With the CPDM providing miners with near real-time feedback about their level of respirable coal dust exposure on the job, a new opportunity is arising for management, in collaboration with their employees, to use this information to determine methods for reduced exposure. Some researchers have effectively argued that the use of information technology can enhance organizational communication around health and safety.1 In line with that argument, taking a nonjudgmental yet proactive approach to discuss the dust data produced by the CPDM may help to identify and support actions to limit future exposure during reoccurring work tasks.

In light of the new regulation, it is highly important for mine operators and miners to not only understand how they can use the technology to monitor personal exposure to respirable dust, but exactly what and how they can engage in actions to reduce exposure. Researchers from the National Institute for Occupational Safety and Health (NIOSH) recently met with several coal miners who were learning how to use the technology during their shifts. During the discussions with these miners, they learned key points about how the CPDM can be introduced and used to encourage positive health communication efforts among miners.

Miner Training — What is the CPDM?
Our discussions showed the importance of introducing the CPDM to everyone during group or shift safety meetings and providing usability training for the technology so everyone understands the purpose of the sampling device. Previous research about the introduction of other mine health and safety technologies, such as proximity detection systems, has shown that miners desire communication and training about the what, why and how of these technologies in the workplace.2 Therefore, miners should understand what information is provided by the CPDM and how that information may affect how they perceive their surrounding environment so they can respond accordingly.

Miner Discussions — What Does the CPDM Tell Us?
When the CPDM is in use, dust data cards are produced from end-of-shift CPDM downloads each day. These dust data cards provide a 30-minute mass concentration (milligrams per cubic meter, mg/m3) and cumulative mass concentration (mg/m3), so miners are able to see when their concentrations were higher during their work shift. Going over these dust data cards with miners as soon as possible after their shift could help them recall and identify where and what their work tasks were during the times of higher exposure. Those workers who wear the technology are the most qualified to discuss causes for variations in and possible ways to mitigate their respirable coal dust exposure, because they are familiar with their work activities and conditions.3 These discussions could help to identify specific work practices to help reduce future exposures, such as changing a stance relative to a machine, curtain or another worker. Additionally, previous research with miners and new technology has shown that, with more communicative support from managers and coworkers, miners are more inclined to behave in ways that limit their exposure.4

Miner Encouragement — Learning From CPDMs
When discussing respirable dust exposure with miners, they noted that relevant dust control practices on the job often are not explicitly discussed; however, miners agreed that they should try to remind each other about small things they can do to reduce personal exposure, rather than assuming everyone already knows what to do. As one miner said, “We constantly stop to talk about a safety hazard and response; we should do the same for our health.” Using the CPDM to initiate some of these positive health responses can be a starting point to encourage such communication. Additionally, miners said that there is more they can do to help reduce each other’s exposure. Discussing with work crews what some of these practices may be, could assist with dust maintenance and reduced exposure as well.

Getting Over the Technology Learning Curve
Initial integration of this technology will require a lot of time, effort and learning, with mine sites all having varying degrees of experience with CPDM sampling and follow-up. If used positively, CPDM feedback can be part of a continuing effort to establish a more integrated approach to managing and encouraging miner health. Everyone in the mining community has the opportunity to understand the message that, despite the varying roles and responsibilities associated with compliance, the fundamental purpose of the new regulation is to reduce the amount of respirable coal dust that miners are exposed to on a daily basis. By communicating about the what, why and how of this new technology, discussing the CPDM dust data cards with miners as soon as possible after their shift, and discussing best practices with work crews based on what is learned from the CPDM data, mine operators can initiate positive communications about miner health.

NIOSH intends to continue research efforts to encourage miner discussion and participation in CPDM feedback to identify potential problems and potential solutions to reduce respirable dust exposure in an effort to help sites begin to use and adapt to this new technology on site. Contact ejhaas@cdc.gov at NIOSH for more information or to participate.

Emily Haas, Ph.D., and Dana Willmer, Ph.D., work with the NIOSH Office of Mine Safety and Health Research in Pittsburgh, Pennsylvania. Haas can be reached at wcq3@cdc.gov. JJ Meadows, MS CMSP, is a safety manager for Patriot Coal, in Winchester, Eskdale, West Virginia.

Disclaimer
The findings and conclusions are those of the authors and do not necessarily represent the views of NIOSH. Mention of any company name, product, or software does not constitute endorsement by NIOSH.

References
1. Hinds, P. & Kiesler, S. (1995). Communication across boundaries: Work, structure, and use of communication technologies in a large organization. Organization Science, 6, pp. 373-393.
2. Haas, E. J., & DuCarme, J. (2015). A different perspective: NIOSH researchers learn from CM operator responses to proximity detection systems. Coal Age, October, pp. 34-35.
3. Edwards, S. (1983). Quality circles are safety circles. National Safety News, pp. 31-35.
4. Haas, E. J., & Cecala, A. B. (2015). Beyond assessment: Helmet-CAM technology influencing dust exposure awareness and response. Rock Products, November, 28-29.


A Solution in Search of a Problem

It has been 18 months since the Mine Safety and Health Administration’s (MSHA) rule aimed at lowering a miner’s exposure to respirable coal mine dust was implemented, and on February 1, the second phase of the rule went into effect. The first phase of the rule increased operator sampling and required operators to take immediate corrective action when a sample showed excessive concentrations.

Under the second phase of the rule, continuous personal dust monitors (CPDMs) must be used to monitor occupations exposed to the highest respirable dust concentrations, as well as all miners with evidence of black lung. For high-exposure occupations, 15 valid samples must be obtained every quarter, instead of the five samples previously collected every two months, followed by sampling of 15 shifts for other occupations. Finally, operators must post results of CPDM sampling within 12 hours of the sampled shift.

The implementation comes after a January 25 U.S. Court of Appeals decision to deny a legal challenge by the National Mining Association (NMA) and operators seeking to delay it on the grounds that the federal regulator overstepped its authority in issuing the rules. The 11th Circuit Court in Atlanta court rejected the claim.

NMA spokesman Luke Popovich said that the decision was disappointing to the group. “First, the court deferred to MSHA’s definition of the problem — something we disagree with.

As we have said, this rule was a solution in search of a problem and the court, rather than addressing this, chose to accept MSHA’s definition of the problem,” he said. “Additionally, the court believes that the consultation process that took place between National Institute for Occupational Safety and Health (NIOSH) and MSHA is an adequate substitute for the statutory requirements for joint action. It diminishes NIOSH’s role in regulatory matters impacting miners’ health and removes one of the checks envisioned by the Mine Act on MSHA’s regulatory powers.”

The third and final phase becomes effective in August. It will lower the dust concentration limit for the dustiest areas of coal mines from 2 to 1.5 mg/m3 of air.