc Act 1974. Asbestos materials should be considered as a potential risk. A knowledge and record of their existence is a first step in managing that risk.Other regulations, such as the Management of Health and Safety at Work Regulations 1999 and the Workplace (Health Safety and Welfare) Regulations 1992, relate to identification and management of risks within the workplace.Under the Control of Asbestos Regulations 2012 (CAR) employers are required to identify the asbestos type for any workers liable to be exposed to asbestos and keep a record, such as a register, of the asbestos present.Regulation 4 of CAR imposes a duty to manage asbestos on those who, by virtue of a contract or tenancy, have maintenance or repair obligations for non-domestic premises or any means of access thereto or egress from.Further, in relation to any part of non-domestic premises where there is no such contract or tenancy a duty will be placed on those parties who have control of that part or any means of access thereto or egress therefrom. A wide range of people may therefore have obligations under regulation 4 such as owners, occupiers, managing agents, architects and surveyors. Where there is more than one duty holder the contribution to be made by each duty holder will be determined by the nature and extent of their maintenance and repair obligations (eg through contracts/tenancy obligations).The duty to manage, in particular, requires duty holders to assess the location of asbestos, keep a record of the assessment, assess the risks associated with any asbestos and then prepare a written plan to manage the risk. Information regarding the location and condition of any asbestos must be provided to every person liable to disturb it and to emergency services. Compliance with regulation 4 of CAR will require a thorough approach to the searching out and documentation of the suspected asbestos materials, ie the creation of an asbestos register. Procedures will need to be put in place to communicate this information to all necessary groups and individuals.In PracticeThe Place of the Asbestos RegisterAsbestos-related diseases are the single greatest cause of work-related deaths in the UK. Consequently, the Control of Asbestos Regulations 2012 (CAR) require employers and those who manage non-domestic premises to protect those who work in such premises (or who use them in other ways) from the risks to ill health that exposure to asbestos causes. Regulation 4 of CAR is designed to make sure that anyone who carries out work in non-domestic premises (or anyone who occupies the premises) is not harmed from exposure to asbestos-containing materials (ACMs) that may be present. The regulation imposes a duty to manage asbestos on those who, by virtue of a contract or tenancy, have maintenance or repair obligations either for non-domestic premises or for any means of access thereto or egress therefrom.The duty to manage the risk from asbestos, in particular, requires duty holders to:assess the location of asbestosassess the Management Surveykeep a record of the assessmentassess the risks associated with any asbestos.Duty holders are then required to prepare a written asbestos management plan. Information regarding the location and condition of any asbestos must be provided to every person liable to disturb it and to emergency services.Once the management survey has located where asbestos is present, or is presumed to be present, and its condition has been determined, the results should be recorded in an “asbestos register”. The asbestos register should then become an integral part of the asbestos management plan, and should be part of the arrangements that are in place to inform every person liable to disturb the asbestos about the location and condition of any asbestos before they start work.Compiling the Asbestos RegisterThe duty holderRegulation 4 of CAR places responsibilities on the duty holder. Normally this will be the employer; however, a wide range of people may have obligations under regulation 4 such as owners, occupiers, managing agents, architects and surveyors. Where there is more than one duty holder the contribution to be made by each duty holder will be determined by the nature and extent of their maintenance and repair obligations.The basic contentThe register should record the asbestos present on the site. It should enable those who work on the site to identify easily where the asbestos materials are located.The asbestos register should include an accurate drawing of the premises. Details of any area not accessed or inspected should be recorded and unless there is strong evidence that it does not contains ACMs, the area must be assumed to contain ACMs — this must be stated in the register.The record and drawing should contain details of the locations of the ACMs, their extent, condition and forms. Other than this, there is no set format for the asbestos register; however, it should include:the name of the duty holderthe address of the sitea description of the areas covered by the asbestos register [& Photo’s attached to file]details of who is responsible for maintaining the asbestos registerFor each ACM located the following basic details should also be included in the register.Exact location of each ACM: each location should have a unique and straightforward means of identifying it so that there can never be any confusion as to the presence of an ACM.The product and what it looks like: eg is it asbestos insulation board, asbestos cement, etc; is