Information

Bee Health Improvement Partnership minutes: August 2020

Minutes of the meeting of the Bee Health Improvement Partnership (BHIP) on 14 August 2020.


Attendees and apologies

Attendees

  • Luis Molero, SG, Lead Bee Inspector
  • Fiona Highet, SG-SASA, Senior Entomologist
  • Mairi Carnegie, SG-SASA, Assistant Zoology Manager
  • Karen MacKenzie, SG, Bee Inspector
  • Jackie Quigley, SG, Secretariat
  • Graeme Sharpe, SRUC, Apiculture Specialist
  • Matthew Richardson, SBA, Bee Health & Science Trustee
  • Phil McAnespie, SBA, President
  • Margaret Ginman, BFA, General Secretary

Apologies

  • Margaret Thomas, NDB
  • Angus MacAskill, SG

Items and actions

Welcome and apologies

Apologies received from Margaret Thomas and Angus MacAskill

Minutes and actions points from 8 June 2020

  • previous minutes were approved. Helen Nelson was added to the previous minutes as Secretary of the SBA
  • Margaret Ginman asked for consistency on naming these minutes/notes. Agreed that we would use “Note of Meeting”

SASA update

COVID-19 and bee health activities:

  •  SASA remained closed to all but essential work until a phased return to work commenced on 29th June. Staff numbers and functions remain severely limited, therefore all but statutory testing (i.e. foulbrood and imports) remain at a standstill

  • in addition two out of three ‘bee team’ staff are within a higher risk category therefore their attendance at HQ is under close scrutiny. We are very grateful to Hanna Gizycka who, until this week, has been handling all bee health samples in the lab
  • pesticide/poisoning incident investigations (Wiis) are now back online (with a backlog); report through the usual channels
  • other bee health incidents are being triaged through Bee’s mailbox (suspected foulbrood) and SRUC (non-foulbrood) until staff return to a more normal working pattern
  • training and talks remain online for now; we are unsure when SASA management will agree to SASA staff attending external events in person
  • Mairi Carnegie has been working remotely with the Bee Health Team as well as her duties for SASA. In addition to this, we have been in regular contact with BHIT (SG bee team) throughout lockdown

Bee health diagnostics: other items, progress and plans

  • foulbrood diagnosis. 151 submissions (totalling 290 samples) have been received to 7th August 2020. We are grateful to the inspectorate team and accredited beekeepers for completing official forms fully and accurately which has helped reduce the admin burden, allowing Hanna to focus on sample processing and diagnosis during a very busy season
  • non-statutory testing. This remains beyond our laboratory capacity for now. We are grateful to Graeme Sharpe for providing Scottish beekeepers support based on symptoms, and to the beekeepers for their patience. We will make an announcement as soon as we can provide a robust testing service again
  • surveys and sentinels. We intend to co-ordinate a small-scale, low impact survey for the presence of Asian Hornet in the near future. We will provide guidance and ask beekeepers to visually monitor their apiary for 15 minutes prior to beekeeping activities on two occasions in autumn. Reports will be welcome (including negative reports), and we will provide a generic SASA address to report activity and location

Education and training activities

  • in-house. SASA contributed to in-house online training material for new bee inspectors. This aims to prepare them with a baseline background knowledge of bee health issues, until practical training is an option
  • talks and presentations. FH and LM attended an SBA webinar on 5th August. This was well attended (>130 attendees) and opens up the possibility of reaching remote audiences on issues affecting their bee health
  • schools, SQA and EBSOC workshops. FH has attended online meetings with EBSOC and teachers to plan a final workshop for first tranche of ‘Beehealth workshop’ SQA students, and future planning for new students. Interest in SQA level 5/6 from 20+ schools, Ray Baxter campaigning for a co-ordinator to help roll this out

R&D

  • PhD studentship – Eastbio Aberdeen Uni/SASA. Pesticide problems for honey bees – a closer look into our towns. This will commence late September 2020 with a literature review
  • foulbrood subclinical work – samples have been collected by bee inspectors from a wider sub-set of Scottish colonies (thank you) in anticipation of a winter student to continue this work. In their absence we hope to have a member of the team start analysis
  • foulbrood strain typing – strain typing planned for winter months using current DWMB staff. This may help to elucidate the source of new outbreaks

SRUC update

Graeme has been managing the online support system available for beekeepers who are wishing to report their concerns of colony loss during COVID. Guidance was distributed to beekeepers through the usual channels in Scotland at the beginning of the COVID crisis. It was also decided that beekeepers should contact me with any bee health-related issues they suspect in their colonies. The Beekeeper provides us with as much detail as possible of symptoms and signs within the colony that are causing concern. From there we can triage the enquiry and give the relevant advice, this output is on-going.

