Chapter 8.11 — COMMERCIAL CANNABIS FACILITIES

The purpose of Chapter 8.11 is to create public health regulatory requirements to ensure that commercial cannabis activities are conducted in a manner that protects the health and safety of the consumer and the public.

(Ord. No. 7326, § 2, 6-5-2018)

Cannabis facilities that have approved backflow prevention devices as required by Title 17 of the California Code of Regulations shall maintain a public health backflow prevention device permit issued by the department for each device, and shall have each device tested at least once each calendar year by a certified backflow tester. Records of backflow prevention device test(s) shall be submitted to the department using the form provided by the department.

(Ord. No. 7326, § 2, 6-5-2018)

Commercial cannabis cultivation sites shall meet all health protection operating criteria for the cultivation of cannabis as required by state law and regulations promulgated by the California Department of Food and Agriculture and local laws and regulations.

(Ord. No. 7326, § 2, 6-5-2018)

A.

Retail cannabis facilities shall meet all health protection operating criteria for the sale of cannabis and cannabis products as required by state law and regulations, and local laws.

B.

Retail cannabis facilities shall operate in a permanently constructed structure and shall not operate from a vehicle or non- permanent structure. Retail cannabis facilities may conduct cannabis and cannabis product delivery services, as authorized to do so by this code.

C.

Permitted retail cannabis facilities shall only store, hold, or sell cannabis and cannabis products approved and permitted by the state. Permitted retail cannabis facilities are prohibited from selling or giving away cannabis-infused beverages in ready- to-drink form.

D.

Permitted retail cannabis facilities shall not receive, store, hold, or sell cannabis or cannabis products unless the cannabis and cannabis products are labeled and packaged as required by state law and regulations.

E.

Permitted retail cannabis facilities may not operate as a permitted food facility, and may not share an entrance with a permitted food facility.

F.

Permitted retail cannabis facilities shall not sell or provide alcohol or tobacco to any customer or the public.

A permitted retail cannabis facility may not hold an alcohol license from the department of alcohol and beverage control.

A permitted retail cannabis facility may not hold a state or local tobacco retailer license.

G.

Permitted retail cannabis facilities are prohibited from giving away any amount of cannabis or cannabis products and are prohibited from providing coupons as part of a business promotion.

H.

Permitted retail cannabis facilities shall not allow the on-site consumption of cannabis and cannabis products by any customer, person or employee.

I.

All TCS products, extractions, concentrates, and infusions, and cannabis products intended for human consumption must be refrigerated at temperatures of 41°F unless otherwise approved by the department. Retail cannabis operator shall follow the manufacturer's requirement for safe storage of such products.

J.

Permitted retail cannabis facilities shall not store, hold, or sell cannabis or cannabis products unless the cannabis and cannabis products are obtained from an approved source. Permitted retail cannabis facilities shall demonstrate all cannabis and cannabis products are obtained from an approved source by providing sales invoices and shipping manifest documents to the department upon request for all inventory held at the facility.

(Ord. No. 7326, § 2, 6-5-2018)

A permitted retail cannabis facility shall display a health warning sign in a conspicuous location at eye height at the point-of- sale counter. The sign shall be approved by the department and in a font that it is easily readable to customers.

(Ord. No. 7326, § 2, 6-5-2018)

A.

Any person proposing to apply for a public health permit for a cannabis facility, or applying as a new owner of an existing cannabis facility shall submit an odor management plan along with the submission of a public health permit application or plans to the department. The odor management plan shall describe sufficient processes which, if implemented, will prevent odors from the cannabis facility from being detected by a person outside of the facility or indoor cultivation site.

B.

The odor management plan shall include a detailed description of the ventilation system used by the cannabis facility, including, but not limited to, how the ventilation systems prevent odor from escaping the facility or indoor cultivation site and how to mitigate the noxious fumes or gases.

C.

The cannabis facility operator shall be responsible for the development, implementation, and maintenance of the odor management plan. Odor mitigation practices shall be based on industry-specific best control technologies and best management practices. The plan shall include the range of odor mitigation practices to be deployed to control odor-emitting activities, sources, and locations, how and when these practices will be deployed, and accounting for any identified odor- emitting activity.

D.

The permittee, operator, or person in charge of a cannabis facility shall maintain, and provide to the department upon request, all records relating to odor management, including, but not limited to, system installation, maintenance, any equipment malfunctions and deviations from odor management plan.

