 All right, today is November 10th. This is a meeting of the, a further record, a meeting of the lab testing and product safety subcommittee. In the room here, we have myself, Kyle Harris from the cannabis control board, and Nellie Marble from the cannabis control board. And we have two members of the public. On the phone, we have Kim Watson, Gary Jigar, and Sherman Hom. I think we have three, but one of them is separate. Three members of the public, excuse me. And Sherman Hom, an expert in this field, has been invited to participate in this meeting. From, where are you Sherman, in Massachusetts, New Hampshire? Sorry, New Jersey? Right, medicinal genomics is based in Massachusetts, and I'm based out of New Jersey. New Jersey, working remotely. Fantastic. Well, I just wanted to give some table setting. Gary, I'm gonna turn it over to you. Maybe if you wouldn't mind giving us an update on what you said, Kim, the other day and how we can hopefully move forward after we have a conversation. Yeah, okay, very good. Thanks. Kyle, I didn't send Kim anything additional beyond what we talked about originally. It just is sort of on paper. And that was using the framework that under Title VI, the Canvas Quality Control Program lays out what is to be tested for for hemp. The levels would be established in rule and non-statute, and using what was already in statute for hemp, the Canvas Quality Control Program, and also incorporating the standard operating procedures that Kim had developed for Oregon for sampling. So the sampling protocol and criteria that Kim developed coupled with the Canvas Quality Control Program as laid out in statute and in the hemp rules for what gets tested and when. And additionally, I appreciate Sherwin's input on actual levels of meaningful action levels, I guess is what I mean to say there. And I believe we should make a recommendation that those levels are incorporated in rule, but not in statute. So I think the level should be set by procedure so the control board can modify and change as new research comes to light. So I went through all the guidance that you sent, the tables basically. And so these tables, as I understand, you want to adapt them for cannabis. Yes? Okay. And then, so some of the language will all change. And I do have a couple of questions. So I noticed, which is interesting in your note four under table one, you do have please apply the standards articulated in the Vermont Hemp Program for potency compliance. And you do talk of a COA, which we talked about last time, you know, as being, were you planning on doing any type of database for reporting of these people sending in their tests or were you gonna, or did they just do it by paper right now? Right now it is by paper, but under a proposal that Trace presented to us, Trace would use a QR code on a product and all those test results would be available to the public. But I didn't want to imply that the control board should use the system that they were going to force one direction as far as database goes. Right, right. But some kind of QR code system to, so the registrant could upload that test to whatever you're gonna store it in or do whatever. Okay. Yeah, that's the, that's the plan. Yeah. So the action limits too, that you have presented in table seven, have any of the labs had a problem meeting the, I guess that level? Because I noticed you're a lot lower than some other states or some other on the pesticide table. And then, but again, it's only those, do you have any known use of dimethylate or carboforan in the state? No. Okay. No. Because I was wondering what limited you to that list. Um, knowledge of what does get used. Okay. In the state sort of, we are involved in the licensing and registration of the applicators for the current dispensaries. And, you know, carboforan, nobody's going to use that as furan than. There isn't any even sold in the state basically. In the list, I think that you see other states use, especially the West Coast states, you see a lot of older chemistry because I think a lot of unregistered chemistry is still coming up from south of the border. We don't really see that here. Folks are trying to use as a general rule, as light of chemistry as possible, trying to be as organic as possible. My concern is that maybe some of the traditional fungicide chemistry gets used. So you'll see that those maintain on there. But we did adopt that list from other states. And it's not as long as... Yeah, no, I know. And I would have to look at the fungicide names. I don't know. Maybe Sherman knows some of them. But I'm not sure. One of the ones that seems to be used, I'm not a pesticide expert, but one of the products that are used a lot is Eagle 20. Yeah. And then have a little bit of ethanol. So you have that on the list, right? Yes. Yeah. And what I'm gonna do, I'm gonna make a notation to send you the list of approximately 25 pesticides that were detected by some laboratory testing cannabis products in the United States that were found in marketed products. So you can just take a look at it. I'm not saying it's gonna be used in Vermont, but to be aware of it. And that one of the biggest problems, I suppose, well, everyone knows, is the mold growing on cannabis because of the high temperatures and humidity used in indoor grows. It's a big problem. And I found nine pesticides that were not tested by any state that were found in cannabis products. And so you might want to cross check that one too. I'll send you my poster. Please don't share it with anybody because it hasn't been published