it painted and if so, what colour?The asbestos type: is it crocidolite, another type of amphibole, chrysotile or is it unknown and presumed to be asbestos?The certainty that asbestos is present: Has it been identified? Is it presumed or strongly presumed?The extent of the ACM: What is the relevant area, length, thickness and volume?The condition of the ACM: Is it damaged or showing signs of deterioration?Surface treatment: Is one present?All register entries should show the date they were entered, when they were last updated and when they are due for review.Description of the locationThe description of the exact location of the ACM must be unambiguous and can be based on the height related to the floor, combined with compass points. Descriptions such as “2m above floor level, north wall” (for a wall pane) or “trench 0.1m below floor level, parallel to west wall” (for pipework) are far more accurate and less prone to misinterpretation.Where equipment contains asbestos, the usual location of the item should be recorded and in case it is moved, any unique detail that could identify the equipment, such as serial number or dimensions, should also be added. A comment on the mobility of the equipment may also be of use, particularly if it is regularly moved within the site (ie a small kiln in a manufacturing plant).In addition to the written description of the location of the ACM drawings, sketches, plans or photographs can assist in the description of the ACM’s location.Identification limitsThe limitations of the certainty of the presence of asbestos should be stated within the asbestos register. For example, if the survey on which the initial register document is based was non-invasive, then the register will have to state:what assumptions have been madewhat asbestos has been specifically identifiedin which areas asbestos has been assumed to exist because sampling or inspection was not possible or was not carried out.Where materials have been sampled and analysed, brief details should be entered in the register.Condition of the asbestosThe condition of the ACM is critical in assessing the risks to those who may be exposed to asbestos. The description of the condition of an ACM should enable an assessment of its potential to release asbestos fibres into the air. The description of the ACM should note whether the ACM is in good condition or, if not, the amount of damage or deterioration. Points to note are whether:there are loose asbestos fibres exposedthe surface of the material is damaged, frayed or scratchedthe surface sealants are intact or are peeling/breaking offthere is evidence for the ACM becoming detached from its base (a particular problem with pipe and boiler lagging and sprayed coatings)there is asbestos dust or debris from damage near the materialThe presence of surface applications should be noted. As these can greatly reduce the possibility of exposure, the need for removal will be greatly reduced and only occasional checks to ensure that its condition remains intact will be required. Any terms used in the register (ie trade names) to describe the nature of the surface protection that are not completely straightforward should be clearly explained.Survey limitationsIf an area could not be, or is not, surveyed, it must be assumed for the purposes of the register that an ACM is present in that area. Asbestos can be hidden in a wide variety of places where only the most rigorous and destructive of surveys will reveal it. The register must state quite clearly that an area or item could possibly contain asbestos, because it was not possible or reasonable to investigate it.Examples of where materials may be hidden include where they have been over-clad, such as damaged wall panels or hidden below layers of insulation, eg pipe lagging debris below mineral fibre insulation in roof spaces.Material and priority scoring toolsThe Health and Safety Executive (HSE) recommends that each entry in the asbestos register should include a:material scorepriority score.These are obtained by using the Material and priority scoring tools on the HSE website. If the ACM is in good condition its material and priority scores are 1 for both. If it is not in good condition the scores are obtained by using the Material and priority scoring tools.Obtaining the Priority score involves allocating scores of 0 to 3 for the:“main type of activity in area”“likelihood of disturbance” (which is the average of the scores for the factors: location, accessibility and extent/amount)“human exposure potential” (which is the average of the scores for: number of occupants, frequency of use of area and average time area is in use)“maintenance activity” (which is the average of the scores for type of maintenance activity and frequency of maintenance activity).The Priority scoring tool gives examples of scoring each factor. As an example for the main type of activity in area, “rare disturbance activity” will score 0, low disturbance activities will score 1, periodic disturbance will score 2 and high levels of disturbance will score 3.The Priority score is obtained by adding the four scores together.The Material score is obtained by adding the scores allocated for the following.Product type — for which asbestos reinforced composites score 1, whereas loosely packed asbestos such as pipe and boiler lagging score 3. Extent of damage/deterioration, for which there is no visible damage scores 0 and high damage or delamination scores 3.Surface treatment — for