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Ismail, Sophie --- "Women, COVID-19 and industrial law" [2021] PrecedentAULA 26; (2021) 164 Precedent 4


WOMEN, COVID-19 AND INDUSTRIAL LAW

By Sophie Ismail

The COVID-19 pandemic has exposed the cracks in our system of workplace regulation, shining a light on the gender inequity hard-wired into our industrial laws. Although the pandemic presents a clear opportunity for positive reform, policy responses to the crisis to date have further entrenched unfairness in our workplace laws – to the detriment of women workers and the national economy more broadly.

EXISTING GENDER INEQUITY IN AUSTRALIA’S INDUSTRIAL LAWS

The Australian labour market is characterised by significant gender-based inequities, with women over-represented in the award-reliant, low-paid and casual workforce.[1] A core part of the problem, as argued by the ACTU before the Fair Work Commission (FW Commission) in 2017, is that ‘modern work is still organised around an old idea’.[2] This ‘old idea’ is that the default worker for the purposes of industrial regulation is a male breadwinner who is unencumbered by parenting and caring responsibilities. Despite feminist academics and unions repeatedly bringing this issue to the attention of law-makers and industrial tribunals and making the case for change, progress in addressing gender inequity in our industrial laws has been painfully slow.[3] As Sharan Burrow pointed out in 2004, while the default worker is long dead, ‘his ghost lurks in the structural foundations of most workplaces’.[4]

The gender pay gap

The consequences of having this kind of gender inequity baked into our industrial laws at a foundational level are wide-ranging and serious; one of the most significant is that work performed by women is not valued as highly as work performed by men. Charlesworth describes the pay equity ‘problem’ as ‘one of the undervaluation of work performed by women – because it is performed by women – that has institutional bases and is part of broader structural discrimination and systemic gender inequality’.[5] Although the principle of equal pay for equal work was embedded in federal law over 50 years ago,[6] a significant gender pay gap persists in Australia. While the gap has closed slightly, progress has been glacial.[7] When full-time ordinary earnings are compared, the national gender pay gap is currently 13.4 per cent.[8] If the reduced number of hours that women work due to caring responsibilities is included in the calculation, the gender pay gap is much higher, at over 30 per cent.[9]

One of the key reasons for the gender pay gap is that the Australian workforce is highly gender segregated,[10] with industries and occupations dominated by women characterised by high levels of award dependency, lower wages and fewer protections.[11] Over the 15-year period between 2006 and 2021, Australia has plummeted from 15th to 50th place in the World Economic Forum’s Global Gender Gap Report.[12] In part, this poor performance relates to our persistently high levels of occupational and industry segregation along gender lines. Many lower paid sectors include workers who have carried our community through the pandemic, including frontline workers in health care and social assistance, and those employed in retail and hospitality.[13]

The modern award safety net

It was originally intended that most workers would eventually be covered by collective agreements, with awards simply underpinning bargaining as a safety net for the few workers who could not access the benefits of bargaining.[14] With this in mind, awards have been stripped back and ‘simplified’ over decades. The result is that large portions of the workforce – 61 per cent of whom are women[15] – have become reliant on instruments which, post-award simplification, were only ever intended to be safety net instruments protecting a minority of workers. There is a gender pay gap within the award system as well as outside it, with research suggesting that ‘the award system sets systematically lower minimums the more heavily an industry employs women’.[16]

Union attempts to raise and restore the relevance of the award safety net through the mechanisms available in the Fair Work Act 2009 (Cth) (FW Act) have been either unsuccessful or only partially successful. This is not due to lack of merit but rather a narrow legislative framework which sets a high and technical bar for variations to awards, with limited discretion for the FW Commission to act proactively to promote gender equity. Award ‘test cases’ have historically played an important role in delivering gender equity improvements to industrial laws,[17] and the current inability to effectively update the safety net is disproportionately impacting women workers.

For example in 2017, the FW Commission declined unions’ claim for ten days of paid family and domestic violence leave in awards, despite finding that:

• family and domestic violence is a significant problem with a real and tangible impact on employees and employers which requires a special response;

• family and domestic violence is a gendered phenomenon that disproportionately affects women;

• existing entitlements do not meet the needs of employees experiencing family and domestic violence; and

• the provision of paid leave would assist employees who are experiencing family and domestic violence, including by reducing the financial impact of the consequences of the violence, and would therefore be a desirable outcome.[18]

The FW Act should be amended to require the FW Commission to promote gender equity in the performance of all of its functions, including variations to modern awards.

