# Presentation: 684550

## NMA/MSHA Approval Workshop

***MSHA Approvals**** *
- Approval and Certification Center
- May 21 and 22, 2008

**Notes:**
Introduce the general approval presentation
I will be happy to address questions during the presentation but if I think the question will be answered in later presentations, I may deflect it.
We would prefer not to address specific application-type questions in this workshop.  We would be happy to address your specific situations after the meeting or at a later time.
Deal with logistics, if necessary

## Why is MSHA Approval Required?

- Federal Mine Safety & Health Act of 1977,Public Law 91-173
- 30 CFR 75.500 requires the use of “permissible” equipment in gassy areas of underground coal mines
- 30 CFR 57.22302 requires MSHA approved equipment for use in hazardous areas of underground gassy metal and nonmetal mines

## What Does “MSHA Approved” Mean?

- Official notification by MSHA that product under consideration meets the applicable 30 CFR requirements
- No likely explosion hazard under normal operation when used in methane-air atmosphere or coal dust
- Typically does not include performance requirements with several exceptions (e.g., methane detectors and cap lamps)

## What Mining Products does MSHA Approve?

- Part 7 – Testing by Applicant or Third Party
- Subpart B – Brattice Cloth and Ventilation Tubing
- Subpart C – Battery Assemblies
- Subpart D – Multiple Shot Blasting Units
- Subpart E – Diesel Engines
- Subpart F – Diesel Power Packages
- Subpart J – Electric Motor Assemblies
- Subpart K – Electric Cables, Signaling Cables and Cable Splice Kits

## What Mining Products does MSHA Approve?

- Part 18 – Electric Motor-Driven Mine Equipment
- Explosion-Proof Enclosures (XPs)
- Intrinsically Safe Circuits, Instruments and Apparatus
- Longwall Mining Systems, Continuous Miners, Shuttle Cars, Roof Bolters, Scoops, etc.
- Conveyor Belt, Conduit Hose, Packing Gland Material, etc.

## What Mining Products does MSHA Approve?

- Part 19 – Electric Cap Lamps
- Part 20 – Electric Mine Lamps other than 			Standard Cap Lamps
- Part 22 – Portable Methane Detectors
- Part 23 – Telephones and Signaling Devices
- Part 27 – Methane Monitoring Systems

## What Mining Products does MSHA Approve?

- Part 33 – Dust Collectors
- Part 35 – Fire Resistant Hydraulic Fluids
- Part 36 – Mobile Diesel-Powered 				Transportation Equipment

## What Other Acceptance Programs Does MSHA Offer?

- Ground Wire Monitors
- STEs (lighting systems)
- Mine Wide Monitoring Systems
- Voluntary Program titled “*Solid Products Taken Into Mines*” (formerly Interim Criteria)
- Products are evaluated for flame resistance

## What is the Difference Between an Approval / Certification / Acceptance?

*Approval* – A formal document issued by MSHA which states that a completely assembled product has met the applicable requirements and which authorizes the attachment of an approval plate.
- Part 7 products are also referred to as “approved”
*Certification* – A formal written notification issued by MSHA which states that a component complies with the applicable requirements and is suitable for incorporation on approved equipment. (e.g., XPs and MMs)
*Acceptance* – Written notification by MSHA that a product has met the applicable requirements and will be listed by MSHA as acceptable.

## What’s Up With the MSHA Approval Numbering System?

- 18-ISA080001-0
- 18 – represents the applicable 30 CFR Part
- IS – represents special approval number designations
- IS for intrinsic safety
- XP for explosion proof enclosure
- Nothing for approved machinery
- A – represents 30 CFR standards
- B would refer to non-MSHA product safety standard such as the IEC
- 08 – Two digit calendar year in which approval is issued
- 0001 – four digit sequential approval number issuance
- 0 – extension number

## Where Can I Find Information on the MSHA Approval Process?

- _[www.msha.gov](http://www.msha.gov/)_
- A&CC Homepage (_[http://www.msha.gov/TECHSUPP/ACC/ACCHOME.HTM](http://www.msha.gov/TECHSUPP/ACC/ACCHOME.HTM)_) includes:
- Application Procedures
- Application Status Feature
- Evaluation Criteria (e.g. Intrinsic Safety Evaluation Criteria)
- Test Procedures
- Lists of Approved Products

## How Can I Monitor My Application Status Online

- _[www.msha.gov](http://www.msha.gov/)__   Product Approval / Application Status Search_
- Manufacturer ID from _[ipso@dol.gov](mailto:ipso@dol.gov)_
- Application Lifecycle from Estimate to Invoice Payment
- Link to A&CC Telephone Directory to speak to Investigator

## How Can I Monitor My Application Status Online

**Online application status site provides:**
- PAR #
- Date Rec.
- Company ID
- Employee Name
- Status Code
- 2 – Awaiting Initial Action
- 3- Investigation in Progress
- 4C – Awaiting company response
- Status Date

## Where Can I Get Help Preparing My Application?

- A&CC webpage compliance guide search feature for ESD products
- Application procedure forms and checklists
- Free A&CC approval application consultation services
- Hoping to introduce online application option

