Ezekiel 4:9-17 – Ezekiel Commanded to Cook Bread on Cow Dung




“‘But as for you, take wheat, barley, beans, lentils, millet and spelt, put them in one vessel and make them into bread for yourself; you shall eat it according to the number of the days that you lie on your side, three hundred and ninety days. Your food which you eat shall be twenty shekels a day by weight; you shall eat it from time to time. The water you drink shall be the sixth part of a hin by measure; you shall drink it from time to time. You shall eat it as a barley cake, having baked it in their sight over human dung.’ Then the LORD said, ‘Thus will the sons of Israel eat their bread unclean among the nations where I will banish them.’ But I said, ‘Ah, Lord GOD! Behold, I have never been defiled; for from my youth until now I have never eaten what died of itself or was torn by beasts, nor has any unclean meat ever entered my mouth.’ Then He said to me, ‘See, I will give you cow’s dung in place of human dung over which you will prepare your bread.’ Moreover, He said to me, ‘Son of man, behold, I am going to break the staff of bread in Jerusalem, and they will eat bread by weight and with anxiety, and drink water by measure and in horror, because bread and water will be scarce; and they will be appalled with one another and waste away in their iniquity.’”

reproduced from the Messianic Kosher Helper

The Book of Ezekiel informs Bible readers a great deal about various aspects of the kosher dietary laws, ancient issues faced in the Sixth Century B.C.E. by the exiles in Babylon, as well as futuristic issues pertaining to the Messianic Age. The Prophet Ezekiel was a priest (1:3), who had been taken into Babylonian captivity, and while in Babylon was directed by the Lord to do some rather out-of-the-ordinary actions, often to depict the shame of the exile.[1]

Among the actions, that Ezekiel is directed by God to perform, is that he was to lie on his left side 390 days for the House of Israel (4:4-5), and on his right side for 40 days for the House of Judah (4:6), with the fall of Jerusalem to Babylon impending. While seemingly an awkward activity, Ralph H. Alexander is right to conclude how, “The text does not demand that Ezekiel be on his side twenty-four hours each day. The rest of chapter 4 has Ezekiel fixing meals, while in chapter 8 Ezekiel sat in his house with the exilic elders during the final days of lying on his right side. It would seem that a portion of each day would suffice to fulfill the symbolism and the text.”[2]

It is important to recognize that there is some debate over the different numbers prescribed to Ezekiel, and what they represent. The Greek Septuagint actually has 190 years (which has passed into the NEB rendering of 4:5),[3] and various interpreters are convinced that this is a better way of approaching the passage, with Ezekiel’s actions looking back at the sins of both the Northern and Southern Kingdoms of Israel.

More customarily, though, and with the traditional Hebrew Masoretic Text in view, a Jewish interpreter like S. Fisch summarizes that “Abarbanel…reckons the period of Samaria’s guilt from the time when the schism took place under Rehoboam (cf. 932 B.C.E.) until the fall of Jerusalem. Corresponding to the 390 years of Israel’s sinning, the prophet was ordered to lie on his left side the same number of days to atone for their iniquity.” He further states, “Judah’s corruption lasted forty years beginning soon after Samaria’s fall. According to Malbim, the time is reckoned from the thirteenth year of the reign of Josiah (626 B.C.E.) when Jeremiah began his ministry (Jer. i. 2).”[4]

A number of interpretational options for the Prophet Ezekiel lying on his left side, then followed by his ride side, are described by Charles L. Feinberg, in his work, The Prophecy of Ezekiel:

“Many believe that the Greek Old Testament is probably correct in giving 190 days (representing years) in verses 5 and 9 instead of 390. Ezekiel would then have been on his left side 150 days and on his right side 40 days. The period from the deportation under Tiglath-pileser in 734 B.C. (II Kings 15:29) to the fall of Jerusalem in 586 B.C. was 148 years, or about 150 years. The forty years (about a generation) for Judah correspond approximately from 586-536 B.C., the time of Judah’s exile in Babylon. According to this reckoning there can be no exactness in the numbers; round numbers are the most that can be hoped for. Another view holds that, since there is no question as to the numbers in the Hebrew text, the longer period must be reckoned from the disruption of the kingdom under Rehoboam, son of Solomon (I Kings 11:31). According to the chronology of the book of Kings the period from Rehoboam to 586 B.C. was 394½ years. The figures can hardly refer to the duration of the northern kingdom apart from Judah nor even to Judah itself, because the kingdom of Israel continued from about 930-722 B.C., while the kingdom of Judah went on about 136 years after the fall of Samaria. The 40 years for Judah are assigned as those of the reign of Solomon.

