CPCS A25/A26 MEWP (Mobile Elevating Work Platform) – Scissor & Boom Course

1. Introduction

This training course is designed to provide all the essential knowledge and skills required by operators of mobile elevating work platforms, in order to carry out their work in a safe and efficient manner. This course is aimed at personnel who are required to operate MEWPs.

Following the introduction of mobile elevating work platforms (MEWPs) operated by anyone needing to access an area above ground level, be it on a construction site or in a factory, it has now become essential that operators have received an appropriate level of formal training in conjunction with the applicable regulatory requirements.

The working from mobile elevating work platforms is a high-risk activity and is a type of work often carried out in construction and other related industries. It is considered to be high risk as it involves working at height, near or adjacent to fragile surfaces or near to other hazards such as overhead power lines.

1.1. Overview

This training course is designed to provide the participants with the knowledge and skills required to use both types of MEWPs, correctly and safely. These courses feature a combination of classroom-based instruction for the theoretical content and instructor-led practical training and assessment. The main objective of the course is to assess the operator’s ability to operate the powered access equipment to an acceptable standard. These training courses will ensure operators are compliant with current health and safety legislation and regulations. Successful candidates will receive a Red CPCS Trained Operator Card valid for 2 years and an IPAF PAL Card. This is recognized throughout the industry as proof of competence in Mobile Elevating Work Platform (MEWP) operation. This is an intensive training course which requires full commitment from the candidates, and no previous knowledge or experience of driving a scissor or boom lift is necessary. The categories the course covers are: CPCS A25 – Mobile Elevating Work Platform (MEWP) – Scissor CPCS A26 – Mobile Elevating Work Platform (MEWP) – Boom

1.2. Course Objectives

The practical element of the course is spent learning pre-use checks, safe operation of the MEWPs, and post-operational procedures. This will include basic operating skills and knowledge of how to transfer and position the machine in an assortment of locations. An understanding of how to minimize any crushing hazards will be gained. The course will make the operator aware of typical hazards associated with using MEWPs and how to avoid them.

The operator will be aware of the different MEWP classifications, for example, the use of indoor and outdoor scenarios. The operator will also be aware of the inspection requirements for MEWPs and understand how to locate and interpret the manufacturer’s instructions. This will include knowing the relevant documentation required for various tasks. Upon successful completion of the theory lessons and a theoretical assessment, the operator will then have sufficient knowledge to operate various MEWPs.

At the end of this course, the operator will be aware of the relevant health and safety regulations and be aware of accepted safe practices when using MEWPs. This will include knowledge of the causes of instability of the machines and how to reduce this instability. The operator will also be aware of hazards when using MEWPs on different ground conditions and near other obstructions.

1.3. Target Audience

This course is aimed at personnel who are involved in or required to work with any kind of Mobile Elevating Work Platform in the workplace. It is intended to provide all the basic knowledge and practical skills required for operating a MEWP Operatives – on completion the learners would have sufficient understanding of the informed supply. This course covers the following categories: A – Static Vertical (1a, 1b, 1c and 1d) mobile scissor and vertical personnel platforms; B – Static Boom (3a and 3b) mobile, cherry picker and personnel platforms mounted on a vehicle; C – Mobile Vertical (3a and 3b), mobile, vertical and personnel platforms and D – Mobile Boom (3a and 3b) and vehicle mounted mobile boom. After successful completion and once you have received your CPCS trained operator card (red card), it will be valid for a period of 2 years. At the end of the 2 years, you will be required to take a 1-day CPCS refresher course before you can renew your card. This will be the same duration for anyone who attained their card before a certain date and received the CTA (Competent Trained Operator) card. This will also need renewing with the correct qualification i.e. scissor and boom A25 and A26. During the course, the trainers will constantly assess to determine the level of understanding and skills capability, with the requirement to achieve 100% passing rate. The duration of the course generally runs as follows: 5 days – novice operators who have never held any sort of certificate or licence. 3 days – operators who have gained a blue or other card through NVQ. 2 days – experienced workers who merely need to brush up on their operating skills and do not require any health and safety training and knowledge. A 1-day test only option is available to those who have worked in the industry a minimum of 5 years, can move and handle the MEWP, and clearly understand all aspects of the operation and safety requirements. This would be determined by the trainer at the time.

2. MEWP Types

There are two basic types of MEWP – scissor and boom. Scissor lifts move only vertically, and are widely used in construction and manufacturing where work platforms need to reach up and over obstacles – such as ceilings. Incorporating the latest technology, scissor lifts are more compact and lighter weight than ever before – offering excellent manoeuvrability in tight spaces – plus electric operation for indoor use. Boom lifts are designed for areas with limited access in construction and industrial applications. Characterised by their ‘up and over’ approach, the upper boom extends ‘up and over’, and the work platform moves vertically, then horizontally. There are various types of boom lifts – trailer booms, self propelled and static booms which can be driven whilst elevated. Due to the utmost importance in safety when working with MEWP, both scissor and boom type machines now come with secondary guarding devices. The MLA and Access Link Up have been working together to make a ‘safety harness something you use instead of a system to stop you using something’. This has resulted in MLA banning the use of safety harnesses in the platforms of certain MEWP in an effort to make the secondary safety devices the primary form of fall protection.

2.1. Scissor Lifts

Scissor lifts are commonly used in construction and are appropriate when a straight vertical lift is required. The key advantage of a scissor lift over other types of MEWPs is its ability to provide a stable platform and often a larger platform size. The CPCS questions for scissor lifts will be based around using and maintaining a scissor lift safely and efficiently. Common questions include pre-use checks, ground assessment, setting up, loading and recharging, safe operation, and shutdown. It would be beneficial to cover the manufacturer’s guide as legislation states operators should have been trained to use the access equipment that they are using. Manufacturers now tend to provide information on DVD video and online, and it is often not in a written format. During the theory session, we will go through this guide to see if it is enough to aid you to operate the scissor lift safely and proficiently. Instructors may wish to mark some of the questions at the end of a session or as an overall assessment, dependent on preference and number of candidates.

2.2. Boom Lifts

Articulated boom lifts are designed to reach up and over obstacles; an ideal option if you have to work in areas which are difficult to access. These cherry pickers are often used for many types of construction jobs as well as maintenance work, they are well suited to tasks such as roof work, as the lift can provide easy and safe access whilst avoiding the need to build towers or scaffolding. These are also a great option for tree surgery as the maneuverability combined with the machine’s light weight can minimize damage to lawns and flowerbeds. A telescopic boom offers greater horizontal reach than any other type of MEWP, making it the best option for areas with limited access, as well as providing the best outreach for high level or outdoor work. This type of lift has best-in-class gradeability and reach, meaning it can handle rough terrain and hard to reach spots.

