SAFETYALERT Safety Alert No. 329 20 February 2018 Contact: Jason Mathews Phone: (504) 731-1496 Potentially Catastrophic Crane and Lifting Incidents Crane boom hanging over the side of drilling rig associated with 29 November 2017 incident Four recent safety incidents have occurred that involve cranes and lifting devices. As the descriptions below demonstrate, the failures could have resulted in catastrophic consequences for personnel and the environment. · 16 October 2017: Incident occurred while conducting the operation of running a drilling riser in preparation for latching up the Blowout Preventer (BOP). While picking up a slick joint to connect to the BOP stack, the joint became un-lodged from the riser running tool and fell across the derrick, causing structural damage to the main drawworks track support bracing, hydraulic line, electrical cables and cable trays. The dropped joint of marine riser weighed 43,000 lbs. No personnel were in the drop zone at the time of the incident. · 28 November 2017: Personnel were attempting to lift a diesel tote from a supply vessel and the fast line was lowered to the deck and attached to the pre-slung diesel tote. When the tote was lifted approximately five feet off of the deck, the fast line parted and about 120 feet of cable, crane ball, and tote fell back to the deck. Failure of the crane was caused by a frozen boom tip sheave which caused the running line to jump the sheave. No personnel were in the drop zone at the time of the incident. · 29 November 2017: Immediately after completing a four-person personnel transfer, workers were preparing to hook up a pallet from a crew boat. The port crane boom fell freely hitting the side of the jack-up rig, puncturing a hole in the port diesel tank. The cause of the failure was missing retaining rings that held the pawl pin in place, causing the pin to dislodge. Inspection of the starboard crane also revealed missing retaining rings. Thirty eight barrels of diesel fuel was released into the Gulf of Mexico as a result of this incident. · 13 December 2017: A rig crew was in the process of loading tubing from the rig to a work boat. When they started to lift a bundle of tubing from the V-door, one 27/8" tubing joint slid out of the center of the bundle of 12 joints and fell about 120 feet to the deck of the work boat below. The joint landed on an empty cutting box, puncturing the lid and then fell to the deck of the boat. No personnel on the boat were near the area of the cutting box and there were no injuries. Therefore, BSEE recommends that operators consider the following options: · Ensure that proper planning is conducted prior to lifts. This planning should include review of drop zones, identification of safe zones while the lift(s) occurs and verification that all participants are trained in the work practices to conduct lifts and/or perform inspections. · Review the mechanical integrity program to verify that crane maintenance and inspections are being performed per the Operator’s SEMS plan, BSEE regulations and API RP 2D. The frequency of inspections and test must meet the manufacturer’s recommendations. Special consideration should be given to: o accessibility and inspection of a crane’s boom hoist lock pawl cylinder assembly; o outer diameter measurements of boom, main, auxiliary and pendant cables; o documentation on installation date, manufacture date and identification information for boom, main, auxiliary and pendant cables; o inspection and lubrication of sheaves; and, o ensuring that wire rope size and sheave sizes are compatible. · Verify that loads are centered, balanced and secured prior to initiating lifts. A Safety Alert is a tool used by BSEE to inform the offshore oil and gas industry of the circumstances surrounding an accident or near miss. It also contains recommendations that should help prevent the recurrence of such an incident on the Outer Continental Shelf. BSEE Launches Risk-Based Inspection Program D?f?fE?l? I?ilE?l?ilir GHLEANS The Eiureau of Safety and Enyironmental Enforcement this week announced the implementation of a new Risk?Based Inspection Program that employs a systematic framework to identify facilities and operations that exhibit a high?risk pro?le. The risk?based inspections supplement ESEE's existing National Eafety Inspection Program. The GIGS Lands Act authorizes to conduct annual scheduled inspections and periodic unannounced inspections of all oil and gas operations. The new risk?based inspection protocol looks beyond compliance and assesses the integrity of critical safety systems on facilities and operations. those that haye had multiple incidents of non?compliance or eyents and may need more attention. ?We deyeloped this program to address areas where trends in compliance and incident data suggest the potential for imminent safety concerns.? said Jason Mathews. chief of Gulf of Mexico Region Safety Management Gf?ce. in the Gulf of Mexico. The risk factor score is based on speci?c performance and risk?related information that falls into two types of risk?based inspections: "facility based" and "performance based.? Based on analysis of this information. BSEE prioritized the areas that require follow?up under the risk?based inspection protocols. The implementation of this program demonstrates signi?cant progress by BSEE oyer the past year. The preyious administration was criticised for a stow pace in implementing such a program from 2011?2015. The Goyernment Accountability Gf?ce in a 2012 report. noted the need for an approach that would identify and eyaluate offshore operations according to risk. In a later report. the GAGL again criticized pace in implementing such an approach under the preyious administration. This administration focused on making this a priority. Risk?based inspections allow BSEE the opportunity to focus on compliance issues and reduce the likelihood of incidents across the Gulf of Mexico Region on a continuous basis. ?rst risk based inspections this year will focus on crane operations and will begin this month. "Gur inspectors are the eyes and ears of what?s reaily happening offshore at any giyen time.? said Mathews. ?Witho ut them. my team would neyer be able to do their analysis. Together. we striye for continuous improyement so that offshore energy operations are safe for workers and the enyironment. Director Angelle made it clear this was a priority to improye safety. We are excited about making the DES a safe place." List of Safety Alerts Concerning Crane Accidents http://www.gomr.boemre.gov/homepg/offshore/safety/safealt/sa_175... U.S. Department of the Interior Minerals Management Service Gulf of Mexico OCS Region Notice No. 175 July 20, 1998 CONTACT: Chuck Schoennagel, Jr. (504) 736-2923 List of Safety Alerts Concerning Crane Accidents Recently, several crane accidents have occurred on leases in the Gulf of Mexico, Outer Continental Shelf (OCS). In addition to our normal investigations into these recent incidents, the Minerals Management Service (MMS) has convened an internal working group to review the entire realm of crane safety. When this group completes its findings, MMS will issue a report on crane safety. In the interim, and so that a more proactive approach at preventing a recurrence of crane accidents may be taken, we have attached copies of previous Safety Alerts concerning crane accidents that have occurred in the Gulf of Mexico OCS. All OCS operators have a positive responsibility to conduct their operations in a safe manner; they must be familiar with these incidents, so that they may design and plan their work to avoid similar incidents. These Safety Alerts are as follows: Notice No. Date Issued 1 of 1 20 February 24, 1975 36 February 2, 1976 47 July 9, 1976 57 March 11, 1977 65 June 13, 1977 79 November 8, 1978 95 January 22, 1980 96 June 20, 1980 104 July 28, 1981 124 March 27, 1984 125 March 27, 1984 166 June 11, 1996 2/21/2012 4:13 PM Number of OCS Lifting Incidents Number of OCS Lifting Incidents 250 200 150 100 50 0 3 2007 2008 2009 2010 Year 2011 2012 2013 2014 Number of OCS Lifting Incidents per Installation 0.09 Number of OCS Lifting Incidents per Installation 0.08 0.07 0.06 0.05 0.04 0.03 0.02 0.01 0 2007 2008 2009 2010 Year 4 2011 2012 2013 2014 Lifting Incidents 300 Lifting Incidents per Installation Number of Lifting Incidents Frequent and routine lifting operations involving personnel and material transfer – both on OCS fa250 cilities and between vessels and facilities – is a necessary and commonplace function of the offshore 200 work environment. As with many hazardous offshore operations, engaging in daily routine activity can lead to complacency and a lowered awareness 150 of risk. Lifting – typically by crane – always carries risk due to close quarters, metocean conditions and 100 the need to coordinate with ongoing simultaneous operations (drilling, production, etc.). Lifting incidents range in severity from near misses and mi50 nor injuries to fatalities. Most lifting incidents are preventable. As such, BSEE pays close attention 0 to lifting practices among OCS operators and has 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 been working on a new Crane Safety Rule, which Fiscal Year is being designed to help reduce lifting incidents. Figure 3.14 Frequent and routine lifting operations for personnel and material are required for The Stop Work Authority institutionalized under offshore oil and gas installations. Over the course of fiscal years 2007 through 2016, an average of 173 lifting incidents was reported to BSEE per year. Overall, lifting incidents have the SEMS program is also of particular value in dy- approximately been variable over time, but were lower in FY 2015 and 2016 than the three preceding years. namic situations involving lifting. BSEE coordinates regularly with the Coast 0.09 Guard, which shares regulatory space with BSEE in regard to lifting incidents. The data presented 0.08 here include lifting incidents that are reportable 0.07 to BSEE. There may be lifting incidents resulting from offshore operations, such as those related to 0.06 vessel-to-vessel transfer of personnel, which may also be reported to other federal agencies (e.g., 0.05 USCG). BSEE requires that all lifting incidents 0.04 (defined as those involving crane or personnel/material handling operations) be reported immediate0.03 ly, per 30 CFR 250.188(a)(8). A follow-up written 0.02 report is required within 15 days. Over the course of fiscal years 2007 through 0.01 2016, an average of approximately 173 lifting incidents were reported to BSEE per year, with an an0 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 nual range of 110 (in 2011) to 243 (in 2009). The Fiscal Year FY 2016 total of 155 lifting incidents is very close to the 10-year average, but is the lowest since FY 2012 Figure 3.15 When lifting incidents are normalized on a per installation basis, the trends look to the trend seen for overall data. For FY 2016, the calculated rate was one lifting incident and is reflective of a slight decline over the prior two similar per 14.1 installations. years (Figure 3.14). When the number of such incidents is calculated on a normalized per installation basis, a slight increase from FY 2015 to FY 2016 emerges (Figure 3.15). For FY 2016, the calculated rate was approximately one lifting incident per 14 installations. BSEE considers this to be an area where much improvement is both needed and possible, and it will continue to be a focus of our regulatory efforts. Gas Releases The management of hazardous gases is a critical component of safety and environmental compliance during offshore drilling, production and processing. These gases range from those that are potentially dangerous if mishandled (e.g., nitrogen gas) to those that are acutely toxic. In the latter category, hydrogen sulfide (H2S) gas requires particular scrutiny during facility design, construction, and operation. BSEE regulations require identification of gas hazards prior to initiating operations, appropriate design and institutional controls on gas management during operations, and rapid reporting of most gas releases. There are two basic levels of reporting gas releases: Safety & Environmental Performance    37 Causes of Fatalities, 2007-2014 Explosions/Fires 5% 5% 5% 2% 2% Helicopter Diving Related 44% 9% Construction Fall Personnel Transfer Man Overboard 12% 16% 2 Lifting Electrocution Support Vessel - Anchor BSEE Director Brian Salerno Delivers Keynote Speech at 2015 API Offshore Safe Lifting Conference and Expo 07-14-2015 Safe Lifting Conference Remarks Good morning. It is great to be here with all of you for the Safe Lifting Conference. I would like to thank API for putting on this important event, and for inviting me to be a part of it. It's an honor to share the podium with Captain Reynolds again, who you will be hearing from next. I always value these opportunities to present together, because we also devote a lot of time to working together in our joint efforts to improve offshore safety. Years ago, when I was still a U.S. Coast Guard inspector based in Port Arthur, I had occasion to conduct an inspection of a semi-submersible rig. I was accompanied by the company safety officer, and the two of us stepped onto the outer rim of a Billy Pugh basket to be hoisted up to the main deck of the rig. As we were going up, and holding on tightly against any jolts or unexpected motions, I commented half-jokingly to the safety officer how I felt good that I was in his company, because it seemed less likely that there would be any horseplay by the crane operator. The safety officer looked at me and confided that he had been thinking the same thing – that he was glad to be in the company of a U.S. Coast Guard inspector – for the same reason. We concluded that neither of us was immune to what at that time was the not-unheard of practice of having a little fun with personnel transfers. But we made it safely. And the crane operator set us down as smoothly as possible, which is the outcome you hope for when you put your life in someone else's hands. Thankfully, we don't hear much about intentional horseplay anymore – some things are happily left in the past. But sadly, we cannot say the same thing about lifting incidents Unfortunately, lifting incidents have been a persistent trend. Ten years ago, when I reported to the U.S. Coast Guard Headquarters and began regular interaction with the Mineral Management Service on offshore safety, lifting emerged as a key area of joint focus. More recently, review of our incident data within BSEE underscores that the problem has not yet been solved. Hard numbers show that lifting is not as safe as it should be. I will share with you just a few slides referencing data that we included in our inaugural Annual Report, released in May at the Offshore Technology Conference. Slide 1 This slide shows fatalities on the OCS between 2007 and 2014. As you can see, 16 percent of fatalities were lifting related. That represents the second most significant cause of fatalities on the OCS, coming in behind fires and explosions. I doubt there is anyone in this room who doesn't see 16 percent as a problem. But I also doubt that there is anyone here who doesn't see this problem as one that can be solved. Slide 2 This slide and the one following show that the trends in lifting incidents are not improving. As you can see, there has been a steady increase every year since 2010. Last year there were over 200 discrete lifting-related incidents. You may be wondering why 2010 and 2011 were lower… that's because there was a low level of activity in deepwater on the OCS at that time, so the 2010/2011 statistics only reflect shallow water activity. Now, these are the raw numbers of lifting incidents. To make this more meaningful, we normalized these incidents to the number of offshore installations. We found that the trend still exists after normalization. Slide 3 Not only does the trend exist, but this chart shows us that the number of incidents per installation has more than doubled in the last four years. Looking at these two graphs I think we can all agree that this demands action by each of us, in order to reverse this trend. Several questions spring to mind when we see this trend information; some quite obvious... such as • • • What accounts for the increasing number of incidents? Has the workforce turned over to such an extent that we have an experience deficit? Are new employees not as well trained in the use of the equipment? Or is the equipment itself the problem? In other words, is it the people or the technology? Or both? This conference is a great place to tackle these questions, and perhaps they will serve as a logical starting point for us to consider how to go about improving lifting safety. And I'll go out on a limb here… I suspect that we will not find a single silver bullet that will make all of this better and reverse the trends we just saw. In all likelihood, this is going to require a variety of strategies implemented by a variety of actors. Operating companies have the most direct control over the maintenance of their cranes and the qualification levels of the crane operators. It has to start there. Standards development organizations have developed, and periodically upgrade, the standards that operators use and which third party verifiers use to certify adherence to safety standards. As a regulator, we too have a responsibility, which generally takes the form of adopting the industry standards as a regulatory foundation that levels the playing field, and then assessing whether the standards are being followed in practice. Along these lines, as most of you surely know, we recently proposed a rule to update our regulations to reflect the most recent industry standards. The proposed rule would implement best practices and update existing regulations for cranes mounted on fixed platforms, specifically addressing safe loading of cranes, service life, braking systems, and personnel safety. Also, as part of our efforts to be consistent across government, our proposed rule aligns with the U.S. Coast Guard's proposed rule on the same subject, which I am sure Captain Reynolds will speak about in more detail. By the way, the comment period closes tomorrow at midnight, so if you have not yet submitted comments, there is still time! Ideally, the industry is already following the consensus standards so that the regulations themselves are more of a formality than a dramatic change to operations. That's in an ideal world. The reality is that not all companies respond to industry standards with the same degree of diligence. This brings me to one of our recurring themes: risk management and, more to the point, riskbased inspections, which bear very much on the topic at hand at this conference. In a broad sense, risk management means that we intend to focus more time and attention on facilities where there is a greater combination of risk factors. This will be a function of past performance, complexity of operations, and adherence to SEMS methodologies. But on another level, it can take the form of a focused inspection campaign. When incidents of a particular type occur with sufficient frequency to indicate a widespread problem, such an approach may be necessary to fully assess whether standards are being followed and if normal industry practices are adequate. That is where we believe we are with respect to lifting incidents. And so we have begun to focus on offshore cranes in conjunction with our normal inspection activity. But as I mentioned earlier, this will require multiple strategies. While I strongly believe updated regulations and continued inspections are necessary and important, they alone aren't enough to reverse the trend we have been seeing. Fortunately, others are taking steps to address this problem as well. The American Bureau of Shipping, for example, recently updated their guide for the certification of lifting equipment. They also completed a study for BSEE to better assess crane safety offshore. But again, it is operating companies that must take the lead in identifying best practices. They are in the best position to observe and identify the human factors involved in lifting incidents, and, just as significantly, the factors contributing to the close calls. Another way of stating this is that lifting safety needs to be considered in the context of SEMS every bit as much as through specific technical standards. As we have all seen, the lack of a meaningful safety culture is often the biggest factor in any kind of safety incident. The leading-edge companies, the ones that have made a true commitment to safety, tend to have far fewer serious incidents. That is because they put a great deal of thought and planning into every operation, including lifting operations, by addressing all possible contingencies in advance as well as the human element in the work process. As many of you are aware, the Ocean Energy Safety Institute is hosting a SEMS workshop on July 29th at the University of Houston. They will be discussing a variety of topics related to improving SEMS planning, including the sharing of information. This would naturally include the desirability of sharing safety information related to lifting operations. This is certainly important at the macro level, where information has system-wide value, but it is also important at the micro level, where the focus is on making sure that all participants in a work effort have shared awareness of planned activities and understand their roles – including what to do if events deviate from the expected process. Lifting safety would benefit from information sharing at both levels. What I would ask is that we tackle this collectively. I believe that regulatory inspections alone will not solve the problem. This issue requires commitment by those who are on scene every day, operating equipment and making decisions in real time. Before I conclude, I want to leave you with a stark example that I believe illustrates why we are here. In April of 2011, at approximately 3:30 a.m. on a Platform located in West Cameron, Block 643, plugging and abandonment operations were taking place as part of decommissioning. Specifically, operations were underway on the main deck of the platform involving a power swivel skid, casing jack, and crane. As the power swivel was being moved by the crane from atop the well, a roustabout who was acting as a rigger to help control the load somehow lost his footing and was either knocked or dragged by the moving load. We will never know for sure what happened. He fell through an opening in the deck which was exposed by the lift of the power swivel, and he landed 30 feet below on the production deck. The roustabout did not survive the fall. To add insult to injury, as he lay there on the deck, a medevac callout was delayed due to confusion over the emergency procedures. An investigation by BSEE revealed several important factors that contributed to this tragic accident. • • • • • There was no emergency plan with med-evac procedures and contact information readily available. The accident occurred shortly after shift change at night, and the pre-shift Job Safety Analysis meeting did not address the opening in the main deck covered by the power swivel. Moreover, the meeting was not attended by everyone involved in the operation, including the roustabout. The pre-lift “toolbox” meeting also did not discuss the existence of the opening beneath the power swivel, and no fall protection was provided as required by company policies, BSEE, and the U.S. Coast Guard. Other plugging and abandonment equipment on the platform was positioned poorly and interfered with the lifting operation. And finally, there was no clearly designated supervisor directing the lift. This incident is just one example… and, sadly there are many more. No one here wants to lose a worker. No one wants to face the family of a worker who dies or is severely injured because we didn't do our jobs correctly, or because we failed to recognize that the risks present on-site were beyond acceptable bounds. So let's see what we can do to reverse these trends. Now I'm going to turn the microphone over the Captain Reynolds, and then at the end we should have some time for questions. Thank you. Federal Register / Vol. 80, No. 114 / Monday, June 15, 2015 / Proposed Rules self-improvement activity and therapy and his utilization of available resources to overcome recognized problems. Achievements in accomplishing goals and efforts put forth in any involvements in established programs to overcome problems are carefully evaluated. (F) Community resources available to assist the offender with regard to his needs and problems, which will supplement treatment and training programs begun in the institution, and be available to assist the offender to further serve in his efforts to reintegrate himself back into the community and within his family unit as a productive useful individual. (ii) If a prisoner has been previously granted a presumptive parole date under the Commission's guidelines at ? 2.80(b) through (m), the presumptive date will not be rescinded unless the Commission would rescind the date for one of the accepted bases for such action, i.e., new criminal conduct, new institutional misconduct, or new adverse information. (iii) Prisoners who have previously been considered for parole under the 1987 guidelines of the former D.C. Board of Parole will continue to receive consideration under those guidelines. Dated: June 3, 2015. J. Patricia Wilson Smoot, Acting Chairman, U.S. Parole Commission. [FR Doc. 2015-13998 Filed 6-12-15; 8:45 am] BILLING CODE 4410-31-P DEPARTMENT OF THE INTERIOR Bureau of Safety and Environmental Enforcement 30 CFR Part 250 [Docket ID: BSEE-2014-0002; 14XE1700DX EX1SF0000.DAQ000 EEEE50000] RIN 1014-AA13 Oil and Gas and Sulphur Operations in the Outer Continental Shelf--Update of Incorporated Cranes Standard Bureau of Safety and Environmental Enforcement (BSEE), Interior. ACTION: Proposed rule. asabaliauskas on DSK5VPTVN1PROD with PROPOSALS AGENCY: BSEE proposes to incorporate by reference the Seventh Edition of the American Petroleum Institute (API) Specification 2C (Spec. 2C), ''Offshore Pedestal-mounted Cranes'' (2012), into its regulations. The Seventh Edition of API Spec. 2C revised many aspects of the standard for design and construction of cranes manufactured since the SUMMARY: VerDate Sep<11>2014 16:22 Jun 12, 2015 Jkt 235001 Seventh Edition took effect in October 2012. The intent of proposing to incorporate this revised standard into BSEE regulations is to improve the safety of cranes mounted on fixed platforms that are installed on the Outer Continental Shelf (OCS). This proposed rule would require that all cranes that lessees or operators mount on any fixed platforms after the effective date of the final rule comply with the Seventh Edition of API Spec. 2C. DATES: Submit comments by July 15, 2015. BSEE may not fully consider comments received after this date. ADDRESSES: You may submit comments on the proposed rulemaking by any of the following methods. Please use the Regulation Identifier Number (RIN) 1014-AA13 as an identifier in your comments. BSEE may post all submitted comments, in their entirety, at: www.regulations.gov. See Public Participation and Availability of Comments. 1. Federal eRulemaking Portal: www.regulations.gov. In the search box, enter ''BSEE-2014-0002,'' then click search. Follow the instructions to submit public comments and view supporting and related materials available for this rulemaking. 2. Mail or hand-carry comments to the Department of the Interior (DOI); Bureau of Safety and Environmental Enforcement; ATTN: Regulations and Standards Branch; 45600 Woodland Road, Mail Code VAE-ORP; Sterling, Virginia 20166. Please reference ''Oil and Gas and Sulphur Operations in the Outer Continental Shelf--Update of Cranes Standard, 1014-AA13,'' in your comments and include your name and return address. FOR FURTHER INFORMATION CONTACT: Kelly Odom, BSEE, Regulations and Standards Branch, 703-787-1775, email address: regs@bsee.gov. SUPPLEMENTARY INFORMATION: Executive Summary As required by law, BSEE regulates oil and gas exploration, development and production operations on the OCS. Among other purposes, BSEE's regulations seek to prevent injury, loss of life, as well as damage to property, natural resources, and the environment. BSEE incorporates by reference in its regulations many oil and gas industry standards in order to require compliance with those standards in offshore operations. Currently, BSEE's regulations require that all cranes on any fixed platform that was installed on the OCS after March 17, 2003, as well as all cranes manufactured after March 17, 2003 and PO 00000 Frm 00034 Fmt 4702 Sfmt 4702 34113 installed (i.e., mounted) on any fixed platform (regardless of when the platform was installed on the OCS), meet the requirements of the Sixth Edition of API Specification 2C, ''Offshore Pedestal Mounted Cranes'' (2004). In 2012, API adopted the Seventh Edition of API Spec. 2C, which extended the standard to more types of cranes and made significant improvements to the standard for design, manufacture and testing of cranes in areas such as gross overload (e.g., from supply boat entanglement), consideration of duty cycles (including intensity and frequency of crane use), structural design, and wire rope design. BSEE has determined that incorporation of the Seventh Edition of API Spec. 2C would improve safety and help prevent injury as well as damage to property. Thus, BSEE proposes to amend its existing regulations by incorporating the Seventh Edition of API Spec. 2C and, thus, to require that any cranes that lessees or operators mount--after the effective date of the final rule--on any fixed platforms meet the requirements of that standard. BSEE also proposes to add a definition of ''Fixed Platform'' to the regulations, consistent with the Sixth and Seventh Editions of API Spec. 2C as well as with related API standards and BSEE regulations. BSEE's Functions and Authority BSEE promotes safety, protects the environment, and conserves offshore oil and gas resources through vigorous regulatory oversight and enforcement. BSEE derives its authority primarily from the Outer Continental Shelf Lands Act (OCSLA), 43 U.S.C. 1331-1356a. Congress enacted OCSLA in 1953, establishing Federal control over the OCS and authorizing the Secretary of the Interior (Secretary) to regulate oil and natural gas exploration, development, and production operations on the OCS. The Secretary has authorized BSEE to perform these functions (see 30 CFR 250.101). To carry out its responsibilities, BSEE regulates exploration, development and production of oil and natural gas on the OCS to enhance safety and environmental protection in a way that reflects advancements in technology and new information. In addition to developing and implementing such regulatory requirements, BSEE collaborates with standards development organizations and the international community to develop and revise safety and environmental standards, which BSEE may incorporate into its regulatory program. BSEE also conducts onsite inspections to ensure E:\FR\FM\15JNP1.SGM 15JNP1 34114 Federal Register / Vol. 80, No. 114 / Monday, June 15, 2015 / Proposed Rules compliance with regulations, lease terms, and approved plans. Detailed information concerning BSEE's regulations and guidance for the offshore industry may be found on BSEE's Web site at: www.bsee.gov/ Regulations-and-Guidance/index. asabaliauskas on DSK5VPTVN1PROD with PROPOSALS Public Participation and Availability of Comments BSEE encourages you to participate in this proposed rulemaking by submitting written comments, as discussed in the ADDRESSES and DATES sections of this proposed rule. This proposed rule provides 30-days for public comment because the Seventh Edition of API Spec. 2C (which was extensively reviewed and discussed during the API standard-setting consensus process) has been in effect for well over two years; thus, the relevant industries are already familiar with both the Seventh Edition and the existing BSEE regulations incorporating the prior edition of that standard. Before including your address, phone number, email address, or other personal identifying information in your comment on this proposed rule, however, you should be aware that your entire comment--including your personal identifying information--may be made publicly available at any time. While you can ask us in your comment to withhold your personal identifying information from public review, we cannot guarantee that we will be able to do so. Procedures for Incorporation by Reference and Availability of Incorporated Documents for Public Viewing BSEE frequently uses standards (e.g., codes, specifications, recommended practices) developed through a consensus process, facilitated by standards development organizations and with input from the oil and gas industry, as a means of establishing requirements for activities on the OCS. BSEE may incorporate these standards into its regulations without republishing the standards in their entirety in the Code of Federal Regulations, a practice known as incorporation by reference. The legal effect of incorporation by reference is that the incorporated standards become regulatory requirements. This incorporated material, like any other properly issued regulation, has the force and effect of law, and BSEE holds operators, lessees and other regulated parties accountable for complying with the documents incorporated by reference in our regulations. We currently incorporate by reference over 100 consensus standards VerDate Sep<11>2014 16:22 Jun 12, 2015 Jkt 235001 in BSEE's regulations governing offshore oil and gas operations (see 30 CFR 250.198). Federal regulations at 1 CFR part 51 govern how BSEE and other Federal agencies incorporate various documents by reference. Agencies may only incorporate a document by reference by publishing the document title, edition, date, author, publisher, identification number, and other specified information in the Federal Register. The Director of the Federal Register must approve each publication incorporated by reference in a final rule. Incorporation by reference of a document or publication is limited to the specific edition approved by the Director of the Federal Register. When a copyrighted industry standard is incorporated by reference into our regulations, BSEE is obligated to observe and protect that copyright. We provide members of the public with Web site addresses where these standards may be accessed for viewing--sometimes for free and sometimes for a fee. The decision to charge a fee is made by each standards development organization. API provides free online public access to at least 160 technical and other key industry standards. Those standards represent almost one-third of all API standards and include all that are safety-related or are incorporated into Federal regulations. These standards are available for review online, while hard copies and printable versions will continue to be available for purchase through API. To review such standards online, go to the API publications Web site at: http://publications.api.org. You must then log-in or create a new account, accept API's ''Terms and Conditions,'' click on the ''Browse Documents'' button, and then select the applicable category (e.g., ''Exploration and Production'') for the standard(s) you wish to review. For the convenience of the viewing public who may not wish to purchase or view the incorporated documents online, they may be inspected at BSEE's office at 45600 Woodland Road, Sterling, Virginia 20166 (phone: 703- 787-1587). Documents incorporated in the final rule will be made available to the public for viewing when requested. Additional information on where these documents can be inspected or purchased can be found at 30 CFR 250.198, Documents incorporated by reference. Background Information for Proposed Incorporation by Reference of Seventh Edition of API Spec. 2C As authorized by OCSLA, BSEE has promulgated regulations governing oil, PO 00000 Frm 00035 Fmt 4702 Sfmt 4702 gas and sulphur exploration, development, and production operations on the OCS (30 CFR part 250). On February 14, 2003, the Minerals Management Service (MMS), the predecessor to BSEE, incorporated the Fifth Edition of API Spec. 2C, ''Specification for Offshore Cranes'' (1995), into its regulations at ?? 250.108(c) and (d) and ? 250.198(e), effective March 17, 2003 (68 FR 7421).1 The purpose of that rule was to require lessees and operators to ensure the safe design, construction, and testing of all cranes mounted on any fixed platform that was installed on the OCS after the effective date of the final rule (March 17, 2003) and of all cranes manufactured after March 17, 2003, and subsequently mounted on any fixed platform (without regard to the platform's installation date on the OCS). On March 15, 2007, the MMS incorporated the Sixth Edition of API Spec. 2C (adopted by API in 2004) into the regulations at ?? 250.108(c) and (d) and ? 250.198(e) in place of the Fifth Edition (72 FR 12088).2 Thus, the regulations currently require that operators and lessees ensure that all cranes mounted on any fixed platform that was installed on the OCS after March 2003, as well as all cranes manufactured after March 2003 and subsequently mounted on any fixed platform (regardless of when the platform was installed on the OCS), meet the requirements of the Sixth Edition of API Spec. 2C. In March 2012, API approved the Seventh Edition of API Spec. 2C (effective in October 2012), reorganizing the standard and providing improved design and construction criteria for new pedestal-mounted cranes (i.e., those manufactured after October 2012). The most significant technical and engineering issues addressed by API in the Seventh Edition of API Spec. 2C include: --Gross overload of cranes and supply boat entanglement issues (i.e., while the Sixth Edition did not require manufacturers to address gross overload conditions, the Seventh Edition requires that manufacturers use a failure mode assessment to address gross overload conditions, such as supply boat entanglement, and provide the failure mode results to crane purchasers); 1 MMS proposed this regulation on July 19, 2001 (see 66 FR 37611). 2 On April 28, 2010, MMS revised and reorganized ? 250.198, and the provision incorporating API Spec. 2C, Sixth Edition, was moved to ? 250.198(h)(69) (see 75 FR 22219). E:\FR\FM\15JNP1.SGM 15JNP1 asabaliauskas on DSK5VPTVN1PROD with PROPOSALS Federal Register / Vol. 80, No. 114 / Monday, June 15, 2015 / Proposed Rules --Consideration of duty cycles in service life design 3 (e.g., while the Sixth Edition did not specifically address duty cycles in the design of cranes, the Seventh Edition expressly includes consideration of duty cycles, or the magnitude of loads and/or frequency of use, in the design life of machinery and wire rope components of cranes); --Wire rope design factors (e.g., while the Sixth Edition included a fixed factor for design of running rigging, the Seventh Edition includes specific reeving efficiency calculations in running rigging design); and --Structural crane design factors for all types of offshore pedestal-mounted cranes (e.g., while the Sixth Edition used a fixed minimum onboard dynamic coefficient, the Seventh Edition uses a more precise sliding minimum onboard dynamic coefficient based on each crane's safe working load). --Dual braking systems (while the Sixth Edition required only parking brake systems for crane hoist systems, the Seventh Edition requires that cranes have both ''parking brake systems'' (i.e., disk or mechanical brakes that act directly on the wire rope drum) and ''dynamic brake systems'' (e.g., brakes that use control fluid from a drive motor) for hoisting operations (i.e., raising or lowering loads)). --Load moment indicator systems (i.e., the Seventh Edition adds a new provision--for intermediate, drilling and construction duty cranes-- requiring load moment indicator systems that sense load and lifting conditions when the crane is in use, compare those conditions to the crane's rated capacity, and alert the operator when the crane approaches an overload condition (e.g., the overturning moment)). --Personnel capacity and Safe Working Load (SWL) calculations (i.e., the Seventh Edition provides more precise methods for calculating the SWL, and increases the capacity for safely hoisting personnel from 35 percent, under the Sixth Edition, to 50 percent of the SWL). In addition, section 4 (''Documentation'') of the Seventh Edition of API Spec. 2C requires purchasers to supply certain information to manufacturers prior to purchasing a crane--and manufacturers to supply certain documentation to the 3 Offshore cranes can experience significantly different intensity and frequency of use depending on many factors, including the location of the platform and the environmental conditions under which the cranes will be used. VerDate Sep<11>2014 16:22 Jun 12, 2015 Jkt 235001 purchaser--in order to ensure that cranes are designed and manufactured, in compliance with the Seventh Edition, to perform safely and properly under the conditions in which the cranes are expected to be used. Discussion of Proposed Amendments BSEE has reviewed the Seventh Edition of API Spec. 2C and determined that the revised edition should be incorporated into the regulations to ensure that lessees and operators are complying with the latest consensus industry practices and standards for cranes. If the Seventh Edition is incorporated into BSEE's regulations, it will require the use of up-to-date industry standard technology, processes, and design criteria to ensure that fixed platform operators mount cranes designed to operate safely in difficult offshore conditions. For example, the failure mode calculations and gross overload protection provisions in the Seventh Edition of API Spec. 2C would help reduce the potential risk of injury to personnel by, among other things: --Addressing the possibility of supply boat entanglement; --Improving crane operator safety in the event of an unbounded gross overload (e.g., supply boat entanglement) without increasing the risk to other personnel from the crane dropping its load; and --Using a higher factor of safety for the pedestal/slew bearing to ensure that the main crane structure and operator cabin remain attached to the platform during a catastrophic event. Similarly, the Seventh Edition's provision for dual braking systems would improve hoisting efficiency and decrease stress on the crane motor and, thus, help prevent both unintended load drops and motor malfunctions. In addition, the Load Moment Indicator System provision would improve safety by alerting the operator (e.g., with bells, warning lights, buzzers) when a crane is approaching a critical overload condition, giving the operator a better chance to prevent the crane from overturning or causing other safety problems. Likewise, the Seventh Edition's improved method for calculating a crane's SWL justifies increasing the personnel capacity to 50 percent of the SWL, which, in turn, should reduce both the number of hoists needed to safely move the same number of people (as compared to the Sixth Edition) and the cumulative risk inherent in multiple hoists. Therefore, BSEE is proposing to amend ?? 250.108 and 250.198(h)(69) to PO 00000 Frm 00036 Fmt 4702 Sfmt 4702 34115 incorporate, and to require that lessees and operators ensure compliance with, the Seventh Edition of API Spec. 2C for all cranes mounted after the effective date of the final rule on any fixed OCS platform without regard to when the platform was installed on the OCS. Unlike the current regulations, compliance with the Seventh Edition of API Spec. 2C would not be tied to the date of manufacture of the crane or the date that the fixed platform was installed on the OCS. The original promulgation of ? 250.108(c) and (d) in 2003 marked the first time that MMS required lessees and operators to ensure that the cranes on fixed platforms complied with the criteria of the version of API Spec. 2C then in effect (i.e., the Fifth Edition). Accordingly, MMS initially made ? 250.108(c) and (d) applicable only to cranes that were manufactured after the effective date of that final rule (March 17, 2003) and then mounted on any fixed platform (regardless of the platform's installation date), as well as to all cranes (regardless of their manufacture dates) mounted on any fixed platform that was installed on the OCS after March 17, 2003. Thus, lessees and operators could become familiar with, and plan for compliance with, the new regulatory requirement before mounting new cranes or installing new platforms. In 2007, when MMS amended ?? 250.108(c) and (d) and 250.198 to require compliance with the Sixth Edition of API Spec. 2C in lieu of the Fifth Edition, MMS retained the original threshold applicability date (March 17, 2003) in ? 250.108 for manufacture of cranes and for installation of platforms. There was no need at that time to change the threshold date because the criteria for design and manufacture of cranes in the Sixth Edition were very similar to those in the Fifth Edition, which had been in effect under ? 250.108 since March 2003. By contrast, the Seventh Edition of API Spec. 2C makes significant changes to the criteria in the Sixth Edition. These changes will result in improvements, as previously described, to safety and personnel protection on fixed platforms. Cranes that meet the specifications of the Sixth Edition may not necessarily meet all of the specifications of the Seventh Edition and would not necessarily achieve the same level of safety afforded by cranes that meet the specifications of the Seventh Edition. In light of those changes, and the fact that the industry has been required to comply with prior editions of API Spec. 2C for over 10 years, the original March 2003 threshold applicability date is no E:\FR\FM\15JNP1.SGM 15JNP1 34116 Federal Register / Vol. 80, No. 114 / Monday, June 15, 2015 / Proposed Rules longer necessary or appropriate. Thus, we propose that operators and lessees ensure that all cranes that they mount on any fixed OCS platforms after the effective date of the new final rule comply with the criteria in the Seventh Edition of API Spec. 2C, without regard to the fixed platforms' installation dates or the cranes' manufacture dates. Because crane manufacturers and offshore lessees and operators have been familiar with, and voluntarily using, the Seventh Edition of API Spec. 2C since October 2012, this proposed requirement should not require significant changes in lessees' and operators' ordinary business practices. Moreover, the proposed rule would effectively eliminate a potential anomaly in the existing rules that arguably could be read to imply that cranes manufactured before March 2003 may continue to be mounted on platforms that were installed on the OCS before March 2003 without complying with any version of API Spec. 2C. We also propose, in accordance with ? 250.108(c) and (d) of the current regulations, to allow lessees and operators to continue to use cranes that comply with the Sixth Edition of API Spec. 2C if they mount (or mounted) a crane on a fixed platform between March 17, 2003, and the effective date of the new final rule and: asabaliauskas on DSK5VPTVN1PROD with PROPOSALS --The fixed platform was installed on the OCS between March 17, 2003, and the effective date of the final regulation; or --the crane was manufactured after March 17, 2003, and before the effective date of the final rule. However, because the Seventh Edition of API Spec. 2C has been in voluntary use by the industry since October 2012, we propose to amend ? 250.108 to give lessees and operators the option of ensuring that any cranes mounted after October 2012 and before the effective date of the new final rule comply with the Seventh Edition of API Spec. 2C in lieu of the Sixth Edition. Currently, ? 250.198(c) allows a lessee or operator to comply with a later edition of any incorporated standard, provided that the lessee or operator shows that the later edition is at least as protective as the incorporated standard and obtains prior written approval from BSEE. The proposed amendment to allow compliance with either the Sixth or Seventh Edition for cranes mounted between October 2012 and the effective date of the new final rule would simply eliminate the need for such a showing and for prior BSEE approval. VerDate Sep<11>2014 16:22 Jun 12, 2015 Jkt 235001 Finally, we propose to add a new definition to ? 250.105 for ''fixed platform,'' solely as used in ? 250.108. The Sixth Edition of API Spec. 2C used and defined the term ''fixed platform'' in virtually the same way as that term is currently defined in API Recommended Practice 2D, ''Operation and Maintenance of Offshore Cranes'' (Sixth Edition, May 2007) (API RP 2D), which is incorporated by reference in ? 250.108(a). However, the Seventh Edition of API Spec. 2C largely replaced the term ''fixed platform'' with the term ''bottom-supported structure,'' which is defined in a way very similar to the definition of ''fixed platform'' in the Sixth Edition of API Spec. 2C. In fact, the Seventh Edition of API Spec. 2C frequently uses the terms ''bottomsupported structure'' and ''fixed platform'' interchangeably. To avoid confusion, however, we propose to add to ? 250.105 a definition of ''fixed platform,'' as used in ? 250.108, that is consistent with the definition of ''bottom-supported structure'' in the Seventh Edition of API Spec. 2C, as well as with the definition of ''fixed platform'' in API RP 2D. In addition, the proposed new definition would be compatible with the definition of ''fixed platform'' in API RP 2A-WSD, ''Recommended Practice for Planning, Designing, and Constructing Fixed Offshore Platforms--Working Stress Design'' (Twenty-first Edition, reaffirmed October 2010) and with the definition of OCS ''facility'' in 30 CFR 250.105. Consistency With United States Coast Guard (USCG) Proposed Rule On May 13, 2013, the USCG proposed to incorporate the Seventh Edition of API Spec. 2C into USCG regulations at 46 CFR parts 107 through 109 for cranes installed on mobile offshore drilling units (MODUs), offshore supply vessels (OSVs), and floating OCS facilities (see 78 FR 27913). Because this BSEEproposed rule would apply only to cranes mounted on offshore fixed platforms--which, as defined in proposed ? 250.105, do not include MODUs, OSVs, or floating OCS facilities--there is no duplication between the USCG proposal and this proposed rule. Similarly, the USCGproposed rule would not duplicate or conflict with the current BSEE requirements at ? 250.108 because the existing BSEE requirements apply only to fixed platforms. In any case, the USCG proposal is essentially consistent with our proposed rule in that USCG would require offshore cranes used for OCS activities, and mounted after the effective date of USCG's final rule, to PO 00000 Frm 00037 Fmt 4702 Sfmt 4702 comply with the Seventh Edition of API Spec. 2C.4 In fact, USCG intends that its proposed rule align with BSEE's requirements for cranes used on offshore fixed platforms (see 78 FR 27914).5 The USCG proposal would also incorporate, and require compliance with, the Sixth Edition of API RP 2D for operation and maintenance of cranes on MODUs, OSVs, and floating OCS facilities in 46 CFR parts 107-109 (see 78 FR 27915). The existing BSEE regulations, at ?? 250.108(a) and 250.198(h)(48), already require that lessees and operators operate cranes on fixed platforms in accordance with the Sixth Edition of API RP 2D. We are aware, however, that API published a Seventh Edition of RP 2D in December 2014. We will evaluate that revised standard and consider whether it should be incorporated by reference in ? 250.108(a) at a later date. Request for Comments on Quality Control In addition to proposing to require lessees and operators to ensure that the cranes on their fixed platforms comply with the Seventh Edition of API Spec. 2C, we are considering whether there are ways to verify that new cranes have been fabricated pursuant to that API standard. For example, we are considering whether lessees and operators should ensure that cranes mounted on their fixed platforms in the future are constructed and marked in accordance with a quality management system such as API Specification Q1, ''Specification for Quality Programs for the Petroleum, Petrochemical and Natural Gas Industry,'' Ninth Edition (2014) (API Spec. Q1). Accordingly, we request comments on whether API Spec. Q1, or any similar quality management systems (such as those found in the International Standards Organization 9000 collection of standards), could help to ensure the overall reliability and safety of cranes. 4 The USCG also proposed to provide an option for compliance with ''other equivalent standard[s] identified by [the] Commandant'' in lieu of compliance with the Seventh Edition of API Spec. 2C (78 FR 27924). The existing BSEE regulations also provide a process for seeking BSEE's approval to use alternate procedures or equipment under appropriate conditions (see 30 CFR 250.141). 5 Although the Seventh Edition of API Spec. 2C has no size limitations on its applicability to cranes, USCG proposes to apply that standard (as well as the Sixth Edition of API RP 2D) only to cranes with a lifting capacity of 10,000 pounds or more (see 78 FR 27915.) There is no such size threshold in BSEE's current regulations at 30 CFR 250.108, and we do not propose to create one. In fact, ? 250.108 is intended to include smaller cranes used for material handling purposes on fixed platforms. E:\FR\FM\15JNP1.SGM 15JNP1 Federal Register / Vol. 80, No. 114 / Monday, June 15, 2015 / Proposed Rules Procedural Matters asabaliauskas on DSK5VPTVN1PROD with PROPOSALS Regulatory Planning and Review (Executive Orders 12866 and 13563) Executive Order 12866 (E.O. 12866) provides that the Office of Management and Budget (OMB), Office of Information and Regulatory Affairs (OIRA), will review all significant rules. BSEE has determined that this proposed rule is not a significant regulatory action as defined by section 3(f) of E.O. 12866 because: --It is not expected to have an annual effect on the economy of $100 million or more; --It would not adversely affect in a material way the economy, productivity, competition, jobs, the environment, public health or safety, or State, local, or tribal governments or communities; --It would not create a serious inconsistency or otherwise interfere with an action taken or planned by another agency; --It would not alter the budgetary impact of entitlements, grants, user fees, or loan programs, or the rights or obligations of their recipients; and --It does not raise novel legal or policy issues arising out of legal mandates, the President's priorities, or the principles set forth in E.O. 12866. In particular, BSEE has determined that this proposed rule would not have a significant economic effect on the offshore oil and gas industry because BSEE includes existing industry standards in the baselines for economic analyses for regulations. OMB Circular A-4, which provides guidance to Federal agencies on the preparation of economic analyses under E.O. 12866, states that the economic baseline represents the agency's best assessment of what the world would be like absent the action. Thus, the baseline should include all practices that already exist, and that would continue to exist, even if the new regulations were never imposed. Since consensus industry standards represent generally accepted industry practices and expectations for use in operations, and are developed and written by industry experts and approved by the industry itself, we understand and expect that industry follows such standards (or similar best practices) to ensure safety and reliability of operations. Therefore, BSEE includes relevant existing standards in the baseline when considering the potential economic impacts of its regulatory actions. Accordingly, because this proposed rule would simply incorporate the Seventh Edition of API Spec. 2C, VerDate Sep<11>2014 16:22 Jun 12, 2015 Jkt 235001 which has been in effect since October 2012, BSEE has not prepared an economic analysis for, and OIRA has not reviewed, this proposed rule. Executive Order 13563 (E.O. 13563) reaffirms the principles of E.O. 12866 while calling for improvements in the nation's regulatory system to promote predictability, to reduce uncertainty, and to use the best, most innovative, and least burdensome tools for achieving regulatory ends. In addition, E.O. 13563 directs agencies to consider regulatory approaches that reduce burdens and maintain flexibility and freedom of choice for the public where these approaches are relevant, feasible, and consistent with regulatory objectives. It also emphasizes that regulations must be based on the best available science and that the rulemaking process must allow for public participation and an open exchange of ideas. We developed this proposed rule in a manner consistent with these requirements. Regulatory Flexibility Act BSEE certifies that this proposed rule would not have a significant economic effect on a substantial number of small entities under the Regulatory Flexibility Act (5 U.S.C. 601 et seq.). The changes that would be incorporated by this proposed rule could affect lessees and operators of leases on the OCS who install new fixed platforms or new cranes on existing fixed platforms. This could include about 130 active companies. Offshore lessees and operators fall under the Small Business Administration's North American Industry Classification System (NAICS) codes 211111 (Crude Petroleum and Natural Gas Extraction) and 213111 (Drilling Oil and Gas Wells). For these NAICS code classifications, a small company is one with fewer than 500 employees. Based on these criteria, an estimated 90 (or 69 percent) of the active lessee/operator companies are considered small. Thus, this proposed rule would affect a substantial number of small entities. However, because the proposed rule simply incorporates an existing standard that has been adopted and followed by industry voluntarily since 2012, it would not impose significant new costs or burdens on the offshore oil and gas industry. Accordingly, the changes in the proposed rule would not have a significant economic effect on a substantial number of small entities, and BSEE is not required by the Regulatory Flexibility Act to prepare an initial regulatory flexibility analysis for this proposed rule. PO 00000 Frm 00038 Fmt 4702 Sfmt 4702 34117 Your comments are important. The Small Business and Agriculture Regulatory Enforcement Ombudsman and 10 Regional Fairness Boards were established to receive comments from small businesses about Federal agency enforcement actions. The Ombudsman will annually evaluate the enforcement activities and rate each agency's responsiveness to small business. If you wish to comment on the actions of BSEE, call 1-888-734-3247. You may comment to the Small Business Administration (SBA) without fear of retaliation. Allegations of discrimination/retaliation filed with the SBA will be investigated for appropriate action. Small Business Regulatory Enforcement Fairness Act This proposed rule is not a major rule under the Small Business Regulatory Enforcement Fairness Act (5 U.S.C. 801 et seq.). This proposed rule would not: --Have an annual effect on the economy of $100 million or more; --Cause a major increase in costs or prices for consumers, individual industries, Federal, State, or local government agencies, or geographic regions; or --Have significant adverse effects on competition, employment, investment, productivity, innovation, or the ability of U.S.-based enterprises to compete with foreign-based enterprises. Unfunded Mandates Reform Act of 1995 This proposed rule would not impose an unfunded mandate on State, local, or tribal governments or the private sector of more than $100 million per year. This proposed rule would not have a significant or unique effect on State, local, or tribal governments or the private sector. Thus, a statement containing the information required by the Unfunded Mandates Reform Act of 1995 (2 U.S.C. 1501, et seq.) is not required. Takings Implication Assessment (Executive Order 12630) Under the criteria in Executive Order 12630, this proposed rule would not have significant takings implications. This proposed rule is not a governmental action capable of interference with constitutionally protected property rights. Thus, a Takings Implication Assessment is not required. Federalism (Executive Order 13132) Under the criteria in Executive Order 13132, this proposed rule would not E:\FR\FM\15JNP1.SGM 15JNP1 34118 Federal Register / Vol. 80, No. 114 / Monday, June 15, 2015 / Proposed Rules have federalism implications. This proposed rule would not substantially and directly affect the relationship between the Federal and State governments. To the extent that State and local governments have a role in OCS activities, this proposed rule would not affect that role. Accordingly, a Federalism Assessment is not required. Civil Justice Reform (Executive Order 12988) This proposed rule complies with the requirements of Executive Order 12988 (E.O. 12988). Specifically, this rule: --Would meet the criteria of section 3(a) of E.O. 12988 requiring that all proposed regulations be reviewed to eliminate drafting errors and ambiguity, be written to minimize litigation, and provide clear legal standards; and --Would meet the criteria of section 3(b)(2) of E.O. 12988 requiring that all regulations be written in clear language and contain clear legal standards. Consultation With Indian Tribes (Executive Order 13175) We have evaluated this proposed rule under the Department's tribal consultation policy and under the criteria in Executive Order 13175 and have determined that it would have no substantial effects on federally recognized Indian tribes and that consultation under the department's policy is not required. asabaliauskas on DSK5VPTVN1PROD with PROPOSALS Paperwork Reduction Act of 1995 (PRA) BSEE has determined that this proposed regulation does not contain new information collection requirements pursuant to the PRA (44 U.S.C. 3501 et seq.). Thus, we will not submit an information collection request to OMB. National Environmental Policy Act of 1969 (NEPA) This proposed rule meets the criteria set forth in 516 Departmental Manual (DM) 15.4C(1) for a categorical exclusion because it involves modification of existing regulations, the impacts of which would be limited to administrative, economic, or technological effects with minimal environmental impacts. We also analyzed this proposed rule to determine if it meets any of the extraordinary circumstances set forth in 43 CFR 46.215, that would require an environmental assessment or an environmental impact statement for actions otherwise eligible for a categorical exclusion. We concluded VerDate Sep<11>2014 16:22 Jun 12, 2015 Jkt 235001 that this rule does not meet any of the criteria for extraordinary circumstances. Data Quality Act Dated: June 7, 2015. Janice M. Schneider, Assistant Secretary, Land and Minerals Management. In developing this proposed rule, we did not conduct or use a study, experiment, or survey requiring peer review under the Data Quality Act (Pub. L. 106-554, App. C sec. 515, 114 Stat. 2763, 2763A-153-154). For the reasons stated in the preamble, the Bureau of Safety and Environmental Enforcement (BSEE) proposes to amend 30 CFR part 250 as follows: Effects on the Nation's Energy Supply (Executive Order 13211) PART 250--OIL AND GAS AND SULPHUR OPERATIONS IN THE OUTER CONTINENTAL SHELF This proposed rule would not be a significant energy action under Executive Order 13211 because: --It is not a significant regulatory action under E.O. 12866; --It is not likely to have a significant adverse effect on the supply, distribution or use of energy; and --It has not been designated as a significant energy action by the Administrator of OIRA. Thus, a Statement of Energy Effects is not required. Clarity of This Regulation (Executive Orders 12866 and 12988) We are required by Executive Orders 12866 and 12988, and by the Presidential Memorandum of June 1, 1998, to write all rules in plain language. This means that each rulemaking we publish must: --Be logically organized; --Use the active voice to address readers directly; --Use clear language rather than jargon; --Be divided into short sections and sentences; and --Use lists and tables wherever possible. If you feel that we have not met these requirements, send us comments by one of the methods listed in the ADDRESSES section. To better help us revise the rule, your comments should be as specific as possible. For example, you should tell us the numbers of the sections or paragraphs that you find unclear, which sections or sentences are too long, and the sections where you feel lists or tables would be useful. List of Subjects in 30 CFR Part 250 Continental shelf, Environmental impact statements, Environmental protection, Government contracts, Incorporation by reference, Investigations, Mineral royalties, Oil and gas development and production, Oil and gas exploration, Oil and gas reserves, Penalties, Pipelines, Reporting and recordkeeping requirements, Sulphur development and production, Sulphur exploration. PO 00000 Frm 00039 Fmt 4702 Sfmt 4702 1. The authority citation for part 250 continues to read as follows: ? Authority: 30 U.S.C. 1751, 31 U.S.C. 9701, 43 U.S.C. 1334. 2. Amend ? 250.105 by adding, in alphabetical order, a definition of ''Fixed platform,'' to read as follows: ? ? 250.105 Definitions. * * * * * Fixed platform, as used in 30 CFR 250.108, means a bottom-supported stationary structure extending above the ocean surface, without significant movement in response to waves or currents in normal operating conditions, and installed for the purpose of exploration, development, or production of oil, gas or sulphur on the OCS. Examples of a fixed platform include gravity-based or jacket-and-pile supported platforms, jackup rigs (once in position and bottom-supported), and submersible bottom-supported rigs. * * * * * ? 3. Amend ? 250.108 as follows: ? a. Revise paragraphs (c) and (d); ? b. Redesignate paragraphs (e) and (f) as paragraphs (f) and (g), respectively; and ? c. Add new paragraph (e). The revisions and additions read as follows: ? 250.108 What requirements must I follow for cranes and other material-handling equipment? * * * * * (c) If you installed a fixed platform after March 17, 2003, and before [EFFECTIVE DATE OF THE FINAL RULE]: (1) All cranes mounted on the fixed platform on or after March 17, 2003, and before October 1, 2012, must meet the requirements of American Petroleum Institute Specification for Offshore Pedestal-mounted Cranes (API Spec. 2C), Sixth Edition (2004), as incorporated by reference in ? 250.198(h)(69)(i); and (2) All cranes mounted on the fixed platform on or after October 1, 2012, and before [EFFECTIVE DATE OF FINAL RULE], must meet either the E:\FR\FM\15JNP1.SGM 15JNP1 Federal Register / Vol. 80, No. 114 / Monday, June 15, 2015 / Proposed Rules requirements of API Spec. 2C, Sixth Edition, or API Spec. 2C, Seventh Edition (2012), as incorporated by reference in ? 250.198(h)(69)(ii). (d) If you installed a fixed platform before March 17, 2003, and mounted a crane on the fixed platform before [EFFECTIVE DATE OF FINAL RULE], and (1) The crane was manufactured after March 17, 2003, and before October 1, 2012, the crane must meet the requirements of API Spec. 2C, Sixth Edition; (2) The crane was manufactured on or after October 1, 2012, the crane must meet either the requirements of API Spec. 2C, Sixth Edition, or API Spec. 2C, Seventh Edition. (e) If you mount a crane on a fixed platform after [EFFECTIVE DATE OF FINAL RULE], the crane must meet the requirements of API Spec. 2C, Seventh Edition. * * * * * ? 4. Amend ? 250.198 by revising paragraph (h)(69) to read as follows: ? 250.198 Documents incorporated by reference. * * * * * (h) * * * (69) API Spec. 2C, Specification for Offshore Pedestal-mounted Cranes: (i) Sixth Edition, March 2004, Effective Date: September 2004, API Stock No. G02C06; incorporated by reference at ? 250.108(c) and (d); (ii) Seventh Edition, March 2012, Effective Date: October 2012, API Product No. G02C07; incorporated by reference at ? 250.108(c), (d) and (e); * * * * * [FR Doc. 2015-14640 Filed 6-12-15; 8:45 am] BILLING CODE 4310-VH-P FEDERAL COMMUNICATIONS COMMISSION 47 CFR Parts 1, 2, 90, 95, and 96 [GN Docket No. 12-354; FCC 15-47] Commission Seeks Comment on Shared Commercial Operations in the 3550-3700 MHz Band Federal Communications Commission. ACTION: Proposed rule. asabaliauskas on DSK5VPTVN1PROD with PROPOSALS AGENCY: In this document, the Commission seeks comment on three specific issues related to the establishment of a new Citizens Broadband Radio Service in the 3550- 3700 MHz band (3.5 GHz Band). These issues are: Defining ''use'' of Priority SUMMARY: VerDate Sep<11>2014 16:22 Jun 12, 2015 Jkt 235001 Access License frequencies; implementing secondary markets in Priority Access Licenses; and optimizing protections for Fixed Satellite Services. DATES: Submit comments on or before July 15, 2015 and reply comments on or before August 14, 2015. ADDRESSES: You may submit comments, identified by GN Docket No. 12-354, by any of the following methods: o Federal Communications Commission's Web site: http:// fjallfoss.fcc.gov/ecfs2/. Follow the instructions for submitting comments. o Mail: All hand-delivered or messenger-delivered paper filings for the Commission's Secretary must be delivered to FCC Headquarters at 445 12th St. SW., Room TW-A325, Washington, DC 20554. The filing hours are 8:00 a.m. to 7:00 p.m. All hand deliveries must be held together with rubber bands or fasteners. Any envelopes and boxes must be disposed of before entering the building. Commercial overnight mail (other than U.S. Postal Service Express Mail and Priority Mail) must be sent to 9300 East Hampton Drive, Capitol Heights, MD 20743. U.S. Postal Service first-class, Express, and Priority mail must be addressed to 445 12th Street SW., Washington DC 20554. o People with Disabilities: Contact the FCC to request reasonable accommodations (accessible format documents, sign language interpreters, CART, etc.) by email: FCC504@fcc.gov or phone: 202-418-0530 or TTY: 202- 418-0432. For detailed instructions for submitting comments and additional information on the rulemaking process, see the SUPPLEMENTARY INFORMATION section of this document. FOR FURTHER INFORMATION CONTACT: Paul Powell, Attorney Advisor, Wireless Bureau--Mobility Division at (202) 418- 1613 or Paul.Powell@fcc.gov. SUPPLEMENTARY INFORMATION: This is a summary of the Commission's Second Further Notice of Proposed Rulemaking in GN Docket No. 12-354, FCC 15-47, adopted on April 17, 2015 and released April 21, 2015. The full text of this document is available for inspection and copying during normal business hours in the FCC Reference Center, 445 12th Street SW., Washington, DC 20554. The full text may also be downloaded at: www.fcc.gov. Alternative formats are available to persons with disabilities by sending an email to fcc504@fcc.gov or by calling the Consumer & Governmental Affairs Bureau at 202- 418-0530 (voice), 202-418-0432 (tty). PO 00000 Frm 00040 Fmt 4702 Sfmt 4702 34119 Comment Filing Instructions Pursuant to ?? 1.415 and 1.419 of the Commission's rules, 47 CFR 1.415 and 1.419, interested parties may file comments and reply comments on or before the dates indicated on the first page of this document. Comments may be filed using the Commission's Electronic Comment Filing System (ECFS). See Electronic Filing of Documents in Rulemaking Proceedings, 63 FR 24121, May 1, 1998. o Electronic Filers: Comments may be filed electronically using the Internet by accessing the ECFS: http:// fjallfoss.fcc.gov/ecfs2/. o Paper Filers: Parties who choose to file by paper must file an original and one copy of each filing. If more than one docket or rulemaking number appears in the caption of this proceeding, filers must submit two additional copies for each additional docket or rulemaking number. Filings can be sent by hand or messenger delivery, by commercial overnight courier, or by first-class or overnight U.S. Postal Service mail. All filings must be addressed to the Commission's Secretary, Office of the Secretary, Federal Communications Commission. o All hand-delivered or messengerdelivered paper filings for the Commission's Secretary must be delivered to FCC Headquarters at 445 12th St. SW., Room TW-A325, Washington, DC 20554. The filing hours are 8:00 a.m. to 7:00 p.m. All hand deliveries must be held together with rubber bands or fasteners. Any envelopes and boxes must be disposed of before entering the building. o Commercial overnight mail (other than U.S. Postal Service Express Mail and Priority Mail) must be sent to 9300 East Hampton Drive, Capitol Heights, MD 20743. o U.S. Postal Service first-class, Express, and Priority mail must be addressed to 445 12th Street SW., Washington DC 20554. People with Disabilities: To request materials in accessible formats for people with disabilities (braille, large print, electronic files, audio format), send an email to fcc504@fcc.gov or call the Consumer & Governmental Affairs Bureau at 202-418-0530 (voice), 202- 418-0432 (tty). Ex Parte Rules This proceeding shall continue to be treated as a ''permit-but-disclose'' proceeding in accordance with the Commission's ex parte rules. See 47 CFR 1.1200 et seq. Persons making ex parte presentations must file a copy of E:\FR\FM\15JNP1.SGM 15JNP1 Q FIRDWOOD ENMY G. M. McCarroll Presiderrt and Chief Executive Officer Direct: 713-969-1015 E-Mail: MattM@firellc.coin July 15, 2015 Department of the Interior (DOI); Bureau of Safety and Environmental Enforcement Attention: Regulations and Standards Branch 45600 Woodland Road, Mail Code VAE-ORP Sterling, Virginia 20166 Re: Proposed Rule - Oil and Gas and Sulphur Opei•ations in the Outer Continental Shelf — Update of Cranes Standard Docket ID: BSEE-2014-0002-0001 RIN: 1014-AA13 Federal Register: 2015-14640 Dear Director Salemo: Fieldwood Energy LLC ("Fieldwood") appreciates the opportunity to comment on the Notice of Proposed Rule Making regarding the incorporation of crane standard API RP 2C seventh edition into 30 CFR Part 250. As you know, Fieldwood is the biggest operator on the Shelf. Fieldwood produces approximately 100,000 boepd net production, owns an interest in 650 OCS blocks covering approximately 2 million net acres, and operates over 600 platforms. Fieldwood's operations are large, with approximately 700 employees, 2,500 offshore personnel, and 390 separate vendor/contractors supporting daily operations. On average during 2014, Fieldwood employed 4 drilling rigs, 8 lift boats, 22 helicopters, and 74 marine vessels to support daily operations. Fieldwood maintains 6-8 P&A spreads and 8-10 construction projects tluoughout the year. Fieldwood cui7•ently maintains an inventory of 447 cranes. Fieldwood's impact to the Gulf Coast regional economy is huge, with thousands, if not tens of thousands, of individual taxpayers either directly or indirectly contributing to Fieldwood's operations by way of equipment, supplies, and logistical support. With limited exceptions as noted below, Fieldwood supports the incorporation of the seventh edition of the API RP 2C into regulation. We agree that new and peirnanently mounted cranes should be manufactured to meet the new design criteria as required in the seventh edition on new platform installations. However, as written, the proposed rule requires that "any" or "all" cranes mounted on a fixed platform after the effective date of the final rule must meet the requirements of API RP Spec 2C, Seventh Edition. This implies that rental and temporary cranes would have to meet the new specifications and does not take into account that the majority of these cranes were manufactured prior to 2003, are currently in service, and are in compliance with the current API RP 2D requirements. The seventh edition of API RP 2D Temporary Crane Installations, Section 9.4.3 states; "since they are not permanent cranes, their fitness for purpose are more specifically identified in the task they are mobilized to address." It is important to note that API RP 2D 6 t" edition and the new 7th edition both include sections for temporary crane installations. These requirements are clearly written to allow for temporary cranes to be installed handling specific "temporary" work in a safe manner. Following these requirements has proven to be effective and safe over the years. Fieldwood believes that the installation and use of temporary cranes is adequately addressed by the existing rules, as set forth in API RP 2D. If the intention of the proposed API RP 2C is to regulate the installation and use of ternporary crane installations, this will cause an immediate and severe shortage of temporary cranes and would greatly impact Fieldwood's ability to timely plug and abandon wells and decommission platforms, and also would hinder our ability to conduct normal maintenance and repair of our existing platforms. Fieldwood believes that the final rule should apply only to new cranes installed on new permanent installations after the effective date of the final rule. In addition, and as indicated in our opening remarks, Fieldwood currently maintains an inventory of approximately 447 cranes on its existing platforms and other structures. In many instances, these cranes are placed on platforms that were installed on the OCS before March 17, 2003. Many of these cranes are installed on small unmanned platforms with very limited usage and loading exposure. In its normal course of operations, Fieldwood may need to temporarily remove an existing crane to be repaired or refurbished in an effort to maintain the crane in safe operational status. As this proposed rule is written, it appears that cranes dismounted and sent in for refurbishment after the effective date will have to meet the API RP 2C seventh edition when remounted on the facility. In most instances, cranes designed to older specifications cannot be retrofitted to meet the new design criteria thereby rendering the crane obsolete. Replacement of these older cranes in use will result in a substantial economic and operational impact to facilities with marginal production. In the event it is uneconomic to replace the crane, operators will be forced to shut in production which, in turn, will result in a reduction in production revenues and royalties paid to the govermnent, Fieldwood therefore urges the DOI to consider the ramifications of imposing a"one size fits all" criteria for all cranes in use after the effective time of the final rule and instead either limit the application of the rule to new cranes permanently installed on facilities after the effective time or grant exceptions for exiting cranes in use that may be temporarily removed from a facility for repairs and refurbishing. Fieldwood shares the Agency's desire to improve the safety of oil and gas operations on the OCS, including safe crane operations. As you are aware, the majority of lifting incidents are often attributed to crane operator error, lack of maintenance, or rigging failure. Actual crane failure is seldom the root cause of lifting incidents. Fieldwood maintains a large fleet of cranes and has installed many temporary cranes on our platforms. The majority of our cranes are placed on platforms that were installed prior to 2003. In comparison to the industry as a whole, Fieldwood's lifting incidents per installation for 2014 was .005 versus .08 for the industry (BSEE 2014 Annual Report). This illustrates that current design criteria for existing and temporary crane installations are effective to maintain safe operations. 