E.

The permittee, operator or person in charge of a cannabis facility shall maintain records of odor complaints received and response actions thereto.

F.

If an inspection or complaint investigation by the department reveals any deviation from the odor management plan, such deviation shall be a violation of this chapter.

G.

If an inspection reveals that the existing odor management plan does not effectively mitigate odors emanating from the cannabis facility or cannabis facility's cultivation site, the department shall provide the operator or person in charge with a notice of deficiencies. The operator or person in charge of the cannabis facility shall be required to submit a modified odor management plan within a reasonable amount of time, as determined by the department. Failure to submit a modified odor management plan within the required time period shall be a violation of this chapter. Failure of an operator to submit and implement a modified odor management plan may result in the suspension of the cannabis facility's public health permit.

H.

When a modification is made to a cannabis facility, or the facility operation, that has the potential to impact the nature or degree of odor, or affects the control of odor, the cannabis facility operator must update its odor management plan within 30 days of facility modification. Failure to submit an updated odor management plan within 30 days of facility modification shall be a violation of this chapter.

(Ord. No. 7326, § 2, 6-5-2018)

A.

Any person proposing to apply for a public health permit for a cannabis facility, or apply as a new owner of an existing cannabis facility shall submit a waste management plan along with the submission of a public health permit application or plans to the department.

B.

A waste management plan shall address the storing, handling, disposing and reusing of all waste by-products and shall characterize the volume and types of waste generated for all commercial cannabis activities in compliance with the best management practices and state law and regulations.

C.

A cannabis facility shall not sell or otherwise transfer title of cannabis waste, except as permitted by state law and regulation.

D.

All cannabis and cannabis products that a cannabis facility intends to render into cannabis waste, whether voluntarily or directed by the department shall be held on the premises in quarantine for a minimum of 72 hours. The cannabis facility operator shall affix to each batch the required document(s) with batch information and weight. At no time during the quarantine period may the cannabis or cannabis products be handled, moved, or rendered into cannabis waste. The quarantined cannabis and cannabis products are subject to inspection by the department.

E.

All garbage and refuse on the cannabis facility premises shall be stored in nonabsorbent, water-tight, vector resistant, durable, easily cleanable, galvanized metal or heavy plastic containers with tight fitting lids. No refuse container shall be filled beyond the capacity to completely close the lid. All garbage and refuse on the premises, whether mixed with rubbish or other material or not, shall not be accumulated or stored for more than seven calendar days, and shall be properly disposed of before the end of the seventh day. All waste, including, but not limited to, refuse, garbage, green waste and recyclables, must be disposed of in accordance with state law and regulation, and local law. All waste generated from commercial cannabis operations must be properly stored and secured, whether in the control of the cannabis facility operator or not, in order to prevent access to the public.

F.

The cannabis facility shall render cannabis and cannabis product into cannabis waste before removing the cannabis waste from the premises and shall be recorded on video, placed in the cannabis facility's refuse bin or transferred to a waste disposal facility approved by the state. All cannabis waste shall be rendered unusable and unrecognizable by mixing, grinding, and incorporating the cannabis waste with a non-consumable material or by incorporating any nonhazardous compostable material so that the resulting mixture is at least 50 percent non-cannabis waste by volume. The cannabis waste shall be tracked by one batch at a time and the cannabis facility shall not comingle different batches into cannabis waste.

G.

After a cannabis facility operator renders the cannabis and cannabis product into cannabis waste, the cannabis facility operator shall do one of the following with the cannabis waste:

Dispose of the cannabis waste at a manned and fully permitted solid waste landfill.

Deposit the cannabis waste at a manned and fully permitted compostable materials handling facility or operation.

Deposit the cannabis waste at a manned and fully permitted in-vessel digestion facility or operation.

H.

The cannabis facility operator shall use the track-and-trace database and onsite documents to ensure the cannabis waste materials are identified, weighed, and tracked while on the cannabis facility premises and when disposed of or deposited. The cannabis facility operator shall enter the date and time that the cannabis product was rendered into cannabis waste and the weight of the resulting cannabis waste into the track-and-trace database.

I.

