Rock Products

MAR 2013

Rock Products is the aggregates industry's leading source for market analysis and technology solutions, delivering critical content focusing on aggregates-processing equipment; operational efficiencies; management best practices; comprehensive market

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dures to ensure compliance with the law. Operators must stay on top of the enforcement history and should consider implementing a systematic evaluation process to review MSHA���s database for accuracy and potential li��� ability. Completion of a thorough self��� evaluation will ensure adequate time to implement an MSHA���approved cor��� rective action program (CAP). Such a plan may be considered a mitigating circumstance by MSHA if it contains ���concrete, meaningful measures that can reasonably be expected to reduce the number of S&S violations at the mine; are specifically tailored to the compliance problems at the mine, and contain achievable benchmarks and milestones.��� In addition, operators must begin to play a more active role in inspections and investigations to reduce the num��� ber of erroneously written citations. www.rockproducts.com Operators should consider providing supervisors with sufficient training to guarantee effective participation both during the inspection and at the close��� out conference. This type of training is provided by Patton Boggs and can be individually tailored to fit the oper��� ator���s needs and schedule. All in all, the new POV rule will im��� pose wide���ranging challenges for op��� erators. How to deal with these challenges and the increased risk of being placed on POV is just being sketched out. But operators must be aware of the increased role they will now play in preventing issuance of POV notices and possible withdrawal orders. In the unfortunate event that an operator is placed on the POV under the new rule, the operator should consider seeking legal counsel to ensure the continued operation of the mine. E Operators should consider providing supervisors with sufficient training to guarantee effective participation both during the inspection and at the closeout conference. ROCKproducts ��� MARCH 2013 75

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