“Other interpreters take the 430 years (390 years plus 40 years) to be symbolic. They see the figures as a representation of the future in the terms of the past, specifically a reminiscence of the 430 years Israel spent in Egypt and of the 40 years in the wilderness. Thus no exact period is in view by the prophet. Obviously, no completely satisfactory solution has been found as to the number, though the general concepts are clear enough.”[5]

There are conservative examiners who will favor the 190 years variant as perhaps being more accurate, but much of whether Ezekiel was to lie on his left side for 390 or 190 days is dependent on how one interprets the different punishments represented. Much of this is related to what Israel and Judah are intended to represent in 4:4-5. Later, in a place like Ezekiel ch. 37, the Northern and Southern Kingdoms of Israel are clearly supposed to be delineated out, with a futuristic reunification in view.[6] A challenge is presented when how the Beit-Yisrael or House of Israel referenced in 4:4, is later in 5:4[7] obviously a reference to Jerusalem and the Southern Kingdom of Judah. Christopher J.H. Wright informs us how most normally in the Book of Ezekiel, when the Northern Kingdom of Israel is intended to be represented, it is often referred to by terminology like Joseph or Ephraim—whereas when the House of Israel is often referred to, it can refer to all of Israel together, or in many cases to the Southern Kingdom of Judah. He explains,

“The northern kingdom of Israel came into existence only after the reign of Solomon around 930 or 920 BC in a coup d’état led by Jeroboam [1 Kgs. 12]. It was finally destroyed when Samaria fell to the Assyrians in 722/721 BC. So ‘Israel’, as the name of the separate northern kingdom, lasted only about 200 years. However, it is only the use of the term ‘Judah’ in 4:6 that makes us think, retrospectively, that ‘house of Israel’ in 4:4-5 refers exclusively to the separate northern kingdom. Up to that point in the preceding chapters of the book (e.g. 2:3; 3:4, 7, 17), the expression ‘house of Israel’ clearly means the whole covenant people, without reference to the historical division into two political states. In fact, since Ezekiel was explicitly told to go and speak to the ‘house of Israel’, the expression obviously means, in those contexts, his fellow exiles from the kingdom of Judah, not the exiles of the northern kingdom who had been scattered by Assyria more than a century earlier. Likewise, in 4:13, ‘people of Israel’ obviously refers to the Judean exiles in their deprivation. It seems very probable, therefore, that the political division of the kingdoms is not in view in these verses, and that ‘house of Israel’ and ‘house of Judah’ are being used virtually synonymously.”[8]

With House of Israel (4:4) representing the whole of Israel, both the Northern and Southern Kingdoms, then the 390 days for the 390 years, begins a period of the Prophet Ezekiel lying on his side for the sins committed by Israel since the time of Solomon, with Wright[9] subsequently taking the 40 days afterward representing the 40 years of exile that Judah would experience. Peter C. Craigie, however, properly directs readers, “it would be a mistake to take the numbers to be the central aspect of this symbolic action. For the audience at that time, the most evident aspect of the action would be that day after day, month after month, there was Ezekiel prostrate on his aside on the ground, symbolising the weight of God’s punishment on his people. It was the length and continuity of the actions that would carry such impact to the audience; only after the actions were completed would the numbers suddenly assume significance.”[10] Indeed, our attention, in view of the bread that the Prophet Ezekiel is directed by the Lord to cook (4:9), and his reaction to cooking it (4:14), is how this affects our overall Biblical understanding of the Torah’s dietary laws.

