Increase Mine Safety with LESS burden on MSHA Inspectors !
Without burdening MSHA inspectors with additional trips to mines, mine Operator representative supervisors could be required to more responsibly and more frequently check MSHA Inspector prescribed areas of concern. Make it a mine specific ORDER from the Secretary, as he has concern for Miners safety & cost effective enforcement of Congress approved Mine Act safety provisions (He might have to write 5 orders a week for a few years). This must be beyond the reach of Operator refusal or any enforcement hindering appeal process to have the desired safety improvement impact.
Safety problems can be eliminated before they start if mine Operator representative supervisors (Operator Reps) are in the Mine checking for safety problems as they develop. They have immediate ability to stop unsafe activity, to call for corrective action (no "layers" of non-culpability), and should do the prescribed inspections and sign off to the safe conditions at an effective frequency (they make the big money for a reason don't they?). Miners are understandably reluctant to announce concerns that may interfere with production to their supervisors.
Example 1:
An MSHA inspector (having been on the particular Mine site & having evaluated a particular Citation's circumstances) determines that the Mine Operator representative supervisor should personally inspect & sign off on the operability of Emergency Shutdown devices on the Mine's clinker belt conveyors on a weekly basis. That Inspector to have the authority to contact the Secretary directly requesting an Order be issued to the Mine requiring the Mine Operator to immediately comply with the MSHA Inspectors prescribed Mine Operator inspections & signed record keeping.
Example 2:
An MSHA inspector (having been on the particular Mine site & having evaluated a particular Citation's circumstances) determines that the Mine Operator representative supervisor should personally inspect & sign off on the sufficiency of air circulation at specific points in an underground coal mine & on the reliability of back-up air circulation provisions on a weekly bases. That Inspector to have the authority to contact the Secretary directly requesting an Order be issued to the Mine requiring the Mine Operator to immediately comply with the MSHA Inspectors prescribed weekly Mine Operator inspections & signed record keeping in the specific area of the Inspector's concern.
> MSHA should require Operator to provide a list of responsible Operator Representatives at the Mine (real culpable people whom have enough authority to immediately correct or head off Safety problems).
> MSHA should require all & any specific Operator's Inspection records to be kept available for Miners' and MSHA Inspectors' inspection at short notice & be kept indefinitely.
> A copy of all the Mine's ORDER prescribed inspection records should be forwarded to the ORDER requesting MSHA Inspector monthly, and all of accumulated inspection records to the local MSHA office annually (scanned digital files on C.D., minimum of 600 KB resolution in jpeg format, File Names to include Mine #, Order #, Date (example: 0400213_2711956_03-28-11).
> The MSHA Inspectors regular inspections of the Mine should then include a review of onsite Operator inspection logs (with the signing Operator representative present to answer Inspector's questions).
This strategy of Operator Responsible self monitoring (& Operator signed affirmation of safe conditions) will probably one of the best methods of getting Mine Operator cooperation with the the Government's strained budget. Then simply follow up Operator non-compliance issues with expedient & brief Mine closures to get their attention. Improves production as Miners know that MSHA really has their back.
Jayson Turner; 10+ Yrs Miner (105C Discrimination Docket # WEST 2006-568-DM)
Representative of Miners
Home 661 242-3000 jturner@calneva.org
P.O. Box C, Pine Mountain, CA 93222
