Get documents about "Msha Part 48 Training Record
Description
Msha Part 48 Training Record document sample
Document Sample
Title 30 CFR Part 48
Training Plans
and
Associated Documentation
A Final Paper
Presented to the
Faculty of the
School of Engineering
Kennedy-Western University
In Partial Fulfillment
Of the Requirements for the Degree of
Bachelor of Science
in
Safety Engineering
by
Ann Petersen
Rock Springs, Wyoming
Abstract
In order to comply with Title 30 CFR Part 48 regulations mine operators
must provide every miner with training, prior to their start of actual work
duties in a mine. This training will somewhat depend on the type of mine
and experience of the miner, but under no circumstances is it legal to
open a new mine or continue to operate an existing mine without a MSHA
approved Title 30 CFR Part 48 training plan. It is the intent of this paper to
provide anyone who finds themselves involved in the process of writing
such a plan with information they need to succeed in doing so.
This information will make writing, submitting for approval and
administering a Part 48 plan much easier. Through out this paper you the
plan writer and administer will be introduced to the legal requirements of
what must be in a plan, a review of documentation that must accompany a
plan and a step by step guide of how to write such a plan and how to
submit it for MSHA approval. Because without an approved Part 48 plan
you do not have a mine and you run the risk of violating several federal
laws.
Table of Contents
CHAPTER 1 INTRODUCTION………………………………………..1
Statement of the Problem………………………………2
Purpose of the Study……………………………………2
Importance of the Study……………………………......3
Scope of the Study……………………………………...4
Rationale of the Study…………………………………..4
Definition of Terms………………………………………5
Overview of the Study…………………………………..8
CHAPTER 2 REVIEW OF RELATED LITERATURE……………...11
CHAPTER 3 METHODOLOGY………………………………….…..42
Approach …………………………….…………….…..42
Data Gathering Method…...…………………………..42
Database of the Study…………………………….…..43
Validity of Data………………………………………....43
Originality & Limitations of Data……………….....….43
Summary…………………..……………………...…....44
CHAPTER 4 DATA ANALYSIS…………………............................45
CHAPTER 5 SUMMARY, CONCLUSIONS AND
RECOMMENDATIONS…………………………….....78
1
CHAPTER 1: INTRODUCTION
A look at the history of mining and the progression of mining
legislation reveals that mining is an inherently dangerous occupation and
that the hazards encountered by miners vary widely from mine site to mine
site. Even though mining has become a much safer occupation, it is still
one of the most dangerous occupations in the United States. The slow but
steady reduction in mining fatalities over the last 100 years can be
attributed to many things including the efforts of the Mine Health and
Safety Administration, United States Department of Labor, Labor Unions
and mine operators.
One of the leading factors in reducing mining injuries and deaths
was the implementation of MSHA’s Title 30 CFR Part 48 training
programs. Unfortunately, the creation and implementation of such a
program can be an overwhelming and daunting task, especially for
someone who is not familiar with MSHA and Title 30 CFR, Part 46, Part
48, 75 and Part 77.
2
Statement of the Problem
Since the inception of MSHA, it has been proven that the number
and severity of accidents, injuries and fatalities can be reduced through
training. The effectiveness of this training can be seen by reviewing the
type and severity of accidents, which involved a lack of training and the
overall reduction in total number of injuries and fatalities incurred by
miners each year (U.S. Department of Labor, Mine Safety and Health
Administration, 2004 e, f). One method of providing this training is through
MSHA mandated Title 30 CFR Part 48 training.
Purpose of the Study
Unfortunately, if you are not extremely familiar with Mine Safety and
Health Act and its associated documents, it can be an intimidating task to
design and implement a Title 30 CFR Part 48 training plan. The intent of
this paper is to provide anyone not familiar with Mine Safety and Health
Act and Title 30 CFR Part 48 training a systematic guide of how to design,
submit for approval, and ultimately implement a Title CFR 30 Part 48
training plan. All aspects of designing a Title 30 CFR part 48 training plan
will be addressed including:
A review of the MSHA Act of 1977.
A review of the Title 30 CFR Part 48 requirements.
3
A review of the Program Policy Manual associated with Title 30
CFR part 48.
A step-by-step walk through of how to design a Title 30 CFR Part
48 training plan.
How to submit the training plan to MSHA for approval.
A review of the requirements to become a Title CFR 30 Part 48
certified instructor.
A review of documents that must be maintained in conjunction with
the presentation of training under an approved training plan
pursuant to Title 30 CFR Part 48 Training plan.
How to effectively administer an MSHA approved Title CFR 30 Part
48 training plan.
Importance of the Study
Every mine operator by federal law must have in place, prior to
operation an approved Title 30 CFR Part 48 training plan. Without an
MSHA approved Title 30 CFR Part 48 training plan in place, a mine
operator runs the risk of receiving substantial fines for violating not only
the Federal Mine Safety and Health Act of 1977 ( Title 1 Section 105 (3)
and 110 I), but also of violating Title 30 CFR Part 100.3 (a) (Baugh,
2004). By using this guide, anyone charged with the task of developing
4
such a plan should be able to do so with minimal difficultly and opposition
from Federal Authorities.
Scope of the Study
Through a review of MSHA Fatalities (U.S. DOL, MSHA, 2004 e, f),
it is obvious that training is a key factor in reducing the number and
severity of accidents in the mining industry. MSHA training, in particular,
Title 30 CFR Part 48, training if used properly is an effective tool in
reducing mine accidents. This paper explores and explains the details of
creating a fully functional Title 30 CFR Part 48 training plan and the
associated documents that are used in conjunction with the plan.
Rationale of the Study
Even though MSHA has been charged with the task of regulating
and mandating miner training, it is ultimately up to the mine operator to
design and implement such training. The challenge of designing and
implementing a Title 30 CFR Part 48 training plan is an ever-evolving
process. The goal of this paper is to help both those experienced in
dealing with MSHA and those new to working with MSHA with a guide
which will help them successfully design and implement a comprehensive
Title 30 CFR Part 48 training plan.
5
Definition of Terms
Term Abbreviation Definition
Code of Federal Regulations CFR A codification of the
general and permanent
rules published in the
Federal Register by the
Executive departments
and agencies of the
Federal government.
(Office of the Federal
Register, National
Archives and Records
Administration, 2002)
CFR 30 Part 48 Approved A training plan designed
Training plan by the operator and
approved by MSHA to
provide training to new
and experienced miners,
and all mine visitors,
Contractors and others.
(Office of the Federal
Register, National
Archives and Records
Administration, 2002)
Experienced Miner Surface Any miner who has
completed MSHA
approved new miner
training and has at least
12 months of surface
mining experience
within the preceding 36
months. (Office of the
Federal Register, National
Archives and Records
Administration, 2002)
6
Experienced Miner Underground Any miner who has
completed MSHA
approved new miner
training and has at least
12 months of underground
mining experience. (Office
of the Federal Register,
National Archives and
Records Administration,
2002)
Hazard Training Training received by all
persons on a mine site
(surface and underground)
including all visitors and
contractors. Which covers
hazard recognition and
avoidance, emergency
and evacuation
procedures, health and
safety standards, safety
rules and procedures.
Persons completing
comprehensive training do
not have to receive hazard
training. (Office of the
Federal Register, National
Archives and Records
Administration, 2002)
Miner Any person who is
engaged in extraction and
production process, or
who is regularly exposed
to mining hazards.
(Office of the Federal
Register, National
Archives and Records
Administration, 2002)
7
Mine Safety and Health MSHA Federal agency created by
Administration Congress in 1977
regulating mining
practices. (U.S. DOL,
MSHA, 2004 d)
New Miner Surface Any person who is not an
experienced miner per 30
CFR Part 48. and who is
NOT qualified to receive
Hazard Training – ONLY.
(Office of the Federal
Register, National
Archives and Records
Administration, 2002)
New Miner Underground Any person who is not an
experienced underground
miner per 30 CFR Part 48.
(Office of the Federal
Register, National
Archives and Records
Administration, 2002)
Newly Hired Experienced Any miner who has
Miner Surface completed MSHA-
approved new miner
surface training and has at
least 12 months surface
experience and who is
NOT qualified to receive
Hazard Training – ONLY.
(Office of the Register,
National Archives and
Records Administration,
2002)
8
Newly Hired Experienced Any miner who has
Miner Underground completed MSHA-
approved new miner
underground training and
has at least 12 months
underground experience.
(Office of the Federal
Register, National
Archives and Records
Administration, 2002)
Mine Operator Any owner, lessee, or
other person who
operates, controls or
supervises a surface mine,
the surface area of a
underground mine and/or
a underground mine; or
any independent
contractor identified as an
operator performing
services or construction at
such time. (Office of the
Federal Register, National
Archives and Records
Administration, 2002)
National Institute for NIOSH Federal Agency of the Of
Occupational Safety Center of Disease and
and Health Control, committed to the
study, research and
development of
occupational health and
safety issues.
9
The Mine ACT The Federal Mine Safety
and Health Act of 1977
written to update the Coal
Act of 1969 and
incorporate Metal/Non-
metal. Basically updates
the MESA ACT to include
Health regulations. (U.S.
DOL, MSHA, 2004 d)
Title 30 CFR 30 CFR Title 30 of the Code of
Federal regulations
dealing with Mineral
Resources and governing
the actions of MSHA and
the mining community.
Overview of the Study
“30 CFR Part 48 requires all mines to have a training plan. 30 CFR
Part 77 requires a program or plan that describes what, when, how,
and where the mine operator will train persons whose work
assignments require that they be certified or qualified ( 77.107-1).
