Episode Transcript
[00:00:00] Speaker A: G'day, everyone.
[00:00:00] Speaker B: Welcome to Lubrication Experts. And today we've got a very special episode because it's one which has been requested a few times, we're going to be talking about rerefined base oils. Now, rerefined base oils is pretty topical because I feel like with increasing sustainability concerns, everyone is looking to lower their carbon footprint. But everyone also has concerns about what's the quality of re refined base oils, how are they manufactured? And I think there's a lot of myth that we might be able to dispel today. And so we have to always go to the best source here. And I think we found that in the senior vice president of safety Clean, which is Joel Garrett. Joel, welcome to the podcast.
[00:00:40] Speaker A: Thank you very much for having me.
[00:00:42] Speaker B: All right, so let's start at the beginning and just define what are re refined base.
Know, what kind of oils can be re refined. So I think from an end user standpoint, end users basically just see kind of like a bucket that they put all their waste oil into, what ends up going into the re refining process, and then what's the kind of like, yield that we can get out of re refined base oil? So maybe if I take a liter of waste oil, how much re refined base oil is coming out of that?
[00:01:19] Speaker A: Yeah, try to answer some of that, I think. And then to help understand, it really all starts at the beginning, and a lot of that is based around the collection, right. I mean, here in the US, there's almost, I think it's 1.2 or 1.4 billion gallons a year of waste oil that gets generated, and about 45% of that goes to re refining, which I'll explain in a second. And then the rest of that goes and gets used for fuel recovery. Right. Because you can take that, it's got good BTU value. It depends on how far away it might be from a re refinery. A lot of that material ultimately doesn't get re refined, and that that does get re refined goes through a lot of steps for processing. So it really all starts with the collection. And that collection is done through what we look at as profiling. So you want to take that. If somebody's waste, you can't just automatically take it and say, oh, here's a new product. You got to really understand the chemistry of what's in there, right? That starts with, is it from an automotive oil changer, is it from a rail fleet, is it from an industrial facility and understanding what that is and then doing a lot of pre qualification testing on it and that pre qualification testing is going to look for things like hazardous materials, chlorinates, other things that might be a problem for processing in a re refinery, such as silicone. So we take that and we do some analytics on it, and I get a base set of data and then take more samples and really get to understand what the characterization looks like for that waste that is getting generated at that location. And then what we ultimately do, once we've pre qualified it, is we'll take it and we will pick it up in a small truck. Right, because you don't want to be out there getting up a massive amount of material if there's something that you haven't tested for, such as pcbs, which is a major challenge for used oil, and we'll take that truck and we'll bring it to a tank that's located probably not that far from the facility, and mix it in with our oven materials, do some more testing or advanced analytics, and make sure now that that aggregated material is still meeting the specification that we have for our re refining. And then ultimately we'll send it by a rail car or sometimes even a barge up to one of our re refiners and we'll put that through our process. And if you look overall at that, and I was mentioning at the beginning, only about 45% of all the used oil that gets generated is going back to re refining. And the key challenges is, for us, is really at that collection part or the starting place. And when we get the used oil and bring it in, is making sure that it's going to meet the requirements that we have to go through all of our processes. So I could tell you a little bit about the process itself, because I think that helps. As you mentioned, what is re refining? A lot of times people think that, oh, run it through a dirty sock, or run it through a sock and you'll clean oil, and here you go, you can use it. And it's probably about the furthest thing from that. I've gotten a pretty significant appreciation of my time working at safety clean, because it's always something new that you're learning. And when we take that, we get it to the re refinery, it's not like we're just processing it. It goes then through some dehydration, because you want to minimize any water that's in there. Then you're taking it and running it through the rest of the processes along the way.
Without going into too much detail about the processes themselves. They do look similar to what you would see in a crew refining world. Once you get it to the re refinery, but you have steps in there after dehydration, where you have distillation, you're getting the various cuts, and then ultimately you get to VGO or vacuum gas oil, which we use to then create the base oil. With that said, there are also other things that get generated before you get to just make base oil. You have the light ends and then you have the heavy ends or the bottoms. And those light ends can be fuels. We'll take as much of that as we possibly can to run our processes. So we use the fuels that we're able to strip off during the process and run our re refineries. And then the rest or the remainder of what's left over, we'll take that and commercialize it and sell it because it has good BDU value. And then that material that's on the bottom with the heavy ends, that goes more like an asphaltic type material, and that will go into roofing, paving, and there's plenty of consumption of that throughout the US and Canada. So that's where all our material.
