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Independent Review of MSHA's Actions at Crandall Canyon Mine

Independent Review of MSHA's Actions at Crandall Canyon Mine

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loc<strong>at</strong>ions, and along normal travel routes for persons who do not have a fixed work loc<strong>at</strong>ion<br />

(pumper, examiner, etc.).<br />

Another requirement <strong>of</strong> the Final Rule is th<strong>at</strong> one additional SCSR be provided for each person<br />

on mantrips or mobile equipment used to transport miners into or out <strong>of</strong> a mine. Also,<br />

oper<strong>at</strong>ors must provide caches <strong>of</strong> SCSRs in each escapeway <strong>at</strong> 30-minute travel distances.<br />

These caches must contain <strong>at</strong> least one SCSR for each person who could be inby th<strong>at</strong> loc<strong>at</strong>ion <strong>at</strong><br />

any given time.<br />

Following the passage <strong>of</strong> the new requirements for SCSRs, there was a huge demand but a<br />

short supply <strong>of</strong> the devices. In Program Policy Letter No. P06-V-10 (See Appendix G), MSHA<br />

permitted mine oper<strong>at</strong>ors to provide a valid purchase order showing a delivery d<strong>at</strong>e until<br />

SCSRs became available. District 9 was following n<strong>at</strong>ional policy on the acceptance <strong>of</strong><br />

purchase orders showing SCSRs had been ordered. The district’s ERP compliance spreadsheet<br />

indic<strong>at</strong>ed th<strong>at</strong> 17 <strong>of</strong> the district’s active underground mines had SCSRs on order on August 6,<br />

2007. Only two mines were documented as having all SCSRs in place, and one other mine was<br />

documented as a new mine and the SCSRs not yet required. The district’s ERP compliance<br />

spreadsheet showed th<strong>at</strong> SCSRs were still on order for the <strong>Crandall</strong> <strong>Canyon</strong> <strong>Mine</strong>, but the<br />

Accident Investig<strong>at</strong>ion team determined the <strong>Mine</strong>’s records showed they had all required<br />

SCSRs <strong>at</strong> the time <strong>of</strong> the accident on August 6 th .<br />

<strong>Mine</strong>s in District 9 employ approxim<strong>at</strong>ely 3850 underground miners. At the time <strong>of</strong> the<br />

August 6 th bounce, the district’s ERP compliance spreadsheet showed th<strong>at</strong> these mines still<br />

had 6337 SCSRs on order. All districts were experiencing a similar shortage <strong>of</strong> SCSRs.<br />

Conclusion: District 9 followed n<strong>at</strong>ional policy by ensuring th<strong>at</strong> all oper<strong>at</strong>ors <strong>at</strong> least had a<br />

valid purchase order to demonstr<strong>at</strong>e th<strong>at</strong> they were making a good faith effort to provide<br />

SCSRs. However, the majority <strong>of</strong> mines in District 9 did not have the required number <strong>of</strong><br />

SCSRs on August 6, 2007.<br />

Recommend<strong>at</strong>ion: The Agency should determine if there are any actions th<strong>at</strong> can be taken to<br />

ensure th<strong>at</strong> SCSRs are provided in accordance with the Final Rule as expeditiously as possible.<br />

This should include re-evalu<strong>at</strong>ing the policy <strong>of</strong> allowing the oper<strong>at</strong>or to obtain a purchase<br />

order for the purchase <strong>of</strong> equipment as compliance with this standard.<br />

Lifelines<br />

The Final Rule outlines requirements <strong>of</strong> lifelines th<strong>at</strong> mine oper<strong>at</strong>ors were to install in each<br />

escapeway. The standards require th<strong>at</strong> lifelines be:<br />

• Continuous and durable;<br />

• Installed and maintained throughout the length <strong>of</strong> each escapeway; and<br />

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