SEAT BELT POLICIES

I still haven’t figured out why we can’t do better! Year after year after year, we still lose more than 100 firefighters a year. Of these 100 or so fatalities, more than 25 percent are attributed to vehicular accidents. I have no statistical proof, but I’m sure that a portion of those 25 or so firefighters killed responding to or returning from incidents were wearing their seat belts. Still, we hear excuse after excuse for firefighters’ failing to “click” their seat belts: “I can’t don my SCBA en route to a fire and wear my seat belt.” “It slows me down.” “I get so pumped when the ‘tones’ go off that I simply forget to put my belt on.”

In Toledo, our seat belt policy is short and simple. It states, “All members shall be seated and wear seat belts while the vehicle is in motion.” A violation of this policy is considered a “safety violation.” The penalty for being found guilty of a safety violation is a written reprimand for the first violation, a five-day suspension for the second violation, a 10-day suspension for the third violation, and immediate dismissal for the fourth violation. Additionally, we hold not only the member but also the officer responsible for enforcing this policy. To the best of my recollection, we have had only one violation of this policy in the past 10 years. This policy is strictly enforced.

—John “Skip” Coleman, deputy chief of fire prevention, Toledo (OH) Department of Fire and Rescue, is author of Incident Management for the Street-Smart Fire Officer (Fire Engineering, 1997) and Managing Major Fires (Fire Engineering, 2000), a technical editor of Fire Engineering, and a member of the FDIC Educational Advisory Board.

Question: Every year, approximately 25 percent of the line-of-duty deaths are related to motor vehicle accidents. Several months ago, a fireengineering.com Quick Poll revealed that approximately half of the respondents said that they do not have a seat belt policy. Does your department have a written seat belt policy, and is it enforced?

Steve Kreis, assistant chief, Phoenix (AZ) Fire Department

Response: It is hard to believe that in 2004 a fire department does not have a written seat belt policy. But, writing a policy is much easier than enforcing one. Our policy is pretty simple: Everybody must be seated and belted before the apparatus moves and must stay that way until the apparatus comes to a complete stop.

We have had a written policy on seat belt use for as long as I can remember, but about 10 years ago we encountered a situation that required a little attention. As with many other departments, we purchased apparatus with the seats that allowed us to have the SCBAs stored in the seat so that firefighters could put on their SCBA en route to an incident. Shortly after, we began hearing that our firefighters were seated and belted at all times except when responding to structural fire incidents.

To make a long story short, within a day or two after a series of meetings with all of the company officers and the chief, all SCBAs were removed from the interior of the apparatus and placed in exterior compartments. Our job is dangerous enough. Wear your seat belt.

Leigh Hollins, battalion chief, Cedar Hammock (FL) Fire Rescue

Response: Our department has a written “Vehicle Operations” ROG that specifically deals with this issue—and, yes, this rule is enforced. In addition, Florida statutes require the use of seat belts. Here are three statements from the ROG.

1. Seat belts shall be worn at all times by all personnel on all department vehicles and apparatus.

2. All personnel on the apparatus shall remain seated and secured until the apparatus has completely stopped and it is safe to disembark.

3. The vehicle operator is responsible for operating the vehicle with due regard for the safety of all persons using the roadway and all personnel on the vehicle.

We train regularly on ROGs and line-of-duty-death (LODD) case histories and realize that the number two cause of LODDs is vehicle-related injuries. Recently at a neighboring fire department, a firefighter fell out of an engine responding to an alarm—an obvious violation that was totally preventable. Luckily, he was not seriously injured. Several of our officers regularly forward Internet news reports of such cases with the reminder, “Don’t let this happen to you!” A simple click of the mouse can send a strong message.

Michael Allora, lieutenant, Clifton (NJ) Fire Department

Response: Our department does not have a written policy specifically addressing seat belt use. Whether or not a policy exists is certainly no excuse for a firefighter to ride an apparatus without wearing a seat belt. However, a department’s attitude toward safety should be reflected in its standard operating guidelines/procedures. For a department to ensure the safety of its members, a safety-conscious atmosphere must be inherent throughout the organization. Simply drafting policies will not make for a safer work environment. The mindset, the attitude toward safety, has to be altered, if necessary, for real change to take place.

