Supplementary Information Tables: 2016–17 Departmental Results Report

Departmental Sustainable Development Strategy

  1. Overview of the federal government's approach to sustainable development
  2. Our Departmental Sustainable Development Strategy
  3. Departmental performance highlights
  4. Strategic Environmental Assessment (SEA)

1. Overview of the federal government's approach to sustainable development

The 2013-16 Federal Sustainable Development Strategy (FSDS) presents the Government of Canada's sustainable development activities, as required by the Federal Sustainable Development Act. In keeping with the objectives of the Act to make environmental decision making more transparent and accountable to Parliament, Health Canada supports the implementation of the FSDS through the activities described in this supplementary information table.

2. Our Departmental Sustainable Development Strategy

This Departmental Sustainable Development Strategy (DSDS) describes Health Canada's actions in support of Theme I - Addressing Climate Change and Air Quality, Theme II - Maintaining Water Quality and Availability, Theme III - Protecting Nature and Canadians, and Theme IV - Shrinking the Environmental Footprint - Beginning with Government. The DSDS report for 2016-17 presents a high-level overview of results and is the final report under the 2013-16 FSDS. Previous reports are available on Health Canada's Web site.

3. Departmental performance highlights

Theme I: Addressing Climate Change and Air Quality

Health Canada contributed to the 2013-16 FSDS through eight implementation strategies for Goal 1: Climate Change and Goal 2: Air Pollution

Department-led targets

The following table shows the FSDS target led by Health Canada, the associated FSDS goals, performance indicators and performance results.

Table - The following table shows the FSDS target led by Health Canada, the associated FSDS goals, performance indicators and performance results.
FSDS goal FSDS target FSDS performance indicator FSDS performance results
Goal 2: Air Pollution

Minimize the threats to air quality so that the air Canadians breathe is clean and supports healthy ecosystems

Target 2.2: Indoor Air Quality.

Help protect the health of Canadians by providing health-based guidance and tools to support actions to better manage indoor air quality.

Actions to manage indoor air quality that incorporate health-based guidance. Published an indoor guideline for acetaldehyde, a volatile chemical found in household products that is released during combustion, for public comment.

Supported the development of two new Canadian Standards Association standards to address indoor air pollutants.

Conducted research showing that indoor air quality in homes can be improved by using an exhaust fan in attached garages.

Communicated with Canadians on the topic of indoor air quality and other environmental health issues via Twitter, Facebook, answering approximately 1,200 phone and email requests.

Informed Canadians about indoor air and other environmental health issues by delivering training, presentations and conducting outreach at conferences.

Performance Summary for Climate Change and Air Quality (Theme I)

Implementation Strategy 1.2.6: Work with Canadian communities to implement heat alert and response systems and provide information/education about the health impacts of extreme heat to public health professionals and the public.

The Department:

  • Continued to support the development of community-based Heat Alert Response Systems in at-risk communities by working closely with provinces in areas such as research, implementation of heat health warning triggers, and harmonizing heat warnings. In Ontario, 24 health units harmonized their heat alerting and messaging over the summer of 2016.
  • Collaborated with the Commission for Environmental Cooperation to pilot real-time monitoring and surveillance systems of heat related health outcomes in North America, for which Ottawa Public Health was selected as a pilot community. These systems are key to early detection of heat-related illnesses and deaths in the community and help to build local capacity to reduce heat health risks.
  • Hosted a series of "Cool Communities" webinars where over 350 stakeholders learned about innovative community-level initiatives to reduce urban heat islands which can significantly magnify health impacts during heat events. Health Canada used these webinars and other tools to disseminate what has been learned from several local-level pilot projects that the Department supported across the country.
  • Continued work to help increase understanding about extreme heat events among health care professionals. For example, contributing to the "Health Care Facility Climate Change Resiliency Workshop" hosted by the Pan-American Health Organization; and making technical guidance and fact sheets on extreme heat available.

Implementation Strategy 1.2.7: Address the health effects of climate change by funding community-based research and assessment projects that enable northern First Nations and Inuit communities to develop climate change adaptation strategies and action plans.

