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A small business environmental primer.

Successful business operations depend on many activities, including knowledge and compliance with the appropriate federal, state and local environmental statutes, regulations and ordinances. Many businesses are finding regulatory compliance is not only mandatory but an effective method for improving business operations and products. Despite the initial costs of compliance, many companies have already found themselves financially benefitting from these changes. Further, companies are experiencing a more positive public image and appear to benefit from an increase in customer demand for their products if the customers are aware of a company's compliance record with the appropriate environmental statutes and regulations.

Although this article does not cover the full array of environmental and natural resource laws, it does discuss many provisions of the better known environmental statutes. Hopefully, this article will increase your sensitivity to some of the environmental problems society faces as well as to provide you with the incentive to question whether your clients' business operations impact the environment. Clearly, it is no longer possible to disregard environmental laws or use a corporate structure as a safehaven to protect businesses or yourself from civil and/or criminal environmental enforcement actions. Instead, businesses are finding environmental compliance and pro-active voluntary initiatives to reduce pollution output may be the most effective methods to minimize the impact on our surroundings and increase profitability.

The Clean Air Act

In 1990, the U.S. Congress amended the federal Clean Air Act (CAA). These amendments greatly expanded the scope of actions included under the CAA, including an expansion of the types of emission sources covered as well as an enhancement of the enforcement authorities.

The current CAA is composed of the following seven main elements: nonattainment areas; mobile sources; air toxics; acid rain; permits; stratospheric ozone protection; and the enforcement provisions. Although each of these elements is important, this article will focus on the nonattainment element, the air toxics element, permits and enforcement.

Under the nonattainment element, national ambient air quality standards (NAAQS) have been set for certain air pollutants, e.g., carbon monoxide, ozone (smog), particulate matter and nitrogen oxides. Since many regions of the country do not attain the NAAQS, the states are to develop implementation plans (SIPs) to meet these standards. These plans contain numerous regulations for reducing emissions of those chemicals forming these pollutants. Consequently, these state and even local regulations often impact many businesses from the small dry cleaner to the large oil refinery.

The air toxics element is a second major area covered by the CAA because approximately three billion pounds of air toxics are annually released into the air. Under the air toxics provisions, source categories emitting any of the 189 identified chemicals above a certain level are required to use certain technologies to reduce these emissions. These technologies must be capable of performing to the level of the stringent emission standards as described in the maximum achievable control technology (MACT) regulations. Once a source category implements MACT, EPA and the state may also require additional control technologies to reduce further the residual risk. The federal and state governments are working to define the technologies to be implemented by a specific source category, e.g., petroleum refineries.

The CAA amendments also have added a permit element. Although some states and localities have previously required some form of operating permit, states are now required to develop operating permit programs. These permits cover major nonattainment sources as well as other emission sources, e.g., air toxic emission sources. The permit may require the permit holder to, among other things, implement the appropriate emission technologies for that source as identified in the regulations. The permit may also include reporting and monitoring requirements. A state may require renewal of that permit after a certain time period.

Finally, enforcement authorities have been enhanced under the CAA. Depending on source-specific information, federal, state or local governments may bring an enforcement action against a source not complying with the appropriate air regulations or permit conditions. These enforcement actions may be civil or criminal in nature and involve the administrative agency or the judicial system. The cost of administrative penalties could range from thousands to hundreds of thousands of dollars. Clearly, this enforcement element creates added incentive for businesses to scrutinize their operations and meet regulatory obligations.

Overall, the CAA will probably require many businesses to reevaluate their manufacturing processes and product compositions in order to meet the requirements of the CAA. As indicated, this is only a brief discussion of a few key provisions of the CAA.

The Clean Water Act

Recently, significant attention has been given to sources of emissions that cause water pollution. Congress revised the Federal Water Pollution Control Act (referred to as "CWA") in 1972, 1977 and 1987, to address some of the problems impacting our nation's water. Basically, the CWA attempts to control discharges of pollutants into the waters of the United States.

Similar to the Clean Air Act, the CWA focuses on non-point sources and specific point sources discharging pollutants into the water instead of the air. The discharges generally come from two basic type of sources: non-point sources and specific point sources.