Yeah, and then you get to the PTO and then we could talk more about that.
[00:05:50] Speaker B: Yeah. Interesting. Maybe just to step back a little bit from the manufacturing mean, before we get too far down the line, it might be helpful to understand what kind of base oil comes out the other end. So what we're working towards is a base oil, which is, if I had to classify it by API category, does it fall into the API categories?
Can you sell it as a group two or whatever?
[00:06:20] Speaker A: Yeah, that's what we do. We make a group two plus really strong high viscosity index. And in the world of re refining, we basically say you are what you eat and it's based on what we collect. And if you think about where would you get used oil, you've got to take it from the places that use it for its initial intent and then refill it, as opposed to fill for life type lubrication. Right. So we're taking something that was consumed and processed, and that's primarily, I mean, about half of, I think, the lubricants in the world are really coming from, or I would say the used oil is primarily coming from the car or loop changers or automotive oil changes. And then there's other things like heavy duty diesel engines, which process wise kind of looks like used car oil or engine oil, and then hydraulic food. Right. Those are probably the big three from what kind of gets generated as used oil as a result, as I said, you are what you eat. We're then generating back group two. Group two, plus base oil that goes back into the same types of product.
[00:07:24] Speaker B: Yeah. Interesting. And then I guess the way, I mean, I'm not a chemical engineer, but the way I always kind of describe a general rule of refining is that the more you refine something, basically the lower the viscosity gets. And you're obviously starting with a lot of engine and hydraulic oils. So does that restrict also the kinds of viscosities and vis that you can manufacture?
[00:07:46] Speaker A: Yeah, I mean, if you ever think about, probably saw some of these, some of the people that you talked to, but when you take a used oil out of your car, it's usually a little thicker anyway. Right. It's a dark color and it pours a little bit slower. And that's because you have the spent additives that are in there. So when you take that material out, you're kind of getting back to pretty close to where you are in the viscosity because you're taking out the stuff that went in there, the impurities, like the additives. Yeah, you're getting pretty back to that.
[00:08:20] Speaker B: Yeah. Cool.
The other thing I'd really like to address kind of up front as well is it's worth touching on the reputation aspect of re refined oils. Right. So I think once upon a time, and certainly some people still believe it, there's probably that reputation that re refined oils are of lesser quality than virgin based oils.
So what makes the modern re refined oils different?
I guess you could say, like, it's not, it's not your grandfather's recycled oil.
And is there a spectrum of quality within the industry, for example, that goes from one end to another. What makes redefine different?
[00:09:07] Speaker A: Yeah, I'd say ultimately it comes down to the process that you're using to do the re refining. And there's a couple of questions in there. And I actually enjoy talking about some of these things because some people think that it's just recycled oil or run through a sock. And here you go. Here's your new product. But the furthest thing from that, we're ultimately starting with what is already really good products. Right. There are many manufacturers out there that make great used engine oil. If we look at that in particular, and the starting products that we have, the used oil, which is made from virgin based stocks, and the products that all these companies make, they're excellent products. They have great vi, they have great properties. Some of them are synthetic. We're processing all that. We're stripping out the kind of the material that's been spent. But that starting point of that used oil for us is a great quality material to begin with. And then really the second part of this question I think that you're asking is, well, what do we do with it?
There's us, and there are other re refiners out there. Some of them have similar processes or technologies. And I think there's a little bit of a spectrum in how they do it. And some do solvent extraction, some do hydro treating. There's different ways to do it. All of them create some benefit. I mean, I can speak to what we do better, but in that overall process, you're taking that material and you are doing several things to it along the way.
