Russell Hoshman Minerals Management Service Gulf of Mexico OCS Region

1.  Russell Hoshman Minerals Management Service Gulf of Mexico � OCS Region

2. Regulatory Authority The Minerals Management Service (MMS) is the regulatory body responsible for crane safety and operations on fixed platforms on the Outer Continental Shelf (OCS) of the United States of America. The United States Coast Guard (USCG) is the regulatory body responsible for crane safety on Mobile Offshore Drilling Units (MODU) and floating production facilities. The MMS is responsible for lifting and hoisting equipment associated with the derrick even on floating facilities. Slide 2: Regulatory Authority Read slide The MMS does not inspect cranes under the authority of the USCG but we do gather information on accidents that happen on OCS facilities. OCS facilities are any installation permanently or temporarily attached to the seabed and erected for the purpose of exploring for, developing, producing and transporting resources from the OCS. Ships and vessels used for transporting hydrocarbons are not OCS facilities. The relationship between the MMS and the USCG on OCS facilities is governed by an agreement between the agencies called the Memorandum of Understanding. Slide 2: Regulatory Authority Read slide The MMS does not inspect cranes under the authority of the USCG but we do gather information on accidents that happen on OCS facilities. OCS facilities are any installation permanently or temporarily attached to the seabed and erected for the purpose of exploring for, developing, producing and transporting resources from the OCS. Ships and vessels used for transporting hydrocarbons are not OCS facilities. The relationship between the MMS and the USCG on OCS facilities is governed by an agreement between the agencies called the Memorandum of Understanding.

3. Overview Statistics and trend analysis for crane, material and personnel handling incidents, injuries, and fatalities in the Gulf of Mexico since 1998. Action taken by the MMS, American Petroleum Institute (API) and industry to improve lifting safety since 1998. Plans by the MMS and industry (API) to improve lifting safety. Slide 3: Overview Read slideSlide 3: Overview Read slide

4. Basis for Regulations MMS Regulations API Recommended Practice (RP) 2D, Fourth Edition API Specification (SPEC) 2C, Fifth Edition USCG Regulations API Recommended Practice (RP) 2D, First Edition API Specification (SPEC) 2C, Second Edition Slide 4: Basis for Regulations Read slides API RP 2D is the Recommended Practice for Operation and Maintenance of Offshore Cranes API Spec 2C is the Specifications for Offshore Pedestal Mounted Cranes (includes instructions form load chart calculation) The basis regulation by both organizations is fundamentally the same. At the end of the presentation is a list of both the MMS and USCG regulation. Note: 2C second edition published1972Slide 4: Basis for Regulations Read slides API RP 2D is the Recommended Practice for Operation and Maintenance of Offshore Cranes API Spec 2C is the Specifications for Offshore Pedestal Mounted Cranes (includes instructions form load chart calculation) The basis regulation by both organizations is fundamentally the same. At the end of the presentation is a list of both the MMS and USCG regulation. Note: 2C second edition published1972

5. How Many Cranes? 2440 pedestal mounted cranes on 4093 fixed and floating production facilities operating in the Gulf of Mexico. Average of 158 platform rigs and MODUs operating in the Gulf of Mexico since 1998. Slide 5: How Many Cranes Read slide Slide 5: How Many Cranes Read slide

6. Types of Production Facilities Caissons 1200 Compliant Towers 3 Fixed-Leg Platforms 2406 Mobile Production Units 2 Mini-Tension Leg Platforms 4 Semi-Submersibles 1 Spars 9 Tension Leg Platforms 8 Well Protectors 460 Slide 6: Types of Production Facilities 1200 Caissons. Caissons are a single piece of structural pipe that supports a well in up to 200 feet of water and may or may not be braced. 15% of the existing caissons have a crane. 3 Compliant Towers. 1000� to 1750� 2406 Fixed Leg Platforms. Less that 1350� 2 Mobil Production Units (Made from Drilling Jackups) 4 Mini Tension Leg Platforms 1 Semi Submersible (6300�) 9 Spars (1900� to 5600�) 8 Tension Leg Platforms (500� to 5000�) 460 Well Protectors. Well protectors are small fixed platforms that support less than 6 well with no more than 2 pieces of production equipment. 35% of the Well Protectors have a crane. Slide 6: Types of Production Facilities 1200 Caissons. Caissons are a single piece of structural pipe that supports a well in up to 200 feet of water and may or may not be braced. 15% of the existing caissons have a crane. 3 Compliant Towers. 1000� to 1750� 2406 Fixed Leg Platforms. Less that 1350� 2 Mobil Production Units (Made from Drilling Jackups) 4 Mini Tension Leg Platforms 1 Semi Submersible (6300�) 9 Spars (1900� to 5600�) 8 Tension Leg Platforms (500� to 5000�) 460 Well Protectors. Well protectors are small fixed platforms that support less than 6 well with no more than 2 pieces of production equipment. 35% of the Well Protectors have a crane.

