Guide To Maintaining Roadworthiness Of Mobile Cranes

Transcription

Guide to MaintainingRoadworthiness ofMobile Cranes

Guide to Maintaining Roadworthiness ofMobile CranesCPA Good Practice GuideNOTE: Whilst every care has been taken to ensure the accuracy of the material contained withinthis booklet, no liability is accepted by the Construction Plant-hire Association in respect of theinformation given.No material from this booklet may be reproduced in any shape or form without thepermission of the Construction Plant-hire Association.Contains public sector information licensed under the Open Government Licence v3.0Reference No. CIG 1901First Published: May 2019Amendment: February 2022Published by:Crane Interest Group (CIG)Construction Plant-hire Association27/28 Newbury StLondonEC1A 7HUTelephone: 020 7796 3366Email: enquiries@cpa.uk.netCPA Copyright 2022Maintaining Roadworthiness of Mobile Cranes1 of 55Version 2: February 2022

ContentsForeword31.0 Introduction and Summary62.0 Legal Requirements83.0 Roadworthiness Inspection Types94.0 Driver Daily Checks and Defect Reports105.0 Regular Safety Inspections136.0 Annual Safety Inspections187.0 Annual Statutory Inspections198.0 Electronic capture and storage of safety inspection data199.0 Inspection Personnel - Attributes, Training and Assessment2110.0 Information for Roadworthiness Inspection Personnel2411.0 Inspection Procedures and Requirements (Regular and AnnualInspection)2612.0 Crane Operator/Owner Management Review of RoadworthinessInspection Records2913.0 Inspection Facilities31Annex ABrake Test Requirement33Annex BInspections and Tests to be Carried Out37Annex CCPA Inspection Record Form VR140Annex D - Pass Certificate VR243Annex EFailure Certificate VR344Annex FSuitable qualifications for vehicle examiners45Annex GIrtec Inspection Technician License Requirements48Annex H Annual In-house Inspection49Annex I51Competence Assessment FormAnnex J - Training Providers53Annex K54BibliographyAnnex L - Working Group MembershipMaintaining Roadworthiness of Mobile Cranes552 of 55Version 2: February 2022

ForewordWelcome to the latest updated droadworthiness of mobile cranes.CPA G daaRoadgoing mobile cranes are a common sight on the roads of this country and, aswith all vehicles, have the potential to cause great harm if they are not maintained in aroadworthy condition.This guide provides good practice advice on the duties and responsibilities that acrane owner or driver have to the roadworthiness of their vehicles. It covers what theyare legally required to do, what is good practice and gives information on where toseek additional help, including technical assistance or training.In the interest of road safety, the CPA C a IGlaunched in 2019 avoluntary annual roadworthiness scheme for those mobile cranes exempted from theHGV testing requirements.This latest guide builds upon and extends the scope of the original guidance, titledAnn al Road or hine In pec ion Scheme for Mobile Crane Mo n ed on a Nonandard Cha i to cover all cranes subject to statutory plating and annual testingand now incorporates guidance on Driver Daily Checks and Regular SafetyInspections.The guidance provided in this document is based on the Driver and Vehicle StandardsAc (DVSA) publicationsGuide to maintaining roadworthinessvehiclesCommercial goods and public serviceHeavy goods vehicle inspection manualThis edition has been developed, based on the original, by a working group with manyacaa d aa cadb ca.Both the Department for Transport (DfT) and the DVSA have provided invaluableassistance with the process and as can be seen below, have expressed their support.Maintaining Roadworthiness of Mobile Cranes3 of 55Version 2: February 2022

The document sets out measures to maintain roadworthiness and includes guidanceon the management of the process, inspection personnel, inspection requirements,records, equipment and facilities, and quality assurance. The advice in the documentis straightforward, comprehensive, and easy to adopt.Whilst this roadworthiness guidance is primarily aimed at mobile cranes it may beapplied to other vehicle mounted equipment such as MEWPs.I thank those who have been involved in its preparation and commend the guidance toall those responsible for maintaining roadworthiness of mobile cranes. Please readthis document and adopt the voluntary roadworthiness inspection scheme for yourmobile crane fleet.Kevin MintonChief ExecutiveConstruction Plant-hire AssociationMaintaining Roadworthiness of Mobile Cranes4 of 55Version 2: February 2022

