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#1 Posted : 11 February 2009 22:12:00(UTC)
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Posted By Crim
Is it acceptable for a "scaff tag" loosely positioned on a MEWP to contain the record of inspection or is a certificate of inspection required on site?

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#2 Posted : 12 February 2009 12:50:00(UTC)
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Posted By Anderson8
Hi,

Scaff tag on a MEWP? that seems a strange one, give us a bit more info mate and we'll try and help.
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#3 Posted : 12 February 2009 14:26:00(UTC)
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Posted By David Matthew
I'd suggest to you that a scafftag product on its own isn't enough as there is a duty to report defects which can't be done by scafftag alone.
Regards
David
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#4 Posted : 12 February 2009 14:31:00(UTC)
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Posted By Raymond Rapp
We scaff tag all our mobile towers, if that is what you are asking.
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#5 Posted : 12 February 2009 14:33:00(UTC)
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Posted By Flic
Many people use paint or coloured tags on equipment to indicate which date they were inspected. This is very useful as you can see at a glance that something is 'in date'. The paper records are then kept elsewhere.

In principle something like a scafftag could be used, but it might not fit your needs very well because it may come with a printed inspection frequency etc that does not fit your needs.

In any event tagging systems do not detract from the need to inspect at the prescribed frequency, keep proper records, and the need for people to report defects as and when they arise.

Flic
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#6 Posted : 12 February 2009 14:43:00(UTC)
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Posted By Anderson8
Hi all,

Are we talking MEWP's (Mobile Elevated Working Platforms)or Mobile Scaffold towers here? Two quite different rule sets on these gents.

That's why i was confused in my earlier post :-)


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#7 Posted : 12 February 2009 14:53:00(UTC)
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Posted By Paul Leadbetter
Well, the question does refer specifically to MEWPs.

Paul
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#8 Posted : 12 February 2009 15:06:00(UTC)
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Posted By Anderson8
Well if that's the case, scafftags wouldn't be used on those.

Correct us if we are misunderstanding here Crim
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#9 Posted : 12 February 2009 17:16:00(UTC)
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Posted By Crim
Hi, just got home, away last night, so couldn't respond until now.

MEWP on hire from hire company with a scafftag in it's bracket on the MEWP.

The Site manager had been in touch and now has the paper certificate so will allow the MEWP to be used.

I was wondering if the scafftag is acceptable as a record on site or should the certificate of testing/inspection be delivered with the MEWP?

Can anyone shed any light of the differences in words used on these things i.e. "Inspection" "Testing" and "Examination".

Thanks for the interest.

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#10 Posted : 12 February 2009 17:31:00(UTC)
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Posted By Flic
Testing implies putting the item under stress and chacking that it does not fail - for example hanging a test weight from a crane, or pressurising a pressure receptacle to a pressure above the intended safe working pressure.

Inspection implies looking carefully at it to ensure that nothing is obviously faulty, that nothing has been tampered with, that everything on it is marked to the correct standards where necessary. Examples are looking at chains to see that none of the links is seriously worn or cracked and that they have not been permanently stretched (and I have seen each of these!).

Examination - I cannot distinguish between this and inspection, but I am sure someone else can!!

Flic
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#11 Posted : 12 February 2009 17:34:00(UTC)
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Posted By Flic
Testing implies putting the item under stress and checking that it does not fail - for example hanging a test weight from a crane, or pressurising a pressure receptacle to a pressure above the intended safe working pressure.

Inspection implies looking carefully at it to ensure that nothing is obviously faulty, that nothing has been tampered with, that everything on it is marked to the correct standards where necessary. Examples are looking at chains to see that none of the links is seriously worn or cracked and that they have not been permanently stretched (and I have seen each of these!).

Examination - I cannot distinguish between this and inspection, but I am sure someone else can!!

Flic

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#12 Posted : 12 February 2009 20:35:00(UTC)
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Posted By TonyB
The three terms are often used interchangeably. There is a difference, but this can be lost in the discussion.

From the original question. You MUST have a copy of the most recent 'Report of Thorough Examination' undertaken by the competent person under LOLER with the equipment on site and it must be 'in date'. This is a requirement under LOLER.

Your manager did exactly the right thing by not allowing its use until the document was both seen and he held a copy. Well done to him.

Cheers

Tony.
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#13 Posted : 12 February 2009 22:08:00(UTC)
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Posted By Nick Andrews
Tony is correct in saying that you must have a 'Report of Thorough Examination' undertaken by the competent person under LOLER with the equipment on site and it must be 'in date'. This is a requirement under LOLER.

If the MEWP lifts persons (as they do) then the inspection frequency is six monthly. There are exceptions to the six month frequency but very rarely used.

