Working at Height Procedure

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1 WILTSHIRE POLICE FORCE PROCEDURE Working at Height Procedure Effective from: Version Page 1 of 20

2 TABLE OF CONTENTS Identification... 3 Ownership... 3 Revision History... 3 Approvals... 3 Distribution... 3 Equality Impact Assessment... 4 Consultation... 4 Implications of the Procedure... 4 Training Requirements... 4 IT Infrastructure... 4 STRATEGIC PRIORITIES... Error! Bookmark not defined. RELATED POLICIES, PROCEDURES and OTHER DOCUMENTS... 5 FREEDOM OF INFORMATION ACT MONITORING and REVIEW... 5 WHO TO CONTACT ABOUT THIS PROCEDURE... 5 Manage the risks associated with fragile roofs... 6 Carry out inspections on work equipment and work at height areas Access Equipment Mobile Scaffold Towers Probationer Training - Dynamic Risk Assessment Guide Cards, in the form of an aide memoir, provide information to all users of working at height equipment and can be printed from those available at the end of the procedure Version Page 2 of 20

3 Identification Procedure Title: Version: Working at Height Procedure V8 Ownership Department Responsible: Procedure Owner: Health and Safety, People Services Sarah Somers, Head of Health and Safety Revision History Effective From Next Review Date: Three years or when significant changes in work activity, process or procedure occur. Revision Date Previous Revision Date Summary of Changes November 2008 November 2007 Standard review. June 2009 November 2008 Standard review. November 2010 June 2009 Standard review no change other than template November 2010 Standard review Standard review Data Protection section amended to reflect implementation of GDPR and new DPA. Approvals This document requires the following approvals: Name & Title Date of Approval Version Occupational Health and Safety Committee (DCC chair) V8 JNCC for ratification Chief Officer Group Not required V8 Distribution This document has been distributed via: Name & Title Date of Issue Version E-Brief - V8 to relevant affected Staff/Officers - V8 Version Page 3 of 20

4 Equality Impact Assessment Has an EIA been completed? Yes No Informal assessment conducted result low risk. If no, please indicate the date by which it will be completed. If yes, please send a copy of the EIA with the procedure. Date: Consultation List below who you have consulted with on this policy (incl. committees, groups, etc): Name & Title Date Consulted Version Occupational Health and Safety Committee V8 Implications of the Procedure Training Requirements Any perceived training requirements needed to implement this procedure should be identified here. IT Infrastructure State here whether implementation of this procedure requires any input from IT, adaption and/or addition to any IT systems or packages? Version Page 4 of 20

5 PROCEDURE OVERVIEW The following procedure details Wiltshire Police s arrangements for the management of working at height within Wiltshire police. The purpose of this health and safety arrangement is to outline the procedures to minimise the risk of falling whilst working at heights within Wiltshire Police. The arrangement is applicable to all police officers, police staff, special constables and contractors working on Police premises. GLOSSARY OF TERMS Term RIDDOR PST Meaning Reporting of Injuries Diseases and Dangerous Occurrences Regulations Personal Safety Training RELATED POLICIES, PROCEDURES and OTHER DOCUMENTS PPE Procedure DATA PROTECTION Any information relating to an identified or identifiable living individual recorded as a consequence of this procedure will be processed in accordance with the Data Protection Act 2018, General Data Protection Regulations and the Force Data Protection Policy. FREEDOM OF INFORMATION ACT 2000 This document has been assessed as suitable for public release. MONITORING and REVIEW The Working at Height Procedure document will be monitored and reviewed every three years by the Force Head of Health and Safety. The Force Occupational Health and Safety Committee will be responsible for approval and monitoring the procedure document and its implementation on a regular basis. WHO TO CONTACT ABOUT THIS PROCEDURE Sarah Somers, Head of Health and Safety David James, Health and Safety Advisor 1. Legal Requirements Version Page 5 of 20

