Quality mobile equipment training is important regardless of the industry, but it is even more critical when you are working on a mine site. Not only is it a challenging and hazardous work environment, but MSHA has certain requirements ranging from how the training should be conducted to how the training should be documented. It is important to understand the requirements, both for the safety of your operators and to ensure that you are in compliance with MSHA. Being out of compliance can be costly both to your reputation and your bottom line.
Identifying Qualified Trainers for Effective Mobile Equipment Training
Before training can even begin, it is important to identify your trainers. MSHA requires that “All training and supervised practice and operation…shall be given by a qualified trainer, or a supervisor experienced in the assigned tasks, or other person experienced in the assigned tasks.” 48.7(e) When selecting your trainers, you should not only look for individuals that are trained on the equipment, but also those who are able to effectively instruct. In fact, MSHA requires trainers to have either formal or informal training on how to task train. And this makes sense. How many times have we worked with an experienced operator who is not shall we say a “people person”? Yes, they may have decades of operating experience, but if they don’t have the skills or desire to pass the information along, they shouldn’t be a trainer.
Once the trainers are identified, it is time to start planning how the training will be conducted. MSHA 48.7 requires that your task training plans be made up of three parts:
- Health and safety aspects and safe operating procedures for work tasks, equipment, and machinery.
- Supervised practice during non-production and supervised practice during production.
- New or modified machines and equipment.
Never have a new operator jump into a new piece of equipment and start their “training” by just putting them to work. Working in a production environment is an important part of the training, but that will come later. In the beginning, the training needs to be in an environment where the new operator can focus only on the training. The task training needs to cover what the operator needs to know to be safe and competent. For example, the inspection of the equipment, the operation of the equipment, how to start up and shut down the equipment, any safety and health concerns with the equipment and how to report any deficiencies with the equipment. In addition, you should train the operators on how to lock out the equipment and the basics of it’s required maintenance. Not how to change the oil, but how frequently the oil needs to be changed, for example.
Typically, mobile equipment training will start with the equipment’s pre-operational inspection. Ensure that the operator in training knows how to check everything that is on the pre-operational inspection form and knows what would be considered a deficiency. Especially any deficiency that would place the equipment out of service. And make sure that the new operator knows how to report any deficiencies they may find. This is an often-overlooked part of the training, but deficiencies that are discovered during an inspection don’t do anyone any good if they are just written down on the inspection form and forgotten.
MSHA-Compliant Mobile Equipment Inspections
MSHA does not lay out line by line exactly what is required to be inspected on mobile equipment, but they do require that the braking system be inspected and there is a particular way it needs to be done. 56.14101 states that “Self-propelled mobile equipment shall be equipped with a service brake system capable of stopping and holding the equipment with its typical load on the maximum grade it travels.” Sometimes equipment manuals will have different procedures on checking brakes. For example, backhoes might require the operator putting the equipment into a certain gear and pulling against the brake but understand that MSHA expects brakes to be checked using the MSHA procedure: Stop on the maximum grade the equipment travels on, set the brakes and ensure that they hold.
The next part of the mobile equipment training is starting and operating the equipment in a controlled environment. This is not the time to head out onto a busy haul road, but instead practice in an area where the new operator can just focus on the training. In a perfect world, the equipment has two seats allowing the trainer to ride along, but that is not always the case. If there is only one seat in the equipment, the trainer must be there directly supervising the operator in training. They cannot be working in the same area and looking over from time to time. The trainer’s only job is supervising the training of that new operator.
Once the new operator is comfortable, it is now time to start training in a production environment. This is specifically stated by MSHA because an important piece of this task training is how to work in and around other mobile equipment and when there is the pressure of production. Keep in mind that the new operator still has not been signed off, so they still need to be supervised. This stage of the training is typically the “final exam” before they are signed off.
When the training is complete, and both the trainer and the trainee feel that the trainee is competent to operate the equipment it is time to document that training as complete. Part 46 and Part 48 mines have different ways that this training should be documented. On a Part 46 mine (sand/gravel pit, quarry, etc.) the training needs to be documented either on a MSHA 5000-23 form, or on a form that has certain information specified by MSHA. Name of trainee, duration, date, name of competent person conducting the training, etc. On a Part 48 mine (metal/non-metal surface/underground mines) the task training can only be documented using a 5000-23 form.
The 5000-23 form is very well-established and is a great way of documenting “who” is trained, but it is not a good way of documenting “how” the person was trained. And the “how” a person is trained is just as important as documenting “who” was trained. I highly recommend creating a written training plan for your equipment. This is for two reasons: the first reason is to ensure consistent training. If you do not have a written training plan, all you have to rely on is the memory of the person conducting the training. And this will lead to very inconsistent training completely depending on the trainer.
The second reason is so that if something happens you have a documented outline of how the training was conducted. It’s even better if you have the person sign the training plan and then issue the 5000-23. Now you have both a signed 5000-23 documenting who is trained and a signed training plan laying out how the training was completed. If there is an accident involving that equipment and the operator’s training becomes an issue it won’t be he said/she said. You will be able to produce exactly how the operator was trained.
The training does not end when the 5000-23 is signed. Operators need to be evaluated periodically and re-trained if there are modifications to existing equipment and/or procedures. This constant training is one of the most important things we can do on a mine site to create a safe working environment. Often training is overlooked for a variety of reasons, ranging from lack of resources to production pressure. A safe mine is a productive mine and a safe operator is a productive operator. So, let’s take the time to make sure that not only is the training being done right, but it is also being done by the right person.
About the Author: John Fowler
John Fowler is a Certified Safety Professional and a Certified Mine Safety Professional who has worked on projects ranging from offshore oil/gas platforms in Alaska to surface and underground mines in the western US. You can contact John at john.m.fowler@gmail.com.
