Because they are still being covertly told by their supervision and management that their jobs depend on writing citations, they are turning to "operator's paperwork" as an area where they can "gibberish" (due to Operator's ignorance of the LAW) their way into issuing a citation the Firm will accept!
One of these reports is "Legal Identity" which is required by 30 CFR 41.12 . Citations are being issued primarily to portable crushers and sites which have temporarily closed for whatever reason.
Prior to leaving the field office for an inspection, the inspectors must review the Legal Identity to ascertain that the Site is operating! One of the pieces of required information is whether or not the site is operating during its "reported" hours. The requirement to report the open or closed status is found in 30 CFR Part 56.1000: Notification of commencement of operations and closing of mines: "The owner, operator, or person in charge of any metal and nonmetal mine shall notify the nearest Mine Safety and Health Administration and Metal and Nonmetal Mine Safety and Health District Office before starting operations, of the approximate or actual date mine operation will commence. The notification shall include the mine name, location, the company name, mailing address, person in charge, and whether operations will be continuous or intermittent.
When any mine is closed, the person in charge shall notify the nearest district office as provided above and indicate whether the closure is temporary or permanent."
30 CFR Part 41.12 gives the Firm 30 calendar days to submit this information as a change to the Legal Identity. Notification on the 31st calendar day or after makes it citable!
Checking the LAW prior to submitting a required record allows the Operator to know what to do and avoid citations.