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Work
ing in a mine can be a great business opportunity for contractors.
By John Fowler, CSP, CMSP
Water is the enemy of most mines and most need dewatering wells if they want to continue mining. They also often need monitoring wells drilled and maintained as well as piezometers and vibrating wire lines installed to monitor groundwater and formation movement. Last but not least, many mines rely on exploration drilling to determine future mining plans.
So, while it can seem a bit intimidating to many groundwater professionals, working in a mine can be a great business opportunity for those contractors who are prepared and understand what is required of them when working on a mine site.
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[restrict userlevel=”subscriber”]Knowing the Site
The first thing you must determine is whether or not you are working on a mine site. Just because you are working in a pit or excavation doesn’t necessarily mean you’re working in a mine. Although the Mine Safety and Health Administration (MSHA) and the Occupational Safety and Health Administration (OSHA) are both under the Secretary of Labor, they each have their own jurisdiction.
The 1977 Mine Act gave MSHA jurisdiction over all types of mining as well as mine development, rehabilitation activities, and exploration work at an established mine. MSHA does not have jurisdiction “where a mineral is extracted incidental to the primary purpose of the activity” (Program Policy Manual Volume 1 4-1).
For example, a highway road cut, highway or train tunnel, borrow pit for fill dirt, underground storage areas, etc. are not considered mines and are under OSHA’s jurisdiction. To further confuse the issue, many states have their own state mining agencies with their own rules and jurisdiction. The best way to determine whether or not you are working on a mine site, if there is any question, is to ask the client.
The Requirements
There are four main areas contractors need to understand and be prepared for when planning to work on a mine site: State and federal MSHA new miner training, equipment guarding requirements, training certificates and required documented inspections.
There are two types of new miner training required by MSHA for working in surface mines: Part 46 training and Part 48 training. Part 46 training is only accepted in quarries, and sand and gravel mines, while Part 48 training is accepted in metal/nonmetal mines, the surface areas of underground mines, as well as the quarries, and sand and gravel mines accepting Part 46 training.
I could write an entire article on the differences between the two types of training, but just know Part 48 training is more regulated and has to be taught by a MSHA-approved instructor using a training plan submitted to MSHA and approved. This is why Part 48 training is accepted training for all surface mines.
Part 46 trainers are only required to be deemed “competent” and the training plan they use must cover the required material specified by MSHA, but does not need to be submitted to MSHA for approval.
Both Part 46 and Part 48 training require 24 hours of new miner training (three eight-hour days) if you are new to mining with eight hours of refresher training every year. Part 46 will allow non-MSHA training (OSHA 10 and 30 for example) to count toward those hours, but Part 48 will not.
There are third-party MSHA-approved instructors with approved training plans who either have open-enrollment training classes or who can put on a class specifically for your company. The classes are full of valuable information and the instructors are great resources for what is required to work on a mine site.
Try to find a trainer who has experience with drill rigs and pump servicing. Online MSHA training is now available, but some mines who will not accept this type of training so make sure to ask the mine. The MSHA website is a great resource and has information on what is required of contractors. Often if you call local mines and ask about third-party trainers they can provide names.
Mine sites have strict equipment guarding requirements especially when it comes to drilling rigs. A guard is required for all moving and rotating parts, and yes, this includes drill rods.
A rotation guard needs to be in place to prevent contact with the rotating rods, and just know before you push back and say that it is impossible or that it will interfere with drilling, it is now commonplace to see rotation guards on drill rigs drilling on mine sites.
One of the common equipment requirements often overlooked are pressure vessel inspections. Mine sites require a documented pressure vessel inspection from a qualified inspector of all pressure vessels, like an air compressor receiver tank over a certain psi and volume. This pressure vessel inspection is often asked for during drill rig inspections because it is so often overlooked.
Mine operators themselves are a great resource because if you get an MSHA citation on their site it will go against the mine’s record as well. In fact, a mine will often inspect your equipment at your yard or in the parking lot outside the mine gate before it allows the equipment onto their site.
Once on a mine site your task and equipment training must be documented on an approved training certificate. On a Part 48 governed mine site (metal/nonmetal, surface of an underground mine) the certificates are known as 5000-23 forms or “5000-23s.”
The 5000-23 form can be downloaded and printed off the MSHA website. Part 46 governed sites will accept 5000-23 forms, but also have their own training forms available on the MSHA website.
Sometimes people go overboard on their task training so just remember if it is a piece of equipment or a major task you should have documented task training. Your MSHA new miner training is a great time to ask questions about the training forms—how to complete them and what training is required to be documented.
The last requirement a water well drilling and pump servicing company needs to understand are the requirements for documented inspections. The main documented inspections are a: work place exam that must be completed at the beginning of the shift and pre-use inspections of mobile equipment before operation.
Again, this will be covered in your new miner training, but often the first thing asked for by a mine representative or MSHA inspector when they show up on your site is for a work place exam form. If you don’t want to create your own forms the mines will have inspection forms they can share. In fact, some mines require that you use their forms.
One Final Tip
Often when drilling and pump servicing companies work on mine sites they come in under the radar and do things like work for a few days at a time thinking they are in compliance. This can lead to citations for both the contractor and the mine.
And unlike OSHA, MSHA is required by law to inspect every surface mine at least two times per year so inspections are common. Often federal MSHA and state agencies work together to ensure mines are inspected as required.
If you are working on a mine site you are required to have either Part 46 or Part 48 new miner training and additional state-required training on occasion. A contractor who is trained and understands the requirements of working on a mine site is less likely to receive a citation.
Just think about it: Who would a mine operator rather have on site: A contractor who has to sneak in and out of the mine a few days at a time or a contractor who understands what is required and can work straight through until the project is completed?
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Fowler will be presenting a workshop on working in a mine at Groundwater Week 2018, December 3-6 in Las Vegas. He will also present a workshop on the new OSHA crane regulations.
John Fowler, CSP, CMSP,is a safety manager for National Exploration, Wells & Pumps in Gilbert, Arizona. He can be reached at jfowler@nationalewp.com.