W ccranes.adCPAdaaadbDVSAa d, ac ,a d aneys for all. Animportant way in which we will achieve this is by helping you keep your crane safe todrive. Whether you operate a large fleet or just one crane, keeping your cranes in aroadworthy condition is good for business, good for the environment and helps youa aB aad .This guide provides you with best practice advice on the responsibilities that anoperator or driver have to ensure the roadworthiness of their vehicles. It also coverswhat you are legally required to do and gives information on where to seek additionalhelp, including technical assistance or training.I am delighted that this guidance has been developed as a consequence, incollaboration with the Driver and Vehicle Standards Agency. It provides a clearframework to help operators discharge their legal obligation to maintain a roadworthyfleet. I would encourage all operators of relevant vehicles to consider taking it up.Gordon MacDonaldHead of Enforcement PolicyDriver and Vehicle Standards AgencyMaintaining Roadworthiness of Mobile Cranes5 of 55Version 2: February 2022

1.0 Introduction and SummaryThis guide has been produced to explain the responsibilities and systems involved inmaintaining mobile cranes in a roadworthy condition, regardless of operatingconditions, fleet size or chassis type. The guidance is directed at crane owners,drivers and all those responsible for operating, maintaining mobile cranes.The Road Vehicles (Construction and Use) Regulations 1986 (as amended) requireall vehicles on the road in the United Kingdom to be maintained in a roadworthycondition.It is not enough to rely on a maintenance system alone, because this cannot ensurethat vehicles are roadworthy. To ensure best practice, crane owners will need tocombine good quality maintenance practices and skills with supervision and effectivemanagement of the system.Mobile cranes mounted on HGV chassis in full compliance with the Construction andUse Regulations are required to have a statutory annual roadworthiness inspection.Tc(aMOT)avehicle is roadworthy and meets the requirements of the various regulationsgoverning its construction and use.Mobile cranes mounted on HGV chassis not in full compliance with ConstructionRegulations and operating under STGO or those on bespoke chassis operatingunder STGO are exempt from statutory plating and annual testing, (see Table 1).It should be borne in mind that although some vehicles are exempt from statutoryannual testing, they are still required by the Road Vehicles (Construction and Use)Regulations 1986 (as amended) to be a a dano danger is caused ori likel o be ca ed o an per on in or on he ehicle or on a road . Equally forthose crane owners with an Operator s licence for their transport fleet anroadworthiness issues with mobile cranes may well result in the revoking,suspension or curtailing of that licence. Detailed information on vehiclemaintenance is given in the DVSA publication Guide to maintaining roadworthiness Commercial goods and passenger carrying vehicles (see Annex K).V cdbc aaaa da d ccacchassis, generally do not comply with all requirements of the Road Vehicles(Construction and Use) Regulations 1986 (as amended) (C & U), particularly in termsof gross vehicle weight, axle weight and brake performance. Consequently, theyoperate under the Road Vehicles (Authorisation of Special Types) (General) Order2003 (STGO). Large vehicles such as mobile cranes may have a gross vehicle weightof over 100 tonnes and travel the length and breadth of the UK.Maintaining Roadworthiness of Mobile Cranes6 of 55Version 2: February 2022

NOTE: Whilst this voluntary roadworthiness inspection guidance is primarily aimed at mobilecranes it may be applied to other vehicle mounted equipment such as MEWPs operating underSTGO.This document sets out measures to ensure roadworthiness providing guidance onthe management of the process, inspection personnel, inspection requirements,records, equipment and facilities, and quality assurance.The document has been prepared by the Crane Interest Group of the CPA, who willreview and amend the document as and when required to take account of changes tolegislation, DVSA vehicle inspection requirements and current practice.Mobile Crane Chassis ection InspectionStatutoryAnnualMOT TestMobile crane or MEWP mountedon HGV chassis in full compliancewith Construction and obile crane or MEWP mountedon HGV chassis not in fullcompliance with Construction andUse Regulations and operatingunder STGORequiredRequiredRequiredExemptMobile crane or MEWP mountedon a bespoke chassis andoperating under STGORequiredRequiredRequiredExemptTable 1: Roadworthiness checks and inspections by mobile crane chassis type.Maintaining Roadworthiness of Mobile Cranes7 of 55Version 2: February 2022

