|U.S. Department of
Mine Safety and Health Administration|
4015 Wilson Boulevard
Arlington, Virginia 22203-1984
Mr. David Hales
Safety and Compliance Supervisor
Canyon Fuels Company, LLC
PO Box 719
Helper, Utah 84526
Dear Mr. Hales:
Thank you for your October 5 letter concerning the diesel regulations and our September 28 meeting in Price, Utah. I am glad to hear that you found the meeting beneficial in resolving some of your questions about the portions of the new diesel regulations which become effective November 25, 1999.
Allyn Davis and I have discussed the issues raised at the meeting and we are working to resolve them as quickly as possible. The Mine Safety and Health Administration (MSHA) intends to apply the diesel safety regulations consistently for each mine operator. I believe that the joint training and hands-on inspection of equipment you have helped organize for our November 9 meeting will be extremely useful in this regard. I am convinced that both MSHA and industry representatives will benefit from this effort. I plan to attend along with Jack Kuzar and the managers from those MSHA district offices where diesel equipment is used extensively.
As promised at our September 28 meeting, we recorded the questions received, both during and after the meeting, and a copy of the questions along with our responses is enclosed. This document will also be distributed to all MSHA enforcement personnel.
In response to your specific question regarding the source of the 150 percent park brake set pressure which was discussed on September 29, I have found that the number was drawn from a 1979 performance criteria document for emergency and automatic parking brakes. This is not a specific requirement and is intended only as guidance. I have enclosed a copy for your information. Because the regulations are performance-based, there have been many questions regarding the acceptability of various methods of compliance. MSHA intends to enforce the regulations consistently and is working to ensure that guidelines are not presented as specific requirements.
I am looking forward to our meeting on November 9. If you have any further questions, please contact me or Allyn Davis at (703) 235-1140.
Robert A. Elam
for Coal Mine Safety and Health
- Questions and Answers from the September 28,1999, meeting of Utah Mining Association in Price, Utah
- Technical Criteria for Certification of Performance of Emergency Brakes and Automatic Parking Brakes for Rubber-Tired, Self-Propelled Electric Underground Mining Equipment - (PDF)