7. How Old are These Cranes? Slide 7: How Old Are These Cranes A 2003 crane survey indicates that 38% of the existing cranes were built before 1983 and are more than 21 years ago. Cranes built before 1983 under MMS authority currently not required to have dynamic load charts. Of all the crane currently in the GOM, 12% of these cranes are replacement cranes. These are older cranes that have been replaced because of age. Slide 7: How Old Are These Cranes A 2003 crane survey indicates that 38% of the existing cranes were built before 1983 and are more than 21 years ago. Cranes built before 1983 under MMS authority currently not required to have dynamic load charts. Of all the crane currently in the GOM, 12% of these cranes are replacement cranes. These are older cranes that have been replaced because of age.

8. Why is the MMS Concerned? Since 1998, lifting of materials and personnel on fixed platforms, MODUs and floating facilities has accounted for 18% of all injuries 28% of all fatalities in the Gulf of Mexico. Slide 8: Why is the MMS Concerned Read slide Slide 8: Why is the MMS Concerned Read slide

9. Rig and Non-Rig Related Lifting1998 - 2003 Slide 9: Rig and Non-Rig Related Lifting 1998 � 2003 Read slides This indicates that over half of all lifting incident are associated with rig activity because this is where the lifting and material handling activity is. This is not an indication that lifting associated with rig activity is any more or less dangerous than production activities. Slide 9: Rig and Non-Rig Related Lifting 1998 � 2003 Read slides This indicates that over half of all lifting incident are associated with rig activity because this is where the lifting and material handling activity is. This is not an indication that lifting associated with rig activity is any more or less dangerous than production activities.

10. All Crane and Material Handling Incidents, Injuries and Fatalities in the GOM Slide 10: All Crane, Material and Personnel Handling Incidents, Injuries and Fatalities in the GOM. Incidents are accident involving mechanical damage or injury or fatalities. One Incident may have more than one injury or fatality. Injuries are incidents involving lost time accidents. This plot shows the current downward accident trend Slide 10: All Crane, Material and Personnel Handling Incidents, Injuries and Fatalities in the GOM. Incidents are accident involving mechanical damage or injury or fatalities. One Incident may have more than one injury or fatality. Injuries are incidents involving lost time accidents. This plot shows the current downward accident trend

11. Drilling and Workover Lifting Incidents Compared to Annual Rig Activity Slide 11: Drilling and Workover Lifting Incidents Compared to Annual Rig Activity Was able to isolate the rig related lifting accidents. The red line shows the annual average yearly rig count in the GOM It is clear that there is a correlation between the numbers of incidents and the rig count and that part of the decline is due to the declining rig count Adjusting for the rig count, the ratios of incidents per rig show that there is a actual decline in Lifting Accidents. Slide 11: Drilling and Workover Lifting Incidents Compared to Annual Rig Activity Was able to isolate the rig related lifting accidents. The red line shows the annual average yearly rig count in the GOM It is clear that there is a correlation between the numbers of incidents and the rig count and that part of the decline is due to the declining rig count Adjusting for the rig count, the ratios of incidents per rig show that there is a actual decline in Lifting Accidents.

12. All Lifting IncidentsCrane and Non-Crane1998 - 2003 Crane Non-Crane Incident 76% 24% Injuries 68% 32% Fatalities 54% 46% Slide 12: All Lifting Incidents Crane and Non-Crane 1998 � 2003 Interesting point is that the Non Crane Fatalities is almost as high as the crane fatalities. Slide 12: All Lifting Incidents Crane and Non-Crane 1998 � 2003 Interesting point is that the Non Crane Fatalities is almost as high as the crane fatalities.