2.0 Legal Requirements2.1 Health & Safety at Work etc. Act 1974 (HSWA)The Health and Safety at Work Act places a duty on employers to ensure the healthand safety of employees and others who may be affected by their work activities.Similar duties are placed on the self-employed and persons in control of premises.Employees, managers, and directors also have responsibilities. The HSWA alsoplaces a duty on construction plant owners and users, where their work activityinvolves plant being used where it could affect the public.2.1 The Road Traffic Act 1984, 1988 and 1991The Road Traffic Act covers requirements for the use of all vehicles on highways andany other road to which the public has access. The act covers the construction anduse of vehicles, including requirements for testing.2.2 The Road Vehicles (Construction and Use) Regulations 1986 (As amended)(C & U)The Road Vehicles (Construction and Use) Regulations, made under the Road TrafficAct 1972, specifies detailed requirements for the construction and use of all roadvehicles, including mobile cranes. Part of the requirements for use is a requirement(Regulation 100) that all vehicles, including mobile cranes, are maintained so thatno danger is caused or is likely to be caused to any person in or on the vehicle oron a road .2.3 The Road Vehicles Lighting Regulations 1989 as amendedThe Road Vehicles Lighting Regulations made under the Road Traffic Act 1988 setout the requirements for the lighting of road vehicles.2.4 The Road Vehicles (Authorisation of Special Types) (General) Order 2003(STGO)This Order, made under Section 44 of the Road Traffic Act 1988, authorises the useon the road of certain types of vehicles, including mobile cranes, which do not fullycomply with the Construction and Use Regulations. The Order also specifies therequirements that must be met by such vehicles.2.5 The Goods Vehicles (Plating and Testing) Regulations1988 (as amended)The Goods Vehicle (Plating and Testing) Regulations, made under the Road TrafficAct 1972, set out the requirements for the annual testing of most goods vehicles.Schedule 2 lists those vehicles which are exempt from the regulations. Schedule 2has been amended by the The Goods Vehicles (Plating and Testing) (MiscellaneousAmendments) Regulations 2017.Maintaining Roadworthiness of Mobile Cranes8 of 55Version 2: February 2022

2.6 The Goods Vehicles (Plating and Testing) (Miscellaneous Amendments)Regulations 2017The Goods Vehicles (Plating and Testing) (Miscellaneous Amendments) Regulationsamend the list of exempted vehicles in Schedule 2 of the 1988 regulations. Theamendments remove mobile cranes from the list of exemptions from plating andtesting. However, those mobile cranes running under STGO (see 3.5) continue to beexempt by virtue of Regulation 44(e) of the Goods Vehicle (Plating and Testing)Regulations 1988.3.0 Roadworthiness Inspection TypesWhen it comes to ensuring the roadworthiness of a vehicle, there are four types ofessential inspections which differ in scope and depth. Each type is used for adifferent purpose and requires different levels of skill to be carried out effectively.The four types of inspection are:Driver Daily Checks Walkaround checks completed by the crane driverbefore the crane is taken onto the public highway, (see Section 5).Regular Safety Inspections In depth inspection of the crane undertaken by avehicle examiner at periodic intervals, (see Section 6).Annual Safety Inspection In depth inspection of the crane undertaken by anindependent vehicle examiner (see Section 7).Statutory MOT Test In depth inspection of the crane to comply withlegislation, (see Section 8).An inspection should not be confused with a service. A service contains itemsrequiring routine maintenance, usually determined in scope and frequency by theca a dcdaca ac.Maintaining Roadworthiness of Mobile Cranes9 of 55Version 2: February 2022

4.0 Driver Daily Checks and Defect Reports4.1 Driver Daily ChecksA driver or responsible person should undertake a daily walkaround check before acrane is taken onto a road or is to be moved on a worksite. Where more than onedriver will use the crane during the day's running, the driver taking charge of a craneshould make sure it is roadworthy and safe to drive by carrying out their ownwalkaround check; however, due to health and safety implications this may not bepractical on all occasions.An example of a system for managing in-service driver changes is where awalkaround check is carried out by a responsible person and the drivers monitor thecrane during the day's running. When there is a change in driver during the day, it issometimes unsafe to carry out a walkaround check (e.g. where the handover is beingmade at the side of a road or layby). This will be considered acceptable where there isa robust driver defect reporting system in place, which details the initial walkaroundc c a da d cd cdddaads ofthat crane.The driver is always legally responsible for the condition of the vehicle while in use.T,c d ca daa adc ca a aadc.Crane Owners can delegate the walkaround check to a responsible person, who mustcarry out a minimum of one check in 24 hours.The check should cover the whole vehicle and should cover interior and exterior itemsthat can be safely assessed without necessarily the use of a workshop.Maintaining Roadworthiness of Mobile Cranes10 of 55Version 2: February 2022

