The International Day for Mine Awareness and Assistance in Mine Action is approaching quickly (April 4). Although this day is an important landmark in mining safety, it’s important to always be vigilant in improving mine safety. One way to improve safety is to be aware of the top MSHA violations and eliminate the causes of those violations.
MSHA first groups violations by facility type:
- Surface Mining, such as open pit mining and strip mining
- Underground Mining, using either a horizontal tunnel (an adit) or a vertical tunnel (a shaft)
- Facilities, such as material processing, loading and transfer sites, etc.
Within each facility type, MSHA then divides violations by the category of materials being handled:
- Sand and Gravel
Not surprisingly, it can be cumbersome to review each category to determine the top overall MSHA violations among the major categories—there are close to 300 top violations in total. This article distills those numbers and breaks down the ten most frequent violations across all categories.
10. Electrical Equipment Maintenance and Testing
Starting at number ten in the underground/coal category is MSHA’s regulation in 30 CFR 75.512: Examination, testing, and maintenance of electrical equipment, with 1,152 violations.
This provision requires all electrical equipment to be regularly examined and maintained by a qualified individual. Any electrical equipment with a potentially dangerous condition must be removed from service until it is fixed.
MSHA defines regular examination as inspections completed on a weekly basis, per §75.512-2.
9. Roof Control Plan
Number nine, also in the underground/coal category, is §75.220(a)(1): Roof control plan, with 1,170 violations.
This provision requires all mine operators to develop and follow a roof control plan that has been approved by the district manager. The plan will provide measures that withstand the main geological conditions at the site, as well as protect individuals from unusual hazards. Failure to have a proper roof control plan can result in cave-ins, collapse, and other hazards.
8. Electrical Conductor Size and Current Capacity
The eighth most common violation, found in the surface/sand and gravel category, is MSHA’s §56.12004: Electrical conductor size and current capacity, with 1,225 violations.
This provision regulates the size and capacity of conductors to ensure safe operation, preventing temperature increases that could damage the equipment during normal use. Additionally, electrical conductors must be protected from mechanical damage.
7. Required Maintenance of Electrical Equipment
Number seven, in the underground/coal category, is MSHA’s §75.503: Permissible electric face equipment maintenance, with 1,505 violations.
This provision requires all electric equipment to be properly maintained (per §75.500, §75.501, §75.504) and to be in proper working condition when brought into or used near the last open crosscut of a mine.
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6. Other Safeguards
At number six, with 1,538 violations in the underground/coal category, is MSHA’s §75.1403: Other safeguards.
MSHA defines other safeguards as follows: Any guarding not covered in the Federal Register. If an approved representative of the secretary determines that additional guards are required, the new safeguards must be implemented within the allotted time, even if the Federal Register does not require them.
These guards must appropriately reduce risks during the transportation of workers and materials. All guards must be in place and maintained at all times, and an attendant must be present when transporting people.
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5. Incombustible Rock Dust
With 1,710 violations, number five on the list is MSHA’s §75.403: Maintenance of incombustible content of rock dust.
This provision applies to situations in which rock dust is required to be applied. Rock dust “shall be distributed upon the top, floor, and sides of all underground areas of a coal mine and maintained” correctly. At least 80% of the dust present needs to be non-combustible to avoid runaway fires and explosions.
Furthermore, the percent of non-combustible content shall be increased by 0.4% for each 0.1% of methane in the mine. The increase of non-combustible content applies to any circumstance with methane in the ventilating current.
4. Moving Machine Parts
Improper guarding of moving machines parts in the surface/sand and gravel category takes the number four spot, with 1,737 violations of MSHA’s §56.14107(a).
This provision requires all moving machine parts to be adequately guarded. This means that guarding must prevent individuals from coming into contact with any moving machine parts, which includes pulleys, idlers, drives, chains, couplings, shafts, and so forth.
MSHA does not require guarding when the moving parts are “at least seven feet from walking or working surfaces [§56.14107(b)].” However, best practices often include near continuous guarding. ANSI provides valuable guidelines and best practices in ANSI B11.19 2003: Performance Criteria for Safeguarding.
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3. Roof, Face, and Ribs
At number three is MSHA’s §75.202: Protection from the collapse of roof, face, or ribs, with 1,742 violations in the underground/coal category.
MSHA’s §75.202 requires that all roofs, sidewalls, and working areas are supported or controlled in a manner that will protect individuals from hazards related to collapses and cave-ins.
2. Mine Shaft Ventilation Plan
Number two is in the underground/coal category with 2,233 violations of MSHA’s §75.370(a)(1): Mine ventilation plan submission and approval.
This provision requires mine operators to develop and follow a ventilation plan that has been approved by the district manager. The plan must provide methods for controlling methane and respirable dust, and must be designed to suit the conditions of the mine.
An inefficient or missing ventilation plan puts lives at risk. Coal mines contain numerous types of dust that cause coal mine dust lung disease (CMDLD), which often requires lung transplantation in the later stages of the disease.
(Source: A. Scott Laney and David N. Weissman, “Respiratory Diseases Caused by Coal Mine Dust,” 2014)
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1. Accumulation of Combustible Materials
The number one MSHA violation is provision §75.400: Accumulation of combustible materials, with 4,377 violations in the underground/coal category.
MSHA requires all combustible material to be cleaned up and not allowed to accumulate in active working areas or on powered equipment.
Poor housekeeping can have disastrous consequences. In 2010, the Upper Big Branch mine suffered a massive explosion that killed 29 workers. This accident was caused by a buildup of methane gas and coal dust.
While mine safety has improved over the last five years, it is important to note that a significant percentage of fatalities in 2015 were caused by not following the MSHA provisions listed in this article. For example, 36% of the fatalities in coal mines were caused by material falling on miners: Roof, walls, or other structures collapsing due to insufficient design and upkeep. Furthermore, the top violation has been the cause of the worst mining disasters in U.S. history. It is concerning that §75.400: Accumulation of combustible materials continues to be the number one violation in mining:
- 4,377 in 2015
- 5,302 in 2014
- 4,894 in 2013
- 6,211 in 2012
Safety must always be the number one priority. Understanding and properly implementing MSHA safety regulations, at all times, will be the number factor in continuing to reduce mining accidents and fatalities.
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