The Department:

  • Expanded the Climate Change and Health Adaptation Program to include programming south of the 60th parallel. This provided funding opportunities for research and adaptation strategies that are specific to the needs of southern First Nations' communities.
  • Engaged with Indigenous communities, Tribal Councils and national organizations, through a series of workshops/webinars to identify and prioritize key health risks associated with climate change such as food security, mental health, and impacts from extreme weather events like flooding, forest fires and storms. These sessions were held in 16 locations across the country, engaging participants from both the northern and southern components of the Climate Change and Health Adaptation Program.

Implementation Strategy 2.1.11: Communicate outdoor air pollution health risks to Canadians through the Air Quality Health Index (AQHI), which provides current and forecast air-quality information and advice on health risks in order to assist Canadians in making decisions on how to reduce their level of exposure. Continue development of the AQHI and continue implementation in all provinces and major communities in the North to achieve access for 80% of the Canadian population.

The Department:

  • Provided access to the AQHI 80% of Canadians, which is now available in all provinces and the Yukon and Northwest Territories.
  • Extensively promoted the Air Quality Health Index with provinces, territories and key partners. This included working with the Government of Alberta to develop a smart phone application; a direct outreach campaign that engaged 8,000 Canadians; outreach to health professionals; focus groups to improve health messaging related to the Index; an educational environmental health video game for school children developed by Nova Scotia; and ongoing work with the British Columbia Centre for Disease Control and the Manitoba Office of Disaster Management on communicating air quality health risks during forest fires.

Implementation Strategy 2.1.13: Undertake and deliver scientific research, monitoring, modeling, testing, data analysis and science advice to inform regulations, policies, programs, science assessments, and services as well as to evaluate effectiveness of actions.

The Department:

  • Completed the Human Health Risk Assessment for Gasoline Exhaust, which will provide the health basis for actions to address air pollution under the Air Quality Management System.
  • Conducted research in a range of areas such as, the health impacts of short and long-term exposure to air pollutants from a variety of sources (industrial, transportation, residential wood smoke); exposure to air pollution during pregnancy and the associated potential adverse birth outcomes; the use of models to predict air pollution levels; studies of exposure to air pollutants during transportation; community exposure to industrial air emissions and short-term risk of respiratory hospitalization for young children in Québec and British Columbia; and an investigation to identify the cause of an observed change in mortality risk attributed to ozone in 24 Canadian cities.
  • One of the most important of these studies, the Canadian Census Health and Environment Cohort study, provided the largest study of the health effects of air pollution in the world and has been adopted into the Global Burden of Disease project which is considered to be the largest and most comprehensive effort to measure epidemiological levels and trends worldwide.
  • The Global Burden of Disease project was used to quantify the health benefits from five regulatory initiatives including new regulations to reduce air pollutant emissions from industrial sources and from small engines, as well as regulations that are meant to reduce greenhouse gases, but which will also have benefits for air quality.

Implementation Strategy 2.1.19: Continue to work collaboratively with provinces, territories and stakeholders to implement the AQMS, which includes new ambient air quality standards, a framework for managing air quality through local air zones and regional airsheds, and emissions requirements for major industrial sectors and equipment types.

Implementation Strategy 2.1.20: Work with other jurisdictions, including the United States under the Canada-United States Air Quality Agreement to undertake regional and international efforts to manage transboundary air pollution of concern for Canadians and their environment. This includes work towards the completion of the necessary scientific, technical and regulatory foundations required for the consideration of a Particulate Matter Annex under the Air Quality Agreement.

The Department:

  • Shared results of research on health impacts of air with the Canada-US Air Quality Committee to influence actions taken in other countries, both to protect the health of their own citizens and to reduce transboundary pollution.

Implementation Strategy 2.2.1: Conduct research, assessments and communication activities in order to provide health-based guidance on reducing exposure to indoor air pollutants.

The Department:

  • Published the proposed Residential Indoor Air Quality Guideline for acetaldehyde for public comment.
  • Participated in a revision of the Canadian Standards Association standard for Residential Carbon Monoxide Alarming Devices, which now allows low levels of carbon monoxide to be displayed, below that which trigger the alarm, but which may pose a health risk to people with existing health conditions.
  • Provided funding for the development of the Canadian Standards Association standard which limits formaldehyde emissions from composite wood products used in residential building materials.
  • Conducted studies to improve our understanding of how indoor air quality may be improved in homes and schools by increasing ventilation and using exhaust fans in garages and kitchens.
  • Approximately 48% of the homes inspected in First Nations communities were found to have some level of mould. Homes are inspected by request so as a demand driven program, comparisons from year to year are not possible.
  • Developed and launched, in collaboration with Environment and Climate Change Canada, an environmental health exhibit that included the health impacts of air quality at Montreal's "Biosphère" Museum

Implementation Strategy 2.2.2: Maintain a database of indoor radon levels in Canadian homes and buildings. Assess new methods and technologies for measuring and reducing radon gas levels in homes and buildings. Maintain a radon awareness program to give information to Canadians on ways to reduce their exposure to radon.

