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UNITED STATES DEPARTMENT OF THE INTERIOR
MINERALS MANAGEMENT SERVICE
GULF OF MEXICO OCS REGION
| NTL No. 2002-N06 |
Effective Date: July 11,
2002 |
Guidelines for
Crane Load Tests and Recordkeeping on Fixed Offshore OCS Facilities
This Notice to Lessees and Operators (NTL) is issued to
address certain safety concerns and questions recently brought to our attention
with respect to cranes installed on fixed offshore platforms. Regulations at 30 CFR
250.108 address cranes and other material handling equipment on fixed offshore
platforms. Section 250.108(a)(1) incorporates by reference the American
Petroleum Institute’s Recommended Practice for Operation and Maintenance of
Offshore Cranes (API RP 2D), Fourth Edition, into the Minerals Management Service
(MMS) regulations. Section 250.108(a)(2) requires that inspection, testing, and
maintenance records must be kept at the OCS facility for at least 2 years.
Recently, MMS has received questions concerning recordkeeping
and the API RP 2D, Appendix E, Note 2, on load testing procedures which states:
"2. Crane shall be thoroughly inspected per API
Recommended Practice 2D, 4.1.2 "Annual Inspection," before and after the
test. Attention should be given to rigging used to attach loads. Tag lines
should be used on test loads."
Therefore, you must perform an "annual inspection" in
accordance with Appendix E, Note 2, before and after conducting a load test.
According to § 250.108(a)(2), you must keep documentation on inspections at the
OCS facility. These records should be readily accessible to MMS and provided
upon request.
Appendix E Commentary on Load Testing of API RP 2D states
that, "A crane load test is required under the
following conditions:
1. New cranes being placed in service.
2. Cranes that are being permanently relocated.
3. Temporary/rental cranes after each rig-up or relocation
Temporary/rental crane installations are an area of
particular concern. These cranes must be inspected according to the
guidelines in API RP 2D, Section 4.1.2, which states that, "Careful
consideration will be given to the installation of temporary rental crane
support structures." A recent accident involving the connection of a
temporary/rental crane to a fixed platform reinforces our concern over the
safety of temporary/rental cranes. You are responsible for ensuring that
records of the installation inspection are retained and available for MMS
review according to § 250.108(a)(2).
Additionally, API RP 2D, section 5.1.6, specifies, "A
wire rope manufacturer’s test certificate must be supplied to the Owner.
Tests will be performed as outlined in API Specification 9A, latest edition.
These tests will include an actual break certificate." Section C.5.1.3,
Wire Rope Replacement Criteria, states that standing ropes include "boom
pendants." Although MMS does not require pendants to be tagged, the
documentation provided by the manufacturer for boom pendant lines should be
retained at the facility as part of the inspection, testing, and maintenance
records required under § 250.108(a)(2).
Paperwork Reduction Act of 1995 (PRA) Statement:
The information collection referred to in this NTL provides clarification,
description, or interpretation of requirements in the 30 CFR 250, subpart A
regulations. The Office of Management and Budget (OMB) has approved the
information collection requirements and assigned OMB control number
1010-0114. This NTL does not impose additional information collection
requirements subject to the PRA.
Contact: If you have any
questions on this NTL, you may contact Wilbon Rhome, Operations Analysis
Branch, Engineering and Operations Division, (703) 787-1587.
/signed Michael C. Hunt
for Thomas A. Readinger
Associate Director for
Offshore Minerals Management