An articulated or telescopic boom lift can be used to gain access to work areas that are up high. This type of mobile elevating work platform (MEWP) is ideal for outdoor use, especially where there is rough or uneven ground. Choose from the environmentally friendly electric plug-in or the hybrid engine powered booms.

2.3. Other Types

There are several MEWP types that not many will be familiar with; however, it is useful knowledge for all plant operators. The first is a Vehicle Mounted Platform, which as the name suggests is a MEWP bucket that is fixed on the back of a vehicle. This could be a very useful machine when having to work along roadways or anywhere that has a slight slope and traction could be an issue. The buckets would come in various shapes and sizes and they can be adapted with various tools or materials handlers. The next type is called a ‘Mast Climber’. This is a work platform that is moved up and down with a direct acting hydraulic lift, very much the same as lifts you will see in many retail or commercial buildings, however, these are much more robust. The last of the other types is an interesting machine known as an Insulated Aerial Device. This MEWP has a specific use. It is used by linesman who would be working on live electrical networks, the insulated device protects the user and is tested to ensure it is safe to use on voltages. If a machine is not safe, it could conduct electricity to the ground and electrocute the operator. All these machines have their uses and specific applications.

3. Safety Regulations

“Training and licensing is not only a requirement by law but also essential to reduce accidents through their gross misuse or inept handling by untrained operatives. It is therefore imperative that thorough theory and practical training is given. Operators should be trained to an approved standard in the categories of machines that they use, training should be machine specific e.g. Static Booms, Mobile Booms, Scissor Lifts and Mast Climbing Work Platforms. Frances Brown, Training and Safety Manager of the Access Alliance, says that ‘Operators should be trained to an approved standard in the categories of machines that they use; training should be machine specific.’ The initial training should consist of 2 parts; theory and practical, with an assessment to measure competence. Successful trainees should be issued with a Licence To Practice, proof of training and operating experience. It should be remembered that machine categories need to be refreshed if an operator is not regularly using a particular type of machine. A more detailed explanation to the above can be found in the HSE document publication ‘Raising the standard’ and in the working relationship with IPAF as an associate member following the standardised training requirements. An on-going assessment for any new risks or knowledge relevant to changes in work equipment or the work environment should be addressed and training modified if necessary. An ‘Experienced and familiarised’ approach should be taken if an operator is to use a new type of MEWPs which is covered under a recent European proposal (EPI 2009/48/EC) on the harmonisation of the laws of member states relating to the making available on the market and supervision of the use of products.” Risk assessment is a legal requirement, necessary to protect the health and safety of employees at work. It should be carried out by the owner or person hiring in the MEWP and should be specific to the tasks and type of MEWP to be used. The assessment should address the applicable risks and appropriate control measures, taking into account the increased likelihood of overturn and crushing accidents when working at height with MEWPs. A detailed guide on risk assessment can be found in the HSE publication ‘Five steps to risk assessment’.” This is also relevant to the work covered under contractors who should co-ordinate and co-operate their activities ensuring safety and health requirements in article 10 of the Construction Industry Directive (89/391/EEC) are met. Requirement should be managed into a method statement specific to the task, type of MEWP and associated risks, highlighting planned control measures and how they will be implemented. A sample list of generic safe working practices for MEWPs can be found in the IPAF publication for safety on MEWP operations. This can assist in the formation of any necessary safe systems of work and should be translated in consideration to many non-native English speakers working in the UK construction industry.

3.1. Legal Requirements

This section requires candidates to understand what is required of them by law in order to work safely with MEWPs; that is to protect the health and safety of employees, the public and to comply with the Work Equipment Regulations 1998 (PUWER). The Health and Safety at Work etc Act 1974 requires employers to ensure the health and safety of all employees and provide adequate training for employees who are considered to be at risk. This is backed up by the Management of Health and Safety at Work Regulations 1999, which requires employers to carry out risk assessments for all work activities. The Provision and Use of Work Equipment Regulations (PUWER) cover equipment used at work. The employer has a duty to ensure that equipment is suitable, maintained, and inspected as well as ensuring the safety of users and non-users. People using MEWPs for work must also comply with the Lifting Operations and Lifting Equipment Regulations 1998 (LOLER). This requires that equipment used for lifting is safe to use, assessed for suitability and has been properly maintained. A25: Crawler – the specific requirements of this category have to ensure that the unit is stable and secure to operate following the requirements of the Work Equipment Regulations; as it applies to construction equipment designed to operate with limited mobility tracked based constructions will be used/selecting this category for MEWP.

3.2. Risk Assessment

Any risk assessment must take into account the suitability of the equipment and its safe use requirements. Often, there will be tasks for which the most suitable equipment will be a MEWP, and this is considered a positive step in that it can avoid work at height using less safe methods such as using ladders or steps. Nevertheless, it is an employer’s duty to weigh up whether work using a MEWP puts operators at an acceptable level of risk in comparison to the nature of the work and to take into account both the cost of safety and the availability of equipment.

If we just consider a task as simple as changing light bulbs in a supermarket, the operator will be working above ground level, and it will not be possible for him to create a safe means of access. Here, an assessment should consider what hazards exist and decide what preventative measures should be taken. For example, the area may need to be cordoned off to ensure others are not put at risk from falling objects or debris.

A MEWP is designed to deliver personnel to an elevated position where it is not possible to do so by means of a solid construction. Since a MEWP is meant to travel, this often leads to its use in areas where driving up to the elevated work area would result in an unstable or dangerous position for the machine. This type of work done on an uneven surface creates a risk of overturn and the crushing or trapping of an operator between the platform and another structure.

A risk assessment must be carried out and documented if more than two people are working together. Where there are five or more employees, regular risk assessments must be carried out. A significant number of people are killed or seriously injured in the workplace. This devastating toll includes a considerable number of employees who are killed or injured when using work equipment. Measures must be taken to control risks, and as a general rule, there are particular hazards associated with work equipment. A risk assessment must be carried out where there may be risks to the operator or others, or where risks cannot be avoided.