6 Health and Safety at Work Act 1974 places a general duty on Wiltshire Police to ensure so far as reasonably practicable the health, safety and welfare at work of all employees. There is an implied duty that the risks from working at height must be prevented or controlled to prevent injury to employees or anyone affected by our work activities. Management of Health and Safety Regulations 1999 place a specific duty on Wiltshire Police to undertake assessments of risk to employees and others health and safety arising from work at height activities. The risk assessments must be suitable and record the significant findings. Work at Height Regulations 2005 place a duty on Wiltshire Police to undertake an assessment of the risks to determine the safe way to work at height. Apply the hierarchy of controls to work at height activities. Plan and organise work at height activities. Ensure those employees who work at height are competent to do so. Ensure the use appropriate work equipment. Manage the risks associated with fragile roofs Carry out inspections on work equipment and work at height areas. 2 Application of Working at Height The Work at Height Regulations 2005 apply to a range of police work activities such as: - Spontaneous police incidents (e.g. pursuit over roofs, offenders at height). Searching activities (e.g. roof searches, CSI examination, and steep ground). Hostage negotiations (e.g. offenders threatening to jump from places at height). Storage areas (e.g. SPR stores, archive stores and general storage areas). Contractors working on police premises (e.g. roof work, window cleaning). General maintenance (e.g. clearing gutters, changing light bulbs and tubes). Technical Support Unit (e.g. positioning and retrieval of covert devices). Wiltshire Police will ensure, so far as is reasonably practicable, that the risk from all work at height is minimised to prevent anyone falling from a place at height and causing personal injury. A place is at height if a person could be injured falling from it, even if it is at or below ground level and work includes moving around at the place of work. To this end Wiltshire Police will apply a hierarchy approach to the risks involved which include: - Avoidance Wiltshire Police will ensure that work is not carried out at height where it is reasonably practicable to carry out the work safely other than at height (e.g. at ground level). Prevention Wiltshire Police will ensure that where work is carried out at height that suitable and sufficient measures to prevent, so far as is reasonably practicable, any person falling a Version Page 6 of 20

7 distance liable to cause personal injury will be used (e.g. use of collective protective measures, use of work restraint safety equipment.). Minimisation Wiltshire Police will ensure that where the risk of falling cannot be eliminated it will use work equipment and other appropriate measures to minimise the distances and consequence of any subsequent fall from height (e.g. use of fall arrest safety equipment). This procedural arrangement recognises that: Wiltshire Police has no capability to physically detain/remove persons at height who are resisting arrest. Wiltshire Police has no in house operational capability for working at height in fall arrest or work restraint mode. Therefore, the use of mutual aid, expert advice and assistance from regional forces and other voluntary and statutory organisations such as the emergency fire and rescue services and cliff rescue teams should be considered and utilised as required. 3 Risk Assessment Risk assessment is the key to the proper planning and organisation of all work at height activities and should inform the selection and use of appropriate work equipment and other safety factors. The risks from a fall from height should always be assessed and every reasonably practicable measure must be taken to prevent anyone falling from height or being hit by falling objects or falling through fragile surfaces. Wiltshire Police have developed a detailed Generic Risk Assessment and Aide Memoir for Working at Height both of which can be found on the Health and Safety portal pages. In addition all Police Officers (up to and including Inspector rank), including Specials and PCSO s will be required to complete a Working at Height e-learning Module to assist operational staff in dynamically risk assessing potential working at height incidents. Student Police Officers, including Specials and PCSO s are required to complete the Working at Height e-learning Module prior to the dynamic risk assessment element of their training. 4 Planning All work at height activities will be properly planned and organised by supervisors including the selection of appropriate work equipment, procedures for emergencies and rescue arrangements, appropriately supervised by a competent person and carried out in a manner, which, so far as reasonably practicable is safe. Work at height should only be carried out when weather conditions do not jeopardise the health and safety of those undertaking the work activity involved. Ambient lighting, wind speed, rain, snow and ice will significantly change the working conditions and may increase the risk of falling or other hazards. Version Page 7 of 20

