Wilfred Guidry

46 CFR 107.111 The API RP 2 D 7th edition has similar wording in the Scope 1.2 b) Shipboard applications; these cranes (rated for 10,000 lbs [4536] or more) are mounted on surfacetype vessels and are used to move materials, containers, ROV's, diving bells, pipeline, subsea components and other materials on the vessel, between vessels, into the sea or to the sea bed. The maintenance on cranes [defined in 7th edition]as power operated equipment that can hoist, lower, slew, and horizonatilly move a suspended load] should not be limited to only those above the 10,000 lb capacity. vessel using cranes By not requiring any maintenance per the intent of the document is a cost factor and not a safety factor. All CRANES with the defination shall be maintained according to manufacturers recomendations and observant to the API RP 2 D 6th edition requirements. I have argued this addition to the RP 2 D 7th scope and the objection is from the OSV operators. My Comments were; All cranes on vessels shall meet the I.6.1 Cranes should be operated, maintained, tested, and inspected in accordance with this recommended practice and any recommendations specified by the manufacturer. I.6.2 Records of periodic tests and inspections should be maintained as required in Section 5.2 and made available upon request