The Department:

  • Launched the fourth annual National Radon Action Month and distributed over 1.4 million radon outreach materials to the Canadian public and targeted audiences, such as, health professionals and the building/renovations and real estate industry.
  • Found that 59% of Canadians surveyed are knowledgeable of radon, which is a radioactive gas that occurs naturally when the uranium in soil and rock breaks down. In enclosed spaces, like homes, it can accumulate to high levels, and become a health risk (e.g., lung cancer).
  • Surveyed households as part of the Statistics Canada 2015 Households and the Environment Survey and found that 6% had tested their homes for radon. To motivate behaviour change related to radon, Health Canada will focus efforts on encouraging the development of regional and community based programs that promote radon testing.
  • Tested approximately 1,300 federal buildings for radon. Since the start of the radon federal building testing program in 2007, approximately 20,500 federal buildings have been tested.
  • Worked with the Canadian General Standards Board, to develop two national standards for radon mitigation: one for new construction and one for existing construction, which are expected to be published in 2017-18.
  • Worked in collaboration with external partners/associations to raise awareness of radon impacts on human health and measures to reduce the risk among Canadians (i.e., a formal agreement for sharing data with the City of Guelph and the local Health Unit to support radon potential mapping in Ontario, Memorandum of Agreement with the Yukon Department of Health and Social Services to develop a territorial radon program).

Theme II Maintaining Water Quality and Availability

Under Theme II, Health Canada contributed to the 2013-16 FSDS through three Implementation Strategies for Goal 3: Water Quality and Water Quantity.

The following table shows the FSDS target led by Health Canada, the associated FSDS goal, performance indicator and performance results.

Table - The following table shows the FSDS target led by Health Canada, the associated FSDS goal, performance indicator and performance results.
FSDS goal FSDS target FSDS performance indicator FSDS performance results
Goal 3: Water Quality and Water Quantity. Target 3.2: Drinking Water Quality.

Help protect the health of Canadians by developing up to 15 water quality guidelines/ guidance documents by 2016.

Water quality guidelines/guidance documents. Finalized three drinking water quality guidelines/guidance documents approved by provinces and territories. A total of twelve final drinking water quality guidelines/ guidance documents have been approved since 2014-15.

Performance Summary for Maintaining Water Quality and Availability (Theme II)

Implementation Strategy 3.1.4: Support all First Nations communities in ensuring ongoing access to a trained Community-Based Water Monitor or Environmental Health Officer. (Health Canada)

The Department:

  • Provided funding to Chiefs and Councils through the Community-based Water Quality Monitoring program for drinking water monitoring and the training of Community-based Water Monitors, who together with Environmental Health Officers, share responsibility for monitoring water quality and providing the results.
  • Ensured that 100% of First Nations communities had access to a Community-based Water Monitor or an Environmental Health Officer, enabling communities to test their drinking water where it otherwise would not be possible on a regular basis.

Implementation Strategy 3.1.5: Support all First Nations communities in ongoing monitoring of drinking water quality as per the Guidelines for Canadian Drinking Water Quality.

The Department:

  • Monitored Public Distribution Systems for bacteriaat 80% of the recommended frequency. This percentage represents the average sampling frequency of Public Distribution Systems, rather than limiting the measurement to those systems with a 100% compliance rate.

*This data excludes communities in Saskatchewan and British Columbia where the environmental public health services have been transferred to a First Nations community and/or organization.

Implementation Strategy 3.2.1: Develop on average five drinking water quality guidelines/guidance documents per year in collaboration with provinces/territories, which are used as a basis for their regulatory requirements.

The Department:

  • Finalized three drinking water quality guidelines/guidance documents approved by provinces and territories.
  • Continued to expand the Canadian Network of Public Health Intelligence's drinking water application to more locations. The drinking water application tracks boil water advisories and the reasons for which they were issued. This will allow the Department to identify trends over time, including reasons for advisories.

