MINING RISK MANAGEMENT SERVICES

Regulatory Compliance Assistance

MSHA Citation Conferences

Management Assistance for Safety and Health

Mining/General Industry Safety and Health Consulting

Safety Training/Safety Meeting Presentations

On-line assistance available for your compliance questions

Mine Inspections and Training Services

Serving Metal/Nonmetal Mining and General Industry in the United States and Canada

Quality On-site Compliance Inspections

Quality Supervisory and Employee Training

Former U.S. Dept. of Labor/Mine Safety and Health Administration (MSHA) supervisory mine inspector with 24 years experience within the Mine Safety and Health Administration enforcement program; 7 years in safety and health compliance risk management consultation; and 42 years total mine-related and industry experiences. I can help you be a success in safety enhanced productivity at your MSHA or OSHA site. Get your assistance from someone who is actively out in the industry environment. Safety and health is serious business! Get the best assistance available anywhere!

Contact MRMS for your compliance needs;

• Professional and thorough MSHA/OSHA compliance site inspections
• Accident Investigations
• MSHA 101 Violation/Hazard Recognition Workshops
  
• Supervisory 101 Responsibility Training, Safety Manager Training, and Employee Safety Training
• Mine Operators and Contractors Training Plan development, review of training plans and required training needs
• Citation/order review and conferencing assistance
• Part 50 employee hours-and-accidents reporting audits and assistance
• Attorney and Insurance Consultation Services
• Noise, dust, and welding fume surveys and engineering controls assistance
• Safety and Health Management Service Programs
• MSHA records compliance review
• and more.
  "No-obligation" service quote:

• For a single event Compliance Assistance Visit (CAV) for a MSHA /OSHA compliance review at your site (conducted even while you are in operation)
• For a 3-month, 6-month, or 12-month compliance assistance service agreement for continuous oversight at single or multiple locations;
• For a service agreement where you select the number of day(s) per month at any specific location or department.
• For a specific area of MSHA compliance enforcement oversite.
• For quality "nuts-and-bolts" safety meeting presentations by someone who is "out there".
• For Part 46 and 48 mandatory training presentations.
• For contractor's 2-hour mining-specific safety and health recognition training to supplement other qualified training subjects taken under OSHA which are applied to Part 46/48 Plan training.

• *Initial New Miner Training, including respirable protection devices and first aid.
  
  *Newly-hired Experienced Miner Training, including respirable protection devices.
  
  *Contractors or mine operators Annual Refresher Training Presentations   (2, 4, 6, or 8 hr sessions as requested)

Contact us!

e-mail: MiningRMS@aol.com

Ralph Christensen, Safety and Health Compliance Consultant

Phone: 906-932-2293

Fax: 906-932-4408

N11949 Salmi Lane, Bessemer, Michigan 49911, USA

Cell Phone: (906)364-1629

MSHA/OSHA Jurisdictional Issues Assistance

Safety and Health is the key to all success!

Protect your valuable employees, promote a safety-enhanced attitude, and save $ on employee replacement hours, accident costs, MSHA/OSHA assessments, attorney fees, and insurance premiums!  Make every day, a normal productive day! Be the best you can be!  Mining Risk Management Services can do a compliance review at your site and get you up to speed with safe conditions and practices at your company. Call now for a solution to your safety compliance issues!

If it doesn't look right, it is usually a violation - and a hazard!

If it doesn't feel right, there is usually a violation - and a hazard!

Stop, Look, Analyze, and Manage! (SLAM)

You get what you accept!

www.msha.gov

www.cdc.gov/niosh/

www.dot.gov

www.osha.gov

www.ansi.org

www.hazard.com/msds/

www.fra.dot.gov

www.nfpa.org

www.atf.treas.gov

www.state.il.us/osfm/

www.asse.org

Maintenance/repair tasks, powered haulage (includes trucks, front-end loaders and conveyor belts), and operating machinery are the highest risk categories for metal/nonmetal mining accidents causing injuries and fatalities.

Failure to wear seatbelts in mobile equipment has caused many powered haulage fatalities. Seat Belts Save Lives!  Always wear the seat belt - and ensure that it is in good condition!

ENSURE THAT ALL EMPLOYEES STAY IN COMPLIANCE ACCORDING TO THE MSHA SEATBELT STANDARDS; 56/57.14130 and 56/57.14131

Slogans:

Safety Begins with You!