8 5 Competence Any person undertaking work at height should be competent to do so or be supervised by a competent person. Competency is a combination of appropriate practical and theoretical knowledge, training and experience, which collectively should enable that person to: - Undertake safely their specified work activity at their level and responsibility. Understand fully any potential risks related to the work activity in which they are engaged. Detect any defects or omissions and recognise any implications for health and safety with the aim of specifying appropriate remedial actions that may be required in relation to their particular work activity. 6 Operational Policing Pre Planned and Spontaneous Incidents Spontaneous Incidents During the course of their duties police officers will be required to attend and work at spontaneous operational incidents where there is a risk of falling from heights greater than 2 metres. This risk can invariably result in serious personal injury and can often be fatal, as the forces of gravity cannot be isolated, minimised or segregated. This risk is usually present during police foot chases and searching activities and can include falling from buildings, walls, fences, roofs, gates, attics, embankments, ditches, bridges, cliffs and similar unprotected edges. The general principal to be adopted by all is to exercise extreme caution during operational foot-chases and similar pursuits in any areas of risk of falling. A suitable and sufficient dynamic risk assessment must be carried out by the individual officer (and within the Crime and Communication Centre) at the time as per their instruction and training if the spontaneous operational circumstances of the incident are of such seriousness to warrant immediate and continued pursuit. All staff must ensure the National Decision Making model and dynamic risk assessment principles are adhered to in order to minimise the risk to their own personal safety. There are very few offences that are of such seriousness to warrant the immediate and continued pursuit into any areas of risk of falling by operational police officers. Often it is far safer for all concerned to secure the area and to await the offender to voluntarily descend from the area in question on their own accord or with assistance from the emergency rescue services. The Force currently has no capability to physically detain persons at height who are resisting arrest. If the spontaneous operational circumstances are of such seriousness to warrant the immediate and continued pursuit by police officer. All staff are reminded of the following preventative control measures that may help minimise the risk to their personal safety by such work activities. Version Page 8 of 20

9 Visually assess the structure and fabric of the building or area into which you are about to enter. Think about how you going to access and follow the offender. Remember that the structure and fabric of the building may well look sound but could fail under your body weight. If you are in any doubt do not follow the offender. (Never assume because an offender has crossed a roof safely you can do so as well.) Never attempt such pursuits when visibility is poor or during inclement weather conditions. If you continue you must follow any displayed safety instructions and rules as determined by the site operators or owner. Use only the available structures for access and egress such as ladders, walkways and walk boards. Never, under any circumstances, deviate from these recognised access and egress structures or routes. Ensure you keep within any areas where edge protection is provided in the form of barriers, guards, handrails, fences or similar structure to prevent falling from height. Consider the use of available mutual aid specialists who have been trained and equipped to ensure the risks of falling are minimised (e.g. Support Group Rope access teams, Fire and Rescue Service) Also remember alternative operational options to follow the pursuit such as the use of the NPAS helicopter. The Crime and Communications Centre have added the following information to their Swiss Knife to assist control room staff and operational officers in incidences with the potential for working at height. Control room to instruct operational staff to avoid working at height wherever possible. Operational staff must contact the control room if there is a possible need to work at height. Ensure control room notify NPAS, to assist if there is a possibility of offenders on roofs. Operational staff must control and contain the area rather than work at height and wait for assistance. Operational staff must carry out a dynamic risk assessment before carrying out work at height. Pre Planned Operations All pre-planned police operations should be adequately assessed for the risks of falling from heights greater than 2 metres and adequate arrangements to prevent such falls should be made before the operation is undertaken as part of the planning process / operational order. A suitable Operational Risk Assessment (ORA) must be completed by a suitably trained and authorised risk assessor who has attended the Force Health and Safety Risk Assessor Course. As a starting point the operational risk assessment should also consider the following factors, this list is not exhaustive: Elimination of risk. Version Page 9 of 20

10 Adopting suitable alternative arrangements to working at height e.g. negotiate from the ground, use of specialist camera s as opposed to searching at height. Location and type of work at height involved. Weather conditions. Appropriate selection and inspection of equipment and system of work. Competent / trained staff. 7 Selection of Working at Height Equipment In the selection of work equipment for use in working at height it is important that the below are taken account of: - Collective protection measures are given priority of personal protective equipment Working conditions and the risks to the safety of persons at the place where the work equipment is to be used. In the case of access and egress the distances to be negotiated. The distance and consequence of a potential fall The duration and frequency of use. The need for easy and timely evacuation or rescue in an emergency. Additional risks posed by the use, installation or removal of that work equipment or by evacuation or rescue from it. In the selection of work equipment for use in working at height use work equipment which: - Has the characteristics and dimensions which are appropriate to the nature of the work to be performed and the foreseeable loadings. Allows passage without risks. In all other respects is the most suitable work equipment. 8 Use of Working at Height Equipment The Work at Height Regulations 2005 recognises that working at height can be performed safely in a number of different ways, using a wide range of work equipment. The choice of equipment will depend on the initial assessment of risk. Whatever work equipment is selected should be of sound construction in suitable materials and be of adequate strength and be free of obvious defects. 9 Access and Egress Every place of work or means of access / egress at height shall: - Be stable and of sufficient strength and rigidity for the purpose of its intended use. As applicable rest on a stable and sufficiently strong surface. Version Page 10 of 20