Independent contractors may submit their own training plan, use
the MSHA approved plan at the mine where they will be working, or
obtain training from an approved cooperative/state grant program.
State grantees and others may also develop their own training
plans” “All training plans must be submitted to and approved by
10
MSHA for the geographical area in which the mine is located. The
plan may be in any format, so long as it includes all the required
information” (U.S. DOL, MSHA, 2004 c)
Therefore it is the responsibility of each mine operator to create and have
approved such a plan prior to mining, basically without such a plan, mining
may not be performed.
11
CHAPTER 2: REVIEW OF RELATED LITERATURE
Unfortunately information on designing and implementing a Title
30 CFR Part 48 training plan is not easily found. Yet having a plan in
place prior to mining is mandatory. Most of the sources used in the
gathering of information for this paper where found searching the MSHA
web page, reviewing the Federal Mine Safety and Health Act of 1977,
reviewing Title 30 CFR Part 48, reviewing training manuals for Title 30
CFR part 48 trainers, reviewing associated documents and reviewing
training plans from several mines and contractors.
It is the goal of the author of this paper, to provide a road map for
those who find themselves challenged with the task of creating a
comprehensive Title 30 CFR Part 48 training plan, that covers the training
and retraining of miners for both Title 30 CFR part 48 subparts A and B,
hazard training, HazCom training, which is also required by Title 30 CFR
Part 62, task training and documentation of such training.
Title: Federal Mine Safety and Health Act of 1977
The Mine Act, as it is commonly referred to, became effective on
November 9, 1977, and was written to strengthen and to amend the
Coal Act of 1969 it consolidated all federal health and safety regulations
12
for the mining industry, coal as well as non-coal mining, under a single
statutory scheme. The Mine Act strengthened and expanded the rights of
miners, and enhanced the protection of miners from retaliation for
exercising such rights. Mining fatalities dropped sharply under the Mine
Act from 272 in 1977 to 86 in 2000 (U. S. DOL, MSHA, 2004 d).
The Mine Act enabled the creation of Title 30 –Mineral Resources
of the Code of Federal Regulations, which deals with all aspects of the
Mine Safety and Health Administration. For the purpose of this paper, a
good place to start a review of The Mine Act is with Section 2 (g) which
states:
“it is the purpose of this Act (1) to establish interim mandatory
health and safety standards and to direct the Secretary of Health,
Education, and Welfare and the Secretary of Labor to develop and
promulgate improved mandatory health or safety standards to
protect the health and safety of the Nation’s coal and or other
miners; (2) to require that each operator of a coal or other mine and
every miner in such mine comply with such standards; (3) to
cooperate with, and provide assistance to, the states in the
development and enforcement of effective State coal or other mine
health and safety programs; and (4) to improve and expand, in
cooperation with the States and the coal or other mining industry,
13
research and development and training programs aimed at
preventing coal or other mine accidents and occupationally caused
diseases in the industry.” (Office of the Solicitor, Division of Mine
Safety and Health, Department of Interior, 1977)
It is clear to see after reading this section of the Mine Act that training is a
federal requirement and without a training plan, you do not have a mine.
The next section of the Act that is relevant to the issue of training is Title I,
Mandatory Health and Safety Training, Section 115 (a).
“(a) Each operator of a coal or other mine shall have a health and
safety training program which shall be approved by the Secretary.
The Secretary shall promulgate regulations with respect to such
health and safety training programs not more than 180 days after
the effective date of the Federal Mine Safety and Health
Amendments Act of 1977. Each training program approved by the
Secretary shall provide as a minimum that--
(1) new miners having no underground mining experience shall
receive no less than 40 hours of training if they are to work
underground. Such training shall include instruction in the statutory
rights of miners and their representatives under this Act, use of the
self-rescue device and use of respiratory devices, hazard
14
recognition, escapeways, walk around training, emergency
procedures, basic ventilation, basic roof control, electrical hazards,
first aid, and the health and safety aspects of the task to which he
will be assigned;
(2) new miners having no surface mining experience shall receive
no less than 24 hours of training if they are to work on the surface.
Such training shall include instruction in the statutory rights of
miners and their representatives under this Act, use of the self-
rescue device where appropriate and use of respiratory devices
where appropriate, hazard recognition, emergency procedures,
electrical hazards, first aid, walk around training and the health and
safety aspects of the task to which he will be assigned;
(3) all miners shall receive no less than eight hours of refresher
training no less frequently than once each 12 months, except that
miners already employed on the effective date of the Federal Mine
Safety and Health Amendments Act of 1977 shall receive this
refresher training no more than 90 days after the date of approval
of the training plan required by this section;
(4) any miner who is reassigned to a new task in which he has had
no previous work experience shall receive training in accordance
with a training plan approved by the Secretary under this
15
subsection in the safety and health aspects specific to that task
prior to performing that task;
(5) any training required by paragraphs (1), (2) or (4) shall include a
period of training as closely related as is practicable to the work in
which the miner is to be engaged.
(b) Any health and safety training provided under subsection (a)
shall be provided during normal working hours. Miners shall be paid
at their normal rate of compensation while they take such training,
and new miners shall be paid at their starting wage rate when they
take the new miner training. If such training shall be given at a
location other than the normal place of work, miners shall also be
compensated for the additional costs they may incur in attending
such training sessions.
(c) Upon completion of each training program, each operator shall
certify, on a form approved by the Secretary, that the miner has
received the specified training in each subject area of the approved
health and safety training plan. A certificate for each miner shall be
maintained by the operator, and shall be available for inspection at
the mine site, and a copy thereof shall be given to each miner at
the completion of such training. When a miner leaves the operator's
employ, he shall be entitled to a copy of his health and safety
16
training certificates. False certification by an operator that training
was given shall be punishable under section 110(a) and (f); and
each health and safety training certificate shall indicate on its face,
in bold letters, printed in a conspicuous manner the fact that such
false certification is so punishable.
(d) The Secretary shall promulgate appropriate standards for safety
and health training for coal or other mine construction workers.
(e) Within 180 days after the effective date of the Federal Mine
Safety and Health Amendments Act of 1977, the Secretary shall
publish proposed regulations which shall provide that mine rescue
teams shall be available for rescue and recovery work to each
underground coal or other mine in the event of an emergency. The
costs of making advance arrangements for such teams shall be
borne by the operator of each such mine.” (Office of the Solicitor,
Division of Mine Safety and Health, Department of Interior, 1977)
This section of the Mine Act outlines all of the requirements that must be
met by a mine operator in regards to training programs. It gives a mine
operator notice that a plan must be approved by the Secretary of Labor or
his delegate before mine operation begins, the number of hours of training
required for both surface and underground miners, a list subjects that
17
must be included in the training, guidelines for pay compensation of
miners while receiving training and how training must be documented.
Unfortunately, The Mine Act does not give you detailed instructions on
how to accomplish this federally mandated training so for that information,
we must now move on to Title 30 CFR for more detailed instructions.
Title: Title 30 Code of Federal Regulations – Mineral Resources
Title 30 CFR is the section of the Code of Federal Regulations that
deals with mineral resources and more importantly, for the purposes of
this paper, mining and miner training. It is broken into three books the first
containing Parts 1 to 199, the second containing 200 to 699 and the third
containing Parts 700 to end (Office of the Federal Register, National
Archives and Records Administration, 2002 Page ix). All information that
is relevant to Title 30, CFR Part 48, Training plans are found in the first
book, the sections that most pertinent to this paper are Parts 46, 47, 48,
62, 75 and 77.
Title 30 CFR, Part 46, deals with the training and retraining of
miners engaged in shell dredging, or employed at sand, gravel, surface
stone, surface clay, colloidal phosphate, or surface limestone mines. Title
30 CFR part 46 was added to the Code of Federal regulations in 1999, it is
very similar to Title 30 CFR Part 48, except that you do not have to submit
18
the plan for approval by the Mine Safety and Health Administration.
However, you must still have the training plan available for review upon
request for inspection by MSHA. and you still must maintain training
records.
Title 30 CFR, Part 48, deals with the bulk of training issues within the
jurisdiction of the Mine Safety and Health Administration. In this section of
the Code of Federal Regulations, is most of the information you will need
to create an MSHA approved Part 48 Training Plan. This section of the
law is broken into two subparts. Subpart A deals with the training and
retraining of underground miners and Subpart B deals with the training
and retraining of miners working at surface mines and surface areas of
underground mines.
Subparts A and B, are very similar in their content, except for a few
rather important differences. The main differences between parts A and B
are Part 48.2 (a) (1) and Part 48.22 (a) (1) to note about this section of
Part 48 is the differences in the definition of what a miner is Subpart A
defines a miner as:
(a)(1) Miner means, for purposes of 48.3 through 48.10 of this
subpart A, any person working in an underground mine and who is
engaged in the extraction and production process, or who is
regularly exposed to mine hazards, or who is a maintenance or
19
service worker employed by the operator or a maintenance or
service worker contracted by the operator to work at the mine for
frequent or extended periods. This definition shall include the
operator if the operator works underground on a continuing, even if
irregular, basis. Short term, specialized contact workers, such as
drillers and blasters, who are engaged in the extraction and
production process and who have received training under 48.6
(experienced miner training) of this subpart A may, in lieu of
subsequent training under that section for each new employment,
receive training under 48.11 (Hazard training) of this subpart A.