anywhere because it was suppressed by the state of New Jersey. Don't ask me why it was. So just looking at the action limits. This is, I'm assuming these are your action limits for hemp as well. Yeah. And speaking of a maze of the nil, I never can pronounce them correctly because they're always driving me. You have 0.04 and a lot of the other states have 0.2. Do they have any problem getting down to 0.04 in labs? No. Okay. No. And why that's so low just because of that concern? Yes, yeah. Okay. The thing is that we're using LC or GC math specs generally for the pesticide work. And we can see some parts per trillion generally. I know on the HPLC, but I didn't think on the GCMS, but they are getting better and better. So I mean, I don't know what could be on the lab. Our lab can generally is looking at residue levels from drift. Okay. So we're, you know, and it's small particles that do drift. We look very, very low. I have to figure out, I have to go back to my notes and figure out why we made that decision. If it is on the mycobutanil is because the other states were using a tolerance and ingestion tolerance in California is doing some of the pyrolysis work for inhalation. Yeah. And I saw some of the early numbers coming out of there. And I think that is why that number is low. It's not even published yet. Okay. This one is not, oh, so is amizanil, I-M-A-C-I-L-I-L. Yeah, that's 0.04. Clopyrifos, I can understand, but I didn't know there was as much work on that other one. And then the amidicloropyrid, you know, your level is so much higher than most states. Why was that? The human toxicity is very low on the neonicotinoids. Okay. Because you've got five PPM and I know to settle a lot of the other states are at 0.4. Right. And again, back to the inhalation studies, the neonicotinoids are sort of synthetic nicotine-type compounds. Yeah. And there's very low human toxicity, very toxic to bugs, but very low, I mean, very high or low in terms of toxicity, I think has the reverse, the inverse relationship. Okay. And also, is that true for your residual solvents? Not many pentanes are used and only the ones listed? I haven't looked at what the product tables are saying in this state. Yeah. And that's basically, we have a program we don't allow hydrocarbon extraction, but there are some after extraction, processing steps that do use hydrocarbons, solvents. Yeah. That's why there's a number of things that are there. But no pentanes and no, so, or the butanes aren't on there. Correct. And, because there should be, there should be none. Yeah, yeah. I don't know if we, if the state will allow hydrocarbon extraction of high THC cannabis and if so, then the butanes should be on there. So should we make that recommendation that maybe, or the, yeah, at least the butanes? I imagine. Even if they're not allowed, we should probably check because they're the most common. Yeah. Well, it, I mean, maybe it seems to me that most of the processes are either using CO2, butane or ethanol. Yeah. With the extractions. And by stat, you know, I can't remember all the statutes for all the different states, but I mean, Vermont is going to allow processes for early year. And then you're going to allow the different methodologies to extract or concentrate, I mean. Yeah. We may want to add that because although it seems, the note seems interesting, any solvent not permitted for extraction of the hemp rule. And then maybe permitted in the recreational rule. Yeah. Anyway, those were only my thoughts on those tables, but other than that, I had no questions about them. I haven't seen the tables and I just wanted to ensure that unless I missed it somewhere to ensure I understood you carry it concerning the microbial recommendations that you made. So my record would be that you said something about the hemp. Yeah. The recommendations would be that the control board used the levels that you've established because our levels were weaned from other states and they didn't necessarily do the health impact study that you've sort of taken the time to do. I guess what I'm saying is our numbers are based on what other states were using in those numbers. The other states were using more based on what they could see and setting an arbitrary threshold. Years are far less arbitrary and I think more useful. Right, I've watched the industry try state by state to make regulations to record microbial testing all the way back to like, I mean, 2012. Everyone started with a table that was published in the monograph in which the monograph in the footnote says, we do not intend these recommendations that we simply gleaned from various organizations throughout the world that you should just use for cannabis because of the unusual matrix, but all the states started doing that and it was a piper effect. And then many people or many regulators thought that, well, let's just take cannabis. Oh, it's a food. We'll start borrowing it from the USP, you know, pharmaceutical or food. It was like all the leader on that route. Being a scientist, I wanted to comb the literature and look at some states that did the same thing and find the pathogens that actually impacted cannabis users and the fact that a phenomenon is occurring amongst early states that have formed various task force and subcommittees to read, look or reexamine their microbial testing and they're circling back and adding these pathogens and doing it correctly. I see too many states that just arbitrarily say pathogenic E. coli without thinking it through. There's six different types of pathogenic E. coli and