An ECA Foundation Interest Group European Qualified Person Association Tool Box – Version 1.0 – September 2014 ............................................................................................................................ .................................................................................................................... ....................................................................................................... ......................................................... ....................................................................................... ..................................................................................... ................................................ ....................................................................................................................... .............................................................................................................................. ................................................................................................................... .................................................................. ................................................................................ ..................................................................................... .............................................................................................................................. .............................................................................................................................. .......................................................................... .................................................................................................................................... .................................................................................................... .......................................................................................... Product Product Name Article Number Batch Number Batch Record Number : : : : Page: Explanation: √= oK; ο= missing, not correct; n.a. = not applicable Incoming date: sender: Check Format (Good Documentation Practice – Conformance): - Record complete - Paging correct - Readable entries and corrections - additional records attached, paged and readable - Thermo paper copied and signed - Fields not used on the form are crossed out - Entries dated and signed - All necessary signatures - Attachments are paged and listed Content: - Batch manufacturing procedure approved - Batch record complete - Manufacturing information given (dates, yield), Due date: Result Remarks X of n - Compounding Ingredients, intermediates and packaging material with article number and batch number Quality Control records/ analytical batch records available Manufacturing - Work Preparation (Equipment, Material) - Initial weight print outs - Initial weight double check - Identity samples taken - Equipment (equipment used recorded, equipment ready for use?) - process data: comply with requirements comply with attachments (cross-reference!) attachments correct - IPC – Data: comply with specifications if OOS, additional documentation availabel (Doc.Nr.) comply with attachments (cross-reference!) attachments correct - Labels: content correct balancing correct - Holding times documented - Yield calculated - Yield within specification Deviations - Deviations documented and evaluated by Head of Production - Deviation process initiated (Doc.-Nr.) Result Remarks Review of Result Remarks - equipment cleaning and approval - room cleaning and approval - Room temperature, humidity and air pressure data Delivery receipt - drum- number/-name or amount of product - signatures complete - Product Quality Review: Data transferred 3.1.2 Example Checklist 2 Product .………........................................................................................................ Batch.no ........................................................... A. Conformity with Marketing Authorisation / Registration Certificate 1 2 3 4 The product name is as specified in the Marketing Authorisation / Registration Certificate Manufacturing formula is the authorized one Expiry data is the authorized one Steps of manufacturing process performed as required 5 All approved controls was performed. Testing was conducted in accordance with approved specifications for intermediary, bulk and finished product 6 Finished product testing results are compliant with the acceptance limits stated in the approved Bulk Product Specification/ Finished Product Specification 7 The labeling is consistent with the Marketing Authorisation / Registration Certificate. On the batch records they are attached samples of printed packaging materials used 8 Leaflet is the latest version authorized by Marketing Authorisation / Registration Certificate B. Conformity with GMP 1 2 3 4 Batch processing/ packaging records are available and provide the history of batch Batch processing/ packaging records include the dates and times for beginning and completion of the manufacturing steps Batch processing/ packaging records signed by the responsible personnel and, where appropriate, for ckeck of major manufacturing steps All manufacturing operations were conducted in accordance with applicable approved procedures DA Yes NU No NA Not applica ble 5 Starting/ packaging materiales used come from approved suppliers 6 Starting