by Marion Nestle

Search results: meat drugs

Mar 3 2013

Food Matters: Horsemeat scandal has eaters nervous

My monthly (first Sunday) column in the San Francisco Chronicle is now out, this time on the horsemeat scandal.

Q: It makes me sick to think that anyone could eat horsemeat. I don’t see how it could get into so many foods. Tell me how I can be sure I’m not eating it.

A: From this side of the Atlantic, the discovery of horsemeat in European hamburger and frozen dinners is the most riveting of scandals, replete with DNA technology, veterinary drugs, impossible-to-trace supply chains, smuggling, organized crime and outright fraud – not to mention the usual finger-pointing, cover-ups and protestations of shock that accompany food crises.

It is easy to explain how horsemeat got into vast amounts of hamburger and prepared meals. Horses are expensive to house and feed. Something has to be done with them when they are no longer wanted for farming, transport, racing or recreation. Horsemeat is edible, even delicious to some, and costs less than beef.

Complications

In Europe, the supply chains are exceptionally complicated, involving countless companies in more than 21 countries that process, transport or sell horses or horsemeat. The complexity makes it relatively easy to use horses to smuggle people or drugs, to label horsemeat as beef or to slip it into hamburger.

This would just be a matter of economic fraud if people didn’t care whether they ate horsemeat. But some Europeans, and most Americans, care very much. Like you, many people are appalled at the idea of eating any companion animal, let alone one symbolic of the rugged West.

Beyond cultural prohibitions, there are other reasons to avoid eating meat from horses not raised for food. Horses are routinely treated with veterinary drugs, legal and not. The drug traces found in European horsemeat may be too low to cause harm, but hardly seem likely to promote human health.

How long horsemeat has been passed off as European beef is unknown, as is why officials in Ireland decided to do DNA tests on supermarket meals in the first place. Whether done as routine testing or because of a tip, the results were startling. More than one-third of the tested “beef” samples contained horsemeat. Later tests in Great Britain identified “beef” meals made entirely from horsemeat.

This, as the Guardian’s writer Felicity Lawrence wrote in her guide to the scandal, can only be “industrial scale adulteration.”

The ensuing crisis forced many food companies and retailers to recall vast numbers of products, some intended for school meals. Nestlé (no relation) recalled pasta meals, but issued assurances that such products do not leave Europe and that none of its American products contains horsemeat-laden European beef.

What to make of this? In our food studies programs at New York University, we discuss food as a marker of cultural identity. People in other nations eat horsemeat. But like you, about 80 percent of Americans are appalled at the idea of eating horsemeat and oppose slaughtering horses for food or any other reason.

Yet horsemeat used to be eaten by Americans (and still is, by some), and even more so by pets. As Malden C. Nesheim and I wrote in our book about the pet food industry, “Feed Your Pet Right,” horse slaughterhouses created pet food companies to dispose of the meat. Through the 1940s, nearly all domestic horsemeat ended up in pet food.

Under pressure from horse lovers and animal welfare advocates, pet food companies replaced horsemeat with meat from other animals. Although horsemeat is permitted in pet food, and in theory could show up in rendered byproducts and meals, no American company would knowingly use it as an explicit item in an ingredient list. One can only imagine the uproar if it did.

Inspection issues

In 2007, Congress blocked the Department of Agriculture from inspecting slaughterhouses, effectively banning their use. As unintended consequences, the 140,000 or so unwanted horses each year had to be transported to slaughterhouses in Canada or Mexico, and populations of neglected and abandoned horses increased. As a result, Congress permitted horse slaughterhouses to reopen last year, but the USDA has yet to authorize inspectors to work in them.

Could American beef be contaminated with horsemeat? We had a similar scandal in the 1950s. But if U.S. officials are testing hamburger for horsemeat DNA these days, they aren’t saying.

Because horsemeat is not produced here, it won’t be in butcher shops or supermarkets – unless the stores imported it or acquired contaminated products before the recalls, or unless the USDA assigns inspectors and allows horse slaughterhouses to reopen. Right now, without DNA testing, you can’t be sure.

You find this alarming? Short of going vegetarian, you have an option: Buy kosher meat. Jewish dietary laws prohibit horsemeat – horses are not ruminants and do not have cloven hooves – and kosher slaughterhouses are diligent about excluding forbidden animals.