2 Therefore, we respectfully request that BSEE re-evaluate the proposed rule language as written with regard to temporary crane installations on facilities located on the OCS as well as to cranes that are temporarily removed and later reinstalled following repair and refurbishment. We appreciate the opportunity to participate in the rulemaking process, and I welcome you to contact me at (713) 969-1015 or at mattm&fwellc.com if I can be of further assistance with these proposed rule changes or any other matter concerning our operations in the Gulf. Sincerely, Aoaz Fieldwood Energy LLC G. M. McCarroll President and Chief Exe er 3 July 15, 2015 U.S. Department of the Interior, Bureau of Safety & Environmental Enforcement Office of the Director 1849 C Street NW, Mail Stop DE5438 Washington, DC 20240 ATTN: Director Brian Salerno Re: Docket No. BSEE-2014-0002: Oil and Gas and Sulphur Operations in the Outer Continental Shelf: Incorporated Cranes Standard – Scope and Impact Comments Via electronic submission to: http://www.regulations.gov/ Director Salerno: Offshore Operators Committee (OOC) appreciates the opportunity to comment on the Notice of Proposed Rule Making (NPRM) addressing updated offshore crane standards. OOC is an organization of some 138 producing and service companies who conduct essentially all of the OCS oil and gas exploration and production activities in the Gulf of Mexico (GOM). Comments made on behalf of OOC are submitted without prejudice to any member's right to have or express different or opposing views. At this time the majority of our members are actively reviewing the Blowout Preventer Systems and Well Control proposed rule whose comment deadline is July 16, 2015. Because the BOP and Well Control rule represents one of the most substantial rulemakings in the history of the BSEE, our members have not had the opportunity to fully review the updated regulations regarding offshore cranes and the applicability of the new standards on existing cranes. A preliminary review of the proposed rule indicated that the propose rule may significantly impact offshore crane operations. In light of the recent questions posted to the docket regarding maintenance and repair of existing cranes and the potential impact to cranes that are purposed-built for temporary installation (not mounted to a structural pedestal), industry is concerned if the scope and application of the new standard adversely affects the safe operation of approximately 2000 cranes still in operation on the Outer Continental Shelf. Unintended consequences of this proposed rulemaking could be significant, thus thoughtful consideration of the application of the new standard to these existing cranes is needed to help ensure the intent of the regulation is achieved. The OOC requests a joint BSEE / OOC detailed review of the proposed regulation if the scope is intended to extend to existing and temporary cranes offshore. LOUISIANA OFFICE One Lakeway-3900 N. Causeway, Blvd., Suite 700, Metairie, Louisiana 70002 (504) 934-2159 Office / (504) 455-0868 Fax TEXAS OFFICE 10777 Westheimer Rd., Suite 700 Houston, Texas 77042 (713) 589-6710 Office / (504) 455-0868 Fax The industry is committed to safe crane operations and supports effective regulations that will improve the performance of offshore crane operations. Should you wish to discuss further or have questions, please feel free to contact me at 713-589-6710. If you have any questions on the comments provided or the reference studies, please feel free to contact me. Respectfully submitted, Evan H. Zimmerman Executive Director Offshore Operators Committee c.c.: Mr. Lars Herbst, BSEE GOMR Mr. Doug Morris, BSEE LOUISIANA OFFICE One Lakeway-3900 Causeway, Blvd., Suite 700, Metairie, Louisiana 70002 (504) 934-2159 Office / (504) 455-0868 Fax TEXAS OFFICE 10777 Westheimer Rd., Suite 700 Houston, Texas 77042 (713) 589-6710 Office / (504) 455-0868 emit-1. nr 39151 and um: ET Ad ministratien Dance bf and REEULATCIET AFFAIRS. U.S.General i tltt- ReginfD.QDV Search: '3 Agenda I Fteg Review I IEH Information Cellectien Review FAQs I Reseurces Contact Us Heme Unified Agendal Regulatery Revlew View Rule 1li'ieil'i ED 12855 Meetings Printer-Friendly 1Ii'ersien Dawnidad Ftihl Data in Jltl'illL DDUESEE Hill: ?I??ld?AA?i Pu blicaticn Fall Elli? T'rtle: Incerperatien efLIpdates deSrane Standards Abstract: In June the Bureau efSafety and Enuirenmental Enfercement tc incerpdrate by reference the Seventh Editicn efthe American F'etreleum nstitute"s Specificatien "Eiffshere F'edestal-Meunted Cranes" Spec inte SSEE regulatidns. This standard was rewritten by te preside mere detailed specificatipns fer design and manufacture pfpedestaI-mpunted cranes in address their intended use. The final rule will allpw SSEE tp reference the best and mast up- te?date requirements ferthe safe design and censtructien dfpedestaI?mdunted cranes fer Uuter Sentinental Shelf Agency: Department pfthe Pripri'ty: Substantive. Hensignificant Rll'i Status: F'reyicusly published in the LinierdAgenda Agenda Stage c-f Eulemalting: Final Ftule Stage Maien Ne Unfunded Mandates: Ne ED 13T'i'1 Designatidn: Net subjectte. net signi?cant EFR 25D LegalAuthdrity: SEI USE. 13?51 31 USS. Sfii?i ea Legal Deadline: Ncne Timetable: Action Date FR Cite ?iiesrii ineneraeis gee Fe sens seem Ccmment Peried End amass" gFi-nal Acticn 'g'ngi'unani Regulatpry Flexibility Analysis Required: Np Epyernment Levels Affected: Hpne Federalism: hie included in the Regulath Plan: Np Rift URL: regulatiensgeu [enter Public Comment liFtL: regulatiensgeu (enter Hit-i [i-ata Printed in the FR: Ne Agen cy Centa ct: Lalreisha Harrispn Chief, Regulatidns and Standards Branch Department pfthe Interipr Eiureau pfSafety and Enuirenmental Read. SterlingyA SENSE Email: Ialreishaharrispn@bsee.gpy UNITED STATES DEPARTMENT OF THE INTERIOR BUREAU OF SAFETY AND ENVIRONMENTAL ENFORCEMENT GULF OF MEXICO REGION ACCIDENT INVESTIGATION REPORT For Public Release 1. OCCURRED DATE: 03-MAY-2016 TIME: 1620 HOURS 2. OPERATOR: Energy XXI GOM, LLC REPRESENTATIVE: TELEPHONE: CONTRACTOR: REPRESENTATIVE: TELEPHONE: 3. OPERATOR/CONTRACTOR REPRESENTATIVE/SUPERVISOR ON SITE AT TIME OF INCIDENT: 4. LEASE: AREA: BLOCK: G01083 WD 73 5. PLATFORM: RIG NAME: X LATITUDE: 28.9463 LONGITUDE: -89.7063 EXPLORATION(POE) DEVELOPMENT/PRODUCTION (DOCD/POD) 7. TYPE: HISTORIC INJURY REQUIRED EVACUATION LTA (1-3 days) LTA (>3 days RW/JT (1-3 days) RW/JT (>3 days) Other Injury X EQUIPMENT FAILURE X HUMAN ERROR EXTERNAL DAMAGE SLIP/TRIP/FALL WEATHER RELATED LEAK UPSET H2O TREATING OVERBOARD DRILLING FLUID OTHER 168 FT. 10. DISTANCE FROM SHORE: 17 MI. 11. WIND DIRECTION: NE HISTORIC BLOWOUT SPEED: 12 M.P.H. UNDERGROUND SURFACE 12. CURRENT DIRECTION: SE DEVERTER SPEED: M.P.H. SURFACE EQUIPMENT FAILURE OR PROCEDURES COLLISION MMS - FORM 2010 EV2010R 8. CAUSE: 9. WATER DEPTH: FATALITY POLLUTION FIRE EXPLOSION LWC 6. OPERATION: X PRODUCTION DRILLING WORKOVER COMPLETION HELICOPTER MOTOR VESSEL PIPELINE SEGMENT NO. OTHER D 6. ACTIVITY: STRUCTURAL DAMAGE X CRANE OTHER LIFTING DEVICE DAMAGED/DISABLED SAFETY SYS. INCIDENT >$25K H2S/15MIN./20PPM REQUIRED MUSTER SHUTDOWN FROM GAS RELEASE OTHER HISTORIC >$25K <=$25K 13. SEA STATE: FT. PAGE: 1 OF 17 04-OCT-2016 17. INVESTIGATION FINDINGS: For Public Release On 03-May-2016 at 1620 hrs at the West Delta (WD) 73-D, OCS-G 1083 Energy XXI Platform, a crane incident occurred while offloading the 4.75 ton rental diesel generator from the Motor Vessel (M/V) Jessica Faye crew change boat to the platform. During the lift, the sea state was observed to be choppy resulting in the M/V constantly moving back and forth during the operations. This incident resulted in shock loading the crane which damaged the crane boom cable. The boom cable is a mechanism responsible for raising and lowering the crane boom. At approximately 1600 hrs, the M/V Jessica Faye entered the Energy XXI WD 73 field. The M/V contacted the platform to inform them of heavy lifts of a 4.75 ton rental diesel generator and a 2 ton diesel tank skid along with crew change personnel. The Fab-Con Crane Operator (#1 CO) responded and started the Job Safety Analysis (JSA) and crane pre-use procedures. When the pre-use was performed on the WD 73-D crane (American Aero G-20F- Serial #87493), it was noted of no discrepancies found at the time of the pre-use inspection. The decision was made by the #1CO to offload the heavy equipment first utilizing the load block and the crew change personnel second utilizing the auxiliary line with personnel basket. While offloading the 4.75 ton rental diesel generator at approximately 1620 hrs from the M/V Jessica Faye with the WD 73-D platform crane, the generator contacted the diesel tank skid lifting it up approximately 5 ft off the M/V deck. The load suddenly released from the diesel tank skid, springing upward and shock loading the crane. The generator was then lifted from the M/V to the platform. The #1 CO then offloaded the personnel from the M/V not recognizing that the crane has just been shock loaded. The #1 CO was relieved of his crane duty by the Fab-Con Crane Operator (#2 CO) who made the final personnel lift along with the #1CO for crew change. The M/V Jessica Faye was released after crane operations were completed at approximately 1830 hrs. At approximately 1730 hrs, Island Operating A - Crew notified the Energy XXI Maintenance Foreman about the WD 73-D platform crane incident that transpired during crew change. The A Operator informed the Maintenance Foreman that the WD 73-D crane needed to be inspected due to the incident that transpired at 1420 hrs. After being informed of the incident, the Maintenance Foreman had the crane tagged out of service. On the day of the incident, Sparrows Offshore Services Ltd (Sparrows) Crane Mechanics were already in the area performing inspections and were scheduled to perform an annual inspection of the WD 73-D crane on 05-May-2016. On 04-May-2016 the Sparrows Crane Mechanics conducted a thorough inspection of the crane. The Mechanics noted that while performing a visual inspection of the boom wire rope condition, high strands were visible on the bottom layer. The Sparrows Crane Mechanics confirmed with the Maintenance Foreman that the crane had been shock loaded due to the incident. According to the crane inspection, Sparrows noted that the boom cable was badly crushed and needed to be replaced. BSEE Investigators arrived on 10-May-2016 to conduct an investigation of the crane incident. Statements, Job Safety Analysis (JSA), pictures and initial reports were obtained. The BSEE investigation revealed that the Fab-Con #1 CO failed to recognize the severity of the hazards that resulted in the shock loading of the crane. The shock loading resulted in damaging the crane. The Fab-Con #1 CO who was involved in the incident was then relieved of crane duty, and the Fab-Con #2 CO made the final personnel lift. Neither of Fab-Con’s Crane Operators recognized the hazards of shock loading the crane and continued to keep the crane in service while transferring personnel. At the time of the incident, no one used Stop Work Authority (SWA) when the 4.75 ton rental diesel generator contacted the diesel tank. MMS - FORM 2010 EV2010R PAGE: 2 OF 17 04-OCT-2016 For Public Release 1. Based on interviews conducted and documents reviewed of the crane incident investigation, it was discovered that during lifting operations, the Fab-Con #1 CO failed to recognize the hazards of heavy lifts associated with shock loading the crane. 2. Lessee failed to perform crane operating practices for attaching and moving the load being utilized in accordance with API RP 2D, paragraphs 3.2.1, 3.2.2 and 3.2.3 3. During the investigation, it was found that the relief Fab-Con #2 CO failed to perform a crane pre-use after the first qualified CO change-over during crane operations on 03-May-2106 in accordance with API RP 2D 4.1.2.2 4. Fab-Con #2 CO Offshore Crane Certification and Evaluations was expired during crane operations on 03-May-2016 in accordance with API RD 2D 6th edition and API specifications 2C crane certification was expired a total of 82 days before renewal. 5. The qualified CO and the designated signal person directing the lift, if utilized, should determine that: A. The load is secured and properly balanced in the appropriate sling or lifting device before it is lifted. B. The lift and swing paths are clear of obstructions and personnel. 6. The CO was not aware of the effects of the velocity and weight of the load to minimize shock loading. 7. The qualified rigger on the M/V Jessica Faye shouldn’t walk away without giving the appropriate hand signals to the CO on the platform during a critical lift. Signals between the CO and the designated signal person should be discernible, audibly or visually, at all times. The CO should not respond unless signals are clearly understood. The designated signal person should be in clear view of the CO to ensure that their signals may be seen. The Rigger position should have a clear view of the load, crane, personnel, and area of operation. If the Crane Operator’s view of the primary signal person is obstructed, a secondary signal person should be provided. 8.The probable cause of this incident was the lessee and the personnel engaged in this lifting operation failed to follow and adhere to safe rigging practices. Also, personnel failed to recognize hazards which could have prevented this incident from occurring. 9. Pre-use inspection API RP 2D 4.1.2.2 shall be performed and documented prior to the first crane use of the day and prior to or during each change in the Crane Operator. The second CO failed to perform a Pre-use inspection in accordance with API RP 2D 4.1.2.2 before operating the crane. 10. After reviewing the Energy XXI crane pre-use, there was no documentation of a second pre-use performed. MMS - FORM 2010 EV2010R PAGE: 3 OF 17 04-OCT-2016 For Public Release 18. LIST THE PROBABLE CAUSE(S) OF ACCIDENT: 1. Lessee failed to perform crane operating practices for attaching and moving the load being utilized in accordance with API RP 2D, paragraphs 3.2.1, 3.2.2 and 3.2.3 2. The Qualified CO and the designated signal person directing the lift, if utilized, should determine that: • The load is secured and properly balanced in the appropriate sling or lifting device before it is lifted. • The lift and swing paths are clear of obstructions and personnel. • The hook is brought over the load in such a manner as to minimize swinging. • The load, boom or other parts of the crane do not contact with obstructions. • The load is free to be lifted utilizing appropriate hand signals. • The Lessee and the personnel engaged in this lifting operation failed to follow and adhere to safe rigging practices. Also, the personnel failed to recognize hazards which could have prevented this incident from occurring. • The second CO failed to perform a pre-use inspection in accordance with API RP 2D 4.1.2.2 before operating the crane. 3. The #1 CO was relieved of his crane duty by the Fab-Con #2 CO who made the final personnel lift along with the #1 CO for crew change. 19. LIST THE CONTRIBUTING CAUSE(S) OF ACCIDENT: • No personnel at the time of the incident used Stop Work Authority (SWA) when the rental generator contacted the diesel tank and lifted it 5 ft before the load spring loaded. • Personnel were transferred after the crane was damaged. This could have elevated into a catastrophic event if the boom cable had parted. • The crew boat deck hand hooked the load and walked away without giving the CO hand signals. • SWA should have been initiated. • The CO did not stop the job and continued to lift the load. • A failure of communication between the crew boat personnel and the CO was the contributing factor in the crane incident. • When CO noticed the crew boat moving around due to choppy seas, SWA should have been initiated. 20. LIST THE ADDITIONAL INFORMATION: Obtained the following documents from Energy XXI: POB, JSEAs, witness statements, crane and rigging certifications, heavy lift operating procedures, Energy XXI HSE incident report, Sparrows thorough examination check sheet, daily safety meeting and operations review log, marine forecast, crane pre-use form, Sparrows quarterly inspection 06-Feb-2016, crane annual inspection 21-May-2016, Photos of crane cable in question, R&R Boats, Inc. cargo log sheet, Energy XXI manifest of generator and fuel tank, Sparrows latest annual crane inspection 06-May-2016. While reviewing the statements and documents, discrepancies were found on the weights of the cargo manifest #05032016 Rental generator 8000 lbs and the 560 gallon Diesel Fuel tank 4000 lbs. 1. The photo of the Rental diesel generator serial #4811 shows it to be 9200 lbs. 2. The manifest from the Energy XXI dock shows it to be 8000 lbs. 3. The statement from the CO shows he was informed to pick up a 9500 lbs load from the Jessica Faye. 4. During the Pre-use inspection before the quarterly inspection were to be performed MMS - FORM 2010 EV2010R PAGE: 4 OF 17 04-OCT-2016 For Public Release of the WD 73-D American Aero Crane dated 6-Feb-2016. The Sparrows Crane Mechanic noted in the inspection that the boom cable was found crushed badly and needed to be replaced. 21. PROPERTY DAMAGED: Boom Cable NATURE OF DAMAGE: Shock load 22. ESTIMATED RECOMMENDATIONS PREVENT RECURRANCE NARRATIVE: AMOUNT TO (TOTAL): BSEE New Orleans District makes no recomendations to the Office of Incident Investigations. 23. POSSIBLE OCS VIOLATIONS RELATED TO ACCIDENT: YES 24. SPECIFY VIOLATIONS DIRECTLY OR INDIRECTLY CONTRIBUTING. NARRATIVE: 1. G-132 - Lessee failed to notify the New Orleans District Office verbally immediate after the crane incident that occurred on 03-May-2016 as required in 30CFR 250.188 2. G-110 - During crane operations, the CO was lifting a 9500 pound rental generator. During the lift the generator contacted the diesel tank frame resulting in shock loading the crane cable. The CO made another lift picking up personnel from and to the crew boat not recognizing the hazards that has occurred shock loading and damaging the boom cable. After the fact during the Investigation additional INCs were issued. MMS - FORM 2010 EV2010R PAGE: 5 OF 17 04-OCT-2016 3. I-143 - During the investigation it was found that the relief CO failed to perform a crane pre-use after the first qualified CO change over during crane operations on 03-May-2016 in accordance with API RP 2D 4.1.2.2 4. I-182- Fab-con CO Offshore Crane Certification and Evaluations was expired during crane operations on 03-May-2016 in accordance with API RD 2D 6th edition and API specifications 2C. Crane certification was expired a total of 82 days before renewal.-Corrected action 21-June-2016 For Public Release 25. DATE OF ONSITE INVESTIGATION: 13-MAY-2016 26. ONSITE TEAM MEMBERS: Johnathan Fraser / Pierre Lanoix / 29. ACCIDENT INVESTIGATION PANEL FORMED: NO OCS REPORT: 30. DISTRICT SUPERVISOR: David Trocquet APPROVED DATE: 03-OCT-2016 INJURY/FATALITY/WITNESS ATTACHMENT X OPERATOR REPRESENTATIVE INJURY CONTRACTOR REPRESENTATIVE FATALITY X OTHER WITNESS NAME: HOME ADDRESS: Roustabout(18 Yrs)/Crane Operator(4 Yrs) CITY: WORK PHONE: STATE: TOTAL OFFSHORE EXPERIENCE: 22 YEARS EMPLOYED BY: BUSINESS ADDRESS: CITY: STATE: ZIP CODE: MMS - FORM 2010 EV2010R PAGE: 6 OF 17 04-OCT-2016 For Public Release INJURY/FATALITY/WITNESS ATTACHMENT X OPERATOR REPRESENTATIVE INJURY CONTRACTOR REPRESENTATIVE FATALITY X OTHER WITNESS NAME: HOME ADDRESS: Fab-con/Roustabout/ Rigger STATE: CITY: WORK PHONE: TOTAL OFFSHORE EXPERIENCE: 5.5 YEARS 8 YEARS EMPLOYED BY: BUSINESS ADDRESS: CITY: STATE: ZIP CODE: X OPERATOR REPRESENTATIVE INJURY CONTRACTOR REPRESENTATIVE FATALITY X OTHER WITNESS NAME: HOME ADDRESS: Compliance Tech STATE: CITY: WORK PHONE: EMPLOYED BY: ISLAND OPERATORS CO. INC. BUSINESS ADDRESS: 108 ZACHARY CITY: LAFAYETTE ZIP CODE: 70583 MMS - FORM 2010 EV2010R TOTAL OFFSHORE EXPERIENCE: / 20324 STATE: LA PAGE: 7 OF 17 04-OCT-2016 For Public Release INJURY/FATALITY/WITNESS ATTACHMENT X OPERATOR REPRESENTATIVE INJURY CONTRACTOR REPRESENTATIVE FATALITY X OTHER WITNESS NAME: HOME ADDRESS: Fab-con/ Crane Operator STATE: CITY: WORK PHONE: TOTAL OFFSHORE EXPERIENCE: 31 YEARS 8 YEARS EMPLOYED BY: BUSINESS ADDRESS: CITY: STATE: ZIP CODE: X OPERATOR REPRESENTATIVE INJURY CONTRACTOR REPRESENTATIVE FATALITY X OTHER NAME: WITNESS Operator HOME ADDRESS: STATE: CITY: WORK PHONE: EMPLOYED BY: TOTAL OFFSHORE EXPERIENCE: ISLAND OPERATORS CO. INC. BUSINESS ADDRESS: 108 ZACHARY CITY: LAFAYETTE ZIP CODE: 70583 / 20324 STATE: LA Crane/Other Material-Handling Equipment Attachment Equipment Information MMS - FORM 2010 EV2010R PAGE: 8 OF 17 04-OCT-2016 For Public Release Installation date: 03-MAY-16 Manufacturer: AMERICAN AERO Manufacture date: 03-MAY-16 Make/Model: G-20F / SERIAL 87493 Any modifications since manufactured? Describe and include date(s). What was the maximum lifting capacity at the time of the lift? Static: Dynamic: Was a tag line utilized during the lift? N Were there any known documented deficiencies prior to conducting the lift? If yes, what were the deficiencies? List specific type of failure that occured during this incident.(e.g. cable parted, sticking control valve, etc.) If sling/loose gear failure occurred does operator have a sling/loose gear inspection program in place? Y Type of lift: MD For crane only: Type of crane: MECHANICAL Boom angle at time of incident: Degrees: 60 Radius: 55 What was load limit at that angle? 0 Crane equipped with: B Which line was in use at time of incident? L If load line involved, what configuration is the load block: 4 MMS - FORM 2010 EV2010R part. PAGE: 9 OF 17 04-OCT-2016 For Public Release Load Information What was being lifted? Description of what was being lifted (e.g. 10 joints of 2 3/8-inch pipe, ten 500-lb. sacks of sand, 2 employees, etc.) 4.75 ton Rental Diesel Generator Approximate weight of load being lifted: 9500 Was crane/lifting device equipped with an operable weight indicator? Y Was the load identified with the correct or approximate weight? N Where was the lift started, where was it destined to finish, and at what point in the lift did the incident occur? Give specific details (e.g. pipe rack, riser cart, drill floor, etc.) The crane incident occurred while offloading the 4.75 ton Rental Diesel Generator from the Jessica Faye crew change boat to the platform resulting in shock loading the crane damaging the crane boom cable which is a critical component to the crane operations. Personnel was lifted after the shock load occurred. The crane operator did not recognize the hazards of shock loading the crane. If personnel was being lifted at the time of this incident, give specific details of lifting device and riding apparatus in use (e.g. 1) crane-personnel basket, 2) air hoist-boatswain chair, other) Were personnel wearing a safety harness? NA Was a lifeline available and utilized? NA List property lost overboard. NONE MMS - FORM 2010 EV2010R PAGE: 10 OF 17 04-OCT-2016 For Public Release Rigger/Operator Information Has rigger had rigger training? Y If yes, date of last training: 23-SEP-13 How many years of rigger experience did rigger have? 4 How many hours was the operator on duty prior to the incident? 10 Was operator on medication when incident occurred? N How many hours was the rigger on duty prior to the incident? 10 How much sleep did rigger have in the 24 hours preceding this incident? 8 Was rigger on medication when incident occurred? N Were all personnel involved in the lift drug tested immediately following this incident? Operator: N Rigger: N Other: NO While conducting the lift, was line of sight between operator and load ma N Does operator wear glasses or contact lenses? N If so, were glasses or contacts in use at time of the incident? Does operator wear a hearing aid? N N If so, was operator using hearing aid at time of the incident? N What type of communication system was being utilized between operator and rigger at time of this incident? RADIO/VHF For crane only: What crane training institution did crane operator attend? FALCK ALFORD Where was institution located? HOUMA LA Was operator qualified on this type of crane? Y MMS - FORM 2010 EV2010R PAGE: 11 OF 17 04-OCT-2016 For Public Release How much actual operational time did operator have on this particular crane involved in this incident? Years:4 Months 2 List recent crane operator training dates. 23-SEP-2013 For other material-handling equipment only: Has operator been trained to operate the lifting device involved in the incident? N How many years of experience did operator have operating the specific type of MMS - FORM 2010 EV2010R PAGE: 12 OF 17 04-OCT-2016 For Public Release Inspection/Maintenance Information For crane only: Is the crane involved classified as Heavy, Moderate or Infrequent use. M Was pre-use inspeciton conducted? Y For the annual/quarterly/monthly crane inspections, please fill out the following information: What was the date of the last inspection? 27-APR-16 Who performed the last inspection? (CRANE OPERATOR #1) Was inspection conducted in-house or by a 3rd party? Who qualified the inspector? TP (CRANE OPERATOR #1) Does operators' policy require load or pull test prior to heavy lift? Y Which type of test was conducted prior to heavy lift? P Date of last pull test: 06-MAY-16 Load test: 06-MAY-16 Results: P If fail explain why: Pull test 100% or less than the LRC load test Test Parameters: Boom angle: 70 Radius: 49 What was the date of most recent crane maintenance performed? 27-APR-16 Who performed crane maintenance? (Please clarify persons name or company name.) SPARROWS Was crane maintenance performed in-house or by a third party? TP What type of maintenance was performed? Annual Inspection MMS - FORM 2010 EV2010R PAGE: 13 OF 17 04-OCT-2016 For Public Release For other material-handling equipment only: Was equipment visually inspected before the lift took place? What is the manufacture's recommendation for performing periodic inspection on the equipment involved in this incident? MMS - FORM 2010 EV2010R PAGE: 14 OF 17 04-OCT-2016 For Public Release Safety Management Systems Does the company have a safety management program in place? N Does the company's safety management program address crane/other materialhandling equipment operations? N Provide any remarks you may have that applies to the company's safety management program and this incident? Did operator fill out a Job Safety Analysis (JSA) prior to job being performed? Y Did operator have an operational or safety meeting prior to job being performed? Y What precautions were taken by operator before conducting lift resulting in in Pre-use inspection and company policies Procedures in place for crane/other material-handling equipment activities: Did operator have procedures written? Y Did procedures cover the circumstances of this incident? Was a copy available for review prior to incident? Were procedures available to MMS upon request? Y Y Y Is it documented that operator's representative reviewed procedures before conducting lift? N Additional observations or concerns: The BSEE investigation revealed that the Fab-Con (#1CO) failed to recognize the severity of the hazards that resulted in the shock loading of the crane. The shock loading resulted in damaging the crane. The Fab-Con #1 CO who was involved in the incident was then relieved of crane duty, and the Fab-Con #2 Crane Operator made the final personnel lift. Neither Fab-Con’s Crane Operators recognized the hazards of shock loading the crane and continued to keep the crane in-service while transferring personnel. At the time of the incident, nobody used Stop Work Authority (SWA) when the 4.75 ton rental diesel generator contacted the diesel tank. MMS - FORM 2010 EV2010R PAGE: 15 OF 17 04-OCT-2016 For Public Release 1. Based on interviews conducted and documents reviewed of the crane incident investigation, it was discovered that during lifting operations, the Fab-Con #1 CO failed to recognize the hazards of heavy lifts associated with shock loading the crane. 2. Lessee failed to perform crane operating practices for attaching and moving the load being utilize in accordance with API RP 2D, paragraphs 3.2.1, 3.2.2 and 3.2.3 3. During the investigation it was found that the relief Fab-Con #2 CO failed to perform a crane pre-use after the first qualified CO change over during crane operations on May 3, 2106 in accordance with API RP 2D 4.1.2.2 4. Fab-Con #2 CO Offshore Crane Certification and Evaluations was expired during crane operations on May 3, 2016 in accordance with API RD 2D 6th edition and API specifications 2C crane certification was expired a total of 82 days before renewal. 5. The Qualified CO and the designated signal person directing the lift, if utilized, should determine that: A. The load is secured and properly balanced in the appropriate sling or lifting device before it is lifted. B. The lift and swing paths are clear of obstructions and personnel. 6. The CO was not aware of the effects of the velocity and weight of the load to minimize shock loading. 7. The qualified rigger on the M/V Jessica Faye shouldn’t walk away without giving the appropriated hand signals to the CO on the platform during a critical lift. Signals between the CO and the designated signal person should be discernible, audibly or visually, at all times. The CO should not respond unless signals are clearly understood. Be in clear view of the CO to ensure that their signals may be seen. The Rigger position should give a clear view of the load, crane, personnel, and area of operation. If the Crane Operator’s view of the primary signal person is obstructed, a secondary signal person should be provided. 8. The probable cause of this incident was the lessee and the personnel engaged in this lifting operation failed to follow and adhere to safe rigging practices. Also, personnel failed to recognize hazards which could have prevented this incident from occurring. MMS - FORM 2010 EV2010R PAGE: 16 OF 17 04-OCT-2016 For Public Release 9. Pre-use inspection API RP 2D 4.1.2.2 shall be performed and documented prior to the first crane use of the day, prior to or during each change in the Crane Operator. The second CO failed to perform a Pre-use inspection in accordance with API RP 2D 4.1.2.2 before operating the crane. 10. According to the Energy XXI Root Cause Analysis (RCA) the Fab-con #1 CO relief the Fab-con #2 CO, made the final lift of personnel onto the M/V Jessica Faye without performing a pre-use inspection. 11. After reviewing the Energy XXI crane pre-use, there was no documentation of a second pre-use performed. MMS - FORM 2010 EV2010R PAGE: 17 OF 17 04-OCT-2016 UNITED STATES DEPARTMENT OF THE INTERIOR BUREAU OF SAFETY AND ENVIRONMENTAL ENFORCEMENT GULF OF MEXICO REGION ACCIDENT INVESTIGATION REPORT For Public Release 1. OCCURRED DATE: 21-SEP-2016 TIME: 1915 HOURS 2. OPERATOR: Fieldwood SD Offshore LLC REPRESENTATIVE: TELEPHONE: CONTRACTOR: REPRESENTATIVE: TELEPHONE: 3. OPERATOR/CONTRACTOR REPRESENTATIVE/SUPERVISOR ON SITE AT TIME OF INCIDENT: 4. LEASE: AREA: BLOCK: G02650 EB 110 5. PLATFORM: RIG NAME: X LATITUDE: LONGITUDE: EXPLORATION(POE) DEVELOPMENT/PRODUCTION (DOCD/POD) 7. TYPE: HISTORIC INJURY REQUIRED EVACUATION LTA (1-3 days) LTA (>3 days RW/JT (1-3 days) RW/JT (>3 days) Other Injury EQUIPMENT FAILURE X HUMAN ERROR EXTERNAL DAMAGE SLIP/TRIP/FALL WEATHER RELATED LEAK UPSET H2O TREATING OVERBOARD DRILLING FLUID OTHER 660 FT. 10. DISTANCE FROM SHORE: 75 MI. 11. WIND DIRECTION: SSE HISTORIC BLOWOUT SPEED: 5 M.P.H. UNDERGROUND SURFACE 12. CURRENT DIRECTION: SSE DEVERTER SPEED: 3 M.P.H. SURFACE EQUIPMENT FAILURE OR PROCEDURES COLLISION MMS - FORM 2010 EV2010R 8. CAUSE: 9. WATER DEPTH: FATALITY POLLUTION FIRE EXPLOSION LWC 6. OPERATION: PRODUCTION DRILLING WORKOVER COMPLETION HELICOPTER MOTOR VESSEL PIPELINE SEGMENT NO. X OTHER Plug and Abandon Operations A-Tequila 6. ACTIVITY: STRUCTURAL DAMAGE X CRANE OTHER LIFTING DEVICE DAMAGED/DISABLED SAFETY SYS. X INCIDENT >$25K Crane failure H2S/15MIN./20PPM REQUIRED MUSTER SHUTDOWN FROM GAS RELEASE OTHER HISTORIC >$25K <=$25K 13. SEA STATE: 4 FT. PAGE: 1 OF 10 08-MAY-2017 17. INVESTIGATION FINDINGS: For Public Release On September 21, 2016, at approximately 19:15 hours, the crane crew was in the process of repositioning three Product Tanks(P-Tanks)on the deck of the Motor Vessel (MV) Candy Barrel. One tank had been sucessfully moved to the Port side of the boat. The second P-Tank was lifted and repositioned along side of and Starboard of the first P-Tank. Initially, the second P-Tank was placed on the deck with the legs touching the first tank which caused it to be sitting at an angle and not flat on the deck. The Crane Operator was instructed by a person on the platform to pick up on the tank and reposition it again. The Crane Operator picked the tank up and swung it to the left (port side) over the water, then back towards the boat. As the load was swinging Starboard, the Crane Operator stopped it over the first tank. The vertical movement of the boat caused the bottom tank to strike the suspended tank several times which caused the crane to be shock loaded. After the crane became shock loaded the wire rope parted, causing the suspended tank attached to the crane to fall on top of the tank below that was situated onto the deck of the MV Candy Barrel. As a result of the crane being shock loaded the boom buckled and fell onto the Gulf of Mexico. 1. Crane Operator did not know the boom radius at the time of the incident and may have allowed the boom to extend beyond the safe lifting radius of the crane. 2. Crane Operator failed to hoist the load to a safe level above the boat allowing the tank to contact equipment on the boat several times prior to the incident. 3. Crane Operator was receiving signals from multiple personnel both on the boat and the platform. 4. Crane was shock loaded causing the wire rope and boom to fail. 5. Crane Operator was new to the platform and had only operated the crane for the previous two weeks. 18. LIST THE PROBABLE CAUSE(S) OF ACCIDENT: 1. Crane Operator did not know the boom radius at the time of the incident and may have allowed the boom to extend beyond the safe lifting radius of the crane. 2. Crane Operator failed to hoist the load to a safe level above the boat allowing the tank to contact equipment on the boat several times prior to the incident. 3. Crane Operator was receiving signals from multiple personnel both on the boat and the platform. 4. Crane was shock loaded causing the wire rope and boom to fail. 19. LIST THE CONTRIBUTING CAUSE(S) OF ACCIDENT: 1. Crane Operator was new to the platform and had only operated the crane for the previous two weeks. 20. LIST THE ADDITIONAL INFORMATION: None 21. PROPERTY DAMAGED: MMS - FORM 2010 EV2010R NATURE OF DAMAGE: PAGE: 2 OF 10 08-MAY-2017 Crane Boom Wire Rope Fast ball and hook Pendant lines Supply Boat ESTIMATED AMOUNT (TOTAL): For Public Release Crane Boom Wire Rope Fast ball and hook Pendant lines Supply Boat $800,000 22. RECOMMENDATIONS TO PREVENT RECURRANCE NARRATIVE: Lake Jackson District has no recommendations at this time. 23. POSSIBLE OCS VIOLATIONS RELATED TO ACCIDENT: YES 24. SPECIFY VIOLATIONS DIRECTLY OR INDIRECTLY CONTRIBUTING. NARRATIVE: • Job Safety Analysis failed to identify this as a heavy lift. • Crane Operator was unaware of the boom radius of the crane at the time of the incident. • Crane Operator was receiving multiple signals from persons other than the Designated Signal Person. • Personnel failed to “Stop Work” when multiple signals where being utilized. • During the repositioning of the second P-tank, the crane was shock loaded resulting in the crane boom parting from the heel and falling into the Gulf of Mexico. 25. DATE OF ONSITE INVESTIGATION: 22-SEP-2016 26. ONSITE TEAM MEMBERS: Ed Keown / Daniel Gonzalez / David Kearns / James Holmes / 29. ACCIDENT INVESTIGATION PANEL FORMED: NO OCS REPORT: 30. DISTRICT SUPERVISOR: Stephen P. Martinez APPROVED DATE: 28-NOV-2016 Crane/Other Material-Handling Equipment Attachment Equipment Information Installation date: 01-JAN-84 Manufacturer: SEAKING Manufacture date: 01-DEC-83 Make/Model: 1400 / 1400 Any modifications since manufactured? Describe and include date(s). MMS - FORM 2010 EV2010R PAGE: 3 OF 10 08-MAY-2017 For Public Release What was the maximum lifting capacity at the time of the lift? Static: Dynamic: Was a tag line utilized during the lift? N Were there any known documented deficiencies prior to conducting the lift? If yes, what were the deficiencies? List specific type of failure that occured during this incident.(e.g. cable parted, sticking control valve, etc.) If sling/loose gear failure occurred does operator have a sling/loose gear inspection program in place? Type of lift: For crane only: Type of crane: HYDRAULIC Boom angle at time of incident: Degrees: 0 Radius: 0 What was load limit at that angle? 38400 Crane equipped with: L Which line was in use at time of incident? L If load line involved, what configuration is the load block: 4 MMS - FORM 2010 EV2010R part. PAGE: 4 OF 10 08-MAY-2017 For Public Release Load Information What was being lifted? Description of what was being lifted (e.g. 10 joints of 2 3/8-inch pipe, ten 500-lb. sacks of sand, 2 employees, etc.) 24000 lb Product Tank Approximate weight of load being lifted: 24000 Was crane/lifting device equipped with an operable weight indicator? Y Was the load identified with the correct or approximate weight? Y Where was the lift started, where was it destined to finish, and at what point in the lift did the incident occur? Give specific details (e.g. pipe rack, riser cart, drill floor, etc.) If personnel was being lifted at the time of this incident, give specific details of lifting device and riding apparatus in use (e.g. 1) crane-personnel basket, 2) air hoist-boatswain chair, other) Were personnel wearing a safety harness? Was a lifeline available and utilized? List property lost overboard. CRANE BOOM FAST LINE BALL AND HOOK PENDANT LINES WIRE ROPE MMS - FORM 2010 EV2010R PAGE: 5 OF 10 08-MAY-2017 For Public Release Rigger/Operator Information Has rigger had rigger training? Y If yes, date of last training: 12-JUL-13 How many years of rigger experience did rigger have? 12 How many hours was the operator on duty prior to the incident? 12 Was operator on medication when incident occurred? N How many hours was the rigger on duty prior to the incident? 12 How much sleep did rigger have in the 24 hours preceding this incident? 12 Was rigger on medication when incident occurred? N Were all personnel involved in the lift drug tested immediately following this incident? Operator: N Rigger: N Other: While conducting the lift, was line of sight between operator and load ma N Does operator wear glasses or contact lenses? N If so, were glasses or contacts in use at time of the incident? Does operator wear a hearing aid? N N If so, was operator using hearing aid at time of the incident? N What type of communication system was being utilized between operator and rigger at time of this incident? RADIO/VHF For crane only: What crane training institution did crane operator attend? SEAKING Where was institution located? LAFAYETTE Was operator qualified on this type of crane? Y MMS - FORM 2010 EV2010R PAGE: 6 OF 10 08-MAY-2017 For Public Release How much actual operational time did operator have on this particular crane involved in this incident? Years:5 Months 0 List recent crane operator training dates. 21-MAY-2016 For other material-handling equipment only: Has operator been trained to operate the lifting device involved in the incident? N How many years of experience did operator have operating the specific type of MMS - FORM 2010 EV2010R PAGE: 7 OF 10 08-MAY-2017 For Public Release Inspection/Maintenance Information For crane only: Is the crane involved classified as Heavy, Moderate or Infrequent use. H Was pre-use inspeciton conducted? Y For the annual/quarterly/monthly crane inspections, please fill out the following information: What was the date of the last inspection? 26-AUG-16 Who performed the last inspection? Was inspection conducted in-house or by a 3rd party? Who qualified the inspector? TP GULF CRANE Does operators' policy require load or pull test prior to heavy lift? N Which type of test was conducted prior to heavy lift? P Date of last pull test: 26-AUG-16 Load test: 04-AUG-16 Results: P If fail explain why: Test Parameters: Boom angle: 51 Radius: 60 What was the date of most recent crane maintenance performed? 04-AUG-16 Who performed crane maintenance? (Please clarify persons name or company name.) Was crane maintenance performed in-house or by a third party? TP What type of maintenance was performed? replaced hoses, fittings, counter balanced valve MMS - FORM 2010 EV2010R PAGE: 8 OF 10 08-MAY-2017 For Public Release For other material-handling equipment only: Was equipment visually inspected before the lift took place? What is the manufacture's recommendation for performing periodic inspection on the equipment involved in this incident? MMS - FORM 2010 EV2010R PAGE: 9 OF 10 08-MAY-2017 For Public Release Safety Management Systems Does the company have a safety management program in place? Does the company's safety management program address crane/other materialhandling equipment operations? Provide any remarks you may have that applies to the company's safety management program and this incident? Did operator fill out a Job Safety Analysis (JSA) prior to job being performed? Did operator have an operational or safety meeting prior to job being performed? What precautions were taken by operator before conducting lift resulting in in Procedures in place for crane/other material-handling equipment activities: Did operator have procedures written? Did procedures cover the circumstances of this incident? Was a copy available for review prior to incident? Were procedures available to MMS upon request? Is it documented that operator's representative reviewed procedures before conducting lift? Additional observations or concerns: MMS - FORM 2010 EV2010R PAGE: 10 OF 10 08-MAY-2017 UNITED STATES DEPARTMENT OF THE INTERIOR BUREAU OF SAFETY AND ENVIRONMENTAL ENFORCEMENT GULF OF MEXICO REGION ACCIDENT INVESTIGATION REPORT For Public Release 1. OCCURRED DATE: 27-JAN-2017 TIME: 0800 HOURS 2. OPERATOR: Energy XXI GOM, LLC REPRESENTATIVE: TELEPHONE: Fluid Crane and Construction CONTRACTOR: REPRESENTATIVE: TELEPHONE: 3. OPERATOR/CONTRACTOR REPRESENTATIVE/SUPERVISOR ON SITE AT TIME OF INCIDENT: 4. LEASE: AREA: BLOCK: G01619 SP 93 5. PLATFORM: RIG NAME: LATITUDE: 28.669635 LONGITUDE: -89.393492 B 6. ACTIVITY: X EXPLORATION(POE) DEVELOPMENT/PRODUCTION (DOCD/POD) 7. TYPE: HISTORIC INJURY 3 X REQUIRED EVACUATION LTA (1-3 days) LTA (>3 days 2 X RW/JT (1-3 days) RW/JT (>3 days) X Other Injury 1 First Aid PRODUCTION DRILLING WORKOVER COMPLETION HELICOPTER MOTOR VESSEL PIPELINE SEGMENT NO. X OTHER crane and boat operations 8. CAUSE: X EQUIPMENT FAILURE HUMAN ERROR EXTERNAL DAMAGE SLIP/TRIP/FALL WEATHER RELATED LEAK UPSET H2O TREATING OVERBOARD DRILLING FLUID OTHER 450 FT. 10. DISTANCE FROM SHORE: 17 MI. 11. WIND DIRECTION: N HISTORIC BLOWOUT SPEED: 31 M.P.H. UNDERGROUND SURFACE 12. CURRENT DIRECTION: NW DEVERTER SPEED: M.P.H. SURFACE EQUIPMENT FAILURE OR PROCEDURES COLLISION MMS - FORM 2010 EV2010R 6. OPERATION: 9. WATER DEPTH: FATALITY POLLUTION FIRE EXPLOSION LWC STRUCTURAL DAMAGE X CRANE OTHER LIFTING DEVICE DAMAGED/DISABLED SAFETY SYS. INCIDENT >$25K H2S/15MIN./20PPM REQUIRED MUSTER SHUTDOWN FROM GAS RELEASE OTHER HISTORIC >$25K <=$25K 13. SEA STATE: 6 FT. PAGE: 1 OF 12 05-SEP-2017 17. INVESTIGATION FINDINGS: For Public Release 1. Personnel transfer was being made from the back deck of the Motor Vessel (M/V) Patience Lab with the use of the four Man Billy Pugh Personnel Basket onto the South Pass (SP) 93 B Platform. The M/V Patience Lab is a 130 foot offshore support vessel with GPS steering control which maintained its position on the north side of the platform. 2. A sudden gust of wind caused the crane boom and the basket to swing just as the four riders stepped on to the basket causing it to lift and drag along the deck until it swung into the side of the boat railing/ bullwork. 3. The crane operator attempted to lock the swing brake, but it would not hold. He then attempted to raise the personnel basket, while swinging the boom in the opposite direction, so it would not hit the railing. But the basket hit in spite of his attempts. Three of the riders managed to jump off as the basket swung and hit the boat railing, while the fourth rider held on as it crashed into the bullwork and then lifted up over the railing and swung over and hit the platform. Personnel were able to get him off the basket about 15 minutes later after the vessel maneuvered under the basket and the crane operator lowered the basket back down onto the boat. 4. The crane was taken out of service immediately after the fourth rider was lowered back down onto the back deck of the M/V. The injured, as well as the entire construction crew on the boat, were sent in for medical evaluation. Three personnel were injured: one Industrial & Oilfield Services (IOS) Construction Consultant, one Fluid Crane Superintendent, and one Deckhand on the boat. 5. The BSEE investigation determined that the crane’s hydraulic swing gear motor (slew drive system) had failed. The mounting bolts that secured it to the cab base had backed out and resulted in a structural failure of the swing gear drive housing, which made the motor insecure and allowed it to ‘cock sideways’ when operated and prevented any control of swing movement. 6. A lieutenant with the USCG met the M/V Patience Lab at the Energy XXI Dock in Grand Isle on the day of the incident and gathered statements. 7. During the follow up BSEE investigation on 1/28/2017, while observing the crane preinspection procedures, the Investigator noticed the hydraulic swing gear motor moving as the operator attempted to swing the boom. The procedure was immediately stopped and under closer inspection, the securing bolts were detected as sheared or missing. 8. A later inspection by a Sparrows Crane Mechanics verified that the swing drive housing had a structural failure where the bolts mounted it to the crane body. 9. The Sparrows Crane Mechanics removed, rebuilt, reinstalled and tested the swing gear motor. 18. LIST THE PROBABLE CAUSE(S) OF ACCIDENT: 1. The condition of the mounting bolts being backed out of the slew drive system (hydraulic swing gear motor) went undetected. The condition of the bolts coming loose over a long period of time went without notice allowing the housing failure to occur. An inspection of the bolts is not part of the normal daily pre-use, quarterly, or annual inspection. To detect abnormal movement of the hydraulic motor requires two personnel, a crane operator and an observer, while in operation. 2. Without the hydraulic motor secured, due to the bolts backing out and subsequent failure of the motor housing, a misalignment with the gears was created. There was a complete lack of control of boom swing movement. The complete failure of the motor housing happened during the personnel lift. MMS - FORM 2010 EV2010R PAGE: 2 OF 12 05-SEP-2017 19. LIST THE CONTRIBUTING CAUSE(S) OF ACCIDENT: For Public Release 1. Sea conditions were three to five feet with an occasional six feet out of the North/ West. 2. Winds conditions were 22 to 27 kts. gusting out of the North. 3. The boom angle used during the lift made it susceptible to be affected by gusting winds. 4. Had the slew drive system failed not due to the bolts backing out, the contributing causes mentioned above would had not been a factor. Normal crane operations can be successful under these same weather conditions. 5. Third party crane inspection contractor had no written process addressing the swing gear housing bolts. 6. Not all bolts on the swing gear drive housing are easily accessible or visible due to the design. 20. LIST THE ADDITIONAL INFORMATION: 1. Immediately after the incident, the crane at SP 93 B was placed out of service. The M/V went to SP 93 A (15 miles away) to attempt to take personnel off at that location. However, it was determined that the weather conditions were not favorable to transfer personnel at that time. 2. The injuries sustained by personnel appeared to be non-life threatening, so the decision was made to send the M/V to the GI Shore Base 3-1/2 hrs away with the entire crew on board. 3. The extent of the injuries were: The deckhand only required first aid and returned to work the same day. The IOS Inspector went on days off and returned back to work after his 14 days off. Energy XXI classified this as Recordable Restrictive Work. The construction superintendent was released by the company doctor, but never returned to work. 4. The crane operator at SP 93 B as well as the deckhand are to be commended for their actions to prevent greater injuries to personnel once the slew drive system failed. 5. The platform crane at SP 93 B was a Titan, Model T5400B with 100 ft. boom. The basket was a 4-Man Billy Pugh. 6. The crane was safely returned to the platform boom rest without further incident. 7. Approval to put the crane back in service was requested and authorized by BSEE once the motor had been repaired, tested and met a punch list of requests by the BSEE Supervisor. 8. The last annual crane inspection prior to the incident was 2/16/2016. 9. The last quarterly inspection prior to the incident was 11/10/2016. 21. PROPERTY DAMAGED: NATURE OF DAMAGE: Crane Hydraulic Swing Gear Motor (slew Internal and External damages drive system) ESTIMATED AMOUNT (TOTAL): $12,314 MMS - FORM 2010 EV2010R PAGE: 3 OF 12 05-SEP-2017 For Public Release 22. RECOMMENDATIONS TO PREVENT RECURRANCE NARRATIVE: 1. The decision was made to repair and reinstall the current 4 bolt swing gear motor installation and then it was replaced with a 10 bolt pattern. Ensuring greater stability and security. 2. A Gulf wide alert was initiated by Energy XXI to ensure that no other platforms under their supervision would be susceptible to this type of incident. Revision of the annual and quarterly inspection process was incorporated with specific details questioning bolt types, torque values and condition of swing drive bolts, finalized 6/1/2017. 3. A Gulf wide alert provided industry wide by BSEE to ensure other companies are not susceptible to this similiar setup. 23. POSSIBLE OCS VIOLATIONS RELATED TO ACCIDENT: NO 24. SPECIFY VIOLATIONS DIRECTLY OR INDIRECTLY CONTRIBUTING. NARRATIVE: No INCs issued at this time 25. DATE OF ONSITE INVESTIGATION: 28. ACCIDENT CLASSIFICATION: MINOR 28-JAN-2017 29. ACCIDENT INVESTIGATION PANEL FORMED: NO 26. ONSITE TEAM MEMBERS: Gerald Taylor / OCS REPORT: 30. DISTRICT SUPERVISOR: David Trocquet 27. OPERATOR REPORT ON FILE: YES APPROVED DATE: 01-SEP-2017 UNITED STATES DEPARTMENT OF THE INTERIOR BUREAU OF SAFETY AND ENVIRONMENTAL ENFORCEMENT GULF OF MEXICO REGION ACCIDENT INVESTIGATION REPORT For Public Release 1. OCCURRED DATE: 07-APR-2017 TIME: 1500 HOURS 2. OPERATOR: LLOG Exploration Offshore, L.L.C. REPRESENTATIVE: TELEPHONE: Seadrill Limited CONTRACTOR: REPRESENTATIVE: TELEPHONE: 3. OPERATOR/CONTRACTOR REPRESENTATIVE/SUPERVISOR ON SITE AT TIME OF INCIDENT: 4. LEASE: AREA: BLOCK: G35662 GC 478 SEADRILL SEVAN LOUISIANA 6. ACTIVITY: X EXPLORATION(POE) DEVELOPMENT/PRODUCTION (DOCD/POD) 7. TYPE: HISTORIC INJURY REQUIRED EVACUATION LTA (1-3 days) LTA (>3 days RW/JT (1-3 days) RW/JT (>3 days) Other Injury 8. CAUSE: X EQUIPMENT FAILURE HUMAN ERROR EXTERNAL DAMAGE SLIP/TRIP/FALL WEATHER RELATED LEAK UPSET H2O TREATING OVERBOARD DRILLING FLUID OTHER 9. WATER DEPTH: FATALITY POLLUTION FIRE EXPLOSION LWC 6. OPERATION: PRODUCTION X DRILLING WORKOVER COMPLETION HELICOPTER MOTOR VESSEL PIPELINE SEGMENT NO. OTHER LATITUDE: LONGITUDE: 5. PLATFORM: RIG NAME: STRUCTURAL DAMAGE X CRANE OTHER LIFTING DEVICE DAMAGED/DISABLED SAFETY SYS. INCIDENT >$25K H2S/15MIN./20PPM REQUIRED MUSTER SHUTDOWN FROM GAS RELEASE OTHER 3801 FT. 10. DISTANCE FROM SHORE: 11. WIND DIRECTION: HISTORIC BLOWOUT SPEED: UNDERGROUND SURFACE 12. CURRENT DIRECTION: DEVERTER SPEED: SURFACE EQUIPMENT FAILURE OR PROCEDURES COLLISION HISTORIC >$25K <=$25K 13. SEA STATE: 112 MI. M.P.H. M.P.H. FT. 14. PICTURES TAKEN: 15. STATEMENT TAKEN: MMS - FORM 2010 EV2010R PAGE: 1 OF 3 28-JUN-2017 17. INVESTIGATION FINDINGS: For Public Release On April 7, 2017, on board the Seadrill Sevan Louisiana operating for LLOG Exploration in Green Canyon Block 478, a joint of 9 7/8”casing was dropped by the Pipe Deck Pipe Handler (PDPH) crane. The joint of 9 7/8” casing was being transferred from one pipe bay to another pipe bay. All personnel assigned for this job scope were standing in the safe zone and outside of the pipe bay area. There was no damage to equipment, and no injuries were reported. On the afternoon of the incident, the deck crew began transferring single joints of 9 7/8” casing from the aft pipe bay to the forward pipe bay using a PDPH knuckle boom crane. To initialize the casing gripper, the crane operator first selected the mode in the PDPH crane so that this particular size pipe could be picked up. The crane operator selected the pipe range of 7” to 10 ¾” and then activated the crane grippers from the open position to the closed position. An audible beeping tone acknowledged that the system was initialized and ready to proceed with picking up the casing. After lifting and transferring approximately 5 joints, the crane operator had to stop in order to reinitialize the casing setting. Re-initialization was necessary because the crane grippers would deactivate periodically. When transferring the first joint of casing after the re-initialization, the flagger noticed the casing joint was slipping out of the aft gripper. The casing slippage occurred during the first four feet of the lift and resulted in one end of the casing falling to the deck. This in turn jolted the opposite end of the casing free from the forward gripper, allowing it to also fall to the deck. The joint of casing came to rest on the wood-covered beams in the pipe bay. Bureau of Safety and Environmental Enforcement (BSEE) Inspectors conducted an onsite inspection/investigation on April 19, 2017, and collected documentation for this incident. The crane operator was also interviewed, and during questioning he could not clarify what “periodically” meant in relation to how often he had to reinitialize the PDPH. The investigation revealed that a hydraulic seal was leaking on the aft pipe adapter cylinder, which ultimately led to the dropped casing joint. The leaking seal allowed the pipe stop on the gripper to override its setting for picking up the selected size of casing, thereby deactivating the initial setting. Once the settings were deactivated, the crane operator had to reselect the appropriate size casing. Though this was a re-occurring issue, the crane operator did not question if the system was working properly or if the crane needed to be inspected. As hydraulic pressure was lost, the gripper slowly lost its closing pressure and eventually allowed the casing to slip out of the gripper. The crane’s gripper function has been removed from service until a full technical investigation is completed and repairs have been made. The contractor is currently working with the original equipment manufacturer to replace the automated pipe adapter system with a manual pin style system, which will reduce the likelihood of equipment failure by eliminating the possibility of leaking hydraulic seals. The manual pin system will also give visual confirmation of a positive latch onto the selected casing. 18. LIST THE PROBABLE CAUSE(S) OF ACCIDENT: - A leaking hydraulic seal on the aft pipe handler cylinder. MMS - FORM 2010 EV2010R PAGE: 2 OF 3 28-JUN-2017 For Public Release 19. LIST THE CONTRIBUTING CAUSE(S) OF ACCIDENT: - Lack of awareness. The crane operator did not identify an issue with having to continously re-initiate the casing settings. This continous re-initialization was evidence of a hydraulic leak that needed to be addressed. 20. LIST THE ADDITIONAL INFORMATION: 21. PROPERTY DAMAGED: N/A NATURE OF DAMAGE: N/A ESTIMATED AMOUNT (TOTAL): 22. RECOMMENDATIONS TO PREVENT RECURRANCE NARRATIVE: BSEE Houma District has no recommendations for the Office of Incident Investigations at this time. 23. POSSIBLE OCS VIOLATIONS RELATED TO ACCIDENT: NO 24. SPECIFY VIOLATIONS DIRECTLY OR INDIRECTLY CONTRIBUTING. NARRATIVE: 25. DATE OF ONSITE INVESTIGATION: 28. ACCIDENT CLASSIFICATION: 19-APR-2017 26. ONSITE TEAM MEMBERS: Gabe Orellana / Daniel Ballard / Paul Reeves / 29. ACCIDENT INVESTIGATION PANEL FORMED: NO OCS REPORT: 30. DISTRICT SUPERVISOR: Bryan Domangue 27. OPERATOR REPORT ON FILE: APPROVED DATE: MMS - FORM 2010 EV2010R 23-JUN-2017 PAGE: 3 OF 3 28-JUN-2017 UNITED STATES DEPARTMENT OF THE INTERIOR BUREAU OF SAFETY AND ENVIRONMENTAL ENFORCEMENT GULF OF MEXICO REGION ACCIDENT INVESTIGATION REPORT For Public Release 1. OCCURRED DATE: 11-APR-2017 TIME: 0710 HOURS 2. OPERATOR: Anadarko Petroleum Corporation REPRESENTATIVE: TELEPHONE: Diamond Offshore Drilling, Inc. CONTRACTOR: REPRESENTATIVE: TELEPHONE: 3. OPERATOR/CONTRACTOR REPRESENTATIVE/SUPERVISOR ON SITE AT TIME OF INCIDENT: 4. LEASE: AREA: BLOCK: G25174 GC 627 5. PLATFORM: RIG NAME: X LATITUDE: LONGITUDE: EXPLORATION(POE) DEVELOPMENT/PRODUCTION (DOCD/POD) 7. TYPE: HISTORIC INJURY REQUIRED EVACUATION LTA (1-3 days) LTA (>3 days RW/JT (1-3 days) RW/JT (>3 days) Other Injury X EQUIPMENT FAILURE HUMAN ERROR EXTERNAL DAMAGE SLIP/TRIP/FALL WEATHER RELATED LEAK UPSET H2O TREATING OVERBOARD DRILLING FLUID OTHER 4409 FT. 10. DISTANCE FROM SHORE: 11. WIND DIRECTION: HISTORIC BLOWOUT SPEED: UNDERGROUND SURFACE 12. CURRENT DIRECTION: DEVERTER SPEED: SURFACE EQUIPMENT FAILURE OR PROCEDURES COLLISION MMS - FORM 2010 EV2010R 8. CAUSE: 9. WATER DEPTH: FATALITY POLLUTION FIRE EXPLOSION LWC 6. OPERATION: PRODUCTION X DRILLING WORKOVER COMPLETION HELICOPTER MOTOR VESSEL PIPELINE SEGMENT NO. OTHER DIAMOND OCEAN BLACKHORNET 6. ACTIVITY: STRUCTURAL DAMAGE X CRANE OTHER LIFTING DEVICE DAMAGED/DISABLED SAFETY SYS. INCIDENT >$25K H2S/15MIN./20PPM REQUIRED MUSTER SHUTDOWN FROM GAS RELEASE OTHER HISTORIC >$25K <=$25K 13. SEA STATE: 137 MI. M.P.H. M.P.H. FT. PAGE: 1 OF 4 28-JUN-2017 17. INVESTIGATION FINDINGS: For Public Release On April 11, 2017, while picking up riser to begin Anadarko’s well 003 in Green Canyon Block 627, an incident occurred on board the Diamond Ocean Blackhornet in which the riser gantry crane (RGC) dropped a joint of riser approximately 19 feet in the riser bay. The riser bay had been barricaded to prevent personnel from entering the work area, and no personnel were injured as a result of this incident. On the morning of the incident, the deck crew was in the process of securing the 4th joint of riser in the riser bay with the RGC. The RGC operator lowered the RGC to the riser joint and commanded the crane hooks to capture it on both ends. The operator received a "Green Light" on his remote console, which indicated that it had properly secured the riser. When the operator began to lift the riser joint, the crane stopped moving and began to give a general alarm on the remote console. The RGC operator attempted to level the crane without success, so the operator stopped the operation and called for an Electronic Technician (ET) to troubleshoot the issue. The ET arrived to find the RGC remote console was not responding and proceeded to place the crane in override mode to level the riser joint. The RGC operator functioned the remote console, and then leveled the riser joint before switching out of override mode. Once the remote console was taken out of override mode, the operator attempted to lift the riser joint again but without success. The ET advised the operator that the remote console had to be powered down, and then powered back up to reboot the system. Once powered down, the aft crane hook lost hydraulics and released the riser joint which allowed it to fall, while the forward end of the riser joint slid off its hook. The riser joint fell approximately 15 feet, striking additional riser joints, and then fell an additional 4 feet to the bottom of the riser bay. Bureau of Safety and Environmental Enforcement (BSEE) Inspectors conducted an inspection / investigation on April 18, 2017 and collected documentation for the incident. It was determined that the riser capture mechanism should not have failed when the system was powered down. The system was designed so that the hydraulics of the system are too weak to open when there is a load on the RGC. The over-center mechanism locks the capture hooks when closed by a link arm which when under a load, exerts force against a mechanical stop/lock. This mechanical stop/lock prevents the hooks from opening while under a load, even if hydraulics are lost. The "Green Light" on the control panel indicated that the RGC had properly secured the riser joint, but in fact it had not. The investigation discovered that the proximity switch activated the "Green Light" without being properly centered and fully secured to the riser. If the riser had been properly secured by the RGC, the riser joint could not have been dropped when the RGC console was powered down. National Oilwell Varco (NOV) has issued a product information bulletin to give effected rigs guidance on how to inspect and correct the RGC riser capture device. The rig has since inspected the load holding valves on the forward and aft riser crane hooks. An adjustment has been made to the position of the hydraulic proximity switches to indicate when the crane hook locks are fully engaged as well as adding “Yoke Landed” criteria to the software to ensure that there is full capture of riser joint with the hooks. The Job Safety Analysis (JSA) and work procedure has been updated to require visual conformation that the forward and aft hooks are fully engaged prior to lifting the riser joint. MMS - FORM 2010 EV2010R PAGE: 2 OF 4 28-JUN-2017 For Public Release 18. LIST THE PROBABLE CAUSE(S) OF ACCIDENT: - Malfunction of the riser capture mechanism. - The proximity switch falsely sent the signal to the control console that the RGC had properly secured the riser by giving the "Green Light" signal. 19. LIST THE CONTRIBUTING CAUSE(S) OF ACCIDENT: - Lack of Awareness: The deck crew failed to notice that the Riser Gantry Crane hooks were not fully engaged in the locked position. 20. LIST THE ADDITIONAL INFORMATION: The RGC is manufactured by NOV, and it is an overhead crane which operates on parallel beams using the Riser Yoke (RY), which lifts the riser and keeps it clamped while delivering it to the Riser Elevation System. The RY uses two sets of lifting hooks, one on each end of the spacer, to pick up a riser joint from the riser bay and is operated by push buttons from the RGC remote console. The entire system is based upon synchronous movements of the gantry crane travel and hoisting. If the system sees unintended movement within certain values, it will shut down the RGC. If the control valve gets stuck or is manually operated (human error) at the wrong time, the system will deactivate and shut down all movements of the crane. There are three safety barriers built into the design of the riser capture device and controls to prevent loads from being dropped. 1) When a load is detected by the load cells, the software inhibits the opening of the riser capture devices. 2) An overcenter lock mechanism mechanically locks the capture fingers during lifts. 3) The hydraulics are set up to be too weak to open the capture finger during lifts. 21. PROPERTY DAMAGED: N/A NATURE OF DAMAGE: N/A ESTIMATED AMOUNT (TOTAL): 22. RECOMMENDATIONS TO PREVENT RECURRANCE NARRATIVE: BSEE Houma District has no recommendations to make to the Office of Incident Investigations at this time. 23. POSSIBLE OCS VIOLATIONS RELATED TO ACCIDENT: NO 24. SPECIFY VIOLATIONS DIRECTLY OR INDIRECTLY CONTRIBUTING. NARRATIVE: MMS - FORM 2010 EV2010R PAGE: 3 OF 4 28-JUN-2017 25. DATE OF ONSITE INVESTIGATION: For Public Release 18-APR-2017 26. ONSITE TEAM MEMBERS: Adriano Garcia / Robert Reeves / 29. ACCIDENT INVESTIGATION PANEL FORMED: NO OCS REPORT: 30. DISTRICT SUPERVISOR: Bryan Domangue APPROVED DATE: MMS - FORM 2010 EV2010R 19-JUN-2017 PAGE: 4 OF 4 28-JUN-2017 UNITED STATES DEPARTMENT OF THE INTERIOR BUREAU OF SAFETY AND ENVIRONMENTAL ENFORCEMENT GULF OF MEXICO REGION ACCIDENT INVESTIGATION REPORT For Public Release 1. OCCURRED DATE: 26-APR-2017 TIME: 0830 HOURS 2. OPERATOR: Fieldwood Energy LLC REPRESENTATIVE: TELEPHONE: CONTRACTOR: REPRESENTATIVE: TELEPHONE: 3. OPERATOR/CONTRACTOR REPRESENTATIVE/SUPERVISOR ON SITE AT TIME OF INCIDENT: 4. LEASE: AREA: BLOCK: G01757 BA A 105 5. PLATFORM: RIG NAME: X LATITUDE: LONGITUDE: EXPLORATION(POE) DEVELOPMENT/PRODUCTION (DOCD/POD) 7. TYPE: HISTORIC INJURY X REQUIRED EVACUATION LTA (1-3 days) X LTA (>3 days RW/JT (1-3 days) RW/JT (>3 days) Other Injury 1 1 EQUIPMENT FAILURE X HUMAN ERROR EXTERNAL DAMAGE SLIP/TRIP/FALL WEATHER RELATED LEAK UPSET H2O TREATING OVERBOARD DRILLING FLUID OTHER 188 FT. 10. DISTANCE FROM SHORE: 39 MI. 11. WIND DIRECTION: ESE HISTORIC BLOWOUT SPEED: 15 M.P.H. UNDERGROUND SURFACE 12. CURRENT DIRECTION: SE DEVERTER SPEED: 1 M.P.H. SURFACE EQUIPMENT FAILURE OR PROCEDURES COLLISION MMS - FORM 2010 EV2010R 8. CAUSE: 9. WATER DEPTH: FATALITY POLLUTION FIRE EXPLOSION LWC 6. OPERATION: X PRODUCTION DRILLING WORKOVER COMPLETION HELICOPTER MOTOR VESSEL PIPELINE SEGMENT NO. OTHER A 6. ACTIVITY: STRUCTURAL DAMAGE X CRANE OTHER LIFTING DEVICE DAMAGED/DISABLED SAFETY SYS. INCIDENT >$25K H2S/15MIN./20PPM REQUIRED MUSTER SHUTDOWN FROM GAS RELEASE OTHER HISTORIC >$25K <=$25K 13. SEA STATE: 7 FT. PAGE: 1 OF 3 05-JUN-2017 17. INVESTIGATION FINDINGS: For Public Release On 26 April 2017, Fieldwood Energy reported a crane incident that occurred at BAA 105A, Lease G01757, at approximately 0830 hours. It was reported that while offloading a 550 gallon diesel tote tank from the Motor Vessel (M/V) Miss Julie a Deckhand was injured. The Deckhand attached the crane’s stringer to a pre-slung, four part wire rope sling on the tote tank, stepped clear of the load, and then signaled to lift the load. The Deckhand then noticed that one leg of the four part wire rope sling was caught on a shackle. The Deckhand proceeded to move toward the tote tank without stopping the lifting action in an attempt to free the sling. The tote tank was lifted while one leg of the sling was caught up on the shackle. As the tote tank came off the deck it was unbalanced, swinging briefly, while pinning the Deckhand between the tote tank and starboard gunwale. The Deckhand was injured, falling to his hands and knees with pain to his right leg and chest. The Deckhand, Injured Person (IP), was kept onboard the Miss Julie and transported to BAA 133 where he was treated by the Field Medic. The Field Medic evaluated the IP, he was then littered to the helideck of BAA 133 and transported by a field helicopter to Christus Spohn Shoreline Hospital in Corpus Christi, Texas. IP was diagnosed with a fracture to his lower right leg and two fractured left ribs. IP underwent surgery to his right leg where a plate and screws were installed to set the fracture. Investigation revealed the four part sling was fabricated with approximately eleven foot legs (11'), normally the slings are fabricated with four foot legs (4') It was surmised that this length of sling may have contributed to the leg of sling wrapping around the shackle. The Job Safety Analysis (JSA) that was conducted for crane operations that day onto the M/V Miss Julie failed to have cooresponding dates throughout the entire JSA. IP approached the tote tank as it was ascending. After he gave the signal to begin the lift, he then placed his body in a pinch point between the tote tank and gunwale. IP entered the area after he had gave the signal to lift the load. IP failed to recognize the immediate hazard by not stopping the crane’s actions before entering the hazardous area. Sea state at the time of the incident was reported at 7 feet. 18. LIST THE PROBABLE CAUSE(S) OF ACCIDENT: IP entered the hazard area after he had gave the signal to lift the load. IP failed to recognize the immediate hazard by not stopping the crane’s actions before entering the hazardous area. 19. LIST THE CONTRIBUTING CAUSE(S) OF ACCIDENT: Investigation revealed the four part sling was fabricated with approximately eleven foot legs (11'), normally the slings are fabricated with four foot legs (4'). It was surmised that this length of sling may have contributed to the leg of sling wrapping around the shackle. Sea state at the time of the incident was reported at 7 foot. 20. LIST THE ADDITIONAL INFORMATION: MMS - FORM 2010 EV2010R PAGE: 2 OF 3 05-JUN-2017 For Public Release 21. PROPERTY DAMAGED: None NATURE OF DAMAGE: None ESTIMATED AMOUNT (TOTAL): 22. RECOMMENDATIONS TO PREVENT RECURRANCE NARRATIVE: The Lake Jackson District makes no recommendation to the Office of Incident Investigations. 23. POSSIBLE OCS VIOLATIONS RELATED TO ACCIDENT: YES 24. SPECIFY VIOLATIONS DIRECTLY OR INDIRECTLY CONTRIBUTING. NARRATIVE: G-110(C) IP entered the area after he had gave the signal to lift the load, IP failed to recognize the immediate hazard by not stopping the crane’s actions before entering the hazardous area. G-110(W) Investigation revealed the four part sling was fabricated with approximately eleven (11') foot legs, normally the slings are fabricated with four (4') foot legs, it was surmised that this length of sling may have contributed to the leg of sling wrapping around the shackle. G-110(W) The JSA that was completed for the Crane operations of off loading and back loading the M/V Julie failed to have corresponding dates through out the entire JSA. 25. DATE OF ONSITE INVESTIGATION: 26-APR-2017 26. ONSITE TEAM MEMBERS: Edward Keown / 29. ACCIDENT INVESTIGATION PANEL FORMED: NO OCS REPORT: 30. DISTRICT SUPERVISOR: John McCarroll APPROVED DATE: MMS - FORM 2010 EV2010R 25-MAY-2017 PAGE: 3 OF 3 05-JUN-2017 UNITED STATES DEPARTMENT OF THE INTERIOR BUREAU OF SAFETY AND ENVIRONMENTAL ENFORCEMENT GULF OF MEXICO REGION ACCIDENT INVESTIGATION REPORT For Public Release 1. OCCURRED DATE: 28-APR-2017 TIME: 1651 HOURS 2. OPERATOR: Arena Offshore, LP REPRESENTATIVE: TELEPHONE: CONTRACTOR: REPRESENTATIVE: TELEPHONE: 3. OPERATOR/CONTRACTOR REPRESENTATIVE/SUPERVISOR ON SITE AT TIME OF INCIDENT: 4. LEASE: AREA: BLOCK: G02118 EI 338 5. PLATFORM: RIG NAME: X LATITUDE: LONGITUDE: EXPLORATION(POE) DEVELOPMENT/PRODUCTION (DOCD/POD) 7. TYPE: HISTORIC INJURY REQUIRED EVACUATION LTA (1-3 days) LTA (>3 days RW/JT (1-3 days) RW/JT (>3 days) Other Injury 8. CAUSE: EQUIPMENT FAILURE HUMAN ERROR EXTERNAL DAMAGE SLIP/TRIP/FALL WEATHER RELATED LEAK UPSET H2O TREATING OVERBOARD DRILLING FLUID OTHER 9. WATER DEPTH: FATALITY POLLUTION FIRE EXPLOSION LWC 6. OPERATION: X PRODUCTION DRILLING WORKOVER COMPLETION HELICOPTER MOTOR VESSEL PIPELINE SEGMENT NO. OTHER K 6. ACTIVITY: STRUCTURAL DAMAGE X CRANE OTHER LIFTING DEVICE DAMAGED/DISABLED SAFETY SYS. X INCIDENT >$25K $32989 H2S/15MIN./20PPM REQUIRED MUSTER SHUTDOWN FROM GAS RELEASE OTHER 270 FT. 10. DISTANCE FROM SHORE: 11. WIND DIRECTION: HISTORIC BLOWOUT SPEED: UNDERGROUND SURFACE 12. CURRENT DIRECTION: DEVERTER SPEED: SURFACE EQUIPMENT FAILURE OR PROCEDURES COLLISION HISTORIC >$25K <=$25K 13. SEA STATE: 67 MI. M.P.H. M.P.H. FT. 14. PICTURES TAKEN: 15. STATEMENT TAKEN: MMS - FORM 2010 EV2010R PAGE: 1 OF 4 28-JUN-2017 17. INVESTIGATION FINDINGS: For Public Release On April 28, 2017 at approximately 1651 hours, the boom heel section of the Titan 5400 crane was found damaged. Prior to the incident, the Crane Operator (CO) was attempting to utilize the Titan 5400 crane to transfer a basket of compressor maintenance equipment from the drilling deck to the production deck. A Job Safety Analysis (JSA) was completed for the lifts involved which specified “boom angles too high or too low”. To eliminate this hazard, the JSA stated ”check and make sure boom angle is not an issue before making lifts”. Once the initial lift was completed, the CO completed three additional lifts to unload the compressor equipment. The CO had the boom positioned at the maximum vertical angle and could not position the basket any closer without overriding the high angle boom winch kick out. The CO bypassed the kick out to complete the additional lifts. Once crane operations were completed, the crane boom was lowered in the boom rest with no notification of damage to the boom. Prior to reusing the crane, employees noticed severe damage on the heel section of the boom. The damage associated with the heel section is comparable to damage due to the heel section coming in contact with the boom stop. This could have only occurred if the angle boom winch kick out was bypassed or if it failed to perform its designed function. Due to the timeline, this could have only occurred during the lifts performed while unloading the compressor equipment. Once the damage was observed, employees raised the crane boom to take photos of boom heel for investigation purposes. Due to the severity of the damage, the crane should have remained out of service until a certified crane mechanic was able to assess the damages.The crane was repaired and placed back in service on May 2, 2017. The BSEE Lafayette District conducted an onsite investigation May 10, 2017. As per API 2C 13.1.1 Boom Angle Limiters and Shut-off Devices: A boom hoist limiter or shut-off shall be provided to automatically stop the boom hoist when the boom reaches a predetermined high angle. Overriding the kick out allowed the CO to raise the boom at the desired angle without the safety device preventing the boom from coming in contact with the boom stop. The CO failed to follow the safety guidelines documented on the JSA. Bypassing the boom kick-out override safety system introduced a risk to the operation that was not discussed in the JSA. Prior to bypassing this safety device the job should have been stopped and this step discussed and/or added to the JSA. Anytime an operational component changes during the present operation, the present operation must be stopped and adjusted to include the operational change. 18. LIST THE PROBABLE CAUSE(S) OF ACCIDENT: MMS - FORM 2010 EV2010R PAGE: 2 OF 4 28-JUN-2017 For Public Release The CO had the boom positioned at the maximum vertical angle and could not position the basket any closer without overriding the high angle boom winch kick out. The CO bypassed the kick out to complete the additional lifts. 19. LIST THE CONTRIBUTING CAUSE(S) OF ACCIDENT: *A Job Safety Analysis (JSA) was completed for the lifts involved which specified “boom angles too high or too low”. To eliminate this hazard, the JSA stated”check and make sure boom angle is not an issue before making lifts”. The CO failed to follow the safety guidelines documented on the JSA. *Bypassing the boom kick-out override safety system introduced a risk to the operation that was not discussed in the JSA. Prior to bypassing this safety device the job should have been stopped and this step discussed and/or added to the JSA. Anytime an operational component changes during the present operation, the present operation must be stopped and adjusted to include the operational change. 20. LIST THE ADDITIONAL INFORMATION: 21. PROPERTY DAMAGED: NATURE OF DAMAGE: Crane Boom ESTIMATED AMOUNT (TOTAL): Heel of crane boom damaged $32,989 22. RECOMMENDATIONS TO PREVENT RECURRANCE NARRATIVE: The BSEE Lafayette District office makes no recommendations to the Regional Office of Incident Investigations (OII). 23. POSSIBLE OCS VIOLATIONS RELATED TO ACCIDENT: YES 24. SPECIFY VIOLATIONS DIRECTLY OR INDIRECTLY CONTRIBUTING. NARRATIVE: G110 (C) Does the Lessee perform all operations in a safe and workmanlike manner and provide for the preservation and conservation of property and the environment? The BSEE Accident Investigation found that the lessee failed to perform crane operations in a safe and workmanlike manner. The following bulleted items document MMS - FORM 2010 EV2010R PAGE: 3 OF 4 28-JUN-2017 Arena Offshore LP unsafe crane practices that damaged the bottom boom section. These unsafe practices posed the possibility of severe injury to personnel, major equipment damage and the possibility of environmental impacts. *The designated crane operator bypassed the boom kick-out override safety system while making a high angle lift from the drill deck to the production deck extending the boom back to an undesirable position ultimately bending the bottom boom section. *Lessee recognized the potential hazard of lifting the boom too high on the job safety analysis but failed to perform the actual lift as per job safety analysis. *Crane operator failed to recognize the damaged boom after the occurrence. Failing to notice this hazard (damaged boom) posed numerous safety hazards by continuing to operate the crane. Operating the crane with damaged boom could have had major impacts including personnel injury and/or further equipment damage. *Once the safety system is bypassed by a person then the person is ultimately taking the responsibility for the safety system. 