# the ZooMed pellet challenge



## Kapidolo Farms (Jan 31, 2013)

So, someone on one of the threads regarding ZooMed Grassland diet sought more specific information about the nutritional content of that diet item. Tom suggested, why not just ask â€“ I did. Following is the whole transcript of that exchange. 

I have removed my personal contact info from the submitted information request.

****************************************************

Me to ZooMed:
1:09 PM (20 hours ago)
Hi,Â 

Do you have - will share a proximateÂ analysisÂ of Grassland or the Forest tortoise diet?

Even a one lot production would give me something to work with.

Will Espenshade
omitted phone number

omitted street address
San Diego, Â CA Â 92126


ZooMed to Me:

Jennifer ShamblinÂ <JShamblinATzoomed.com>

1:57 PM (19 hours ago)

toÂ me

Hello Will,
Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â  Thank you for contacting us. Iâ€™ve pasted into the email what is available for the Grassland Tortoise food.
Suncured Oat Hay, Suncured Timothy Hay, Soybean Hulls, Wheat Middlings, Suncured Alfalfa Meal, Whole Ground Wheat, Escarole, Endive, Calcium Carbonate, Monocalcium Phosphate, Dicalcium Phosphate, Yeast Culture, Dandelion Greens (dried), Sodium Bicarbonate, Soy Lecithin, Direct-Fed Microorganisms (heat stable cultures of Lactobacillus acidophilus, Lactobacillus casei, Bifidobacterium bifidum, Enterococcus faecium, Aspergillus oryzae), Yeast Extract, Hydrated Sodium Calcium Aluminosilicate, Garlic Extract, Anise Extract, Cassia Extract (Chinese), Ginger Extract, Horseradish Extract, Juniper Extract, Natural Flavoring, Marigold (petal extract), Yucca schidigera (whole plant powder), L-Ascorbyl-2-Polyphosphate (source of stabilized Vitamin C), Zinc Methionine Complex, Selenium Yeast, Vitamin E Supplement, Mixed Tocopherols, Rosemary Extract, Ascorbic Acid, Citric Acid, Lecithin, Silicon Dioxide, Choline Chloride, Vitamin A Supplement (Retinyl Acetate), Vitamin D3 Supplement, Niacin Supplement, d-Calcium Pantothenate (source of Vitamin B5), Menadione Sodium Bisulfite Complex (source of Vitamin K activity), Riboflavin Supplement (source of Vitamin B2), Thiamine Mononitrate (source of Vitamin B1), Pyridoxine Hydrochloride (source of Vitamin B6), Biotin, Folic Acid, Vitamin B12 Supplement, Zinc Oxide, Manganous Oxide, Ferrous Sulfate, Tribasic Copper Chloride, Calcium Iodate, Sodium Selenite.
Crude Protein (Min) 9.0%Crude Fat (Min) 2.0%Crude Fiber (Max) 26.0%Moisture (Max) 13.0%Ash (Max) 10.0%Calcium (Min) 0.9%Calcium (Max) 1.3%Phosphorus (Min) 0.4%Sodium (Max) 0.3%
Please let me know if you have any further questions.
Â 
Kind Regards,
Jennifer Shamblin
Customer Service

Zoo Med Laboratories, Inc.
3650 Sacramento Drive
San Luis Obispo, CA 93401
888-496-6633Â - Toll Free
805-542-9988Â - DirectÂ 
805-542-9295Â - Fax
www.zoomed.com
Â 


Me to ZooMed


William EspenshadeÂ <william.espenshadeiiiATgmail.com>

3:41 PM (18 hours ago)

toÂ Jennifer

Hi Jennifer,

Thanks, I have bought the grassland and use it.

What I'm looking for is not the label content, or list ofÂ ingredients. Â I have that on the bottle.

But look at your ingredients, you list for example vitamin E supplement, so what is theÂ analysisÂ of that addition, how much is there.

My idea of a proximate analysis includesÂ 
Water
Carbohydrates
ProteinsÂ  (how much of each amino acid)
Dietary fibres
Fatty acids
Ash
VitaminsÂ  (like the vitamin E)
Dietary minerals

You see, I can't believe you all added vitamin E willy-nilly without knowing how much, right?

I am a biologist with food chemistry background, as well as herpetology. Â I would like a full proximate analysis to understand why just sprinkling some un-quantified amount of vitamin mineral powder is not better.

