Responding to MSHA’s request for comments on their draft Program Policy Letter on mine communications and tracking requirements, WVCA has urged MSHA to accept the state’s plan that is currently nearing full implementation.
Questioning the reasoning or basis behind MSHA’s proposed changes, WVCA cited the complexities of adding additional components or changes to an already complex system in order to meet compliance with MSHA’s proposed requirements, adding that the state requirements were jointly constructed and approved by state, labor and management representatives.
WVCA requested MSHA to modify its draft PPL to make it consistent with the legislatively approved requirements of the State of West Virginia, or in the alternative, to accept compliance with existing state plans and requirements as meeting compliance with MSHA’s final PPL.