Bed-Rail Safety and Entrapment

William A. Hyman wrote an article in McKnight's Long Term Care News on July 24, 2008 about the dangers of bed rails and the problem with entrapment.

Bed-rail entrapments and deaths continue to occur in nursing homes, other facilities and in the home because rail and bed designs that are clearly dangerous continue to be used. Such rails may be in your inventory, or in the inventory of your rental supplier.

The U.S. Food and Drug Administration has recognized and reported on the problem of lethal entrapments for over 10 years, but it has not ordered recalls. Some manufacturers have designed safer rails yet not replaced those already in use. And despite the publicity efforts of the FDA, The Joint Commission published articles and others, there continues to be a lack of practical understanding of the nature of this hazard and how to recognize a dangerous bed.

The time to end lethal bed-rail entrapments is now, and the way to do it is to remove from the inventory those bed-rail systems that are unreasonably dangerous, and to insist that suppliers provide beds that at least meet current guidelines.

It is now 13 years since the FDA's Safety Alert on the dangers of entrapment in bed rails, and other parts of hospital and nursing home beds (1). This alert was directed to Home Healthcare Agencies, Hospices, and Nursing Homes, among others. It was based, in part, on already published work and reports to the FDA of deaths and injuries associated with beds and bed rails, the latter going back to publicly available data since 1985. The FDA alert triggered a number of related reports and announcements in the clinical literature (2- 4).

The entrapment issues stimulated the creation of the Hospital Bed Safety Workgroup (HBSW) (5) in 1999. The work group is a partnership among FDA, the medical bed industry, national healthcare organizations, patient advocacy groups and other federal agencies. This group labored for many years to reconcile the diverse interests of its members, and to balance safety and economic concerns. The HBSW ultimately produced a brochure, which currently has a 2006 update date, along with guidance documents and a gap measurement methodology. Earlier drafts of the guidelines also were publicly available, but are no longer posted at the FDA/HBSW Web site. The guidance is not applicable to all beds. For example, air-fluidized beds, bariatric beds, pediatric beds, infant cribs, and pressure-reduction products such as air mattresses are fully or partially excluded. Air mattresses that replace the regular mattress may present particular risk for under the side rail entrapment because of the high compressibility of the air mattress at the edge (6). It is notable that air mattresses in particular are excluded--not because of any lack of risk, but because of "technically difficulties with measuring certain dimensional gaps."

Articles and other material on bed and bed rail entrapment hazards have continued to appear in announcements from the FDA (7), The Joint Commission (8), the Veteran's Administration (9), on National Public Radio (10), and in the pages of Nursing Homes (11). The latter article addresses the March 10, 2006, FDA guidance (12).

Regrettably, none of the FDA's efforts have resulted in recalls or other manufacturer formal actions to remove dangerous bed-rail systems from use. In fact, the guidance notes that the "FDA does not intend to take enforcement actions for failure to submit reports of corrections and removals under 21 CFR Part 806 for actions taken in response to this guidance that correct or improve hospital beds currently in use or held as inventory" (12). Thus, the manufacturers achieved protection from the "recall" label, if they took any action at all. Individual nursing homes or equipment dealers may have removed from inventory certain bed systems, but their disposition is unknown. At least some design improvements for new equipment have become available. While the latter may increase the safety of newly purchased beds, it does not protect either patients or providers from the use of older equipment. In fact, the open availability of better products, along with the extensive literature on the hazard, most likely increases the liability exposure of the nursing home, particularly with respect to the possible assertion that they didn't know about the risk.

Although the effort to inform the user community about bed-rail entrapment hazards has been ongoing, there continue to be deaths in nursing homes resulting from such entrapments. Some individual nursing homes have had more than one such death, and some corporate chains have had deaths in more than one facility. In some cases, corporate level expertise has generated warnings and or guidance documents to their individual facilities, but whether there has been decisive or ongoing vigilance with respect to these issues is not clear.

What is the problem?

