Today MSHA held a briefing to present their proposed rule change for Workplace Examinations in Metal-Nonmetal. My preliminary assessment is that it makes the following changes:
- Examinations will be required at the START of each shift. Yes, I’ve said this in Refresher classes. It’s silly, but the current rule just says that it’s required during each shift. No problem here. If you’re doing it effectively now you’re already doing it at the start of the shift.
- Examination records must include hazards found and corrections made. This is the stickiest of things to include in an MSHA required report, but again an important part of a good safety examination process. Joe Main dodged the question of how MSHA Inspectors may or may not use these records to write citations based on the hazards recorded by iterating that this was a briefing and such questions were more correctly addressed during the 90 day comment period to commence tomorrow.
- Examination records must be available to miners and miner representatives. While this isn’t included in the current rule again, an effective program certainly has to warn the workers who would be exposed to the hazard or even a corrected hazard.