there's no single test that can detect those six of them. We got to go with the most toxic one. I mean, pathogenic one, which I checked with the laboratory director who is an MD at that start where I used to work in New Jersey. He totally agreed from a clinical viewpoint on picking, you know, stack E. coli and sell them out a lot of is, these are for sanitary purposes. And then the Aspergillus, there's, it's in the literature, it's killed people. Going to Florida, I just want to mention in Florida, an unnamed multi-state operator producing cannabis flower released product into the Florida medical cannabis industry that was contaminated with one of the Aspergillus pathogens. So you have, and I'm trying to track down whether a lab gave a false negative for this organization simply trying to slip it through. You got to be real watchful. So that I'm, I know you guys are referring to table five. And what was, what were some of the action limits? I didn't see those action limits proposed. Perry, for the trim, is it all different or what, what are we looking at? Yeah, they're not proposed other than we've gone back and forth on that level, yeah. Well, are we speaking about South Stack and the four Aspergillus pathogens? Or are we speaking about something else? Something else, we hadn't. Oh, okay. Oh, okay. The human pathogens we hadn't considered. Okay. Yeah, yeah, like if you're in a compost tea or a live manure or some processor is unsanitary. We hadn't really got there. We were focusing on micro toxins that were Oh, yeah. From botrytis or Aspergillus type. That was, was our thought and our focus, but you've included the human pathogens that we didn't, we weren't thinking about at all. Well, the thing is, is that one of the interesting pieces of literature I came across is that a lot of people may surmise that through burning or vaporizing cannabis that spores are destroyed. You're not. I have purified literature that shows that spores survive that process and they're inhaled and you have some individuals that are immunocompromised. And I even found one piece of, or one purified literature that showed that somebody that worked at a dispensary and selling, I mean Bakersfield, California, which is in the Big Valley. He was not immunocompromised and he was infected in the lung with another fungi. I forget which one. So, but anyway, so. Did he live? I don't remember. I mean, it's just, I wish I could. You can see, you know, you can see my white hair here. My memory is just that it's good. I'd have to look into that one. So what I hear you saying is that there's some added testing that would be the parameters for the cannabis side of things to this table five. Well, I'm a proponent of what I simply, I guess my cliche is the California model is that ever since they had medical and now they have both medical and adult uses that they've championed the, the list past the testing of just these six human pathogens and they're sticking to that and other states have done the same. I believe Alaska has done that. My trusty table is a little dated. It goes back to 2019 because I had to shut everything down and shift all my efforts towards COVID-19 the last 18 months I went with the Department of Health in New Jersey, but let's say. Okay. All right, we'll go forward that on. So I'll see what those are. Okay. So I remember looking at the Vermont hemp microbial testing and it had, let's say, total aerobic and total yeast and mold. Yeah. Um, various types of products. Mycotoxin, total of A-flactoxin, B1, B2, G1. Well, I see those are the mycotoxins. And then, Orc-Rotoxin A or. Right. No, one, two, three, four. Those represent the mycotoxins or aquatoxins that do, that are carcinogenic or otherwise impact humans. They may not necessarily be the correct one. Some of them only grow on grain. But it was a very fairly easy sweet to analyze for in the lab. So we kept them all. Right. That's what seems like everyone else's. That's what we started with back in 2012. Yeah. Where? With the help of DOA. But I guess what I'm asking Kerry is this, so you're recommending this total aerobic and total yeast and mold as we should have for him? So Sherwood, I really appreciate the work you've done. And I'm almost, I'm looking for your expertise to guide us there. My sort of expertise is the pesticide side and heavy metal. And then very much we lack. Right. Well, it's for these things. Same here. Well, I keep saying the same thing to many regular leaders. You know, all over the country is that, is that whatever action level you have for any total count, like what you have for the hemp, you know, total aerobic or total yeast and mold is that a commercial laboratory that has been licensed by the state of Vermont will perform some kind of test. And let's say the action level is above your action level. Then there's going to be a consequence to that grower, either remediation, I mean, diverting that batch to concentrate and to see if people are remediating the dried pure cannabis and retesting or destroying the crop. And maybe I'm too simplistic, but I keep saying to myself as a scientist, I really didn't get any information from the commercial laboratory that the batch sample that was tested had any deleterious human pathogens in the sample. So I'm not a proponent of total counts. As you know, in the original monograph that has been read by so many cannabis regulators, which is that American herbal pharmacopoeia published in 2014 indicates that if you read that section it says that total counts should not be utilized to fail a batch and no