Mining operations in the US are required to provide health and safety training to all people working at mine sites according to Section 48 of the MSHA regulations. Some operators may not be providing the required comprehensive training or hazard training to short-term or irregular visitors like contractors, researchers, or students who are at mine sites for less than a day. Not properly training these people could result in serious incidents or fatalities. While operators may not be intentionally avoiding training to save costs, the regulations could be interpreted in a way that causes confusion about training requirements for short-term visitors. A review of laws and cases provides guidance that short-term visitors who frequently visit mine sites for less than a day still require comprehensive or hazard training.

1. Mining Operations USA - MSHA Section 48 Training
Section 115 of the American Federal Mine Safety and Health Act of 1977 stipulates mandatory
health and safety training for people working at mines - underground, surface and surface
operations of underground mines. It broadly outlines the 40 hour training for new miners at
underground mines and 24 hour training for surface mines respectively as well as training for
experienced miners. It empowered the Secretary of MSHA to promulgate regulations to address
training requirements. Regulation 30 CFR 48 deals with the training requirements.
Some operators who have mining operations in the US may not be complying with MSHA regulations
regarding the "Comprehensive Training" and/or the "Hazard Training" as required by section 48 of
the MSHA regulations with respect to "irregular" and/or "short-term" (> 1day) people such as
corporate personnel, contractors, consultants, researchers, visitors, students, etc at mine sites -
underground, surface and surface operations of UG mines. Some operators may think that the above
two types of training is not required for such people and just a short induction, followed by a quick
training of how to done a self rescuer, etc only is required because an experienced miner from the
operator's crew could escort these people whilst on site. Unfortunately this is not the correct
interpretation of s48 and nor should it be if safety is kept at the forefront of the mind and given
utmost priority.
It is not the compliance issue that is worrying but what the end result could be when proper training
is not provided to such people - i.e. serious incidents, fatalities, etc. Also, it is clear that operators are
not doing this on purpose to save costs, etc but because the way the regulations are written, some
confusion is created; on this issue the attached decision actually points this out and expresses the
view that even MSHA may not have understood their own regulations!
Research and review of the regulations (30 CFR Part 48), the empowering Act (Mines Act), PPM Vol.
III (Policy Program Manual) and case laws (so far I have only found one which is not to point
regarding training but which does show MSHA's way of thinking on this - I have attached these for
your perusal).
You will see that the case attached mentions how MSHA may now be interpreting s48 of the
regulations and as mentioned the decision is not on this point but it does provide some guidance.

2. I believe what this means is that visitors to mines who can get away from the comprehensive or
hazard training are limited to visitors who will be there for less than one day and who will do so
occasionally only. Those who will be there frequently, albeit for less than a day, will require the
comprehensive or the hazard training.
Comments are welcomed.