A seven-step operating workflow for US independent pharmacies: classify every message, gate campaigns on real service capacity, map permission and data flows, and measure completed services instead of opens.
Most email advice aimed at pharmacies is retail advice in a lab coat. Swap the word "shoes" for "prescriptions" in those articles and they still read fine, and that is exactly the problem: a pharmacy's list was created by health care, so parts of it carry obligations a shoe store's list never will.
Get the governance wrong and three things happen. Potentially identifying health data drifts into an ordinary marketing platform. A promotional blast goes out under mechanics meant for transactional notices. And the report afterwards counts opens and clicks while nobody can say how many completed services the campaign produced.
This guide is the operating workflow that prevents all three: promotional email at a US independent pharmacy in seven steps, from classification to reconciliation. It does not give legal, clinical, or cybersecurity advice, it does not rank email platforms, and it never treats a prescription record as a segmentation toy. Your pharmacist-in-charge, privacy lead, and counsel make the regulated calls. This workflow makes sure they happen before the send, not after.
Here is what you will build:
- A decision record that classifies every email before anyone writes it
- A service and capacity gate that stops campaigns your shelves or schedule cannot support
- A permission and data-flow map covering every field a campaign touches
- A pre-send approval sheet with named sign-offs and a rollback owner
- A bounded experiment sheet and a full funnel, from delivered messages to completed services
What you need before you start
Before writing a single subject line, assign four roles: a pharmacist-in-charge or clinical reviewer, a privacy or security lead, a marketing owner, and an operations owner. You also need your pharmacy's service list, dispensing and appointment records, a written data policy, and an approved email system.
Every later step routes decisions to a named person. In a one-store independent, one person may hold two roles, as long as the privacy review and the marketing send are not the same pair of eyes. Name a backup for each role, then gather the records:
- Service list with authority. Every service you might promote, with the state and location authorization behind it. Your state board of pharmacy is the source of truth; the NABP directory of boards of pharmacy routes you to each board's current site.
- Capacity records. Appointment slots, staffing rosters, and inventory levels from your pharmacy management and POS systems.
- Seasonality evidence. Your own dispensing and service volumes by week, ideally 24 months. There is no universal vaccination, allergy, or holiday calendar; your records are the only honest source.
- Contribution definition. Your written gross-profit or contribution measure per completed service, from your own management, POS, and accounting systems. No portable per-prescription value exists.
- Written data policy. Which fields exist, what purposes they serve, and which identifiers may be joined across systems.
If your pharmacy also needs the search side of demand, our pharmacy SEO guide covers how patients find you on Google. This page starts where that one stops: what you may say, to whom, through email.
Step 1: Classify the email before writing it
Every pharmacy email falls into a class before it falls into a template. Write a one-page decision record naming the message's purpose, audience, data, sender, legal basis or permission, approver, and the rules you relied on. If the class is unclear, stop and route it to your privacy lead or counsel.
Classification is the step retail guides skip, and it is where pharmacies get hurt. HHS guidance on HIPAA and marketing generally requires authorization for uses or disclosures of PHI that meet the Privacy Rule's marketing definition, with defined exceptions, and whether a specific message qualifies is fact-specific. The FTC's CAN-SPAM guide applies its own test: the message's primary purpose decides which rules govern it. Your qualified reviewer makes the call; the decision record is where it gets written down.