SRUC Dealt with enquires forwarded from the BHIT team from the bees mailbox. This output has been on-going. Also been dealing with normal day to day enquires from beekeepers in Scotland that come through the advisory office phone, e-mail and in writing. This output is also ongoing.

Advice has been given on a wide range of beekeeping husbandry matters to ensure best practice. A few examples of beekeeping topics that advice has been given on is listed below:

  • moving bees
  • clearing honey
  • IPM Varroa
  • life cycle of the Varroa mite
  • taking Nucs
  • swarm control methods
  • swarm control when you can’t find the queen
  • dealing with bumble bees
  • starvation
  • EFB identification
  • temperatures to handle honey
  • demaree method of swarm prevention
  • use of Acetic acid for the sterilization of stored comb
  • sterilization of second-hand equipment
  • cupkit queen rearing system
  • signs of swarming
  • licenced products available for Varroa control
  • varroa control and monitoring
  • the price of honey wholesale
  • chalk brood
  • signs of CBPV
  • parasitic mite syndrome signs and symptoms
  • tips on how to find a queen
  • transferring nuc to full colony
  • making up queenless NUCs
  • uniting colonies
  • how to start beekeeping
  • management of SRUC education apiary. Inspections every 7-days from May-July.
  • regular catch ups with the BHIT team
  • contact with Veto-pharma technical representative. We have had discussions around the use of Apivar when the honey supers are on the hive. Objective was to obtain clarity from veto-pharma technical team
  • discussions with BFA chairman regarding Amitraz licenced products for Varroa control

During the restrictions due to the control of COVID-19, we have been working from home. An exception to this is when we have been carrying out inspections at SRUC education apiary. Due to personal circumstances, some groups members are working flexible hours during COVID.

SBA update

Subsequent to the online AGM and appointment of several new trustees, the SBA has undertaken monthly online trustee meeting in an effort to further SBA projects and ascertain methods of interacting with and educating our membership.

These have resulted in a number of online Q&A sessions and various educational webinars. We recently had the opportunity of hosting a webinar with Luis and Fiona, which was exceptionally well received with approximately 180-90 people being registered for attendance. This use of the webinar system will continue on a monthly basis with Q&A sessions together with speakers from national and international locations being available and on varying subjects.

A change of magazine printer has been initiated and the SBA magazine will be printed by Rannoch Press, (Glasgow) from October onwards. A new online and web based system called “Magentrix” is being examined and this system will potentially be used as a future platform to host all of the SBA online systems.

This will incorporate our present “Salesforce” (database) system together with a new “Online Bee Academy”, which will be the basis for our educational programme. This educational programme will be designed to assist beekeepers not only in practical educational matters but also in modular exam assistance. It will also have educational benefits to members of the public, who will be able to access various parts of the system/webpages.

Should the system be adopted, it is envisaged to undertake the work of all the existing platforms and bring a cohesive concept to the SBA educational and advisory methods. Trustees will have responsibility for updating their relevant pages on the website, releasing the sole responsibility from the webmaster.

Due to the COVID-19 virus, all SBA meetings for 2020 are, at present to be online and Affiliated Beekeeping Associations have, ostensibly ceased beginner beekeeper programmes. There are a few associations who are holding online courses and occasional ones who are attempting practical mentoring work. These however are in the minority.

The SBA magazine has been used well and various disease articles and announcements have been included from Matthew Richardson (bee health trustee) and Luis Molero (Lead Bee Inspector). Our development Officer (Michelle Berry) has been very effective in transmitting information to our membership and members of the public via Mailchimp and other social media platforms.

The use of online platforms, magazine and social media shows the potential for widespread communication but more importantly the opportunity to work together as a partnership to benefit our bees, beekeeping community and the public at large.

Our last webinar demonstrated that varroa is still a major concern for beekeepers and Luis’ consideration of a “varroa working group” is certainly to be commended together with continued articles regarding treatments and their safe usage/disposal.

