Rock Products

APR 2019

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50 • ROCK products • April 2019 www.rockproducts.com LAW rigorous standards. They have to implement effective safety and health management systems and keep injury and illness rates below national industry averages. They must show pro- active cooperation among leadership, the workforce, labor unions, and OSHA. As long as a site demonstrates lower-than-average risk – and maintains VPP's exacting standards – it is exempt from OSHA programmed inspections. That allows OSHA compliance offi- cers to spend their time visiting more hazardous places. It also frees up the VPP company's internal safety team to focus on bringing safety to the next level, rather than accompanying inspectors and haggling over citations. OSHA's VPP is not perfect, but the results are impressive. Accord- ing to OSHA, VPP sites consistently have lower accident and workers' compensation rates than other sites. The average VPP site has a Days Away Restricted or Transferred (DART) case rate 52 percent below industry average. In 2017, 414 VPP companies had zero recordable injuries and illnesses. Can MSHA Borrow Some Of This Experience? While there are no doubt still some bad apples in mining, many mine operators have sophisticated safety programs that far exceed MSHA regulations. MSHA inspectors shouldn't have to spend weeks or even months at these sites looking at every cover plate, conveyor guard, and dust pile – especially when another facility down the road really needs closer in-person attention. The Mine Act's requirement that MSHA inspect every mine "in its entirety" does not have to mean physically observing every nook and cranny. There is legal precedent suggesting that a series of spot inspections could count as a complete inspection. Isn't a 2-month regular inspection effectively a series of spot inspections anyway? Court opinions also say that an inspection should involve thoroughly reviewing the "conditions and practices through- out a mine." Let's be honest. MSHA's current model focuses almost entirely on the "conditions" part of this equation. But, it is no less valid to shift the paradigm a bit and focus more on a mine's "practices" (such as reviewing safety programs, risk assessment systems, and training efficacy), especially when MSHA can assure itself that the mine regularly meets a high bar for safety. MSHA says it is looking to become more efficient and to run more like a business. As it does so, it certainly cannot compromise on its safety and health mission. With these goals in mind, whether with these proven OSHA models or others, MSHA should look for ways to better align resources with hazards. Future trends in mine safety could hang in the balance.

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