6 thoughts on “Resources”

1. Jamar St. Clair February 8, 2021 / 10:21 am

   Hello,
   I work for a fire extinguisher company and my job is to recharge and perform the monthly inspections at various places. One of the places I work at every month is a cement plant. The safety person at the plant told me and my boss that I am going to need to be MSHA Part 46 trained, and that our company will need to file as contractors with MSHA. Is this true, or are they trying to make us do extra stuff?

   Thank you,
   Jamar
2. renewcomer February 8, 2021 / 4:01 pm

   Yes, unless you are accompanied by a trained miner as you perform your tasks on the mine site that would likely be true.
3. Jamar February 9, 2021 / 10:30 am

   Thank you. My boss asked me to ask you one more question. The cement safety person told my boss that since we are there monthly, we need to set ourselves up as contractors with MSHA. The safety guy gave him a list of things we need to do, and it says:
   Contractor ID, Part 46 approved training plan, and file quarterly reports with MSHA. Is this true? He said this is all pretty easy to do, but if we didn’t want to do it ourselves there were some places out there that can do this for pretty cheap – he mentioned a few places.
4. Randy February 9, 2021 / 10:50 am

   Yes, you’ll need all those things. Part 46 new miner training (24 hours) and annual 8 hour MSHA Refreshers. You can get more information here: bit.ly/MSHAGUIDE. We can help guide you to do it yourself or do it for you. Email me at randy@completesafetysolutions.com or check the office hours above and check when the chat button to the right is active.
5. Rachel Oaks February 9, 2021 / 10:54 am

   Jamar,

   The Safety Person at the cement plant is correct – pretty much. All contractors who work on mine sites for frequent or extended periods of time (over 5 consecutive days is extended, over a few times a year is frequent) are required to be MSHA trained. Since you already know this is a Part 46 location, that means you will fall under the Part 46/56 regulations.
   Now, per MSHA, you are not required to have a Contractor ID unless you are cited by MSHA* [this is accurate for this particular activity, but not all, see next comment – randy]; now, the cement company can require it, for that moves some of their burdens onto your company (not all, but some).
   I saw a great video explaining this, and you can find it here:

   https://www.youtube.com/watch?v=zeWZA1Qjk6M

   Rachel
6. renewcomer March 10, 2021 / 11:14 pm

   You are required to have an ID in advance of performing work for specific activities at the mine as explained in MSHA’s Small Mines Handbook:
   45.3 MSHA Identification of Independent ContractorsAny independent contractor that requests an identification number will receive one from MSHA. However, unless cited for a violation, only those independent contractors performing work at mine sites, or with contracts to perform at a mine(s) any of the nine types of services or construction listed below, are required by MSHA to have identification numbers:
   1.Mine development, including shaft and slope sinking;
   2.Construction or reconstruction of mine facilities; including building or rebuilding preparation plants and mining equipment, and building additions to existing facilities;
   3.Demolition of mine facilities;
   4.Construction of dams;
   5.Excavation or earthmoving activities involving mobile equipment;
   6.Equipment installation, such as crushers and mills;
   7.Equipment service or repair of equipment on mine property for a period exceeding five consecutive days at a particular mine;
   8.Material handling within mine property; including haulage of coal, ore, refuse, etc., unless for the sole purpose of direct removal from or delivery to mine property; and
   9.Drilling and blasting.
   MSHA does not require independent contractors to have identification numbers as a precondition to bidding for work contracts on mine property. If an independent contractor becomes a successful bidder and if the contract to be performed covers any of the nine types of service or construction listed above, the contractor must obtain an identification number.

This site uses Akismet to reduce spam. Learn how your comment data is processed.