The US Coast Guard updated decades old regulations regarding offshore cranes and inspection practices. Anthresia McWashington takes a look at the changes to come.
The US Coast Guard (USCG) recently proposed revisions to the design, certification, inspection, and testing of cranes installed on Mobile Offshore Drilling Units (MODU), Offshore Supply Vessels (OSV), and floating Outer Continental Shelf (OCS) facilities. The USCG also proposed bringing in organizations other than USGC marine inspectors to certify, inspect, and test cranes.
Image: The USCG defines a crane as an offshore pedestal with a minimal lifting capacity of 5-ton. (Photo: Huisman)
The regulations proposed in May will affect businesses that own OSVs with cranes that have a minimum lifting capacity five tons (10,000 lb); businesses that own MODUs with cranes; and businesses that own 18 floating OCS facilities. In all, 2 cargo gear organizations, 19 crane manufacturers, and about 7 classification societies will be affected by the changes.
Until the passage of the 1996 Coast Guard Authorization Act (Pub. L. 104- 324, 110 Stat. 3901), the USCG could only delegate marine safety functions related to vessel plan review and inspection to the American Bureau of Shipping (ABS), and the International Cargo Gear Bureau (ICGB). Section 607 of Pub. L. 104-324 amended 46 U.S.C. 3316 to allow delegation of these functions to international classification societies.
Revisions also authorize the USCG to approve organizations other than the ABS and the ICGB as crane-certifying authorities.
The USCG expects that the additional classification societies will reduce crane operational down time, and allow greater flexibility in scheduling crane inspections and meeting required standards. Before any classification society can be delegated authority under this amendment to act on behalf of the USCG for any purpose, the statute requires that the classification society be recognized by the USCG.
According to the USCG, using outside organizations for crane approvals and inspections has proven successful on other USCG inspected vessels. The USCG has verified that these organizations have personnel who are specifically trained and qualified to witness tests of cranes and conduct crane inspections, and that these inspections can be scheduled more conveniently than inspections by the USCG.
ABS Vice President of Offshore Technology Bret Montaruli, said that this update in crane regulations is essential in improving day-to-day operations offshore.
“The USCG is introducing new regulations to address safety issues because it is important in a rapidly-changing market to make sure rules are in line with industry needs,” Montaruli said. “ABS takes a similar approach, gathering input from industry experts to develop guidance like Guide for Certification of Lifting Appliances to help companies work safely as the work environment and the government rules change.
“It is an ongoing effort to keep pace with changes in the industry and to make sure the framework is in place for publishing Guide and Rule updates when they are needed,” he said.
In addition to expanding the number of crane-certifying authorities, the proposed revisions include an explanation of the term “crane,”—defining it as offshore pedestal cranes with a minimal lifting capacity of five tons that would be listed in the Crane Record Book (CRB).
Image: Subsea7's construction vessel Seven Borealis had its 5000-tonne offshore mast crane installed by Huisman in Schiedam, Netherlands, in 2011. (Photo: Huisman)
Comments regarding the new proposals closed on August 12, and despite some companies’ concerns that sections of the revisions regarding crane regulations are inconsistent, the USCG insists that the current regulations are outdated and scarcely used within the industry, indicating the necessity for revisions.
As an example, Alan Spackman, IADC vice president of the offshore division, pointed out a conflicting statement in the USCG’s clarification of the types of cranes that will be affected.
“They [USCG] define cranes as having a lifting capacity of more than five tons, but later state that they want something less than five tons,” Spackman said. “We’re just trying to get clarity as to what they actually want the records on, and make sure that the regulations are clear.”
American Petroleum Institute (API) spokesman Brian Straessle said that API agreed that the new rule is necessary; however, the organization believes a few technical edits would help clarify certain requirements.
In a August 12th letter to the USCG, API’s Director of Standards, David Miller said: “This proposed rule is necessary to enhance the safety of offshore cranes by ensuring that industry uses the best available and safest technologies for the operation, maintenance, design, and construction of cranes used on MODUs, OSVs, and floating OCS facilities.
“The proposed rule would also align Coast Guard regulations with Bureau of Safety and Environmental Enforcement requirements for cranes used on offshore fixed platforms.
“Additionally, the proposed rule would provide owners and operators of vessels the option and flexibility of using additional organizations and associations for the certification of cranes.”
According to the US Federal Register, the USCG points out that current regulations reference the first edition of API’s Recommended Practice for Operation and Maintenance of Offshore Cranes, published in October 1972, and the second edition of API’s Specification for the Offshore Pedestal Mounted Cranes, published in February 1971.
The USCG’s proposal updates these regulations by adopting more recent editions of the API Spec. 2c and RP 2D standards.
The proposed rules would also cause affected parties to include training, purchase API standards, and inspecting or reviewing operations in order to be in regulation. The USCG projects the costs of the proposal to be highest in the first year of compliance, at about US$886,000 (undiscounted 2011 US$), with additional annually recurring costs.
For the 10-year period of this analysis, the USCG estimates the annualized discounted cost of this proposed rule to be $445,000 at a 7% discount rate for a total of $3.12 million over 10 years, and $435,000 at a 3% discount rate for a total of $3.71 million over 10 years.
If approved, the implementation of these regulations could take place at any time; however, Charlie Papavizas, partner in the Winston and Strawn LLP law firm, said that there is no certainty to when updates will be put into effect. “In my recollection, these regulations were first required in the 2010 Coast Guard Act,” Papavizas said. “Updates will be enforced immediately upon effective date of the rule—sometime in the future after comments are received and analyzed.” OE