Three examples of pollution from non-point sources are pesticide runoff from farms, herbicide runoff from golf courses and chemical runoff from highways. In contrast, pollution from specific point sources include direct and indirect discharges from industrial facilities and the like. These pollutants may directly enter the water through pipes, wells, conduits, ditches, and tunnels or indirectly through publically owned treatment works (POTWs). Despite the difference in the sources of the pollutants, significant challenges exist for controlling the deleterious impact these discharges have on our nation's water.

Generally, the water pollutants fall into three categories: toxic, (priority), conventional and non-conventional pollutants. A two tiered (level) approach exists to control these pollutants. The first tier involves implementation of identified technologies for certain source categories. Different levels of technologies are required for a source to respond to the severity of the pollutant, i.e., toxic and nonconventional pollutants require the use of best available treatment (BAT) where as conventional pollutants require the use of best conventional technologies (BCT).

Once these technologies are implemented, a state may require a source meet specific state water quality standards (WQS) through the implementation ofeven further source specific technology controls. WQS generally reflect uses of the water and the criteria needed to protect the use.

Under the CWA, a national permit discharge emission source (NPDES) is required for direct discharges into U.S. water. These permits generally contain numerous provisions, including the following: the incorporation of the applicable technology based effluent standards, e.g., BAT or BCT, for the source: monitoring and reporting requirements; an enforcement provision; and other criteria required to operate under the NPDES. Generally, EPA administers the permitting process unless EPA has authorized a state to perform this function. Although a state may be authorized to issue NPDES permits, the federal government still retains oversight and may enforce the terms of the NPDES as well as the state.

Indirect sources are also a second major form of water pollution. These sources include industries that discharge into publically owned treatment works (POTWs) - the sewer system. EPA has developed pretreatment standards for discharges into POTWs. These pretreatment standards limit the type of pollutants which can enter the POTW in order to preserve the efficiency of the POTW system. Since the standards primarily implemented and enforced through the state and local governments, a discharger should consult state regulations and local ordinances for determining the appropriate pretreatment standards and appropriate local permitting requirements. These local requirements may be fairly rigorous because the POTW, itself, must have a NPDES for direct discharges into the water.

Finally, many sources of pollutants are not currently regulated, but the CWA does control the discharge of dredge and fill materials into U.S. waters, including wetlands. The use of wetlands is becoming an explosive area of litigation as the demand to use these precious areas has increased.

In conclusion, many business operations are impacted by the CWA and a thorough analysis of discharges, direct and indirect, including stormwater discharges, is critical to compliance with the CWA.

Section 311 of the Clean

Water Act As Amended By

The Oil Pollution Act

Congress enacted the Oil pollution Act of 1990 (OPA) in an attempt to prevent massive oil pollution such as that caused by Exxon Valdez and other oil discharges. Among other things, a few of the primary accomplishments of OPA were to expand the oil pollution prevention and response requirements of vessel and facility owners and operators; establish Federal authority to direct spill responses; increase the liability limits to responsible parties; establish a billion dollar oil spill liability trust fund; and create an expanded oil pollution research and development program.

Section 311 of the Clean Water Act (33 U.S.C. Section 1321), amended by OPA, does the following: prohibits the discharge of oil or certain hazardous substances in quantities that may be harmful; requires "persons in charge" to give immediate notification for a discharge (failure to do so may lead to criminal sanctions including up to five years in prison and/or a heavy fine); provides the authority for the EPA and the U.S. Coast Guard to direct removal of spills (and requires EPA or Coast Guard direction for discharges posing a substantial threat to the public health or welfare of the United States); and provides the underlying authority for regulating facilities handling oil and hazardous substances.

EPA regulates non-transportation-related facilities. Currently, EPA only regulates facilities handling oil and not those handling hazardous substances. This regulation, the Oil Pollution Prevention regulation, is also known as the Spill Prevention, Control and Countermeasures (SPCC) regulation. (The Coast Guard regulates transportation related facilities).

The SPCC regulation applies generally to non-transportation-related onshore or fixed facilities which, due to their locations, could reasonably be expected to discharge oil in quantities that may be harmful. There are several requirements under this regulation, including requiring a prevention plan (SPCC plan) be developed, certified by professional engineer and implemented.

