Minnesota Department of Health (MDH)
Food Safety Partnership (FSP) and
Partnership and Workforce Development Unit (PWDU)
QUARTERLY UPDATE
Volume 4, Issue 3, July 2010
A MESSAGE from PWDU
We know summers are busy with special events,
swimming pool inspections, and budget preparations,
so it was wonderful to see so many of you at our recent
FSP Field Day to Appert’s and the Donnay Dairy.We’re
already collecting ideas for next year’s trip and look
forward to receiving location ideas from you.
PWDU staff are busy reviewing Delegation Agreement
submissions, conducting program evaluations, and
scheduling standardizations. We’re also updating
factsheets and making plans to revamp the EHS web
pages. Please see our contact information on the last
page, and don’t hesitate to contact us.
We hope that clean-up from the recent storms is
winding down and you are able to get back to the more
enjoyable activities of summer. We look forward to
seeing you at the Germ City display at this year’s Great
Minnesota Get-Together!
April and the rest of the PWDU team.
SECTION HEADINGS
Request for Germ City Volunteers ………..…..
1
New Partners, New Resources ..….….……….. 2
Events and Announcements …………………..
3
Food Code Rulemaking Update ………………
4
Food and Food Safety Matters …..….………… 4
Legislative Activities, 2010……………………… 5
Environmental Odds and Ends ………………..
5
“Bug” of the Quarter …..………………….....…
6
nd
2 Annual Farm-to-Fork Field Day Photos .…
8
PWDU Staff Contact Information .................…. 9
PWDU Quarterly Newsletter
GERM CITY JOINS HEALTHFAIR 11 at
the STATE FAIR - HELP NEEDED
We are very pleased that HealthFair 11 has created a
place for Germ City at their busy State Fair venue in
the Crossroads Auditorium at Dan Patch Avenue and
Cooper Street on the fairgrounds.
(http://www.mnstatefair.org/_assets/pdf/MSF_Fairg
rounds_Map.pdf)
We need your help to make this an entertaining and
successful public health experience for thousands for
fairgoers. Join us any day from August 26 thru
September 6 in our new location.
Shorter shifts: Volunteer work shifts will be three
hours this year, instead of four hours. Shifts will be
from 9-12, 12-3, 3-6 and 6-9. Each shift will have one
experienced Germ City veteran as shift leader.
Volunteers will receive a Germ City tee-shirt and one
ticket to the Fair for each shift they work. Volunteers on
Friday nights, or any shift on Saturday, Sunday or
Labor Day will receive two tickets per shift.
Your Name Here: Each day, we’ll post the names of
volunteers’ schools, agencies, or employers on a board
at the front of the display. Think about sponsoring a
shift (or several) this year. Online registration will be
available in mid-July and information will be sent to all
FSP members. Contact Deborah (651-201-4509 or
[email protected]) for more details.
Page 1 of 9
NEW PARTNERS, NEW RESOURCES
ECHO: Bridging the Gap for Immigrants and
Refugees in Minnesota
Joanna Olson, ECHO
Part One: What is ECHO?
The cultural landscape in Minnesota is constantly
changing. Each year, 18,000 immigrants settle in
Minnesota. Nearly half a million residents speak a
language other than English. That means English
isn’t spoken in ten percent of Minnesota homes!
To ensure that these individuals receive vital health,
safety, emergency and civic engagement information,
ECHO was formed in 2004 to help this diverse
population integrate and become successful in
Minnesota’s communities.
ECHO communicates this crucial information in seven
languages (Somali, Hmong, Spanish, Lao, Khmer,
Vietnamese, and low-literacy English) via a television
show broadcast on tptMN, a website that houses all
past shows and topical information, public service
announcements, and outreach activities within the
community.
Part Two: Minnesota Department of Agriculture
Calls on ECHO to Spread Food Borne Illness
Warning
ECHO’s (Emergency, Community, and Health
Outreach) system for quickly communicating critical
health information was recently activated in April when
the Minnesota Commissioner of Agriculture’s office
placed a call to ECHO.
MDA officials had discovered and embargoed more
than 400 pounds of dried uneviscerated fish at ethnic
grocery stores in the Twin Cities due to the high risk of
it being contaminated with Clostridium bacteria known
to produce potentially deadly botulinum toxin.
However, they did not have a means to get this health
information out to the East African individuals and
families that had already purchased the product.
Within a few short hours, ECHO had translated the
Department of Agriculture’s news release into Somali
and Oromo. It was then circulated through ECHO’s
partner system to key contacts within the East African
community, ethnic media, and was posted on East
African websites. The word about this potential foodborne illness was successfully spread within the East
African community.
PWDU Quarterly Newsletter
Want to learn more or get involved?
Visit www.echominnesota.org where you can
become an ECHO partner,
sign up for e-alerts and our
free newsletter, like us on
Facebook, follow us on
Twitter, help shape our
programming, sign up to be
a volunteer and more.
MDH 2007 Gastroenteritis Outbreak Summary
The 2007 MDH Gastroenteritis Outbreak Summary
compiled by the MDH Infectious Disease
Epidemiology, Prevention and Control Division can be
found with the June 8 FSP meeting materials at:
http://www.health.state.mn.us/divs/eh/food/pwdu/fs
p/index.html or ordered at:
http://www.health.state.mn.us/divs/idepc/dtopics/fo
odborne/outbreak/outbreaksummary.html.
Marketing Local Food
Marketing Local Food is a handbook designed to help
Minnesota farmers explore the various options for
marketing local food. It introduces the basics of
different marketing systems, suggests resources and