25. DATE OF ONSITE INVESTIGATION: 28. ACCIDENT CLASSIFICATION: 10-MAY-2017 26. ONSITE TEAM MEMBERS: R. Johnson / J. Mouton / W. Guillotte / 29. ACCIDENT INVESTIGATION PANEL FORMED: NO OCS REPORT: 30. DISTRICT SUPERVISOR: Elliott Smith For Public Release 27. APPROVED DATE: MMS - FORM 2010 EV2010R 27-JUN-2017 PAGE: 4 OF 4 28-JUN-2017 UNITED STATES DEPARTMENT OF THE INTERIOR BUREAU OF SAFETY AND ENVIRONMENTAL ENFORCEMENT GULF OF MEXICO REGION ACCIDENT INVESTIGATION REPORT For Public Release 1. OCCURRED DATE: 31-MAY-2017 TIME: 1410 HOURS 2. OPERATOR: Arena Offshore, LP REPRESENTATIVE: TELEPHONE: ISLAND OPERATORS CO. INC. CONTRACTOR: REPRESENTATIVE: TELEPHONE: 3. OPERATOR/CONTRACTOR REPRESENTATIVE/SUPERVISOR ON SITE AT TIME OF INCIDENT: 4. LEASE: AREA: BLOCK: G02118 EI 338 5. PLATFORM: RIG NAME: X LATITUDE: LONGITUDE: EXPLORATION(POE) DEVELOPMENT/PRODUCTION (DOCD/POD) 7. TYPE: HISTORIC INJURY X REQUIRED EVACUATION LTA (1-3 days) X LTA (>3 days RW/JT (1-3 days) RW/JT (>3 days) Other Injury 1 1 8. CAUSE: EQUIPMENT FAILURE X HUMAN ERROR EXTERNAL DAMAGE SLIP/TRIP/FALL WEATHER RELATED LEAK UPSET H2O TREATING OVERBOARD DRILLING FLUID OTHER 9. WATER DEPTH: FATALITY POLLUTION FIRE EXPLOSION LWC 6. OPERATION: X PRODUCTION DRILLING WORKOVER COMPLETION HELICOPTER MOTOR VESSEL PIPELINE SEGMENT NO. OTHER K 6. ACTIVITY: STRUCTURAL DAMAGE X CRANE OTHER LIFTING DEVICE DAMAGED/DISABLED SAFETY SYS. INCIDENT >$25K H2S/15MIN./20PPM REQUIRED MUSTER SHUTDOWN FROM GAS RELEASE OTHER 270 FT. 10. DISTANCE FROM SHORE: 11. WIND DIRECTION: HISTORIC BLOWOUT SPEED: UNDERGROUND SURFACE 12. CURRENT DIRECTION: DEVERTER SPEED: SURFACE EQUIPMENT FAILURE OR PROCEDURES COLLISION HISTORIC >$25K <=$25K 13. SEA STATE: 67 MI. M.P.H. M.P.H. FT. 14. PICTURES TAKEN: 15. STATEMENT TAKEN: MMS - FORM 2010 EV2010R PAGE: 1 OF 5 25-AUG-2017 17. INVESTIGATION FINDINGS: For Public Release On May 31, 2017 at approximately 1410 hours, an employee was severely injured by a construction tool house that was being moved with the platform crane. A crane operator was attempting to relocate a construction tool house from the cellar deck to the drill deck. The tool house weighed approximately 10,000 lbs. The rigger was located on the cellar deck hooking up the tool house to the slings. The crane operator could not see the rigger on the cellar deck;therefore, radios were used between the rigger and the crane operator to communicate. As the tool house was being lifted, it came in contact with a piece of channel iron. The channel iron was located behind the tool house approximately 9 1/2 ft. above the deck connected to a structural member. The channel iron extended approximately 1 ft. but it's reason for being there is unknown to the employees on board. The crane operator stated he noticed the weight indicator increase briefly, and then went back to the previous reading. During the lift, additional third party personnel were located on the drill deck looking down at the rigging operations. As the crane operator began the lift, a third party employee observed the tool house coming in contact with the channel iron. Due to the height of the tool house, the rigger could not detect any hazards associated with the lift. The third party employee attempted to get the crane operators attention to stop the lift but was unsuccessful. The rigger inadvertently placed himself between the tool house and a handrail allowing a possible pinch point hazard. Once the load separated from the channel iron, it shifted causing the rigger to get wedged between the tool house and the hand rails. Following the contact with the handrails, the rigger complained of pain in his left hip. The injured employee sustained a fractured pelvis and has undergone surgery. The BSEE Lafayette District conducted an onsite investigation June 7, 2017. *As per Wood Group’s GOM-SWP-Cranes and Lifting Equipment Standard 4.10 Signal states signals to operators shall include use of the hand, voice and/or audible method. Means of transmitting the signals (direct line of sight, radio, etc.) must be suitable and appropriate for the site conditions. Signals between the Crane Operator and designated signal person shall be discernible, audibly or visually at all times. The Crane Operator shall not respond unless signals are clearly understood. A signal person must be provided for the following situations: 1. The point of operation is not in full view of the operator 2. The view is obstructed when the equipment is traveling 3. The operator or the person handling the load determines it is necessary due to site specific concerns *As per Island Operating’s Safe Practices Manual 28.45 Crane movement shall always be governed by a standard set of signals, transmitted to the operator by a signalman. 28.47 Signalers should be provided with a clearly identifiable marking, such as a conspicuous arm band, hat, glove or other badge of authority. 28.48 Where visual or audible signals are inadequate, telephone or portable radio communication should be used. *As per Island Operating’s Job Safety Analysis dated May 31, 2017, Section 5-Always watch out for your co-worker to insure that they are in a safe place and out of the line of fire before making lift from the platform. MMS - FORM 2010 EV2010R PAGE: 2 OF 5 25-AUG-2017 For Public Release 18. LIST THE PROBABLE CAUSE(S) OF ACCIDENT: The rigger inadvertently placed himself in a hazardous location allowing the tool house and a handrail to be a possible pinch point hazard. 19. LIST THE CONTRIBUTING CAUSE(S) OF ACCIDENT: *As per Wood Group’s GOM-SWP-Cranes and Lifting Equipment Standard 4.10 Signals states signals to operators shall include use of the hand, voice and/or audible method. Means of transmitting the signals (direct line of sight, radio, etc.) must be suitable and appropriate for the site conditions. Signals between the Crane Operator and designated signal person shall be discernible, audibly or visually at all times. The Crane Operator shall not respond unless signals are clearly understood. A signal person must be provided for the following situations: 1. The point of operation is not in full view of the operator 2. The view is obstructed when the equipment is traveling 3. The operator or the person handling the load determines it is necessary due to site specific concerns *As per Island Operating’s Safe Practices Manual 28.45 Crane movement shall always be governed by a standard set of signals, transmitted to the operator by a signalman. 28.47 Signalers should be provided with a clearly identifiable marking, such as a conspicuous arm band, hat, glove or other badge of authority. 28.48 Where visual or audible signals are inadequate, telephone or portable radio communication should be used. *As per Island Operating’s Job Safety Analysis dated May 31, 2017, Section 5-Always watch out for your co-worker to insure that they are in a safe place and out of the line of fire before making lift from the platform. 20. LIST THE ADDITIONAL INFORMATION: 21. PROPERTY DAMAGED: MMS - FORM 2010 EV2010R NATURE OF DAMAGE: PAGE: 3 OF 5 25-AUG-2017 N/A ESTIMATED AMOUNT (TOTAL): N/A For Public Release $ 22. RECOMMENDATIONS TO PREVENT RECURRANCE NARRATIVE: The BSEE Lafayette District office makes no recommendations to the Regional Office of Incident Investigations (OII). 23. POSSIBLE OCS VIOLATIONS RELATED TO ACCIDENT: YES 24. SPECIFY VIOLATIONS DIRECTLY OR INDIRECTLY CONTRIBUTING. NARRATIVE: G110 (C) Does the Lessee perform all operations in a safe and workmanlike manner and provide for the preservation and conservation of property and the environment? Upon the BSEE onsite Accident Investigation, the following items were found to be part of an unsafe crane operation which caused severe injury to a lessee contract representative. Number 1 task step listed on the potential hazard section of the Job Safety Analysis (JSA) focuses on poor communication not understanding hand signals. The investigation revealed lack of communication in regards to rigging personnel not effectively communicating with the crane operator in a timely fashion to eliminate this undesirable event. It is important to note that there was no line of sight during signals so the signals so the signals were communicated via radio, in which the crane operator never heard the communication trying to be established with him to stop the lift. Number 5 task step listed on the potential hazard section of the JSA focuses on making lifts. Hazard controls on this section of the JSA stresses "staying out of the line of fire". The injured person (IP) was located directly in between a major pinch point (large, 10,000 lb. construction tool box and handrails). The load (top of)came in contact with a piece of metal channel iron which protrudes from one of the structural members. Once the load broke free from the bind (structural member metal channel iron), it smashed the IP who was locted in between the two aforementioned items, also which would be defined as in the line of fire. 25. DATE OF ONSITE INVESTIGATION: 07-JUN-2017 28. ACCIDENT CLASSIFICATION: 29. ACCIDENT INVESTIGATION PANEL FORMED: NO 26. ONSITE TEAM MEMBERS: Raymond Johnson / John Mouton / Wade Guillotte / OCS REPORT: 30. DISTRICT SUPERVISOR: Elliott Smith 27. OPERATOR REPORT ON FILE: MMS - FORM 2010 EV2010R PAGE: 4 OF 5 25-AUG-2017 APPROVED DATE: MMS - FORM 2010 EV2010R 27-JUL-2017 For Public Release PAGE: 5 OF 5 25-AUG-2017 UNITED STATES DEPARTMENT OF THE INTERIOR BUREAU OF SAFETY AND ENVIRONMENTAL ENFORCEMENT GULF OF MEXICO REGION ACCIDENT INVESTIGATION REPORT For Public Release 1. OCCURRED DATE: 20-JUL-2017 TIME: 1645 HOURS 2. OPERATOR: Arena Offshore, LP REPRESENTATIVE: TELEPHONE: CONTRACTOR: REPRESENTATIVE: TELEPHONE: 3. OPERATOR/CONTRACTOR REPRESENTATIVE/SUPERVISOR ON SITE AT TIME OF INCIDENT: 4. LEASE: AREA: BLOCK: G03331 EI 251 5. PLATFORM: RIG NAME: X LATITUDE: LONGITUDE: EXPLORATION(POE) DEVELOPMENT/PRODUCTION (DOCD/POD) 7. TYPE: HISTORIC INJURY REQUIRED EVACUATION LTA (1-3 days) LTA (>3 days RW/JT (1-3 days) RW/JT (>3 days) Other Injury EQUIPMENT FAILURE X HUMAN ERROR EXTERNAL DAMAGE SLIP/TRIP/FALL WEATHER RELATED LEAK UPSET H2O TREATING OVERBOARD DRILLING FLUID OTHER 111 FT. 10. DISTANCE FROM SHORE: 11. WIND DIRECTION: SE HISTORIC BLOWOUT SPEED: 4 UNDERGROUND SURFACE 12. CURRENT DIRECTION: DEVERTER SPEED: X SURFACE EQUIPMENT FAILURE OR PROCEDURES COLLISION MMS - FORM 2010 EV2010R 8. CAUSE: 9. WATER DEPTH: FATALITY POLLUTION FIRE EXPLOSION LWC 6. OPERATION: PRODUCTION X DRILLING WORKOVER COMPLETION HELICOPTER MOTOR VESSEL PIPELINE SEGMENT NO. OTHER C 6. ACTIVITY: STRUCTURAL DAMAGE CRANE X OTHER LIFTING DEVICE Traveling Block DAMAGED/DISABLED SAFETY SYS. INCIDENT >$25K H2S/15MIN./20PPM REQUIRED MUSTER SHUTDOWN FROM GAS RELEASE OTHER X HISTORIC >$25K X <=$25K 13. SEA STATE: 1 54 MI. M.P.H. M.P.H. FT. PAGE: 1 OF 5 31-OCT-2017 17. INVESTIGATION FINDINGS: For Public Release At 16:45 hour on 20 July 2017, Arena Offshore, LP (Arena) had a dropped objects incident onboard the drilling rig while conducting drilling operations at Eugene Island (EI) Block 251C. The incident involved drill line that unspooled and detached from the drawworks drum causing the traveling block to descend to the rotary table and approximately 123 feet (ft) of drill line to fall to the rig floor. There were no injuries or structural damage; however, there was damage to the drawworks drum drill line clamp and approximately 123 ft (two sheaves) of drill line during this incident. The drawworks cover guard fell off during the incident and was reinstalled. At 07:21 hour on 21 July 2017, Arena reported the incident to the Bureau of Safety and Environmental Enforcement (BSEE) Lafayette District. On 19 July 2017, the drill crew began the non-routine task of dissembling the topdrive to install a new motor and transmission. The top-drive was removed leaving the traveling block and compensator that reduced the traveling assembly weight from 80,000 pounds (lbs) to 12,000 lbs. The Driller operated the traveling block on 12 lines without the weight of the top drive or other substantial load. The Driller operated the drawworks brake and controls while utilizing the traveling block and rig up lines to pick up and move the old top-drive motor and transmission to the rig floor port and starboard sides; respectively, without incident. On 20 July 2017, the Offshore Installation Manager (OIM) was operating the traveling block as it was being lowered to connect to the rig up lines to the new top-drive transmission located at the bottom of the v-door. Due to the stiffness of 1.625-inch drill line and lack of weight to keep these lines stretched, the 7 to 9 wraps on the drawworks drum required to suspend loads became loose. The OIM’s use of the traveling block to assist in laying down the motor and transmission loosened the wraps on the drum to a condition where the drill line clamp became exposed to excessive tension and the drill line pulled free from the clamp. When the traveling block was approximately 10 to 20 ft above the rotary, the drill line came out of the drawworks drum clamp and unspooled off the drawworks drum. The traveling block slowly descended landing on the rotary table and two sheaves of drill line (123 ft) fell to the rig floor. The traveling block was held upright by the traveling block dolly on the guide track. On 21 and 25 July 2017, a BSEE incident investigation team mobilized to the rig and conducted onsite investigations. The BSEE incident investigation team conducted the following activities: 1) gathered all applicable documents; 2) performed written and photo-graphic documentation of the incident scene; 3) conducted a post-incident inspection; 4) documented the Operator's corrective actions; and 5) re-interviewed witnesses to the incident. On 7 August 2017, Arena issued a Safety Alert on the traveling block dropped incident that summarized the incident investigation findings and recommended actions. Arena Energy commissioned an independent company to perform a third party investigation on the subject incident with a detailed analysis on the rig clamp utilized. The report stated the following: “The 1-5/8" drill line is very stiff and hard to keep tight when operating on the lower layer wrap of the drum unless a sufficient block load is maintained. Operating the empty travel block on 12 lines (12 lines elevating from the travel block to the crown block) without the top-drive, or a substantial load, will not provide enough line tension to keep the line wrapped tight against the drum. Slacking on and off the drum spool in this condition will cause the drill line to loosen its grip around the circumference of the drum thus exerting excessive load against the drum drill line clamp. The drum drill line clamp is designed to secure the tail end of the line until 6 to 9 wraps are tightly wrapped around the drum and the drill line is kept in tension.” MMS - FORM 2010 EV2010 PAGE: 2 OF 5 31-OCT-2017 For Public Release The report indicates improper sized drill line drum clamp and clamp bolts were installed on the drawworks drum. Although records indicate (the designated) correct torque (200 ft-lbs) was applied to the drawworks drum drill line clamp bolts, the investigation report states (due to the clamp bolts and nuts installed during the time of the incident) “a proper torque value would be impossible to maintain when installed and at least one lock nut would not reach its proper position to ensure it could not back off during operation.” Operational error does not seem to be evident in the investigative findings. The OIM, operating the traveling block at the time of the incident, performed similar travel block operations as which the driller performed the day before. Based on the MRI incident investigation report, the repetitive drawworks operation (slacking on and off the drum spool) during the time of the incident would have caused the line to loosen its grip around the circumference of the drawworks drum thus exerting excessive load against the drum drill line clamp. Operational error does not seem to be evident in the investigative findings. The OIM, operating the traveling block at the time of the incident, performed similar travel block operations as the Driller performed the day before. Based on the incident investigation report, the repetitive drawworks operation (slacking on and off the drum spool) during the time of the incident would have caused the drill line to loosen its grip around the circumference of the drawworks drum thus exerting excessive load against the drum drill line clamp. 18. LIST THE PROBABLE CAUSE(S) OF ACCIDENT: BSEE's incident investigation revealed the primary cause of the incident was attributed to the drill line unspooling from the drawworks drum. 19. LIST THE CONTRIBUTING CAUSE(S) OF ACCIDENT: The possible contributing causes identified by BSEE for this incident included: 1) failure to prevent the drill line from developing slack on the drawworks drum’s bottom layer and unseating from the LeBus grooves; 2) failure to include enough drawworks drum drill line wraps to ensure proper seating on the drum grooves; 3) failure to install the properly sized drill line cable clamp; 4) failure to install proper drum drill line clamp bolts; and 5) failure to identify the hazards in the pre-job job safety analysis of controlling a lighter traveling block load while maintaining drill line tension so that the drill line was properly seated in the drum grooves on the drawworks drum. The OIM, who was operating the traveling block at the time of the incident, was performing similar travel block operations that the driller performed the day before with the same light block load. The differences in the traveling block operator’s capability to operate the drawworks brake to ensure proper fast line tension could have been a contributing cause of the incident. Currently there is no evidence for this case. While evidence does exist that proper slacking on and off the drum spool during the time of the incident would cause the line to loosen its grip around the circumference of the drawworks drum thus exerting excessive load against the drum drill line clamp. MMS - FORM 2010 EV2010 PAGE: 3 OF 5 31-OCT-2017 For Public Release 20. LIST THE ADDITIONAL INFORMATION: A. 21. PROPERTY DAMAGED: Drawworks drum drill line clamp and approximately 123 feet of drill line. ESTIMATED AMOUNT (TOTAL): NATURE OF DAMAGE: Drawworks drum dill line clamp broke and drill line were replaced. $1,300 22. RECOMMENDATIONS TO PREVENT RECURRANCE NARRATIVE: Prior to commencing removal of the top-drive from the traveling block, BSEE recommends that operators consider slipping an additional wraps of drill line (above the recommended minimum amount) onto the drawworks drum to prevent the drill line from developing slack on the drum’s bottom layer and unseating from the drum grooves due to lack of tension on the fast line. BSEE recommends operators to consider: 1) verifying the properly sized drawworks drill line clamp is installed with certified bolts; 2) verifying the recertification of the drawworks drum shafts include inspecting the drum drill line clamp as part of their procedure; and 3) incorporating the inspection of the drum drill line clamp to the rig’s drawworks preventative maintenance program and the annual lifting gear inspection. 23. POSSIBLE OCS VIOLATIONS RELATED TO ACCIDENT: YES 24. SPECIFY VIOLATIONS DIRECTLY OR INDIRECTLY CONTRIBUTING. NARRATIVE: Based on the incident investigation findings, a G-110 Incident of Noncompliance (INC) was issued “After the Fact” to document that Arena Offshore (Arena) failed to provide adequate supervision during drilling operations on the jack-up drilling rig on Well C-3 located in Eugene Island Block 251-C. 23. POSSIBLE OCS VIOLATIONS RELATED TO ACCIDENT: YES 24. SPECIFY VIOLATIONS DIRECTLY OR INDIRECTLY CONTRIBUTING. NARRATIVE: Based on the incident investigation findings, a G-110 Incident of Noncompliance (INC) was issued “After the Fact” to document that Arena Offshore (Arena) failed to provide adequate supervision during drilling operations on the White Fleet Drilling (WFD) 300 jack-up rig on Well C-3 located in Eugene Island Block 251-C. The G-110 INC was issued to Arena “After the Fact” for the failure to perform drilling operations in a safe and workmanlike manner. On 20 July 2017, while conducting maintenance on the top-drive, the traveling block slowly descended to the rotary table and drill line suddenly fell to the rig floor due to the failure to properly operate the drawworks brake. MMS - FORM 2010 EV2010R PAGE: 4 OF 5 31-OCT-2017 For Public Release 25. DATE OF ONSITE INVESTIGATION: 28. ACCIDENT INVESTIGATION PANEL FORMED: NO 21-JUL-2017 OCS REPORT: 26. ONSITE TEAM MEMBERS: Troy Naquin (25-JUL-2017) / Jack Angelle (21-JUL-2017) / Ernest Carmouche (21-JUL-2017) / Roy Kuhn (21-JUL-2017) / Johnny Serrette (25-JUL-2017) / 29. DISTRICT SUPERVISOR: Elliott Smith APPROVED DATE: MMS - FORM 2010 EV2010R 16-OCT-2017 PAGE: 5 OF 5 31-OCT-2017 UNITED STATES DEPARTMENT OF THE INTERIOR BUREAU OF SAFETY AND ENVIRONMENTAL ENFORCEMENT GULF OF MEXICO REGION ACCIDENT INVESTIGATION REPORT For Public Release 1. OCCURRED DATE: 15-SEP-2017 TIME: 1150 HOURS Talos Energy, LLC (Talos) 2. OPERATOR: REPRESENTATIVE: TELEPHONE: CONTRACTOR: REPRESENTATIVE: TELEPHONE: 3. OPERATOR/CONTRACTOR REPRESENTATIVE/SUPERVISOR ON SITE AT TIME OF INCIDENT: 4. LEASE: AREA: BLOCK: G04842 ST 34 5. PLATFORM: RIG NAME: LATITUDE: LONGITUDE: B 6. ACTIVITY: X EXPLORATION(POE) DEVELOPMENT/PRODUCTION (DOCD/POD) 7. TYPE: HISTORIC INJURY REQUIRED EVACUATION LTA (1-3 days) LTA (>3 days RW/JT (1-3 days) RW/JT (>3 days) Other Injury X PRODUCTION DRILLING WORKOVER COMPLETION HELICOPTER MOTOR VESSEL PIPELINE SEGMENT NO. X OTHER loading boat with grocery box 8. CAUSE: EQUIPMENT FAILURE X HUMAN ERROR X EXTERNAL DAMAGE SLIP/TRIP/FALL WEATHER RELATED LEAK UPSET H2O TREATING OVERBOARD DRILLING FLUID OTHER 50 FT. 10. DISTANCE FROM SHORE: 11. WIND DIRECTION: HISTORIC BLOWOUT SPEED: UNDERGROUND SURFACE 12. CURRENT DIRECTION: DEVERTER SPEED: SURFACE EQUIPMENT FAILURE OR PROCEDURES COLLISION MMS - FORM 2010 EV2010R 6. OPERATION: 9. WATER DEPTH: FATALITY POLLUTION FIRE EXPLOSION LWC STRUCTURAL DAMAGE X CRANE OTHER LIFTING DEVICE DAMAGED/DISABLED SAFETY SYS. X INCIDENT >$25K $270,450 H2S/15MIN./20PPM REQUIRED MUSTER SHUTDOWN FROM GAS RELEASE OTHER HISTORIC >$25K <=$25K 13. SEA STATE: 9 MI. M.P.H. M.P.H. FT. PAGE: 1 OF 3 15-DEC-2017 17. INVESTIGATION FINDINGS: For Public Release On September 15, 2017, an incident occurred on the South Timbalier 34B Platform (Lease OCS G04842). Talos Energy, LLC (Talos) is the Designated Operator of Records. The platform is situated nine nautical miles from shore in fifty feet of water. After completing a third and final lift on the back deck of the Motor Vessel (M/V), the crane operator was in the process of laying the boom down in its rest when the boom encountered a failure. Just prior to completing the boom rest operation, the two bottom bolts connecting the midsection and heel section failed. The failure of the bolts caused excessive stress on the remaining top bolts. Once the top bolts failed the top section of the boom collapsed (jackknifed) to the right, then dropped down, eventually hanging by the main and auxiliary cables on the west side of the platform. The crane operator was able to exit the crane cab. Once the incident was over, the platform Emergency Shutdown (ESD) system was activated. No reportable injuries occurred during the incident. Though the crane was not present at the facility during onsite inspection by BSEE Houma District personnel, photos obtained of the lower bolt showed signs of stretching and bending, indicating contact. Therefore, it appears the most likely cause of the failure of the bottom bolts in the boom midsection was due to a probable boom/boom stop contact that day or in recent days prior to the incident. The following third party investigative findings support this conclusion: 1) "Despite heavy corrosion of these portions of the lower bolts blocked from view by the connection plates and nuts, the shafts of both fasteners show signs of significant elongation and necking. This indicates that both lower fasteners were significantly overloaded in tension prior to or during the collapse." 2) "Elongated connection holes at the upper connection pads and bent upper bolts indicate that the lower bolts failed first and the boom jackknifed downward prior to separation." 3) "Calculated tensile forces during a boom stop contact event are more than adequate to fail the splice connection lower bolts in tension." 4) "Fresh signs of contact between the boom and both boom stops were photographed and noted by the Talos investigator." 5) "It is more likely than not that the lower bolts at the heel/mid-section splice were damaged (broken and partially stripped) during a boom stop contact event. As the boom was lowered to the rest, the gradually increasing tensile loading overcame the remaining strength of the lower fastners." 18. LIST THE PROBABLE CAUSE(S) OF ACCIDENT: The probable cause of the failure of the bottom bolts in the boom midsection was likely due to a recent boom/boom stop contact. 19. LIST THE CONTRIBUTING CAUSE(S) OF ACCIDENT: Heavy corrossion may have further weakened the lower connecting bolts. 20. LIST THE ADDITIONAL INFORMATION: N/A MMS - FORM 2010 EV2010R PAGE: 2 OF 3 15-DEC-2017 21. PROPERTY DAMAGED: NATURE OF DAMAGE: Crane boom (all sections) Main line Auxilliary line Bent/broken boom and lines For Public Release ESTIMATED AMOUNT (TOTAL): $270,450 22. RECOMMENDATIONS TO PREVENT RECURRANCE NARRATIVE: The Houma District has no recommendations for the Regional Office. 23. POSSIBLE OCS VIOLATIONS RELATED TO ACCIDENT: NO 24. SPECIFY VIOLATIONS DIRECTLY OR INDIRECTLY CONTRIBUTING. NARRATIVE: None 25. DATE OF ONSITE INVESTIGATION: 18-SEP-2017 28. 29. ACCIDENT INVESTIGATION PANEL FORMED: NO 26. ONSITE TEAM MEMBERS: Micah Charpentier / Terry Hollier / OCS REPORT: 30. DISTRICT SUPERVISOR: Bryan Domangue APPROVED DATE: MMS - FORM 2010 EV2010R 12-DEC-2017 PAGE: 3 OF 3 15-DEC-2017 UNITED STATES DEPARTMENT OF THE INTERIOR BUREAU OF SAFETY AND ENVIRONMENTAL ENFORCEMENT GULF OF MEXICO REGION ACCIDENT INVESTIGATION REPORT For Public Release 1. OCCURRED STRUCTURAL DAMAGE CRANE X OTHER LIFTING Riser Running Tool 2. OPERATOR: BP Exploration & Production Inc. DAMAGED/DISABLED SAFETY SYS. REPRESENTATIVE: X INCIDENT >$25K damaged to equipment TELEPHONE: H2S/15MIN./20PPM REQUIRED MUSTER CONTRACTOR: Ensco Offshore Co. SHUTDOWN FROM GAS RELEASE REPRESENTATIVE: OTHER Dropped Object - Riser Jt. X TELEPHONE: DATE: 16-OCT-2017 TIME: 1730 HOURS 3. OPERATOR/CONTRACTOR REPRESENTATIVE/SUPERVISOR ON SITE AT TIME OF INCIDENT: 4. LEASE: AREA: BLOCK: G09868 MC 778 5. PLATFORM: RIG NAME: PRODUCTION DRILLING WORKOVER COMPLETION HELICOPTER MOTOR VESSEL PIPELINE SEGMENT NO. X OTHER Running BOP's LATITUDE: LONGITUDE: THUNDER HORSE PDQ 6. ACTIVITY: X EXPLORATION(POE) DEVELOPMENT/PRODUCTION (DOCD/POD) 7. TYPE: HISTORIC INJURY REQUIRED EVACUATION LTA (1-3 days) LTA (>3 days RW/JT (1-3 days) RW/JT (>3 days) Other Injury EQUIPMENT FAILURE X HUMAN ERROR EXTERNAL DAMAGE SLIP/TRIP/FALL WEATHER RELATED LEAK UPSET H2O TREATING OVERBOARD DRILLING FLUID OTHER 6037 FT. 11. DISTANCE FROM SHORE: 12. WIND DIRECTION: SPEED: HISTORIC BLOWOUT UNDERGROUND SURFACE DEVERTER SURFACE EQUIPMENT FAILURE OR PROCEDURES COLLISION 9. CAUSE: 10. WATER DEPTH: FATALITY POLLUTION FIRE EXPLOSION LWC 8. OPERATION: HISTORIC >$25K <=$25K 2 MI. NE 7 13. CURRENT DIRECTION: SPEED: 14. SEA STATE: 60 M.P.H. NE 1 M.P.H. FT. 15. PICTURES TAKEN: 16. STATEMENT TAKEN: MMS - FORM 2010 EV2010R PAGE: 1 OF 3 08-MAR-2018 17. INVESTIGATION FINDINGS: For Public Release On 10/16/2017, at approximately 1620 hours, the drill crew was in the process of running the drilling riser in preparation to latch the BOP stack to the subsea wellhead. While picking up a joint of riser (joint #8) to connect to the riser string, the riser joint became disengaged from the riser running tool and dropped 30' to the aft side of the derrick. The joint of riser struck the Top Drive System (TDS) dolly track and wire trays. After securing this joint of riser safely back to the deck, an inspection was conducted and found structural damage to the drawworks track and support bracing. There was also damage to hydraulic lines, electrical cables, and cable trays. All energized areas of concern were isolated and secured. There was no harm to personnel or damage to the environment. According to witness statements, Red Zone Management was in effect and no one was in the Red Zone at the time of the incident. NOV technicians on location conducted a further inspection of the damaged equipment. The joint of marine riser at issue weighed approximately 43,000 lbs and caused damage with an estimated $25,000 to $35,000 in repair cost. After conducting structural integrity inspections and completing additional repairs to the hydraulic lines, TDS support beams, and electrical trays, well operations resumed on 10/21/2017. After reviewing the "Ensco Thunder Horse Work Instructions" for running riser, the following issues were critical with respect to this incident: 1) Step (3) page (2) - Lower the front gate on the spider and hoist running tool horizontally with the air hoist. Bring in skate and stab the running tool into the riser. Latch the running tool. 2) Step (4)(a) - Assistant Driller (AD) will verify that the riser running tool is properly locked prior to hoisting riser off of the skate to prevent the riser from falling. 3) Also noted in the "Ensco Thunder Horse Work Instructions" Consequence-Equipment Damage/Personal Injury Hazard. a) Gravity-Riser joint falling to the rig floor due to the running tool not properly locked. A drill crew member, the floor hand, is responsible for manually locking the joint of riser to the riser running tool. This part of the operation was not completed. A crew member stated to the BSEE Investigator the Floorhand thought he had utilized the manual lockdown, listed in step (3), but this did not happen. The AD did not verify that the joint of riser had been manually and mechanically locked into the riser running tool prior to lifting the riser joint vertical as listed in step (4). The riser running tool was not properly engaged into the profile of the riser joint. There was no verification that the secondary mechanical lock was closed on the riser running tool prior to raising the joint of riser. There was poor communication among the drill crew team members involved in this operation. 18. LIST THE PROBABLE CAUSE(S) OF ACCIDENT: 1)Riser running tool was not properly engaged into profile of the riser joint. 2) No verification that the secondary mechanical lock was closed on the riser running tool prior to raising the joint of riser to the vertical position. MMS - FORM 2010 EV2010R PAGE: 2 OF 3 08-MAR-2018 3) Poor communication among the drill crew team members involved in this operation. For Public Release 19. LIST THE CONTRIBUTING CAUSE(S) OF ACCIDENT: See Initial findings in Section 17. 20. LIST THE ADDITIONAL INFORMATION: 21. PROPERTY DAMAGED: NATURE OF DAMAGE: Top drive system (TDS) dolly track. Also, structural damage to the draw works track and support bracing. Hydraulic lines, electrical cables and cable (wire) trays on the TDS. ESTIMATED AMOUNT (TOTAL): Structural $35,000 22. RECOMMENDATIONS TO PREVENT RECURRANCE NARRATIVE: The BSEE New Orleans District makes no recommendations to the Office of Incident Investigation. 23. POSSIBLE OCS VIOLATIONS RELATED TO ACCIDENT: YES 24. SPECIFY VIOLATIONS DIRECTLY OR INDIRECTLY CONTRIBUTING. NARRATIVE: G-110 (W) 30 CFR 250.107. Does The Lessee Perform All Operations in a Safe and Workmanlike Manner and provide for the Preservation and Conservation of Property and the Environment? At the conclusion of the investigation, BSEE investigators determined that the operator failed to conduct operations in a safe and workmanlike manner on 10/16/2017. This resulted in a joint of Riser becoming disengaged from the running tool. The top of the riser joint fell approximately 30 feet, contacting the Top-Drive System, Dolly Track and wire trays before coming to a rest. 25. DATE OF ONSITE INVESTIGATION: 20-OCT-2017 26. INVESTIGATION TEAM MEMBERS: 29. ACCIDENT INVESTIGATION PANEL FORMED: NO 30. DISTRICT SUPERVISOR: OCS REPORT: David Trocquet Earl Roy / APPROVED DATE: 07-MAR-2018 MMS - FORM 2010 EV2010R PAGE: 3 OF 3 08-MAR-2018 UNITED STATES DEPARTMENT OF THE INTERIOR BUREAU OF SAFETY AND ENVIRONMENTAL ENFORCEMENT GULF OF MEXICO REGION ACCIDENT INVESTIGATION REPORT For Public Release 1. OCCURRED DATE: 29-NOV-2017 TIME: 2015 HOURS 2. OPERATOR: W & T Offshore, Inc. REPRESENTATIVE: TELEPHONE: CONTRACTOR: Enterprise Offshore Drilling REPRESENTATIVE: TELEPHONE: STRUCTURAL DAMAGE X CRANE OTHER LIFTING DAMAGED/DISABLED SAFETY SYS. X INCIDENT >$25K 200,000 H2S/15MIN./20PPM REQUIRED MUSTER SHUTDOWN FROM GAS RELEASE OTHER 3. OPERATOR/CONTRACTOR REPRESENTATIVE/SUPERVISOR ON SITE AT TIME OF INCIDENT: 4. LEASE: AREA: BLOCK: G34340 ST 224 LATITUDE: LONGITUDE: 5. PLATFORM: RIG NAME: ENTERPRISE 264 6. ACTIVITY: X 7. TYPE: EXPLORATION(POE) DEVELOPMENT/PRODUCTION (DOCD/POD) HISTORIC INJURY REQUIRED EVACUATION LTA (1-3 days) LTA (>3 days RW/JT (1-3 days) RW/JT (>3 days) Other Injury 9. CAUSE: X EQUIPMENT FAILURE HUMAN ERROR EXTERNAL DAMAGE SLIP/TRIP/FALL WEATHER RELATED X LEAK UPSET H2O TREATING OVERBOARD DRILLING FLUID OTHER 175 FT. 11. DISTANCE FROM SHORE: 12. WIND DIRECTION: SPEED: HISTORIC BLOWOUT UNDERGROUND SURFACE DEVERTER SURFACE EQUIPMENT FAILURE OR PROCEDURES COLLISION PRODUCTION X DRILLING WORKOVER COMPLETION HELICOPTER MOTOR VESSEL PIPELINE SEGMENT NO. OTHER 10. WATER DEPTH: FATALITY X POLLUTION FIRE EXPLOSION LWC 8. OPERATION: HISTORIC >$25K <=$25K 3 MI. N 10 13. CURRENT DIRECTION: SPEED: 14. SEA STATE: 50 M.P.H. M.P.H. FT. 15. PICTURES TAKEN: 16. STATEMENT TAKEN: MMS - FORM 2010 EV2010R PAGE: 1 OF 4 02-MAR-2018 17. INVESTIGATION FINDINGS: For Public Release On November 29, 2017, the Enterprise 264 jack-up drilling rig was contracted to W & T Offshore to drill a new well in South Timbalier Block 224. While offloading equipment from a supply vessel, the boom on the port side crane fell uncontrollably and came to rest against the side of the rig. The hull of the rig was punctured by the crane boom, which allowed approximately 38 barrels of diesel to leak into the Gulf of Mexico. There were no injuries to personnel as a result of this incident. At approximately 1950 hours, the Crane Operator (CO) completed the pre-use inspection of the port side crane and proceeded to transfer two Enterprise personnel to the supply vessel to assist with the loading and unloading of equipment. Two other Enterprise personnel were then transferred to the rig as part of crew change. At approximately 2015 hours, the CO had made two lifts and was booming down for the third lift when he heard a loud “pop,” and the 110-foot crane boom fell uncontrollably and came to rest against the side of the rig. The headache ball landed on the back deck of the supply vessel and was still attached to the crane by the cables. The crew on the supply vessel removed the headache ball by sliding the ball into the water, and the vessel moved safely away from the rig. All personnel were accounted for and once it was verified that there were no injuries, personnel surveyed the rig for damage. During this survey it was observed that there was diesel leaking below the rig, and the crew immediately transferred diesel from the port side diesel tank to the starboard side diesel tank and the supply vessel. The release was stopped by 0600 hours when the diesel transfer was complete, but approximately 38 barrels of diesel were released into the Gulf of Mexico. The Bureau of Safety and Environmental Enforcement (BSEE) investigation team conducted an initial onsite investigation on November 30, 2017. The team collected evidence and took pictures of the Nautilus 340 L-110 port side crane and the area where the incident occurred. The investigation team examined the water in the areas around the rig and did not observe a sheen or pollution from this event. The diesel had dissipated by the time the investigation team arrived, but the sheen was initially reported to BSEE as being 5.1 miles long and up to 50 yards wide. The puncture from the crane boom to the rig’s hull was on the bottom of the rig and was not visible at the time of the investigation. The investigation determined that the two snap rings which keep the ratchet pawl cylinder pin in place were missing, allowing the pin to vibrate its way out of the linkage assembly. This pin connects the boom pawl cylinder and the boom pawl. When the pin vibrated out, the pawl engaged against the boom winch dogs. The sudden stopping force caused by the boom pawl engagement applied extreme force back to the drive motor, which sheared the bolts of the drive/motor brake bale housing and separated the drive/motor from the winch allowing the crane boom to fall. When the boom fell, part of the crane whipped under the rig and punctured the hull. The last annual inspection on the crane was in April 2017, and the crane inspector noted that all winches were in good condition but were due to be changed. The boom winch was changed on May 19, 2017, by Enterprise personnel. During this installation, the ratchet pawl pin should have been installed, but there is not documentation stating specifically that the snap rings were actually installed. It is possible that the rings were installed, but corrosion or the actual design of the pin allowed the rings to be knocked off as the pin moved back and forth. The snap rings were not found during the investigation. The weekly inspection, which is actually a 10 hour inspection, does include a requirement to, “visually inspect pins, keepers, and bolts.” W&T and Enterprise stated that this refers to pawl cylinder pin and snap rings, so the assembly was being inspected weekly/every 10 hours of use. The “Preventive Maintenance Daily Inspection” is the daily inspection that is conducted by each CO at the beginning of the shift. This inspection instructed the CO to check the MMS - FORM 2010 EV2010R PAGE: 2 OF 4 02-MAR-2018 “Boom Hoist Lock Pawl Engagement/Disengagement with Ratchet Wheel Teeth,” but this only ensures that the pawl is engaging and disengaging when ordered to do so. It does not instruct the CO to check the ratchet pawl cylinder pin. Release For Public Since the incident, Enterprise Offshore has installed an upgraded pin and retainer ring design so that it includes a raised shoulder on one side and a washer with duel cotter pins on the other side. The inspection program has also been improved by specifically requiring the ratchet pawl pin and its related assembly to be inspected daily, weekly and monthly. This inspection will also be added to the rig’s preventative maintenance program, and Enterprise Offshore will distribute a Safety Alert for this incident to their entire fleet of rigs. The hull of the rig was repaired and put back into service on December 10, 2017. 18. LIST THE PROBABLE CAUSE(S) OF ACCIDENT: - The snap rings which keep the ratchet pawl cylinder pin in place were missing, which allowed the pin to vibrate its way out of the linkage assembly. 19. LIST THE CONTRIBUTING CAUSE(S) OF ACCIDENT: - The "Preventive Maintenance Daily Inspections" did not require the CO to inspect the ratchet pawl cylinder pin. 20. LIST THE ADDITIONAL INFORMATION: - This crane is under United States Coast Guard (USCG) jurisidiction, and they conducted their own investigation into this incident. The USCG issued a deficiency report to the Enterprise 264 as a result of their investigation. - During the USCG investigation, it was found that the starboard side crane was also missing snap rings from one side of its ratchet pawl cylinder pin. This was corrected and approved by the USCG. 21. PROPERTY DAMAGED: NATURE OF DAMAGE: Port crane boom Port side diesel tank ESTIMATED AMOUNT (TOTAL): Damaged crane boom. Hole in Port side diesel tank $200,000 22. RECOMMENDATIONS TO PREVENT RECURRANCE NARRATIVE: BSEE Houma District has no recommendations for the Office of Incident Investigations at this time. 23. POSSIBLE OCS VIOLATIONS RELATED TO ACCIDENT: YES 24. SPECIFY VIOLATIONS DIRECTLY OR INDIRECTLY CONTRIBUTING. NARRATIVE: An E-100 was issued as follows: "On November 29, 2017, the Enterprise Rig 264's port crane failed causing a puncture in the rig's hull. This resulted in a discharge of 38 barrels of diesel fuel into the Gulf of Mexico." 25. DATE OF ONSITE INVESTIGATION: 30-NOV-2017 28. ACCIDENT CLASSIFICATION: 29. ACCIDENT INVESTIGATION PANEL FORMED: NO OCS REPORT: MMS - FORM 2010 EV2010R PAGE: 3 OF 4 02-MAR-2018 26. INVESTIGATION TEAM MEMBERS: Josh Naquin / Troy Boudreaux / Robert P Reeves / 30. DISTRICT SUPERVISOR: For Public Release Bryan Domangue 27. OPERATOR REPORT ON FILE: APPROVED DATE: MMS - FORM 2010 EV2010R 01-MAR-2018 PAGE: 4 OF 4 02-MAR-2018 ROB BISHOP OF UTAH RAUL GRIJALVA OF ARIZONA CHAIRMAN RANKING MEMBER CODYSTEWART momma 13%. ?it-Inna]: nf illeprwentattuw Olnmmittre mt Natural Eeanurrm E01 211515 January 19, 2018 The Honorable Ryan Zinke Secretary US. Department of the Interior 1849 Street, NW Washington, DC. 20240 Dear Secretary Zinke: On December 29, 2017, the Bureau of Safety and Environmental Enforcement (BSEE) published a proposed rule in the Federal Register that, if adopted, would significantly modify the September 2016 Production Safety Systems rule.I News reports indicate BSEE is developing another proposed rule that would revise the April 2016 Well Control Rule.2 Both 2016 rules regulate offshore oil and gas activities on the Outer Continental Shelf (OCS) and were developed by the Interior Department in collaboration with industry in response to the 2010 Deepwater Horizon disaster, which caused the deaths of 11 platform workers and resulted in the largest oil spill in US. history. Before the ?nalization of the 2016 BSEE rules, regulations for offshore oil and gas production safety systems had not undergone major revisions since their ?rst publication in 1988. Over the past few decades, advances in technology have enabled offshore energy development to take place in deeper water and for more equipment to be permanently positioned on the sea ?oor. As industry and technology have progressed, the need for robust federal offshore safety and environmental regulations has increased as well. While the Interior Department under the previous Administration responded to the Deepwater Horizon with carefully crafted rules developed with a safety-?rst mindset and input from all stakeholders, recent actions would be a significant step backwards from efforts to improve the safety culture of offshore operators. Additionally, there appear to be few, if any, good reasons for making the proposed changes, which would undermine the current offshore safety rules. According to BSEE, the 2016 Production Safety Systems rule was ?intended to improve worker safety and protection of marine and coastal ecosystems by helping to reduce the number of production-related incidents resulting from oil spills, injuries, and fatalities.?3 A component of the 2016 Rule requires the operator of safety and pollution prevention equipment (SPPE) to ?have 82 FR 61203 2 Mann, Ted. ?Regulators Propose Rollbacks to Offshore Drilling Safety Measures.? The Wall Street Journal, Dec. 25, 2017. . l4206800#comments_sector 3 81 FR 61833 atu ra I re ecu rces. housegov a quali?ed independent third?party review and certify that each device will function as designed under the conditions to which it may be exposed,? and that ?each device be designed to function and to close in the most extreme conditions to which it may be exposed.?4 This provision was recommended by the bipartisan presidential commission that was established after the Deepwater Horizon disaster.5 However, 2017 proposed rule would, ?remove the requirement for operators to certify through an independent third party that each device is designed to function in the most extreme conditions to which it will be exposed and that the device will function as designed.?6 Returning to an over-reliance on industry self-policing of safety issues would be an unfortunate step back towards the situation that existed prior to the Deepwarer Horizon. One of the most important components of the Production Safety Systems Rule is the change in the de?nition of Best Available and Safest Technology (BAST) to more closely align with the Outer Continental Shelf Lands Act. This requirement goes beyond simply production safety systems, improving safety across the full spectrum of offshore operations. request for comments on the BAST de?nition in the proposed rule raises the possibility that BSEE may attempt to change the definition in the final rule without fully opening it to public review and comment. Although the proposed revisions to the Well Control Rule have not been published in the Federal Register yet, the text available through media reports raises a number of questions. The failure of Deepwarer Horizon ?s blowout preventer (BOP) allowed over one hundred million gallons of oil to spill into the Gulf of Mexico, killing thousands of marine animals and causing billions of dollars in damage to the fishing and tourism industries. After numerous investigations, analyses of the events, and a review of recommendations, BSEE published the Well Control Rule in April 2016 in order to ?prevent future well?control incidents, including major incidents like the 2010 Deepwater Horizon catastrophe.?7 According to analysis, the 2016 Well Control Rule incorporated ?the latest industry standards that establish minimum baseline requirements for the design, manufacture, repair, and maintenance of blowout preventers.?8 At the time, BSEE stated, ?adoption of these [standards] will ensure that regulations match the performance requirements recommended by the industry in the time since the Deepwarer Horizon, tragedy.?9 The potential prOposal, however, would weaken a number of provisions related to BOP capability, inspection, reporting, and testing. 4 Id. 5 Eilpcrin, Juliet and Dino Grandoni. ?Trump administration to overhaul safety-monitoring rules for offshore drilling.? The Washington Post, Dec. 28, 20 [(37-9192- 72bal b223670 6 82 FR 61703 at 617104 7 8] FR 25887 8 ?Well Control Rule,? Bureau OfSrifefy and Environmental 9 ?Proposed Well Control Rule Fact Sheet,? Bureau oqufety and Euvu'onmenta! Eiy?Orcemenl. One example of this, which appears in the Production Safety Systems Proposed Rule as well, is the proposal to formalize in regulation the ability for companies to report equipment and BOP failures to instead of BSEE. was originally designed to be an optional reporting system for near-misses, not an alternative and anonymous repository for information that should be submitted directly to BSEE. Companies are currently required by regulation to submit SPPE and BOP failure reports to BSEE. Although BSEE has a memorandum of understanding with the Bureau of Transportation Statistics (BTS) allowing companies to submit those failure reports directly through the existing regulation appears to provide more authority to BSEE to obtain the full reports on its own. Effectively writing into regulation for the expressly stated purpose of shielding companies from unwanted public disclosure, reduces authority, eliminates transparency, and, by hiding which companies may have inadequate maintenance or operational procedures, harms efforts to develop a risk?based inspection system. As part of our oversight reSponsibilities as Ranking Members of the House Natural Resources Committee and the Energy and Mineral Resources Subcommittee, we ask you to answer the following questions at the earliest opportunity: 1) Please provide all correspondence between personnel in the Immediate Of?ce of the Secretary and the Bureau of Safety and Environmental Enforcement between January 20, 2017, and December 29, 2017, regarding the decision to propose changes to the Production Safety Systems Rule and the Well Control Rule. 2) Please provide all correspondence between personnel in the of?ce of the Assistant Secretary for Land and Minerals Management and the Bureau of Safety and Environmental Enforcement between January 20, 2017, and December 29, 2017, regarding the decision to propose changes to the Production Safety Systems Rule and the Well Control Rule. 3) Please provide all correspondence between the Bureau of Safety and Environmental Enforcement, the of?ce of the Assistant Secretary of Land and Minerals Management, and the Immediate Of?ce of the Secretary with the American Petroleum Institute and the National Ocean Industries Association between January 20, 2017, and December 29, 2017 regarding the decision to propose changes to the Production Safety Systems Rule and the Well Control Rule. 4) Please provide all correspondence between the Bureau of Safety and Environmental Enforcement, the of?ce of the Assistant Secretary of Land and Minerals Management, and the Immediate Of?ce of the Secretary with the American Petroleum Institute and the National Ocean Industries Association between January 20, 2017, and December 29, 2017, regarding the de?nition of Best Available and Safest Technology and any proposed modi?cations of that de?nition. 5) Please provide all correspondence between the Bureau of Safety and Environmental Enforcement, the of?ce of the Assistant Secretary of Land and Minerals Management, and the Immediate Of?ce of the Secretary with the American Petroleum Institute and the National Ocean Industries Association between January 20, 2017, and December 29, 2017, regarding 6) Please provide all instances since publication of the 2016 Well Control rule where an operator was required to complete a blowout prevention failure investigation and analysis within 120 days and was not able to complete the review in the required time, and how BSEE accommodated those circumstances. 7) All non-correspondence documents related to the decision to propose changes to the Production Safety Systems Rule and the Well Control Rule, including but not limited to schedules, meeting minutes, and phone logs. Thank you for your attention to this request. Sincerely, mt WW Raul M. Grijalva Alan Lowenthal Ranking Member Ranking Member House Committee on Natu a1 Resources House Subcommittee on Energy and Mineral Resources ?nittd 5mm; Ewrnatr WASHINGTON. DC 20510 February 21, 2018 The Honorable Ryan Zinke Secretary Department of the Interior 1849 Street, NW Washington DC. 20240 Dear Secretary Zinke: On December 7, 2017, the Bureau of Safety and Environmental Enforcement (BSEE) ordered the National Academies of Sciences, Engineering, and Medicine (NAS) to stop its work on a study ordered by the agency in 2016. The 21-month study by the NAS would evaluate and make recommendations to the BSEE on its inspection program for offshore oil and gas development, including how best to minimize risks associated with these drilling operations. At the time of the cancellation, BSEE had already spent $100,000 on the study. The NAS had formed a committee of experts, held its ?rst meeting, and started planning its second study meeting. BSEE did not give a cause or explanation for stopping this study. As senators representing coastal states, we are acutely aware of the threats offshore drilling can pose to ocean and coastal wildlife, habitats, and communities. The 2010 Deepwater Horizon oil spill demonstrated how devastating a leak can be from an improperly inspected and managed offshore rig. In the months following the spill, we learned the Deepwater Horizon rig had missed a third of its required federal inspections in the 28 months prior to the disaster}ll Eleven people lost their lives, 3-4 million barrels of oil spilled into the ocean, around 1,300 miles of the Gulf shoreline were oiled, and the Gulf of Mexico?s commercial fishing industry lost upwards of $1.6 billion in sales and salary!? The administration?s January 4, 2018 announcement that it would open up additional areas of our coasts to drilling makes it more important than ever that the federal government is using best practices to monitor the safety of these rigs. BSEE has been criticized in the past for failing to make signi?cant progress in improving its safety and environmental stewardship programs. Last March, the Government Accountability Office (GAO) released a performance audit report, ?Oil and Gas Management: Stronger Leadership Commitment Needed at Interior to Improve Offshore Oversight and lntemal Management," which noted that ?since 2013, BSEE leadership has started several key strategic initiatives to improve its internal management, but none have been successfully Among the failed safety initiatives, the GAO Found that has not successfully implemented supplemental risk-based inspection capability in the 5 years since taking over the initiative from BSEE should continue its efforts to respond to concerns and improve its inspection program. This should include soliciting impartial input from the experts through the ?1 http: 20 12 l3] v.3. .cao. ugv- (18385;,pdf NAS. sudden cancellation of this review does not instill con?dence as the administration tries to broaden offshore drilling opportunities. The stop-work order submitted by BSEE allows for the restart of the work within 90 days of its issuance. We urge BSEE to authorize the NAS to complete the study immediately. Please do not hesitate to contact our staffs to discuss this matter further. ff Sincerely, 43mgdon Whitehouse Ron Wyden 2 United States Senator United States Senator am 6 Thomas R. Carper Margar ood Hassan United States Senator United States Senator -. Richard Blu El abeth Warren menthal ted States Senator United States Senator ?enjamin L. Cardin 'Robert Menendez United States Senator United States Senator Kirsten Gillibrand at?! Reed United States Senator 1 States Senator I. Charles E. Sehumer Christopher A. Coons United States Senator United States Senator hris Van Hollen A. Booker United States Senator United States Senator Wala D. Harris UDianne Feinstein United States Senator uUnited States Senator Edward Mag): 3% Jeanne Shaheen United States Senator United States Senatm Mazie KgHirono United States Senator The Honorable Ryan Zinke US Secretary of the Interior Department of the Interior 1849 C Street NW Washington, DC 20240 Dear Secretary Zinke, As a united group of 227 state legislators representing 17 coastal states, we are writing to you to oppose the Proposed National Outer Continental Shelf Oil and Gas Leasing Program for 2019-2024 (Proposed Leasing Program). This proposal seeks to exponentially expand oil and gas exploration, production, and drilling in the Atlantic Ocean, Pacific Ocean, and Gulf of Mexico, which for many of us, represents the first time in decades our coasts would be exposed to such development. While these oil and gas reserves are technically recoverable, we urge you to consider the repercussions, as you have done so in Florida, to local and regional economies and ecosystems. We are encouraged by your recent action to remove Florida’s coasts from the Proposed Leasing Program, a decision based on potential threats that offshore drilling would impose on coastal tourism, the recreational economy, and the hundreds of thousands of jobs that depend upon it. Given that one state has been removed from the program, we strongly urge you to grant other states the same opportunity to protect their economy and coastal and marine resources. Coastal tourism, fisheries, shipping, and defense are not only critical economic drivers in Florida, but are the underpinning of all U.S. coastal states. NOAA reports that coastal communities alone provide 45 percent of our nation’s gross domestic product. Furthermore, California, Oregon, and Washington combined represent the fifth largest economy in the world, a level of prosperity that would not be achieved without their ocean-dependent industries. It is clear that U.S. coastlines are a fundamental part of the nation’s economic activity and would be threatened by the offshore drilling plan. Offshore exploration, construction, and drilling can damage marine habitats and injure or kill the animals in the surrounding area through direct impact and altering of light and sound environments. The significant impacts associated with offshore oil and gas development pale in comparison to the impacts associate with those of oil spills. Examples from across the country highlight the irreparable damage infringed upon coastal communities and ecosystems due to these accidents. After the Exxon Valdez oil tanker crashed in Alaska’s Prince William Sound in 1989, 11 million gallons of oil spilled NOAA https://toolkit.climate.gov/topics/marine/fisheries-and-coastal-communities TIME Magazine http://time.com/3748246/exxon-valdez-history/ 3 Columbia University http://bit.ly/2rlf3vh 4 TIME Magazine http://content.time.com/time/health/article/0,8599,1986323,00.html 1 2 and polluted over 1000 miles of coastline. This spill decimated the environment, killing thousands of salmon, otters, and eagles, as well as a quarter of a million seabirds 2. In 2005, Hurricane Katrina caused over 40 spills and 8 million gallons of expelled oil. One of the most significant accidents during the hurricane was the Murphy Oil Refinery spill, which released over 1 million gallons of oil, contaminating flood waters and harming over 1000 adjacent homes 3. The 2010 Deepwater Horizon spill in the Gulf of Mexico alone – which resulted in 210 million gallons of oil entering the Gulf and caused billions of dollars in damage to local fisheries and tourism industries 4– provides ample evidence that accidents can and do happen. As these examples highlight, no amount of planning or resources could fully mitigate the harm done to animals, fisheries, tourism, and the economy in the event of an accident. However, the probability of these spills occurring only increases if U.S. coastlines are opened to offshore drilling under the Proposed Leasing Program. The Proposed Leasing Program claims that these new oil and gas projects will create jobs and bolster the U.S. economy, but with the risk of spills, and the threats of exploration and production alone, the Program will ultimately hurt coastal economies’, and that of their entire states, more than it will benefit them. Our coastlines serve as a significant economic driver that is entirely dependent upon healthy marine life and coastal ecosystems. Not only will offshore drilling hurt state economies, but this construction would also negatively affect diverse ecosystems and fishing and shipping sectors. Considering this threat to coastal ecosystems and economies, we oppose the Proposed Leasing Program and urge you to at least grant all coastal states with the opportunity to opt out of these leases. We are heartened by your exemption of Florida and hope you take our request into consideration. Thank you for your time. Sincerely, Senator Kevin Ranker Washington Senator Kevin de León California Assemblyman Thomas Abinanti New York Senator Ricardo Lara California Representative John Ager North Carolina Senator Susan Lee Maryland Senator Ben Allen California Representative Chris Lee Hawaii Representative Sherry Appleton Washington Representative Matthew Lesser Connecticut Representative David Arconti Connecticut Delegate Robbyn Lewis Maryland Representative John Autry North Carolina Senator Lynwood Lewis Virginia Representative Phil Barnhart Oregon Delegate Karen Lewis Young Maryland Chairman Kumar Barve Maryland Delegate Brooke Lierman Maryland Representative Paul Baumbach Delaware Assemblywoman Barbara Lifton New York Representative Mary Belk North Carolina Representative Matthew LoPresti Hawaii Senator Shenna Bellows Maine Representative Nicole Lowen Hawaii Assemblyman Daniel Benson New Jersey Delegate Eric Luedtke Maryland Representative Jennifer Benson Massachusetts Representative Nicole Macri Washington Representative Lori Berman Florida Senator Richard Madaleno, Jr. Maryland Representative Seth Berry Maine Representative Sheri Malstrom Oregon Senator Andy Billig Washington Senator James Manning Oregon Representative Deborah Boone Oregon Senator David Marsden Virginia Delegate Jennifer Boysko Virginia Representative Pam Marsh Oregon Senator Cathy Breen Maine Representative Grier Martin North Carolina Representative Cecil Brockman North Carolina Assemblymember Shelley Mayer New York Representative Robert Brown South Carolina Senator John McCoy Washington Assemblyman David Buchwald New York Assemblyman John McKeon New Jersey Representative Deb Butler North Carolina Representative Susan McLain Oregon Senator Jeanine Calkin Rhode Island Senator Jeremy McPike Virginia Senator Reuven Carlyle Washington Senator Rebecca Millett Maine Delegate Al Carr Maryland Senator Dave Miramant Maine Representative Lauren Carson Rhode Island Representative Howard Moffet New Hampshire Senator Stanley Chang Hawaii Senator William Monning California Representative Mike Chapman Washington Delegate David Moon Maryland Senator Maralyn Chase Washington Representative Marcia Morey North Carolina Representative Eileen Cody Washington Delegate Dan Morhaim Maryland Assemblyman Herb Conway New Jersey Senator Sharon Nelson Washington Representative Janice Cooper Maine Representative Rob Nosse Oregon Representative Richard Creagan Hawaii Assistant Speaker Felix Ortiz New York Senator Julian Cyr Massachusetts Representative Lillian Ortiz-Self Washington Senator Jeannie Dameille Washington Representative Tina Orwall Washington Representative Matthea Daughtry Maine Representative Ed Osienski Delaware Senator Michael Dembrow Oregon Assemblyman Anthony Palumbo New York Representative Michael Devin Maine Senator Guy Palumbo Washington Senator Manka Dhingra Washington Representative Jennifer Parker Maine Senator Patrick Diegnan New Jersey Retired Senator Fran Pavley California Assemblyman Jeffrey Dinowitz New York Representative Sarah Peake Washington Representative Laurie Dolan Washington Senator Jamie Pederson Washington Representative Susan Donovan Rhode Island Representative Strom Peterson Washington Representative Michelle DuBois Massachusetts Representative Teresa Pierce Maine Assemblymember Steve Englebright New York Senator Paul Pinsky Maryland Representative Paul Evans Oregon Delegate Andrew Platt Maryland Representative Julie Fahey Oregon Delegate Kenneth Plum Virginia Representative Jean Farmer-Butterfield North Carolina Representative Gerry Pollet Washington Representative Richard Farnsworth Maine Senator Nicole Poore Delaware Representative Jessica Fay Maine Representative Karin Power Oregon Representative Ryan Fecteau Maine Representative Denise Provost Massachusetts Representative Dylan Fernandes Massachusetts Senator Floyd Prozanski Oregon Representative Jake Fey Washington Representative Ellen Read New Hampshire Representative Susan Fisher North Carolina Delegate Kirill Reznik Maryland Representative Joe Fitzgibbon Washington Representative William Richardson North Carolina Delegate Robert Flanagan Maryland Senator Chuck Riley Oregon Representative Bob Foley Maine Representative June Robinson Washington Delegate David Fraser-Hidalgo Maryland Senator Christine Rolfes Washington Senator Lew Frederick Oregon Senator Jim Rosapepe Maryland Assemblymember Laura Friedman California Senator Russell Ruderman Hawaii Senator David Frockt Washington Honorable Rick Russman New Hampshire Delegate Barbara Frush Maryland Representative Cindy Ryu Washington Mike Gabbard Hawaii Representative Andrea Salinas Oregon Representative Cedric Gates Hawaii Senator Rebecca Saldana Washington Speaker Sara Gideon Maine Senator Adam Satchell Rhode Island Delegate Jim Gilchrist Maryland Representative John Schneck Maine Representative Rosa Gill North Carolina Representative Mike Sells Washington Senator Gayle Goldin Rhode Island Representative Tana Senn Washington Representative David Gomberg Oregon Representative Bryon Short Delaware Assemblywoman Lorena Gonzalez Fletcher California Senator Troy Singleton New Jersey Delegate Wendy Gooditis Virginia Senator Bob Smith New Jersey Representative Roger Goodman Washington Senator Will Smith Maryland Representative Chris Gorsek Oregon Representative Frank Smizik Massachusetts Assemblymember Richard Gottfried New York Delegate Ana Sol Gutierrez Maryland Representative Mia Gregerson Washington Representative Janeen Sollman Oregon Representative Marty Grohman Maine Representative Joseph Solomon Jr. Rhode Island Assemblymember Reed Gusciora New Jersey Representative Derek Stanford Washington Representative Patricia Haddad Massachusetts Delegate Dana Stein Maryland Representative Jim Handy Maine Senator Steiner Hayward Oregon Representative Edward Hanes North Carolina Senator Henry Stern California Representative Pricey Harrison North Carolina Assemblymember Mark Stone California Senator Bob Hasegawa Washington Senator Cynthia Stone Creem Massachusetts Delegate Anne Healey Maryland Delegate Rip Sullivan Virginia Representative Jonathan Hecht Massachusetts Senator Scott Surovell Virginia Representative Debra Heffernan Delaware Representative Roy Takumi Hawaii Senator Robert Hertzberg California Representative Gael Tarleton Washington Representative Natalie Higgins Massachusetts Representative Maureen Terry Maine Representative Paul Holvey Oregon Representative Steve Tharinger Washington Delegate Patrick Hope Virginia Senator Laura Thielen Hawaii Representative Brian Hubbell Maine Assemblyman Fred Thiele New York Senator Sam Hunt Washington Representative Cynthia Thielen Hawaii Representative Patty Hymanson Maine Representative Dawn Thomas Washington Representative Verla Insko North Carolina Assemblymember Phil Ting California Representative Kristin Jacobs Florida Representative Ryan Tipping Maine Representative Evan Jenne Florida Representative Carlos Tobon Rhode Island Representative Aaron Johanson Hawaii Representative Brian Turner North Carolina Representative Erik Jorgensen Maine Representative Javier Valdez Washington Representative Ruth Kagi Washington Senator Terry Van Duyn North Carolina Senator Karen Keiser Washington Senator Eloise Vitelli Maine Speaker Pro Tempore and Rep Brian Kennedy Rhode Island Delegate Jeff Waldstreicher Maryland Representative Alissa Keny-Guyer Oregon Representative Charlotte Warren Maine Representative Christine Kilduff Washington Senator David Watters New Hampshire Representative Shelley Kloba Washington Delegate Vivian Watts Virginia Delegate Kaye Kory Virginia Senator Bob Wieckowski California Representative John Kowalko Delaware Delegate Jheanelle Wilkins Maryland Delegate Ben Kramer Maryland Representative Kimberly Williams Delaware Senator Patty Kuderer Washington Representative Mike Woodard North Carolina Representative Walter Kumiega Maine Representative Sharon Wylie Washington Delegate Stephen Lafferty Maryland Delegate Pat Young Maryland Delegate Clarence Lam Maryland Representative Stanley Paige Zeigler Maine Senator Craig Zucker Maryland Crane Safety Assessment Findings, Results, and Recommendations Final Report Submitted to The Bureau of Safety and Environmental Enforcement (BSEE) Submitted by ABSG CONSULTING, INC. 1525 Wilson Blvd., Suite 625 Arlington, VA 22209 (703) 351-3700 Deliverable E: Final Report (Final) BPA Contract # E13PA00008 Task Order # E14PB00023 April 24, 2015 _u>mm Executive Summary The Bureau of Safety and Environmental Enforcement (BSEE) works to promote safety, protect the environment, and conserve natural resources on the Outer Continental Shelf (OCS) through vigorous regulatory oversight and enforcement. BSEE is responsible for enforcing the regulations found at 30 CFR 250.108 for cranes and material handling equipment installed on fixed platforms on the OCS. In addition to the 30 CFR 250 crane regulations, BSEE requires lessees and operators to comply with various industry standards incorporated by reference into regulation. Conversely, the United States Coast Guard (USCG) is responsible for safety of life on floating facilities operating on the OCS. The USCG crane and material handling certification and inspection strategy is promulgated in 46 C.F.R. §107.258 and 259. Crane inspections may be conducted by a USCG marine inspector or by one of two authorized thirdparty inspectors. On April 25, 2014, BSEE initiated the Crane Safety Assessment. The study involved analysis of cranes and material handling equipment operating on the OCS, analysis of BSEE lifting Potential Incidents of Noncompliance (PINCs) and incidents, review of industry standards and practices, and recommendations for changes to lifting regulation. The goal of this study was to develop an inspection methodology that may be used by BSEE and USCG personnel in performing an assessment in regards to the safety of cranes and material handling equipment. The team began by researching the population and attributes of cranes and material handling equipment operating on the OCS. Crane operators and service providers were consulted to provide information on the age, type, and population of cranes operating on the OCS. BSEE and USCG provided Government Furnished Information (GFI) such as lifting PINCS, records of OCS lifting incidents, and records of crane populations on the OCS to inform the study. Following the collection of information, the study team performed a statistical analysis on the population of cranes and material handling equipment operating on the OCS. The incident data supplied by BSEE through GFI was analyzed to identify failure event data, trends and key issues that could be addressed in the development of an improved offshore crane and material handling equipment inspection program. The study team reviewed the lifting PINCs and provided recommendations for improvement and consideration. Lifting standards, inspection methodologies and strategies were analyzed to identify best practices and provide ̤ζΨ̍̍̕ζ̎βΚ̲ϵ̨̎̕ π̤̕ ϶EEϳ̨ Ψ̨̎̕ϵβζ̤Κ̲ϵ̎̕ ϵ̎ ̲ϲζ ϵ̎Ψ̡̤̤̕̕Κ̲ϵ̎̕ ̕π ̲ϲζ̨ζ practices into an inspection strategy. BSEE stakeholders were consulted and engaged throughout the analysis phase of the study and provided interim feedback on the analysis results. The study team evaluated the findings of the incident analysis and applied their understanding of lifting standards and methodologies to develop interim recommendations. The USCG BSEE Memorandum of Understanding/Memorandum of Agreement (MOU MOA) was reviewed to inform the study of the responsibility each agency shared in the oversight of lifting equipment on the OCS. BSEE stakeholders were consulted to provide feedback on the interim recommendations drafted by the study team. Based on the information gathered and analysis conducted it is recommended that the future inspection strategy move away from a ̡̤ζ̨Ψ̤ϵ̡̲ϵ͘ζ ̍ζ̲ϲ̕β̇̕̕Ϩ͟ϭ ϶EEϳ̨ philosophy of strict regulatory compliance, and toward ensuring that operators create and comply with a robust Safety and Environmental Management System (SEMS) tailored for their facility. Crane Safety Assessment i Page The following recommendations are outlined in the report to produce a robust crane and material handling inspection program for offshore facilities which harmonizes with 30 C.F.R §250.108 and 30 C.F.R. §250.1913, et seq. and with the intentions of 46 C.F.R. §107.258 and 259:  Create database of offshore facilities having cranes subject to API Spec 2D, API RP 2D, and material handling equipment with capacities greater than 5 short tons subject to ASME B30.2.  Amend regulation 30 C.F.R. §250.108 for pedestal, overhead bridge, and gantry cranes.  Amend regulation 30 C.F.R. §250.108 for material handling.  Amend regulation 30 C.F.R. §250.198 to incorporate applicable ASME B30 series standards.  Amend PINCs to harmonize with the requirements of 30 C.F.R. §250.1900.  Train BSEE inspectors to become qualified crane and rigging inspectors as promulgated by API RP 2D and ASME B30 series standards, or audit crane inspection records performed by thirdparty qualified inspectors similar to the strategy adopted by the USCG in 46 C.F.R. §107.259.  Require drilling systems used on mobile offshore drilling units (MODUs) to be certified drilling systems (CDS) and inspected by the marine classification society that issued the CDS certificate.  Develop a formal training qualification program for BSEE inspectors in mechanical and electrohydraulic equipment fundamentals, hazard identification for machine safety.  Inspect or audit third-party inspections to ensure that the cranes and material handling equipment are designed, maintained, and operated in accordance with the standards promulgated by marine classification societies, API, or ASME as regulations promulgated by 30 C.F.R. 250.108 and 30 C.F.R. 250.1913 (d); The following recommendations for changes to 30 CFR 250.108 (a-e) are shown in red and proposed to improve worker safety while operating cranes installed on fixed OCS facilities. §250.108 What requirements must I follow for cranes and other material-handling equipment? (a) All pedestal cranes installed on fixed platforms must be operated in accordance with American Petroleum Institute's Recommended Practice for Operation and Maintenance of Offshore Cranes, API RP 2D (as incorporated by reference in § 250.198). (b) All cranes installed on fixed platforms must be equipped with a functional anti-two block device. (c) If a fixed platform is installed after March 17, 2003, all pedestal cranes on the platform must meet the requirements of American Petroleum Institute Specification for Offshore Pedestal Mounted Cranes, API Spec 2C (as incorporated by reference in §250.198). (d) All pedestal cranes manufactured after March 17, 2003, and installed on a fixed platform, must meet the requirements of API Spec 2C. (e) All overhead bridge cranes manufactured after 1 January 2016 and installed on a fixed platform must meet the requirements of CMMA Specification No. 70 ̌ Specifications for Electric Overhead Travelling Cranes (as incorporated by reference in §250.198). (f) All overhead bridge cranes installed on fixed platforms must be operated in accordance with the American Society of Mechanical Engineers (ASME) B30.2, Safety Standard for Overhead Bridge and Gantry Cranes (Top Running Bridge, Single or Multiple Girder, Top Running Trolley Hoist) or ASME B30.17 Safety Standard for Overhead Bridge and Gantry Cranes (Top Running Bridge, Single Girder, Underhung Hoist), as applicable to the type of crane, (as incorporated by reference in §250.198). Required frequent and periodic inspections (other than daily or operational Crane Safety Assessment ii Page inspections) of overhead bridge cranes shall be performed by a qualified crane inspector designated by the crane manufacturer or certified in accordance with the requirements of the National Commission for the Certification of Crane Operators (NCCCO). (g) All operators of overhead bridge cranes greater than 5 tons must be certified in accordance with the requirements of the National Commission for the Certification of Crane Operators (NCCCO). Rigging of loads greater than 5 tons shall be conducted by personnel certified in accordance with API RP 2D or certified in accordance with the NCCCO requirements for Rigger I for loads up to 15 tons and Rigger II for loads over 15 tons. (h) All crane owners or operators on fixed platforms must have a crane operations safety policy that differentiates between routine, critical and engineered lifts. Routine lifts are those not designated as critical or engineered lifts. Critical lifts are those where the failure or loss of load control could result in loss of life, major structural damage to facilities or equipment, or large environmental release. Some factors, but not all factors, that may be used to determine a critical lift are:  When a load is lifted over or near operating equipment or safety areas designated by a dropped object study;  When two or more pieces of lifting equipment are required to work in unison, including trolleys installed on the same bridge;  When special lifting equipment such as non-standard crane configurations or purpose built, one-off lifting appurtenances will be used;  The weight of the load exceeds set limits such as 20 tons;  ϼϲζ ͙ζϵϨϲ̲ ̕π ̲ϲζ ̇̕Κβ ζ͞Ψζζβ̨ ϳϱ ̡ζ̤Ψζ̲̎ ̕π ̲ϲζ Ψ̤Κ̎ζϳ̨ ̤Κ̲ζβ ΨΚ̡ΚΨϵ̲͟Ϯ ̤̕  When making personnel transfers. Engineered lifts are those that exceed the rated capacity of the crane at the required lifting angle (not to include load testing requirements in API Spec 2C). Engineered lifts are so exceptional that there shall be increased inspection requirements to be met prior to operation. For engineered lifts, the crane shall be inspected by the crane manufacturer or a qualified third-party inspector in accordance with API Spec 2D annual inspection requirements not more than two days prior to the lift. Any deterioration or defects found by that shall be considered in design calculations to support the lift. The crane shall also be inspected by the crane manufacturer or a qualified third-party in accordance with annual inspection requirements, including and non-destructive testing required by the manufacturer, after the engineered lift is completed and prior to release for use in normal operations. A record of the engineered lift, including supporting calculations, inspections, weights, and all distances moved, shall maintained in accordance with (i) (2) below. (i) You must maintain records specific to a crane or the operation of a crane installed on an OCS fixed platform, as follows: (1) Retain all design and construction records, including installation records for any anti-two block safety devices, for the life of the crane. The records must be kept at the OCS fixed platform. (2) Retain all inspection, testing, and maintenance records of cranes for at least 4 years. The records must be kept at the OCS fixed platform. (3) Retain the qualification records of the crane operator and all rigger personnel for at least 4 years. The records must be kept at the OCS fixed platform. Crane Safety Assessment iii Page The following recommendations for changes to 30 CFR 250.108 (f) are shown in red and proposed to improve worker safety while operating material handling equipment installed on fixed OCS facilities. §250.108 What requirements must I follow for cranes and other material-handling equipment? (j) You must operate and maintain all other material-handling equipment in a manner that ensures safe operations and prevents pollution. (1) All winches, including, but not limited to, wireline winches, pneumatic and hydraulic line tuggers, electric, pneumatic and hydraulic planetary gear hoists and winches, electromechanical and umbilical winches, man-riding winches, or any other power-driven drum devices shall be designed, operated and maintained in accordance with ASME B30.7, Winches (as incorporated by reference in §250.198). (2) All slings shall be operated and maintained in accordance with ASME B30.9, Slings, which is incorporated by reference in API RP 2D Section 5.2.1 (as incorporated by reference in §250.198). (3) All hooks shall be operated and maintained in accordance with ASME B30.10, Hooks (as incorporated by reference in §250.198). (4) All monorails and underhung cranes shall be operated and maintained in accordance with ASME B30.11, Monorails and Underhung Cranes (as incorporated by reference in §250.198). (5) All overhead hoists shall be operated and maintained in accordance with ASME B30.16, Overhead Hoists (as incorporated by reference in §250.198). (6) All below-the-hook lifting devices, including, but not limited to, structural, mechanical, vacuum, close-proximity lifting magnets, plate clamps, or any other device or appurtenance used for attaching a load to a hoist, shall be operated and maintained in accordance with ASME B30.20, Below-the-Hook Lifting Devices (as incorporated by reference in §250.198). Moreover, all below̌the-hook lifting devices, including, but not limited to, spreader bars and frames, pad eyes, attachment points, and all other lifting appurtenances shall be designed in accordance with ASME BHT-1, Below-the-Hook Lifting Devices (as incorporated by reference in §250.198). (7) All ratchet and pawl and friction brake type lever chain, rope, and web strap hoists (comea-long) used for lifting, pulling, and tensioning applications shall be operated and maintained in accordance with ASME B30.21, Lever Hoists (as incorporated by reference in §250.198). (8) All detachable rigging hardware used for load-handling activities, including but not limited to, shackles, links, rings, swivels, turnbuckles, eyebolts, hoist rings, wire rope clips, wedge sockets, rigging blocks, and load-indicating devices, shall be operated and maintained in accordance with ASME B30.26, Rigging Hardware (as incorporated by reference in §250.198). (9) All loads suspended from rotorcraft-helicopters shall be conducted in accordance with Federal Air Regulation 14 C.F.R. Part 133 and ASME B30.12, Handling Loads Suspended from Rotorcraft (as incorporated by reference in §250.198). Personnel rigging external loads must have specialized training in helicopter external load operations. (10) Rigging of loads greater than 5 tons shall be conducted by personnel certified in accordance with API RP 2D or certified in accordance with the NCCCO requirements for Rigger I for loads up to 15 tons and Rigger II for loads over 15 tons. (11) All specialty material handling equipment, including, but not limited to, bails, BOP/LMRP service cranes and transporters, crown and traveling blocks, deadline anchors, drilling derricks or masts, draw works, drill floor manipulator arms, drilling elevators, riser handling systems and carts, iron roughnecks, kelly drives, top drives, riser spiders, rotary tables, and drill Crane Safety Assessment iv Page ̨͙ϵ͘ζ̨̇ϭ ̨ϲΚ̇̇ Χζ ̡̕ζ̤Κ̲ζβ Κ̎β ̍Κϵ̲̎Κϵ̎ζβ ϵ̎ ΚΨΨ̤̕βΚ̎Ψζ ͙ϵ̲ϲ ̲ϲζ ̍Κ͍̎πΚΨ̲͍̤ζ̤ϳ̨ recommendation and instructions. Such recommendations and instructions shall be supported by a Failure Modes, Effects and Criticality Analysis (FMECA) in accordance with generally accepted engineering practices to verify the required inspection and maintenance schedules for the service intended. Design and installation of specialty material handling equipment should consider ASTM F1166, Human Engineering Design for Marine Systems, Equipment and Facilities. All specialty material handling equipment shall also be subjected to a task analysis and job safety analysis by a qualified human factors or safety professional to ensure safe operation. Moreover, all specialty material handling equipment shall be installed, operated, and maintained to ensure that inadvertent leaks or spills of operating fluids do not result in an environmental release. (k) All owners or operators on fixed platforms shall have a safety policy and procedures that cover all material handling equipment. (l) All required maintenance on material handling equipment shall be performed by a qualified maintenance or service personnel. All required inspections shall be performed by a qualified inspector or third-party inspection service. A qualified person is one who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training and experience, has successfully demonstrated their ability to inspect, diagnose and troubleshoot faults, and service or repair the specific equipment. (m) You must maintain records specific to the material handling equipment installed on an OCS fixed platform, as follows: (1) Retain all design and construction records, including installation records for any specialty material handling equipment for the life of the equipment. The records must be kept at the OCS fixed platform. (2) Retain any required operator or daily inspection records for a period of not less than 90 days. The records must be kept at the OCS fixed platforms. (3) Retain all frequent and periodic inspection and testing records for all material handling equipment for at least 4 years. The records must be kept at the OCS fixed platform. (4) Retain the qualification records of all material handling maintenance, inspection, and all rigger personnel for at least 4 years. The records must be kept at the OCS fixed platform. Crane Safety Assessment v Page Table of Contents Executive Summary........................................................................................................................................ i 1 Introduction .................................................................................................................................... 