Will


ZooMed to Me:


Jennifer Shamblin

9:40 AM (19 minutes ago)

toÂ me

Hello Will,
Â Â Â Â Â Â Â Â Â Â Â Â Â Â Â  This is the guaranteed analysis we have for the Tortoise food.
Crude Protein (Min) 9.0%
Crude Fat (Min) 2.0%
Crude Fiber (Max) 26.0%
Moisture (Max) 13.0%
Ash (Max) 10.0%
Calcium (Min) 0.9%
Calcium (Max) 1.3%
Phosphorus (Min) 0.4%
Sodium (Max) 0.3%
Â 
Kind Regards,
Jennifer Shamblin
Customer Service

Zoo Med Laboratories, Inc.
3650 Sacramento Drive
San Luis Obispo, CA 93401
888-496-6633Â - Toll Free
805-542-9988Â - DirectÂ 
805-542-9295Â - Fax
www.zoomed.com
Â 
**********************************************

My TFO narrative again

I do not know what to make of this. If any of you work in a lab that can do all or most of a proximate analysis. I'll put some $$ for it to be done, maybe someone else would care to contribute, and we can post the 'as bought' at a retail location proximate analysis here. Declared for the lot used in the analysis we are on solid ground to post findings in a public venue. 

Of course ZooMed pays for advertising here, don't know what to make of that either.

Let's do some science here, and less debate about it!

Will


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## Spn785 (Jan 31, 2013)

I would be willing to donate some money to that. I was planning on buying some of this, but with their reaction to your query I have second thoughts.


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## Cowboy_Ken (Jan 31, 2013)

Well done Will. I think though, that Jennifer is unfortunately the wrong contact person in that I believe she thought she was giving you the information you requested yet obviously couldn't. Maybe you could contact Geovani at the bean farm and ask him to contact the sales manager who maybe better able to gather this information from the proper department. I figure with the Beanfarm being a retail outlet for them it may carry more weight than a single user.


It again I commend you for picking this up.


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## Kapidolo Farms (Jan 31, 2013)

Well put Ken, I will follow up on your suggestion. At the most recent LA (Pomona) Reptile SuperShow I chatted up one of the ZooMed people there, and they suggested the route I took. 

I guess there are two messages in one. "You never really know who you are talking to" and "Don't pacify with the easy answer" as it's now public.

I'll connect the BeanFarm people to this Thread. I know I over estimate peoples' tolerance to read more than a sentence or two. But that won't change much on either front. Sometimes a thought is bigger than ten words, or at least my ability to reduce it to that few.

Will


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## lynnedit (Jan 31, 2013)

Thank you, Will, for looking into this.


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## Kapidolo Farms (Jan 31, 2013)

The info request to the BeanFarm

*********************************************************************

Hi,

It was suggested I contact you folks on a quest for information about the ZooMed Grassland Diet.

http://www.tortoiseforum.org/post-611010.html#pid611010

Is a transcript of that quest so far.

In short terms - I would like a proximate analysis of the ZooMed Grassland and/or Forest Tortoise diets.

My initial inquiry to ZooMed has returned with a product label only disclosure. This current e-mail is my followup with your company, a commercial buyer, and not a lone customer of ZooMed.

Please read the thread with the URL above.

Thank you much.

Will Espenshade 

********************************************************************************

When I hit the submit button I got "Your enquiry has been successfully sent to the Store Owner."

So, lets see what happens.

Will


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## Kapidolo Farms (Jan 31, 2013)

It turns out, Ken, that the BeanFarm does not sell any ZooMed tortoise foods at all <http://beanfarm.com/index.php?cPath=1283>. 

I spoke with one person there who was remote to their customer service e-mail. That person said they would follow-up with me. Another person (not who I spoke with on the Phone) did respond. Those responses were not informative to the goal - a proximate analysis of the diets.

So Ken got a 'shout out' for the BeanFarm, good for you both. Maybe the Bean Farm will be able to get some sort of response that Jennifer from ZooMed did not provide. Maybe not, but as they don't sell the item, I would have to consider any follow-up from the Bean Farm extreme kindness. 

Alternatively, towards the goal (proximate analysis) I will inquire via the TSA who actually has there logo on the bottle. I'll keep you posted.

Will


The TSA inquiry, lets hope!!

**********************************

William Espenshade <william.espenshadeiiiATgmail.com>
2:44 PM (1 minute ago)

to hlowe 
Hi Heather,

I am inquiring with you the following interest, as your contact info is on the webpage for the TSA.

I see that the TSA endorses the use of the ZooMed Grassland diet by virtue of your logo being on their label. I use and like it.