3.3. Personal Protective Equipment (PPE)

An individual must assess the risks associated with the use of MEWPs and select the most appropriate PPE for the task. In principle, if the work situation is such that it requires a hi-visibility jacket to keep the wearer safe, then the same situation would require the use of a harness and energy absorbing lanyard to keep the wearer safe while working from a MEWP. The only exception to this rule is when the user is at AWE and the EWP has been selected as the means of access due to its safety and there is no requirement for additional PPE as the EWP is the control measure. Choose the right PPE to match the task and situation. Remember that the use of PPE will always be the last line of defence and should be used to compliment other control measures. The following is a list of the most commonly used PPE for work in or from a MEWP and its suitability. Hi-visibility Jacket – essential for all construction work and often a requirement when using an EWP as it can be difficult for other site personnel and vehicle operators to see the EWP and its operator.

4. MEWP Components

4.2 Platform The platform should be capable of carrying a load as specified by the manufacturer. There should be a means to secure the platform to the machine for transportation. The platform and guardrail system should conform to applicable standards. On a scissor MEWP, the platform extensions must have an automatic locking device.

4.1 Control Panel An integrated key switch on a MEWP must allow the operator to select either platform or ground control. A boom-type MEWP should have a function that enables the operator to select either rotating the turret or using the upper controls. The symbols on the controls and the following text should be as defined in ISO 6405 and ISO 3864. Boom-type MEWPs should also have a function that enables the operator to start/stop the LOTS.

MEWPs are designed and manufactured in accordance with rigorous European standards for mobile elevating work platforms. For safety purposes, MEWPs are equipped with a Loss of Tractor System (LOTS) to stop the machine from moving when it detects a low amount of power from the engine. This is especially important for a boom-type MEWP, as it can be very dangerous if the machine stops moving while the platform is still in the air. Boom-type MEWPs also have audible alarms, an active up and down function for the platform, and an overload sensor that indicates to the operator when the machine is overloaded.

A mobile elevating work platform (MEWP), also known as a cherry picker, aerial platform, or access platform, is a mechanical device used to provide temporary access for people or equipment to inaccessible areas, usually at height. There are two distinct types of MEWPs: boom and scissor. A scissor MEWP uses a linked, folding support in a criss-cross “X” pattern, known as a pantograph, to elevate and descend in a straight line. A boom-type MEWP is commonly referred to as a “cherry picker” and consists of a platform or bucket at the end of a hydraulic lifting system.

4.1. Control Panel

The control panel will be used to control the powered movement of the machine. They will usually employ touch-sensitive controls that will only move the machine if an operator has both hands on the controls. This is a safety feature to ensure the operator is in the safest possible position while moving the machine. The controls will also have an ‘enable’ button that must be pressed before the controls are operational. This is another safety feature to ensure the machine cannot be operated by unauthorized personnel or children when the machine is not in use. The control panel is often the most vulnerable part of the machine and is likely to be damaged if the machine collides with any overhead obstacles. This could cause the controls to malfunction and move the machine in an unintended direction. If the controls do not respond in the expected manner, cease operation of the machine and have it inspected by a professional.

4.2. Platform

The platform is the main area for personnel to work, and is designed as an integral part of the machine. It consists of a toeboard to prevent objects from falling from the platform, an entrance trap to allow easy access to and from the ground, and a full mid-rail and guardrail. The platform is also fitted with an auxiliary lowering system designed to allow descent in the event of a power failure. This system should be of a controlled type (which provides a means of retarding the rate of descent) and capable of multiple operations i.e. it should not be simply a transport and braking device. Material used in the construction of the platform should be either metal or other suitable materials i.e. glass reinforced plastic, but under no circumstances should timber be used. The platform should be of a type which is specific to the MEWP and not a makeshift scaffolding platform. If frequent directional changes are to be made by the machine whilst the platform is occupied, the platform should be of a rotating type.

4.3. Stabilizers

Raw Materials 1.1 Stabilizers for Scissor Lifts – Mechanical These are usually the cheaper of the two types and are usually a set of bars that are bolted into place. The operator has to manually lower these stabilizer bars to the ground using a wrench. They will then need to manually retract the bars when he wants to move the MEWP. These stabilizers are fine when working on concrete ground. However, in instances where the scissor lift has to be used on tarmac or a public highway, the bars will most likely cause an obstruction and cannot be used. – Hydraulic Scissor Lifts will usually have hydraulic outriggers. These offer a lot quicker and easier setup than the mechanical bars. These outriggers will have a trigger on the scissor lift control panel that allows the operator to lower the outriggers until they make contact with the ground. The operator can then continue to lower the outriggers to increase the angle of the scissor lift. Normally, an orange indicator will become visible on the control panel to show that the machine is no longer safe for use and that the stabilizers must be raised. The MEWP cannot be moved until the stabilizers are retracted and the orange light is no longer visible.

4.4. Emergency Controls

Emergency rescue procedures should be included in operators’ training and machine support manuals in the event a stranded machine with personnel in the platform requires ground-based rescue. Lowering functions of the machine will be used for rescue operations, with all transport functions being prohibited. The rescue plan will specify procedures for the preparation of the machine, necessary equipment, available personnel, maintenance of safe working conditions and practices, inspection and test procedures, and operations.

Emergency lowering functions should be tested for proper operation with the engine stopped and with the engine running. Where applicable, the platform-mounted control switch is to be operated with the engine stopped and with the engine running. For machines equipped with an engine stop/start at the platform, the engine stop function is to be tested for proper operation from both the platform and the ground controls with the engine running. The engine is to stop immediately when either the control at the platform or the ground controls is actuated. Controls are to be tested from the platform and the ground control. The engine is to stop when the start control is actuated, and engine start is to be prevented with the engine running. These functions are to only be tested in an area free of overhead obstructions with the wheels or the machine properly chocked. Step covers close captions.

5. Pre-Operational Checks

Functional testing will usually start with the machine engine. Here the person who is conducting the check should be looking for general smooth running, unusual noises and knocking in the engine. The engine may be hard to start or have poor running due to dirty fuel and the customer running the machine which has contaminated the waterproof engine with hydraulic oil. Step height and platform entrance points should be checked for stability and function. If the machine is folding or extendable, these joints should be checked for security and damage. Once the platform is raised, it should be operated to ensure that all functions are working and no joints are trapping or fouling. The lowering functions for the machine and platform should be checked to ensure that they are not too fast or uncontrolled. A lowering function that is too fast can damage the machine and elements in the floor of the machine may break the fail-safe of automatic descent brake on powered scissor. Finally, the drive and steer functions should be checked. Function explains the operation of the drive system and whether it is two or four-wheel drive.