Those things don't necessarily happen to a crude based gallon of oil or liter of oil. And you're creating a brand new product which is of exceptional quality. When we compare it to what else is out there in the market or the alternative products that our customers can choose, there's a reason why they buy our product. And it's not just the quality which is very well demonstrated. And if you look at the characteristics of it, whether it's high temperature properties or low temperature properties, vi the things that are really important when they're designing their product portfolio. But there's also other things in there. There's one of them is sustainability from the re refining process and the reduction of the carbon footprint value that they get. And there's also the reliability of supply, which for us, our re refineries are primarily outside of those places where there are hurricanes or pretty harsh negative weather events which happen and it shuts down refineries. And so our customers know that that reliability of supply is continuous all the time. They can always get it. Combine that with the quality and the sustainability, there's a very strong value proposition for re refined base oil. And again, us, as well as what would be our competitors. But we're very close to those other re refined base oil companies because it's an industry that's very large, having friends versus at least is pretty important. And although we compete out there in the market, we also have a similar kind of, I would say similar goals as far as advancing the segment of the industry about re refining.
[00:12:10] Speaker B: Yeah, that's really interesting. And I guess when I spoke to that spectrum, I always kind of give the analogy in the biofuels world where, let's say, for example, biodiesel, there's plenty of very high quality biodiesel, which is highly regulated going into commercial markets.
Unfortunately, you do also have people that are recycling biodiesels in their basement. And so in some ways the entire industry gets tarnished with the reputation of that kind of process. But obviously here we're talking about industrial scale redefining. That has been done to quite a high quality. And now I think it's probably worth us kind of like stepping back into the process. You mentioned briefly, you're taking these waste streams, you're doing a certain amount of qualification testing on them.
First step? Well, one of the first steps is to remove water.
I think the obvious question in terms of removal would be, let's say with your engine oils, as you mentioned, in some cases you might have glycol or fuel contamination as well.
How do you go about, is that part of the pre qualification that if we find that there's a lot of contamination with glycol, this is just not something that can be re refined? Or are there steps that can accommodate that?
[00:13:39] Speaker A: Yeah, you can. I mean, you can do it. It's like anything, it's going to use a lot more energy. Let's say it had a lot of water, right? And you couldn't just simply separate out the water. You had to do things like increase the temperature to be able to evaporate off the water and then you had to separate it. The more you have to manage that on the front end, the higher your cost of operation is. So when it comes to the testing on the front end, I said we do the profiling to really understand what that waste stream looks like. But then what we also ultimately collected and every time we do pick it up, we're validating that against their spec. So you think about if you were to buy any type of lubricant and you had an IR spec in your files for it, you receive it in and you'd run an IR on it to say, okay, yes, I got it. It matches what I think it's supposed to be. It's very similar in the collection of used oil. Right? Am I getting what I thought I was going to get? Because I need to make sure that my decision for taking that and processing it was based on what I saw as the specification for that. If it looks different, then you've got to do something different. When it comes to glycols, you can certainly process those off, but it has an impact on your systems and processes, right? Because you've got to run it through and do more. You got more energy going in there for the distillation, then you got to manage that material that comes off the process. You've got to manage that as a separate product. And if you don't have, I guess what we try to do is manage that on the front end, so we don't have anything like that in our process. I mean, if you do, it's very rare that we would have something like that, but if you do, it just costs time and money for anybody to deal with it.
[00:15:16] Speaker B: Yeah, that makes sense. And probably the biggest difference, I think, in most people's minds at least. I don't know if this is true from a technical standpoint, when people think of the difference between re refining lubricants versus refining crude is the fact that you have to deal with all the additives. So especially with the engine oils highly additiveized, you've got your TBN additives, you've got rust and corrosion inhibitors, in some cases, reasonably complex molecules, polymers, ocps and all that sort of stuff, how are we removing those?
And maybe another question would also be the removal of some of, like the oxidation products, too. So you talked about the oils go dark in service. Probably a combination of oxidizing the base oil as well as soot contamination.
It seems like a very wide range of molecules to have to remove.
[00:16:20] Speaker A: Yeah, but I think that from a process perspective, they're the physical characteristics of the chemistry. So even if you have a wide range of the actual chemical structure of those materials, the process itself will kind of segregate out those, even if they're different chemistries. I think one thing that, as we were talking about earlier, is that the used oil that we collect is usually coming from similar collection processes. So passenger car engine oil, oil changers, right. I mean, the formulations for those, they're different, but they're not that different as if you were going to an industrial source or you were collecting things like polyglycols. Right. I mean, we're not going and collecting certain types of industrial gear oils where we're getting polyglycols or things like esters. We're not collecting those types of lubricants. We're collecting pretty similar materials to what we're ultimately making. So we have, again, the testing on the front end and the validation and everything that goes with it. Got a pretty good handle on what that looked like and what to do with it. I think the big thing, and you asked what happens with those materials? And it all ends up in what we call the bottoms or the materials that will go into the asphaltic type products, they actually provide excellent characteristics for processes and things like that. So when they collect, when somebody's building a new road or constructing that. They're taking a lot of used where they're pulling up the old road and they're taking all that material which is based on the gravel, rocks, not so much the concrete, but just the asphalt. They're taking all that. And those polymers and other materials that are in the used oil that come out in the bottoms for us actually are great technical characteristics for the process of collecting that and making new rows. So there are a lot of advantages that we didn't see.