The SBA have had a few queries regarding people keeping bees in their gardens and having problems with neighbours because of this. Luis has had to do a few MACCS cases on this subject and is happy to send a standard response to the SBA to have to hand.

LM to send SBA standard reply to keeping bees in your garden and having issues with your neighbours.

Question – would it be possible for the SBA to add a bit at the end of their videos advising people of their civic responsibilities?

BFA update

As you will appreciate this is a very busy time for bee farmers. Since we last reported to you, we have further postponed our fact-finding trip to France until next spring. The floral harvest has been a varying picture up and down the country, but the heather harvest looks good The BFA colony survival and honey crop survey for last year has been published in our current Bee Farmer magazine.

Thanks to Luis’ introduction, we continue to attend the Government agricultural stakeholders group, which is now meeting monthly. Through this the BFA is happy to be involved in the redrawing of the animal health regulations. Bees were not previously included. We have supplied a copy of the BFA Code of Conduct for members which we hope is to be reflected in the new rules. We look forward to seeing the draft.

It is worth pointing out that recent surveys have shown a huge increase in home baking and the use of quality ingredients like good quality local honey.

During the current crisis the pastoral care of our members has been paramount, and we continue to deal with providing information on available assistance. We pointed out at the last meeting that home schooling proved a significant burden to younger members at such a busy time of year.

Scottish Government update

All bee health activities scheduled for 2020 were cancelled with the exception of bee health inspections. Newly recruited bee inspectors will not be trained until government’s guidance allow us to carry out the training in a safe manner for all. We still hope to be able to give them a taste of bee inspections before the end of the year if guidance allow us to do so in a safe and practical manner.

Bee inspections have continued under strict COVID-19 guidance. In addition to the LBI, we have 2 full time and 2 part time bee inspectors. (Gordon Mackay, Claire Gill, Angus MacAskill and Jim Anderson). As per previous years, inspections are envisaged to continue until the end of August. After August inspections will be weather dependent and only responding to ad-hoc calls by beekeepers and high risk follow up inspections. Each inspection will be assessed on its own merits.

Mairi Carnegie has been working remotely with the bee health team as well as completing her duties for SASA. Mairi has been a key support for the LBI acting as deputy and completing a wide variety of tasks.

The following points have been noted during the inspections completed until now:

  • we are keeping regular contact with all team members to assess how the current COVID-19 safety arrangements are impacting on them.
  • we have not had concerns from our inspectors or members of the beekeeping community. We believe that our amended practices are safe and comply with COVID-19 NHS and Government guidance. We continue to review and discuss regularly with our inspectors, stakeholders and operational partners on weekly conferences.
  • our biggest risk continues to be the long days of physical work exacerbated by the need to do long drives to attend to high risk inspections in geographical areas where we do not have a regular presence of inspectors.

We have addressed this situation by ensuring our inspectors do not have more than two long days per week and regularly assessing levels of tiredness. As above, inspectors are asked to make a self-assessment and full confidence is placed on their decision making, with an overview from the LBI.

The flexibility and commitment of the whole team has been the key to the success on our delivery and we would like to publically express thanks to the four inspectors and the rest of the team for all they have done this year so far.

Bee Health Inspectorate: other items, progress and decisions made

Business Support for the Bee Health Team. Following the retirement of Graham Lumsden, SGRPID’s senior management provided two members of business support: Carol Jackson and Roseanna (Rose) Huggett. Both have turned out to be a great asset to the team and their performance has signified a huge improvement in our administrative capacity.

Weekend Working: an issue on which we have made a decision relates to weekend working: on a variety of occasions our inspectors have now been asked to attend to weekend calls by beekeepers.

The agreement is as follows:

  • the Scottish Bee Health inspectorate does not carry out routine inspections out of hours
  • there is not an out of hour’s number neither is the Bees_mailbox@gov.scot monitored out of hours
  • we have risk assessed the potential calls out of hours and have agreed that, with the exception of exotic invasive pests, there is nothing which is so urgent that it needs immediate attention from our team. A 3-day turnaround is suitable for cases of suspected foulbrood
  • in the case of an invasive pest report we envisage that the call would come to the LBI or another member of the senior management team in SG, SASA or SRUC. We have put in place alternative methods of internal communication for these instances

Registration reminder for beekeepers 

During our inspections it has become clear that our disease control strategy is heavily influenced by the quality of the records in BeeBase.