11 2 Methodology................................................................................................................................... 11 3 Crane Assessment ........................................................................................................................... 13 3.1 Assumptions and Limitations ...................................................................................................... 13 3.2 Crane Analysis ............................................................................................................................. 14 3.3 Observations ............................................................................................................................... 22 4 Material Handling Equipment Assessment ..................................................................................... 22 4.1 Analysis ....................................................................................................................................... 24 4.1.1 Certified Drilling System (CDS) Equipment ......................................................................... 24 4.1.2 Hoisting, Lifting, Rotating and Handling Systems ............................................................... 25 4.1.3 Auxiliary Hoisting and Material Handling Equipment ......................................................... 27 4.1.4 BSEE I-190 PINC for Material Handling Equipment............................................................. 28 5 Analysis of Lifting PINCs, INCs, and OIRs......................................................................................... 30 5.1 PINC Analysis ............................................................................................................................... 32 5.1.1 Discussion and Analysis....................................................................................................... 57 5.1.2 Conclusion and Recommendations..................................................................................... 60 5.1.3 Updated PINCs .................................................................................................................... 61 5.2 Analysis of INCs and OIRs ............................................................................................................ 61 5.2.1 Results ................................................................................................................................. 62 5.2.2 Conclusion and Recommendations..................................................................................... 73 6 Analysis of Industry Standards ........................................................................................................ 74 6.1 Domestic and International Inspection Methodologies ............................................................. 74 6.1.1 Comparison of Existing Inspection Methodologies ............................................................ 74 6.1.2 Inspection Authority Delegated to Third Parties ................................................................ 81 6.2 API Specification 2C .................................................................................................................... 84 6.2.1 Analysis ............................................................................................................................... 85 6.2.2 Inspection............................................................................................................................ 86 6.2.3 Other Standards .................................................................................................................. 87 6.3 API Recommended Practice 2D .................................................................................................. 90 6.3.1 Analysis ............................................................................................................................... 90 6.3.2 Inspection............................................................................................................................ 92 6.3.3 Conclusion and Recommendations..................................................................................... 93 6.4 ISO Crane Inspection Standards and Regulatory Guidelines ...................................................... 95 6.4.1 Analysis ............................................................................................................................... 95 6.4.2 Conclusion and Recommendations................................................................................... 100 6.5 ASME B30 Standards ................................................................................................................. 100 6.5.1 B30.2: Overhead and Gantry Cranes................................................................................. 101 6.5.2 B30.4: Portal and Pedestal Cranes .................................................................................... 106 6.5.3 B30.7: Winches ................................................................................................................. 110 Crane Safety Assessment vi Page 6.5.4 B30.8: Floating Cranes and Floating Derricks ................................................................... 112 6.5.5 B30.9: Slings ...................................................................................................................... 114 6.5.6 B30.10: Hooks ................................................................................................................... 120 6.5.7 B30.16: Overhead Hoists................................................................................................... 122 6.5.8 B30.20: Below-the-Hook Lifting Devices ........................................................................... 126 6.5.9 B30.21: Lever Hoists.......................................................................................................... 131 6.5.10 B30.24: Container Cranes ................................................................................................. 133 6.5.11 Additional B30 Standards for Consideration .................................................................... 135 7 USCG MOU/MOA Review ............................................................................................................. 140 7.2 USCG MODU Requirements ...................................................................................................... 141 8 Recommendations ........................................................................................................................ 142 8.1 Cranes Regulatory Changes ...................................................................................................... 142 8.2 Material Handling Equipment Improvement ............................................................................ 144 8.3 Lifting Inspection Strategy ........................................................................................................ 147 8.3.1 Staff Augmentation ........................................................................................................... 148 8.3.2 Develop a Communication Strategy ................................................................................. 148 8.3.3 Metric Reporting and Data Collection .............................................................................. 149 8.4 Program Related Recommendations ........................................................................................ 150 8.4.1 Harmonize Various PINC Initiatives .................................................................................. 150 8.4.2 Staff Retention .................................................................................................................. 150 8.4.3 Standards Development Organization Outreach .............................................................. 150 Appendix A. Revised PINCs ........................................................................................................................... A Crane Safety Assessment vii Page List of Tables Table 1: OCS Cranes by Mount Type and Capacity ..................................................................................... 15 Table 2: Descriptive Statistics of the Frequency Distribution ..................................................................... 16 Table 3: Descriptive Statistics of the Trimmed Frequency Distribution ..................................................... 16 Table 4: OCS Cranes by Boom Type ............................................................................................................ 17 Table 5: OCS Cranes by Manufacturer/Service Provider ............................................................................ 18 Table 6: Average Crane Age by Mount and Boom Type ............................................................................. 19 Table 7: Descriptive Statistics of the Age Frequency Distribution .............................................................. 20 Table 8: OCS Cranes Average Off-Board Lift Capacities by Mount and Boom Type ................................... 20 Table 9: Descriptive Statistics of the Age Frequency Distribution .............................................................. 21 Table 10: Scope of Material Handling Equipment Analysis ........................................................................ 23 Table 11: Recommendations for Changes to PINCs.................................................................................... 32 Table 12: Lifting Incident Type .................................................................................................................... 63 Table 13: Failure Cause ............................................................................................................................... 64 Table 14: Lifting Device that Failed ............................................................................................................. 65 Table 15: Type of Lifting Failure .................................................................................................................. 66 Table 16: Type of Lift................................................................................................................................... 67 Table 17: Type of Facility ............................................................................................................................ 68 Table 18: Activity at Time of Incident ......................................................................................................... 69 Table 19: Location of Incident..................................................................................................................... 70 Table 20: Injury to Whom ........................................................................................................................... 71 Table 21: Contributing Factor to Failure ..................................................................................................... 72 Table 22: B30 Standards and Topics ........................................................................................................... 87 Table 23: ISO Standards Related to Crane Inspections ............................................................................... 96 Table 24: ASME Crane and Material Handling Standards ......................................................................... 101 Table 25: Recommended Crane Regulatory Changes ............................................................................... 142 Table 26: Recommended Material Handling Equipment Regulatory Changes......................................... 145 Crane Safety Assessment viii Page List of Figures Figure 1: Assessment Methodology............................................................................................................ 12 Figure 2: Formula for Minimum Sample Size .............................................................................................. 14 Figure 3: Frequency Distribution of Capacities ........................................................................................... 15 Figure 4: Frequency of Distribution Capacities ........................................................................................... 16 Figure 5: Frequency Distribution of Crane Ages (Years) ............................................................................. 19 Figure 6: Frequency of Off-board Lift Capacities (mT) at 25 ft Radius........................................................ 21 Figure 7: Sample I PINC ............................................................................................................................... 75 Figure 8: Sample Z PINC .............................................................................................................................. 79 Figure 9: CG Form 5432 .............................................................................................................................. 80 Figure 11: NRC Inspection Manual.............................................................................................................. 84 Figure 12: Inspection-related gap analysis results concerning elements .................................................. 89 Figure 13: Overhead Crane ....................................................................................................................... 101 Figure 14: Gantry Crane ............................................................................................................................ 102 Figure 15: Pedestal Crane ......................................................................................................................... 107 Figure 16: Portal Crane ............................................................................................................................. 107 Figure 17: Comparison of Relevant B30 Series Standards ........................................................................ 109 Figure 18: Single-Drum Winch .................................................................................................................. 111 Figure 19: Three-Drum Winch with Attached Swinger ............................................................................. 111 Figure 20: Floating Crane .......................................................................................................................... 112 Figure 21: Floating Derrick ........................................................................................................................ 112 Figure 22: Issues to Consider when Assessing Operating List and Trim ................................................... 113 Figure 23: Various Alloy Steel Chains ........................................................................................................ 115 Figure 24: Rated Load for Grade 80 Alloy Steel Chain Slings ̎ Vertical, Basket, and Bridle Hitches ...... 116 Figure 25: Braided Eye-and-Eye Wire Rope Sling ..................................................................................... 117 Figure 26: Wire Mesh Sling ....................................................................................................................... 118 Figure 27: Synthetic Rope Slings ............................................................................................................... 118 Figure 28: Synthetic Webbing Slings ......................................................................................................... 119 Figure 29: Synthetic Round Slings ............................................................................................................. 120 Figure 30: Base-Supporting Hooks ............................................................................................................ 121 Figure 31: Hooks that Do Not Support Direct Pull .................................................................................... 122 Figure 32: Hand-Operated Chain Hoists ................................................................................................... 123 Figure 33: Electrical-Powered Chain Hoist ................................................................................................ 123 Figure 34: Electric-Powered Wired Rope Hoist......................................................................................... 124 Figure 35: Air-Powered Wire Rope Hoist .................................................................................................. 124 Figure 36: Pressure-Gripping Lifters ......................................................................................................... 126 Figure 37: Vacuum Lifters ......................................................................................................................... 127 Figure 38: Magnetic Lifters ....................................................................................................................... 128 Figure 39: Scrap and Material Handling Grapples .................................................................................... 129 Figure 40: Load Controlling Ratchet and Pawl Type Mechanisms ............................................................ 131 Figure 41: Rope Lever Hoists..................................................................................................................... 132 Crane Safety Assessment ix Page Figure 42: Web Strap Lever Hoists ............................................................................................................ 132 Figure 43: Rubber Tired Container Cranes................................................................................................ 133 Figure 44: Rail Mounted Container Cranes ............................................................................................... 134 Figure 45: Monorail Crane with Underhung Hoist .................................................................................... 136 Figure 46: Shackles.................................................................................................................................... 138 Figure 47: Turnbuckles #1 ......................................................................................................................... 138 Figure 48: Eyebolts .................................................................................................................................... 139 Figure 49: Eyenuts..................................................................................................................................... 139 Figure 50: Swivel Hoist Rings .................................................................................................................... 139 Figure 51: Rigging Blocks........................................................................................................................... 140 Figure 52: 30 CFR 250.108 - Crane Regulatory Language ......................................................................... 142 Figure 53: 30 CFR 250.108(f) ̌ Material Handling Equipment Regulatory Language .............................. 144 Figure 54: PINC I190 .................................................................................................................................. 145 Crane Safety Assessment x Page 1 Introduction The Bureau of Safety and Environmental Enforcement (BSEE) is responsible for the oversight of exploration, development, and production operations for oil and natural gas on the Outer Continental ϶ϲζ̇π ̖O ϶̗ϰ ϶EEϳ̨ ̤ζϨ͍̇Κ̲ϵ̎̕ Κ̎β ̕͘ζ̨̤ϵϨϲ̲ ̕π Fζβζ̤Κ̇ ̕ππ̨ϲ̤̕ζ ̤ζ̨͍̤̕Ψζ̨ ζ̨͍̤̎ζ̨ ̲ϲΚ̲ ζ̎ζ̤Ϩ͟ development on the OCS is done in a safe and environmentally responsible manner. The functions of BSEE include oil and gas permitting, facility inspections, regulations and standards development, safety research, data collection technology assessments, field operations, incident investigation, environmental compliance and enforcement, oil spill prevention and readiness, review of operator oil spill response plans, oversight of production and development plans, and resource conservation efforts.1 BSEE works to promote safety, protect the environment, and conserve natural resources on the OCS through vigorous regulatory oversight and enforcement. BSEE is responsible for enforcing the regulations found at 30 CFR 250.108 for cranes installed on fixed platforms on the OCS. In addition to the 30 CFR 250 crane regulations, BSEE requires lessees and operators to comply with various industry standards incorporated by reference into regulation. BSEE is also responsible for the oversight of material handling equipment located on fixed platforms. Conversely, the United States Coast Guard (USCG) is responsible for safety of life on floating facilities operating on the OCS. The USCG crane and material handling certification and inspection strategy is promulgated in 46 C.F.R. §107.258 and 259. Crane inspections may be conducted by a USCG marine inspector or by one of two authorized thirdparty inspectors. The USCG ensures compliance by auditing the results of third-party inspections or by ̤ζ̇͟ϵ̎Ϩ ̎̕ ϶EEϳ̨ ̨̡̡͍̤̲̕ ϵ̎ Ψ̎̕β͍Ψ̲ϵ̎Ϩ USCG mandated inspections in accordance with Z-PINC. On April 25, 2014, BSEE initiated the Crane Safety Assessment. The study involved analysis of cranes and material handling equipment operating on the OCS, analysis of BSEE lifting Potential Incidents of Noncompliance (PINCs) and incidents, review of industry standards and practices, and recommendations for changes to regulation. The goal of this study was to develop an inspection methodology that may be used by BSEE and USCG personnel in performing an assessment in regards to the safety of cranes and material handling equipment. This report contains the results of the assessment. The following sections describe the assessment methodology, findings, analysis, and ̤ζΨ̍̍̕ζ̎βΚ̲ϵ̨̎̕ π̤̕ ϶EEϳ̨ Ψ̨̎̕ϵβζ̤Κ̲ϵ̎̕ ϵ̎ ̲ϲζ βζ͘ζ̡̇̍̕ζ̲̎ ̕π Κ lifting inspection strategy. 2 Methodology To provide a recommendation for a lifting inspection strategy, the ABS Group Team, herein referred to as the study team, met with BSEE stakeholders to review the plan of action for accomplishing the tasks outlined in the Crane Safety Assessment. Figure 1 illustrates the assessment methodology for collecting 1 ϼϲζ ̀̎ϵ̲ζβ ϶̲Κ̲ζ̨ Dζ̡Κ̤̲̍ζ̲̎ ̕π ̲ϲζ I̲̎ζ̤ϵ̤̕ϭ ϲ ͍βϨζ̲ J̨͍̲ϵπϵΨΚ̲ϵ̨̎̕ Κ̎β Pζ̤π̤̍̕Κ̎Ψζ I̎π̤̍̕Κ̲ϵ̎̕ Fϵ̨ΨΚ̇ ̒ζΚ̤ Ϯ΄ϭϱ π̤̕ ̲ϲζ ͍̤ζΚ͍ ̕π ϶Κπζ̲͟ Κ̎β E̎͘ϵ̤̎̍̕ζ̲̎Κ̇ E̎π̤̕Ψζ̍ζ̲̎ϰϳ Rζ̲̤ϵζ͘ζβ π̤̍̕ ϶EEϰϨ̕͘ϯ https://www.bsee.gov/uploadedFiles/BSEE/About_BSEE/Budget/00000%20BSEE%20FY%202015%20Final%20Gree nbook%20File.pdf. (April 14, 2015). Crane Safety Assessment 11 Page information, conducting analysis, and evaluating the findings in order to provide recommendations for the development of an improved offshore crane and material handling equipment inspection program. Figure 1: Assessment Methodology The team began the study by researching the population and attributes of cranes and material handling equipment operating on the OCS. The study team collected open source information, which included ̡͍Χ̇ϵΨ̇͟ Κ͘Κϵ̇ΚΧ̇ζ ϵ̎π̤̍̕Κ̲ϵ̎̕ϭ ̨͍Ψϲ Κ̨ ̤̕ϵϨϵ̎Κ̇ ζ̣͍ϵ̡̍ζ̲̎ ̍Κ͍̎πΚΨ̲͍̤ζ̨̤ ̖OEM̗ β̤ϵ̇̇ϵ̎Ϩ Ψ̲̤̎̕ΚΨ̲̤̕ϳ̨ websites and ABS vessel information. ϶EEϳ̨ website was queried however no information specific to cranes or material handling located on a facility or vessel under its jurisdiction was identified. Next, crane operators and service providers were consulted to provide information on the age, type, and population of cranes operating on the OCS. The study team requested Government Furnished Information (GFI) such as lifting PINCS, records of OCS lifting incidents, and records of crane populations on the OCS to inform the study. BSEE provided limited data related to cranes by facility and material handling equipment operating on the OCS contained in the Technical Information Management System (TIMS) database. Following the collection of information, the study team performed a statistical analysis of the population of cranes and examined material handling equipment installed on existing OCS facilities and vessels under BSEE and USCG jurisdiction. The data was examined to: (1) identify equipment included in the scope of this study; (2) ensure relevancy to the scope; and (3) resolve issues of data quality and duplication. The incident data supplied by BSEE through GFI was analyzed to identify failure event data, Crane Safety Assessment 12 Page trends and key issues that could be addressed in the development of an improved offshore crane and material handling equipment inspection program. The study team reviewed the lifting PINCs and provided recommendations for improvement and consideration. Lifting standards, inspection methodologies and strategies were analyzed to identify best practices and provide recommendations π̤̕ ϶EEϳ̨ Ψ̨̎̕ϵβζ̤Κ̲ϵ̎̕ ϵ̎ ̲ϲζ ϵ̎Ψ̡̤̤̕̕Κ̲ϵ̎̕ ̕π ̲ϲζ̨ζ ̡̤ΚΨ̲ϵΨζ̨ ϵ̲̎̕ Κ̎ ϵ̨̡̎ζΨ̲ϵ̎̕ ̨̲̤Κ̲ζϨ͟ϰ BSEE stakeholders were consulted and engaged throughout the analysis phase of the study and provided interim feedback on the analysis results. The study team evaluated the findings of the incident analysis and applied their understanding of lifting standards and methodologies to develop interim recommendations. The USCG BSEE Memorandum of Understanding/Memorandum of Agreement (MOU MOA) was reviewed to inform the study of the responsibility each agency shared in the oversight of lifting equipment on the OCS. BSEE stakeholders were consulted to provide feedback on the interim recommendations drafted by the study team. Based upon the results of the study and the feedback received from BSEE stakeholders, the study team developed a lifting inspection strategy that recommended changes to crane regulations and improvements to material handling oversight. 3 Crane Assessment The study team analyzed cranes found on fixed and floating offshore facilities, floating production storage and offloading vessels (FPSOs), and mobile offshore drilling units (MODUs). Two offshore operators and one crane equipment contractor voluntarily provided crane information for assets they operated, owned or serviced. The majority of the data points collected from operators were for cranes located on fixed platforms while most of the data points extracted from publicly available sources were located on cranes on MODUs. The objectives of this effort were to (1) analyze the current population of cranes operating on the OCS, (2) perform statistical analyses to identify trends, and (3) identify the breadth and depth of crane types which will form part of the inspection program. The effort sought to identify potential safety issues that should be added to the crane inspection program. The following section summarizes the data gathered from publicly available information from original equipment manufacturers (OEMs), drilling contractors and OCS field operators. The availability of the data, limited the analysis to the current population of offshore facilities without regard for current operating location. The analysis focused on sorting and trending the data from 921 cranes to identify:  Generic crane types used on the OCS; and  Descriptive statistics concerning crane load ratings and ages. 3.1 Assumptions and Limitations The results are based on the following assumptions and limitations:  The raw data obtained from publicly available sources was assumed to be accurate and complete. When possible, the study team, attempted to correct identified data anomalies; and Crane Safety Assessment 13 Page  Duplicate data points were purged when verified as duplicates. Population sampling techniques were applied for the analyses because the actual crane population size was unknown. There was no publicly available data on the actual population size of cranes operating on the Gulf of Mexico (GOM) Region OCS. Based on guidance from BSEE stakeholders, the study team assumed a sample size of 5000 cranes operating in OCS. The number was based upon the data available on BSEEϳ̨ ͙ζΧ̨ϵ̲ζ ̨̲Κ̲ϵ̎Ϩ that there are approximately 2,500 active platforms in the GOM Region. The study team conservatively estimated that each platform had two cranes. Considering a crane population of 5000 cranes and a desired confidence level of 95%, the minimum desired crane sample size, 146, was determined with the following formula: 𝐍= 𝐧 𝟏+ , where n = 𝐧 𝐩𝐨𝐩𝐮𝐥𝐚𝐭𝐢𝐨𝐧 𝐙 𝟐 𝐱 𝐏(𝟏,𝐏) 𝐃𝟐 A sampling distribution size based on a 95% confidence interval repeatedly used to draw from the population tends to yield distribution means that fall within approximately two standard deviations of the sample mean. This prediction assumes that the sampling distribution is also normal. N = Sample size Z = Area of normal distribution corresponding to confidence level P = Expected value D = Confidence interval Population = 5000 Confidence Level/Value of Z Z = 1.96 90%/1.645 P = 0.5 95%/1.960 D = 0.08 99%/2.575 n = 150.06 99.9%/3.29 N = 146 Figure 2: Formula for Minimum Sample Size 3.2 Crane Analysis The study team collected data points on 921 cranes for the analysis. Table 1 provides the classification of the cranes organized by mount type. Out of the 921 crane units, 471 units did not provide information regarding mount type and, as a result, could not be classified. Crane Safety Assessment 14 Page Table 1: OCS Cranes by Mount Type and Capacity Data Source Mount Type King Post Swing Bearing Mount No Data Provided Operator 1 and Service Provider 32 Operator 2 Total 44 Public Source 24 247 103 - 350 120 141 210 471 100 Figure 3 shows the frequency distribution of crane capacities across 188 data points. The distribution bimodal has two commonly-occurring values and is slightly positively skewed by a small number of outliers. Based upon the statistical analysis, the most appropriate representative measure of the distribution is the arithmetic mean (70.3 mT). Approximately 75% of the cranes fall within one standard deviation of the arithmetic mean of crane capacities (i.e. 70.3 ± 31.9). Due to five outlier data points, which were more than two and a half standard deviations above the mean, the distribution was positively skewed. Figure 3: Frequency Distribution of Capacities Crane Safety Assessment 15 Page Table 2 below provides the descriptive statistics of the frequency distribution of capacity data for the cranes shown in Figure 3. This information was collected from publicly available sources. Table 2: Descriptive Statistics of the Frequency Distribution Statistical Term Capacity (mT) Mean Mode Median Minimum Maximum Range Standard Deviation Count 70.3 74.0 85.0 12.0 165 153 31.9 188 Figure 4 below shows the frequency distribution of capacities, in metric tons (mT), across 182 cranes. Note that the data is a subset of the data shown in Figure 3. Figure 4 shows the data from Figure 3 without the outliers mentioned above. Figure 4: Frequency of Distribution Capacities Descriptive statistics of the trimmed distribution from Figure 4 are listed in Table 3 below. Table 3: Descriptive Statistics of the Trimmed Frequency Distribution Statistical Term Capacity (mT) Mean Mode Median Minimum Maximum Crane Safety Assessment 67.2 85.0 71.0 12.0 136 16 Page Range Standard Deviation Count 124 27.3 182 Table 4 provides crane classification organized by boom type. Lattice booms represent 30% of the sample size and approximately 60% of the cranes operating on the OCS.2 This is an important observation to note, as lattice boom type cranes are maintenance intensive due to bolted construction, particularly in a corrosive environment. Table 4: OCS Cranes by Boom Type Data Source Boom Type Lattice Boom Fixed Length Box Boom Telescopic Box Boom Knuckle Boom No data provided 2 Operator 1 and Service Provider 187 Operator 2 Total 92 Public Source - 88 83 - 171 4 9 - 13 - - 71 71 120 104 163 387 279 Cranes data points that did not provide boom type data were excluded from this analysis in Table 4. Crane Safety Assessment 17 Page Table 5 provides the cranes by mount and boom type and is organized by manufacturer/ crane service provider. Table 5: OCS Cranes by Manufacturer/Service Provider Mount Type Boom Type Fixed Manufacturer/Crane Swing King Length Service Provider Bearing Post Box Lattice Telescopic Mount Mount Unknown Boom Boom Box Boom Unknown Gulf Crane Service 247 21 120 88 176 4 120 EBI 15 0 1 15 - - 1 NAUTILUS 71 10 21 62 15 9 16 UNIT-MARINER 6 7 35 6 39 - 3 AMERICAN-AERO 11 1 40 - 24 - 28 SEATRAX - 26 - - 14 - 12 COASTAL - - 2 - - - 2 EMC - - 1 - - - 1 HOUSTON-SYSTEMS - - 5 - - - 5 HYDRA CRANE - - 1 - - - 1 JOE STINE - - 3 - - - 3 LINKBELT - - 2 - - - 2 M&M - - 1 - - - 1 MANITEX - - 2 - - - 2 PEDESTAL - - 2 - - - 2 PMC - - 2 - - - 2 RH-ENTERPRISE - - 1 - - - 1 SMATCO - - 3 - - - 3 TITAN - - 17 - - - 17 WEATHERFORD - - 1 - - - 1 ENERGY CRANES - - 1 - - - 1 Crane Safety Assessment 18 Page Two operators provided data points that identified crane age. Table 6 provides average crane organized by mount and boom type. Crane age data was collected for total of 238 cranes.3 Table 6: Average Crane Age by Mount and Boom Type Crane Type Boom Type Fixed Swing King Length Bearing Post Box Lattice Telescopic Mount Mount Unknown Boom Boom Box Boom Unknown Average Age (Years) 22.6 24.3 27.7 23.6 28.2 20.4 24.7 Maximum Age (Years) 39.07 40.07 30.07 44.07 40.07 30.66 44.07 Minimum Age (Years) 4.07 8.49 19.07 4.07 4.07 8.82 4.07 Figure 5 shows the frequency distribution of the OCS crane ages sample across 238 cranes from the two operators who provided crane data. Figure 5: Frequency Distribution of Crane Ages (Years) 3 According to supporting information provided by GOM Region personnel, the average crane age is driven by the current regulation and API standard. Operators do not want to upgrade their cranes because of cost, and the current standards. The current standards require an operator to meet the requirements of API Spec 2C if a crane is manufactured after March 17, 2003, and installed on a fixed platform. Thus, the operator would prefer to keep Κ̎β ̍Κϵ̲̎Κϵ̎ ̲ϲζϵ̤ ̇̕βζ̤ Ψ̤Κ̎ζ ΧζΨΚ̨͍ζ Κ Ψ̤Κ̎ζ ̍Κ͍̎πΚΨ̲͍̤ζβ Χζπ̤̕ζ MΚ̤Ψϲ ϭϳϭ Ϯ΄΄ϯϭ β̕ζ̨̎ϳ̲ ϲΚ͘ζ ̲̕ ̍ζζ̲ !PI Spec 2C requirements. Crane Safety Assessment 19 Page The distribution shows that ages are fairly consistent with the exception of noticeable upward trends in the age range of 28 to 36. Consistent with this observation, approximately 55% of the cranes fall within the age group of 24 to 40 years; this is an important observation because old cranes require more careful and detailed inspection. Moreover, these cranes are more maintenance intensive due their oftfatigued critical components and due to extended exposure to particularly corrosive environments. Table 7 provides the descriptive statistics of the age distribution shown in Figure 5. Table 7: Descriptive Statistics of the Age Frequency Distribution Statistical Term Capacity (mT) Mean Mode Median Minimum Maximum Range Standard Deviation Count 24.7 35.1 26.5 4.0 44.1 40.1 10.1 238.0 Table 8 identifies average off-board lift capacities by mount and boom type. The off-board lift data was supplied by two operators. The majority of the cranes fall within the range of 1700 to 32000 LBS lift capacity. Table 8: OCS Cranes Average Off-Board Lift Capacities by Mount and Boom Type Crane Type Boom type Fixed Off board Lift Average Off board Lift - All Weights at 25 ft Radius ( Lbs) Maximum ̌ Off board Lift King Length Swing Bearing Mount Box Lattice Telescopic Mount unknown Boom Boom Box Boom Unknown 15167 17131 14462 13517 17174 13991 14663 103546 48000 42200 103546 61210 33759 70000 1727 1980 41593 1727 2732 2360 1980 Minimum ̌ Off board Lift Post Figure 6 provides frequency distribution of off-board lift capacities in mT across 238 cranes from the sample containing offshore operator data. Crane Safety Assessment 20 Page Figure 6: Frequency of Off-board Lift Capacities (mT) at 25 ft Radius Table 9 below provides descriptive statistics of the frequency distribution shown in Figure 6. Table 9: Descriptive Statistics of the Age Frequency Distribution Statistical Term Capacity (mT) Mean Mode Median Minimum Maximum Range Standard Deviation Count Crane Safety Assessment 10.86 5.22 8.61 0.78 73.65 72.86 11.69 238 21 Page 3.3 Observations The following observations should be considered:  The data obtained for the analysis were assumed to be accurate and complete within common industry practices. However, it is likely that some details included in the data set may contain inaccuracies.  The type and quality of the available data was inconsistent from operator to operator and from OEM to OEM.  Despite these limitations, the study team was still able to achieve a scientifically reasonable sample size that could be used with some confidence to characterize the offshore crane population. It should be noted here that inferences about the general population of cranes in the GOM Region offshore community are qualified by the lack of statistical normality in the distributions shown above. Inferences should be drawn with requisite caution.  Unfortunately, there is no universal repository of offshore crane location or capacity data. Data supplied by the crane inspection vendor, owner or operator included only limited capacity data which could be rationally analyzed. Therefore, the data only allowed for gross characterization by pedestal mount and boom type.  The most likely explanation for the bimodal nature of the capacity distribution is that the sample includes two distinct subpopulations of fixed platforms and MODUs. The former tend to have lower capacity cranes than the latter due to the weights of the routine lifts performed during their operations.  The upward trends in the crane age is coincides with the offshore oil boom between 1978 and 1986, which can clearly account for the increased number of cranes in this range.  The taper in the number of cranes at the higher end of the age distribution is likely due to both fatigue-life limits and lifecycles of fixed platform and MODU facilities. 4 Material Handling Equipment Assessment An assessment and analysis was performed of material handling equipment used on fixed and floating offshore facilities, FPSO and mobile offshore drilling units (MODU). This equipment includes, but is not limited to, the following types of lifting devices:        gin pole cranes man-riding hoists equipment-based hoists winches come-alongs BOP hoists riser carts Crane Safety Assessment  drill floor/derrick lifting equipment (Kelly drives, elevators, top drive systems)  below-the-hook (BTH) lifting devices  manual lifting device 22 Page The lifting equipment described in the call order varies in nomenclature and function. The purpose of reviewing material handling equipment for this study was to explore application of crane-like inspection methods and procedures to the subject equipment. Accordingly, the scope of the analysis was limited to material handling equipment with crane-like, or at least crane related, properties. Equipment βζ̲ζ̤̍ϵ̎ζβ ̲̕ Χζ ϶ϵ̎-̨Ψ̡̕ζϷ π̤̕ ̲ϲϵ̨ ̡̤́̕ζΨ̲ Κ̤ζ Ψ̕͘ζ̤ζβ ϵ̎ ̲ϲζ π͙̇̇̕̕ϵ̎Ϩ ̨̲Κ̎βΚ̤β̨ ̨ϲ͙̎̕ ϵ̎ Table 10.4  All equipment covered by ASME BTH-1-2011 and the ASME B30 series commonly used in the offshore industry (excluding vacuum, magnetic and grapple lifting devices);  !̇̇ ζ̣͍ϵ̡̍ζ̲̎ ̇ϵ̨̲ζβ Κ̨ ϶̍Κ̲ζ̤ϵΚ̇ ϲΚ̎β̇ϵ̎Ϩ ζ̣͍ϵ̡̍ζ̲̎Ϸ ϵ̎ ϶EE PINC I-190; and  Lifting equipment in ABS Guide for the Classification of Drilling Equipment 2012 (2012 CDS). Table 10: Scope of Material Handling Equipment Analysis In Scope* ASME BTH-1-2011 & B30 SERIES BSEE PINC I-190 ABS 2012 CDS Other Below the hook rigging and rigging hardware Below the hook rigging and rigging hardware Hooks Air hoists Riser running tool Hoists Riser spider (when used for lifting) Industrial rollers Tugger Crown block Slings Air tugger Traveling block Winches (lifting only) Supporting lifters Pressure gripping lifters Friction type lifters Winch (lifting only) Man-riding winch Deadline anchor Top drive Drawworks Drilling elevators Bails/links Air casters and pallets Balance lifting units Pad eyes Scissor lift Aerial manlift Floating cranes Overhead bridge cranes and hoists Stacker cranes Monorails Gantry crane Horizontal to Vertical (HTV) machine BOP crane Man Basket / ϶ ϵ̇̇͟ P͍ϨϲϷ Out of Scope Jacks Elevators (nondrilling) Vacuum lifting device Magnetic lifting device Grapple Mobile cranes Tower cranes 4 Only lifting equipment is considered (e.g. equipment that applies a vertical force to the top of an object) in this review. Material handling equipment which supports the object from underneath (scissor lift) or provides for horizontal translation (riser catwalk) was not considered during this review. Crane Safety Assessment 23 Page In Scope* ASME BTH-1-2011 & B30 SERIES BSEE PINC I-190 ABS 2012 CDS Other Jib crane Articulating boom crane Out of Scope Container cranes Loads suspended from rotorcraft Riser tensioning system Personnel lifting systems Material placement systems Come-alongs * All of the equipment covered by ASME BTH-1 and B30 series is covered in the ASME B30 review section. 4.1 Analysis The following sections outline the analysis conducted on material handling equipment. 4.1.1 Certified Drilling System (CDS) Equipment Certified Drilling System (CDS) equipment refers to equipment specifically designed for use in marine drilling systems and which is generally covered by a standard of design promulgated by a marine classification society. To obtain Κ D϶ ̍Κ̤̄ ̤̕ ̲̎̕Κ̲ϵ̎̕ ̎̕ ̲ϲζ πΚΨϵ̇ϵ̲͟ ̤̕ MOD̀ϳ̨ Ψ̇Κ̨̨ϵπϵΨΚ̲ϵ̎̕ certificate, the equipment must be designed to a standard, such as the ABS Guide for the Classification of Drilling Systems or one published by other marine classification societies such as L̇̕͟βϳ̨ RζϨϵ̨̲ζ̤ ̖LR̗ϭ Det Norske Veritas (DNV), Bureau Veritas (BV), or Germanischer-Lloyd (GL), among others. CDS equipment includes material handling devices such as riser running tools, top drive systems, draw works, and BOP cranes, which are unique to mobile offshore drilling units (MODU). Typical components of the hoisting system include the crown block with its support beams, traveling block with its guide track and dolly, sheaves for the crown block and traveling block, deadline anchors, draw works, drilling hook, top drive, drilling line, drilling elevators and links, hydraulic cylinders for overhead hoisting power swivel, bells, and rotary swivel, wire rope and hoisting equipment gears. There is no universal database that reports what specific equipment is installed on an individual facility. Research indicates that much of this information is proprietary. In fact, a number of devices are unique, having been specifically designed or retrofitted to an individual MODU or facility, and therefore are not representative of the fleet operating on the OCS. Typical nomenclature and functions of material handling equipment are presented below. Crane Safety Assessment 24 Page 4.1.2 Hoisting, Lifting, Rotating and Handling Systems Bail: The bail is a large, cylindrical steel bar that supports the swivel and connects it to the drill hook on the travelling block. BOP/LMRP Service Crane: provide the lifting capacity when handling the BOP Stack and a complete assembly or the LMRP and BOP individually between the transporter and storage positions. BOP/LMRP Transporter: transports a BOP from its crane loading position to well center. The BOP Transporter travels on rails under the moon pool via hydraulic cylinders. Crown Block: The crown block is the stationary section of the derrick drill string lifting apparatus that contains a set of sheaves through which the drill line wire rope is reeved and is opposite and above the travelling block. Deadline Anchor: The deadline anchor or deadline tie-down anchor is a mechanical device used to secure the deadline section of the drill line to the mast or derrick substructure. Derricks/Masts: Derricks and masts provide the structural stability for load handling and positioning the drilling string above the downhole or well bore and contains the machinery for turning the drilling bit and controlling the weight on the drill string. Draw Works: The draw works is the primary hoisting machinery of the rotary drilling system. Its main function is to provide motive power to raise and lower the travelling block. The wire rope drilling line winds on the draw works drum and extends to the crown and travelling blocks, allowing the drill string to be moved up and down and to vary the weight on the drill bit. The draw works typically consists of the wire rope drum, motor, reduction gear, main brake and auxiliary brake. Motive power is usually through an AC motor using a variable frequency control but may be by DC traction motors using a thyristor control, closed-loop hydraulic system, or by direct drive from a diesel engine, depending upon the age and configuration of the system. Some draw works may also provide motive power to the rotary table. Drill Floor Manipulator Arm (DFMA): A drill floor manipulator arm (DFMA) is a single working guide arm that guides tubulars to and from the wellbore to a laydown area or pipe rack. It is fixed mounted with a heavy duty slewing bearing for rotation and a telescoping box arm for reach. It is designed to handle a large variety of tubular diameters and to tail in marine risers and slip joints as well as stab in drill string components. The DFMA is generally controlled from a free-standing Ψ̲̤̎̇̕̕ ͍̎ϵ̲ ̎̕ ̲ϲζ β̤ϵ̇̇ π̤̇̕̕ ̤̕ Χ͟ ̤Κβϵ̕ ̤ζ̲̍̕ζ Ψ̲̤̎̇̕̕ π̤̍̕ ̲ϲζ β̤ϵ̇̇ζ̤ϳ̨ ΨΚΧϵ̎ϰ Drill Hook: A large hook mounted on the bottom of the travelling block which holds the swivel and drill string. Drill Line: The drill line is a multi-thread, twisted wire rope reeved through the crown and travelling blocks to lower and lift the drill string in and out of the wellbore. The section of drill line from the β̤Κ͙ ̨͙̤̄̕ β̤͍̍ ̲̕ ̲ϲζ Ψ̤͙̎̕ Χ̇̕Ψ̄ ϵ̨ ̲ϲζ ϶πΚ̨̲̇ϵ̎ζϷϰ ϼϲζ β̤ϵ̇̇ϵ̎Ϩ ̇ϵ̎ζ ̲ϲζ̎ ̤ζζ͘ζ̨ ̲ϲ͍̕Ϩϲ ̲ϲζ sheaves of the crown block and makes several passes through the travelling block to create the Crane Safety Assessment 25 Page mechanical advantage for hoisting the drill string. The line then exits the last sheave on the crown Χ̇̕Ψ̄ Κ̎β ϵ̨ πΚ̨̲ζ̎ζβ ̲̕ ̲ϲζ βζ̤̤ϵΨ̄ Κ̎β ϵ̨ ΨΚ̇̇ζβ ̲ϲζ ϶βζΚβ̇ϵ̎ζϷϰ Drilling Elevators: Drill elevators are a set of large clamps that grip the drill string or casing to facilitate the lifting or lowering of tubular as a whole, or is used to resist cross-axial loads of the weight of the pipe joints. Drilling elevators are highly stressed components that require regular, careful inspection. Hoisting Equipment: Typical components of the hoisting system would include the crown block with its support beams, traveling block with its guide track and dolly, sheaves for the crown block and traveling block, deadline anchors, drawworks, drilling hook, top drive, drill line and sand line, drilling elevators and links, hydraulic cylinders for overhead hoisting power swivel, bells, and rotary swivel, wire rope and hoisting equipment gears. Horizontal Riser Handling System: A riser handling cart or skate is a mechanical device which horizontally transports a riser assembly to the derrick for positioning in the wellbore and is a type of horizontal-to-vertical material handling device. The riser must be transported to the riser lift tool at the wellbore. This is achieved with a riser skate or multi-function catwalk machine. The riser is landed on the skate by a riser handling crane and driven to the wellbore for attachment to the lift tool. Once the riser is lifted clear by the traveling block, the rear support of the cart freewheels along the skate or catwalk with the riser bucket pivoting to follow the changing angle of the riser as it transitions from horizontal to vertical. When the riser is centered in the wellbore, the lower riser end may be tailed out of the cart using a dedicated tailing arm or drill floor manipulator arm fitted with a riser tailing head. Iron Roughneck: The iron roughneck is so named because it replaces the personnel (roughnecks) and automates the installation and removal of drill pipe from the drill floor. The iron roughneck is fed tubulars mechanically and personnel are removed from the dangerous conditions during drill string insertion or removal from the wellbore, drilling operations being remotely controlled from the ̨Κπζ̲͟ ̕π ̲ϲζ β̤ϵ̇̇ζ̤ϳ̨ ΨΚΧϵ̎ϰ ϼϲζ ϵ̤̎̕ ̤͍̕Ϩϲ̎ζΨ̄ Ψ̇Κ̡̨̍ ̲ϲζ Χ̲̲̍̕̕ ̡ϵ̡ζϭ ̡̤̕͘ϵβϵng torque, while a spinning or rotary wrench turns the top pipe, joining the two sections together. When a drill bit must be replaced or the well is completed, the pipe is simply turned in the opposite direction to disconnect and remove it. Kelly Bushing: The Kelly bushing is an adapter that connects the rotary table to the Kelly drive. The Kelly bushing has an inside profile, square or hexagonal, which matches the Kelly drive on the drill string and is connected to the rotary table by four large steel pins that fit into mating holes on the rotary table. The rotary motion from the rotary table is transmitted to the bushing through the pins and then to the Kelly drive through the square or hexagonal surfaces between the Kelly drive and the Kelly bushing. The Kelly drive then rotates the entire drill string. Depth measurements for the wellbore are commonly referred to as KP or depth below the Kelly bushing. Kelly Drive: The Kelly drive is a long, square or hexagonal steel bar, rifle drilled for a fluid path, and is used to transmit rotary motion and torque from a rotary table system (in lieu of a top drive system) or Kelly bushing to the drill string. This allows the drill string to be raised or lowered while Crane Safety Assessment 26 Page turning the drill bit. The Kelly is inserted into the Kelly bushing which is in turn attached to the rotary table which provides motive power to the drill string. Riser Spider: The riser spider is used to run riser sections through any the rotary table. Retractable dogs or pawls are hydraulically activated to support the riser string. The riser spider is remotely ̡̕ζ̤Κ̲ζβ ̲ϲ̤͍̕Ϩϲ Κ ̡Κ̎ζ̇ ϵ̎ ̲ϲζ β̤ϵ̇̇ζ̤ϳ̨ ΨΚΧϵ̎ϭ ζ̇ϵ̍ϵ̎Κ̲ϵ̎Ϩ ̲ϲζ ̎ζζβ ̲̕ ̍Κ͍̎Κ̇̇͟ ̤ζ̲̤ΚΨ̲ Κ̎β ζ̲͞ζ̎β the dogs as each section of the riser is positioned in the wellbore. Rotary Table: The rotary table is the revolving section of the drill floor that provides motive power and torque to the drill string. The rotary motion and power are transmitted through the Kelly bushing and Kelly drive. Almost all drilling systems have a rotary table as a primary or backup system for rotating the drill string, although many modern drilling systems have dispensed with the rotary table and use a top drive system exclusively. Swivel: The swivel is a mechanical device that suspends the weight of the drill string from the drill hook and traveling block. It is designed to allow rotation of the drill string while conveying high ͍̇̍͘̕ζ̨ ̕π ̡̤ζ̨̨͍̤ζ Ψ̲̤̎̇̕̕ ϶͍̍βϷ β̤ϵ̇̇ϵ̎Ϩ π͍̇ϵβ Χζ̲͙ζζ̎ ̲ϲζ ͍̍β Ψϵ̤Ψ͍̇Κ̲ϵ̎̕ ̨̨̲͟ζ̍ Κ̎β ̲ϲζ β̤ϵ̇̇ string. Top Drive: The top drive is a mechanical device which provides torque to the drill string to rotate the drill bit. A top drive system is used in lieu of a rotary table such as a Kelly drive because it lessens the manual labor and risks on the drill floor and allows the longer sections of the drill string to be used in a single operation (typically three tubulars). The top drive is suspended from the hook of the travelling block and is thus free to travel up and down with the drill string. Motive power for the top drive is usually through an AC motor using variable frequency control but may also be through a closed-loop hydrostatic transmission system using a hydraulic motor. Travelling Block: The travelling block is the freely moving section of the derrick drill string lifting apparatus that contains a set of sheaves through which the drill line wire rope is reeved and is opposite and under the crown block. Depending upon the size of the drill system, travelling blocks can be quite massive (>80-100 tons) with loads of over one million pounds and represent a serious dropped-object hazard. Vertical Riser Handling System: A vertical riser handling system is a mechanical device for moving slip joints and marine risers from a vertical storage position to the wellbore, together with a top drive and traveling block. The system typically consists of a riser handling gantry crane and hoist, fingerboard or racking board locks, riser chute, tail-in arm, and control cabin mounted on the riser crane. The riser handling crane lifts the riser from vertical storage to the riser chute. The riser tail-in arm guides the tail end of the riser from the chute to the wellbore. 4.1.3 Auxiliary Hoisting and Material Handling Equipment Auxiliary hoisting and manual material handling equipment is that which may or may not be associated exclusively with the drilling process but may be used for material handling. These items include, but are not limited to: Crane Safety Assessment 27 Page Man-Riding Winch: A man-̤ϵβϵ̎Ϩ ͙ϵ̎Ψϲ ϵ̨ ̨͍ζβ π̤̕ ̇ϵπ̲ϵ̎Ϩ ̡ζ̨̤̎̎̕ζ̇ ϵ̎ Κ ϲΚ̤̎ζ̨̨ ̤̕ Χ̕Κ̨̲͙Κϵ̎ϳ̨ ΨϲΚϵ̤ to upper levels of the derrick such as fingerboards or monkey boards. These winches require a minimum of an 8:1 design factor to safe working load limit, overload devices, slack wire detectors, limit switches, emergency stops, and emergency lowering and spooling devices. They are often built to marine classification society standards. Tongs: Tongs are large clamps used to manually manipulate tubulars in the wellbore by the drill crew. Tongs may be designated as lead, makeup, or breakout depending upon their function. These have been replaced by the iron roughneck and drill floor manipulator arm (DFMA) on modern drilling systems. Tugger: A tugger is an electrically, pneumatically, or hydraulically-operated drum and wire or synthetic rope winch system often mounted on the drill floor and used to hoist or tag-line control heavy drilling components. Winch: A winch is an electrically, pneumatically, or hydraulically-operated horizontal (windlass) or vertical (capstan) hoisting or pulling system used to provide motive power to raise or lower material or to tension a line or rope. 4.1.4 BSEE I-190 PINC for Material Handling Equipment The BSEE I-190 PINC is grounded in 30 C.F.R. Part 250.108 (f) which states that the operator must operate and maintain all other material handling equipment in a manner that ensures safe operations and prevents pollution. Material handling equipment is not defined in 30 C.F.R. Part 250.105. BSEE could define material handling equipment as devices, appliances, components, attachments, etc. the purpose of which is to facilitate or stabilize the movement (horizontal and vertical) of machinery, tools, contained liquids and solids or any material or equipment which cannot be moved safely and within the physical capabilities of the human being. The BSEE I-190 compliance guidance requires inspectors to determine if all material handling equipment is operated and maintained in a manner that ensures safe operation and prevents pollution. The current inspection procedure also requires an inspection of records to ensure material handling ζ̣͍ϵ̡̍ζ̲̎ ϵ̨ ̡̕ζ̤Κ̲ζβ ϶̡ζ̤ ̍Κ͍̎πΚΨ̲͍̤ζ̨̤ Κ̎β̤̄̕ ̡̕ζ̤Κ̨̲̤̕ ̨̡ζΨϵπϵΨΚ̲ϵ̨̎̕ϰϷ ϼϲζ inspector must also issue a component shut-in (C) incident of noncompliance citation when these conditions are not met. Although material handling equipment is not defined in the statute, the I-190 PINC notes that material handling equipment includes, but is not limited to: air hoists, hoists, tugger, air tugger, man-riding winch, come-a-long, monorail, gantry crane, jib crane, etc. Since the statute does not define material handling equipment, any equipment which moves or manipulates components or material would rightly be subject to this regulation; this includes CDS and auxiliary material handling equipment referred to above. The I-190 PINC guidance to BSEE inspectors subjects the regulated entity to variations in the training, experience, and capriciousness of the inspector; making compliance and inspection difficult. Moreover, the large variation in the motive power and functionality of the equipment makes it highly unlikely that any one inspector would be a subject matter expert (SME) or competent inspector of all of the systems covered by the regulation. Crane Safety Assessment 28 Page Most standards, such as those promulgated by API or marine classification societies, consider the design Κ̎β ̲̎̕ ̲ϲζ ϵ̨̡̎ζΨ̲ϵ̎̕ ̤̕ ̍Κϵ̲̎ζ̎Κ̎Ψζ ̕π ̲ϲζ ζ̣͍ϵ̡̍ζ̲̎ Κ̲ ̲ϲζ ̨͍ζ̤ϳ̨ level. Companies operating material handling equipment on the OCS must develop operations, maintenance safety and environmental pollution control procedures. This is normally accomplished through a Failure Modes, Effects and Criticality Analysis (FMECA) which qualitatively identifies the failure modes and effects of the ζ̣͍ϵ̡̍ζ̲̎ϳ̨ ̍Κ̤́̕ Ψ̡̍̎̕̕ζ̨̲̎ Κ̎β ̇ϵ̎ζ ̤ζ̡̇ΚΨζΚΧ̇ζ ͍̎ϵ̨̲ Κ̎β ̣͍Κ̇ϵ̲Κ̲ϵ͘ζ̇͟ ζ͘Κ͍̇Κ̲ζ̨ ̲ϲζ π̤ζ̣͍ζ̎Ψ͟ ̕π failure based on cycle or fatigue limits. Instructions on how to perform the FMECA may be found in MILSTD-1629A, Procedures for Performing a Failure Modes, Effects and Criticality Analysis, as well as other treatises on FMECA. From the FMECA, a robust, predictive and preventative inspection and maintenance schedule may be produced. The FMECA is sometimes produced by the manufacturer to form the basis of an inspection and maintenance schedule and this information is incorporated into the ζ̣͍ϵ̡̍ζ̲̎ϳ̨ ̡̕ζ̤Κ̲ϵ̨̎̕ Κ̎β ̍Κϵ̲̎ζ̎Κ̎Ψζ ϵ̨̲̤͍̎Ψ̲ϵ̨̎̕ϰ ϼϲζ̤ζπ̤̕ζϭ ̲ϲζ ζ̣͍ϵ̡̍ζ̲̎ ͙̎̕ζ̤ ̤̕ ̡̕ζ̤Κ̲̤̕ may de͘ζ̡̇̕ Κ̎ ϵ̨̡̎ζΨ̲ϵ̎̕ Κ̎β ̍Κϵ̲̎ζ̎Κ̎Ψζ ̨Ψϲζβ͍̇ζ ΧΚ̨ζβ ̎̕ ̲ϲζ ̍Κ͍̎πΚΨ̲͍̤ζ̤ϳ̨ ϵ̨̲̤͍̎Ψ̲ϵ̨̎̕ϰ ϼϲϵ̨ ̍Κ͟ Χζ ͘Κ̇ϵβϭ ϲ͙̕ζ͘ζ̤ϭ ̎̇̕͟ ϵπ ̲ϲζ ̨Ψϲζβ͍̇ζ Κ̎β ̍Κ͍̎πΚΨ̲͍̤ζ̤ϳ̨ ϵ̨̲̤͍̎Ψ̲ϵ̨̎̕ Κ̤ζ ΧΚ̨ζβ ̎̕ Κ FME !ϰ Once the inspection and preventive maintenance schedule is produced from an FMECA or from the ̍Κ͍̎πΚΨ̲͍̤ζ̤ϳ̨ ϵ̨̲̤͍̎Ψ̲ϵ̨̎̕ ΧΚ̨ζβ ̎̕ Κ̎ FME !ϭ Κ ́̕Χ ̨Κπζ̲͟ Κ̎Κ̨̇͟ϵ̨ ̖J϶!̗ Κ̎β ̲Κ̨̄ Κ̎Κ̨̇͟ϵ̨ ̖ϼ!̗ ̨ϲ͍̇̕β be performed to produce the inspection procedure. The JSA and TA take into account the inspection and maintenance tasks, the frequency and sequence in which they are to be performed, and the pass or fail criteria for the components to be inspected. From the JSA and TA, an inspection and maintenance checklist or other job aid may be produced and entered into a computerized maintenance management system. This system would schedule and track inspection and maintenance to ensure the equipment is maintained in a safe and efficient manner. Generally, inspections are scheduled on a frequent or periodic basis. Frequent inspections are those operational and preventive maintenance checks and services performed by a competent equipment operator on a daily, pre-operational, or shift-change basis. Periodic inspections are those performed by qualified maintenance or service personnel on a calendar basis, as recommended by the inspection and maintenance schedule discussed above. Sometimes, equipment owners and operators will have the equipment manufacturer or other independent third party perform the annual inspection of the equipment as an audit check of the inspection and maintenance quality of its own maintenance personnel. Although Office of Safety and Health Administration (OSHA) does not have jurisdictional responsibility on the OCS, definitions of competent and qualified personnel are shown below: A competent person is one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt, corrective measures to eliminate them. Thus, a competent operator would be one who is trained in accordance with a written qualification or structured on-the-job (OJT) training program, depending upon the complexity of the equipment; and who is trained to recognize the safety and environmental hazards of the equipment and is able to take corrective actions to eliminate those hazards. Crane Safety Assessment 29 Page Conversely, a qualified person is one who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training and experience, has successfully demonstrated their ability to solve or resolve problems relating to the subject matter, the work, or the project. This generally refers to inspection and maintenance personnel who are either ̍ζΨϲΚ̎ϵΨΚ̇ ζ̎Ϩϵ̎ζζ̨̤ ̤̕ ͙ϲ̕ Χ͟ Κ ̍Κ͍̎πΚΨ̲͍̤ζ̤ϳ̨ ̤̕ ̎Κ̲ϵ̎̕Κ̇̇͟-recognized certification training program, or who through a combination of education, training AND experience, is a subject matter expert on the operation, inspection and maintenance of the equipment, and can render Κ̎ ζβ͍ΨΚ̲ζβϭ ϵ̎π̤̍̕ζβ ̡̕ϵ̎ϵ̎̕ ̎̕ ̲ϲζ ̨Κπζ̲͟ Κ̎β ζππϵΨΚΨ͟ ̕π ̲ϲζ ζ̣͍ϵ̡̍ζ̲̎ϳ̨ ̡̕ζ̤Κ̲ϵ̎̕ Κ̎β maintenance. Therefore, maintenance personnel should be qualified to perform the periodic inspections as required by the inspection and maintenance schedule by formal training or certification procedure. Thus, inspectors of CDS and material handling equipment must be qualified by some formal training program. The marine classification societies offer courses in CDS equipment inspection for their surveyors which may be attended by BSEE inspectors. Moreover, inspectors should have formal training in mechanical and electro-hydraulic equipment fundamentals, hazard identification such as machine safety and machine guarding and other OSHA-type hazard identification procedures, and general inspection and maintenance auditing procedures. Lastly, it is well recognized the 60 to 80 percent of mishaps involve human error. Many times, these errors are due to a lack of training and qualification of personnel as discussed above. The mishaps are just as likely to be the result of an error provocative design or improper installation of the equipment. The frequency and magnitude of near misses and mishaps could be significantly reduced by subjecting the equipment to a human factors analysis (HFA) which specifically addresses the human-machine interface (HMI). This analysis may be based on ASTM F1166, Standard Practice for Human Engineering Design for Marine Systems, Equipment and Facilities. By subjecting the equipment to a HFA by trained human factors engineering personnel, many of the human error producing conditions may be eliminated. 5 Analysis of Lifting PINCs, INCs, and OIRs The study team analyzed the PINC list associated with the operations of offshore cranes and material handling equipment on the OCS. The objective of this task was to analyze PINCs and identify key issues that could be addressed in the development of an improved offshore crane and material handling equipment inspection program. The study team conducted analysis on the PINCs in determining the objectivity and ambiguity of PINC ̣͍ζ̨̲ϵ̨̎̕ϰ ϼϲζ PIN ̨ ͙ζ̤ζ ̤ζ͘ϵζ͙ζβ ̲̕ βζ̲ζ̤̍ϵ̎ζ ̲ϲζ ϵ̨̡̎ζΨ̲̤̕ϳ̨ ΚΧϵ̇ϵ̲͟ ̲̕ Ψ̎̕πϵ̤̍ Κ̎ ̡̕ζ̤Κ̲̤̕ϳ̨ compliance or non-compliance and the consistency of the recommended enforcement action (sanctions with potential consequences). In addition to the recommendations shown in Table 11, changes to PINCs ͙ζ̤ζ β̤Κπ̲ζβ ̲̕ ̨ζ̤͘ζ Κ̨ ̲ϲζ ϵ̲̎ζ̤ϵ̍ ̇ϵπ̲ϵ̎Ϩ PIN ̨ β͍̤ϵ̎Ϩ Κ ̲̤Κ̨̎ϵ̲ϵ̎̕ π̤̍̕ ̲ϲζ ϶!̨-ĮϷ ̲̕ ̲ϲζ ϶ϼ̕- ζϷ structure. The updated PINCs are shown in Appendix A. The analysis shown below focused on the following: Crane Safety Assessment 30 Page     Standards incorporated by reference in 30 CFR 250 associated with lifting PINCs Objectivity and ambiguity of PINC questions Ability for the inspector to confirm an operators compliance or non-compliance with the PINC Consistency of the inspectors enforcement action (sanctions with potential consequences) Crane Safety Assessment 31 Page 5.1 PINC Analysis ϼϲζ π͙̇̇̕̕ϵ̎Ϩ ̤ζΨ̍̍̕ζ̎βΚ̲ϵ̨̎̕ π̤̕ ΨϲΚ̎Ϩζ̨ ̲̕ PIN ̨ ͙ζ̤ζ ΧΚ̨ζβ ̡͍̎̕ ̲ϲζ ̨̲͍β͟ ̲ζΚ̍ϳ̨ Κ̎Κ̨̇͟ϵ̨ Κ̎β Κ̤ζ ̡̤̕͘ϵβζβ π̤̕ ϶EEϳ̨ Ψ̨̎̕ϵβζ̤Κ̲ϵ̎̕ ϵ̎ the development of a future lifting inspection strategy. In addition to the recommendations provided below, modifications to existing BSEE Table 11: Recommendations for Changes to PINCs # PINC Original Text I-101 WHENEVER THERE IS ANY DOUBT AS TO SAFETY, DOES THE CRANE OPERATOR STOP AND REFUSE TO HANDLE LOADS OR CONTINUE OPERATIONS AS SAFETY DICTATES IN ACCORDANCE WITH API RP 2D, PARAGRAPH 3.1.5a? Note: PINC list can only be used if crane operations continued under adverse conditions and caused an accident or near miss, which resulted in injury, death, pollution, or property damage. INSPECTION PROCEDURE: Verify that crane operations were restricted during periods of bad weather, such as ̇ϵϨϲ̲̎ϵ̎Ϩϭ ϲϵϨϲ ͙ϵ̎β̨ ̤̕ ϲϵϨϲ ̨ζΚ̨ϭ ̤̕ ͙ϲζ̎ ̲ϲζ ̤Κ̎ζ O̡ζ̤Κ̲̤̕ϳ̨ ΚΧϵ̇ϵ̲͟ ̲̕ ̨ζζ ̲ϲζ signal person is impaired by darkness, fog, rain, etc. Comments for Consideration This is a leading question; it telegraphs the desired answer. The requirement needs to be elicited using an action verb. An example is as π̨͙̇̇̕̕ϯ ϶Dϵβ ̲ϲζ Ψ̤Κ̎ζ ̡̕ζ̤Κ̲̤̕ βζ̨̲̤̍̎̕Κ̲ζ sufficient or adequate knowledge of the ̡̕ζ̤Κ̲̤̕ϳ̨ Ψ̤Κ̎ζ ̨Κπζ̲͟ ̡̤̕Ψζβ͍̤ζ̨ϰϷ How would the inspector verify the answer to this question? Are crane operation logs required? Do the logs capture real-time climatological data? How would impaired visibility be verified? IF NONCOMPLIANCE EXISTS: Issue a warning (W) INC if inspection reveals that crane was operated under adverse conditions and caused an accident which resulted in injury, death, pollution, or property damage. The restrictive language of the note ̡ζ̡̤ζ̲͍Κ̲ζ̨ ̲ϲζ ϶Ψ̡̍̇̕ϵΚ̎Ψζ ̍ζ̲̎Κ̇ϵ̲͟Ϸ discussed later in this analysis. INSPECTION COUNT/ INC Enter one item checked/ issue one INC for each crane inspected. I-102 ARE PROPER CRANE OPERATING PRACTICES FOR ATTACHING AND MOVING THE LOAD BEING UTILIZED IN ACCORDANCE WITH API RP 2D, PARAGRAPHS 3.2.1, 3.2.2 AND 3.2.3 AND API RP 2C, PARAGRAPH 7.5.4.3 ? INSPECTION PROCEDURE: ϶G͍ϵβζ̇ϵ̎ζ̨Ϸ Κ̤ζ ̲̎̕ ̎ζΨζ̨̨Κ̤ϵ̇͟ ̍Κ̎βΚ̲̤̕͟ Κ̎β therefore may not be enforceable; by contrast, the procedures must comply with a regulation or standard adopted by reference. 1. Verify that the load is attached to the hook by means of slings or other suitable devices. Sling use shall be in accordance with the guidelines of API RP 2D, Appendix Crane Safety Assessment 32 Page # PINC Original Text Comments for Consideration B, paragraph B.3.2.2.c, and Appendix G, paragraph G.5.2.1. 2. Verify that Hooks are equipped with a latch to retain loose lifting gear under nonlifting conditions and that the latch is lockable if the hook is used for transporting personnel. 3. Procedures for moving the load are in accordance with the guidelines of API RP 2D, Appendix B, paragraph B.3.2.3. IF NONCOMPLIANCE EXISTS: Issue a component shut-in (C) INC if procedures for attaching and/or moving the load are not within specified guidelines. INSPECTION COUNT/INC Enter one item checked/issue one INC for each crane inspected. I-103 ARE PROCEDURES FOR PERSONNEL TRANSFER PERFORMED IN ACCORDANCE WITH RECOMMENDED PRACTICES SPECIFIED IN API RP 2D, PARAGRAPH 3.4 AND APPENDIX B, PARAGRAPH B.3.4? INSPECTION PROCEDURE: If at the time of inspection, personnel are being transferred via personnel carrier from vessel to vessel, vessel to platform, or from platform to vessel, verify that: 1. Personnel carrier is of an approved type and is maintained in a safe conditions 2. All hooks used for support of personnel carrier are equipped with a safety latch. 3. Personnel are riding the carrier in a safe manner and are wearing an approved PFD. 4. Personnel are not raised or lowered directly over a vessel. ϼϲζ ̡̕ζ̤Κ̲̤̕ϳ̨ ̍Κ͍̎Κ̇ ̎ζζβ̨ ̲̕ Χζ ζ͘Κ͍̇Κ̲ζβ for procedures that meet API RP 2D; then the demonstration needs to be conducted in accordance with the manual. What Ψ̤ϵ̲ζ̤ϵΚ βζπϵ̎ζ ϶̨Κπζ ̍Κ̎̎ζ̤ϥϷ How does the inspector address a safety violation observed during an actual lift? Is it correct to shut-in the component for a personnel violation? IF NONCOMPLIANCE EXISTS: Issue a component shut-in (C) INC for a violation of 1 through 4 above. Crane Safety Assessment 33 Page # PINC Original Text Comments for Consideration INSPECTION COUNT/INC Enter one item checked/issue one INC for each crane inspected. I-104 ARE CRANES WHICH ARE POSITIONED IN THE PROXIMITY OF HELIDECKS OR APPROACH/TAKE-OFF ZONES NOT OPERATED DURING HELICOPTER OPERATIONS IN ACCORDANCE WITH API RP 2D, PARAGRAPH 3.1.5M? Non-compliance with this requirement is, by definition, a safety of flight issue. A warning should not be an appropriate sanction. INSPECTION PROCEDURE: If the crane and helicopter operations are in progress at the time of the inspection, verify that the crane boom is positioned and secured as required and the Crane Operator is out of the cab unless he is in direct voice communications with the pilot. IF NONCOMPLIANCE EXISTS: Issue a warning (W) INC if the crane boom is not positioned and secured as required or if the Crane Operator remains in the cab without direct voice communications with the pilot during landings/take-offs. INSPECTION COUNT/INC Enter one item checked/issue one INC for each crane observed. I-105 IF DEFICIENCIES THAT IMPAIR SAFE OPERATION ARE KNOWN, IS THE CRANE TAKEN OUT OF SERVICE OR ITS OPERATION RESTRICTED TO ELIMINATE THE UNSAFE CONDITION IN ACCORDANCE WITH API RP 2D, PARAGRAPH 3.1.5c? Note: Limited (restricted) service may, in some cases, be continued after the identification and before correction of a deficiency. In such cases, the deficiency must be documented and cautionary notices posted in accordance with API RP 2D, paragraph 1, item c. What records are available/ required to determine when the crane was operated? How would the inspector verify that the crane was operated with a deficiency? INSPECTION PROCEDURE: 1. Check facility crane inspection records to determine if any deficiencies have been identified. 2. If deficiencies have been identified, verify that cautionary notices have been Crane Safety Assessment 34 Page # PINC Original Text Comments for Consideration posted. IF NONCOMPLIANCE EXISTS: Issue a component shut-in (C) INC if deficiencies have been identified and cautionary notices have not been posted. INSPECTION COUNT/INC Enter one item checked/issue one INC for each crane inspected. I-111 IS AN OPERABLE SWING BRAKE MECHANISM INSTALLED THAT IS CAPABLE OF SMOOTH STARTS AND STOPS WITH CONTROLLABLE RATES OF ACCELERATION AND DECELERATION AS SPECIFIED IN API SPEC 2C PARAGRAPH 9.1 ON EACH CRANE MANUFACTURED AFTER MARCH 17, 2003, AND ON EACH CRANE ON A FIXED PLATFORM INSTALLED AFTER MARCH 17, 2003? INSPECTION PROCEDURE: Verify that the swing brake mechanisms listed below operate according to the requirements in API SPEC 2C Paragraphs 9.1.3, 9.1.3, and 9.1.4: 1. 2. 3. Parking Brake. Automatic Parking Brake. Dynamic Friction Brake. ϼϲζ ϵ̨̡̎ζΨ̲̤̕ ̨ϲ͍̇̕β ͘ζ̤ϵπ͟ ̲ϲΚ̲ ̲ϲζ ̡̕ζ̤Κ̲̤̕ϳ̨ manual contains procedures for the swingbrake check and that the procedures conform to the API 2C, 7.4. The question should be two parts: First, verify the procedure is written and compliant; second, observe the conduct of the check by the crane operator. Should BSEE incorporate API Spec 2C, 7th edition, by reference the PINC should be corrected to the following citation: API SPEC 2C, Paragraph 7.4. IF NONCOMPLIANCE EXISTS: Issue a warning (W) INC for each crane audit that does not confirm that the operator has records of inspecting each crane swing brake mechanism that does not comply with the requirement in API SPEC 2C, Paragraph 9.1. Issue a component shut-in (C) INC for each crane swing brake mechanism inspected that does not comply with the requirements in API SPEC 2C, Paragraph 9.1. INSPECTION COUNT/INC Enter one item checked/issue one INC for each crane inspected. Crane Safety Assessment 35 Page # PINC Original Text Comments for Consideration I-112 IS AN OPERABLE BOOM HOIST HIGH LIMITER OR SHUTOFF PROVIDED TO AUTOMATICALLY STOP THE BOOM HOIST WHEN THE BOOM REACHES A PREDETERMINED HIGH ANGLE, AS SPECIFIED IN API SPEC 2C, PARAGRAPH 13.1.1, ON EACH CRANE MANUFACTURED AFTER MARCH 17, 2003, AND ON EACH CRANE ON A FIXED PLATFORM INSTALLED AFTER MARCH 17, 2003? D̕ζ̨ ̲ϲζ ̡̕ζ̤Κ̲̤̕ϳ̨ ̍Κ͍̎Κ̇ Ψ̲̎̕Κϵ̎ ̡̤̕Ψζβ͍̤ζ̨ for inspecting the boom hoist limiter or shutoff that comply with API RP 2D? Does the operator maintain records of boom hoist limiter/shutoff ϵ̨̡̎ζΨ̲ϵ̨̎̕ϥ Dϵβ ̲ϲζ Ψ̤Κ̎ζ ̡̕ζ̤Κ̲̤̕ϳ̨ Χ̍̕̕ hoist limiter inspection conform to the manual? Note: Low angle limiter or shut off shall not be inspected by BOEMRE. INSPECTION PROCEDURE: Verify that the crane boom hoist high limiter or shutoff will automatically stop the boom hoist when the boom reaches a pre-determined high angle. IF NONCOMPLIANCE EXISTS: Should BSEE incorporate API Spec 2C, 7th edition, by reference the PINC should be corrected to the following citation: API SPEC 2C, Paragraph 10.3.2.1. Issue a warning (W) INC for each crane audit that does not confirm that the operator has records of inspecting the boom hoist limiter or shutoff as specified in API RP 2D, Paragraph 4.2.2. Issue a component shut-in (C) INC for each crane inspected that does not comply with the requirements in API SPEC 2C, Paragraph 13.1.1. INSPECTION COUNT/ INC Enter one item checked/issue one INC for each crane inspected. I113 ARE BOOM STOPS PROVIDED TO RESIST THE BOOM FALLING BACKWARDS IN A HIGH WIND OR SUDDEN RELEASE OF THE LOAD, AS SPECIFICED IN API SPEC 2C, PARAGRAPH 13.1.2, ON EACH CRANE MANUFACTURED AFTER MARCH 17, 2003, AND ON EACH CRANE ON A FIXED PLATFORM INSTALLED AFTER MARCH 17, 2003? Should BSEE incorporate API Spec 2C, 7th edition, by reference the PINC should be corrected to the following citation: API SPEC 2C, Paragraph 10.3.2.2. INSPECTION PROCEDURE: Verify that the crane boom stops provided are designed to resist the boom falling backwards. Note: Designs for boom stops include one of the following: 1. 