Assistance may be required at some time during the check, for example, to see thatlights are working. Alternatively, a brake pedal application tool may be used as aneffective way of making sure stop lamps are working, and that the braking system isfree of leaks. In addition, a torch, panel lock key or other equipment may be needed. Itcould be beneficial to incorporate a post use check, to save downtime.It is important however that drivers are aware of the overall vehicle dimensions andshould display an in-cab overall height indicator.4.2 D i eDefect ReportsThere should be a system of reporting and recording defects that may affect theroadworthiness of the crane. This must include how they were rectified before thecrane is used.Daily defect checks are vital, and the results of such checks must be recordedas part of the maintenance system.It is important that enough time is allowed for the completion of walkaround checksand that staff are trained to carry them out thoroughly.Drivers should be made aware that daily defect reporting is one of the criticalelements of any effective crane roadworthiness system and reminded that they arelegally responsible for the condition of their crane when in use on the road.Drivers should report any defects, or symptoms of defects, that could prevent the safeoperation of the cranes. In addition to daily walkaround checks, they should monitor theroadworthiness of their crane when being driven and be alert to any indication that thecrane is developing a fault e.g., warning lights, vibrations, or other symptoms.4.3 Pre-travel checksWhen a crane has finished work at a site, the driver should walk around the crane beforeleaving the site to identify any faults. If any safety defects are found, they should not usethe crane on the road until it is repaired.4.4 Providing a written reportAny defects found during the daily walkaround check, while the crane is in use or on itsreturn to base, must be the subject of a written report by the driver or some otherperson responsible for recording defects.The details recorded should include:crane registration or identification mark;date;Maintaining Roadworthiness of Mobile Cranes11 of 55Version 2: February 2022

details of the defects or symptoms;the reporter s name;who the defect was reported to;assessment of the defect;rectification work;date rectification work was completed.It is also common practice to use a composite form that includes a list of the itemschecked each day. Where practicable the system should incorporatereportingwhen each driver makes out a report sheet - or confirms by another means that a dailycheck has been carried out and no defects found. Electronic records of reporteddefects are acceptable and must be available for 15 months, along with any record ofrepair.4.5 Appropriate ActionWhere faults have been detected during and inspection, it is essential that thecrane is not taken onto the public or private highway until the severity of thedefect has been assessed by a responsible person.All ddefect reports should be given to a responsible person with sufficientauthority to ensure that any appropriate action is taken. This might include takingthe crane out of service.Any report listing defects is part of the crane s maintenance record and must bekept for at least 15 months, together with details of the rectification work andrepairer.It is good practice to haved caa aac cthat drivers are carrying out their duties and these forms can be used for auditpurposes. Ad cdaac c a bc d c dand is a positive report that the vehicle is free from defects.4.6 D i eRe pon ibili ieDrivers must be made aware of their legal responsibilities regarding cranecondition and the procedures for reporting defects. Owners must ensure that alldrivers are adequately trained to perform this function, and this may be part oftheir driver s certificate of professional competence training.Driver s responsibilities should be detailed in writing, describing defect reportingsystems as well as any other duties they are expected to perform. The drivershould sign to confirm they have received their responsibilities in writing andunderstand what is required.A copy of the document should be kept on file. Drivers share the responsibility forthe crane s roadworthiness with the operator. They may be fined or prosecutedfor roadworthiness offences found on cranes if they are considered partly orwholly responsible.4.7 Minor repairs by DriversIf drivers who are expected to repair minor defects in service, they should be providedwith appropriate training.Maintaining Roadworthiness of Mobile Cranes12 of 55Version 2: February 2022

