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2 Mine Safety Regulations and Practices I n this chapter, we consider the regulations related to emergency pre- paredness, both their context and implementation, as well as processes for the adoption of needed technologies. We discuss mine practices and how they could be improved if information gathered under the normal working conditions unique to coal mining would be used to apply lessons learned to assess the efficacy of current procedures. We end the chapter with our conclusions and recommendations. REGULATORY CONTEXT AND COMPLIANCE As noted in Chapter 1, in the United States, the number of underground miners ranges from less than 20 to more than 500 (Mine Safety and Health Administration, 2011). The breadth of mine operations in size, multiplicity, and longevity in the United States leads to separate consideration of small mines and large mines (Yang, 2011). Although opportunities may exist for small mines to benefit from the experience and investment opportunities of large mines, uniform rules or regulations are more often interpreted as forcing small mines to try to keep up with larger mines (e.g., in purchas- ing power for cutting-edge training, safety systems, and technology). This range of operations across the industry leads to difficulty to proscribe a single, best systematic approach to manage mine safety. Regulations cre- ate a process to ensure mine safety that can be effectively applied to all mines, regardless of the mining method, production capacity, number of employees, or other mine characteristics. Consequently, regulations may be generically written to enforce only least-common denominator factors. 19

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20 IMPROVING SELF-ESCAPE FROM UNDERGROUND COAL MINES Regulatory compliance may serve the basic needs of some mines; however, many mines employ their own safety inspectors and have a safety manage- ment program that extends beyond focusing only on regulatory compliance. Housed in the U.S. Department of Labor, the Mine Safety and Health Administration (MSHA) is charged with carrying out regulatory provisions of the Federal Mine Safety and Health Act of 1977 (includes the original 1969 act and amendment in 20061) to enforce compliance with mandatory safety and health rules in U.S. mines. While the Mine Act designates respon- sibility for mine safety to the mine operator, MSHA is still considered to be a major factor in assuring mine safety (Independent Assessment Panel, 2012). Mine operators have an obligation to comply with the law. That compliance may be an important element of mine safety, because regula- tions require specific processes designed to prevent emergencies. In states where both MSHA and state-level agencies exercise authority over mine operations, regulatory compliance is enhanced but can be chal- lenging. Although not all coal mining states have their own legislation, most do, for example, Pennsylvania and West Virginia. In many instances, op- portunities exist for the actions of state agencies to positively influence the actions of federal agencies: for example, West Virginia legislation preceded federal legislation on refuge shelters. And in some cases state agencies have stronger safety rules for mines in their own jurisdiction than required by federal legislation: for example, regulations on diesel exposure are stricter in West Virginia and Pennsylvania than those implemented by federal regu- lations.2 The committee recognizes the potential value of understanding the differences of state and federal levels of enforcement, including why some states appear more active in mine safety than others or the federal govern- ment; however, these issues are beyond the scope of this study. The most significant federal regulation influencing mine safety pro- cedures in the last decade is the Mine Improvement and New Emergency Response (MINER) Act of 2006. This legislation, largely a response to the Sago Mine and Darby Mine No. 1 incidents, laid out a series of new safety expectations for mine operators. First and foremost, the MINER Act requires operators to develop an emergency response plan specific to each mine, to be regularly updated and approved by MSHA. It also requires rapid deployment of local rescue teams and provides certain liability protec- tion for those working in mine rescue or recovery operations. Also critical in the MINER Act are penalties: regulatory compliance is a moot point without enforcement capabilities. The act increased both 1  vailable: A http://www.msha.gov/REGS/ACT/MinerAct2006home.asp [November 2012]. 2  or F West Virginia, see Chapter 22A, Article 2A and Title 196, Series 1, Federal Sec- tion 72.502, available: http://www.wvminesafety.org/PDFs/Law%20Rev%202011%20- CORRECTED.VERSION.09.2.11.pdf [November 2012].