The work/life collision

A significant consequence of the ‘male breadwinner’ model of industrial regulation is the inadequate support provided to working parents and carers, most of whom are women. While there is no country in the world where women and men share unpaid domestic and care work equally,[19] Australia is one of the most unequal countries in the Organisation for Economic Co-operation and Development (OECD) in this regard.[20] Pre-COVID-19, our system was already failing on three core issues for working parents and carers.

Firstly, the high cost of early childhood education and care (ECEC) in Australia is a significant barrier to women’s workforce participation. For example, OECD data measuring financial disincentive to enter employment caused by ECEC costs shows that a couple with two children aged two and three years old – where one parent is earning the minimum wage and the other works full-time at 67 per cent of the average wage – would lose 74 per cent of their income to either higher taxes or lower benefit entitlements if they access ECEC.[21] During the height of the pandemic, 60 per cent of Australian households who accessed ECEC during the Government’s ‘fee-free’ period[22] indicated that one parent would have to reduce their paid work when fees returned, and 68 per cent of these households indicated that it would be the mother who would do so.[23]

Secondly, despite compelling evidence of the significant child and maternal health and welfare benefits of a 6–12 month absence from work,[24] Australia’s paid parental leave scheme remains one of the least generous of any comparable country, providing only 18 weeks of paid leave at the federal minimum wage. A 2019 UNICEF report ranks Australia second last (out of 41 comparable EU and OECD countries) on paid parental leave provided to mothers and 27th on parental leave provided to fathers, finding that Australia provides the full-time equivalent of only eight weeks’ paid leave to mothers and the full-time equivalent of only 0.8 weeks’ paid leave to fathers and partners.[25] Further, the superannuation guarantee is not applicable during parental leave.

Thirdly, the FW Act does not provide access to quality, secure, flexible working arrangements for all employees who need them. While employees have a ‘right to request’ flexible working arrangements under s65 of the FW Act, an employer’s refusal is not subject to appeal.[26] This means that the employment safety net regarding requests for flexible working arrangements (and unpaid parental leave) is neither guaranteed nor enforceable. Consequently, many workers’ requests are rejected (either partially or entirely) without any recourse, and a large cohort of people (including many men) do not ask at all, for reasons including that their workplace is hostile to flexible work and they fear reprisals.[27]

Insufficient support in our industrial system for working parents and carers reinforces traditional gender roles and results in women being forced to drop out of the workforce altogether, put promotions or training on hold, and/or accept lower paid or less secure work in order to manage their unpaid care and domestic work commitments.[28] COVID-19 has further exacerbated the care crisis in Australia as the care of school-aged children following school closures and ill and vulnerable family members affected by COVID-19 has largely fallen on women.[29] Due to lower pay and job insecurity, women who managed to hang on to their jobs during the pandemic were soon faced with significant pressure to reduce paid working hours in order to undertake unpaid care and domestic work.

THE IMPACT OF COVID-19 ON WOMEN

These gendered weaknesses in our industrial system have been exposed and aggravated by the pandemic.

Job losses and paid pandemic leave

The first phase of the pandemic saw tens of thousands of Australian workers lose their jobs almost overnight, giving new meaning to the phrase ‘job insecurity’. There was a heavily gendered aspect to this, with women bearing the brunt of early job losses in sectors such as retail, hospitality, the arts and tourism, due to women’s over-representation among the insecure workforce and disproportionate responsibility for caring work: 57 per cent of women workers experienced precariousness in their work pre-COVID; and 50 per cent of women who stopped working during the pandemic did so to undertake unpaid housework and caring roles, compared with 17 per cent of men. Due to the COVID-19 crisis, 21 per cent of the female workforce (or 1.3 million women) has lost work or is experiencing pressures on their capacity to retain paid work.[30]

Frontline workers

During public health emergencies, much of the work done by women, despite its critical nature, is either underpaid or unpaid.[31] For women who retained employment, the pandemic exposed the injustice of occupational and industrial segregation. Low-paid, insecurely-employed women in frontline service and care industries were expected to work longer hours with no or limited compensation during the crisis, often in hazardous conditions without sufficient protective equipment or other support, in order to keep our community safe.[32]