Theme III Protecting Nature and Canadians

Under Theme III, Health Canada contributed to the 2013-16 FSDS through seven Implementation Strategies for Goal 4: Conserving and Restoring Ecosystems, Wildlife and Habitat, and Protecting Canadians.

The following table shows the FSDS target led by Health Canada, the associated FSDS goal, performance indicator and performance results.

Table - The following table shows the FSDS target led by Health Canada, the associated FSDS goal, performance indicator and performance results.
FSDS goal FSDS target FSDS performance indicator FSDS performance results
Goal 4: Conserving and Restoring Ecosystems, Wildlife and Habitat, and Protecting Canadians.

Resilient ecosystems with healthy wildlife populations so Canadians can enjoy benefits from natural spaces, resources and ecological services for generations to come.

Target 4.8: Chemicals Management.

Reduce risks to Canadians and impacts on the environment and human health posed by releases of harmful substances.

(Note: Health Canada shares responsibility for this target with Environment and Climate Change Canada.)

Reduce levels of human exposure to harmful substances.

(Due to the long term nature of the Chemicals Management Plan (CMP) and the range of substances being addressed, it is not possible to indicate quantitative progress toward Target 4.8 within the time frame of FSDS 2013-2016. Approaches for reporting progress will continue to evolve over the duration of the CMP as trends are identified.)

Continued to develop a methodology for collecting and analysing data in order to report by 2020 on the ultimate outcome of the Chemicals Management Plan, which is to reduce threats to Canadians and impacts on the environment from the harmful effects of chemicals. Harmful effects could include cancer, effects on the liver and other organs, effects on fertility, reproduction and development, etc.

Canadian Environmental Sustainability Indicators

Performance Summary for Protecting Nature and Canadians (Theme III)

Implementation Strategy 4.7.4: In accordance with mandated responsibilities, provide environmental and/or other information to reduce the risk of, and advice in response to, the occurrence of events such as polluting incidents, wildlife disease events or severe weather and other significant hydro-meteorological events as applicable.

The Department:

  • Completed 100% of planned emergency preparedness exercises and reviewed them to identify any problems, inadequacies, or gaps in preparedness and response plans.
  • Made available environmental radioactivity surveillance data on the Health Canada Web site and the Open Data Canada Web site, which allows Canadians to view monthly summaries of various environmental radioactivity level data from across Canada, improving access to and understanding of radioactivity exposure from natural and man-made sources.
  • Maintained and operated Canada's national environmental radioactivity surveillance and monitoring capabilities in support of Health Canada's obligations under the verification regime of the Comprehensive Nuclear-Test-Ban Treaty.

Implementation Strategy 4.8.2: Guidance and program policies developed by the Federal Contaminated Sites Action Plan program secretariat and the expert support departments are provided to federal custodians for program implementation activities.

The Department:

  • Provided human health advice and guidance to other federal departments as part of the Federal Contaminated Sites Action Plan. In addition, training sessions were offered to custodial departments in multiple regions across the country on how to conduct human health risk assessment and strategies for interpreting and communicating the results of risk assessments.

Implementation Strategy 4.8.5: Assess 100% of 1,500 targeted existing commercial substances as identified under the Chemicals Management Plan for risks to human health and/or the environment by 2016.

The Department:

  • Published, as part of Phase II of the Chemicals Management Plan (CMP) (2011-12/2015-16), draft screening assessment reports for 38 existing priority substances and final screening assessment reports for 1,141 existing priority substances, in collaboration with Environment and Climate Change Canada. Since work on this target began in 2011, the program has published draft screening assessment reports (DSARs) for 1,421 substances (95% of the 1,500 existing substances planned for assessment) and final screening assessment reports (FSARs) for 1,564 substances (105% of the 1,500 existing substances planned for assessment).
  • Published, as part of Phase III of the CMP (2016-17/2020-21), DSARS for 314 existing priority substances in collaboration with Environment and Climate Change Canada Footnote 1.
  • Published four Science Approach documents, covering 749 low concern substances from Phase III of the CMP. The documents provide a description of the scientific approach to evaluate environmental or human health risk of substances Footnote 2. Conclusions for these substances will be published in screening assessment reports at a later date.