| Class | Purpose | Data involved | Default owner | Required reviewer | System class | Permission question | CAN-SPAM primary purpose | Stop condition |
|---|---|---|---|---|---|---|---|---|
| Promotion | Sell a service or product | Email, name, approved segment fields | Marketing owner | Privacy + PIC | Marketing system | Authorization or permission on file? | Commercial? | Basis missing or unclear |
| Own-service information | Inform about an available service | Email, eligibility fields | Marketing owner | Privacy + PIC | Marketing system | Permitted use for this list? | Informational or commercial? | Eligibility unclear |
| Treatment / health-care operations | Care, coordination, operations | PHI from pharmacy systems | Pharmacist | Privacy lead | Pharmacy system | Permitted treatment/operations use? | Usually not commercial | Purpose drifts outside care |
| Refill / pickup notice | Alert: due or ready | Prescription status data | Pharmacy staff | Privacy lead | Pharmacy system | Patient consented to this channel? | Transactional? | Any promotional content added |
| Prescription transfer | Move a prescription between pharmacies | Prescription and identity data | Pharmacist | Privacy lead | Pharmacy system | Patient request documented? | Transactional? | No patient request on file |
| Receipt | Confirm a transaction | Purchase record | POS owner | Privacy lead | POS / pharmacy system | Channel permitted for receipts? | Transactional? | Marketing content added |
| Public-health / service notice | Hours, closures, recalls, clinics | Email, location | Marketing owner | Privacy + PIC | Marketing system | List permission covers notices? | Informational? | Health claims creep in |
| Clinical one-to-one | Answer one patient's question | Full clinical context | Pharmacist | Privacy lead | Approved clinical channel | Reasonable safeguards applied? | Not commercial | Becomes a campaign |
| Review request | Ask for feedback or a review | Email, fact of visit | Marketing owner | Privacy + PIC | Marketing system | Permitted, minimum necessary? | Commercial? | Incentives or health detail used |
Treat the table as a worksheet, not a legal conclusion: your reviewer decides each message against current HHS and FTC material and your state rules. Two failure patterns recur. A refill reminder with a promotional footer gets filed as "operational," but the primary-purpose test reads the whole message, offer included. A newsletter quietly becomes a promotion when a service offer dominates it. Review requests are their own class, covered in how to ask customers for reviews; never fold them into a promotional send to dodge review.
Step 2: Define the service, capacity, and economics gate
Promote one real service your pharmacy is licensed, staffed, and stocked to deliver, or one operational objective you can measure. Write down the service authority, staffing, inventory or appointment capacity, geography, hours, qualification rule, completion rule, contribution measure, seasonal evidence window, and the pause condition before anyone drafts copy.
Email is a demand valve. Open it wider than your operation and you do not get extra revenue; you get patients told to call about a vaccine you ran out of on day two, or an appointment calendar booked solid for six weeks so regulars cannot get in. The gate sizes the campaign to what the pharmacy can complete.
A worked example: one immunization-certified pharmacist can realistically deliver about 12 appointments a week alongside dispensing duties. A transfer campaign to 5,000 addresses is mis-sized for that schedule. Cap the first cohort to what two to four weeks of open slots can absorb, and expand only when completion data says you can.
| Capacity card element | What to write | Source |
|---|---|---|
| Service | One named service or operational objective | Your service list |
| Authorized state and location | Where the pharmacy may deliver it | State board of pharmacy |
| Staff and credential owner | Who delivers it, with required credentials | Roster, licenses |
| Inventory / appointment capacity | Units or slots per week | Management system, schedule |
| Hours and geography | When and where it is available | Store operations |
| Qualification rule | Who is eligible, in writing | Clinical / operations policy |
| Completion rule | What counts as a completed service | Operations policy |
| Source system | Where completion is recorded | Management / POS system |
| Contribution definition | Your written gross-profit or contribution per completion | Management, POS, accounting |
| Seasonal evidence window | Weeks your own records support | 24 months of volumes |
| Pause trigger | Stock-out, schedule full, staff absence | Operations owner |
| Claim restrictions | What the message may not assert | PIC and privacy review |
Candidate services come from your own authorized list: prescription transfers, refill and pickup programs, medication synchronization, vaccination or other appointment-based services, delivery, compounding, front-store and OTC programs, or screenings where your state authorizes them. The most common mistake: promoting a service chain-wide in email when only one location is staffed and authorized to deliver it.
Step 3: Build the permission and data-flow map
List every data field the campaign would touch, where it comes from, what purpose it was collected for, where it goes, which vendor holds it, and how it is corrected or deleted. Keep PHI-bearing operational systems separate from ordinary marketing lists unless a qualified review approves the exact flow in writing.
The HIPAA Privacy Rule protects individually identifiable health information held or transmitted by covered entities and their business associates. Before any campaign, determine the pharmacy's role, the data involved, and the permitted uses and disclosures for each field. HHS confirms that covered providers may email patients about health issues with reasonable safeguards, but that answers a clinical-communication question. It does not authorize a promotional campaign, a vendor, or a data flow.