We all know we should wear our seat belts, but “The seat belt gets in the way.” “It slows us down.” “It’s a hassle.” So what is the answer? Draft a policy that states that all personnel aboard the apparatus must be properly seat-belted prior to the apparatus’ moving, period. After that, hold the company officers responsible for enforcing the policy. The chief of the department must ensure that all members are aware that this is not a punitive measure. Communicate to your people that their safety comes first and that there is no excuse for an injury that is as foreseeable and as preventable as one sustained because a seat belt is not worn.

Doing something for years without getting hurt does not make it a safe practice. It just means that you’ve been fortunate up to this point not to have been hurt or killed doing it. I could not believe my eyes as I watched a New Jersey department respond to a call. As the truck turned the corner, I saw three firefighters standing on the back step. We recently read about the incident where a firefighter from New Jersey was injured as she fell from the back step of the apparatus. We cannot tolerate the loss of life under these circumstances any longer. Our job is dangerous enough. Draft a policy, enforce it, and empower your company officers to make safety paramount in all that the company does.

Ron Hiraki, assistant chief, Gig Harbor (WA) Fire & Medic One

Response: Our policy requires the use of safety belts at all times when the vehicle is in motion. Our members follow the policy; therefore, enforcement does not seem to be a major issue.

The department policy is based on the State of Washington Administrative Code (WAC 296-305-04503), which requires that all persons riding on fire apparatus be seated and secured by seat belts anytime the vehicle is in motion. Members actively administering emergency medical care to patients are allowed some latitude in being restrained if necessary. This chapter of the WAC is enforced by the state’s safety and health inspectors. Failure to comply with the seat belt policy would most likely result in a citation and monetary penalty from the state.

In training, the practice of using seat belts is referenced in the NFPA standards and is also on the skills checklist for Firefighter I certification. From the start of firefighter training, the use of seat belts is a learning objective taught and reinforced, resulting in the establishment of seat belt use as a true safety habit.

Bob Zoldos, captain, Fairfax County (VA) Fire and Rescue Department

Response: Our policy is to require that all members in all positions wear their seat belts at all times when a vehicle is in motion.

Gary Seidel, fire chief, Hillsboro (OR) Fire Department

Response: Our department has a written seat belt policy and enforces it. In May of this year in our weekly article, which focused on Six Minutes for Safety, I encouraged each member of the department to take the opportunity to read the LODDs reports, which were distributed electronically by the United States Fire Administration (USFA). The reason for asking our employees to read the reports was to ensure that each member would make sure that “seat belt-related accidents” would not include them. Our policy, as well as the reminder in May, states: “To all Hillsboro Fire Department personnel: While riding in any fire apparatus, ambulances, rescue squads, sedans, etc., ALL PERSONNEL IN MOVING APPARATUS WILL BE BUCKLED IN.”

How do we enforce it? Mostly through the honor system. All members realize the importance of preventing injuries and reducing LODDs. That’s why we ensure that our members read the U.S. Fire Administration report on LODDs. Our members also realize that Oregon state law requires everyone to buckle up when in a moving vehicle, which includes fire apparatus. In addition, our members are aware that if they were involved in an accident that resulted in an injury or, worse, a fatality, and they weren’t buckled in, their workers’ compensation benefits could be in jeopardy. So for us, the honor system is working.

Jeffrey Schwering, lieutenant, Crestwood (MO) Department of Fire Services

Response: The first part of the question is easy. Most definitely, my department has a written seat belt policy in place. The second part is a little more complicated. We are approximately 85 percent effective in having all members wear seat belts. Everyone has heard the reasoning for not wearing a seat belt. I am sure we all could make a long list, but excuses will not save us in a rollover accident; the seat belt will. All of our members know that if a chief sees you without a belt on, you will hear about it. This brings us to the company officers. We need to educate our members, probie or veteran, as to why it is so important to wear our seat belts at all times. I would rather my firefighters take five seconds to buckle their waist strap on their SCBA when we get on the scene than not have them wear their seat belts while responding to the incident.

On January 3, 1979, one of our engine companies was involved in a serious accident while responding to a structure fire. All three firefighters on the truck were wearing seat belts and survived with only minor injuries. I use this example because the firefighter in the jump seat that day is a captain today and a good friend. Many responsibilities come with being an officer. Ensuring that all of our firefighters are belted, responding or returning, has to be a top priority not just because the rules say so but also because we all have family to go home to the next morning.