includes profiles of farmers who are selling farm
products locally. It also contains information about
selling indirectly via retail food establishments or food
services. Marketing Local Food can be found at:
http://www.misa.umn.edu/Marketing_Local_Food2.
FDA: Retail Food Protection Employee Health
and Personal Hygiene Handbook
The Food and Drug Administration (FDA) has
developed an Employee Health and Personal Hygiene
Handbook to encourage practices and behaviors that
can help prevent food employees from spreading
viruses and bacteria to food. The handbook is now
available in PDF version at:
http://www.fda.gov/downloads/Food/FoodSafety/Re
tailFoodProtection/IndustryandRegulatoryAssistan
ceandTrainingResources/UCM194575.pdf
To order a paper copy, send an email to
[email protected] and request the
publication by name and publication number, IFS 04.
Page 2 of 9
EVENTS AND ANNOUNCEMENTS
2010 Health Care Occupational and
Environmental Safety Workshop
SAVE THE DATE: Environmental Sampling in
Food Manufacturing Facilities Workshop
This workshop, co-sponsored by Cincinnati Children’s
and Texas Children’s Hospitals, will be held in
Minneapolis on September 21-22, 2010
This workshop, hosted by Minnesota Food Safety and
Defense Task Force and the Minnesota Department of
Agriculture, will be held on Wednesday, July 21 from
9:00 a.m. until 5:00 p.m.
The workshop will include discussion on developing an
effective environmental sampling program, targeting
Listeria and Salmonella sp. as well as interpreting and
responding to sample results. Funding for this
workshop was made possible, in part, through a grant
by the Food and Drug Administration.
The workshop will provide attendees with practical and
up to date information on health care occupational and
environmental safety. Speaker topics relate to
Environment of Care, emergency management,
employee safety, infection control, and environmental
safety.
For registration information and workshop agenda:
http://www.childrensmn.org/conferences/
International Food Protection Training
Institute (IFPTI) 2010 Courses
More detailed information, including agenda and
registration, will be forthcoming.
FSP-Plus Short Sessions
The third FSP-Plus training will be held on
Wednesday, September 15 from 10:00 to 12:00 noon.
We are pleased to announce that Dr. Kirk Smith from
the MDH Infectious Disease Epidemiology, Prevention
and Control (IDEPC) Division will present
Epidemiology 101. The training will be available at the
usual FSP video-conference sites.
For more information, or to suggest training topics,
contact Michelle Messer (651-201-3657 or
[email protected]).
The International Food Protection Training Institute
(IFPTI) is a non-profit organization established to
deliver food protection training for state and local food
safety professionals. The IFPTI 2010 Course Schedule
is available at: http://www.ifpti.org.
This summer’s courses include, Livestock Slaughter
Inspection, Foodborne Illness Investigation, Response
to Food Emergencies, Seafood HACCP, and Instructor
Development.
All costs for training and travel by state and local
participants in this training are reimbursed by IFPTI.
Food Safety Partnership Video-Conference
The next Food Safety Partnership video-conference
will be held on Tuesday, October 5, 2010 from 9:30
a.m. to 1:00 p.m. The meeting will be hosted from the
Freeman building in St. Paul. Video-conference sites
have been reserved at MDH regional offices and other
locations. Please join us.
For information about video-conference sites or webstreaming the event, contact Maggie Edwards (651201-4506 or [email protected]).
See past FSP presentations and meeting notes at:
http://www.health.state.mn.us/divs/eh/food/pwdu/fs
p/index.html.
PWDU Quarterly Newsletter
.
Photo Courtesy of Karen Everstine
2010 Field Day participants at Donnay Dairy in
Kimball in conversation with Brad Donnay
Page 3 of 9
FOOD CODE RULEMAKING
Minutes of the Rulemaking Advisory Committee
meeting can be found on the Rule Revision website at:
http://www.health.state.mn.us/divs/eh/food/code/20
09revision/index.htm.
Food Code stream and archive addresses can no
longer be posted on the web but will be sent with
meeting notices, or can be obtained by contacting
Susan Peterson ([email protected]).
Each meeting will also be recorded and available on
DVDs. Please contact Susan if you would like her to
send you a DVD of an Advisory Committee meeting.
The next meeting of the Rulemaking Advisory
Committee will be held by video-conference on July 8,
2010, from 12:30 to 3:00 p.m. For more information
about this or future meetings, the rulemaking process,
or the Advisory Committee, contact Food Code Rule
Coordinator, Linda Prail ([email protected] or
651-201-5792.)
St. Paul and Ramsey County Announce
New Food and Nutrition Commission
In June, the City of Saint Paul announced the
formation of a joint Saint Paul – Ramsey County Food
and Nutrition Commission. Commission members
include representatives from academia, industry, and
the community.
The Commission will discuss topics such as hunger,
nutrition, food-related illness, community and backyard
gardening, farmers markets, culturally-specific food
availability, transportation for distributing and obtaining
food, food access and security and environmental
concerns related to food systems.
The Commission will
create an action plan
for a sustainable
system that increases
production, distribution
and consumption of
healthy, local food.
FOOD and FOOD SAFETY MATTERS
Minnesota Salmonella Cases Linked to
Nationwide Recall of Frozen Meals
Minnesota Department of Health (MDH) News
Release, June 18, 2010.
Summertime Consumer Resources:
Old and new materials for those of us who receive food
safety inquiries from the public:

Two recent cases of salmonellosis in Minnesota were
linked to a national recall of Marie Callender’s brand
Cheesy Chicken and Rice frozen meals.
The Centers for Disease Control and Prevention (CDC)
are conducting an investigation involving 30 people in
15 states who have been diagnosed with infection of a
rare type of Salmonella called Salmonella Chester.
Eight of the cases reported eating this product in April
and May 2010 prior to becoming ill.
MDH determined that there have been two cases of
infection with Salmonella Chester in Minnesota, and
that both cases ate the Marie Callender’s product that
was recalled. The Minnesota Department of Agriculture
isolated Salmonella Chester from an intact package of
Marie Callender’s Cheesy Chicken and Rice collected
from the home of one of the ill people.
More information is available at
http://www.fsis.usda.gov/News_&_Events/Recall_0
36_2010_Release/index.asp.
PWDU Quarterly Newsletter
USDA: Kitchen Companion: Your Safe Food
Handbook
http://www.fsis.usda.gov/PDF/Kitchen_Comp
anion.pdf
Purchasing, preparing and storing food safely –
every day and in emergencies.

USDA: Barbecue and Food Safety
http://www.fsis.usda.gov/Factsheets/Barbecu
e_Food_Safety/index.asp
Guidelines for safe home outdoor cooking.

