Christel Fouche

Contractors Health & Safety File Explained

  • February 18th, 2009

Health and Safety files are a contentious issue. I’m referring to the Safety files that are expected to be compiled, maintained and available by the contractor/sub-contractor. The average contractor views the Health and Safety file as a one to five page document (which cannot be further from the truth).

The Construction Health and Safety file is one of the biggest problem areas.

The problem in general is that the emerging contractor who normally knows very little about Health and Safety knows even less about what a Health and Safety file is and what it must contain. A guiding tool to the contents of a Safety file follows.

The file can be divided into the following sections:

Section 1: Introduction
Section 2: Reference Documents
Section 3: Definitions and terminology
Section 4: Roles & Responsibilities
Section 5: Objectives & Targets
Section 6: Planning & Procedures
Section 7: Health & Safety Specification Implementation

Section 8: Application of the Health & Safety Specification

8.1 Compensation for Occupational Injury & Diseases
8.2 Occupational Health and Safety Policy
8.3 Hazard Identification & Risk Assessment
8.4 Health & Safety Committees
8.5 Health & Safety Training
8.6 General Record Keeping
8.7 Incentives
8.8 Penalties
8.9 Emergency Procedures
8.10 Hazards & Potentially Hazardous

Situations

8.11 PPE & Clothing
8.12 Safety Signage
8.13 Permits
8.14 Contractors & Suppliers

Section 9: Health & Safety Practice

9.1 Excavations
9.2 Demolition
9.3 Explosives & Blasting
9.4 Stacking of Materials & Housekeeping
9.5 Hazardous Chemical Substances
9.6 Asbestos
9.7 Plant & Machinery

ANNEXURES/ADDENDUMS:

A Health & Safety Policy
B Hazardous Task Identification
C Risk Assessment
D Induction
E Toolbox Talk
F Audit Schedule

Let us start at the beginning and explain what is meant by “Section 1: Introduction”. This paragraph or page describes the purpose and scope of the safety file and in doing so is answering the following questions:

• Who are we? (Name of organization)
• What do we do? (Eg. Engineering, electrical installations, mining, etc.)
• Why are we compiling this document/file?
• What are the boundaries within which we are operating in terms of health and safety?

In “Section 2: References” you need to list the sources you are referring to within this document such as:

• Occupational Health & Safety Act, Act 85 of 1993
• OHSAS18001: 2007
• ABC Company’s quality management system

Remember: you may not refer to a standard/law/code of practice or any other document throughout your Health and Safety file if you did not list them under this heading of references.

“Section 3: Definitions & Terminology” is important in that it explains and defines terms and abbreviations which everybody reading your file might not be used to and therefore not understand. This could include words such as:

• OHSAct
• ISO
• HIRA
• Contractor
• SOP
• JSA

“Section 4: Roles & Responsibilities” are important in that it gives clarity about who is accountable and responsible for the contents of this file. Ideally an organogram makes this part more visual but is not a requirement. At each level and each function the responsibilities need to be identified and listed – this could include internal as well as external role-players.

When we look at “Section 5: Objectives & Targets” we are expecting you to use the S.M.A.R.T. principles to compile your SHE objectives for this project or the next financial year. Make sure that it is balanced and not only safety objectives. Objectives always include reducing the incident rate, training & legal compliance.

“Planning and Procedures” under Section 6 of the file focuses more on the procedures that are going to be used as part of the project. Remember to use the correct procedure writing format:

• Scope
• Purpose
• Objective
• Responsibility and Authority
• Terms and Definitions
• References
• Links
• Actual procedure (step-by-step)
• ISO9001 quality banner

Examples of likely procedures that will be required are:

• HIRA (Hazard Identification & Risk Assessment) procedure
• Training procedure
• Communication procedure
• Auditing procedure

(It is not limited to these procedures only).

And then finally there is the “Section 7: Implementation of the Occupational Health & Safety Specification”. An undertaking by your organization to ensure the effective implementation of not only your own management system but also that of the client (depending on your agreement/contract) is required under this heading. What needs to come to the foreground is your commitment to safety and health or SHE.

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Health and Safety Plan Development Workshop:

Advantage A.C.T has now launched a 3-day workshop called How to Develop a Health and Safety Plan. This workshop will be held a number of times during this year. Please follow the link for more details.

