#msha-official

[msha-official]

Long story short: a revision to MSHA's requirements was proposed to remove the clause "Additional measures may be required in plans by the District Manager." (30CFR § 75.222)

This will cause more miners to die.

The public comment period ends July 31, 2025. The link with the rule change and instructions to comment is below.

I've also included my own defense for why this regulation change is hazardous and ultimately more costly for the mining industry as a whole.

Variability in roof conditions means not every coal mine is able to support the roof in a way that will prevent roof falls from killing the miners with the minimum roof support. The clause "Additional measures may be required in plans by the District Manager" (30CFR § 75.222)" addresses these shortcomings to suit the requirements of the individual mine's roof control plan to best protect the miners, without having to hold the entire industry to an unreasonably high standard, just to protect the miners at the mine with the worst conditions. By having the discretion to individually allocate minimum support at each mine based on the conditions present, this clause is actually saving the rest of the industry from having to follow stricter regulations everywhere.

Executive Order 12866 requires agencies to tailor regulations to impose the least burden on society. Having individualized roof control plans does this by imposing the burden of following stricter guidelines on only one mine instead of requiring every mine in the country to follow those stricter regulations

Removing this clause places the onus of miner safety more fully in the operator's hands to be able to address conditions that are not addressed in the minimum roof control requirements set forth by the regulations. The District Manager adds individualized mine requirements based on the conditions of each mine to ensure the safety of the miners working there. These additions are non-arbitrary and based on addressing the conditions of the mine. If this ability of the District Manager is removed, more miners will die from roof falls where the minimum roof control requirements are not sufficient to address individual mine conditions.

2016 marked the first year in US history where 0 roof fall fatalities occurred. Having additional requirements for each mine at the discretion of the District Manager is proven to work at preventing roof fall fatalities.

In addition, preventing fatalities by using appropriate roof support to begin with simply costs less than addressing fatalities. The annual savings estimated by this proposal of $1.1 million over 10 years is outweighed by the cost of addressing fatalities that will occur if mine-specific regulations, addressed by the District Manager, are removed.

The rule change also cites that this role change will result in "a more efficient Agency review and approval of roof control plans for underground coal mines." If every proposed change to a roof control plan needs full comment periods and the equivalent status of a publicly-applied law for a change that should only affect a single mine, the roof control plan approval process will significantly slowed.

Further note: the regulations for ventilation requirements and other specific mining plans are also being edited to remove similar clauses. Please also submit comments to those regulation changes.

[msha-official]

[msha-official]

Thank you to our fearless (unconfirmed) leader for checking the buzz word sheet (but not much else) before opening up the town hall to everyone in MSHA. Wayne and Julianne really made it clear how much they care about mining in this country, and fast-tracking some mines keep critical minerals that we don't want to pay another country for, since we've already burned all those bridges.

Thank you Wayne for emphasizing how much you value community policing. Everyone loves having their work and opinions scrutinized by someone who doesn't know what they do.

Thank you for emphasizing transparency, but making sure our business is our business and we shouldn't talk to the media.

Wayne, you brought up your amazing critical thinking skills very often. I'd love to see you employ them someday.

It was wonderful you opened the town hall to everyone asking questions, and then proceeded to flounder every single one. I do love that you mentioned multiple times you had "no transparency" especially concerning the multiple questions about RIF notices, and whether they are forthcoming. I see that all types of transparency are being employed.

You did make it very clear you don't know economics, as you claimed at the start. I'm sure when you were growing up dazzled by America's booming industry, you were missing the lessons on what tariffs even are.

The one true thing you said was that our job is to protect miners and I am at least grateful you understand that much.

[msha-official]

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[msha-official]

I'm planning on delving deeper into the mines of moria, good idea y/y?

Hello, Anon! I recently came from inspecting the Mines of Moria and can tell you that the mine is closed due to significant safety violations and will not be able to reopen until those issues are addressed. I have included a brief overview of some of the more significant violations that have caused us to come to this conclusion:

30 CFR § 48.5 - Training of new miners; minimum courses of instruction; hours of instruction. 

A significant number of miners were operating without the necessary 40 hours of training before beginning work duties.

30 CRF § 56.15002-56.15005 -  Personal Protection.

There was a severe lack of personal protective equipment including a lack of hard hats, protective footwear, eye protection, and safety belts and lines where there is danger of falling.

30 CFR § 57.17010 - Electric lamps.

Nowhere in Moria were electric lamps provided, nor was there sufficient alternative light source provided. All workers underground need to have individual light sources in order to make sure they are working safely.

 30 CFR § 57.11051 - Escape routes.

Two or more separate, and accessible escapeways are needed for all underground operations, and these escapeways need to be properly maintained and clearly marked. While there were two routes of escape from the mine, they were not easily accessible, clearly marked, or maintained.

The first escape route was blocked by a doorway not visible in daylight and locked by a puzzle in a language that most of the mine operators do not speak.

The second escape route was only accessible by a bridge barely wide enough for workers to cross in single file.

30 CFR § 57.11050 - Escapeways and refuges. 

In the event that an escapeway cannot be accessed within 1 hour of travel, sufficient refuge chambers must be provided within 30 minutes of any working areas.

As it takes a total of 3 days of travel to cross the mine workings, a significant number of refuge areas were needed. Management at Moria failed to provide a sufficient number of well-constructed refuge chambers that would provide sufficient protection against the hazards in the mine workings.

30 CFR § 50.10 - Immediate notification. 

The operator shall immediately contact MSHA at once without delay and within 15 minutes at the toll-free number, 1-800-746-1553, once the  operator knows or should know that an  accident has occurred involving: (a) A death of an individual at the mine; (b) An injury of an individual at the mine which has a reasonable potential to cause death; (c) An entrapment of an individual at the mine which has a reasonable potential to cause death; or (d) Any other accident.

MSHA was not notified within 15 minutes of the first death that occurred in the Mines of Moria, thus putting the operation in significant violation.

30 CFR § 57.11002 - Handrails and toeboards. 

The walkways in Moria were severely lacking in substantial construction, were poorly maintained, and lacked any handrails and toeboards.

30 CFR § 57.4161 - Use of fire underground. 

Fires shall not be lit underground, except for open-flame torches. Torches shall be attended at all times while lit.

Moria was found to be in significant violation of this standard by having an open pit directly to a hell plane, which unleashed its flames, entirely unchecked and unattended, into the mine workings.

I hope this helps you understand the severe safety violations that were present while the Mines of Moria were in operation.

I would strongly urge you to not enter the abandoned mine workings. Remember: Stay Out, Stay Alive. Exploring or playing at active and abandoned mine sites is dangerous, and potentially fatal.

[msha-official]

I think you mean MSHA compliant, Magnus

[msha-official]

As part of the US Department of Labor, we are wishing you a very happy Labor Day! If you're interested in joining a union, the DOL has updated the knowledge center with new information and resources. Know your rights!

The DOL is working to build an equitable, empowered workforce for all.

[msha-official]

Join us on May 17 for Stand Down to Save Lives. There have been far, far too many mining fatalities already this year. Mine owners and operators, spend some time with your miners to talk about safety. Take time, save lives.