one seems to have read that part. And they're in the process that had communications with them and then they're in the process of rewriting and coming out with a new addition and they've asked me to write microbial section that at the time I was busy with COVID-19. But there are differences of opinion by many state regulators throughout the country. But that's the only thing that makes sense to me and others that medicinal genomics is to start with that. With the interview literature, the ideal thing is something that I don't think will ever happen. I may have mentioned that in the previous meeting and I'll just briefly summarize by saying it would be the most ideal thing is to get samples to be tested, it's called microbiome, hogenome sequence, cannabis samples from all over the country and to collect all of that information and identify truly what are the pathogens found that has grown in cannabis throughout the United States of America. Then those are the ones that should be looked at. But that's never gonna happen. That is a major project that could be funded by the federal government or something like that. We're talking lots of money, but I think the ideal at the same time. But we start with the peer reviewed literature and then monitor that literature and add more human pathogens more and more information comes out. But that's why I start with these six because in Oklahoma, for example, because I attend many meetings throughout the country and listen in Oklahoma, they had some problems with Salmonella, for example. And where did it come from? It's a little funny, you know. The grower let his pet of Juana freely roam in his indoor grower. Oh, wow. So it's that kind of thing. Yeah, everybody's thinking that people are washing their hands and then they handle the cannabis inside the grower, but it could be from other reasons perhaps. But I'm sure that Vermont is gonna have a much better regulated industry than Oklahoma, which is the most out of hand. They have 13,000 licensees. They have no caps for growers. Wow. There's 13,000 and only 31 teams of inspectors. It's a horrifying situation to have there. I can't imagine. I know how they are in regular pesticide work. Well, that's what I recommend. I don't really recommend anything else. I can get behind that, I don't know. Those are my reasons. The thing also, in terms of the accuracy, even when you try to do total counts, any laboratories end up using auger plating techniques, but one has to really examine this cannabis matrix. And again, I go to the peer review literature is that there's multiple publications that indicate that the different cannabinoids are anti-biotic, anti-biotic properties. So you've homogenized the cannabis sample and then you plate directly on an auger medium and when you have some of those cannabinoids that you've put on the plate and so you have some antibiotic, you're gonna get lower counts. People don't think about that. Also, the human pathogens that have killed people, they're endo-fights. It's another thing. These cells live inside the plant cells and so plating is never going to identify those human pathogens, the aspergillus and even the enterics like salmonella E. coli. I can provide you with peer-reviewed literature that shows they have been found inside plant cells. These are some literature that's just coming out the last few years. Mechanisms have not been identified yet. And again, that's why I've had a five-year decade-long career in microbiology besides my graduate degree being in microbiology and I started plating on auger plates as a sophomore in college and I've been through the PCR, I've been through hoaching and sequencing and I was a subject matter expert for the state of New Jersey and that was a recommendation I gave to the Medical Cannabis Program that was accepted but as soon as I disappeared from the scene, it got into another direction but that's up to that regulatory commission that I hope to see the light in the end. So that's, I think what I sent to Gary was my last modification with all the peer-reviewed literature and everything. Very good. So are you thinking of adding what he listed there as the aspergillus pathogens and the salmonella species and the toxin-producing E. coli? I do think that makes a lot of sense to him. Like I said, we're getting invaluable input from an expert and this is out of my depth. I'm, you know, like, it's not good. Yeah. The only place I deal with my co-toxins is the feed regulatory program and that's why you see what you're seeing on the cannabis side. Drawing on expertise from one of my other program or, you know, standards from one of my other programs but we have a strong recommendation from a depth of knowledge that I don't have and I think we do use your SOPs, the outline that the hemp program has developed with the modification on the pathogen side of exactly what Sherman has proposed. Nice. And also the original consultant, maybe that was mentioned in the last minute, the original consultant wore the state of Vermont when it was only a medical cannabis program. I found some document that was provided to the state of Vermont back a few years that recommended exactly what I recommended. And I think I shared that with someone at the state. I can dig that up too. Carrie, I think Stephanie had mentioned that she was aware of the document that Sherman was referring to. Yeah. I haven't seen that document though. Right. All of it. That document that NSL put together, that was another one, Monique McHenry and his name just slipped my mind but they were one