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The next article will discuss the “Application of the Health and Safety Specification” under Section 8 in detail.

64 Responses to “Contractors Health & Safety File Explained”

  1. SAMANTHA Says:

    HI CHRISTEL
    I NEED TO COMPILE THE SAFETY FILE FOR OUR COMPANY BUT I DONT KNOW WHERE TO START. I HAVE BEEN APPOINTED TO DO IT,BUT NEED HELP.THIS MORNING I HEARD THAT AUDITORS WILL HAVE TO TAKE A LOOK AT IT AND I AM FREAKING OUT.WE ARE SEVEN PEOPLE WORKING FOR THIS COMPANY.PLEASE GIVE ME AN IDEA WHERE TO START
    REGARDS SAMANTHA

  2. ARVIND KUMAR ROY Says:

    I’ve been working as an Occupational Health,Safety & Environmental Professional since 1992 in the various construction projects, engineering & petrochemical industries. ITo enhance my professional skill, want to meet you and take some more guidelines for better professionalism.

  3. Gerhard Smit Says:

    Hi Christel, I’ve enjoy reading this blogg but in one of your other bloggs you’ve commented on QMS and here are you guys assisting she personnel(only), what about a frame work for QMS I am using your book and why don’y you publish a simmular book with regards to layouts and requirements from an auditors perspective on quality more QA than QC

    Also SHE is now a law with statutes, by laws, what is your theory of quality becomming a law and why don’t we create a permanent frame work for everybody to utilize it like NEMA for environment.

    thnks for what your are doing in the industry

  4. James Says:

    Hi there, I am trying to find out what are the requirements for making use of gardeners (subcontracted) to work in our complex. What are they bound by, legal wise?

  5. Jaundre Smook Says:

    Hi Christel

    Thanks for a good article about HSE files. What you say is very true, most contractors have no idea about the HSE requirements on site. I think it is good to give a guideline of your requirements for their safety file compilation, but an even bigger issue, is ensuring your contractor complies with what he/she states the company will to towards HSE.

    I see a lot of contractors, mostly the smaller ones, coming to site with nice looking HSE files. They make use of HSE consultants to set-up a file for them, with all the correct things in the file, without really knowing what is going on or really required.

    Thanks once again.

  6. christel Says:

    Hi Jaundre

    I fully agree. The consultants are making a killing selling these files and completing it on behalf of the contractor not realizing the “reasonably practicable” implications if anything should go wrong. Is it reasonably practical for a contractor to have this file but not knowing the content thereof or not having had an input in the compilation of this file? I do not think so.

    Thank you for the feedback.

    Regards. Christel.

  7. ARTHUR CULLEN Says:

    Hi,I visit this site more often in future>

  8. Priscilla Says:

    So true as most have highlighted that emerging contractors do not know the contents of the H&S file, we as a company provide agent services and compliancy services. The contractors do not realise that msot of the documents in the file are working docs.When evaluating a file i specify why a file has not been approved.thank you for all other super info.

  9. Lepekola Says:

    I have been looking for simple way to explain the format for H&S file to our Contractors and my visit to your website happened at the right time. Thank you

  10. christel Says:

    Hi Priscilla
    Always a pleasure. What is even more shocking is that the uninformed is expecting to have such a completed file ready and workable within an hour or two. Either it is a copy and paste exercise not applicable to the site or it is completely incomplete in terms of content. Regards Christel.

  11. christel Says:

    Hi Lepekola
    Thank you for the response. Keep your eyes on this article/site as there are two more coming to assist you with the rest of the file. Good luck. Christel.

  12. LORRAINE Says:

    HI CHRISTEL

    THANK YOU FOR THE EYE OPENERS!!! I DO HAVE MY FILES IN ORDER AND STILL TRYING TO BE A GOOD SHEQ OFFICER SO READING THROUGH YOUR INFO HAS BEEN UPLIFTING AND MAKES ONE TO BE MORE ALERT TO OUR EVERYDAY WORK .

  13. christel Says:

    Hi Lorraine
    Thank you for the positive feedback. Good luck with the managing and implementation of your systems. Regards Christel.

  14. Amalia van Rhyn Says:

    Hi Christel

    Can you please assist on any information regarding BBS?

