respirators and MSHA

[Kent Lee Ivey <kkiveylw@xxxxxxxx>]

* Follow-up to message from: George Graham
* Original date (y/m/d) was: 03 May 2003
* Original subject was: hand carving memorials/resperators

As the subject is on masks, eye protection and such, though
I hate to do it , I feel compelled to chime in on a subject
not so popular ... laws regarding health and safety. Before
I started this , I checked the archives for any reference to
MSHA ... Mine Safety and Health Administration. Here in the
USA, this bunch has new jurisdiction over ANY mine activity.
If you so much as stick a shovel in the ground , and use
that mineral for commercial purpose, then they have laws
covering  the health and safety of YOUR outfit... Like it or
not.

I found no reference to MSHA , but have read some wonderful
posts from quarrymen. I have run a sand and gravel quarry
for a few years , and am still responsible for the safety
aspects of this operation.We get visits from the mine
inspectors twice yearly, and though we strive for
perfection, the inspector is NOT going to leave without at
least one citation... and these be not cheap.

A grinder with out a gaurd, a break in the insulation of an
electric cord... lack of a no smoking sign in the proper
place... before you know it 800 bucks  down the tubes. And
they just grin and grin.

Perhaps there is some clause in the Federal Register that I
have not stumbled on , but as I read it , any operation
involving any stone is subject to  inspection, at any time .
OSHA has been somewhat muzzled in the last few years , but
MSHA is just now standing on their legs  and starting to
flex their muscles. In addition to general and specific
physical safety issues, MSHA has training requirements for
any and all employees who so much as visit a quarry once.
more than about three visits and one is classified as a
miner, with a much more rigorous training regimine.

This is know as Part 46  Training, and there are about30
subjects that MUST be taught, in addition , a yearly
updatemust be taught. Initial training takes all of 8 hours
talking as fast as I can , with me waiting till my miners
are squirming in their seats  for three breaks.

THEN .... there must be documented records of ATTENDED on
the job training...daily records of quarry inspections,
equipment inspections, repair records... it just has no end.
Ah , I remember what brought me here ... masks. MSHA
requires a yearly hearing and dust monitoring regimine.In
past , MSHA inspectors would do this , but it is now the
responsibility of mine or quarry operators.

This involves wearing an air sampleing device for 8 hours,
pulling the air sample from the collar area of ones shirt,
so the sample is the same air the miner... or carver... is
breathing. The filter inside the device is then sent to a
lab to test for silica, and for exposer limits.Woe to the
mine or quarry that exceeds the daily parts per million
level.

At the same time , a hearing test is run, using a decible
meter and time weighted exposure parameters. On  calculation
of exposure by the miner, the inspector may make
RECOMENDATIONS(!!!!!) as to toneing down noise in work
areas, or additional hearing protection measures.

Also , MSHA has just put into force a HAZCOM enforcement
policy , involving MORE training for personel.... Not a bad
thing , but more hassle on top . MSHA has been and will
continue to become more aggressive in enforcing these laws
and fines. And they are really looking for small
quarries...hard.

The big guys are already in their net... now they are
seining the creeks for the rest of the fish.

MSHA. gov will take you to their web site... I strongly
recomend that anyone in any way involved with stone  take a
look at them. Ignorance of the law is no excuse, and these
guys are serious.

Again , if there is some codicile or clause exempting
carvers or stone quarries, please let me know , for I do not
know of it . I thank you all for the great sharing that goes
on here, I wish I had something more positive to share ...
If I can help anyone with dealing with MSHA, let me know , I
am deeply emeshed in their net , and may be able to save
someone some heartache and wallet ache.

Gratefull for the learning you folks give... Kent Lee Ivey,
Big Spring Texas.