The functional test should be systematically carried out to ensure that all parts of the machine are checked. Each test will consist of inspecting a part of the machine to ensure that its functions are working correctly and are not producing any unusual noise or vibration.

The visual inspection is the most important part of the pre-operational checks. Any damage, inter-relation of parts, loose or missing fixings could create a hazardous situation. The inspection should be carried out in a logical sequence to ensure that no part of the machine is missed. Any damage or faults should be recorded and reported to the appropriate personnel. Individuals undertaking the visual check should be aware of the relevant Health and Safety law particularly in relation to duties of an employee (PUWER 98), and understand the implications of unsafe machinery being used (HSWA 74 Section II, III, IV). These laws place the responsibility of safety firmly on the employer and the employee has the right to refuse the use of unsafe machinery. With unsafe machinery defined as anything, including parts and equipment, which may be dangerous to persons in any relevant circumstances or conditions.

5.1. Visual Inspection

The operator has to check the machine in accordance with the manufacturer’s instructions. Any damage or malfunction identified may make the machine unsafe to operate and must be rectified and confirmed using the relevant notes from the maintenance section in the Operator’s Manual. The operator should check for any visible defects on the platform and ground controls. This would include checking the condition and operation of the guardrails, midrails, and toeboards, and the platform entry gate, ensuring they are undamaged and correctly secured. The platform floor and control panel should also be checked for any damage. All damage should be repaired as per the manufacturer’s recommendation before the MEWP is put back into service. All platform controls should be tested for correct operation. The controls should allow the platform to be operated from the ground controls in the stowed position.

5.2. Functional Tests

Documentation review It is a requirement under PUWER regulation 6 that a machine is only used if a valid report of thorough examination is in place. For hired machines, this will be a report issued at the time of supply. If a machine is to be hired, a good practice is to request that the report be current and that a valid LOLER certificate is also available. Failure to follow these regulations can result in a stop of machine use or prosecution.

Functional tests In addition to the checks detailed in 5.1, a series of functional tests should be carried out to ensure that the MEWP is operating correctly. These include operational checks with the engine off and then running. Controls should be tested for function and then the overall operation of the machine. An operational check of the emergency lowering procedures should be conducted with the engine turned off. This is a critical test to ensure that measures are in place to safely lower a platform should a power failure occur while it is elevated. This may require specific procedures to be put in place if the test causes the platform to lower to the ground.

Pre-operational checks Before a MEWP is used each day or shift, it shall undergo pre-operational checks. These shall ensure that, where any defects are found, the necessary repairs are carried out before the MEWP is used. Specific checks may need to be added for complex or older maintenance machines. This will only be adequate if operators and maintenance staff are given sufficient knowledge and understanding to determine which defects are serious enough to warrant repair.

5.3. Documentation Review

The term “documentation” means the process that documents the inspection, testing, servicing, and thorough examination or test and thorough examination passed reports. There are two main types of documentation records, i.e. the PDI (Pre Delivery Inspection) and the Handover certificates. Both documents together should give a clear and concise history of the machine from new to current and a clear indication of the machine’s condition, any defects, their repair, and the RIDDOR reportable incident or mechanical failure. It is essential that these last two are reported and copied to any enforcing authority, e.g. HSE. A manufacturer’s, inspection, servicing & thorough examination, and hire company/supplied as new report will provide written evidence stating that the above specific machinery has been adequately tested and examined to ensure that it is safe, and a certificate of thorough examination will clearly state any defects in the current setting. Finally, there is a handover certificate from the hire company or last owner to the hirer or new buyer that ensures they receive the PDI and the machine’s condition and RIDDOR reportable incident or mechanical failure. Any changes or additional information to these documents will allow adequate storage of the documents previously stated. All documentation shall be kept throughout the machine’s whole history and changed if documents referred to change.

6. Safe Operation Procedures

6.1. Start-Up and Shut-Down Although it may seem a trivial matter, correct machine preparation is fundamental to safe operation. The start of each shift should be marked by a pre-use inspection. Follow the machine manufacturer’s guidelines and the machine-specific handbook provided. Any defects or issues arising should be noted and reported, and the machine taken out of service if it is not safe. On completion of the pre-use inspection, the machine should still undergo a start-up procedure as detailed in the CPCS theory test. The in-cab or on multiple control panel sequence should be followed exactly to avoid damage to the machine and avoidable injury. The machine should be shut down by following the stop procedure or pressing the emergency stop.

The Mobile Elevated Work Platform (MEWP) as a machine for operating at height is subject to the Provision and Use of Work Equipment Regulations (PUWER) 98 and the Lifting Operations Lifting Equipment Regulations (LOLER) 98, as well as the more specific standards detailed in the European wide EN280 standard. These all require that the operator is competent and familiar with the machine and its operation. CPCS meets and exceeds these requirements in the level of training and testing provided.

6.1. Start-Up and Shut-Down

The operation of the MEWP in a certain area and at a certain height, etc. can be considered like tight-rope walking near the edge of the rope, with the rope thickness and safety net being the only parameters separating a safe task from a dangerous one. If at any point any of the limiting parameters change for the worse, then the task should be aborted. For example, if an operator finds themselves raising the scissor machine to reach something and is on tiptoes leaning forward, then the task is not being safely carried out. Any task that steadily maneuvers away from a safe work area should be stopped in its progression, and re-evaluation of the area should be done to ensure safe task completion.

To shut down the machine in an emergency or for normal end of operation, these same procedures apply, especially for the recovery of a machine stuck in a rut, hole, or on an inclined surface. Emergency recovery (i.e. lifting the machine with another piece of lifting equipment) should only be done after consultation with the manufacturer and their explicit approval. Set-up, and particularly shut-down and recovery of MEWPs, is probably the most important phase of the operation during the whole span of working at height. The probability of turning over a machine is greatly diminished, and the risk of accidents to operators is at its lowest.