The hard rule: never upload prescription, diagnosis, medication, claims, refill, immunization, or other potentially identifying health data to a general email platform. Any exception requires a documented data-flow and vendor review, a minimum-necessary analysis, and contract review where a business associate relationship applies. A vendor calling itself secure, or offering a contract, does not make a flow compliant on its own.
| Field | Source | Health-related? | Approved purpose | Destination | Contract review | Encryption / access owner | Retention | Suppression | Correction / deletion route | Prohibited use |
|---|---|---|---|---|---|---|---|---|---|---|
| Email address | Consent form, POS opt-in | No, by itself | Messages the person asked for | Email system | Vendor terms reviewed | Encrypted; marketing owner | Opt-out + policy window | Global opt-out list | Named correction contact | Bought or rented lists |
| Full name | Consent form | No, by itself | Addressing the message | Email system | Vendor terms reviewed | Encrypted; marketing owner | Opt-out + policy window | Global opt-out list | Named correction contact | Matching to health records |
| Phone | Consent form | No, by itself | Only if campaign uses it | Email system | Vendor terms reviewed | Encrypted; marketing owner | Opt-out + policy window | Global opt-out list | Named correction contact | Unrelated outreach |
| Consent / opt-out status | Consent records | No | Permission proof, suppression | Email system + policy file | Reviewed | Privacy lead | Per retention policy | Source of truth | Privacy lead | Overriding an opt-out |
| Language preference | Consent form | No | Message language | Email system | Vendor terms reviewed | Marketing owner | Until opt-out | Follows opt-out | Named correction contact | Inferring conditions |
| Broad interest (e.g. delivery) | Self-selected preference | Potentially | Segment approved in writing | Email system | Privacy review | Marketing owner | Until opt-out | Follows opt-out | Named correction contact | Any clinical inference |
| Prescription, refill, claims, immunization data | Pharmacy management system | Yes | Treatment and operations only | Stays in pharmacy systems | Business associate review | Encrypted; privacy lead | Per record retention law and policy | Not a marketing field | Privacy lead | Promotional segmentation or personalization |
Rebuild this map for each new system or field, and re-verify it when a vendor changes terms. Where pharmacies go wrong: someone exports "just emails" from the dispensing system. The export path itself is the problem, because a list pulled from a care database carries the context it was pulled from. Draw audiences only from sources your reviewer approved for that purpose.
Your website content deserves the same discipline your email does. theStacc's Content SEO module researches, drafts, queues, and publishes articles for your pharmacy's site on a schedule, so governed channels like email stay your team's only manual work.
Step 4: Create one audience and one useful message
Segment only on fields your data-flow map approved, and write one message that tells the truth about one service: what it is, who is eligible, where and when it is available, what to do next, and its limitations. Route medical questions to an approved clinical channel, never to a marketing reply-to address.
One campaign, one audience rule, one message. A good audience rule reads like a database query against approved fields: front-store customers who opted in to service updates and live inside the delivery zone. A bad one reads like a clinical hunch: patients whose dispensing pattern suggests a condition. The second is out of bounds no matter how well it would convert.
The message itself has seven parts:
- Sender and subject that identify the pharmacy honestly.
- The service truth: what it is, in plain language.
- The eligibility boundary: who qualifies, matching your written rule.
- Availability: real hours, real locations, real stock.
- One action: call the pharmacy, or use the approved form. Not both plus three more.
- Limitations: what the service does not cover, and where medical questions go.
- Opt-out: a working unsubscribe mechanism and your physical address.
Health and product claims need substantiation before the send. FTC health-products guidance requires claims to be truthful, not misleading, and adequately substantiated, and it is not a safe harbor you can cite as cover. Have the PIC review service claims and the privacy lead review personalization. A first name is fine if your map approved it. "We noticed you haven't picked up your refill" turns medication data into casual personalization, and that crosses the line this workflow holds. For general campaign craft and copy basics, our guide to email marketing for local businesses owns the generic mechanics this page deliberately skips.
Step 5: Run privacy, pharmacy, deliverability, and accessibility checks
Before any send, four reviews happen in writing: PIC or clinical review of pharmacy-service content, privacy and security review of data and tools, marketing review of sender, subject, footer, and opt-out mechanics, and a technical pass on links, forms, mobile rendering, and readability. A named release owner signs the approval sheet.