I have an interest to get a proximate analysis for this diet.

http://www.tortoiseforum.org/thread-64528.html is an online forum thread describing the nature of my interest, and the result so far.

I will post a copy of this e-mail on that thread as well as your/TSA's response.

I have to consider that the association between the diet and the TSA is founded on some nutrition based science. I am aware that the many species specific needs may not be known, but we ought to know what we are feeding.

Does the TSA have a proximate analysis for ZooMed Grassland diet? Can that be shared? Would you please see if such information is available from ZooMed?

My direct effort failed.

Will Espenshade

******************************************

Will


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## tortadise (Jan 31, 2013)

If your inquires keep coming to a failure I can see what my moms lab can do in terms of analyzing this product. Maybe if that lab can do so. We could do a comparative analysis of each commercial diet, while we are on the track of analysis. I will see what they are set up to do in these realms.


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## Cowboy_Ken (Jan 31, 2013)

Kelly,
That would so kickâ€¦


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## tortadise (Jan 31, 2013)

Well I am on it. If they fail, I could see if the Biology department at A&M could help me out. i doubt they have the technology though. Been using them for a lot of articles and research for tortoises recently. Whats another lab test for them. Ha


The answer will have to wait till the am though. I don't want to call and wake my mom at this hour. So stay tuned.


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## Kapidolo Farms (Jan 31, 2013)

Read the forward <http://www.ct.gov/caes/lib/caes/documents/publications/bulletins/b956.pdf>. 

They do not analyse the ZooMed Tortoise food. 

But it is indicated that Connecticut has laws about feed quality and it is based on the Association of the American Feed Control Officials <http://www.aafco.org/>.



Will


http://www.fda.gov/AnimalVeterinary/NewsEvents/FDAVeterinarianNewsletter/ucm130726.htm

Probably to much reading, but this is a good, bit old, summary of the rules of pet food labeling.

My favorite quote from this article "They will not tell you how much liver, for example, is in their product, because that's part of their proprietary formula. But they should tell you how much of any nutrient is in the product." as it relates to dog food.

Will


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## Cowboy_Ken (Jan 31, 2013)

Here I was thinking it would only pertain to animals deemed as livestock. For instance, my insurance company sees a huge difference between my horses as pets or as livestock. Apparently you don't make money from pets, so they have no value. Livestock on the other hand has value because you breed them to pass the young off either for money or whatever.


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## Spn785 (Feb 1, 2013)

tortadise said:


> If your inquires keep coming to a failure I can see what my moms lab can do in terms of analyzing this product. Maybe if that lab can do so. We could do a comparative analysis of each commercial diet, while we are on the track of analysis. I will see what they are set up to do in these realms.



That is an Awesome suggestion!


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## Thalatte (Feb 1, 2013)

Cowboy_Ken said:


> Here I was thinking it would only pertain to animals deemed as livestock. For instance, my insurance company sees a huge difference between my horses as pets or as livestock. Apparently you don't make money from pets, so they have no value. Livestock on the other hand has value because you breed them to pass the young off either for money or whatever.



Does this mean my worms, roaches, and mice are livestock?
Wonder what my insurance company would say about covering 5k roaches?


I would like to know the information on the repcal tortoise diet. It is what one tort I have has eaten his entire life and it smells sickeningly sweet. I have a feeling its high in fruit and low in grasses.


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## Kapidolo Farms (Feb 1, 2013)

I found several analytical labs that for a fee will identify most macro and micro nutrients. It seems to me that if the TSA has there name on the bottle of the ZooMed products they might be prompted to pay for that, but then they would own the result and no guarantee it would be made public. States that have stricter label and content laws may be prompted to do the analysis for their own state compliance and those would be public (tax payer $$). Some Ag extension offices may do it if they deem it to be within their scope of interest. An independent lab that will put their name on the result such as the Ag extension or state labs puts a level of authority on the result, that a 'backdoor' route would lack.

Mazuri, ZooMed, and the others are all mail order, so they are in effect sold in every state. Some bit more leg work, and I'll see what the best result may be in terms of low $$ resource needs, and a credible independent result.

It seems to me wholly irresponsible that the added nutrients to not been quantified. I understand all that not fitting on a label, but the vendor webpage should show they periodically do their own audit of the manufacture who puts a product in a bottle with the vendors name on it. 

It further seems that if a large member organization has an association such that their logo is on the bottle, they too - that member organization, would want some assurance of the quality of the product that is not a preponderance of anecdote, but actual analysis. 