It is essential that these procedures are conducted as per the manufacturer’s guide. Doing so in an arduous and thorough manner will ensure that knowledge and familiarity, and thus safe operation of the machine, will be achieved. MEWPs should only be operated on a pre-planned designated area once a suitability inspection has been carried out. This will ensure safety in regards to ground conditions and overhead obstructions. During the inspection, the operator should assess the area and look for potential hazards (e.g. holes, ruts, slopes) and obstructions in travel (e.g. pedestrians, vehicles) and proximity to other electrical and mechanical site plant. If any of these conditions are present and hazardous to the operation of the MEWP, then alternative means of access should be sought. Next, the operator should check grounding conditions in the erect position and stall the machine on a level surface to ensure stability during operation. All of the aforementioned will ensure safe and effective operation of the MEWP.

6.2. Maneuvering and Positioning

For machines with tracks, the operator must understand how to operate the track drive and how to adjust the track tension. He should refer to the machine’s operator manual for this information.

MEWPs with booms have three different types of steer: (a) ‘direct’ (also known as ‘conventional’) which steers the rear wheels in the opposite direction to the front wheels; (b) ‘coordinated’ which means that the front and rear wheels steer in the same direction (e.g. with 4-wheel steer); (c) ‘crab’. The type of steer must be known and understood by the operator because it greatly affects the machine’s maneuverability.

The operator must not move the MEWP until he knows and understands what is required of him. He must check that the travel route is clear of obstacles and other personnel. If there is any doubt about the safety of a particular route, a full site survey should be conducted and any necessary action points communicated to all relevant personnel.

The operator and any person directing the movement of the Mobile Elevating Work Platform (MEWP) must use hand signals. These signals must be the same as those agreed upon in familiarization training. Standard signals are given in BS 7121 – Code of practice for safe use of Cranes. The following signals are recommended for use with MEWPs.

6.3. Working at Height

The definition of “working at height” is a very broad term. It can be applicable to various tasks that are undertaken in various industries. For example, it could be applicable to someone working on a roof as well as someone lowering equipment into a hole. The key issues are identifying what are the hazards involved with the task and how we can eliminate or control the risk of the person(s) involved from sustaining injury. When operating a MEWP, the main priority is to have the operator working from the work platform properly protected by suitable fall prevention equipment (i.e. a properly adjusted harness with a short lanyard) or better still equipment that has a suitable guardrail around the edge of the platform. If it is possible to eliminate the task or the need for the personnel to work at height, this is the best possible scenario. An example of this could be using an extendable platform lift to work at height to change lightbulbs. This task could be eliminated by using extendable light bulb changing equipment from ground level. There may be situations where personnel may need to work at height to gain access to a particular task on a building/structure and then need to move the MEWP to drive back down to finish lower level work. An example of this could be window cleaners who require access by lifting the MEWP to a higher level then need to track the machine down to lower level to gain access to other windows. Tracks must plan to ensure employee safety at all times by determining the best possible access route to the higher/lower level work areas. Identify any hazards that may be encountered during tracking of the machine and ensure that these hazards can be controlled. For example, if the machine needs to track over an excavation, ensure that the area is well barricaded off to prevent accidental machine entry into the excavation. Step-rated access is a good way of ensuring that the work required is planned and completed in the safest way possible.

6.4. Emergency Situations

In every situation of injury to a person whilst operating a MEWP, the first consideration is to alert the ground personnel or other persons to your emergency, to ensure that no other persons enter the Danger Zone and risk being struck by moving or falling objects from the MEWP. This is particularly important if the operator is rendered unable to control the machine or is unconscious.

First-Aid Training We do not attempt to train operators to perform first-aid. If, however, an operator already has first-aid knowledge, it may be possible to use the casualty handling and safe use of the rescue equipment from a MEWP in a first-aid situation. This should only be done by a skilled operator and must not compromise the safety of the casualty.

Introduction The operator must be able to react quickly in an emergency situation. The more severe the injury to a casualty, the greater his/her knowledge and skill must be to deal with the emergency. Many accidents happen, not because the operator does not know what to do, but because he/she does the wrong thing or does the right thing too late. It is essential to know the capabilities and limitations of your first-aid knowledge. If in doubt, keep the casualty warm and comfortable and wait for professional help.

7. Load Management

Loads should always have documented information concerning the weight and dimensions to allow assessments to be made. If there is no information on the load, it is possible that the load has been previously moved without assessment as to whether it could be carried by the MEWP. This situation has caused incidents whereby loads were thought to be light enough when workers had moved it by hand, but when loaded between forklift prongs had exceeded the capacity of the MEWP or forklift. In such instances, the load should be weighed or its suitability should be assessed in relation to the weight of similar loads which have documentation. Random objects should not be carried if their weight is not known – remember that loads include personnel and any objects on the platform. Load capacity and the weight of loads being lifted should always be considered in the planning of lifting operations.

Loads should be light and evenly distributed. If a load is too heavy, the MEWP may become unstable, so an assessment must be made of the load’s weight and the MEWP’s capacity. If the load cannot be weighed, it is important to know the weight of similar loads so an educated estimate can be made. When estimating the weight of the load, consider: is it made of a dense/heavy material? What are the dimensions and shape of the load? Would a load of similar size and/or surface area be considered heavy? Remember that the rated capacity includes the weight of personnel, tools, and any other objects on the MEWP. Loads that are not centrally positioned and are too heavy on one side should not be carried. An off-center load will reduce the machine’s capacity on one side and can cause uneven tire pressure, which may affect stability.

It is important to manage loads when operating a MEWP, to ensure any loads being carried do not cause the MEWP to become unstable and to ensure the safety of personnel in the work platform. Load management concentrates on load weight, dimensions and position in relation to the capacity and stability of the MEWP.

7.1. Load Capacity Limits

The safe working load of a MEWP varies between makes and models. It is important for operatives to be fully aware of the machine’s capabilities. It is the operator’s responsibility to ensure that the MEWP being used is suitable for the task. MEWPs are designed to lift personnel and their tools to a position where they can work at height. Manufacturers usually state the safe working load in two ways. Firstly by the number of men the machine can carry, then secondly by the number of kilograms the machine can lift. For example, 3 men/230kg. If units are working from the platform they shall take into account the weight of other equipment and materials being taken up. This and the total weight of personnel must not exceed the stated load. If in any doubt about a machine’s lifting capabilities, contact the manufacturer.