The CAN-SPAM side is mechanical and non-negotiable for commercial messages. Per the FTC's compliance guide: accurate header information, a non-deceptive subject line, required identification and a valid physical postal address where applicable, a working opt-out, opt-outs honored promptly, and oversight of any vendor sending for you. You cannot contract that responsibility away.
| Pre-send check | Evidence required | Sign-off owner |
|---|---|---|
| Health / product claims | Substantiation on file for each claim | PIC / clinical reviewer |
| Clinical content | Service description matches authorized practice | PIC |
| Privacy and security | Audience fields match the approved data-flow map | Privacy / security lead |
| State-board / legal | Service authority and advertising rules checked | Privacy lead or counsel |
| Sender, subject, footer, opt-out | CAN-SPAM mechanics tested and screenshot | Marketing owner |
| Link, form, and call test | Every link, form, and phone link exercised | Marketing owner |
| Service availability | Capacity card reconfirmed within days of send | Operations owner |
| Accessibility | Legible type, alt text, plain language, mobile render | Marketing owner |
| Release | Named approver authorizes the send | Release owner |
| Rollback | Named person who can halt mid-campaign | Rollback owner |
Treat the sheet as a checklist attached to the campaign record. Once the template exists, a typical independent clears it in one focused working session; set your own pace and never borrow a completion time from a blog, including this one. The most common miss is the capacity reconfirmation: availability checked three weeks ago is not evidence for a send tomorrow.
Step 6: Launch a bounded cohort and preserve every stage
Send to a declared audience with a start date, an end date, a send cap, a geography, a suppression list, an owner, and a written stop rule. Record every funnel stage separately: sent, delivered, click, call click, form, qualified enquiry, booked service, completed service. Mark impression unavailable if your system does not define it.
A bounded cohort is a campaign with edges. For a first run, a typical independent caps the audience at a few hundred approved addresses rather than the full list, because a small cohort contains every kind of mistake. Declare the experiment before launch:
| Experiment field | What to declare |
|---|---|
| Hypothesis | One sentence tying the message to the service objective |
| Communication class | From the Step 1 decision record |
| Audience rule and exclusions | Approved fields only, plus suppression list |
| Cohort dates | Send window start and end |
| Send and time cap | Maximum messages in the window |
| Service and capacity gate | The Step 2 card, reconfirmed |
| Stage events | Which systems record which funnel stage |
| Owner | One named person for the cohort |
| Review lag | Enquiry-to-completion time from your records |
| Complaint / opt-out threshold | The tripwire that pauses the send |
| Keep / change / stop rule | Decision criteria written before results |
Then keep the funnel stages separate, each with its own source system:
| Stage | Definition | Source system |
|---|---|---|
| Sent | Messages accepted for send in the cohort | Email system |
| Delivered | Messages recorded delivered | Email system delivery export |
| Impression | Only if the source system documents a definition; otherwise unavailable | Email system, if defined |
| Click | Unique delivered recipients clicking an approved tracked link | Email system click export |
| Call click | Phone-link taps from the message | Email system or call log |
| Form | Submissions on the approved form | Form records |
| Qualified enquiry | Enquiries meeting the written service, location, authority, and capacity rule | Intake record |
| Booked service | Appointments recorded under the written booking rule | Scheduling system |
| Completed service | Services delivered and recorded under the completion rule | Management / POS system |
Notice what is missing: the open. Open rates rest on image-loading behavior you cannot verify, so this system treats opens as unavailable evidence, never as a funnel stage. An open, click, call click, form, reply, transfer request, or refill request is also never, by default, a qualified enquiry, a booking, or a completed service. Where pharmacies go wrong: counting a transfer request as revenue the moment it arrives. It is an enquiry until the written rules say otherwise.
Bounded experiments work on your website too. While your email cohorts stay small and measured, theStacc's Content SEO module keeps new articles researched, drafted, queued, and published on your pharmacy's site.
Step 7: Reconcile completed-service evidence and decide
After the declared lag, join campaign responses to completed services using only identifiers your data policy approves, under PIC and privacy oversight. Compare the cohort against its written objective, review complaints, opt-outs, unsupported requests, and capacity, then keep, change, or stop on first-party evidence.
