November 2005
Cogent eBulletin
The Sector Skills Council for Chemicals, Nuclear, Oil and Gas, Petroleum and Polymers
Cogent SSC
 
     
  Welcome to the latest issue of Cogent's eBulletin.

We very much welcome your news, views and ideas.

Please email Judith Cowan if you would like to contribute to the next issue.

 
   
 
 Contents
 
     
  Phil Hope sets out SSC strategy
Building a Skills Agreement for Cogent Industries
National Occupational Standards Directory Launched
Employers Call For Energy Decisions
Futureskills Scotland Spotlight Cogent Footprint
Foster Report Welcomed by Skills for Business
Pharma Institute Reveals Science Graduates Lacking Skills
LSC Transformation to Focus on Grassroots
SSDA Reveals Differences in Sector Performance
Cogent and SummitSkills Join Forces in Scottish Petrol Forecourt Pilot
SSCs Move Forward On Brokerage
Apprenticeships On The Up
Lord Sainsbury listens to Cogent employers
 
     
 
 
 
Phil Hope sets out SSC Strategy
 
 
Speaking at the Annual Skills For Business Convention, Phil Hope, Parliamentary Under Secretary For Skills said that since coming into the role his top priority has been the Skills Strategy and the role of Sector Skills Councils in delivering that strategy.

He told an audience of SSC delegates: “Two White Papers produced by my Department on skills show that this Government is serious about helping to raise business performance through skills and that we are serious about listening to employers and about creating a system that is not only business responsive, but business driven.”

Mr Hope said that during recent meetings with SSC Chief Executives he found great enthusiasm for the tasks ahead  including Sector Skills Agreements, Skills Academies and the opportunity to really make a difference to the 14 - 19 learning phase through specialised Diplomas.

He added: “Some are suggesting that we are rushing all this a bit. It is true that the timetable is pressing: but so too is the need. And I believe it can be done. It will require close working between all partners, and for employers to be involved at every stage.

“I will not compromise on quality: only those schools and colleges able to offer a good quality experience will be able to teach the Diplomas in 2008.”

Mr Hope outlined the key challenges for the Skills For Business Network

  • The ability to demonstrate real active and broad employer engagement in SSC plans
  •  Secondly every SSC should develop a robust sector agreement based on high quality analysis and dialogue
  •  All SSCs need to have considered the balance between work to attract young people into the sector and skills enhancement of the existing workforce to support productivity improvement
  • Every SSC needs to consider how to improve the linkages with and influence on over the supply of skills.  Skills Academies are a very powerful way of putting employers in the driving seat and The Foster review on further education provides another way to get involved in shaping learning 
  • Finally, the need to reform vocational qualifications 

Mr Hope recognised that the last challenge had been on the agenda for years, “whilst some progress has been made, we never seem to quite crack it. Indeed, I am told that, five years into a so-called "rationalisation" exercise, there are now more qualifications and units on the market than ever - most of them not even on the National Qualifications Framework.  The result is that, too often, employers are confused, learners are put off; and the general public views vocational learning as second-rate.”

The Minister announced two decisions:

  • The go-ahead to the Qualifications and Curriculum Authority to begin the trialling and testing stage of a new qualification framework, called the Framework for Achievement.  This new framework will capture the qualifications that employers value; short, relevant, up-to-date units of learning available flexibly and on-time.
  • Secondly, to put Sector Skills Councils in the driving seat.  SSCs will be asked to set out precisely the skills; knowledge and competences which are needed for qualifications in their sectors, “out of this process we will get fewer qualifications, less confusion and more value.”

The Minister concluded by stating that, “ together, these two actions will mean a big step forward in bringing our country's qualifications system into the 21st century. What I have announced is a major opportunity for business to shape learning. Please take it and use it."

“We must now be totally focused on how we drive the network forward so that the Skills for Business network can rightly claim its position as the true voice of a broad range of employers and one with real clout. “

 
   
     
 
 
 
Building a Skills Agreement for Cogent Industries
 
 
Cogent SSC is moving ahead with its SSA process, designed to tackle its industry footprint skills needs.

There is a clear vision for the process - to have a sector that is fully qualified, highly professional, working to strict safety standards and which has the capability for innovation.

Next month, Cogent will launch the first stage in this agreement - the Skills Needs Assessment (SNA) - an analysis of current and future employer skill needs.