4:9-11 The Prophet Ezekiel was instructed by God to make a special kind of bread to eat, which included ingredients not normally used to make bread: “take wheat, barley, beans, lentils, millet, and emmer. Put them into one vessel and bake them into bread. Eat it as many days as you lie on your side: three hundred and ninety” (v. 9, NJPS). Craigie labels this as “a kind of ‘bits-and-pieces bun.’”[11] The main point, more than anything else, is that the bread which Ezekiel was directed to make is the food of hard-rationing, which would be present in Jerusalem during the Babylonian siege (vs. 1-2). The actual measurements for the bread and water to be consumed are stated in vs. 10-11, “The food that you eat shall be by weight, twenty shekels a day; this you shall eat in the space of a day. And you shall drink water by measure; drink a sixth of a hin in the space of a day” (NJPS). Twenty shekels is about 8 ounces or 0.23 kilograms, and a sixth part of a hin is about 1.4 pints or 0.6 liters.[12] IVPBBC further describes,

“The fact that Ezekiel’s food has to be weighed out and eaten at a particular time signals that this is the hard-rationing that would have been necessary during a siege. Twenty shekels would be equivalent to eight ounces of food. That amount of calories would keep him alive, but it would also significantly weaken him. The weakness of a starvation diet mirrors conditions in Jerusalem….Water rationing would also be necessary during the siege, since the people would be dependent on the supply in cisterns…and the pool deriving from the Siloam tunnel. Ezekiel’s ration is one-sixth of a hin or two-thirds of a quart per day. The extremely hot conditions during the summer and fall of 588 would have severely taxed the besieged people of Jerusalem. Such a small water ration would have further contributed to their misery.”[13]

Because of the commercial popularity, in various Christian and even Messianic quarters, of what has been marketed as “Ezekiel’s bread” as a healthy bread—much can be lost on some readers. Katheryn Pfisterer Darr makes light of how, “In our age, ‘multi-grain’ bread is lauded for its nutritional benefits. Here, however, Ezekiel’s resort to a bit of this and that signals shortages in Jerusalem, where no single foodstuff is available in sufficient amount to make a loaf.”[14] Some later, rather negative and crude observations, on the bread to be cooked by Ezekiel, were made in the Talmud:

“Said R. Hiyya bar Abin said Rab, ‘They prepare a fictive fusion meal with bread made from lentils.’ Well, now, is that so? But wasn’t some bread of that kind made in Samuel’s time, and he didn’t eat it but tossed it to his dog? That bread was made up of a mixture of various kinds of grain, for thus it is written: ‘Take for yourself wheat, barley, beans, lentils, millet, and spelt’ (Eze. 4:9) [this is a time of famine, and people eat anything, but ordinarily people don’t eat that kind of bread (Slotki)]. R. Pappa said, ‘That was baked in human shit: “And you shall bake it with shit that comes out of a man in their sight” (Eze. 4:12).’ What’s the meaning of “barley” in the verse, ‘And you shall eat it as barley cakes’ (Eze. 4:12)? Said R. Hisda, ‘It means, in fixed quantities.’ R. Pappa said, ‘It is prepared the way barley bread is prepared, not the way wheat bread is’” (b.Eruvin 81a).[15]

4:12-13 What is a bit revolting about the bread that the Prophet Ezekiel was directed to prepare, is seen in how he was directed to cook it: “[The bread] you eat is to be baked like barley cakes; you are to bake it before their eyes, using human dung as fuel” (v. 12, CJB). This is a bread that is to be cooked via a fire, which uses human excrement for fuel! It does need to be noted—before modern, Western readers, seem a bit nauseated about this—that the use of excrement, due to the scarcity of wood in the Ancient Near East, was hardly uncommon. Lamar Eugene Cooper describes,

“The use of animal manure as a fuel did not violate the strict dietary laws of Israel. Human waste, however, was considered a defilement (Deut 23:9-14), and its use in such a manner was strictly prohibited. Having grown up in a priestly family and probably in training as a priest himself, Ezekiel was especially sensitive to this command to prepare a meal in such an unclean manner.”[16]

The specific Hebrew instruction was, b’gel’lei tzei’at ha’adam te’ugenah. Perspective issues are present with how to translate the Hebrew preposition b’, with English versions variably having “over” (NASU), “on” (RSV/NRSV/ESV), “with” (NJPS, ATS), and with the NIV employing the ambiguous “using.” A very obvious translation of the preposition b’ can actually be, as it is the first definition of b’ provided by BDB, “In.”[17] While some context needs to always be considered, A Guide to Biblical Hebrew Syntax indicates that a spatial usage of the preposition b’ “indicates localization, especially ‘in,’ ‘at’ or ‘on’ a place.”[18] As some have had to note (discussed further), Ezekiel was actually instructed to cook this bread in the hot coals of a fire fueled by human excrement.