All cannabis facility operators shall maintain accurate and comprehensive records regarding cannabis waste material that account for, reconcile, and evidence all activity related to the generation and disposal or deposition of cannabis waste. The cannabis facility operator shall obtain a record from the solid waste facility or operation evidencing the acceptance of the cannabis waste material at the facility or operation. The record must contain the name and address of the operation or facility, the date, the volume or weight of the cannabis waste accepted, and the name and signature of the person in charge of the facility or operator who accepts the cannabis waste. Once the cannabis waste is accepted by the solid waste facility, the cannabis facility operator shall input the date and time of the disposal or deposition of the cannabis waste at a solid waste facility into the track-and-trace database. These documents are records subject to inspection by the department.

J.

All commercial cannabis operations that utilize and generate hazardous materials or hazardous waste shall comply with all applicable hazardous material regulations, including, but not limited to, hazardous waste generator, underground storage tank, above ground storage tanks and hazardous materials handling requirements and maintain any applicable permits for these programs from the Pasadena Fire Department and/or Agricultural Commissioner.

(Ord. No. 7326, § 2, 6-5-2018)

A.

A cannabis facility shall ensure compliance with the requirements for record keeping as required by the state and local enforcement agencies.

B.

A cannabis facility operator shall make such records available upon request by the department.

(Ord. No. 7326, § 2, 6-5-2018)

A.

A permitted cannabis facility shall utilize the track and trace system as required by state law and regulations and local laws.

B.

A permitted cannabis facility shall make track and trace system records available to the department upon request.

(Ord. No. 7326, § 2, 6-5-2018)

A.

The city health officer shall have authority to exclude any cannabis facility employee that handles edible cannabis and cannabis products from any cannabis facility conducting operations, including, but not limited to, cultivation, extraction, preparation, manufacturing, distribution and testing, if the employee is diagnosed with an infectious agent specified in

subsection (B)(1)—(8), and the employee is either symptomatic and still considered infectious, or is not experiencing symptoms of the illness associated with that agent but is still considered infectious.

B.

For purposes of this section, "illness" means a condition caused by any of the following infectious agents:

Hepatitis A virus.

Salmonella typhi.

Salmonella spp.

Shigella spp.

Entamoeba histolytica.

Enterohemorrhagic or shiga toxin producing Escherichia coli.

Norovirus.

Other communicable diseases that may be transmitted to others through the handling of edible cannabis and cannabis products.

C.

The person in charge shall do either of the following:

Exclude an employee that handles edible cannabis and cannabis products from a cannabis facility if the employee is diagnosed with an infectious agent specified in this chapter.

Restrict an employee from working with exposed edible cannabis and cannabis products; clean equipment, utensils, and linens in an edible cannabis manufacturing and distributing facility if the employee is suffering from symptoms of an acute gastrointestinal illness.

D.

The person in charge may remove a restriction for an employee upon the resolution of symptoms as reported by an employee that handles edible cannabis and cannabis products if the employee states that he or she no longer has any symptoms of an acute gastrointestinal illness.

E.

Only the department shall remove exclusions or restrictions, or both, related to diagnosed illnesses due to infectious agents specified in this chapter after the city health officer provides a written clearance stating that the excluded or restricted employee is no longer considered infectious.

(Ord. No. 7326, § 2, 6-5-2018)

A.

The cannabis facility operator shall implement a training program to ensure that all employees, including the person in charge, present at the premises are provided information, training, and shall have adequate knowledge of cannabis safety procedures and protocols, which, at minimum, shall include, but not be limited to, the following:

All cannabis facility employees within 30 calendar days of the start of employment shall be trained in all health and safety hazards, hazards presented by all solvents or chemicals used at the premises as described in the material safety data sheet for each solvent or chemical. All employees shall review all emergency procedures, security procedures, record keeping requirements and training requirements.

Prior to independently engaging in any commercial cannabis activity, the cannabis facility employee shall be trained on the overview of the cannabis facility operation and all standard operating procedures, all quality control procedures, and all hazard analysis and control procedures as appropriate. The employee shall be trained on the proper and safe usage of equipment or machinery as applicable and safe work practices applicable to an employee's job tasks. This shall include appropriate usage of any necessary safety or sanitary equipment, cleaning and maintenance requirements, and emergency operations, including shutdown procedures, or any additional information reasonably related to an employee's job duties.