materials and packaging materials were tested in accordance with approved specifications and have been released for manufacturing by the responsible persons 7 Manufacturing formula is correctly calculated and starting materials batch numbers used are documented 8 9 10 11 12 Approved, applicable procedures have been used The manufacturing process has been validated Yields obtained are within the limits set Equipment used is qualified Reports for monitoring the environmental conditions as stipulated in the approved procedures are attached Sterilization reports of equipment / parts used are attached Testing methods have been validated Deviations were recorded and investigated according to the applicable procedure OOS results were recorded and investigated according to the applicable procedure The changes implemented have been approved A program to monitor the stability is implemented and results are available All reference samples and relevant samples are available at all times Batch Records have been assessed by Head of Production and Head of Quality Control 13 14 15 16 17 18 19 20 Comments: ............................................................................................................................................... ............................................................................................................................................... ............................................................................................................................................... ............................................................................................................................................... ............................................................................................................................................... Checklist for Review of Batch Documentation Product Name: Dosage strength Batch No.: PL Number: If “no”, fill in justification/ remarks below Batch Documents Batch documents equivalent to Master Documents All records comply with the rules of Good Documentation practice (SOP xyz) All entries have been made in the correct data fields Batch Manufacturing Instructions Line clearances (equipment/ area) carried out Strat up tests carried out and verified All challenge tests carried out All in-process checks (IPC) carried out at correct intervals Print-outs for IPC are attached and numbered All IPC within specification Process yields are correct and within acceptable limits or justified Identification/ cleaning labels are attached Time limitation of each production step within acceptable limits Raw data accurate? Batch Packaging Instructions Line clearances (equipment/ area) carried out Product and packaging material identification approved Strat up tests carried out and verified All challenge tests carried out All in-process checks (IPC) carried out at correct intervals Print-outs for IPC are attached and numbered All IPC within specification Representative sampling of each pack type and size Yield and reconciliation correct and within acceptable limits Correct batch number and expiry date on primary and secondary packaging PIL/Carton is correct and pertains to product Transit Temperature Data Report Report attached Deviations/ OOS All deviations logged and justified Deviation reports available Did OOS results occur? If yes, check if OOS documentation is available and complete Change Control Did Changes occur? If yes, check if Change Control documentation is available and complete Yes No Yes No Yes No Yes No Yes No Yes No Additional Requirements for Sterile Products: Checklist for Review of Batch Documentation Product Name: Dosage strength Batch No.: PL Number: If “no”, fill in justification/ remarks below Additional Documents for Sterile Products All necessary reports available like environmental reports, sterilisation cycle reports, lyophilisation cycle reports, filtration integrity testing reports All records comply with the rules of Good Documentation practice (SOP xyz) Was batch included in any stability, environmental program or validation exercise? Records for sterility testing available? Yes No Product: Description Investigational medicinal product: * EudraCT number: * Study protocol code, and Centre Dosage form: Pack size: Batch: In charge: Date of manufacture: Planned release: Expiry date: o placing o release regular o clinical trial o stored until processing o release quarantined * If known No. 01 Request: Application of the sponsor for the conduct of the trial is available 02 Manufacture and testing instructions in accordance with IMPD 03 Manufacturing and test record are in accordance with manufacturing and testing instruction. Randomisation code is correct 04 05 06 07 08 09 10 11 Manufacturing and testing record are dated and signed by the Head of Manufacturing and Head of Quality Control. Selected storage and transport conditions are suitable. Deviations occurred in the production have been documented, investigated and closed. OOS occurred during the testing have been documented, investigated and closed. Planned changes are approved and if necessary, reported to the authority. Starting materials were only used if released by the QC. 12 Raw materials and packaging materials were used, which were obtained by approved, qualified suppliers. Critical manufacturing and test methods are validated. 