Over the years, in the mining industry, there have been dozens of fatalities and hundreds of injuries involving mobile equipment. Unfortunately, there have already been 5 mobile equipment related fatalities and dozens of injuries in 2024 and the year is only half over. In an effort to improve miners’ safety around mobile equipment, the Mine Safety and Health Administration (MSHA) will begin enforcing Part 56 Subpart T for Surface Mines and Part 57 Subpart U for Underground Mines on July 17th. These new regulations require all Production Operators and Part 45 Independent Contractors to have a written Safety Program for Surface Mobile Equipment.
Before beginning to write your new program, you need to know what equipment this new standard applies to and how MSHA defines “mobile equipment”. According to MHSA, this written program applies to all surface mobile equipment operating at surface mines (both coal and metal/nonmetal) and any mobile equipment that operates solely in the surface areas of underground mines. The only equipment that is excluded from the new safety program operates either entirely underground or a combination of underground and on surface.
Typically, when MSHA says “mobile equipment” they are referring only to self-propelled mobile equipment. However according to 56.23001, this new standard covers all “wheeled, skid-mounted, track-mounted, or rail-mounted equipment capable of moving or being moved, and any powered equipment that transports people, equipment, or materials, excluding belt conveyors”. So, to summarize, this written safety program should cover all mobile equipment (self-propelled equipment, equipment capable of being moved and equipment used for transporting people and anything else) operating at all surface mines and the surface areas of underground mines.
Now that we know what MSHA expects, we can begin the process of building your program. The first step is to put together a comprehensive list of all the different types of mobile equipment used in your operations. It is a good idea to separate them into the different categories that MSHA uses: wheeled equipment, skid-mounted equipment, track-mounted equipment, and rail-mounted equipment. Under each category, list your equipment by type, not by make and model. It is the same idea as when you built the task training section of your MSHA Training Plan. For example, use an electric shovel, bulldozer, excavator, wheeled loader, etc.
MSHA expects your written safety program to have four main sections for each of these equipment categories:
- Identifying and analyzing risks involved with mobile equipment operation
- Developing schedules and procedures for routine and non-routine maintenance
- Identifying emerging technologies that can enhance mine safety
- Training the miners to identify and address mobile equipment hazards
The first section of the safety program requires that you work with the miners who are operating the mobile equipment to identify potential risks. Some risks are going to be similar across all mining operations, for example: weather conditions, terrain, environmental factors, maintenance, and repair risks.
Some risks will be specific to your operation: areas with overhead powerlines and specific congested areas like a crusher for example. Don’t just focus on the mining operations, think about everything impacted by mobile equipment, from administrative areas to pedestrian walkways.
Once the risks are identified, start listing the controls in the safety program that can be used to mitigate the risks. Think about both what you are currently doing to keep your miners safe and any improvements that you can make. These controls can be anything ranging from written procedures and risk assessment tools to backup cameras and proximity detection systems. Make sure that you keep track of what risks are mitigated by which controls.
The second section concerns the schedules for both routine and non-routine maintenance. Explain that you follow manufacturer recommendations and Original Equipment Manufacturer’s (OEM) and supplier maintenance recommendations. When detailing maintenance requirements in the safety program do not just copy preventative maintenance schedules out of the owner’s manual.
Only include the general requirements for each. For example, maybe you require 250-hour oil changes and 1000/2000-hour services for all your skid-mounted equipment and 5000-mile oil changes for your light vehicles. Include those schedules under the appropriate equipment category. And don’t forget to include any special maintenance requirements such as tracking the hours on wire rope.
Also include in this second section how your maintenance system works. Include how equipment hours are tracked, work orders are managed, and how you schedule repairs. It makes sense to tie this section in with the third section dealing with emerging technologies since there are such good computer and app-based maintenance tracking systems out there now.
For non-routine maintenance, you should explain how your maintenance group responds when equipment goes down and what can be done to improve it. Do you have 24-hour on-call maintenance supervisors and mechanics? Any written procedures that would cover emergency breakdowns? What are your safety policies? You don’t have to list out exactly how many mechanics you have or all the written procedures, just that you have them in place.
The third section is where you explain how you are going to keep up to date with emerging technologies. There is a lot of new technology available from proximity detection systems to maintenance tracking systems. Include if there are any industry representatives you communicate with, conferences you attend or manufacturer websites you visit.
If you don’t do any of those things it might be a good idea to start. There are a lot of resources out there and a lot of technology that can help. GroundHog, for example, has a web and app-based system that will allow you to manage and track equipment maintenance. MSHA showcased some emerging technology on their last call and they clearly want the industry to start innovating.
The fourth and last section covers how you are training your miners. One of the best ways to ensure that consistent training is being done is to create written training plans for each piece of equipment. Do you have written procedures for equipment inspections, maintenance and for locking out the equipment? And when the training is complete, how do you track it? If you are using a system like GroundHog LMS to manage your training, you can include that you are using an app and web-based program.
Once you have gathered all this information, it is time to put your written program together. As far as the format, there is no required one, but MSHA has several example templates on their website: www.msha.gov/compliance-assistance-templates-and-other-resources. When I wrote my program, I did not use these formats and simply wrote it as a document without using tables. Use whatever format that works best for you and your company.
You can begin with the basic safety controls that apply to all of your mobile equipment: wheel chocks, parking ditches, parking brakes, etc. Then each category of equipment needs to have its own section with all the identified hazards, controls, maintenance, potential emerging technologies and training plans for the miners. The final two sections of the program should cover who the responsible person for the program is and how the miners are able to review the program.
Per MSHA, the responsible person or persons for the written program must “have experience and knowledge about mining conditions and processes necessary to evaluate and update the written safety program”. Do not include the actual name of the responsible person(s), just include their position and/or title. After the main responsible person(s) is identified indicate who will be responsible for:
- Changes in Conditions/Practices Adversely Affecting Health and Safety
- Occurrence of Accidents/Injuries
- Surface Mobile Equipment Changes/Modifications
This could be the same person for all, but it is recommended you break the responsibilities out like this.
Finally, explain how this program is being communicated to the miners. Is it discussed at safety meetings, or posted in line-out rooms? And ensure that miners not only can read the program but that they can make comments and suggest changes.
When your written program is complete, it is not a bad idea to reach out to your local MSHA Educational Field and Small Mine Services (EFSMS) representative and have them take a look. EFSMS is a very underutilized group in MSHA that exists to help and train and are one of the best resources when it comes to a new program like this. Their website is: arlweb.msha.gov/epd/efsms/
Operating mobile equipment can be one of the most hazardous activities that we do as part of our mining operations. While at first this new requirement for a written program may seem like a huge task, you are likely doing most of it already and just need to gather what you are likely already doing into one comprehensive written program. At the same time use the opportunity of writing this program to look with fresh eyes at what you are doing and what can be done better to keep your miners safe.
A Safety Training System commonly used in mines is GroundHogLMS.com
You can also read more about Safety at mines at https://groundhogapps.com/mining-safety-lms/
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.