The process will then be rolled out in the following four stages, the findings of which will be integrated into a final Sector Skills Agreement document to be published in May 2006.

Stage Two - Assessment of Current Provision

This is an assessment of the current state of available training provision across the Cogent footprint, and Cogent will be asking employers what works and what doesn’t.

The draft document for consultation will be available online by the middle of January 2006.

Stage Three - Gap Analysis

This part of the process is analysing the gaps and weaknesses in the training and education which is available and identifying and agreeing priorities and objectives to deliver relevant 21st century skills.

The draft document for consultation will be available online at the end of February 2006.

Stage Four (December - April)

Cogent representatives will work during this stage to agree with industry the scope for collaboration by employers to tackle the identified priorities, and assess their expected contribution.

Stage Five - May

Cogent  will develop a costed action plan with training providers and other delivery bodies that specifies actions, responsibilities and levels of contribution.

The final Sector Skills Agreement Document will be launched across the nine English regions.

Cogent CEO Joanna Woolf said: “We must be employer-led. And we need employer input and support to move forward. It is critical that our education and training system keeps pace with employer needs and delivers enough people of the right calibre, with the right skills and qualifications to take businesses much higher up the value-chain.

“This process formally gives employers a say in the skills and training needs of their industries.  And it is critical that we work, on their behalf, with the supply side bodies including the LSC and RDAs to secure action plans and targets.”

 
   
     
 
 
 
National Occupational Standards Directory Launched
 
 
The Skills for Business network has launched a central directory for national occupational standards (NOS) to make them freely and publicly available.   The directory will act as an integral tool for access to and promotion of NOS. It can be accessed at  www.ukstandards.co.uk

The NOS Directory is a landmark achievement and will provide the first free public access to the full range of National Occupational Standards, signposting users of the website to the relevant Sector Skills Council or standards setting body for further information.

The Skills for Business network is enhancing its arrangements for quality assuring its NOS effectively.  The network is currently testing quality assurance principles and criteria that underpin an effective standards-setting function.  It is also putting in place arrangements for the peer review of national occupational standards to ensure they meet the requirements of the specification.

The programme to develop NOS is co-managed by Qualifications and Curriculum Authority (QCA)/Scottish Qualifications Authority (SQA).  The Sector Skills Development Agency (SSDA) is working with all key partners to transfer the management arrangements for NOS to the SSDA.

Apprenticeships/Modern Apprenticeships - N/SVQs and Technical Certificates within Apprenticeships are based on NOS. And importantly many qualifications within Sector Qualifications Strategies (SQS) will be based on NOS - the Cogent strategy will be clarified via the SSA process.

 The Skills for Business network's work on NOS will also provide the content for qualifications developed for inclusion in credit and qualifications frameworks.

NOS also influence education and training - many Foundation Degrees frameworks and some honours degrees are based on NOS.

This will be the first time that people can access all NOS in one place and is a useful tool for a range of people including employers, individuals, education and training providers, partners and funders.

National Occupational Standards help employers increase productivity, improve services and act as a benchmark for rewarding experience, knowledge and competency. They help employees identify skills required for occupations, identify career paths and increase mobility within industries.

Cogent Occupational Standards Project Leader, Peter Crowther said: " NOS are widely and effectively used in qualifications in many sectors. In our process industries, many employers are not using them yet and don't yet understand their value. I would recommend all Training and HR managers in the Cogent sector to take some time to investigate and look for material which they can use, free of charge and fully accessible on the website."

 
   
     
 
 
 
Employers Call For Energy Decision
 
 
Business needs a revamped, coherent energy strategy as key policy gaps could threaten the security of energy supplies in the future, employer body the CBI have said.

Publishing its paper, ‘Powering the Future’, the CBI said energy costs rising to uncompetitive levels, and concerns over gas supplies this Winter, had shot the issue of UK energy needs to the top of the business agenda.

The document identifies that a third of UK generating capacity, much of it nuclear, needs to be replaced by 2020 - in ways that maintain long-term security of supply, deliver prices that compare favourably with EU rivals, and fit with the UK's environmental aims.

The CBI is calling on the Government to get a coherent energy policy in place as a matter of urgency, including a decision within a year on whether to back a new generation of nuclear power stations.