5.0 Regular Safety Inspections5.1 Inspection Scope and ContentRegular safety inspections are essential to an effective roadworthiness maintenancesystem. A safety inspection can be a freestanding inspection of just those itemsaffecting road safety and certain environmental issues, or it can be part of a morecomprehensive inspection that, in addition, considers items relating to the vehicle swork, performance and economic operation. Although a part of the overall cranemaintenance plan, the inspections should ideally be undertaken as a separate, albeitoften sequential, operation to routine servicing and repair.This provides the maintenance programme with the flexibility to intensify or otherwisechange frequency of inspections. It also allows the introduction of ad-hoc inspections,should they be required, without affecting frequency of servicing and other routinework (e.g. when the operating conditions call for more regular checks or when firstuse inspections are required).In addition, freestanding inspection reports can be produced which provide theoperator with the means of determining not only the roadworthiness of individualvehicles in service but also the overall effectiveness of their vehicle maintenancesystem, thus enabling the instigation of any changes that may be necessary.Although primarily undertaken in the interest of safe crane operations, safetyinspections together with prompt remedial action are also cost effective. The earlyindication of wear, damage or maladjustment may prevent sudden failure ofcomponents resulting in unscheduled downtime, or prevent wear becoming soadvanced that premature replacement becomes necessary.The braking and suspension systems on mobile cranes can be very complex and varybetween different crane manufacturers. It is essential that the persons undertaking theinspections are familiar and have received training on equipment and systems in useon the cranes they will be required to inspect.Maintaining Roadworthiness of Mobile Cranes13 of 55Version 2: February 2022

5.2 First use Inspection5.2.1 Cranes brought into useWhen a crane is first brought into use with an owner it should have undergone a firstuse inspection, which is essentially the first safety inspection. New vehicles enteringservice that have undergone a recorded pre-delivery inspection (PDI) that is ascomprehensive as a safety inspection will not require a further inspection. Usedvehicles, not previously operated, should be given a full safety inspection.5.2.2 Vehicles being returned to useIf a crane has been off the road for a period longer than the planned maintenanceinspections, it should be given a full safety inspection prior to being brought back intouse. A note must be placed on the crane maintenance file to show the vehicle hasbeen off the road.5.3 Scope5.3.1 Scope of Safety InspectionA safety inspection should include all the items listed in Annex B. The safetyinspection form can be any format as long as all items in Annex B are included.5.3.2 Standards to be appliedReference should be made to manufacturrecommended tolerances to ensure thateach item covered by the safety inspection is inspected properly and limits of wearand tolerance are adhered to.In addition, the DVSA produces annual test inspection manuals, which give details ofinspection methods and pass/fail criteria. Copies of the annual test inspectionmanuals and a manual tool to aid categorisation of defects can be downloaded free ofcharge by visiting the GOV.UK website.It must be emphasised that the standards for the annual test are the minimum legalstandards and should be used as guidance for the safety inspection. The inspectorwill need to consider the frequency of inspection, the age of the crane, expectedmileage and type of work undertaken to assess whether a component would remainin a serviceable condition before the next inspection is due.Maintaining Roadworthiness of Mobile Cranes14 of 55Version 2: February 2022

5.4 Safety Inspection IntervalsOperational needs must not override safety considerations. Safety inspections should,where it is practicable, be programmed to follow a time-based pattern. The frequencyat which inspections are undertaken should be determined by assessing the level ofmechanical degradation likely to be incurred over a period because of the crane susage. This will depend on such factors as:the age and type of crane operated;the recommendations of the crane manufacturer;the weight of the crane, the equipment, and fittings it carries or supports;the type and range of operations on which it is likely to be engaged;the type of terrain and the nature of the environment in which it operates or islikely to operate;the distance and speeds at which it travels and the journey times.Assessing the above factors for each crane will, in most cases, enable a time-basedprogramme of inspections to be formulated. Some operations, however, are subject tocontinuous change, or vehicles can frequently be reassigned alternative tasks or routes,making the adoption of a strictly time-based inspection programme impracticable.Mileage-based inspection programmes may be more suitable for some owners but willneed to be linked to time.5.4.1 Older cranesAs cranes age, the average inspection failure rate increases, and they are more likelyto experience in-service roadworthiness defects than newer vehicles. Therefore, theguidance has reflected older cranes will need more frequent maintenance and hasindicated a minimum safety inspection frequency of six weeks requirement for cranesaged 12 years and older.However, depending on usage, i.e., low mileage and light conditions, the frequencymay be extended or reduced accordingly.5.4.2 A guide of safety inspection intervalsAn inspection frequency would normally range between 4 to 13 weeks. See Table 2below for examples of operating conditions.Operating ConditionsA.Lightly loaded vehiclesB.easy operating conditions:Frequency136 weeksGeneral use:105 weeksC.Arduous work - constant long journeys betweenjobsites:84 weeksD.Unmade roads or off-road:4 weeksE.Cranes of 12 years or older:6 weeksTable 2: Safety Inspection Interval GuideMaintaining Roadworthiness of Mobile Cranes15 of 55Version 2: February 2022