The SPCC regulation was first published in 1973, revised in 1976 and is being revised to become more stringent. It will include new requirements under OPA, such as preparation and submittal of response plans. EPA is revising the regulation in two phases. Phase One revisions were proposed in the Federal Register on October 22, 1991 (56 F.R. 54612). Phase one revisions include provisions generally not requiring substantial additional Agency data gathering, e.g., technical amendments to clarify the regulatory requirements. Phase Two revisions will address more substantive requirements, such as facility specific contingency planning and other requirements in the OPA.

Resource Conservation and

Recovery, Act

Subtitle C - Hazardous Waste


Most business operations generate waste in some form during the normal course of business. Congress recognized the need to respond to these wastes in order to protect human health and the environment, reduce waste output, conserve resources and minimize the generation of new waste. The Resource Conservation and Recovery Act of 1976 (RCRA) as amended by the Solid Waste Disposal Act of 1984 is the primary federal statute designed to manage and track hazardous waste, non-hazardous waste, medical waste and underground storage tanks.

Although a full analysis of RCRA would be very long and extensive, this section will hopefully prompt businesses to ask themselves some basic questions about the waste it generates. 1. The first need is to identify

whether the waste is hazardous,

non-hazardous; or does it appear

to have both non-hazardous and

hazardous characteristics.

Although a hazardous waste is defined by statute, the identification of a waste as such is made difficult by the complex federal regulations. Essentially, a waste may be considered hazardous if it is specifically listed in the regulations. However, an unlisted waste may still be considered hazardous if it exhibits at least one of the following characteristics: corrosive, reactive, ignitable or toxic. As a note, certain exclusions exist for certain wastes. 2. Once a waste is determined to be

hazardous, the waste must be

managed according to RCRA's

Subtitle C for hazardous waste.

Subtitle D is reserved for nonhazardous

waste. The management

process and requirements

vary between the two subtitles.

Under Subtitle C, a set of federal technical regulations exist for facilities possessing the waste. The regulations provide baseline requirements for managing the waste; however, a state and even a local government may develop more stringent regulations ordinances or guidelines. These requirements describe how to treat, store or dispose of the waste. In addition, the regulations may also specify the amount of waste and time permitted for storing the waste as well as identifying specific administrative requirements, e.g., recordkeeping imposed on the generator, transporter; or on treatment, storage or disposal facility (TSD). These requirements may vary depending on the amount of waste present at facility during a specific time period.

Permits and waste identification numbers are issued by the states and EPA to generators, transporters and TSDs. These permits embody the technical and administrative requirements identified above for handling hazardous waste. In addition, a uniform hazardous waste manifest is used to trace the waste shipment as it travels from the generating facility to the TSD. A generator is required to first fill out the manifest identifying the volume and type of waste along with other information. This manifest travels with the waste and a copy is kept by the generator, transporter and the TSD facility. The TSD should send a copy back to the generator as notification the waste arrived at the anticipated location. This "cradle to grave" system has been designed to minimize unauthorized disposal of waste.

Clearly, the federal RCRA programs relies heavily on states who implement the RCRA requirements and/or state hazardous waste requirements. RCRA is essentially a program delegated to the states. When a state develops a program fully equivalent to the federal program it seeks authorization to run this program. A state program must at least meet the minimum federal requirements, but may also develop even more stringent regulatory criteria.

Along with federal enforcement authorities, state are to have their own enforcement authorities. These authorities generally include the authority to bring civil and criminal actions at the administrative and judicial levels. Enforcement activities may be aimed at individuals and companies not complying with regulations and who disregard monitoring and reporting activities. Further, a state or EPA may order a facility to perform a corrective action in order to cleanup a threat of release or release of a hazardous waste at a facility. Compliance with this subtitle is very important due to its impact and the enforcement potential.

Subtitle D-State or Regional Solid

Waste Plans

Even if a waste is not considered a hazardous waste under Subtitle C, it should not be left unmanaged. Subtitle D of RCRA addresses this problem of managing non-hazardous solid waste, such as, household waste, commercial refuse, various sludges and other forms of waste. The subtitle D program's goal is to promote the conservation and recycling of resources and help states develop proper solid waste management plans. These goals are met through the help of an EPA system for classifying solid waste disposal facilities and the development of a basic structure for state solid waste management plans.