The basic bed-rail entrapment problem is that the design of the bed frame, the bed rail and the mattress may create gaps into which body parts can become trapped. These components together are called the bed system. When the body part is the neck or chest, this can lead to death. Seven particular entrapment zones have been clearly identified and graphically illustrated. These are:


Zone 1: Within (between) the bars of the rails
Zone 2: Under the bottom rail, between the rail and the mattress or bed frame
Zone 3: In the gap between the rails and the mattress
Zone 4: Under the rail and between the rail and the mattress at the outside edge of the rail
Zone 5: Between split rails
Zone 6: Between the end of the rail and the head or foot board
Zone 7: Between the end of the mattress and the head or foot board

The FDA guidance, which is voluntary, only contains test protocols for Zones 1-4. Thus, a bed that asserts it is compliant with the guidance may not adequately address all of the zones. It should also be noted that the situations illustrated are not the only relevant risks. For example, in Zone 2 the illustration shows the head having entered the gap. Alternatively, the body can slide through this gap while the head might not, leading to strangulation aided by body weight. Such a situation is shown in the Zone 4 and Zone 5 graphics, but those graphics do not in turn show headfirst entry. Also, Zones 2 and 3 are highly interactive. The space between the bottom rail and the top of the mattress relevant to Zone 2 is a function of both the horizontal distance between the inner face of the bed rails and the edge of the mattress and the vertical space between the bottom of the lowest rail and the top of the mattress. The resulting oblique distance can be substantially increased as body weight compresses the edge of the mattress.

The "gap" in Zone 3 is a function of the horizontal distance between the edge of the mattress and the inside face of the bed rail, but the risk is also a function of where the bottom rails are as well as the compressibility of the mattress. In addition, whether the mattress is centered or not affects the Zone 2 and 3 gaps and assessment should be made with the mattress pushed all the way to one side, even if no-slip pads or physical mattress retention systems are supposed to be used. In many designs, this horizontal gap seems to have been intentionally increased by the bed or bed rail manufacturer by making the structure that holds the bed rail stand out from the bed frame that supports the mattress. This may be to facilitate raising and lowering the bed rail, or being able to change the bedding, without interference from contact between the mattress and the rails.

However, this convenience feature increases the risk of entrapment and is therefore a poor trade-off. Some newer designs move the side rails closer to the mattress, and add one or more bars to the bottom of the side rails in order to reduce or eliminate the vertical component of the Zone 2 gap. It must also be noted that articulating the bed can significantly increase the Zone 2 gap in a full rail. In turn, readjusting the rail, if there are adjustment points between fully up and fully down, can reduce this gap increase, but this requires specific knowledge and consistent action by staff.

The challenge of bed assessment is increased by the mix of products that may become in use even at a single facility. For example, any two or all three of the bed, bed rails, and mattress may come from different manufactures. Thus, a bed system that was reasonably safe today may become relatively unsafe if any component is changed tomorrow. The mismatch is facilitated by many components being more-or-less mechanically interchangeable, even though they may be functionally different. This mismatch can be a particular challenge when rental equipment is used since the rental supplier may have a variety of bed components in its inventory such that one day's delivery is relatively safe while the next bed delivered is relatively unsafe.

In addition, not all patients are of equal risk. In particular, small, lightweight patients are generally at the greatest risk given that their small physical dimensions may enhance their ability to fit into a gap, in whole or in part. Of course, such relatively small people are a common element in many nursing home settings. Another patient consideration is mobility, agitation and temporary or chronic reduced mental capacity. In this regard it must be understood that a major critical use situation of the bed rail will be when the bed occupant moves or rolls into contact with the rails. Often, this occupant will not be in full use of normal physical or mental faculties. Pretending that a bed rail is only to "remind" the occupant that they have come to the edge, or that it is only an aid to turning or bed egress (half-rails), is a fantasy that does not address actually use and risk. This fantasy is partially driven by the need to reduce restraints, as well as by manufacturer's liability "risk management" by disclaimer.

What are the real solutions?

When bed rails are indicated and specifically ordered, the ideal solution is to not have any beds or bed systems that present unreasonable risks of entrapment. This is the only solution that eliminates the problem, and elimination is always the first choice in hazard reduction. In addition, elimination of hazardous bed systems by manufacturers addresses the problem where the solution can be most effectively implemented, rather than relying on the far more numerous users to address the problem. This has been called solving the problem at the blunt end, rather than at the sharp end where the hazard actually manifests itself. At the blunt end the manufacturer also has more technical expertise and is not under short time constraints.