**Notes:**
Close attention to documentation requirements will help expedite process (e.g., Subterracom submission)

## How can I submit my application electronically?

- Email
- Send as attachments (max size 20 megabytes)
- Can send multiple emails for same application
- _[ipso@dol.gov](mailto:ipso@dol.gov)_
- FTP Submittal
- Posted at mfgr.msha.gov
- No file size limit or number of files limit
- Files can be organized and viewed by applicant
- Contact _[ipso@dol.gov](mailto:ipso@dol.gov)_ for more information on setting up a FTP account
- Can still use email to send drawing corrections directly to the investigator

**Notes:**
Some alternatives to using the U.S. mail to send us drawings or applications:

One can submit applications and accompanying drawings electronically, by sending email directly to our Information Processing Services Office (IPSO).  IPSO will reply acknowledgement with the issuance of a par (tracking) number.  There is a 20 mb limit on email attachments that we can receive.  Email server will not accept .zip files. Popular electronic formats are acceptable, such as .doc, .xls, .pdf, .dwg., .tif.

Another option is the use of the MSHA FTP to transfer files via the internet.   IPSO still need alerted by applicant email that new application or replacement drawings are available.  This puts the files in a staging area, not direct link to investigator.   There are no file size or # of files limit.

Some applicants may choose to mail a CD of their drawings. I have had applicants mail a CD with all the documents, during the evaluation process, after some of the drawings have been revised.  That way I know I have all the latest that the manufacturer is working with.  Especially helpful when there are a lot of drawings involved.

## How Does the MSHA Approval Process Work?

- In general the process is as follows:
- Fee estimation process
- Preliminary Review
- Pre-authorizations
- Blanket Authorizations
- Documentation Review / Compliance Verification
- Discrepancy Letters
- Testing / Inspection
- Finalization / Approval Letter
- conditions of use

**Notes:**
Some programs use variations of this process due to unique program needs.

## How Do I Modify a Previously MSHA Approved / Certified / Accepted Product?

- Revised Approval Modification Program (RAMP)
- Replaced the popular SNAP and SRA programs
- Permits multiple changes to previously issued approvals
- Testing can be performed under a RAMP
- Submit description of changes and revised drawings
- Extensions of Approval
- Need is determined by applicant or in consultation with A&CC investigator
- Extension process is described in 30 CFR
- Generally extensions include more extensive changes than RAMPs

**Notes:**
The RAMP is a faster turnaround program

## What is MSHA’s Quality Assurance Program?

- Approval-holder responsible for producing products in accordance with approved drawings and specifications
- MSHA Post-approval product audit program
- Applicant submits factory inspection form / certified statement with approval request.
- After receiving equipment/products, owner is responsible for maintaining in accordance with MSHA approval

## How Does MSHA Secure MSHA Approval Documents?

- MIMs Drawing System
- 30 CFR Confidentiality Obligation
- Trade Secrets Act
- MSHA maintains confidentiality of all approved documentation
- Documents are for exclusive use of MSHA personnel

**Notes:**
Emphasize the importance of confidentiality

## What is MSHA’s Cancellation Policy?

- 6 month response time
- Must address all items in discrepancy letter
- If additional discrepancies are noted, additional letters will be sent
- A&CC is considering reducing time frame (e.g., 3 months)
- 3 month reminder
- 1 week warning
- No extensions of time

## What Types of Applications Does MSHA Assign High Priority?

- Any application that MSHA enforcement identifies as necessary to address an imminent safety or health concern
- Longwalls and related approval applications
- Communications and Tracking

## Why Doesn’t MSHA Accept IEC Standards?

- Proposed Part 6 in 1994
- Revised Part 6 promulgated in 2003
- Federal Mine Safety & Health Act of 1977 requires that all new standards promulgated must provide at least the same degree of protection as existing standards

## IEC Acceptance Complications

- IEC standards are for components only
- IEC standards do not provide for system evaluations like:
- Longwalls, machines, communication systems, tracking systems, shield control systems, etc.
- Most countries that utilize IEC standards have additional requirements:
- System Safety Analyses that must be performed by mine operators

## What Approval Alternatives does Part 6 Permit?

- Independent Laboratories can perform test and evaluation to MSHA Requirements
- Lab must be recognized by a reputable accrediting organization (e.g., OSHA NRTL or IECEx)
- Complete evaluation report with test data
- MSHA can approve equipment designed to third party standards (e.g. IEC) if MSHA determines such standards are equivalent
- Only IEC 60079-1 (Flameproof Enclosures) so far
- IEC 60079-11 (IS) is under consideration

## What Does Part 7 Offer?

- Testing by Applicant or Third Party
- Mature product lines for which testing results are considered non-subjective
- MSHA reserves the right to witness product testing
- Very successful program – other certifying bodies are only now beginning to consider similar programs

## What Can Applicants do to Expedite the MSHA Approval Process?

- Ensure all required documentation is included with original application
- Provide timely response to investigator requests for corrections or test samples

## Questions?

*Contact Info:*
*David Chirdon*
*Phone: (304) 547-2026*
*Email:**	*_*[chirdon.david@dol.gov](mailto:chirdon.david@dol.gov)*__* *_