You are in control of your destiny!  Don't take it lightly!

"You will get what you accept!"

"It is better to "keep up", than "catch up".

"If you have time to lean, you have time to clean."

Let's not meet by accident!

Some common records to be maintained for MSHA inspector review:

• MSHA 7000-1: Accident Reports
• MSHA 7000-2: Quarterly Employment Reports
• 56/57.18002: Examination of working places by a competent person at least once each shift.
• 56/57.14100: Pre-shift mobile equipment defect records (if any).
• 56/57.4201: Firefighting equipment inspection documentation, including annual testing records and monthly visual inspections.
• 56/57.12028: Continuity and resistance of electrical equipment grounding test records.
• 56/57.13012: Inspection of compressed air receiver tanks and other unfired pressure vessels. (MSHA currently enforces the State rule, referencing the National Boiler Inspection Code - contact MSHA and your state for specifics.)
• 56/57.18010: Documentation/certification for currently trained individual(s) capable of providing first-aid assistance on all working shifts when hazardous work is being conducted.
• Part 41: A review of the mine operator's Legal Identity Report for accuracy, and 30-day update requirement.
• Part 46/48: Miners Training Plan, and certification of training of employees.
• 56/57.5005: Respiratory Protection Program and respirator fit-testing records requested during MSHA health sampling activities of employees (determines amount likely penalty if there is an over-exposure to surveyed contaminants).
• Part 62: Hearing Conservation Program, and required annual training record.
• Part 47: Hazardous Communication Program

Operator and Mine Contractor Assistance 

PART 46 TRAINING PLANS: 

MSMS can develop a user-friendly Part 46 Training Plan for you in short order; whether you are a present mine operator looking to refine your plan; a new mine operator; or a contractor who is going to work on a mining site.  YOU MUST HAVE SOME TRAINING BEFORE YOU CAN WORK ON ANY MINE SITE.  THAT'S THE LAW.  STIFF PENALTIES CAN APPLY FOR FAILURE TO BE CURRENTLY AND ADEQUATELY TRAINED.

MSMS will assist you in getting an MSHA mine identification number, if you don't have one.  We can develop a plan quickly for you.  You will be guided in an appropriate "competent persons" instructor list.  Your safety meetings can be easily credited to your annual refresher training.  Your training time will be realistic. Your subjects will be appropriate for your type of operation.  Your plan will be neatly organized in a binder, with resource material included.  And, we can conduct initial training for you to comply.  We can also provide a source for you for organized record keeping. 

Respirable Silica (Quartz) Dust

Respirable silica (quartz) dust is a significant hazard to employees in the mining and milling industry. "If it doesn't get you now, it will get you later". Humans were not meant to be breathing contaminated air - dust, fumes, mist, and gases. Doing so can cause serious health consequences. MSHA vigorously pursues sampling for respirable silica (quartz) dust exposures at mining and milling sites during its inspections - and rightfully so. Mine operators are required to survey for these contaminants as stated in Standard 56/57.5002. If mine operators do not know how to survey - or do not have the equipment, the equipment can be rented or contractors are available to conduct sampling and determine compliance. Ignoring the airborne hazards in the mining and milling environment is not the thing to do. Certain occupations at mines and mills are more vulnerable to over-exposures. MSHA looks for mine operators to provide engineering controls to eliminate the source of the contaminant. This is the only real sure way to combat dangerous exposures.

A Respiratory Protection Program meeting ANSI Z88.2-1969 (or newer) should be implemented and/or already in place at mining and milling operations to ensure that employees are provided the protection they need. Respiratory protection is only an interim measure while engineering controls are being implemented, or if employees go into areas such as dust collectors for maintenance tasks - that they are ensured protection. Medical evaluation and fit-testing are just two of many important requirements within a respiratory program. Mobile units are available in many locations to come to mining and milling sites for conducting medical evaluations for the wearing of respirators. Respirator manufacturers and distributors often times will come to the properties to conduct fit-testing at no charge. Quality respirators should be used to ensure adequate protection. To purchase a respirator off the shelf and wear it, does not ensure adequate protection without fit-testing. Persons wearing respirators must be clean shaven in the area of the respirators seal. Fit-testing should be conducted every year. Employees facial structure can change during the year and may require a different size or model of a respirator.