Addressing elimination at the local or facility corporate level requires an assessment of current bed systems and combinations, and a replacement strategy using manufacturer certified compliant beds. To aid in this process, the manufacturer of a single sourced existing bed system should in principle be a good source of information as to whether that bed system is compliant if properly maintained. An answer that is not meaningful is a bad sign. A rental supplier should be similarly asked what their own assessment of their equipment has revealed. If either the bed manufacturer or rental supplier hasn't done an assessment, doesn't understand the question, or asserts that the guidance is only a guidance and/or that it doesn't apply to older beds, it may be time to find new sources.

When replacing or adding beds, it is not logical to buy a new bed system and then take on the primary responsibility of measuring it for compliance. Contracts with suppliers must specify that only bed systems that are compliant may be delivered to the facility or its patients, and actual compliance with this contract provision must be assured. However, even here it must be remembered that the FDA guidance does not address all hazards, e.g. most measurements are made with the bed flat or with an assumed direction of into the entrapment Zone. Thus, it is equally appropriate to ask manufacturers what they themselves have done to address entrapment risks, aside from or in addition to the FDA guidance.

In addition, active policies must be in place with respect to maintaining system integrity with respect to replacement parts including mattresses. Similarly, separate or add-on products such as air mattresses must be certified by their manufacturer, or physically tested within the facility, to assure that their use does not increases the entrapment risk. Such testing must use specific and meaningful criteria. Associated product demonstrations must consist of a full system of mattress, bed and bed rails. Demonstrating an air mattress on a cafeteria table will not adequately address entrapment risks. If the product does increase the entrapment risk, but is desirable none-the-less, explicit and realistic measures to mitigate the risk must be identified and consistently implemented. It is not appropriate to simply "accept" the risk without mitigation.

A less-than-ideal solution is to identify bed, bed rail, mattress combinations that are of greater risk than some other combinations, and to create a system that assures that the undesirable combinations are never used. As above, a similar requirement must be placed on rental suppliers. Another less-than-ideal approach is to identify bed, bed rail, mattress combinations that present increased risk to certain segments of the patient population (e.g. patient's below a certain weight), and to have a functional and realistic plan to assure that such patients are not put in high risk beds. For a bed system from a single manufacturer, if there is a population for which the product is not suitable, that population should be identified by the manufacturer as a contraindication. On the other hand, broad warnings that seek in effect to shift the burden to the end user should be recognized and the product avoided.

The challenge in implementing either a product- intensive or patient-intensive plan is that each requires ongoing vigilance by trained and knowledgeable people. The associated challenge is training relevant personnel so that they can and will make informed judgments about the suitability of a bed system for a particular patient or type of patient. Such training must include specific and measurable criteria. For example, an instruction to "make sure the gap is not too big" is basically meaningless since it does not adequately address whether the gap in question is viewed from the side or above or at an angle, whether it is actually measured or just eyeballed, and what in fact makes a gap "too big." Similarly, entrapment risk warning labels on inherently dangerous products that do not provide any clear guidance as to how to assess the bed or the patient cannot be effective, unless used as a guide to not purchase such a product in the first place.

Another facility-based work-around for excessive gaps, besides realistic bed and patient assessment, is attempts to fill such gaps with dedicated or ad hoc products. Such solutions must be carefully assessed for their actual suitability and effectiveness. They also must be routinely practiced or the situation could end up that a risk was identified and a solution was identified, but the solution was not implemented, thereby leading to death. Furthermore, such work-arounds are inherently an attempt to locally fix a situation that should not exist in the first place.

Explaining the death that occurs

When an entrapment death occurs, there will often be a common set of facts that must be addressed. One is that the death itself demonstrates the hazard, and that the general hazards are "well known," and have been for well over a decade. The issue may also be compounded by a state level facility investigation and sanctions. This makes a claim of not knowing about the hazard hard to justify for both the facility and equipment suppliers, yet such a defense is often made. In this regard it should be noted that there are few other patient deaths for which graphic illustrations already exist, and even more graphic photographs may be taken.

Second, it may be the case that the hazard is "obvious" to a knowledgeable observer, and can be readily demonstrated. For example, a test device such as that recommended by the FDA may freely fall through an oversize gap, even without pressure on the mattress or simple hand pressure on the mattress may open a clearly dangerous gap. The manufacturer may use this fact to assert that it should then have been obvious to the users at the facility, and that they had provided various warnings. However, in the absence of specific training about the hazard and its meaningful assessment, such obviousness will likely not actually be within the working knowledge of the caregivers.