2. A fixed or telescoping bumper. A shock absorbing bumper Crane Safety Assessment 36 Page # PINC Original Text 3. Comments for Consideration Hydraulic boom elevation cylinder(s). IF NONCOMPLIANCE EXISTS: Issue a component shut-in (C) INC for each crane inspected that does not comply with the requirements in API SPEC 2C, Paragraph 13.1.2. INSPECTION COUNT/INC Enter one item checked/issue one INC for each crane inspected, I114 I϶ ! OOM !NGLE OR LO!D R!DÌ϶ INDI !ϼOR RE!D! LE FROM ϼHE OPER!ϼORϳ϶ STATION PROVIDED, AS SPECIFIED IN API SPEC 2C, PARAGRAPH 13.1.4.1, ON EACH CRANE MANUFACTURED AFTER MARCH 17, 2003, AND ON EACH CRANE ON A FIXED PLATFORM INSTALLED AFTER MARCH 17, 2003? Should BSEE incorporate API Spec 2C, 7th edition, by reference the PINC should be corrected to the following citation: API SPEC 2C, Paragraph 10.3.2.4 INSPECTION PROCEDURE: If the boom angle or load radius indicator is a safety device, then inspection and verification of proper operation serves as safety-critical functions. How can lack of inspection records for a safety device be worthy of only a warning? Verify that the crane boom angle or load radius indicator is provided and readable π̤̍̕ ̲ϲζ ̡̕ζ̤Κ̲̤̕ϳ̨ ̨̲Κ̲ϵ̨̎̕ϰ IF NONCOMPLIANCE EXISTS: Issue a warning (W) INC for each crane audit that does not confirm that the operator has records of inspecting the boom angle/radius indicators over full range for accuracy as specified in API RP 2D, Paragraph 4.2.2. Issue a component shut in (C) INC for each crane inspected that does not comply with the requirements in API SPEC 2C, Paragraph 13.1.4.1. INSPECTION COUNT/INC Enter one item checked/issue one INC for each crane inspected. I115 HAVE SECURELY FASTENED GUARDS BEEN INSTALLED ON EXPOSED MOVING PARTS WHICH MAY CONSTITUTE A HAZARD, AS SPECIFIFED IN API SPEC 2C, PARAGRAPH 13.2, ON EACH CRANE MANUFACTURED AFTER MARCH 17, 2003, AND ON EACH CRANE ON A FIXED PLATFORM INSTALLED AFTER MARCH 17, 2003? Crane Safety Assessment Should BSEE incorporate API Spec 2C, 7th edition, by reference the PINC should be corrected to the following citation: API SPEC 2C, Paragraph 10.3.3. 37 Page # PINC Original Text Comments for Consideration INSPECTION PROCEDURE: 1. Verify that exposed moving parts such as gears, set screw, projecting keys, chains chain sprockets, and reciprocating or rotating parts which may constitute a hazard under normal operating conditions are guarded. 2. Verify that an appropriate sign is posted if a guard is impractical to install on the above crane components. IF NONCOMPLIANCE EXISTS: Issue a component shut in (C) INC for each crane inspected that does not comply with the requirements in API SPEC 2C, Paragraph 13.2. INSPECTION COUNT/INC Enter one item checked/issue one INC for each crane inspected. I116 HAS AN ANTI-TWO BLOCK DEVICE BEEN PROVIDED TO PROTECT HOIST ROPES, STRUCTURAL COMPONENTS AND MACHINERY FROM DAMAGE WHICH MAY OCCUR WHEN TWO SHEAVE GROUPS (e.g., LOAD BLOCK AND BOOM HEAD) COME INTO CONTACT AS THE HOIST CABLE IS DRAWN IN, AS SPECIFIED IN API SPEC 2C, PARAGRAPH 13.7, ON EACH CRANE ON A FIXED PLATFORM INSTALLED BY MARCH 16, 2005? Note: 1. BSEE Inspectors do not test stalling mechanisms for hoist drum. Should BSEE incorporate API Spec 2C, 7th edition, by reference the PINC should be corrected to the following citation: API SPEC 2C, Paragraph 10.3.6. If the anti-two block device is a safety device, then inspection and verification of proper operation serve safety-critical functions. How can lack of inspection records for a safety device be worthy of only a warning? 2. A control override device or proximity warning device may be used. Stalling of the hoist drum is acceptable where damage or loss on control would not result. INSPECTION PROCEDURE: 1. Verify that a means to protect hoist ropes, structural components and machinery from damage is provided on all cranes. 2. Verify that the operator is documenting the proper inspection of the controls override or proximity warning device as specified in API RP 2D, Crane Safety Assessment 38 Page # PINC Original Text Comments for Consideration Paragraph 4.2.2. IF NONCOMPLIANCE EXISTS: Issue a warning (W) INC for each crane audit that does not confirm that the operator has records of inspecting the control override or proximity warning devices as specified in API RP 2D, Paragraph 4.2.2. Issue a component shut in (C) INC for each crane inspected that does not have an operational control override or proximity warning device installed. INSPECTION COUNT/INC Enter one item checked/ issue one INC for each crane inspected. I117 IS THERE A FIRE EXTINGUISHER OF APPROPRIATE SIZE AND TYPE KEPT IN THE CAB OR VICINITY OF THE CRANE IN ACCORDANCE WITH AP1 RP 2D, PARAGRAPH 3.5.2? Note: ASME B30.4c recommends a portable fire extinguisher with a basic minimum extinguisher rating of 10 BC. (10 = 10 lbs., B = Flammable Fluids, C = Energized Electrical). INSPECTION PROCEDURE: Verify that a fire extinguisher is located in the crane cab or near the crane. IF NONCOMPLIANCE EXISTS: Issue a component shut-in (C) INC if fire extinguisher: 1. Is not located where required. 2. Is not of the appropriate size or type. 3. Does not exist or is inoperable. INSPECTION COUNT/INC Enter one item checked/issue one INC for each crane inspected. I131 IS THE CORRECT LOAD RATING CHART FOR THE CRANE CONFIGURATION IN USE AT THE PRIMARY CONTROL STATION IN ACCORDANCE WITH API RP 2D, PARAGRAPH Crane Safety Assessment 39 Page # PINC Original Text Comments for Consideration 3.2.1? INSPECTION PROCEDURE: Verify that the load chart is legible, posted and visible in the primary control station for the crane configuration in use. IF NONCOMPLIANCE EXISTS: Issue a component shut-in (C) INC for the crane if the correct load rating chart is not posted and visible at the primary control station for the crane. INSPECTION COUNT/INC Enter one item checked/issue one INC for each crane inspected. I132 ARE WRITTEN REPORTS ON LOAD TESTS PREPARED BY A QUALIFIED CRANE INSPECTOR SHOWING LOAD TEST PROCEDURES AND RESULTS WHEN LOAD TESTS ARE REQUIRED IN ACCORDANCE WITH API RP 2D, PARAGRAPH 4.2.3? Note: Load tests are required under the following conditions: 1. 2. 3. 4. New cranes being placed in service. Cranes that are being permanently relocated. Temporary/rental cranes after each rig-up or relocation. When repairs or replacement do not meet the requirements of API RP 2D, paragraph 4.3.3. INSPECTION PROCEDURE: Verify from facility crane records that load tests were conducted when required by a qualified crane inspector using API RP 2D, Appendix E, as a reference guide. IF NONCOMPLIANCE EXISTS: Issue a component shut-in (C) INC if load tests are not conducted when necessary by a qualified crane inspector using API RP 2D, Appendix E, as a referenced guide. INSPECTION COUNT/INC Crane Safety Assessment 40 Page # PINC Original Text Comments for Consideration Enter one item checked/ issue one INC for each crane inspected. I133 HAVE STATIC AND DYNAMIC LOAD RATING CHARTS BEEN ESTABLISHED FOR ALL CRANES IN ACCORDANCE WITH API RP 2D, PARAGRAPH 3.1.5h? Note: 1. Static Load Ratings must be established for lifting from or setting on the crane-supporting structure (platform). 2. Dynamic Load Ratings must be established for lifting from or setting on vessels. INSPECTION PROCEDURE: Verify from facility crane records that static and dynamic load ratings charts have been established for all cranes. IF NONCOMPLIANCE EXISTS: Issue a component shut-in (C) INC if records indicate that: 1. Static and dynamic load ratings have not been established for all cranes. 2. Crane has operated without appropriate load rating charts established and posted. INSPECTION COUNT/INC Enter one item checked/issue one INC for each crane inspected. I134 IS THE LOAD BLOCK RATING LABEL(S) PERMANENTLY AFFIXED TO THE HOOK BLOCK, AS SPECIFIED IN AP SPEC 2C, PARAGRAPH 7.5.3.2, ON EACH CRANE MANUFACTURED AFTER MARCH 17, 2003, OR EACH CRANE ON A FIXED PLATFORM INSTALLED AFTER MARCH 17, 2003? Should BSEE incorporate API Spec 2C, 7th edition, by reference the PINC should be corrected to the following citation: API SPEC 2C, 7.2.5.3. INSPECTION PROCEDURE: 1. Verify that the load block rating label(s) is permanently affixed to the hook block. 2. Verify that the label includes the following load block requirements. Crane Safety Assessment 41 Page # PINC Original Text Comments for Consideration a. The maximum static and personnel rated loads. b. The service temperature and assembly weight. IF NONCOMPLIANCE EXISTS: Issue a component shut-in (C) INC for any crane load block that does comply with the requirements in API SPEC 2C, Paragraph 7.5.3.2. INSPECTION COUNT/ INC Enter one item checked/ issue one INC for each crane inspected. I141 H!̋E M!ǸF! ϼ̀RERϳ϶ RE OMMEND!ϼION϶ EEN IN L̀DED IN E϶ϼ! LI϶HING ALL INSPECTION REQUIREMENTS IN ACCORDANCE WITH API RP 2D, PARAGRAPH 4.1.2 AND APPENDIX C? INSPECTION PROCEDURE: ̋ζ̤ϵπ͟ ̲ϲΚ̲ ̲ϲζ ̍Κ͍̎πΚΨ̲͍̤ζ̤ϳ̨ ̤ζΨ̍̍̕ζ̎βΚ̲ϵ̨̎̕ ϲΚ͘ζ Χζζ̎ ϵ̎Ψ͍̇βζβ ϵ̎ ζ̨̲ΚΧ̇ϵ̨ϲϵ̎Ϩ all inspection requirements. Is a warning an appropriate sanction for an improperly and/or incompletely inspected crane? If the crane has not been inspected in accordance with all standards and ̍Κ͍̎πΚΨ̲͍̤ζ̤ϳ̨ ̤ζ̣͍ϵ̤ζ̍ζ̨̲̎ϭ ϲ͙̕ β̕ζ̨ ̲ϲζ operator know that it is safe to operate? IF NONCOMPLIANCE EXISTS: Issue a warning (W) INC if records indiΨΚ̲ζ ̲ϲΚ̲ ̍Κ͍̎πΚΨ̲͍̤ζ̤ϳ̨ ̤ζΨ̍̍̕ζ̎βΚ̲ϵ̨̎̕ have been excluded from establishing inspection requirements. INSPECTION COUNT/INC Enter one item checked/issue one INC for each crane inspected. I142 HAVE NEW OR RELOCATED CRANES RECEIVED AN INITIAL INSPECTION BY A QUALIFIED INSPECTOR WITH RECORDS MAINTAINED AT AN APPROPRIATE LOCATION FOR FOUR YEARS IN ACCORDANCE WITH API RP 2D, PARAGRAPH 4.1.2.1 AND 4.2.2? Is a warning if most current inspection is up to date and accurate. A (C) should be issued if no records are available. Note: Cranes in this category are required to be load tested in accordance with API RP 2D, Appendix E. INSPECTION PROCEDURE: Crane Safety Assessment 42 Page # PINC Original Text Comments for Consideration Verify that: 1. Records of initial inspection are readily available and are maintained for a period of 4 years. 2. Inspection and load test was performed. 3. Records include date and time of inspection and name/initial of person performing the inspection. IF NONCOMPLIANCE EXISTS: Issue a warning (W) INC if records of initial inspection are not available and/or not maintained for 4 years. Issue a component shut-in (C) INC if: 1. The crane was not inspected prior to use when new or prior to use after being permanently relocated. 2. The crane was not load tested. INSPECTION COUNT/ INC Enter one item checked/issue one INC for each crane inspected. I143 HAVE PRE-USE INSPECTIONS BEEN PERFORMED PRIOR TO USE (TYPICALLY DAILY) BY A QUALIFIED CRANE OPERATOR/INSPECTOR WITH RECORDS, IN ACCORDANCE WITH API RP 2D, PARAGRAPHS 4.1.1.1 AND 4.1.2.2, MAINTAINED AT AN APPROPRIATE LOCATION FOR FOUR YEARS? ̌ϲΚ̲ Ψ̤ϵ̲ζ̤ϵΚ βζ̲ζ̤̍ϵ̎ζ̨ Κ̎ ϶Κ̡̡̡̤̤̕ϵΚ̲ζ ̇̕ΨΚ̲ϵ̎̕ϥϷ Note: Applies to all cranes, regardless of usage category. The pre-use inspection must be conducted prior to using the crane. Pre-use inspection record can be a record, a record book, a logbook, a computerized data collector, or an electronic data collector. Inspection criteria must be in accordance with API RP 2D, Appendix C, paragraph C.4.1.2a. INSPECTION PROCEDURE: Verify that: Crane Safety Assessment 43 Page # PINC Original Text Comments for Consideration 1. Pre-use inspections are performed. 2. Records are kept at an appropriate location and are maintained for a period of 4 years. 3. Records include date and time of inspection and name/initial of person performing the inspection. IF NONCOMPLIANCE EXISTS: Issue a warning (W) INC if: 1. Records indicate that a pre-use inspection was missed or did not occur on schedule, but the most recent pre-use inspection has been performed. 2. Records are not maintained for a period of 4 years. Issue a component shut-in (C) INC if: 1. Records of pre-use inspections are not available or are not kept at an appropriate location. 2. Records do not indicate that a pre-use inspection has been performed. 3. The pre-use inspection currently due has not been performed. INSPECTION COUNT/INC Enter one item checked/issue one INC for each crane inspected. I144 HAVE MONTHLY INSPECTIONS BEEN PERFORMED BY A QUALIFIED CRANE OPERATOR/INSPECTOR WITH RECORDS, IN ACCORDANCE WITH API RP 2D, PARAGRAPH 4.1.2.3 AND 4.2.2, READILY AVAILABLE FOR A PERIOD OF FOUR YEARS? Note: 1. !̡̡̇ϵζ̨ ̲̕ HζΚ͘͟ ̨̀ΚϨζ Κ̲ζϨ̤̕͟ Ψ̤Κ̎ζ̨ϰ !̎ O̡ζ̤Κ̲̤̕ϳ̨ failure to document usage category will cause the crane to default to the Heavy Usage category. Inspection criteria must be in accordance with API RP 2D, Appendix C, paragraph C.4.1.2b. 2. Rζπζ̤ζ̎Ψζ !̡̡ζ̎βϵ͞ Ϯϰ π̤̕ βζπϵ̎ϵ̲ϵ̎̕ ̕π ϶M̲̎̕ϲ̇͟Ϸ Κ̎β βζ̨Ψ̤ϵ̡̲ϵ̎̕ ̕π ϶̨̀ΚϨζ Crane Safety Assessment 44 Page # PINC Original Text Comments for Consideration Κ̲ζϨ̤̕͟ϰϷ INSPECTION PROCEDURES: Verify that: 1. Monthly inspections are performed by qualified personnel. 2. Verify that records are readily available and are maintained for a period of 4 years. 3. Verify that records include date and time of inspection and name/initial of person performing the inspection. IF NONCOMPLIANCE EXISTS: Issue a warning (W) INC if records indicate that monthly inspection was missed or did not occur on schedule, but the most recent monthly inspection was completed. Issue a component shut-in (C) INC if: 1. Records of monthly inspections are not available or are not maintained for a period of 4 years. 2. Records do not indicate that a monthly inspection has been performed. 3. The monthly inspection currently due has not been performed. INSPECTION COUNT/ INC Enter one item checked/ issue one INC for each crane inspected. I145 HAVE QUARTERLY INSPECTIONS BEEN PERFORMED BY A QUALIFIED CRANE INSPECTOR WITH RECORDS, IN ACCORDANCE WITH API RP 2D, PARAGRAPH 4.1.2.4 AND 4.2.2, READILY AVAILABLE FOR A PERIOD OF FOUR YEARS? Note: 1. Applies to Moderate Usage Category cranes and Heavy Usage Category Ψ̤Κ̎ζ̨ϰ !̎ O̡ζ̤Κ̲̤̕ϳ̨ πΚϵ͍̤̇ζ ̲̕ β̕Ψ͍̍ζ̲̎ ̨͍ΚϨζ ΨΚ̲ζϨ̤̕͟ ͙ϵ̇̇ ΨΚ̨͍ζ ̲ϲζ crane to default to the Heavy Usage category. Inspection criteria must be in accordance with API RP 2D, Appendix C, paragraph C.4.1.2c. Crane Safety Assessment 45 Page # PINC Original Text Comments for Consideration 2. Rζπζ̤ζ̎Ψζ !̡̡ζ̎βϵ͞ Ϯϰ π̤̕ βζπϵ̎ϵ̲ϵ̎̕ ̕π ϶Q͍Κ̤̲ζ̤̇͟Ϸ Κ̎β βζ̨Ψ̤ϵ̡̲ϵ̨̎̕ ̕π ϶̨̀ΚϨζ Κ̲ζϨ̤̕͟ϰϷ INSPECTION PROCEDURE: Verify that: 1. Quarterly inspections are performed by a qualified crane inspector. 2. Records are readily available and are maintained for a period of 4 years. 3. Records include date and time of inspection and name/initial of person performing the inspection. IF NONCOMPLIANCE EXISTS: Issue a warning (W) INC if records indicate that quarterly inspection was missed or did not occur on schedule, but the most recent quarterly inspection was completed. Issue a component shut-in (C) INC if: 1. Records of quarterly inspections are not available or are not maintained for a period of 4 years. 2. Records do not indicate that a quarterly inspection has been performed. 3. The quarterly inspection currently due has not been performed. INSPECTION COUNT/ INC Enter one item checked/ issue one INC for each crane inspected. I146 HAVE ANNUAL INSPECTIONS BEEN PERFORMED BY A QUALIFIED CRANE INSPECTOR WITH RECORDS, IN ACCORDANCE WITH API RP 2D, PARAGRAPHS 4.1.1.1, 4.1.2.5, AND 4.2.2, READILY AVAILABLE FOR A PERIOD OF FOUR YEARS? Note: 1. Applies to all cranes, regardless of usage category. Cranes that have been out of service for 12 months or more must have an annual inspection before being used. Additionally, annual inspections must include inspection of crane critical components in accordance with API RP 2D, Appendix C, Crane Safety Assessment 46 Page # PINC Original Text Comments for Consideration paragraph C.4.1.2d, items 22, 23, and 24. 2. Reference Appζ̎βϵ͞ Ϯϰ π̤̕ βζπϵ̎ϵ̲ϵ̎̕ ̕π ϶!͍̎̎Κ̇Ϸ Κ̎β βζ̨Ψ̤ϵ̡̲ϵ̨̎̕ ̕π ϶̨̀ΚϨζ Κ̲ζϨ̤̕͟ϰϷ INSPECTION PROCEDURE: Verify that: 1. Annual inspections are performed by a qualified crane inspector. 2. Records are readily available and are maintained for a period of 4 years. 3. Records include date and time of inspection and name/initial of person performing the inspection. IF NONCOMPLIANCE EXISTS: Issue a warning (W) INC if records indicate that annual inspection did not occur on schedule, but the most recent annual inspection was completed. Issue a component shut-in (C) INC if: 1. Records of annual inspections are not available or are not maintained for a period of 4 years. 2. Records do not indicate that an annual inspection has been performed. 3. The annual inspection currently due has not been performed. INSPECTION COUNT/ INC Enter one item checked/ issue one INC for each crane inspected. I147 HAS A WIRE ROPE INSPECTION PROGRAM BEEN ESTABLISHED IN ACCORDANCE WITH Is a warning appropriate for improperly API RP 2D, PARAGRAPH 5.1.2 AND ARE INSPECTION RECORDS MAINTAINED FOR A maintained records? An improperly PERIOD OF FOUR YEARS? maintained record is the same as no record. Is a wire rope program that is not being followed DEFINITION: any different than no program at all? Wire Rope Inspection Program - A wire rope inspection program is an inspection program which takes into consideration crane type, frequency of usage, history of ̍Κϵ̲̎ζ̎Κ̎Ψζϭ ͙ϵ̤ζ ̡̤̕ζ ̍Κ͍̎πΚΨ̲͍̤ζ̤ϳ̨ ̤ζΨ̍̍̕ζ̎βΚ̲ϵ̨̎̕ϭ Κ̎β Ψ̤Κ̎ζ Crane Safety Assessment 47 Page # PINC Original Text Comments for Consideration man͍πΚΨ̲͍̤ζ̤ϳ̨ ̤ζΨ̍̍̕ζ̎βΚ̲ϵ̨̎̕ϰ Note: 1. Inspection records must be maintained per API RP 2D, paragraph 4.2 to determine the time interval for retirement of the wire rope. Records must be readily available until the specific wire rope is retired. All observed wire rope deterioration as listed in API RP 2D, Appendix G, paragraph G.5.2.1b must be recorded on these inspection records. 2. Rζπζ̤ζ̎Ψζ !̡̡ζ̎βϵ͞ Ϯϰ π̤̕ βζ̨Ψ̤ϵ̡̲ϵ̨̎̕ ̕π ϶F̤ζ̣͍ζ̎Ψ͟ ̕π ̨̀ΚϨζϰϷ INSPECTION PROCEDURE: Verify that: 1. A wire rope inspection program has been established. 2. Wire rope inspection records are available and are maintained for a period of 4 years. IF NONCOMPLIANCE EXISTS: Issue a warning (W) INC if: 1. Records are not readily available or are not maintained for a period of 4 years. 2. Records are incomplete or inaccurate, but are sufficient to indicate that a wire rope inspection program has been established. 3. Issue a component shut-in (C) INC if: 4. A wire rope program has not been established. INSPECTION COUNT/ INC Enter one item checked/ issue one INC for each crane inspected. I151 HAS A PREVENTATIVE MAINTENANCE PROGRAM BEEN ESTABLISHED WITH RECORDS, IN ACCORDANCE WITH API RP 2D, PARAGRAPH 4.3.1, READILY AVAILABLE FOR A PERIOD OF FOUR YEARS? Crane Safety Assessment Is a warning appropriate for improperly maintained records? An improperly maintained record is the same as no record. Is a 48 Page # PINC Original Text Note: Comments for Consideration preventative maintenance program that is not being followed any different than no program at all? A preventative maintenance program takes into consideration crane type, frequency of usage, histor͟ ̕π ̍Κϵ̲̎ζ̎Κ̎Ψζϭ Κ̎β ̍Κ͍̎πΚΨ̲͍̤ζ̤ϳ̨ ̤ζΨ̍̍̕ζ̎βΚ̲ϵ̨̎̕ϰ Rζπζ̤ζ̎Ψζ !̡̡ζ̎βϵ͞ Ϯϰ π̤̕ βζ̨Ψ̤ϵ̡̲ϵ̨̎̕ ̕π ϶F̤ζ̣͍ζ̎Ψ͟ ̕π ̨̀ΚϨζϰϷ INSPECTION PROCEDURE: Verify that: A preventative maintenance program has been established. Preventative maintenance records are readily available and are maintained for a period of 4 years. IF NONCOMPLIANCE EXISTS: Issue a warning (W) INC if preventative maintenance program records are not immediately available or are not maintained for a period of 4 years. Issue a component shut-in (C) INC if records do not indicate that a preventive maintenance program has been established. INSPECTION COUNT/ INC Enter one item checked/ issue one INC for each crane inspected. I152 ARE WRITTEN REPORTS CONFIRMING ADEQUACY OF REPAIRS OR ALTERATIONS IN ACCORDANCE WITH API RP 2D, PARAGRAPH 4.3.3c, MAINTAINED FOR A PERIOD OF FOUR YEARS? Is a warning appropriate for improperly maintained records? An improperly maintained record is the same as no record. Note: All replacement parts must be equal to or better than the original equipment. No welding repairs may be made to critical components, such as booms and swing circle assemblies, without specific repair procedures and recommendations from the original crane manufacturer or other similar qualified source. INSPECTION PROCEDURES: Crane Safety Assessment 49 Page # PINC Original Text Comments for Consideration Verify that: 1. Written reports confirming the adequacy of major repairs or alterations are available. 2. The reports are maintained for a period of 4 years. IF NONCOMPLIANCE EXISTS: Issue a warning (W) INC if written reports confirming the adequacy of repairs or alterations are not immediately available or are not maintained for a period of 4 years. Issue a component shut-in (C) INC if written reports: 1. The operator is not prepared confirming the adequacy of repairs or alterations performed. 2. Are incomplete or inaccurate. INSPECTION COUNT/ INC Enter one item checked/ issue one INC for each crane inspected. I153 ARE REPAIRS OR REPLACEMENTS OF CRITICAL COMPONENTS MADE PROMPTLY IN ACCORDANCE WITH API RP 2D, PARAGRAPH 4.3.3b? Note: All replacement parts must be equal to or exceed the original equipment. No welding repairs may be made to critical components, such as booms and swing circle assemblies, without specific repair procedures and recommendations from the original crane manufactṳζ̤ϭ ̤̕ ̲̕ϲζ̤ ̣͍Κ̇ϵπϵζβ ̨͍̤̕Ψζϰ P̡̤̲̍̇̕͟ ̍ζΚ̨̎ ϶D̎̕ζ ̌ϵ̲ϲ͍̲̕ Dζ̇Κ͟ϰϷ INSPECTION PROCEDURE: ϶P̡̤̲̍̇̕͟Ϸ Κ̎β ϶͙ϵ̲ϲ͍̲̕ βζ̇Κ͟Ϸ β̕ ̲̎̕ Κ̡̡ζΚ̤ in API RP 2D, PARAGRAPH 4.3.3b or Appendix F, paragraph F.4.3.3, item b. What criteria exist fo̤ βζ̲ζ̤̍ϵ̎ϵ̎Ϩ ϶̡̡̤̲̍̇̕͟Ϸ ̤̕ ϶͙ϵ̲ϲ͍̲̕ delay? API RP 2D, PARAGRAPH 4.3.3b states: ϶Rζ̡Κϵ̨̤ ̤̕ ̤ζ̡̇ΚΨζ̍ζ̨̲̎ ̕π Ψ̤ϵ̲ϵΨΚ̇ components should be made as soon as ̡̤ΚΨ̲ϵΨΚ̇Ϸ ̨̖ζζ Fϰϰϰϯϰϯ̗ϰ 1. Check facility crane records for evidence of crane repair or replacements of critical components. 2. If repair or replacement has been made, verify work was done promptly and accomplished in accordance with API RP 2D, Appendix F, paragraph F.4.3.3, Crane Safety Assessment 50 Page # PINC Original Text Comments for Consideration item b. IF NONCOMPLIANCE EXISTS: Issue a component shut-in (C) INC if records indicate that work is not done promptly or accomplished in accordance with API RP 2D, Appendix F, paragraph F.4.3.3, item b. INSPECTION COUNT/ INC Enter one item checked/ issue one INC for each crane inspected. I161 ARE SLINGS OF ALL TYPE, GRADE, AND CONSTRUCTION IDENTIFIED AS REQUIRED IN API RP 2D, PARAGRAPH 5.2.4b? Note: ϶̇ϵ̎Ϩ ϵβζ̲̎ϵπϵΨΚ̲ϵ̎̕ ϵ̎Ψ͍̇βζ̨ ̨̇ϵ̎Ϩ ̍Κ͍̎πΚΨ̲͍̤ζ̤ϳ̨ ̎Κ̍ζϭ ̡ζ̤̲ϵ̎ζ̲̎ ͙̤̄̕ϵ̎Ϩ load limits, proof test certification number, length, diameter, and date of proof test. INSPECTION PROCEDURE: Verify that the slings have the specified ID tags attached. IF NONCOMPLIANCE EXISTS: Issue a component shut-in (C) INC if sling identification tag is missing. INSPECTION COUNT/ INC Enter one item checked/ issue one INC for each facility inspected. I162 ARE SLINGS PROPERLY STORED WHEN NOT IN USE IN ACCORDANCE WITH API RP 2D, APPENDIX G, PARAGRAPH G.5.2.1? Note: Slings should be stored in an area where they will not be exposed to water, extreme heat, or corrosive fumes, liquids and sprays. Slings should not be stored on the deck. All slings, when not in use, should be kept on a rack. Use of a rack minimizes accidental damage and allows easier monitoring of condition between regular inspections. If space limitations require that slings be stored along the side of the platform, they should be secured in a manner to prevent abrasion due to Crane Safety Assessment 51 Page # PINC Original Text Comments for Consideration rubbing and maintained in a manner to minimize corrosion. INSPECTION PROCEDURE: Visually inspect areas near cranes for slings which are not properly stored and maintained. IF NONCOMPLIANCE EXISTS: Issue a warning (W) INC if slings are not properly stored. Issue a component shut-in (C) INC if slings are not maintained in a manner to prevent loss of integrity due to abrasion or corrosion. INSPECTION COUNT/ INC Enter one item checked/ issue one INC for each facility inspected. I171 IS THE LESSEE ENSURING THAT THE MANUFACTURER IS CERTIFYING EACH CRANE MANUFACTURED AFTER MARCH 17, 2003, OR THAT EACH CRANE ON A FIXED PLATFORM INSTALLED AFTER MARCH 17, 2003, MEETS THE DESIGN, MATERIAL AND DIMENSIONAL SPECIFICATIONS USED IN THE CALCULATIONS AND HAS BEEN AUTHENTICATED IN ACCORDANCE WITH API SPEC 2C, PARAGRAPHS 5.5 AND 6.2? INSPECTION PROCEDURE: Should BSEE incorporate API Spec 2C, 7th edition, by reference the PINC should be corrected to the following citation: API SPEC 2C, Paragraph 4.1, and possibly 12.1.1. The ̲ζ̤̍ ϶Κ͍̲ϲζ̲̎ϵΨΚ̲ζβϷ β̕ζ̨ ̲̎̕ Κ̡̡ζΚ̤ ϵ̎ !PI SPEC 2C. 1. Verify that a nameplate is installed in compliance with API SPEC 2 C. 2. In the absence of the nameplate, verify that the lessee has the required ̍Κ͍̎πΚΨ̲͍̤ζ̤ϳ̨ ϵ̎π̤̍̕Κ̲ϵ̎̕ϰ IF NONCOMPLIANCE EXISTS: Issue one component shut-in (C) INC for each crane certification audited if the Lessee does not comply with API SPEC 2 C, Paragraph 5.5 and 6.2. INSPECTION COUNT/ INC Enter one item checked/ issue one INC for each crane inspected. Crane Safety Assessment 52 Page # I181 PINC Original Text Comments for Consideration DO ONLY QUALIFIED PERSONNEL PERFORM RIGGING OPERATIONS IN ACCORDANCE WITH API RP 2D, PARAGRAPHS 2.44, 3.1.3, AND 3.1.4? The reference to API RP 2D, Appendix A2 is incorrect. DEFINITION: The reference should be to Appendix A3. Rigger - Anyone who attaches or detaches lifting equipment to loads or lifting devices and who has received training in accordance with API RP 2D, paragraph 3.1.4 and Appendix A2. INSPECTION PROCEDURE: If rigging operations are in progress at the time of inspection, verify that personnel involved are qualified. IF NONCOMPLIANCE EXISTS: Issue a component shut-in (C) INC if rigging operations are in progress and personnel involved are not qualified. INSPECTION COUNT/ INC Enter one item checked/ issue one INC for each facility inspected. I182 ARE CRANES OPERATED ONLY BY QUALIFIED PERSONNEL IN ACCORDANCE WITH API RP 2D, PARAGRAPHS 3.1.1? DEFINITION: Qualified Person: A person who has met and passed the requirements of API RP 2D, paragraphs 2.42 and 3.1.2;    A trainee under the direct supervision of a Qualified Crane Operator; Appropriate maintenance and supervisory personnel, when it is necessary for them to do so in the performance of their duties. Note: No one other than the personnel specified above should enter a crane Crane Safety Assessment 53 Page # PINC Original Text Comments for Consideration cab. INSPECTION PROCEDURE: 1. Verify from facility records that crane operations were performed by qualified personnel. 2. If crane is in operation, verify that the person operating the crane is qualified. Note: 1. A crane operator is not qualified if qualifications are not maintained, at a minimum, every four years. 2. A written document from the facility operator stating that qualifications have been met is sufficient. IF NONCOMPLIANCE EXISTS: Issue a warning (W) INC if facility records indicate that the crane was previously operated by unqualified personnel. Issue a component shut-in (C) INC if the crane in operation during the inspection is operated by unqualified personnel. INSPECTION COUNT/ INC Enter one item checked/ issue one INC for each facility inspected. I183 ARE CRANE INSPECTORS QUALIFIED IN ACCORDANCE WITH API RP 2D, PARAGRAPH 2.43? The actual source documents of training and qualification should be verified. DEFINITION: Qualified Crane Inspector - A person so designated by the employer who by reason of appropriate experience and training, in addition to meeting the requirements of Qualified Crane Operator, has attended formal training in and successfully completed courses on crane maintenance and troubleshooting, hoist Crane Safety Assessment 54 Page # PINC Original Text Comments for Consideration troubleshooting and overhaul, and on structural aspects of offshore cranes, which gives a knowledge of structurally critical components and critical inspection areas for non-mechanical and/or mechanical cranes, as applicable. INSPECTION PROCEDURE: Verify from facility crane records that duties requiring a qualified crane inspector have been performed by qualified personnel. Note: 1. A crane inspector is not qualified if qualifications are not maintained, at a minimum, every 4 years. 2. A written document from the Operator stating that qualifications have been met is sufficient. IF NONCOMPLIANCE EXISTS: Issue a component shut-in (C) INC if records indicate that duties requiring a qualified crane inspector have been performed by unqualified personnel. INSPECTION COUNT/ INC Enter one item checked/ issue one INC for each facility inspected. I190 IS ALL MATERIAL-HANDLING EQUIPMENT OPERATED AND MAINTAINED IN A MANNER THAT ENSURES SAFE OPERATIONS AND PREVENTS POLLUTION? This question is excessively subjective. INSPECTION PROCEDURE: 1. Verify that material handling equipment is operated and maintained in a safe and pollution free manner. 2. Inspect records to ensure material handling equipment is operated per manufacturers and/or operators specifications. IF NONCOMPLIANCE EXISTS: Crane Safety Assessment 55 Page # PINC Original Text Comments for Consideration Issue a component shut-in (C) INC when; 1. Material handling equipment is not operated and maintained in a safe manner. 2. Material handling equipment is not operated and maintained in a pollution free manner. INSPECTION COUNT AND INC COUNT: Enter one item checked / issue one INC for facility inspected. NOTE - Material handling equipment includes, but is not limited to; air hoists, hoists, tugger, air tugger, winch, man-riding winch, come-a-long, monorail, gantry crane, jib Crane Safety Assessment 56 Page 5.1.1 Discussion and Analysis The objective of BSEE inspections is to ensure operator compliance with the letter and spirit of the statutes applicable to offshore operations. The letter of the law is objectively set out in specific regulatory language. The spirit of the law is much more subjective but can be inferred from the broad mandate of 30 CFR § 250.107: (a) You must protect health, safety, property, and the environment by: (1) Performing all operations in a safe and workmanlike manner; and (2) Maintaining all equipment and work areas in a safe condition. BSEE currently uses an inspection rubric based upon PINC. The PINCs are restatements of proscriptive and prescriptive regulations and standards incorporated by reference in 30 CFR 250. An observation, by a BSEE inspector, of non-compliance with a PINC gives rise to an Incident of Non-Compliance (INC). The IN ̍Κ͟ Χζ Κ ͙Κ̤̎ϵ̎Ϩϭ Ψ̡̍̎̕̕ζ̲̎ ϶̨ϲ͍̲-ϵ̎Ϸ ̤̕ πΚΨϵ̇ϵ̲͟ ϶̨ϲ͍̲-ϵ̎ϰϷ ϼϲζ̤̕ζ̲ϵΨΚ̇̇͟ϭ IN ̨ Κ̎β ̲ϲζ Ψ̤̤̕ζΨ̲ϵ͘ζ actions that follow should prevent the consequences associated with the hazards targeted by the PINC and identified by the INC; thereby achieving the goals described in the CFR. A review of the BSEE statistics on Crane and Personnel/Material Handling Incidents on the OCS indicates that from CY 2007 to CY 2013, there were 1158 incidents in those two combined categories. The raw totals for each year are: 161, 201, 222, 101, 109, 179 and 185. The two-year decline, 2010 to 2011, in incidents is most likely attributable to the moratorium on drilling in the aftermath of the Deepwater Horizon accident in April 2010. The yearly average is 165 incidents in the combined categories. In CY 2010, for example, 33 workers sustained reportable injuries during crane and material handling operations, with 24 requiring evacuation to shore-based medical facilities. The upward trend in the yearly totals since CY 2010 begs an attention-getting question. The BSEE inspection program could be one of the answers to this question. The PINCs, in their current form, focus on individual, technical compliance issues. The reported incidents/accidents, however, were the culmination of many in-process decisions and subsequent behaviors. An example of the difference in emphasis between ensuring technical compliance and ensuring that a comprehensive decision making process is at work may be found in a crane accident that occurred in November of 2007. The nylon sling used to lower a section of flowline was exposed to turbine generator exhaust of 800 degrees F, and subsequently failed, dropping the load 20 feet and pinning a rigger. The rigger had to be medically evacuated by helicopter due to serious injuries. The cause of the accident was listed as equipment failure, but there was no material fault found with the sling. There was no INC assessed; presumably the operator had satisfied PINC I161 and I162. A focus ̎̕ ̲ϲζ ̡̕ζ̤Κ̲̤̕ϳ̨ ϲΚͤΚ̤β analysis, JSA programs, and human error issues may have indicated a weakness in those areas or a more general safety culture issue. Of note, also, is the lack of emphasis on human factors in the PINCs. Many of the incident/accident reports list human error as the single cause or one of two causes. The field of human error has multiple Crane Safety Assessment 57 Page facets and is heavily nuanced. Frontline personnel errors, for example, cannot be viewed out of context; they must be analyzed in relation to possible supervisory, managerial, or organization errors. ϼϲζ PIN ̨ Κ̎β ̲ϲζ Κ̨̨̕ΨϵΚ̲ζβ βΚ̲Κ Ψ̤ζΚ̲ζ ϶̇ΚϨϨϵ̎ϨϷ ϵ̎βϵΨΚ̨̲̤̕ ̕π ̲ϲζ ̨Κπζ̲͟ ̨̲Κ̨̲͍ ̕π Κ̎ ̡̕ζ̤Κ̲̤̕ϰ !π̲ζ̤the-fact inspections of historical data tell little of the daily, operational culture of the organization. There are few questions regarding operator training requirements or programs. There are no questions on Safety and Environmental Management Programs (SEMP). There are no questions on neařmiss reporting. There are no questions concerning job hazard/safety analyses (JSA/JHA) or pre-lift/premovement surveys or plans. For example, in 2011, a fatal accident occurred on an offshore production platform. A rigger handling a ̲ΚϨ ̇ϵ̎ζ ͙Κ̨ ̄ϵ̇̇ζβ ͙ϲζ̎ ̲ϲζ Ψ̤Κ̎ζϳ̨ ̍Κϵ̎ ϲ̕ϵ̨̲ ͙ϵ̤ζ ̡̤̕ζ πΚϵ̇ζβϰ ϶̍̕ζ ̕π ̲ϲζ πϵ̎βϵ̎Ϩ̨ ̕π ̲ϲζ ϶EE investigation were:     The Crane was at approximately 118% of its capacity when the lift was undertaken; the operator did not have a separate written policy or manual for operation of cranes specifying procedures, use of tag lines, positioning of riggers, pre-use crane inspection; there was no internal methodology to insure the annual inspections by third parties comprehensively checked all components of the crane; the applicable JSA had been prepared two days earlier and used multiple times. A comprehensive crane safety policy would most likely contain a robust JSA program along with appropriate initial and recurrent training requirements. These programs indicate a pro-active safety and compliance attitude. Inspection parameters that highlighted pro-active safety program elements would provide data on what the operator is doing right, overall, rather than what went wrong in a specific incident. ϼϲζ ̨Κ̎Ψ̲ϵ̨̎̕ Ψ̲̎̕Κϵ̎ζβ ϵ̎ ̲ϲζ PIN ̨ ϵ̎βϵΨΚ̲ζ ̲ϲζ ΚϨζ̎Ψ͟ϳ̨ ̡̤ζβϵ̨̡̨̕ϵ̲ϵ̎̕ ̲͙̕Κ̤β Κ͙̇̇̕ϵ̎Ϩ ̡̕ζ̤Κ̲ϵ̨̎̕ ̲̕ continue for all but the most egregious non-compliant behavior. Many of the sanctions are inconsistent with the nature of the non-compliance or fail to consider the severity of the consequences if the hazard had resulted in an accident. For example: ϶I-182- ARE CRANES OPERATED ONLY BY QUALIFIED PERSONNEL IN ACCORDANCE WITH API RP 2D, PARAGRAPHS 3.1.1? Issue a warning (W) INC if facility records indicate that the crane was ̡̤ζ͘ϵ̨͍̇̕͟ ̡̕ζ̤Κ̲ζβ Χ͟ ͍̣͍̎Κ̇ϵπϵζβ ̡ζ̨̤̎̎̕ζ̇ϰϷ If the crane was operated by non-qualified personnel, the facility manager or operator allowed it, actually or constructively. The operating policies and procedures of the facility or vessel are suspect and need to be thoroughly reviewed for active and latent hazards. Allowing continued operations with only a warning validates the non-compliant attitudes. Additionally, there are several PINCs which allow a warning for missing or non-existent records of inspections, i.e. ϶I-152 ARE WRITTEN REPORTS CONFIRMING ADEQUACY OF REPAIRS OR ALTERATIONS IN ACCORDANCE WITH API RP 2D. Issue a warning (W) INC if written reports confirming the Crane Safety Assessment 58 Page adequacy of repairs or alterations are not immediately available or are not maintained for a ̡ζ̤ϵ̕β ̕π ϰ ͟ζΚ̨̤ϰϷ BSEE should consider reviewing the enforcement action related to I-15Ϯ Κ̎β ζ͘Κ͍̇Κ̲ζ ϵπ ϶͍̎Κ͘Κϵ̇ΚΧ̇ζ ̤ζΨ̤̕β̨Ϸ ̨ϲ͍̇̕β ͙Κ̤̤Κ̲̎ Κ ̤̍̕ζ ΚϨϨ̤ζ̨̨ϵ͘ζ ζ̎π̤̕Ψζ̍ζ̲̎ ΚΨ̲ϵ̎̕ ̲ϲΚ̎ Κ ͙Κ̤̎ϵ̎Ϩϰ Iπ Κ̎ ̡̕ζ̤Κ̲̤̕ ϵ̨ ̲̎̕ keeping records of inspections they are more than likely not conducting inspections. If an operator is not conduction inspections then they are unsafe to operate. ϼϲζ Ψ͍̤̤ζ̲̎ ̇ϵπ̲ϵ̎Ϩ PIN ̨ ̍Κ͟ πΚ̇̇ ϵ̲̎̕ ̲ϲζ ΨΚ̲ζϨ̤̕͟ ̕π ϶Ψ̡̍̇̕ϵΚ̎Ψζ ̍ζ̲̎Κ̇ϵ̲͟ϰϷ ϼϲϵ̨ ̡ϲ̤Κ̨ζ ͙Κ̨ ̨͍ζβ Χ͟ the Committee on Alternatives for Inspection of Outer Continental Shelf Operations (Committee), National Research Council in their 1990 report: Alternatives for Inspecting Outer Continental Shelf Operations.5 I̎ ̲ϲζ ̤ζ̡̤̲̕ ̲ϲζ ̍̍̕ϵ̲̲ζζ ζ̡̍ϲΚ̨ϵͤζβ ̲ϲΚ̲ ϶Ψ̡̍̇̕ϵΚ̎Ψζ β̕ζ̨ ̲̎̕ ζ̣͍Κ̇ ̨Κπζ̲͟ϰϷ ϼϲζ Committee explained that: ϶̘̲̙ϲζ Ψ̡̍̇̕ϵΚ̎Ψζ ̍ζ̲̎Κ̇ϵ̲͟ ζ̨̨ζ̲̎ϵΚ̇̇͟ ϵ̨ Κ̎ ΚΧΚ̎βonment of responsibility and judgment on the part of the operator and the passing of that responsibility to the regulating agency and its ϵ̨̡̎ζΨ̨̲̤̕ϱI̎ ͍̍Ψϲ ̲ϲζ ̨Κ̍ζ ͙Κ͟ϭ Κ̎ ϵ̨̡̎ζΨ̲̤̕ ̍Κ͟ πΚϵ̇ ̲̕ ̇̄̕̕ π̤̕ Χ̇Κ̲Κ̲̎ ̨Κπζ̲͟ ̡̤̕Χ̇ζ̨̍ because he has come to believe that, "My job is only to verify that all items on the checklist are OK. As long as I've done that job well, I can't be criticized if something goes wrong." F͍̤̲ϲζ̤ ζ͘ϵβζ̎Ψζ ̕π ̲ϲζ ϶Ψ̡̍̇̕ϵΚ̎Ψζ ̍ζ̲̎Κ̇ϵ̲͟Ϸ π̨̲̕ζ̤ζβ Χ͟ ̲ϲζ PIN ϳ̨ ϵ̨ π͍̎̕β ϵ̎ ̤ζ̡̤ζ̨ζ̲̎Κ̲ϵ͘e accident/incidents reports published on the BSEE website, District Investigation Reports: On 12/17/13 the lessee did not perform all operations in safe and workmanlike manner. An accident occurred that could have resulted in loss of life. A Spartan Offshore employee fell approximately 55 feet from the Texas Deck to the production platform below. BSEE investigators found the following during the investigation. 1) Grating on the Texas Deck was not secured at the time of the incident. 2) Injured employee was not introduced into the JSA. 3) Injured employee did not utilize fall protection properly. 4) Injured person did not have "Fall Protection Including Rescue Planning (OSHA 1926.500) and/or SPRAT Training" as stated in Spartan Offshore training matrix. Appropriate INCs were issued but no recommendations for long-term corrective actions were made to the operator or the Agency. O̎ OΨ̲̕Χζ̤ Ϯϯϭ Ϯ΄ϭϯϱ͙ϲζ̎ ̲ϲζ ̨ζΨ̎̕β ́̕ϵ̲̎ ̕π ΨΚ̨ϵ̎Ϩ ζ̍ζ̤Ϩζβ π̤̍̕ ̲ϲζ ͙ζ̇̇ Κ̎β Ψ̇ζΚ̤ζβ ̲ϲζ top of the work basket on the casing jacks, the dead man pad eye for the main hoist line ripped out of the right cord of the crane boom to which it had been welded. The main hoist block, weight indicator and the 1.5" two-part sling in use fell from the boom and was left suspended from the top of tϲζ ΨΚ̨ϵ̎Ϩ ̲̕ ͙ϲϵΨϲ ϵ̲ ͙Κ̨ Κ̲̲ΚΨϲζβϱϼϲζ ̨̲Κ̲ϵΨ ̇̕Κβ ̇ϵ̍ϵ̲ ͙Κ̨ ͍̲ϵ̇ϵͤζβ π̤̍̕ ̲ϲζ load chart rather than the dynamic limit. At 27,000 lbs. of pull, the dynamic limit of 19,710 lbs. 5 The Committee on Alternatives for Inspection of Outer Continental Shelf Operations National Research Council. Alternatives for Inspecting Outer Continental Shelf Operations (1990). Retrieved from NAP.EDU: http://www.nap.edu/catalog/1517.html. (November 17, 2014). Crane Safety Assessment 59 Page was exceeded by 7,290 lbs. when initially attempting to free the casing from the well. The installation of the failed dead man pad eye for the main hoist line was performed without an installation procedure, welding procedure, engineered drawing of the pad eye, NDT procedure or any type of approval or guidance from the original manufacturer of the crane, crane service company, or engineer. The incorrect installation of the pad eye led to it being pulled from the crane boom cord. Again, appropriate INCs were issued without operator or Agency recommendations. BSEE should review both scenarios and determine why accident investigators would not express greater Ψ̎̕Ψζ̤̎ ͙ϲζ̎ Κ πΚ̲Κ̇ϵ̲͟ ϵ̎Ψϵβζ̲̎ ͙Κ̨ ̎Κ̤̤͙̇̕͟ Κ͘̕ϵβζβ ϵ̎ ̎̕ζ ϵ̨̲̎Κ̎Ψζ Κ̎β Κ Ψ̤Κ̎ζϳ̨ β̎͟Κ̍ϵΨ ̇ϵ̍ϵ̲ ͙Κ̨ ζ͞Ψζζβζβ Χ͟ ϯϲ% ϵ̎ ̲ϲζ ̲̕ϲζ̤ϰ ϼϲζ ̨̲̤̕ζβ ζ̎ζ̤Ϩ͟ ϵ̎ ̲ϲζ Ψ̤Κ̎ζϳ̨ Χ̍̕̕ Κ̎β ΨΚΧ̇ζ Ψould have been suddenly released with catastrophic consequences. The Committee made several recommendations in its 1990 report, two of which are appropriate to this discussion of PINCs:  ϱ̲ϲΚ̲ MM϶ ̡̇ΚΨζ ϵ̨̲ ̡̤ϵ̍Κ̤͟ ζ̡̍ϲΚ̨ϵ̨ ̎̕ βζ̲ζΨ̲ϵ̎̕ ̕π ̡̲̕ζ̲̎ϵΚ̇ ΚΨΨϵβζ̎t-producing situations̎particularly those involving human factors, operational procedures, and modifications of equipment and facilities̎rather than scattered instances of non-compliance with hardware specifications. ..  ϱ̲ϲΚ̲ MM϶ ζ̎Ψ͍̤̕ΚϨζ ϵ̨̲ ϵ̨̡̎ζΨ̨̲̤̕ ̲o uncover emerging kinds of safety risks and changing risks on OCS facilities. The position description, job assignments, and reward structure for MMS inspectors should be modified to reflect the importance of uncovering and reporting safety risks. The Com̍ϵ̲̲ζζ π͍̤̲ϲζ̤ ζ̡̇͞Κϵ̎ζβ ̲ϲΚ̲ ϶[t]he hardware-oriented PINCs seemingly are not tied closely to current accident experience-this observation does not imply that fatalities have not been averted as a result of these PINCs being enforced̎rather it is meant to suggest that the safety-enhancement limits ̕π Κ ϲΚ̤β͙Κ̤ζ ̤̕ϵζ̲̎ζβ ϵ̨̡̎ζΨ̲ϵ̎̕ ̡̤̕Ϩ̤Κ̍ Κ̤ζ Χζϵ̎Ϩ ̤ζΚΨϲζβϰϷ ϼϲζ̨ζ ̕Χ̨ζ̤͘Κ̲ϵ̨̎̕ ͙ζ̤ζ ̍Κβζ ̤̍̕ζ ̲ϲΚ̎ π͍̤̲̕ζζ̎ ͟ζΚ̨̤ ΚϨ̕ϰ ϼϲζ PIN ̨ Κ̡̡ζΚ̤ ̲̕ ϲΚ͘ζ ΨϲΚ̎Ϩζβ ̇ϵ̲̲̇ζ ̨ϵ̎Ψζ ̲ϲζ ̍̍̕ϵ̲̲ζζϳ̨ ϭϵϵ΄ ̤ζ̡̤̲̕ϰ 5.1.2 Conclusion and Recommendations The analysis of the current PINC-ΧΚ̨ζβ ϵ̨̡̎ζΨ̲ϵ̎̕ ̡̤̕Ϩ̤Κ̍ ϵ̎βϵΨΚ̲ζ̨ ̲ϲΚ̲ ϵ̲ ̤ζ̇ϵζ̨ ϲζΚ͘ϵ̇͟ ̎̕ Κ ϶̤̲̕ζϷ level of compliance with individualized requirements. The tools provided inspectors are simple restatements of proscriptive and prescriptive regulations and standards incorporated by reference without a clear, comprehensive goal. The sanction guidance in the PINC also needs to be reviewed for consistency with the hazard identified and associated potential consequences. The current PINCs anβ ̨Κ̎Ψ̲ϵ̨̎̕ Κ̤ζ Κ ϶ϲΚ̤β͙Κ̤ζ ̤̕ϵζ̲̎ζβ ϵ̨̡̎ζΨ̲ϵ̎̕ ̡̤̕Ϩ̤Κ̍Ϸ Κ̎β ζ͘ϵβζ̎Ψζ ̕π ̲ϲζ ϶Ψ̡̍̇̕ϵΚ̎Ψζ ̍ζ̲̎Κ̇ϵ̲͟Ϸϭ ̲ϲΚ̲ ͙Κ̨ βζ̨Ψ̤ϵΧζβ ϵ̎ ̲ϲζ ̍̍̕ϵ̲̲ζζ ̎̕ !̲̇ζ̤̎Κ̲ϵ͘ζ̨ π̤̕ Į̡̎ζΨ̲ϵ̎̕ ̕π O͍̲ζ̤ Continental Shelf Operations 1990 report. The conclusion of this analysis is that the assessment and recommendations of the Committee are still valid. BSEE should: Crane Safety Assessment 60 Page  Place its primary emphasis on detection of potential accident-producing situations̎particularly those involving human factors, operational procedures, and modifications of equipment and facilities̎rather than scattered instances of non-compliance with hardware specifications;  Encourage its inspectors to uncover emerging kinds of safety risks and changing risks on OCS facilities. The position description, job assignments, and reward structure for MMS inspectors should be modified to reflect the importance of uncovering and reporting safety risks.  Subject all safety of life or high consequence near-miss incidents to a through root case analysis (RCA) that incorporates human factors to generate long-term corrective actions for the industry. ϼϲζ π͙̇̇̕̕ϵ̎Ϩ ̤ζΨ̍̍̕ζ̎βΚ̲ϵ̨̎̕ π̤̕ ̍̕βϵπϵΨΚ̲ϵ̨̎̕ ̲̕ ̲ϲζ ̇ϵπ̲ϵ̎Ϩ PIN ̨ Κ̤ζ ̡̤̕͘ϵβζβ π̤̕ ϶EEϳ̨ consideration and intended to improve the oversight of lifting operations on the OCS.  BSEE shou̇β ̤ζ̡ϲ̤Κ̨ζ ̲ϲζ PIN ̣͍ζ̨̲ϵ̨̎̕ ̲̕ ζ̡̍ϲΚ̨ϵͤζ Κ̎ ̡̕ζ̤Κ̲̤̕ϳ̨ ̤ζ̨̡̨̎̕ϵΧϵ̇ϵ̲͟ ̲̕ Ψ̡̍̇̕͟ with 30 CFR 250.198 and 30 CFR 250.1902(c).  For a number of the PINCs, BSEE should require an operator produce documentation and demonstrate proficiency in locating information related to his or her duties and responsibilities. Next, the inspector should evaluate it against applicable standards and practices 5.1.3 Updated PINCs ϼϲζ ̨̲͍β͟ ̲ζΚ̍ ̡̤̕͘ϵβζβ ̤ζΨ̍̍̕ζ̎βΚ̲ϵ̨̎̕ π̤̕ ϶EEϳ̨ Ψ̨̎̕ϵβζ̤Κ̲ϵ̎̕ π̤̕ ̡͍βΚ̲ϵ̎Ϩ ̲ϲζ ζ͞ϵ̨̲ϵ̎Ϩ ̇ϵπ̲ϵ̎Ϩ PINCs. The recommendations were circulated amongst internal BSEE stakeholders for feedback. The project team updated the PINCs based on the final direction recommended by the BSEE project sponsors. Changes and modifications to existing lifting PINCs are highlighted and displayed in track changes below. PINCs are provided in Appendix A and will serve as the interim lifting PINCs during a ̲̤Κ̨̎ϵ̲ϵ̎̕ π̤̍̕ ̲ϲζ ϶!̨-ĮϷ ̲̕ ̲ϲζ ϶ϼ̕- ζϷ ̨̲̤͍Ψ̲͍̤ζϰ 5.2 Analysis of INCs and OIRs The objective of this effort was to analyze failure event data to identify trends and key issues that could be addressed in the development of an improved offshore crane and material handling equipment inspection program. This following analysis summarizes the data provided by BSEE. The scope of this effort included the analysis of PINC, Incidents of Noncompliance (INC), and Offshore Incident Reports (OIR) data as recorded by BSEE over varying periods of time (2004 ̌ 2014). This analysis involved the review and trending of 846 Incidents for a nominal 5-year time period (i.e., 2009 through 2013) of operations in the GOM Region and Pacific Regions. The analysis focused on sorting and trending the data to identify the failure event trends based on:      Failure cause Incident type Lifting Device Failure Type of Lift Type of facility Crane Safety Assessment 61 Page    Activity at time of the incident Location of the incident Contributing Factor to Failure The analysis results presented in based on the following assumptions:    The raw failure event data provided by the BSEE were assumed to be accurate and complete. This analysis is limited to the data provided by BSEE. The Offshore Incidents Reports (OIRs) did not provide sufficient data for analysis and was included from the analysis. 5.2.1 Results This summary provides an overall view of the dominant failures and failure modes for the cranes and material handling equipment operating in the GOM Region and Pacific Regions. These results are based on the number of recorded incidents and corresponding failure modes included in the BSEE provided data. Crane Safety Assessment 62 Page Lifting Incident Type Table 12 provides summary of the lifting incident type based on the categories as provided by the BSEE. Crane non-lifting incidents refer to incidents while the crane was either not engaged in an actual lift such as repositioning or the incident defect was discovered during inspection or maintenance. The majority of the incidents occurred during material handling, followed by pipe handling, and crane (nonlifting)." Non-lifting incident are those that occurred while the crane or material handling equipment was not involved in a lifting evolution, such as when repositioning the boom for maintenance. Also it is evident from the data that there was significant reduction in the incidents during period 2010 which is attributed to the OCS drilling moratorium. After a short decrease in the incident rate, the rate rapidly increased to pre-moratorium levels. Table 12: Lifting Incident Type Equipment Type Crane (non-lifting) Material Handling Personnel Handling Pipe Handling Combination Other Device (non-lifting) Crane (unspecified) Unknown Total 2009 18 138 18 32 0 0 0 0 206 2010 7 82 8 12 0 0 0 0 109 2011 18 81 10 20 6 1 3 1 140 2012 11 113 12 36 0 1 0 7 180 2013 12 137 13 34 0 4 2 7 209 Number of Failures Lifting Incident Type 100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% 600 500 400 300 200 100 0 Failure Type Crane Safety Assessment 63 Page Failure Cause Table 13 provides summary of the failure causes that contributed to the crane incident. As evident from the data, employee failure was the main cause of the incidents from year 2009 to 2013. The bulk ΨΚ̨͍ζ ̕π ̲ϲζ ̇ϵπ̲ϵ̎Ϩ πΚϵ͍̤̇ζ̨ ϵ̨ Ψ̇Κ̨̨ϵπϵζβ Κ̨ ζϵ̲ϲζ̤ ϶ζ̡̍̇̕͟ζζ πΚϵ͍̤̇ζϷ ̤̕ Κ̨ ͍̎βζ̲ζ̤̍ϵ̎ζβϰ ϶ϵ̎Ψζ ̲ϲζ ΨΚ̲ζϨ̤̕ϵζ̨ ̕π πΚϵ͍̤̇ζ Κ̤ζ ͍̎βζπϵ̎ζβϭ ͙ζ Κ̨̨͍̍ζ ̲ϲΚ̲ ϶ζ̡̍̇̕͟ζζ πΚϵ͍̤̇ζϷ ϵ̨ ζϵ̲ϲζ̤ Κ̎ ϵ̲̎ζ̲̎ϵ̎̕Κ̇ ̤̕ unintentional human error or a routine or exceptionȧ ͘ϵ̇̕Κ̲ϵ̎̕ ̕π ̲ϲζ ̡̕ζ̤Κ̲̤̕ϳ̨ ̍Κ̲ζ̤ϵΚ̇ ϲΚ̎β̇ϵ̎Ϩ safety policies or procedures. This would be expected since between 60 and 80 percent of these kinds of incidents are related to human error. However, the data is not classified in a way that lends itself to any meaningful analysis of human error. Conversely, a large fraction of the data could not be classified due to a lack of specificity or taxonomy in the collection. Table 13: Failure Cause Failure Cause Employee failure Equipment failure Other Unknown 2009 134 63 6 3 2010 76 28 1 4 2011 91 46 0 3 2012 97 38 8 37 2013 102 42 31 34 250 200 Cause of Failure Can't tell from data 150 Cause of Failure Other 100 Cause of Failure Equipment failure Cause of Failure Employee failure 50 0 2009 Crane Safety Assessment 2010 2011 2012 2013 64 Page Failed Lifting Device Table 14 ̨͍̍̍Κ̤ϵͤζ̨ ̲ϲζ ϵ̎Ψϵβζ̲̎ ̡̲͟ζ ΧΚ̨ζβ ̎̕ ̲ϲζ ̇ϵπ̲ϵ̎Ϩ βζ͘ϵΨζ ϵ̎̇͘̕͘ζβϰ ϼϲζ ϶̡ζ̤̍Κ̎ζ̲̎ Ψ̤Κ̎ζϷ category had the highest number of associated incidents. The data analysis is confounded by the inclųϵ̎̕ ̕π ϶ζ̡̍̇̕͟ζζϷ Κ̨ Κ ̇ϵπ̲ϵ̎Ϩ βζ͘ϵΨζϰ Table 14: Lifting Device that Failed Failed Lifting Device 2009 Permanent Crane 155 Other (Unspecified) 18 Air Tugger (construction) 10 Temporary crane (leap frog) 7 Elevators on Drilling Rig 5 Come-Along 3 Crane Winch 2 Employee 2 Lifting Spider 1 Over Hoist 1 Slings 1 Bridal 0 Chain fall 0 Lifting Ring (D Ring) 0 Monorail 0 Top Drive on Drilling Rig 0 Workover Unit 0 2011 118 4 2 0 5 1 3 4 0 3 0 0 0 0 0 0 0 2012 129 20 7 0 5 2 2 2 1 0 4 0 1 3 0 4 0 2013 150 9 6 0 8 0 2 9 0 6 11 0 2 0 0 3 3 2013 2012 Permanent Crane Other !ϵ̤ ̲͍ϨϨζ̤ϱ ϼζ̡̤̍̕Κ̤͟ Ψ̤Κ̎ζϱ Elevators on drlg rig Come along Crane winch Employee Lifting spider Over hoist Slings Bridal Chain fall Lifting Ring (D ring) Monorail Top Drive on drlg rig Workover unit 700 600 500 400 300 200 100 0 2010 84 4 14 0 4 0 0 0 1 0 0 0 1 0 0 1 0 2011 2010 2009 Lifting Device that Failed Crane Safety Assessment 65 Page Lifting Failure Type Table 15 ϵ̨͍̲̤̇̇Κ̲ζ̨ ϵ̎Ψϵβζ̲̎ βΚ̲Κ ΧΚ̨ζβ ̎̕ ̲ϲζ ̡̲͟ζ ̕π ̇ϵπ̲ϵ̎Ϩ πΚϵ͍̤̇ζϰ ϶L̕Κβ ̨̎ΚϨϨζβ ̤̕ Ψ̲̎̕ΚΨ̲ζβϷ ͙Κ̨ ̲ϲζ ̨̲̍̕ ̡̤ζ͘Κ̇ζ̲̎ πΚΨ̲̤̕ Ψ̲̤̎̕ϵΧ͍̲ϵ̎Ϩ ̲̕ Ψ̤Κ̎ζ ϵ̎Ψϵβζ̨̲̎ϭ π͙̇̇̕̕ζβ Χ͟ ϶E̡̍̇̕͟ζζ FΚϵ͍̤̇ζϰϷ Here also, the data analysis is confused by the inclusion of employee failure as a causal factor alongside other mechanical equipment. Table 15: Type of Lifting Failure Lifting Failure Load Snagged or Contacted Component of lifting device other than boom (i.e. hoist, wire, etc.) Employee Failure Rigging Component Load Shifted Boom Failure Other Drilling Associated Equipment Failure Unspecified Tag Line Snagged 300 250 200 150 100 50 0 2009 77 2010 43 2011 36 2012 45 2013 68 36 14 21 29 45 25 23 12 11 8 7 5 1 15 8 10 13 0 6 0 0 30 14 1 16 16 3 0 3 62 17 4 4 9 6 2 2 17 17 12 11 17 18 2 1 2013 Tag Line snagged Unspecified Drlg assoc. eqmt failure Other Boom Failure Load shifted Rigging Component Employee failure Component of lifting βζ͘ϵΨζ ̲̕ϲζ̤ ̲ϲΚ̎ϱ Load Snagged or contacted 2012 2011 2010 2009 Type of Lfiting Failure Crane Safety Assessment 66 Page Lift Type ϶DζΨ̄ ̲̕ DζΨ̄Ϸ ̡̕ζ̤Κ̲ϵ̨̎̕ ΚΨΨ͍̲̎̕ζβ π̤̕ ̲ϲζ ̍Κ̤́̕ϵ̲͟ ̕π Ψ̤Κ̎ζ ϵ̎Ψϵβζ̨̲̎ϭ ΚΨΨ̤̕βϵ̎Ϩ ̲̕ βΚ̲Κϭ Κ̨ illustrated by Table 16. This generally results from conducting critical lifts such as blind lifts from one laydown area on the platform to another laydown area on the platform or picking or landing a load in a congested area. Non-lifting events include events that caused a failure or incident when the equipment was not actually engaged in a lift or the damage was discovered during inspection or maintenance. Table 16: Type of Lift Lift Type 2009 99 43 25 15 3 17 4 0 Deck to Deck Marine Vessel to Platform Deck Plat. Deck to Marine Vessel Rig floor/V-door/Well Vessel to Vessel Non-Lift Subsea to Facility Unknown 2010 48 21 16 13 2 8 1 0 350 300 250 200 150 100 50 0 2011 32 30 28 12 2 18 4 14 2012 59 35 28 18 2 13 11 14 2013 82 37 21 33 2 15 8 9 2013 Unknown Subsea to facility Non-lift Vessel to Vessel Rig floor/V-door/Well Plat. Deck to Marine Vessel Marine Vessel to Plat. Deck Deck to Deck 2012 2011 2010 2009 Type of Lift Crane Safety Assessment 67 Page Facility Type The vast majority of crane incidents on the OCS occurred on fixed platforms, as shown in Table 17. This would be noteworthy since fixed platforms are the most stable of offshore facilities and not subject to dynamic loading due to facility motion in a seaway. The data are interpreted to be a skew due to relative population sizes between fixed and floating facilities. Table 17: Type of Facility Facility Type Caisson Drill Ship Fixed Platform FPSO Jackup MODU Liftboat Marine Vessel Other Semisubmersible MODU SPAR TLP Unknown 2009 0 4 137 1 16 11 5 1 12 5 6 0 2010 0 0 67 1 3 3 2 0 9 9 10 0 2011 2 4 72 0 13 0 4 2 15 12 9 7 450 400 350 300 250 200 150 100 50 0 2012 4 20 77 0 14 0 0 4 23 10 11 17 2013 2 20 85 0 6 0 0 27 45 8 8 8 2013 2012 Unknown TLP SPAR Semisubmersible Other Marine Vessel Liftboat Jackup drilling rig FPSO Fixed Platform Drill ship Caisson 2011 2010 2009 Type of Facility Crane Safety Assessment 68 Page Activity Type As the majority of lifting operations are conducted in support of drilling and production operations, the data shown in Table 18 supports a finding that a majority of crane and material handling incidents occurred during production operations. Table 18: Activity at Time of Incident Activity Type Completions Construction Drilling Other Production Operations Workover 2009 10 23 39 3 106 17 2010 0 9 30 1 61 8 400 350 300 250 200 150 100 50 0 2011 5 12 20 12 78 13 2012 5 5 52 24 53 13 2013 19 14 58 23 81 14 2013 Workover Production Operations Other Drilling Construction Completions 2012 2011 2010 2009 Activity at time of Incident Crane Safety Assessment 69 Page Incident Location Table 19 shows the locations of the incidents. The high percentage of incidents on the production platform is expected due to population skew. The percentage of drill rig floor and MV deck incidents are interpreted to be due to high congestion and vessel motion, respectively. Table 19: Location of Incident Incident Location Production Platform Drilling Rig Floor MV Deck Underwater Crane Other Unknown 2009 144 17 29 3 6 6 0 2010 0 0 0 0 0 0 0 400 350 300 250 200 150 100 50 0 2011 68 25 38 1 0 0 0 2012 57 47 41 0 16 16 0 2013 88 45 33 4 7 28 0 2013 2012 2011 Other Crane Underwater MV deck Drlg Rig floor Prod Platform 2010 2009 Location of Incident Crane Safety Assessment 70 Page Employees Injured Table 20 indicates that Riggers and Rig Floor Hands experienced most of the injuries associated with lifting incidents. It is expected that these two categories of workers would be involved in the most incidents since they have the most temporal and spatial exposure to lifting equipment and operation. Mention is made of the number of personnel injured during lifting operations involving the personnel basket transfers. Table 20: Injury to Whom Employee Type Rigger Rig Floor Hand Other Personnel Basket MV Deckhand Crane Operator Flagger (Signalman) Production Operator Diver 2009 32 10 9 6 4 1 1 1 0 2010 20 12 2 4 1 0 0 0 0 90 80 70 60 50 40 30 20 10 0 2011 3 4 11 0 4 1 0 0 0 2012 15 22 13 8 5 3 0 3 0 2013 15 19 5 3 0 1 0 0 1 2013 2011 Diver Prod Operator Flagger (signalman) Crane Operator MV Deckhand Personnel basket Other Rig Floor hand Rigger 2012 2010 2009 Injury to whom Crane Safety Assessment 71 Page Contributing Failure Table 21 shows the contributing factor to lifting failure. The three major contributors to lifting failures in βζ̨Ψζ̎βϵ̎Ϩ ̤̕βζ̤ ͙ζ̤ζ ̖ϭ̗ P̨̕ϵ̲ϵ̎̕ϭ ̖Ϯ̗ Κ̎ϳ̲ ϼζ̇̇ π̤̍̕ DΚ̲Κ Κ̎β ̖ϯ̗ ϼ̤Κϵ̎ϵ̎Ϩϰ I̎ Κββϵ̲ϵ̕n, a significant ͍̎̍Χζ̤ ̕π ̲ϲζ ϵ̎Ψϵβζ̨̲̎ ̖ϱϭ̗ ͙ζ̤ζ Κ̲̲̤ϵΧ͍̲ΚΧ̇ζ ̲̕ ϶O̲ϲζ̤ϰϷ !̎͟ ϵ̎πζ̤ζ̎Ψζ̨ ̤̕ ̲̤ζ̎β̨ β̤Κ͙̎ π̤̍̕ ̲ϲϵ̨ data are uncertain due to the significant number of contributing factors that are undefined or unidentified. Table 21: Contributing Factor to Failure 2009 72 54 42 20 12 6 Training Can't Tell from Data Position Other Lack of Maintenance Lack of Knowledge 2010 30 48 27 3 1 0 2011 0 4 6 15 1 0 120 100 80 60 40 20 0 2012 0 4 16 2 0 0 2013 6 4 25 11 1 0 2013 Lack of knowledge Lack of maintenance Other Position Can't tell from data Training 2012 2011 2010 2009 Contributing factor to failure Crane Safety Assessment 72 Page 5.2.2 Conclusion and Recommendations INC data provided by BSEE provided basic numerical information concerning involved mechanical components, generic operating parameters, and location. However, the data are not organized in any systematic way which would lend itself to reliable analysis. All categories and taxonomies of data are those supplied by BSEE. It was not possible to determine what many of these taxonomies included in ̲ϲζ βΚ̲Κϰ ϼϲ̨͍ϭ ϨΚ̡̨ ϵ̎ ̲ϲζ βΚ̲Κ ϵβζ̲̎ϵπϵζβ Χ͟ ΨΚ̲ζϨ̤̕ϵζ̨ ̨͍Ψϲ Κ̨ ϶̲̕ϲζ̤Ϸϭ ϶̇ΚΨ̄ ̕π ̍Κϵ̲̎ζ̎Κ̎ΨζϷϭ ϶ζ̡̍̇̕͟ζζ πΚϵ͍̤̇ζϷϭ ϶̨̡͍̎ζΨϵπϵζβϷϭ Κ̎β ϶͍͙̎̄̎̎̕Ϸϭ ͍̎βζ̤̍ϵ̎ζ ̲ϲζ Ψ̤ζβϵΧϵ̇ϵ̲͟ ̕π Κ̎͟ ϵ̎πζ̤ζ̎Ψζ̨ ̤̕ ̲̤ζ̎β̨ϰ F̤̕ ζ͞Κ̡̍̇ζϭ ϶ζ̡̍̇̕͟ζζ πΚϵ͍̤̇ζϷϭ ϶̲̤Κϵ̎ϵ̎ϨϷ Κ̎β ϶̇ΚΨ̄ ̕π ͙̄̎̇̕ζβϨζϷ Κ̤ζ Κ̇̇ ϲ͍̍Κ̎-centric contributing factors; but lack of knowledge could be the result of improper or incomplete training. For example:       How is employee failure defined? Was the failure a mistaken application of an acquired psychomotor skill or the correct accomplishment of an incorrect procedure? In what type supervisory environment did the failure occur? Was the procedure involved established or ad hoc or were the operators freelancing? In what operational environment did the failure occur? Was there an actual or implied pressure from upper management to meet an operational deadline or goal? Incident data must to be collected with the goal of identifying undesirable circumstances and behaviors, which can then be targeted by strategies to mitigate future occurrences. The data provided by BSEE appears to be collected without any strategic goal other than to document incidents that have occurred on the OCS. There is no unified or cohesive taxonomy which would allow analysis to predict where inspection and enforcement mitigation efforts should be applied. Therefore, it is difficult or impossible to conclude any definitive findings or produce recommendations from the data set provided. Offshore Incident Reports (OIR) were even more generic and provided little detail so they were excluded from the data. BSEE data collection should be organized with a taxonomy that classifies the incidents in a way that allows comprehensive data analysis. This analysis can then be used to guide and increase the efficiency of regulatory surveillance efforts. INC data can be customized to the desired end state and data Ψ̇̇̕ζΨ̲ϵ̎̕ ζππ̤̲̕ϰ ϼϲϵ̨ πΚΨζ̲ ̕π βΚ̲Κ Ψ̇̇̕ζΨ̲ϵ̎̕ ̨͍̲̍ Χζ Κϵ̍ζβ Κ̲ ΚΨΨ͍͍̍̇Κ̲ϵ̎Ϩ ϶̇ζΚβϵ̎Ϩ ϵ̎βϵΨΚ̨̲̤̕Ϸ ̲ϲΚ̲ could point to active and latent hazards, which could then be targeted for elimination or mitigation. Leading indicators identify hazards and deficiencies before they achieve negative results. Examples of leading indicators would be:     Interval between mishap/incident and final report Number of incident report recommendations actually implemented Number of supervisory/management personnel with formal incident investigation training Number of supervisory/management personnel with formal human error prevention training Crane Safety Assessment 73 Page      Overtime ratios Near miss reports Span of control ratios J϶!ϳ̨ ̨̡̲̕ ΨϲζΨ̄ζβ Χ͟ ϶Κπζty Personnel Policy and procedural review intervals It is recommended that BSEE adopt the root cause analysis (RCA) methodology promulgated in ABS Guidance Notes on the Investigation of Marine Incidents. This incident methodology provides an effective and efficient approach for investigating marine incidents of any magnitude, including offshore material handling and crane operations. It provides a technique that will guide BSEE investigators in identifying, documenting, classifying and trending the causes of mishaps (incidents and accidents) and allow analysis as to whether the mishap is related to safety, the environment, human error, or mechanical failure. The data collection process and storage is easily adapted to this methodology through its numeric coding of causal factors and root causes of the mishap. This numeric coding can then be easily analyzed to guide regulatory surveillance efforts. 6 Analysis of Industry Standards The study team analyzed lifting standards, inspection methodologies and strategies to identify best ̡̤ΚΨ̲ϵΨζ̨ Κ̎β ̡̤̕͘ϵβζ ̤ζΨ̍̍̕ζ̎βΚ̲ϵ̨̎̕ π̤̕ ϶EEϳ̨ Ψ̨̎̕ϵβζ̤Κ̲ϵ̎̕ ϵ̎ ̲ϲζ ϵ̎Ψ̡̤̤̕̕Κ̲ϵ̎̕ ̕π ̲ϲζ̨ζ ̡̤ΚΨ̲ϵΨζ̨ into an inspection strategy. The following sections summarize the analysis and results. 6.1 Domestic and International Inspection Methodologies The study team evaluated other inspection methodologies being applied domestically and internationally on cranes and material handling equipment. The objective was to compare the procedures and guidance of existing crane inspection methodologies with the PINC methodology. The comparison validates the PINC methodology and informs future improvements. 6.1.1 Comparison of Existing Inspection Methodologies There is a long list of manufacturers that design and build lifting equipment for installation and use offshore. There is an impressive array of crane types, configurations and capabilities. Many cranes have been in operation for multiple decades. The inherent complexities of crane operation and inspection require that inspectors have a broad scope of technical knowledge and operational experience to effectively employ any inspection methodology that purports to assess compliance with offshore regulations and standards. Currently, BSEE inspectors employ an inspection methodology that evaluates an operator against PINC. PINCs Κ̤ζ ϶ΨϲζΨ̄̇ϵ̨̲ ϵ̲ζ̨̍ ͙ϲϵΨϲ ϶EE ϵ̨̡̎ζΨ̨̲ to pursue safe operations on the OCS. This list of ϵ̨̡̎ζΨ̲ϵ̎̕ ϵ̲ζ̨̍ ϵ̨ βζ̤ϵ͘ζβ π̤̍̕ Κ̇̇ ̤ζϨ͍̇Κ̲ϵ̨̎̕ π̤̕ ̨Κπζ̲͟ Κ̎β ζ̎͘ϵ̤̎̍̕ζ̲̎Κ̇ ̨̲Κ̎βΚ̤β̨ϰϷ Crane Safety Assessment 74 Page PINC as a Baseline for Comparisons PINC specific t̕ ̕ππ̨ϲ̤̕ζ Ψ̤Κ̎ζ̨ Κ̤ζ Ψ̕βζβ Κ̨ ϶I-ϭ͞͞ϰϷ EΚΨϲ ͍̎̍Χζ̤ζβ PIN Ψ̨̎̕ϵ̨̨̲ ̕π Κ ̨ϵ̎Ϩ̇ζ ̣͍ζ̨̲ϵ̎̕ or challenge that targets a specific standard or criteria, i.e. API RP 2D, PARAGRAPH 3.1.5a. Included in the PINC is a regulatory reference, level of sanction and inspection procedure. An example of a cranespecific PINC is displayed below. I-144 HAVE MONTHLY INSPECTIONS BEEN PERFORMED BY A QUALIFIED CRANE OPERATOR/INSPECTOR WITH RECORDS, IN ACCORDANCE WITH API RP 2D, PARAGRAPH 4.1.2.3 AND 4.2.2, READILY AVAILABLE FOR A PERIOD OF FOUR YEARS? Authority: 30 CFR 250.108 Enforcement Action: W/C Note: ϭϰ !̡̡̇ϵζ̨ ̲̕ HζΚ͘͟ ̨̀ΚϨζ Κ̲ζϨ̤̕͟ Ψ̤Κ̎ζ̨ϰ !̎ O̡ζ̤Κ̲̤̕ϳ̨ πΚϵ͍̤̇ζ ̲̕ document usage category will cause the crane to default to the Heavy Usage category. Inspection criteria must be in accordance with API RP 2D, Appendix C, paragraph C.4.1.2b. Ϯϰ Rζπζ̤ζ̎Ψζ !̡̡ζ̎βϵ͞ Ϯϰ π̤̕ βζπϵ̎ϵ̲ϵ̎̕ ̕π ϶M̲̎̕ϲ̇͟Ϸ Κ̎β βζ̨Ψ̤ϵ̡̲ϵ̎̕ ̕π ϶̨̀ΚϨζ Κ̲ζϨ̤̕͟ϰϷ INSPECTION PROCEDURES: Verify that: 1. Monthly inspections are performed by qualified personnel. 2. Verify that records are readily available and are maintained for a period of 4 years. 3. Verify that records include date and time of inspection and name/initial of person performing the inspection. IF NONCOMPLIANCE EXISTS: Issue a warning (W) INC if records indicate that monthly inspection was missed or did not occur on schedule, but the most recent monthly inspection was completed. Issue a component shut-in (C) INC if: 1. Records of monthly inspections are not available or are not maintained for a period of 4 years. 2. Records do not indicate that a monthly inspection has been performed. 3. The monthly inspection currently due has not been performed. INSPECTION COUNT/ INC Enter one item checked/ issue one INC for each crane inspected. Figure 7: Sample I PINC This inspection method has several important elements:  Objectivity: Each PINC targets a specific, published and authoritative standard which is known or available to the entity being inspected.  Procedural Standardization: Each PINC includes appropriate procedural guidance to promote predictability and standardization across the inspector cadre. Crane Safety Assessment 75 Page  Sanction Guidance: The PINC provide appropriate sanctions for non-compliance, as well as the conditions under which non-compliance will be assessed. This feature benefits all parties by removing guesswork and the subjectivity inherent in human interpretation. For purposes of analyzing and comparing other inspection methodologies, the current PINC system is a natural template. To be comparable, an inspection method needs to possess at least those elements that comprise the PINC, i.e. published standard, specific procedural guidance, conditions of noncompliance, means of enforcement and exact character of sanction. For this discussion, a ϶̍ζ̲ϲ̕β̇̕̕Ϩ͟Ϸ ̎ζζβ̨ ̲̕ ̲ζ̇̇ Κ̎ ϵ̨̡̎ζΨ̲̤̕ ͙ϲΚ̲ ̲̕ β̕ϭ Κ̎β ϲ͙̕ Κ̎β ͙ϲζ̎ ̲̕ β̕ ϵ̲ϰ ϶ϵ̡̍̇y listing technical criteria falls short of the utility needed by BSEE personnel. These utilitarian features are even more critical if BSEE anticipates delegating inspection authority to non-governmental third parties. Comparisons to PINC The task order identifies ̨ζ͘ζ̤Κ̇ ϶ϵ̨̡̎ζΨ̲ϵ̎̕ ̍ζ̲ϲ̕β̇̕̕Ϩϵζ̨Ϸ ̲ϲΚ̲ Κ̤ζ may be applied domestically and internationally on cranes and material handling equipment:  IADC Crane Inspection and Maintenance Program  API RP 2D Crane Inspectors Training Course  International Association of Oil and Gas Producers (OGP), Lifting & Hoisting Crane Safety Recommended Practice  DNV-Recommended Practice-DET Norske Veritas DNV Standard Certification 2.22, Lifting Appliance, October 2011  American Bureau of Shipping (ABS), Guidelines for certification of Lifting Appliances, JULY 2007 (Updated October 2013)  Offshore Cranes and Lifting Appliances International & European maritime Legislation and Standardization with special emphasis on the Norwegian petroleum activities sector 3rd Edition, December 2011. In addition, two ISO standards were reviewed:   ISO 23814:2009, Competency Requirements for Crane Inspectors ISO 17020:2012, Requirements for the Operations of Various Types of Bodies Performing Inspections When evaluated against the PINC characteristics listed above, none of the documents or publications identified ΨΚ̎ Χζ Ψ̨̎̕ϵβζ̤ζβ Κ̨ ϶̍ζ̲ϲ̕β̇̕̕Ϩϵζ̨ϭϷ ̡ζ̤ ̨ζϰ ϼϲζ βϵ̨̲ϵ̎Ψ̲ϵ̎̕ ϵ̨ ̲̎̕ ̍ζ̤ζ̇͟ ̨ζ̍Κ̲̎ϵΨϮ ϵ̲ ϵ̨ drawn along functional lines. ϶EEϳ̨ Ψ͍̤̤ζ̲̎ PIN approach provides a single source of tools that a qualified inspector can take to an offshore facility and efficiently evaluate and document the compliance state of an operator. The publications listed in the task order do not reach the minimum level of utility required for this analysis. The reasons for this determination are discussed below.  API RP 2D Crane Inspectors Training Course ̌ The course is not a complete inspection methodology. It is a training course, offered by multiple commercial training providers which results in a certification that the participant has met the requirements of API RP 2D for qualified inspector or authorized surveyor. An Internet search of training providers advertising this specific training yielded a sampling of the offerings available to industry: Crane Safety Assessment 76 Page      JCD Training (http://www.jcdtraining.com)  Alford Safety Services, (www.alfordservices.com)  Energy Cranes, (www.energycranes.com)  Chevron Employee Resource & Training Center, (www.chevron.com)  Global Training & Environmental, (www.globaltraining.com)  PTTCO Ltd. (www.pttco.org)  Seatrax Inc. (www.seatrax.com)  Sparrows Offshore, (www.sparrows.biz) IADC Crane Inspection and Maintenance Program ̌ This program is not an inspection methodology. It refers to a body of training courses endorsed by the International Association of Drilling Contractors (IADC). The IADC provides accreditation to training providers who demonstrate compliance with the IADC curriculum requirements for courses that lead to operator and inspector certification. The Drilling Industry Training Accreditation Systems (DIT) offers a variety of accreditation opportunities for training institutions, providers and programs. International Association of Oil and Gas Producers (OGP), Lifting & Hoisting Crane Safety Recommended Practice ̌ This document does not put forth an inspection methodology. It describes lifting and hoisting safety elements to be incorporated into a management system that is consistent with the OGP Guidelines for the development and application of a health, safety and environmental management systems (OGP Report 210). This information would be ͘Κ͍̇ΚΧ̇ζ ϵ̎ Κ̎ ̡̕ζ̤Κ̲̤̕ϳ̨ Ψ̤Κ̎ζ ̡̕ζ̤Κ̲ϵ̎̕ ̍Κ͍̎Κ̇ϭ ϶Κπζ̲͟ Κ̎β E̎͘ϵronmental Management System (SEMS) or similar document. It could serve as a reference or companion publication imbedded in an inspectors training and reference material. DNV-Recommended Practice ̌ DET Norske Veritas DNV Standard Certification 2.22, Lifting Appliance, October 2011 ̌ This document is not an inspection methodology. It provides criteria and guidance for certification and verification of the design, materials, fabrication, installation, testing and commissioning of lifting appliances. Appropriate elements of this publication could be included in the criteria and specifications a qualified inspector or surveyor could use to determine the status of a crane with respect to its original design. The document is most properly employed during the initial certification and classification of the appliance. It may also be a reference document for on-site inspectors when technical data are required. The information might be useful if a BSEE or third party inspector needed to verify the specifications to which an appliance had been certified or classed. American Bureau of Shipping (ABS), Guidelines for Certification of Lifting Appliances, JULY 2007 (Updated October 2013) ̌ The guidelines contains provisions for the certification of lifting appliances installed aboard vessels and/or offshore floating/fixed structures. It is not, per se, an inspection methodology in the sense that it could be used, as is, by an on-site inspector. It is more properly a companion document to API RP 2D and API Specification 2C. It could also serve Κ̨ Κ ̤ζπζ̤ζ̎Ψζ ̡͍Χ̇ϵΨΚ̲ϵ̎̕ ϵ̍Χζββζβ ϵ̎ Κ̎ ϵ̨̡̎ζΨ̲̤̕ϳ̨ ̲̤Κϵ̎ϵ̎Ϩ Κ̎β ̤ζπζ̤ζ̎Ψζ ̍Κ̲ζ̤ϵΚ̇ϰ Offshore Cranes and Lifting Appliances International & European Maritime Legislation and Standardization with Special Emphasis on the Norwegian Petroleum Activities Sector 3rd Edition, December 2011 ̌ This document is not an inspection methodology, standard or regulation. It is Crane Safety Assessment 77 Page a compendium and synopsis of international offshore regulatory bodies and associated regulations and contact points.  ISO 23814 ̌ The standard contains five sections and two annexes, A and B, which cover recommended crane inspector categories and criteria for technical knowledge. The standard relies heavily on other referenced standards and guidelines. The emphasis of ISO 23814 is inspection organization independence, impartiality, and integrity, as well as technical knowledge, experience requirements, and techniques for crane inspection. The technique section specifies training of crane inspectors. The conclusions reached in the analysis of API 2C and 2D was that although ISO 23814 provides some helpful insights, it does not provide a significant additional value beyond the usefulness of API Spec 2C and API RP 2D, used in tandem.  ISO 17020 ̌ The standard layouts the general requirements for the operation of various types of bodies performing inspection. This document does not offer a complete inspection methodology. Application of this standard promotes confidence in the entities performing inspections. Although this standard does not target offshore crane inspections, it has features that BSEE might incorporate into its own inspection processes. Z-PINC compared to CG 5432 The US Coast Guard also has regulatory responsibilities on fixed offshore facilities that relate to safety of life at sea (SOLAS). CG Form 5432, FIXED OCS FACILITY INSPECTION REPORT, documents the results of inspections conducted to determine compliance with applicable maritime regulations. In 1988, the USCG promulgated self-inspection regulations to shift the burden for conducting the annual inspection of the USCG-regulated items on each OCS platform to the owners and operators, and required them to document their inspections on Form CG 5432. Via a Memorandum of Understanding (MOU), dated 27 November 2012, and Memorandum of Agreement (MOA) OCS-09, dated 19 September 2014, BSEE inspectors cover USCG SOLAS responsibilities using Z-PINC. A representative Z-PINC is displayed below. Z-110 IS EYEWASH EQUIPMENT IMMEDIATELY AVAILABLE NEAR THE DRILL FLOOR, MUDROOM, AND OTHER AREAS WHERE THERE IS A REASONABLE PROBABILITY THAT EYE INJURY MAY OCCUR? Authority: 33 CFR 142.4 Action: W/C Enforcement Note: 1. Eyewash equipment must be located within 10 seconds of the hazard and on the same level. 2. The path of travel to the eyewash equipment must be unobstructed. INSPECTION PROCEDURE: 1. Verify that operable portable or fixed eyewash equipment is located in required areas on all manned fixed platforms. 2. Verify that required eyewash equipment is adequately maintained. 3. Verify that personnel are knowledgeable of the location, purpose, and operation of the eyewash equipment. IF NONCOMPLIANCE EXISTS: Crane Safety Assessment 78 Page Issue a warning (W) INC if: 1. Portable or fixed eyewash equipment is not immediately available near the drill floor, mudroom, and other areas where there is a reasonable probability that eye injury may occur. 2. Personnel working in the area are not knowledgeable of the location, purpose, and operation of the eyewash equipment. 3. Eyewash equipment is not adequately maintained. Issue a component shut-in (C) INC for the operation if present during an operation in which eye injury may occur and portable or fixed eyewash equipment is not immediately available and/or operable. INSPECTION COUNT/ INC Enter one item checked/ issue one INC for each platform inspected. Figure 8: Sample Z PINC Crane Safety Assessment 79 Page The Z-PINC mirrors the requirements of CG Form 5432, FIXED OCS FACILITY INSPECTION REPORT. On closer analysis, the Z-PIN Κ̡̡ζΚ̤ ̲̕ Χζ ̤̍̕ζ ϶ϵ̨̡̎ζΨ̲̤̕ π̤ϵζ̎β̇͟Ϸ ̲ϲΚ̎ G F̤̍̕ ϱϰϯϮ ϵ̎ ̲ϲΚ̲ ̲ϲζ͟ provide more specific guidance on how to evaluate compliance and rely less on inspector knowledge of specific regulatory technicalities. Form CG 5432 is reproduced below. Figure 9: CG Form 5432 Crane Safety Assessment 80 Page 6.1.2 Inspection Authority Delegated to Third Parties Third party inspectors are currently used extensively by BSEE and USCG. In the case of BSEE, third party inspectors exercise a sub-set of inspector authority. For the USCG, third party inspectors perform the complete facility inspection required by USCG regulations. Limited Authority for BSEE Crane Inspections The periodic inspections required by API RP 2D for cranes are conducted and documented by nongovernmental operator/facility personnel. API RP 2D defines an initial inspection and four periodic inspections that are based upon frequency of use: pre-use, monthly, quarterly and annually. The initial, quarterly and annual inspections must be conducted by a Qualified Inspector; a qualified crane operator may perform the pre-use and monthly inspections. A Qualified Crane Operator is designated by the crane owner and should have been trained in accordance with API RP 2D, Appendix A1. Worldwide, there are many organizations that provide formalized training for Qualified Crane Operators that meet or exceed the requirements of API RP 2D. A Qualified Inspector is designated by the crane owner and should be trained in accordance with API RP 2D, Appendix A2. Qualified Operators and Inspectors perform and document the crane inspections that are audited by BSEE personnel during facility visits. BSEE inspectors cannot be expected to maintain the proficiency required by API RP 2D on the myriad of crane types found on the OCS and therefore must rely on the competence and integrity of the qualified crane operators and inspectors who perform and document required crane inspections offshore. Limited Authority for USCG Facility Inspections Third party inspectors are used extensively by USCG. In accordance with 33 CFR 140.103, the USCG performs the initial inspection of a new facility to ensure compliance with safety related items under USCG purview. Subsequent inspections of USCG safety items are performed by a person designated by the facility owner/operator and documented on the Fixed Platform Self-Inspection form (Form CG5432). The USCG verifies compliance with their annual inspection requirement via periodic on-site inspections. In support of oversight efforts, BSEE inspectors use Z-PINC to assess operator compliance on the behalf of the USCG, and in so doing, accept the inspection results of third party inspectors. Full Authority for BSEE and USCG Inspections The Executive Branch has recently released a plan to permit petroleum exploration and drilling in the !̲̇Κ̲̎ϵΨ O ϶ϰ !