I have some time today to reach out to some labs and get some idea of costs, or potential public service analysis. If the cost is simply providing the sample, I'll cover that, and post the result here, or a link to the lab, if they require control of result via their webpage/publication.

Will


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## theTurtleRoom (Feb 1, 2013)

Will...let me get this for you. I've got a contact there. May take a month, but I can get it. They specifically assigned an employee to find exact amounts for me in their aquatic foods.

...and noone will have to pay anything!

EDIT: sent the email to my contact. Hopefully I hear again soon.


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## Spn785 (Feb 1, 2013)

I agree with you completely Will. Hope to hear about cost of this soon.


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## Thalatte (Feb 1, 2013)

I can provide samples and some money towards the repcal products if that is needed. 
Thank you for doing all this!


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## theTurtleRoom (Feb 1, 2013)

Something I should add to this (and why I've gone through ZooMed instead of trying to find someone to do the study for me): the sample size required to get quality statistics will make the cost for accurate data quite high. To properly estimate the nutrients, there should be 1 25# bag pulled from each of (at least) 30 different production lots (60 would be even better). Then the analysis would have to be performed and then you take the data received and calculate the proper statistics.

Like I said above - I've gotten thorough information through ZooMed on their aquatic turtle foods (specifically Vitamin E, D3, and A, C). I'll have them do the same for the Tortoise Foods and then post the information.

(The Math Grad Student in me just had to make sure this was mentioned)


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## Thalatte (Feb 1, 2013)

Oh wow didn't hink of using such large samples...that changes what I can do. I can provide some money towards it then.


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## theTurtleRoom (Feb 1, 2013)

Thalatte said:


> Oh wow didn't hink of using such large samples...that changes what I can do. I can provide some money towards it then.



Yeah...the reality of these foods, is however hard a company tries, no two lots will be the same...almost like dying yarn. So, you could test a small sample, but the reality is there is no guarantee your next lot will be the same. That's why even the data available on packaging is "min" or "max". Once you get up to 30+ samples, the mean data from the sample then is approximately distributed normal (...add some more statistical terminology here most people won't understand...), etc. At that point, one can then truly estimate what the typical content of the food is.


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## Thalatte (Feb 1, 2013)

I understand that they have to test a bunch if different batches but dent realize they would need so much of each batch. I was thinking a cup or less not a 25lb bag per batch.


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## Kapidolo Farms (Feb 1, 2013)

I received the following data sheet for nutrients as an e-mail. I preserved the integrity of the data in the e-mail by making it a PDF. That PDF is

here. . .
View attachment ZooMed.pdf


On the notion that multiple hundreds of pound of product need be looked at by the lab characterizing several lots for an analysis - that is just not so. Consumer products are analyzed in the form available to the consumer. As a consumer you are not expected to buy multiple lots mix them, to get a product represented on the bottle or by stated analysis. There is a prescribed error standard that is allowable, that is without the product being out of compliance with labeling practices. The result of an analysis is simply published describing the lot examined. As one lot of a food item may be represented by ten pounds or ten mega tones, samples from several lots may or may not be even possible.

So like yarn, which can vary from lot to lot - that yarn still has to be within tolerance if say that yarn producer wants to claim the color is a PMS standard (people who have set standards for color of ink, fabric, and several other media). 

The lab would further guarantee their analysis within some standard tolerance, i.e. 300ppm +/- 3ppm. Labs that are used by state and federal agencies are sent samples within know tolerances to verify they are in compliance and able to state their tolerances accurately. This is done for two reasons, One - not all lab methods are identical, but one lab method should still end up with a statistically similar result as another lab that may use a different method, and two - it is a way for the lab to be certified as to the reliability of what they do.

Any how, it is absolutely OK, for a sample to be large enough for the labs' needs, and no more, multiple tests over time is a truer test of a consistent and uniform product line.

Ask a lab about a certified analysis, and this is what they tell you.

Will


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## Thalatte (Feb 1, 2013)

I can't see the pdf.


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## jaizei (Feb 1, 2013)

Thalatte said:


> I can't see the pdf.


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## Cowboy_Ken (Feb 1, 2013)

Thanks Will. That's good work and a short turn around.


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## Yellow Turtle (Feb 1, 2013)

Thank you Will.

Now can we get such information from Mazuri as well cause seems Mazuri more popular among us here.


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## theTurtleRoom (Feb 2, 2013)

Yellow Turtle said:


> Thank you Will.
> 
> Now can we get such information from Mazuri as well cause seems Mazuri more popular among us here.