Implementation Strategy 4.8.7: The Northern Contaminants Program will continue monitoring contaminant levels in wildlife and people in the Canadian North.

The Department:

  • Provided funding for six one-year human biomonitoring and health projects as part of the Northern Contaminants Program. These projects addressed interactions between contaminants and affected health outcomes, links between contaminant exposure and health, implementation of health communication tools, modelling of human exposure to contaminants, and collection of biomonitoring data among key population groups including mothers in Nunavik, Quebec and adults from indigenous communities in the North West Territories.

Implementation Strategy 4.8.8: Address 100% of new substances, for which Environment and Climate Change Canada has been notified by industry of their intended manufacture or import, to determine if they may pose risks to human health and/or the environment within the timelines in the regulation or established services standards.

  • Assessed within targeted timelines, 100% of new substance notifications (473 of 473) received from industry.

Implementation Strategy 4.8.9: Ensure at least one risk management measure is in place for 100% of substances deemed to be harmful to human health and/or the environment.

  • Developed and put in force within mandated timelines, 18 risk management actions (e.g., regulations, guidelines, codes of practice) covering 37 existing substances that have been assessed to be potentially harmful to human health and/or the environment.
  • Developed and put in force within mandated timeframes, risk management instruments (e.g., prohibitions, Ministerial conditions, Ministerial requests for additional information, or Significant New Activity Notices) for 100% (10 of 10) of new substances that were assessed to be harmful to human health.

Implementation Strategy 4.8.11: Prevent unacceptable risk to people and the environment through the regulation of pesticides by initiating 100% of the re-assessments of registered pesticide products identified in the Re-evaluation Initiation Schedule.

The Department:

Theme IV: Shrinking the Environmental Footprint, beginning with the Government

Under Theme IV Health Canada contributed to the 2013-16 FSDS through work related to Goal 6: Greenhouse Gas Emissions and Energy, Goal 7: Waste and Asset Management and Goal 8: Water Management.

Performance Summary for Shrinking the Environmental Footprint, beginning with the Government (Theme IV)
FSDS goal FSDS target FSDS performance indicator FSDS performance results
Goal 6: Greenhouse Gas Emissions and Energy

Reduce the carbon footprint and energy consumption of federal operations

Target 6.1: GHG Emissions Reduction

The Government of Canada will reduce greenhouse gas emissions from its buildings and fleets by 17% below 2005 levels by 2020.

Departmental Green House Gas emission reductions from buildings and fleets relative to fiscal year 2005-06 expressed as a percentage. On-road fleet-related Green House Gas emissions have been reduced by 31.9% from the baseline year of 2005-06, surpassing the departmental commitment of a 20% reduction by 2020-21.
Goal 7: Waste and Asset Management

Reduce waste generated and minimize the environmental impacts of assets throughout their life-cycle.

7.1: Real Property Environmental Performance

As of April 1, 2014, and pursuant to departmental Real Property Sustainability Frameworks, an industry-recognized level of high environmental performance will be achieved in Government of Canada real property projects and operations.

A Real Property Sustainability Framework in place to improve the management of energy, waste and water in departmental real property assets by March 31, 2015. A Real Property Sustainability Framework is in place to improve the management of energy, waste and water; outlines greening practices that are applied to all temperature-controlled office and laboratory spaces.

Industry-recognized tools were used to verify and assess the level of performance in the sustainable management of buildings.
The collection, recycling and disposal of waste from the workplace, including e-waste, construction and demolition materials, in government owned buildings was done in an environmentally responsible way.

7.2: Green Procurement

As of April 1, 2014, the Government of Canada will continue to take action to embed environmental considerations into public procurement, in accordance with the federal policy on Green Procurement.

Departmental approach to further the implementation of the Policy on Green Procurement in place as of April 1, 2014. Health Canada had a Departmental approach to further the implementation of the Policy on Green Procurement in place as of March 31, 2015.
Number and % of procurement and/or materiel management specialists who completed the Canada School of Public Service Green Procurement course (C215) or equivalent, in fiscal year 2016-17. All procurement and/or material management specialists* at Health Canada (n=38) completed the Canada School of Public Service Green Procurement course which covers the reasons for buying green, identifying the major eco-labels and what makes an item or service green.

*New employees will be required to have the training included in their personal learning plan for completion within a year.