Sir Digby Jones, CBI Director-General, said: “The threat to companies of gas shortages and rising energy costs this Winter has shot the issue of energy to the top of the business agenda.

“Risk is an accepted fact of business life. But what users and producers of energy need, as in any marketplace, is a clear framework that lets them manage that risk in the most effective way.

“One third of UK power generating capacity needs to be replaced by 2020. But without a coherent and integrated energy policy there is a risk that the billions of investment required will not come at the right time or at the most efficient cost."

The CBI’s paper stresses that business does not want to see greater intervention in the energy market by Government - just greater clarity. It calls on the Government to:

  • Lead a national debate to resolve the future of nuclear by the end of 2006;
  • Prioritise energy market liberalisation in EU political negotiations;
  • Streamline the process for energy infrastructure planning applications;
  • Increase Government investment in energy R&D and actively promote a wider range of low-carbon technologies;
  • Work with industry to assess in more detail the risks to security of supply;
  • Improve emergency planning to minimise the impact of short-term disruptions;
  • Make the economy more resilient to price rises by increasing the efficiency of energy use;
  • Promote a stronger engineering skills base for the energy industry.

Stop press....Prime Minister Tony Blair has revealed the Government will set up a review on the 2003 Energy White Paper's goals and report back early next summer on whether to facilitate a new generation of nuclear facilities.

Speaking at the CBI conference in London, the Prime Minister issued a defiant message to Greenpeace protestors who had halted the speech, emphasising the need for "serious, organised, democratic debate" on nuclear energy.

Mr Blair pointed out the UK was decommissioning nuclear and coal plants which generate 30 per cent. of the total energy supply. He warned this proportion could not be replaced by renewable energy sources.

Energy Minister Malcolm Wicks will lead the review

 
   
     
 
 
 
Futureskills Scotland Spotlight Cogent Footprint
 
 
Oil & Gas Industry
Futureskills Scotland has released an analysis of the Cogent sector footprint, with considerable input from Cogent SSC.

A key section of the report presents Cogent’s views. Changes in the structure of the market and increasing competition from within Scotland were seen as the main challenges facing businesses in the Cogent sectors.

Changes in the market structure are being witnessed across the Cogent sector. For example in the oil and gas industry, there is a trend towards outsourcing work to contactors in the supply chain. Recent years have seen a new type of Operating Company moving into oil and gas in the UK who tend to be leaner operations sub-contracting operational activities to supply chain contractors.

Likewise, the structure of the Polymers market has been changing and continues to change as the variety and range of products using polymer technologies expands. The automotive and aerospace industries are increasingly using polymers as a substitute for metal components. Also, as consumer tastes change there is an increase in demand for production of consumables such as fashion driven colour co-ordinated domestic and kitchen appliances.

Futureskills Scotland is part of Scottish Enterprise and Highlands & Islands Enterprise.  It aims to:

  • analyse the Scottish labour market to inform policy making
  • improve the availability, quality and consistency of labour market information and intelligence across Scotland
  • work closely with Careers Scotland to provide the organisation and its clients with labour market information

For copy of the repot click here

 
   
     
 
 
 
Foster Report Welcomed by Skills for Business
 
 
Skills for Business, including Cogent SSC, has welcomed the commitment to involve more employers in Further Education (FE), which is outlined in a major education report published earlier this month.

The Foster Review examines the key challenges and opportunities facing FE colleges.  Amongst the report's recommendations are:

  • colleges to improve their response to the needs of local and regional employers;
  • revitalised workforce reform and leadership development to include developing vocational expertise;
  • funding incentives to encourage colleges to develop vocational specialisms.

Geoff  Fieldsend, Director of Workforce Development at the Sector Skills Development Agency (SSDA), said: "We are extremely pleased the Foster Review has emphasised the contribution that employers have to make in the development and delivery of vocational education and skills in FE.

"Eighty per cent of today's workforce will still be in work in 2010 and the only way we will ensure we have the skills we need for a prosperous future is for employers and colleges to work more closely together."

Joanna Woolf, Cogent’s CEO added: "Sector Skills Agreements will bring employers and colleges more closely together, by mapping out exactly what skills employers need their workforce to have and as well as the supply of those skills.

“We will be working over the longer term with the LSC and other partners in delivering the recommendations of this important report.”