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MINE SAFETY REGULATIONS AND PRACTICES 21 civil and criminal penalties for violations of federal mining safety standards and gave MSHA the ability to temporarily close a mine that fails to pay the penalties or fines. Unfortunately, violations of the law have too frequently been associated with mine disasters, which compliance with the law may have prevented (Independent Assessment Panel, 2012). However, all pos- sible emergency contingencies cannot be anticipated and therefore cannot be prevented through regulation. Compliance is an important component of prevention and a minimum requirement for safety, but it is important to realize that it is only a starting point in a more comprehensive process of managing hazards, promoting safe behaviors and when necessary facilitat- ing self-escape. Ultimately, every mine operator has the responsibility to promote mine safety using every available resource. In its final sections, the MINER Act calls for the establishment of a Technical Study Panel on the Utilization of Belt Air and the Composition and Fire Retardant Properties of Belt Materials in Underground Coal Min- ing, additional research to be carried out by the Office of Mine Safety and Health at the National Institute for Occupational Safety and Health, and scholarships. These mandated programs have ushered attention to mine safety as well as to the improvement and development of more advanced communication systems, tracking devices, dust explosibility meters, and shelters and chambers. The committee heard from industry stakeholders who all reported significant safety advances since 2006. Research continues to explore new technologies that will further benefit the health and safety of miners, such as improved ventilation systems, emergency communica- tion and tracking systems, and breathable devices. Research is also being conducted to improve escape training, firefighting preparedness, and rescue training. Independent groups of stakeholders have also played a role in influencing mine safety procedures. The West Virginia Mine Safety Technol- ogy Task Force and the Mine Safety Technology and Training Commission have both produced reports with several recommendations to improve mining technology, among other things (see West Virginia Mine Safety Technology Task Force, 2006, and Mine Safety Technology and Training Commission, 2006). REGULATORY PROCESSES Enforcement In recent years, MSHA’s highly prescriptive regulatory paradigm and its enforcement have come under criticism (Yang, 2011; Luxbacher, 2012). A recent report analyzing the agency’s performance in relation to the Upper Big Branch disaster identified underlying and structural problems in the federal enforcement process for the Upper Big Branch incident as well as

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22 IMPROVING SELF-ESCAPE FROM UNDERGROUND COAL MINES five previous disasters. The report also concluded that the current opera- tions are problematic due to the breadth, complexity, and growth of MSHA inspector responsibilities (Independent Assessment Panel, 2012). The task of mine inspection has become one in which “few if any could be expected to succeed . . . the MSHA IR [Internal Review] Report describes in detail a workforce that is unprepared to undertake the full scope and complexity of inspecting the mines and overseeing the enforcement process” (Indepen- dent Assessment Panel, 2012). MSHA’s assistant secretary reported that reductions in staffing in the early to mid-2000s, particularly experienced inspectors, affected the agency’s ability to complete all mandatory inspec- tions. They have since hired more inspectors; new hires go through exten- sive training, and the agency has just recently begun to recover the needed expertise and manpower (Main, 2012). Technology Approval and Certification Similar deficiencies have been identified with the federal approval and certification process for technology. The mining technologies and products that are used in U.S. coal mines, ranging from small devices to large mining systems, are subject to MSHA’s approval and certification process. Equip- ment, instruments, and materials are evaluated and tested by technical experts for compliance with federal regulations. Organizational, manage- rial, and resource constraints within MSHA can pose a challenge to the introduction of new technology and mining methods that can improve miner safety and health. The regulations require a full subchapter in Title 30 CFR, including Parts 6, 7, 14, 15, 18, 19, 20, 22, 23, 27, 28, 31, 32, 33, 35, and 36.3 A wide range of items are presented in these parts including flame resistant conveyor belts, electrical equipment, intrinsically safe electrical systems, cap lights, diesel engines, to name a few, as well as other technologies specifi- cally relevant to the task of self-escape (see discussion in Chapter 3). A range of stakeholders informed the committee that the current tech- nology regulatory and approval process in the United States appears to be a deterrent to rapid technological innovation and access to global markets. Furthermore, lack of congruence between MSHA and internationally ac- ceptable requirements for approved equipment frustrates access to global markets for equipment designed for the U.S. market, which hampers the commercial viability of innovation (Luxbacher, 2012). At various times, MSHA’s Approval and Certification Center is under- staffed and in need of equipment upgrades to properly test new submittals for compliance with the existing rules. For instance, when new regulatory 3  Available: http://www.msha.gov/30CFR/CFRINTRO.HTM [November 2012].