The current situation

The current situation with respect to bed-rail dangers is that (a) entrapment hazards have been clearly identified, (b) bed systems that embody those hazards continue to exist in nursing home and rental agency inventories, (c) bed system or bed components that do not adequately address these hazards are still on the market, (d) too many nursing homes and equipment suppliers either remain uninformed or do not have an effective action plan to mitigate the risks, and (e) bed users continue to die.

The FDA's action to address this situation has been limited to safety alerts, brochures and guidance documents, and seemingly protecting manufacturers from recalls. In addition, many bed rails receive relatively little regulatory review before being marketed because of the FDA classification of hospital beds. The responsible nursing home should act now to assess its, and its supplier's inventory, and to institute a clear and effective plan to eliminate or actively and effectively manage the entrapment hazard.

While it is true that some bed systems may be safe for some patients yet unsafe for others, the continued presence and deployment of bed rails and beds that are known to be hazardous to at least a common class of patients presents excessive opportunity for these bed rails to be used for inappropriate patients.

A patient dying from strangulation in a bed rail is clearly an event that is intolerable when it occurs because of well-known bad bed rail design, or a bad bed rail/bed/mattress system. The often-associated lack of continuous observation is hardly surprising and is in fact what can be reasonably expected in most care settings.

When entrapment and strangulation occurs with older designs that should have been recalled or replaced, the situation is even more offensive. And when those same bed rails have contributed to prior deaths, and continue to be used, the offensive is magnified. The time to retire dangerous bed rails is now!

William A. Hyman is a professor in the Department of Biomedical Engineering at Texas A & M University in College Station, TX. You can e-mail him at w-hyman@tamu.edu or call him at 979-845-5593. For more, go to http://biomed.tamu.edu.

Joint Commission News Release re: 2009 Safety Goals for LTC

NEWS RELEASE

Ken Powers
Media Relations Manager
630-792-5175
kpowers@jointcommission.org

The Joint Commission Announces 2009 National Patient Safety Goals
for Long Term Care Organizations

(OAKBROOK TERRACE, Ill. – June 17, 2008) The Joint Commission today announced the 2009 National Patient Safety Goals and related requirements for accredited long term care organizations. The National Patient Safety Goals promote specific improvements in patient safety by providing health care organizations with proven solutions to persistent patient safety problems. These Goals apply to the more than 15,000 Joint Commission-accredited and -certified health care organizations and programs.

Major changes include a new requirement related to preventing deadly central line-associated bloodstream infections. This addition builds on an existing National Patient Safety Goal to reduce the risk of health care associated infections, and recognizes that patients continue to acquire preventable infections at an alarming rate while receiving health care. The new infection-related requirement has a one-year phase-in period that includes defined milestones, with full implementation expected by January 1, 2010.

“The 2009 National Patient Safety Goals represent ongoing opportunities for improvement that can immediately benefit patients,” says Mark R. Chassin, M.D., M.P.P., M.P.H., president, The Joint Commission. “By taking action to consistently meet the Goals, health care organizations can substantially improve patient safety in America.”

A revision of the requirements for the existing medication reconciliation Goal is based on feedback obtained from a Medication Reconciliation Summit convened in late 2007 and is included in the 2009 update.

The 2009 Long Term Care National Patient Safety Goals:

Improve the accuracy of resident identification.
· Use at least two resident identifiers when providing care, treatment, and services.

· Prior to the start of any surgical or invasive procedure, individuals involved in the procedure conduct a final verification process, such as a time-out, to confirm the correct resident, procedure and site, using active, not passive, communication techniques.

Improve the effectiveness of communication among caregivers.
· For verbal or telephone orders or for telephone reporting of critical test results, the individual giving the order verifies the complete order or test result by having the person receiving information record and “read-back” the complete order or test result.

· There is a standardized list of abbreviations, acronyms, symbols, and dose designations that are not to be used throughout the organization.

· The organization measures, assesses, and, if needed, takes action to improve the timeliness of reporting, and the timeliness of receipt of critical tests and critical results and values by the responsible licensed caregiver.