The cannabis facility operator shall ensure that all personnel receive annual refresher training to cover, at minimum, the topics listed in this Section. This annual refresher training must be completed within 12 months of the previous training completion date.

B.

The cannabis facility operator shall maintain a record which contains at minimum, but not limited to:

An annual confirmation by the cannabis facility operator that the employee has received and understood all information and training provided in the training program.

A list of all employees at the premises, including at minimum, name and job duties of each.

Documentation of training topics and dates of training completion for all employees.

Training topics and dates of refresher training completion for all employees.

The signature of the employee and the cannabis facility operator verifying receipt and understanding of each training or refresher training completed by the employee.

Any official documentation attesting to the successful completion of required training by the employee.

C.

The cannabis facility operator may assign the responsibility for ensuring compliance by an employee with the requirements of this chapter to the person in charge. The assigned person in charge must have the education, training, experience, or a combination thereof necessary to ensure the production of clean and safe cannabis and cannabis products by all employees. The designated person in charge shall sign and date a document on an annual basis attesting that the supervisor has received and understood all information and training provided in the training program. This documentation shall be maintained as part of the record requirements.

(Ord. No. 7326, § 2, 6-5-2018)

A.

All employees involved in face-to-face sales of cannabis or cannabis products or management of stores or inventory must undergo a minimum of 2 hours of training on legal requirements and best practices for cannabis retailing using a curriculum approved by the department.

B.

The training shall include hazards associated with cannabis use, including, but not limited to, hazards of use during pregnancy and lactation; motor vehicle use; cognitive effects and mental illness; safe and appropriate dosages, especially for initial use; delayed effects of edible cannabis products; hazards of early initiation and of intensive use by youth; storage to protect children; and smoke-free air provisions.

C.

All employees shall complete the training within 90 days after the date of hire.

D.

Commercial cannabis facilities shall maintain records of all employee's cannabis retailing education on-site and shall make such records available upon request by the department.

(Ord. No. 7326, § 2, 6-5-2018)

A.

The department shall have the right to enter a cannabis facility to conduct an inspection during the facility's hours of operation to inspect the premises of the facility and enforce compliance with this chapter, and applicable state and local public health laws and regulations.

B.

Inspections shall consist of a periodic unannounced site visit conducted by the department at a minimum of twice annually and as needed to conduct complaint investigations to determine compliance with this chapter and applicable state public

health laws and regulations.

C.

The person in charge of the cannabis facility shall allow the department's inspectors access to all areas of the cannabis facility during the cannabis facility's hours of operation to inspect the cannabis facility premises, storage areas, equipment, storage or delivery of cannabis and cannabis products, or any place at which cannabis or cannabis products are sold, cultivated, or stored, or at any site where evidence of activities are allegedly taking place.

D.

Inspections shall include review of all pertinent records including, but not limited to, the track and trace system, plans required by the department, and standard operating procedures. The person in charge of the cannabis facility shall provide records upon request to the department.

E.

The department shall be granted access to conduct investigations concerning the adulteration and misbranding of cannabis and cannabis products, unpermitted cannabis operations, and overall sanitation of any cannabis facility including the ability to enter and inspect any place where any cannabis or cannabis product is reasonably suspected of being manufactured or held in violation of this chapter or state or local laws and regulations.

F.

When a person in charge of a cannabis facility fails to fully cooperate with the department's inspection and/or investigation, that act or omission shall be a violation of this chapter, and subject the cannabis facility to the immediate suspension or revocation of its public health permit.

(Ord. No. 7326, § 2, 6-5-2018)

A.

The department or its designee may collect from a cannabis facility samples of cannabis and cannabis product, at no cost to the department, to verify compliance with the cannabis and cannabis product laboratory testing and labeling requirements from a cannabis facility during the cannabis facility's operational hours without advance notice.

B.

The department may secure any sample or specimen of any cannabis product or ingredients used therein by the cannabis facility and make analyses or examinations of any sample obtained.

C.

The department shall provide the cannabis facility operator with a receipt or documentation of sample(s) collected prior to leaving the premises.

D.

A copy of the results of the sample analysis shall be provided to the person in charge of the cannabis facility.

E.

The department may take an enforcement action necessary to protect the health of the public depending on the testing results and analysis of the sample or samples collected at the cannabis facility.

(Ord. No. 7326, § 2, 6-5-2018)

A.