Thomas Dunne, deputy chief, Fire Department of New York (FDNY)

Response: FDNY mandates the use of seat belts on all department vehicles. In fact, disciplinary action is considered when personnel are involved in an accident and it is discovered that the belts were not worn.

Despite this requirement, establishing 100 percent compliance is a challenge. Firefighters may resist using seat belts for a number of reasons. For one thing, there is an illusion of “safety” when riding in a large fire truck. The massive height and weight of the vehicle mask the possibility of being thrown through a window in a serious accident.

The distraction and stress of a response may also be factors. A firefighter is likely to be concentrating on gathering information on the fire or emergency, listening to the department radio, and exchanging knowledge with other crew members. The seat belt requirement may get lost in the excitement.

Unfortunately, poor habits and even peer pressure may keep some people from consistently buckling up. (Why should I be the one to look like a wimp?)

I do not believe that the threat of disciplinary action is enough to break bad habits. The company officer should set the tone by using his seat belt and requiring his personnel to do the same. A firefighter should be trained early in his career before bad habits develop.

According to the National Safety Council, a vehicle death occurs every 12 minutes in this country (there were 44,000 in 2002). With numbers like these, it is incumbent on any department to set an example by requiring and enforcing seat belt use by all personnel.

Rick Lasky, chief, Lewisville (TX) Fire Department

Response: Our department has a policy regarding seat belts; it is within the Apparatus Operations section. The policy is current and in force; all personnel are required to abide by it. The section pertaining to seat belts reads as follows:

A. All LFD personnel are required to use seat belts at all times when operating a City vehicle equipped with seat belts.

    1. Anyone riding as a passenger in a City vehicle is also required to use seat belts.

    B. If the vehicle is on the air (out of station) and receives an emergency run, the officer in charge can respond as quickly as possible with everyone staying belted in or pull the apparatus to a full stop, allow personnel to safely bunk out and return to their seats with seat belts on before the vehicle proceeds.

    It seems that not a week goes by where we don’t read about an accident involving fire department apparatus, and that’s considering those we just read about. With that in front of us, not wearing a seat belt today just doesn’t make it any more. If a department is operating without an SOP regarding seat belts, it is behind the 8-ball already and needs to implement one sooner than later. No matter how you paint it, wearing a seat belt makes a firefighter just that much more safer.

    Peter Sells, district chief, officer development, Toronto Fire Services

    Response: Our written policy on the use of seat belts references and is consistent with the Highway Traffic Act of the province of Ontario. The policy states, in part:

    “All personnel riding in or on Toronto Fire Services vehicles shall be in a seated position and wearing a seat belt while the vehicle is in motion. While in motion, the donning or doffing of equipment and personal protective clothing that requires removal of any restraining belt or other device shall be prohibited.”

    All officers shall ensure that persons under their command riding in Toronto Fire Services vehicles shall follow this policy. It is recognized that this guideline may not address all circumstances. Conditions may exist that might require reasonable discretion on the part of the officer in charge. Decisions should always take into consideration the safety of the public and Toronto Fire Services personnel.

    The only exception to this rule is when the apparatus are slowly moving at an emergency scene—e.g. laying out hose, picking up hose, and positioning apparatus, for example. This exemption is consistent with a similar exemption within the Highway Traffic Act, which states that the seat belt requirements do not apply to a person who is actually engaged in work that requires him to alight from and reenter a motor vehicle at frequent intervals and who, while engaged in the work, does not drive or travel in a vehicle at a speed exceeding 40 kilometers per hour.

    Craig H. Shelley, fire protection advisor, Saudi Aramco

    Response: Our department is part of a large corporation of 55,000 employees. It has policies that govern the use of all company vehicles. These policies set the legal requirements for operating vehicles, speed limits, training requirements, and individual department responsibilities. One of the requirements for operating a company vehicle is the use of seat belts by all drivers and passengers. Company security officers strictly enforce these policies, and violation points are issued for infractions. Accumulated penalty points may result in warning letters or even dismissal. Each step in the disciplinary chain is clearly defined.

    Every employee must take a driver education course every three years, and operators of specialty vehicles must take a course specific to the specialized vehicle. In addition to the company requirement for specialized training, an operator of a fire apparatus must possess a special license issued by the government (similar to a commercial driver’s license) before operating the fire apparatus. Any infraction by an employee is also charged against the department’s safety record.

