# Presentation: 334301

## MSHA – APPROVAL & CERTIFICATION CENTER

**MINE EQUIPMENT COMPLIANCE SPECIALIST**
**QUALITY ASSURANCE & MATERIALS TESTING DIVISION**

**MSHA – APPROVAL & CERTIFICATION CENTER**

**30CFR, PART 6 POST-APPROVAL PRODUCT AUDIT PROGRAM & DEFECT NOTIFICATION TO MSHA**

## MAJOR POINTS

**  ****QA&MTD**

**  ****CODE OF FEDERAL REGULATIONS (30CFR, PART 6****)**

**POST-APPROVAL PRODUCT AUDIT PROCESS**

**  ****DEFECT NOTIFICATION TO MSHA**

## QUALITY ASSURANCE & MATERIALS TESTING DIVISION

**(QA&MTD)**

**  ****KEN SPROUL – DIVISION CHIEF**
**  ****JIM ERLINGER – TEAM LEADER**

**  ****MINING EQUIPMENT COMPLIANCE SPECIALISTS**
**  ****ENGINEERS**
**  ****PHYSICAL SCIENTISTS**
**  ****TECHNICIAN**
**  ****CHEMIST**

**Notes:**
5 mining equipment compliance specialists

5 interdisiplinary engineers

1 physical scientist

1 engineering technician

1 chemist

## 	The Quality Assurance and Materials Testing Division

**(QA&MTD)**

**Maintain Integrity of MSHA Approval**
**	****The Quality Assurance and Materials Testing Division**
**	****conducts audits to verify the manufacturer is producing products as approved.**

**QA&MTD MISSION**

**Notes:**
QA&MTD works with mines, equipment manufacturers, districts, and other divisions to resolve any equipment or material problems that are found.

## 	The Quality Assurance and Materials Testing Division 

**(QA&MTD)**

**Approval of Mining Materials****  **
**	****The Quality Assurance and Materials Testing Division **
**	****ensures that mining materials conform to the applicable requirements of 30 CFR.**

**QA&MTD MISSION**

**Notes:**
QA&MTD works with mines, equipment manufacturers, districts, and other divisions to resolve any equipment or material problems that are found.

## QUALITY ASSURANCE & MATERIALS TESTING DIVISION

**(QA&MTD)**

**Auditing**

**V/CAP**
**Voluntary Compliance Assistance Partnership**

**Field Complaints**

**Approval Programs**

**Technical Assistance**

**Accident Investigation**

**PROGRAMS**

**Notes:**
Auditing:  verify if in accordance with the approval documentation

Approval programs:  evaluate material to determine compliance with 30CFR

v/cap:  work with rebuilders/repair shops to make sure repaired equipment meets approval documentation  -  train rebuild/repair shop personnel, audit when finished, eventually rebuilder makes audit form and msha checks for accuracy

Technical assistance:  provide district, other msha personnel with technical support as needed

Field complaints:  deal with product nonconformance and product safety issues

Accident investigation:  assist accident investigation team  with evaluation of equipment and/or material involved in an accident 

## QUALITY ASSURANCE & MATERIALS TESTING DIVISION

**(QA&MTD)**

**FIELD COMPLAINT TYPES**

**NON-CONFORMING PRODUCT**
**IMPROPER USE OF PRODUCT**
**PRODUCT PERFORMANCE ISSUES**

**FIELD COMPLAINT -  SERVES AS A METHOD TO INVESTIGATE **
**                            ****	****	****PROBLEMS ASSOCIATED WITH A SPECIFIC**
**	****	****PRODUCT  **

**Notes:**
Nonconforming product:  notified by inspectors, mine operators, equipment manufacturers

Improper use: e.g. not using methane monitor correctly

Product performance issues:  e.g. sticking valve, incorrect reading

Safety issues:  

Maintenance issues:  

## QUALITY ASSURANCE & MATERIALS TESTING DIVISION

**(QA&MTD)**

**FIELD COMPLAINT TYPES**

**SAFETY ISSUES ON NON-APPROVED EQUIPMENT**
**MAINTENANCE ISSUES**
**6.10 (f) – DEFECT NOTIFICATION TO MSHA**

**FIELD COMPLAINT -  SERVES AS A METHOD TO INVESTIGATE **
**                            ****	****	****PROBLEMS ASSOCIATED WITH A SPECIFIC**
**	****	****PRODUCT  **

**Notes:**
Nonconforming product:  notified by inspectors, mine operators, equipment manufacturers

Improper use: e.g. not using methane monitor correctly

Product performance issues:  e.g. sticking valve, incorrect reading

Safety issues:  