This definition does not include:
(i) Workers under subpart C of this part 48, including shaft and
slope workers, workers engaged in construction activities ancillary
to shaft and slope sinking, and workers engaged in the construction
of major additions to an existing mine which requires the mine to
cease operations;
(ii) Supervisory personnel subject to MSHA approved State
certification requirements; and,
(iii) Any person covered under paragraph (a)(2) of this section.
20
Title 30 CFR Part 48 Subpart B defines a miner as:
(a)(1) Miner means, for purposes of 48.23 through 48.30 of this
subpart B, any person working in a surface mine or surface areas
of an underground mine and who is engaged in the extraction and
production process, or who is regularly exposed to mine hazards,
or who is a maintenance or service worker employed by the
operator or a maintenance or service worker contracted by the
operator to work at the mine for frequent or extended periods. This
definition shall include the operator if the operator works at the
mine on a continuing, even if irregular, basis. Short-term,
specialized contract workers, such as drillers and blasters, who are
engaged in the extraction and production process and who have
received training under 48.26 (Training of newly employed
experienced miners) of this subpart B, may in lieu of subsequent
training under that section for each new employment, receive
training under 48.31 (Hazard training) of this subpart B. This
definition does not include:
(i) Construction workers and shaft and slope workers under subpart
C of this Part 48;
(ii) Any person covered under paragraph (a)(2) of this section.
21
(2) Miner means, for purposes of 48.3 (Hazard training) of this
subpart B, any person working in a surface mine, including any
delivery, office, or scientific worker or occasional, short-term
maintenance or service worker contracted by the operator, and any
student engaged in academic projects involving his or her extended
presence at the mine. This definition excludes persons covered
under paragraph (a)(1) of this section and subpart C of this part.
One of the main differences between Subparts A and B is that
Subpart A deals with underground miners and Subpart B deals with
surface miners. It is also interesting to note that both Subpart A and B
refer to a Subpart C, which does not exist. It is noted that MSHA never did
promulgate Subpart C. However, shaft and slope workers are covered in
other parts of 30 CFR and must be trained accordingly. (Baugh, 2004).
In addition, Subpart A and B each list the required subjects that
must be covered during the training and retraining of miners. In particular,
it is important to review sections 48.5 and 48.25 and note the differences
between what is required for a surface miner and an underground miner.
22
30 CFR 48.5
Training of new miners; minimum courses of instruction; hours of
instruction.
(a) Each new miner shall receive no less than 40 hours of training
as prescribed in this section before such miner is assigned to work
duties. Such training shall be conducted in conditions which as
closely as practicable duplicate actual underground conditions, and
approximately 8 hours of training shall be given at the minesite.
(b) The training program for new miners shall include the following
courses:
(1) Instruction in the statutory rights of miners and their
representatives under the Act; authority and responsibility of
supervisors. The course shall include instruction in the statutory
rights of miners and their representatives under the Act, including a
discussion of section 2 of the Act; a review and description of the
line of authority of supervisors and miners' representatives and the
responsibilities of such supervisors and miners' representatives;
and an introduction to the operator's rules and the procedures for
reporting hazards.
(2) Self-rescue and respiratory devices. The course shall include
instruction and demonstration in the use, care, and maintenance of
23
self-rescue and respiratory devices used at the mine. Training in
the use of self-contained self-rescue devices shall include complete
donning procedures in which each person assumes a donning
position, opens the device, activates the device, inserts the
mouthpiece or simulates this task while explaining proper insertion
of the mouthpiece, and puts on the nose clip. The course shall be
given before the new miner goes underground.
(3) Entering and leaving the mine; transportation; communications.
The course shall include instruction on the procedures in effect for
entering and leaving the mine; the check-in and checkout system in
effect at the mine; the procedures for riding on and in mine
conveyances; the controls in effect for the transportation of miners
and materials; and the use of the mine communication systems,
warning signals, and directional signs.
(4) Introduction to the work environment. The course shall include a
visit and tour of the mine, or portions of the mine which are
representative of the entire mine. A method of mining utilized at the
mine shall be observed and explained.
(5) Mine map; escapeways; emergency evacuation; barricading.
The course shall include a review of the mine map; the escapeway
system; the escape, firefighting, and emergency evacuation plans
24
in effect at the mine; and the location of abandoned areas. Also
included shall be an introduction to the methods of barricading and
the locations of the barricading materials, where applicable. The
program of instruction for escapeways and emergency evacuation
plans approved by the District Manager shall be used for this
course.
(6) Roof or ground control and ventilation plans. The course shall
include an introduction to and instruction on the roof or ground
control plan in effect at the mine and procedures for roof and rib or
ground control; and an introduction to and instruction on the
ventilation plan in effect at the mine and the procedures for
maintaining and controlling ventilation.
(7) Health. The course shall include instruction on the purpose of
taking dust, noise, and other health measurements, and any health
control plan in effect at the mine shall be explained. The health
provisions of the act and warning labels shall also be explained.
(8) Cleanup; rock dusting. The course shall include instruction on
the purpose of rock dusting and the cleanup and rock dusting
program in effect at the mine, where applicable.
(9) Hazard recognition. The course shall include the recognition
and avoidance of hazards present in the mine, particularly any
25
hazards related to explosives where explosives are used or stored
at the mine.
(10) Electrical hazards. The course shall include recognition and
avoidance of electrical hazards.
(11) First aid. The course shall include instruction in first aid
methods acceptable to MSHA.
(12) Mine gases. The course shall include instruction in the
detection and avoidance of hazards associated with mine gases.
(13) Health and safety aspects of the tasks to which the new miner
will be assigned. The course shall include instruction in the health
and safety aspects of the tasks to be assigned, including the safe
work procedures of such tasks, the mandatory health and safety
standards pertinent to such tasks, information about the physical
and health hazards of chemicals in the miner's work area, the
protective measures a miner can take against these hazards, and
the contents of the mine's HazCom program.
(14) Such other courses as may be required by the District
Manager based on circumstances and conditions at the mine.
(c) Methods, including oral, written, or practical demonstration, to
determine successful completion of the training shall be included in
the training plan. The methods for determining such completion
26
shall be administered to the miner before he is assigned work
duties.
(d) A newly employed miner who has less than 12 months of mining
experience and has received the courses and hours of instruction in
paragraphs (a) and (b) of this section, within 36 months preceding
employment at a mine, does not have to repeat this training. Before
the miner starts work, the operator must provide the miner with the
experienced miner training in 48.6(b) of this part and, if applicable,
the new task training in 48.7 of this part. The operator must also
provide the miner with annual refresher training and additional new
task training, as applicable.
30 CFR 48.25
Training of new miners; minimum courses of instruction; hours of
instruction.
(a) Each new miner shall receive no less than 24 hours of training
as prescribed in this section. Except as otherwise provided in this
paragraph, new miners shall receive this training before they are
assigned to work duties. At the discretion of the District Manager,
new miners may receive a portion of this training after assignment
to work duties: Provided, That no less than 8 hours of training shall
in all cases be given to new miners before they are assigned to
27
work duties. The following courses shall be included in the 8 hours
of training: Introduction to work environment, hazard recognition,
and health and safety aspects of the tasks to which the new miners
will be assigned. Following the completion of this preassignment
training, new miners shall then receive the remainder of the
required 24 hours of training, or up to 16 hours, within 60 days.
Operators shall indicate in the training plans submitted for approval
whether they want to train new miners after assignment to duties
and for how many hours. In determining whether new miners may
be given this training after they are assigned duties, the District
Manager shall consider such factors as the mine safety record, rate
of employee turnover and mine size. Miners who have not received
the full 24 hours of new miner training shall be required to work
under the close supervision of an experienced miner.
(b) The training program for new miners shall include the following
courses:
(1) Instruction in the statutory rights of miners and their
representatives under the Act; authority and responsibility of
supervisors. The course shall include instruction in the statutory
rights of miners and their representatives under the Act, including a
discussion of section 2 of the Act; a review and description of the
28
line of authority of supervisors and miners' representatives and the
responsibilities of such supervisors and miners' representatives;
and an introduction to the operator's rules and the procedures for
reporting hazards.
(2) Self-rescue and respiratory devices. The course shall include
instruction and demonstration in the use, care, and maintenance of
self-rescue and respiratory devices, where applicable.
(3) Transportation controls and communication systems. The
course shall include instruction on the procedures in effect for riding
on and in mine conveyances where applicable; the controls for the
transportation of miners and materials; and the use of mine
communication systems, warning signals, and directional signs.
(4) Introduction to work environment. The course shall include a
visit and tour of the mine, or portions of the mine which are
representative of the entire mine. The method of mining or
operation utilized shall be observed and explained.
(5) Escape and emergency evacuation plans; firewarning and
firefighting. The course shall include a review of the mine escape
system, and escape and emergency evacuation plans in effect at
the mine; and instruction in the firewarning signals and firefighting
procedures.
29
(6) Ground control; working in areas of highwalls, water hazards,
pits and spoil banks; illumination and night work. The course shall
include, where applicable, and introduction to and instruction on the
highwall and ground control plans in effect at the mine; procedures
for working safely in areas of highwalls, water hazards, pits and
spoil banks; the illumination of work areas; and safe work
procedures during the hours of darkness.
7) Health. The course shall include instruction on the purpose of
taking dust measurements, where applicable, and noise and other
health measurements, and any health control plan in effect at the
mine shall be explained. The health provisions of the Act and
warning labels shall also be explained.
(8) Hazard recognition. The course shall include the recognition
and avoidance of hazards present in the mine.
(9) Electrical hazards. The course shall include recognition and
avoidance of electrical hazards.