13 Relevant manufacturing and testing equipment are qualified . Result: o does o does not o not applicable o does o does not o not applicable o does o does not o not applicable o does o does not o not applicable o does o does not o not applicable o does o does not o not applicable o does o does not o not applicable o does o does not o not applicable o does o does not o not applicable o does o does not o not applicable o does o does not o not applicable o does o does not o not applicable o does o does not o not applicable No. 14A Request: A valid manufacturing license is available. 14b A valid GMP certificate is available. 15 Contract manufacturer and laboratories are audited/ qualified. 16 18 The current PQR shows no negative trends or other indications of risk to the overall product quality. The review of the follow-up stability revealed no indications of deviations from the specification. Other factors affecting the quality of the product are not known. 19 The required retention and reference samples are stored. 20 The batch was entered in the release register. 17 Result: o does o does not o not applicable o does o does not o not applicable o does o does not o not applicable o does o does not o not applicable o does o does not o not applicable o does o does not o not applicable o does o does not o not applicable o does o does not o not applicable Comments: Result: o complies with all the above points, batch can be released o lack of at the following points: Measures: o no release and destruction o quarantine and the following measures: Check list completed by: __________________________________________________________________ ______ Product (name, strength, dosage form)/ Batch Number Intermediate product/ Bulk product in original packing material/ Bulk product/ Deliverable/ Finished product No. Document QA Note review/ Initials 1 Specifications, analytical methods – API, excipients, packaging materials 2 Specifications-intermediate and finished product 3 Quality/Technical agreement 4 Approval of clinical trials from the medical products Agency (the equivalent of authority) as well as Ethics Committee/ 5 Approved Clinical Trial protocol 6 Randomisation list/key 7 Approved receiver of product 8 Manufacturing Standards; Date; Signatures; Calculations; Process controls/parameters; Deviations; Labels; Local Conditions; IMPD 9 Packing Instructions: Date; Signatures; Calculations; Process controls/parameters; Deviations; Labels; Local conditions/ 10 CoA: results from QC: analytical methods; Validation of methods; Date; Signatures; Calculations; Deviations; OOS 11 Stability data / Data for shelf life/retest period and storage conditions 12 Shelf life and storage conditions/ 13 Packaged product Other Notes/ Other comments : QP review/ Initials Report number: ___________ Name of the product: Internal code: Batch size: Batch number: Date of production: Number of the work order: Date of the beginning of the production: Expiry date: Date of finishing of the production: Documentation of packaging process Document Present (√) Date Present (√) Date Filled protocol of packaging The work order of packaging process MONITORING Sample of packaging material Primary packaging ( t °C i % RH) yes no Secondary packaging ( t °C i % RH) yes no Analytical dossier / Documentation of Quality Control Document Aluminum foil Certificate of analysis of packaging material PVC or PVdC foil Boxes Leaflets Intermediate Certificate of analysis In Bulk Report of analysis of a finished product Certificate of analysis of a finished product Quality report / OOS yes no Document Present (√) Documentation of Quality Assurance Quality report / deviations if any and undertaken preventive and corrective actions yes no Approval of proposed changes no Notes: QP responsible for batch realise to the market: Date: yes Date Supplier: Supplier categories identified in the table that follows may be used to assign an initial risk category. However, they are subject to change based on a review of intended use (risk), frequency of use (volume), quality history, previous use, and so on. Risk Criteria Example(s) High Medium Low Has direct impact or data provided contributes to a decision in terms of: a. Patient safety b. Product / data quality c. Product efficacy d. Personnel safety, or a e. Regulatory requirement Has in-direct impact or data indirectly contributes to a decision in terms of any a-e item listed, or A regulatory requirement is involved, however it does NOT have a direct impact on any a-e item. No direct impact or indirect impact on non-vital or any ae listed item, or there is no regulatory requirement. Contract Research Organizations (CRO) Contract Research Laboratories (CRL) Contract manufacturers, laboratories, and packagers Software and/or service suppliers generating data for regulatory approval submission Consultants that assesses data, specimens, or other study-related materials and provide contributing scientific reports and there are secondary Pharmaxyz checks to detect defects Provider/supplier of indirect impact database, software and related support services Provider of materials, such as active ingredients; comparators; excipients; printed materials; and primary terials Warehouse or distributor of finished clinical supplies Provider that supports non-clinical studies and does not generate, measure, or assess data or study materials Provider of network, hardware and related support services with no impact on safety, quality or efficacy Suppliers of biological