Back in November, MSHA head David Zatezalo indicated that MSHA’s initiative to “blur the lines” between coal and M/NM enforcement had ended. As an apparent follow-up, in late December MSHA released a new, unified M/NM and coal inspection handbook, and has now started training investigators on the new handbook.
This handbook replaces two previous handbooks – the 2016 version of PH19-IV for Coal and the 2009 version of PH09-IV-1 for M/NM – creating a single handbook for both coal and M/NM. Below are some of the key takeaways for mine operators as they encounter MSHA inspections under this new handbook, with a focus on the differences M/NM operators can expect.
By squeezing two longer handbooks into just 58 pages, the new handbook pares down, generalizes or cuts out a lot of material. To create one inspection handbook for all types of mines, MSHA believed that it needed to give more discretion to inspectors, noting: “Not all procedures and requirements are applicable for all mine types. Any deviation from the procedures outlined in this handbook should be based on the inspector’s professional judgment, and discussion with the inspector’s supervisor.”
Nonetheless, apparently recognizing that there are significant differences between coal and M/NM mines, the new handbook retains features unique to coal mines, such as for coal mine dust sampling, and also includes in its Appendices separate checklists for mine records and postings for different mine types. In some ways, the new handbook underscores, perhaps unintentionally, that “blurring” can only go so far.
Read about the major changes in the new handbook in the latest issue of Rock Products here.