(10) First aid. The course shall include instruction in first aid
methods acceptable to MSHA.
(11) Explosives. The course shall include a review and instruction
on the hazards related to explosives. The only exception to this
30
course component is when no explosives are used or stored on
mine property.
(12) Health and safety aspects of the tasks to which the new miner
will be assigned. The course shall include instructions in the health
and safety aspects of the tasks to be assigned, including the safe
work procedures of such tasks, the mandatory health and safety
standards pertinent to such tasks, information about the physical
and health hazards of chemicals in the miner's work area, the
protective measures a miner can take against these hazards, and
the contents of the mine's HazCom program.
(13) Such other courses as may be required by the District
Manager based on circumstances and conditions at the mine.
(c) Methods, including oral, written or practical demonstration, to
determine successful completion of the training shall be included in
the training plan. Upon completion of training, the methods for
determining successful completion shall be administered to the
miner. The method for determining successful completion of pre-
assignment training under paragraph (a) of this section shall be
administered to the miner before he is assigned to work duties.
(d) A newly employed miner who has less than 12 months of mining
experience and has received the courses and hours of instruction in
31
paragraphs (a) and (b) of this section, within 36 months preceding
employment at a mine, does not have to repeat this training. Before
the miner starts work, the operator must provide the miner with the
experienced miner training in 48.26(b) of this part and, if
applicable, the new task training in 48.27 of this part. The operator
must also provide the miner with annual refresher training and
additional new task training, as applicable.
After reading these two sections of Title 30 CFR, part 48, it is easy to see
how designing and implementing a training program all of a sudden
becomes a monumental task for a mine operator. In 48.2 it states that all
new underground miners must receive 40 hours of training and in 48.25 it
says that all new surface miners need 24 hours of training with only 8 of
those hours required before beginning actual mine work.
Title: MSHA Program Policy Manual
As a Title 30 CFR Part 48 program designer and administrator, the
Program Policy Manual (U.S. DOL, MSHA, 1996) is one of the best
resources you have (Baugh, 2004). This is the place you go to find out
how to interpret and comply with Title 30 of the Code of Federal
Regulations. This document is published and updated periodically by the
Mine Safety and Health Administration and is basically a “users guide” of
32
how to interpret the Title 30 Code of Federal regulations. It is broken in to
five volumes. Volume I, interprets the Act of 1977, Volume II, testing and
evaluation, Volume III, 30 CFR parts 40 thorough 50 and part 100, Volume
IV, Metal and Non-Metal mining and Volume V, Coal Mines. It is in the
Program Policy Manual Volume III, that you find information dealing with
the training and retraining of miners. It is in Volume III, that the definitions
of what a “miner” is and how those definitions apply to different training
requirements. It is in this manual that you will find the answers to many of
your questions concerning who should get what training. Volume III is an
excellent guide for making decisions as to who qualifies as an
experienced or inexperienced miner and how much time can elapse
between periods of mine work before a miner must be retrained as a new
miner instead of a newly hired experienced miner. You should consult the
program policy manual often to keep yourself abreast of any changes in
interpretation of Title 30 CFR, remember it is up to you the “operator” to
keep yourself informed and in compliance with Title 30 of the Code of
federal Regulations and the Act of 1977 (Baugh, 2004).
33
Title: 5000-23 form
One of the key elements of any program or policy is the
documentation of the compliance with that program or policy and the Mine
Safety and Health Administrations addresses training documentation in
Title 30 CFR part 48.9 and 48.29
“Upon a miner’s completion of each MSHA approved training
program, the operator shall record and certify on MSHA form 5000-
23 that the miner has received the specific training” (Office of the
Federal Register, National Archives and Records Administration,
2002, Part 48 Subpart A 48.9 and Subpart B 48.29)
In order to comply with this requirement of the federal law you must
use an approved 5000-23 form, which can be obtained from any MSHA
field office, download off of the MSHA web site or created by the Operator
and submitted to MSHA for approval. At first glance, this form appears
rather simple and straightforward but in reality, it can be a very complex
and confusing document. There are only eight sections to this form, most
of which present you the trainer with several options and opportunities for
error. It is strongly advised that you consult the MSHA program policy
manual volume III (U.S. DOL, MSHA, 1996) for some very helpful advice,
as an error in filling out this federal document can be considered a federal
violation.
34
“This certificate is required under Federal Law 91-173 as amended
by Public Law 95-164. Failure to comply may result in penalties and
other sanctions as provided by sections 108 and 110, Public Law
91-173 as amended by Public Law 95-164.” (U.S. DOL, MSHA,
2002)
Title: Instructions for Completing a Mine Safety and Health
Administration Certificate of Training Form (5000-23)
As mentioned earlier MSHA 5000-23 forms can be very confusing,
the pre-printed version which is available from all MSHA field offices
comes standard with four copies which must be properly filled out and
distributed to:
“Copy 1 (white) - Employer's Personnel Record
Copy 2 (pink) - Employee's Record Copy
Copy 3 (yellow) - Employee's Separation Copy
Copy 4 (green) - Record Keeping
(U.S. DOL, MSHA, 2004, April, b)
This instructional guide offers a through step by step walk through of how
to properly fill out a 5000-23 form.” (U.S. DOL, MSHA, 2002, April) It is
wise to take special note of how to fill sections number 4 and 5 as these
two sections deal with training that has been started but not entirely
35
finished and incorrectly filling out these sections can be a federal violation.
Item 4. Date Training Requirements Completed
Depending on whether the training is complete or partially will
determine how this item is completed. Only entering a date
indicates that the training marked in item 2 is completed. Placing a
check in the box to the right of the date entry, indicates that the
training for the program(s) marked in item 2 is not complete. The
appropriate boxes in item 5 must then be checked to indicate what
subjects were completed.
The following are some examples of partially completed training: (1)
training for new miners given away from the mine site (which will
then require site specific training at the mine site); (2) utilizing the 8
and 16 hours in 60-day provision for newly employed inexperienced
surface miners; and (3) providing partially completed annual
refresher training. (U.S. DOL. MSHA, 2004, April b)
Item 5. Check Subjects Completed (use only for partially completed
training)
“This is generally used for conducting annual refresher training in
increments throughout an annual refresher cycle; or for newly
employed inexperienced miner training which does not cover mine
36
specific courses that are required to be covered at the mine site.”
(U.S. DOL. MSHA, 2004,April b)
Title: A Guide To Miners Rights and Responsibilities Under the
Federal Mine Safety and Health Act of 1977
This guide is a very informative publication designed by MSHA to
give miners both experienced and in experienced information that
“summarizes the rights and responsibilities of miners, their
representatives and applicants for mine work under the Act” (U.S.
DOL, MSHA. National Mine Safety Academy. Revised 2000).
Trainers and Part 48 Plan administrators will find this guide to be a
valuable reference for not only the design phase of a Part 48 plan, but
also during the implementation phase, as this guide lends itself well to
being used as a instructional aid. It spells out in plain English, a miners
rights to training, health and safety. Anyone even attempting to
understand the complexities of a Title 30 CFR Part 48 training plan should
have and read repeatedly a copy of this guide. Along with giving a miners
a summary of their rights it also contains a wealth of information on a wide
range of MSHA topics including Part 48 Training. This guide gives
37
inexperienced Part 48 Training Plan administrators a brief overview of
highlights of what a Part 48 Training Plan should include and why these
items are important.
Title: Compliance Guide of MSHA’s Modified Regulations on
Training and Retraining of Miners
This is basically a collection of commonly asked questions about
Title 30 CFR Part 48 Training and the correct answers to those questions.
This guide brings to light some very pertinent questions that all Title 30
CFR Part 48 Training plan administrators should ask themselves when
determining what training is needed by whom and how often it is needed.
This compliance guide does a good job of defining for someone unfamiliar
with MSHA, what the definition of an experienced miner is
“the new rule requires that a miner both receive new miner training
and have 12 months of mining experience to qualify as an
“experienced Miner”” (U.S. DOL, MSHA. 1998, December)
And covers many of the “what if” questions that Part 48 Training Plan
administrators encounter. Such as:
“What are the different kinds of “experienced Miners” who must
take the experienced miner training?”
38
“Experienced miners” are miners who are: (1) Newly
employed by the operator, (2) transferred to the mine,
(3) Transferred from surface to underground or vice versa,
and (4) Returning to mining after an absence of more than
12 months” (U.S. DOL, MSHA. 1998, December)
Title: Instructors Training Workshop – Part 48
This guide is actually one of a series of guides written and
published by the Mine Safety and Health Administration to help operators
comply with the Act of 1977 and Title 30 of the Code of Federal
regulations. In fact, in the introduction of this guide it spells out its
intended purpose quite clearly.
“30 CFR Part 48 requires that persons who provide that training
and retraining be approved to do so”
“This Instructor Training Workshop has been developed to assist
instructors and potential instructors with the following goals:
- To become knowledgeable in the requirements of 30 CFR Part 48
- To become effective classroom trainers”
(Department of Labor, Mine Safety and Health Administration,
National Mine Safety Academy, 2002, page iii)
39
If you are new to MSHA and MSHA Part 48 Training, in particular this may
actually be one of the first guides to consult, as it gives you some very
straightforward information on what Title 30 CFR is and how it pertains to
Miner training and retraining. In this guide you will find some very useful
information on how to apply for and become an MSHA approved
instructor.
This guide also contains a very informative section on the principals
of adult learning, with one key point being “adults are not just “big children”
nor can they be treated as such in the training situation.” (U.S. DOL
MSHA, MSA, 2002 page T-53) For those who have limited and or no
experience in the training field, this can be valuable information.