11 Be of sufficient dimensions to permit safe passage of persons and the safe use of plant or materials required to be used and to provide a safe work area having regard to the work to be carried out there. Possess suitable and sufficient means of preventing a fall. Possess a surface which has no gaps though which a person, object or material may fall and injure a person, or give rise to other risks of injury unless measures have been taken to protect persons against such risks. Be constructed, used and maintained in such condition as to prevent the risk of slipping and tripping, or any person being caught between it and any adjacent structure. Where it has moving parts be prevented by appropriate devices from moving inadvertently during work at height. 10 Danger Area Where a workplace contains any areas which, owing to the nature of the work being undertaken at height, there is a risk of any person falling a distance or being struck by a falling object, which is liable to cause personal injury. Any such dangerous work areas should so far as is reasonably practicable be clearly indicated and unauthorised persons prevented from accessing such areas. 11 Fragile Surfaces Where it cannot be avoided, all that is reasonably practicable must be done to make anyone who may go onto or near a fragile surface aware of the danger by prominent warning signs or notices fixed at the approach to the danger zones. Where work is required to be carried out on or near a fragile surface: - Suitable platforms, coverings, ground rails or similar collective measures are employed to minimise the risk of falling through. Should any risk of a fall remain the distance and effect of that fall must be minimised. 12 Falling Objects Everything that is reasonably practicable must be done to stop objects falling. Nothing must be thrown or tipped from height or be stored in such a way that its movement is likely to cause injury to anyone. Where there is a danger of falling objects the area must be clearly indicated and access restricted so as to ensure unauthorised people are unable to reach the area. 13 Types of Work Equipment Collective Protective Equipment At all stages of the work at height procedure collective protective measures such as barriers, guards, rails, nets, airbags etc will have precedence over any personal protective height safety equipment e.g. work restraint equipment, fall arrest equipment. Version Page 11 of 20

12 Work restraint safety equipment Work restraint equipment prevents employees from falling from places of height and commonly includes safety ropes, lines and harnesses. They are of sufficient length to only allow approach to edges and are fixed in length to prevent the employee falling from the edge. Fall arrest safety equipment Fall arrest safety equipment is designed to provide a safe connection between the employee and a fixed workplace structure and arrest and minimise falling distances. Basic fall arrest safety equipment is made up of the following approved components: Full Body Safety Harness Safety Lanyard Connectors Anchorage Points It should be noted that Wiltshire Police do not have any in-house capability for working in or within Fall Arrest. Therefore, the use of specialist mutual aid from regional forces and/or competent contractor assistance and/or statutory organisations such as the emergency fire and rescue services must be considered and utilised as required. Ladders / Stepladders Ladders and stepladders should only be used for access and egress or at a place of work where a risk assessment shows that the use of other work equipment is not justified because of the low risk and short duration of the work activity or other unalterable features of the workplace. All ladders/step ladders purchased by the Force should be suitable, sufficient and fit for purpose. Only approved ladders which meet EN 131 and/or BS2037 ladders will be purchased by the Wiltshire Police. If ladders are to be used to work from Wiltshire Police s general safe use of ladders guidance aide memoir must be adhered to at all times. Vehicles with Fixed Ladders There are a small number of vehicles within the Force s fleet which have fixed ladders on the side of the vehicle. A visual check and inspection must be carried out by the user prior to every occasion it is used. If any faults or defects are identified, the user must inform their line manager/appointed responsible person. The ladder / step ladder must not be used until repaired or replaced. The fixed ladders will also receive formal inspection by competent staff within the force workshop as part of the vehicles routine servicing and / or annually. Access Equipment Mobile Scaffold Towers All mobile scaffold towers purchased by the Force must be suitable, sufficient, fit for purpose and asset registered as per Force Policy. This includes ensuring the platform has sufficient strength and rigidity for Version Page 12 of 20

