One-size Regulation Doesn’t Fit All? Consider a Modification
In recent years, a number of our clients have faced Mine Safety and Health Administration (MSHA) inspectors writing citations based on new interpretations of old standards. Sometimes, the district office rubber-stamps these new “rules” — and sometimes, these seem like district initiates. When the changes demanded by the MSHA to equipment or operations are significant, it is not uncommon for the mine operator to believe the changes actually would decrease, rather than increase, safety. Other times, the operator may believe its approach is at least as safe, and achieves the same goal, as the standard.
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