· The organization implements a standardized approach to hand-off communications, including an opportunity to ask and respond to questions.

Improve the safety of using medications.
· The organization identifies and, at a minimum, annually reviews a list of look-alike/sound-alike medications used in the organization, and takes action to prevent errors involving the interchange of these medications.

· Reduce the likelihood of resident harm associated with the use of anticoagulation therapy. (Note: This requirement applies only to organizations that provide anticoagulation therapy and/or long-term anticoagulation prophylaxis (for example, atrial fibrillation) where the clinical expectation is that the resident’s laboratory values for coagulation will remain outside normal values. This requirement does not apply to routine situations where short-term prophylactic anticoagulation is used for venous thrombo-embolism prevention (for example, related to procedures or hospitalization) and the clinical expectation is that the resident’s laboratory values for coagulation will remain within, or close to, normal values.

Reduce the risk of health care-associated infections.
· Comply with current World Health Organization (WHO) hand hygiene guidelines or Centers for Disease Control and Prevention (CDC) hand hygiene guidelines.

· Manage as sentinel events all identified cases of unanticipated death or major permanent loss of
function related to a health care associated infection.

· Implement best practices or evidence-based guidelines to prevent central line-associated bloodstream infections. Note: This requirement covers short and long term central venous catheters and PICC lines.

Accurately and completely reconcile medications across the continuum of care.

A process exists for comparing the resident’s current medications with those ordered for the resident while under the care of the organization.
When a resident is referred or transferred from one organization to another, the complete and reconciled list of medications is communicated to the next provider of service and the communication is documented. Alternatively, when a resident leaves the organization’s care directly to his or her home, the complete and reconciled list of medications is provided to the resident’s known primary care provider, or the original referring provider, or a known next provider of service. (Note: When the next provider of service is unknown or when no known formal relationship is planned with a next provider, giving the resident, and family as needed, the list of reconciled medications is sufficient.)
When a resident leaves the organization’s care, a complete and reconciled list of the resident’s medications is provided directly to the resident, and the resident’s family as needed, and the list is explained to the resident and/or family.
In settings where medications are used minimally, or prescribed for a short duration, modified medication reconciliation processes are performed. Note: This requirement does not apply to organizations that do not administer medications. However, it is important for health care organizations to know what types of medications their residents are taking because these medications could affect the care, treatment, and services provided.
Reduce the risk of resident harm resulting from falls.

· The organization implements a fall reduction program that includes an evaluation of the effectiveness of the program.

Reduce the risk of influenza and pneumococcal disease in institutionalized older adults.
· The organization develops and implements protocols for administration of the flu vaccine.

· The organization develops and implements protocols for administration of the pneumococcus vaccine.

· The organization develops and implements protocols to identify new cases of influenza and to manage outbreaks.

Encourage residents’ active involvement in their own care as a resident safety strategy.
· Identify the ways in which the resident and his or her family can report concerns about safety and encourage them to do so.

Prevent health care associated pressure ulcers (decubitus ulcers).
· Assess and periodically reassess each resident’s risk for developing a pressure ulcer (decubitus ulcer) and take action to address any identified risks.

The development, annual review and modification of the National Patient Safety Goals, first introduced in 2003, is overseen by the Sentinel Event Advisory Group, a panel that includes widely recognized patient safety experts, nurses, physicians, pharmacists, risk managers and other professionals who have hands-on experience in addressing patient safety issues in hospitals and other health care settings. Each year, this panel works with The Joint Commission to undertake a systematic review of the literature and available databases to identify potential new Goals and requirements. The Joint Commission also conducts an extensive field review of candidate new Goals and seeks input from practitioners, provider organizations, purchasers, and consumer groups among others. The Joint Commission’s Board of Commissioners approves the Goals and requirements each year. Compliance with the requirements is a condition of continuing accreditation or certification for Joint Commission-accredited and -certified organizations.

The full text of the 2009 National Patient Safety Goals and requirements for all accreditation programs, along with the elements of performance, can be found on The Joint Commission’s website. Compliance with the requirements is a condition of continuing accreditation or certification for Joint Commission-accredited and -certified organizations.



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Another story of neglect

WFTV in Florida had an article about a nursing home allowing one of their residents to fall NINE times from a her wheelchair.  This is neglect.  Why didn't they try a safety device like a tray or belt?  I wonder if they were given her the right amount of medication or if they were using the medications as a chemical restraint?   Hopefully the family will get some answers during the lawsuit. 