Reconciliation is where pharmacy email programs quietly fail, because the report stops at clicks. Four rates carry the real answer, and each keeps all seven fields: numerator, denominator, evidence window, source system, owner, and exclusions. No portable benchmarks exist for these; your baseline is your own previous cohort.
| Formula | Numerator | Denominator | Evidence window | Source system | Owner | Exclusions |
|---|---|---|---|---|---|---|
| Delivery rate | Unique campaign messages recorded delivered | Unique messages accepted for send in the cohort | One declared send window | Email system delivery export | Email-program owner | Internal tests, duplicates, suppressed records, canceled sends, records without delivery status |
| Click rate | Unique delivered recipients with at least one approved tracked link click | Unique recipients with a delivered message in the cohort | Send window plus a declared 7- or 14-day response window | Email system click export | Email-program owner | Bot and security-scanner clicks under the written filter, internal tests, duplicates, records suppressed pre-send |
| Qualified-enquiry rate | Unique attributable enquiries meeting the written service, location, authority, and capacity rule | All unique attributable call-click, form, or reply enquiries from the cohort | Cohort plus the declared service decision lag | Email analytics plus call, form, and intake records | Intake owner | Duplicates, spam, clinical-only messages, employment and vendor enquiries, unsupported service or geography, unreachable records, existing booked or completed services |
| Completed-service rate | Unique attributable booked services marked completed under the written rule | All unique qualified enquiries from the cohort | Cohort plus the declared booking and completion lag | Scheduling, management, and POS records joined under the approved data policy | Operations owner with PIC and privacy oversight | Canceled, no-show, or incomplete services, duplicates, pre-existing bookings, services outside the promoted cohort, unattributable completions |
Decide from the written rule, not from the mood the numbers create. Keep means the cohort met its objective inside capacity. Change means adjusting one declared variable, the audience rule or the message, and re-running bounded. Stop means complaints, opt-outs, unsupported requests, or capacity say the campaign should not run again as designed. One honest caution: some completed services would have happened with no email at all. Compare against your written objective and your own pre-campaign volumes before crediting the campaign, and exclude completions you cannot attribute under the approved join.
Troubleshooting: failure states and first responses
Every campaign produces failure states, and each one has a first response and a record owner. The table below covers the thirteen states independent pharmacies actually see, from bounces to incomplete services. Log every one; a pattern in any single row is a process problem, not bad luck.
| Failure state | What it means | First response | Record owner |
|---|---|---|---|
| Bounce | Address rejected the message | Remove or correct through the correction route; review list source | Email-program owner |
| Spam complaint | Recipient reported the message | Suppress immediately, log, re-check classification and permission record | Email-program owner |
| Opt-out | Recipient unsubscribed | Honor promptly, suppress across marketing lists, confirm no resend | Marketing owner |
| Wrong recipient | Message reached someone else | Treat as possible disclosure; notify privacy lead, follow incident process | Privacy lead |
| Suspected privacy incident | Health data possibly exposed | Stop affected sends, escalate, document | Privacy / security lead |
| Unsupported service or geography | Request outside authority or area | Decline politely, route to a correct resource, log | Intake owner |
| No inventory or capacity | Promoted item or slot unavailable | Pause campaign, correct availability, notify affected patients | Operations owner |
| Clinical reply | Medical question in a campaign reply | Route to the approved clinical channel; never answer clinically from marketing | PIC / clinical reviewer |
| Call click without connection | Phone-link tap, no conversation | Log as call click only; check phone routing and hours | Operations owner |
| Invalid form | Submission failed validation | Repair and re-test the form; record the affected window as unavailable | Email-program owner |
| Unqualified enquiry | Fails the written rule | Record the reason, exclude from the qualified rate | Intake owner |
| Canceled booking | Booked, then canceled | Keep out of completed counts; review reminder process | Operations owner |
| Incomplete service | Started but not finished | Exclude from completed rate; operations review of cause | Operations owner |
The two rows that deserve standing attention are spam complaints and wrong recipients, because they change your regulatory posture, not just your numbers. Everything else is operations: fix the cause, keep the log, and let the log tell you when a one-off has become a pattern.
Frequently asked questions
These are the eight questions pharmacy owners, pharmacists-in-charge, and privacy leads ask before their first governed send. Each answer names the decision owner, because in this vertical the honest answer to most compliance questions is a fact-specific review, not a rule of thumb copied from a retail blog.
Is pharmacy email marketing allowed under HIPAA?