Maintenance issues:  

## CODE OF FEDERAL REGULATIONS (30CFR, PART 6)

**6.2  DEFINITIONS**
**POST-APPROVAL PRODUCT AUDIT – **
**EXAMINATION AND/OR TESTING BY MSHA OF APPROVED **
**PRODUCTS SELECTED BY MSHA TO DETERMINE WHETHER **
**THOSE PRODUCTS MEET THE APPLICABLE PRODUCT **
**APPROVAL REQUIREMENTS AND HAVE BEEN **
**MANUFACTURED AS APPROVED**

## CODE OF FEDERAL REGULATIONS (30CFR, PART 6)

**6.10 (e)**
**UPON REQUEST BY MSHA, APPROVAL HOLDERS OF **
**PRODUCTS APPROVED BASED ON INDEPENDENT **
**LABORATORY TESTING AND EVALUATION MUST MAKE **
**SUCH PRODUCTS AVAILABLE FOR POST-APPROVAL AUDIT **
**AT A MUTUALLY AGREEABLE SITE AT NO COST TO MSHA**

**  ****AUDIT CONDUCTED NOT MORE THAN ONCE A           **
**    ****YEAR, EXCEPT FOR CAUSE**

## POST-APPROVAL PRODUCT AUDIT PROCESS

**AUDIT MAY BE CONDUCTED IF MSHA, APPROVAL HOLDER, OR OTHER  INTERESTED PARTIES DETERMINES AN APPROVED PRODUCT MAY NOT BE IN COMPLIANCE WITH THE TECHNICAL REQUIREMENTS OF THE APPROVAL**

## POST-APPROVAL PRODUCT AUDIT PROCESS

**SCHEDULING AND TRACKING SYSTEM TO MONITOR APPROVAL HOLDER AUDITS**

- AUDIT PREPARATION

**  ****MSHA NOTIFIES APPROVAL HOLDER**

**MSHA AND APPROVAL HOLDER AGREE ON AUDIT LOCATION AND TIME**

**  ****AUDIT MAY BE CONDUCTED AT:**
**APPROVAL HOLDER FACILITY**
**A&CC**
**MINE SITE**
**THIRD PARTY SITE**

## POST-APPROVAL PRODUCT AUDIT PROCESS

**AUDIT TEAM MEETS WITH APPROVAL HOLDER REPRESENTATIVE TO EXPLAIN INSPECTION/TEST PROCESS**

**  ****MEASUREMENTS RECORDED**
**  ****PHOTOGRAPHS**
**  ****DEFECTS WELL DOCUMENTED**

**AUDIT TEAM MEETS WITH REPRESENTATIVE TO DISCUSS RESULTS OF THE INSPECTION/TEST**

- AUDIT

## POST-APPROVAL PRODUCT AUDIT PROCESS

- POST AUDIT

**AUDIT TEAM REVIEWS APPROVAL DOCUMENTATION TO VERIFY DEFECTS**

**  ****IF NO DEFECT:**
**    ****AUDITOR NOTIFIES REPRESENTATIVE OF AUDIT **
**    ****RESULTS BY LETTER**

## DEFECT CLASSIFICATION

- POST AUDIT

**DEFECT CLASSIFICATION**

**CRITICAL --   ****WILL**** ADVERSELY AFFECT PRODUCT SAFETY ****	****	****	****AND PERFORMANCE**
**MAJOR 1--    ****IS LIKELY TO**** ADVERSELY AFFECT PRODUCT ****	****	****	****SAFETY AND PERFORMANCE**
**MAJOR 2--    ****IS NOT LIKELY**** TO ADVERSELY AFFECT ****	****	****	****PRODUCT SAFETY AND PERFORMANCE**
**MINOR --   ****	****WILL NOT**** ADVERSELY AFFECT PRODUCT ****	****	****	****SAFETY OR PERFORMANCE**

## POST-APPROVAL PRODUCT AUDIT PROCESS

- POST AUDIT

**IF DISCREPANCY:**
**AUDITOR CONTACTS REPRESENTATIVE BY   PHONE TO DISCUSS**

**FOLLOW-UP LETTER SENT TO DOCUMENT DEFECT AND NECESSARY ACTIONS**

**AUDITOR MONITORS CORRECTIVE ACTION UNTIL COMPLETE AND DOCUMENTED**

## POST-APPROVAL PRODUCT AUDIT PROCESS

**  ****POSSIBLE CORRECTIVE ACTIONS:**
**PRODUCT RECALL**
**PRODUCT RETROFIT**
**APPROVAL DOCUMENTATION CHANGE**
**FOR CRITICAL DEFECTS – MSHA MAY REQUIRE **
**	****APPROVAL HOLDER TO IMMEDIATELY REMOVE **
**	****PRODUCT FROM SERVICE **
**	**