If MSHA conducts a respirable dust survey at a mining or milling site and finds an over-exposure, a Respiratory Protection Program will be required to be implemented for the employee(s) that were found to be over-exposed. If there was no program, the penalty will be greater because the employee was not assured as protected adequately.

Implement a Respiratory Protection Program now. Your employees will feel better at the end of the day. And, you will feel confident that you did the right thing. Make your company - The Best It Can Be!

MSHA Tidbits

(My original version)

Help me Improve my Safety Program!

Help me Recognize Hazards!

• Natural gas will defuse and deteriorate any rubber hose because of its small molecular structure. Semi-flexible hose-piping designed for natural gas must be used.  Contact a reputable manufacturer for the right applications
  
• LP/Propane-approved hose is labeled for that purpose and is the only hose that should be used for LP/propane.
• Seat belts may not be complete if the tether strap connections have been removed (or not connected) on certain pieces of mobile equipment. They, then, may not meet the SAE J386 approval. If in doubt, contact your manufacturer. If tether straps came with the equipment from the factory, they must be maintained as such.
• All drills (including underground and surface) must always have a method being used to control the drill dust; such as water or a dust collector. Drilling with no controls is a violation. Natural water in the hole is not considered a compliance measure.
• Hard-surface welding is lethal to an employee if not provided with "localized" ventilation and appropriate fit-tested respirators with welding fume cartridges. "Localized" ventilation is the removal of contaminants BEFORE they enter the employee's breathing zone. All welding is required to be well ventilated whether welding inside or outside, and shielded from flashburn hazard to other persons in the area.
• Mine dusts, gases, and fumes that effect the same organ of an exposed employee during their work shift is considered an additive mixture of contaminant and the exposure is calculated and compared with the "unity of one". Over the "unity of one" represents a violation for overexposure. Formula: conc./TLV x EF + conc./TLV x EF + conc./TLV x EF + conc./TLV x EF = 1.0 (unity) (TLV= threshold limit value, EF= error factor applied)
• On electrical equipment, if an ohm reading on the non-current carrying frame ground wire is 2 ohms or greater resistance, the breaker may not trip out fast enough to prevent electrocution. As a "rule of thumb" any time the resistance is divided into the voltage-to-ground and the current is less that 10 times the breaker rating, the grounding path is ineffective. The correction is to check for loose and corroded connections in the non-current carrying ground wire and get the resistance to as close to "zero" as possible.
• MSHA reportable accidents also include application for sutures (stitches) , positive x-rays, chiropractors, prescriptions for the eyes, light duty, and diagnosis of silicosis or pneumoconiosis (even after termination of employment as the operator becomes aware). If in doubt, call your nearest MSHA District Office.
• Employees and work hours reported to MSHA are those which employees WORKED ON mine property and were exposed to the mining environment, including office workers ON mine property. Sick leave, vacation days, jury duty, for instance are not reportable. Overtime (time and a half) are reported as straight time on the form because that was the actual amount of time exposed to the mine hazards.
• Roll-Over Protective Structures (ROPS) are required to have a legible certification label in order to verify that it is the right one for the piece of equipment. They should not be covered up, sand blasted off, painted over, or removed. It would then be a violation.
• Ventless gas heaters in closed up areas, such as in semi-trailers, can cause a buildup of carbon dioxide and carbon monoxide to dangerous levels. Read the manufacturer's recommendations before you buy and use.
• Machinery, equipment, and tools are not to be used beyond the design intended by the manufacturer.
• Before using self-propelled mobile equipment, the operator is required to inspect it for safety defects BEFORE putting it to use. Defects must be corrected in a timely manner, and recorded if not repaired immediately. Items not repaired immediately must not pose a safety hazard if operation continues (such as wipers - and it is not raining; or, lights - and it is not dark). Do it right - fix it right away.
• Working places are required to be examined during each shift by a competent person to eliminate hazardous conditions and work practices that could adversely affect safety and health of miners, and examinations recorded and kept for one year.