Under this subtitle, solid waste disposal facilities (SWDFs) are considered "open dumps" and may represent sent a threat to the environment unless properly regulated. Federal and state technical regulations and standards are implemented to reduce the threat to human health and the environment. The states may even have more stringent regulations than the federal regulations. Since this program is also delegated to the states, the states should have a solid waste management plan which includes these regulations as well as incentives, capacity limits and enforcement authorities. As part of the state program, a state is to provide EPA with an inventory of those SWDFs that are in compliance with the appropriate regulations. This information may be useful to a business interested in knowing whether its waste is going to a compliant SWDF.

Due to the threat of release of substances into the environment and the threat of federal enforcement action, states have permitting programs to implement these regulations. A state may also have regulations for safely closing a SWDF. Both the permit and regulatory components are designed to help minimize the threat of environmental damage due to mismanaged SWDFs or "open dumps." Although this discussion may raise questions about waste management, it may provide a business with the incentive to minimize waste output and develop its own waste management plan!

Subtitle I Regulation of

Underground Storage Tanks

The Underground Storage Tanks (UST) Program is designed to manage over a million underground storage tanks which may contain petroleum products or certain hazardous substances.(1) The UST program contains federal standards controlling the operation of old and new USTs, however, a few exemptions to the UST program exist for certain tank sizes and contents. Although standards differ for old and new tanks, they generally include tank design and performance standards, notification requirements, leak detection requirements, financial assurance requirements and standards for closing out a tank. Further, RCRA has broad authority under which the federal or state agency may order the owner or operator of a facility to perform a corrective action such as a cleanup of an old or leaky tank. Funds are also available through the UST Trust Fund to cleanup USTs which may pose a threat to the environment.

Similar to other RCRA programs, EPA will delegate the management authorities to a state if it meets certain federal standards. Nonetheless, dual federal/state enforcement authorities exist even if a program is delegated to a particular state. However, a state is given notice by EPA before a federal enforcement action is brought.

Finally, RCRA also covers medical waste, however, due to the complexity of this issue, it is inappropriate to provide a discussion on this topic at this time.

Emergency Planning and

Community Right-To-Know

In the wake of the Bhopal incident and other emergency situations, Congress enacted the Emergency Planning and Community Right-to-Know Act of 1986 (EPCRTKA or EPCRA) in order to help prevent future incidents. EPCRA addresses this problem through the use of emergency planning, notification and reporting requirements.

Essentially, EPCRA is composed of the following four elements: 1. Emergency planning; 2. Emergency notification; 3. Material data safety sheet requirements

and emergency and hazardous

chemical inventory reporting

requirements; and, 4. Toxic chemical release inventory

reporting requirements.

Under EPCRA, state emergency response commissions (SERCs) and local emergency planning districts/committees (LEPCs) were established to help implement the EPCRA program. A primary mission of these organizations is to identify facilities subject to EPCRA. Although a facility may have been identified by the state/local planning organizations, one should understand why a specific facility is covered by the emergency planning and notification requirements. To trigger these requirements, the facility must have a substance identified by EPA as an extremely hazardous substance (EHS), or a CERCLA hazardous substance, toxic chemical, or, for some reporting requirements, a substance for which a Material Safety Data Sheet (MSDS) is required under the Occupational Safety and Health Act of 1970 (OSHA). In addition, if any of the EHSs are present at a facility above the threshold planning quantity, then this facility is subject to the EPCRA Section 302 requirements. The threshold planning quantity is two pounds unless specified. Even if a facility does not appear to qualify, a state may identify a facility after public notice and comment.

The local emergency planning committee (LEPC) is also responsible for preparing a comprehensive emergency response plan to deal with an emergency situation, including evacuation and training plans. A facility should designate a representative to participate in the committee s planning process and inform the planning committee of any changes at the facility. The State commission will review the plan.

What happens if a release occurs? The owner/operator of a facility must immediately notify the state and local emergency response committees if an EHS or a CERCLA hazardous substance at a reportable quantity is released from a facility at which a hazardous chemical is produced, used or stored. Unless otherwise specified by regulation, a release of one (1) pound or more is the quantity requiring the facility to notify the SERC and the LEPC. The owner/operator should provide as much information about the release as possible to not delay any form of emergency response. After the release, the owner/operator should submit a written report as soon as practicable to the appropriate SERCs or LEPCs.