HIPAA does not ban promotional email, but it generally requires a written authorization before PHI is used or disclosed for a purpose that meets its marketing definition, with defined exceptions. Whether a specific campaign counts as marketing is fact-specific. Your privacy lead, with counsel where needed, makes that call using HHS guidance, not this article.
Is a refill or pickup reminder the same as a marketing email?
No. A refill or pickup notification about an existing prescription is generally an operational or treatment communication, not a promotional campaign. The line blurs when you add promotional content: regulators look at the message's primary purpose. Keep service notices clean of offers, and have your qualified reviewer classify anything mixed before it sends.
Can a pharmacy upload its patient list to a regular email platform?
Not without a documented review. A patient list built from prescription, diagnosis, medication, claims, refill, or immunization records is potentially identifying health information, and the HIPAA Privacy Rule restricts how covered entities and business associates use and disclose it. Your privacy lead must approve the purpose, fields, vendor, contract, and safeguards in writing first.
What consent or authorization does a pharmacy need before sending promotional email?
It depends on the classification. Commercial email always needs CAN-SPAM mechanics: truthful headers and subjects, a working opt-out honored promptly, and your valid physical address. When a campaign meets HIPAA's marketing definition and involves PHI, an authorization is generally required unless an exception applies. Your privacy lead decides which regime governs each message.
Does CAN-SPAM apply to pharmacy email marketing?
Yes. CAN-SPAM covers commercial email, including business-to-business messages, and pharmacies get no special exemption. For each message it requires accurate header information, a non-deceptive subject line, required identification and address where applicable, a working opt-out, prompt opt-out processing, and oversight of any vendor sending on your behalf.
Which pharmacy services can an independent pharmacy promote by email?
Only services the pharmacy actually offers and is authorized and staffed to deliver at the promoted location: for example prescription transfers, medication synchronization, vaccination or other appointment-based services, delivery, compounding, front-store and OTC programs, or screenings where locally authorized. Your state board of pharmacy defines service authority; your staffing, inventory, and appointment records define real capacity.
Does an email open, click, call click, or form count as a booked pharmacy service?
No. An open, click, call click, form submission, reply, transfer request, refill request, or appointment request is an early funnel stage, not a booked or completed service. A booking exists only when your scheduling system records one under your written rule, and a completion exists only when the service is delivered and recorded.
How long should a pharmacy wait before evaluating a campaign?
Wait for your declared review lag: the send window plus the time your own records show between an enquiry, a booking, and a completed service. For many appointment-based pharmacy services that lag runs days to a few weeks, but declare it from your scheduling and dispensing history, not from a generic benchmark, and write it into the experiment sheet before launch.
The cadence that keeps pharmacy email safe
Pharmacy email marketing works when it runs as an operating discipline: classify every message, gate every campaign on real service capacity, map every data flow, check every send, bound every cohort, and judge only completed services. Seven steps, run in order, keep promotional email useful and defensible.
Put the discipline on a calendar your own records justify. Re-verify the data-flow map and service authority quarterly, or whenever a vendor, service line, or state rule changes. Review the failure-state log monthly. Run each campaign through all seven steps, even the small ones, because the small ones are where habits form.
Keep the surrounding channels in their own lanes. Generic campaign craft lives in our guide to email marketing for local businesses. Search demand lives in the pharmacy SEO guide. Review requests follow their own process in how to ask customers for reviews. And if you want the website side handled for you, theStacc's Content SEO module researches, drafts, queues, and publishes articles, while the Social Media module prepares and schedules posts across Facebook, Instagram, LinkedIn, and X with approval options. Neither is an email service, a consent manager, or a compliance tool, and this guide never pretends software replaces your reviewers.
Pair a governed email program with a website that keeps earning visits. theStacc publishes SEO content for independent pharmacies, researched, drafted, queued, and published for you, so your team can spend its judgment where judgment is legally required.
Sources & references
- HHS — HIPAA Privacy Rule: laws and regulations for individually identifiable health information held by covered entities and business associates
- HHS — HIPAA guidance on marketing: authorization requirements and defined exceptions
- HHS — FAQ 570: emailing patients about health issues with reasonable safeguards
- FTC — CAN-SPAM Act compliance guide for business
- FTC — Health Products Compliance Guidance on truthful, substantiated claims
- NABP — directory of state boards of pharmacy
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