September 1, 2010
Guarded About Guarding
By Therese Dunphy
Been guarded about your guards lately? If so, you’re not the only one. Operators around the nation are likely quite familiar with two particular sections of the Code of Federal Regulations — 30 CFR § 56.14107 (moving machine parts) and 30 CFR § 56.14112 (construction and maintenance of guarding). Mine Safety and Health Administration (MSHA) inspectors have written these numbers quite a bit during recent months.
In fact, from Jan. 1 through mid-August, stone, sand and gravel operators received 3,628 citations for 56.14107(a), 879 citations for 56.14112(a1), and 415 citations for 56a.14112(b). For a little perspective, moving machine parts citations account for 10.11 percent of all citations issued to stone producers this year, while they account for nearly 12.89 percent of all citations issued to sand and gravel producers during the same time period.
Anecdotally, stories about guarding requirements and citations have begun to resemble fish tails, with each operator having a more outlandish and seemingly far-fetched story than the next.
And it’s no wonder. While guarding has been a high priority during inspections, it has seemed that a clear, concise explanation of guarding may not have been a high priority when it came to inspector training. As the ranks of MSHA inspectors swelled, new field personnel each seemed to have a different interpretation of what was a proper guard and what was not. Even new equipment, fresh from the original equipment manufacturer, has not escaped unscathed, as safety features on some of these machines were also found inadequate.
After much discussion between industry inspectors and regulators, MSHA undertook an effort to update its guidance on guarding. Its newly released presentation, Guarding Conveyor Belts at Metal & Nonmetal Mines, addresses guarding around conveyor belts and serves as a supplement to its 2004 guidance, MSHA’s Guide to Equipment Guarding. The presentation contains numerous pictures of adequate and inadequate guards, along with more detailed analysis in the notes section of each page.
It’s worth noting that MSHA is responding to a valid criticism about how its inspectors conduct their site visits. Without clearly defined expectations, it is difficult for well-intentioned operators to meet an inspector’s expectations, and in today’s environment, most strive for a clean inspection. The presentation will go a long way toward providing clarity on this topic for regulators and operators alike.
The agency’s willingness to educate both the industry and its inspectors on this issue is refreshing and should be met with optimism — albeit guarded optimism.