7.2. Load Distribution

If the platform is loaded with heavy materials, it is more likely that the machine will tip with a slight gradient. The platform must not be used as a crane, and the load should be guided by a banksman on the ground or by a slinger on an adjacent mobile elevating work platform. The load should be placed in the center of the platform. Uneven loading is a major factor when mobile elevating work platforms tip over. An article published by accident specialists in New York, USA found that in cases of scissor lift tip-overs, they were usually a result of going through an entryway or turning a corner. In many other cases, an unstable or mobile surface. During trials performed by the Centre for Construction Research and Training (CPWR), NIOSH (The National Institute for Occupational Safety and Health), and ANSI (American National Standards Institute) at the NIOSH testing facility, Morgantown, approvals were given to standards for stability tests on rough terrain mobile elevating work platforms and newly developed testing prototype tilt-tables, to help prevent tip-overs with the use of sensor technology. The zenith of tilt and load sensors on today’s mobile elevating work platforms may well be the development of tip-over protective structures (TOPS), to help provide fall-over protection. There is evidence of this from the work by J Middleton and E Funk, who tested scissor lift stability to see if it met today’s safety standards and found that it didn’t. They then went on to design and build an electronic stability + grade + load sensor system with automatic hydraulic outrigger legs for a scissor lift.

7.2. Load Distribution

CPCS A25/A26 MEWP (Mobile Elevating Work Platform) – Scissor & Boom Course

7.3. Securing Loads

There are several ways to secure a load, these include: a) Tying the load directly to structural parts of the machine by ropes, slings, or chains. This is the most secure method and prevents the load from moving, however consideration needs to be taken over the type of rope/sling/chain and how it is fastened to the machine. The strength and method of restraining needs to be sufficient for the load and the method of fastening to prevent the rope/sling/chain from coming loose. For example, it would be unadvisable to tie a heavy load with a smooth surfaced rope around a round ROPS bar as it is likely to slip. It is important to regularly check the condition of the rope/sling/chain to make sure it is not worn or damaged. b) Placing the load against the guardrails of the platform. Providing the guardrails are of sufficient height and the item is not too heavy, this can be a simple effective method as the item is prevented from falling by a barrier. Any items placed above the height of the guardrails need to be extra secured. c) Using a specifically designed load pallet or carrier tray for the machine. This is a good way of securing several items of a similar size/shape, as they are prevented from moving on the pallet and can be secured to the machine by other methods.

Items are easily dislodged from a machine when it is in motion or being steered. Therefore, it is important to secure loads to prevent them from falling or moving. To take into account the forces involved, all items should be secured by use of a restraint sufficient to withstand half the weight of the item. As the situation could differ each time or only pose a minor risk, we need to determine the most practical/effective way of securing the load considering the suitability of the machine. For example, a small lightweight item on a predominantly solid floored level is unlikely to need a complex restraint system. However, a large heavy item on an incline would need a more thorough securing using a variety of methods.

8. Maintenance and Inspections

The MEWP owner is responsible for the routine maintenance of the machine. This should be carried out by competent personnel and should take into account the manufacturer’s recommendations. The manufacturer’s handbook will give clear instructions on how to carry out routine maintenance. It is important that this is done at the correct intervals so as not to cause damage to the machine and to generally keep the machine in safe working order. Failure to maintain a MEWP can lead to unsafe working conditions and thus an unsafe structure to work off, resulting in potential serious injury or fatality. Regular maintenance should include checking and replacing hydraulic hoses to ensure there are no leakages and thereby no loss in hydraulic pressure. Visual inspections of all components to check for damage or wear and tear and regular greasing of components. This is intended to give longer life to those components and prevent the need for premature replacement. Grease nipples are provided at key points on the chassis and other components and should be greased by using a grease gun at given intervals. Other routine maintenance can include the minor adjustments and servicing of control and safety devices. An up-to-date record should be kept by the owner of all maintenance work, including dates and details of work carried out. As per routine maintenance, periodic inspections should bear in mind the manufacturer’s instructions for specific inspection and also the capability for a particular inspection to detect a given type of defect. This can vary greatly for different types of inspection.

8.1. Routine Maintenance

The help and cooperation of operatives and their detailed knowledge of how the machine should perform are key to an effective maintenance scheme. Measures to ensure routine maintenance is carried out can involve fairly simple stages such as: – Posting reminder notices in the platform or within the operator’s environment – Setting aside specific times when maintenance can be carried out in dry/wet conditions to allow inspection of weather-dependent items. – Implementing a return procedure at the end of shifts where any defects or items to be repaired can be logged. – Involving the operatives in choosing times when the machine can be spared for maintenance.

A well planned and executed maintenance scheme will ensure the mobile elevated work platform remains in good mechanical condition. This will ensure the equipment remains safe to use, downtime is kept to a minimum, and any potential defects can be rectified before they become a danger. Manufacturers provide maintenance schedules for their equipment, and it is suggested that maintenance tasks are planned into work schedules on a weekly basis. Tick off tasks on a maintenance log or on the actual maintenance schedule in the machine file to avoid any items being forgotten. Some maintenance tasks can be delegated to the operator, providing he has had the correct training and instruction.

8.2. Periodic Inspections

Further to this, CPCS and IPAF recommend that devices are also subject to a 10-year examination. This examination is similar in nature to a LOLER inspection, and it would be beneficial to have a 10-year examination take place at the same time as a LOLER inspection. This examination must be carried out by a competent person, and all devices should have a 10-year examination record book.

All MEWPs require a LOLER inspection, and this would be determined by the device in use and its environment. The maximum period a device can be used until its next LOLER inspection is 6 months. These inspections should be recorded, and any defects found should be addressed as soon as possible. A record of each examination is to be made and kept throughout the lifetime of the machine. These inspections are thorough and focused on safety-critical parts of the equipment to ensure continued safe use.

8.3. Reporting Defects

META Tag Description

The process of repair and maintenance can involve various new part installations and replacements, and these actions can be the cause of an unforeseen safety hazard due to the “no change is made” wording in the regulations. If employers or employees are in any doubt concerning the effects of their repairs/replacements, they should take further advice from the manufacturer/supplier or a competent person. This particular regulation is applied to the identification and detection of defects resulting from repairs or replacements, and so long as steps are taken to solidify what work has been done is necessary and minimally invasive, it may still be deemed that the particular actions fall under satisfactory compliance with PUWER on work equipment maintenance.

Every employer shall ensure that no change is made which could put at risk the integrity of work equipment. With respect to work equipment provided for his employees, every employer shall take appropriate steps to ensure that no change is made which would put at risk the integrity of work equipment.

