Practical Compliance Problems With The New Mine Lighting Law – Coal (bb120824-5702-4bc1-9648-7c820231b278)

Section 317(e) of the Federal Coal Mine Health & Safety Act of 1969 directed the Secretary of the Interior to prepare standards under which all working places in a mine shall be illuminated by permissible lighting while persons are working in such places. Section 317(e) further provides that such working places shall be illuminated within 18 months after such standards are promulgated. In accordance with this section of the Act, there was published in the Federal Register for December 91, 1970, a notice of proposed rulemaking which prescribed the illumination to be provided in the working places of underground coal mines. In light of written comments, suggestions, and objections to this proposed rulemaking, the proposedstandards were withdrawn and reproposed in the Federal Register for Wednesday, October 27,-19h. In light of further comments, suggestions, and objections, a public hearing was held on April 4, 1974, and standards were again reproposed and published in the Federal Register for April 1, 1976. Promulgation of the final lighting standards took place on October 1, 1976, which means that the underground coal mining industry must comply with face illumination requirements by April 1, 1978. As mentioned previously, the first proposed rulemaking for illumination of underground coal mines was published in the Federal Register on October 27. 1971. In early 1972, Consolidation Coal Company (Consol) and the United States Bureau of Mines agreed to a cooperative study of underground face illumination: Consol felt that expertise is this field would become increasingly important. Consol's initial efforts in illumination were aimed at investigating practical lighting systems for underground face equipment. We were concerned with installing unobtrusive lights which provided sufficient face illumination for safety, but at the same time were readily maintainable, electrically reliable, and physically sheltered from damage. We believe that our initial lighting systems did provide sufficient face lighting for safety, but because only prototype components were available for field testing, the resultant poor system reliability and maintainability necessitated drastic improvement before face lighting could become practical. Final Lighting Standards Deem Early Lighting Installations Out Of Compliance On April 1, 1976, the Federal Register contained the final version of the illumination standards (as they were later promulgated in October). When these illumination regulations and measurement techniques were defined and measuring instruments were available, Consol checked their lighting systems underground and determined that the systems were not in compliance with these final illumination standards. More Lighting Hardware Added In An Attempt To Achieve Compliance. After determining that all of our face lighting systems were not in compliance, we began adding additional lighting hardware in order to meet compliance with published regulations. Unfortunately, to date, we have not been able to meet compliance with practical lighting systems. We have determined from our field installations that the required additional lighting hardware, (to meet compliance) with its increased vulnerability and decreased reliability, renders the lighting systems impractical, if not impossible, to reasonably maintain. Our attempts to provide 0.06 footlamberts have also produced adverse operator reaction to the glare and to illumination systems in general. BCOA Members Ask MESA To Demonstrate Practicability Of Compliance With Regulations Industry concern about meeting the impending lighting regulations was mounting, and in May of 1976 a meeting between MESA and BCOA members was held to discuss lighting compliance problems. At this meeting, BCOA offered to work cooperatively with MESA in testing the practicability of various lighting systems mounted on underground mining equipment. Field tests were to be conducted by United States Steel Corporation, American Electric Power Service Corporation, and Consolidation Coal Company. The purpose of this underground field testing was to develop capability to provide adequate face illumination in a safe, workable manner which would not detract from efficiency of operation. BCOA members involved in this cooperative study were to submit necessary machine drawings, sketches, etc. to MESA in order that MESA could perform a "black-box" study and specify the type and location of luminaires to be installed on the test machines. MESA was confident that they could specify lighting systems that would be in compliance and would be practical so as not to detract from efficiency of operation. Consol was first to install lighting hardware under the BCOA/MESA cooperative agreement. As per MESA specifications, Control Products HgV luminaires were installed on a Joy 2BT-2H boring machine at the Williams Mine of Northern West Virginia Region. As of mid-October, 1976, Consol had approximately eight weeks operating experience with the lighting system on this boring machine underground and had drawn the following conclusions: The lighting system installed at Williams Mine (1) does not meet compliance with lighting standards as originally proposed by MESA, (2) does not provide illumination in a safe workable manner, and (3) will detract from efficiency of the mining operation due to operational delays. Although Consol has rearranged lights on this boring machine in an attempt to reduce operator objections, a practical lighting system which is "in compliance" has not been arrived at as of this writing.