John Brennan, Chief Executive of the Association of Colleges added: "It is a huge and welcome opportunity for colleges. Sir Andrew Foster has affirmed just how important they are to this country's young people, adults and businesses. Colleges will welcome an even sharper focus on generating skills for employment and a closer relationship with employers."

Click here for report

 
   
     
 
 
 
Pharma Institute Reveals Science Graduates Lacking Practical Skills
 
 
The UK's traditional strength in science is eroding, science graduates are lacking practical skills useful to industrial research and urgent action by a range of partners is required to arrest this decline - these are among the findings of a new report by the Association of the British Pharmaceutical Industry (ABPI).

The study, the result of a six-month analysis by the ABPI Science, Technology, Engineering and Manufacturing (STEM) Education & Skills Taskforce, recognised Government commitment to science - but highlighted particular shortages in chemistry, clinical pharmacology and in vivo biology.

Responses from companies also show a decline in higher level mathematics skills among life scientists and major knowledge gaps in other areas of use to industry. Real concern was expressed by industry survey respondents that, thanks to constrained curricula, graduates lack practical "hands on" laboratory experience - an essential element for an industrial scientist. There are also insufficient specialist physics/chemistry teachers and limited opportunity for work placements. Worryingly, awareness of the wide variety of science careers available within the pharmaceutical industry among school pupils and science graduates is low.

"This report serves as a call to action for society to fill the growing science skills gap," said ABPI Director of Science & technology, Dr Philip Wright. "The Government has been a real champion for science, but if the UK economy, especially the research-based pharmaceutical industry, is to flourish then we need to work more intensively with Government to equip the next generation with the skills to succeed."

Recommendations included within the report call for all stakeholders to work together to arrest the decline. They include changes that could be made to the curriculum alongside greater commitment from science-based industries to support science education and promote careers. 

Copies of the report, entitled Sustaining the skills pipeline in the pharmaceutical and biopharmaceutical industries, are available to download from the ABPI website: http://www.abpi.org.uk

 
   
     
 
 
 
LSC to Focus on Grassroots
 
 
The Learning and Skills Council (LSC), the organisation responsible for making England better skilled and more competitive, through planning and funding high-quality vocational education and training for everyone,  has announced further details of its proposed transformation programme.

The focus for the LSC is on achieving better quality and more consistent delivery at a local level and it has announced the creation of 148 local Partnership Teams providing a countrywide network of highly skilled and experienced education and training professionals working closely with partner organisations.

The local Partnership Teams will work alongside local Economic Development Teams (35 in total across the country) that will focus on skills for employers and regeneration.

Nine regional centres, from which operational services such as finance will be delivered, will support local teams and build stronger regional links with partners such as the Regional Development Agencies.

A reduced national office function will concentrate on supporting regional and local delivery, providing national expertise such as legal services and clear frameworks to ensure consistency across the country.

Mark Haysom, Chief Executive of the LSC said: “We need to get under the skin of local needs and ensure that funding and delivery of local learning and training is relevant and delivered quickly. Our transformation will see the vast majority of our workforce focused outwards on frontline delivery through strategic relationships at the local and regional level.

“There is more work to do in terms of fleshing out details of each level of operation and the next few months will see further work and consultation with staff, our nonexecutives, partner organisations and with the trade union.”

The LSC agenda for change is a dynamic programme of reform that will help to transform the way the learning and skills sector operates. The agenda for change prospectus (available at www.lsc.gov.uk) is a blueprint for a transformation of the further education sector.

One of the key proposals is to create a new network of colleges that are quality marked by business to enable colleges and other training providers to go further in offering employers the appropriately skilled employees they require.

Commenting on the plans, Cogent CEO Joanna Woolf said: “The LSC’s commitment to making more impact at grassroots level supports our own efforts in a number of key areas including the 14-19 agenda and our own sectoral skills strategies. 

“The LSC’s locally focussed teams will also ensure that national and regional skills priorities are delivered in a way that best meets local needs.”

 
   
     
 
 
 
SSDA Reveals Differences in Sector Performances
 
 
UK productivity is amongst the best in the world in sectors such as food & drink manufacturing, agriculture and transport, according to a major study amongst international countries.