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MINE SAFETY REGULATIONS AND PRACTICES 23 requirements are established MSHA’s workload is increased so that mines can comply with the law. An example of a challenge of this increased workload occurred following the passage of the 2006 MINER Act. The act required all U.S. underground coal mines to have communication and tracking systems. Since the solutions were not yet commercially avail- able, this requirement has driven advancements in technology, known as “technology forcing.” As the industry scrambled to find suppliers for these products, MSHA was swamped with new submittals. In many cases, the manufacturers had not fully developed their technologies, but were jock- eying for position to hold a place in the line. It took some manufacturers more than 2 years to finalize their products and get them approved. This process also slowed the approval of all other products going through the pipeline at the same time. Clearly, this hampered mine operators’ attempts to utilize the latest technologies. Some foreign companies who have relevant working systems have opted not to incur the costs of approval in the U.S. market when demand is so uncertain. In fact, there is a question as to whether the U.S. underground coal mining market is large enough to generate broad interest from manu- facturers of new technologies unless they have an opportunity to capture the lion’s share of the market (see West Virginia Mine Safety Technology Task Force, 2006). This situation, known as the “small market” issue, ef- fectively eliminates any opportunity for small companies to overcome the financial barriers to enter this marketplace while simultaneously creating a disincentive for large companies to do so. In addition, MSHA is having a difficult time recruiting the expertise needed to better understand emerging technologies and how they can be safely applied in the mining environment. The Independent Assessment Panel (2012) report on the Upper Big Branch disaster cited gaps in techni- cal knowledge and practice among the MSHA work force that need to be highlighted and systematically addressed. Furthermore, MSHA decided to abstain from full participation in an international standard certification effort (Chirdon, 2012),4 which impedes the acceptance of safety equipment certifications issued by other respected agencies, both domestic and abroad. This factor, along with the time, cost 4  0 3 CFR Part 6 permits manufacturers to have their products approved based on non-MSHA product safety standards. [However], this will occur only after MSHA has determined that such standards are equivalent to its applicable product approval requirements or can be modified to provide at least the same degree of protection as those MSHA requirements. To date, MSHA has reviewed the International Electrotechnical Commission (IEC) Standards for Flameproof (Explosion-proof) Enclosures and has found that these standards can be modified to provide at least the same degree of protection as those MSHA requirements. (Chirdon, 2012, p. 7)

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24 IMPROVING SELF-ESCAPE FROM UNDERGROUND COAL MINES of approval, and MSHA’s resource limitations, delays the development and introduction of new technology in U.S. mines. For a number of years, independent groups, analysts and other stake- holders have recommended that the approval process be expedited and harmonized with international standards. A key recommendation from the Mine Safety Technology and Training Commission (2006, p. 9) report stated, “In particular, MSHA should work to expedite the approval and certification process for technologies that can improve life safety.” A similar statement was made more than a decade earlier in 1993 through the Na- tional Performance Review (1993, recommendation DOL07): The harmonization of MSHA standards with those of industry and foreign governments will allow manufacturers already in the market (as well as those who previously found the industry to be unprofitable) to compete in world markets by permitting a single, globally acceptable product line with better control of replacement parts, reduced manufacturing costs, and improved quality control. International Standards for Equipment Some countries, such as Australia, have had success having their na- tional certification process closely aligned with international certification schemes. An internationally recognized certification system, under the aus- pices of the International Electrotechnical Commission for Certification to Standards Relating to Equipment for Use in Explosive Atmospheres (IECEx), promotes international cooperation on standardization for the safety of equipment in explosive areas where the objective is “to facilitate international trade while maintaining the required level of safety.”5 Key characteristics include • Reduced testing and certification costs to manufacturer • Reduced time to market • International confidence in the product assessment process • One international database listing • Maintenance of international confidence in equipment and services covered by IECEx certification The IECEx designation is accepted in more than 30 countries. Australia provides a good example of how participation in the IECEx has expedited the certification process. Most of the relevant Australian (and New Zealand) standards have now been derived from the IECEx standards so they are equivalent if not exactly the same. Testing may be done by an 5  vailable: A http://www.iecex.com/about.htm [November 2012].