13. Crane IncidentsRig and Non-Rig Related1998 - 2003 Rig Non-Rig Incident 49% 51% Injuries 50% 50% Fatalities 43% 57% Slide 13: Crane Incidents Rig and Non-Rig Related 1998 � 2003 158 rigs vs 2440 production cranes. Of the Crane Incidents shown, 56% involved Human Error and 51% involved Equipment failure. Slide 13: Crane Incidents Rig and Non-Rig Related 1998 � 2003 158 rigs vs 2440 production cranes. Of the Crane Incidents shown, 56% involved Human Error and 51% involved Equipment failure.

14. Is Crane Age a Factor? 89% of all Crane Incidents on MODU�s in the last 6 years in the GOM involved MODU�s built before 1983. Estimated 68% of all MODU�s in the world were built before 1983. Slide 14: Is Crane Age a Factor? This is a question that I wish that I could answer but I do not have the direct data. Just because the MODU was built before 1983 does not mean that the crane currently in use is also pre 1983. The estimation of the age of all MODU�s is based on a sample of 285 MODU�s. This does not mean that the MODU�s used in the GOM are the same age. This is an indirect indication that crane age may be a factor. Slide 14: Is Crane Age a Factor? This is a question that I wish that I could answer but I do not have the direct data. Just because the MODU was built before 1983 does not mean that the crane currently in use is also pre 1983. The estimation of the age of all MODU�s is based on a sample of 285 MODU�s. This does not mean that the MODU�s used in the GOM are the same age. This is an indirect indication that crane age may be a factor.

15. What is Material Handling? Non-Crane Material handling is the movement of personnel or equipment on a facility or MODU from point to point. Listed below are just a few pieces of equipment that are commonly utilized for material handling purposes: Overhead Rail Crane Jig Crane BOP Hoist Air Hoist Come-a-long Chain Fall Hoist Slide 15: What is Material Handling Read slide In my material handling statictis, I did not include pipe handling such as elevators, pipe tonges and draw works. This is a separate topic. Slide 15: What is Material Handling Read slide In my material handling statictis, I did not include pipe handling such as elevators, pipe tonges and draw works. This is a separate topic.

16. Non-Crane Material and Personnel Handling IncidentsRig and Non-Rig Related Rig Non-Rig Incident 74% 26% Injuries 74% 26% Fatalities 83% 17% Slide 16: Non Crane Material and Personnel Handling Incidents, Rig and Non-Rig Related. Read slide Rigs are where the material and personnel handling incidents occur because this is where the material and personnel handling activity is. Slide 16: Non Crane Material and Personnel Handling Incidents, Rig and Non-Rig Related. Read slide Rigs are where the material and personnel handling incidents occur because this is where the material and personnel handling activity is.

17. Equipment Used In Material Handling Incidents Slide 17: Equipment Used in Material Handling Incidents Read slide The air hoist is by for the most accident prone piece of equipment. Pipe handling is shown here for comparison but is not part of previous statistics. (pipe tongs, power tongs, draw works, elevators) Some of the others manual winch, chain fall hoist, scissor lift etc. Slide 17: Equipment Used in Material Handling Incidents Read slide The air hoist is by for the most accident prone piece of equipment. Pipe handling is shown here for comparison but is not part of previous statistics. (pipe tongs, power tongs, draw works, elevators) Some of the others manual winch, chain fall hoist, scissor lift etc.

18. Injuries by Equipment Used In Material Handling Incidents Slide 18: Injuries by Equipment Used in Material Handling Incidents The air hoist is the big offender. 6 or the 15 Air Hoist injuries involved using the air hoist to lift a man into the derrick. Slide 18: Injuries by Equipment Used in Material Handling Incidents The air hoist is the big offender. 6 or the 15 Air Hoist injuries involved using the air hoist to lift a man into the derrick.

19. Fatalities by Equipment Used In Material Handling Incidents Slide 19: Fatalities by Equipment Used in Material Handling Incidents Read slide Again the air hoist is the big offender. 2 of the 4 Air Hoist deaths involved lifting a man into the derrick. Air Hoist + BOP Hoist account for 75% of Fatalities for Non-Crane Material Handling. Slide 19: Fatalities by Equipment Used in Material Handling Incidents Read slide Again the air hoist is the big offender. 2 of the 4 Air Hoist deaths involved lifting a man into the derrick. Air Hoist + BOP Hoist account for 75% of Fatalities for Non-Crane Material Handling.