A second major component of EPCRA is the requirement involving the material safety data sheet (MSDS) for a hazardous substance under OSHA. Under EPCRA the owner or operator of a facility who must prepare an MSDS must also submit the MSDS for each chemical or a list of these chemicals to the SERC, LEPC, and the local fire department. Upon request, a LEPC shall make the MSDS available to the public. Despite the need and demand for this information, some narrow exceptions to the definition of "hazardous chemical" exist which may limit the need to submit information on all chemicals. In addition, EPCRA has some limitations on the contents of the chemical list and the treatment of chemical mixtures. These limitations exist primarily to reduce the transmission of unnecessary information.

A third component of EPCRA is the emergency and hazardous chemical inventory forms. Owners or operators of a facility which must prepare a MSDS under OSHA shall prepare and submit an emergency and hazardous chemical inventory form (inventory form) to the SERC, LEPC and the fire department. The inventory form containing Tier I information had to be submitted by March 1, 1988, then annually to the SERC, LEPC and the fire department. This information generally includes an estimate of the maximum and average amount of chemicals in each.category present at the facility at any time during the preceding calendar year, as well as the location of these chemicals in the facility. Tier II information may be submitted in lieu of Tier I information. Again, this information may also be requested by the public. Finally, a new facility must have submitted the first form by March 1, 1990.

The fourth major element is the annual submission of the toxic chemical release form (Form R). Here, the owner or operator of a facility that manufactured, processed or used quantities in excess of the threshold limit in the previous year shall annually submit a Form R. However, the covered facilities must have 10 or more full-time employees and be classified in Standard Industrial Classification Codes 20-39. The first Form R submission was due on July 1, 1988. An owner or operator should contact the federal, state or local government to obtain a list of the covered chemicals and the minimum quantity of chemicals to be used at a facility to trigger the reporting requirements. Generally, a facility using 10,000 lbs. of a covered toxic chemical must submit the Form R information,

Information submitted by an owner or operator must certify that it is a reasonable estimate of releases based upon data available at the facility. A claim that some information is covered by a "trade secret" must not be frivolous and must be substantiated. As noted, if an emergency exists, then an owner or operator must submit a MSDS, an emergency and hazardous chemical inventory form, plus trade information to a health professional upon request.

Finally, federal, state and local governments may seek to impose civil and criminal penalties for statutory and regulatory non-compliance.


In 1980, Congress enacted the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), as amended by the Superfund Amendments and Reauthorization (SARA) in 1986. This statute is often referred to as "Superfund" because the act created a multi-billion dollar fund designed to respond to the release or threat of release of hazardous substances primarily caused by abandoned facilities (sites). EPA is to respond and remediate the worst sites first. The site determination is made through a complex prioritization system used by EPA.

This program is partially funded by a tax on certain basic chemicals. EPA may elect to use the fund to perform the cleanup itself or may instead take an enforcement action against the potentially responsible party (PRP). Under the enforcement scenario, the PRP is to perform the site remediation with its own money. The enforcement scenario saves the superfund dollars for those situations where the PRP can not pay or the PRPs are not know. In all scenarios, EPA involvement is required.

Generally, CERCLA provides for two types of cleanups: short-term removal actions responding to an imminent and substantial threat to the environment and long-term remedial actions. Since removal actions are designed to respond to an immediate threat, these actions may be initiated immediately or shortly after an assessment of the threat to the environment.

The second type of action is the long-term remedial action which is used to address the more complex problematic sites. Sometimes remedial actions are used after the short-term removal action is performed. Overall, these long-term remedial actions are much more resource intensive and require significant amounts of money. An average remedial action may cost 10-30 million dollars and take 15-20 years. Although these dollar values and the time allocation seems extreme, the contamination may be so extensive, often including groundwater contamination, that the current technologies limit the response time and prevent instant cleanups.

Once EPA ranks a superfund facility (site) and determines a cleanup is necessary, the cleanup process will include five major phases. This process usually involves federal, state, and local officials as well as the PRPs and the surrounding community.