[00:18:17] Speaker B: Yeah, I mean, that's really awesome to see that.
It's that old saying of one person's trash is another person's treasure. Right. And I think it's kind of a key tenet of this circular economy that we're trying to build is that we do have to find uses for all this stuff. And I think it being a high quality input into asphalt is so interesting. Now, you already talked about after we've removed kind of all the contaminants and the additives and stripped all that kind of stuff out that you mentioned, there are various different refining processes that get applied. So in some cases it might be hydro treating or hydrocracking or however it looks. That kind of looks a little bit more like the standard refining process. So at the end of it, you're saying that we have effectively a group, two plus style product that comes out at the end of the safety clean process.
When that product comes out, is there any way to tell the difference between something that's a re refined product versus something that is, quote unquote, a virgin base oil? And what kind of testing do you have to do to the end product before it kind of goes out. Is it much the same as for the crude refiners?
[00:19:43] Speaker A: Yeah, it really is. The only way you can really tell would be if you bought something or had a sample from our product and you ran your testing before you would use it, and you could map it out and say, oh, that's the safety clean oil, or this is supplier XYZ. But re refining versus not re refined versus non refined, you would not be able.
You're basically using that same starting point material and extracting all the contaminants and everything that's in there and starting over and reprocessing it. So that I know of. There's no testing that basically tell whether it was re refined or not. The only way you would be able to tell is if you ran all the testing characteristics and said, yeah, that matches up with the Vi, the NOAc and all the others with safety cleans oil versus somebody else's. But other than that, that's the only thing.
[00:20:38] Speaker B: Yeah, really interesting. And then a lot of the different base oil companies have done different performance benchmarking and performance testing and that kind of stuff. Have you got any examples of the type of work that safety clean has done as well?
[00:20:52] Speaker A: Yeah, we've done a lot of testing. There's the lab, and that gives you a good indication of how things are going to look with no variables in there. Right. And then you get into the real world, and then there are always things that are going to make a difference. We've done a lot of engine testing bothering passenger cars as well as with heavy duty diesel engines. Not long ago, they just did a full tear down of an engine. So you're not only getting the performance characteristics and the data from the lab, you're getting kind of, hey, this is what it actually looked like. And 10,000 hours, 20,000 hours, et cetera, getting to see that physically is really valuable. We've done that with race cars, hydraulic systems, anything that can really give you that real world testing and is really helpful, I think. And it also helps validate. So when you're going to a customer and you're talking about, well, this is really beneficial because of these characteristics that you're going to get. They really want to see that, well, what happens when our competitor uses it? How is that working for them? And when you have that real world data, it really helps to kind of communicate the benefits of it. So, yeah, we do quite a bit of that. We do a lot of work with oems. We do a lot of work with additive companies.
And there's also the things that, there are a lot of independent labs that want to take a deeper dive on our materials because of the sustainability benefits both to, I guess I would say sometimes to, I don't know, almost like say that, no, it's not going to be good enough.
And also to find something wrong because they want to refute it. And a lot of the feedback is, wow, I was pretty surprised that we got this far on this test. And then sometimes you learn things that you just didn't know. And that's important. For anything that we do or any of your customers or competitors are doing out there in the market. You want to know everything you can know. You've been in the lubrication industry for a while. I have, too. There's just so much learning that occurs. There's some new test or there's something that somebody did with your product that you didn't think anything about ever before. So the learning is critical.
[00:23:08] Speaker B: Yeah, interesting. I think that's a really good segue to talk about the kind of the sustainability chops of re refining.
Maybe helpfully, APIs just put out their, I think they're calling it a technical report. It's not a recommended practice or anything, but was it 1533, I think, is the number that got assigned to it, which is giving us guidance for how to kind of calculate the carbon footprint associated with the manufacturing of base oils or the entire lubricants value chain.