ΨΨ̤̕βϵ̎Ϩ ̲̕ ̲ϲζ ̌Κ̇̇ ϶̲̤ζζ̲ J͍̤̎̕Κ̇ϭ JΚ͍̎Κ̤͟ Ϯϳϭ Ϯ΄ϭϱϭ ϶ϱ̲ϲζ Ϩ̕͘ζ̤̎̍ζ̲̎ ͙͍̇̕β ϲ̇̕β β̤ϵ̇̇ϵ̎Ϩ ̇ζΚ̨ζ ̨Κ̇ζ̨ Χζ̲͙ζζ̎ Ϯ΄ϭϳ Κ̎β Ϯ΄ϮϮ ̕ππ ̲ϲζ Ψ̕Κ̨̲ π̤̍̕ ̋ϵ̤Ϩϵ̎ϵΚ ̲̕ Gζ̤̕ϨϵΚϱϷ If the plan moves forward as outlined, the decision will greatly increase BSEE and USCG responsibility and constructively reduce their inspection forces. BSEE and USCG cannot expect that increases in inspector staffing will keep pace with the expansion of offshore activity into the Atlantic OCS. Existing responsibilities can ζ̡͞ζΨ̲ ̲̕ Χζ ϶̲̤ϵΚϨζβϷ ̲̕ ̍Κ̄ζ ̤̍̕̕ π̤̕ ̎ζ͙ζ̤ϭ ζ͞ϵϨζ̲̎ ̡̤ϵ̤̕ϵ̲ϵζ̨ϰ Most likely, BSEE will not be able to simply increase the number of third party inspectors with limited authority. Consideration must be given to vesting non-governmental agencies or individuals with authority to perform all BSEE inspector functions under supervision and oversight of qualified, Crane Safety Assessment 81 Page experienced BSEE inspectors. Two examples of programs with extensive third party inspection authority are the Federal Aviation Administration (FAA) Designated Examiner program and the Institute of Nuclear Power Operations (INPO). Both of these programs are reviewed below. These two programs are concerned with industries that can have issues with immediate and serious consequences to public health and safety. The regulatory oversight of these industries is at least as critical as that of the industries related to the OCS. FAA Designated Examiner Model A model for a third party inspector system can be found in the Designated Examiner (DE) program run by the Federal Aviation Administration (FAA). Designated examiners currently perform more than ninety percent of pilot, flight engineer, mechanic and parachute rigger certifications in the United States. Designees are not FAA employees or contractors of FAA. Their authority is exercised independently or under the auspices of a certificated organization, such as a repair station. They are allowed to charge a ϶̤ζΚ̨̎̕ΚΧ̇ζ πζζϷ π̤̕ ̲ϲζϵ̤ ̨ζ̤͘ϵΨζ̨ϰ Designated Pilot Examiners (DPEs) conduct practical tests and issue all certifications from student pilot to Airline Transport Pilot to Flight Instructor. They also issue instrument, multi-engine and aircraft type ratings. Designated Maintenance Examiners (DMEs) conduct practical tests and issue certifications for aircraft mechanics, avionics technicians and parachute riggers. Designated Airworthiness Representatives (DAR) and Designated Engineering Representatives (DERs) issue original type certificates for aircraft, engines and components. Aviation Medical Examiners (AMEs) issue 99% of FAA medical certificates. DEs, like BSEE inspectors, must document extensive industry experience and a broad spectrum of qualifications. In addition to maintain aircraft and instructor qualifications and proficiency, they must attend a week-long training course at the FAA Academy that focuses on evaluation procedures, techniques and documentation. They must be observed conducting actual applicant testing at least once per year, by an FAA Aviation Safety Inspector (ASI). DPEs and DMEs operate using the same procedural guidance as their ASI counterparts. Each function has comprehensive and detailed guidance on test construction, applicant eligibility and documentation. The DE is provided with specific procedures for successful and unsuccessful test outcomes. The DE program allows the FAA to leverage its limited inspector force and meet the extensive demands of aviation safety. In Calendar Year 2013, the FAA issued 85, 293 certificates; an average of 7108 per month. There were 67,765 certificates that required evaluation and testing, of which 98.2% were conducted by Designated Examiners. (http://www.faa.gov/). FAA Organization Designation Authorization Model The FAA delegates certification and inspection authority to industry organizations known as Organization Designation Authorizations (ODA). The basis for granting an ODA is the same as for other FAA designees, 14 CFR 183. ODAs exercise FAA certification authority for many functions, most of which concern aircraft and component airworthiness. The FAA may also delegate authority to conduct and Crane Safety Assessment 82 Page certify knowledge tests for FAA airman certificates. The principals of ODAs must complete training and qualification requirements similar in scope and complexity to those of Designated Examiners. This model could be useful to BSEE when determining the process for delegating authority to third party industry groups or companies. Institute of Nuclear Power Operations /Nuclear Regulatory Commission Model The Institute of Nuclear Power Operations (INPO) is a non-profit organization established by the nuclear power industry in 1979 in response to a presidential recommendation (not unlike the Final Report for ̲ϲζ P̤ζ̨ϵβζ̲̎ϳ̨ Oil Spill Commission, which recently recommended improvement of self-regulation in the oil-drilling industry) after a serious nuclear power plant incident (Three Mile Island). All of the 60+ U.S. sites with nuclear power reactors are members of the INPO, ͙ϲ̕ ϶Ϩ̤Κβζ̨Ϸ ζΚΨϲ ̡̇Κ̲̎ ̎̕ ̨Κπζ̲͟ Κ̎β reliability, and operates on the threat to reveal non-compliance to the Nuclear Regulatory Commission (NRC). The INPO establishes performance objectives, criteria and guidelines for the nuclear power industry. Regular and thorough onsite evaluations of nuclear electric generating facilities are conducted by the INPO. In addition, the INPO provides in-person or online training and accreditation (through its National Academy for Nuclear Training, and accreditation through the independent National Nuclear Accrediting Board), evaluation of internal plant training programs, event analysis, information exchange and other technical or operations management assistance by industry request. Through the INPO information exchange and publication, members communicate lessons learned and best practices throughout the nuclear power industry. The NRC provides government oversight and enforcement to complement the efforts of the INPO. The NRCϳ̨ ϵ̨̡̎ζΨ̲ϵ̎̕ manual provides policy and procedural guidance to inspectors. ϼϲζ NR ϳ̨ ϵ̨̡̎ζΨ̲ϵ̎̕ ̍Κ͍̎Κ̇ϳ̨ ̍ζ̲ϲ̕β ̕π ̨̲Κ̎βΚ̤βϵͤΚ̲ϵ̎̕ ̤̎̍̕Κ̇ϵͤζ̨ ̲ϲζ βϵππζ̤ζ̎Ψζ̨ Κ̍̎̕Ϩ̨̲ Κ̲̲ϵ̲͍βζ̨ϭ ̲̤Κϵ̎ϵ̎Ϩϭ ζ̡͞ζ̤ϵζ̎Ψζ and expertise found across an inspection task force. ϼϲζ NR ϳ̨ inspection model is a leading example of a highly detailed guidance manual that should be considered by BSEE. The excerpt below is an example of the scope and depth of information the NRC considers important. NRC INSPECTION MANUAL 0102-04 OVERSIGHT AND OBJECTIVITY REQUIREMENTS AND GUIDANCE 04.01 General. The requirements and guidance provided in section 0102-04 are to be used by NRC managers to verify employee performance and objectivity by direct observation of on-site activities at power reactor facilities and through other available indirect methods as needed. On-site activities include individual or team inspections, examinations, audits, visits, and reviews. NRC employees should use the applicable guidance and requirements of this section in the performance of their on-site activities. 04.02 Individual Inspectors, Team Leaders, and Examiners a. Inspectors, team leaders, chief examiners, and other staff who lead NRC on-site activities should develop an appropriate plan, brief and receive approval from the line supervisor responsible for the activity on their planned activities, and should provide a copy of the inspection, examination, or audit plan to the responsible regional office Division of Reactor Projects (DRP) supervisor before the on-site activities begin. b. All NRC staff who leads NRC on-site activities will conduct an entrance meeting with the principal facility personnel before beginning on-site activities. The senior resident inspector (SRI), or the resident inspector in the SRI=s absence, should be invited to all entrance briefings. c. All NRC staff who leads NRC on-site activities should brief the immediate line supervisors responsible for the activity and the SRI regarding their findings before any exit meeting with the facility licensee takes place. d. Inspectors, team leaders, chief examiners, and other staff who lead or participate in NRC on-site activities shall maintain a professional, objective relationship with licensee management and staff. 04.03 Senior Resident Inspectors Crane Safety Assessment 83 Page a. SRIs should routinely brief their immediate supervisor on resident inspection issues and findings and should keep their supervisor informed of scheduled exit meetings. Issue Date: 04/24/13 4 0102 b. SRIs should keep abreast of all NRC on-site activities at the facility to which they are assigned. However, minor issues should not be tracked or trended. c. SRIs should attend entrance and exit meetings. If the SRI is unavailable, other resident inspectors should attend in their place. For economy of time, meetings for multiple on-site activities should be combined whenever possible. d. To enhance objectivity, SRIs and resident inspectors shall spend a minimum of one week each year inspecting at another site. This inspection may be accomplished by participating in a team inspection at another site, or by visiting their backup site for familiarization. 04.04 Line Managers a. Line managers should keep abreast of on-site activities conducted by employees over whom they have supervisory authority. 1. Line managers should discuss on-site activity plans with their employees before on-site activities begin to ensure the employee's activities are properly scheduled, coordinated and focused. 2. Regional DRP line managers should talk with their resident inspectors at each of their sites several times a week. 3. Line managers responsible for an on-site activity should discuss the findings and concerns with the employees assigned to the activity before the facility exit meeting is held. Discussions should focus on potential safety and regulatory approaches to issues to ensure mixed messages are not sent to the licensee. Figure 10: NRC Inspection Manual Third Party Inspector Hybrid BSEE inspectors have a unique set of responsibilities. They also exercise broad regulatory authority on behalf of the taxpayers, some of which cannot be delegated to non-governmental entities. There are many inspector functions, however, which can be reasonably and effectively performed by properly trained and supervised third parties. Ultimately, the non-governmental entity vested with BSEE authority will be a hybrid of inspector and industry attributes. Delegates will represent the US government and must demonstrate the ability to conduct inspections, audits and evaluations independently, to the same standards as BSEE employees. BSEE will need to devise training and qualification protocols that are customized to third party inspector roles and responsibilities. BSEE should consider training and qualifying third party inspectors in the same manner and to the same standards as BSEE inspectors. The curriculum should be shortened and customized to fit the extent of the responsibilities and authority the government decides to delegate. !̲̇ϲ͍̕Ϩϲϭ ̲ϲϵ̤β ̡Κ̤̲͟ ϵ̨̡̎ζΨ̨̲̤̕ ϲΚ͘ζ ̲ϲζ Κβ͘Κ̲̎ΚϨζ ̕π Χζϵ̎Ϩ ϶π̤̕Ψζ ͍̲̍̇ϵ̡̇ϵζ̨̤Ϸ for the government, they also create a burden of oversight and supervision, which must be considered as BSEE seeks options for accomplishing its mandate. 6.2 API Specification 2C API Specification ϶̡ζΨ Ϯ ϭ ϶Oππ̨ϲ̤̕ζ Pζβζ̨̲Κ̇-͍̲̍̎̕ζβ ̤Κ̎ζ̨ϭϷ ̡̤̕͘ϵβζ̨ ̤ζ̣͍ϵ̤ζ̍ζnts for design, construction, and testing of offshore pedestal-mounted cranes. BSEE currently incorporates the sixth edition of this standard by reference in 30 CFR 250.198. The seventh edition of the standard was published in 2012 and has not been incorporated in the Regulation. The following sections address the three most typical contexts for such cranes outlined in API Spec 2C, which are shipboard applications, heavy-lift applications, and offshore oil and gas production. Crane Safety Assessment 84 Page API Spec 2C gives extended treatment of offshore crane design, construction, and testing specifications. An indication of its comprehensiveness is that it identifies over 20 normative references and notes them as important for application of the specification. A critical reference is !PI RP ϮDϭ ϶RζΨ̍̍̕ζ̎βζβ P̤ΚΨ̲ϵΨζ π̤̕ O̡ζ̤Κ̲ϵ̎̕ Κ̎β MΚϵ̲̎ζ̎Κ̎Ψζ ̕π Oππ̨ϲ̤̕ζ ̤Κ̎ζ̨ϭϷ Κ ̨ϵ̨̲ζ̤ ̨̲Κ̎βΚ̤β ͙ϵ̲ϲ ͙ϲϵΨϲ !PI ϶̡ζΨ Ϯ parallels. This particular connection is key for the present analysis of crane safety standards primarily because appropriate crane inspection programs should reflect the complementary nature of API Spec 2C and API RP 2D. Recommending that API Spec 2C be used for inspection programs, as will be done here, unequivocally implies that API RP 2D be used as well. Indeed, API Spec 2C explicitly encourages the reader to review API RP 2D concurrently. It is clear that the usefulness of API Spec 2C derives in large part from the value of API RP 2D, an interdependency that is especially true in the areas of crane operator training, load handling, crane rating, and crane inspection. What follows is a more specific review of API Spec 2C, which leads to more specific points regarding its use in inspection programs. The analysis concludes with commentary on some comparisons and contrasts between API Spec 2C and other industry standards. Due to the complementary nature of API Spec 2C and API RP 2D, relevant recommendations for using API Spec 2C in offshore crane inspection programs are deferred to the end of the API RP 2D analysis section. 6.2.1 Analysis The API Spec 2C standard has improved over the decades by developing clearer definitions of which cranes the standard covers. It has also expanded its list of critical components. Such components have no redundancy; if they fail, the result would be uncontrolled descent of load and/or uncommanded rotation of the upper crane structure. The Spec 2C document is designed to be used as an international standard that reflects realistic criteria. To that end, one particularly useful feature of the standard is its requirement that manufacturers keep their test and inspection records for 20 years. The goal of this requirement is to help ensure that relevant data can be tracked and analyzed for future design, construction, and testing of offshore cranes. Other key features of API Spec 2C include guidelines on (a) what information the manufacturer must provide the purchaser, (b) what information the purchaser must provide the manufacturer, and (c) what human factors (HF) and health, safety, and environment (HSE) issues must be addressed. There are several detailed sections that describe how to calculate dynamic components of load and structures. The load section facilitates clear calculations of safe working loads by giving three possible methods for computing dynamic forces acting on a crane at sea state. These methods are the Vessel-specific Method, the General Method, and the Legacy Dynamic Method. Each of these methods is discussed at length. The standard even provides an extensive commentary appendix in which the benefits and potential downsides of each method are discussed. The standard repeatedly notes that load estimation for offshore cranes is complex and stresses that the purchaser must provide the manufacturer with as much data as possible on the parameters of the context in which the crane will operate. Variables of particular interest in this respect are wind, ice, and seismic conditions. These considerations, along with several others having to do with structural and mechanical requirements, rely on duty classification. The Crane Safety Assessment 85 Page standard describes four duty classes: (1) Production Duty; (2) Intermediate Duty; (3) Drilling Duty; and (4) Construction Duty. These categories are used as organizing features for several requirements, such as appropriate time between overhaul, limits on frequency of use, and critical component repair. Commensurate with the sections just mentioned is an entire section devoted to gross overload conditions. Within this section, quite useful specifications for failure mode calculations are given to manufacturers. Examples include: In the event an unbounded gross overload is applied to the block by a moving load, the applicable components supporting the operator control station shall not be the first to fail; the calculations shall assume the wire rope is not paid out from the hoist drums; and the crane shall fail into a safer and less critical situation with respect to the crane operator. Several other relevant requirements are listed. The human factors (HF) and Health, Safety, and Environment (HSE) section is quite involved, covering several critical issues over nearly ten pages. The fact that so many issues are called out there is a testament to the myriad problems that can arise when cranes are not designed with human capabilities, limitations, and safety in mind. It is excellent that the standard addresses these HF and HSE issues. However, the points are not given the weight of consideration they deserve. Given that the primary goal of the section is to help manufacturers design out error-likely situations, it would be useful if examples of such situations were given. One such example comes from a human-factors analysis, conducted by ABS Group, concerning a problematic pedestal crane typical of those found offshore. The analysis revealed that the front windscreen contained an opaque horizontal joint approximately one-third of the way from the bottom of the cabin. As a result of its opacity and location, the crane operator often stood up in order to see over the joint and to make visual contact with the hoisted load. In turn, this action required the operator to rotate the palms in the opposite direction, compared to the normal seated position, in order to manipulate the controls. This was an error-likely situation for several reasons, all of which need not be explicated in detail here. Suffice it to say, however, one of the most critical problems arose because in this new hand configuration the same movements of the hands and fingers produced the opposite action of the crane, compared to the normal seated position. It should be noted that other real-world ζ͞Κ̡̍̇ζ̨ π̤̍̕ ̲ϲζ ̕ππ̨ϲ̤̕ζ ϵ̎β̨͍̲̤͟ Κ̤ζ ̡̤̕͘ϵβζβ Κ̎β Ψ̇ζΚ̤̇͟ Ψ͍̍̍̎̕ϵΨΚ̲ζβ ϵ̎ !PI ϳϳ΄ϭ ϶! MΚ̎ΚϨζ̤ϳ̨ G͍ϵβζ ̲̕ Rζβ͍Ψϵ̎Ϩ H͍̍Κ̎ Ę̤̤̤̕ϭϷ ͙ϲϵΨϲ ϶EE ̍ϵϨϲ̲ Ψ̨̎̕ϵβζ̤ Κβ̡̲̕ϵ̎Ϩ Κ̨ Κ ̨upplement to API Spec 2C, API RP 2D, or both, for inspection programs. Returning to the present analysis, the annexes contained in API Spec 2C are extensive and informative. They include examples of critical components, API monogram guidelines, and cylinder calculation methods. Perhaps the most useful are the annexes containing involved commentaries and thorough examples of crane design loads, overturning moments, wire rope design factors, and safe working loads. 6.2.2 Inspection The API Spec 2C standard explicitly touches on the issue of inspection in several ways. As mentioned above, the standard requires the manufacturer to maintain all inspection and testing records for 20 years and that the records be made part of a quality audit program. The manufacturer must also Crane Safety Assessment 86 Page prepare a list of critical components, for each crane, that are subject to especially stringent inspection requirements. Note here that the standard provides an appendix (Annex A), which delineates examples of critical components. However, the reader should consult API RP 2D for explicit definitions of particular inspection schedules. This issue is taken up further in our analysis of API RP 2D. The API Spec 2C standard goes on to lay out requirements for manufacturers to provide inspection, maintenance, and replacement procedures for all wire rope. It requires that fasteners not immediately accessible for inspection be positively restrained from rotation by nonpermanent means, and that the materials of other critical structural components are made traceable through a process subject to inspection. The standard notes that such components are of particular interest in inspection and that critical structural elements fabricated from steel plate be ultrasonically tested. It describes vital inspection requirements for pre and post heavy-lift load-test periods, fracture toughness, additional nondestructive examination of critical components, and nondestructive examination procedures. 6.2.3 Other Standards The present review stresses the point that API Spec 2C is extensive and wide ranging. As such, there are no available ISO standards which are comparable. The general ISO approach to crane-related standards has been to separate the many crane-related issues into several individual standards and to give them only slightly more in-depth treatment. For example, there are separate ISO standards solely for the vocabularies associated with different types of cranes. There is an entire family of ISO standards that gives design principles of loads and load combinations for different types of cranes (e.g., ISO 8686). But the cranes are not differentiated based on those crane types typically found offshore. Nor are there recommendations given for how to incorporate the uniquely challenging conditions found offshore, such as wind and seismic loads. For those recommendations, the reader must consult other families of ISO standards (e.g., ISO 4302). Moreover, the depth of each separate ISO standard is essentially comparable to the depth found in API Spec 2C. Given that the relative depths of coverage are similar, but that the API Spec 2C covers so many issues in one standard, it is in the best interest of BSEE to retain API Spec 2C and to incorporate API Spec 2C in their inspection program. Another set of relevant standards comes from the American Society of Mechanical Engineers (ASME) B30 series. The scope of the series covers construction, installation, operation, testing, maintenance, material handling, and inspection. Though the wide-ranging series contains nearly 30 standards, as can be seen in Table 1 below, it is still more manageable than the ISO series noted above. Moreover, several of the standards can be eliminated from the current discussion about the inspection of offshore cranes because they are generally irrelevant to offshore pedestal mounted cranes. B30.1 B30.2 B30.3 B30.4 B30.5 B30.6 Crane Safety Assessment Table 22: B30 Standards and Topics Jacks, Industrial Rollers, Air Casters and Hydraulic Gantries Overhead and Gantry Cranes Tower Cranes Portal and Pedestal Cranes Mobile and Locomotive Cranes Derricks 87 Page B30.7 B30.8 B30.9 B30.10 B30.11 B30.12 B30.13 B30.14 B30.16 B30.18 B30.19 B30.20 B30.21 B30.22 B30.23 B30.24 B30.25 B30.26 B30.27 B30.28 B30.29 Winches Floating Cranes and Floating Derricks Slings Hooks Monorails and Underhung Cranes Handling Loads Suspended from Rotorcraft Storage/Retrieval Machines and Equipment Side Boom Tractors Overhead Hoists Stacker Cranes Cable Ways Below-the-Hook Lifting Devices Lever Hoists Articulating Boom Cranes Personnel Lifting Systems Container Cranes Scrap and Material Handlers Rigging Hardware Material Placement Systems Balancing Lifting Limits Self-Erecting Tower Cranes The standard of the series most germane to the current analysis, which addresses offshore cranes and the crane-̡̲͟ζ ̇ζ͘ζ̇ ̕π Κ̎Κ̨̇͟ϵ̨ϭ ϵ̨ !϶ME ϯ΄ϰϰϭ ϶P̤̲̕Κ̇ Κ̎β Pζβζ̨̲Κ̇ ̤Κ̎ζ̨ϰϷ ϼϲζ !϶ME ϯ΄ϰϰ ̨̲Κ̎βΚ̤β is briefly reviewed below, but two things should be noted prior to that review. First, there are several ASME B30 standards that specifically address particular critical components, such as slings, hooks, and winches. Second, several of those components singled-out within their own particular ASME B30 standards are sufficiently addressed by API Spec 2C and API Spec 2D, in tandem. Figure 11 below shows only a small number of exceptions to this general observation, such as derricks, winches, and cableways. Crane Safety Assessment 88 Page Figure 11: Inspection-related gap analysis results concerning elements API Spec 2C, API RP 2D, and relevant ASME B30 standards6 Whereas the API Spec 2C standard addresses inspection throughout the document, the ASME B30.4 standard devotes a specific section to inspection, testing, and maintenance. This is another feature which contributes to the brevity of B30.4 relative to API Spec 2C, along with the fact that the ASME B30 series breaks out relevant issues in several smaller standards. The inspection section of the ASME B30.4 carves inspection classification into initial inspection, which entails all new, reinstalled, altered or repaired cranes, and regular inspection, which entails two subcategories. The two subcategories are frequent and periodic. The former subcategory could be monthly for light service, weekly for normal service, or daily for heavy service. The latter subcategory, periodic inspection, is done on the order of 1- to 12-month intervals, or as specifically recommended by 6 ϼϲζ ̖̗̓ ϵ̎βicates coverage. Empty cells indicate no coverage. Crane Safety Assessment 89 Page the manufacturer. The standard then lays out several explicit criteria for appropriate inspection on these different schedules. The only critical component given special attention, however, is wire rope inspection and replacement criteria. Table 2 shows that there are several more inspection-related issues addressed by API Spec 2C that are not addressed by ASME B30.4. One might counter that this observation is invalid because it does not consider the fact that there are many other standards in the ASME B30 series that could, when taken together, cover the same scope. However, Table 2 also shows that several of the issues addressed in those other, singled-out ASME B30 standards are also addressed by API Spec 2C. Thus, API Spec 2C appears to be much more comprehensive. It is also more efficient and cost-effective because the information is found in only one single publication. Lastly, the API Spec 2C relies on a more detailed, rigorous, and well-defined inspection schedule (laid out in API RP 2D). Another notable inspectionrelated shortcoming of ASME B30.4 relative to API Spec 2C and API RP 2D is the lack of any inspector training requirements. Note again that this issue is taken up more specifically in the accompanying analysis of API RP 2D. 6.3 API Recommended Practice 2D !PI RP ϮDϭ ϶RζΨ̍̍̕ζ̎βζβ P̤ΚΨ̲ϵΨζ π̤̕ O̡ζ̤Κ̲ϵ̎̕ Κ̎β MΚϵ̲̎ζ̎Κ̎Ψζ ̕π Oππ̨ϲ̤̕ζ ̤Κ̎ζ̨ϭϷ ϵ̨ Κ Ϩ͍ϵβζ π̤̕ crane owners and operators to use for safe operation of pedestal-mounted cranes on fixed or floating offshore platforms, jackup rigs, semi-submersibles, and other types of mobile offshore drilling units. The document, in its sixth addition as of 2007 is currently incorporated by reference in 30 CFR 250.198. It is comprehensive, addressing a wide range of issues in operations, testing, maintenance, and inspection. API RP 2D is a sister standard to API Spec 2C, as noted in the analysis above. Of particular interest here, are the several inspection-related issues covered in API RP 2D and how they relate to API Spec 2C. The present analysis precedes much like the analysis of API Spec 2C. Below is a more specific review of API RP 2D, which develops into a more specific analysis of the inspection-related criteria put forth therein. It should be noted that API RP 2D contains many more inspection-related issues compared to API Spec 2C. It should also be understood that nearly all these issues discussed in this analysis can be connected to the issue of inspection in one way or another. The present analysis draws out the most important of these connections. 6.3.1 Analysis The initial focus of API RP 2D is the general issue of operations, which it breaks into four main parts. The first provides clear and appropriate physical criteria by which a crane operator may become qualified to operate relevant cranes and sets forth additional (minimum) training requirements. Here, the standard references sister standard, API Specification 2C, to point out that any operator should have basic working knowledge of several technical fundamentals. These fundamental requirements concern design, construction, and testing of new offshore pedestal-mounted cranes. Less stringent requirements are set forth for riggers, though a detailed suggested training plan is included in one of several appendices. Crane Safety Assessment 90 Page Returning to operations, the operator is required to meet several well-defined best practices, as specified in the main document and in a second appendix on operations. Best practices include pre-use verification of crane capabilities, appropriate communication with signal persons, securing the crane before a period of nonuse, and handling personnel transfers. Several useful miscellaneous issues are also treated, such as best practices for refueling, fire protection, load testing, and pull testing. The API RP 2D standard defines a qualified crane operator as: ϶! ̡ζ̨̤̎̕ ̨̕ βζ̨ϵϨ̎Κ̲ζβ Χ͟ ̲ϲζ ζ̡̍̇̕͟ζ̤ ͙ϲ̕ ϲΚ̨ Κ̡̡̡̤̤̕ϵΚ̲ζ ̕ππ̨ϲ̤̕ζ ζ̡͞ζ̤ϵζ̎Ψζ Κ̎β ̲̤Κϵ̎ϵ̎Ϩϰ Such appropriate experience and training must comprise minimum amounts of classroom-type sessions and hands-on field training, on cranes specific to the type of crane to be operated by ̲ϲζ ̣͍Κ̇ϵπ͟ϵ̎Ϩ ̤Κ̎ζ O̡ζ̤Κ̲̤̕ϰϷ ϼϲζ βζπϵ̎ϵ̲ϵ̎̕ ̨͍̲́ ̤ζ͘ϵζ͙ζβ ̤ζ̨̨̲ ̎̕ Κ Ϩζ̎ζ̤Κ̇ βζπϵ̎ϵ̲ϵ̎̕ ̕π ̲ϲζ ̲ζ̤̍ ϶̣͍Κ̇ϵπϵζβϭϷ Ϩϵ͘ζ̎ Χ͟ !PI RP ϮD Κ̨ϯ ϶! ̡ζ̨̤̎̕ ͙ϲ̕ϭ Χ͟ ̡̨̨̕ζ̨̨ϵ̎̕ ̕π Κ ̤ζΨ̕Ϩ̎ϵͤζβ βζϨ̤ζζϭ Ψζ̤̲ϵπϵΨΚ̲ζ ̕π professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated the ability ̲̕ ̨̇̕͘ζ ̤̕ ̤ζ̨̇̕͘ζ ̡̤̕Χ̇ζ̨̍ ̤ζ̇Κ̲ϵ̎Ϩ ̲̕ ̲ϲζ ̨͍Χ́ζΨ̲ ̍Κ̲̲ζ̤ Κ̎β ͙̤̄̕ϰϷ Together, these definitions can be contrasted with what the Occupational Safety and Health !β̍ϵ̎ϵ̨̲̤Κ̲ϵ̎̕ ̖O϶H!̗ βζπϵ̎ζ̨ Κ̨ Κ ϶Ψ̡̍̕ζ̲ζ̲̎ ̡ζ̨̤̎̕ϭϷ ̡ζ̤ Ϯϵ FR ϭϵϮϲϰϯϮϯ ϶O̎ζ ͙ϲ̕ ϵ̨ ΨΚ̡ΚΧ̇ζ ̕π ϵβζ̲̎ϵπ͟ϵ̎Ϩ ζ͞ϵ̨̲ϵ̎Ϩ Κ̎β ̡̤ζβϵΨ̲ΚΧ̇ζ ϲΚͤΚ̤β̨ ϵ̎ ̲ϲζ ̨͍̤̤͍̎̕βϵ̎Ϩ̨ ̤̕ working conditions which are unsanitary, hazardous, or dangerous to employees, and who has Κ͍̲ϲ̤̕ϵͤΚ̲ϵ̎̕ ̲̕ ̲Κ̄ζ ̡̡̤̲̍̕ Ψ̤̤̕ζΨ̲ϵ͘ζ ̍ζΚ̨͍̤ζ̨ ̲̕ ζ̇ϵ̍ϵ̎Κ̲ζ ̲ϲζ̍ϰϷ ϼϲζ Ψ̲̤̎̕Κ̨̲ Χζ̲͙ζζ̎ ϶̣͍Κ̇ϵπϵζβϷ Κ̎β ϶Ψ̡̍̕ζ̲ζ̲̎Ϸ ̡ζ̨̨̤̎̕ ϵ̨ ̲͍̕Ψϲζβ ̎̕ ϲζ̤ζ Χ͍̲ ̤̍̕ζ π͍̇̇͟ Κββ̤ζ̨̨ζβ in the recommendations given at the end of this analysis. API Spec 2C and API RP 2D do not make such a distinction and should consider making more relevant to offshore crane inspection. Returning once again to the API RP 2D standard, it is stated that the qualified crane operator should also be sufficiently qualified to perform pre-use crane inspections outlined later in the standard and in this analysis. The exceptions are, as will be made clearer below, the more involved Initial, Quarterly, and Annual inspections. The API RP 2D document provides needed training and refresher requirements. These criteria include, but are not necessarily limited to: ϶ϱ͍̇Χ̤ϵΨΚ̲ϵ̎Ϩ ̡̕ϵ̨̲̎Ϯ Κβ̨͍̲́̍ζ̨̲̎Ϯ ̡̤ϵ̎Ψϵ̡̇ζ̨ ̕π Ψ̤Κ̎ζ ̡̕ζ̤Κ̲ϵ̎̕ϭ ζ̨̡ζΨϵΚ̇̇͟ Χ̍̕̕ ̡̕ζ̤Κ̲ϵ̎Ϩ procedures; safety devices and anti-two blocking systems; the proper use and care of all running cables (wire and rope) and pendants; and the proper reading and understanding of crane lifting capacity and reeving charts, boom and indicator charts and hand signal charts. Further, the qualifying Crane Operator shall attend hands-on training on the proper inspection, use and maintenance of rigging gear (slings, shackles, hooks, nylon slings, etc.) and be trained in Κ̇̇ ̤ϵϨϨζ̤ ̤ζ̣͍ϵ̤ζ̍ζ̨̲̎ϰϷ The qualified operator requirements also specify that before a person may be designated a Qualified Crane Operator, he or she is also required to demonstrate hands-on proficiency in the safe operation of cranes he or she is to operate. More concrete requirements for hands-on proficiency are offered. Crane Safety Assessment 91 Page 6.3.2 Inspection Perhaps the most useful feature of API RP 2D for the current analysis is its inclusion of well-defined crane usage categories in relation to inspection, testing, and maintenance. This inclusion reflects a significant expansion of API RP 2D over the years. The sixth edition is now incorporated by reference in 30 C.F.R. 250.198(h)(48). The API RP 2D standard defines a qualified inspector as: A person so designated by the employer who by reason of appropriate experience and training, has successfully completed classroom-type training on crane maintenance and troubleshooting; on hoist troubleshooting and overhaul; and on the structural aspects of offshore cranes, which gives a knowledge of structurally critical components and critical inspection areas. These minimum training requirements are outlined in Appendix A2 (of API RP 2D). Additionally, individuals recognized by regulatory authorities may conduct inspections of cranes pursuant to this edition, provided they meet the requirements of Appendix A2. With successful completion of this minimum training supplemented with requalification at a minimum of every four (4) years, the inspector is considered qualified to perform the Initial, Pre-use, Monthly, Quarterly, and Annual Inspections. There are three general usage categories: infrequent, moderate, and heavy. Infrequent usage is defined as 10 hours or less per month, as measured by average over the course of a quarter. Moderate usage is defined as over 10 hours but less than 50 hours per month, as measured by average over the course of a quarter. Heavy usage is defined as 50 hours or more per month, as measured by average over the course of a quarter. Each of these categories is used to determine the level of inspection that must be applied: Initial, Preuse, Monthly, Quarterly, and Annually. Infrequent usage requires pre-use and annual inspections. Moderate usage requires pre-use, monthly, quarterly, and annual inspections. Heavy usage requires pre-use, quarterly, and annual inspections The levels just described are obviously incremental in the sense that the second includes the first, the third includes the second, and so on. Thus, the standard document is redundant here, giving a full list for each inspection level. However, this criticism is minor, mainly because thoroughness is preferred over conciseness. The more important point is that this scheme is rigorous and well outlined. Another appendix, perhaps the most involved in the entire standard, lays out specific minimum guidelines for usage, inspection, testing, and maintenance. Key issues here are that (a) it is the responsibility of the crane owner to develop a preventative maintenance program in accordance with the manufactures recommendations; (b) the program should dictate a maintenance and inspection schedule based on a duty cycle versus strict time limits; and (c) the program should list specific testing methods to be carried out. The appendix offers several detailed methods. Specific preventive maintenance guidelines are described and general procedures for repairs and replacements are outlined. The relatively brief treatment given repairs and replacements is acceptable because mechanical components have more failure modes than functionality. Thus, a full treatment of Crane Safety Assessment 92 Page guidelines for repairs would be well outside the scope of the standard. However, specific treatment is given to the very important issues of wire rope and sling inspection. An entire detailed appendix is devoted to education and requirements concerning inspection, storage, handling, installation, and replacement of wire rope. Slings are also included. It provides clear pictures that show both the correct and incorrect methods, and other diagrams that leave very little room for ambiguity. Of additional help here is a basic inspection guideline for critical crane components in the three main types of swing circle assemblies typically used on pedestal-mounted cranes. Those assemblies are Hook and Roller, King Post, and Ball/Roller Bearings. That the standard separates these assemblies and gives them specific and extended treatment is quite useful, especially for those cranes typically found on the OCS. The API RP 2D has a few slightly undesirable traits, such as a lack of a threshold limiting the size of cranes to which its requirements apply, ill-defined miscellaneous-section issues, a fuzzy stance on the development of maintenance and operation programs, and essentially absent mention of human factors that make the bulk of mishap root causes. These criticisms notwithstanding, there is no available ISO standard that comes close to covering such a breadth of useful issues for crane operations, testing, maintenance, and, of particular interest here, inspection. There are shorter ISO standards that individually address some of the issues contained in API RP 2D. Examples include the ISO 23814 standard (Competency Requirements for Crane Inspectors) and the ISO 4309 standard (Wire Ropes, Maintenance and Installation). However, there are several important issues not individually addressed by ISO, and several relevant ISO standards do not specify that they address cranes typically found offshore. For the above reasons, it is recommended that BSEE retain API RP 2D as the best currently available and most comprehensive standard for the operation, maintenance, and inspection of offshore cranes. It is also recommended that BSEE retain the necessary companion document, API Spec 2C. 6.3.3 Conclusion and Recommendations Concerning the criticism that API RP 2D gives scant treatment of human factors, it should be noted that the standard gives little guidance on how to assess the physical qualifications of the crane operator. Addressing this issue is pivotal for ensuring that the operator has the physical capabilities required to operate crane controls for appropriate durations. It is recommended that BSEE adopt the physical instructions to physicians for qualifying physical examinations, put forth by the National Commission for the Certification of Crane Operators (NCCCO) as a supplement to API RP 2D. This form provides very clear and explicit instructions for appropriate examinations. Two other recommendations related to the one just given are (a) that BSEE adopt API 770, ϶! MΚ̎ΚϨζ̤ϳ̨ G͍ϵβζ ̲̕ Rζβ͍Ψϵ̎Ϩ H͍̍Κ̎ Ę̤̤̤̕ϭϷ Κ̨ Κ ̨̡̡͍̇ζ̍ζ̲̎ ̲̕ !PI ϶̡ζΨ Ϯ ϭ !PI RP ϮDϭ ̤̕ Χ̲̕ϲϭ π̤̕ ϵ̨̡̎ζΨ̲ϵ̎̕ ̡̤̕Ϩ̤Κ̨̍ Κ̎β ̖Χ̗ ̲ϲΚ̲ ϶EE Κβ̡̲̕ !̍ζ̤ϵΨΚ̎ ϶̕Ψϵζ̲͟ π̤̕ ϼζ̨̲ϵ̎Ϩ Κ̎β MΚ̲ζ̤ϵΚ̨̇ ̖!϶ϼM̗ Fϭϭϲϲϭ ϶϶̲Κ̎βΚ̤β Practice for Human Engineering Design for MΚ̤ϵ̎ζ ϶̨̲͟ζ̨̍ϭ Ẹ͍ϵ̡̍ζ̲̎ϭ Κ̎β FΚΨϵ̇ϵ̲ϵζ̨ϰϷ ϼϲζ π̤̍̕ζ̤ provides much-needed and easy-to-understand information that can help decision makers and front-line personnel alike be better able to recognize hazards that stem from the cognitive and biomechanical Crane Safety Assessment 93 Page limitations of humans. These limitations are especially pertinent for qualified inspectors who should be trained to recognize both mechanical and human-factors related hazards. The human factors standard, ASTM F1166, provides detailed ergonomic design criteria with respect to well-known fundamentals of human performance. Indeed, the best-case scenario for avoiding mishaps entails the consideration and implementation of such factors at the earliest possible stage. It is critical to note here that doing so would not just help curtail negative impacts of cognitive and biomechanical limitations of human operators, but it would also promote positive impacts by making nominal performance more efficient. Incorporating ASTM F1166 in operator and inspector training would not only be fairly easy to accomplish from a logistical standpoint, it would serve as a useful bridge between the general human-factors related hazards described in API 770 and the lower-level details of crane design, operation, and inspection. Regarding general crane inspection methodologies, it is recommended here that BSEE implement the following practices: 1 ̌ Provide a means for determining whether the crane in question has been inspected frequently by a competent operator.7 Here we return ̲̕ ̲ϲζ βϵ̨̲ϵ̎Ψ̲ϵ̎̕ Χζ̲͙ζζ̎ ϶̣͍Κ̇ϵπϵζβϷ Κ̎β ϶Ψ̡̍̕ζ̲ζ̲̎Ϸ ̡ζ̨̨̤̎̕ϰ ̡̍̕ζ̲ζ̎Ψ͟ ϵ̨ βζ̨̲̤̍̎̕Κ̲ζβϭ ̲̎̕ Ψζ̤̲ϵπϵζβϰ ! Ψ̡̍̕ζ̲ζ̲̎ ̡ζ̨̤̎̕ ̨͍̲̍ show ability to recognize hazards and to take steps in mitigating those hazards. Therefore, it is not only qualified persons who can inspect cranes. Rather, anyone who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them, can, and should, frequently inspect the cranes. Here we take a ̨͍ζπ͍̇ Ψ͍ζ π̤̍̕ !϶ME ϯ΄ϰϰϭ ͙ϲϵΨϲ βζπϵ̎ζ̨ ϶π̤ζ̣͍ζ̲̎Ϸ ϵ̨̡̎ζΨ̲ϵ̎̕ Κ̨ ̲ϲζ ͘ϵ̨͍Κ̇ ζ͞Κ̍ϵ̎Κ̲ϵ̎̕ Χ͟ the operator, or other designated person. However, ASME B30.4 explicitly suggests that records not be required for frequent inspections. We suggest that BSEE require some sort of documentation of frequent visual inspections to help ensure that they are, in fact, conducted. The recommendations can be combined with the useful usage categories laid out by API RP 2D, such that infrequently used cranes should receive a visual exam by a competent person monthly, moderately used cranes should receive a visual exam by a competent person weekly to monthly, and heavily used cranes should receive a visual exam by a competent person daily to weekly. The benefit of allowing frequent inspections by competent persons is that there are often several people at a worksite who can be reasonably defined as competent. This helps increase the chances that hazardous conditions of the cranes are recognized and called to the immediate attention of management. Requiring documentation of these frequent inspections will help ensure that any hazardous conditions are actually called to the attention of management. 7 Qualified generally refers to documentation of credentials. Competency is a demonstration of knowledge and ̍Κ̎ϵ̡͍̇Κ̲ϵ͘ζ ̨̄ϵ̇̇ ̲̕ Κ ̡͍Χ̇ϵ̨ϲζβ ̨̲Κ̎βΚ̤βϰ ̌ζΧ̨̲ζ̤ϳ̨ DϵΨ̲ϵ̎̕Κ̤͟ βζπϵ̎ζ̨ Ψ̡̍̕ζ̲ζ̲̎ Κ̨ϯ ϶having the required skills for an acceptable level of performanceϷ I̲ βζπϵ̎ζ̨ ̣͍Κ̇ϵπϵζβ Κ̨ϯ a skill, an ability, or knowledge that makes a person able to do a particular job. The study team found no specific regulatory definitions of these two words. Crane Safety Assessment 94 Page 2 ̌ Provide a means for determining whether the crane in question has been inspected periodically by a qualified ̡̕ζ̤Κ̲̤̕ϭ ͙ϲζ̤ζ ϶̣͍Κ̇ϵπϵζβϷ ϵ̨ βζπϵ̎ζβ ̡ζ̤ !PI ϶̡ζΨ Ϯ Κ̎β !PI RP ϮDϭ Κ̎β ͙ϲζ̤ζ ϶̡ζ̤ϵ̕βϵΨΚ̇̇͟Ϸ ϵ̨ ̇ϵ̎̄ζβ ̲̕ ̲ϲζ ̨͍ΚϨζ ΨΚ̲ζϨ̤̕ϵζ̨ (infrequent, moderate, heavy) and relevant inspection schedules put forth by API RP 2D. 3 ̌ Provide a means for determining whether the crane has been tested by a qualified person. Tests that should be completed are jointly specified by API Spec 2C ad API RP 2D and include fracture toughness testing, heavy lift load tests, nondestructive examination of critical components, pull tests, and nominal load tests. 4 ̌ Provide means for determining whether and how different categories of lifts are addressed. The concern here is that a crane policy is deemed appropriate only if it addresses three main types of lifts: routine, critical, and engineered. Routine lifts are those lifts involving routine lifting operations governed by standard industry rules and practices, except as supplemented with unique company testing, operations, maintenance, inspection, and personnel certification requirements contained in the company safety policies and procedures manual. These lifts are those mainly addressed by API RP 2D, which, it should be noted here, does not draw a distinction between routine, critical, and engineered lifts. Critical lifts are those lifts where failure and/or loss of control could result in loss of life, loss of, or damage to major components, or a lift involving special items such as unique articles or major facility components whose loss would have serious contractual, delivery, or operational impact. Engineered lifts are those lifts whose loads exceed the rated capacity of the crane. Engineered lifts should be performed only in exceptional circumstances and upon express approval of multiple management personnel. Every planned engineered lift shall be treated as an exceptional and separate event. 6.4 ISO Crane Inspection Standards and Regulatory Guidelines The following analysis overlaps with the analyses performed on API Spec 2C and API RP 2D. The analyses complement each other insofar as the points made previously are used to compare the adequacy and appropriateness of inspection-relevant ISO standards for offshore cranes. It is repeated for emphasis here that API Spec 2C and API RP 2D are rather extensive and wide ranging. It is also noted here and in the previous analyses that there are no available ISO standards which are comparable to the coverage and methodology that API Spec 2C and API RP 2D, provide in tandem. The same conclusion is drawn and reinforced below. 6.4.1 Analysis As noted before, the general ISO approach to crane-related standards has been to separately address in several individual standards the body of crane-related issues. This practice has led to an inordinate number of standards. In fact, ISO has published approximately 100 separate crane-related standards! Moreover, the scale on which ISO has broken apart the standards is surprisingly and, in our opinion, Crane Safety Assessment 95 Page unnecessarily fine-grained. For example, there are entirely separate ISO standards dedicated solely to ̡̤̕͘ϵβϵ̎Ϩ ̲ϲζ ͘̕ΨΚΧ͍̇Κ̤ϵζ̨ Κ̨̨̕ΨϵΚ̲ζβ ͙ϵ̲ϲ βϵππζ̤ζ̲̎ ̡̲͟ζ̨ ̕π Ψ̤Κ̎ζ̨ϰ ϼϲζ ̲ζ̤̍ ϶̨ζ̡Κ̤Κ̲ζϷ ϵ̨ ̲̎̕ ̲̕ Χζ Ψ̎̕π̇Κ̲ζβ ͙ϵ̲ϲ ϶͍̎ϵ̣͍ζϭϷ however. Given that there is much overlap in crane terminology, this approach seems overwrought. The main rationale on the part of ISO for breaking up the body of standards into so many constituent parts is that doing so leaves each technical committee able to give the respective issue more in-depth treatment. While it is reasonable to claim that separating the issues can allow the committees to pursue each issue more thoroughly, one can evaluate the standards in usefulness-depth space. Here, usefulness is plotted against the depth of treatment. In such space, usefulness generally increases as depth increases, but there is point at which the usefulness then begins to decline precipitously with increasing depth. The main reason for this decline is mostly logistical ̌ it becomes cumbersome for the readers, many of whom do not have advanced technical backgrounds, to keep track of so many disparate documents and the links which bind them. Note here that each standard gives several normative references to other ISO standards. Our opinion is that the optimal point in usefulness-depth space is exceeded by the current ISO approach to crane-related standards and that whatever depth of treatment it achieves still does not justify the disconnection that arises from having so many standards. Some more specific reviews and critiques of the most inspection-related ISO standards follow. Table 23 shows those standards and gives their brief descriptions. Table 23: ISO Standards Related to Crane Inspections The first critique is related to the first row in Table 23. That is, the ISO crane standards are not differentiated on the basis of those typically found offshore. This is an unfortunate characteristic when it comes to the BSEE goal of promoting safety through improved inspection methods. This observation is also contrasted by API Spec 2C and API RP 2D, which, taken together, more specifically address pedestalmounted cranes much more typical of those found offshore. The second critique is related to the first, and it pertains to the ISO 4309 standard. The ISO 4309 document concerns maintenance and installation of wires and ropes typically found on those cranes described by ISO 4306. These cranes include, cable and portal cable cranes, cantilever cranes, such as pillar jib, wall, or walking cranes, deck cranes, derrick and guy derrick cranes, derrick cranes with rigid bracing, floating cranes, mobile cranes, overhead travelling cranes, portal or semi-portal bridge cranes, portal or semi-portal cranes, railway cranes, tower cranes, and, lastly, offshore cranes. The ISO 4309 standard defines offshore cranes as those mounted on a fixed structure supported by the sea bed or on a floating unit supported by buoyancy forces, though no specific guidance is given on Crane Safety Assessment 96 Page those types of cranes versus any others. The ISO 4306 largely mirrors the guidance given by API Spec 2C and API RP 2D, but it does provides an additional section that lays out slightly more specific criteria for discarding wires and ropes. Note again, however, that there are no specific directions given for how to incorporate the uniquely challenging conditions found offshore, such as wind and seismic loads. For those, the reader would have to consult an entirely different family of ISO standards. Another inspection-related document, the ISO 9927-1 standard contains very general inspection criteria and offers some more specific guidance for tower cranes. The issue of tower cranes does not concern BSEE in this project, and it should be noted that ISO included in this standard a nearly identical set of inspection guidelines as can be found API Spec 2C, API RP 2D, and AMSE B30.4. There are additional ̨ζΨ̲ϵ̨̎̕ ϵ̎Ψ͍̇βϵ̎Ϩ ϶ζ͞Ψζ̡̲ϵ̎̕Κ̇ ϵ̨̡̎ζΨ̲ϵ̎̕ϭϷ ϶̍Κ̤́̕ ϵ̨̡̎ζΨ̲ϵ̎̕ϭϷ Κ̎β ϶ζ̎ϲΚ̎Ψζβ ̡ζ̤ϵ̕βϵΨ ϵ̨̡̎ζΨ̲ϵ̎̕ϰϷ However, these additional sections are either overcomplicating, unnecessary, or both. Moreover, ISO points out that these standards are still under development, and that ISO 9927 provides an example of the inherent incompleteness that comes with that development. For example, ISO 9927 currently consists only of a part on general inspection and a part on tower cranes. A part on bridge and gantry cranes are said only to be planned at this time. Perhaps the most pertinent ISO standard to the goal of the BSEE Crane Safety project is ISO 23814, which provides competency requirements for crane inspectors ̌ those who carry out periodic, exceptional, alteration and thorough inspections of cranes. Unlike the system we recommended in the analysis of API Spec 2C and API RP 2D and AMSE B30.4, the ISO 23814 explicitly and unfortunately excludes the day-to-day inspections by crane operators and maintenance personnel. The ISO 23814 document contains five sections and two annexes, A and B, which delve slightly deeper into recommended crane inspector categories and performance criteria for technical knowledge, respectively. As is typical of the ISO crane-related standards, there are five normative references to track in relation to the standard. The bulk of the information on inspection comes from the last two main sections, which address inspection requirements and training suggestions for crane inspectors. The former entails independence, impartiality, and integrity, technical knowledge, experience requirements, and techniques for crane inspection. The latter specifies training of crane inspectors. Our opinion, however, is that neither section promulgates information that is useful above and beyond the very similar information found in API Spec 2C and API RP 2D. Here again, parsimony and ease of use become the paramount characteristics. Moreover, the number of crane-related ISO standards is so large that it constrains the scope of the competency requirements in ISO 23814 to a topical and general level. Again, this generality is contrasted by the useful offshore-crane specialty of API Spec 2C and API RP 2D. Finally, there is one more ISO standard that is related, at a higher, more abstract level, to crane inspection on the OCS. It is the ISO 17020, which lays out general requirements for the operation of various types of bodies performing inspection. The overarching goal of the standard is to promote confidence in the various bodies that perform inspections. It should be noted here very definitively that this document does not specifically address offshore crane inspection. However, there are features of the standard that BSEE might be able to draw on to help improve its own inspection processes. The ISO approach to harmonizing inspection bodies is relatively thorough. As a result, the expansive ISO 17020 document spans several issues of inspection. These issues include: Crane Safety Assessment 97 Page - General requirements (impartiality and independence); Structural requirements (administrative requirements and organizational management); Resource requirements for personnel, facilities and equipment, and subcontracting; Process requirements (methods, procedures, items, records, complaints, and appeals); Management system requirements (documentation and control of records); Management review (Internal audits, corrective actions, and preventive actions); and Annexes pertaining to additional independence requirements for inspection bodies Though the ISO approach to inspection body harmonization is thorough, it is not particularly novel. It tends to follow well-established best practices related to the above issues. That it places such a high importance on impartiality and independence is laudable but probably of less importance to BSEE. The same goes for the management system requirements to document and control all records associated with inspections and the relevant structural requirements. Of particular interest, however, are resource requirements which place emphasis on the ability of inspectors. Appropriate ability is understood as necessitating both theoretical knowledge and practical knowhow. Moreover, the able inspector may likely be required to have familiarity with relevant regulations, technologies, processes, standards, codes, materials, failure modes, and industry practice. This definition is somewhat ill-βζπϵ̎ζβ ϵ̎ ̲ϲζ ̨ζ̨̎ζ ̲ϲΚ̲ ̲ϲζ Ψ̤ϵ̲ζ̤ϵ̎̕ ̕π ϶πΚ̍ϵ̇ϵΚ̤Ϸ ϵ̨ ̲̎̕ π̤̍̕Κ̇̇͟ ̕ππζ̤ζβϰ However, the span of categories listed in the definition just given may help augment the API RP 2D βζπϵ̎ϵ̲ϵ̎̕ ̕π ϶̣͍Κ̇ϵπϵζβ ϵ̨̡̎ζΨ̲̤̕Ϸ ͙ζ ̡̤ζ͘ϵ̨͍̇̕͟ described. For reference, that definition was as follows: ϶! ̡ζ̨̤̎̕ ̨̕ βζ̨ϵϨ̎Κ̲ζβ Χ͟ ̲ϲζ ζ̡̍̇̕͟ζ̤ ͙ϲ̕ Χ͟ ̤ζΚ̨̎̕ ̕π Κ̡̡̡̤̤̕ϵΚ̲ζ ζ̡͞ζ̤ϵζ̎Ψζ Κ̎β ̲̤Κϵ̎ϵ̎Ϩϭ has successfully completed classroom-type training on crane maintenance and troubleshooting; on hoist troubleshooting and overhaul; and on the structural aspects of offshore cranes, which gives a knowledge of structurally critical components and critical inspection areas. These minimum training requirements are outlined in Appendix A2 (of API RP 2D). Additionally, individuals recognized by regulatory authorities may conduct inspections of cranes pursuant to this edition, provided they meet the requirements of Appendix A2. With successful completion of this minimum training supplemented with requalification at a minimum of every four (4) years, the inspector is considered qualified to perform the Initial, Pre-use, Monthly, Quarterly, Κ̎β !͍̎̎Κ̇ Į̡̎ζΨ̲ϵ̨̎̕ϰϷ N̲̕ζ ̲̕̕ϭ ̲ϲΚ̲ I϶O ϭϳ΄Ϯ΄ ̡̇ΚΨζ̨ ̨̡ζΨϵΚ̇ ζ̡̍ϲΚ̨ϵ̨ ̎̕ ͙ϲΚ̲ ϵ̲ ΨΚ̨̇̇ ϶ζππζΨ̲ϵ͘ζ ̨̡͍ζ̤͘ϵ̨ϵ̎̕Ϸ ̕π ϵ̨̡̎ζΨ̲̤̕s, which is said to help ensure the quality of inspections. Effective supervision is defined primarily by regular proficiency testing for all inspectors. In addition, it indicates that a quality assurance program be developed for inspections and offers several suggests several methods for doing so. Suggested methods include the following: - - Comparison of findings in which several inspectors inspect an item and their findings are compared for reliability; Measurement audits in which an object of inspection with known reference values or qualities be used in a manner similar to the comparison-of-findings method and the variance between the reported results form inspector and referenced value is evaluated; Technical witnessing in which an inspector is observed by another inspector; Crane Safety Assessment 98 Page - - Partial-process schemes in which the ability to perform parts of the overall inspection process are evaluated; Review of records and supporting materials; Client / operator communication in which appropriately structured interviews are Ψ̎̕β͍Ψ̲ζβ ̲̕ Ϩ̇ζΚ̎ ϵ̎π̤̍̕Κ̲ϵ̎̕ ΚΧ͍̲̕ ̲ϲζ ϵ̨̡̎ζΨ̲̤̕ϳ̨ Κ̡̡̤̕ΚΨϲϭ ΧζϲΚ͘ϵ̤̕ϭ Κ̎β performance; and Review of produced reports; The inspection methods information (Section 7) also calls for job-specific sampling plans, where appropriate based on professional judgment, that involve specific analyses about where to sample, how to sample, how much to sample, and what criteria will be used to retain or discard the sampled item(s). Finally, the ISO 17020 standard also lists detailed content that should be in an inspection report. Potentially relevant information is as follows: a) Designation of the document, i.e. as an inspection report or an inspection certificate; b) Identification of the issuing body; c) Unique identification of report; The report must carry this unique identification on each page; d) Indication of the total number of pages, each page being numbered for multi-page reports; e) Identification of the client; Note the owner of the inspected item can be mentioned in the report or certificate if the owner is not the client; f) Description of the inspection work ordered; g) Date(s) of inspection; h) Information on where the inspection was carried out; i) Identification or brief description of the inspection method(s) and procedure(s) mentioning deviations from, additions to or exclusions from the agreed methods and procedures; j) Reference to the use of sub-contractors (where appropriate) including identification of the sub-contracted inspection and/or testing results; k) Identification of the items inspected; l) Identification of equipment used for measuring / testing; m) Where applicable, and if not specified in the inspection method or procedure, reference to or description of the sampling methods and information on where, when, how and by whom the samples were taken; n) Information on environmental conditions during the inspection, if relevant; and o) Inspection results p) A statement of conformity where applicable; q) Statement that the inspection results relate exclusively to the work ordered or to the items or lot inspected; r) Information on what has been omitted from the original scope of work; ̨̗ ϼϲζ ϵ̨̡̎ζΨ̲̤̕ϳ̨ ̍Κ̤̄ ̤̕ ̨ζΚ̇Ϯ Crane Safety Assessment 99 Page t) Names (or unique identification) of the personnel members who have performed the inspection and in cases when secure electronic authentication is not undertaken u) Signature or other indication of approval, by authorized personnel; v) Date of issue of the report; w) Any other information required by the client. x) Caveats and assumptions made by the facility, and the basis for these (where applicable); and y) Clear identification of inspection and test data from non-accredited sources that has been utilized in the inspection (where appropriate); 6.4.2 Conclusion and Recommendations The foregoing analysis of ISO standards relevant to crane inspection on the OCS makes clear that there are some useful features of the ISO approach. Perhaps the most useful feature is that the standards are written with the goal of harmonizing an international community of crane owners, operators, and inspectors. However, this very challenging endeavor has led to the promulgation of far too many separate and disparate standards. Moreover, offshore cranes, most of which are pedestal-mounted, are not specifically treated like they are in API Spec 2C and API RP 2D; this is true even though there exists this great number of standards. A final and related major criticism is that the standard set is still in development, and it certainly needs to be consolidated some before it can be recommended that BSEE adopts it wholesale. The most potentially useful components of the inspection-related ISO standards come from ISO 17020. There BSEE is encouraged to find and consider the slightly expanded set of categories that can be used to train and ensure the ability of qualified inspectors. This set can be used to augment the definition of ̣͍Κ̇ϵπϵζβ ϵ̨̡̎ζΨ̨̲̤̕ Ϩϵ͘ζ̎ Χ͟ !PI RP ϮDϰ ϼϲζ̤ζ Κ̤ζ Κ̨̇̕ ̨ζ͘ζ̤Κ̇ ϶ζππζΨ̲ϵ͘ζ ̨̡͍ζ̤͘ϵ̨ϵ̎̕Ϸ Κ̎β ϶̣͍Κ̇ϵ̲͟ Κ̨̨͍̤Κ̎ΨζϷ ̍ζ̲ϲ̕β̨ Ϩϵ͘ζ̎ π̤̕ ζ̨͍̤̎ϵ̎Ϩ ϵ̨̡̎ζΨ̨̲̤̕ ̡ζ̤π̤̍̕ ͙ζ̇̇ Κ̎β ϵ̨̡̎ections are of the best possible kind. Related benefits might be gained from being very explicit about the components that must be found in an official inspection report. With the above analysis and conclusions in mind, it is recommended that BSEE retain API Spec 2C and API RP 2D as the best currently available and most comprehensive set of standards for the operation, maintenance, and inspection of offshore cranes. 6.5 ASME B30 Standards The study team reviewed and analyzed the American Society of Mechanical Engineers (ASME) B30 standard series, concerning crane and material handling equipment, as part of developing inspection strategy and methodologies for BSEE. The B30 series addresses the construction, installation, operation, inspection, testing, maintenance, and use of cranes and other lifting and material-movement related equipment. The stated purpose of the B30 series is to (a) prevent or minimize injury to workers, and otherwise provide for the protection of life, limb, and property by prescribing safety requirements; (b) provide direction to manufacturers, Crane Safety Assessment 100 Page owners, employers, users, and others concerned with, or responsible for, its application; and (c) guide governments and other regulatory bodies in the development, promulgation, and enforcement of appropriate safety directives (p.viii). The scope of the analysis covers a general review of the B30 standard series and does not assume specialized knowledge of crane operations. Where appropriate, however, it does focus on whether and how the particular standard being reviewed speaks to the issue of inspection. What follows is the requested review and analyses of the most current version of the B30 documents. The relevant ASME B30 standards addressed by ASBG, per BSEE request, are listed in Table 24. Table 24: ASME Crane and Material Handling Standards B30.2:2011 B30.4:2010 B30.7:2011 B30.8:2010 B30.9:2010 B30.10:2014 B30.16:2012 B30.20:2013 B30.21:2014 B30.24:2013 Overhead and Gantry Cranes Portal and Pedestal Cranes Winches Floating Cranes and Floating Derricks Slings Hooks Overhead Hoists Below-the-Hook Lifting Devices Lever Hoists Container Cranes 6.5.1 B30.2: Overhead and Gantry Cranes The B30.2 includes provisions that apply to the construction, installation, operation, inspection, and maintenance of hand-operated and power-driven overhead and gantry cranes that have a top-running single-girder or multiple-girder bridge, with one or more top-running trolley hoists used for vertical lifting and lowering of freely suspended, unguided loads consisting of equipment and materials. Figure 12 and Figure 13, show schematics of overhead and gantry cranes. Figure 12: Overhead Crane Crane Safety Assessment 101 Page Figure 13: Gantry Crane There are four major sections of the B30.2 standard; (1) general construction and installation (2) inspection and testing (3) operator training and operation (4) maintenance and maintenance training. Each section is addressed below, with special emphasis on inspection testing, per the scope of work. The existence and use of appropriate markings are an integral part of any safe crane operation. Therefore, markings need to be considered from the earliest stages of development. The B30.2 standard gives guidance on this issue, calling for intelligible markings for crane load, hoist load, manufacturer identification, multiple hoists, and general warning markings. Where appropriate, the markings must be legible from the ground and must also be available on the controls used by the operator(s). Unfortunately, the document does not define specifics concerning the makeup of the markings (e.g., size, color, font, etc.), but it does reference a useful label standard ̌ the American National Standards Institute (ANSI) Z535.4. Guidance on clearances, runways, supporting structures, foundations, anchorages, welds, and girders are provided next. The B30.2 addresses these issues topically, though it does a fair job at touching on the important issues while referencing other standards for more in-depth treatment where necessary. While it is noted that most overhead cranes do not incorporate a cab as do pedestal cranes, a subsequent section concerns the crane cab and control interface. There is an unfortunate paucity of useful information about the design of this critical human-machine interface. For example, the B30.2 states: ϶The general arrangement of the cab and the location of the control and protective equipment should be such that all operating handles are within reach of the operator when facing the area to be served by the load block, or while facing the direction of travel of the cabϱϷ ϶ϱ̲ϲζ Κ̤̤Κ̎Ϩζ̍ζ̲̎ ̕π ̲ϲζ ΨΚΧ ̨ϲ͍̇̕β Κ͙̇̇̕ ̲ϲζ ̡̕ζ̤Κ̲̤̕ Κ π͍̇̇ ͘ϵζ͙ ̕π ̲ϲζ ̇̕Κβ Χ̇̕Ψ̄ ϵ̎ Κ̇̇ positions. This is an important and desirable condition, but it is recognized that there are physical arrangements that may make this impossible, and, when the load block is in these positions, the operator shall be aided by other means such as, but not limited to, closed-circuit TV, mirrors, radio, ̲ζ̇ζ̡ϲ̎̕ζϭ ̤̕ Κ ̨ϵϨ̎Κ̡̇ζ̨̤̎̕ϰϷ However, API Specification 2C which is applicable to offshore pedestal cranes, provides some welldefined human factors recommendations in Section 10. A much more desirable situation would be the Crane Safety Assessment 102 Page adoption and inclusion of more specific and well-understood human factors principles, such as those discussed in American Society of Testing Materials (ASTM) F1166. This document, as well as the American Petroleum Institute (API) 770 standard, gives clear, and easy-to-use guidance on designing operator stations in a way that facilitates human performance and avoids placing operators in errorprovocative situations. The ABS Group Consulting Human Factors Engineering Group has performed several analyses of error-provocative crane cabs that have led to several mishaps. It would be in the best interest of BSEE to incorporate the knowledge learned from these analyses, much of which is already reflected in ASTM F1166. The B30.2 standard offers fairly well-defined specifications for the construction of service platforms and foot-walks, ladders and stairways, and other parts related to control of moving parts, such as trolleys, bumpers, and other braking mechanisms. This section is followed by another detailed one on electrical equipment, including controllers, resistors, switches, conductors, and magnets. A very important section on hoisting equipment follows. The information contained therein is critical, and those involved in relevant crane construction would do well to pay close attention to it. It includes sheaves, drums, ropes, and hooks. It should be noted, however, that the information is almost entirely qualitative, as opposed to the more quantitative information given in other places (e.g., API Spec 2C). The section most critical to the BSEE Crane Safety project is the second ̌ Inspection and Testing. The stated purpose of the section is to provide criteria for determining whether the crane can be expected to perform as intended. The standard defines five unique types of inspection. They are: Initial inspection ̌ a documented initial visual and audible crane examination concerning any new, reinstalled, altered, repaired, and/or modified equipment; Functional test inspection ̌ a documented initial visual and audible crane examination, especially concerning operational controls, upper limit devices, and rope, shall be conducted at the beginning of every shift; Frequent inspection ̌ a documented initial visual and audible crane examination on the basis of ͙ϲζ̲ϲζ̤ ̲ϲζ Ψ̤Κ̎ζ ϵ̨ ϵ̎ ϶̤̎̍̕Κ̇ϭϷ ϶ϲζΚ͘͟ϭϷ ̤̕ ϶̨ζ͘ζ̤ζϷ ̨ζ̤͘ϵΨζϭ ͙ϵ̲ϲ ̤ζ̨̡ζΨ̲ϵ͘ζ ϵ̨̡̎ζΨ̲ϵ̎̕ intervals being monthly, weekly to monthly, and daily to weekly, respectively; The definitions of normal, heavy, and severe, are as follows:8 Heavy ̌ service that involves operating at 85 to 100% of rated load or in excess of 10 lift cycles/hr as a regular specified procedure; Normal – service that involves operating at less than 85% of rated load and not more than 10 lift cycles/hr except for isolated instances; and Severe ̌ service that involves normal or heavy service with abnormal operating conditions 8 The items to be inspected are operating mechanisms, upper limit devices, hydraulic components, hooks, hook latches, attachments, rope, and warning devices. Crane Safety Assessment 103 Page Periodic inspection ̌ a documented initial visual and audible crane examination on the basis of whether the c̤Κ̎ζ ϵ̨ ϵ̎ ϶̤̎̍̕Κ̇ϭϷ ϶ϲζΚ͘͟ϭϷ ̤̕ ϶̨ζ͘ζ̤ζϷ ̨ζ̤͘ϵΨζϭ ͙ϵ̲ϲ ̤ζ̣͍ϵ̨ϵ̲ζ ϵ̲̎ζ̤͘Κ̨̇ ΚΧ̕͘ζϰ9 Inspection of equipment not in regular use ̌ a crane that has been idle for a period of 1 month or more, but less than 1 year, shall be inspected before being placed in service in accordance with the requirements listed for frequent inspection, and a crane that has been idle for a period of 1 year or more, shall be inspected before being placed in service in accordance with the requirements listed for periodic inspection. The standard also states that in addition to the above inspections, any other inspection provisions found ϵ̎ ̲ϲζ Ψ̤Κ̎ζ ̍Κ͍̎Κ̇ ̨ϲ͍̇̕β Κ̨̇̕ Χζ π͙̇̇̕̕ζβϰ !̇̇ ϵ̨̡̎ζΨ̲ϵ̨̎̕ ̨͍̲̍ Χζ ̡ζ̤π̤̍̕ζβ Χ͟ Κ ϶βζ̨ϵϨ̎Κ̲ζβ ̡ζ̨̤̎̕ϰϷ ϼϲζ̤ζ Κ̤ζ ̨̡ζΨϵπϵΨ Κ̎β Κ̡̡̡̤̤̕ϵΚ̲ζ Ϩ͍ϵβζ̇ϵ̎ζs for rope inspection, as well as operational and load tests, including, lifting and lowering, trolley travel, bridge travel, and hoist-limit devices. Unfortunately, there is little differentiation in B30.2 between types of lifts for overhead cranes and there is no requirement for any pre-lift planning. In our opinion, this is a serious safety defect in both the ASME B30 series standards and in API RP 2D. Important types of lifts are routine, critical, and engineered, and their definitions are as follows: Routine ̌ lifts involving routine lifting operations governed by standard industry rules and practices, except as supplemented with unique company testing, operations, maintenance, inspection, and personnel certification requirements. Routine lifts are those mainly addressed by API RP 2D, which, it should be noted here, also does not draw a distinction between routine, critical, and engineered lifts. Routine lifts are often designated from critical lifts by a weight limit as mentioned below. Critical ̌ lifts where failure and/or loss of control could result in loss of life, loss of, or damage to major components, environmental releases, or a lift involving special items such as unique articles or major facility components whose loss would have serious contractual, delivery, or operational impact. There are few set rules to define whether a lift is considered critical and thereby requires a pre-lift plan. Crane manufacturers and owners or operators often set specific criteria that determine whether a lift plan is required. Some factors which determine whether or not a lift should be designated as critical are:  When a load is lifted over or near operating equipment or safety areas designated by a dropped object study;  When two or more pieces of lifting equipment are required to work in unison, including trolleys installed on the same bridge;  When special lifting equipment such as non-standard crane configurations or purpose built, one-off lifting appurtenances will be used;  The weight of the load exceeds set limits such as 20 tons; 9 Aperiodic inspection should address the components listed under criteria for frequent inspection and should include an exhaustive list of additional components specified in the standard. Crane Safety Assessment 104 Page  ϼϲζ ͙ζϵϨϲ̲ ̕π ̲ϲζ ̇̕Κβ ζ͞Ψζζβ̨ ϳϱ ̡ζ̤Ψζ̲̎ ̕π ̲ϲζ Ψ̤Κ̎ζϳ̨ ̤Κ̲ζβ ΨΚ̡ΚΨϵ̲͟Ϯ ̤̕  When making personnel transfers. Engineered ̌ lifts whose loads exceed the rated capacity of the crane. Engineered lifts should be performed only in exceptional circumstances and upon express approval of multiple management personnel. Every planned engineered lift should be treated as an exceptional and separate event. Engineered lifts are so exceptional that there should be increased inspection requirements to be met prior to their operation: One additional requirement is that the crane should be inspected by the crane manufacturer or a qualified third-party inspector in accordance with periodic inspection requirements not more than two days prior to the lift; Another is that any deterioration or defects found by that inspector shall be considered in design calculations to support the lift; The crane should also be inspected by the crane manufacturer or a qualified third-party in accordance with periodic inspection requirements after the engineered lift is completed and prior to release for use in normal operations; and Finally, a record of the engineering lift, including supporting calculations, inspections, weights, and all distances moved, should be placed on file. Note that B30.2 does address planned engineered lifts but does not compare them specifically to critical or routine lifts. The study team recommends that BSEE note the differences between these lift types and adopt an associated inspection approach to those lifts, such as the one outlined immediately above. Moreover, there should be kept on record specific forms documenting critical and engineered lift operations. The next section of the B30.2 standard addresses operations and operator training. The operator training is not extensive. It does lay out specific items that should be incorporated into the training regimen, but it suggests very little about the duration, intensity, or frequency of the training. For exΚ̡̍̇ζϭ ̲ϲζ β̕Ψ͍̍ζ̲̎ ̨̲Κ̲ζ̨ ̎̇̕͟ ̲ϲΚ̲ ϶ϱ͙̤ϵ̲̲ζ̎ Κ̎β ̡̤ΚΨ̲ϵΨΚ̇ ζ͞Κ̍ϵ̎Κ̲ϵ̨̎̕ ̲ϲΚ̲ ͘ζ̤ϵπ͟ ̲ϲΚ̲ ̲ϲζ person has acquired the knowledge and skill to operate the particular crane(s) that will be operated by ̲ϲζ ̡ζ̨̤̎̕ϰϷ ϼϲζ β̕Ψ͍̍ζ̲̎ Ϩϵ͘ζ̨ ̤̍̕ζ βζ̲Κϵ̇ζβ Κ̲̲ζ̲̎ϵ̎̕ to operations criteria and assigns various operations-relevant responsibilities to management and to operators. To meet the operator training requirements of B30.2, the study team recommends that BSEE require an overhead crane operator certification program which is consistent with the requirements of the National Commission for Certification of Crane Operators (NCCCO) for overhead cranes. A copy of the NCCCO candidate handbook for overhead crane operator certification is attached as Appendix A. The NCCCO certification requires both a cognitive and psychomotor demonstration of operator competence. This objective demonstration of crane operator competence cannot be overestimated. One useful, operations-relevant facet of the B30.2 is the detailed treatment of the standard visual signals that should be given to the operator during lifts. Such signaling is critical to safe operations because verbal communication is unavailable due to ambient noise. A series of clear schematics are Crane Safety Assessment 105 Page given. Thereafter, a miscellaneous section contains various items, such as ladders, cabs, fire extinguishers, and lockout-tagout policies and procedures. The final section of the B30.2 standard is quite helpful. It not only lays out issues critical to maintenance, but it specifically addresses the training of maintenance personnel. It offers sources of training material and assigns responsibilities to persons involved in crane maintenance. However, the usefulness of this section is curtailed somewhat by the lack of depth in recommendations about the nature of training ̌ basically the same problem noted above with respect to operator training. This observation notwithstanding, the final sections on crane and rope maintenance are appropriately detailed and useful. To meet the inspector training requirements of B30.2, the study team recommends that BSEE require that all frequent and periodic crane inspections be performed by an overhead crane inspector certified by a program which is consistent with the requirements of the National Commission for Certification of Crane Operators (NCCCO) for overhead cranes. A copy of the NCCCO candidate handbook for crane inspector certification is attached as Appendix B. The NCCCO certification requires both a cognitive demonstration of inspector competence and least five years of documented crane inspection experience. The study team recommends the incorporation by reference of ASME B30.2 in 30 C.F.R. 250.198 and a specification for operation of overhead cranes in accordance with B30.2 in 30 C.F.R. 250.108. 6.5.2 B30.4: Portal and Pedestal Cranes Some of what follows in this review of B30.4, Portal and Pedestal Cranes, is adopted from the inspection-specific gap analyses conducted in the analysis of API Spec 2C and API RP 2D. ͟ πΚ̤ϭ !϶ME ϯ΄ϰϰϭ ϶P̤̲̕Κ̇ Κ̎β Pζβζ̨̲Κ̇ ̤Κ̎ζ̨Ϸ ϵ̨ ̲ϲζ ̨̲Κ̎βΚ̤β ̕π ̲ϲζ ϯ΄ ̨ζ̤ϵζ̨ ̨̲̍̕ Ϩζ̤̍Κ̎ζ ̲̕ ̲ϲζ offshore community. The reason is simple: Portal and pedestal cranes are the most common crane type found in offshore GOM Region operations. Below, the ASME B30.4 standard is reviewed more deeply than in previous tasks, again with a special emphasis on inspection. The specific scope of the B30.4 offers provisions that apply to the construction, installation, operation, inspection, and maintenance of electric motor or internal-combustion engine-powered portal and pedestal cranes that adjust operating radius by means of a boom luffing mechanism or by means of a trolley traversing a horizontal boom, that may be mounted on a fixed or traveling base, and to any variation thereof that retain the same fundamental characteristics. Relevant Definitions Luffing crane ̌ a crane with a boom pinned to the superstructure at its inner end and containing load-hoisting tackle at its outer end and with a hoist mechanism to raise or lower the boom in a vertical plane to change load radius; Pedestal crane ̌ a crane consisting of a rotating superstructure with operating machinery and boom, all of which is mounted on a pedestal; and Portal crane ̌ a crane consisting of a rotating superstructure with operating machinery and boom, all of which is mounted on a gantry structure, usually with a portal opening between the Crane Safety Assessment 106 Page gantry columns or legs for traffic to pass beneath the crane. The crane may be fixed or on a traveling base. A pedestal crane is shown in Figure 14 and a portal crane is shown in Figure 15, both cranes have luffing booms. Figure 14: Pedestal Crane Figure 15: Portal Crane There are three main sections in the B30.4 standard. The first concerns the erection, characteristics, and construction of pedestal and portal cranes. The second concerns inspection, testing, and maintenance. The third concerns operation. The first section in B30.4 gives detailed treatment of crane supports, general erection requirements, and pre-operation procedures. The only mention of inspection in these early paragraphs requires crane components to be inspected visually to ensure they are not damaged, prior to erection. Later paragraphs address load ratings and stability and differentiate between ratings where stability primarily governs lifting performance and where structural competence primarily governs lifting performance. The former category focuses on stipulated operating radii with the boom in the least stable direction. There are directions to manufacturers to consider the most important stability factors Crane Safety Assessment 107 Page when calculating load ratings. These factors include, boom length, jib, or combination of boom and jib mounted, counterweight arrangement, and, when applicable, tower height. Wind forces and lifting attachments that are permanent parts of the crane are also noted as important stability considerations. The latter category ̌ load ratings where structural competence governs performance ̌ is based on stipulated operating radii in the least favorable direction and at the maximum in-service velocity, per manufacturer specification. The standard is performance based in this regard, because neither the least favorable situation, nor a representative set of unfavorable conditions is well defined. This lack of definition requires the manufacturer to provide case-by-case data for each crane. Next, clear and important requirements for load rating charts, backward stability, out-of-service stability, and procedures for altered or modified cranes are given. The B30.4 is very clear about the documentation that should be provided to the crane designers in order to meet the structural requirements given site preparation and crane support design data. Other important documentation includes erection instructions for the relevant personnel, operating instructions, maintenance requirements, repair recommendations, and design characteristics affecting safety. These characteristics are spelled out nicely; they include limiting and indicating devices, hydraulic and pneumatic relief valves, and limitations on service life of load-bearing members or mechanisms. General qualitative requirements for hoisting equipment, including hoist drums, hoist brakes, hoist sheaves, and hoist ropes are addressed before more specific requirements for boom hoist drums, boom hoist sheaves, and load trolley systems. Slewing (swinging) and linear traveling equipment are mentioned, though they are given only short treatment. Similar information is given for brakes, switches and limiting devices, boom and jib support ropes, reeving accessories, and counterweights. The requirements are for the operating controls and operator cabs are disappointingly similar to those given for overhead and gantry cranes in B30.2. They almost exclusively focus on the failsafe modes of the controls, but do not incorporate human factors information, such as those given by ASTM F1166. Incorporating such principles are well known to not only increase safety, but also to increase optimal nominal performance. General requirements for the electrical equipment, foot-walks, ladders, and guards for moving parts are all similar to B30.2. However, some notable differences between overhead cranes and pedestal mounted cranes can be observed. For example, there is a requirement that exhaust gases be piped and discharged away from the operator due to the proximity of the engine. The second major section of the B30.4 is the most important for this analysis ̌ Inspection, Testing, and Maintenance. That these three issues are treated in one section contributes to the brevity of B30.4 relative to API Spec 2C and API RP 2D, along with the fact that the ASME B30 series breaks out relevant issues in several smaller standards. The inspection section of the ASME B30.4 carves inspection classification into initial inspection, which entails all new, reinstalled, altered or repaired cranes, and regular inspection, which entails two subcategories. The two subcategories of regular inspection are frequent and periodic. The former subcategory could be monthly for light service, weekly for normal service, or daily for heavy service. The latter subcategory, periodic inspection, is done on the order of 1- to 12-month intervals, or as Crane Safety Assessment 108 Page specifically recommended by the manufacturer. The standard then lays out several explicit criteria for appropriate inspection on these different schedules, as noted above. Again, the main critical component given special attention, however, is wire rope inspection and replacement criteria. Table 2 shows that there is quite a bit of overlap between the inspection requirements given for overhead and gantry cranes (B30.2) and for pedestal-mounted and portal cranes (B30.4). The differences primarily reflect the differences in the crane design and operations. However, the magnitude of the scope of parts to be inspected and the schedule on which they are to be inspected are similar. One difference is that the B30.4 goes into much more detail about what information needs to be recorded in the test record than does B30.2. Note that both require records to be laid down. The B30.4 goes into much greater detail for rope inspection and replacement as well. It also comments on the maintenance of the rope and gives very specific criteria for thresholds past which the rope should be repaired or replaced. Despite some differences, the fundamental approach to inspection is quite similar across the standards. The table shows the results of an inspection-related comparison concerning ̲ϲζ !