of our dispensaries and did put together a document years ago. Oh, I see. I thought it was an independent consultant. It was a dispensary, one of our dispensaries. But currently the dispensaries, there is no consumer protection component to the medical program at all. Right, yeah. But that occurred in other states until it was legislated. Like Arizona didn't have any protection for consumers for upwards of seven or eight years. And it was finally legislated. And then they had a big fight there between the leaders in the industry and so forth and so on. And then they came out with some testing regulations. So, right. And so those are, you know, I put all my thoughts in those words and we have that much more to add. And I've counted as many, I think now 12 states that have either began with or circled back and are adding these pathogens. And more and more states are automatically adding, well, salmonella has never been a problem. Everybody knows that every species of salmonella that exists on the earth is pathogenic. But for E. coli, I got a laugh, I'm sorry. We see regulations that just simply say E. coli and with an action level of less than one. And anybody can go into Wikipedia under E. coli and see that not all E. coli's are pathogenic. So you might detect a non-pathogenic E. coli and have a consequence on a grower. That's state of affairs. I just want to, that's why I've been, I was hired by MGC and wanted to do this as a government official, but I was never allowed to. And now I simply communicate with every state they like to communicate with and try to bring science into their programs. That's always been what I've known in serving the public for 20 years in public health. I want to protect the consumers and the patients. That is what I live for. I think your timing was perfect for interaction, interacting with Ramon and really appreciate everything you're offering. But you're most welcome. I also want to say to you, and thank you very much for inviting me to share with what I do know because not every state is as welcoming. That's just the facts. I think Ramon cares a lot about public input. So across the state, so. There are some very opinionated regulators, even a scientific subject matter experts that entered the cannabis field without humility. I don't know anything about cannabis in December, 2011 when I was asked to be the program project manager to start the first cannabis testing lab and know a thing. And I've learned one thing in my scientific career and that is to go into the literature and keep my mouth shut and learn. I've been learning for almost 10 years. And I continue to learn as I learned from experts and pesticides and metals and so forth and so on. And the cannabinoids too. I have one pet peeve about states that put in their rules what cannabinoids must be tested for, and of course there's the big four, but I hate it when they list a neutral form without listing the acid form because greater than 90% of the cannabinoids stored in trichomes are in the acid form. Cannabinoids are quantitatively determined, utilizing HPLC, which is formed at a new temperature and is not gonna convert any of the acid forms into the neutral forms. I see Reagan-Langer's making that error because they're copying each other, but that's not my purview. I have to focus on the microbial testing. That's one thing that I have to do, but when I do have the opportunity, one-on-one I do mention it. That is something that we've been aware of all along, so as we, yeah. Not everybody is, Kari, not everybody, you know. So Kari, go ahead, Kari. Go ahead. I was gonna say, do we wanna, I'm trying to find a natural conclusion to the substantive conversation here, and I'm way out of my element because I don't have the expertise that the three of you have when it comes to determining these action limits for various, various pesticides and others, microbials and stuff like that that are on all these tables. I'm trying to find a logical ending to talking about procedure as it relates to getting a tangible document to the full board and how might that look and timing and so on and so forth. So, but if you have a more substantive comment, Kari, before that, feel free to go. I don't, Kyle, you in the board and we collectively all, we have all the pieces, we just haven't put them together in a recommendation to you. Yeah, that's what I was wondering to, is it, I'm wondering how you wanna go about that. I certainly recognize that there is, that the information is all there, that the puzzle or Lego set just needs to be put together and delivered. So, I wanted to talk about what works considering that this is supplemental to your day jobs. I don't wanna overly burden either one of you, but who might be best positioned to get a draft of all this together and does it make sense to have another meeting next Wednesday to talk about that draft and get its final approval from the two of you and square up any loose ends or do you think that can be done via email? I think the goal is hopefully I can take some of this conversation to our board meeting next Friday and make sure that the board examines the proposal and raises any concerns so that hopefully, and I see David's watching, we're trying to get certain rules pre-filed for the end of the month. So, I just wanna be conscious of time and for the folks listening or for the folks in their room, there will be many more comment periods down the road. So even if the board does recommend that we take the subcommittees work next Friday, there will be multiple times to express