OCS Crane Open Forum

Q & A’s

1. It is our intention, as a minimum, to rigger train crane operators and roustabouts who are responsible within their daily routine duties for rigging. Is this the mandate of the Bureau or are personnel in other positions (which positions?) required to receive this training?

   Response: Rigger training is required by 30 CFR 250.108(a) to be in accordance with API RP 2D, Fourth Edition. Since paragraph 2.3 in API RP 2D, Fourth Edition, states, "A rigger is anyone who attaches or detaches lifting equipment to loads or lifting devices," rigger training will be required by the Bureau for anyone who rigs loads for lifting by cranes located on fixed offshore OCS platforms. Further, as a result of statements in paragraph 3.1.2c. and in paragraph 2.2 of API RP 2D, Fourth Edition, the Bureau will require qualified crane operators and qualified crane inspectors for cranes located on fixed offshore OCS platforms to receive rigger training.
    
2. Do air hoist, chain falls, come-a-longs, block and tackles, and the main lifting block on the drill floor (Top Drive) fall under the rigger part of API RP 2D as lifting devices? After all, the entire Main Block (Top Drive) is a lifting device that lifts pipe and the pipe has to be attached to it via the elevators by a person. (The operations as referred to in this section relate to minor lifts such as positioning motors, equipment, etc. that don’t require crane assistance.)

   Response: Since 30 CFR 250.108(a) only addresses cranes on fixed offshore OCS platforms, the specifications in API RP 2D, Fourth Edition, will only be required by the Bureau for cranes located on fixed offshore OCS platforms. The Bureau regulation 250.108(b) states only that you must operate and maintain all other material-handling equipment (on fixed offshore OCS platforms) in a manner that ensures safe operations and prevents pollution.
    

3. Should anyone who incidentally neither a routine action nor a part of their normal scope of responsibilities) attaches or detaches a load to a crane be required to have rigger training per API RP 2D?

   Response: Rigger training is required by 30 CFR 250.108(a) to be in accordance with API RP 2D, Fourth Edition. Since paragraph 2.3 in API RP 2D, Fourth Edition, states, "A rigger is anyone who attaches or detaches lifting equipment to loads or lifting devices," rigger training will be required by the Bureau for anyone who rigs loads for lifting by cranes located on fixed offshore OCS platforms. You need to follow U.S. Coast Guard requirements for anyone who rigs loads for lifting by cranes located on vessels or mobile offshore drilling units.
    

4. Should everyone who receives rigger training be required to train on every item listed in 2D Appendix A2 even if this person does not and will never use that item in his everyday duties?

   Response: Those personnel required by the Bureau to have rigger training, must receive, as a minimum, all of the training specified in Appendix A2 of API RP 2D, Fourth Edition.
    

5. Can a crew that has 3 or so persons who are rigger trained have an additional trainee assigned to the crew who is not yet rigger trained if supervised by fully trained people? This would apply to newly promoted personnel that haven’t yet attended formal classroom rigger training.

   Response: Since paragraph 3.1.3 in API RP 2D, Fourth Edition, states, "Crane load rigging will only be performed by a qualified rigger," the Bureau will require that all of the qualifications specified in API RP 2D, Fourth Edition, to be a qualified rigger be completed before a person can rig loads for cranes located on fixed offshore OCS platforms.
    

6. What is the date the Bureau will begin enforcement of the rigger training section of API RP 2D and does that mean all have to be trained by that date or can a company have a training plan in process?

   Response: The Bureau has recently published Notice to Lessees and Operators (NTL) No. 2000-N04, which states, "After April 1, 2001, you must comply with API RP 2D, Fourth Edition, for training of all riggers and crane operators . . ." This NTL became effective on September 15, 2000.
    

7. Rigging has been a priority for us for some time and as a result developed a training program in which we are proud. Rigger training had been part of our in-house training program since early 1997. The training program includes those items required per last issuance of API RP 2D for riggers. Our classroom plus hands-on training averages10 hours whereas approved classes to teach rigger training per API RP 2D take 6 to 8 hours. However, our in-house certificates do not state "Rigger Training per API RP 2D" because it had not been written and issued at that time. My question is, can our certificates that state "Basic Lifting Techniques and Basic Rigging Techniques" suffice when audited via the Bureau inspectors? If not, why and what can be a resolution without having to repeat the identical (or in most cases less) training. Copies of type certificates can be provided upon request.

Response: After April 1, 2001, all training required by the Bureau for riggers must be in compliance with API RP 2D, Fourth Edition, as a minimum. To ensure that these requirements are met, after April 1, 2001, certificates for qualified riggers for loads rigged for cranes located on fixed offshore OCS facilities must indicate compliance with API RP 2D, Fourth Edition. The problem that you identified could be addressed either by having the trainer/certifier/issuer of the original certificate issue a revised certificate annotated to indicate compliance with API RP 2D, Fourth Edition or issue an endorsement signed by the trainer/certifier/issuer of the original certificate that states that, "The completed training is certified to be in compliance with API RP 2D, Fourth Edition."

8. Paragraph 3 of NTL No. 2000-N04, as well as paragraph 3.1.2d of API RP 2D, specifies the minimum training refresher for Qualified Operators. Are there any training refresher requirements for Qualified Riggers, other than the initial qualification?

Response: As you have correctly stated, paragraph 3 of NTL No. 2000-N04, as well as paragraph 3.1.2d 0f API RP 2D, specifies the minimum training refresher requirements for Qualified Operators. Neither API RP 2D nor the Bureau requires refresher training for Qualified Riggers. The API considered this option before sending the revised Fourth Edition of the RP, dated August 1999, to its members for balloting. However, API decided against incorporating Qualified Rigger refresher training for the following reasons:

	Rigging is a very repetitive job by nature;
	Rigging is considered to be short term, usually lasting 6 months to no more than 2 years; and
	Most riggers usually move on to become crane operators.

Thus, API could not justify incorporating refresher training for Qualified Riggers in the Fourth Edition of API RP 2D; and the Bureau concurs with this assessment.