One note of caution, if you hire a MEWP or any other lifting equipment from say XYZ Hire Ltd and the certificates of thorough examination are produced by XYZ Hire Ltd, treat with caution. That is not to say that they are not bona fide and competent to produce such examination reports but they may just as likely not be. A SAFED member company would have engineers competent to carry out the thorough which is what the duty holder needs to ensure compliance. Remember, you have a duty to check competence. After all, would you let a gas engineer service your gas boiler if he wasn't CORGI registered?
Hope this helps
Nick
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#14 Posted : 13 February 2009 07:18:00(UTC)
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Posted By Flic
While I agree that testing, inspection and examination are often used interchangeably, this is incorrect. Testing, in the context of lifting equipment and pressurised equipment is definitely NOT the same as inspection or examination.

Flic
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#15 Posted : 13 February 2009 09:39:00(UTC)
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Posted By Crim
Thanks for the input, I will congratulate the site manager for his actions.

Next question:

Most MEWP's have either a white area or circular disc on the base with some information re the inspection dates. Is this information a substitute for the certificate?

I take the point about the hirer printing off the inspection information, I've had work done by alleged CORGI gas people that was not up to the required standard so I hear what you say.

Thanks again.

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#16 Posted : 13 February 2009 10:06:00(UTC)
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Posted By David Matthew
No in response to your last question
David
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#17 Posted : 13 February 2009 10:39:00(UTC)
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Posted By Crim
Thanks to all.

I have spoken to the site manager and congratulated him on standing his ground, informing him that the paper certificate is required.

That should just about end this thread.
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#18 Posted : 26 March 2009 17:41:00(UTC)
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Posted By knutsfordsafety
MEWPs, towers, scaffold platforms, cradles etc. are all covered by the same requirement for inspection under Reg 12 of the WAH Regs. If used for construction >2m they must be inspected by a competent person when first erected, or in the case of a MEWP, before first use on site. An inspection produced by the hire company at their depot will not suffice because the inspection must take place after delivery on site (to allow for any damage during transit). All the above platforms must then be inspected at least once every 7 days etc. and a report that conforms with schedule 7 of WAHR produced, issued within 24 hours and then kept on site until the end of construction and 3 months thereafter.

A scaff tag is a nice indication that the inspection has been carried out but does not contain sufficient information to satisfy the requirements of schedule 7.
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#19 Posted : 26 March 2009 20:34:00(UTC)
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Posted By Railroad
MEWP machines are thoroughly examined and records made under LOLER regs at intervals not exceeding 6 monthly.
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#20 Posted : 27 March 2009 14:50:00(UTC)
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Posted By Crim
knutsfordsafety says:

MEWPs, towers, scaffold platforms, cradles etc. are all covered by the same requirement for inspection under Reg 12 of the WAH Regs. If used for construction >2m they must be inspected by a competent person when first erected, or in the case of a MEWP, before first use on site.

Railroad says:

MEWP machines are thoroughly examined and records made under LOLER regs at intervals not exceeding 6 monthly.

Two similar requirements but each quoting different Regs.

Should I now be confused or should I accept that both are correct and attempt to apply all above requirements? I do understand that more than one Regulation can apply.

I thought the >2m rule had gone now?
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#21 Posted : 27 March 2009 16:04:00(UTC)
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Posted By JohnV
Crim, I have "cut & pasted" the following extract from HSE's "The selection and management of mobile elevating platforms" (CIS 58), which I hope will be of help. I would recomend you download a copy of CIS 58 as it has much useful reference material on MEWPS

"Thorough examination: MEWPs, and any material handling attachments, must be thoroughly examined at least every six months by a
competent person or in accordance with an
examination scheme drawn up by such a competent
person. You should ask to see and retain the report of the thorough examination for the equipment you are going to allow to be used on your site. If the report shows any defects" seek confirmation from the supplier that they have been remedied.
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#22 Posted : 27 March 2009 16:51:00(UTC)
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Posted By Dave Merchant
knutsfordsafety is correct - WAHR beats LOLER and PUWER (as it's more recent).

WAHR 12(4):

...every employer shall ensure that a working platform -
(a) used for construction work; and
(b) from which a person could fall 2 metres or more,
is not used in any position unless it has been inspected in that position or, in the case of a mobile working platform, inspected on the site, within the previous 7 days.

Note the (a) *and* (b). The "inspection" is not the same as the Thorough Exam (and isn't necessarily as in-depth), but is required to comply with WAHR Schedule 7 and the send-a-report-within-24-hours rule.
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#23 Posted : 27 March 2009 17:12:00(UTC)
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Posted By Crim
Dave, thanks, is the report then kept on site?
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#24 Posted : 28 March 2009 07:25:00(UTC)
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Posted By Dave Merchant
Crim - yes. See WAHR 12(6 - 8):

(6) Every employer shall ensure that the result of an inspection under this regulation is recorded and, subject to paragraph (8), kept until the next inspection under this regulation is recorded.
(7) A person carrying out an inspection of work equipment to which paragraph (4) applies shall -
(a) before the end of the working period within which the inspection is completed, prepare a report containing the
particulars set out in Schedule 7; and
(b) within 24 hours of completing the inspection, provide the report or a copy thereof to the person on whose behalf the
inspection was carried out.
(8) An employer receiving a report or copy under paragraph (7) shall keep the report or a copy thereof -
(a) at the site where the inspection was carried out until the construction work is completed; and
(b) thereafter at an office of his for 3 months.

