| Position: |
 | The National Mining Association (NMA) supports the objectives of restoring confidence in the sampling process and eliminating coal workers' pneumoconiosis
(black lung disease) -- goals that underlie the Mine Safety and Health Administration's (MSHA) Proposed Rules to revise the existing respirable coal mine dust sampling regulations.
The Proposed Regulations, while not perfect, seek to advance a 30-year old system that currently relies on old procedures and technology to protect miners from exposure to excessive dust concentrations. As currently written the Proposed Rules fail to fully address the shortcoming of the existing program. The proposal can and must be revised to achieve compliance with the objectives that all parties support and we are developing the alternative regulatory language that will:
- Remove the cloud of controversy that continues to surround the coal mine dust sampling program;
- Build confidence, on the part of both miners and mine operators, that sampling results are reliable and representative of the dust concentrations to which miners are exposed;
- Encourage the use of all appropriate tools to protect miners where traditional controls and not sufficient; and
- Encourage the introduction of new sampling technology to empower miners and operators to initiate intervention measures based upon the results of real-time sampling results.
NMA believes the Proposed Regulations are a step in the right direction to eliminate coal workers' pneumoconiosis. The Proposed Regulations, however, must be improved, and the rulemaking process is the instrument to introduce changes that build upon the framework MSHA has developed.
For more information, see Testimony given by Bruce Watzman on May 22, 2003, (PDF, (110 KB)
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