We issued a reminder which was distributed widely in an attempt to reach as many beekeepers as possible, registered and not registered. The exercise was a partial success with over 100 new registrations recorded within the immediate following weeks and over 100 beekeepers updating their details. However, it remains paramount that, in order for Beebase to work successfully as a disease management tool, beekeepers register and keep their apiary locations as up to date as possible, amending as they complete moves for different crops. (i.e. moving to heather, rape etc.).

Reminder on use of medicines by VMD

We worked with DEFRA, WG, Northern Ireland and the VMD to instigate this announcement. We discussed in previous BHIP meetings the use of Amitraz by those beekeepers taking bees to the heather and the difficulties in establishing an effective treatment protocol.

This issue has been very positive on establishing a good working relationship with VMD and the FSS. We will continue to work together to establish responsibilities and communications to ensure good practice.

To note that conversations have highlighted the seriousness of using non-authorised products or using authorised products against the data label. As well as possible penalties and legal actions, the VMD and FSS would likely consider as part of their action the recall from public consumption of all honey produced by the beekeeper if there is a risk for public health. This would likely be the case if Amitraz is used as there is a risk for the maximum residue limit (MRL) to be exceeded.

This would not only be considerably damaging to the finances of the beekeeper in question but could potentially damage the reputation of the beekeeping community and honey producers as a whole.

VARROA working group

The conversations held around the use of Amitraz and the program for Varroa treatment for beekeepers migrating to the heather crops have highlighted some challenges in terms of Varroa control by these beekeepers.

We have also noticed that the majority of beekeepers, both hobbyist and commercials, are more concerned about Varroa than foulbroods despite the majority of our government work being focused on the control of foulbroods, in particular, EFB. Naturally this is due to the widespread nature of Varroa mites and their deregulation as a quarantine pest, whilst the foulbrood diseases affect a relatively small percentage of beekeepers and remain under legislative controls.

We are therefore suggesting to the BHIP that we consider the formation of a Varroa working group to discuss and issue advice on best practice for treatment of Varroa with a special focus on Scottish beekeepers, their practices, beekeeping calendar and our weather limitations.

Crofter's grants for beekeeping 

We have produced some guidance and comments for colleagues on Crofting Policy. They are looking at a ‘National Development Plan for Crofting’ under the Crofting Agricultural Grant Scheme (CAGS) and asked for our input.

Currently, CAGS provides grants to tenant and owner occupier crofters towards the costs of a range of agricultural operations.

As we come to the end of the current Scottish Rural Development Programme (SRDP), they are reviewing their schemes and seeing what improvements they can make. One such improvement under consideration is the introduction of a Bee keeping package under CAGS. This grant would go towards the purchasing of hives, extractions kits, safety gear, smoker etc. It could not be used for stock (bees).

We have discussed this with them and members of the BHIT and provided them with guidance and suggested rules for the scheme such as compulsory registration for applicants, maximum size of apiaries, discussion with SNH to protect sensitive areas for wild pollinators, local sourcing of bees, requirement to have completed a beginners course, joining a local association and more.

Buyers of imported bees/importers of bees and queens reported as selling packages and Nucs as “Scottish Bees”

From the BHIT we monitor and risk assess all notifications of imports into Scotland. We are also aware of some of the onward distribution of these packages of bees and queens.

In the past it has been reported that some of the regular buyers or importers of bees and queens are advertising sale of these bees, or stocks produced from them, as “Scottish” and “local”.

An internet search of these suppliers has indicated an improvement to the advertising statements of these companies, with one website now clearly stating where queens for sale are of EU origin. The other company no longer claims outright to be selling ‘Scottish bees’, although some of the wording is still ambiguous and may be easily interpreted as such.

For reasons of confidentiality and libel the ambiguous wording is not an issue which can be raised publicly, and a general ‘be aware’ announcement is likely to put an even more negative spin on the import of bees into Scotland.

We continue to be interested in hearing about any recent instances where beekeepers are being offered ‘Scottish’ or ‘local’ bees from sellers who import stocks and, if necessary, we would approach Trading Standards to discuss the matter. However, it is envisaged that it would be difficult for Trading Standards to establish fraudulent activity due to the lack of a regulatory framework and the grey area about when bees become “Scottish”.