Number and % of managers and functional heads of procurement and materiel whose performance evaluation includes support and contribution toward green procurement, in fiscal year 2016-17. All performance evaluations for procurement and materiel management managers (n=2) included a discussion about how they supported and contributed to green procurement practices.
  Volume of IT hardware purchases that meet the target objective relative to the total volume of all purchases for IT hardware in the year in question. Health Canada exceeded the 90% federal target to include environmental impact criteria in Information Technology hardware purchases*, such as computers. In 2016-17, 99% of purchases used these criteria to reduce the environmental impact associated with the production, acquisition, use and disposal of the equipment.

*This does not included laboratory, field equipment, as well as purchases made using acquisition cards.

Volume of office supply purchases that meet the target objective relative to the total volume of all office supply purchases in the year in question. Health Canada exceeded the federal target of 80% of office supplies purchased to include environmental features. In 2016-17, 99% of purchases included these features; up from 81% in 2015-16 and 61% in 2014-15.

*This excludes purchases made using acquisition cards.

Number of vehicle purchases that meet the target objective relative to the total number of vehicle purchases in the year in question. Health Canada exceeded the federal target of 90% of vehicles purchased being right-sized and the most fuel efficient in their class at the time of purchase. In 2016-17, 92% of vehicles purchased met these criteria.
Target 7.3: Sustainable Workplace Operations

As of April 1, 2015, the Government of Canada will update and adopt policies and practices to improve the sustainability of its workplace operations.

Approach to maintain or improve the sustainability of the departmental workplace in place as of March 31, 2015. A working group was established with representatives from the Health Portfolio to develop a Sustainable Workplace Operations Approach which outlines the commitment to improving the sustainability of workplaces across Canada. This includes a commitment to: continue to engage employees in greening government operations; maintain or improve existing approaches to printer ratios, paper usage and green meetings; dispose of e-waste in an environmentally sound and secure manner; and reuse or recycle workplace materiel and assets in an environmentally sound and secure manner.
Goal 8: Water Management 8.1 Water Management As of April 1, 2014, the Government of Canada will take further action to improve water management within its real property portfolio. Approach to improving water management included in Real Property Sustainability Framework in place by March 31, 2015. The approach to sustainable water management is defined in the Real Property Sustainability Framework.
Amount and % of floor space in buildings over 1000 m2 that includes water metering, in fiscal year 2015-16 (where feasible). All of the Crown owned and leased buildings that Health Canada occupied in 2016-17 used water meters. In addition, regular audits were conducted to ensure the safety of the drinking water and to obtain data that was analysed to identify opportunities to improve water management practices.

4. Strategic Environmental Assessment (SEA)

During the 2016-17 reporting cycle, Health Canada considered the environmental effects of initiatives subject to the Cabinet Directive on the Environmental Assessment of Policy, Plan and Program Proposals (the Cabinet Directive), as part of its decision-making processes. Health Canada contributed to Detailed Analyses led by other departments, but did not issue any public statements because Health Canada was not the lead on any initiatives requiring a Detailed Analysis.

As a means of supporting the revised SEA Policy, Health Canada continues to provide annual training to employees on the SEA process and requirements to help maintain compliance with the Cabinet Directive and to reinforce the importance of SEA as a tool for incorporating environmental considerations into the decision-making process. In 2016, Health Canada released an online SEA course that is available to all departmental employees and was actively promoted by senior management. Employees are encouraged to include the course as part of their annual learning plan.

Health Canada will continue to ensure that its decision-making process includes consideration of the FSDS goals and targets through the SEA process. A SEA for policy, plan or program proposals includes an analysis of the impacts of the given proposal on the environment, including on the FSDS goals and targets. Should a proposal have the potential for significant positive, negative or uncertain environmental impact, a detailed analysis would be completed and the results of the analysis would be made public when the initiative is announced.

In 2016-17, Health Canada's SEA process was applied to 98% of proposals going to Cabinet and Treasury Board, as well as 100% of regulatory proposals, to determine if there were positive or negative environmental effects. This resulted in the completion of 52 Preliminary Scans.

Footnotes

Footnote 1

This activity reflects CMP Phase III achievements outside of Implementation Strategy 4.8.5

Return to footnote 1 referrer

Footnote 2

Ibid.

Return to footnote 2 referrer

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