By Steve Fiscor, Editor-in-Chief
He has not quit his day job as a mine safety compliance attorney. In his spare time, however, Mark Savit with the help of his son Josh, he has developed an interactive Web-based software system, Predictive Compliance, that allows mine operator to effectively track citations from the Mine Safety and Health Administration (MSHA).
“Our software is designed to be as user friendly as possible,” Savit said. “All you need to do is upload citations as you get them and our proprietary software calculates the predicted penalty, shows you the impact that this citation (and future citations) would have on compliance costs, allows you to plan how best to contest the citation, and provides a platform for citation management.” It also will allow miners to predict the impact of future citations on costs, resources and operations. Predictive Compliance will allow a mining company to dramatically reduce costs of compliance and allocate resources for safer, more efficient operations.
A safety manager simply uses a scanner to upload the citation and the software instantly calculates the likely penalty. It can also predict how the new citation may affect penalties for future citations (VPID and RPID) as well as determining whether a mine could be facing additional evaluation for Pattern of Violations (POV) consideration.
“Our proprietary analytical program will enable miners to instantly determine the possible impact of contesting each of the criteria on the citation—including likelihood, severity, negligence and number of persons affected,” Savit said. It will immediately shows how much money a successful contest can save the operation or what an upward modification will cost.
Mines can customize the software to write their own reports. Users can choose from 25 different categories to group the citations. All of the citation data can be transferred to a single page along with notes, pictures and any other data that might be needed for the future. The information for that citation is all stored on one database page.
The data can then be manipulated. For example, a mining company could sort citation data by cost center, by individual supervisor or by inspector. “The data could be used to quantify the impact of compliance costs on production,” Savit said. The integrated data can be easily forwarded to corporate management, consultants and counsel without the need for them to create separate databases. That saves time and money.
All of the citation data could be managed from one central location. Multiple mine operations will be able to compare mine-to-mine data as well as plan and coordinate all needed activities with counsel and consultants with little or no need for additional report preparation.
A mine could use the software to identify citation writing tendencies among different inspectors. An operator can determine where they stand as far as S&S citations for instance by making mine-to-mine comparisons. The mines could cross-reference the data and sort by foremen. A manager could enter the identifier for a foreman and determine whether that foreman has a compliance issue.
Predictive Compliance has different advantages for different mines. For big underground coal operators, it’s a good way to track all of the citations. A surface mine could review the information, determine repeat violations and see where the mine is receiving excessive penalties. Using that information, they could reallocate resources to avoid those particular citations. By reassigning some labor crews, Savit said one customer avoided $40,000 in citations. It’s also a great way to consolidate multiple sites.
“It’s a citation management tool and it’s a better way to communicate with lawyers and consultants,” Savit said. “Someone uploads the information and office types can look at the information without PDFs or faxes.”
Newmont Tested the System
Predictive Compliance signed a three-year subscription agreement with Newmont Mining Co., a gold miner with mines in Nevada, after the first three months of testing its software. With the Newmont pilot project successfully completed, an additional 25 mining companies and contractors have signed subscription agreements. The company now supports more than 70 current users.
We have found the Predictive Compliance software to be a very valuable tool in helping miners and mine management to make important decisions in the days leading up to a MSHA inspection, said Jon Upsahw, SLP data analyst, Newmont Mining. “The citation management portion of the software has helped identify trouble areas that exist at many of the different sites,” Upshaw said. “This information helps managers know before hand which regulations they need to avoid, and due to the analytics portion of the software, how badly they need to avoid them.”
Newmont was able to bring the total number of housekeeping citations from about six per inspection