USDA: Handling Food Safely on the Road
http://www.fsis.usda.gov/Factsheets/Handlin
g_Food_Safely_on_the_Road/index.asp

MDH: Fish Consumption Advice
http://www.health.state.mn.us/divs/eh/fish/

EPA: Should I Eat the Fish I Catch?
http://www.epa.gov/waterscience/fish/files/fis
heng.pdf
Page 4 of 9
2010 LEGISLATIVE ACTIVITIES
There were a couple of unexpected bills

Legislative Activity Related to Food
Colleen Paulus, MDH
MDH had two legislative initiatives:


Consolidation of lodging terms: House File 3476,
author, Representative Laine. After several
hours of testimony the bill was tabled. Review
this bill at:
http://www.house.leg.state.mn.us/bills/billnu
m.asp?Billnumber=HF3476&ls_year=86&sess
ion_year=2009&session_number=0
MDH submitted language to make slight
corrections to statute language. During the 2009
legislative session, changes were made to
statute that resulted in unintended
consequences. One resulted in some youth
camps paying two license fees and the other
was that Manufactured Home Parks paid two
base fees. Both situations were corrected during
the 2010 legislative session. The following two
items are found in larger bills. A summary of the
language is provided:
Youth Camps: The following correction was
made to Minnesota Statutes Section 157.16
Subd. 3 (i):
This bill modified Minnesota Statute Chapter 157
and added language that says concessions
stands operated by the schools do not have to
pay an additional license fee.

ENVIRONMENTAL ODDS and ENDS
Asian Carp: Coming Soon to a River Near You
Asian carp (seen at left in a
photo from the U.S. Fish
and Wildlife Service) were
imported by catfish farmers
in the 1970s to remove
algae and other matter
from ponds. When ponds
overflowed during floods in
the 1990s, the carp made it
to the Mississippi River and
have been steadily
swimming north.
Manufactured Home Parks and Recreational
Camping Areas: The following correction was
made to Minnesota Statutes Section 327.16:
License Required; Renewal; Fees
Subd. 3. Fees, manufactured home parks and
recreational camping areas
(iii) 100 or more sites, $300.
PWDU Quarterly Newsletter
Mobile food units – HF 3591, authors
Representative Hornstein SF 3115 Senator
Dibble. This bill can be reviewed at
https://www.revisor.mn.gov/revisor/pages/se
arch_status/status_detail.php?b=House&f=H
F3591&ssn=0&y=2009
This bill modifies Minnesota Statute Chapter 157
by allowing mobile food units to be in one place
longer than 21 days with the approval of the
regulatory authority
(i) A youth camp which pays fees under part (d)
of this subdivision is not required to pay fees
under part (h) of this subdivision.
In addition to the base fee, manufactured home
parks and recreational camping areas shall pay
$4 for each licensed site. This paragraph does
not apply to special event recreational camping
areas. or to operators of a manufactured home
park or a recreational camping area also
licensed under section 157.16 for the same
location shall pay only one base fee, whichever
is the highest of the base fees found in this
section or Minnesota Statute 157.16.
School concession stands: HF 3347, authors
were Representative Urdahl SF 2996 Senator
Fishbach. This bill can be reviewed at:
http://www.house.leg.state.mn.us/bills/billnu
m.asp?Billnumber=HF3347&ls_year=86&sess
ion_year=2009&session_number=0
A 23-pound big-head carp
was found in Lake Pepin in
October.

