MSHA Enforcement: RESPA® saves Underground Silica Mine Thousands in MSHA FINES

When permissible exposure limits (PELs) are exceeded, companies can face heavy fines. Thankfully, Sy-Klone offers the RESPA® Series products that have proven case studies to show their effectiveness in reducing exposure, thus helping to reduce fines.

 

 

Silica airborne particles are 20 times more toxic to the lungs than coal dust alone; nevertheless, silicosis is the world’s oldest known occupational disease. Workers who are exposed and inhale invisible Silica (RCS) particles are at increased risk of developing serious – and often deadly – silica-related disease.

In the United States, the Mines Safety and Health Administration (MSHA) has introduced a new rule that has lowered the concentration limit for respirable coal dust from 2.0 mg/m³ to 1.5 mg/m³.In regard to Silica, the Occupational Safety and Health Administration (OSHA) new rule has been brought in and is expected that MSHA will follow suit. The new limit from OSHA’s new rule cuts the permissible exposure limit (PEL) in half from 100 to 50 micrograms (as an 8-hour time-weighted average). Failure to meet these limits means fines to the site.

The Case Study

The case study below features an excavator using a RESPA® in 2008 & 2009.  Since this study, Sy-Klone has introduced newer patented technology that is smaller and offers even better filtration options.  So, while this case study is impressive, the newest technology reduces PELs even further. You can read about our newest technology here and even another case study here.

A Caterpillar 330CL excavator, operating as a scaler in an underground Silica Mine in Wisconsin, USA., was out of compliance each of the five times that the Mine Safety and Health Administration (MSHA) tested the average daily exposure rate of the operator to (RCS). Prior to the installation of the REPSA®, the excavator not only failed every time it was tested, but it failed by a rather dramatic margin.

Each of the tables shown below is the actual MSHA test reports as shown on the MSHA website for the specific mine and machine tested. See Table “A”

Table “A” (Before RESPA-SD)

Guide to abbreviations and codes below, please scroll down. Failing results listed in red.
MSHA Mine Inspection: Personal Health Sampling Results
Date Location Job Contaminant Concentration PEL PPE Action % Below PEL
10/31/2009 UG – Active production Scaling (mechanical) Quartz, respirable, > 1% Qtz 0.43 0.21 Y C (Citation order issued) 205% of PEL
08/25/2009 UG – Active production Scaling (mechanical) Quartz, respirable, > 1% Qtz 1.32 0.21 Y C (Citation order issued) 629% of PEL
12/16/2008 UG – Active production Scaling (mechanical) Quartz, respirable, > 1% Qtz 1.06 0.70 Y C (Citation order issued) 151% of PEL
10/28/2008 UG – Active production Scaling (mechanical) Quartz, respirable, > 1% Qtz 1.03 0.41 Y C (Citation order issued) 251% of PEL
07/16/2008 UG – Active production Scaling (mechanical) Quartz, respirable, > 1% Qtz 2.20 0.33 Y C (Citation order issued) 667% of PEL

The last time the machine failed, it received a D-Citation and the machine was removed from operation until it could be brought into compliance. Each of the citations was accompanied by a substantial fine.

The mine operator sealed the cab and was still unable to get the cab to meet the exposure limits.

The RESPA® was properly installed on the sealed cab on 11/5/2009. MSHA tested the operator of the cab on 11/17 and 11/18 and for the first time since the excavator began operation at the mine, it passed the MSHA test. It was released to full operation in the mine. Since that time was again inspected on 2/3/2010 and was still under the Permissible Exposure Limit (PEL).

Table “B” (After RESPA-SD)

Guide to abbreviations and codes below, please scroll down. Failing results listed in red.
MSHA Mine Inspection: Personal Health Sampling Results
Date Location Job Contaminant Concentration PEL PPE Code % Below PEL
02/03/2010 UG – Active production Scaling (mechanical) Quartz, respirable, > 1% Qtz 0.25 0.26 Y 96% of PEL
11/18/2009 UG – Active production Scaling (mechanical) Quartz, respirable, > 1% Qtz 0.71 1.47 Y 48% of PEL
11/17/2009 UG – Active production Scaling (mechanical) Quartz, respirable, > 1% Qtz 0.18 0.49 Y 37% of PEL

Worth noting:

  • The cost of the RESPA® installation was less than one of the MSHA fines.
  • As the filter loads, cab pressurization is reduced. This problem is easily solved by a changing the fresh and recirculation filtration.
  • The concentrations go up and down dependent on the actions of the operator on the day of the MSHA test. The number times the operator opens the cab door will also affect how much silica is brought into the cab.
  • This was a RESPA® installation which filters only the fresh air. With an upgrade to the RESPA-CF2 and a RESPA-FFX2 system (which addresses the fresh AND recirculation air), the silica concentrations would be dramatically reduced. Filtering all of the recirculation air within 2 minutes after the door is shut through high-efficiency filtration dramatically reduces the concentrations of silica in the cab. This is a proactive approach which leads to short decay times (the period of time it takes for the silica to fall or be taken out of the air) The RESPA® Cab and Enclosure Air Quality Products are the most effective solutions for meeting cab enclosure compliance requirements.

MSHA Enforcement of Permissible Exposure Limit (PEL)

MSHA is very serious about the Permissible Exposure Limit (PEL). They are actively testing and citing out of compliance cabs. Fines associated with a citation run from thousands to tens of thousands of dollars. D-Citations put the machine out of commission, compounding the mine owners expense associated with downtime on critical equipment.

The good news is that Sy-Klone developed RESPA in conjunction with NIOSH to provide a low-cost engineering control to help bring machines into PEL compliance.

If you have further questions about this particular case study or desire more specific information about your situation and Sy-Klone’s cab air quality systems, please e-mail sales@sy-klone.com

Legends (Guides to MSHA Codes and Abbreviations)

Personal Health Sampling Results: Key to Abbreviations
Abbreviation or Label Meaning
PEL: Permissible Exposure Limit: Shown in Red if the concentration exceeds PEL x Error Factor
Units: Dust expressed in mg/m3
Noise expressed in % noise dose
DPM expressed in µg/m3
Fume expressed in µg/m3 or mg/m3
CO2 expressed in %
Other mine gases expressed in ppm
Asbestos and Mineral Fibers expressed in fibers/ml
For DPM, The miner is overexposed when: a) EC on the personal sample exceeds 160 x EF; or
b) EC on the personal sample is less than 160 x EF, TC on the personal sample exceeds 160 x EF, and EC on the personal sample times the ratio of TC to EC from the area sample exceeds 160 x EF.
PPE: Personal Protective Equipment Used
Action: MSHA enforcement action taken.

 

MSHA Action Code Translation Table
Code Action Code Action
C Citation or Order issued E Exceeds the PEL, but not the PEL x Error Factor
P All feasible engineering controls completed T Citation or order terminated
X Citation or order extended N Exceeds the PEL (code no longer used)
L Lab Results Indicate Exposure Limit Exceeded N/C Not cited (additional controls determined to be infeasible)

If you have further questions about this particular case study or desire more specific information about your situation and Sy-Klone’s cab air quality systems, please e-mail sales@sy-klone.com

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