The first phase is known as the remedial investigation/feasibility study (RI/FS). The RI/FS involves an assessment of the nature and the extent of the risk at the site based on extensive site testing (RI) and. an engineering study of potential remedies. Once the RI/FS is completed, the public is provided an opportunity to comment on the potential remedies. Next, EPA reviews the comments and decides on the final cleanup remedy. This decision is made in the Record of Decision (ROD).

The third and fourth phases are the remedial design/remedial action (RD/RA) which involve designing the plans for implementing the remedy for the site (RD) and performing the actual site remediation, i.e, implementation of the remedy (RA). After the remedy is essentially complete, certain measures are taken to maintain the effectiveness of the remedial action. This final phase is called operation and maintenance (O&M).

The remediation process has two discrete periods when EPA may negotiate with the PRPs to perform the RI/FS and the RD/RA. Depending on the success of these negotiations, EPA may perform the actions itself or use enforcement documents, e.g., unilateral or consent administrative orders and judicial settlement decrees which require the PRPs to perform the appropriate action. In some cases, PRPS are also required to pay past and future costs for activities related to the site cleanup.

Throughout this process, EPA tries to identify PRPs involved with the site. Since CERCLA's liability scheme is broad reaching, the following entities may be named as PRPs: current and past owners/operators; transporters; and persons who arranged for the disposal/transport/treatment of the hazardous substances, e.g., generators. Under this liability scheme, EPA could find a generator responsible for cleaning up the whole facility if the generator's hazardous substances can not be distinguished from identical or other hazardous substances at the facility. Nonetheless, EPA tries to spread the cost of cleaning up a facility among many PRPs if available.

After EPA has identified the PRPs, the PRPs should try to work with other PRPs to structure a scheme allocating site cleanup costs. The PRPs may avoid significant transaction costs by minimizing extensive negotiations and legal suits over cost-allocation disputes. PRP settlements with EPA and other PRPs is generally preferred over litigation. Often a settlement may include some form of protection, e.g., contribution protection, from third-party lawsuits as well as other forms of protection.

Clearly, this process is quite burdensome and potentially very expensive. Although past superfund sites already exist, it is hoped careful compliance witli federal, state and local environmental laws will reduce the number of future superfund sites. In the case of an oil or chemical spill,the National Response Center should be immediately notified. The 24-hour toll free telephone number is 1-800-424-8802.

The Rulemaking Process

When a government agency decides to issue a rule or regulation, it usually needs to go through the following five basic steps: 1. The agency drafts a proposed

regulation; 2. The proposed regulation is published

in the publically available

Federal Register or the equivalent

state or local publication; 3. The public is given approximately

30-60 days to provide

oral and/or written comments on

the proposed regulation; 4. After the comment period, the

agency will review the comments

and may revise the draft regulation

before the agency issues the

final version of the regulation;

and 5. The final regulation is published

and eventually placed in the Code

of Federal Regulations (C.F.R.)

or the equivalent state or local


Hopefully, this quick review of the rulemaking process will make you aware of your ability to provide input on a particular rule.


Again, this article provides a general overview of some of the major environmental statutes. It is not intended, in any way, to provide specific guidance on the applicability of these or other environmental statutes to a specific business operation. Clearly, a more thorough analysis of these statutes and other federal, state and local statutes and regulations is needed before making any decisions.

Pursuant to federal regulations, I am not receiving any compensation, financial or otherwise, for writing this article. I hope you find this article useful.

Remember, the earth and the environment are here for this generation and the future generations to enjoy and respect - please proceed with care!


(1) Tanks containing hazardous waste are regulated under sub-title C.

Fred Zimmerman works for the United States Environmental Protection Agency (EPA) in the Superfund Enforcement Division located in Washington, D.C. He is a member of the Pennsylvania Law Bar. He received a law degree from the University of Miami School of Law and an undergraduate degree in chemistry from the University of Pennsylvania. He has worked in the chemical industry and represented the paint industry before working for the EPA.
COPYRIGHT 1992 National Society of Public Accountants
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Copyright 1992 Gale, Cengage Learning. All rights reserved.

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Title Annotation:information on different environmental protection laws
Author:Zimmerman, Fred
Publication:The National Public Accountant
Date:Jun 1, 1992
Previous Article:The impact of government regulations on small business.
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