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Hi Frank,
I want to point you and your readers to an important bit of information found at http://www.scmines.com
On the Mining Association of South Carolina websites front page you will find a downloadable excel workbook that contains MSHA stats. Even though the data indicates that it is South Carolina Data there is nationwide data within the workbook.
On one of the sheet tabs there is a breakdown of all MSHA electrical citations written from 2000 through March 2011 for all Metal and Non-Metal mining in the country. This table lists every standard from the most frequently cited to the least and analyzes how the agency has written each in terms of gravity and negligence. There is another sheet that has all the electrical accident data for all MNM mining. One can easily see that while mining has become safer and safer the MSHA is evaluating the workplace becoming more and more dangerous. They (MSHA) are also writing citations with a much higher degree of negligence.
When comparing the citations vs. the accident data there is no question that the agency is flat out over assessing likelihood and gravity. If the workplace is so much more hazardous there should be an increase in electrical accidents and injuries.
MSHA is supposed to use “all available information” (this is a quote from the citation writing handbook) when evaluating gravity and negligence. For heaven’s sake, this is their own data, taken straight from the new open government data sets.
The industry must use information like this to hold MSHA to a higher standard.
Thanks for all you do,
Safety Officer