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Questions from the Crane 2001 Workshop
No. However, with the anticipated incorporation of API
2C into the regulation, the requirement for an anti-two blocking device will become a
regulatory requirement. Jurisdiction is based on the location of the crane. MMS
takes jurisdiction on all fixed facilities. USCG has jurisdiction on all MODU and
OSV’s. A liftboat is an OSV and therefore, the USCG would have jurisdiction over the
crane and the riggers. Only one tag is required for the lifting assembly
(multi-part slings, personnel baskets, spreader bars) provided those assemblies cannot be
taken apart and used separately. Pendant lines on cranes are considered part of the
crane’s working parts and do not require a tag. Annual crane inspections must occur by the last day of
the 12th month following the previous annual inspection. For example, if you conduct an
annual inspection on January 02, 2001, you must complete the next annual inspection by
January 31, 2002. MMS will not require the lease operator to maintain
documentation for the crane inspector unless that inspector is directly employed by the
lessee. The employer of the crane inspector is responsible for maintaining the
documentation and the crane inspector should be able to provide evidence of qualification. MMS regulates crane operations and personnel transfers
through the incorporation of API RP 2D. 2D does not require the use of certified winches
to handle personnel. When making personnel lifts, the load is required to be under control
in both up and down directions. The lessee should follow the winch manufacturers’
recommendations on the lifting of personnel. American Bureau of Shipping (ABS) sets design criteria
for construction of personnel baskets. However, they do not approve personnel basket
construction unless specifically requested by the basket manufacturer. You are required to keep 2 years of records. These
records should be kept on the platform or the nearest field office. If you (as a new
lessee) cannot obtain the records from the previous lessee, you should notify the MMS
District Supervisor as soon as possible. Records transfer and recordkeeping issues should
be discussed during negotiations and addressed prior to close of property sale. MMS requires that crane operations be conducted in
accordance with the latest edition of API RP 2D. 2D only specifies the type and content of
the necessary training. 2D does not dictate who is to conduct the training. Rigger training is required for anyone who is involved
in hooking or unhooking loads from fixed facility crane. As a result from several recent accidents, MMS is
reviewing other recommended practices from ANSI, OSHA, ASME, and API on use of hoisting
equipment and personnel lifting equipment. It is not known at this time if any regulatory
action will take place as a result of this review. No. If a sling is found with no identifying tag, it must be removed from service. If a sling is found with no identifying tag, it must be
removed from service. The lessee can destroy the sling and replace it or have it certified
and tagged. API RP 2D, paragraph 3.1.5a states in part,
"Whenever there is any doubt as to safety, the [crane] operator will have the
authority to stop and refuse to handle loads or continue operations as safety
dictates." PINC G191 is issued to the lessee and is intended to determine if the
lessee has given the crane operator the authority to shut down crane operations as safety
dictates. The lessee is responsible for ensuring that the crane operator has such
authority and that the crane operator exercises that authority when necessary without fear
of reprisal by the lessee. The definition of "promptly" is "done
without delay". Repair or replacement of critical components should be made as soon
as reasonably possible. MMS understands that parts may have to be ordered and received on
location and this may take some time. You as the lessee must ensure that every possible
measure is taken to ensure safe crane operations during this waiting time for parts. This
may mean restricting the operation of the crane to eliminate any unsafe conditions created
by the disrepair of any critical component. This can include prohibition of crane
operations all together until the necessary repairs are made. The documentation must include the type of training,
name of the crane operator or rigger, the date of the training, and the vendor who
provided the training. Slings must be stored in a manner to prevent them from
being subjected to damage as outlined in API RP 2D. Slings should not be stored on the
deck (solid or grating), or near excessive heat, harsh or corrosive chemicals. API RP 2D, section 3.1.2 – Qualification for
Operators—outlines the qualification for crane operators. The lessee is responsible
for ensuring that all personnel designated as crane operators have met all
of the qualification requirements. MMS assumes that if an individual is designated as a
crane operator and provides proof of training, then that individual has met all
of the physical requirements also. Any person that does not meet the physical requirements
should not be designated as a crane operator and should not be allowed to operate any
crane. Crane operators that were trained prior to the 4th
edition of API RP 2D must receive, as a minimum, the rigger training as outlined in the 4th
edition of 2D. The minimum expectations for a pre-use inspection shall
be in accordance with the latest edition of API RP 2D and the crane
manufacturer. MMS’s expectation is that the operator documents the pre-use
inspection. The crane operator may record the pre-use inspection is his/her tally book
provided that all inspected items are identified. This information must be transferred
into the crane records by the end of the working day. Deckhands must be rigger trained if they participate in
any rigging, hooking or unhooking of any load to/from a fixed facility crane. Grease sample analysis is an acceptable method in
monitoring the ballring wear as discussed in API RP 2D. The PINCs for crane and rigging operations were
developed by MMS using API RP 2D. If the wire rope inspection is conducted as part of the pre-use inspection, then a separate inspection program is not required provided you have included all of the recommended elements of a wire rope inspection program in your pre-use inspection procedures. Privacy | Disclaimers | Accessibility | Topic Index | FOIA Last Updated: 07/15/2008, 07:39 AM
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