test systems -the-shelf items or blank labels systems Animal, animal feed, and bedding supplier Supplier and / or distributor of materials such as secondary packaging General risk assessment questions Yes 1 Have clients identified problems, issues or concerns? If yes, explain: 2 Has/will a new technology, product or process been/be introduced? If yes, explain: Are there new or revised regulatory / compliance requirements that apply which need to assessed? If yes, explain: Have service(s) have been transferred or been assumed? If yes, explain: Has there been a change to any existing process or service requirements? If yes, explain: Do business risk issues exist that need to be assessed? If yes, explain: Does the CRO, CRL or consultant assess data, specimens, or other studyrelated materials, under the control of a study director? Does the suppliers quality assurance unit review the data and/or a subsequent report that is generated? Will the supplier provide low risk materials only? Is there evidence of satisfactory audits by regulatory bodies / second-third parties? Is the supplier used, known or recognized as a supplier to the pharmaceutical industry? Has the supplier been audited by a sister-division? Were the results of the audit satisfactory for QA intended use? Has there been an ownership, management, or quality system change? Have the results of prior audits identified problems, issues or concerns? If yes, explain: Does verification of corrective actions from previous audits exist? 3 4 4 5 6 7 8 9 10 11 12 13 14 Since the last evaluation or quality history review… + 15 Has the volume of studies, study related work, contracted work, product procured, and so on remained about the same (NC), increased (+), or decreased (-)? 16 Has there been a change in the rate of non-conformances or deviations? (e.g., about the same, increased or decreased). 17 What audit type was last performed? ___ Not applicable Quality History Second / Third Party Audit Questionnaire / Self-Assessment Sister-division evaluation Pre-screening interview Comments / description of other: Certifications (describe) On-site audit Other (describe) No N/A NC N/A 18 19 20 21 22 23 How long has the supplier been used? When was the supplier last used? How long has the supplier provided the product or service to Pharmaxyz? The rating of the last audit was … When was an audit last performed? Was corrective action requested of the supplier? Describe if yes. If no, explain: Description / explanation: High <2 years >5 years <2 years Med 2-4 years 2-4 years 2-4 years Unsatisfactory Restricted >5 years Inadequate 2-4 years In-process (not verified as effective) Not effective Assignment of the supplier volume-risk category For the known/predicted volume, the supplier is: The overall supplier risk is: Comments: High Low >5 years 2-4 years >5 years Satisfactory 2-4 years Closed Verified Medium Low Use the Audit Type Table below to select the audit type(s) based on the overall supplier risk determined. Record the audit type(s) in Section B of the Risk Based Audit Decision Tool. When using the table: The table represents minimum expectations “Yes” designates an accepted audit type Quality History applies to existing suppliers only More than one audit type can be selected, and Use of an audit type other than that indicated, or designated as “No” is allowed. However, its use requires documented rationale and justification for use, and Audit Type Table Audit Types Quality History (existing supplier only) Questionnaire / self-assessment Sister-division evaluation Pre-screening (documented interview) Second-Third Party Audits Certifications On-Site Audit Other Low Risk Yes Yes Yes Yes Yes Yes No Yes Audit Frequency A supplier determined to be… Low Risk Medium Risk High Risk Has a time period between audits of… 4 years 3 years 2 years Comments: Medium Risk Yes Yes Yes Yes Yes Yes No Yes High Risk Yes No Yes No No No Yes Yes Section A Supplier Name: Date of request: Address: Phone: City / State / Province / Region: Fax: Country: E-mail / Website: Name/Area Requesting Audit: Department: Extension: What is the planned use for the supplier? (e.g., the product or service to be provided): Target date / quarter that the supplier is intended to be used: Is the supplier being used for a specific project and/or study? Yes name: _ Phase 1, 2 3 or Pivotal Phase 4 No If yes, list project/study by PMOS (Post Market Observational Study) Project Number: Study Number: Other: What is the anticipated volume of product or service? (number of studies, sites, batches, tests, patients, etc.) Are any of the following available or in-place? Review them, if applicable for quality considerations it (they) may contain. Master Services Agreement Preferred Supplier Quality Agreement Technical Agreement Request for Capital Expenditure (RCE) Other (describe): Section B The supplier is categorized as: Low Volume / Low Risk Low Volume / Medium Risk High Volume / Low Risk High Volume / Medium Risk The audit frequency is 4 The audit frequency is 3 years years Perform the following: On-Site Audit Quality History Existing Sister-division audit supplier only Preliminary / prescreening interview Second-Third Party Audits Low Volume / High Risk High Volume / High Risk The audit frequency is 2 years Certifications Other (describe): Questionnaire / SelfAssessment Functional area(s) to perform the CBS GCP GLP GMP audit: Estimated Audit Travel Cost: Compass