Thoughts and Concerns

	Human factors play a large role in crane accidents, the root cause of many accidents is human error
	Lack of experience can also be a factor, but serious accidents can occur even with experienced personnel
	Some of the cranes on platforms are in poor working condition
	Judgement of personnel involved in crane operations (operator, riggers, ship captain, and facility manager) may be influenced by pressure to get the job done

Regulations
 

	API RP 2D is a good document. Our use of RP 2D is a good example of performance based regulations.
	Potential additions or shortcomings of API RP 2D -- further define or specify minimum experience requirements for operators and riggers (we noted that there is no mention of training for persons assisting the crane operator); clarify when operator or inspector should take crane out of service; and discuss operating limits or curtailment criteria for rough sea state or poor weather conditions
	USCG regulations also use API RP 2D as the basis for their operation and maintenance requirements. USCG goes a couple of steps further by requiring the certification of cranes and third-party inspection and testing.
	MMS should examine need for certification and third party inspections
	MMS needs to reexamine our PINC's to ensure that they adequately cover API RP 2D
	A good Safety and Environmental Management Plan should cover crane operations and address the above shortcomings.

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