This gives the horsemeat scandal one clear winner: Sales of kosher meat are booming.

Feb 19 2013

The horsemeat scandal–an object lesson in food politics

The unfolding drama around Europe’s horsemeat scandal is a case study in food politics and the politics of cultural identity.

Cultural identity?  They (other people) eat horsemeat.  We don’t.

Most Americans say they won’t eat horsemeat, are appalled by the very idea, and oppose raising horses for food, selling their meat, and slaughtering horses for any reason.

These attitudes have created dilemmas.  Since Congress effectively banned horse slaughter in 2006, roughly 140,000 horses a year have been transported to Canada and Mexico to be killed.  Whether this is better or worse for the horses is arguable.  Some—perhaps most—of that meat will be exported as food.

As Mal Nesheim and I wrote in our book about the pet food industry, Feed Your Pet Right, most—more than 90%—of domestic horsemeat ended up in pet food (the rest was eaten or shipped to Europe).  In the 1920s, horse slaughterhouses started pet food companies as a means to dispose of the meat.  Horsemeat remained a major ingredient of dog foods throughout the 1940s.

Since then, pet food companies replaced horsemeat with meats from other animals.  Although it continues to be permitted in pet food, I’m not aware of any company that would dare use it.  It would have to be disclosed on package labels.

That brings me to the European horsemeat crisis, one brought about by advances in DNA technology that allow officials to test for species in foods.

I’m indebted to Joe O’Toole, president of Lucullus, a French specialty food company, for keeping me up to date on the unfolding saga of how horsemeat got into European hamburger and so many other foods.  He sent me links to early stories:

The problem first emerged earlier in January when the Food Safety Authority of Ireland handed over results of DNA tests it had carried out on burgers produced in Ireland for sale in the UK. Samples from 10 of 27 products sourced from three processing plants had tested positive for horse DNA. One sample is said to have contained 29 percent horse.

As the article explained, the immediate response was “a relatively faultless exercise in damage control.”  Food processors immediately recalled their products and Tesco, Britain’s largest supermarket chain, placed an ad and followed it up with a video apology.  This is viewed as excellent damage control.  Although Tesco shares dropped by 1 percent for a loss of  $475 million, it could have been worse.  

Leaving aside the cultural prohibitions against eating horsemeat, here’s what I find fascinating:

  • DNA technology made this possible.
  • The supply chain is so complicated and involves so many countries—Romania, Ireland, Netherlands, Spain, Poland, France, and, no doubt, others—that where the meat comes from is impossible to trace.
  • The finger pointing  over who is to blame.
  • The enormous number of companies involved.
  • The idea that this is a drug issue (horses are treated with drugs).
  • The idea that horse transport is used as a cover for smuggling (drugs and people).
  • The involvement of organized crime (if selling horsemeat is illegal…).

By far the best place to start on this story is Felicity Lawrence’s Horsemeat Scandal: The Essential Guide, in The Guardian. She did this as a Q and A:

1. Where did the horsemeat scandal begin?

2. Where did the horse and pig found by the Irish in beef products come from?

3. Why did some products contain so much more horse than others?

4. How did the rest of Europe get involved?

5. Is the source of the Irish horsemeat the same as the French one?

6. Why are the supply chains so complex?

7. Why has it happened?

8. How is the meat industry regulated?

9. What about industry claims that it has full traceability?

10. What happened to government control of food safety and standards?

11. Where do the horses come from?

12. What part do UK horse abattoirs play?

13. Why are governments talking about organised crime?

14. Is it a health problem?

I will have more to say about this later, as more details emerge.  Stay tuned!

Addition, February 27: Australia Food Safety News offers this terrific infographic on the scandal.

Apr 19 2011

The politics of contaminated meat

By this time, you must have heard about the study in Clinical Infectious Diseases sponsored by the Pew Charitable Trusts.  The study found nearly half of supermarket meat and poultry samples to be contaminated with Staphylococcus aureus. Half of the contaminated samples were resistant to multiple antibiotics.

Staph causes awful infections.  When I was a child, my mother had a Staph infection that kept her out of commission for what seemed like months in that pre-antibiotic era.  Antibiotics can keep Staph under control, but not if the Staph are antibiotic-resistant.   Staph resistant to multiple drugs are a clear-and-present danger.  No wonder this study got so much attention.