    Additionally, our department has an SOP pertaining to the operation of emergency vehicles. This SOP includes the provision that “the … emergency vehicle apparatus driver must not move the fire truck until [he is] sure that the entire crew is properly attired in full protective clothing, seated, and securely belted in place.”

    Vehicle safety is more than just wearing seat belts or enforcing a seat belt policy. A vehicle safety program should cover all aspects of responding, operating at, and returning from alarms as well as preventive maintenance programs. The days of riding the tailboard are over, but we still see injuries happening from such actions. We need to work together and make the vehicle safety program part of an all-encompassing health and safety program and continue to develop a “culture of safety.”

    Robert Shelton, firefighter/EMT-I, Cincinnati (OH) Fire Department

    Response: Nationally, there is a seat belt policy with the slogan “Click it, or ticket,” penalties, and media campaigns extolling the benefits of using seat belts. Yet, we, the people who see the aftermath of accidents where seat belts are not used, are being injured and killed because we don’t use them.

    In my department, the seat belt policy is in our procedures manual on fire division vehicles under the title of “Driving and Operations.” The objective of this policy “is to provide procedures for safe and efficient operation of fire department vehicles.” In the section under “Driving” is the following:

    1. “Defensive driving shall be observed at all times.”

    2. “Drivers shall adjust to road, traffic, and weather conditions.”

    3. “The officer shall make a VISUAL check of apparatus to be certain that members are in position before boarding. The Officer will signal the driver to proceed ONLY after he has acknowledged everyone is in a seated position with SEAT BELTS FASTENED.”

    Another part of that policy states, “Members shall respond in a SEATED position with SEAT BELT in service. Members shall not stand on back platform for any reason.” Even during tillerman training, the person outside the tiller cab MUST wear a lifebelt hooked onto the apparatus.

    The procedure is in place and in writing, with no options. The procedure holds the person in the right front seat, be it an officer or a firefighter riding in charge, responsible for ensuring that all are seated and belted in their respective riding positions before the apparatus moves.

    I have worked for two full-time and two combination departments in my almost 14 years in the fire service; all have had written seat belt policies. The issue is not one of implementation, as I see it, but enforcement. While responding to a run, so many things run through your mind—location of hydrants, for example, for an engine company; type of building, aerial placement, for example, for a truck company—that the last thing considered is whether a firefighter’s seat belt is fastened. There are some individual exceptions, as with everything, but this has generally been the rule in my experience. And, I admit that I am guilty of not doing this while riding in charge as well.

    All of us need to put forth a more diligent effort to do everything we can to get us home at the end of the shift. We have state-of-the-art equipment, thermal imaging cameras, protective gear, and so on, to help us do our job and be safe. Who would consider entering a toxic atmosphere without an SCBA? The safety belt is just another tool in our ever-changing arsenal that has been overlooked for some time by so many. This one tool will help ensure our safety and longevity in the fire service and, hopefully, decrease instead of increase the statistics on accidents.

    Danny Kistner, battalion chief, Garland (TX) Fire Department

    Response: It is our policy to wear safety belts whenever apparatus are in motion, regardless of the type of apparatus. Enforcement is the responsibility of the company officer and the apparatus driver. Additionally, a presumption exists that every firefighter should share in the burden of his own safety by buckling up.

    No doubt, the reluctance to wear safety belts contributes to morbidity and mortality in apparatus collisions. Why, then, are some firefighters hesitant to wear them? Firefighters, like everyone else, are human and often rationalize to justify specific behaviors—seat belts hinder the donning of protective gear, they are uncomfortable, they prevent firefighters from turning around and facing forward in the crew cab, they prevent firefighters from standing up to see what’s ahead. Many can remember the days when the thought of a safety belt did not even enter the thought process. Further, throw EMS into the mix, and firefighter/paramedics riding in the patient compartment can argue that rescue personnel wearing safety belts can inhibit patient care.