So that's given us a lot of guidance. And my understanding is that over in Europe, I think it's ateel is working on a very similar kind of framework for the EU. So it might be helpful to understand a little bit more about what are the sustainability benefits. Because my understanding at least, anyway, is that when you go through and you calculate what are the carbon emissions associated with every step of the lifecycle of a liter of lubricant, that yes, there is obviously carbon associated with finding, producing and refining crude oils, but that the vast majority of the co2 emissions is actually in the incineration of waste products.
That's my understanding anyway.
So first of all, is that true?
And if so, what kind of carbon are we averting by diverting these waste streams from going to the landfill?
[00:24:57] Speaker A: Yeah, it's a real interesting thing, both for the industry and just in general.
I saw that API report, I think right when it was coming out, or maybe a few days before it was in a final draft, I was kind of surprised, but I wasn't for a few reasons.
It depends on how you look at the environment and if you look at it, if I say, well, I did this or I went from point a to point b, and therefore, let's say I have a big truck and I buy a truck and it can emit a ton of pollutants and things like that. But if I say, well, I only drove it from point a to point b, and therefore that's all I'm responsible for. But I created that truck, or I asked for it, I bought it. Eventually, something has to be done with that truck. But if I look at that truck where I drove it from point a to point b, and not ultimately, what happens to that later on, whether it gets spoiled or it goes in a landfill, whatever happens, some people look at it from the point a to point b, which is the use of what you're doing, and then the lubricants is a good example it's like, well, I only did this with it, but if you create the purchase or you create the development of something, and then that material or product gets used by you, and then it gets disposed of or it gets burned for fuel recovery or something, that's the full cradle to grave versus the cradle to gate. And that's the kind of the big difference right now, I think. And that's probably got a lot of years of further discussion. A lot of people are looking at it from cradle to gate. We look at it cradle to grave because we're taking something that would have otherwise caused environmental contamination or would have been burned for fuel recovery and would have caused some emissions. And we're taking that and we're processing it for reuse and we're factoring in everything from what does it take to collect it? As we're talking about the collection and profiling, sending it to the refinery, we're looking at all those steps along the way and all the environmental impacts we have, and then the impacts for processing it and creating a new product and then sending it back on to a customer and then closed looping it over and over again, or re refining as much you can. So about 80% of the material can be continuously used. So you might have a lubricant that's got additives that are going into roofing and paving, or you've got water in there, other contaminants. You're not going to get all that material to be useful for a new product, but about 80% of what we collect is going to be used in making a new product. And when you look at that and you look at the cradle to grave kind of world, it's a pretty significant impact.
While on a gallon basis, a little over, I think, 10 equivalent per gallon of that reduction. And that's about, I think, two and a half or 2.7 head there, that reduction. But you start multiplying, that times a lot of gallons or a lot of liters, and you're having a reasonable impact on reducing that footprint. And that reduction is coming a little bit from the manufacturing process itself, but even more so from not burning it. So you're not taking that and then essentially putting it into its final position of waste and the collection of it. And if you're bringing back new product, and so if you're doing more of a circular loop for a customer or somebody who's consuming that and you're continuing to bring that back, you're really reducing the environmental impact. So it really depends on whether or not you believe that reusing something and recycling it, getting a new value out of it is probably more beneficial for the environment. If you really believe that, then you would see that cradle to grave is probably the way to look at it. But not everybody is there yet, so it'll probably be controversial for a decade. That's why I'd be.
[00:29:01] Speaker B: Yeah, interesting.
With obviously these base oils, you are in many ways like competing against the conventional base oil, so to speak.
In some ways even just understanding, sort of like the rough. Obviously I'm not asking you for a price here, but in the ballpark, is the process of re refining price competitive with the virgin base oils?
[00:29:34] Speaker A: Yeah, it is.