In an attempt to relieve some of the enormous pressure on these and other frontline workers, unions and business joined forces to call on the Government to ‘urgently provide for and fund a national Paid Pandemic Leave Scheme’ as an ‘essential public health measure’, pointing out that for those workers with no sick leave, the cost of isolation (and sometimes repeated periods of isolation) is particularly burdensome.[33] The Government never implemented the scheme. On 8 April 2020, the FW Commission acted on its own motion and varied 99 awards to provide an entitlement to two weeks’ unpaid pandemic leave, with unions quickly moving in response to seek award variations to provide for paid pandemic leave across the health sector.[34] In response to the unions’ application, the FW Commission granted paid pandemic leave only to aged care workers and excluded casual workers with irregular hours – the very cohort likely to experience the greatest financial pressure if required to isolate, and many of whom are low-paid women.

This gap in the employment safety net meant that casual and insecure work was a factor in almost every major COVID-19 outbreak, and most notably in the aged care sector.[35] The characteristics of casual and insecure work – including work across multiple facilities with changing work routines and equipment, low pay, no sick leave, and inadequate (or non-existent) training in infection control or personal protective equipment – endangered the lives of employees, customers and clients, as well as the wider community.

Temporary awards variations

In March 2020, unions entered into discussions with employer groups who were seeking variations to a number of awards to deal with the COVID-19 crisis. In the usual course, a party seeking to vary a modern award must advance a merit argument supported by an analysis of the relevant legislative provisions and probative evidence.[36] This usually lengthy process in the FW Commission was truncated during the crisis, and temporary variations were quickly made to six awards[37] with the consent of unions on the basis that they were necessary to preserve jobs and the ongoing viability of businesses during COVID-19. Temporary variations allowed employers to reduce hours of work, change duties and the location of work, and require employees to take annual leave. These measures were subject to protections for workers as a condition of union consent, including access to arbitration for disputes. Subsequent requests to extend the life of the variations were considered by unions on a case-by-case basis, including whether there was probative evidence in support of continuing variations.[38]

Working from home

The only COVID-19-related award variation that is still in force is Schedule I to the ‘Clerks – Private Sector Award 2020’ (Clerks Award) which is due to expire on 30 June 2021.[39] The Clerks – Private Sector Award 2020 – Work from home case – AM2020/98[40] case was the first to deal with industrial issues arising from the increased incidence of working from home (WFH) caused by the pandemic. Most notably, Schedule I of the Clerks Award contains a clause allowing employees who are WFH to agree to work an extended span of hours with no overtime or penalties payable during the extended hours.[41] Unions opposed subsequent applications seeking an extension to this temporary variation, including on the grounds that women workers would be disproportionately and negatively impacted by extended uncompensated working hours if this became the new normal.[42]

The surge in WFH is an impact of COVID-19 with a deeply gendered dimension. A FW Commission survey found that 63 per cent of employees covered by the Clerks Award have been WFH since 1 July 2020, 72.9 per cent of whom are women. Of these workers, 40.7 per cent reported that they changed their hours while WFH to accommodate family and caring commitments.[43] Economy-wide, ABS data showed that women (56 per cent) were more likely to have been WFH than men (38 per cent) during COVID-19.[44] This is partly because higher numbers of women were employed in sectors that were able to support remote working, and partly due to the care burden. An ACTU survey showed that women who are WFH are working both earlier and later than men, which is also likely to be connected to women’s unpaid care and domestic responsibilities. Importantly, 81 per cent of the ACTU survey participants said that they would like to continue to have the option of WFH, as long as sufficient support is provided.[45]

The FW Commission’s Clerks Award survey confirmed that most employers (59 per cent) do not have any WFH policy.[46] The International Labour Organisation’s Home Work Convention[47] establishes the core principle of equality of treatment in remuneration and other working conditions for home workers. The ACTU’s Work From Home Charter, published in December 2020, addresses five key areas for reform:

1. Workers’ rights at home.

2. Work health and safety.

3. Work-life balance.

4. Connection and support.

5. Job quality across all workplaces.[48]

It will be crucial to ensure that fair and reasonable employment standards are negotiated for WFH, bearing in mind the gendered consequences of getting this wrong.