    Administrative and physical controls need to be applied simultaneously. Administrative controls exist in the forms of SOPs, policies, and procedures. A clear line of accountability that identifies the person responsible for enforcement and consequences for not following policy needs to be drawn. Escalating discipline must follow noncompliance. Physical controls on apparatus exist in the form of alarms, pressure switches, and the like. A buzzer signals to the driver or officer that a seat is occupied but the safety belt is not engaged. Care must be taken to see that these devices are not circumvented or sabotaged, and it must be made clear that personnel caught tampering with these devices will be subject to discipline. The officer and the driver who enforce the policy show a true concern for firefighters’ well-being.

    Garland firefighters are instructed to don all PPE prior to boarding apparatus or to the apparatus’ exiting the station. If a response comes in while the vehicle is already out, firefighters are instructed to don gear on arrival at the scene. All firefighters participate in weekly drills on donning PPE to keep actual performance times to a minimum.

    Firefighters engaged in EMS activities during transport should exercise as much discretion as possible. It is understood within the department that paramedics can tend to the patient’s needs as the situation dictates; however, when not actively engaged in administering medical intervention, the paramedic must be seated and belted.

    All firefighters on an apparatus should be held accountable for the proper use of safety belts while the apparatus is in motion. The driver should not engage the vehicle until he is sure that all personnel are properly strapped in. The fire officer, likewise, should not give the order for the apparatus to proceed until he is sure all firefighters are observing proper safety procedures and are strapped in. Finally, the individual firefighters should insist that the apparatus not leave the station until they are properly strapped in. All personnel owe it to themselves, their families, and the community they serve to stay alive.

    Keith D. Smith, chief, Westfield Washington Township (IN) Fire Department

    Response: We have a written apparatus/ vehicle seat belt policy that has been in effect for more than five years. Enforcement is the responsibility of the company officer, but mandatory use is not as big an issue for us as it is with many departments.

    There is a very practical reason for wearing seat belts—self-survival for our firefighters. In our response area (metro Indianapolis), two major arteries handle huge volumes of traffic. Both highways are also truck routes. The practicality of seat belts derives from our emergency responders’ having to cross both arteries almost daily. Accidents at these busy intersections are frequent and deadly. Both highways are among Indiana’s most hazardous.

    Firefighters recognize those hazards and see traffic accident results almost every day. The seat belt lesson is obvious, because not being fastened in the cab is nearly suicidal given the nature of our environment. It is fairly common for our firefighters to still witness the resulting injuries at accidents where seat belts were unused. That picture does well for enforcing the use of seat belts.

    Tom Cole, battalion chief, Miami Dade (FL).Fire Rescue

    Response: In Miami Dade County, several policies state that seat belts should be worn. There is an Administrative Order that states that all occupants will wear seat belts or safety belts when a fire department vehicle is in motion. There is also a Safety Manual prepared by the Office of Safety and Risk Management Division that states that the employee is responsible for ensuring that all occupants properly wear seat belts and/or other required personnel restraints when operating a county vehicle. Furthermore, the Metro-Dade County Employee Safe Driving Rules Manual stresses the importance of wearing seat belts while driving any fire department vehicles and that failure to wear the appropriate restraint device may result in denial of disability leave benefits. The department strongly enforces these policies, and they are not to be taken lightly.

    Whether responding to a call or simply driving to the grocery store, it is ultimately the unit officer’s responsibility to ensure all persons are properly seat belted and the apparatus is safe to drive.

    Brian Bartolick, lieutenant, Bushnell’s Basin Fire Department, Perinton, New York

    Response: At this time, our department does not have a written seat belt policy. However, we have recently introduced a draft policy into the departmental review process. There has been a push in recent months by the company officers to get firefighters to buy into the mandatory seat belt concept. We have two engines, which have shoulder and lap belts in each seat. They are easy to access and use, eliminating the most common excuse for not using the seat belt.

    For the most part, our drivers and company officers are leading by example and use the seat belt at all times, but firefighters in the rear of the cab are not always taking the hint. Most crew members refuse to buckle up during an emergency response, citing the need to “pack up.” We’ve dispelled this misconception by showing the firefighters that only a few seconds are wasted by getting the pack on once the apparatus arrives at the scene.

    We hope that in the future, with increased training, a written policy, and increased leadership by first-line supervisors, all firefighters will use the seat belts provided in the apparatus anytime the unit is in motion.