It's interesting because obviously pricing comes down everything. If I told you I could give you a little bit of a benefit, but it was going to cost you ten times as much, you would say, well thanks, but I'm going to talk to you again versus somebody, you're going to get a pretty big improvement and it's only a small price higher. You might do it. I think it depends a lot on what the customers are trying to look at for their sustainability commitments. If we take some of these facilities that are trying to reduce their footprint for their buildings and they're buying hydraulic fluids, they see a real advantage to having no sustainable products because it's just reducing the footprint of their operation. And then if somebody's using it as a passenger car engine oil, they might not even know it's re refined base oil. So they say, why would I pay extra for that? That's like when you're walking through the line and somebody says I can pay one dollars extra for something better in their world, whatever that is, and people aren't going to pay for it. I think that there is a value. Customers do pay a higher price, they certainly don't pay double. But part of that is also we do have higher quality than what you would typically see if you were to compare that. And it's not that other products aren't as good, it's just you get what you get and people are then paying for the technical performance characteristics so they don't have to use a cutter stock. When you use a product like ours, because you're already hitting that kind of technical threshold to be able to make certain types of pcos or heavy duty diesel engine oils, you're getting a little bit of a premium for that. Somebody might paying a little bit more for the sustainability.
Like I said, it's not double. There is definitely an increase and I think we saw that really starting to evolve last year, and it's going to be an interesting ride, I think, on this because we also work really closely with the traditional crude refiners and the other ones, and there's value to all this. And certainly the work that they do and the products that they create are going into what we're taking to re refine. And then we make products with some of their materials and put it together and make finished products. So I think it ultimately will come down to some government regulation. It will come down to, unfortunately, if we see the world still changing of what seems to be a little bit of an environmental difference out there, at least I see that whether or not people think it's man made or not manmade, there are some changes that are occurring in the environment. And so if there are things that we can do to reduce those impacts, I think that that will also drive some of that. But I'd prefer that we don't have all those environmental impacts, quite frankly.
Yeah, it's going to be an interesting probably decade, I think, in the world of people really getting to a point where they see all the value in this and pay more.
[00:32:33] Speaker B: Yeah. And that's a really good segue into whenever we're wrapping up these kind of interviews. I like to ask a little bit about the future, and you've already touched on effectively where regulation might be going and where I think public sentiment might be going as well in terms of the perception of the value proposition, at least for re refined. So because we've already addressed that, maybe a question I wouldn't mind asking though is where does the technology for re refining go from here?
Have we reached peaked, re refined? Or is there still innovations that could enable, for example, high viscosity, re refined base oils to be made?
Maybe there's better performance that could be extracted through different refining processes. Is that kind of on the table or given the performance characteristics of the products that we have versus what the market demands, is there already kind of a pretty good synergy there?
[00:33:42] Speaker A: Yeah.
One thing that I find super exciting about working in this part of the industry is wanting to get to that next level. Right? What can we do differently? What's the future have for us?
What does the investment plan look like? What kind of things are we seeing in some of the data that might have something that would further enhance what we're doing? I definitely think that we'll have more synthetics and group threes. I think that we'll have higher viscosity products.
To me, it's super exciting. I mean, we have so many r and D projects going on and development projects with a lot of different types of groups. Some of those are in the industry and some of those are outside of the industry because there's so much learning that can occur. And overall, the lubricants industry, the whole focus on reducing friction and tribology and everything that's occurring out there is really about extending the life of assets. Right. You take a million dollar piece of equipment and with a little bit of lubrication, you can extend the life of that pretty significantly. And the need for products that can perform and products that have those environmental benefits, that's going to continue to evolve. I think also the world of AI and technology and what does the market need versus what the market creating and then connecting kind of what used materials are out there and what materials can be made from it. I see a lot of evolution in that, probably not all in my work career, but certainly in the coming years that will really advance the materials that we have coming out. So I see some really great things coming, and I know we're doing some of them, but others will do that as well.
[00:35:32] Speaker B: Yeah. Interesting.
Anytime I kind of ask about the future, it always seems like there's just kind of endless opportunity in our industry, which is very encouraging for people that have still a few decades left in this career. So, Joel, thanks so much for helping to answer a lot of questions. I think hopefully that's dispelled a lot of myths, I think, about re refining because there is that sort of uncertainty about what redefining is. And so I think you've helped a lot of people, I think, understand exactly what the processes are and the kind of quality of the end product as well, and what are know, what are the sustainability benefits of doing that. So I think that's a really helpful conversation to have had and hopefully people get a lot out of it. But Bajol, thanks so much for sharing your insight.
[00:36:29] Speaker A: Yeah, thank you very much for having me and best of luck. Talk to you soon.