Charge # Approval Initiator Date Printed Name ______________________________ _____________ ________________________ QA Management Date Printed Name ______________________ _____________ ________________________ Note: QA Management approval not required in the EU if this document is completed or approved by a Qualified Person. Address: Type of Company: Intended Use: Category as per SOP xyz Points to consider Background information Reason for (re-)qualification Description / Details / Information Supplier History / Changes Current status of supplier / service provider Satisfactory (approved for use) Restricted Unsatisfactory (not approved for use) Not rated yet Approved by sister division Assessment / Monitoring activities as per Sop xyz: Questionnaire Audit Audit sister division / third party Quality history Certificates others Audit Report (date of approval) Audit Letter (date of mailing) Response to observations (receipt, comments)) Rating of supplier as per SOP xyz (with limitations if applicable) Next evaluation/ monitoring Date and signature of person who performed assessment / monitoring Approval QA Management (QP for Europe) _______________________________________ (Name and function) _______________________________________ (Name and function) Item 1 Company profile (including a description of the type of business) (Please describe your company) 1.1 Address: Year company was established: Internet address: 1.2 Does your company have other sites? 1.3 Details of company ownership: 1.4 Are you part of a corporation? 1.5 Details on size of company (applicable site) No ( ) Yes( ) (please provide address) No ( ) Yes( ) Number of employees: Number of employees involved in Quality Management: Size of company premises in square meters: 1.6 Details on range of services provided 1.7 Please attach an organization chart to this questionnaire. 2 Quality 2.1 Is your company certified according to any guidelines? Which? > > > > DIN EN ISO 9001 SCC/SGU DIN EN ISO 14001 OHSAS 18001 No No No No ( ( ( ( ) ) ) ) Yes Yes Yes Yes ( ( ( ( ) ) ) ) (please (please (please (please attach attach attach attach certificate) certificate) certificate) certificate) Are any other quality assurance measures installed? If yes, which? 2.2 Is your company certified according to other criteria (e.g. GxP, GSP, GDP,etc.)? No ( ) Yes ( ) (please attach certificate) 2.3 Do you perform audits on your own company? No ( ) Yes ( ) 2.4 Do you employ qualified subcontractors (e.g. housekeeping, pest control, transport, storage?) No ( ) Yes ( ) If yes, do these companies have the same or similar qualifications as your company does? No ( ) Yes ( ) 3 Have you worked for a company belonging to the xyz corporation before? Or are you currently already working under contract in our company? No ( ) If yes, which organisation? When? 3 Please supply the following details: Name and telephone number of person responsible for Quality Management Comments This questionnaire was completed by: Name/signature: Function: Date: Yes ( ) Please return to: Quality Assurance Department Number of inquiry: Company profile Company name: Address: Telephone number: Fax number: Contact person: Please enclose company brochure and organizational chart Ownership Contact persons for: Private society One owner Mixed Sales department Quality department Representative State company Technical department Job type Production Services Distribution Row materials/APIs Montage/Installation Other (Please name) Number of employees Total : Finance and administration ( ) Do you have more than one facility/site? Distribution ( ) Yes Production Development Engineering ( ( ( ) ) ) ( ) No ( ) Management responsibilities Do you have company mission? (Please enclose) Yes ( ) No ( ) Do you have written environment protection policy? (Please enclose) Do you have or you are in process of establishing the management system for environment protection? If the answer is yes, are you in compliance with ISO14001 or EcoManagement ? Do you have regular meetings consecrate to quality analyses? Do you have official quality policy? (Please enclose) Do you have Quality Manuel (QM)? (Please enclose table of contents) Does you company have ISO accreditation? GMP or PCP (Pharmaceutical Code of Practice) accreditation? (Please enclose copy of Certificates) Do you have GMP Certificate issued by MHRA? Do you have GMP Certificate issued by FDA? Do you have Health and Safety Protection of employees policy? Yes ( ) No ( ) Yes ( ) No ( ) Yes Yes Yes ( ( ( ) ) ) No No No ( ) ( ) ( ) Yes ( ) No ( ) Yes Yes ( ( ) ) No No ( ) ( ) Yes Yes Yes ( ( ( ) ) ) No No No ( ) ( ) ( ) Yes Yes Yes Yes Yes ( ( ( ( ( ) ) ) ) ) No No No No No ( ( ( ( ( ) ) ) ) ) Yes ( ) No ( ) Yes Yes Yes ( ( ( ) ) ) No No No ( ( ( ) ) ) Do you supply other pharmaceutical companies? Yes ( ) No ( ) Do you have: Yes Yes Yes ( ( ( ) ) ) ( ( ( ) ) ) Yes Yes ( ( ) ) No No ( ( ) ) Yes ( ) No ( ) Quality Assurance Do you have: Product specification? Process specification? Internal control procedure? Meetings devoted to quality improvement? Control and testing plans? Formalized system of compliance with customers? Is the system batch approval and batch release independent from production process? Have your procedures been checked by external inspection? Has your computer system been harmonized with GAMP 4? Production Production procedures? Inter-process control? Identification and Traceability of product? (please enclose