϶ME ϯ΄ ̨̲Κ̎βΚ̤β̨ϰ ϼϲζ ̖̗̓ ϵ̎βϵΨΚ̲ζ̨ Ψ̕͘ζ̤ΚϨζϰ E̡̲̍͟ Ψζ̨̇̇ ϵ̎βϵΨΚ̲ζ ̎̕ Ψ̕͘ζ̤ΚϨζϰ Other B30 series standards are included in the table but analyzed later in this analysis. Figure 16: Comparison of Relevant B30 Series Standards The final section of B30.4 addresses operations. It puts forth qualifications for and conduct of operators and operating practices. Only designated persons, trainees under direct supervision of a designated person, maintenance and test personnel, and crane inspectors shall enter the crane cab. The standard Crane Safety Assessment 109 Page lays out qualifications for operators, which are slightly and usefully more involved than those put forth in B30.2. The same holds for the conduct of operators subsection, which addresses issues such as attention diversion, mental fitness, and response to warning indications. Because pedestal-mounted and portal cranes are versatile, and because they are often used in unique places like the offshore community, the B30.4 also addresses personnel lifting in an extended section. Standard, hand, and special signals are also schematized in the standard, much like in the B30.2. API SPEC 2C and API RP 2D substantially include all of design, inspection the training requirements of B30.4 with the exception of medical qualifications of the operator, but are aimed at the specific requirements for the offshore environment. Since the API RP 2D standard gives little guidance on how to assess the physical qualifications of the crane operator, addressing this issue is pivotal for ensuring that the operator has the physical capabilities required to operate crane controls for appropriate durations. Thus, the study team recommends that BSEE adopt either ASME B30-4, Portal and Pedestal Cranes, section 4-3.1.2, or the physical instructions to physicians for qualifying physical examinations (attached as Appendix C) put forth by NCCCO as a supplement to API RP 2D. Otherwise, the study team does not recommend the adoption of ASME B30.4 as a substitute for the two API standards already incorporated by reference in 30 C.F.R. 250.108. 6.5.3 B30.7: Winches The specific scope of the B30.7 standard is to give provisions that apply to the construction, installation, operation, inspection, testing, and maintenance of winches arranged for mounting on a foundation or other supporting structure for moving loads. Winches addressed in this standard are those typically used in industrial, construction, and maritime applications. The requirements included in this Volume apply to winches that are powered by internal combustion engines, electric motors, compressed air, or hydraulics, and that utilize drums and rope. Importantly, the standard explicitly excludes overhead hoists and winches used with the following: (a) all-terrain-type recreational vehicles; (b) drill rig relocation trucks; (c) tow trucks; (d) vehicle recovery units; (e) boat trailers; (f) amusement park rides; (g) excavating equipment; and (h) equipment covered by ANSI A10, A17, A90, A92. Note that a winch is defined as a power-driven drum that when attached to a load is capable of moving the load. Examples of winches are shown below in Figure 17 and Figure 18 below. Crane Safety Assessment 110 Page Figure 17: Single-Drum Winch Figure 18: Three-Drum Winch with Attached Swinger The B30.7 standard on winches adequately addresses ratings, markings, and construction. Especially important sections concern brakes, guards, and ropes. The controls must be marked and must be located within reach of the operator while at the operator station. Electrical winches are to have an interlock that will disconnect all motors from the power source in the event of a power failure and will not permit any motor to be restarted until the controller handle is brought to the off position or a rest switch or button is depressed. Remote-operated winches must stop in the event that the control signal for any motion becomes ineffective. The standard concludes the construction section by making short but important statements on engine clutches, electrical components, and lubrication. An installation section assigns the responsibility of winch attachments solely to the operator, who should be a qualified person. The installation section is quite short, concluding with a statement that all winches should be installed in a manner that allows proper rope spooling on the drums. The second section of B30.7 addresses the inspection, testing, and maintenance. Here, the five types of inspection show up again. These are the initial, daily, frequent, periodic, and irregular-use inspections. This common framework is modified as needed for the specific issues involved with winches. Operational and load tests are specified and required. There are clear and concise preventive maintenance requirements that simply refer the reader to the manual specifications of the winch manufacturer and to ANSI Z244.1 for lockout/tagout procedures to be used during maintenance. The final section concerns qualifications and conduct of operators. Qualified persons are those who have met the requirements put forth in subsequent paragraphs, trainees under the direct supervision of an operator, and maintenance, inspection, and test personnel who have been trained. Crane Safety Assessment 111 Page The qualifications and conduct of operators requirements closely mirror those described above. There are specific cautions to personnel with regard to winches that include avoiding crushing or pinch points, not standing in line with a load line that is under tension, standing clear of any slack, loops, or curves while the rope is being tensioned, inspecting the load line paths and operating areas to establish suitable barriers and guards, not placing any portion of the body on a winch line under tension, and not wearing loose clothing around winch operations. The study team recommends the incorporation by reference of ASME B30.7 in 30 C.F.R. 250.198 and a specification for operation of winches in accordance with B30.7 in 30 C.F.R. 250.108. 6.5.4 B30.8: Floating Cranes and Floating Derricks This standard applies to cranes and derricks, used for vertical lifting and lowering of loads, mounted on barges or pontoons. An example is shown in Figure 19 and Figure 20 below. Figure 19: Floating Crane Figure 20: Floating Derrick The B30.8 standard is structured similarly to B30.4, reviewed above. It has three major sections, which again look at construction and installation, inspection, testing, and maintenance, and operations. Crane Safety Assessment 112 Page Together, the B30.4 and the B30.8 are the two B-series documents that address those cranes most likely to be found offshore. In the case of the B30.8, which concerns floating cranes and derricks, the standard notes that cranes and derricks can be designed for barge or pontoon mounting, or they can be designed for land but then mounted on barges or pontoons. In the former case, the load ratings are more dependent upon structural competence, rope strength, hoist capacity, the structural attachment to the floating platform, and upon stability and freeboard of the floating platform, barge, or pontoon. In the latter case, the load ratings are more dependent upon stability, structural competence, rope strength, and hoist capacity of the crane or derrick, and also upon the stability and freeboard of the floating platform, barge, or pontoon upon which they are mounted. With these issues in mind, several specific issues relating to rated loads and rated load marking are presented. The standard then focuses on ensuring that the barge or pontoon is capable of withstanding the weight of the crane or derrick plus lift weight and other anticipated deck loads. To help ensure safe operations, the operational criteria include operating list and trim of the barge or pontoon as a result of the lift. This consideration is schematized in Figure 21 below. Figure 21: Issues to Consider when Assessing Operating List and Trim The more specific quantitative considerations are spelled out for floating cranes and derricks designed for barges / pontoons and for land. The standard rightly addresses the general requirements for the pontoons and barges. Critical to this general issue are several more specific ones, such as watertight compartments to avoid capsizing, manholes and hatches, fittings, life preservers, and rescue skiffs. The crane- and derrick-specific requirements guards on electrical and certain mechanical equipment, and miscellaneous equipment, such as a Coast Guard-approved fire extinguisher, audible warning devices, self-closing filler cap for fuel tanks, and navigational lights. Boom hoists and loads are then specifically addressed, along with the control, braking, and locking of any swing mechanisms. The subsection on controls is nearly identical previous sections on controls reviewed above. Likewise, requirements for ropes, sheaves, cabs, and booms are all given similar treatment. Crane Safety Assessment 113 Page The inspection, testing, and maintenance section of B30.8 contains now-stock information on initial and regular inspection classifications. However, many of the items to be inspected are unique to floating cranes, derricks, barges, and pontoons. The list is longer and slightly more involved for the periodic inspections, per common practice in the B30 series. Detailed requirements are given for the operational and load tests, also per custom. The maintenance specifications are very similar, though this standard calls for a service history ̌ a historical inspection program including records on examination of ropes removed from service so a link between visual observation and actual condition of the internal structure can be established. This feature is highly desirable, mainly because collecting and analyzing those data can help better predict the condition of the equipment as a function of time and usage. The operations section is nearly identical to those reviewed above. However, one particular difference of note is the issue of securing booms during nonuse. It is noted that floating crane and derrick booms are not normally designed to resist substantial wind loads. Thus, it is required that unloaded booms not be left at high angles. When not in use, the derrick booms must be laid down, secured to a stationary member, raised to a vertical position an secured to the mast. When not in use the crane booms must be lowered to the deck of the barge and secured and secured on the boom rest or cradle. For both lifting devices there should be engaged positive locking mechanisms on the boom hoist. There are also some unique issues with providing means suitable for embarking and disembarking barges or pontoons in accordance with regulatory requirements. Floating cranes and derricks also do not meet personnel lifting or elevator requirements and thus should not be operated when anyone is on the hook, load, man-lift platform, boom, or other personnel lifting device attached to the crane load line or boom, unless each several special following conditions are met. The standard lays out those conditions thoroughly. Finally, there are several requirements put forth for clear communication with the operator. These include those signals mentioned several times above. Because floating vessels such as barges are not attached to the OCS as are fixed platforms or mobile offshore drilling units, they fall under the jurisdiction of the U.S. Coast Guard and therefore the study team does not recommend the incorporation of B30.8 in 30 C.F.R. 250.198. 6.5.5 B30.9: Slings Slings are assemblies to be used for lifting when connected to a lifting mechanism. The upper portion of each sling is connected to the lifting mechanism and the lower supports the load. As the interface between the load and the crane, the sling remains an incredibly critical component. Perhaps unsurprisingly, then, ASME devoted an entire 80-page standard to addressing the fabrication, attachment, use, inspection, and maintenance of slings used for lifting purposes. The following is a review and analysis of that information, which covers slings fabricated from alloy steel chain, wire rope, metal mesh, synthetic fiber rope, synthetic webbing, and synthetic fiber yarns in a protective cover. At a high level, the B30.9 standard takes a nearly identical to all slings made of the different materials just mentioned. The present analysis capitalizes on this observation by laying out, just one time, the general template used by B30.9 with alloy chain slings as an example. The analysis then notes only Crane Safety Assessment 114 Page those important features that differ across the different types of slings subsequently mentioned. In turn, this point points up the fact that the section associated with each type of sling does contain several unique pieces of information. Per the present call order, inspection-relevant issues are drawn into particular focus, though the general template includes training, materials and components, fabrication and configurations, proof tests, sling identification, effects of environment, inspection, removal, and repair, and operating practices. The first type of slings addressed by B30.9 is alloy steel chain. Examples are shown in Figure 22 below. Figure 22: Various Alloy Steel Chains Alloy chain sling users are supposed to be trained in the selection, inspection, cautions to personnel, effects of environment, and rigging practices. Specific criteria are given for the composition of the primary material ̌ in this case, alloy steel ̌ and for the welding of specific components, such as handles, fasteners, and coupling links. Several ASTM and ASME standards are used as normative references. Different possible configurations are mentioned and explained, along with the relevant design factor. The standard is quite explicit and detailed when it comes to data for rated loads. Figure 23 below shows an example of the detail level to which loads are given. In the standard, another whole table addresses Crane Safety Assessment 115 Page the same data but for Grade 100 alloy steel chain slings. That particular table is not shown here for the sake of brevity. Figure 23: Rated Load for Grade 80 Alloy Steel Chain Slings — Vertical, Basket, and Bridle Hitches Proof tests are critical. The standard states that prior to initial use, all new and repaired chain and components of an alloy steel chain sling, either individually or as an assembly, shall be proof tested by the sling manufacturer or a qualified person. Several more specific proof load requirements for various slings are given. The following items of identification must be present for the life of the sling: (a) name or trademark of manufacturer; (b) grade; (c) nominal chain size; (d) number of legs; (e) rated loads for at least one hitch type and the angle upon which it is based; (f) length (reach); and (g) individual sling identification (e.g., serial numbers). The effects of the environment are always a necessary consideration. For alloy steel slings, high or low temperatures, along with chemically active environments are clear performance reducers. Optimal temperature ranges are given, and the standard requires consultation with the sling manufacturer to understand the chemicals which can reduce the performance of the slings. Initial, frequent, and periodic inspections are required. Written records are not required for initial and frequent visual inspections. Periodic inspections should address each link component. The frequency of periodic inspections are not concretely defined; they are based on the following duty cycle factors: Crane Safety Assessment 116 Page (1) frequency of sling use; (2) severity of service conditions; (3) nature of lifts being made; and (4) experience gained on the service life of slings used in similar circumstances. There are guidelines for time intervals. The first is that the period between periodic inspections should not exceed one year. The other guidance criteria are as follows: (1) normal service ̎ yearly; (2) severe service ̎monthly to quarterly; and (3) special service ̎ as recommended by a qualified person. A written record of the most recent periodic inspection is required to be maintained and available. The standard does a good job at laying out fairly specific criteria for removal of the sling. There are 12 criteria in all, and some other ASME B30 series standards are referenced for additional guidance. Slings are to be repaired only by the sling manufacturer or other qualified persons. A marking is required for those slings that have been repaired ̌ a very good idea. In addition, there are some components that, upon inspection, are deemed inadequate for continued use, must be replaced, not repaired. These components include cracked, broken, or bent chain links. The final section, on operating practices, gives guidance on sling selection, cautions to personnel, such as clearance for body parts and where to stand during lifts, effects of environment, such as appropriate storage locations, and rigging practices. The last of these practices, rigging, is given particular treatment, with over 15 criteria explicitly laid out in order to avoid problems, such as shock loading, twisting, and kinking. The second type of slings addressed by B30.9 is wire rope. An example is shown in Figure 24 below. Figure 24: Braided Eye-and-Eye Wire Rope Sling As noted above, the approach of the standard to all sling types is similarly structured. One key difference for wire rope slings is their versatility in hitch configurations. Because of this versatility, there are several more load ratings given for wire rope per the different possible configurations. The inspection approach is also quite similar. Initial, frequent, and periodic inspections are required. The period between periodic inspections cannot exceed one year, and written record of only the most recent periodic inspection is required. Several more details are specific to the wire rope sling and its many variants. The third type of slings addressed by B30.9 is metal mesh. An example is shown in Figure 25 below. Crane Safety Assessment 117 Page Figure 25: Wire Mesh Sling The fourth type of slings addressed by B30.9 is synthetic rope. Examples are shown in Figure 26 below. Figure 26: Synthetic Rope Slings Crane Safety Assessment 118 Page The fifth type of slings addressed by B30.9 is synthetic webbing. Examples are shown in Figure 27. Figure 27: Synthetic Webbing Slings Crane Safety Assessment 119 Page The sixth type addressed by B30.9 is the synthetic round sling. Examples are shown in Figure 28. Figure 28: Synthetic Round Slings API RP 2D Section 5.2.1 incorporates ASME B30.9; therefore, the study team does not recommend incorporating B30.9 in 30 C.F.R. 250.198. 6.5.6 B30.10: Hooks The B30.10 standard puts forth provisions that apply to the fabrication, attachment, use, inspection, and maintenance of hooks used for load handling purposes, in conjunction with equipment described in other B30 series standards. There are two main sections. The first is the main section, covering selection, use, and maintenance. The second section addresses miscellaneous information. The first section applies to the types of hooks exemplified in Figure 29. These hooks support the load in the base of the hook, in the bowl, saddle, or pinhole. Crane Safety Assessment 120 Page Figure 29: Base-Supporting Hooks Hooks can be considered parts of other equipment, in addition to being equipment unto their own. Thus, the B30 series gives special attention to hooks in their own standard but also notes that the requirements given therein must be used in addition to any other hook-related requirements given in any other B30 standard. The document gives suggestions about sources for required training of hook users, who are required to be trained in the selection, inspection, cautions to personnel, effects of environment, and operating practices, as covered by the subsequent sections. Crane Safety Assessment 121 Page Specific requirements are given for materials and components, fabrication configurations, design factors, and rated loads. Proof test requirements are somewhat involved but appropriate. Temperature and chemical effects of the ambient environment are briefly described and ranges optimal operating ranges are given. The approach to hook inspection is somewhat unique, given that hooks can be integral parts to other pieces of equipment. All inspections are to be performed by a designated and qualified person. Inspection procedure and record keeping requirements for hooks in regular service are to be governed by the kind of equipment in which they are used. This point means that there are likely to be other requirements for hooks coming from standards on other equipment in which they are integrated. When this occurs, the more stringent of the two sets of requirements (the other set coming from the B30.10) should be used. The criteria given in the B30.10 include initial, frequent, and periodic inspections, all qualified by the same definitions given in previous sections of this analysis. Written records are required for periodic inspections. Several specific removal criteria are given. Finally, the operating practices are divided into subsections that address single-point hooks and multiple-point hooks separately. The second, miscellaneous section applies to all hooks that do not support a load in a direct-pull configuration, such as grab hooks, foundry hooks, sorting hooks, and choker hooks. Examples of such hooks are shown in Figure 30. All the other subsections of this second section are laid out identically to the previous section just described. Some information unique to hooks that do not support direct pull populate these subsections. None of that information directly bears on inspection, however. Figure 30: Hooks that Do Not Support Direct Pull The study team recommends the incorporation by reference of ASME B30.10 in 30 C.F.R. 250.198 and a specification for operation of hooks in accordance with B30.10 in 30 C.F.R. 250.108. 6.5.7 B30.16: Overhead Hoists The B30.16 standard puts forth provisions that apply to the construction, installation, operation, inspection, testing, and maintenance of hand chain-operated chain hoists and electric- and air-powered chain and wire rope hoists used for, but not limited to, vertical lifting and lowering of freely suspended, Crane Safety Assessment 122 Page unguided loads that consist of equipment and materials. Hoist examples are shown in Figure 31 through Figure 34 below. Figure 31: Hand-Operated Chain Hoists Figure 32: Electrical-Powered Chain Hoist Crane Safety Assessment 123 Page Figure 33: Electric-Powered Wired Rope Hoist Figure 34: Air-Powered Wire Rope Hoist Three main sections of B30.16 put forth requirements for marking, construction, and installation, inspection and testing, and operator training and operations. The marking requirements concern making clear the rated loads, the direction of travel related to certain controls, and type identification. There is also a list of product safety information that should be made available, per the standard. The construction section is straightforward, addressing mechanical, electrical, and design features, along with controls, ropes, sheaves, load sprockets, load chains, hooks, load blocks, and brakes. There is also a series of unique protections required. These include guards against over-travel and power failure. Installation requirements specify procedures, required support, locations, and power connections. The standard calls for initial inspection but also for a series of other inspections. Inspection procedures for hoists in regular service are divided into three general classifications based upon the intervals at Crane Safety Assessment 124 Page which inspection should be performed. The intervals depend, in turn, on the nature of the critical components of the hoist and the degree of their exposure to wear, deterioration, or malfunction. The three general classifications are designated as pre-operation, frequent, and periodic, with respective intervals between inspections as follows: (1) pre-operation inspection: visual inspection by a designated person with records not required, performed before the first use of each shift; (2) frequent inspection: visual examinations by a designated person with records not required; (a) normal service ̎ monthly; (b) heavy service ̎weekly; (c) severe service ̎ daily; and (3) periodic inspection: visual inspection by a designated person who makes records of external conditions to provide the basis for a continuing evaluation. An external coded mark on the hoist is an acceptable identification in lieu of records; (a) normal service ̎yearly; (b) heavy service ̎ semiannually; (c) severe service ̎quarterly. Specific requirements are nicely put forth with respect not only to the three inspection categories above, but also with respect to hand chain-operated hoists, and electric- or air-powered hoists. Inspection records for all types are to be kept on hand and available to appointed persons. The section concludes with specific criteria for operational and load tests for the hoist categories discussed above. Regarding operator training, the standard states that the hoist is a component of equipment addressed by another B30 volume, the training and operation requirements of that volume shall apply. The rest of the operator and operator training sections are very similarly laid out compared to other sections discussed previously in this analysis. It offers sources of training material and assigns responsibilities to persons involved in hoist operations, such as management and operators. It also addresses planned engineered lifts in a way nearly identical to B30.2. Likewise, B30.16 does not define, compare, or specifically address critical or routine lifts. As noted above, the study team recommends that BSEE incorporate the differences between these types of lifts and adopt an associated inspection approach to those lifts, such as the one outlined in the analysis of B30.2 above. Moreover, there should be kept on record specific forms documenting critical and engineered lift operations. The fourth and final section of the B30.16 standard puts forth maintenance training and general maintenance requirements. It notes that although there are many different types of hoists that handle many different types of materials in many different locations and capacities, the requirement for training as a hoist maintenance person should be general, consistent, and should apply to all persons who maintain the mechanical, structural, and electrical components of the equipment. Several sources of training material are provided and responsibilities are assigned to maintenance persons. These responsibilities range from very general and to quite specific. For example, the persons are encouraged Crane Safety Assessment 125 Page to become familiar with the manual and relevant standards but also instructed not to use the wire rope, load chain, or hook as a ground for welding. The section calls for the establishment of a maintenance program, which should include preventive maintenance, appropriate procedures, and policies on adjustments, repairs, and replacements. Special instructions are given for replacement and maintenance of welded link chains and roller chains. 6.5.8 B30.20: Below-the-Hook Lifting Devices This standard includes provisions that apply to the marking, construction, installation, inspection, testing, maintenance, and operation of below-the-hook lifting devices, other than components addressed by other B30 standards used for attaching loads to a hoist. A below-the-hook lifting device is defined as a device used for attaching a load to a hoist. The device may contain components such as slings, hooks, and rigging hardware. There are five main sections of the B30.20. The first concerns structural and mechanical lifting devices. The second, vacuum lifting devices. The third, close proximity operated lifting magnets. The fourth, remotely operated lifting magnets. And the fifth, scrap and material handling grapples. Some schematic examples of these are shown in Figure 35 through Figure 38. Figure 35: Pressure-Gripping Lifters Crane Safety Assessment 126 Page Two-Pad Mechanical Vacuum Liftat Id) Four-Pad Powoted Vacuum Lifter Four-Pad Powered Vacuum Lifts Manipulator Figure 36: Vacuum Lifters Crane Safety Assessment 127 Page ABS Consulting lei Cloee Proximity Operated Battery Powered Lifting Electromegnet lei Close Proximity Opereted Manually Controlled Permanent Magnet Close Proximity Operated Electrically Controlled Permanent Magnet a) he Remote Operated Lilting (el Remote Operated Lifting Electromagnet Circular Electromagnet Rectangular Figure 37: Magnetic Lifters Crane Safety Assessment 128 Page ABS Consulting Figure 38: Scrap and Material Handling Grapples The B30.20 standard clearly specifies the marking for rated loads and identification required for structural and mechanical lifting devices. The construction section specifies criteria for welding, guards for moving parts, electrical equipment, alterations, slings, hooks, and rigging hardware, though information on slings, hooks, and rigging hardware is all outsourced to the relevant B30 series standard. Crane Safety Assessment 129 Page Structural and mechanical lifting devices are to be inspected by a designated person and any deficiencies identified shall be examined and a determination made by a qualified person. The three general classifications of inspection are every-lift, which requires that the equipment be visually inspected before every lift, frequent, which requires visual inspection by the operator or other designated persons with records not required on the basis of normal, heavy, sever, and special or infrequent service, and periodic, which requires visual inspection with records of apparent external conditions to provide the basis for a continuing evaluation. The every-lift inspection should address, before and/or during the lift, any indication of damage including surface of the load, condition and operation of the controls, and condition and operation of the indicators and meters when installed. Comparably specific instructions are given for frequent and periodic inspections. Dated inspection reports shall be made on critical items and should be available for each periodic inspection and when the lifter is either altered or repaired. Operators should be trained, designated persons. They should be instructed in the use of the device by another designated person and should pertain to items such as, special operations, manufacturer suggested operating procedures, storage of the lifter to protect it from damage, and proper attachment of adapters, in addition to several more. Finally, various operational responsibilities are assigned to owners and operators. The remaining sections, which cover vacuum lifting devices, close proximity operated lifting magnets, remotely operated lifting magnets, and scrap and material handling grapples, are written in nearly identical fashion and format. The notable exception is that there is no requirement for an every-lift inspection for remotely operated lifting magnets or for scrap and material handling grapples. Other than that, details pertinent to the various characteristics of the different lifting devices vary as needed. Offshore operators often design specialty or one-off below-the-hook lifting devices. ASME BTH-1 provides minimum structural and mechanical design and electrical component selection criteria for ASME B30.20 below-the-hook lifting devices. The provisions in this standard apply to the design or modification of below-the-hook lifting devices. Compliance with requirements and criteria that may be unique to specialized industries and environments such operators on the OCS. Lifting devices designed to this standard must comply with ASME B30.20 reviewed above. ASME BTH-1 addresses only design requirements. As such, ASME BTH-1 should be used in conjunction with ASME B30.20, which addresses safety requirements. ASME BTH-1 does not replace ASME B30.20. The design criteria set forth are minimum requirements that may be increased at the discretion of the lifting device manufacturer or a qualified person. ASME BTH-1 and ASME B30.20 are to be used in conjunction with equipment described in other volumes of the ASME B30 series of safety standards. The study team recommends the incorporation by reference of both ASME B30.20 and BTH-1 in 30 C.F.R. 250.198 and a specification for design and operation of below-the-hook lifting devices in accordance with B30.20 and BTH-1 in 30 C.F.R. 250.108. Crane Safety Assessment 130 Page 6.5.9 B30.21: Lever Hoists The B30.21 standard includes provisions that apply to the construction, installation, operation, inspection, and maintenance of ratchet and pawl and friction brake type lever chain, rope, and web strap hoists used for lifting, pulling, and tensioning applications. Lever hoists are manual lever-operated devices used to lift, lower, or pull a loads and to apply or release tension. Ratchet and pawl types are load-controlling mechanisms consisting of interlocking pawls and ratchet that act to hold the load by mechanical engagement. A ratchet is a toothed member for engagement with the pawl. A pawl is a device that engages the ratchet to prevent rotation. See Figure 39 through Figure 41 for schematic examples. Friction brake types are load controlling mechanisms are automatic types of brakes used for holding and controlling loads. These unidirectional devices require forces applied to the operating levers to lower the load but do not impose additional lever pulls when lifting the loads. Figure 39: Load Controlling Ratchet and Pawl Type Mechanisms Crane Safety Assessment 131 Page Figure 40: Rope Lever Hoists Figure 41: Web Strap Lever Hoists The first section, on construction and installation, states that rated loads, controls, identification, and product safety information should be clearly marked. The mechanical design, especially in terms of stress loads and modifications are developed. Other critical issues addressed include load sprockets, drums, load chains, rope, web straps, hooks, load blocks, load controlling mechanisms, over-travel restraints, convertible load ratings, and lubrication. The second section, on inspection and testing, states that inspections shall be performed by a designated person in accordance with the manufacturer recommendations and with the requirements put forth in the B30.21. The general inspection classifications for lever hoists include initial inspection, per-operation inspection, frequent inspection, periodic inspection, and inspection for hoists not regularly in service. There is an entire detailed subsection devoted to the inspection of chain, rope, and/or web strap equipment. This information is indispensable for the proper and safe operation of the lever hoists. Operational and load tests are detailed next. Nothing too special about those specifications, other than that they concern the types of hoists and mechanisms mentioned above. The third section, on operation and operator training, closely parallels previous operations sections. One difference for the lever hoist standard is that, as the standard states, such hoists are subject to certain hazards that cannot be abated mechanical means but only by the exercise of intelligence, care, common sense, and experience in anticipating the motions that will occur as a result of operating the controls. Thus, the training of lever hoist operators is even more important. With these points in mind, very strict, clear, and required steps to prepare the hoist operation and to handle the load are given. Crane Safety Assessment 132 Page The fourth and final section, on maintenance and maintenance training, is nearly identical in format to previous sections on maintenance and maintenance training reviewed above. The information is, of course, specific to lever hoists. This information includes welded link chain replacement and maintenance, roller and rollerless chain replacement and maintenance, rope replacement and maintenance, and web strap replacement and maintenance. The study team recommends the incorporation by reference of ASME B30.21 in 30 C.F.R. 250.198 and a specification for operation of lever hoists in accordance with B30.21 in 30 C.F.R. 250.108. 6.5.10 B30.24: Container Cranes The B30.24 standard includes provisions that apply to the construction, installation, operation, inspection, testing, and maintenance of container cranes used for lifting purposes. The document includes power-operated container cranes whose power source is either self-contained or provided externally. The box girder construction can be single or double, either on utilizing a trolley and a container-handling spreader or other applicable lifting apparatus, such as a hook, beam, or magnet. A container crane is a crane with single or multiple girders that uses either a movable or fixed hoisting mechanism that lifts intermodal shipping containers with a trolley and handling spreader assembly. Figure 42: Rubber Tired Container Cranes Crane Safety Assessment 133 Page Figure 43: Rail Mounted Container Cranes The standard has three sections: One on construction and installation, one on inspection, testing, and maintenance, and one on operation. The first lays out a relatively brief number of required markings. These include rated loads, manufacturer ratings applicable to the B30 crane volume, a durable nameplate, weight, and a rated-load marked head block. Because there is usually no intended rotation of container cranes, there is a clear focus on clearances from parallel and perpendicular obstructions. There is also a specific section on pedestrian traffic. There is special concern with the construction of runways for rail-mounted container cranes, and with their runway safeguards, such as bumpers and bumper pads. These stops must be capable of resisting the stall load of the drive motor. There is heightened concern for wind with container cranes, which tend to be very tall. Wind-indicating devices are mandated, as are overturning moments that do not exceed 80% of the stabilizing or resisting moments. Other specifications are given for welding procedures, crane structural members, truck frame drop limits (for rail-mounted container cranes), machinery housing, gantry drives, spreaders, electromagnetic interference, guards for moving parts, lubrication, fire extinguishers, and other miscellaneous modifications. There are several construction requirements for the operator cab, most of which exist for safety reasons. Unfortunately, nothing is mentioned about human factors and ergonomics ̌ a problem common to other B30 series standards, as mentioned above. There is an entire section devoted to lighting systems, which distinguishes this particular standard from the others reviewed in this analysis. The primary reason for this inclusion is that container cranes almost always operate quayside. Therefore, they cannot typically benefit from the ambient lighting provided by facilities (e.g., offshore platforms and vessels) like other cranes do. This observation fits Crane Safety Assessment 134 Page with the previous mention that the most common types of cranes found offshore are pedestal-mounted and portal cranes ̌ not container cranes. Due to limited visibility that arises during typical container crane operations, there is also a strong emphasis on effective communication. This emphasis is clearly reflected in the B30.24. There are also construction requirements put forth for service platforms, with special emphasis on stairs, ladders, stairways, and emergency egress. These criteria result too from the abnormal height of typical container cranes. Also prominent in the standard are load control mechanisms, electrical safeguards, and hoisting equipment. This particular standard also uniquely gives a rather extensive set of documentation requirements related to the construction and installation. The inspection, testing, and maintenance section proceeds much like the others reviewed above. The inspection classifications are initial, frequent, periodic, and not in regular service, which entail some container crane-specific criteria of what to inspect and when, as one would expect. Operational and load tests are laid out, per custom. Preventive maintenance, repair, and wire rope replacement are adequately addressed. The final section, on operations, is again much of the same. The qualifications for operators entail vision factors, which has not typically been the case in the standards reviewed here. Other physical factors such as strength, endurance, agility, and coordination are mentioned, though specific minimums do not abound in the standard. Typical rules are given for the conduct of operators, such as not diverting attention or operating the crane in an otherwise unfit condition. Finally, other miscellaneous, but important, specifications regarding load weight, moving the load, signal communication, ladders, and other articles to be found in the operator cab are covered. Container cranes are not used on the OCS, therefore, the study team does not recommend the incorporation by reference of ASME B30.24 in 30 C.F.R. 250.198. 6.5.11 Additional B30 Standards for Consideration The following analysis of ASME B30 standards is provided because the study team believes they are essential for a complete analysis of the standards to ensure material handling safety on the OCS. B30.11 Monorails and Underhung Cranes Monorails and underhung cranes are used extensively in material handling for installation and maintenance of line replaceable units on all offshore facilities. ASME B30.11 Volume B30.11 includes provisions that apply to the construction, installation, operation, inspection, testing, and maintenance of underhung crane and monorail systems, track sections, and load-carrying members, such as end trucks or carriers (commonly called trolleys) that travel either on the external or internal lower flange of a track section. The track sections include single monorail track, crane bridge girders and jib booms, all curves, switches, transfer devices, and lift and drop sections. Provisions apply to both power-driven and handoperated equipment in which the carriers are independently controlled. Figure 44 shows a typical example of a monorail underhung crane used in offshore maintenance. Crane Safety Assessment 135 Page Figure 44: Monorail Crane with Underhung Hoist The standard includes sections on construction and installation, inspection and testing, operator training, operational procedures, and maintenance and maintenance training. Inspecting and testing has the typical five types of required inspections: initial, functional test, frequent, periodic, and inspection of equipment not in regular used. Equipment is to be inspected by a qualified person. Inspection of the hoist, limit devices, and wire rope is to be in accordance with ASME B30.16 above. Hooks and latches are to be inspected in accordance with ASME B30.10 above. Because monorails and underhung hoists are extensively used for maintenance tasks on the OCS, the study team recommends the incorporation by reference of ASME B30.11 in 30 C.F.R. 250.198 and a specification for operation of lever hoists in accordance with B30.11 in 30 C.F.R. 250.108. B30.12 Handling Loads Suspended from Rotorcraft Material handling by external load from a helicopter is frequently conducted on the OCS. ASME B30.12 applies to the protection of flight crews, ground personnel, and property on the surface while working directly with or in the vicinity of rotorcraft conducting external-load operations. The standard applies to the handling of loads suspended from rotorcraft using a cargo sling or powered hoist, or other attaching means, to lift, carry, pull, or tow a jettisonable load outside of the rotorcraft airframe. The standard classifies external helicopter loads in accordance with FAA classifications and provides guidance for lifting components, inspection and maintenance, operating practices, load handling, signals and communications, and limited guidance on fueling and ground-based facilities at the work area. Because rigging of helicopter external loads are unique, specific training in this type of rigging must be provided to all personnel engaged in such operations. Because of the significant hazards presented by helicopter external load operations, the study team recommends the incorporation by reference of ASME B30.12 in 30 C.F.R. 250.198 and a specification for operation of lever hoists in accordance with B30.12 in 30 C.F.R. 250.108. Crane Safety Assessment 136 Page B30.17 Overhead and Gantry Cranes (Top Running, Single Girder, Underhung Hoist) ASME B30.17 is essentially similar to the ASME B30.2 overhead crane standard analyzed above but applies to the construction, installation, operation, inspection, and maintenance of hand-operated and power-driven overhead and gantry cranes that have a top-running, singleg-girder bridge, with one or more underhung hoists operating on the lower flange of the bridge girder, used for vertical lifting and lowering of freely suspended, unguided loads. This differs from ASME B30.2 as that standard applies to top-running single-girder or multiple-girder bridge, with one or more top-running trolley hoists (as opposed to underhung hoists. Otherwise, the standards are nearly identical. Because there are numerous underhung as opposed to top-running trolleys on service bridge cranes in use on the OCS, the study team recommends the incorporation by reference of ASME B30.17 in 30 C.F.R. 250.198 and a specification for operation of lever hoists in accordance with B30.17 in 30 C.F.R. 250.108. B30.23 Personnel Lifting Systems ASME B30.23, Personnel Lifting Systems, establishes the design criteria, equipment characteristics, and operational procedures that are required when hoisting equipment within the scope of the ASME B30 Standard is used to lift personnel. Hoisting equipment defined by the ASME B30 Standard is intended for material handling. It is not designed, manufactured, or intended to meet the standards for personnel handling equipment, such as ANSI/SIA A92 (Aerial Platforms). The equipment and implementation requirements are not the same as that established for using equipment specifically designed and manufactured for lifting personnel. Hoisting equipment complying with the applicable ASME B30 Standard shall not be used to lift or lower personnel unless there are no less hazardous alternatives to providing access to the area where work is to be performed. The lifting or lowering of personnel using ASME B30-compliant hoisting equipment is prohibited unless all applicable requirements of this B30.23 have been met. ζΨΚ̨͍ζ ̡ζ̨̤̎̎̕ζ̇ ̲̤Κ̨̎πζ̤ Χ͟ Ψ̤Κ̎ζϭ ̡Κ̤̲ϵΨ͍̇Κ̤̇͟ ̨͍ϵ̎Ϩ Κ ̡ζ̨̤̎̎̕ζ̇ ΧΚ̨̄ζ̲ ̤̕ ϶ ϵ̇̇͟ P͍ϨϲϷ ̨̨̲͟ζ̍ϭ ϵ̨ Κ routine operation on the OCS and is extensively covered in API RP 2D and the cranes used are covered by API Specification 2C, the study team does not recommend the inclusion by reference of ASME B30.23 in 30 C.F.R. 250.198. Crane Safety Assessment 137 Page B30.26 Rigging Hardware ASME B30.26, Rigging Hardware, includes provisions that apply to the construction, installation, operation, inspection, and maintenance of detachable rigging hardware used for load-handling activities in conjunction with equipment described in other B30 standards. This hardware includes shackles, links, rings, swivels, turnbuckles, eyebolts, hoist rings, wire rope clips, wedge sockets, rigging blocks, and loadindicating devices. The standard has extensive requirements for selection, use, and maintenance of detachable hardware and load-indicating devices. Figure 45 through Figure 50 show various types of detachable rigging hardware. Figure 45: Shackles Figure 46: Turnbuckles #1 Crane Safety Assessment 138 Page Figure 47: Eyebolts Figure 48: Eyenuts Figure 49: Swivel Hoist Rings Crane Safety Assessment 139 Page Figure 50: Rigging Blocks Because detachable rigging hardware is used extensively on the OCS, the study team recommends the incorporation by reference of ASME B30.26 in 30 C.F.R. 250.198 and a specification for operation of lever hoists in accordance with B30.26 in 30 C.F.R. 250.108. 7 USCG MOU/MOA Review The USCG and BSEE (formerly known as MMS) pursue specific missions to prevent oil spills in offshore waters, limit environmental and economic resource impact in the event of a spill, and ensure safe working conditions on offshore facilities and vessels. BSEE focuses on oil and mineral exploration, drilling and production activities, and regulates offshore oil lease operators is outlined in 30 CFR Part Ϯϱ΄ϰ ̀϶ Gϳ̨ π̕Ψ̨͍ζ̨ ̎̕ ̲ϲζ ̨Κπζ̲͟ ̕π ̇ϵπζ Κ̎β ̡̡̤̕ζ̤̲͟ Κ̎β ̲ϲζ ̨Κπζ̲͟ ̕π ̎Κ͘ϵϨΚ̲ϵ̎̕ and protection of the environment on OCS units and vessels operating on the OCS. In September 2004, MMS and USCG signed a Memorandum of Understanding (MOU), along with associated Memorandum of Agreement (MOA). The MOU documented a broad agreement for cooperation between MMS and USCG and set forth a framework for MOAs to be issued under this "umbrella" MOU. MOAs address specific topics and establish a cooperative interagency partnership to increase communications, manage shared responsibility, and minimize duplicative or conflicting regulations on the affected industry. In October 2011, MMS (BOEMRE) was divided into two agencies, BSEE and BOEM. Despite the organizational changes that occurred prior to the formation of BSEE, interagency commitment to cooperative oversight of the offshore oil and gas industry between the USCG and the Department of Interior has remained unchanged. USCG and BSEE renewed their ongoing commitment for oversight of offshore oil and gas industry in the BSEE/USCG MOU signed on November 27, 2012. The MOU superseded the agreement between MMS and USCG that was signed in 2004 but the vision and mission remained of the unchanged. BSEE and USCG agreed shared responsibility in the oversight of offshore oil and gas operations. The MOU was reviewed in-depth by the technical team during the study. Crane Safety Assessment 140 Page 7.2 USCG MODU Requirements The study team reviewed and discussed the MOU along with related MOAs with the BSEE technical team. In addition, the study team consulted with USCG subject matter experts (SMEs) in order to βζ̲ζ̤̍ϵ̎ζ ΚϨζ̎Ψ͟ ̨̡ζΨϵπϵΨ ̤ζ̣͍ϵ̤ζ̍ζ̨̲̎ Κ̎β ̤ζ̨̡̨̎̕ϵΧϵ̇ϵ̲ϵζ̨ Κ̨ ̤ζ̇Κ̲ζβ ̲̕ ̲ϲζ Κ̨̨ζ̨̨̍ζ̲̎ ̕π Ψ̤Κ̎ζϳ̨ operating on the OCS. The USCG crane and material handling certification and inspection strategy is promulgated in 46 C.F.R. §107.258 and 259. According to regulation, the inspection may be conducted by a USCG marine inspector or by one of two authorized third-party inspectors. Typically, the USCG ensures compliance by auditing the results of a third-party inspection or by having BSEE perform some of the USCG mandated inspections in accordance with Z-PINC. During a working session with the USCG, CDR Jim Rocco provided an overview of USCG responsibilities as related to the regulation of cranes on the OCS. The USCG offshore crane inspection regulations are located at 46 CFR 107, 108.601, and 109. USCG regulations incorporate by reference API Spec. 2C, first edition and API RP 2D, first edition where as BSEE incorporates conflicting editions of each standard in ϯ΄ FR Ϯϱ΄ϰϭϵϴϰ ̀϶ Gϳ̨ Ψ̤Κ̎ζ Ψζ̤̲ification process in regards to third party inspections is outlined in 46 FR ϭ΄ϳϰϮϱϴϰ ̀϶ Gϳ̨ Ψ̤Κ̎ζ ϵ̨̡̎ζΨ̲ϵ̎̕ Κ̎β ̲ζ̨̲ϵ̎Ϩ ϵ̨ ͍̲̇̕ϵ̎ζβ ϵ̎ ϰϲ FR ϭ΄ϳϰϮϱϵϰ ̀϶ G ̡̇̕ϵΨ͟ ̤ζ̇Κ̲ζβ ̲̕ cranes is primarily outlined in our Marine Safety Manuals Volumes II and IV. The USCG released a Notice of Proposed Rulemaking in May 2013 for Crane Regulation Standards located on Mobile Offshore Drilling Units, Offshore Supply Vessels, and Floating OCS Facilities.10 The revision would update industry standards incorporated by reference with more recent versions, which are already adopted by BSEE. In the proposed rule, the USCG seeks to revise regulations as related to the certification, inspection, and testing of crane including the use of third part inspectors. Following the disΨ̨̨͍ϵ̎̕ ̕π ̀϶ Gϳ̨ ̤ζϨ͍̇Κ̲̤̕͟ ̤ζ̨̡̨̎̕ϵΧϵ̇ϵ̲ϵζ̨ϭ DR R̕ΨΨ̕ ϵβζ̲̎ϵπϵζβ ̤ζ̇Κ̲ζβ MO!̨ϰ ϶EE and USCG signed MOA: OCS-08 in June 2013 that outlined the shared responsibilities for regulation, inspection, and oversight of systems and subsea systems MODUs. The MOA identifies the USCG as the ̤ζ̨̡̨̎̕ϵΧ̇ζ ̤ζϨ͍̇Κ̲̤̕ π̤̕ ϶Κ̇̇ ̍Κ̲̲ζ̨̤ ̤ζ̇Κ̲ζβ ̲̕ ̲ϲζ ̡̤̲̍̕̕ϵ̎̕ ̕π ̨Κπζ̲͟ ̕π ̇ϵπζ Κ̎β ̡̡̤̕ζ̤̲͟ϭ Κ̨ ͙ζ̇̇ Κ̨ π̤̕ ͍̤̎ζϨ͍̇Κ̲ζβ ϲΚͤΚ̤β̨͍̕ ͙̤̄̕ϵ̎Ϩ Ψ̎̕βϵ̲ϵ̨̎̕ ̎̕ ̲ϲζ O ϶ϰϷ ϼϲζ ΚϨ̤ζζ̍ζ̲̎ ϵβζ̲̎ϵπϵζ̨ ϶EE Κ̨ ̲ϲζ ̤ζ̨̡̨̎̕ϵΧ̇ζ ̤ζϨ͍̇Κ̲̤̕ ϶π̤̕ well operations, including drilling, completions, workover, production and βζΨ̍̍̕ϵ̨̨ϵ̎̕ϵ̎Ϩ ͙ϲζ̎ ̲ϲζ MOD̀ ϵ̨ ̲ζ̡̤̍̕Κ̤ϵ̇͟ Κ̲̲ΚΨϲζβ ̲̕ ̲ϲζ ̨ζΚΧζβϰϷ According the USCG inspection policy, any crane deficiencies discovered on an US-flagged MODU would result in a form CG-835. It should be noted that the MODU fleet operating the Gulf of Mexico Region is comprised of 11 US-flagged jack-up MODUs while the remaining working/drilling vessels a foreign flagged. An outstanding deficiency identified on a foreign flagged MOD̀ ͙͍̇̕β ̤ζ̨͍̲̇ ϵ̎ Κ ϶F̤̍̕ Ϸ ̲̕ the Certificate of Compliance. Each of these deficiencies would be tracked in the USCG Marine 10 ϲ ̤Κ̎ζ RζϨ͍̇Κ̲ϵ̎̕ ϶̲Κ̎βΚ̤β̨ϯ M̕Χϵ̇ζ Oππ̨ϲ̤̕ζ D̤ϵ̇̇ϵ̎Ϩ ̀̎ϵ̨̲ϭ Oππ̨ϲ̤̕ζ ϶̡̡͍̇͟ ̋ζ̨̨ζ̨̇ϭ Κ̎β Ḟ̕Κ̲ϵ̎Ϩ O͍̲ζ̤ Continental Shelf Facilities; Revision (Federal Register Publication). Retrieved from Regulations.gov: http://www.regulations.gov/?p=109#!documentDetail;D=USCG-2011-0992-0001. (October 20, 2014) Crane Safety Assessment 141 Page I̎π̤̍̕Κ̲ϵ̎̕ π̤̕ ϶Κπζ̲͟ Κ̎β LΚ͙ E̎π̤̕Ψζ̍ζ̲̎ βΚ̲ΚΧΚ̨ζϰ I̎ ̨ϲ̤̲̕ϭ ϶EEϳ̨ ̤ζϨ͍̇Κ̲̤̕͟ Κ͍̲ϲ̤̕ϵ̲͟ ϵ̨ ̤ζ̇Κ̲ζβ ̲̕ operations on fixed facilities while USCG regulatory authority is related to operations on floating facilities. 8 Recommendations Based on information gathered throughout this study and the analysis, the following recommendations are provided for BSEEϳ̨ Ψ̨̎̕ϵβζ̤Κ̲ϵ̎̕. 8.1 Cranes Regulatory Changes BSEE is responsible for enforcing of regulations found in 30 CFR 250.108 (a ̌ e), as shown in Figure 51, for cranes installed on fixed OCS facilities. In addition, BSEE requires lessees and operators to comply with API Recommended Practice 2D, sixth edition and API Specification 2C, sixth edition, as found in 30 CRF 250.198. Figure 51: 30 CFR 250.108 - Crane Regulatory Language The following recommendations for changes to 30 CFR 250.108 Κ̤ζ ͍̲̇̕ϵ̎ζβ π̤̕ ϶EEϳ̨ Ψ̨̎̕ϵβζ̤Κ̲ϵ̎̕ϰ These recommendations are based on the information gathered and analyses conducted throughout the study and are intended to improve worker safety while operating cranes installed on fixed OCS facilities. Recommended changes are labeled in red text as shown in Table 25 below. Table 25: Recommended Crane Regulatory Changes §250.108 What requirements must I follow for cranes and other material-handling equipment? (a) All pedestal cranes installed on fixed platforms must be operated in accordance with American Petroleum Institute's Recommended Practice for Operation and Maintenance of Offshore Cranes, API RP 2D (as incorporated by reference in § 250.198). Crane Safety Assessment 142 Page (b) All cranes installed on fixed platforms must be equipped with a functional anti-two block device. (c) If a fixed platform is installed after March 17, 2003, all pedestal cranes on the platform must meet the requirements of American Petroleum Institute Specification for Offshore Pedestal Mounted Cranes, API Spec 2C (as incorporated by reference in §250.198). (d) All pedestal cranes manufactured after March 17, 2003, and installed on a fixed platform, must meet the requirements of API Spec 2C. (e) All overhead bridge cranes manufactured after 1 January 2016 and installed on a fixed platform must meet the requirements of CMMA Specification No. 70 ̌ Specifications for Electric Overhead Travelling Cranes (as incorporated by reference in §250.198). (f) All overhead bridge cranes installed on fixed platforms must be operated in accordance with the American Society of Mechanical Engineers (ASME) B30.2, Safety Standard for Overhead Bridge and Gantry Cranes (Top Running Bridge, Single or Multiple Girder, Top Running Trolley Hoist) or ASME B30.17 Safety Standard for Overhead Bridge and Gantry Cranes (Top Running Bridge, Single Girder, Underhung Hoist), as applicable to the type of crane, (as incorporated by reference in §250.198). Required frequent and periodic inspections (other than daily or operational inspections) of overhead bridge cranes shall be performed by a qualified crane inspector designated by the crane manufacturer or certified in accordance with the requirements of the National Commission for the Certification of Crane Operators (NCCCO). (g) All operators of overhead bridge cranes greater than 5 tons must be certified in accordance with the requirements of the National Commission for the Certification of Crane Operators (NCCCO). Rigging of loads greater than 5 tons shall be conducted by personnel certified in accordance with API RP 2D or certified in accordance with the NCCCO requirements for Rigger I for loads up to 15 tons and Rigger II for loads over 15 tons. (h) All crane owners or operators on fixed platforms must have a crane operations safety policy that differentiates between routine, critical and engineered lifts. Routine lifts are those not designated as critical or engineered lifts. Critical lifts are those where the failure or loss of load control could result in loss of life, major structural damage to facilities or equipment, or large environmental release. Some factors, but not all factors, that may be used to determine a critical lift are:  When a load is lifted over or near operating equipment or safety areas designated by a dropped object study;  When two or more pieces of lifting equipment are required to work in unison, including trolleys installed on the same bridge;  When special lifting equipment such as non-standard crane configurations or purpose built, one-off lifting appurtenances will be used;  The weight of the load exceeds set limits such as 20 tons;  ϼϲζ ͙ζϵϨϲ̲ ̕π ̲ϲζ ̇̕Κβ ζ͞Ψζζβ̨ ϳϱ ̡ζ̤Ψζ̲̎ ̕π ̲ϲζ Ψ̤Κ̎ζϳ̨ ̤Κ̲ζβ ΨΚ̡ΚΨϵ̲͟Ϯ ̤̕  When making personnel transfers. Engineered lifts are those that exceed the rated capacity of the crane at the required lifting angle (not to include load testing requirements in API Spec 2C). Engineered lifts are so exceptional that there shall be increased inspection requirements to be met prior to Crane Safety Assessment 143 Page operation. For engineered lifts, the crane shall be inspected by the crane manufacturer or a qualified third-party inspector in accordance with API Spec 2D annual inspection requirements not more than two days prior to the lift. Any deterioration or defects found by that shall be considered in design calculations to support the lift. The crane shall also be inspected by the crane manufacturer or a qualified third-party in accordance with annual inspection requirements, including and non-destructive testing required by the manufacturer, after the engineered lift is completed and prior to release for use in normal operations. A record of the engineered lift, including supporting calculations, inspections, weights, and all distances moved, shall maintained in accordance with (i) (2) below. (i) You must maintain records specific to a crane or the operation of a crane installed on an OCS fixed platform, as follows: (1) Retain all design and construction records, including installation records for any anti-two block safety devices, for the life of the crane. The records must be kept at the OCS fixed platform. (2) Retain all inspection, testing, and maintenance records of cranes for at least 4 years. The records must be kept at the OCS fixed platform. (3) Retain the qualification records of the crane operator and all rigger personnel for at least 4 years. The records must be kept at the OCS fixed platform. 8.2 Material Handling Equipment Improvement BSEE is responsible for enforcing the regulations found in 30 CFR 250.108 (f), as shown in Figure 52, which applies to material handling equipment installed on fixed OCS facilities. Figure 52: 30 CFR 250.108(f) – Material Handling Equipment Regulatory Language BSEE does not incorporate any industry standards by reference in regulation of material handling equipment. Guidance provided to BSEE inspectors for the enforcement of material handling equipment regulation is outline in PINC I190 below. The PINC identifies material handling equipment as including, but not limited to, air hoists, hoists, tugger, air tugger, winch, man-riding winch, come-a-long, monorail, gantry crane, jib (sic). The subjective nature and overall breath of this PINC instruction to meet the inspection requirements of 30 C.F.R. 250.108 (f) can hardly be overstated. As discussed in the analysis of material handling equipment, this equipment is not defined in 30 C.F.R. 250.105. The I-190 compliance guidance requires inspectors to determine if all material handling equipment is operated and maintained in a manner that ensures safe operation and prevents pollution. The current inspection procedure also requires an ϵ̨̡̎ζΨ̲ϵ̎̕ ̕π ̤ζΨ̤̕β̨ ̲̕ ζ̨͍̤̎ζ ̍Κ̲ζ̤ϵΚ̇ ϲΚ̎β̇ϵ̎Ϩ ζ̣͍ϵ̡̍ζ̲̎ ϵ̨ ̡̕ζ̤Κ̲ζβ ϶̡ζ̤ ̍Κ͍̎πΚΨ̲͍̤ζ̨̤ Κ̎β̤̄̕ ̡̕ζ̤Κ̨̲̤̕ ̨̡ζΨϵπϵΨΚ̲ϵ̨̎̕ϰϷ ϼϲζ ϵ̨̡̎ζΨ̲̤̕ ̨͍̲̍ Κ̨̇̕ ϵ̨̨͍ζ Κ Ψ̡̍̎̕̕ζ̲̎ ̨ϲ͍̲-in (C) incident of noncompliance citation when these conditions are not met as discussed above. Crane Safety Assessment 144 Page Since the statute does not define material handling equipment, any equipment which moves or manipulates components or material would rightly be subject to 30 C.F.R. 250.108 (f); this includes classified drilling equipment (CDS) and auxiliary material handling equipment such as BOP handling equipment, riser carts, drill floor and derrick lifting equipment, top drive systems, etc. The I-190 PINC guidance to BSEE inspectors subjects the regulated entity to variations in the training, experience, and capriciousness of the inspector, making compliance and inspection difficult. Moreover, the large variation in the motive power and functionality of the equipment makes it highly unlikely that any one inspector would be a subject matter expert (SME) or competent inspector of all of the systems covered by the regulation. Figure 53: PINC I190 The following recommendations for changes to 30 CFR 250.108(f) are ͍̲̇̕ϵ̎ζβ π̤̕ ϶EEϳ̨ Ψ̨̎̕ϵβζ̤Κ̲ϵ̎̕ϰ As noted above, BSEE does not incorporate any industry-standards in Regulation of material handling equipment. BSEE has worked extensively in the past with the American Society form Mechanical Engineers (ASME) Standards Development Organization (SDO) in reviewed several ASME B.30 series standards on material handling equipment. These recommendations are based on the information gathered and analyses conducted throughout the study and are intended to improve worker safety while operating material handling equipment installed on fixed OCS facilities. Recommended changes are labeled in red text as shown in Table 26 below. Table 26: Recommended Material Handling Equipment Regulatory Changes §250.108 What requirements must I follow for cranes and other material-handling equipment? (j) You must operate and maintain all other material-handling equipment in a manner that ensures safe operations and prevents pollution. (1) All winches, including, but not limited to, wireline winches, pneumatic and hydraulic line tuggers, electric, pneumatic and hydraulic planetary gear hoists and winches, electromechanical and umbilical winches, man-riding winches, or any other power-driven drum devices shall be designed, operated and maintained in accordance with ASME B30.7, Winches (as incorporated by reference in §250.198). (2) All slings shall be operated and maintained in accordance with ASME B30.9, Slings, which Crane Safety Assessment 145 Page is incorporated by reference in API RP 2D Section 5.2.1 (as incorporated by reference in §250.198). (3) All hooks shall be operated and maintained in accordance with ASME B30.10, Hooks (as incorporated by reference in §250.198). (4) All monorails and underhung cranes shall be operated and maintained in accordance with ASME B30.11, Monorails and Underhung Cranes (as incorporated by reference in §250.198). (5) All overhead hoists shall be operated and maintained in accordance with ASME B30.16, Overhead Hoists (as incorporated by reference in §250.198). (6) All below-the-hook lifting devices, including, but not limited to, structural, mechanical, vacuum, close-proximity lifting magnets, plate clamps, or any other device or appurtenance used for attaching a load to a hoist, shall be operated and maintained in accordance with ASME B30.20, Below-the-Hook Lifting Devices (as incorporated by reference in §250.198). Moreover, all below̌the-hook lifting devices, including, but not limited to, spreader bars and frames, pad eyes, attachment points, and all other lifting appurtenances shall be designed in accordance with ASME BHT-1, Below-the-Hook Lifting Devices (as incorporated by reference in §250.198). (7) All ratchet and pawl and friction brake type lever chain, rope, and web strap hoists (comea-long) used for lifting, pulling, and tensioning applications shall be operated and maintained in accordance with ASME B30.21, Lever Hoists (as incorporated by reference in §250.198). (8) All detachable rigging hardware used for load-handling activities, including but not limited to, shackles, links, rings, swivels, turnbuckles, eyebolts, hoist rings, wire rope clips, wedge sockets, rigging blocks, and load-indicating devices, shall be operated and maintained in accordance with ASME B30.26, Rigging Hardware (as incorporated by reference in §250.198). (9) All loads suspended from rotorcraft-helicopters shall be conducted in accordance with Federal Air Regulation 14 C.F.R. Part 133 and ASME B30.12, Handling Loads Suspended from Rotorcraft (as incorporated by reference in §250.198). Personnel rigging external loads must have specialized training in helicopter external load operations. (10) Rigging of loads greater than 5 tons shall be conducted by personnel certified in accordance with API RP 2D or certified in accordance with the NCCCO requirements for Rigger I for loads up to 15 tons and Rigger II for loads over 15 tons. (11) All specialty material handling equipment, including, but not limited to, bails, BOP/LMRP service cranes and transporters, crown and traveling blocks, deadline anchors, drilling derricks or masts, draw works, drill floor manipulator arms, drilling elevators, riser handling systems and carts, iron roughnecks, kelly drives, top drives, riser spiders, rotary tables, and drill ̨͙ϵ͘ζ̨̇ϭ ̨ϲΚ̇̇ Χζ ̡̕ζ̤Κ̲ζβ Κ̎β ̍Κϵ̲̎Κϵ̎ζβ ϵ̎ ΚΨΨ̤̕βΚ̎Ψζ ͙ϵ̲ϲ ̲ϲζ ̍Κ͍̎πΚΨ̲͍̤ζ̤ϳ̨ recommendation and instructions. Such recommendations and instructions shall be supported by a Failure Modes, Effects and Criticality Analysis (FMECA) in accordance with generally accepted engineering practices to verify the required inspection and maintenance schedules for the service intended. Design and installation of specialty material handling equipment should consider ASTM F1166, Human Engineering Design for Marine Systems, Equipment and Facilities. All specialty material handling equipment shall also be subjected to a task analysis and job safety analysis by a qualified human factors or safety professional to ensure safe operation. Moreover, all Crane Safety Assessment 146 Page specialty material handling equipment shall be installed, operated, and maintained to ensure that inadvertent leaks or spills of operating fluids do not result in an environmental release. (k) All owners or operators on fixed platforms shall have a safety policy and procedures that cover all material handling equipment. (l) All required maintenance on material handling equipment shall be performed by a qualified maintenance or service personnel. All required inspections shall be performed by a qualified inspector or third-party inspection service. A qualified person is one who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training and experience, has successfully demonstrated their ability to inspect, diagnose and troubleshoot faults, and service or repair the specific equipment. (m) You must maintain records specific to the material handling equipment installed on an OCS fixed platform, as follows: (1) Retain all design and construction records, including installation records for any specialty material handling equipment for the life of the equipment. The records must be kept at the OCS fixed platform. (2) Retain any required operator or daily inspection records for a period of not less than 90 days. The records must be kept at the OCS fixed platforms. (3) Retain all frequent and periodic inspection and testing records for all material handling equipment for at least 4 years. The records must be kept at the OCS fixed platform. (4) Retain the qualification records of all material handling maintenance, inspection, and all rigger personnel for at least 4 years. The records must be kept at the OCS fixed platform. 8.3 Lifting Inspection Strategy The following actions and recommendations are suggested to produce a robust crane and material handling inspection program for offshore facilities which is harmonized with 30 C.F.R §250.108 and 30 C.F.R. §250.1913, et seq. and with the intentions of 46 C.F.R. §107.258 and 259: 1. Create database of offshore facilities having cranes subject to API Spec 2C and API RP 2D and overhead, jib, and gantry cranes with capacities greater than 5 short tons subject to ASME B30.2; 2. Amend regulation 30 C.F.R. §250.108 for pedestal, overhead bridge, and gantry cranes inspection as suggested in Section 8.1. 3. Amend regulation 30 C.F.R. §250.108 for material handling as suggested in Section 8.2. 4. Amend regulation 30 C.F.R. §250.198 to incorporate applicable ASME B30 series standards as identified in Section 8.2 and Section 6.5. 5. Amend PINCs as suggested in Section 5.1.1 to harmonize with the requirements of 30 C.F.R. §250.1900, et seq. 6. Train BSEE inspectors to become qualified crane and rigging inspectors as promulgated by API RP 2D and ASME B30 series standards, or audit crane inspection records performed by thirdparty qualified inspectors similar to the strategy adopted by the USCG in 46 C.F.R. §107.259; Crane Safety Assessment 147 Page 7. Require drilling systems used on MODUs to be certified drilling systems (CDS) and inspected by the marine classification society that issued the CDS certificate. 8. Develop a formal training qualification program for BSEE inspectors in mechanical and electrohydraulic equipment fundamentals, hazard identification for machine safety, and other OSHAtype hazard identifications and mitigation procedures, as well as general inspection and maintenance auditing procedures as suggested in Section 4.1. 9. Inspect or audit third-party inspections to ensure that the cranes and material handling equipment are designed, maintained, and operated in accordance with the standards promulgated by marine classification societies, API, or ASME and regulations promulgated by 30 C.F.R. 250.108 and 30 C.F.R. 250.1913 (d); 10. A human factors analysis in accordance with ASTM F1166 should be required for humanmachine interfaces for all CDS material handling equipment. 11. BSEE should require operators to have formal or structured OJT program to produce qualified operators and riggers for material handling equipment; 12. BSEE should require that material handling equipment inspection and maintenance schedules be developed based on a FMECA ̡̤̕β͍Ψζβ Χ͟ ̣͍Κ̇ϵπϵζβ ̡ζ̨̤̎̎̕ζ̇ ̤̕ π̤̍̕ ̲ϲζ ̍Κ͍̎πΚΨ̲͍̤ζ̤ϳ̨ instructions which are based on a FMECA; and 13. BSEE should verify the qualifications of operational and inspection personnel for all cranes and material handling equipment. 8.3.1 Staff Augmentation Based on the information gathered throughout the study, analysis conducted, and technical recommendations identified BSEE should consider the following staff augmentation recommendations:  Augment BSEE inspector force, as necessary, to ensure timely evaluation of documents submitted to comply with SEMS II.  Augment BSEE inspector force, as necessary, to ensure adequate inspector coverage for future OCS initial and periodic facility inspections. (Section 6.1 offers two examples of third-party inspection options which are currently being used effectively by other Executive Branch agencies). 8.3.2 Develop a Communication Strategy BSEE should develop key messages for internal stakeholders. The messages for internal audiences should be developed and tailored to the unique needs of BSEE employees. Senior Leadership should be provided with specific messages on their involvement with implementing key initiatives, Regional and District personnel need information on program administration and priorities in order to implement consistent approaches. For example, All ζ̡̍̇̕͟ζζ̨ ̎ζζβ ϵ̎π̤̍̕Κ̲ϵ̎̕ ̎̕ ͙ϲΚ̲ϳ̨ ζ̡͞ζΨ̲ζβ ̕π ̲ϲζ̍ϭ ϲ͙̕ ̲ϲζ͟ Κ̤ζ ̡ζ̨̤̎̕Κ̇̇͟ ϵ̎̇͘̕͘ζβ ϵ̎ achieving ϶EEϳ̨ Ϩ̕Κ̨̇ Κ̎β ϲ͙̕ they can work together as a team. Crane Safety Assessment 148 Page BSEE should develop key messages for external stakeholders and audiences. The message for external audience should also be developed and tailored to the unique needs of operators. BSEE should also develop a communication strategy that ensures each lease holder/permit applicants receives the same comprehensive information on the historical, philosophical and statutory foundations of the Safety and Environmental Management Systems Program (SEMS II), 30 C.F.R. §250.1900, et seq. that is provided to BSEE management and inspectors This includes developing tailored messages to different stakeholders that clearly communicates the goals, mission, and vision for the program. For example, BSEE should develop a communications plan that provides OCS lease permit applicants with the guidelines and rubrics which will be used to evaluate documents submitted to comply with SEMS II. 8.3.3 Metric Reporting and Data Collection BSEE should develop and capture metrics which are leading indicators of lease holders and industry compliance culture. Leading indicators provide a means to change course before a negative result. BSEE focus should be place on capturing leading indicators instead of lagging indicators because they are not predictive of future system performance. Lagging indicators are those that document past events (i.e., lost time incidents, annual injuries by category). These leading indicators metrics should include:        Number of supervisory and management personnel with formal human factors and error prevention training. Number of supervisory and management personnel with formal incident/accident investigation and root cause analysis training. Number of dedicated safety professionals per facility. (A dedicated safety professional is one with formal, comprehensive safety training or credentials and who has no collateral duties on the facility). N͍̍Χζ̤ ̕π ϶̎ζΚ̤-̍ϵ̨̨Ϸ ϵ̎Ψϵβζ̨̲̎ ̤ζ̡̤̲̕ζβϰ Elapsed time from incident/accident occurrence to report submission to recommendation implementation. Elapsed time from report submission to recommendation implementation. Number of near-miss and incident/accident reports with zero recommendations. BSEE should require lease holders to immediately report significant financial issues or changes in ownership, mergers and acquisition. This information should be tracked central location that is accessible to BSEE wide. The information is a leading indicator of a potential distressed financial state and should alert BSEE to degradation in maintenance, training, workforce, operating philosophy and Crane Safety Assessment 149 Page corporate culture. The foundations upon which SEMS II program documents were approved may be compromised.11 BSEE should employ metrics such as leading indicators to revise BSEE crane and material handling oversight emphasis items and assist individual operators with improving and amending SEMS compliance documents. 