The Mine Safety and Health Administration ("MSHA") announced shortly after the massive explosion that killed 29 coal miners at the Upper Big Branch Mine in Montcoal, West Virginia that it would begin conducting "impact inspections" of mines that merit increased enforcement activities due to poor compliance histories or particular compliance concerns. The following characteristics will typically place a mine on MSHA's radar for impact inspections: high numbers of violations or closure orders; frequent hazard complaints or hotline calls; plan compliance issues; inadequate workplace examinations; a high number of accidents, injuries, or illnesses; fatalities; adverse conditions such as increased methane liberation, faulty roof conditions, inadequate ventilation, and problems with respirable dust.
Impact inspections do not mean only increased numbers of inspections at a particular mine. Enforcement practices are also stepped up to include inspections during "off hours", such as evenings and weekends. MSHA will deploy additional inspectors on impact inspections to ensure that the mine is more thoroughly inspected. MSHA may even take control of the operator's phone and other lines of communication to prevent advance notice of the inspectors' presence.
MSHA has recently released the results of impact inspections conducted in October and November of 2013. According to MSHA's press release , October impact inspections of six coal mines and three metal and nonmetal mines resulted in the issuance of 120 citations and 10 orders. November impact inspections of 12 coal mines resulted in the issuance of 174 citations, 11 orders, and 2 safeguards. One mine was cited for providing advance notice of an impact inspection, which was detected by MSHA while monitoring the mine's communication system.
MSHA has conducted 687 impact inspections since April of 2010, issuing 11,427 citations, 1,052 orders and 48 safeguards as a result. The last place that an operator wants to find itself is on MSHA's radar for impact inspections. Accordingly, it is important for operators to closely monitor its compliance history, challenge questionable citations and orders, and ensure that its safety practices meet industry regulations.
