An Evaluation of the Relative Safety of U.S. Mining Explosion-Protected Equipment Approval Requirements versus Those of International Standards

"INTRODUCTION “Explosion protection” refers to techniques used to minimize the potential for electrical and electronic equipment to create an ignition while operating in a hazardous location (HAZLOC). In particular, U.S. coal mines are required to use equipment in certain areas of the mine that has been approved by the Mine Safety and Health Administration (MSHA) for use in a methane and coal dust environment to limit the risk of the equipment creating an ignition-capable spark or a thermal energy ignition. In general, MSHA’s regulations for explosion protection recognize two techniques: the use of explosion-proof enclosures (XP boxes) and 2-fault intrinsic safety for electrical and electronic equipment. For 2-fault intrinsically safe (IS) equipment, the U.S. mining industry requirements are unique in that the equipment is certified by MSHA. The criteria MSHA uses to evaluate equipment for intrinsic safety, as required by Title 30 of the Code of Federal Regulations (30 CFR) [30 CFR, Sections18.20(b), 18.68(a)(1), 19.1(b), 20.1(c)(2), 22.6, 23.6, and 27.20(a)], is published in a document referred to as ACRI2001 (1). Outside of U.S. underground mining, many industries and countries accept equipment that is designed to a consensus-based international standard (ANSI/ISA 60079-11 is the U.S. version). The purpose of this study is to provide an overall assessment of the ANSI/ISA 60079-11 standard on 2-fault intrinsic safety and the MSHA ACRI2001 acceptance criteria, and determine if the ANSI/ISA document can be an alternative to ACRI2001 while maintaining an equivalent or better level of safety for miners. There are many drivers for this study. First, immediately after the 2006 MINER Act (2) was passed, there was a perception in the industry that the unique MSHA requirements were contributing to delays or restricting the availability of equipment to meet the requirements of the Act. Additionally, the MINER Act required that mine operators submit an accident response plan for MSHA approval, to be reviewed every six months. MSHA is required to determine if these plans reflect the most recent credible scientific research and make use of currently commercially available technology. There is a concern, as expressed in a recent National Academy of Science (NAS) study (3), that the unique requirements for U.S. mining may be limiting the technologies available to coal miners and technology options for mine operators. Accordingly, the study recommended that the National Institute for Occupational Safety and Health (NIOSH) and MSHA re-examine their technology approval and certification processes to ensure they are not deterring innovation, and explore opportunities to cooperate with other international approval organizations to harmonize U.S. and international standards without compromising safety. Lastly, the National Technology Transfer Act (NTTA) and the accompanying Office of Management and Budget’s OMB-119 circular mandate the use of consensus-based standards by federal agencies. However, for U.S. mining operations, MSHA cannot accept such standards unless a determination is made that such standards provide an equivalent level of protection for the miner, per the requirements of the 1977 Mine Act, the 2006 MINER Act, and 30 CFR Part 18 regulations."