It's basically a mirror of the TE system, and intentionally so as a TE report can be used in place of a WAHR inspection report.
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#25 Posted : 28 March 2009 10:36:00(UTC)
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Posted By George Wedgwood
Inspection of an item of work equipment, be it lifting, pressure, personal protective, vehicle, etc. is normally associated with a competent (or simply trained, recorded, appointed and aware) person undertaking a prescribed physical and visual observation of the equipment with a view to recording its condition in respect of its general and operational safety. Sometimes the instruction may include removal of certain parts as to allow a more detailed look at specific parts and will sometimes include a running or operational test to ensure that function is as the manufacturer's specification. It will not include stressing parts of the equipment as has been rightly pointed out.

Examination is more specifically a detailed process carried out by a competent person who has recorded knowledge of that equipment in detailed design and operational terms. Usually this means competent to specific criteria, such as for PSR. It will usually involve removal of parts, non destructive testing, measurement, detailed engineering reports, referral to design drawings and the involvement of engineers. All of this will be in accordance with a written scheme of examination approved by the CP and the owner of the equipment. It will usually involve a supervised operational test at and sometimes in excess of, normal operating parameters.

I hope this clarifies some of the confusion, though there is a lot more if anyone is interested!

Regards, George
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#26 Posted : 28 March 2009 19:33:00(UTC)
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Posted By Crim
Thanks to all, I thought this thread has finished last week but it just shows that there is a lot of interest in this forum and people jump in and out from time to time.

The most recent contributions have been most interesting and I will try to apply them in future.

Thanks again,

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#27 Posted : 30 March 2009 08:08:00(UTC)
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Posted By Anderson8
Hi all,

Dave, regs don't "beat" other regs simply because they are more recent unless it is an update on those specific regs.

All the regs apply you have being discussing, LOLER,WAHR & PUWER, as do others such as the Management & welfare regs etc. In many cases a situation may involve referencing many different ACOP'S, guidance and regs when carrying out an assessment.

Hope this helps
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#28 Posted : 30 March 2009 09:53:00(UTC)
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Posted By Dave Merchant
Anderson - in this case they do. WAHR.12(9) and LOLER.9 reports are equivalent, and WAHR specifies a stricter scheme than either LOLER or PUWER does. By following WAHR.12 you satisfy the other regulations by default, but can't satisfy WAHR.12 by implementing only the other two (which typically end up being interpreted as a 6-monthly reporting scheme). I'm not saying LOLER/PUWER etc no longer apply at all, but that their reporting systems are insufficient for working platforms as of 2005, because a more specific Regulation has been implemented.
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#29 Posted : 30 March 2009 11:21:00(UTC)
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Posted By Anderson8
I agree to a degree (if that makes sense). All work equipment need inspecting under PUWER, however, certain types of equipment whether that be lifting equipment, LEV equipment or indeed pressure equipment also requires additional inspections and testing under other legislation, so in carrying this out you are complying with PUWER & the above said requirements. That's not to say it does not apply, nor does it's latter release date hold any baring.

It's a technicality which is not really worth getting bogged down in, so long as you are complying with the relevant regs, in this case LOLER you are in turn complying with others.

regards
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#30 Posted : 30 March 2009 12:02:00(UTC)
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Posted By Davelfc
Reading through the posts I feel some people are getting mixed up between pre-use inspections, weekly inspections and the Through examination inspection, which in this case would all apply.

So you would be compliant with PUWER/LOLER & W@Ht Regs. If your competent operator inspected pre use daily and recorded, your manager or competent person inspected and recorded minimum weekly for a work platform that remained in one position for a week. You would still require the 6 monthly Thorough Examination for lifting equipment that lifts people, if it where materials lifting equipment then 12 monthly Thorough examination would apply.


So as someone quite rightly pointed out PUWER/LOLER and W@Ht regs all apply to MEWP's

As simply put you are using work equipment, you are also using lifting equipment (for people) and those people are working at height, simple really.

Scaftag is all well and good as a visual aid for putting equipment in and out of use for suitable controls.

Crim,

practically

If it helps I worked with scaftag at previous company to make a mast climber tag, as we had 36 of the things on a high rise development, we used the tag to put equipment in and out of use daily, so transient operatives could see at the user end that the equipment had been pre use inspected and put into use daily. This did not stop us having a daily Pre use inspection recorded and signed up to in the office, a weekly inspection which had other checks other than the Pre Use daily, 6 weekly maintenance inspections and 6 monthly Through Examination Inspection all recorded and filed away by competent persons,

The scaftag was particularly useful as a control as if something was found faulty the tag was simply removed and prohibited the use of the equipment until the fault was rectified and the tag simply inserted and put back into service. (oh this was also recorded)

If these procedures are in place it would difficult to find fault with your management systems, I appreciate MEWP's would have additional checks for ground conditions etc, but the principals are similar.

Hope this helps

Dave
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