Mazuri's info is widely available.


Will - I guess I come from the content from a statistical point of view where sample size and selection is the most important part of the process. It is probably true at this point that the process is refined enough to do as you say. However, I'd be fairly certain the guaranteed analysis they publish on each package came from thorough statistical analysis over a large sample of samples to make sure they had accurate data.

Glad someone else got back to you. Sounds like when they had one of their engineers run the Aquatic Turtle Diets for me last year, they decided to do all of it. (My contact is Animal Care Coordinator).


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## Kapidolo Farms (Feb 2, 2013)

It is not lost on me that the data provided by ZooMed was 'guaranteed' by an employee/owner, and not a lab. I will continue to see if I can find a certified lab that will do the analysis for compliance with state regulations.

Distinct data missing from the report are viable pro-biotic cultures per unit weight or volume. The moisture value was lower than the label, which indicates they are maintaining compliance with min's and max's. The D content was listsed as D and not D3, and I suggest we need not debate the value of that difference.

If a lab will run an analysis for their compliance regulations I will pursue they do the ZooMed Grassland, more because I like the product than have worries. I find some great value in this diet in that when I scrutinize the tortoises fecal, I am seeing whole bits of undigested grass leaf. That is a good clue to me that among pelleted or commercial diets, the grassland has relatively good 'long fiber'.

This long fiber concept is extremely ill-defined. In a recent conversation with someone I consider an expert, long fiber is a feedback based value. The feedback is the fecal, did some visible lengths of items consumed make it through the digestive process and come out recognizable? That's the feedback criteria, and right away you can see it will be different for animals based on the animals' size.

For the longest time I had an image that long fiber was some quantity of how many carbon atoms were in a chain to form one molecule, not how many molecules are in a chain, to such an extent that you see whole "long" bits of grass in the fecal.

So a hoarse/cow long fiber would be different than a sheep, from a 200 pound sulcata to a 50 gram sulcata. 

I recall the Galops at the Fresno Chaffee Zoo had whole bamboo leaves apparent in their fecal, that was their long fiber.

Back to the ZooMed, I see whole bits come through. So then I'm thinking well, what about D3, what about A, E and the rest? I think if the micronutrients are present in that expert's opinion, and I use it as a large portion, but not 100% diet item, I may stick with it for a longer term than 'just try it'. I mostly keep smaller species, so that relative criteria for long fiber will be well provided for with this diet.

I also use my own hand chopped grasses. I notice when I used the dry, it works better if I let those chopped pieces soak for awhile.

To be species specific, the pancakes I have seem to not care for long fiber as defined here longer than about an inch. However when fed arugula (the type where the leaves are about 3 to 5 inches and has convoluted edges) the pancakes will pick the stem end and eat the whole leaf into their mouth, with bites that draw it in, not chop it off. 

Maybe the pancakes' long fiber is more the stem of leafy things, or the stem of say a small vinning weeds. They love to eat the stem of cucumber plants, and again they eat long pieces by drawing it into their mouth, not chopped off by their beak, bite by bite.

I suppose the subject title and all this are not in 'topic' strictly speaking. What to do?

Will


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## Yellow Turtle (Feb 2, 2013)

theTurtleRoom said:


> Mazuri's info is widely available.



Thanks for the attachment. Seeing from the pdf file, Ca ratio is less than 1?


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## Thalatte (Feb 2, 2013)

Thanks for the pic jaizei. 

And thanks will for the investigations.


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## ianedward1 (Feb 2, 2013)

Well I am glad that posting about asking for nutrition contents a while back has really seemed to turn out some results lol. Glad to see that somebody followed up on my concerns and from what it looks like, the ZooMed has decent Ca to P ratios and nothing too extreme in terms of Vitamins (which can often be overused).


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## Kapidolo Farms (Feb 2, 2013)

ianedward1 said:


> Well I am glad that posting about asking for nutrition contents a while back has really seemed to turn out some results lol. Glad to see that somebody followed up on my concerns and from what it looks like, the ZooMed has decent Ca to P ratios and nothing too extreme in terms of Vitamins (which can often be overused).



Thank you for reposting your initial interest here, that thread you started is 

http://www.tortoiseforum.org/thread-63467.html

and Madkins007 had some good links in response to your inquiry. 

It also seems that I was overstating the variability of pet food labeling for actual content. The ingredients are not as rigorously tested before product release as human food, the label does have to accurately depict the content within a tolerance, but the total quality control parameters with pet foods is "loose" compared to human food.

Will


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