We would like to hear the views from the BHIP members on this.

Update on bee inspections 

Totals                                         2018      2019   Up to 3rd August 2020

Inspected colonies                     3767    4117   7373

Inspected apiaries                      208      200     359

Inspected beekeepers               65        58       84

AFB colonies                                0           10       7

AFB apiaries                                 0            5        4

AFB beekeepers                          0            1        1

EFB colonies                                59          193     143

EFB apiaries                                37           61       60

EFB beekeepers                          14          13       18

Notes about these figures

Figures change daily following recording by Business Support (BS) in Beebase and reporting of SASA’s lab results. These figures need to be understood and discussed as they are influenced by a large number of factors:

  • this year we have changed the disease control strategy. We have put more responsibility on the infected businesses under the EFB control plan on self-reporting and self-inspecting
  • of 90 positive inspections, 27 have been done by bee inspector and 63 are self-inspections by accredited bee farmers
  • of 448 total inspections, 139 done by bee inspectors and 309 done by accredited bee farmers

This shows the importance of these accredited bee farmers taking responsibility for their own disease inspections, management and reporting. The bee health inspectorate does not have the resources to tackle the levels of infection within these accredited businesses in addition to monitoring for the spread of disease to hobbyist and other commercial beekeepers, so compliance with all aspects of the scheme is essential and has been emphasised this year with positive results.

Our new business support team has done an amazing job at recording all self-inspections and the two statutory foulbrood inspections as per the EFB control plan.

We have led the bee inspectors to a different strategy than previous years; we have not targeted so much the known infected businesses and we have focussed a large part of our resources on new commercial beekeeping businesses and 3km contacts. This would not have been possible without the cooperation of those commercial businesses signed up to the EFB control plan.

We continue to see the same patterns:

  • EFB appears to be deeply embedded in five commercial businesses in the EFB notional infection zone
  • two of these commercial businesses account for 77.7% of all EFB found in Scotland
  • the sporadic outbreaks to hobbyists are linked through movement of infected bees or close proximity to infected apiaries of these commercial businesses
  • a new commercial business in Aberdeenshire has been found to be heavily infected with EFB. There is a clear link to one of the established infected commercial beekeepers where disease is present. This shows the importance of ensuring bees are sourced from clean, healthy stocks
  • there is an ongoing outbreak of EFB in two different areas of Dumfries, but we believe that both are linked to the outbreak in 2018, showing the difficulties of eradicating EFB which can lie dormant (sub-clinical) in a colony for long periods of time before the disease symptoms are expressed

The SBA asked if there has been any consideration to treating EFB like AFB and destroying the hive or having compulsory registration.

LM: Compulsory registration is high on our list of priorities. We have expressed since my appointment that we do not believe that we can effectively carry out a disease control program without adequate registration of beekeepers and traceability of all hives in Scotland. Currently we are pending implementation of the European Animal Health Regulations into Scottish law. The new regulations include compulsory registration for all livestock keepers, including bees. If the regulations are fully adopted by Scottish ministers, registration will be compulsory. We will carry out a consultation in any case prior to any changes.

All options are currently on the table regarding EFB. These year we have gathered a wider picture than in previous years and we plan to consider all possible options.

Something that is becoming clear is that our current approach, whereas effective at keeping the levels of infection down, doesn’t have the wider approach of trying to control disease at Scotland’s level. EFB is a difficult disease that spreads easily within the business due to poor biosecurity practices. We need to change the attitude of bee farmers and make them understand that they need to treat EFB at apiary level, not only looking at the individually infected hives and to improve on their bio-security.

The EFB control plan will be put on the website but the format has had to be changed to make it user friendly.

Terms of reference

All in agreement with the Terms of Reference (ToR). These will be published on the SG website and will have the logos of all the organisations involved.

Members of the BHIP

  • Luis Molero or Fiona Highet, Chair
  • Scottish Government, Secretariat
  • Fiona Highet or Mairi Carnegie, SASA
  • Angus MacAskill and Karen MacKenzie, SG Bee Inspectors
  • Phil McAnespie and Matthew Richardson, SBA 
  • Margaret Ginman, BFA
  • Margaret Thomas, NBD
  • Graeme Sharpe, SRUC
  • Jim Jeffrey, SNH

It was agreed that Jim Jeffrey from SNH should be invited to the BHIP meetings. Also work more in conjunction with SNH on the Honey Bee Health Strategy. We will try and set up a meeting with the Pollinators Strategy to introduce ourselves.