20. MMS Crane Work Group Four crane fatalities in OCS waters in 1998 moved the MMS to form a Crane Work Group to review accident trends and make recommended changes in crane policies. Slide 20: MMS Crane Work Group Read slide MMS regulations are aimed at fixed platforms only Slide 20: MMS Crane Work Group Read slide MMS regulations are aimed at fixed platforms only

21. Activities Since 1998 1998 The MMS Crane Group identified that a large percentage of crane related injuries on fixed platforms involved personnel associated with rigging. 1999 The API revised the API Recommended Practice (RP) 2D (4th Edition, August 1999) to include rigger training requirements. 2000 The MMS incorporated the new edition of API RP 2D into the regulation. Slide 21: Activity Since 1998 Read slide Slide 21: Activity Since 1998 Read slide

22. Activities Since 1998 The MMS, the API and industry sponsored Crane Workshops in 2000, 2001 and 2003 to help raise the awareness about crane accidents. Slide 22: Activity Since 1998 Read slide Slide 22: Activity Since 1998 Read slide

23. Activities Since 1998 2003 - MMS incorporated the 5th Edition of API Specification 2C. 2003 - MMS requires the installation of anti-two block devices on all cranes by March 2005. 2003 - API revised API RP 2D as the 5th Edition, June 2003, to include: Crane inspector training Positive locking latch on hooks used for personnel transfer Deck/structure evaluation for temporary cranes. Slide 23: Activity Since 1998 Read slide 2C 5th edition (1995) This is the first time that the MMS had adopted API Spec 2C. Before 2003 cranes were not required to be constructed to API 2C specifications. Anti-two block devices became a requirement after an Oct. 2000, IADC Safety Alert on the subject. In this safety alert, the IADC was recommending the use of anti-two block devices on all cranes. The MMS agreed. Slide 23: Activity Since 1998 Read slide 2C 5th edition (1995) This is the first time that the MMS had adopted API Spec 2C. Before 2003 cranes were not required to be constructed to API 2C specifications. Anti-two block devices became a requirement after an Oct. 2000, IADC Safety Alert on the subject. In this safety alert, the IADC was recommending the use of anti-two block devices on all cranes. The MMS agreed.

24. Activities Since 1998 2004 - API revised API SPEC 2C as the 6th Edition, March 2004. The dynamic load calculation section was expanded. 2004 - MMS developed a crane and material handling incident data base. 2004 - MMS developed a standardized list of data for crane accident investigations involving serious injuries and fatalities. Slide 24: Activity Since 1998 Read slide The data base will help to identify trends and relationships. This will be available to the public. By reviewing the existing data we have realized that we have not been asking all the right questions when an accident occurs. Slide 24: Activity Since 1998 Read slide The data base will help to identify trends and relationships. This will be available to the public. By reviewing the existing data we have realized that we have not been asking all the right questions when an accident occurs.

25. MMS Future Actions Cosponsoring an API Conference on Safety and Environmental Management Programs (SEMP), Rigging and Fall Protection Safety, on June 29 & 30, 2004, in Houston, Texas. Latest edition of API RP 2D and Specification 2C will be evaluated for possible incorporation into the regulations. Slide 25: MM Future Actions Read slide If interested in this conference information can be found on API web site. Based on API RP 75. Addresses the identification of management of safety and environmental hazards in design, construction, startup, operation and maintenance of new, existing or modified drilling and production facilities. Slide 25: MM Future Actions Read slide If interested in this conference information can be found on API web site. Based on API RP 75. Addresses the identification of management of safety and environmental hazards in design, construction, startup, operation and maintenance of new, existing or modified drilling and production facilities.

26. MMS Future Actions New regulation or revision of API RP 2D to require that all cranes regardless of the date of manufacture will have both a static and a dynamic load chart calculated in accordance with API Specification 2C. Reviewing a proposed regulation that would require cranes to be load tested once every 5 years. Slide 26: MM Future Actions 5 year load testing is currently the requirement of the USCG not the MMS.Slide 26: MM Future Actions 5 year load testing is currently the requirement of the USCG not the MMS.