What is intended to be insulting and humiliating about this bread, is how God tells Ezekiel, “Thus will the Children of Israel eat their food: unclean, among the nations where I will banish them” (v. 13, ATS). The bread of the exile is bread that is decisively unclean (cf. Hosea 9:4).

4:14-15 The Prophet Ezekiel’s response to the Lord’s direction is one of not only disgust, but one of reminding Him how he has been consistent in his obedience to the Torah’s instructions on food: “Ah, Lord GOD, my person was never defiled; nor have I eaten anything that died of itself or was torn by beasts from my youth until now, nor has foul flesh entered my mouth” (v. 14, NJPS). To cook bread within the hot coals of human dung, would be just as bad to eat from an animal that had been violently killed, or to eat any other kind of “loathsome” (ATS) meat. Here, it is useful to keep in mind what is communicated by Deuteronomy 23:12-14, regarding the disposal of human waste:

“You shall also have a place outside the camp and go out there, and you shall have a spade among your tools, and it shall be when you sit down outside, you shall dig with it and shall turn to cover up your excrement. Since the LORD your God walks in the midst of your camp to deliver you and to defeat your enemies before you, therefore your camp must be holy; and He must not see anything indecent among you or He will turn away from you.”

With Ezekiel having told the Lord how he had never violated the instructions of clean or unclean, or had been defiled by what he had eaten, the concession is made to him to instead cook his bread over cow manure: “He answered me, ‘See, I allow you cow’s dung instead of human excrement; prepare your bread on that’” (v. 15, NJPS). Here, the Hebrew clause of interest is v’asita et-lach’mekha alei’hem, “and-you-can-make *** bread-of-you over-them” (Kohlenberger).[19] The preposition al, being spatial or locative, often “indicates a location ‘over’ or ‘upon’ an object” (A Guide to Biblical Hebrew Syntax).[20] Noting the differences between the prepositions b’ (v. 12) and al (v. 15), Steven Tuell concludes,

“The Hebrew implies that Ezekiel’s bread was to be cooked not over the fire, but in its hot ashes, so that the food would be in direct contact with the unclean fuel…But now God tells Ezekiel that he may prepare his bread over cow manure…Rather than cooking his food in the ashes, he can fry his bread above them. Apart from the uncleanness incurred in collecting and drying the manure, Ezekiel is spared defilement—as well as the indignity of collecting, drying, and cooking in his own dung.”[21]

4:16-17 It is decreed to Ezekiel that the food supplies of Jerusalem will be rationed, and that his actions are mimicking of what is to transpire: “Son of Man, behold, I am breaking the staff of bread in Jerusalem, and people will eat bread by weight and with worry, and drink water by measure and with consternation; for they will lack bread and water, and every man and his brother will be confounded, and they will pine away in their iniquity” (ATS). Vs. 16-17 include some echoes of Leviticus 26:26, 39:

“When I break your staff of bread, ten women will bake your bread in one oven, and they will bring back your bread in rationed amounts, so that you will eat and not be satisfied…So those of you who may be left will rot away because of their iniquity in the lands of your enemies; and also because of the iniquities of their forefathers they will rot away with them.”

Ezekiel 4:9-17 application The main thrust of what is seen in Ezekiel 4:9-17 is that the Prophet Ezekiel, having already been taken into Babylonian exile, is directed by God to eat the sort of food that those in Jerusalem will be forced to eat, as the city will soon be under siege. As Marvin A. Sweeney observes, “The coming disaster will result in the people lacking food, so that they and the priests will be compelled to violate their food restrictions, and will have to eat impure food when Jerusalem and the Temple are under siege and ultimately destroyed. Ezekiel mixes a variety of grains, including those not normally consumed in bread, to demonstrate that there is insufficient grain to make an entire loaf of bread.”[22]

The most shocking piece of instruction within Ezekiel 4:9-17 is undeniably how the Prophet was first directed by God to cook this bread within the hot coals of a fire fueled by human feces (4:12). Given the fact that Ezekiel was a priest, and observed the Torah’s dietary laws, the Prophet declares that he is innocent of any violation of the Law (4:14). The Lord makes a concession to Ezekiel, that he may cook his bread over a fire instead fueled by cow dung (4:15), meaning that the only uncleanness Ezekiel would contract, would be by collecting and processing this. It is to be recognized, however, that those in Jerusalem, who would have to suffer through the siege and hard-rationing, would have to cook their bread over their own excrement.

