Impact of Hong Kong’s Revised "Guidance Notes on Safe Use of Mobile Elevating Work Platforms" on Original Equipment Manufacturers (OEMs) and Recommended Actions

Impact of Hong Kong’s Revised "Guidance Notes on Safe Use of Mobile Elevating Work Platforms" on Original Equipment Manufacturers (OEMs) and Recommended Actions 1. Introduction In February 2026, the H

1. Introduction

In February 2026, the Hong Kong Labour Department launched the revised “Guidance Notes on Safe Use of Mobile Elevating Work Platforms” (the “GNs”), superseding the former “Guidance Notes on Safe Use of Power-operated Elevating Work Platforms”. The revision consolidates common accident causes and outlines enhanced safety requirements for duty holders, including workplace owners, contractors and employers. Although the GNs are addressed primarily to end‑users and duty holders, OEMs of mobile elevating work platforms (“MEWPs”) – particularly those supplying equipment into the Hong Kong market – will be materially affected by the new requirements. This paper analyses the key impacts on OEMs and sets out recommended actions to ensure compliance and maintain market competitiveness.

2. Overview of the Key Revisions and the Grace Period

The revised GNs introduce four main categories of enhanced requirements:

Operator training – The training courses must now include at least 3 hours of theoretical instruction and at least 4 hours of practical training and assessment, with a maximum class size of 20 persons.

Secondary guarding devices – Where there is a risk of crushing or entrapment between the platform and overhead structures or adjacent objects, duty holders are required to install effective secondary guarding devices, such as physical barriers, sensing devices or proximity detection systems that alert the operator and stop the platform when a hazard is detected.

Regular non‑destructive testing (NDT) of critical load‑bearing components.

Emergency rescue plans – Users must formulate and implement documented plans for rescuing personnel from the platform in emergency situations.

Crucially, a grace period is provided for the operator training and secondary guarding device requirements until 31 December 2026. The industry – including OEMs and end‑users – must make sufficient preparations before the grace period expires.

3. Impact Analysis for OEMs

3.1 Product Design and Engineering Requirements (Secondary Guarding Integration)

The installation of “effective secondary guarding devices” shifts from a recommended best practice to an expected baseline requirement. Although the GNs do not prescribe a specific technical standard for secondary guarding systems, the effectiveness of such devices will inevitably be scrutinised by duty holders and, ultimately, the Labour Department. OEMs that equip their MEWPs with integrated, factory‑installed secondary guarding solutions – or that provide clearly documented retrofit options – will have a distinct competitive advantage. Conversely, OEMs that do not address secondary guarding will see their equipment become less attractive to Hong Kong buyers, as end‑users will face the cost and complexity of after‑market retrofits.

Furthermore, secondary guarding technologies interact directly with critical machine systems, including platform controls, emergency stops, guardrail structures and load‑sensing functions. Poorly integrated after‑market solutions may introduce unintended hazards or system conflicts. OEMs that supply MEWPs without pre‑engineered secondary guarding provisions will likely encounter compatibility issues, increased warranty claims and potential liability risks.

3.2 Technical Documentation and Product Information Support

The GNs explicitly require that critical load‑bearing components undergo regular non‑destructive testing. This places a direct obligation on OEMs to:

Clearly identify which components are “critical load‑bearing components” for each MEWP model;

Specify the recommended NDT methods, intervals and acceptance criteria;

Provide this information in the operation and maintenance manuals supplied to Hong Kong users.

OEMs that fail to provide such guidance will leave end‑users uncertain about compliance, potentially leading to improper testing, missed defects and increased accident risks – all of which may invite regulatory attention and reputational damage.

3.3 Training Requirements and OEM Responsibilities

While the direct responsibility for operator training lies with employers and duty holders, OEMs have an indirect but critical role. The GNs require that training is conducted on the specific model of MEWP that the operator will use. Therefore, OEMs must ensure that:

Their equipment is accompanied by comprehensive, model‑specific operator manuals and familiarisation materials;

Where OEMs conduct or authorise training programmes, those programmes meet the stipulated 3‑hour theory and 4‑hour practical requirements;

OEMs’ distributor or dealer networks in Hong Kong are equipped to deliver or support compliant training.

