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U.S. Department of Labor

Mine Safety and Health Administration
201 12th Street South, Suite 401
Arlington, VA 22202-5450

EFFECTIVE DATE: June 24, 2013 EXPIRATION DATE: 3/31/2024            
LAST VALIDATED: 03/31/2021


                    Administrator for
                    Coal Mine Safety and Health

SUBJECT:     Reissue of P11-V-03 - Electric Equipment; Examination, Testing and

This Program Policy Letter (PPL) applies to coal mine operators, coal mine safety and health enforcement personnel, miners' representatives and other interested parties.

The purpose of this PPL is to clarify the interpretation and application of 30 C.F.R. §§ 75.511 and 77.501 to certain electric equipment. This PPL supersedes the previous reissue. This PPL also defines the term "distribution circuits or equipment" in an effort to promote consistency in enforcing these standards.

Existing §§ 75.511 and 77.501 require that electrical work on low-, medium-, or high-voltage distribution circuits or equipment must be performed by a qualified person or by a person trained to perform electrical work under the direct supervision of a qualified person. A "qualified person" is defined as an individual who meets the requirements of § 75.153 or § 77.103, as applicable. The term "distribution" is defined in the Institute of Electrical and Electronics Engineers (IEEE) Standard Dictionary of Electrical and Electronics Terms (3d. ed. 1984), page 270, as an adjective to denote application or restriction of the circuits or equipment or both, to "that part of an electric system used for conveying energy to the point of utilization from a source or from one or more main receiving stations." Work on distribution circuits and equipment poses great hazards to personnel performing it. Equipment such as battery cap lamps, telephones or telephone circuits, approved battery flashlights, approved methane detectors, atmospheric monitoring systems, post accident communication and tracking systems and electric circuits on board surface mobile equipment powered by internal combustion gasoline engine are not considered distribution equipment (This does not include electric motors powered by generator sets onboard large surface equipment, such as shovels, draglines, and off-highway haul trucks). Work on and repair and maintenance of such electric equipment does not pose the same hazard as work on distribution circuits and equipment. Consequently, a qualified person would not be required to install, repair, or maintain these types of circuits and equipment.
Although §§ 75.512 and 77.502 require that all electric equipment be examined, tested, and properly maintained by a qualified person and do not distinguish between "distribution circuits or equipment" and other electric equipment, the Mine Safety and Health Administration (MSHA), through a memorandum issued in 1999 to the District Managers, exempted the equipment listed above from being repaired and maintained by qualified persons as long as the persons performing the work are properly trained in such work. These circuits and equipment, however, are required to be examined and tested at least weekly as specified in § 75.512-2 and monthly as specified in § 77.502-2. A record of this examination and test is not required. Additionally, although methane monitoring systems and methane monitors are electric equipment, they are not required to be maintained by a qualified person. Section 75.342(a)(4)(i) requires using persons properly trained in the maintenance, calibration, and permissibility of methane monitors to calibrate and maintain these devices. Section 75.351(o) requires that records be made by individuals designated by the operator, and § 75.351(q) requires training for AMS operators and does not require these operators to be qualified in accordance with §§ 75.153 or 77.103, as applicable.

Individuals working on the equipment listed above, however, must be properly trained in the maintenance, repair, calibration and any other tasks they are performing on these types of equipment. For example, these individuals must be trained in the permissibility requirements to ensure that permissible equipment is maintained in permissible condition.

Questions were raised regarding the applicability of §§ 75.511, 75.512, 77.501 and 77.502 to equipment such as cap lamps and methane detectors. Specifically, MSHA was asked whether persons performing work or maintenance on this equipment are required to be qualified in accordance with §§ 75.153 or 77.103, as applicable, and whether this type of equipment is "distribution" equipment.

The Federal Mine Safety and Health Act of 1977, as amended, 30 U.S.C. § 801 et seq., the MINER Act, and 30 C.F.R. §§ 75.511, 75. 512, 77.501 and 77.502.

Internet Availability
This PPL may be viewed on the World Wide Web by accessing the MSHA Home Page at ( under MSHA’s Major Laws, Regulations and Policies choose “Compliance Information (PIBs, PILs, the PPM, and More” and select “Program Policy Letters”.

Issuing Office and Contact Person
Mine Safety and Health Enforcement, Safety Division
Rodney Adamson, (202) 693-9549

MSHA Program Policy Manual Holders (w/attachments)
Coal Mine Operators
Miners' Representatives
Special Interest Groups