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> MSHA Enforcement: RESPA-SD saves Underground Silica Mine Thousands in MSHA FINES
MSHA Enforcement: RESPA-SD saves Underground Silica Mine Thousands in MSHA FINES
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 respirable crystalline silica (RCS). Prior to the installation of the REPSA–SD, the excavator not only failed every time it was tested, but it failed by a rather dramatic margin. Each of the tables shown below are 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-SD 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-SD 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 an RESPA-SD installation which filters only the fresh air. With an upgrade to the RESPA-SDX system (which addresses the fresh AND recirculation air) the silica concentrations would be dramatically reduced. Filtering all of 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 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-SDX system is the most effective solution and should be used on cabs that cannot be brought into compliance with the RESPA-SD fresh air system.
MSHA Enforcement of Permissable 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. There is nothing on the market today that incorporates the unique, patented Gideon particle-separation technology into a low cost highly effective fresh and recirculation air Cab Air Quality System like RESPA-SD and RESPA-SDX.
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 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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