which composite materials containing asbestos score 0; unsealed laggings and sprays score 3.Asbestos type — for which chrysotile scores 1; amphibole asbestos excluding crocidolite scores 2 and crocidolite scores 3.The two scores can be used to determine which work to carry out first. The ACM with the highest priority score should be tackled first and if two ACMs have the same priority score, the one with the higher material score should be carried out first.TerminologyTechnical or peculiar building terms may not be familiar to all users of the asbestos register. For example, features such as soffits, fascia boards, lagging and fire stopping may need further explanation. Any terms that may cause confusion should be clearly defined, both in the document at their point of first use, and preferably in a separate glossary of terms. The register could include a summary of regularly used terms to avoid confusion.Common forms of asbestos materials, such as asbestos cement and asbestos insulating board are frequently referred to using the acronyms AC and AIB alone. The meanings of these acronyms must always be obvious and easily referenced, if required. As a rule, the acronym should be redefined at the beginning of each section of the document, the first time it is used. Trade names of ACMs are fast becoming forgotten and should be replaced with a generic description.Other contents of the asbestos registerAfter the basic information has been included in the asbestos register, the following are other topics that can be included.Options availableThere would be benefit in including possible management courses of action as part of the register to help with action plans and work prioritisation. The different options for action that are available include:inspectseal and manage [with a sealant paint without disturbing the asbestos]label and reassessmanage in short term and remove in the long termprogramme to removeurgent removal required.Inspection regimesWhere a material is subject to regular inspection, the register may be used to note the date of the last inspection and the date of the due inspection.Photographic recordsInclusion of photographs in the register is useful to help others locate materials that may be concealed or disguised. They also provide a record of the condition of a material and are less open to misinterpretation than written descriptions. Increasingly, photographs are either taken using a digital camera or scanned so that they can be included in documents stored on a computer.Information from other sourcesIn some buildings the management survey may not be 100% successful in uncovering all asbestos on a site. However, other information sources can provide information on the possibility of the presence of ACMs if needed. These sources, which may include the building specification, records of remedial works and building refurbishment projects, can be included in the asbestos register.Non-asbestos materialsA note in the register can be of benefit where non-asbestos materials have been used in positions commonly occupied by asbestos materials. Locations where asbestos removal work and reinstatement have been carried out (eg replacement of an asbestos door panel or replacement of an asbestos cement sheet with an asbestos-free product) may generate enquiries every time redecoration works are planned. If information is available within the register, this can prevent unnecessary and costly re-inspections.In-house asbestos proceduresIt may be useful to include reference to the site asbestos procedures and brief notes on:the responsibilities of the employer and employeesprocedures for register maintenance and updatingthe asbestos management regimes employedany emergency procedures or permit-to-work systems that may be in force.The Asbestos Register in the Management PlanOnce produced, the asbestos register will be an integral part of the asbestos management plan. The plan should also include information on:who is responsible for managing asbestosthe plans for any work on asbestos-materialsthe schedule for monitoring the materials' condition.The plan should also specify the arrangements for managing ACMs in the building and informing every person liable to disturb the asbestos.Instructions should be included in the plan highlighting that any work on the fabric of the building cannot be allowed to start without the relevant parts of the record/register having being checked, as well as details on how this will be achieved.The plan should include details of the procedures and arrangements to make sure the:asbestos register is checked in good time before the work startsinformation on the presence of asbestos has been understoodcorrect controls will be usedwork will be carried out by competent asbestos-trained contractors.Provision of InformationAn essential part of the duty to manage under CAR is making sure that information on the location and condition of any ACMs is passed on to contractors and any other workers who may carry out work on the fabric of the building that could damage or disturb asbestos. Copies of the asbestos register, or relevant parts of it, should be used to inform every person liable to disturb an ACM or be affected by the presence of an ACM. Copies should be given to:employees, particularly maintenance staff, and their representativesvisiting maintenance workers and other tradesmen, who will need them to know the location and condition of any ACM before they start workthe emergency services.Management