In addition, this guide contains a Part 48 training matrix chart,
which is extremely valuable to even experienced trainers as it gives you a
quick and easy reference guide to ascertain who needs what types of
training, and when. Unfortunately, one of the drawbacks of this Instructors
guide is that like many MSHA materials it leaves many things out.
40
Title: MSHA Training Plan Advisor
MSHA has found that providing mine operators with online information and
resources is a great way to enhance mine operator voluntary compliance
with The Act of 1977 and Title 30 CFR
“this computerized plan is strictly optional. You may use the entire
format or selected portions. This plan format includes and
requests all required information. The required subjects for each
program are preprinted on the plan. The plan provides
selection spaces for teaching and evaluation methods, course
materials, and hours (where applicable), so that you can customize
the plan to meet your specific needs.” (U.S. DOL, MSHA 2004 a)
This particular web page gives the Part 48 plan administrator, a
systematic, plug and play training plan guide. It is a very well designed
page and allows the user to virtually design and submit a training plan for
approval online. Regrettably, like so many of MSHA’s “user friendly” tools
it is not as simple as it first appears, once again if you have a limited
understanding of MSHA and the Act of 1977 you will find that making
mistakes is easy. In order to be successful using this page the plan
administrator must be very cautious in how they fill out each of the many
sections. It is wise to allow oneself abundant freedom when entering the
41
time frames for each type of training, do not limit yourself needlessly by
limiting training times for the various subjects, remember once this plan is
approved the plan administrator must follow it or revisit this filing and
approval process to modify it.
42
CHAPTER 3: METHODOLOGY
Approach
As with any project, it is often a combination of research methods
that leads to the best understanding of the subject in question. A through
review of the manuals, guides, laws and existing training plans relating to
Part 48 training is one element of the search for understanding, another
element is to become involved in all phases of the process, from plan
design to implementation and the last element is to network and learn
from other plan administrators and trainers who have already traveled this
rocky and dimly light trail before you.
Data Gathering Method
As mentioned earlier in this paper resources and information on this
subject are rather limited and not easily found. Sources of information and
direction for this project were found by interacting with numerous plan
administrators, researching federal documents associated with the topic,
spending countless hours at the MSHA website reviewing and collecting
information on part 48 training and participating in Part 48 training.
43
Data Base of the Study
The data for this paper is a ever growing collection of Federal
Documents, such as Title 30 of the Code of Federal Regulations, Volume
III of the MSHA Program Policy Manual, Various MSHA instructor guides,
Internet files, informal interviews with plan administrators, existing Part 48
training plans, both approved and rejected by MSHA and hours of hands
on experience in writing and administering a Part 48 training plan.
Validity of Data
The collection of data for this paper is not only one of the most
comprehensive but also one of the most up-to-date collections on this
subject. All of the information used in this project has been gathered within
the last 24 months and has not been revised to the author’s knowledge
since its publication. Many of the sources for this project are Federal
Government documents and therefore are indeed valid.
Originality and Data Limitations
The author of this paper has found that not only is the collection of
documents assembled during the research for this project valid but
extremely comprehensive. The data collection covers not only the legal
aspects of a Part 48 training plan, but also documentation, plan
44
submission and approval and practical application and administration of
the plan. It appears the only limitations of the data gathered are:
Time- as time elapses and the mining industry evolves it will
undoubtedly be necessary for MSHA to revise and update
the Title 30 CFR Part 48 requirements.
Your plan- also as time rolls by, your particular mining
operation may change and become only a surface operation
or a combination of both surface and underground, therefore
requiring you, the plan administrator to modify, and update
your plan as needed.
Summary
Therefore it is strongly advised that you, the plan administrator, keep
abreast of the latest revisions to Title 30 CFR and Volume III of the
program policy manual, as non compliance with either is not a wise
choice.
45
CHAPTER 4: DATA ANALYSIS
Now that you the program administrator and designer have had a
chance to acquire, review and become familiar with the Federal Mine
Safety and Health Act of 1977, which gives miners a right to training, Title
30 of the Code of Federal Regulations-Mineral Resources, in which mine
operators will find direction as to what subjects must be covered during
training. The MSHA Program Policy Manual, MSHA form 5000-23 and the
other sources listed in chapter 2 it is time to start designing a plan of your
own.
So where to begin? A good place to start is Title 30 CFR Part 48
as this section of the federal law gives you a step by step guide of what
needs to be in your plan. We will go through Part 48 one section at a time
and discuss each section and its relevancy to designing a plan as needed.
There are some elements of a part 48 training plan that will always be the
same regardless of who is writing the plan or what type of mining
operation it is being written for, but there are also many sections of the
plan that need to be tailored to fit the needs of each individual mining
operation. It is in this chapter that the intricate details of how to write a
plan for your mining operation will be discussed. To make the process of
writing a plan easier to understand lets break writing a plan into sections:
46
Section 1: Identifying what type of plan you need.
Section 2: Parts of a plan that will always be the same regardless of
whether it is a Subpart A or Subpart B plan.
Section 3: New Miner Training
A: Items that are found in both Subpart A and B Plans.
B: Items specific to new miner training for Subpart A plan.
C: Items specific to new miner training for a Subpart B Plan.
Section 4: Experienced Miner training
A: Items that are found in both Subpart A and B Plans.
B: items that are specific to a newly hired experienced miner under
Subpart A.
C: items that are specific to a newly hired experienced miner under
Subpart B.
Section 5: Task Training
Section 7: Annual Refresher Training
Section 8: Records of Training
Section 9: Hazard Training
47
Section 1: Identify what type of plan you need.
The first step in writing a comprehensive Part 48 training plan is to identify
what type of plan you need for your mining operation. To do this lets
review Title 30 CFR part 48.1 and 48.21,
30 CFR 48.1
Scope.
The provisions of this subpart A set forth the mandatory
requirements for submitting and obtaining approval of programs for
training and retraining miners working in underground mines.
Requirements regarding compensation for training and retraining
are also included. The requirements for training and retraining
miners working at surface mines and surface areas of underground
mines are set forth in subpart B of this part.
30 CFR 48.21
Scope.
The provisions of this subpart B set forth the mandatory
requirements for submitting and obtaining approval of programs
for training and retraining miners working at surface mines and
surface areas of underground mines. Requirements regarding
compensation for training and retraining are also included. The
requirements for training and retraining miners working in
48
underground mines are set forth in subpart A of this part.
This part does not apply to training and retraining of miners at shell
dredging, sand, gravel, surface stone, surface clay, colloidal
phosphate, and surface limestone mines, which are covered under
30 CFR Part 46.
Now ask yourself what type of mine do you have? Is it a surface
only operation or does it include both underground and surface
operations? Also as a point of interest, if you happen to be developing a
training plan for any surface sand, gravel, shell dredging, clay, limestone
or phosphate operations you need to refer to 30 CFR Part 46 as those
types of surface operations are covered in Title 30 CFR Part 46 of the
Code of Federal Regulations.
Once you have determined what type of training plan your
operation needs a, Subpart A and B plan or Subpart B (surface only) plan,
lets move on to the next step.
Section 2: Parts of a plan that will always be the same regardless of
whether it is a Subpart A or Subpart B plan.
Title 30 CFR Part 48.3 and 48.23 provide you the program
administrator with a list of what is required to be submitted to MSHA in a
49
Part 48 training plan. By using these two sections as a guide we can begin
filling in the blanks of our plan. Regardless of whether you are writing a
Subpart A plan or a B plan or both there are certain elements that will be
the same for both. Title 30 CFR part 48.3 (c) (2) and 48.23(c) (2) (1)
covers one area of the plan that will be identical for both.
“The company name, mine name, and MSHA identification number
of the mine.”
As with any MSHA document you need this information filled out,
the only portion of this that may be somewhat hard is, finding out or
obtaining your mines identification number. If this is a new operation and
you do not have an MSHA ID number now would be a good time to get
one, let’s refer to Title 30 CFR Part 41.20 to see how to apply for an ID
number.
30 CFR 41.20
Legal identity report.
Each operator of a coal or other mine shall file notification of legal
identity and every change thereof with the appropriate district
manager of the Mine Safety and Health Administration by properly
completing, mailing, or otherwise delivering form 2000-7 "legal
identity report" which shall be provided by the Mine Safety and
50
Health Administration for this purpose. If additional space is
required, the operator may use a separate sheet or sheets.
After you have filled out form 2000-7 and have received you MSHA ID
number you are ready to continue with the writing of the plan. As you will
notice the next item of business would be Title 30 CFR Part 48.3 (c) (2)
and 48.23 (c) (2)
The name and position of the person designated by the operator
who is responsible for health and safety training at the mine. This
person may be the operator.
You need to identify who is going to be responsible for this training.
This person can be you or anyone appointed by the mine operator, it is not
a requirement that this person is a MSHA approved instructor. Or even be
involved with the writing of the plan. But you must list someone as a
responsible person with whom MSHA can contact if there is a question
regarding the plan.
Moving on to the next section Title 30 CFR Part 48.3 (c) (3) and
48.23 (c) (3)
51
“A list of MSHA approved instructors with whom the operator
proposes to make arrangements to teach the courses, and the
courses each instructor is qualified to teach.”