13 the purpose for which it is intended to be used. Only appropriately approved mobile scaffold towers will be purchased by the Force. A suitable risk assessment must be completed by the line manager and forwarded to the Buying Coordinators requesting the purchase. The assessment will then be reviewed by Health and Safety Department and where appropriate approved for purchase. Advice and guidance regarding all aspects of mobile tower scaffolds can be sought from the Health and Safety Department as required. It should be noted that Wiltshire Police do not currently have any in-house mobile scaffold towers. Therefore, the use of specialist mutual aid from regional forces and/or competent contractor assistance must be considered and utilised as required. 14 Inspection and Maintenance of Equipment Equipment used for work at height must be regularly inspected to ensure it is safe to use. Marking of the equipment may be required to ensure that it is obvious when the next inspection is due. Formal inspection of equipment used for work at height should not be confused or substituted for any pre-use checks or procedures that the user should make before using work equipment. Inspection of work equipment should only be undertaken by competent employees and records will be maintained of all inspections of work equipment used for work at height. Records will be retained locally. If any faults or defects are identified, the user must inform their line manager/appointed responsible person. The equipment must be taken out of use until repaired or replaced. Ladder Inspections A formal annual inspection of all ladders, step ladders and mobile scaffold towers within Force must be undertaken and a record kept. Full details of this process are detailed in the Ladder Inspection Site located on the Health and Safety Portal Site. In summary, Managers of Departments which have ownership of ladders, must complete and save, or nominate a responsible person to complete and save, relevant parts of the Ladder Form held within this Ladder Inspection site. A Ladder tag, available from the Health and Safety Department, should be attached to every ladder, step ladder and mobile scaffold tower detailing the required pre use and in use checks and ladder inspection record. 15 Management of Contractors All contractors employed by the Force/Management Agents and Partners will be responsible for their own working at height arrangements including risk assessments, method statements, safe systems of work and regular maintenance, service and inspection of their work at height equipment including scaffolds, tower scaffolds and working platforms. The risk assessment must ensure the selection of appropriate access equipment for the work considering the duration of work and degree of risk. Wiltshire Police will ensure evidence of this is provided at the tender stage through the contractor s method statements and risk assessments. The tender stage will also ensure that only competent scaffolders (CITB) approved will Version Page 13 of 20

14 be utilised by Wiltshire Police or sub contractors of Wiltshire Police. Wiltshire Police will reserve the right to review or inspect these records at any time. Permit to work arrangements for contractor working at height activities provide formally written safety control systems when it is intended to undertake work of a hazardous nature and the potential risk is high. A permit will include details of how the planned work will be managed. Permits can only be authorised by the Estates Management Services Contractor in consultation with or by the Estates Department. Please refer to the Force Management of Contractors Policy and Procedural guide for full details. 16 Information, Instruction and Training Training Any person undertaking work at height should be competent to do so or be supervised by a competent person. Competency is a combination of appropriate practical and theoretical knowledge, training and experience. Probationer Training - Dynamic Risk Assessment All Police Officers, including Specials, and PCSO s are required to complete the Force working at height e-learning module prior to receiving training in basic height safety awareness principals and dynamic risk assessment as part of their probationer/induction. Probationers will also be provided with a working at height aide memoir and a copy of the safe system of work/dynamic risk assessment flowchart. The dynamic risk assessment training provides staff with an increased knowledge and understanding of risk and the hierarchy of control measures to be considered including avoidance and substitution. The training and guidance is designed to assist operational staff with their spontaneous decision making in all areas of policing including the potential for working at height. In addition, all dedicated search and firearms officers receive appropriate advice and guidance in the form of awareness/refresher training, briefings, debriefings, provision of information regarding working at height, safe systems of work and written risk assessment to be adhered to. Police Officers, including Specials, and PCSO s From May 2016 all Police Officers, including Specials, and PCSO s already in post, or transferring into the organisation, will be required to complete the Force Working at Height e-learning module and offered a Working at Height Aide Memoir, for their retention and future reference, to assist in their dynamic risk assessing processes in the event of a working at height incident. Guide Cards Version Page 14 of 20