The word of Ezekiel 4:14, “Ah, Lord GOD! Behold, I have never defiled myself. From my youth up till now I have never eaten what died of itself or was torn by beasts, nor has tainted meat[23] come into my mouth” (ESV), is quite similar to what the Apostle Peter would later say in Acts 10:14,[24] when he would be shown the vision of the sheet with various unclean animals on it.[25] There is discussion as to whether or not the Prophet Ezekiel, in being directed to bake the bread in human feces, and later over cow excrement, was a part of some significant alteration being made by God to His Instruction. Alexander takes the view, “God was not changing his law when he commanded Ezekiel to do all this. God temporarily caused Ezekiel to disregard the principle of eating unclean food to dramatize in an extreme way how abhorrent the Captivity would be. God used an acted parable to convey this truth in a way that would surely be understood. However, this was only symbolic; the eating of unclean food as a normal practice was not being condoned. God sovereignly protected Ezekiel against any ill effects of eating defiled food.”[26]

While the bread Ezekiel was directed to cook hardly sounds appetizing, and having to cook it over cow dung formed and dried with one’s own hands is not at all appealing—it would be those in Jerusalem having to cook with their own feces, who would be in far more violation of Torah instructions regarding cleanliness, than Ezekiel’s minor infractions. This is especially realized in how the siege of Jerusalem would result in cannibalism (5:10), something also having been witnessed with the previous siege of Samaria (2 Kings 6:28). The Prophet Ezekiel’s actions are a far cry from what the Prophet Jeremiah decreed would happen, and what the author of Lamentations (likely Baruch) observed:

“I will also make this city a desolation and an object of hissing; everyone who passes by it will be astonished and hiss because of all its disasters. I will make them eat the flesh of their sons and the flesh of their daughters, and they will eat one another’s flesh in the siege and in the distress with which their enemies and those who seek their life will distress them” (Jeremiah 19:8-9).

“The hands of compassionate women boiled their own children; they became food for them because of the destruction of the daughter of my people” (Lamentations 4:10).

Per the reaction of the Prophet Ezekiel (4:14), various Christian interpreters have rightfully noted that there is some kind of a connection to be made with the Apostle Peter’s word, when shown the vision of the sheet. It is often recognized that for the Prophet Ezekiel, who was directed by God to do some out-of-the-ordinary things in cooking the bread, that ultimately the dietary laws of the Torah were not abolished—as instead Ezekiel was directed to demonstrate some of what the Jerusalemites would have to do under siege. Yet, most Christian commentators on the Book of Ezekiel would conclude that the later vision given to the Apostle Peter in Acts chs. 10-11, does communicate that the Torah’s dietary laws have been abolished for the post-resurrection era. In the estimation of Joseph Blenkinsopp, “Inevitably, the reader of the New Testament will recall Simon Peter’s reaction when commanded to eat ritually impure food (Acts 10:9-16; 11:5-10). The fact that these laws were eventually abrogated within the mainstream of Gentile Christianity should not lead the Christian reader to misconstrue their intent.”[27] He describes the uniqueness of Ezekiel’s community, urging contemporary Christians not to be negative toward the kosher dietary laws, by further stating, “There is a certain ecological concern here—for bodily states, what we ingest; in a word, for the body as that part of the world for which we are especially responsible…The preservation of that culture in the inhospitable milieu in which the deportees found themselves remained a major concern of his throughout his career.”[28] The bread that Ezekiel had to eat was intended to ultimately communicate how humiliating the judgment and exile upon Israel was going to be, and how much of the Torah would be unable to be properly followed in exile.

Messianic readers of Ezekiel 4:9-17, who adhere to the continued validity of the kosher dietary laws in the post-resurrection era, will need to take some cues from what the Prophet Ezekiel was instructed to do (4:9-12), his reaction (4:14), and God’s allowance to him (4:15). While the bread he was directed to bake was hardly appetizing, the only uncleanness Ezekiel would contract would be with having to get his hands dirty in collecting and processing the cow excrement for the fire; Ezekiel would not be eating unclean bread cooked with human waste, unlike those in Jerusalem under siege, and a great many of those who would go into the exile, as a part of their punishment.