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MINE SAFETY REGULATIONS AND PRACTICES 25 Australian laboratory, but the regulators will also accept certification from other nationally accredited testing stations. The country then has the choice of whether or not to accept certification from overseas stations. If concerns arise, testing agencies undertake a desktop exercise on behalf of the regula- tors that can take a few days to assess the quality of a certification from outside the country. This approach is much easier and quicker than a full assessment, which can take 12 weeks to 18 months to process, depending on the backlog. In contrast, the MSHA process requires that it does all test- ing for all equipment. Australian manufacturers, by having IEC certificates done in Australia, can very easily market to the European countries with Australian manufactured products. U.S. certified equipment may not meet IECEx certification standards and so cannot be marketed internationally without further testing. If IECEx standards were used in the United States, U.S. products could be marketed in Europe and other countries and the “small market” challenge could be reduced. Part 50 Reportable Accidents Section 50.20 of Part 50, Title 30 requires a Mine Accident, Injury, Ill- ness Report (Form 7000-1) to be prepared and filed with MSHA for each accident, occupational injury, or occupational illness (see Appendix B). The requirement includes all accidents, injuries, and illnesses as defined in Part 50, whether company employees or a contractor’s employees are involved: accidents that are immediately reportable are shown in Box 2-1. Although separate reporting of incidents requiring self-escape is not required, a review of Part 50 provides the opportunity to consider these in- cidents as reported on the 7000-1 forms. From an online database of more than 7,000 reports filed for 2006-2011, the committee examined data from all nonfatal reports to identify any incidents requiring evacuation from mines. Using the limited incident narratives, we used the terms “evacu- ate,” “escapeway,” “got out,” “withdrawn,” and “SCSR” (self-contained self-rescuers). The search identified 22 evacuations without fatalities: 8 due to inunda- tion of water, 5 from inundation of gas, 5 from mine fires, 1 from ignition of methane, and 3 were precautionary because equipment used in a primary escapeway was down or an escapeway was blocked. In all but two cases of mine fires, the fire was extinguished. From the brief narratives included with the reports, the committee noted conditions that triggered the response to evacuation. These included water flowing into active working areas; detection of elevated levels of carbon monoxide (CO) or methane through readings or atmospheric moni- toring system (AMS) alerts; and detection of odor of burning coal. It was

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26 IMPROVING SELF-ESCAPE FROM UNDERGROUND COAL MINES BOX 2-1 Immediately Reportable Accidents   1. DEATH: A death of an individual at a mine;   2. SERIOUS INJURY: An injury to an individual at a mine which has a rea- sonable potential to cause death;   3. ENTRAPMENT: An entrapment of an individual for more than 30 minutes or which has a reasonable potential to cause death;   4. INUNDATION: An unplanned inundation of a mine by a liquid or gas;   5. GAS OR DUST IGNITION: An unplanned ignition or explosion of gas or dust;   6. MINE FIRE: In underground mines, an unplanned fire not extinguished within 10 minutes of discovery; in surface mines and surface areas of underground mines, an unplanned fire not extinguished within 30 minutes of discovery;   7. EXPLOSIVES: An unplanned ignition or explosion of a blasting agent or an explosive;   8. ROOF FALL: An unplanned roof fall at or above the anchorage zone in active workings where roof bolts are in use; or, an unplanned roof or rib fall in active workings that impairs ventilation or impedes passage;   9. OUTBURST: A coal or rock outburst that causes withdrawal of miners or which disrupts regular mining activity for more than one hour; 10.  IMPOUNDING DAM: An unstable condition at an impoundment, refuse pile, or culm bank which requires emergency action in order to prevent failure, or which causes individuals to evacuate an area; or, failure of an impoundment, refuse pile, or culm bank; 11.  HOISTING: Damage to hoisting equipment in a shaft or slope which endangers an individual or which interferes with use of the equipment for more than thirty minutes; and 12.  OFFSITE INJURY: An event at a mine which causes death or bodily injury to an individual not at the mine at the time the event occurs. SOURCE: MSHA Mine Accident, Injury and Illness Report, Form 7000-1, see Appendix B. not always clear who initiated the evacuation, but the language indicates some sort of order is given, such as: “The mine was evacuated.” “Miners were withdrawn.” “The CO system sounded an alarm and the section crew was notified.” “Based on [the] findings [from two longwall coordinators] a decision was made to evacuate the mine.” “The AMS operator was alerted. . . . Shift Coordinator was notified and investigated. The odor of burning coal was detected and the order was given to evacuate the mine.” It was not clear whether SCSRs were donned in any of the incidents. The current Form 7000-1 for reporting injuries and illnesses includes a