• Before starting crushers - and moving self-propelled mobile equipment - if persons are exposed to a hazard from the movement of the equipment, they must be warned of the impending movement.
• The purpose of 56/57.14109 is to prevent persons from falling ON or AGAINST an unguarded moving conveyor belt. Emergency stop cords need to be positioned in such a manner that the emergency stop cord will deactivate the conveyor emergency stop switch if an employee were to fall on or against the moving conveyor belt; or, a railing (optional) can be provided to prevent the employee from falling on or against the moving conveyor belt.
• MSHA regulations serve as a minimal guideline standard of safety protection for employees. Mine operators and contractors are encouraged to exceed those standards of safety and health.
• Compressed air receiver tanks, and other fired and unfired pressure vessels, are required to be inspected for the appropriate required safe guards and construction by inspectors holding a valid National Board Commission Boiler and Pressure vessel certification and authorization. Inappropriate and defective air receiver tanks used for compressed air or other pressured purposes can explode and cause serious injury or death to persons. MSHA enforcement dictates each specific states' established procedures and policies for compliance with the standard.
• A written and implemented respirator protection program consistent with the requirements of ANSI Z88.2-1969 is required if MSHA finds an overexposure to a contaminant which required the use of respiratory protection as an interim measure of protection while feasible engineering controls are being pursued. It is always beneficial to have a Respirator Program in place to protect your employees from contaminants in the work place. Don't wait for MSHA to find a problem at your site. Protect your employees' future health.
• All safety features that manufacturers provide for equipment must be maintained. Seat belts must also be worn in all mini-loaders. The hydraulic-activation safety bar does not take the place of the seatbelt.
• Mill hours have been mis-reported on MSHA 7000-2 Quarterly employment Report forms by mine operators by misunderstanding the code areas. Stripping, open pit mining, or quarrying should be reported under "code 03" on the form. Hours spent in milling (crushing, screening, prep plants, breakers, or their related shops and yards should be reported under "code 30". The exception is that sand and gravel sizing operations are reported under "code 03"; or, "code 06" if it is a dredge operation. Call your local MSHA District or field office if you would like a copy of "instructions for MSHA Form 7000-2" brochure.
• A common violation found in laboratories on mine properties is compressed gas cylinders not secured in an upright position, or the cylinder valves not protected as required by 56/57.16005 and .16006.
• A Hearing Conservation Program (HCP) is specifically required for THE EMPLOYEE that is determined to be over-exposed to the "action level". When MSHA finds that an employee is between the action level (85-90 dBA), the inspector will ask for the record of that employee being under the HCP as required (ie; monitoring, notifying the miner, providing hearing protectors, training in the required subjects, offering an audiogram, certification of training, and annually thereafter. The record must be specific for that employee. All employees can be and should be included in the Hearing Conservation Program.
• The subjects that must to taught during Part 46 annual refresher training are: "changes at the mine...", and all other topics listed in the annual refresher training section of the operator's Part 46 Plan, and within the time frames established, and by a competent person listed for that subject.
• Many mine contractor violations include; not wearing (or not having attached) a fall restraint system during a fall hazard, lack of guarding on moving machine parts, no fire extinguisher on the immediate site of welding or cutting, compressed gas cylinders not secured in the upright position, compressed gas cylinder valves not protected during transport or storage, fire extinguishers not tested annually or no monthly visual inspection record, lack of a Part 46 training plan (or plan deficient), not wearing goggles or face shields during operation of a grinding wheel, not wearing correct burning goggles during torch work, not setting the parking brake and chocking the wheels of mobile equipment when parked on a grade and left unattended (including service trucks and pickup trucks)...

It is more comfortable to be hanging from a safety harness and lanyard restraint system, than to fall to the ground and be severely or fatally injured.

Wear your restraint 100% of the time when there is a chance to fall. It makes good sense.

Safety is our first concern!