differing opinions when it comes to these action limits and allowables and so on and so forth. So what I am going to recommend that the board do is adopt a framework similar to what's in statute in Title VI about the Canvas Quality Control Program and what to test and then the action levels and what like list of pesticides be done via either rule or procedure so the board can modify them without going through changing legislation and what those procedures. So you can go ahead with a proposed rule and then have in your folder or back pocket if you will the outline that we're proposing and that's that the Vermont adopt the SOPs and procedures that Kim developed for Oregon as far as taking a sample and getting those samples to the lab, I'd even propose that the board hire Kim to do training of field inspectors and the criteria that gets tested for is what's outlined in the HEM program with the modification of throwing away what's in there completely that we have for microtoxins and substituting what Sherman has proposed as the most appropriate human pathogens or pathogens to be tested for in Canvas. The SIGs if you will. Right and the action levels for that is it's non-detected. It's president's absence, it's that is always the action level in all states that have adopted testing of any of those six human pathogens, always non-detected. So period Kim can we get that kind of all packaged into one document including the SOPs and so on and so forth by like next Wednesday? Is that a timeline that might work? A couple of weeks ago I kind of like volunteered to do that. Some of the stuff has gotten lost in my email but I have Sherman's document. Kim, I apologize for asking but can you resend me those SOPs and I'll put it all together in one document by the end of the week. That would be fantastic. Kim, you're muted. Sorry, I was, so what I hear is you're going to take, you need to take the whole act and reproduce it with the words or what are you actually proposing that you have to do? Because I looked at these tables and this is pretty much the testing and the action limits with the modifications that we've talked about today. What else do you have to produce for them? Just the whole rule or what do you have to do, Gary? I'm like, I feel bad. I don't, I don't, and as far as the rule goes, Kim, I'll send you a copy of the statue. Okay, I have that, I think. I think that's what they need to do. Okay. It's going to test for but not when to test for it. It's just, it basically says that the cannabis control board would take the cannabis quality control program language from Title VI. Okay. So that's all they need for rule. And then the action limits and all that would be done by procedure. So if a new, if new chemistry shows up, they can add it to the list. Right, I, yeah. Or removal chemistry without having to go to the legislature. That's the best way to do it. So then you're going to do that by the end of this week. Do you want to, or next week? Yeah, no, I'm going to do it probably Friday. Okay. A 930 meeting and then a whole until noon. So from 930 noon, I can work on that. So we tentatively just schedule a meeting and hold it on your calendars for next Wednesday in case we need to clear up any loose ends. And if it's not needed and it's going to be done via email, we can cross that bridge when we get there. Do you want to, were you going to set up another standard operating procedure with like Vermont's information? And because I think you guys had a little bit different incremental sampling when I looked on the website, but were you just going to set up an SOP or use the generic one from Oregon or how do you want to do that? Either way, worse. I've used the generic one from Oregon and just let the board map their applications. Yeah, let me see if I can order. Okay. How about, does that work for you? Yeah, that is an open document that they made free to everybody. It's been on their website for ages. Okay, well, I'm talking with Nellie. We might have a, okay. She says, no board meeting next Wednesday. Okay. So does Wednesday get noon again to put on your calendars and hold that for the 17th? Work. I'm trying to think, I'm actually going to be away. And if I have to take someone to the airport, I may not be available or I'll have to, I can call in from, I'll let you know if I can call in or not. Kyle, this is just two of us and we've already expressed to the board whatever intent is. I think we can accomplish, Tim and I can accomplish this and keep Sherman involved as well to make sure we don't screw up his edition. We can accomplish this over email and I'll email, include everyone on this invite on the email I send out Friday and we can go from there. So you officially have a proposal from us but don't have it in writing yet. I think we can tackle it via email. Yeah, absolutely. That sounds good. And I can follow up what you carry as needed as well but I appreciate everybody's time here today. I think we're getting pretty close to moving on to the next phase. Last call for public comment? Yeah, I'll be back for the following Wednesday if you choose to, that distant. Great, yeah. I saw David just jump in really quick. David, do you have the floor? Real quick, Carrie, if you can just keep me on those emails as I'm trying to put this into real language, that'll be super helpful. Excellent, thanks, David. Thank you. All right, well, we can end this a little bit early, 12.54. Thank you, everybody, looking forward to Friday. All right, thank you. Bye. Bye. Thank you very much. Everybody have a great week. Bye.