Given this background for what the Apostle Peter would later declare to God in the vision of the sheet (Acts 10:9-15), there should be a greater probing of the setting considered by readers, further consideration for the details of what Peter would be shown by God, and also an evaluation of Peter’s subsequent actions (discussed further).


[1] Consult the entry for the Book of Ezekiel in the workbook A Survey of the Tanach for the Practical Messianic.

[2] Ralph H. Alexander, “Ezekiel,” in EXP, 6:769; also Christopher J.H. Wright, The Message of Ezekiel (Downers Grove, IL: InterVarsity, 2001), 77 fn#40; Daniel I. Block, New International Commentary on the Old Testament: The Book of Ezekiel, Chapters 1-24 (Grand Rapids: Eerdmans, 1997), 179.

[3] “Allowing one day for every year of their iniquity, I ordain that you bear it for one hundred and ninety days; thus you shall bear Israel’s iniquity” (Ezekiel 4:5, NEB).

[4] S. Fisch, Soncino Books of the Bible: Ezekiel (London: Soncino, 1950, 1994), 21.

[5] Charles L. Feinberg, The Prophecy of Ezekiel: The Glory of The Lord (Chicago: Moody Press, 1969), pp 33-34.

[6] Consult the exegesis paper on Ezekiel 37:15-28, “Have the Two Sticks Been Reunited?” by J.K. McKee, appearing in his book Israel in Future Prophecy.

[7] “Take again some of them and throw them into the fire and burn them in the fire; from it a fire will spread to all the house of Israel” (Ezekiel 5:4).

[8] Wright, The Message of Ezekiel, 78; also Iain M. Duguid, NIV Application Commentary: Ezekiel (Grand Rapids: Zondervan, 1999), 91; Block, Ezekiel 1-24, pp 75-76; Steven Tuell, New International Biblical Commentary: Ezekiel (Peabody, MA: Hendrickson, 2009), 26 take both the Northern and Southern Kingdoms of Israel being in view here.

[9] Wright, The Message of Ezekiel, 80.

[10] Peter C. Craigie, Daily Study Bible Series: Ezekiel (Philadelphia: Westminster Press, 1983), 31.

Ibid., 32 takes the view that the 430 days represents the 430 years connected to the servitude in Egypt and the Exodus, and that a New Exodus from the exile is in view with Ezekiel’s actions.

[11] Ibid., 33.

[12] David J. Reimer, “Ezekiel,” in ESV Study Bible, 1507.

[13] Walton, Matthews, and Chavalas, 693.

[14] Katheryn Pfisterer Darr, “The Book of Ezekiel,” in NIB, 6:1148.

[15] The Babylonian Talmud: A Translation and Commentary.

[16] Lamar Eugene Cooper, New American Commentary: Ezekiel (Nashville: Broadman & Holman, 1994), 97.

[17] BDB, 975.

[18] Bill T. Arnold and John H. Choi, A Guide to Biblical Hebrew Syntax (New York: Cambridge University Press, 2003), 103.

[19] Kohlenberger, 4:309.

[20] Arnold and Choi, 120.

[21] Tuell, 28.

[22] Marvin A. Sweeney, “Ezekiel,” in Jewish Study Bible, 1052.

[23] Block, Ezekiel 1-24, 186 describes how “the last expression, bĕśar piggûl, is rare, but the sense is suggested by Lev. 7:18 and 19:7, where piggûl refers to sacrificial meat that has not been eaten by the third day. In the absence of refrigeration such meat would obviously have begun to decompose. In Isa 65:4, the only other occurrence of the term, the ‘broth of piggulîm’ is pared with bĕśar haḥazîr, ‘the flesh of swine.’”

[24] “No, Lord; for I have never eaten anything that is common or unclean” (Acts 10:14, RSV).

[25] Cf. John B. Taylor, Tyndale Old Testament Commentaries: Ezekiel (Downers Grove, IL: InterVarsity, 1969), 84; Wright, The Message of Ezekiel, 82; Duguid, Ezekiel, 96.

[26] Alexander, in EXP, 6:770.

[27] Joseph Blenkinsopp, Interpretation, A Bible Commentary for Teaching and Preaching: Ezekiel (Louisville, KY: John Knox Press, 1990), pp 37-38.

[28] Ibid., 38.