After deteriorations and faults have been identified during inspections, the equipment owner must start to distinguish between what repairs or part replacements can be done internally and what work requires involvement from a competent specialist from the manufacturer/supplier, or a similarly competent person. This is due to the fact that people who give a similar level of expertise to the persons mentioned could be an employee in a company’s active management of health and safety measures, so long as that person has had sufficient training in the use of the specific work equipment to identify what control measures are necessary and has the necessary experience to understand what the results of any potential inspection could reveal. This decision-making process should be recorded and a repair/replacement log should be kept.

In respect of what can be deemed as maintenance on work equipment, PUWER regulation 5 states that every employer shall ensure that work equipment is maintained in an efficient state, in efficient working order, and in good repair.

Employers also have a duty not to return machinery to service unless it’s safe. This would involve completion of necessary repair actions after a machine inspection or say making a machine out of service by removing a key ignition and leaving a safe out of service notice in the operator station.

Employers also have a duty to ensure that equipment is used only for work at height for which it is suitable, and which is in safe enough condition to prevent danger to health and safety. This includes the incorrect use of a work platform for the work at height task (i.e. overloading a personnel basket with tools/equipment) and a simple example would be using a mobile access tower with wheel brakes that are not properly functional on an incline. This would also cover the situations where an owner operator might take it upon himself to weld/fabricate a repair to an existing piece of work platform equipment on site. This should be avoided as it falls into the category of maintenance and the person carrying out the particular activity need not forget the duties under the regulations.

Employers have a duty not to recklessly or wilfully interfere with or misuse anything to do with their own safety or another person’s safety. This includes activities on the machine which owner operators are often guilty of. This also applies to the likes of maintenance of the machine not being carried out by a competent person or repairs being improperly completed.

Employees have a duty to take reasonable care for the health and safety of themselves and of other persons who may be affected by their acts or omissions at work, and to cooperate with their employer so far as is necessary to enable that duty or requirement to be performed or complied with.

When an employer is using the plant on site, they have two main duties under the regulations.

9. Practical Training

9.1. Hands-On Exercises Candidates are to be given “Hands-on” experience over a total duration of time as to reflect the relevant experience required. In the case of an inexperienced operative, the duration of the basic operator course may not be adequate. The duration of the course being up to a maximum of 5 days and for the combined operator and instructor up to a maximum of 10 days. (Number of days may vary depending on the ratio of candidates to machines)

On completion of the theory session, candidates will be able to: – Identify the basic construction, components, purpose, and use of all controls and gauges. – Identify and comply with manufacturers’ instructions in accordance with the operator’s handbook, lift trucks, and attachments. – Conduct all necessary safety checks at the work area, activating and safely securing the MEWP as required.

9.1. Hands-On Exercises

At 9m is a safe and suitable working height compared to a step ladder. It is capable of lifting 2 persons, tools and materials to a platform height of 7m. Rugby Cement asked if the 920 could be modified to fit 3 persons, although this is not possible it is essential to know that MEC machines are designed to carry a specified load to a specified height, overloading the platform can cause instability and the machine to tip. Before discussing the machine modification the trainer will read the MEWP familiarisation to the candidates. It explains the two types of scissor lifts: slab and rough terrain, the machine that has been donated to the school is a rough terrain scissor lift, there are a few differences between the 2 types. The trainer will then point out that all controls for operating the machine are found on the platform control box and the scissor lift is designed to elevate work only, it is not to be used to travel around a site. The task is to safely load the machine from the MEC store area, travel to C Block and transfer some materials (subject to weight limit) from a bench to the top of a wall in a safe and controlled manner. This will be assessed using the task assessment. The MEWP store area is accessed by a steep incline and the parking area is limited. This is an ideal opportunity to discuss with the candidate whether the slope and conditions are suitable for travel. A risk assessment can be used for this exercise and the trainer can discuss the logic of the machine limitations and the decision process to abort or continue the task.

9.2. Operating Scissor Lifts

You will be shown how to carry out a pre-use inspection of the scissor lift in accordance with the manufacturer’s instructions. There are a number of basic inspection checks and procedures which you need to carry out. If these are carried out correctly, it will prepare you to operate the machine more effectively and will also prevent you from causing damage to the machine or creating a hazardous working environment. These checks and tests can be done quickly but will vary depending on the manufacturer. Some of the checks to be carried out are: check for fluid leaks, check all the functions of the machine to ensure that they work correctly, an inspection of the platform and guardrails, and check all the safety decals are in place and legible. You will then be required to place the machine into the correct location so you can use it to carry out the upcoming exercises and to ensure that you position it level on firm ground. You will then be shown how to maneuver the machine correctly so it can be driven into position and also shown how to drive it in elevated position. You will then complete the following exercises listed below.

9.3. Operating Boom Lifts

– Overhead hazards: Anyone working from a boom type platform needs to consider the overhead clearances and the carrying capacity of the structure being worked on. This is the same for any type of boom lift, regardless of power source. This needs to be checked in accordance with the manufacturer’s guidelines. This may involve a written risk assessment. An example of this would be changing a light bulb. It is essential to check the weight of the person and the light bulbs compared to the machine’s carry capacity and to check the manufacturer’s guidelines for the maximum load this specific machine can carry. It is then necessary to ensure the light bulb can be reached safely without leaning out over the guardrails.

– Adjacent hazards: Never drive the machine to another location while the platform is still elevated. Never elevate the platform when on a moving or mobile vehicle. The stability of the machine on the ground needs to be considered, especially on sloping or uneven ground.

– To avoid trapping and crushing, do not work the controls from outside the platform. Moving the platform upper controls and the ground controls could trap or crush anyone between the moving part and a stationary part or between two moving parts. Keep yourself and the controls inside the platform at all times unless using an approved method to override the controls in an emergency while carrying out the risk assessment for that task. An approved method might be working from underneath the machine to carry out maintenance or repairs using a harness line for fall protection. This would involve a higher risk as any fall from the platform would involve being suspended by the harness line either above the ground or from other parts of the machine.