The study, published by the Sector Skills Development Agency, covering 16 countries revealed comparatively strong performances, compared with our main international competitors, in four broad sectors:

  • manufacture of food, drink and tobacco - ranked 2nd only to Canada
  • manufacture of furniture, jewellery, musical instruments, toys and miscellaneous products and recycling - ranked 1st amongst all competitor countries
  • transport - ranked 2nd only to the United States
  • agriculture, hunting forestry and fishing - ranked 2nd only to Japan

However, the research also revealed weaker performance across some sectors including:

  • Wholesale, retail and car repairs
  • financial services
  • energy and chemicals
  • manufacture of transport equipment sectors

This performance suggests that the UK’s productivity gaps are associated with particular sectors rather than general poor performance as is often thought.  

Professor Mike Campbell, Director of Strategy and Research at the Sector Skills Development Agency, said: “Although the UK is the world’s fourth largest economy, and is currently enjoying a period of unprecedented stability, this research has highlighted there are areas of weakness and concern. Productivity variations do exist across different sectors of the economy reinforcing the position that no single skills strategy can be applied to all sectors.

“Sector Skills Councils have a key role to play by understanding future skills needs and then bringing employer-led influence to bear on all the critical factors linked to skills which determine the nation’s ability to perform at a world class standard.

“Unless solutions can be found, the UK could find itself overtaken by its economic rivals in the global market and unable to fulfil the promise of its businesses and public services and the aspirations of individuals.”

Sector Skills Councils including Cogent are working with employers and training providers to improve the provision of employer-friendly training throughout the UK and raise productivity levels. 

 
   
     
 
 
 
Cogent and SummitSkills Join Forces in Scottish Petrol Forecourt College Pilot
 
 
An innovative pilot programme aimed at both upskilling local electricians and ensuring the future and safety of petrol stations in the Highland and Islands is shortly be delivered in three Highlands and Islands locations.

The delivery of the programme is being overseen by a Steering Group comprising of representatives from Cogent and SummitSkills SSCs, the Electrical Contractors body SELECT, Highland and Island Enterprise and Highlands Council. 

With financial assistance from the Highlands Skills Fund and Highlands and Islands Enterprise a team from Forth Valley College will be taking a simulated petrol station rig to venues in Inverness, Elgin and Thurso to deliver pilot courses leading to the industry standard Comp’ex qualifications.

With this qualification, locally based Electrical Firms will be able to offer Petrol Station Owners/Operators installation, repair and maintenance services which they predominately have to currently obtain from firms located outwith the Highlands and Islands, thereby increasing their costs.

Walter Williamson, (pictured) Northern Ireland and Scotland Manager for Cogent says: “Oil and petrol supply companies are driving forward this requirement in order to increase safety at the end of the supply chain.  It is a natural extension of industry standards across the entire supply chain which has improved so much over the years.  We saw the Highlands and Islands community as a special case because it is so dispersed and, therefore, we created this roadshow package using the considerable expertise of Forth Valley College.

“Our hope is that all the electrical contractors in the region who currently supply their services to petrol stations or hope to do so in the future, will take advantage of this excellent opportunity and we are working with SummitSkills, the Sector Skills Council for the Building Services Sector and others to promote these unique opportunities.

“In view of the financial support secured from HIE and the Highlands Skills Fund, participants will only be asked to contribute £250 per person towards the cost of participating in the 5 day course. This would normally cost in the region of £900 plus travel and subsistence costs - a real bargain to gain an important qualification”.

Many forecourt accidents throughout Britain and beyond have been caused by sparks from faulty electrical equipment igniting dangerous petrol vapours - which are 150 times more flammable than petrol.

Operators risk losing their licence to supply petrol if they do not comply with the latest regulations and equipping local firms with the appropriate skills and qualifications is all part of the process of both minimising risk and ensuring cost effective adherence to the regulations. 

The need to support rural petrol stations is particularly important in the Highlands and Islands where around 124 rural petrol stations service 420,000 people.  Often these remote petrol stations provide multiple community facilities such as a post office and local shop.

Gillian Black, (pictured) Commercial Development Manager at Forth Valley College, says:  “Along with Cogent and Highland and Islands Enterprise, we decided to put this vital roadshow together to target the more dispersed communities of the Highlands and Islands, and we are delighted with the support which will enable us to get the show on the road.”

 
   
     
 
 
 
SSCs Move Forward on Brokerage
 
 
Cogent is pleased to announce a partnership approach to tendering for Train2Gain (formerly NETP) LSC brokerage contracts in the English regions.

