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Coal Mining Industry Perspective on Respirable Dust February 8, 2017 Claims of Increasing Prevalence of CWP Led to New Dust Sampling Regulations Percentage of Examined Miners with CWP (category 1/0+) by Tenure in Mining, (1970-2006) 35 30


  1. Coal Mining Industry Perspective on Respirable Dust February 8, 2017

  2. Claims of Increasing Prevalence of CWP Led to New Dust Sampling Regulations Percentage of Examined Miners with CWP (category 1/0+) by Tenure in Mining, (1970-2006) 35 30 tenure (yrs) 25 0-9 20 10-14 15 15-19 10 20-24 25+ 5 0 § Chart presented in NIOSH Work-Related Lung Disease (WoRLD) Surveillance Report, 2007 § Presents increasing trend in CWP prevalence since 1995 § 2005-2006 reported as a partial period § “Based on recent data from the National Institute for Occupational Safety and Health (NIOSH), the prevalence rate of black lung is increasing.” - Preamble explanation accompanying the Proposed Rule

  3. 2016 CPDM Dust Sample Review 86,491 CPDM Dust Samples sent to MSHA between 4/ 1/ 2016 and 12/ 31/ 2016

  4. 2016 CPDM Dust Sample Review Sample Type Sample Type Number of Samples Invalid Sample Type 22 Designated Occupation 30,267 Non Designated Occupation 54,807 Designated Area 539 Designated Work Position 36 Part 90 Miner 815 NonDesignated Work Position 5 Total 86,491

  5. 2016 CPDM Dust Sample Review Valid/Void Void, 20924, 24% Valid, 65567, 76%

  6. 2016 CPDM Dust Sample Review Void Type Other , 2638, 13% Invalid or Missing Time, 1920, Invalid 9% Production, 9367, 45% Excess Sample, 2547, 12% Effective Functioning Impaired, 4452, 21%

  7. 2016 CPDM Dust Sample Review Valid Samples that Exceed ECV .19% or 121 of 65,567 valid Samples exceeded the ECV

  8. 2016 CPDM Dust Sample Review Q3 vs Q4 Results 2016 Q3 Q4 Number of Average Number of Average Sample Type Samples Concentration Samples Concentration Designated Occupation 7,457 0.683 7,728 0.670 Non Designated 14,827 Occupation 14,566 0.567 0.634 Other 404 0.259 522 0.334 2016 Q3 Q4 Number of Average Number of Average District Samples Concentration Samples Concentration C02 1,933 0.586 2,093 0.653 C03 1,976 0.624 2,053 0.650 C04 2,886 0.599 3,101 0.607 C05 2,653 0.492 2,739 0.553 C07 1,376 0.604 1,701 0.563 C08 4,254 0.673 4,279 0.706 C09 1,174 0.550 1,118 0.597 C10 3,271 0.712 3,213 0.789 C11 797 0.290 564 0.479 C12 2,107 0.552 2,216 0.543

  9. 2016 CPDM Dust Sample Review CM vs LW Results 2016 Q3 Q4 Number of Average Number of Average Designated Occupation Samples Concentration Samples Concentration 7,051 Continuous Miner 6,745 0.664 0.651 Longwall 626 0.866 581 0.903 CM - 036 / LW - 041, 044

  10. 2016 CPDM Dust Sample Review Observations The CPDM has proven to be an effective device • MSHA should eliminate gravimetric sampling for underground • occupations other than as necessary for determination of quartz concentrations The CPDM should be improved to allow for the measurement of quartz • Other manufacturers should be incentivized to develop a PDM • Reduction in physical size and weight should be pursued •

  11. 2016 CPDM Dust Sample Review Observations The rule requires an excessive amount of samples to be collected and future • reductions in exposure have been halted The dust rule, and MSHA enforcement, provide no incentive for innovative engineering • controls The application of engineering controls should be allowed to substitute for unnecessary • sampling The entire section should be allowed to be sampled at one time, giving a complete • understanding of the relationship between occupations Inflexible minimum production requirements result in excessive sampling of longwall • development units due to normal variability of the mining process Sampling should be allowed on consecutive days instead of consecutive shifts to reduce the • burden on mine administration The frequency of sampling should be adjusted for risk • Unnecessary sampling not only burdens mine administration, it should be avoided due to • ergonomic concerns for miners Sample results must be viewed in total when assessing worker exposure to respirable dust • and effectiveness of engineering controls

  12. Updated Trend in CWP Prevalence Percentage of Examined Miners with CWP (category 1/0+) by Tenure in Mining, (1970-2014) 35 30 tenure (yrs) 25 0-9 20 10-14 15 15-19 10 20-24 25+ 5 0 § Chart created using NIOSH Coal Workers’ Health Surveillance Program (CWHSP) Data Query System, Feb 2017 § Results from 1995 – 1999 period appears to be an outlier § Prevalence of CWP hasn’t changed much since 1980 despite significant reductions to respirable dust levels in mines

  13. Participation in the CWHSP Should Be Mandatory § Mandatory screenings can improve the quality of the CWHSP data set and provide researchers the information required to implement appropriate corrective actions in the correct locations in a timely manner § Mandatory screenings provide the safety net necessary to completely eliminate Black Lung

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