- POST AUDIT

## DEFECT NOTIFICATION TO MSHA

**DEFECT:  ANY DEVIATION FROM THE RECORDS,**
**	****DRAWINGS, OR SPECIFICATIONS CONTAINED IN THE**
**	****MSHA APPROVAL RECORDS**

**6.10 (f)**
**ONCE THE PRODUCT IS APPROVED, THE APPROVAL HOLDER MUST NOTIFY MSHA OF ALL PRODUCT DEFECTS OF WHICH THEY BECOME AWARE**

## DEFECT NOTIFICATION TO MSHA

**APPROVAL HOLDER MUST NOTIFY MSHA **
**	****OF DEFECTS WHEN:**

**APPROVED PRODUCT IS DISTRIBUTED WHICH DOES NOT MEET APPROVAL DOCUMENTATION**

## DEFECT NOTIFICATION TO MSHA

**PROCEDURE:**
**NOTIFICATION TO MSHA SHOULD BE MADE BY**
**	****TELEPHONE, E-MAIL, OR FAX**
**THE TELEPHONE NOTIFICATION SHOULD BE**
**	****FOLLOWED-UP WITH A LETTER TO DOCUMENT**
**	****THE DEFECT**
**THE LETTER SHOULD BE ADDRESSED TO KEN SPROUL – QA&MTD CHIEF**
**THE DEFECT WILL BE PROCESSED AS A FIELD COMPLAINT**

## CONCLUSION

**QA&MTD CONDUCTS POST-APPROVAL AUDITS REQUIRED BY 30CFR, PART 6**
**AUDITS CONDUCTED PER DOCUMENTED PROCEDURE**
**APPROVAL HOLDER MUST TAKE CORRECTIVE ACTION WHEN DEFECTS ARE IDENTIFIED**
**APPROVAL HOLDER MUST NOTIFY MSHA WHEN APPROVED PRODUCT IS DISTRIBUTED WHICH DOES NOT MEET APPROVAL DOCUMENTATION**

## QUESTIONS ?

## Slide 23

## Slide 24

## ____________(Date)

- ________________________(Company Representative)
- ________________________ (Company)
- ________________________(Address)
- _________________________
- Dear Mr./Ms. _____________:
- On behalf of the Mine Safety and Health Administration, I would like to thank you for your
- cooperation during the post approval product audit investigation of Approval No. ___________,
- conducted by _______________________________________________(QA&MTD auditor(s),
- at  _________________________________________________________________(location),
- on _____________________(date).
- A post approval product audit is conducted to ensure conformity with the technical requirements
- upon which the approval was based.
- The post approval product audit did not disclose any defects and therefore the approved
- product is deemed by MSHA to meet the approval requirements.
- Sincerely,
- _______________________(QA&MTD Auditor)
- Mining Equipment Compliance Specialist
- Quality Assurance & Materials Testing Division
- Approval and Certification Center

## ____________(Date)

- ________________________(Company Representative)
- ________________________ (Company)
- ________________________(Address)
- _________________________
- Dear Mr./Ms. _____________:
- With reference to our telephone conversation on _________________ (date), the following
- ____________________ (product) approved under 30 CFR, Part 6, has been scheduled for post-
- approval product audit:
- _Approval No._				_Product_
- Please submit a sample for each MSHA approved product listed above.  Approval holders of
- products approved based on independent laboratory testing and evaluation must make such
- products available for post approval audit at a mutual agreeable site at no cost to MSHA.
- Representatives of _____________ (approval holder) are welcome to witness the post-approval
- product audit testing of the products listed above.  Please notify this office if representatives of
- _________________ (approval holder) will be present, and we will attempt to schedule testing
- accordingly.
**If the product is not currently available for audit, but is available during the next 12**
**months, please notify us regarding testing scheduling, or submit a sample.**
- If you have any questions, please feel free to contact me at __________________ (auditor’s
- phone number), or John C. Petrus at (304) 547-2049.  Thank you for your cooperation in this matter.
- Sincerely,
- ____________________ (QA & MTD Auditor)
- Mining Equipment Compliance Specialist
- Quality Assurance & Materials Testing Division
- Approval and Certification Center