    Thank you

  15. Teresa du Plessis Says:

    Good day, I desperately need advise, my son was Squashed on top of a lift he was working on in Sandton, He died a few days later, now the WCA says he was a subcontractor and will not pay, I need to write a good objection as he has two childern, left without parents, we as the grand parents do what we can, but on our pension it is hard. Can you help me please I cannot afford to pay somebody upfront to help. I have been fighting this case 3 yrs now. Last Monday they just told me it was repudiated in 2007. I have been in contact with them on a regular basis, Phoning, emailing, faxing, going directly to the WCA claims, then to the person working with the file, following it up with Labour dept, keeping in touch with the Justice department, because they feel his employer was Neglect. I filled a objection form in January 2007, but as all the documents it was just thrown away like all the other document I had to resend a dozen times..
    Thank you Kind regards Teresa (desperate grand mother)

  16. Dicky Says:

    Christel
    Thank you for being a role model. I admire your passion and commitment when it comes to H&S. It motivates me to make a success of my career in this field. Your objective articles are eye openers.

  17. christel Says:

    Hi Dicky
    This type of comment makes what I do worthwhile. Thank you for the positive feedback and keep me informed on how I can be of further assistance, please.

    Regards Christel

  18. christel Says:

    Hi Amalia
    I will answer your request personally and not on this page. Keep a look-out in your in-box.
    Regards Christel.

  19. christel Says:

    Hi Theresa
    Thank you for the comment. I will answer you personally - may e-mail will follow shortly.
    Regards Christel

  20. Jaco Fourie Says:

    Hi Christel,

    I’ve known about your website for a while but, to my own disadvantage, never logged in to have a look. We are a small OHS Consultancy company concentrating more on the construction industry. The Safety Files that we developed for our clients over the past couple of years were, in our opinion, of a high standard compared to the other junk that’s been offered to contractors at sometimes ridiculous fees. To confirm our opinion and feedback from our clients, our files stood firm through quite a number of Department of Labour and other Consultants’ evaluations. Department of Labour evaluations don’t count for much, considering the standard of most inspectors, so we base our opinion more on the feedback from other Consultants in the industry. What I would like to ask about, is if there is any body or organisation with credibility where we can hand our Safety Files for evaluation to get a real and objective evaluation report on the standard of our files. Any criticism and recomendations will be welcomed in order to lift our standard and to deliver a better product to our clients.

    Kind Regards

    Jaco

  21. Sydney Says:

    Hi Christel
    Thank you for a very informative article on the Contractor H&S file.
    As a Safety Professional myself it does get frustrating when you need to train every new contractor on the requirements of a H&S file, so it does help to be able to refer them to a guideline document.
    Keep up the good work !
    Many thanks
    Sydney

  22. christel Says:

    Hi
    Thank you Sydney. Keep on trying. If you need any assistance in the future you are welcome to contact me. Regards Christel.

  23. christel Says:

    Hi Jaco
    We offer this service: either checking legal compliance or ISO/OHSAS compliance. You are welcome to contact us @ 012 8094210.
    Regards
    Christel

  24. Neil Enslin Says:

    Hi guys,

    Masterbuilders South Africa has a Health and Safety Manual that was developed for the contractors in the construction industry (was used to train DOL inspectors on construction regulation.) This manual has all the required appointment letters, annexure, registers etc all explained in such a way that they will be able implentment it successfully. Call your local master builders for assistances.

    Regards,

    Neil

  25. christel Says:

    Hi Neil

    Thank you for keeping us informed. Any chance of giving our readers pro-active information on any changes that are in the pipeline? Regards Christel.

  26. johan labuschagne Says:

    Hi
    I work for a small H&S consultancy and have over the past 5 years made some shocking discoveries about contractors SHE files.
    1. The one that stands out the most is the incompetence of people who sell themselves as H&S professionals while not having a clue about how an H&S System works. A lot of these people don’t even know the minimum requirements of the Construction Regulations.
    2. Traceability or “closing the loop”. If you perform a HIRA make sure people are trained in this HIRA and ensure that they sign a register in which they acknowledge that they understood what was told to them. If you appoint a 1st aider, ensure that he/she has a valid certificate and keep a copy of the certificate in the file.
    3. A lot of consultants don’t seem to have the ability to understand that each contractor has his/ her own format for a SHE plan or own methodology for performing HIRA’s or that each project and site is unique and therefore come up with findings that are not relevant to the project/ site.
    4. The legal relevance of the wording in the appointment letters. A lot of appointment letters that I have seen will not stand up in a court of law if something happens because the wording in it has no legal reference.
    5. You can only appoint a person in a position if that person is competent; this is clearly stated in the Construction Regulations. And yes, you may give one person more that one responsibility, e.g. Site Supervisor and Risk Assessor and First Aider, as long as that person is competent to perform all these tasks. You may also use one document to make all the appointments as long as you make reference to the relevant regulation in that letter.
    6. I have read through the audit checklist of the MBA and it does have a few good properties. My problem is that even companies like NOSA are moving away from a point system because you either comply with a requirement or you don’t. A good auditor that knows the Regulations don’t need a checklist that takes 3 hours to complete on a small site.

    I agree that small construction companies find it difficult to implement and maintain proper SHE systems but it must be taken into consideration that H&S in the construction industry has not even began to crawl yet where OHS in countries like the UK and USA is a way of living and not a burden.

    Regards

    Johan

  27. christel Says:

    Hi Johan
    I strongly agree! One comment: the point system has been redundent for the past 10+ years and this process was initiated by the ISO/OHSAS process where you get a non-conformance or a finding. This means that a deviation form a set standard has been observed. You cannot be partially (80%) there - you either conform or you don’t. This has also put a better quality on SHEQ auditing and training over the past few years.
    Regards Christel.

  28. Dorie Says:

    Hi

    I need to implement the ISO at our workshop. Don’t know where to start. Can you maybe give me some guidelines.

    Regards

  29. christel Says:

    Hi Dorie
    I have sent you personally some information to browse through to assist - I hope you have received it and is looking forward to further assistance.
    Regards Christel

  30. Ndumiso Jikela Says:

    Hi Christel,
    I wish to request your assistance re appointment letters in terms of OHS ACT Section 16(1) for one of our construction site.
    Kindly assist.
    Regards
    Ndumiso Jikela

  31. christel Says:

    Hi Ndumiso
    I am sending you the information to your personal e-mail address.
    Regards Christel

  32. Michelle Says:

    Hi there,

    We need a H&S File and are in the Pretoria East area. We don’t wan’t to be ripped off and would like to know of someone doing this and what it is going to cost us.
    Thanks

  33. christel Says:

    Hi Michelle
    I have sent the information to your personal e-mail. Please have a look.
    Regards Christel.

  34. Robert Says:

    Hi Christel, i`m in the demolition and blasting industry, and need to set up Health & Safety files quite often! Where can I find a template for such a file in civil blasting?

  35. christel Says:

    Hi Robert
    Thank you for your enquiry. I have replied to your personal e-mail address.
    Regards Christel

  36. Amelia Says:

    Hi
    We are doing an event at Emperors and I need a safety file, please can you help

  37. christel Says:

    Hi Amelia
    I am sending information to your e-mail listed.
    Regards Christel

  38. Anton van Zijl Says:

    Hi Christel

    I am auditing the safety files of our sub-contractors. Recently I have received a file for a company that only provides a tower crane.

    The file they have sent me is not site specific at all. I don’t really have a proper template. I am trying to be strict but fair. Was thinking to send thee entire file back and simply request that they send a site specific file to us.

    Whould you recommend I take such drastic steps or should we (as a principal contractor) be more lenient?

    Your insight would be of a great help.

  39. christel Says:

    Hi Anton

    This is a serious concern but simple to answer. Are you prepared to take the legal responsibility of approving a sub-standard file as the principle contractor? I would not. Also, if you become lenient to one sub-contractor you have to do the same to all the others. I would suggest that you have a meeting to discuss what they need from you and try and assist WITHOUT DOING THEIR FILES FOR THEM or have a standard template of what is required by you that you issue to all contractors - this would be in line with the “reasonably practicable” concept of the act. Regards Christel.

  40. Puleng Says:

    Hi Christelle

    We need to compile a safety file and dont know where to start or who to consult for assistance can u pls help we in the Midrand area

  41. christel Says:

    Hi Puleng
    I have sent you a mail to your address with assistance - please keep an eye open for the information. Regards Christel.