The study provides strong support for the idea that we ought to be reducing use of antibiotics as growth promoters in farm animals, an idea strongly supported by the CDC.

Even though 80% of U.S. antibiotic use is for farm animals, the meat industry strong opposes any proposal to change its practices.

The National Cattleman’s Beef Association responds by attacking the science:

Calling into question the safety of U.S. beef without conclusive scientific evidence is careless and misleads consumers. Pew Charitable Trusts, an agenda-driven organization on this issue, funded this study, which concludes that its extremely small sample size was ‘insufficient to accurately estimate prevalence rates’ and that ‘public health relevance of this finding is unclear.’ The study’s authors clearly call into question the validity of their own study. The bottom-line is U.S. beef is safe and is part of a healthy, well-balanced diet.

The American Meat Institute reassures the public that meat is safe.  After all, you are going to cook your meat, aren’t you?  In any case, the responsibility rests with you.

While the study claims that the many of the bacteria found were antibiotic resistant, it does note that they are not heat resistant.  These bacteria are destroyed through normal cooking procedures, which may account for the small percentage of foodborne illnesses linked to these bacteria.

As with any raw agricultural product, it is important to follow federal safe handling recommendations included on every meat and poultry package that urge consumers to wash hands and surfaces when handling raw meat and poultry and to separate raw from cooked foods to ensure that food is safe when served.

These sound like the arguments that the meat industry has made for years for Salmonella and E. coli O157:H7.

I see this study as another reason why we need better food safety regulation, and the sooner the better.

Postscript: Bill Marler reports that he had 100 samples of chicken tested from Seattle markets:

IEH Labs found S. aurea [sic], or staph, in 42 percent of the samples overall and Campylobacter in 65 percent. The supermarket chicken was contaminated with other pathogens as well: 19 percent of the samples tested positive for Salmonella, one tested positive for Listeria, and 10 percent showed the presence of the methicillin-resistant S. aureus (MRSA). In an unusual finding, one of the chicken samples tested positive for E. coli 0126, Shiga-toxin producing E. coli (STEC) bacteria more likely to be a contaminant of beef than poultry. Organic Chicken proved to be slightly less contaminated than nonorganic with 7 of the 13 (54%) testing positive for harmful bacteria.

As I said….

Sep 30 2016

Weekend reading: “Chickenizing”

Ellen K. Silbergeld. : How Industrial Meat Production Endangers Workers, Animals, and Consumers.  Johns Hopkins Press, 2016.

Ellen Silbergeld, a professor of environmental health sciences, epidemiology, and health policy at Hopkins, has long been a strong advocate for getting toxic substances out of our food supply.  Here, she takes on our system of industrial farm animal production in a plea for better treatment of everyone and everything involved in it.

Big issue #1: the use of antibiotics as growth promoters.  This not only induces bacteria to become resistant to those drugs, but also is unnecessary.

Big issue #2: the failure of HACCP (Hazard Analysis and Critical Control Point—the method for preventing food safety problems) to prevent harmful, antibiotic-resistant bacteria from reaching the public.

Overall, she says:

The inextricable relationship between industrial food animal production and the environment challenges us in two ways.  First, we are all at risk–not just those of us who consume the products of industrially raised animals–and second, decontaminating food products will not contain the public health problems of this industry.  It is time to think about industrial food animal production as an industry in terms of environmental pollution, and it is long overdue to recognize that its pollution footprint, like its production, is industrial in scale (p. 127).

As for the remedy, “agriculture is an industry, and as such it carries certain obligations.”  These include, among others:

  • Industries must abide by laws that prevent monopolization, price fixing, and overconcentration.
  • Industries must bear full liability for unsafe products.
  • Industries must obey the labor laws of the country.

She has plenty more to say about government’s role in all this.

Our role is to insist that industry and government follow and apply laws.  We had best get busy.

Dec 17 2013

The FDA issues guidance on animal antibiotics–voluntary, alas, but still a major big deal

I was in Washington DC last week when the FDA announced  that it was taking significant steps to address antibiotic resistance, a problem caused by overuse in raising animals for food.