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MINE SAFETY REGULATIONS AND PRACTICES 27 number of elements that might complement information necessary to moni- tor and assess experiences with self-escape. The form collects identifying information on mine/contractor and on the injured/ill individual; a crude code for type of accident that is immediately reportable; location and tim- ing of accident/injury/illness; equipment involved (if any); work activity at time of accident/injury/illness; experience of injured, and information about disability and/or return to work. There are two sections for narrative descriptions. The first (#9) provides several lines to respond to the query “Describe Fully the Conditions Contributing to the Accident/Injury/Illness, and Quantify the Damage or Impairment.” The second (#20) provides only one-half line to describe “What Directly Inflicted Injury or Illness?” Information required with an accident, injury, or illness reportable on Form 7000-1 could be enhanced to regularly characterize any instances in which self-escape efforts were initiated. In the review conducted by the committee, basic information about events that involved evacuations was identifiable. However, there was insufficient detail on such a range of fac- tors, such as whether an SCSR was donned, when the decision to evacuate was made, and the number of miners evacuated. The lack of information may be due to the limited space on the form. If so, the additional data necessary to improve self-escape training could be provided by MSHA personnel with brief written reports of self-escape incidents that are linked to the relevant Form 7000-1. The committee’s assessment required a word search of narrative sec- tions of the reports and hence was limited to those reports in which the narrative included key words. A more structured inquiry about self-escape experiences (even in the absence of any accident, injury, or illness) could provide important data to enhance understanding of successful self-escapes. If the inquiry included information about escape training and drills, it might prove possible to associate successful self-escape with the quality, timing and frequency of self-escape related exercises. PLANNING FOR EMERGENCY RESPONSE The U.S. mining industry has a number of ongoing programs and pro- cedures that promote planning for emergencies. Understanding these was a critical part of the committee’s deliberations and development of their recommendations presented later in this chapter and the summary. This section includes a brief overview of four such programs and procedures of particular relevance to the committee’s charge: mine emergency and fire evacuation plans, mine emergency response development (MERD) exer- cises, quarterly escapeway drills, and emergency response plans (ERPs).

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28 IMPROVING SELF-ESCAPE FROM UNDERGROUND COAL MINES Mine Emergency Evacuation and Firefighting Program Title 30 CFR (§ 75.1502) defines the mine emergency evacuation and firefighting program of instruction. As its title implies, it requires each mine operator to plan and train for evacuations and firefighting. The mine op- erator’s program of instruction is approved at the MSHA district level and must define procedures for: (i) Evacuating the mine for mine emergencies that present an imminent danger to miners due to fire, explosion, or gas or water inundation; (ii) Evacuating all miners not required for a mine emergency response; and (iii) The rapid assembly and transportation of necessary miners, fire suppression equipment, and rescue apparatus to the scene of the mine emergency.  The regulation also requires that miners be instructed on the use and maintenance of SCSRs and refuge alternatives. While it requires training programs on SCSR usage, it does not specify training hours or frequency; instead, it requires that instructors of such training be able to “evaluate whether miners can successfully don the SCSR and transfer to additional SCSR devices.” It also emphasizes training programs that use scenarios to encourage discussion of options and optimal decisions given a wide range of potential conditions that could be experienced in a mine emergency. The regulation also includes provisions for training miners on the mine map and locations of emergency equipment and materials, as well as escape routes, all of which are important elements to wayfinding, communications, and self-escape in an emergency. Mine Emergency Response Development Exercises All mines are required to have emergency, firefighting, and evacua- tion plans, but having a plan does not guarantee knowing that it works and how it works. Unless practiced and tested through the use of MERD exercises, system failures in response plans may be hard to identify and could compromise the response process in the case of an actual emergency. MERD exercises are command-center-based training role-playing exercises designed to test emergency response. They are not required by regulation, but MSHA does provide guidelines and allows the option for a MERD exercise to satisfy as a “local mine rescue contest,”6 of which two of these are required, provided certain conditions are met. 6  A local mine rescue contest is training that provides an objective evaluation of demon- strated mine rescue team skills and can be a MERD exercise or a practical simulation exercise, such as a fire or explosion drill, where the rescue team participates in simulated mine rescue team exercises and wears breathing apparatus.

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MINE SAFETY REGULATIONS AND PRACTICES 29 Furthermore, MERD exercises should not only test the plans in place, but they should also test the success of training. That is, have key emer- gency personnel been trained to competency or simply completed the train- ing time required? To be maximally beneficial, MERD exercises should not be conducted in isolation. They should include a review of past incidents at other mines and all facets of past response incidents. While it may be tempting to limit participation in a MERD exercise to emergency personnel, including mine management, rescue teams, federal and state government officials, and local emergency responders (U.S. Department of Labor, 2008), the role of additional actors should not be overlooked. For example, role playing to represent the interests and actions of family members, hourly workers, the media, and other individuals and groups could prove beneficial to un- derstanding the impact of the response plan to all the people who may be affected in the case of a mine emergency. Quarterly Escapeway Drills Under CFR Title 30 (§ 75.1504 Mine emergency evacuation training and drills), regulations now require that all miners participate in emergency evacuation training and drills and that these should occur at minimum on a quarterly basis. Among other expectations, these activities include (a) knowledge of all SCSRs in use at the mine, how the devices function and what might be indications of malfunction, and direct experience in donning the SCSRs and transferring between devices; (b) escapeway drills that use different scenarios each quarter, [with] par- ticipation by all individuals traveling primary and alternate escapeways in entirety including addressing the different complications present in the different routes, locating and using lifelines as well as locating all relevant refuges and SCSR caches; and (c) a sound understanding of the mine map and location of equipment for firefighting and plans for diverting smoke from escapeways. In addition there will be annual “expectations training” that includes the donning and transferring of SCSRs in smoke or equivalent degraded en- vironment and the use of training units that provide the sensation of SCSR airflow resistance and heat. Individual miners should also experience how to deploy the available refuge alternatives. No assessment of the effective- ness of these drills is required.