The falls caused Ruth Boelke to prematurely die. The nursing staff failed to follow the doctor's orders and best safety practices by failing to use a safety device to prevent Ruth from falling out of  her wheelchair.   The home's director said it did call her doctor a few days before she died and sent her to the hospital. The family claims the nursing home should have called for help sooner.

2 residents killed after wandering away from facility

Here is an article about a tragic case where a nursing home failed to supervise residents who ended up walking away from the facility and was killed in a car accident.  For the second time in six weeks, a resident of the Dover Woods health care facility has been struck and killed by a car. 

Township officials expressed frustration at their inability to come to an agreement over safety measures for the facility's residents with its owners, the Erez Health Care Realty Company LLC of Lakewood.

A meeting had been scheduled for mid-January, but it was canceled it because the company wanted its corporate defense lawyer to appear. No new date has been scheduled.   The facility doers not seem concerned that two of their residents have died as a result of their failure to properly supervise their residents as they are required and paid to do.

In December, police were called to Dover Woods for more than 37 incidents ranging from residents wandering along the highways picking up cigarette butts to the harassment of customers at a nearby shopping center.   The Police Department has responded to the facility 27 times this year.


Family wants answers about "disappearance"

Family of man who disappeared sues Gooding nursing home.  The family of a man who allegedly wandered away from the Idaho nursing home five years ago has sued thecorporation that operates the facility.

In the lawsuit filed on behalf of Magic Valley Manor resident John Henry Davis allege the home and Northwest Bec-Corp didn't supervise him or keep him safe and free from harm.

Wendell, who suffered from Alzheimer's disease, disappeared in July 2002.


New product QuietCare helps elderly avoid nursing homes

There is a new product called QuietCare which is a home monitoring system that tracks a resident's health, and alerts designated neighbors by e-mail or phone when something is wrong. 

The QuietCare monitoring system can keep up with meals and medications, and to alert others if he has had a fall or other emergency.

In an industry that is becoming proactive, QuietCare focuses on keeping aging or disabled people at home longer. Everything from computerized medication dispensers to concierge health-care managers aim to give the elderly and disabled the assistance they need to stay independent and safe.

With the cost of nursing home care skyrocketing and baby boomers reaching retirement, the country is facing an expensive health-care bill. Nursing homes are already crowded, and at a cost of $6,000 to $6,500 per month in Central Florida, providing round- the-clock nursing home care to an increasing number of seniors could be back-breaking for the nation's health-care system.

There certainly is no shortage of products designed to help seniors and caregivers.

AT&T offers home video monitoring, or so-called nanny cams, that some people are using to keep a watch on elderly relatives.

LifeAlert -- known for its marketing slogan "I've fallen and I can't get up!" -- markets emergency-button systems. Other companies offer similar personal emergency-response systems as well, with prices ranging from $200 to more than $1,500, plus monthly monitoring fees.

If taking medication is an issue, Guardian Medical offers a pill dispenser that can be programmed to dispense medication at certain times, and provide alerts by phone if pills are missed.

Lawsuit related to fall that led to death

 A wrongful death lawsuit was filed against a Menomonee Falls nursing home, contending that a resident died from complications caused by broken bones in both legs that she suffered during a fall that was not reported.

Dorismae Burgardt was dropped by a nursing assistant at Menomonee Falls Health Care Center using an improper technique. The incident was not reported to a registered nurse or the woman's physician. The first mention that something was amiss came the next day, when it was noted on her chart that Burgardt had "bruises" on both knees caused by being "lowered to the floor".

Three weeks later, Burgardt was dead. She was 81.

"This lawsuit is about dignity and safety," said attorney Jay Urban, who filed the lawsuit on behalf of Burgardt's estate and her husband, Allan Burgardt of Germantown. 

See full article


The nursing assistant did not use a required safety belt during the shower, and she should have been assisted by another employee but was not. In addition to not reporting the matter to a physician or a registered nurse, the two failed to document it in Burgardt's chart.

Burgardt was taken to Community Memorial Hospital in Menomonee Falls, where X-rays revealed broken bones in both legs, according to the lawsuit.

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