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IMA-NA Files Comments on MSHA Examinations Proposal

Posted By Mark Ellis, Tuesday, November 14, 2017

As previously reported, on September 12, 2017, MSHA proposed two changes to its final rule on Examination of Working Places in Metal and Nonmetal Mines.  The proposed changes would:


  • Require that an examination of the working place be conducted before work begins or as miners begin work in that place; and

  • Require that the examination record include descriptions of adverse conditions that are not corrected promptly and the dates of corrective action for these conditions.


IMA-NA filed comments yesterday supportive of the two proposals.  IMA-NA also used the comments as an opportunity to encourage MSHA to make further improvements in the examinations rule.  Among the improvements suggested were that MSHA should adopt an audit "safe harbor" policy (similar to OSHA's policy) so that, on historical reports, hazards that were abated would not be the basis for citations under the Mine Act, that MSHA should offer relief from recordkeeping by harmonizing its current policies on examinations records retention and that MSHA should refrain from double-dipping alleged examination violations to address alleged task training deficiencies.


A copy of the comments is attached.

Download File (PDF)

Tags:  examinations of working places; proposed rule; fin  MSHA 

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