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30 IMPROVING SELF-ESCAPE FROM UNDERGROUND COAL MINES Emergency Response Plans A new safety preparedness requirement included in the MINER Act of 2006 was the ERP to be developed by operators of underground coal mines and uniquely created for each mine. The mine’s ERP is updated and recertified by MSHA at least every 6 months. According to the MINER Act (Section 2803), approved ERPs shall (i) afford miners a level of safety protection at least consistent with the existing standards, including standards mandated by law and regulation; (ii) reflect the most recent credible scientific research; (iii) be technologically feasible, make use of current commercially avail- able technology, and account for the specific physical characteristics of the mine; and (iv) reflect the improvements in mine safety gained from experience under this Act and other worker safety and health laws. It is worth noting that many mine operators have, in addition to their required ERPs, emergency response protocols designed to address specific events such as serious injury, search for missing miners, and severe weather. Like the ERP, miners are trained on these protocols. The MINER Act defines several content areas that must be included in an approved ERP: post-accident communications, tracking, breathable air, and lifelines; training; and local communications. The ERP should attend to the likely survivability of equipment and technology in the case of a fire or explosion and include redundant systems, as appropriate. Further guidance for the contents of ERPs is contained in MSHA-issued program information bulletins,7 program enforcement letters,8 and procedure instruction letters.9 Although the required ERP contents are critical, notably absent are human-systems and human behavioral considerations, particularly those relevant to self-escape. Those considerations could include, for example, the role of individuals (or position duties) involved in an emergency: the responsible person, communication center officer, mine management, un- derground team leader, and rescue teams. 7  SHA M program information bulletins are available: http://www.msha.gov/REGS/COMPLIAN/ PIB/PIB.HTM [August 2012]. 8  SHA program enforcement letters are available: http://www.msha.gov/REGS/COMPLIAN/ M PPLMEN.HTM [August 2012]. 9  SHA procedure instruction letters are available: http://www.msha.gov/REGS/COMPLIAN/ M PILS/PIL.HTM [August 2012].

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MINE SAFETY REGULATIONS AND PRACTICES 31 TESTING EMERGENCY RESPONSE: LESSONS FROM AUSTRALIA As noted above, testing of an emergency response system must be done rigorously and under the stresses and conditions that would occur during a real incident. In Queensland, Australia, training requirements in mine emergency management are outlined in Recognised Standard 08: Conduct of Mine Emergency Exercises (Queensland Government, 2009). Table 2-1 summarizes a hierarchy of exercise types across four levels ranging from statewide exercises to supporting exercises in individual mines. These standards provide a way to meet safety and health obligations, but they are not mandatory. Other ways of managing risk may be adopted. However the method adopted must show that it was at least equivalent to the recognized standard method. Each year in Queensland10 the emergency preparedness of one underground coal mine is tested through an audit by a team of external personnel, with up to 50 assessors. The audit team includes representa- ����������� tives from regulators, the mining union, and mining companies, as well as specialist technical experts. The aim of the exercise is to test the whole emergency response system, including interaction with other agencies, the media, and government. It is often these complex interactions that can impede an expeditious and appropriate emergency response. An incident scenario is developed that is based on incidents at the mine or nearby mines that will require management of the incident and may require evacuation of all or part of the mine. Often there are “injured” personnel to cope with and “lost” or “disoriented” persons. The process, which has been under way since 1998, has been judged to have resulted in significant benefits for the whole industry (Watkinson and Brady, 2008). Real progress has been made in underground escape, including the introduction of compressed air breathing apparatus (CABA), changeover stations, lifelines, and in seam first response. It has been possible to critically evaluate the status of other initiatives, such as personnel and equipment tracking systems, refuge bays, nonverbal communications, and remote sealing capacity. The exercise has highlighted such issues as the need to be in regular contact with underground personnel during an evacuation and the need to know what has happened and what is happening underground. The reports from each exercise are publically available from the Queensland government.11 In addition, the findings from each exercise are made available to the mining industry through presentations 10  here T are currently only 12 underground coal mines in Queensland, employing a total of about 6,500 workers, producing about 30 million tons of coal. 11  hey can be found on the government’s website: http://mines.industry.qld.gov.au/safety- T and-health/emergency-excercise-reports.htm [November 2012].