http://www.dnr.state.mn.us/invasives/aquatic
animals/asiancarp/index.html

http://www.dnr.state.mn.us/volunteer/marapr
04/fncarp.html

http://wcco.com/local/asian.carp.sex.2.17690
63.html
Page 5 of 9
BUG of THE QUARTER
(Recognizing and Regulating) Non-O157 shiga
toxin-producing E. coli (non-O157 STEC)
"Whatever the serotype, if a bacterium is making Shiga
toxins in the gastrointestinal tract of an infected
individual, that person is at risk for developing
[hemorrhagic colitis] and HUS."
(David Acheson and Gerald Keusch ASM News)
Background
For most Americans, E. coli is the name of a bug that
is associated with serious illness, occasional death,
and a growing awareness of food safety concerns.
E. coli became part of the national vocabulary in 1993,
when hundreds of people became ill and four children
died after eating adulterated hamburger patties at Jack
in the Box restaurants. Some people – including those
who have suffered from ill effects of E. coli-caused
foodborne illness – may know the full name of that
culprit, E. coli O157:H7 or the shorter version, O157.
However, many fewer people know that there are more
than 250 types of E. coli that produce Shiga toxin - the
toxin that can cause illness with severe stomach
cramps, and bloody diarrhea, and that may trigger the
life-threatening hemolytic uremic syndrome (HUS).
Of the many types of E. coli, there are six lesscommon strains have been identified as causing most
of the non-O157 shiga toxin-producing E. coli (or
non-O157 STEC) cases in the U.S. The CDC
estimates that these six strains (O26, O45, O103,
O111, O121 and O145) cause 36,700 illnesses, 1,100
hospitalizations and 30 deaths in the U.S. each year,
compared to about 73,000 illnesses for O157.
For example, in 2008, E. coli O111 infected more than
300 patrons of an Oklahoma restaurant. Seventy
people were hospitalized, 17 with HUS required
dialysis, and one died. Most recently, at least 26
people in five states - including three teenagers who
suffered kidney failure - became ill this April after
eating bagged romaine lettuce contaminated with
E. coli O145.
Evidence for Testing in Human Cases
The evidence that non-O157 STECs are present in the
food supply and causing significant illness is well
known by food scientists, the government and industry
but little has been done to regulate these toxic strains.
PWDU Quarterly Newsletter
In an August 2007 letter to the journal, Emerging
Infectious Disease, a group of Idaho scientists made
the case for routine culture for non-O157 STEC:
"Several studies have shown an increased incidence
of non-O157 STEC infections in the United States.
For example, a community hospital in Virginia
detected non-O157 serotypes in 31% of patients with
STEC from 1995–2002 (1). A 1998 Nebraska study
that analyzed 30,000 diarrheal stool samples found
that non-O157 and O157:H7 STEC were equally
prevalent (2). Additionally, findings from a
Connecticut study of laboratory-confirmed cases (3),
STEC surveillance results from Montana (4), and a
recent study from Michigan (5) indicate that nonO157 serotypes comprise a substantial percentage
of STEC cases.”
These and other researchers say that routine testing of
patients for the “big six” non-STECs is not performed
for two main reasons, cost and the (perhaps, now
diminishing) perception that the incidence of non-O157
STEC infections is very low.
Minnesota Data:
In a Minnesota study looking at non-O157 cases
from 2000 to 2006 (See Hedican et al reference
below), the number and proportion of STEC cases
indentified each year in Minnesota increased from
2004 to 2006.
Of 206 STEC-only cases, 108 (52 percent) involved
non-O157 serotypes and 98 (48 percent) involved
O157.
Five serotypes represented 74 percent of the nonO157 isolates: O26, O45, O102, O111, and O145.
Four of the “big six” are included in this group.
Legislation, Petition
Pressure for change is coming from other quarters as
well. Senator Kirsten Gillibrand (D-N.Y.) recently
proposed legislation to require USDA to regulate the
“big-six” non-O157 STECs. The law would make it
illegal to sell ground beef contaminated with the six
non-O157 STECs by including them in the definition of
adulterated meat. It would require meat companies to
test for and discard batches of ground beef containing
any of the described toxic strains, and would allow
USDA to identify and regulate additional strains in the
future.
Page 6 of 9
Non-O157 STEC, continued …
At the same time, Marler Clark LLP has filed a citizen
petition with the USDA-Food Safety and Inspection
Service, “Petition for an Interpretive Rule Declaring all
Enterohemorrhagic Shiga Toxin-producing Serotypes
of Escherichia coli including Non-0157 Serotypes, to
be Adulterants Within the Meaning of 21 U.S.C. §
601(m)(1).”
The consumer advocacy group Safe Tables Our
Priority (STOP) has also petitioned UDSA, requesting
that they expand the definition of adulterant to include
E. coli O157:H7 and the six other STECs when they
are in any type of beef, not just ground beef or beef
intended for ground beef.