systems must be in place to ensure employees and visiting tradesmen are provided with relevant information from the asbestos register about the location of ACMs before they start any work in any areas where ACMs could be disturbed. A record should be kept of the information having been supplied and understood to demonstrate that asbestos management procedures are being applied.Knowing the exact location of ACMs (or presumed ACMs) is central to protecting people. The description of the location must be clear enough to allow the ACM to be easily found. This is particularly so for complex sites that must have a well-organised and clear system of describing the exact location of any suspected or identified ACM. The copies of the register provided must therefore:identify the exact location and condition of all known and presumed ACMs present in the premisesbe easily accessible and easy to understandbe current and updated as soon as any changes in the building occur.The asbestos register should clearly identify any areas:where there is a high risk due to the nature or condition of the ACMthat are either prohibited or restricted.Record KeepingThe full value of the information-gathering exercise is only realised if the data is presented in a form that is easy to manage and understand. The form of the register will be greatly influenced by the quantity of information acquired and the frequency with which it needs to be distributed. For example, multi-site organisations using a register in a key role in the management of ACMs will require a more sophisticated system than the owner of a small retail outlet.There are no set rules on the format of the asbestos register. The typical register entry format may be suitable for many organisations or could be adapted as required. Where a great deal of information has been obtained, it may be useful to restrict the amount that goes into the asbestos register record. For example, if information has been collected on materials that are frequently confused with asbestos-based products, by virtue of their use or appearance, their inclusion in the register may make it unwieldy. Any information that is too bulky can be cross-referenced from the register entry, either to an appendix or its filed location elsewhere.The format must allow for relatively easy updating, which may include comments when items have been removed, but may also result in the register increasing in size if additional materials are identified. Register Update Form provides an example method of doing this.The register or parts of it should be available in a clearly understandable form to inform every person who is liable to disturb an ACM or be affected by the presence of an ACM.There are set no rules on how the asbestos register should be kept. CAR states that the records can be kept either in an electronic or written form.Electronic recordsElectronic registers can be extremely useful if well managed. The register can be printed and the electronic version kept as the current version. Additional copies or sections can be easily printed. Spreadsheets and database systems are excellent if the register is to be used as a source of information for management or progress reports. These can also be set up to link in with other computer-based asset registers. Some specific asbestos management software is commercially available.Where a business is networked, including intranet systems, electronic registers can be easily distributed to relevant departments.Paper-based registersA one or two-page document may be adequate for sites where there is very little or no asbestos, as long as any relevant comments are also noted. If research has shown asbestos materials are unlikely, a register is still recommended, if only to record the efforts made in the process and the arguments used to reach the “asbestos-free” conclusion.Sketches or plans can be annotated and used as a register. If the location of the asbestos is marked up on the plan and information on the material form, extent and condition is included, this is a very effective method of communicating the information to contractors, etc. The system works well even if room numbers change, but difficulties can arise if building works significantly change the size or internal layout of the building. A disadvantage of plans is that it is difficult to include the form, extent and condition for each ACM location. In addition, there may be difficulties updating the plan. Colour coding asbestos occurrences on plans is common. However, it should be remembered that unless a colour copier is used the colours will be lost.The most effective way of using sketches and plans may be to reference them within simple register records for each area, so that they can be used in conjunction with the register forms to clarify the situation with regard to the presence of asbestos.Ring files are generally the most suitable system for small to medium-sized organisations. Information can be easily updated and copied. If the records increase, the documents can be divided among a number of files. A single record can then be easily expanded and the extra material slotted in if one certain area of a site requires a far greater amount of information due to the presence of asbestos.AppendicesWhere there is useful supportive information, it is often better to put this in an appendix rather than make the listings section too bulky. Typical appendices include:photographs, ie originals, scanned or from a digital camera or smart