Any cannabis facility public health permit issued to a permittee may be suspended or revoked by the department for a violation of the requirements of this chapter, or state and local laws or regulations. Any cannabis facility for which the public health permit has been suspended or revoked shall close and cease doing business and remain closed until the permit has been reinstated or reissued by the department.

B.

Whenever the department finds that a cannabis facility is not in compliance with the requirements of this chapter or state and local laws or regulations, a written notice of violation that contains a required compliance date shall be issued to the permittee. If the permittee fails to correct the violation within the specified time, the department shall issue to the permittee a written notice setting forth the permit violations found by the department. The notice shall inform the permittee of a right to a compliance review, if requested, to show cause why the permittee's public health permit should not be suspended or revoked. A permittee must make a written request to the department for a compliance review within 10 calendar days of service of the notice, or correct the violation. A failure to request a compliance review within 10 calendar days after service of the notice shall be deemed a waiver of the right to a compliance review, and may subject the permittee's permit to immediate suspension by the department.

C.

The compliance review shall be held within 15 calendar days of the department's receipt of the permittee's written request for a compliance review. Upon written request by the permittee, the compliance review officer may postpone any compliance review date, if circumstances warrant such action, or cancel the compliance review if the permittee's violations are corrected as verified by the department.

D.

At the compliance review, the department's compliance review officer shall hear testimony and read and consider document submissions from the permittee and department representatives.

E.

The compliance review officer shall issue and serve a written decision to the permittee within 15 working days following the compliance review. In the event of suspension or revocation, the decision shall specify the permit violations that were found to exist and/or continue, the extent of the suspension of the permit, and the actions required for correction of the continuing violations. If the permittee's public health permit has been revoked, the decisions shall state the reasons for the revocation.

F.

Notwithstanding any other provision of this chapter, if any immediate danger to the public health or safety is found or is reasonably suspected, unless the danger is immediately corrected, the department may immediately suspend the permittee's public health permit and order the cannabis facility immediately closed, pending the determination of a compliance review. Immediate danger to the public health or safety shall include any condition, based upon inspection findings or other evidence, that can cause, or is reasonably suspected of causing, infection, illness or disease transmission, or any known or reasonably suspected hazardous condition.

Whenever a public health permit is suspended as the result of an immediate danger to the public health or safety, the department shall issue to the permittee a notice setting forth the violations that have caused the immediate danger, specifying the sections of this chapter or state and local laws or regulations, allegedly violated, and informing the permittee of the right to a compliance review.

At any time within 10 calendar days of service of a notice pursuant to subsection G, the permittee may request, in writing, a compliance review before a compliance review officer to show cause why the public health permit suspension is not warranted. The compliance review shall be held within 15 calendar days of the receipt of a request for a compliance review. A failure to request a compliance review within 10 calendar days shall be deemed a waiver of the right to such compliance review.

G.

The department may, after providing opportunity for a compliance review, modify, suspend, or revoke a public health permit for serious or repeated violations of the requirements of this chapter or state and local laws and regulations, or for interference in the performance of the inspection and investigation duties of the department.

H.

A public health permit may be reinstated, or a new public health permit issued, if the department determines that conditions which prompted the suspension or revocation no longer exist.

(Ord. No. 7326, § 2, 6-5-2018)

A.

All cannabis facilities shall establish and implement a written procedure approved by the department for the recall of cannabis and cannabis products that are determined to be misbranded or adulterated in accordance with the requirements of state and local laws or regulations. Recall procedures shall include, but not limited to:

Factors which dictate a recall;

Employees responsible for implementing the recall procedures;

Notification protocols, including:

a.

A mechanism to immediately notify the department.

b.

A mechanism to notify all customers that have, or could have, obtained the product, including communication and outreach via media, as necessary and appropriate.

c.

A mechanism to notify any operator of a cannabis facility that was supplied or received the recalled product.

d.

Instructions to the general public and/or other cannabis facilities for the return and/or destruction of the recalled product.

The person in charge of the cannabis facility shall provide the following information to the department upon request to assist in the recall investigation:

a.

Source of the implicated cannabis or cannabis product.

b.

Name, contact information, and state license number of the distributor and manufacturer.

c.

Complete distribution list including name, address and contact information; and product identification information (e.g. batch #, lot #, product coding, etc.).

