Aggregates Manager Digital Magazine
Issue link: https://read.dmtmag.com/i/113147
OPERAT 1 By the numbers Partnerships Produce a Common Understanding on Requirements W hen it comes to inspections, one area has long stood out as a trouble spot: guarding. In 2006, nearly one in six citations involved guarding. From a raw numbers perspective, paper written against the various guarding regulations peaked in 2010, with 10,877 citations issued. Operators were frustrated by guarding and other rules that seemed to be enforced differently from one part of the country to another and angered over citations that seemed to run contrary to prior regulatory guidance, particularly on matters such as inadvertent contact, fall protection on mobile equipment, and berms around scales. At the same time, changes to Part 100 essentially doubled the cost of fines and cut a 30-percent reduction in penalty for good faith — i.e., rapid compliance and correction of the violation in a timely manner — to 10 percent. "In the metal/non-metal business, the prices of material are fairly low, it was really starting to cut into people and affect their profits," recalls Ed Elliott, safety and health director, Rogers Group, Inc., Nashville. "The majority of non-metal mines are small mines, so if you have one site and an inspector comes in and writes some heavy penalties, it has a pretty dramatic effect." Assistant Secretary of Labor for Mine Safety and Health Joseph A. Main explains that when he became secretary in late 2009, "there was a realization in (the Mine Safety and Health AGGREGATES MANAGER Administration) MSHA that the most commonly cited violation dealt with guarding." Neal H. Merrifield, administrator in the Metal and Nonmetal Mine Safety and Health Administration, was already working on the issue, but Main says they decided to "beef up our education and outreach in that area to better protect our nation's miners, be more consistent, and better explain what our expectations were." MSHA worked with a number of state and national associations, including the National Stone, Sand & Gravel Association and state associations in Oregon, California, Virginia, and North Carolina to identify areas that needed to be clarified and develop tools that provide that clarity. Among the results are two Power Point presentations that detail examples of adequate and unacceptable guards. The first presentation, "Guarding Conveyor Belts in Metal and Nonmetal Mines," was published in 2010. In October 2012, a second presentation, "Guarding Machinery at Metal and Nonmetal Mines," was released. "If you really want to measure the success of what we've done, you can start all the way back and look at fiveyear intervals," Merrifield notes. From 1996-2000, there were 15 guard-related fatalities; from 2001-2005, there were eight; from 2006-2010, there were three; since 2010, there has been only one. "I think we're moving in the right direction," Main says. "We keep doing what we're doing. It works." According to the newest Power Point presentation released by MSHA, "Guarding Conveyor Belts in Metal and Nonmetal Mines," injuries caused by at-risk work practices represent approximately 30 to 40 percent of guarding-related injuries, while inadequate guard design, construction, and maintenance are responsible for 60 to 70 percent of guarding-related injuries. Inherently dangerous guards, with features such as sharp edges or points, caused lacerations and puncture wounds accounting for 12 percent of guard-related injuries. 4 Guarding by location? This photo shows an unguarded V-belt drive at a ladder-less work platform. This drive is not guarded by location because it is not 7 feet from the working surface. The work platform is the elevation reference point for the 7-feet guarded-by-location measurement rather than the surface of the ground below. Therefore, a point of contact guard is required at this location to protect miners from contacting the rotating components. If a work platform exists, the moving machine parts to which it provides standing access must be guarded.