The FDA called on makers of animal antibiotics to:

  • Voluntarily stop labeling medical important antibiotics as usable for promoting animal growth or feed efficiency (in essence, banning antibiotics from these uses).
  • Voluntarily notify the FDA of their intent to sign on to these strategies within the next three months.
  • Voluntarily put the new guidance into effect within 3 years.
  • Agree to a proposed rule to require a veterinarian’s prescription to use antibiotics that are presently sold over the counter (the proposal is open for public comment for 90 days at www.regulations.gov.   Docket FDA-2010-N-0155).

Voluntary is, of course, a red flag and the Washington Post quoted critics saying that the new guidance falls far short of what really is needed—a flat-out ban on use of antibiotics as growth promoters.

  • Consumers Union is concerned about the long delay caused by the 3-year window.
  • CSPI is worried about all the loopholes.
  • NRDC thinks the FDA is pretending to do more than it’s really doing and “kicks the can significantly down the road.”
  • Mother Jones points out that the meat industry can still “claim it’s using antibiotics ‘preventively,’ continuing to reap the benefits of growth promotion and continue to generate resistant bacteria.”
  • Civil Eats reminds us that the Pew Commission on Industrial Farm Animal Production (on which I served) recommended a ban on nontherapeutic use of all antibiotics.

Yes, the loopholes are real, but I view the FDA’s guidance as a major big deal.  The agency is explicitly taking on the antibiotic problem.  It is sending a clear signal to industrial farm animal  producers that sooner or later they will have to:

  • Stop using antibiotics as growth promoters.
  • Stop using antibiotics indiscriminately, even for disease treatment.

I think the FDA is dead serious about the antibiotic problem.  If the FDA seems to be doing this in some convoluted fashion, I’m guessing it’s because it has to.  The FDA must not have been able to find any other politically viable way to get at the antibiotics problem.

I see this as a first step on the road to banning antibiotics for any use in animals other than the occasional treatment of specific illnesses.

As the New York Times puts it,

This is the agency’s first serious attempt in decades to curb what experts have long regarded as the systematic overuse of antibiotics in healthy farm animals, with the drugs typically added directly into their feed and water. The waning effectiveness of antibiotics — wonder drugs of the 20th century — has become a looming threat to public health. At least two million Americans fall sick every year and about 23,000 die from antibiotic-resistant infections.

Still not convinced antibiotics are worth banning for promoting growth?

The best explanation is the Washington Post’s handy guide to the antibiotic-perplexed.  Here, for example, is its timeline of development of microbial resistance to antibiotics.  The bottom line: the more widespread the use of antibiotics, the greater the onset and prevalence of resistance.  And it takes practically no time for bacteria to develop resistance to antibiotic drugs.

nchembio.2007.24-F1

Resources from FDA

Apr 12 2012

The FDA takes action on animal antibiotics, at long last

Yesterday, the FDA proposed long-awaited action against use of antibiotics for non-therapeutic purposes in animal agriculture.

From the outside, this might look more like inaction.  The agency is asking drug companies to voluntarily cut back on producing antibiotics for non-therapeutic purposes and to require veterinary oversight of use of these drugs.

The announcement comes in the form of three documents in the Federal Register.

  • Final Guidance for Industry: The Judicious Use of Medically Important Antimicrobial Drugs in Food-Producing Animals.
  • Draft Guidance for Industry aimed at assisting drug companies in voluntarily removing from FDA-approved product labels uses of antibiotics for production rather than therapy, and voluntarily changing the marketing status to include veterinary oversight.  This is open for public comment.
  • A draft of a proposed Veterinary Feed Directive regulation,  also open for public comment, outlining how veterinarians can authorize the use of antibiotics in animal feed.

In an FAQ on the announcement, the FDA answers some obvious questions:

4. What is “judicious use” and what are FDA’s recommendations?

“Judicious use” is using an antimicrobial drug appropriately and only when necessary;

Based on a thorough review of the available scientific information, FDA recommends that use of medically important antimicrobial drugs in food-producing animals be limited to situations where the use of these drugs is necessary for ensuring animal health, and their use includes veterinary oversight or consultation.

FDA believes that using medically important antimicrobial drugs to increase production in food-producing animals is not a judicious use (my emphasis).

5. Why did FDA decide to do this now?

FDA has worked with many stakeholder groups and the U.S. Department of Agriculture (USDA) to develop a strategy that will be successful in reducing antimicrobial resistance while minimizing adverse impacts on animal health and disruption to the animal agricultural industry.