Regardless of whether you are planning on doing all of your training
in house or contracting it to an outside source, MSHA requires that when
you submit a training plan, you also must submit a list of all the MSHA
approved instructors which you plan on using to implement the training
plan. It is advisable to be very liberal in compiling this list, as one can
never have too many instructors available. The instructors on this list can
be either employed by your mine or be independent contractors. To be on
this list a person needs to be an MSHA approved instructor and MSHA
does not view all instructors as equal, so it is in your best interests to
check the credentials of those you are placing on this list to be sure they
are approved by MSHA for the subjects you are requesting them to teach.
One point of interest with this part of your plan is how to go about
getting a person approved as a MSHA instructor. Title 30 CFR Part 48.3
(h) and 48.23 (h) explains how to go about the process of applying for and
receiving MSHA approved instructor status.
“(h) Instructors shall be approved by the District Manager in one or
more of the following ways:
52
(1) Instructors shall take an instructor's training course conducted
by the District Manager or given by persons designated by the
District Manager to give such instruction; and instructors shall have
satisfactorily completed a program of instruction approved by the
Office of Educational Policy and Development, MSHA, in the
subject matter to be taught.
(2) Instructors may be designated by MSHA as approved
instructors to teach specific courses based on written evidence of
the instructors' qualifications and teaching experience.
(3) At the discretion of the District Manager, instructors may be
designated by MSHA as approved instructors to teach specific
courses based on the performance of the instructors while teaching
classes monitored by MSHA. Operators shall indicate in the training
plans submitted for approval whether they want to have instructors
approved based on monitored performance. The District Manager
shall consider such factors as the size of the mine, the number of
employees, the mine safety record and remoteness from a training
facility when determining whether instructor approval based on
monitored performance is appropriate.
(4) On the effective date of this subpart A, cooperative instructors
who have been designated by MSHA to teach MSHA approved
53
courses and who have taught such courses within the 24 months
prior to the effective date of this subpart shall be considered
approved instructors for such courses.”
As you can see there are three ways to become a MSHA instructor,
the first is by attending a MSHA approved Instructors class, these courses
are generally 24 hour courses and are given periodically at the MSHA
academy in Beckley, West Virginia and elsewhere around the nation. To
find one contact the MSHA Academy or one of the MSHA educational field
services offices. Once you have attended the class there may be a 3 to 4
week wait before receiving your instructor approval status, so plan ahead.
The second way of obtaining instructor approval is by submitting a
resume to MSHA that outlines and explains your credentials, be sure it
reflects all of your teaching experience and pertinent subject
understanding. MSHA understands that even non-miners can be
excellent instructors simply by virtue of their expertise on a given subject.
And the third way to become a MSHA approved instructor is to
teach a class which is monitored by a MSHA field representative. This
probably the hardest way to become an instructor as it takes schedule
coordination with MSHA to arrange for a representative to be available
and at your selected location to monitor your teaching abilities.
54
While we are on the subject of MSHA approved instructors you may want
to review 30 CFR Part 48.3 (h) (4) (i) and 48.23 (h) (4) (i) of how a person
can lose their MSHA approval.
“Instructors may have their approval revoked by MSHA for good
cause which may include not teaching a course at least once every
24 months. Before any revocation is effective, the District Manager
must send written reasons for revocation to the instructor and the
instructor shall be given an opportunity to demonstrate or achieve
compliance before the District Manager on the matter. A decision
by the District Manager to revoke an instructor's approval may be
appealed by the instructor to the Administrator for Coal Mine Safety
and Health or Administrator for Metal and Non-metal Safety and
Health, as appropriate, MSHA, 1100 Wilson Boulevard Room 2424
(Coal) or Room 2436 (Metal and Nonmetal), Arlington, Virginia
22209-3939. Such an appeal shall be submitted to the
Administrator within 5 days of notification of the District Manager's
decision. Upon revocation of an instructor's approval, the District
Manager shall immediately notify operators who use the instructor
for training.”
55
Not mentioned, but another way of losing MSHA approved
instructor status is to falsify records or documents including 30 CFR Part
48 training plans and MSHA 5000-23 forms.
Next on the list of things to include in your training plan is the
information requested in Title 30 CFR Part 48.3 (c) (4) and 48.23 (c) (4)
“The location where training will be given for each course.”
To allow you the trainer as much flexibility as possible in training
and to remain in compliance with the law, be sure to list both onsite and
offsite as possible training locations. Because as you will recall from Title
30 CFR part 48.5 (a)
“(a) Each new miner shall receive no less than 40 hours of training
as prescribed in this section before such miner is assigned to work
duties. Such training shall be conducted in conditions which as
closely as practicable duplicate actual underground conditions, and
approximately 8 hours of training shall be given at the mine site.
You will need to do at least 8 hours of training at the mine for
Subpart A miners and it is recommended that you do some of the training
for Subpart B miners at the mine site also. In addition to the minesite be
sure to make a note that training may also be conducted off of the mine
56
site as needed, if you do not list this option you will be required to do all of
your training on site and that may not be to you advantage.
The next section which MSHA requires to be in your plan is Title 30
CFR part 48.3 (c) (5) and 48.23 (c) (5)
“(5) A description of the teaching methods and the course materials
which are to be used in training.”
As with some of the other sections, this can be a simple, yet
deceiving part of your plan. Do not be bashful about listing a wide range
of materials and methods, the more options you create for yourself the
more flexible and user-friendly your training plan will become. List as
many training methods as you can think of, including lecture, overheads,
video, PowerPoint, hands on instruction, and any other methods you might
use. Just because you list a method you do not have to use them but, they
are available if a situation or course should come along where they would
be appropriate. Many trainers have found that it is wise to use a broad
array of training methods and materials as not all students learn in the
same way.
Next in Title 30 CFR Part 48.3 (c) (6) and Part 48.23 (c) (6) MSHA
asks for:
57
“The approximate number of miners employed at the mine and the
maximum number who will attend each session of training.”
MSHA allows you to choose how big or small your class sizes are
going to be, but it is recommended you keep your class sizes to maximum
of 30 people. Most plan administrators and writers have found that by
listing a maximum class size of 30 people they can accommodate their
mines needs and still receive a MSHA approval for their plan. Remember
this is maximum number if you wish to do training in groups smaller you
are welcome to do so.
Moving onward with the process of plan writing you need to next
address Title 30 CFR Part 48.3 (c) (7) and Part 48.23 (c) (7)
“The predicted time or periods of time when regularly scheduled
refresher training will be given. This schedule shall include the titles
of courses to be taught, the total number of instruction hours for
each course, and the predicted time and length of each session of
training.”
58
Of the many places MSHA looks for violations in the compliance of
training this is one of their favorites, as you will recall from Title 30 CFR
Part 48.8 (a) and Part 48.28 (a)
“Each miner shall receive a minimum of 8 hours of annual refresher
training as prescribed in this section.”
In other words MSHA wants to know when you are going to
conduct those 8 hours of training, are you planning on doing it once a year
during a certain time frame such as “every April” or are you planning on
doing it through out the year in 1 hour blocks, or some other variation?
Most trainers have found it is much easier to designate a certain month of
the year to do annual refresher training and conduct it in a one day 8 hour
session, if you opt for some other variation you will find that the record
keeping for it becomes a labor intensive nightmare. And if you happen to
lock yourself into rigid time frames for each of your subjects only to find
out later that you really only need a fraction of the allotted time for it or
vice a versa twice a much time you have a problem. To avoid this list a
flexible time frame for each topic such as 15 minutes to 2 hours, by doing
these two things you have allowed yourself great flexibility.
It is at this point in writing a training plan that each plan starts to
take on an identity of its own and become unique to the mining operation it
59
is intended to serve. Part of this individualization of a plan depends on
your mines makeup it is a Subpart A, B or both mine? For a
comprehensive discussion and to cover all types of plans lets assume that
your plan needs to be both, a Subpart A and B plan so that all types of
training are covered. There are specific types of training that must be
covered by every Part 48 training plan, New Miner, Experienced Miner,
Task Training, Annual refresher and Hazard training.
Section 3: New Miner Training
If you refer to Title 30 CFR Part 48.5 and 48.25 you will note that
one of the main the differences is that miners covered under part 48.5
need 40 hours of new miner training and those covered under part 48.25
only need 24 hours of new miner training. But, not only are the time
requirements different, the content of the training is also a little different.
There are seven courses that are required by both Subpart A and B plans,
Instruction in the statutory rights of miners and their representatives under
the Act; authority and responsibility of supervisors, Introduction to the work
environment, Health, Hazard Recognition, Electrical hazards, First Aid,
Health and Safety aspects of the tasks to which the new miner will be
assigned. And then there are another group of courses that will be quite
different in their content between Subpart A and B, there are seven
60
additional courses required for a Subpart A plan and six for a Subpart B
plan. The courses needed to complete the this portion of a Subpart A plan
are Self-rescue and respiratory devices, Entering and leaving the mine;
transportation; communications, Mine maps; escapeways; emergency
evacuation; barricading, Roof or ground control and ventilation, Cleanup;
rock dusting, Mine gases and Such other courses as may be required by
the district manager. For a Subpart B plan the courses are Self-rescue
and respiratory devices, Transportation controls and communication
systems, Escape and emergency evacuation plans; firewarning and
firefighting, Explosives and Such other courses as may be required by the
district manager.
In order to avoid leaving out any parts of your plan lets first review
the seven courses that are common to both types of plans and then look
at the courses that are unique to Subpart A and B.
New Miner Subpart A and B courses
These are courses that are required for both Subpart A and B and
need to be handled in the same manner and cover the same material
regardless if you are working on Subpart A or B training.
61
Title 30 CFR Part 48.5 (b) (1) and 48.25 (b) (1) require that new
miners receive
“Instruction in the statutory rights of miners and their
representatives under the Act; authority and responsibility of
supervisors.”