The main points to remember when operating a boom type of Mobile Elevated Work Platform (MEWP) are as follows:

10. Written Assessment

The written test comes at the end of the day, when the candidates are quite tired, but it is an essential part of the assessment to test the candidates’ overall knowledge of the plant. A selection of around 20 open and multiple choice questions are asked to the candidates. Open questions are marked according to the accuracy of the answer and multiple choice questions are marked at one point each. An overall mark of 70% must be reached to achieve successful completion of the course. If a candidate fails to reach the required pass mark, they are allowed one re-sit at the test. If unsuccessful at the re-sit, it is at the discretion of the instructor to allow the candidate to re-sit at a later date. After completing the test, all question papers can be scored by the trainer. The practical test can take place straight after the theory assessment on some occasions, or more usually on the following day. The trainer must ask himself whether he has seen each candidate operating the particular machine satisfactorily, and is confident in their knowledge and ability to complete the practical test. It is important to give clear instruction to the candidates and make them aware that the completion of a task is not a foregone conclusion. Candidates should be treated the same as much as possible when taking the practical test, and each operator should be allocated the same piece of confined or overhead working tasks, to avoid any dispute in the result of the test.

10.1. Knowledge Test

The setting of this multiple choice written machine test has been discussed to be assessed on an A-C grading system, similar to the theory driving test. If this does get passed, it would be a requirement to be deemed competent to hold a plant operator’s card within 2 or 3 years, so we are having in-depth discussions at the moment. This assesses the candidate and also benefits the employer, as by having the CPCS competent operator card, it shows that the cardholder has successfully completed the theory test within the last 2 or 3 years, thus saving the employer time losing trained staff for a refresher theory test.

This is a test with a worded question paper completed by the candidate, with the answers graded by the test setter. This is a multiple choice type test with a very small number of written questions. If the candidate has a learning difficulty such as dyslexia, they can request to have the CSCS test read to them. Also, if the candidate has a language barrier (i.e. first language not English), a translator can be provided to convert questions to the candidate’s chosen language. However, the CSCS test cannot be translated, but in some cases, certain questions can be rephrased to help understanding.

10.2. Practical Test

Practical tests will follow the completion of the knowledge test paper. There will be a refusal of the test certificate if the practical tests are not completed within 90 days of the completion of the knowledge tests, unless an extension has been agreed with CPCS head office, or with prior agreement between CPCS and the test candidate’s employer. Only one item of plant will be tested per practical test. If the scissor and/or boom has been categorized as an ‘All sizes non restricted’ sub-category, then the candidate must advise the tester on which type of scissor or boom is to be tested, as it may not be possible to cover all sizes in the one test. The practical test must always be carried out at a CPCS accredited test centre. A training provider will not be eligible to perform or supervise tests on their own candidates at their own premises, as this is considered as an ‘in-house’ test which is not permitted with CPCS national vocational qualifications. A test certificate will be issued upon successful completion of the practical and knowledge tests at a CPCS accredited test centre. The practical tests are designed to see how the candidate can apply his knowledge and thinking to work through the safe and logical processes involved in operating a scissor or boom. It is essential that the plant being tested with has been previously assigned to the present test candidate, as training and assessment will be closely linked to the candidate’s prior knowledge and experience with a specific type of plant. This can be reinforced with an employer testimony.

11. Certification and Renewal

There is one training manual specific to the category of MEWP (A25/A26) at present from which training can be delivered. This is known as the mobile elevating work platform category 3A/3B. This is a combined category covering booms (3B) and scissor lifts (3A). Upon successful completion of training, an operator will obtain a red trained operator card specific to the category of machine on which they have been trained. The length of validity of the newly acquired CPCS card will be two years during which time the operator is advised to register onto an NVQ in plant operations as this will enable the operator to renew his card when the time comes by completing the VQ. Failure to do this will mean the operator needs to re-sit his theory test and carry out a practical test to achieve a new card.

NB: For operators who may require a card with a combined category e.g. (A17D) the MEWP mounted on vehicle, a further H (endorsement to the trained operator card) & L (inexperienced operator card) theory test will be required. These theory tests have replaced the old style combined theory tests.

In order to successfully and legally operate a MEWP on-site, the operator must obtain a CPCS card. The CPCS card will stipulate the level of training and/or testing the operator has undertaken. For the A25/A26 category, the operator has two routes to obtain the red trained operator card. The first of these is to undertake a CPCS technical test (practical and theory tests) and the CSCS health and safety test. This is the recognised route if the operator has no NVQ in plant operations. The second route is for the operator to register onto an NVQ in plant operations and then achieve the VQ (vocational qualification). This automatically grants the operator a red trained operator CPCS card.

11.1. Obtaining the CPCS A25/A26 MEWP Card

The first requirement to obtaining a CPCS card is to pass the relevant CITB Health Safety and Environment Test and the CPCS theory test. You also need to pass a CITB operators level knowledge-based practical assessment. The technical tests are there to ensure you know how to operate the plant and have the knowledge and understanding required for a red trained operator. This is where we come in. The technical tests were designed to be achieved on-site in as realistic a situation as possible, and if you are not experienced on MEWPs, then the tests can be quite tricky to pass. We have a great deal of experience in training and testing operators to the required standard, and we can offer a package which includes training and testing on the same day. This will take 1 day for a scissor lift or vertical mast and 1 day with an additional half day for a boom lift depending on experience level. Once you have successfully passed the CITB technical test and training with us, you are entitled to your red trainee operator’s card, and you have 2 years to gain site experience. This then leads onto the next step of the process. The next step would be to upgrade from the red trainee operator’s card to the (A26) scissor lift and (A25) mobile vertical. This requires evidence of a level 2 NVQ or SVQ in plant operations (for the category you are applying for) or a CPCS logbook. With the NVQ/SVQ, you can fast track your way to the competent operator’s (blue) card, and the logbook will consist of you completing a VQ assessment. This is observed assessments on-site to compile the necessary evidence, and once all the evidence has been signed off, you will receive the blue card. As the rules are always changing, you must keep track of any information that becomes available or call for the most up-to-date advice.

11.2. Renewal Process

The first step to renewing an existing CPCS A25/A26 red card will be completing the relevant CITB Health, Safety & Environment test for operatives. This must have been achieved within the last two years and cannot be used if it is any older. The candidate must then go on to apply for the CPCS A25/A26 theory test, which will then lead onto the two-part practical renewal tests. All of these can be arranged and booked through the nearest CPCS test centre. Once these tests have been completed and the candidate has achieved a pass mark, they will receive their CPCS A25/A26 MEWP card. This will typically be within a duration of 6 weeks from passing the practical tests.

This process will comprise of the CPCS A25/A26 theory test, followed by the two CPCS renewal red card practical tests. Once all is successfully completed, the candidate will achieve the CPCS A25/A26 MEWP qualifications (this is now the red card).