In June 2010, FDA released a draft guidance document explaining its recommendations for change and in the interim period sought and received input from various stakeholders, including the animal pharmaceutical industry, animal feed industry, veterinary and animal producer communities, consumer advocacy groups and USDA.

Translation: this has been in the works for a long time and is the result of extensive discussions with the relevant industries.

As Food Safety News explains, the reaction of just about everyone to this announcement has been tepid.

  • Food safety advocates object to voluntary, because it never works.
  •  The meat industry insists that non-therapeutic antibiotics are essential for producing cheap meat under crowded conditions.

For example, the National Pork Producers make the usual industry arguments:

Harm to small farmers: The guidance could eliminate antibiotics uses that are extremely important to the health of animals…And the requirement for VFDs [veterinary oversight] could be problematic, particularly for smaller producers or producers in remote areas who may not have regular access to veterinary services.

Voluntary equals regulation: The guidance, which does not have the force of law but may be treated as such by FDA, is a move to address an increase in antibiotic-resistant illnesses in humans, which opponents of modern animal agriculture blame on the use of antibiotics in livestock and poultry production.

The science is “junk”: But numerous peer-reviewed risk assessments, including at least one by FDA, show a “negligible” risk to human health of antibiotics use in food-animal production.

My interpretation:

The FDA’s position on non-therapeutic use of antibiotics in animal agriculture is quite clear.  The agency recognizes that based on the science, the use of antibiotics as growth promoters in animals poses a serious risk to human health.

I’m guessing this is the best the FDA can do in an election year.

This move looks to me like a direct challenge to drug companies and meat producers to clean up their acts and take some responsibility for the effects of their misuse of animal antibiotics on public health.

It’s also a challenge to food safety advocates to make sure that the FDA monitors the effects of its voluntary guidance and, if the industries don’t cooperate, that the FDA gets busy on real regulations.

Addition: The account in today’s New York Times explains why the FDA is starting with voluntary efforts:

The reason for the reliance on voluntary efforts is that the F.D.A.’s process for revoking approved drug uses is lengthy and cumbersome, officials said. The last time the F.D.A. banned an agricultural use of a medically important antibiotic against the wishes of its maker, legal appeals took five years. In this case, hundreds of drugs are involved, each with myriad approved uses in various animals.

“You and I and our children would be long dead before F.D.A. could restrict all of these uses on its own,” Ms. Rogers [of the Pew Foundation]said.

Apr 6 2012

Tired of hearing about beef processing? Try chicken.

Apparently as a result of a need to cut costs, the USDA is changing the way its inspectors oversee chicken processing.

As Dana Milbank of the Washington Post puts it, this is

a proposal to allow chicken slaughterhouses to inspect themselves — eliminating those pesky federal monitors who have the annoying habit of taking diseased birds out of the food supply.

Even if the Obama administration were inclined to bring down capitalism with an orgy of overregulation, there isn’t enough money in the budget to enforce the rules on the books.  That’s what the chicken fight is about: Spending cuts…are a form of de facto deregulation (my emphasis).

The New York Times account of this policy change notes that inspectors:

had observed numerous instances of poultry plant employees allowing birds contaminated with fecal matter or other substances to pass. And even when the employees try to remove diseased birds, they face reprimands….

The Agriculture Department proposal allows poultry plants to speed up their assembly lines to about 200 birds per minute from 140, hampering any effort to examine birds for defects.

But that’s not all.  The Center for Livable Future at Johns Hopkins  reports that meal made from chicken by-products (in this case, feathers) contains arsenic and antibiotics such as fluoroquinolones that have been banned by the FDA for use in poultry.

A study published in Environmental Science & Technology found fluoroquinolone antibiotics in 8 of 12 samples of feather meal collected from six states and China.

A second study found arsenic in every sample of feather meal tested.

These findings indicate that poultry producers are using these drugs, even though they are not allowed to.

The U.S. poultry industry raises about 9 billion chickens and 80 million turkeys for human consumption each year.  Meal made from their feathers is commonly added to feed for chickens, pigs, cattle, and fish.  This could be a reentry route into the human food supply for such drugs.

Nicholas Kristof explains in the New York Times that these studies also found feather meal to contain

an antihistamine that is the active ingredient of Benadryl…[and] acetaminophen, the active ingredient in Tylenol.  And feather-meal samples from China contained an antidepressant that is the active ingredient in Prozac.

