|U.S. Department of
Mine Safety and Health Administration|
201 12th Street South, Suite 401
Arlington, VA 22202-5450
PROGRAM INFORMATION BULLETIN NO. P11-49
FROM: KEVIN G. STRICKLIN
Coal Mine Safety and Health
LINDA F. ZEILER
Acting Director of Technical Support
SUBJECT: Reissue of P08-16 - Clarification of Procedures to Use When
Reporting Self-Contained Self-Rescuer (SCSR) Inventories
Who needs this information?
This Program Information Bulletin (PIB) is intended for underground coal mine operators, independent contractors, miners' representatives, Mine Safety and Health Administration (MSHA) personnel, and other interested parties.
What is the purpose of this PIB?
This PIB informs the coal mining industry regarding the proper procedures to use to report Self-Contained Self-Rescuer (SCSR) inventories using the MSHA database accessed through the MSHA home page at www.msha.gov. Since the development of the database in 2007, over 200,000 SCSRs have been entered into the system. During this period, MSHA has made several improvements to facilitate the entry of SCSRs into the database by mine operators and has identified problems with some inventory submittals. This PIB is also being revised to incorporate information which was previously part of the guidance in PIB No. P07-13, SCSR Inventory and Report.
Operators should check their inventories on-line at http://www.msha.gov to confirm that their SCSR inventory is correctly entered in the database. Operators should use the online forms for reporting inventory and updates so that MSHA can accurately update the SCSR database as required by Title 30, Code of Federal Regulations (30 C.F.R.) § 75.1714-8.
Section 75.1714-8(a) requires mine operators to provide MSHA with a complete inventory of all SCSRs at each mine as defined in 30 C.F.R. § 75.1714-1. Operators were required to submit the inventory within the first quarter of 2007 for existing mines and within 3 months of beginning operation at new mines. Section 75.1714-8(a) (1) requires that the inventory include the mine name, MSHA mine ID number, mine location, and, for each SCSR unit, the manufacturer, the model type, the date of manufacture, and the serial number. Section 75.1714-8(a) (2) requires mine operators to update the inventory. Operators must report to MSHA only changes to the inventory within the quarter that the changes occurred. This requirement keeps the database current and assists mine operators in complying with 30 C.F.R. § 75.1714-3. Also, consistent with other sections of this regulation, this provision specifies calendar quarters for reporting, i.e., January-March, April-June, July-September, and October-December.
Detailed instructions are provided to users when accessing the SCSR Inventory/Report on the MSHA web page, using their eGov password and Mine ID. Users can input their inventory on the optional electronic form and file on-line (preferred method and fastest submission option). Using the electronic form, users can add one or more SCSRs to their inventory, modify an SCSR entry in the inventory, remove SCSRs from the inventory, or import several SCSRs using a spreadsheet. Any electronic submissions will be certified and updated in the database as soon as possible.
Multiple SCSRs can also be added to the inventory database utilizing a properly formatted spreadsheet attached to an e-mail and submitted to: zzMSHA-Scsr.Inventory. In addition, mine operators can also print a form and either fax it to: (412) 386-5345 or mail it to:
- Mine Safety and Health Administration
Pittsburgh Safety and Health Technology Center
Attn: SCSR Coordinator
Cochrans Mill Road
P.O. Box 18233
Pittsburgh, PA 15236
However, these options can take much more time to process than electronic submittals, and several problems have been identified as outlined below.
Key problems encountered by mine operators in submitting SCSR inventories by e-mail or fax to MSHA include the following:
- E-mails with attachments sent to SCSR.Inventory@dol.gov may have unintentionally been blocked, so inventory lists were never delivered to MSHA.
- Solution: Operators need to check their on-line SCSR inventory (for detailed instructions, go to http://www.msha.gov, click on SCSR Inventory/Report, click on Detailed Instructions). If previously submitted SCSR data is not found in the database, you will need to resend your inventory, either to SCSR.Inventory@dol.gov, or use the electronic form.
- Inventories submitted by e-mail or fax are often missing contact information; all incomplete inventories are returned to the operator for correction and need to be resubmitted.