8.4 Program Related Recommendations ϼϲζ π͙̇̇̕̕ϵ̎Ϩ ̡̤̕Ϩ̤Κ̍ ̤ζ̇Κ̲ζβ ̤ζΨ̍̍̕ζ̎βΚ̲ϵ̨̎̕ Κ̤ζ ̕Χ̨ζ̤͘Κ̲ϵ̨̎̕ Κ̤ζ ̡̤̕͘ϵβζβ π̤̕ ϶EEϳ̨ consideration. 8.4.1 Harmonize Various PINC Initiatives BSEE has various initiatives underway to provide recommendations for changes to PINCs, including The National PINC Team and BSEE funded technical projects (i.e., Crane Safety and Assessment of API Standards). BSEE should align all stakeholders involved in these initiatives and establish a systematic process to review the changes that are being proposed. Alignment across all stakeholder groups would enable success in the development of PINCs by identifying safety concerns amongst industry, inspections needs on the OCS, and timely understanding of support information. 8.4.2 Staff Retention Staff retention directly impacts BSEE operations throughout the organization. BSEE invests time and money to onboard new employees with no guarantee of commitment. The training and experience that BSEE provides makes employees extremely marketable to the oil and gas industry. Ultimately, many employees leave after gaining experience within the agency. In addition, BSEE cannot compete with ϵ̎β̨͍̲̤͟ϳ̨ Ψ̡̍̕ζ̨̎Κ̲ϵ̎̕ ̡ΚΨ̄Κges. For this reason, BSEE is not only losing staff to industry, but finding it increasingly difficult to recruit inspectors with relevant industry experience. This lack of personnel leaves existing staff over utilized. An industry recruitment program to acquire recently retired industry personnel would benefit the agency. 8.4.3 Standards Development Organization Outreach BSEE incorporates 117 industry-developed standards by reference in Title 30 CFR 250. Incorporation by Reference (IBR) allows Federal agencies to comply with the requirement to publish rules in the Federal Register and CFR by referring to material published elsewhere. BSEE references standards IBR daily while conducting inspections. Standards Development Organizations (SDOs) directly influence the 11 U.S. Department of the Interior, Bureau of Safety and Environmental Enforcement. Investigation of November 16, 2012, Explosion, Fire and Fatalities at West Delta Block 32 Platform E. Washington, D.C.: U.S. Department of the Interior, 2013.) Crane Safety Assessment 150 Page development of standards incorporated by reference in BSEE regulation. The foundation ̕π ϶EEϳ̨ current inspection methodology is the application of PINCs which reference to standards incorporated by reference in regulation. Therefore, it is necessary that BSEE has active participation in SDOs to provide an understanding the changes and modifications to the standard that may impact a future regulatory need. It is noted that BSEE is actively involved with many SDOs through committee meetings, conferences, ongoing communication with SDO personnel, and established relationships with committee members. However, BSEE requires additional support staff in order to communicate the events of the standard committee to the appropriate channels at the Headquarters and Regional level. BSEE should identify additional support staff to develop a standards database. The database would be Κ̎ Κ̨̨ζ̲ ̲̕ ϶EEϳ̨ OORP and the National PINC Team (NPT) in the development and update of standards incorporated by reference in BSEE regulation and the development of inspection PINCs. The database would track the following information on standards incorporated by reference in BSEE regulation and standards not incorporated by reference but indicated a priority to BSEE. The NPT could reference this database during their annual review of inspections PINCs to identify pending changes to standards that ̨ϲ͍̇̕β Χζ ̤ζΨ̍̍̕ζ̎βζβ π̤̕ ϶EEϳ̨ Ψ̨̎̕ϵβζ̤Κ̲ϵ̎̕ϰ Crane Safety Assessment 151 Page THIS PAGE INTENTIONALLY LEFT BLANK Crane Safety Assessment 152 Page ABS Consulting Appendix A. Revised PINCs ϼϲζ ̨̲͍β͟ ̲ζΚ̍ ̡̤̕͘ϵβζβ ̤ζΨ̍̍̕ζ̎βΚ̲ϵ̨̎̕ π̤̕ ϶EEϳ̨ Ψ̨̎̕ϵβζ̤Κ̲ϵ̎̕ π̤̕ ̡͍βΚ̲ϵ̎Ϩ ̲ϲζ ζ͞ϵ̨̲ϵ̎Ϩ ̇ϵπ̲ϵ̎Ϩ PINCs. The recommendations were circulated amongst internal BSEE stakeholders for feedback. The project team updated the PINCs based on the final direction recommended by the BSEE project sponsors. Changes and modifications to existing lifting PINCs are highlighted and displayed in track changes below. Crane Safety Assessment A Page _u>mm BSEE Crane Safety – PINCs (FINAL) E14PB00023 CRANE LIFTING OPERATIONS GUIDELINES LAST UPDATE, 2011APRIL 2015 Note: The following PINC’s only pertain to personnel or loads lifted with cranes, temporary cranes, or other type of lifting equipment mounted on fixed OCS platforms. The personnel or loads lifted may be on fixed OCS platforms, MODUs, or vessels. OPERATING PROCEDURES I – 101 WHENEVER THERE IS ANY DOUBT AS TO SAFETY, DOES THE CRANE OPERATOR STOP AND REFUSE TO HANDLE LOADS OR CONTINUE OPERATIONS AS SAFETY DICTATES IN ACCORDANCE WITH API RP 2D, PARAGRAPH 3.1.5a? Regulatory Authority: Enforcement Action: WW/C 30 CFR 250.108(a) API Reference: API RP 2D Paragraph 3.1.5(a) NOTE: PINC (Potential incident of Noncompliance List) can only be used if crane operations continued under adverse conditions and caused an accident or near miss which resulted in injury, death, pollution, or property damage. INSPECTION PROCEDURE: Verify that crane operations were restricted during periods of bad weather, such as lightning, high winds or high seas, or when the Crane Operator’s ability to see the signal person is impaired by darkness, fog, rain, etc. IF NONCOMPLIANCE EXISTS: Issue a warning (W) INC if inspection reveals that crane was operated under adverse conditions and caused an accident which resulted in injury, death, pollution, or property damage. Issue a component shut in (C) if inspection reveals that the crane operator does not stop and refuses to handle loads where there is a doubt as to safety (being witnessed). INSPECTION COUNT/ INC COUNT: Enter one item checked/ issue one INC for each crane inspected BSEE Crane Safety – PINCs (FINAL) E14PB00023 (Operating Procedures Continued) I – 102 ARE PROPER CRANE OPERATING PRACTICES FOR ATTACHING AND MOVING THE LOAD BEING UTILIZED IN ACCORDANCE WITH API RP 2D, PARAGRAPHS 3.2.1, 3.2.2 AND 3.2.3 AND API RP SPEC 2C, PARAGRAPH 7.5.4.3. ? Regulatory Authority: Enforcement Action: C 30 CFR 250.108(a) API Reference: API RP 2D 3.2.1, 3.2.2, 3.2.3, and API RP 2C 7.5.4.3 INSPECTION PROCEDURE: 1. Verify that the load is attached to the hook by means of slings or other suitable devices. Sling use shall be in accordance with the guidelines of API RP 2D, Appendix B, paragraph B.3.2.2.c, and Appendix G, paragraph G.5.2.1. 2. Verify that Hooks are equipped with a latch to retain loose lifting gear under non lifting conditions and that the latch is lockable if the hook is used for transporting personnel. 3. Procedures for moving the load are in accordance with the guidelines of API RP 2D, Appendix B, paragraph B.3.2.3. IF NONCOMPLIANCE EXISTS: Issue a component shut-in (C) INC if procedures for attaching and/or moving the load are not within specified guidelines. INSPECTION COUNT/ INC COUNT: Enter one item checked/ issue one INC for each crane inspected. BSEE Crane Safety – PINCs (FINAL) E14PB00023 (Operating Procedures Continued) I – 103 ARE PROCEDURES FOR PERSONNEL TRANSFER PERFORMED IN ACCORDANCE WITH RECOMMENDED PRACTICES SPECIFIED IN API RP 2D, PARAGRAPH 3.4 AND APPENDIX B, PARAGRAPH B.3.4? Regulatory Authority: Enforcement Action: C 30 CFR 250.108(a) API Reference: API RP 2D 3.4 and Appendix B 3.4 INSPECTION PROCEDURE: If at the time of inspection, personnel are being transferred via personnel carrier from vessel to vessel, vessel to platform, or from platform to vessel, verify that: 1. Personnel carrier is of an approved type (Appendix B3.4) and is maintained in a safe condition. 2. All hooks used for support of personnel carrier are equipped with a safety latch. 3. Personnel are riding the carrier in a safe manner and are wearing an approved PFD. 4. Personnel are not raised or lowered directly over a vessel. IF NONCOMPLIANCE EXISTS: Issue a component shut-in (C) INC for a violation of 1 through 4 above. INSPECTION COUNT/ INC COUNT: Enter one item checked/ issue one INC for each crane inspected. I – 104 ARE CRANES WHICH ARE POSITIONED IN THE PROXIMITY OF HELIDECKS OR APPROACH/TAKE-OFF ZONES NOT OPERATED DURING HELICOPTER OPERATIONS IN ACCORDANCE WITH API RP 2D, PARAGRAPH 3.1.5M? Regulatory Authority: Enforcement Action: WC 30 CFR 250.108(a) API Reference: API RP 2D 3.1.5(m) INSPECTION PROCEDURE: If the crane and helicopter operations are in progress at the time of the inspection, verify that the crane boom is positioned and secured as required and the Crane Operator is out of the cab unless he is in direct voice communications with the pilot. IF NONCOMPLIANCE EXISTS: Issue a warning (W) component shut-in (C) INC if the crane boom is not positioned and secured as required or if the Crane Operator remains in the cab without direct voice communications with the pilot during landings/take-offs. INSPECTION COUNT/ INC COUNT: Enter one item checked/ issue one INC for each crane inspected. BSEE Crane Safety – PINCs (FINAL) E14PB00023 (Operating Procedures Continued) I – 105 IF DEFICIENCIES THAT IMPAIR SAFE OPERATION ARE KNOWN, IS THE CRANE TAKEN OUT OF SERVICE OR ITS OPERATION RESTRICTED TO ELIMINATE THE UNSAFE CONDITION IN ACCORDANCE WITH API RP 2D, PARAGRAPH 3.1.5c? Regulatory Authority: Enforcement Action: C 30 CFR 250.108(a) API Reference: API RP 2D, 3.1.5(c) NOTE: Limited (restricted) service may, in some cases, be continued after the identification and before correction of a deficiency. In such cases, the deficiency must be documented and cautionary notices posted in accordance with API RP 2D, paragraph 1, item c. INSPECTION PROCEDURE: 1. Check facility crane inspection records to determine if any deficiencies have been identified. 2. If deficiencies have been identified, verify that cautionary notices have been posted. IF NONCOMPLIANCE EXISTS: Issue a component shut-in (C) INC if deficiencies have been identified and cautionary notices have not been posted. INSPECTION COUNT/ INC COUNT: Enter one item checked/ issue one INC for each crane inspected. BSEE Crane Safety – PINCs (FINAL) E14PB00023 CRANE SAFETY DEVICES I – 111 IS AN OPERABLE SWING BRAKE MECHANISM INSTALLED THAT IS CAPABLE OF SMOOTH STARTS AND STOPS WITH CONTROLLABLE RATES OF ACCELERATION AND DECELERATION AS SPECIFIED IN API SPEC 2C PARAGRAPH 9.1 ON EACH CRANE MANUFACTURED AFTER MARCH 17, 2003, AND ON EACH CRANE ON A FIXED PLATFORM INSTALLED AFTER MARCH 17, 2003? Regulatory Authority: Enforcement Action: W/C 30 CFR 250.108(c) API Reference: API SPEC 2C 9.1 INSPECTION PROCEDURE: Verify that the swing brake mechanisms listed below operate according to the requirements in API SPEC 2C Paragraphs 9.1.3, 9.1.3, and 9.1.4: 1. Parking Brake. 2. Automatic Parking Brake. 3. Dynamic Friction Brake IF NONCOMPLIANCE EXISTS: Issue a warning (W) INC for each crane audit that does not confirm that the operator has records of inspecting each crane swing brake mechanism that does not comply with the requirement in API SPEC 2C, Paragraph 9.1. Issue a component shut-in (C) INC for each crane swing brake mechanism inspected that does not comply with the requirements in API SPEC 2C, Paragraph 9.1. INSPECTION COUNT/ INC COUNT: Enter one item checked/ issue one INC for each crane inspected. BSEE Crane Safety – PINCs (FINAL) E14PB00023 (Crane Safety Devices Continued) I – 112 IS AN OPERABLE BOOM HOIST HIGH LIMITER OR SHUTOFF PROVIDED TO AUTOMATICALLY STOP THE BOOM HOIST WHEN THE BOOM REACHES A PREDETERMINED HIGH ANGLE, AS SPECIFIED IN API SPEC 2C, PARAGRAPH 13.1.1, ON EACH CRANE MANUFACTURED AFTER MARCH 17, 2003, AND ON EACH CRANE ON A FIXED PLATFORM INSTALLED AFTER MARCH 17, 2003? Regulatory Authority: Enforcement Action: W/C 30 CFR 250.108(c) API Reference: API SPEC 2C 13.1.1 NOTE: Low angle limiter or shut off shall not be inspected by BOEMRE BSEE. INSPECTION PROCEDURE: Verify that the crane boom hoist high limiter or shutoff will automatically stop the boom hoist when the boom reaches a pre-determined high angle. IF NONCOMPLIANCE EXISTS: Issue a warning (W) INC for the most current each crane audit that does not confirm that the operator has records of inspecting the boom hoist limiter or shutoff as specified in API RP 2D, Paragraph 4.2.2. (monthly, quarterly, and annual inspection) Issue a component shut-in (C) INC for each crane inspected that does not comply with the requirements in API SPEC 2C, Paragraph 13.1.1. INSPECTION COUNT/ INC COUNT: Enter one item checked/ issue one INC for each crane inspected. BSEE Crane Safety – PINCs (FINAL) E14PB00023 (Crane Safety Devices Continued) I – 113 ARE BOOM STOPS PROVIDED TO RESIST THE BOOM FALLING BACKWARDS IN A HIGH WIND OR SUDDEN RELEASE OF THE LOAD, AS SPECIFICED IN API SPEC 2C, PARAGRAPH 13.1.2, ON EACH CRANE MANUFACTURED AFTER MARCH 17, 2003, AND ON EACH CRANE ON A FIXED PLATFORM INSTALLED AFTER MARCH 17, 2003? Regulatory Authority: Enforcement Action: C 30 CFR 250.108(c) API Reference: API SPEC 2C 13.1.2 INSPECTION PROCEDURE: Verify that the crane boom stops provided are designed to resist the boom falling backwards. Note: Designs for boom stops include one of the following: 1. A fixed or telescoping bumper 2. A shock absorbing bumper 3. Hydraulic boom elevation cylinder(s). IF NONCOMPLIANCE EXISTS: Issue a component shut-in (C) INC for each crane inspected that does not comply with the requirements in API SPEC 2C, Paragraph 13.1.2. INSPECTION COUNT/ INC COUNT: Enter one item checked/ issue one INC for each crane inspected. BSEE Crane Safety – PINCs (FINAL) E14PB00023 (Crane Safety Devices Continued) I – 114 IS A BOOM ANGLE OR LOAD RADIUS INDICATOR READABLE FROM THE OPERATOR’S STATION PROVIDED, AS SPECIFIED IN API SPEC 2C, PARAGRAPH 13.1.4.1, ON EACH CRANE MANUFACTURED AFTER MARCH 17, 2003, AND ON EACH CRANE ON A FIXED PLATFORM INSTALLED AFTER MARCH 17, 2003? Regulatory Authority: Enforcement Action: W/C 30 CFR 250.108(c) API Reference: API SPEC 2C 13.1.4.1 INSPECTION PROCEDURE: Verify that the crane boom angle or load radius indicator is provided and readable from the operator’s stations. IF NONCOMPLIANCE EXISTS: Issue a warning (W) INC for each crane audit that does not confirm that the operator has records of inspecting the boom angle/radius indicators over full range for accuracy as specified in API RP 2D, Paragraph 4.2.2 & Appendix C 4.1.2(c)(d). Issue a component shut in (C) INC for each crane inspected that does not comply with the requirements in API SPEC 2C, Paragraph 13.1.4.1. INSPECTION COUNT/ INC COUNT: Enter one item checked/ issue one INC for each crane inspected. I – 115 HAVE SECURELY FASTENED GUARDS BEEN INSTALLED ON EXPOSED MOVING PARTS WHICH MAY CONSTITUTE A HAZARD, AS SPECIFIFED IN API SPEC 2C, PARAGRAPH 13.2, ON EACH CRANE MANUFACTURED AFTER MARCH 17, 2003, AND ON EACH CRANE ON A FIXED PLATFORM INSTALLED AFTER MARCH 17, 2003? Regulatory Authority: Enforcement Action: C 30 CFR 250.108(c) API Reference: API SPEC 2C 13.2 INSPECTION PROCEDURE: 1. Verify that exposed moving parts such as gears, set screw, projecting keys, chains chain sprockets, and reciprocating or rotating parts which may constitute a hazard under normal operating conditions are guarded. 2. Verify that an appropriate sign is posted if a guard is impractical to install on the above crane components. IF NONCOMPLIANCE EXISTS: Issue a component shut in (C) INC for each crane inspected that does not comply with the requirements in API SPEC 2C, Paragraph 13.2. INSPECTION COUNT/ INC COUNT: Enter one item checked/ issue one INC for each crane inspected. BSEE Crane Safety – PINCs (FINAL) E14PB00023 (Crane Safety Devices Continued) I – 116 HAS AN ANTI-TWO BLOCK DEVICE BEEN PROVIDED TO PROTECT HOIST ROPES, STRUCTURAL COMPONENTS AND MACHINERY FROM DAMAGE WHICH MAY OCCUR WHEN TWO SHEAVE GROUPS (e.g., LOAD BLOCK AND BOOM HEAD) COME INTO CONTACT AS THE HOIST CABLE IS DRAWN IN, AS SPECIFIED IN API SPEC 2C, PARAGRAPH 13.7, ON EACH CRANE ON A FIXED PLATFORM INSTALLED BY MARCH 16, 2005? Regulatory Authority: Enforcement Action: W/C 30 CFR 250.108(c) API Reference: API SPEC 2C 13.7 BOEMRE BSEE Inspectors do not test stalling mechanisms for hoist drum. A control override device or proximity warning device may be used. Stalling of the hoist drum is acceptable where damage or loss on control would not result. INSPECTION PROCEDURE: 1. Verify that a means to protect hoist ropes, structural components and machinery from damage is provided on all cranes. 2. Verify that the operator is documenting the proper inspection of the controls override or proximity warning device as specified in API RP 2D, Paragraph 4.2.2. IF NONCOMPLIANCE EXISTS: Issue a warning (W) INC for each crane audit that does not confirm that the operator has records of inspecting the control override or proximity warning devices as specified in API RP 2D, Paragraph 4.2.2 & C.4.1.2(b),(c),(d). Issue a component shut in (C) INC for each crane inspected that does not have an operational control override or proximity warning device installed. INSPECTION COUNT/ INC COUNT: Enter one item checked/ issue one INC for each crane inspected. BSEE Crane Safety – PINCs (FINAL) E14PB00023 (Crane Safety Devices Continued) I – 117 IS THERE A FIRE EXTINGUISHER OF APPROPRIATE SIZE AND TYPE KEPT IN THE CAB OR VICINITY OF THE CRANE IN ACCORDANCE WITH AP1 RP 2D, PARAGRAPH 3.5.2? Regulatory Authority: Enforcement Action: C 30 CFR 250.108(a) API Reference: API RP 2D 3.5.2 NOTE: ASME B30.4c recommends a portable fire extinguisher with a basic minimum extinguisher rating of 10 BC. (10 = 10 lbs., B = Flammable Fluids, C = Energized Electrical) INSPECTION PROCEDURE: Verify that a fire extinguisher is located in the crane cab or near the crane. IF NONCOMPLIANCE EXISTS: Issue a component shut-in (C) INC if fire extinguisher: 1. Is not located where required. 2. Is not of the appropriate size or type. 3. Does not exist or is inoperable. INSPECTION COUNT/ INC COUNT: Enter one item checked/ issue one INC for each crane inspected. BSEE Crane Safety – PINCs (FINAL) E14PB00023 LOAD RATING AND TESTS I – 131 IS THE CORRECT LOAD RATING CHART FOR THE CRANE CONFIGURATION IN USE AT THE PRIMARY CONTROL STATION IN ACCORDANCE WITH API RP 2D, PARAGRAPH 3.2.1? Regulatory Authority: Enforcement Action: C 30 CFR 250.108(a) API Reference: API RP 2D 3.2.1 INSPECTION PROCEDURE: Verify that the load chart is legible, posted and visible in the primary control station for the crane configuration in use. IF NONCOMPLIANCE EXISTS: Issue a component shut-in (C) INC for the crane if the correct load rating chart is not posted and visible at the primary control station for the crane. INSPECTION COUNT/ INC COUNT: Enter one item checked/ issue one INC for each crane inspected. I – 132 ARE WRITTEN REPORTS ON LOAD TESTS PREPARED BY A QUALIFIED CRANE INSPECTOR SHOWING LOAD TEST PROCEDURES AND RESULTS WHEN LOAD TESTS ARE REQUIRED IN ACCORDANCE WITH API RP 2D, PARAGRAPH 4.2.3? Regulatory Authority: Enforcement Action: C 30 CFR 250.108(a) API Reference: API RP 2D 4.2.3 NOTE: Load tests are 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. 4. When repairs or replacement do not meet the requirements of API RP 2D, paragraph 4.3.3. INSPECTION PROCEDURE: Verify from facility crane records that load tests were conducted when required by a qualified crane inspector using API RP 2D, Appendix E, as a reference guide. IF NONCOMPLIANCE EXISTS: Issue a component shut-in (C) INC if load tests are not conducted when necessary by a qualified crane inspector using API RP 2D, Appendix E, as a referenced guide. INSPECTION COUNT/ INC COUNT: Enter one item checked/ issue one INC for each crane inspected. BSEE Crane Safety – PINCs (FINAL) E14PB00023 (Load Rating and Tests Continued) I – 133 HAVE STATIC AND DYNAMIC LOAD RATING CHARTS BEEN ESTABLISHED FOR ALL CRANES IN ACCORDANCE WITH API RP 2D, PARAGRAPH 3.1.5h? Regulatory Authority: Enforcement Action: C 30 CFR 250.108(a) API Reference: API RP 2D 3.1.5(h) NOTE: 1. Static Load Ratings must be established for lifting from or setting on the crane-supporting structure (platform). 2. Dynamic Load Ratings must be established for lifting from or setting on vessels. INSPECTION PROCEDURE: Verify from facility crane records that static and dynamic load ratings charts have been established for all cranes. IF NONCOMPLIANCE EXISTS: Issue a component shut-in (C) INC if records indicate that: 1. Static and dynamic load ratings have not been established for all cranes 2. Crane has operated without appropriate load rating charts established and posted 2.3.Records are not visible to the crane operator at control station. INSPECTION COUNT/ INC COUNT: Enter one item checked/ issue one INC for each crane inspected. I – 134 IS THE LOAD BLOCK RATING LABEL(S) PERMANENTLY AFFIXED TO THE HOOK BLOCK, AS SPECIFIED IN AP SPEC 2C, PARAGRAPH 7.5.3.2, ON EACH CRANE MANUFACTURED AFTER MARCH 17, 2003, OR EACH CRANE ON A FIXED PLATFORM INSTALLED AFTER MARCH 17, 2003? Regulatory Authority: Enforcement Action: C 30 CFR 250.108(c) API Reference: API SPEC 2C 7.5.3.2 INSPECTION PROCEDURE: 1. Verify that the load block rating label(s) is permanently affixed to the hook block & over haul ball. 2. Verify that the label includes the following load block requirements a. The maximum static and personnel rated loads. b. The service temperature and assembly weight. IF NONCOMPLIANCE EXISTS: Issue a component shut-in (C) INC for any crane load block that does comply with the requirements in API SPEC 2C, Paragraph 7.5.3.2. INSPECTION COUNT/ INC COUNT: Enter one item checked/ issue one INC for each crane inspected. BSEE Crane Safety – PINCs (FINAL) E14PB00023 CRANE INSPECTIONS I – 141 HAVE MANUFACTURER’S RECOMMENDATIONS BEEN INCLUDED IN ESTABLISHING ALL INSPECTION REQUIREMENTS IN ACCORDANCE WITH API RP 2D, PARAGRAPH 4.1.2 AND APPENDIX C? Regulatory Authority: Enforcement Action: WW/C 30 CFR 250.108(a) API Reference: API RP 2D 4.1.2 and Appendix C INSPECTION PROCEDURE: Verify that the manufacturer’s recommendations have been included in establishing all inspection requirements. IF NONCOMPLIANCE EXISTS: Issue a warning (W) INC if records indicate that manufacturer’s recommendations have been excluded from establishing inspection requirements. Issue a component shut-in (C) INC for components that have exceeded the manufacture time limit and have not been overhauled or replaced. INSPECTION COUNT/ INC COUNT: Enter one item checked/ issue one INC for each crane inspected. BSEE Crane Safety – PINCs (FINAL) E14PB00023 (Crane Inspections Continued) I – 142 HAVE NEW OR RELOCATED CRANES RECEIVED AN INITIAL INSPECTION BY A QUALIFIED INSPECTOR WITH RECORDS MAINTAINED AT AN APPROPRIATE LOCATION FOR FOUR YEARS IN ACCORDANCE WITH API RP 2D, PARAGRAPH 4.1.2.1 AND 4.2.2? Regulatory Authority: Enforcement Action: W/C 30 CFR 250.108(a) API Reference: API RP 2D 4.1.2.1 & 4.2.2 NOTE: Cranes in this category are required to be load tested in accordance with API RP 2D, Appendix E. INSPECTION PROCEDURE: Verify that: 1. Records of initial inspection are readily available and are maintained for a period of 4 years. 2. Inspection and load test was performed. 3. Records include date and time of inspection and name/initial of person performing the inspection. IF NONCOMPLIANCE EXISTS: Issue a warning (W) INC if records of initial inspection are not available and/or not maintained for 4 years. Issue a component shut-in (C) INC if: 1. The crane was not inspected prior to use when new or prior to use after being permanently relocated. 2. The crane was not load tested. INSPECTION COUNT/ INC COUNT: Enter one item checked/ issue one INC for each crane inspected. BSEE Crane Safety – PINCs (FINAL) E14PB00023 (Crane Inspections Continued) I – 143 HAVE PRE-USE INSPECTIONS BEEN PERFORMED PRIOR TO USE (TYPICALLY DAILY) BY A QUALIFIED CRANE OPERATOR/INSPECTOR WITH RECORDS, IN ACCORDANCE WITH API RP 2D, PARAGRAPHS 4.1.1.1 AND 4.1.2.2, MAINTAINED AT AN APPROPRIATE LOCATION FOR FOUR YEARS? Regulatory Authority: Enforcement Action: W/C 30 CFR 250.108(a) API Reference: API RP 2D 4.1.1.1 and 4.1.2.2 NOTE: Applies to all cranes, regardless of usage category. The pre-use inspection must be conducted prior to using the crane. Pre-use inspection record can be a record, a record book, a logbook, a computerized data collector, or an electronic data collector. Inspection criteria must be in accordance with API RP 2D, Appendix C, paragraph C.4.1.2a. INSPECTION PROCEDURE: Verify that: 1. Pre-use inspections are performed. 2. Records are kept at an appropriate location and are maintained for a period of 4 years. 3. Records include date and time of inspection and name/initial of person performing the inspection. IF NONCOMPLIANCE EXISTS: Issue a warning (W) INC if: 1. Records indicate that a pre-use inspection was missed or did not occur on schedule, but the most recent pre-use inspection has been performed. 2. Records are not maintained for a period of 4 years. Issue a component shut-in (C) INC if: 1. Records of pre-use inspections are not available or are not kept at an appropriate location. (lessee’s field office) 2. Records do not indicate that a pre-use inspection has been performed. 3. The pre-use inspection currently due has not been performed. INSPECTION COUNT/ INC COUNT: Enter one item checked/ issue one INC for each crane inspected. BSEE Crane Safety – PINCs (FINAL) E14PB00023 (Crane Inspections Continued) I – 144 HAVE MONTHLY INSPECTIONS BEEN PERFORMED BY A QUALIFIED CRANE OPERATOR/INSPECTOR WITH RECORDS, IN ACCORDANCE WITH API RP 2D, PARAGRAPH 4.1.2.3 AND 4.2.2, READILY AVAILABLE FOR A PERIOD OF FOUR YEARS? Regulatory Authority: Enforcement Action: W/C 30 CFR 250.108(a) API Reference: API RP 2D 4.1.2.3 and 4.2.2 NOTE: 1. Applies to Heavy Usage Category cranes. An Operator’s failure to document usage category will cause the crane to default to the Heavy Usage category. Inspection criteria must be in accordance with API RP 2D, Appendix C, paragraph C.4.1.2b. 2. Reference Appendix 24 for definition of “Monthly” and description of Usage Category.” INSPECTION PROCEDURE: Verify that: 1. Monthly inspections are performed by qualified personnel. 2. Verify that records are readily available and are maintained for a period of 4 years. 3. Verify that records include date and time of inspection and name/initial of person performing the inspection. IF NONCOMPLIANCE EXISTS: Issue a warning (W) INC if records indicate that monthly inspection was missed or did not occur on schedule, but the most recent monthly inspection was completed. Issue a component shut-in (C) INC if: 1. Records of monthly inspections are not available or are not maintained for a period of 4 years. 2. Records do not indicate that a monthly inspection has been performed. 3. The monthly inspection currently due has not been performed. INSPECTION COUNT/ INC COUNT: Enter one item checked/ issue one INC for each crane inspected. BSEE Crane Safety – PINCs (FINAL) E14PB00023 (Crane Inspections Continued) I – 145 HAVE QUARTERLY INSPECTIONS BEEN PERFORMED BY A QUALIFIED CRANE INSPECTOR WITH RECORDS, IN ACCORDANCE WITH API RP 2D, PARAGRAPH 4.1.2.4 AND 4.2.2, READILY AVAILABLE FOR A PERIOD OF FOUR YEARS? Regulatory Authority: Enforcement Action: W/C 30 CFR 250.108(a) API Reference: API RP 2D 4.1.2.4 & 4.2.2 NOTE: 1. Applies to Moderate Usage Category cranes and Heavy Usage Category cranes. An Operator’s failure to document usage category will cause the crane to default to the Heavy Usage category. Inspection criteria must be in accordance with API RP 2D, Appendix C, paragraph C.4.1.2c. 2. Reference Appendix 24 for definition of “Monthly” and description of Usage Category.” INSPECTION PROCEDURE: Verify that: 1. Quarterly inspections are performed by a qualified crane inspector. 2. Records are readily available and are maintained for a period of 4 years. 3. Records include date and time of inspection and name/initial of person performing the inspection. IF NONCOMPLIANCE EXISTS: Issue a warning (W) INC if records indicate that quarterly inspection was missed or did not occur on schedule, but the most recent quarterly inspection was completed. Issue a component shut-in (C) INC if: 1. Records of quarterly inspections are not available or are not maintained for a period of 4 years. 2. Records do not indicate that a quarterly inspection has been performed. 3. The quarterly inspection currently due has not been performed. INSPECTION COUNT/ INC COUNT: Enter one item checked/ issue one INC for each crane inspected. BSEE Crane Safety – PINCs (FINAL) E14PB00023 (Crane Inspections Continued) I – 146 HAVE ANNUAL INSPECTIONS BEEN PERFORMED BY A QUALIFIED CRANE INSPECTOR WITH RECORDS, IN ACCORDANCE WITH API RP 2D, PARAGRAPHS 4.1.1.1, 4.1.2.5, AND 4.2.2, READILY AVAILABLE FOR A PERIOD OF FOUR YEARS? Regulatory Authority: Enforcement Action: W/C 30 CFR 250.108(a) API Reference: API RP 2D 4.1.1.1., 4.1.2.5 & 4.2.2 NOTE: 1. Applies to all cranes, regardless of usage category. Cranes that have been out of service for 12 months or more must have an annual inspection before being used. Additionally, annual inspections must include inspection of crane critical components in accordance with API RP 2D, Appendix C, paragraph C.4.1.2d, items 22, 23, and 24. 2. Reference Appendix 24 for definition of “Annual” and descriptions of “Usage Category.” INSPECTION PROCEDURE: Issue a warning (W) INC if records indicate that annual inspection did not occur on schedule, but the most recent annual inspection was completed. Issue a component shut-in (C) INC if: 1. Records of annual inspections are not available or are not maintained for a period of 4 years. 2. Records do not indicate that an annual inspection has been performed. The annual inspection currently due has not been performed. IF NONCOMPLIANCE EXISTS: Verify that: 1. Annual inspections are performed by a qualified crane inspector. 2. Records are readily available and are maintained for a period of 4 years. 3. Records include date and time of inspection and name/initial of person performing the inspection. INSPECTION COUNT/ INC COUNT: Enter one item checked/ issue one INC for each crane inspected. BSEE Crane Safety – PINCs (FINAL) E14PB00023 (Crane Inspections Continued) I – 147 HAS A WIRE ROPE INSPECTION PROGRAM BEEN ESTABLISHED IN ACCORDANCE WITH API RP 2D, PARAGRAPH 5.1.2 AND ARE INSPECTION RECORDS MAINTAINED FOR A PERIOD OF FOUR YEARS? Regulatory Authority: Enforcement Action: W/C 30 CFR 250.108(a) API Reference: API RP 2D 5.1.2.1(b) NOTE: Wire Rope Inspection Program -. A wire rope inspection program is an inspection program which takes into consideration crane type, frequency of usage, history of maintenance, wire rope manufacturer’s recommendations, and crane manufacturer’s recommendations Note: 1. Inspection records must be maintained per API RP 2D, paragraph 4.2 to determine the time interval for retirement of the wire rope. Records must be readily available until the specific wire rope is retired. All observed wire rope deterioration as listed in API RP 2D, Appendix G, paragraph G.5.2.1b must be recorded on these inspection records. 2. Reference Appendix 24 for descriptions of “Frequency of Usage.” INSPECTION PROCEDURE: Verify that: 1. A wire rope inspection program has been established. 2. Wire rope inspection records are available and are maintained for a period of 4 years IF NONCOMPLIANCE EXISTS: Issue a warning (W) INC if: 1. Records are not readily available or are not maintained for a period of 4 years. 2. Records are incomplete or inaccurate, but are sufficient to indicate that a wire rope inspection program has been established. Issue a component shut-in (C) INC if a wire rope program has not been established. 1. A wire rope program has not been established. INSPECTION COUNT/ INC COUNT: Enter one item checked/ issue one INC for each crane inspected. BSEE Crane Safety – PINCs (FINAL) E14PB00023 REPAIRS OR ALTERATIONS I – 151 HAS A PREVENTATIVE MAINTENANCE PROGRAM BEEN ESTABLISHED WITH RECORDS, IN ACCORDANCE WITH API RP 2D, PARAGRAPH 4.3.1, READILY AVAILABLE FOR A PERIOD OF FOUR YEARS? Regulatory Authority: Enforcement Action: W/C 30 CFR 250.108(a)(e) API Reference: API RP 2D 4.3.1 NOTE: 1. A preventative maintenance program takes into consideration crane type, frequency of usage, history of maintenance, and manufacturer’s recommendations. 2. Reference Appendix 24 for descriptions of “Frequency of Usage.” INSPECTION PROCEDURE: Verify that: 1. A preventative maintenance program has been established. 2. Preventative maintenance records are readily available and are maintained for a period of 4 years. IF NONCOMPLIANCE EXISTS: Issue a warning (W) INC if preventative maintenance program records are not immediately available or are not maintained for a period of 4 years. Issue a component shut-in (C) INC if records do not indicate that a preventive maintenance program has been established or are not immediately available. INSPECTION COUNT/ INC COUNT: Enter one item checked/ issue one INC for each crane inspected. BSEE Crane Safety – PINCs (FINAL) E14PB00023 (Repairs and Alterations Continued) I – 152 ARE WRITTEN REPORTS CONFIRMING ADEQUACY OF REPAIRS OR ALTERATIONS IN ACCORDANCE WITH API RP 2D, PARAGRAPH 4.3.3c, MAINTAINED FOR A PERIOD OF FOUR YEARS? Regulatory Authority: Enforcement Action: W/C 30 CFR 250.108(a)(e) API Reference: API RP 2D 4.3.3(c) NOTE: All replacement parts must be equal to or better than the original equipment. No welding repairs may be made to critical components, such as booms and swing circle assemblies, without specific repair procedures and recommendations from the original crane manufacturer or other similar qualified source. INSPECTION PROCEDURE: Verify that: 1. Written reports confirming the adequacy of major repairs or alterations are available. 2. The reports are maintained for a period of 4 years. IF NONCOMPLIANCE EXISTS: Issue a warning (W) INC if written reports confirming the adequacy of repairs or alterations are not immediately available or are not maintained for a period of 4 years. Issue a component shut-in (C) INC if written reports: 1. Were not prepared confirming the adequacy of repairs or alterations performed. 2. Are incomplete or inaccurate INSPECTION COUNT/ INC COUNT: Enter one item checked/ issue one INC for each crane inspected. BSEE Crane Safety – PINCs (FINAL) E14PB00023 (Repairs and Alterations Continued) I – 153 ARE REPAIRS OR REPLACEMENTS OF CRITICAL COMPONENTS MADE PROMPTLY AS SOON AS PRACTICAL IN ACCORDANCE WITH API RP 2D, 4.4.3(b) Regulatory Authority: Enforcement Action: C 30 CFR 250.108(a) API Reference: API RP 2D 4.3.3(b) NOTE: All replacement parts must be equal to or exceed the original equipment. No welding repairs may be made to critical components, such as booms and swing circle assemblies, without specific repair procedures and recommendations from the original crane manufacturer, or other qualified source. Repairs or replacements of critical components should be made as soon as practical (API RP 2D, Appendix F.4.3.3) Promptly means “Done Without Delay.” INSPECTION PROCEDURE: 1. Check facility crane records for evidence of crane repair or replacements of critical components. 2. If repair or replacement has been made, verify work was done promptly and accomplished in accordance with API RP 2D, Appendix F, paragraph F.4.3.3, item b. IF NONCOMPLIANCE EXISTS: Issue a component shut-in (C) INC if records indicate that work is not done promptly or accomplished in accordance with API RP 2D, Appendix F, paragraph F.4.3.3, item b. INSPECTION COUNT/ INC COUNT: Enter one item checked/ issue one INC for each crane inspected. BSEE Crane Safety – PINCs (FINAL) E14PB00023 SLINGS I – 161 ARE SLINGS OF ALL TYPE, GRADE, AND CONSTRUCTION IDENTIFIED AS REQUIRED IN API RP 2D, PARAGRAPH 5.2.4b? Regulatory Authority: Enforcement Action: C 30 CFR 250.108(a) API Reference: API RP 2D 5.2.4(b) NOTE: Sling identification includes sling manufacturer’s name, pertinent working load limits, proof test certification number, length, diameter, and date of proof test. INSPECTION PROCEDURE: Verify that the slings have the specified ID tags attached and that the ID tags are legible. IF NONCOMPLIANCE EXISTS: Issue a component shut-in (C) INC if sling identification tag is missing. INSPECTION COUNT/ INC COUNT: Enter one item checked/ issue one INC for each crane inspected. I – 162 ARE SLINGS PROPERLY STORED WHEN NOT IN USE IN ACCORDANCE WITH API RP 2D, APPENDIX G, PARAGRAPH G.5.2.1? Regulatory Authority: Enforcement Action: W/C 30 CFR 250.108(a) API Reference: API RP 2D Appendix G 5.2.1 NOTE: Slings should be stored in an area where they will not be exposed to water, extreme heat, or corrosive fumes, liquids and sprays. Slings should not be stored on the deck. All slings, when not in use, should be kept on a rack. Use of a rack minimizes accidental damage and allows easier monitoring of condition between regular inspections. If space limitations require that slings be stored along the side of the platform, they should be secured in a manner to prevent abrasion due to rubbing and maintained in a manner to minimize corrosion. INSPECTION PROCEDURE: Visually inspect areas near cranes for slings which are not properly stored and maintained IF NONCOMPLIANCE EXISTS: Issue a warning (W) INC if slings are not properly stored. Issue a component shut-in (C) INC if slings are not maintained in a manner to prevent loss of integrity due to abrasion or corrosion. INSPECTION COUNT/ INC COUNT: Enter one item checked/ issue one INC for each crane inspected. BSEE Crane Safety – PINCs (FINAL) E14PB00023 CERTIFICATION I – 171 IS THE LESSEE ENSURING THAT THE MANUFACTURER IS CERTIFYING EACH CRANE MANUFACTURED AFTER MARCH 17, 2003, OR THAT EACH CRANE ON A FIXED PLATFORM INSTALLED AFTER MARCH 17, 2003, MEETS THE DESIGN, MATERIAL AND DIMENSIONAL SPECIFICATIONS USED IN THE CALCULATIONS AND HAS BEEN AUTHENTICATED IN ACCORDANCE WITH API SPEC 2C, PARAGRAPHS 5.5 AND 6.2? Regulatory Authority: Enforcement Action: C 30 CFR 250.108(c) API Reference: API SPEC 2C 5.5 and 6.2 INSPECTION PROCEDURE: 1. Verify that a nameplate is installed in compliance with API SPEC 2 C. 2. In the absence of the nameplate, verify that the lessee has the required manufacturer’s information. IF NONCOMPLIANCE EXISTS: Issue one component shut-in (C) INC for each crane certification audited if the Lessee does not comply with API SPEC 2 C, Paragraph 5.5 and 6.2 INSPECTION COUNT/ INC COUNT: Enter one item checked/ issue one INC for each crane inspected. BSEE Crane Safety – PINCs (FINAL) E14PB00023 PERSONNEL QUALIFICATIONS I – 181 DO ONLY QUALIFIED PERSONNEL PERFORM RIGGING OPERATIONS IN ACCORDANCE WITH API RP 2D, PARAGRAPHS 2.44, 3.1.3, AND 3.1.4? Regulatory Authority: Enforcement Action: C 30 CFR 250.108(a) API Reference: API RP 2D 2.44, 3.1.3, and 3.1.4 DEFINITION: Rigger - Anyone who attaches or detaches lifting equipment to loads or lifting devices (API RP 2D 2.44) and who has received training in accordance with API RP 2D, paragraph 3.1.4 and Appendix A2Appendix A3. INSPECTION PROCEDURE: If rigging operations are in progress at the time of inspection, verify that personnel involved are qualified IF NONCOMPLIANCE EXISTS: Issue a component shut-in (C) INC if rigging operations are in progress and personnel involved are not qualified. INSPECTION COUNT/ INC COUNT: Enter one item checked/ issue one INC for each crane inspected. BSEE Crane Safety – PINCs (FINAL) E14PB00023 (Personnel Qualifications Continued) I – 182 ARE CRANES OPERATED ONLY BY QUALIFIED PERSONNEL IN ACCORDANCE WITH API RP 2D, PARAGRAPHS 3.1.1? Regulatory Authority: Enforcement Action: W/C 30 CFR 250.108(a) API Reference: API RP 2D 3.1.1 NOTE: Qualified Person: A person who has met and passed the requirements of API RP 2D, paragraphs 2.42 and 3.1.2; 1. A trainee under the direct supervision of a Qualified Crane Operator; 2. Appropriate maintenance and supervisory personnel, when it is necessary for them to do so in the performance of their duties. Note: No one other than the personnel specified above should enter a crane cab. INSPECTION PROCEDURE: 1. Verify from facility records that crane operations were performed by qualified personnel or under direct supervision of a qualified crane operator (a trainee). 2. If crane is in operation, verify that the person operating the crane is qualified or under direct supervision of a qualified crane operator (a trainee). Note: 1. A crane operator is not qualified if qualifications are not maintained, at a minimum, every four years 2. A written document from the facility operator stating that qualifications have been met is sufficient IF NONCOMPLIANCE EXISTS: Issue a warning (W) INC if facility records indicate that the crane was previously operated by unqualified personnel. Issue a component shut-in (C) INC if the crane in operation during the inspection is operated by unqualified personnel INSPECTION COUNT/ INC COUNT: Enter one item checked/ issue one INC for each crane inspected. BSEE Crane Safety – PINCs (FINAL) E14PB00023 Personnel Qualifications Continued) I – 183 ARE CRANE INSPECTORS QUALIFIED IN ACCORDANCE WITH API RP 2D, PARAGRAPH 2.43? Regulatory Authority: Enforcement Action: C 30 CFR 250.108(a) API Reference: API RP 2D 2.43 DEFINITION: Qualified Crane Inspector - A person so designated by the employer who by reason of appropriate experience and training, in addition to meeting the requirements of Qualified Crane Operator, has attended formal training in and successfully completed courses on crane maintenance and troubleshooting, hoist troubleshooting and overhaul, and on structural aspects of offshore cranes, which gives a knowledge of structurally critical components and critical inspection areas for non-mechanical and/or mechanical cranes, as applicable. INSPECTION PROCEDURE: Verify from facility crane records that duties requiring a qualified crane inspector have been performed by qualified personnel. Note: 1. A crane inspector is not qualified if qualifications are not maintained, at a minimum, every 4 years. 2. A written document from the Operator stating that qualifications have been met is sufficient. IF NONCOMPLIANCE EXISTS: Issue a component shut-in (C) INC if records from a previous inspection indicate that duties requiring a qualified crane inspector have been performed by unqualified personnel. INSPECTION COUNT/ INC COUNT: Enter one item checked/ issue one INC for each crane inspected. BSEE Crane Safety – PINCs (FINAL) E14PB00023 MATERIAL HANDLING I – 190 IS ALL MATERIAL-HANDLING EQUIPMENT OPERATED AND MAINTAINED IN A MANNER THAT ENSURES SAFE OPERATIONS AND PREVENTS POLLUTION? Regulatory Authority: Enforcement Action: C 30 CFR 250.108(f) API Reference: API RP 2D 3.1.5c INSPECTION PROCEDURE: 1. Verify that material handling equipment is operated and maintained in a safe and pollution free manner. 2. Inspect records to ensure material handling equipment is operated per manufacturers and/or operators specifications. IF NONCOMPLIANCE EXISTS: Issue a component shut-in (C) INC when; 1. Material handling equipment is not operated and maintained in a safe manner. Material handling equipment is not operated and maintained in a pollution free manner. INSPECTION COUNT/ INC COUNT: Enter one item checked / issue one INC for facility inspected. NOTE - Material handling equipment includes, but is not limited to; air hoists, hoists, tugger, air tugger, winch, man-riding winch, come-a-long, monorail, gantry crane, jib BSEE Panel Report 2017-001 Investigation of October 20, 2015 Fatality During Pipe Handling Lease OCS-G 33531, Keathley Canyon Block 96 Drillship Pacific Santa Ana Gulf of Mexico Region, Lake Jackson District Off Texas Coast March 3, 2017 U.S. Department of the Interior Bureau of Safety and Environmental Enforcement Contents Contents ........................................................................................................................................... i List of Acronyms…………………………………………………………………………….……ii Figures............................................................................................................................................ iii Executive Summary .........................................................................................................................1 Introduction ......................................................................................................................................3 BSEE Investigation and Findings ....................................................................................................9 Conclusions ....................................................................................................................................18 Recommendations ..........................................................................................................................19 i List of Acronyms AD Assistant Driller BHA - Bottom Hole Assembly BSEE - Bureau of Safety and Environmental Enforcement HR Hydra Racker MHR - Main Hydra Racker MODU - Mobile Offshore Drilling Unit NOV - National Oilwell Varco OCSLA -Outer Continental Shelf Lands Act OJT - On the Job Training PJSM - Pre Job Safety Meeting PSA - Pacific Santa Ana SES - Stress Engineering Services SSE - Short Service Employee TIH Tripping in the Hole TRA - Task Risk Assessment USCG - United States Coast Guard ii Figures____________________________________________________________ Figure 1- Lease Location & Position of Pacific Santa Ana on October 20, 2015 Figure 2- The Pacific Santa Ana Figure 3-Looking upward from the deck. In the foreground is the lower finger board. Latches in closed position can be seen holding stands of pipe in place. Figure 4- The Main Hydra Racker (MHR) lower guide head is visible in its position around a pipe stand at the bottom of the photo. Figure 5- Inside the drill shack; The Assistant Driller (AD) control position is in the foreground. The driller would occupy the far chair. The yellow Main Hydra Racker (MHR) is seen in the upper right corner. Figure 6 - View from drill floor. Stand #32 is obstructed by latch on lower finger board. Figure 7- The view from the Main Side AD control chair, looking towards the setback area. Figure 8 – Fingerboard latches. Note the latch in the up (open) position. The silver top of the piston rod can be seen pulled down. Figure 9 – Latch Cylinder Drawing Figure 10 – Incident Location Plan View iii Executive Summary On October 20, 2015, an incident resulting in a single fatality occurred onboard the Drillship Pacific Santa Ana (PSA). The PSA, owned by Pacific Drilling, was operating approximately 250 miles south of Lake Charles, Louisiana in the Gulf of Mexico. The PSA under contract to Chevron USA Inc. (Chevron) was in the Keathley Canyon Area, Block 96 to drill an exploratory well under Lease OCS-G 33531. The drill crew onboard the PSA was in the initial stages of the drilling process, lowering the Bottom Hole Assembly (BHA) and 36 inch structural casing to the sea floor in order to begin making the well. This process involved work on the drill floor to successively connect lengths of pipe and lower them through the rig’s main drill center, referred to as “Tripping in the Hole” (TIH). At approximately 10:10 a.m., a floor hand employed by Pacific Drilling, died when he was struck in the head by the bottom end of 6 ⅝ inch drill pipe1 as it was being moved from its storage location to the main drill center. The victim, a Pacific Drilling employee since January 4, 2015, had previously worked as a roustabout. The victim had been training during off hours and when operations allowed with the drill crew. The day of the incident was the victim’s first shift after having been fully promoted to floor hand. The PSA is equipped with a dual activity derrick having a main well center and auxiliary well center along with a main and auxiliary National Oilwell Varco (NOV) Hydra Racker IV (HR) for pipe handling. Drill pipe is stored vertically in a setback area located between the two drill centers. The pipes are secured using two fingerboards in the derrick which maintain the pipes in the vertical orientation and prevents unintentional movement. The setback area was considered a no entry zone while the HR was handling pipes. Standing on end, four single drill pipes (joints) are assembled to form a stand of pipe. At the time of the incident, each of the stands being worked was approximately 125 foot long. While stored in the setback area, referred to as “racked back”, the stands are held in individual slots by pneumatic latches along each row of the upper and lower fingerboards. Each latch between the stand being handled and the opening of the fingerboard is only opened after the stand is secured by the HR. To retrieve a stand, the HR extends three arms which make contact with the stand. The center arm is equipped with a gripper head which grips and lifts the weight of the stand. The upper and lower arms of the HR have guide heads, which act to stabilize and maintain the stand in a vertical position. The guide heads have claws that close around the stand, but these claws are not intended to grip the stand while it is being moved. Once the gripper head has control of the stand, the stand would be lifted and all three arms would retract back to the base of the HR. The HR would then rotate and traverse down a track transporting the stand to the drill center. The HR would then be returned to the setback area. During the TIH operation, the victim had been assigned to spot for the Assistant Driller (AD) who operated the Main Hydra Racker (MHR) from inside the drill shack. As a spotter, the victim had the responsibility of visually verifying latches on the lower and upper fingerboards in 1 Pipe is referred to by its outside diameter. 1 the path of the stand being moved were in the open position prior to the retracting of the HR arms. This observation was done standing to the side of the HR base, and outside of the setback area. The victim would verbally convey the position of the latches (open or closed) to the AD by way of a hand held radio. In addition to spotting, the victim had also been tasked with keeping the setback area clean, applying thread lubricant to the stands (referred to as doping), and re-numbering the stands with a paint stick. By the time of the incident, the process of handling stands of 6⅝ inch pipe with the MHR had repeated 31 times. The AD began the process of removing stand 32 with the MHR after hearing the victim over the radio verify that the latches were open. As the MHR arms retracted however, the stand was obstructed by a closed latch on the lower fingerboard. There were no indications that anyone was aware the latch was closed. As the HR continued to retract, the claws of the lower guide head remained closed and the stand of pipe began to bow as it was pulled against the closed fingerboard latch. The victim had at this point stepped into the setback area and into the path that the stand had travelled. The force being applied to the claws of the lower guide head by stand 32 ultimately forced open the aft claw. All of the stored energy from the stand being bowed was released and it recoiled towards the setback area striking the victim. The injuries sustained by the victim were described by coworkers who came to his aide as immediate and obviously fatal. From the start of the sequence to retrieve stand 32 to the time the victim was struck, 6-8 seconds had passed. The Bureau of Safety and Environmental Enforcement (BSEE) conducted a panel investigation into the victim’s death and the causal factors that led to the incident. The panel consisted of professionals from both BSEE and the United States Coast Guard (USCG). The Panel travelled to the PSA, conducted interviews, reviewed documents and witnessed the testing of components removed from the PSA. Based on the investigation, the Panel concluded that the fatal incident was the result of:   The failure of a rod seal located within a lower finger board latch cylinder. The victim moving into the setback area while a pipe stand was being moved. In addition, the Panel identified the following contributing factors:    Insufficient supervision over an employee new to a position. Assignment of multiple tasks to an employee new to a position. Failure to recognize risks associated with an operation. 2 Introduction Pursuant to 43 U.S.C. § 1348(d)(1), (2) and (f) [Outer Continental Shelf Lands Act, as amended] (OCSLA) and Department of the Interior regulations 30 CFR Part 250, the Bureau of Safety and Environmental Enforcement (BSEE) is required to investigate and prepare a public report of this incident. BSEE convened a panel to conduct the investigation. Panel members were: Michael Fornea, Field Engineer, BSEE Lake Jackson District James Holmes, Inspector, BSEE Lake Jackson District Michael Idziorek2, Special Investigator, BSEE Safety and Incident Investigations Division Troy Naquin, Inspector, BSEE Lafayette District USCG Marine Casualty Investigator, Lt. Walter Hutchins from Marine Safety Unit Texas City assisted in the investigation. The purpose of this investigation was to identify and document the cause or causes of the fatality which occurred onboard the PSA. The report prepared includes the conclusions made by the Panel. Also included are recommendations that may help to reduce the likelihood of a recurrence or similar incident in the future. 2 Panel Chair 3 Lease Location and Information Lease OCS-G 33531(the lease) is approximately 250 miles south of Lake Charles, LA and covers approximately 5,760 acres encompassing all of Keathley Canyon Block 96 (KC 96), in the Gulf of Mexico Western Planning Area (Figure1). The block was purchased by BP Exploration & Production Inc., as the sole lease owner/operator, in the GOM Western Lease Sale 210 in 2009. Chevron USA Inc. became a partner and Lease Owner Group Operator in March of 2014; BP held 55% working interest (WI) and Chevron held 45% WI. ConocoPhillips Company joined as a partner on December 1, 2014; Chevron held 45% WI, BP held 34% WI and ConocoPhillips held 21% WI. As of December 31, 2014, the lease was owned by Chevron (36% WI), BP (34% WI), and ConocoPhillips (30% WI) with Chevron being the operator. Pacific Drilling was contracted to drill well number 1 (the well) located in KC 96 using the drillship PSA. The water depth at this location is 4,847 feet (1477 meters). Figure 1- Lease Location & Position of Pacific Santa Ana on October 20, 2015 4 Pacific Santa Ana Drillship The PSA is a 748 foot (228 meter) long, 60,538 Gross Ton Drillship. Constructed by Samsung Heavy Industries of South Korea in 2011 (Figure 2), The PSA is owned by Pacific Drilling Limited headquartered in Katy, Texas. The flag state for the PSA is Liberia. As a drillship, the PSA falls into the category of being a Mobile Offshore Drilling Unit or MODU. MODU’s like the PSA move under their own power as a conventional ship between drilling locations. Once at a drilling site, the PSA uses dynamic positioning to remain on station throughout the course of drilling operations. The PSA has a dual derrick system consisting of main and auxiliary drill centers. This allows for dual activity operations. Figure2- The Pacific Santa Ana 5 Pipe Stands and Fingerboards The stands are stored vertically in the setback areas and held in place using two fingerboards. Each board is comprised of several fingers which extend horizontally with openings facing the center of the ship. A lower fingerboard (~50 feet above the deck) and an upper fingerboard (~108 feet above the deck) hold the stands in rows with each stand in its own slot (Figure 3). Pneumatic latches on each fingerboard secure the stands in their slots. The latches are opened when one of two vertical pipe handlers is used to move a stand. Figure 3- Looking upward from the deck. In the foreground is the lower fingerboard. Latches in closed position can be seen holding stands of pipe in place. Pipe Handling Equipment To move stands of pipe in and out of the setback area, the PSA has two vertical pipe handlers, a main and auxiliary. Both are Hydra-Racker IV’s manufactured by NOV. On October 20, 2015, the Main Hydra Racker (MHR) was being used during the TIH operation. The MHR was operated by the AD from controls located inside the drill shack. To move and control pipes, the MHR has three arms: a griper head in the center, a lower guide head at the bottom, and upper guide head at the top. The griper head is used to grip and lift a selected pipe. The upper and lower arms of the M HR have guide heads, which act to stabilize and maintain the stand in a vertical position. The guide heads have claws that close around the stand, but these claws are not intended to grip the stand while it is being moved. Once the gripper head has control of the stand, the stand would be lifted and all three arms would retract back to the base of the MHR. The MHR rotates at its base so the pipe stand can be properly oriented to the drill center (Figure 4). 6 The MHR is operated using joystick hand controls on a “cyber chair” by the AD from a console with monitor displays inside the drill shack. The display provides the AD information such as the weight taken on by the MHR and the position of the three arms relative to each other. The display digitally depicts each row of pipe in the fingerboard, with pipes depicted in individual slots as circles. The finger board latches are depicted as a solid black line between each slot. Once a desired stand is secured by the MHR, the AD selects the command to open the latches in that row. This command allows rig air pressure to open the latches in front of the selected stand. On the display, the black lines depicting the latches disappear. Despite this visual indication, the system cannot tell the AD if an individual latch is truly open or if one closes prematurely. The disappearance of lines in a selected row only confirms that the command to open was given or sent. Figure 4- The MHR lower guide head is visible in its position around a pipe stand at the bottom of the photo. 7 Figure 5- Inside the drill shack; The Assistant Driller (AD) control position is in the foreground. The driller would occupy the far chair. The yellow Main Hydra Racker (MHR) is seen in the upper right corner. With the dual activity capability of the PSA, there are two complete sets of controls in the drill shack. There are chairs for both the Driller and AD. Each pair of chairs faces either the main or auxiliary drill centers (Figure 5). The pipe being used for the TIH operation was stored in the auxiliary setback area, located towards the bow of the ship. The main well drill center where the pipe stands were being transported to was towards the aft. As seen in Figure 5 above, the Driller and AD control positions are facing the main well drill center. Pipe stands from the vertical rack would be gripped by MHR and pulled out of the setback area. The MHR would rotate clockwise at its base, and then traverse down a track towards the main well drill center. Once a stand of pipe was at the drill center, the AD would align the new stand to the top of the previous stand. Control of the pipe would then be transferred to the top drive. From the same control chair and console, the AD would transition to operating the Hydra Tongs to connect the two stands. The top drive, operated by the Driller, would then lower the stands through the drill center. 8 Incident Timeline Under contract with Chevron Deepwater Exploration and Projects Business Unit (Chevron), the PSA arrived at KC 96 on October 17, 2015, to drill a new well. Preparations were made to begin drilling the well. This included surveying and marking the well location on the seafloor and inspecting the drill floor equipment. The next step would be to set a 36 inch casing into the seafloor, starting the well. After beginning their tour at midnight on October 20th, the drill crew, which included the victim, started to prepare the casing handling equipment and bottom hole assembly. This process was completed at 5:30 a.m. At 7:30 a.m., work began to “trip in the hole” (TIH) with the 6 ⅝ inch drill pipe through the main well drill center lowering the 36 inch casing 4,847 feet to the sea floor. There were five crew members involved with the operations on the drill floor. Inside the drill shack were the Driller and AD. Two floor hands worked at the main well drill center to assist with connecting the pipe stands. A third floor hand, the victim, acted as a spotter when the MHR would retrieve stands out of the setback area. The spotter would notify the AD when the fingerboard latches were open so the movement of the pipe stand could proceed without being obstructed. On October 20, 2015, the victim was working with the responsibility of spotting for the AD while pipe stands were being retrieved during the TIH operation. He was also tasked with renumbering3 pipe stands with a paint stick, cleaning and doping4 the pipe threads and keeping the setback area clean. The spotting was done while standing next to and forward of the MHR; however, the additional tasks involved him entering the setback area and working close to the stands. By approximately 10:10 AM, 31 stands had been moved to the main well drill center. The AD was retrieving stand 32 from row 46 of the finger boards after receiving verbal confirmation over the radio from the victim that the latches were open (Figure 6). At some point during the movement of stand 32, the fourth latch from the opening of the row on the lower finger board dropped into the closed position blocking the moving stand. Despite this obstruction, the arms of the MHR continued to retract. Claws around the pipe on the lower guide head remained closed during this retraction and the pipe began to bow. As the bow in the pipe increased, the bottom of the pipe was pulled in an upward direction against the inside of the claws. 3 Each pipe has a hand written number placed on it to aid the Driller in keeping track of the drill strings total length. A pipe stand had been damaged during the PSA’s previous drilling operation and pulled from service removing it from the sequence. 4 Doping refers to the process of applying a lubricant to the pipe threads. This aids in a proper connection between pipes. 9 The lower guide head had retracted approximately four feet from directly under the obstructing latch. Under the strain of force the lower guide head aft gate opened freeing the pipe. The stored energy from the bowing of the pipe was suddenly released. The victim by this time had moved directly into the path of the pipe between the MHR and the setback area. The pipe struck him before it impacted other pipe stands and a horizontal steel beam at the rear of the setback area. The jarring sound of the impact alerted other crew members on the drill floor and at 10:11 a.m. operations were halted. The injuries sustained by the victim were described by coworkers who came to his aide as immediate and obviously fatal. From the start of the sequence to move stand 32 to the time the victim was struck, 6-8 seconds had passed. Figure 6 - View from drill floor. Stand #32 is obstructed by latch on lower finger board. 10 BSEE Investigation & Findings At approximately 11:00 a.m. on October 20, 2015, a representative from Chevron U.S.A. notified the BSEE, Lake Jackson District that a fatality had occurred during operations onboard the PSA. BSEE and United States Coast Guard personnel travelled to the PSA later that same day to begin the investigation into the incident. The BSEE/USCG team collected pertinent records, conducted preliminary interviews of personnel, and documented the incident area with photographs. BSEE’s Panel was convened to conduct the full investigation into the facts and circumstances that resulted in a fatality. Panel members travelled to the PSA to complete documentation of the incident location and speak to onboard crew members. The BSEE Panel reviewed electronic and written material, including but not limited to data, emails and other records related to operations on the PSA. The BSEE Panel conducted interviews of personnel and observed testing of involved equipment. The Victim The victim was a 34 year old man from Hope, Maine and had been employed by Pacific Drilling since January 4, 2015. The job onboard the PSA was the victim’s first in the offshore oil and gas industry. As is normal with personnel new to the industry, the victim began work as a roustabout. In this entry level position the victim would work as a rigger on crane operations, perform general maintenance, and would assist the drill floor crew. The crew on the PSA worked in 28 day hitches5. October 20th was day 20 of the victim’s hitch. The victim was noted to be an enthusiastic worker. When operations allowed, the victim voluntarily trained with the drill floor crew. This training and work resulted in the victim being promoted to floor hand. The day the victim was killed, was the first day in that new position. The victim was attended to by co-workers and the ships medic within minutes6 of the incident. The medic reported the injuries he observed were traumatic and “incompatible with the sustainment of life.” The victim’s body was flown from the PSA and ultimately taken to the Lafourche Parish (Louisiana) Coroner’s Office. An autopsy report summarized the cause of death to have been blunt force trauma to the skull. 5 Offshore workers schedules follow multiple day rotations. For this crew the schedule was 28 days on, and 28 days off. Each worker would work a 12 hour tour (shift)/day. 6 Records from Pacific Drilling show that the medic was summoned at 10:12 a.m. and arrived on the drill floor at 10:15 a.m. 11 October 20th Tripping in the Hole Prior to starting their tour, the drill crew, including the victim attended a pre-job safety meeting at 11:30 p.m. on October 19th. This meeting encompassed all of the different crews on the PSA that would be working various tasks over the next 12 hours. The victim’s crew then held a job specific meeting and began the task of changing out equipment on the drill floor in order to run the 6⅝ inch drill pipe. The equipment change out was completed by 5:30 a.m. Led by the Driller, an additional pre job safety meeting (PJSM) was held by the drill crew to TIH with the 6⅝ inch pipe. The victim was assigned the task of spotting for the AD who operated the MHR to pull pipe stored in the auxiliary setback area. Additionally, the victim was tasked with re-numbering pipe, doping the pipe threads, and cleaning any residual mud7 that dropped from the pipe stands when they were lifted. The cleaning and doping were normal things done while TIH. The renumbering, although not unusual, was specific to the use of the 6⅝ inch on this operation. When the pipe was being pulled out of the hole and stored from its last use, thread on one section was found to be damaged. That stand of pipe was removed from use, requiring the renumbering8. A Task Risk Assessment (TRA) for the TIH operation was completed and signed by each member of the drill floor crew during the PJSM. The BSEE Panel’s review of the TRA showed that tasks and risks noted were broad and encompassing of the overall TIH operation. Each member of the drill floor crew had a different responsibility during the operation. Tasks and risks associated were not specific to the positions. The TRA did call for a spotter to confirm the position of the latches; however, the additional duties assigned to the victim were not identified on the TRA. During the operation, both the Driller and AD were in the chairs facing the main drill center. Pipe stands being run through the main drill center were stored in the auxiliary setback area and not in the direct line of sight of either the Driller or AD (Figure 7). At various times during this operation, members of the drill crew recalled seeing the victim performing his assigned tasks. One crew member recalled to the Panel that he had seen the victim in the setback area, but that it was when the MHR was at the main drill center. Neither the AD nor other floor hands had a direct line of sight to where the victim was working, and communication between the crew was conducted by using hand held radios. The AD, Driller and other floor hands stated to the Panel that they heard the victim say over the radio that the latches were open prior to hearing the sound of the recoiling pipe. 7 Drilling fluid, or mud, sometimes remains inside the drill pipe when it is pulled out of the hole. This occurred on October 10, 2015 while pulling out of the hole (POOH) at another drilling location. The 6⅝ inch pipe had not been used since then until the day of the incident. 8 12 Figure 7- The view from the Main Side AD control chair, looking towards the auxiliary setback area. During TIH operations the driller would be occupying the other chair. 13 Figure 8 – Fingerboard latches. Note the latch in the up (open) position. The silver top of the piston rod can be seen pulled down. Lower Fingerboard Row 46 Latch # 4 The fingerboard latch assembly consists of a spring loaded piston that when air pressure is applied, pulls a rod into the cylinder body raising the latch (Figure 8). When there is insufficient pressure on the rod end of the piston to overcome the force of the spring the latch will close. This means that if there was a loss in air pressure, the latches would remain closed and the pipe stands will be secured (Figure 9). On October 20th from 7:30 a.m. until the incident occurred, 31 stands of pipe had been retrieved from the auxiliary setback area. Stand 32 was located in slot 8 of row 46 in the fingerboard. Over the course of TIH operation, latch 4 in row 46 had functioned 4 times prior to retrieving stand 32. 14 As stand 32 was being retrieved, latch 4 closed. The force applied to the latch by stand 32 caused the latch to twist on its mount, but it did not break free or open. At the conclusion of the onsite visit to the PSA by the BSEE Panel, latch 4 was removed for testing. Pacific Drilling contracted Stress Engineering Services (SES) in Houston, TX to conduct testing on the latch. BSEE Panel members reviewed the proposed testing protocols and witnessed the testing over multiple days. After the tests, it was concluded the latch initially opened when air pressure was supplied; then immediately closed due to a leaking rod seal and pressure building up on the backside of the piston. During testing of the incident latch, it was found that air was flowing through the vent on the cylinder when air was supplied. This means air was flowing by the piston, due to the rod seal leak, at a faster rate than air flowing out of the vent. The vent on the cylinder is there to prevent pressure building up on the backside of the piston. When there is not significant pressure build up on the rod end of the piston the spring will extend the rod out of the cylinder, closing the latch. Figure 9 – Latch Cylinder Drawing 15 Dropped Object Hazard During interviews, members of the crew explained the hazard they were concerned with regarding the latches was one could break free and drop to the drill floor. Pacific Drilling provided the BSEE Panel an information bulletin sent out by the HR manufacturer, NOV. This bulletin highlighted there were past instances when a latch would not fully open or would close unexpectedly. It was for this reason the bulletin recommended the position of the latch be visually verified. Worker Training Onboard the PSA, a short service employee (SSE) would be anyone with less than six months experience on the ship. So other crew members would be aware of a person’s experience level, SSE’s on the PSA would wear a green hard hat instead of the normal white. After the six month mark, the employee would wear the white hard hat. This only applied to personnel new to the PSA and not to a new position on the ship. The BSEE Panel reviewed training records for the victim provided by Pacific Drilling. The records showed that although the victim had completed a number of the training modules required by Pacific Drilling, none of the modules were specific to the operational tasks performed by a floor hand. Pacific Drilling conducted on the job training (OJT) in which a person in training would “shadow” a more experienced worker on a particular crew. If a person in training performed satisfactorily, they would be evaluated by the supervisor prior to any advancement. In the case of the victim, performance was evaluated by the Driller who approved and made a recommendation for promotion. There was not, however, clear documentation of this OJT program. No determinations could be made as to when the victim had been trained on specific tasks or to what proficiency. Members of the crew, when interviewed, indicated they had all trained as and worked as spotters during pipe handling operations. Crew members would relieve each other for breaks and meals based on the tasks being performed. During the Panel’s site visit to the PSA, crew members were asked to demonstrate how the spotter would perform their task. Since the MHR was going to move from the auxiliary setback area towards stern, it was demonstrated to the Panel the spotter would stand next to the MHR base. From this position, the spotter could see up to the fingerboards and the latches. Once the pipe had been gripped and the arms retracted, the MHR would rotate in a clockwise direction9 before moving down a track to the main well center. 9 This properly orients the pipe string so that it can be lowered to the drill center. 16 The Panel found there was no standard practice as to when a person could enter the setback area during pipe handling operations. The floor hands interviewed all indicated that movement into the setback area while the stands were being moved was not allowed. However, determining exactly when it was safe to move into the setback area varied. Operation of the Hydra Racker The rows and slots for the stands needed for a particular operation are predetermined and loaded into the HR controls. The system is calibrated so once a command to move is input by the AD, the arms would secure at the proper points on the stand. The system displays the weight of the stand, and would shut down if an attempt was made to lift a stand exceeding the maximum weight set point. There was not, however, any way to display if during operation there was any resistance to the lateral movement of the stand. The system would also shut down if there was more than 11.8 inches difference in alignment between the upper and lower guide heads. Despite the resistance encountered the guide heads alignment did not exceed this limit during movement of stand 32. The AD during the TIH operation was seated in the far left seat in the drill shack. This was the farthest station from the auxiliary setback area where the victim was working. The AD, not having a direct line of sight, relied on radio communication with the victim (Figure 10). The MHR did have a video camera mounted on its base. However, the camera was used primarily to confirm alignment with the targeted stand and when a connection was being made at the drill center with the hydra tongs. A second camera on the MHR had been located higher near the upper guide arm and used in a similar manner. This camera had reportedly been broken off during a prior operation and had not yet been replaced. Regardless, neither camera would show the fingerboards or the setback area. Figure 10 – Incident Location Plan View 17 Conclusions The conclusions of direct and contributing factors reached by the BSEE Panel are based on the observations made during the investigation, interviews that were conducted and a review of documentation collected from Pacific Drilling and Chevron. Taking into account the totality of circumstances, the Panel concluded that the death of the victim was the direct result of moving into the setback area and into the path of the pipe stand being held under tension when a latch on the lower fingerboard closed. The Panel believes that the victim had correctly observed and communicated that the latches were open. After making this report, the victim went on to other tasks which had been assigned to him taking his attention from the fingerboards before the pipe stand cleared the last latch. Post incident testing of the latch did show that a faulty seal on the latch cylinder allowed the latch to drop back into the closed position. However, if the victim had not moved into the setback area at the critical time, he would have been clear of the pipe when it recoiled from the lower arm of the HR. It is the conclusion of the panel that the multiple tasks assigned to the victim required that he enter the setback area. His inexperience and lack of consistent training about when it was permissible to enter the setback area may have contributed to the victim’s decision to step in when he did. The Panel also concluded that the assignment of additional tasks to the victim was made without consideration as to how those tasks contributed to risk. None of the tasks were listed on the TRA prepared before the operation began. The victim was also performing all of his duties out of the direct view of supervisors or other more experienced co-workers. Despite being his first day in the new position, there was no follow up or observation made to determine if he was performing the tasks in a safe manner. 18 Recommendations Based on the findings from this investigation, the BSEE Panel recommends companies operating on the U.S. Outer Continental Shelf consider the following to further protect health, safety, property and the environment. Pre-Job Safety Analysis: The BSEE Panel recommends that all tasks included in an operation be evaluated for risks. Evaluations should include how planned tasks relate to each other. On The Job Training (OJT): Although an effective means for training, the BSEE Panel recommends that OJT programs be reviewed. Consideration should be made to formalize OJT programs to provide continuity between those conducting the training. Short Service Employees (SSE): Most SSE supervision programs focus on personnel new to work offshore. The BSEE Panel recommends that management controls of SSE programs be evaluated and personnel new to a position should also be specifically addressed in these programs. Finger Board Spotter: The BSEE Panel recommends that operations which use a spotter to verify the position of finger board latches review where that task is performed. Consideration should be made to the positioning of the spotter and their proximity to the moving pipe stands. No tasks should be assigned to the spotter that places them in setback areas during pipe handling operations. 19