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MSHA revises workplace inspection guidelines

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World Cement,

Alongside other industry groups, the National Stone, Sand and Gravel Association (NSSGA) has expressed concerns regarding the Mine Safety and Health Administration’s (MSHA) new requirement for compliance with the workplace exams standard in Program Policy Letter (PPL) 30.

Initial meeting regarding new workplace requirements

The first PPL, obtained by NSSGA on 9 July, stated that workplace examiners would have to be task trained under part 46 or 48 before conducting an examination. If a trained examiner fails to identify multiple safety hazards, this could suggest that their training was inadequate.

After obtaining the initial PPL, NSSGA staff shared their concerns with MSHA at a stakeholder meeting with Neal Merrifield, MSHA's Administrator for Metal/Non-Metal on 22 July. This PPL would have heightened the number of tasks required in workplace exams and lengthened the training process for examiners.

Also, during this meeting, MSHA revealed an improved and less-burdensome PPL. However, according to the NSSGA, whilst it has been improved, the added compliance burdens in this PPL risk making it more difficult for operators to manage for safety.

The revised PPL, unveiled on 22 July, has modified the original PP, suggesting that evidence of inadequate training may require revisions in the training plan, evidently softening the previous strict requirement.

Fair notice will be given to operators regarding the improved guidance for workplace exams. Inspectors will outline the PPL to operators at their next inspection.

Compliance burdens can impede the cause for safety

Joseph Casper, NSSGA Vice President for Safety, said that PPL revisions help to make this change in guidance less burdensome than the original version. “While we realise the importance of a quality workplace exam, the fact is that additional compliance burdens can impede the cause for safety,” he said.

Adapted from press release by

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