27. MMS Future Actions MMS is currently reviewing existing standards and regulations by other agencies for possible incorporation into MMS regulation for non-crane material and personnel handling. Possible Crane Workshop in 2005. Slide 27: MM Future Actions Read slide The current MMS regulation is �You must operate and maintain all material handling equipment in a manner that ensures safe operation and prevents pollution.� There are no incorporated material handling standards. Slide 27: MM Future Actions Read slide The current MMS regulation is �You must operate and maintain all material handling equipment in a manner that ensures safe operation and prevents pollution.� There are no incorporated material handling standards.

28. Comments / Questions Russell Hoshman Phone: 504-736-2627 russell.hoshman@mms.gov OFFSHORE CRANE SAFTY WEBSITE IS LOCATED AT: http://www.mms.gov/cranes MMS CRANE GROUP CONTACT Wilbon Rhome 703-787-1587 Slide 28: Comments and Questions This presentation can be located at this web site along with the presentations from the last Crane Work Shop. Slide 28: Comments and Questions This presentation can be located at this web site along with the presentations from the last Crane Work Shop.

29. Current MMS Regulations Cranes - 30 CFR 250.108 (a) All cranes on fixed platforms must operate according to API Recommended Practice (RP) 2D, 4th Edition. - 30 CFR 250.108 (b) All cranes on fixed platforms must be equipped with anti-two block devices by March 16, 2005.

30. Current MMS Regulations Cranes -30 CFR 250.108 (c) If a fixed platform is installed after March 17, 2003, all cranes on the platform must meet the requirements of API Spec 2C, 5th edition. -30 CFR 250.108 (d) All cranes manufactured after March 17, 2003, and installed on a fixed platform must meet the requirements of API Spec 2C, 5th edition.

31. Current MMS Regulations Cranes -30 CFR 250.108 (e) You must maintain record specific to a crane as follows: *Design, construction and anti-two block for life of the crane. *Inspection, testing and maintenance records for 4 years. *Qualification records: crane operators and riggers for 4 years.

32. Current MMS Regulations Material Handling - 30 CFR 250.108(f) � You must operate and maintain all other material handling equipment in a manner that ensures safe operations and prevents pollution. - No incorporated material handling standards.

33. Summary of USCG Regulations 46 CFR 107.231 Inspection for certification 46 CFR 107.258 Crane certification 46 CFR 107.259 Crane inspection and testing 46 CFR 107.260 Rated load test for cranes 46 CFR 107.309 Crane plans and information Slide 32: Summary of USCG Regulations Inspection and certification Crane certification. USCG will accept certification issued by the American Bureau of Shipping or the International Cargo Gear Bureau Crane inspection and testing. Each crane must be tested and inspected per API RP 2D, First Edition (Oct. 1972) except load rating test must be performed according to Sec. 107.260 Rated load test for cranes. Specifies proof loads to be used and when the crane is to be load tested. When installed, each 60 months and after structural repairs or alterations. Crane plans and information. All design calculation, installation plans and testing programs. Slide 32: Summary of USCG Regulations Inspection and certification Crane certification. USCG will accept certification issued by the American Bureau of Shipping or the International Cargo Gear Bureau Crane inspection and testing. Each crane must be tested and inspected per API RP 2D, First Edition (Oct. 1972) except load rating test must be performed according to Sec. 107.260 Rated load test for cranes. Specifies proof loads to be used and when the crane is to be load tested. When installed, each 60 months and after structural repairs or alterations. Crane plans and information. All design calculation, installation plans and testing programs.

34. Summary of USCG Regulations 46 CFR 108.601 Crane design 46 CFR 109.437 Crane record book 46 CFR 109.521 Crane General 46 CFR 109.525 Crane working load 46 CFR 109.527 Crane Operator Designation Slide 34: Summary of USCG Regulations Crane design. Designed in accordance with API Specification 2C, Second Edition with additional safety design requirement Crane Record Book. Record keeping requirements Crane general. Crane to be operated and maintained in accordance with API PR 2D, First Edition with supplement 1 Crane working Load. Describes the load charts Crane operator designation. Who can designate a crane operator and only designated crane operators can operate the crane. Slide 34: Summary of USCG Regulations Crane design. Designed in accordance with API Specification 2C, Second Edition with additional safety design requirement Crane Record Book. Record keeping requirements Crane general. Crane to be operated and maintained in accordance with API PR 2D, First Edition with supplement 1 Crane working Load. Describes the load charts Crane operator designation. Who can designate a crane operator and only designated crane operators can operate the crane.