Violence at work and at home

The pandemic has exacerbated the risks of violence against women, consistent with a global trend.[49] Public health directives to stay at home increased the risk of family and domestic violence for many Australians. A substantial number of respondents to the ACTU’s WFH survey (about 200 people, or 2 per cent) said that they had been exposed to family and domestic violence while working from home.[50] Despite this, most workplaces have neither assessed for risks of family and domestic violence in their employees’ homes nor put measures in place to control these risks, evidencing a lack of clarity in our legal framework regarding employer obligations in these situations. Frontline workers in care and service industries already faced high levels of occupational violence and harassment pre-pandemic and these risks only increased as pandemic-related pressures took their toll on the mental health of the public.[51]

There is now an even more urgent need for regulatory reform to address these risks to women’s health and safety at work, including the inclusion of paid family and domestic violence leave in the national employment standards to enable women to escape violent situations without losing income, and improving Australia’s work health and safety framework to better deal with psychosocial hazards such as violence and harassment.[52]

INDUSTRIAL RELATIONS WORKING GROUPS AND THE OMNIBUS BILL

In May 2020, the Prime Minister announced the establishment of five tripartite working groups to discuss industrial relations (IR) reform in the context of the pandemic. The IR working groups met regularly from June until September 2020 to discuss casual and fixed-term employment, award simplification, enterprise agreements, compliance and enforcement, and greenfields agreements. Discussions were held in confidence but the gender equity implications of various proposals were regularly discussed, particularly in the working groups pertaining to casual workers, awards and bargaining.

In December 2020, the Government introduced the Fair Work Amendment (Supporting Australia’s Jobs and Economic Recovery) Bill 2020 (Omnibus Bill) into the House of Representatives. The Omnibus Bill originally had seven schedules, five of which covered the topics discussed in the IR working groups. The ACTU and others argued that the proposed changes would have a ‘negative effect on those workers whom we have relied on to deliver us through the COVID-19 pandemic, with women and young people particularly adversely affected.’[53] Ultimately, the Bill failed to win the support of the cross bench and four out of the five schedules were withdrawn by the Government. The remaining schedule sets out a definition of a casual worker, which allows an employer to designate a worker as casual through the offer of employment and, in a significant departure from established case law,[54] removes the capacity for a court to look beyond this designation and examine the true nature of the employment relationship. This change risks exacerbating the insecure work crisis for women.

CONCLUSION

Women were already over-represented among workers in insecure, award-reliant and low-paid jobs and were shouldering the majority of unpaid domestic and care labour before the pandemic struck. The pandemic has exacerbated these inequalities and exposed the ‘old ideas’ underpinning our industrial laws. Now is the time to genuinely review and reform our workplace laws and build an industrial system which meets the needs of all workers, rather than clinging on to outdated notions that further entrench gender inequity in our industrial laws.

Sophie Ismail is a Legal and Industrial Officer (Gender Equity) at the ACTU.


[1] R Wilkins and F Zilio, Prevalence and Persistence of Low Paid Award-reliant Employment (Report, 2020) 11, table 3; Annual Wage Review 2019–20 [2020] FWCFB 3500, [115], [127] and [400].

[2] Australian Council of Trade Unions (ACTU), ‘Submission in Family Friendly Work Arrangements Case – AM2015/2’ (Closing submissions, 19 December 2017).

[3] A Chapman, ‘Industrial law, working hours and work, care and family’, Monash University Law Review, Vol. 36, 2010, 190; S Charlesworth, ‘Law’s response to the reconciliation of work and care: The Australian case’ in N Busby and G James (eds), Families, Care-giving and Paid Work, Edward Elgar Publishing, 2011; J Murray, ‘Labour law: Reconciling work and care responsibilities’, Alternative Law Journal, Vol. 30, No. 2, 2005, 86.

[4] S Burrow, ‘An unequal world’, UNSW Law Journal, Vol. 27, No. 3, 2004, 887.

[5] F Macdonald and S Charlesworth, ‘Equal pay under the Fair Work Act 2009 (Cth): Mainstreamed or marginalised?’, UNSW Law Journal, Vol. 36, No. 2, 2013, 565.