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TABLE 2-1  Summary of Queensland Emergency Exercises Standard 32 Level 1- Level 2- Level 3- Level 4- State-Level Exercise Major Mine Site Exercise Minor Mine Site Exercises Supporting Exercises Type One mine selected for the Whole of mine Part mine or system Mine state each year Frequency Once per year at selected Once per year at all mines Once per year for each crew Annually/periodically mine Scope Practical exercise to test the Practical exercise to test Practical test to ensure Desktop/semi-practical to test emergency response system the emergency response all personnel are familiar ability to – AND the ability of external system including effective with the Mine Emergency (a) respond to a medical services to administer communication with Response and/or Evacuation emergency, assistance. Involves – external services and Plan. Involves – (b) search and rescue, and (1) Mine response to periodic mobilization of the (1) Part mine evacuation. (c) provide theoretical/practical scenario to test self-escape/ QMRS Inertisation Unit. (2) All crews, all shifts training in emergency response, aided escape and IMT Involves – including weekends. including evacuation. response. (1) Whole mine response. (3) Whenever a crew’s (2) Mobilization of (2) Mine’s rescue stations workplace changes (a) Queensland Mine and other external significantly. Rescue Service (QMRS) providers to contact stage Participation in Levels 1 – rescue team response to only “Can you respond?” and 2 qualifies for this mine’s rescue agreement Each year the day of the exercise. standard—1 team to be week, the time of day, and deployed underground. personnel involved is to be (b) Simtars as required by verified. The scenario is to scenario. be varied each year in order (c) External assistance per to test all aspects of the exercise plan. mine emergency procedures “Replaces Level 2 Exercise” plan.

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Control Chief Inspector must ensure Site Senior Executive Site Senior Executive must Site Senior Executive must the exercise is organized must ensure the exercise ensure these exercises are ensure these exercises are each year. State Emergency is organized. Organizing organized. Organizing organized. Exercise Executive committee is to include committee is to include Committee to include (a) QMRS representative, (a) site QMRS (a) one representative from and representative, and Inspectorate, (b) site safety and health (b) site safety and health (b) one representative from representative. representative. Simtars, (c) one representative from host mine, (d) one representative from QMRS, and (e) one industry safety and health representative. Audit/Report Statewide District inspector/industry District inspector/industry Annually/periodically as required as required SOURCE: Queensland Government (2009, Table 1). 33

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34 IMPROVING SELF-ESCAPE FROM UNDERGROUND COAL MINES at conferences and forums to promote discussion and improvement in emergency preparedness (Queensland Government, 2009). This process also places a lot more pressure on mine sites than do internal training exercises and has highlighted the limitations in the incident management process. It also allows the evaluation of linkages with external agencies and the capacity of other mines to render assistance in a timely manner. This in turn has led to the Queensland Mines Rescue Service, which developed the Mine Emergency Management System from the Incident Control System (ICS),12 which is widely used by emergency services in Australia. The exercises have also provided the catalyst for a number of major research projects that have led to improved capabilities for mine environmental monitoring, improved mine reentry capabilities, and incident management. During a training exercise, some of the evacuating miners don SCSRs, giving the miners experience in how they feel and operate. This practical experience has greatly increased the acceptance and understanding of SCSRs. Over the years using real SCSRs has also identified a number of design and operational limitations of various units. During the exercises, miners are also often placed in simulated smoke environments. Practical experience in these environments under controlled conditions reduces the level of uncertainty and the fear of the unknown among the workers. Requiring the testing of an emergency response plan through a rigorous and realistic exercise not only aids training, but also provides a valuable opportunity to improve system and safety performance through the careful and constructive assessment of the plan. The outcome of such an effort contributes to a human-systems integration approach. Information gathered speaks to the effectiveness of current practices and processes specifically with regard to effective decision making and action(s) at both the individual and systems level. CONCLUSIONS AND RECOMMENDATIONS The mining industry has made many significant strides forward to mitigate hazards, train miners, and advance mine safety. Improvements in regulations, procedures, and technologies have positively altered the mine environment and consequently reduced the frequency and severity of emer- gencies. Yet the committee is concerned that improvements in mine safety, especially in regulation, have historically followed major mine disasters. These often draw the attention of legislators to apply what was learned from disaster investigations and enact rules meant to mitigate the specific 12  he T ICS was first developed in the United States for the management of wildfires in California.

