The Bureau is responsible for the regulation of cranes, booms, and other material-handling equipment installed on fixed platforms according to the 1989 Bureau/USCG Memorandum of Understanding (MOU). Bureau regulates cranes by requiring lessees and operators to comply with American Petroleum Institute’s Recommended Practice for the Operation and Maintenance of Offshore Cranes (API RP 2D), Third Edition, June 1, 1995. The Bureau incorporates this document by reference in the regulations found at 30 CFR 250.120(c), Safe and workmanlike operations.

API RP 2D provides practical guidance for the safe operation, inspection, and maintenance of pedestal-mounted cranes. It also outlines the necessary qualifications and minimum training requirements for crane operators. Bureau inspectors have used this document to establish potential incident of noncompliance (PINC) items associated with crane operations, inspection, and maintenance. Bureau crane inspections are discussed in greater detail later in the document.

As noted above, the Bureau is also responsible for booms and other material-handling equipment on fixed platforms. Since API RP 2D only addresses pedestal-mounted cranes, the Bureau does not have specific regulations that address the operation of other cranes, booms, or other materials-handling equipment. The Bureau discussed the need for developing regulations to address this equipment for several years following the signing of the MOU and finally determined that specific regulations were not needed. In the meantime, the Pacific Region has issued a Letter to Lessees on June 5, 1996, that encourages lessees to apply the same basic inspection, maintenance, and handling practices described in API RP 2D to other cranes, booms, or other materials-handling equipment. This encouragement was proposed to become a requirement via the Notice of Proposed Rulemaking for Subpart A which was published in the Federal Register on February 13, 1998.

Under the 1989 Bureau/USCG MOU, USCG is responsible for cranes, booms and other material-handling equipment installed on mobile drilling units and floating production systems that receive a Certificate of Inspection or Letter of Compliance. USCG regulates the operation and maintenance of cranes in a manner similar to Bureau by referencing API RP 2D (46 CFR 109.521). USCG further requires that cranes installed on those facilities to be:
 

	designed in accordance to API Specification for Offshore Cranes (API Spec 2C);
	installed according to an approved crane plan; and
	inspected and load tested by USCG or an approved third party when the crane is installed, every 48 months, and following repairs or alterations to any structural component of the crane.

Under the proposed Bureau/USCG MOU, the division in responsibilities for regulating cranes does not change from the current MOU. Also, USCG, like Bureau, does not appear to have specific requirements for booms and other material-handling equipment in its regulations.

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