B.

Cannabis or cannabis products that are subject to recall or embargo because they are or are reasonably suspected of being adulterated or misbranded shall include, but are not limited to, the following circumstances:

Laboratory testing reports show presence of pesticide residues not permitted for use on cannabis, or a residual of permitted pesticide above that which has been determined as safe in sampled cannabis or cannabis products.

Retail cannabis and cannabis product is found to have a contaminant in levels exceeding those established as permissible by the state, which shall be considered to be a failed contaminant test.

Use of solvents that were not approved for use.

If a test is found to contain levels above those established by the state agency, of any mold, mildew, or filth that could be toxic if consumed.

If the THC content of a cannabis product is determined through testing to not be homogenous, within the allowable margin of error as established by applicable state regulations, then it shall be considered to have failed potency testing.

Cannabis product contains undeclared allergens.

C.

The department may initiate a recall investigation.

D.

When the department has evidence that any cannabis or cannabis products are adulterated or misbranded, the department, shall notify the permittee and order the cannabis facility to immediately cease activities related to the manufacturing, sale and distribution of all cannabis and cannabis products that have been identified as being potentially adulterated or misbranded. The department may, after consultation with the state, order a recall or embargo of any adulterated or

misbranded cannabis or cannabis products if the manufacture, distribution, or sale of the product would create or pose an immediate and serious threat to human life or health.

E.

Upon confirmation by the department or other licensing entity that the identified cannabis or cannabis product is adulterated or misbranded, the department may issue orders to permittees regarding the required movement, segregation, isolation, or destruction of the adulterated or misbranded cannabis and cannabis products, and may order those to be held in place, embargoed, or quarantined. It is unlawful for any person or permittee to move or allow to be moved any cannabis or cannabis products that is subject to an order issued pursuant to this chapter, unless that person has first obtained written authorization from the department.

F.

The department shall provide the permittee an opportunity for an informal review proceeding on the matter, as determined by the department, within five days, on the actions required by the department's recall order and on why the quarantined or embargoed cannabis or cannabis product should not be recalled. Following the proceeding, the order may be affirmed, modified, or set aside as determined appropriate by the department.

G.

A permittee shall follow its recall procedures for the collection, storage and destruction of any recalled cannabis products. Such procedures shall include, but not be limited to, the following requirements:

All recalled cannabis and cannabis products that are intended to be destroyed shall be quarantined for a minimum of 72 hours. The product held in quarantine shall be subject to auditing from the department.

Following the quarantine period, the permittee shall render the recalled cannabis product unusable and unrecognizable, and the rendering shall be recorded on video and maintained by the permittee for inspection by department or other licensing entities.

A permittee shall dispose of chemical, dangerous, or hazardous waste in a manner consistent with federal, state, and local laws. This requirement shall include, but is not limited to, recalled products continuing or consisting of pesticide or other agricultural chemicals, certain solvents of other chemicals soaked in a flammable solvent for the purpose of producing manufactured cannabis batches.

A permittee shall not dispose of recalled product in an unsecured waste receptacle that is not in the possession and/or control of the permittee.

H.

All recalled cannabis and cannabis products shall be separated and stored in a manner that shall prevent the contamination of other cannabis or cannabis products.

I.

A permittee shall use the track-and-trace system database and on-site documentation to ensure that recalled cannabis or cannabis products intended for destruction are identified, weighed, and tracked while on the premises and when disposed of in accordance with state law and regulation, and local laws.

(Ord. No. 7326, § 2, 6-5-2018)

This chapter is not intended to conflict with state law. This chapter shall be interpreted to be compatible with state enactments and in furtherance of the public health and safety purposes that those enactments encompass.

(Ord. No. 7326, § 2, 6-5-2018)

This chapter is not intended to conflict with federal law or stand as an obstacle or conflict with any efforts made by the federal government to enforce federal laws related to cannabis related activities.

(Ord. No. 7326, § 2, 6-5-2018)

If any section, subsection, subdivision, clause, sentence, phrase, or portion of this chapter is held unconstitutional or invalid or unenforceable by any court or tribunal of competent jurisdiction, the remaining sections, subsections, subdivisions, clauses, phrases or portions of this measure shall remain in full force and effect, and to this end the provisions of this chapter are severable.

(Ord. No. 7326, § 2, 6-5-2018)