Comprehensive guidelines on MSHA policies for roller baskets, guarding by location, and safety standards for roadways and walkways.
MSHA’s Policy on Roller Baskets and “Guarded by Location”
The Mine Safety and Health Administration (MSHA) is tasked with ensuring the safety and health of miners across the United States. As part of its regulations, MSHA addresses the use of roller baskets and their compliance with guarding requirements. This article explores MSHA’s stance on roller baskets when the concept of being “guarded by location” is applied, providing clarity on how to ensure compliance and maintain a safe work environment.
What Are Roller Baskets?
Roller baskets are mechanical components used in conveyor systems to support and guide belts during operation. These components often involve moving parts, which present potential hazards, including pinch points and entanglement risks. Given these hazards, MSHA mandates that such equipment be guarded to protect workers from injury.
The Concept of “Guarded by Location”
“Guarded by location” is a term used in safety regulations to describe a situation where the placement of equipment inherently reduces or eliminates access to hazardous areas. According to MSHA, equipment can be considered “guarded by location” if its position naturally prevents miners from coming into contact with dangerous components, such as being placed at significant heights or behind barriers.
MSHA’s Policy on Roller Baskets and Guarding
While MSHA permits the use of “guarded by location” as a means of compliance in some cases, it applies strict criteria to determine whether this approach is acceptable for roller baskets. Key considerations include:
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Accessibility: If the roller basket is located in an area where workers cannot reasonably access it during normal operations, MSHA may deem it adequately “guarded by location.” However, if access is possible during maintenance, inspection, or any other task, additional guarding measures are required.
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Height and Barriers: Roller baskets situated at elevated positions or behind physical barriers may qualify as “guarded by location.” The height or barrier must effectively prevent unintended contact.
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Risk Assessment: MSHA expects mine operators to conduct a thorough risk assessment to determine whether the “guarded by location” designation is appropriate. Factors such as the likelihood of worker exposure and the severity of potential injuries are taken into account.
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Roadways and Walkways: MSHA has specific standards regarding roadways and walkways that intersect with or are near equipment like roller baskets. If a roller basket is located near a roadway or walkway, it must be evaluated to ensure that its placement does not pose a hazard to workers or equipment operators. Guarding by location in such scenarios often requires additional barriers or signage to prevent inadvertent access.
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Catch Baskets Above Roadways and Walkways: MSHA also requires the installation of catch baskets or similar devices above roadways and walkways to prevent debris, tools, or materials from falling and striking workers or vehicles. This is especially important in areas where conveyor systems or roller baskets are positioned overhead. The catch baskets must be robust and properly maintained to ensure they effectively mitigate falling object hazards.
Best Practices for Compliance
To ensure compliance with MSHA’s policies on roller baskets and guarding, mine operators should:
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Evaluate All Roller Baskets: Conduct a detailed assessment of the location and accessibility of all roller baskets in your operation.
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Implement Additional Guarding: If there is any possibility of worker exposure, install physical guards, such as enclosures or railings, to eliminate hazards.
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Document Risk Assessments: Maintain clear records of risk assessments and any measures implemented to address hazards. This documentation can be invaluable during MSHA inspections.
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Train Workers: Ensure all employees are trained to recognize the hazards associated with roller baskets and understand the importance of guarding systems.
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Regular Inspections: Periodically inspect guarding systems and roller basket placements to ensure continued compliance and safety.
Conclusion
MSHA’s policy on roller baskets and the concept of “guarded by location” underscores the importance of proactive safety measures in mining operations. While “guarded by location” can be an acceptable means of compliance in specific situations, it requires careful evaluation and documentation to meet MSHA’s standards. By prioritizing worker safety and adhering to these guidelines, mine operators can foster a safer working environment and remain in compliance with federal regulations.