The International Powered Access Federation (IPAF) has already issued a specialised document entitled “Mobile Elevating Work Platform (MEWP) Operator Training Course Requirements in Hong Kong” to assist stakeholders in meeting the new standards. OEMs should align their training support offerings with IPAF’s guidance to ensure market acceptance.

3.4 Clarity on Manufacturer versus User Responsibilities

Although the GNs are directed at duty holders (end‑users), OEMs must recognise that their product liability exposure may increase. If an accident occurs due to:

the absence of factory‑provided secondary guarding provisions;

incomplete or unclear documentation regarding NDT requirements; or

inadequate operator familiarisation materials,

OEMs could face claims under product liability principles, even if the immediate regulatory obligation rests with the user. The GNs also serve as a benchmark for what is considered “reasonably practicable” safety in the Hong Kong context, and courts or regulatory bodies may refer to them in determining whether a product is fit for purpose.

3.5 Alignment with International Standards

While the GNs are Hong Kong‑specific, they align with broader global trends in MEWP safety regulation. The recently published ISO 16368:2024, “Mobile elevating work platforms — Design, calculations, safety requirements and test methods,” serves as a guide for manufacturers to eliminate or reduce accidents and personal injuries, establish criteria for design and testing, and clarify manufacturer responsibilities. The increasing focus on secondary guarding is also reflected in debates within the international industry, with IPAF emphasising that internationally agreed standards are essential to provide clarity for OEMs, rental companies, inspectors and trainers.

OEMs that proactively align their products with ISO 16368:2024 and emerging secondary guarding standards will be well‑positioned not only for Hong Kong but also for other markets with similar requirements.

4. Recommended Actions for OEMs

4.1 Short‑Term Actions (Before 31 December 2026 – During the Grace Period)

4.1.1 Conduct a Gap Analysis

Immediately review each MEWP model supplied or intended to be supplied to the Hong Kong market against the four key requirement areas:

Requirement Area	Assessment Criteria
Operator Training	Has the model‑specific training content been validated against the 3+4 hour requirement?
Secondary Guarding	Is the model factory‑equipped with an effective secondary guarding system? If not, what retrofit options are available?
NDT of Critical Components	Are critical load‑bearing components identified and NDT methods/intervals specified in the documentation?
Emergency Rescue	Does the operation manual include guidance on formulating a rescue plan applicable to the model?

4.1.2 Accelerate Integration of Factory‑Installed Secondary Guarding

Given the grace period expires on 31 December 2026, OEMs should prioritise design and engineering resources to integrate secondary guarding provisions – such as proximity sensors, physical barriers or integrated detection systems – into MEWPs destined for Hong Kong as soon as possible. For existing inventory that cannot be modified before the deadline, OEMs must develop certified retrofit kits and provide clear installation instructions to authorised dealers or end‑users.

4.1.3 Update Technical Documentation

Revise operation and maintenance manuals to:

List all critical load‑bearing components with recommended NDT methods and intervals;

Include a section on emergency rescue planning tailored to the specific MEWP model;

Describe the functionality and limitations of any secondary guarding device installed.

Ensure that all documentation is readily available in English (and ideally in Traditional Chinese to facilitate end‑user understanding), as the GNs are issued by the Hong Kong Labour Department in both languages.

4.1.4 Strengthen Training Support

Develop model‑specific operator training modules that meet the 3‑hour theory and 4‑hour practical requirements.

Where OEMs do not directly conduct training, work with authorised distributors or IPAF‑approved training centres in Hong Kong to ensure that training on OEM equipment is compliant with the GNs.

Provide trainers with detailed familiarisation guides covering all control configurations, emergency procedures and platform‑specific hazards.