procedure for batch marking) Procedure for deviations? Pest control program? Do you use statistical analyses in production monitoring? No No No Purchasing Do you have: Row materials/excipients/API specification? Purchasing records? Packaging material specifications? Qualified suppliers? Supplier evaluation system? Do you have regular inspection for your suppliers? Do you work according the official supply contract? Yes Yes Yes Yes Yes Yes Yes ( ( ( ( ( ( ( ) ) ) ) ) ) ) No No No No No No No ( ( ( ( ( ( ( ) ) ) ) ) ) ) Final product Do you have: Storage and handling procedures? Yes ( ) Procedure for withdrawal from the market? Yes ( ) Your own distribution? Yes ( Quarantine area? Yes Dispatch control? No ( ) No ( ) ) No ( ) ( ) No ( ) Yes ( ) No ( ) Internal Controls of Goods? Yes ( ) No ( ) Do you have CoA and CoC? Yes ( ) No ( ) Information Please put the details below about the person responsible for filling this questionnaire: Name: Title: In behalf of: (name and company stamp) General Information Overview This questionnaire is provided to prospective or current clinical trial (study) distribution /depot sites, to be completed as a self-assessment of their warehousing and distribution capabilities, quality systems and applicable processes. It is not to be used for organizations that repackage or transfer material from one container system to another. Name of Company: Address: City: State/Province: Post / Zip Code: Website address: Phone Number: Fax Number: Distributor Facility Information: Number of Facility Personnel (total): ________ Note: Please attach a copy of your organizational structure. Country: Are all distribution operations carried out at this location only? Yes No If no, what processes and services are not carried out at this location? List the primary type of activities performed with clinical products (i.e. distribution, packaging, overlabeling, returned goods, etc.) Has this location performed clinical study distribution activities before? Yes No If yes, mark the type: Double-Blind Single-Blind Open-Label Other (specify type) ___________________________________________________________ Do you utilize other facilities or distribution centers other than your own to distribute clinical supplies? Yes No If yes, provide the name and location of facilities used in addition to your own. Would your site be receptive to an on-site evaluation by a representative of Pharmaxyz Laboratories? Yes No If no, please explain: _________________________________________________ Would a confidentiality agreement be required for the evaluation? Yes No Has your company been inspected by U.S. FDA, or another countries government / organization? Yes No If yes, provide the name of the regulatory agency, inspection dates, and results: Does the site maintain GMP certification, or is it registered with the U.S. FDA? Yes No If yes, attach a copy of the GMP certificate and / or provide the FDA establishment registration number: Is this facility inspected by any other local, State, Federal/Country regulatory agencies? Yes If yes, please list them: No Is this facility ISO 9000 certified? Yes No If yes, who is the Registrar? _____________________ If no, is there a plan to certify this facility? Yes No Is the facility a Controlled Drug site (e.g., authorized to receive, store and distribute controlled drug substances such as Schedules I, II, III, IV, and V materials)? Yes No If yes, to what agency / organization(s) is the facility registered? _______________________________ Are there drug accountability (inventory) procedures? Yes No Does the site compare inventory records with actual receipts, shipments, returns, etc? Yes Does the site record what is sent out? Yes No No Are unused clinical products stored separately from returned clinical products? Yes No Are there documented controls and established responsibilities in place for the destruction of unused and/or returned clinical supplies? Yes No Is there documentation that clinical products returned to your facility were returned to the sponsor or disposed of according to the sponsor’s instructions? Yes No Are there controls / instructions in place to ensure that the shipping of clinical supplies are conducted according to instructions given by or on behalf of the sponsor? Yes No If the site is notified by any party along the supply chain of a complaint or inquiry, are there documented procedures in place to receive and record the conclusions of any investigation carried out in relation to a complaint or inquiry which could arise from the quality of the product? Yes No Does the site maintain adequate records that include the name of the investigator to whom the study drug was shipped? Yes No Does the site have the capability to show where clinical supplies were sent but not to reveal the name of the investigator to whom the clinical supplies were sent? Yes No Attestation of Review and Approval Where possible, the Warehouse Manager and a Quality or Regulatory Affairs representative must sign this form. Provide an explanation if the signature if from any other function. _____________________________________ Signature __________________________ Title ______________ Date _____________________________________ Printed Name _____________________________________ ___________________________ _______________ Signature Title Date _____________________________________ Printed Name
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