The five SSCs with manufacturing activity within their footprints (Cogent, Improve, Proskills, SEMTA and Skillfast) have agreed to submit manufacturing brokerage consortium bids for all nine English regions.

Separately to this Cogent is part of two energy consortia - in the East of England and the South East - bidding for Energy Brokerage contracts in these regions.

Commenting on these developments, John Holton, Cogent Strategy Development Director said: “This is a great example of cross-sector working, with key SSCs collaborating to develop and secure employer-led training provision which goes to the very heart of our remit.”

This group of SSCs have also agreed a lead SSC in each English Region who will steer the development of regional Expressions of Interest for brokerage.

 
   
     
 
 
 
Apprenticeships On The Up
 
 
The number of young people starting apprenticeships rose by 16.7 per cent in the 12 months to the end of March beating the government's annual target of 175,000, Ruth Kelly, education secretary, reported this month. 

The drive to ease severe skill shortages in engineering and manufacturing industries has prompted a big increase in apprenticeship training programmes. But Ms Kelly admitted Britain had a "mountain to climb" if it was to catch up with the educational attainment of its main international competitors.

Figures published by the Learning and Skills Council reveal that the number of 16- to 21-year-olds starting apprenticeships has risen by almost 29 per cent from 137,023 in 2001-02 to 176,631 last year.

The number of drop-outs has also fallen. According to the council, nearly 40 per cent of apprentices successfully completed their courses in 2004-05, compared with only 24 per cent in 2001-02.

An industry taskforce, headed by Sir Roy Gardner, chairman of Centrica, the household gas and electricity supplier, advised ministers earlier this year that apprenticeship completion rates should be raised to the 60 to 75 per cent levels achieved in Denmark, the Netherlands and Germany.

The government's target of 175,000 starting apprenticeships annually represented about 28 per cent of all youngsters, but this rate was still well below levels in Germany, Sir Roy said.

The industry taskforce recommended the government should make resources available so that employers could offer apprenticeships to 35 per cent of young people by 2010. It also said companies bidding for public sector contracts should be given priority if they develop training programmes to curb the "chronic skills shortages experienced in many parts of the economy".

The LSC's annual statement of priorities reports that it is on the way to achieving its target of improving the basic literacy and numeracy skills of 1.5m adults by 2007. It is on target to increase the proportion of youngsters achieving level two skills, equivalent to five A-C grade GCSEs. By 2010, some 95 per cent of jobs are expected to require level two skills, it says.

Speaking to a conference of further education college heads, Ms Kelly quoted data from the Organisation for Economic Co-operation and Development showing Britain was 24th out of 30 in terms of the proportion of young people staying on in education at 17. It lies in 21st position for the proportion of the adult workforce with level two skills.

She said the network of FE colleges, which specialise in vocational training and adult learning, was essential for improving the nation's competitiveness.

 
   
     
 
 
 
Lord Sainsbury Listens to Cogent Employers
 
 
Last month, executives from leading employers within Cogent’s footprint had the opportunity to share their concerns and priorities regarding skills with Lord Sainsbury of Turville, Minister for Science and Innovation.

The meeting gave the employers the opportunity to discuss with the DTi Minister their views on how key stakeholders within the public sector and industry can work together to help raise skills levels within the industry - particularly around science and innovation.

Cogent has received positive feedback from many of the employers who attended. They were pleased to have the opportunity to come together in an informal setting, and discuss areas of mutual concern. They appreciated the networking opportunity with fellow businesses,  and they were delighted that a well-respected Government Minister was prepared to share views and take challenging questions over the course of the evening.

The Minister emphasised SSCs'  role in determining industry-focused education and training routes and qualifications.   At the meeting there was support for broad consultation and collaboration around skills, sometimes across sectors, with industry-specific fine tuning and bespoke delivery in the regions.

Mervin Dadd, Head of Communications at Cogent, said: "The meeting was very helpful. Talking to Executives within our footprint gave the minister a clearer understanding of employer skills needs within the sector, and helped employers get a deeper understanding about the government's strategy and its commitment to help.

"We look forward to inviting employers to take part in our regional consultations in February 2006 to discuss the findings from our analysis of skills needs and exisiting and anticipated provisision."

 
   
     
 
 
 
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