Poultry-growing literature has recommended Benadryl to reduce anxiety among chickens, apparently because stressed chickens have tougher meat and grow more slowly. Tylenol and Prozac presumably serve the same purpose.

Such findings indicate some of the worst problems with industrial poultry production.  They result from pressures to produce chickens cheaply.  The faster chickens can be pushed to grow, the less feed they consume and the cheaper they are to raise.

I don’t know what the best system for inspection might be, but I’m quite sure that leaving food safety oversight to the discretion of the packers is not a good idea.  Neither is speeding up the line.  And neither is feeding chickens drugs that can affect human health.

Here is even more evidence for the need for an overhaul of our food safety system.

A single food safety system anyone?

Jan 10 2012

Antibiotics in farm animals: FDA issues weak rule

By this time everybody knows—or ought to—that the non-therapeutic use of antibiotics in farm animals is a threat to human health. 

Using antibiotics to promote animal growth or reduce feed requirements is a bad idea.  Widespread use of these drugs induces microbial resistance, making the antibiotics ineffective against human disease.

So you would think that public health agencies would be falling all over themselves trying to reduce antibiotic use in farm animals.  No such luck.  Proposals to restrict use of antibiotics for therapeutic purposes runs up against the interests of meat and poultry industries. 

The best the FDA can do falls far short of what is needed.  Witness its pussy footing on cephalosporin drugs.

On January 4, the FDA proposed a final rule on use of cephalosporin drugs in animal agriculture.

The rule bans some “extralabel” (i.e., unapproved) uses of cephalosporin antimicrobial drugs in some food animals—cattle, swine, chickens, and turkeys. 

As the FDA’s press release explains, it is banning use of cephalosporins:

  • At unapproved dose levels, frequencies, durations, or routes of administration
  • In forms that are not approved for use in cattle, swine, chickens, and turkeys because they are intended for humans or companion animals
  • For disease prevention

These are all good things but should do much more. 

Cephalosporins are used in humans to treat pneumonia, skin and soft tissue infections, pelvic inflammatory disease, diabetic foot infections, and urinary tract infections.

If bacteria are resistant to cephalosporins, doctors have fewer options for treatment and these are less effective or more harmful.

 What is troubling is that the FDA proposed a more restrictive ban in 2008 but reversed the decision under pressure from industry veterinarians.

As Food Safety News reports, the new order, which is scheduled to go into effect in April, follows a couple of previous notices published last year. 

In November, the FDA turned down consumer petitions calling for a ban on the non-therapeutic use of a broader range of antibiotics in farm animals. 

In December, the FDA admitted that it had given up a plan first announced in 1977 to withdraw approval for penicillin and tetracyclines in animal feed.

Apparently, the FDA has decided to try to get drug companies and the meat and poultry industries to reduce the use of antibiotics voluntarily.

Good luck with that. 

Philip Brasher writes in the Des Moines Register that the new restrictions will hit hardest on the chicken industry, which uses the drugs for disease prevention. 

He says the FDA’s 2008  proposal would have blocked hog producers from treating illnesses that aren’t listed on the label.   He quotes the chief veterinarian for the National Pork Producers Council:

We are pleased that FDA balanced the need to protect animal health with their concerns about resistance.

This is not about animal health.  Nobody is trying to stop the use of antibiotics to treat animal disease.  At issue is their use as growth promoters or feed savers.

Congresswoman Louise Slaughter (Dem-NY) understandably views the FDA’s action as “tepid.”  She has introduced the  Preservation of Antibiotics for Medical Treatment Act to deal with the problem of non-therapeutic antibiotic use.  Of the FDA’s proposal, she said:

This is a modest first step by the FDA…but we’re really just looking at the tip of the iceberg. We don’t have time for the FDA to ploddingly take half-measures. We are staring at a massive public health threat in the rise of antibiotic-resistant superbugs. We need to start acting with the swiftness and decisiveness this problem deserves.

We do indeed.  Her bill deserves much support.   Public health should not be left up to the meat, poultry, and drug industries to decide.

Addition, January 12: I missed the New York Times editorial on this issue:

It’s time for the F.D.A. to consider the public’s health as carefully as it considers the interests of intensive agriculture and pharmaceutical companies.

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