5.4.3 Experienced Crane OwnersExperienced crane owners are free to tailor these inspections to suit the nature of theiroperations and crane characteristics. They may even deploy more than one systemacross a fleet, where cranes and the nature of their work vary - even where one aspectof a vehicle s operations require a greater inspection frequency than the whole vehiclefleet. Systems will be judged primarily on their effectiveness in maintainingroadworthiness.It follows, therefore, that to maintain an inspection regime that is sufficiently flexible toaccommodate these changing criteria, it might be more appropriate to adopt aninspection frequency determined by, for instance, the crane s mileage. However, if aninspection schedule is modified, it is sensible to monitor the effect on roadworthinessmonthly. If an unacceptable increase in defects were seen, then a change back to theoriginal schedule would be necessary.To allow some flexibility in planning safety inspections, it is recommended that theInternational Organisation for Standardisation (ISO) week numbering system is used.With this system, the safety inspection should be completed within the relevant ISOweek it falls. ISO defines the week as always starting with Monday through toSunday.Example: a crane came into service and had a first use inspection in week 10 of theISO calendar. The following safety inspections should then be completed within ISO16, 22, 28, 34, 40, 46c.If a safety inspection was completed outside the planned schedule, for examplebecause of a breakdown, a new schedule may need to be created.For the example given above, it would not be permissible to carry out an early SI inweek 20 and then have an eight-week interval to week 28. The operator would needto either carry out another SI at week 22 - and continue with the originally plannedschedule - or reschedule 6-week intervals from week 20 to 26, 32 . etc.Vehicles that are only used for part of the year, or that have been out of service forsome time, should be inspected before they are brought back into service.When they are being used, the subsequent safety inspection intervals should bedetermined in accordance with Table 2, conditions of use and the equivalent annualmileage e.g. 20,000 miles covered over a six month period represents an equivalentannual mileage of 40,000.Where there are doubts about what interval to choose, new crane owners are advisedto be cautious and make more, rather than less, checks.Where vehicles are operating in difficult conditions e.g. in quarry work, on buildingsites, land reclamation sites, or close to the sea where conditions result inaccelerated component wear and vehicle damage - the crane owner is advised toincrease the number of safety inspection checks above the guidance in the tableshown.5.5 Safety Inspection Report FormsA safety inspection report must be completed for each safety inspection. If the safetyinspection report is to be stored electronically, then the paper version does not needto be retained. This does not rule out the use of electronic devices (e.g. tablets) inplace of paper safety inspection reports.For further information relating to computer systems, see Section 7.Maintaining Roadworthiness of Mobile Cranes16 of 55Version 2: February 2022

Each report must show at least the following:name of crane owner;date of inspection;crane identity (registration/trailer number);make and model;odometer (mileage recorder) reading (if appropriate);a list of all items to be inspected;an indication of the condition of each item inspected;details of any defects found;name of inspector;details of any remedial/rectification or repair work and who carried out thework;a signed statement that any defects have been repaired satisfactorily and thevehicle is now in a safe and roadworthy condition.Examples of suitable safety inspection report forms are given in Annex C.The report may contain details of any work to be carried forward. Further checks maybe needed on certain items deemed likely to deteriorate during service and make thevehicle unroadworthy before the next scheduled inspection or routine service (thesechecks must be noted on the inspection report where this assessment is made).5.6 Intermediate Safety CheckWith some types of vehicles and operation, it may be nec

9.0 Inspection Personnel - Attributes, Training and Assessment 21 10.0 Information for Roadworthiness Inspection Personnel 24 11.0 Inspection Procedures and Requirements (Regular and Annual Inspection) 26 12.0 Crane Operator/Owner Management Review of Roadworthiness Inspection Records 29 13.0 Inspection Facilities 31