- Solution: Use the electronic form. When submitting SCSR data on-line, the inventory system will not allow incomplete information to be entered. When submitting information by email or fax, make sure to include: 1) mine name, 2) mine ID, 3) company name, 4) address, 5) contact name, and 5) the telephone number for your contact. Submitted inventories that are handwritten are often not legible; faxed copies can be smeared and not readable; and typing or handwriting is sometimes small and hard to read. These types of inventories are also returned to the operator for correction and need to be resubmitted.
Additional guidance follows:
- Submitted inventories should only include SCSRs used in the mine, including those units on mantrips and mobile equipment.
- Clarification: SCSRs not in use, such as those in warehouses, do not have to be reported.
- Inventories submitted on properly formatted spreadsheets, were previously required to include the information on the MSHA Form 2000-222.
- Suggestion: Use the electronic form. The on-line system will not permit entry of data that is not required.
- Operators should only submit one MSHA Form 2000-222 per mine ID inventory, and attach a list of any additional units if there is more than one SCSR at that location.
- Suggestion: Use the electronic form. When submitting SCSR data on-line, the inventory system will allow for the entry of one unit or multiple entries by importing the information from any attached list.
- Submitted inventories that include SCSRs taken out of service need to state a reason for the SCSR being taken out of service. MSHA Form 2000-222 provides a list of the reasons.
- Suggestion: Use of the electronic form to submit will ensure that this requirement is not overlooked.
- After the initial inventory is submitted, the required quarterly updates should include only SCSRs that are either removed from service or new additions to the in-mine inventory.
- Clarification: If there is no change to report, the operator does not have to submit any quarterly update to MSHA. Only changes are to be submitted each quarter, not the entire inventories.
- Submission of inventories with typographical errors in the SCSR serial numbers frequently leads to system duplicates with SCSR serial numbers that are submitted by other operators.
- Suggestion: Submittal by electronic form will immediately identify the duplicates. After assuring which operator has the incorrect serial number, the operator with the error will be contacted to remove the erroneous serial number from their inventory.
- In response to the 30 C.F.R § 75.1714-8 requirement that mines "submit to MSHA" or "report the change to MSHA," mines have handed inventories to Coal Mine Safety and Health inspectors and considered that to be their official submittal to MSHA.
- Clarification: All SCSR inventories must be submitted ONLY to MSHA's
Technical Support through on-line submission, mail, or fax. Inventories
handed to Coal Mine Safety and Health personnel will not be accepted.
What is the background for this PIB?
In the past, MSHA has discovered problems with all brands of SCSRs. Sometimes, these problems were related to specific production runs that generated unique serial numbers for the SCSRs. Sometimes, the problems affected SCSRs from one manufacturer. During past recalls, MSHA had problems locating outdated or nonworking SCSRs. MSHA inspectors had to travel to each mine to examine each SCSR to make sure all affected devices were actually removed from service. The Emergency Mine Evacuation Rule and the MINER Act required a significant number of additional SCSRs, a centralized database can facilitate the identification of problem SCSRs. An up-to-date inventory allows MSHA to inform the affected mine operator expeditiously and ensure that these SCSRs are removed from service before miners attempt to use them in a mine emergency.
Several mine operators have reported difficulty inputting their SCSR inventories into the MSHA database. Past problems include: 1) a DOL server malfunction prevented delivery of inventory lists to MSHA, 2) mine operators not providing sufficient information, 3) unnecessary submittals of complete inventories when only quarterly updates are required, 4) some mine operators are not validating that their on-line inventory is correct, and 5) mine operator submission of inventories with typographical errors in the SCSR serial numbers resulting in system duplications. This PIB clarifies procedures to follow to assist mine operators in getting their SCSR inventories entered into the database, and provides examples of some typical problems that have been encountered in populating the database.
What is the authority for this PIB?
The Federal Mine Safety and Health Act of 1977; as amended, 30 U.S.C. § 801 et seq.; 30 C.F.R. § 75.1714-8.
Who is the contact person for this PIB?
Jeffery H. Kravitz, (412) 386-6923
Coal Mine Safety and Health, Safety Division
Johnny P. Calhoun, (202) 693-9507
Is this PIB on the Internet?
This PIB may be viewed on the Internet by accessing MSHA's home page at (http://www.msha.gov) then choosing "Compliance Info" and "Program Information Bulletins."
Who will receive this PIB?
MSHA Program Policy Manual Holders
Underground Coal Mine Operators
Special Interest Groups