An easy way of complying with this requirement and not leaving
anything out is to provide each new miner with a copy of The Act and read
though it as a group, being sure to include section 2 as required. Many
trainers have found it helpful to cover Title 1, sections 104, 105, 107, 109,
110 and 115 of The Act during new miner training as these are the
sections of The Act that deal directly with issues of importance to miners
and their representatives. Also a good reference to use during this
portion of the training is the Guide to Miners Rights and Responsibilities
under the Federal Mine Safety and Health Act of 1977, which we reviewed
in chapter 2.
Title 30 CFR Part 48.5 (b) (4) and Part 48.25 (b) (4)
“Introduction to the work environment.”
is the next topic which is found in both plans, it is easy to accomplish all
you are required to do is give the new miner a tour of your mine to
acquaint them with how your mine operates.
62
Title 30 Part 48.5 (b) (7) and Part 48.25 (b) (7)
“Health.”
In this section of the training you need to inform the new miner of why and
how you test for dust and noise hazards at you mine and the importance
of that testing to them the miner. It is advised that you introduce the new
miner to Part 62 of Title 30 CFR as it the section of the federal regulations
that deals with the dust and noise compliance.
Title 30 CFR Part 48.5 (b) (9) and Part 48.25 (b) (8)
“Hazard Recognition.”
Even though a surface and underground mine will have different and
unique hazards teaching a new miner how to identify and avoid hazards is
the same no matter the environment.
Title 30 CFR Part 48.5 (b) (10) and Part 48.25 (b) (9)
“Electrical hazards.”
Both surface and underground mining operations utilize many types of
electrically powered equipment ranging from 12 volts to 7200 volts and it
is imperative that you the trainer spend adequate time acquainting all new
miners with the electrical hazards at your mine and how to work safely
around them.
Title 30 CFR Part 48.5 (b) (11) and Part 48.25 (b) (10)
“First aid.”
63
During this section of new miners training it is wise to introduce them to
the types and location of first aid supplies at your operation. MSHA not
expects all miners to know where first aid supplies are at but also how to
use them. It is recommended that you spend 12 hours on this subject with
Subpart A miners and at least 6 hours on it with Subpart B miners.
Title 30 CFR Part 48.5 (b) (13) and Part 48.25 (b) (12)
“Health and Safety aspects of the tasks to which the new miner will
be assigned”
This is the last of the subjects which are alike for both Subpart A and B.
Because this section of training is also addressed in Title 30 CFR Part
48.6 (b) (11), Part 48.26 (b) (11), Part 48.7 and 48.27 it will be covered in
detail later in this chapter in section 7: Task training.
New Miner Subpart A Specific courses
This group of courses is tailored to meet the needs of a Subpart A
New Miner underground.
Title 30 CFR Part 48.5 (b) (2)
“Self-rescue and respiratory devices.”
Underground miners must be instructed on the care and use of a Self
Contained Self Rescuer commonly known as a SCSR and other
64
respiratory protection devices that may be used at your mine. They must
become proficient at donning, using and inspecting their SCSR in order to
comply with this section of the training.
Title 30 CFR Part 48.5 (b) (3)
“Entering and Leaving the mine; transportation; communications.”
MSHA is asking for a brief description of how you plan to teach new
miners about proper check-in and check-out at your mine, what is the
appropriate way to transport people thought out the mine and what type
and how to use the various communication systems in the mine.
Title 30 CFR Part 48.5 (b) (5)
“Mine map; escapeways; emergency evacuation; barricading.”
Using maps of your mine teach your new miners how to read them and
why it is important know where they are located. Review the various
escapeways at your mine and the importance of being aware of their
locations. Lead your new miners on a mock emergency evacuation so
they understand how to evacuate in a safe manner and have you new
miners practice building a barricade.
Title 30 CFR Part 48.5 (b) (6)
“Roof or ground control and ventilation plans.”
To comply with this section of the plan it is best to give you new miners a
copy of you current roof control and ventilation plans and review it with
65
them, pointing out any and all items that are of great importance, such as
bolt spacing patterns and procedures to be used in the event of a
ventilation system failure.
Title 30 CFR Part 48.5 (b) (8)
“Cleanup; rock dusting.”
Every underground mine must have in addition to roof control and
ventilation plans a cleanup and rock dusting plan. During this section of
new miners training MSHA asks that you share with and explain the
various components of your mines cleanup and rock dusting plans.
Title 30 CFR Part 48.5 (b) (12)
“Mine gasses.”
Making new miners aware of mine gasses and their hazardous properties
is vital to their safety as they go about their daily work duties within the
mine. It is recommended that each new miner be introduced to a mine
gas chart which lists all of the mine gases that may be found in
underground mines. Also it is wise to review the properties of these gases
and their health effects on the miners.
Title 30 CFR Part 48.5 (b) (14)
“Such other courses as may be required by the District Manager
based on circumstances and conditions at the mine.”
66
Each district manager has the option based on a mines record or type to
add to the list of courses required under Subpart A as they deem fit.
Some district managers make these course requirements a blanket policy
for all mines in their district and others require these courses of only
certain types of operations or even individual mines. In order to comply
with this you must contact the District Manager for the district in which the
mine is located and inquire as to whether or not there are any additional
courses required.
New Miner Subpart B specific courses
This group six courses are required in addition to the courses that are
common to both Subpart A and B plans, in order to meet the needs of a
New Surface Miner.
Title 30 CFR Part 48.25 (b) (2)
“Self-rescue and respiratory devices.”
Even thought this course is similar to what is required for a Subpart A
miner you will notice that you do not need to cover SCSR’s in this section
of training for a new surface miner.
Title 30 CFR Part 48.25 (b) (3)
“Transportation controls and communication systems.”
67
As with any mining operation it wise to inform anyone new to the operation
about how to communicate with others. A review of the communication
systems that are in place at the mining operation and how to use them will
fulfill this portion of the training.
Title 30 CFR Part 48.25 (b) (5)
“Escape and emergency evacuation plans; firewarning and
firefighting.”
This section of training for a surface miner requires you to review you
mines escape and evacuation plans from facilities and work areas and
how to go about fighting a fire if one should occur.
Title 30 CFR Part 48.25 (b) (11)
“Explosives.”
Most surface mines use explosives in their daily operations it is required
that you cover the safe identification of explosives and what a new miner
should do if they encounter explosives or even more importantly misfired
explosives in the work place.
Title 30 CFR Part 48.25 (b) (13)
“Such other courses as may be required by the District Manager
based on circumstances and conditions at the mine.”
68
Each district manager has the option based on a mines record or type to
add to the list of courses required under Subpart A as they deem fit.
Some district managers make these course requirements a blanket policy
for all mines in their district and others require these courses of only
certain types of operations or even individual mines. In order to comply
with this you must contact the District Manager for the district in which the
mine is located and inquire as to whether or not there are any additional
courses required.
Section 4: Experienced Miner Training
The training of an experienced miner is similar to that of a new
miner with a few subtle differences. Since these miners have at least 12
months of previous mining experience and have already been through
New Miner training, this training is geared more towards acquainting and
reminding miners, who are returning to a mine or newly employed at your
mine about specific items in relation to health and safety training.
One of the main differences is the amount of time required for this
training. If you review Title 30 CFR part 48.6 (b) you will notice that there
is not a specified amount of time for a miner who has been an active miner
69
within the last five years but, if they have been out of the industry for more
than five years this training must take at least 8 hours.
Another difference is the topics that must be covered some are the
same as they would be for a new miner some are similar and some are
entirely different. There are nine topics that are required to be covered for
both Subpart A and B experienced miner training plans, Introduction to the
work environment, Mandatory Health and Safety Standards, Authority and
responsibility of supervisors and miner’s representatives, Hazard
recognition, Prevention of accidents, Emergency medical procedures,
Health, Health and safety aspects of the tasks to which the experienced
miner is assigned and such other courses as required by the district
manager. Then there are four topics which are specific to Subpart A and
another three which are specific to Subpart B. The topics for Subpart A
are Entering and leaving the mine; transportation; communications, Mine
map; escapeways; emergency evacuation; barricading, Roof or ground
control and ventilation plans. For Subpart B the topics are Transportation
controls and communication systems, Escape and emergency evacuation
plans; firewarning and firefighting, Ground controls; working in areas of
highwalls, water hazards, pits, and spoil banks; illumination and night
work.
70
As with the new miner training let us first review the topics that are
common to both Subpart A and B Experienced Miner training and then
take a look at the topics that are unique to Subpart A and then the ones
for Subpart B.
Experienced Miner Subpart A and B courses
Of the nine courses that are the same for both Subpart A and B
There are five that can be addressed the same as you would for a new
miner, those courses are Introduction to the work environment, Hazard
recognition and Health and Health and safety aspects of the task to which
the experienced miner is assigned and such other courses as may be
required by the district manager, the remaining four require discussion for
our purposes.
The first being Title 30 CFR Part 48.6 (b) (2) and Title 30 CFR Part 48.26
(b) (2)
“Mandatory health and Safety Standards.”
This section of an experience miners training is to acquaint the miner with
the rules and regulations that are pertinent to the type of mining and tasks
with which they will be involved.
The second is Title 30 CFR Part 48.6 (b) (3) and Title 30 CFR Part
48.26 (b) (3)
71
“Authority and responsibility of supervisors and miner’s
representatives.”