4.1.5 Engage with Hong Kong Stakeholders

Establish direct communication with the Hong Kong Labour Department (enquiry hotline: 2542 2172) for clarification on ambiguous requirements – particularly regarding the definition of “effective secondary guarding devices.”

Engage with industry associations such as IPAF and local construction trade bodies to align on best practices and avoid conflicting customer specifications.

Monitor guidance issued by the Electrical and Mechanical Services Department (EMSD), which regulates building-site lifts and tower working platforms in Hong Kong, as MEWP compliance may intersect with their requirements.

4.2 Medium‑Term Actions (2027 and Beyond)

4.2.1 Full Integration into New Product Development

Incorporate the Hong Kong GNs requirements – secondary guarding provisions, clear critical‑component identification, and model‑specific training support – into the standard design and documentation processes for all new MEWP models intended for international markets. Given the global trend toward enhanced MEWP safety, aligning with ISO 16368:2024 will provide a strong foundation.

4.2.2 Quality Assurance for Retrofits and After‑Market Modifications

For MEWPs that are modified after manufacture – whether by retrofitting secondary guarding devices or other alterations – OEMs should be aware that such modifications may render the equipment a “new piece of equipment” requiring fresh safety checks and documentation. OEMs should:

Issue clear guidelines specifying that only OEM‑approved retrofit kits and modification procedures are permitted;

Where modifications are carried out by third parties, provide technical support for re‑certification and remind users of their legal obligations.

4.2.3 Periodic Review of the GNs

The Labour Department has indicated that it will continue to update its occupational safety publications. OEMs should monitor the Labour Department’s website (https://www.labour.gov.hk) for any subsequent revisions or supplementary guidance to ensure ongoing compliance.

4.3 Table of Recommended Actions by Timescale

Timescale	Action	Priority
Immediate (1–3 months)	Gap analysis across all MEWP models supplied to Hong Kong	High
Immediate (1–3 months)	Update operation/maintenance manuals with NDT and rescue plan guidance	High
Short-term (4–8 months)	Integrate secondary guarding into production models for Hong Kong	High
Short-term (4–8 months)	Develop/compliant operator training materials and partner with local training providers	Medium
Before grace period expiry (by 31 Dec 2026)	Ensure all MEWPs supplied to Hong Kong after this date are fully compliant with training and secondary guarding requirements	Critical
Medium-term (2027)	Incorporate HK GNs requirements into global NPD processes and align with ISO 16368:2024	Medium
Ongoing	Monitor Labour Department website for revisions and maintain stakeholder engagement	Low

5. Conclusion

The Hong Kong Labour Department’s revised “Guidance Notes on Safe Use of Mobile Elevating Work Platforms” marks a significant step forward in workplace safety for MEWP operations. For OEMs supplying the Hong Kong market, the GNs present both challenges and opportunities. The grace period until 31 December 2026 offers valuable time to adapt product designs, update documentation and strengthen training support. Proactive OEMs that act promptly to integrate secondary guarding provisions, clearly define critical‑component testing requirements and provide model‑specific training materials will not only achieve compliance but also differentiate themselves in a safety‑conscious market. Those that delay may find their equipment effectively excluded from the Hong Kong market or exposed to increased liability risks.

As the International Powered Access Federation has noted, internationally agreed standards are essential to provide clarity for OEMs and to support consistent deployment across fleets. OEMs should view the Hong Kong GNs not as an isolated local requirement but as part of a global shift toward higher MEWP safety standards – and position themselves accordingly.

Note: The above analysis is based on publicly available information regarding the revised Guidance Notes. OEMs are advised to consult the full text of the Guidance Notes, available for free download from the Labour Department’s website at https://www.labour.gov.hk/eng/public/os/C/EWP.pdf, and to seek independent legal advice concerning their specific compliance obligations.

Impact of Hong Kong’s Revised "Guidance Notes on Safe Use of Mobile Elevating Work Platforms" on Original Equipment Manufacturers (OEMs) and Recommended Actions