The petitions from Marler Clark and STOP essentially
request that USDA take action on the matter of nonO157 STECs. The legislation would circumvent what
has already been a lengthy government process by
creating new law requiring immediate action.
Response from Industry and Others
"We share Sen. Gillibrand’s desire to eradicate
pathogenic bacteria, but we don’t believe that an act
of Congress can make these bacteria disappear.”
(American Meat Institute Statement)
In addition to saying that declaring non-O157 STECs
an adulterant would do little to enhance food safety, a
statement from the American Meat Institute claimed
that there is no test available to detect the six toxic
strains. The reality may be that there is no cheap and
simple, rapid test available to the industry.
The meat industry is not alone in their opposition to a
law imposing immediate regulation of non-O157
STECs.
Dr. David Goldman, assistant administrator for the
Office of Public Health Science for FSIS, says the
agency is reluctant to broaden the definition of
adulterant until a reliable and rapid test is ready for the
market. He said that such a screening tool would be
available in the “next six months or so.”
However, the agency currently plans to do its own
testing to determine the extent to which the non-O157
strains exist in the meat supply before taking any
action.
.........
PWDU Quarterly Newsletter
One (massive) retailer doesn’t plan to wait for either
legislation or government action. In late April, Walmart
announced that it would require specialized testing for
E. coli O157, Salmonella, and non-O157 strains of E.
coli in meat products purchased for Walmart and
Sam’s Club stores.
"In light of recent beef recalls, we determined it was
prudent to require an additional layer of protection for
our customers," said Frank Yiannas, Walmart's vice
president for food safety. "As part of our continuous
improvement efforts, we go further than many U.S.
retailers in requiring leading-edge food safety
standards throughout the entire food production chain."
The preceding article was adapted from these and
other sources:
Which Shiga Toxin-Producing Types of E. coli Are
Important?
David W. K. Acheson and Gerald T. Keusch, ASM News,
Vol. 62, NO.6, 1996
Shiga toxin–producing Escherichia coli,[letter],
Lockary VM, Hudson RF, Ball CL. Idaho. Emerg Infect Dis,
2007 Aug
Characteristics of O157 versus Non-O157 Shiga ToxinProducing Escherichia coli Infections in Minnesota,
2000-2006
Hedican E, Medus C, Besser J, et al, Clinical Infectious
Diseases, 2009:49, (1 August)
Shiga Toxin–producing Escherichia coli, New Mexico,
USA, 2004–2007,
Sarah Lathrop, Karen Edge, and Joseph Bareta, EID
Journal Vol.15, NO. 8, August 2009
In E. Coli Fight, Some Strains Are Largely Ignored,
William Neuman, New York Times, May 26, 2010
http://www.nytimes.com/2010/05/27/business/27bugs.h
tml
Questioning the Search for More Strains of E. coli
Food Safety News, June 25, 2010
http://www.foodsafetynews.com/2010/06/questioningthe-search-for-more-strains-of-e-coli/
and now for something completely different
...
Page 7 of 9
Second Annual FSP Farm to Fork Field Trip: Appert’s Food Service, St. Cloud and Donnay Dairy, Kimball.
We didn’t get many photos at Appert’s
because cameras weren’t allowed, but
Lynne Markus and Angie Wheeler got
these shots of the front entrance, and of
Field Day participants getting all dolled
up for their visit to the production plant .
Everyone liked most of the tour but hardly
anyone wanted to stay long in the
gigantic freezers.
Both tour groups asked a lot of questions about cheese processing at the Donnay Dairy. (Yes, the
cheese is pasteurized, and yes, the family drinks raw goat’s milk) However, the goats seemed to be the
biggest attraction. Brad Donnay milks 132 goats twice a day. And no, goats won’t eat just anything.
Although they nibbled at a few shirts and fingers, everyone and most every thing departed intact.
PWDU Quarterly Newsletter
Page 8 of 9
Thanks to Angie Wheeler, Colleen Paulus, Karen Everstine, Sara Shafer and Trisha Robinson for Photos
PARTNERSHIP AND WORKFORCE DEVELOPMENT UNIT STAFF CONTACTS
April Bogard Supervisor, PWDU
[email protected]
651-201-5076,
612-296-8118
Deborah Durkin, Food Safety Partnership, newsletter,
manual, food safety education and outreach
[email protected]
651-201-4509,
651-295-5392
Maggie Edwards, administrative support
[email protected]
651-201-4506
Lynne Markus, emergency response, climate change
[email protected]
651-201-4498
Michelle Messer, training, program evaluation,
standardization
[email protected]
651 201-3657,
651 775-6238
Michael Nordos, training, program evaluation,
standardization
[email protected]
651-201-4511,
651-775-6234
Angie Wheeler, training, program evaluation,
standardization
[email protected]
651-201-4843
651-373-7381
MINNESOTA DEPARTMENT OF HEALTH
DIVISION OF ENVIRONMENTAL HEALTH
Orville L. Freeman Building
625 North Robert Street
Saint Paul, Minnesota 55155
PWDU Quarterly Newsletter
http://www.health.state.mn.us/ehs
http://www.health.state.mn.us/foodsafety
Page 9 of 9