    Jack M. Smith, training officer, North Slope Borough Fire Department, Barrow, Alaska

    Response: We have a driving policy that mandates the use of seat belts in all vehicles. The policy is usually enforced in fire apparatus and EMS units, but many individuals fail to abide by the policy in other fire department vehicles. Training programs have stressed the importance of making wearing seat belts a habit in every vehicle. Although many of the remote seven communities strictly enforce the policy, the largest community continues to have some members who fail to abide by the policy. In a combination department, this can be disturbing; volunteers frequently look to the career personnel as role models. For a policy to be effective and enforceable, every one must comply.

    Lance C. Peeples, instructor, St. Louis County (MO) Fire Academy

    Response: It strikes me as incredible that 50 percent of respondents to a Fire Engineering poll indicated that their department did not have a policy requiring members to don their seat belts prior to operating the apparatus. The chief and company officers who tolerate such conditions are indeed poor excuses for fire officers. Let us resolve right here and now that no brothers or sisters shall ever again die needlessly in a traffic crash because they weren’t wearing a seat belt.

    In fact, because so many officers are clearly negligent in ensuring the safety of their members, let’s not leave it up to them anymore. Let’s require engineering controls that won’t allow the parking brake to disengage until all riding positions in which a person’s weight is present have engaged seat belts. We might need some type of override device to allow for the rare case where the sensors are faulty; however, some type of device could be used to record these failures. Safety officers would periodically inspect the apparatus to ensure the devices had not been defeated. Let’s grow up and act responsibly! Let’s quit killing ourselves unnecessarily. Let’s quit driving like irresponsible idiots. Let’s not bury any more brothers or sisters because they weren’t wearing a seat belt.

    Bobby Halton, chief, Coppell (TX) Fire Department

    Response: Our department has a directive that requires all members to be belted at all times while the apparatus is in motion. The company officer is responsible for ensuring that the company members are properly turned out for the run before they get on. There is no reason for any Coppell firefighter to be unrestrained in the cab of a fire truck. Electronic devices to prevent the apparatus from starting until everyone is belted are not used, but our department would not oppose them.

    We stop at red lights and stop signs and try to keep our speed below mach 2. We trust the officers managing our hiring process to weed out any crash test dummies and prevent them from being members of the department. It is hard for us to imagine how anyone cannot understand the value of a seat belt.

    To my knowledge, we have not had to enforce this policy through disciplinary actions or anything of that nature, which shows the caliber of our folks. Smart people working for and with smart people generally have little trouble doing the right thing.

    Richard Royston, chief, Delhi Township Fire Department, Holt, Michigan

    Response: Our department has a policy concerning the wearing of seat belts in all fire department apparatus: The engineer is not to move the vehicle on any call until all personnel are in their seats with their seat belts fastened.

    Although this was very difficult to enforce in the beginning, it has become easier as personnel have begun to realize that the added time it takes to fasten the seat belt does not have an overall impact on arrival times or the outcome of the call.

    We have found that it is particularly difficult, but not impossible, for the officer in each fire apparatus to don the seat belt because of the limited space available in the officer seat and the need for the officer to don the SCBA prior to being belted in the seat. This has resulted often in the officer’s taking the SCBA unit out of the seat and placing it on his back before getting into the apparatus. He then fastens the seat belt.

    We are committed to making this safety policy work and have no intention of changing it because of any difficulties associated with using SCBA or any other fire department materials.

    I cannot imagine trying to explain to a firefighter’s loved one that he died or was critically injured as a result of something as simple as not wearing a seat belt. Deaths such as these are the most preventable.

    Jeff A. Welch, reserve firefighter, Coeur d’ Alene (ID) Fire Department

    Response: Our seat belt policy is very short and to the point. It states that all personnel riding on apparatus shall be seated and all personnel shall use seat belts. It also states that it is the responsibility of the officer and the driver to ensure that all personnel are in place and seat belts are used before allowing the driver to move the vehicle. I believe that nearly everyone (if not everyone) uses this piece of safety equipment. If positive reinforcement is needed when this piece of safety equipment is not being used, it would come from the station officer.

    I would be curious to find out how many responders to the survey mentioned above in fact use a seat belt in the apparatus even though their departments do not have a seat belt policy, (I do not have a seat belt policy for my personal vehicle, but I wear a seat belt.) How many departments have a written policy that says PPE shall be donned when entering a fire? Common sense tell us that if there is something we can use or an action we can take to minimize our exposure to injury or death, it should be done regardless of whether a written policy exists.

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