Margaret Ginman will see if she can get a Scottish representative for the BFA but she is quite happy attending the meetings. We will ask someone from the education sector to join us when required.

SG to publish the ToR and to format the document with the logos of all partners and stakeholders.

Honey Bee Health Strategy

The review of the honey bee health strategy should be published by the end of December 2020. This would allow us to start working on a new strategy for June 2021.

We would like to review things that have happened over the past 10 years. This will include a review from each group on the implementation of the strategy, success and areas for improvement as well as a suggestion for the focus of the new 10 years strategy.

Luis to send out template for the groups to fill in.

Varroa treatment

We plan to create a Varroa Treatment working group for 2021. The Varroa Treament group will be a group of experts who will review all available treatments and their data sheets, solving any discrepancies with their current use. Furthermore, the group will aim to provide expert advice on Varroa control in Scotland for both commercial and hobby beekeepers. The main area of concern is finding a suitable IPM protocol for beekeepers taking bees to the heather crop. The group will report back to the BHIP.

COLLASS already done some work on this a few years ago. The information is out there it just needs to be collated.

The group recognises that there are beekeepers who make up their own treatments. This is also due to the cost of buying the treatments. Some of these treatments were promoted by stakeholders and operational partners. There is a role on education and making beekeepers aware of the risks of these treatments for them, public health and bee health.

VMD authorise the use of medicines in the UK. It is important to understand that those using illegal treatments will face legal action.

Discussion ensued on membership and chairmanship of this group. The following was agreed:

  • the group should not be chaired by SG/LBI: this should be an industry lead group
  • Matthew Richardson was proposed as chair of the group due to his expertise and legal background
  • the group should include members from VMD and pharmaceutical companies which have offered technical support
  • Graeme Sharpe proposed to start his Varroa course again if this would help beekeepers. This was seen as a good idea and seconded by all.

Graeme Sharpe to include Varroa courses on his delivery outcomes. We will try and get this meeting arranged for some time in October. Luis to organise first meeting for October.

AOB

Nothing under AOB

Date of next meeting

Jackie will send out a doodle poll for the next meeting.

Previous action points

  • completed – LM to write an article for SBA magazine (Luis (LBI) to write an article for the SBA Monthly Magazine)
  • ongoing – LM to draft new ‘Good practice for selling nucs’ guidelines & standards and will circulate for comment (this is in the Restocking Options report produced by Gavin Ramsay)
  • completed – MG to consult with the BFA and see if she can share the code of good practice from the BFA members with LM (there has just been a meeting. MG will update us shortly)
  • on hold – MG to invite LM to next BFA meeting (LM will be invited to the next meeting but unsure when that will be)
  • on hold – MG to consider to invite Robert Field to speak to the BFA members, with emphasis on EFB control plan group, on his biosecurity and compartmentalisation methods (Robert Field can do it but not before October 2020)
  • completed – BFA to seek clarification from VetoPharma regarding use of Apivar with honey supers. BFA to discuss this with their members and raise awareness (some progress on this but need to get an update)
  • ongoing – GS suggested each stakeholder group writes a section on their inputs to the Strategy over last 10 years and sends to LM.
  • completed – LM to circulate Key Point Indicators and proposed format to BHIP by March
  • completed – Luis to circulate document if allowed as comments need to be received by end of March

Action points from 8th June 2020

  • completed – Jackie to get list of committee members from Phil McAnespie

Action points from 14th August 2020

  • ongoing – LM to send standard reply to SBA for keeping bees in your garden and having issues with neighbours
  • ongoing – SG to publish the ToR and to format the document with the logos of all partners and stakeholders
  • ongoing – Luis to send out template for the 10 year review of the Honey Bee Health Strategy
  • ongoing – Graeme Sharpe to include Varroa courses on his delivery outcomes.
  • ongoing – Luis to organise first meeting for October for Varroa Group

Contact

Email: BeesMailbox@gov.scot

Post: 
Bees Health Improvement Partnership (BHIP)
c/o Scottish Government
Saughton House
Edinburgh
EH11 3XD

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