[6] Australasian Meat Industry Employees Union v Meat and Allied Trades Federation of Australia [1969] CthArbRp 278; (1969) 127 CAR 1142; National Wage and Equal Pay Case [1972] CthArbRp 1420; (1972) 147 CAR 172.

[7] ACTU, ‘Submission to the Annual Wage Review 2019–20’ (Initial submission, 20 March 2020) 221.

[8] Workplace Gender Equality Agency (WGEA), The national gender pay gap drops to 13.4 per cent (25 February 2021) <https://www.wgea.gov.au/newsroom/the-national-gender-pay-gap-drops-to-13.4%25>.

[9] Australian Bureau of Statistics (ABS), Average Weekly Earnings, Australia (November 2020) table 2.

[10] WGEA, Gender Segregation in Australia’s Workforce (17 April 2019) <https://www.wgea.gov.au/publications/gender-segregation-in-australias-workforce>.

[11] Wilkins and Zilio, above note 1, 11, table 3; B Broadway and R Wilkins, ‘Probing the effects of the Australian system of minimum wages on the gender wage gap’, Melbourne Institute Working Paper Series, No. 31/17, 2017.

[12] World Economic Forum, Global Gender Gap Report (Report, 2021).

[13] FW Commission, Statistical report – Annual Wage Review 2019–20 (Report, 18 June 2020) 38, table 7.1.

[14] House of Representatives Official Hansard, Industrial Relations Reform Bill 1993, Second Reading Speech, 3.

[15] ABS, Employee earnings and hours (May 2018).

[16] Broadway and Wilkins, above note 11, 20.

[17] Maternity Leave Case (1979) 218 CAR 120; Parental Leave Case (1990) 36 IR 1; Parental Leave – Casual Employees – Test Case (Re Vehicle Industry – Repair, Services and Retail Award 1981) (2001) 107 IR 71; Personal/Carer’s Leave Test Case (1995) 57 IR 121; Parental Leave Test Case 2005 (2005) 143 IR 245.

[18] 4 yearly review of modern awards – Family and Domestic Violence Leave Clause [2017] FWCFB 3494, [42]–[46], [49], [51], [55]–[56] and [116].

[19] J Charmes, The Unpaid Care Work and the Labour Market. An analysis of time use data based on the latest World Compilation of Time-use Surveys (Research paper, 2019) 3.

[20] R Cooper, M Foley and M Baird, Women at Work: Australia and the United States (Report, October 2016) 15.

[21] OECD, Net childcare costs (28 February 2021) <https://data.oecd.org/benwage/net-childcare-costs.htm>.

[22] Prime Minister of Australia, ‘Early childhood education and care relief package’ (Media Release, 2 April 2020).

[23] The ParentHood, ‘60 per cent of Australian families will have a parent forced to reduce work when childcare fees return & 68 per cent will be women, survey of 2,200 Australian families reveals’ (Media Release, 1 June 2020).

[24] Productivity Commission, Paid Parental Leave: Support for Parents with Newborn Children (Inquiry Report No. 47, 28 February 2009) 4.1, 4.2 and 4.14.

[25] Y Chzhen, A Gromada and G Rees, Are the world’s richest countries family friendly? Policy in the OECD and EU (Paper, June 2019) 6 and 9.

[26] See Fair Work Act 2009 (Cth), ss44(2), 65, 76(4), 146, 186(6), 739(2) and 740(2).

[27] N Skinner, A Cathcart and B Pocock, ‘To ask or not to ask? Investigating workers’ flexibility requests and the phenomenon of discontented non-requesters’, Labour and Industry, Vol. 26, No. 2, 2016, 103–19.

[28] S Austen, The Effects of Parenthood and other Care Roles on Men’s and Women’s Labour Force Participation and Experiences of Paid Work (Report, May 2017) [5]; G Argyrous, L Craig and S Rahman, The effect of a first-born child on work and childcare time allocation: Pre-post analysis of Australian couples’, Social Indicators Research, Vol. 131, No. 2, 2017, 831–51; S Charlesworth, L Strazdins, L O’Brien and S Sims, ‘Parents’ jobs in Australia: Work hours polarisation and the consequences for job quality and gender equality’, Australian Journal of Labour Economics, Vol. 14, No. 1, 2011, 35–57.

