Comment Log Display

August 20, 2012

Clerk of the Board, 
Air Resources Board
1001 I Street, 
Sacramento, California 95814

Subject:  Comments to Verification Procedures Regulation
(verdev2012).

Dear ARB:

As you are aware, the combined requirements of the On-Road Rule and
Off-Road Rule will soon require that all mobile cranes operating in
normal service throughout California be retrofitted with verified
diesel emission control systems (VDECS) in the very near future. 
As the deadlines approach, and the state’s crane owners begin to
undertake VDECSs retrofits, several serious safety and feasibility
issues have surfaced.  We have brought these issues to the
attention of the Mobile Source Control Division, and are pleased to
report that they have been very responsive to these issues and are
in the process of exploring them first hand.  Therefore, we wish to
use the current rulemaking to provide an update of the current
issues we believe to remain with regard to VDECS installations on
mobile cranes.

•	Cranes do little lifting and a lot of holding, idling, and
sitting.  We have provided staff with documentation from engine
manufactures that shows in our application the cranes and trucks
never get hot enough to meet minimum temperature requirements.   We
have likewise made several cranes available for exhaust temperature
mapping to illustrate this point. 

•	In addition to engine exhaust temperature, there is the issue of
safety regarding the active VDECS.  If there is a load on the hook,
OSHA regulations require that the engine remain on for safety
reasons.  The exhaust temperature of a passive VDECS cannot be
maintained in idle, and that a shutdown (including an automatic
shutdown) required by an active VDECS is not feasible. 

•	The crane body itself, i.e., the structural build, is engineered
and in “ANSI & ASME Code Compliance” as a lifting machine, not a
driving vehicle.  As discussed, the total weight and the “Center of
Gravity”  is what makes the crane, a crane.  To our knowledge and
from our experience thus far, we have yet been able to get a
manufacture to approve and/or certify a repower or retrofit, as is
required by California and federal OSHA regulations. 

•	The crane owners believe that the manufacturers’ reluctance to
approve VDECS retrofits is directly related to the weight of the
engine and where they put the engine in the crane.  Different
models of cranes, even if they are from the same manufacturer, make
each engine in a different configuration, compacting and lightening
it as much as possible.   Adding weight will require the
manufactures to confirm and re-certify their load charts.  For
cranes that have been working for years and/or are no longer
manufactured, no crane manufacturer is willing to do this.  If we
change anything on the crane that is not a factory supplied or
approved aftermarket parts with a part number, that alters the
structural integrity of the crane, it voids all charts and
certifications and therefore no longer meets ANSI standards and we
will be operating outside of OSHA regulations.  The crane will not
pass certification and we have no protection against any failure. 


•	The crane owners note that the verifying Executive Orders for
passive VDECS are being issued with the following standard
condition:  “The engine must not be in an auxiliary power unit for
on-road trucks, transport refrigeration unit, gantry crane,
stationary application, marine vessel, or locomotive”  [Emphasis
Added].   We believe that the same feasibility issues  applicable
to gantry cranes also apply to mobile cranes (and to an even
greater degree).  Likewise we believe that due to the difference in
lift patterns and lift duration, the same feasibility issues
preclude the installation of active systems on mobile cranes.”

Again, we appreciate your time in noting the unique challenges that
face our industry and would like to thank staff for their
willingness to explore these issues further.

Kind regards,

Bryn Burke on behalf of the Mobile Crane Operators Group