Questions from the Crane 2001 Workshop

1. Is the Bureau going to develop manufacturing specifications for anti-two blocking devices?

   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.
    

2. If a crane is located on a liftboat and the rigger is located on the platform, who has jurisdiction over the riggers? the crane?

   Jurisdiction is based on the location of the crane. The Bureau 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.
    

3. What are the tagging requirements for independent legs of multi-part slings, personnel baskets, pendant lines, spreader bars?

   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.
    

4. What is the time frame for which an annual crane inspection must be conducted?

   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.
    

5. What documentation will be required to be kept by the lease operators for crane inspectors?

   The Bureau 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.
    

6. When conducting personnel transfer operations with a crane, does the Bureau require the use of winches certified to handle personnel?

   The Bureau 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.
    

7. Who approves personnel basket construction?

   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.
    

8. Crane records are required to be kept for 2 years. What if a new operator (who buys an older platform) cannot obtain the crane records from the previous owner of the platform?

   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 Bureau District Supervisor as soon as possible. Records transfer and recordkeeping issues should be discussed during negotiations and addressed prior to close of property sale.
    

9. Can lessees train their personnel internally or are they required to use outside training to meet the requirements of 2D?

   The Bureau 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.
    

10. Is rigger training required for floorhands on drilling rigs?

    Rigger training is required for anyone who is involved in hooking or unhooking loads from fixed facility crane.
     

11. What is the Bureau considering with respect to regulating boom and other material handling equipment?

    As a result from several recent accidents, the Bureau 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.
     

12. Can slings be used that do not have tags?

    No. If a sling is found with no identifying tag, it must be removed from service.

13. If a lessee finds a sling on his facility, can he send it in and have it restressed and certified?

    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.
     

14. With reference to PINC G191…If and when the Bureau issues this INC, does the Bureau fully understand the implication and liability placed on the crane operator should an accident have occurred?

    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.
     

15. With reference to PINC G226…What is the definition of "promptly"?

    The definition of "promptly" is "done without delay". Repair or replacement of critical components should be made as soon as reasonably possible. The Bureau 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.
     

16. What are the information requirements for rigger and operator "cards"?

    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.
     

17. What are the Bureau’s requirements for the storage of slings?

    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.
     

18. Will the Bureau check to verify that a crane operator has met the physical requirements as outlined in 2D?

    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. The Bureau 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.
     

19. Do crane operators that were trained prior to the latest edition of 2D have to be retrained in accordance with latest edition?

    Crane operators that were trained prior to the 4^th edition of API RP 2D must receive, as a minimum, the rigger training as outlined in the 4^th edition of 2D.
     

20. What does the Bureau require for recording and documenting the pre-use inspections? What are the minimum expectations for a pre-use inspection?

    The minimum expectations for a pre-use inspection shall be in accordance with the latest edition of API RP 2D and the crane manufacturer. The Bureau’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.
     

21. Do deckhands that hook and unhook loads on a boat have to be rigger trained?

    Deckhands must be rigger trained if they participate in any rigging, hooking or unhooking of any load to/from a fixed facility crane.
     

22. API RP 2D identifies the requirement of annual ballring readings. Will grease samples be accepted in lieu of the annual ballring readings?

    Grease sample analysis is an acceptable method in monitoring the ballring wear as discussed in API RP 2D.
     

23. Where did the PINCs for crane operations come from?

    The PINCs for crane and rigging operations were developed by the Bureau using API RP 2D.
     

24. RP 2D identifies the requirement for a wire rope inspection program. If the wire rope inspection is conducted as part of the pre-use inspection, is a separate wire rope inspection program required?
    
    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.