The goal of this portion of the training is to share with miners new to your
operation the roles and responsibilities of your supervisors and to inform
them as to who the miners representatives are and how to contact them if
you should need their assistance.
The third is Title 30 CFR Part 48.6 (b) (8) and Title 30 CFR Part
48.26 (b) (8)
“Prevention of accidents.”
This topic is a new one, it is not required in new miner training, the
purpose of this section is to inform those new to your operation about the
types of accidents your mine has had in the past and what has been done
to prevent their recurrence.
The fourth is Title 30 CFR Part 48.6 (b) (9) and Title 30 CFR Part 48.26
(b) (9)
“Emergency medical procedures.”
Unlike new miner training which requires first aid this section of an
experience miners training is geared toward informing them about the
location of first aid supplies through out your mining operation and the
system in place to summon medical help if it should be needed.
72
Experienced Miner Subpart A specific courses
All four courses that are specific to a Subpart A experienced
miners training, Entering and leaving the mine; transportation;
communications, Mine map; escapeways; emergency evacuation;
barricading, Roof or ground control and ventilation plans, Self-rescue and
respiratory devices, are courses that can be address the same as you
would for a new miner. Just remember that the need to discuss these
topics in great detail is not needed as the experience miner already
understands the basic concepts and does not need the in depth training
that would be needed by a new miner on these subjects.
Experienced Miner Subpart B specific courses
For the Subpart B miner there are three courses that are the same
as they would be for a new miner, Transportation controls and
communication systems; Escape and emergency evacuation plans;
firewarning and firefighting, Ground controls, working in areas of
highwalls, water hazards, pits, and spoil banks; illumination and night
work. Once again these courses can be approached as you would for the
73
new miner but only a brief overview of the material is need rather than a
lengthy discussion.
Section 5: Task Training
MSHA views this portion of a miners training as extremely
important, as you have noticed it is addressed in both new miner Title 30
CFR Part 48.5 (b) (13) and 48.25 (b) (12), experienced miner Title 30 Part
48.6 (b) (11) and 48.26 (b) (11) and here again in its own section of your
training plan Title 30 CFR part 48.7 and 48.27
“Training of miners assigned to a task in which they have had no
previous experience; minimum courses of instruction.”
Regardless of who is receiving this training there are four components that
must be accomplished, the Health and safety aspects and safe operating
procedures for work tasks, equipment, and machinery, Supervised
practice during nonproduction, Supervised operation during production,
New or modified machines and equipment.
Most training plan administrators have found it useful to develop a
task training matrix chart to address this section of their training plan.
74
Section 7: Annual Refresher Training
In order to reduce the redundancy in this paper Title 30 Part 48.8
and 48.28
“Annual refresher training of miners; minimum courses of
instruction; hours of instruction.”
can be addressed without reviewing each separate subject. As with new
miner and experienced miner training there are some differences in the
training required under Subpart A and B, for annual refresher training you
the plan administrator must spend at least a total of 8 hours reviewing the
subjects that are relevant to your operation for each respective subpart
with all miners covered by that training plan.
Section 8: Records of training
In chapter two we reviewed MSHA 5000-23 forms their importance
and how easy it is to make an error when filling them out. But remember
this is not an option this is a federal regulation which MSHA does enforce
with little leniency. This is how you must document what training each
miner has received. Please take note of how long you must keep
completed 5000-23 forms on file for each miner Title 30 CFR Part 48.9 9
(c) and 48.29 (c)
75
“Copies of training certificates for currently employed miners shall
be kept at the minesite for 2 years, or for 60 days after termination
of employment.”
Section 9: Hazard Training
Since mining is a very divers industry and each mining operation
presents unique dangers to those who not only work there but also those
who are visitors as part of your training program you also need to address
Title 30 CFR part 48.11 and 48.31
“Hazard Training.”
Compliance with this section of the law can be accomplished by simply
informing everyone who comes to your operation of the items that are
listed in Title 30 CFR part 48.11 (1) (2) (3) (4) (5) and 48.31(1) (2) (3) (4)
(5)
“(1) Hazard recognition and avoidance;
(2) Emergency and evacuation procedures;
76
(3) Health and safety standards, safety rules, and safe working
procedures;
(4) Use of self-rescue and respiratory devices, with self-contained
self-rescue device training that includes complete donning
procedures in which each person assumes a donning position,
opens the device, activates the device, inserts the mouthpiece or
simulates this task while explaining proper insertion of the
mouthpiece, and puts on the nose clip; and (5) Such other
instruction as may be required by the District Manager based on
circumstances and conditions at the mine.”
There are several key points to remember with this training, with the first
being Title 30 CFR Part 48.11 (b) and 48.31 (b)
“Miners shall receive the instruction required by this section at least
once every 12 months.”
The second Title 30 CFR Part 48.11 (d) and 48.31 (d)
“In accordance with §48.9 (Records of training) of this subpart A,
the operator shall maintain and make available for inspection
77
certificates that miners have received the hazard training required
by this section.”
And the Third being Title 30 CFR Part 48.11 (e)
“Miners subject to hazard training shall be accompanied at all times
while underground by an experienced miner, as defined in §48.2(b)
(Definition of miner) of this subpart A.
Many mine operators have found that the use of a short video
program or a PowerPoint presentation helps make Hazard training easier
to accomplish and provides continuity so that all who receive the training
get the same information.
78
CHAPTER 5: SUMMARY, CONCLUSIONS AND RECOMMENDATIONS
Summary
In summary this paper has met the goal as stated in Chapter 1: to
provide anyone not familiar with Mine Safety and Health Act and Title 30
CFR Part 48 training a systematic guide of how to design, submit for
approval, and ultimately implement a Title CFR 30 Part 48 training plan
has been met. A through review of the federal laws and regulations that
mandate Title 30 CFR Part 48 was accomplished. A step by step walk
through of how to write a plan was done, with each section addressed as
needed. A review of the accompanying MSHA 5000-23 form which
documents that the training was accomplished has been covered.
Conclusions
It would be impossible to write a document that could cover all
variations and questions that a Title 30 CFR Part 48 plan administrator
might encounter, but the basic building blocks for creating and
implementing a plan have been well address in this paper. To the authors
knowledge there is no one document available that addresses Title 30
CFR Part 48 training as comprehensively as this paper does.
79
Recommendations
As noted early on in this paper Title 30 CFR Part 48 training is an
ever evolving process, one that will continually present you the plan
administrator with countless questions. It is strongly urged by the author
of this paper that anyone who finds themselves involved with Part 48
training plans to welcome any and every opportunity to expand their
knowledge of the subject.
There are several ways in which to do this, one is to consider
MSHA your ally instead of your adversary when it comes to training. You
may find it wise to frequently check with the MSHA in particular the
educational field services division, to stay abreast of changes being
proposed for MSHA training. A second way is to become involved in any
industry trade groups which may have valuable training ideas or plans in
place. And, a third is to develop a network of associates within the mining
industry which have been or are now going down the same bumpy road
you are on.
References
Baugh, H. (2004, May) Train the Trainer, International Society of
Mine Safety Professionals. Salt Lake City, UT
Office of the Federal Register, National Archives and Records
Administration (2002, Revised July 1). Title 30 Code of Federal
Regulations Mineral Resources
Office of the Solicitor, Division of Mine Safety and Health, Department of
Interior. (1977). Federal Mine Safety and Health Act of 1977
U.S. Department of Labor, Mine Safety and Health Administration.
(Published 1996). MSHA Program Policy Manual Volume III
U.S. Department of Labor, Mine Safety and Health Administration.
(1998, December). Compliance Guide of MSHA’s Modified
Regulations on Training and Retraining of Miners
U.S. Department of Labor, Mine Safety and Health Administration.
(2002, April). MSHA Form 5000-23
(a)U.S. Department of Labor, Mine Safety and Health Administration.
MSHA Training Plan Advisor. Retrieved April 20, 2004. from
http://www.dol.gov/elaws/msha/training/miner_rights.asp
(b)U.S. Department of Labor, Mine Safety and Health Administration.
Instructions for Completing a Mine Safety and Health
Administration Certificate of Training Form (5000-23)
Retrieved April 20,2004 . from
http://www.msha.gov/forms/523INSTR.htm
(c)U.S. Department of Labor, Mine Safety and Health Administration.
Training Plan Requirements Independent Contractors, Grantees
and Other Training Providers, Surface Coal Mines and Surface
Areas of Underground Coal Mines. Retrieved April 20, 2004. from
www.dol.gov/elaws/msha/training/startplan.asp
(d)U.S. Department of Labor, Mine Safety and Health Administration.
History of Mine Safety and Health U.S.
Retrieved June 25, 2004. from
Legislation from http://www.msha.gov/mshainfo/mshainf2.htm
(e)U.S. Department of Labor, Mine Safety and Health Administration.
Coal Fatalities for 1900 to 200.3
Retrieved June 25, 2004. from
http://www.msha.gov/stats/centurystats/coalstats.htm
(f)U.S. Department of Labor, Mine Safety and Health Administration.
Metal/Nonmetal Fatalities for 1900 through 2003
Retrieved August 11, 2004 from
http://www.msha.gov/stats/centurystats/mnmstats.htm
U.S. Department of Labor, Mine Safety and Health Administration.
National Mine Health and Safety Academy. (Revised 2000) .
A Guide to Miners Rights and Responsibilities Under the Federal
Mine Safety and Health Act of 1977
US Department of Labor, Mine Safety and Heath Administration, National
Mine Safety Academy. (Revised 2002) . Instructor Training
Workshop -Part 48 Instructional Guide Series #IG 24a