[29] L Craig and B Churchill, ‘Dual-earner parent couples’ work and care during COVID-19, Gender, Work and Organisation, Vol. 28, No. S1, 2021.

[30] ACTU, Leaving Women Behind: The Real Cost of the COVID Recovery (Report, November 2020) (ACTU Women and COVID Report) 2, 9 and 20.

[31] C Wenham, J Smith and R Morgan, ‘COVID-19: The gendered impacts of the outbreak’, The Lancet, Vol. 395, 2020.

[32] Australian Nursing & Midwifery Federation, Federal Government needs to be clear on strategies to prevent spread of COVID-19 (16 March 2020) <http://anmf.org.au/news/entry/federal-government-needs-to-be-clear-on-strategies-to-prevent-spread-of-cov> WGEA, Gendered Impacts of COVID-19 (Report, May 2020).

[33] ACTU, ‘ACTU – BCA Joint Letter: Pandemic Leave’ (Media Release, 3 August 2020) <https://www.actu.org.au/actu-media/media-releases/2020/actu-bca-joint-letter-pandemic-leave>.

[34] Health Sector Awards – Pandemic Leave [2020] FWCFB 7059.

[35] ABC, ‘Workplace coronavirus transmission driving Victorian case numbers, including in aged care’, 20 July 2020, <https://www.abc.net.au/news/2020-07-19/workplace-coronavirus-transmission-in-victoria-in-aged-care/12470704>.

[36] 4 yearly review of modern awards – Penalty Rates [2017] FWCFB 1001, [52] and [111(b)].

[37] Fast Food Award 2020; Vehicle Repair, Services and Retail Award 2020, Educational Services (Schools) General Staff Award 2020; Clerks – Private Sector Award 2020; Hospitality Industry (General) Award 2020; and Restaurant Industry Award 2020.

[38] I Ross, R Clancy and M Bisset, Application to vary the Clerks-Private Sector Award 2020 – AM2020/30 (Transcript of proceedings, 30 June 2020) [44] and [63].

[39] Clerks – Private Sector Award 2020 – Work from home case – AM2020/98 [2020] FWCFB 6985.

[40] Ibid.

[41] Clerks Private Sector Award 2020, sch 1, cl I.2.1(c).

[42] I Ross, R Clancy and M Bisset, Applications to vary the Clerks-Private Sector Award 2020 – AM2020/30 (Transcript of proceedings, 30 September 2020) [112]–[114].

[43] FW Commission, Survey analysis for the Clerks – Private Sector Award 2020 – Work from home case, February 2021.

[44] ABS, Household impacts of COVID-19 survey (29 April–4 May 2020) as quoted in the ACTU Women and COVID Report, above note 30, 9.

[45] ACTU, Working from Home Survey Report (Report, November 2020) (ACTU WFH Survey Report).

[46] Ross, Clancy and Bisset, above note 42.

[47] 1996 (No. 177).

[48] ACTU, Working from Home Charter (Charter, December 2020).

[49] UN Women, ‘Inter-agency statement on violence against women and girls in the context of COVID-19 (Statement, 24 June 2020).

[50] ACTU WFH Survey Report, above note 45, 12–3.

[51] Shopping Centre News, ‘SDA, NRA & SCCA urge the community to “respect our retail workers”’, April 2019, <https://www.shoppingcentrenews.com.au/shopping-centre-news/industry-news/sda-nra-scca-urge-the-community-to-respect-our-retail-workers/>.

[52] M Boland, Review of the Model Work Health and Safety Laws (Final report, December 2018) rec 2.

[53] ACTU, ‘Fair Work Amendment (Supporting Australia's Jobs and Economic Recovery) Bill 2020’ (Submission, 5 February 2021) 8; see also, A Stewart, S McCrystal and JR Munton, T Hardy and A Orifici, ‘Submission to the Senate Education and Employment Legislation Committee Inquiry into the Fair Work Amendment (Supporting Australia’s Jobs and Economic Recovery) Bill 2020’ (Submission, 5 February 2021) 56.

[54] Hamzy v Tricon International Restaurants trading as KFC [2001] FCA 1589; MacMahon Mining Services Pty Ltd v Williams [2010] FCA 1321; WorkPac Pty Ltd v Skene [2018] FCAFC 131; WorkPac Pty Ltd v Rossato [2020] FCAFC 84.


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