  42. Anton van Zijl Says:

    “If the ladder is not leaning against the right wall, every step we take just gets us to the wrong place faster” - Stephen Covey

    Thanx for keeping our ladders leaning against the right wall….

    Anton

  43. Christel Fouche Says:

    Wow! Thanks Anton - this is one of the nicest compliments I have received! This is what keeps me motivated - people like you!!! Regards Christel.

  44. Kosie Aucamp Says:

    Hi Christel,
    I need to compile a Safety file for a job I need to do. I tried my best but it was not to their specifications I am in die blind installation business and need some advice.I am in Germiston area.
    Regards
    Kosie

  45. Christel Fouche Says:

    Hi Kosie
    I am sending you information to your private e-mail. Please keep me informed if this is what you needed.
    Regards Christel

  46. Gregor Fortuin Says:

    Hi Christel
    I really enjoy reading all your articles that is whenever i have the time to do so. I have also beeninvolved in Health and Safety for a long time and have recently joined another company as SHER-Co-ordinator and
    According to the standards of the company any contractor should have a Safety File. I have been going through the documentation that my predecessor has left and I have never seen such a lot of confusion. Companies subcontracting for cleaning on the premises, the pest control company, maintenance companies ie. toyota forklifts etc. everyone has a safety plan of some sorts. Is it really necessary for them to submit a safety plan? I understand the implication when it comes to construction, but the others?
    I am currently facing the problem that at one of our plants which is situated in the rural area and very far out we have small smme’s tendering to do certain work. When asking about a safety plan, legal liability insurance, letter of good standing - these people have got no clue what you are talking about. Getting someone in to do a certain job can then sometimes be a major problem. What do I do?

  47. Christel Fouche Says:

    Hi Gregor
    I fully understand - we have the same problem with ISO certification being forced upon smaller companies who do not really need it. THe decision however is that of the client requesting the services of the contractor - if it is their requirement the contractor does not have a choice if they want the income. I however believe that legal compliance is first and the rest follows on from there. I suggest you set a new standard in this company according to what you believe is correct but ensuring legal complaince. Just be careful: the safety files’ intent was good initially - and that was to elliminate fly-by-nights who can cause more harm than anything else and who come in at the cheapest price with NO regard for safety and their employees!! The rule is standardization amongst your contractors, simplifying the process and ensuring legal compliance. Good luck. Christel.

  48. Helen Mokitimi Says:

    Just a note to say that I find the website to be very informative. I have been trying to put the Master file in order and have been struggling. Now I’ve got all the answers I need.

    Thank you.

    Regards
    Helen

  49. Christel Fouche Says:

    Hi Helen
    Thank you for your compliment. Good luck.
    Regards Christel.

  50. Lindsay du Toit Says:

    Hi Christel
    I am in the process of compiling a safety file for a small firm doing joinery/woodwork/shopfitting in Nelspruit, Mpumalanga.
    Our tender has been approved subcontracting on a large site. I am struggling with the wording and format as well as content required.
    We are aware of the option to use the services of a labour consultant, however we cannot afford to pay a consultant to compile it on our belhalf, and I believe compiling the file myself will be beneficial to the understanding and successful implementation of the concepts, principles and regulations of the OHSA.
    Any guidance will be greatly appreciated.

  51. Christel Fouche Says:

    Hi Lindsay
    I have sent you 3 documents to your personal e-mail. If you need further information - kindly contact me.
    Regards Christel

  52. Samantha Says:

    Hi Christel, Firstly you really are an angel for this website and I am so glad I found you!!
    Please could you assist me, our company is doing the plumbing on a large construction site and we have been asked for our safety file which I have been commissioned to put together and I ama bit lost to say the least. I really want to make sure it is accurate! I have a copy of another sub contractor’s file but can’t make head or tail of it! i have printed the article above however if you have any other material for me which may be useful I would be very grateful!

    Thank you.

  53. Christel Fouche Says:

    Hi Samantha
    Thank you - I would like to strive towards being an Angel. I am sending you more detail. Good luck Christel.

  54. Ephraim Says:

    Hi Christel, thax for the information I got about the health and safety file. i’ve been trying to put a safety file together but the information that I need is not complete. I would appretiate it if you would explain further especially from section 8

    Regards
    Ephraim

  55. Christel Fouche Says:

    Hi Ephraim
    It is a pleasure. I am still owint the market the 3rd article on the final part of the file. I will write this early in January and keep you all informed. Regards Christel.