15 Guide Cards, in the form of an aide memoir, provide information to all users of working at height equipment and can be printed from those available at the end of the procedure. Working at Height Aide Memoir Working at Height Aide Memoirs provide information to operational staff and are available in the below formats from: Pocket sized hard copy available from the Health and Safety Department A4 available at the end of this procedure and the Health and Safety Section of the Forms and Templates tab on Firstpoint A3 poster available from the Health and Safety Department Version Page 15 of 20

16 SAFE USE OF SEARCH TEAM LADDERS GUIDE CARD STORAGE Ladders are to be kept in the Headquarters and / or Hub PSU stores. Storage areas should be easily accessible, clean and dry. Ladders should be hung from the stile or rung when not in use. INSPECTION A visual inspection of ladders should be routinely carried out both before and after task by the user. Any faults identified should be reported to the line manager immediately. The visual inspection should include looking at the general condition of the ladder, loose/missing rungs, footpads, etc. A formal annual inspection must also be carried out, by a nominated person, using the Health and Safety Ladder Inspection Site located with the People Services Portal Site. SAFE USE Ensure the appropriate ladder is used for specific tasks. User to be competent in the use of ladder. Always work in pairs and ensure the ladder is footed at all times. User to wear suitable and appropriate footwear for the task. Ensure ladder is secure and supported on a firm and level surface. Ensure metal ladders are not used near any potential electrical hazards. Only one user to use the ladder at any one time. Rest the top of the ladder against a solid surface. Place the ladder at a suitable angle to minimise the risk of slipping outwards (ideally 75 degrees to the horizontal). Never carry heavy items up a ladder. Ensure the ladder is used as per the manufacturer s instructions. Version Page 16 of 20

17 SAFE USE OF FIREARMS LADDERS GUIDE CARD STORAGE Ladders are to be kept in the Headquarters and/or Hub PSU stores. Storage areas should be easily accessible, clean and dry. Ladders should be hung from the stile or rung when not in use. INSPECTION A visual inspection of ladders should be routinely carried out both before and after task by the user. Any faults identified should be reported to the Firearms Training Instructor immediately. The visual inspection should include looking at the general condition of the ladder, loose/missing rungs, footpads, etc. A formal annual inspection must also be carried out, by a nominated person, using the Health and Safety Ladder Inspection Site located with the People Services Portal Site. SAFE USE Firearms Training Instructor to ensure the appropriate ladder is used for specific tasks. Firearms officers to be competent in the use of ladder. Firearms officers to wear suitable and appropriate footwear for the task. Ensure the ladder is appropriately footed at all times. Ensure ladder is secure and supported on a firm and level surface. Ensure metal ladders are not used near any potential electrical hazards. Ensure the top of the ladder is rested against a solid surface. Place the ladder at a suitable angle to minimise the risk of slipping outwards (ideally 75 degrees to the horizontal). Ensure the ladder is used as per the manufacturer s instructions. Safe system of work to be adhered to at all times. Firearms officers to comply with the Firearms Training Instructors at all times. National Police Firearms Training Curriculum to be adhered to by Firearms Training Instructors. Version Page 17 of 20

18 GENERAL SAFE USE OF LADDERS / STEP LADDERS GUIDE CARD STORAGE Ladders are to be kept in suitable storage rooms. Storage areas should be easily accessible, clean and dry. Ladders should be hung from the stile or rung when not in use. INSPECTION A visual inspection of ladders should be routinely carried out both before and after task by the user. Any faults identified should be reported to the line manager immediately. The visual inspection should include looking at the general condition of the ladder e.g. loose/missing rungs, footpads, corrosion etc. A formal annual inspection must also be carried out, by a nominated person, using the Health and Safety Ladder Inspection Site located with the People Services Portal Site. SAFE USE Ensure the appropriate ladder is used for specific tasks. Consider if the work is more suited to use of a scaffold or mobile tower. User to be competent in the use of ladder. Whenever possible work in pairs and ensure the ladder is footed at all times. User to wear suitable and appropriate footwear for the task. Ensure ladder is secure and supported on a firm and level surface. Ensure metal ladders are not used near any potential electrical hazards. Only one user to use the ladder at any one time. Rest the top of the ladder against a solid surface. Place the ladder at a suitable angle to minimise the risk of slipping outwards (ideally 75 degrees to the horizontal). Never carry heavy items up a ladder. Ensure the ladder is used as per the manufacturer s instructions. Version Page 18 of 20

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