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MINE SAFETY REGULATIONS AND PRACTICES 35 causes of particular incidents. What has been missing is the consideration of safety improvements in advance of incidents, using available knowledge from research, and consideration of larger systemic issues. This chapter has specifically addressed MSHA’s role relevant to self- escape. However, there are other stakeholders in successful miner self-escape, including other federal agencies, like the National Institute for Occupational Safety and Health, state and local mining agencies, miner organizations, as well as the mine operators and miners themselves. They differ in mission, and these specialized divisions and units add value of depth in expertise. However, bureaucratic divisions also facilitate isolation and discourage unity. Mismatches between needs, standards, practices, and evaluations were a source of frustration to many who made presentations to the committee. The perception (whether factual or not) that advances in self-escape are hampered by the actions of people outside one’s own organization is detrimental to both the specific tasks and the strategic mission to improve mine safety. Although the committee does not advocate abolishing these bureaucratic divisions, the need for improved collaboration and integration is paramount. Regulations and compliance provide a key support to mine safety, but regulations alone cannot guarantee safety. Improving the ability of miners to self-escape cannot be extracted and examined in isolation from the entire system. The operational realities of relationships and interactions between organizations and individuals simultaneously present opportunities and challenges. Although the challenges may seem daunting at times, there are many opportunities that remain unrealized and which could significantly improve mine safety. CONCLUSION: Efforts on the part of mine operators and other in- dustry stakeholders to empower self-escape in a mine emergency—to include, but not be limited to training, technology, equipment, and emergency response plans—need to be fully integrated and coordinated, using a human-systems integration approach, to establish unified, effi- cient, and effective protocols. Among the key issues to be considered in pursuit of this goal are robust data collection, careful and constructive assessment of emergency response plans, feedback mechanisms from miners and mine operators to identify residual challenges and remedies, and active engagement with technology suppliers. One need to promote a more systemic assessment is a public database populated with pertinent information across a wide range of mine incidents or emergency scenarios to support development of self-escape training and research. Such a database could possibly be populated with data from information already collected, but data relevant to escape from mines are very limited and currently insufficient for analytic and information-sharing

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36 IMPROVING SELF-ESCAPE FROM UNDERGROUND COAL MINES purposes. Another possibility is to include data from interviews with se- lect miners to gather knowledge from their experience about emergency situations and how to deal with them. Systematic efforts are needed to collect and analyze regularly information from escape situations and make outcomes and lessons learned available to stakeholders for future improve- ments. The currently required quarterly escapeway drills provide an avenue for collecting such information with minimum additional impact on mines and miners. Under the regulations, escapeway drills are intended to use dif- ferent emergency scenarios quarterly to test emergency preparations (e.g., miners’ knowledge of their mines, conditions and locations of emergency equipment, use of breathing apparatus, and plans for diverting smoke and fighting fires). RECOMMENDATION 1: At least annually, and in conjunction with one of the required quarterly escapeway drills, mine operators should conduct a comprehensive self-escape scenario exercise at every un- derground mine. These exercises should be an integrative practice incorporating the roles of miners, the responsible person as defined in 30 Code of Federal Regulations § 75.1501, the mine communications center, and any other stakeholders that the operator deems pertinent to a successful self-escape, including representatives of the miners where applicable. The scenario should test all aspects of the mine’s emergency response plan and mine emergency evacuation and firefighting program to assure that these are effective and up to date. Information gathered from the proposed annual exercises will speak to the effectiveness of current practices and processes specifically with regard to effective de- cision making and action(s) at both the individual and systems levels. Appropriate staff from the National Institute for Occupational Safety and Health (NIOSH) should attend as many exercises as necessary to collect and interpret pertinent outcomes and lessons learned us- ing a standard process. The NIOSH assessment of performance at individual mines of all key personnel, both internal and external, and the effectiveness of emergency response systems should be shared with the personnel involved in each exercise. In addition, a report that has been scrubbed of identifying markers, detailing the outcomes and les- sons learned should be prepared and entered into a public database for use by any interested parties to develop better self-escape capabilities (overall practices, policies, technologies, and training). New resources for NIOSH to accomplish this responsibility should be identified so as not to draw resources from critical program elements.