device (phone or tablet)plans, ie to help locate area references and/or marked up to show asbestos occurrencesreports, ie analytical reports, either materials analysis or air quality resultsspecial waste consignment notes, ie for asbestos waste removed from site by a licensed contractor.ArchivingThe register must show current incidences of asbestos materials, but a historical record of where they have been found, when they were removed, etc provides evidence of a good asbestos management system.Maintenance, Review and UpdateIt is recommended that procedures for maintenance, review and update are put in place, together with a means of publicising the existence of the register and designating responsibilities to relevant individuals or groups.Updating detailsWhen there is a change in the condition of an ACM, or additional ACMs are identified or suspected, it is essential that the asbestos register is updated.The register should also be updated when an ACM is repaired or removed. Information on the remedial works can also be included in the asbestos register, for example, references to the licensed contractor, analytical company, analytical reports, special waste consignment notes, duration of works, client department. This will enable any necessary records or documents to be traced if future problems arise.Information may be generated from a number of sources including:regular inspection of materials as part of the asbestos management schemereports on new or suspect materialscontractors who have carried out works and suspect that asbestos materials may be presentthe health and safety file listed within the Construction (Design and Management) Regulations 2015 — this can provide details of any remaining asbestos materials and include copies of analytical reports and inspections.Updates should be carried out as frequently as possible to keep the register current. In large companies the mechanism for updating needs to be in line with other systems in the company.ReviewOn sites where there is very little information to put into a register, the document will probably be easy to operate. Where many entries are present, it is usually worth reviewing the format before it is “published”. Difficulties with updating or copying procedures can then be identified and remedied.Discussions before publication with contributors and specialists, such as site engineers, and potential enquirers, such as contractors or designers can identify inaccuracies or ambiguities in the register before the document is used.Regular audits of the register, especially during its early operation, will encourage fine-tuning of the procedures and improvements to be made to the asbestos management system. Review of the register is required under regulation 4 of the CAR if there is reason to suspect that it is no longer valid or there has been a significant change in the premises.AccessProcedures should be in place to ensure that anyone liable to disturb ACMs is aware of their presence. Consequently, an up-to-date copy of the register must be available for anyone who requires it. The existence of the register and the relevant procedures should be well publicised, for example using notice boards, company newsletters or department briefings. The aim should be to encourage use of the register, both as a source and a recipient of information. For new employees or site contractors, information could be included as part of the site health and safety induction training.The actual location of the register, and how many copies are available, will depend on a number of factors. In many organisations, it will be suitable to keep the register in the main reception area or in the health and safety department. It should be readily accessible to contractors or anyone who could disturb the ACMs. This may require more than one copy of the register to be available. On the other hand, if there are numerous copies of the register, keeping all copies up to date can be a problem. Providing copies of the relevant part of the register may be preferable.List of Relevant LegislationHealth and Safety at Work, etc Act 1974Construction (Design and Management) Regulations 2015Control of Asbestos Regulations 2012Management of Health and Safety at Work Regulations 1999Workplace (Health, Safety and Welfare) Regulations 1992Further InformationPublicationsHSE PublicationsThe following are available from the HSE website:SG227 A Comprehensive Guide to Managing Asbestos in PremisesHSG264 Asbestos: The Survey GuideINDG223 Managing Asbestos in Buildings: A Brief GuideOrganisationsAsbestos Control and Abatement Division (ACAD)TICA-ACAD | Thermal Insulation Contractors AssociationACAD, a division of the Thermal Insulation Contractors Association (TICA), is a trade association that represents organisations specialising in asbestos and its removal.Asbestos Removal Contractors Association (ARCA)Asbestos Removal Contractors AssociationARCA aims to promote and maintain the safe working standards required for the handling and removal of asbestos and other hazardous materials.Health and Safety Executive (HSE)Information about health and safety at workThe HSE is responsible for the regulation of the risks to health and safety arising from work activity in England, Scotland and Wales, except in certain businesses (regarded as lower risk), which are the responsibility of local authorities. Its roles are to prevent work-related death, injury or ill health.

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