  56. Tumi Says:

    Hi Christel
    where have you been all my life? i just found out about you today by chance, i’m already a subscriber and i’m hooked!

    I’m working for an engineering company and we manufacture material handling equipment. Safety here has never ever been a priority and we have those “permanent contractors” doing work for us; and they also do as they see fit. i’ve recently started working here as a SHEQ coordinator, and in a way i’m trying to implement our safety system; and its a challenge to change old habits and mindsets of people when they are used to doing things in a certain way which always worked for them.
    I want to implement signing of contractor’s agreement & submission of safety files for all our contractors, but some of our project managers dont understand why we should implement yet another “useless paper exercise”. i’ve tried to explain it to them over & over again why its necessary and that its a legal requirement. Please provide me with some more points and facts that i can also present to top management so that they too can support this course and enforce it.

    Kind regards
    Tumi

  57. Christel Fouche Says:

    Hi Tumi
    What I find works and is normally very neglected is a legal liability session for ALL managers. Once managers realize their criminal, civil, vicarious and strict liability in terms of SHEQ they normally catch a wake-up. A SHE legal compliance GAP audit by an external provider (remember you are never believed internally!!) also provides an eye opener. I hope this will help. Keep on chatting to me. Regards CHristel.

  58. Jurgens Oosthuizen Says:

    Hi Christel

    I am employed by my employer (FET College) to oversee the construction of a new building (classrooms). According to the architects I need to report on health and safety issues during site meetings. I am urgently in need of a health and safety checklist to us for reporting purposes. Can you please assist me in this regard..

    Kind regards

    Jurg

  59. Christel Fouche Says:

    Hi Jurg
    What a dilemma. IT is not as simple as just getting hold of a H&S checklist and then it is all in order, however I am going to forward a very generic format to you to start the process off. Good luck - Christel.

  60. Ncebakazi Says:

    I have been in the Health and Safety officer for 3 years and now I recently started working for a big company in the same position. the company i work for is a subcontractor for IT related things in a mining environment. Now I am supposed to prepare health and safety files for a total of 22 sites and in some of theses sites there is only 1 or 2 technician from my company. In these sites there is a first aider and safety rep in each and every floor of the building but these safety reps belong to the client. Can you please assist me and guide as in to how I can go about and compile a safety file for each and every site. Do I need to appoint these technicians as safety reps and first aiders? I have also been invited to a meeting by the principal contractor to present the EHS site compliance matrix, in my line of work I have never come across that let alone compile it. Please help me as I don’t know how to go about these major issues and no one knows anything about these issues in my company as I am the first H&S Officer to be employed and there are no records the only thing available is the policy

  61. Christel Fouche Says:

    Hi Ncebakazi
    Yes - you are in a dilemma. I have sent you the contractor file that we use succesfully with all our clients and their contractors. When referring to the site compliance EHS matrix - is this legal compliance, ISO compliance or the training matrix that is referred to? Some advice: Take a deep breath - I know it looks daunting but you will have to set clear objectives and targets and start adressing them one by one. To touch here and then there will not assist you towards success. Good luck - Christel.

  62. Ncebakazi Says:

    Hi Christel

    Thank you for your responce, tthe information hepled me a lot with my safety file. I’m in the negotiation process so that I can get the documents you recomended. From now onwards I am going to take one step at a time because panicing wont assist with anything.

  63. wayne Says:

    Hi Christel.

    I just qualified as a safety officer. Do you have any pointers on where to start? I need a step by step guideline from the first day at work?

    Thank you,

    Wayne

  64. Christel Fouche Says:

    Hi Wayne
    My opinion: you start with legal compliance which include getting management commitment and the policy signed, then do a legal compliance gap audit - the report becomes your objectives and targets for the next year to close out; followed by ensuring risk assessments have been done; then appointments and training of employees; once this has been done there are general duties to perform such as attending of meetings; contractor compliance; investigation of incidents; audits; continual communication to management and employees on H&S; ensuring daily safety such as wearing of PPE; medical examinations; machine safety, etc. I think this is a mouthful already. All the best to you. Christel.

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