Current MSHA emphasis areas:

• Mobile equipment, setting parking brakes and chocking the wheels, or turning them into a stop block or an embankment when parking on a grade unattended. (56/57.14207)
  

• Failure to wear seat belts when required on mining equipment. (56/57.14130)
  

• Protection of electrical conductors. (56/57.12004)
  

• Identification labels on electrical control distribution boxes. (56/57.12018)
  

• Removal of abandoned electrical wiring. (56.4011)
  

• Equipment guarding thoroughness. (56/57.14107a)
  

• Temporary container labeling as per the Hazcom Rule. (47.34)
  

• Proper and timely reporting of accidents (remember: send in back-to-work information on ALL forms. Fill out Section D on your 7000-1 accident report form, or you may be assessed a penalty). (Part 50)
  

• Miner Training with current (unexpired) training certificates. (Part 46 & 48)
  

• Conveyor return idler guarding at vulnerable cross-under areas. (56/57.14107a)

• Spillage falling from processing equipment. (56/57.14110)
  

• Mine contractor's compliance. (Part 45)
  

• Correcting safety defects before putting equipment, machinery, and tools to use. (56/57.14100b)

• Lockout/tagout. (56/57.12016 & .12017)
  

• Housekeeping of tools, old parts, and spillage on walkways. (56/57.20003)
  

• Air compressors over 10 hp to have temperature activated shut-off sensors or fusable plugs if overheating. (56/57.13010)
  

• Monitoring respirable and total dust exposure to employees. (56/57.5002)
  

• Grounding or insulators on guy wires, even the 480 v. if it appears that the guy wire might be rubbing a phase wire on insulated electrical cords on poles (MSHA has been citing this under 56.12030 (The catch-all Standard).

• Hazcom:  Have the correct MSDS on file, including the brand name. (47.51)
  

• Cutting Torches:  Make sure the gages are reading properly and zeroing out when shut off. (56/57.14100b)

Failure to comply with mandatory safety and health regulations and safe work practices will get you hurt in due time! It makes the best sense to always comply to reduce the odds for an accident.

Metal/Non-Metal Mine Fatal Accident Statistics in the USA!

2008 MNM Mining Fatal Accidents

22 fatal accidents

1 in 8,183 MNM miners were fatally injured

18% were fall accidents (No fall restraint used)

22% were contractor employees

23% were powered haulage accidents

14% were machinery accidents

13% were fall of roof/back accidents

23% were contractor employees

2009 Metal/Non-Metal Fatal Accidents

13 Fatalities as of 07/02/2009

3  Falling/sliding Material (23%)

4  Machinery  (30%)

1 Electrical (8%)

1 Fall of Person (8%)

3  Powered Haulage (23%)

1 Fall of roof (8%)

30% of fatals were contractor employees

(Warning Alert POSTER)

ATTENTION: Customer TRUCK DRIVERS

For your safety, you must stay in your truck in all loading, unloading, and congested areas. (You will not be loaded if you are not in the driver's seat).

Drivers must follow the posted traffic rules, patterns, adhere to warning signs, wear their seat belts at all times, and not exceed the posted speed limits.

Trucks backing up are required to have an operating backup alarm, or an observer to signal when backing up. Drivers are required to sound a warning if any other persons are in the hazardous vicinity of their truck to warn them of the impending movement, before moving the truck.

Climbing on top of your truck is prohibited unless you are secured with an appropriate safety restraint.

Truck drivers have been fatally injured at mine sites in the past. Driver hazards have consisted of: being run over by mining equipment and other trucks; stockpiles which have collapsed, drivers in truck beds being buried by the front-end loader(s) loading the truck; trucks colliding with each other caused by blind spots; raising truck beds into high voltage lines; going off the "beaten path" into active mining areas; defective equipment; drivers falling off the top of their trucks; drivers running after their truck when they failed to activate the parking brake and not chocking the wheels as required; and by trucks falling over with their beds in the elevated position because of uneven and/or non-compacted dumping areas.

Thank you for your compliance! Have a Safe Trip!

Keep your Seat Belt on!

Truck Drivers Alert!

Do not leave your truck cab, or go by any truck, with the box up in the air while dumping a load.  Do not let anyone stand by the truck - even when delivering to a residental area, as they might be exposed to the potential fall of the truck if the wheels were to sink on one side.  This has occurred.  Do not lift the box up in the air if you are not level.  Watch for overhead power lines.  Wear your seatbelt while dumping also.  Some trucks have fallen over and fatally injured the drivers.  Some of the reasons have been: the ground was not level, the area was soft and the wheels on one side sank down first, material stuck in the upper portion of the box to one side and caused an imbalance, one truck parked by another with both having their box up - one fell over on the other and crushed the cab fatally injuring the driver.  It takes no longer to do it right.  Be aware of the risks involved!  Save a life!