EFFECTIVE DATE: 06/24/13

PROGRAM POLICY LETTER NO. P13-V-08

FROM: KEVIN G. STRICKLIN 

 Administrator for 

 Coal Mine Safety and Health

SUBJECT: Reissue of P11-V-03 - Electric Equipment; Examination, Testing and 

Maintenance

Scope

This Program Policy Letter (PPL) applies to coal mine operators, coal mine safety and health 

enforcement personnel, miners' representatives and other interested parties. 

Purpose

The purpose of this PPL is to clarify the interpretation and application of 30 C.F.R. §§ 75.511 

and 77.501 to certain electric equipment. This PPL supersedes the previous reissue. This PPL 

also defines the term "distribution circuits or equipment" in an effort to promote consistency in 

enforcing these standards. 

Policy

Existing §§ 75.511 and 77.501 require that electrical work on low-, medium-, or high-voltage 

distribution circuits or equipment must be performed by a qualified person or by a person trained 

to perform electrical work under the direct supervision of a qualified person. A "qualified 

person" is defined as an individual who meets the requirements of § 75.153 or § 77.103, as 

applicable. The term "distribution" is defined in the Institute of Electrical and Electronics 

Engineers (IEEE) Standard Dictionary of Electrical and Electronics Terms (3d. ed. 1984), page 

270, as an adjective to denote application or restriction of the circuits or equipment or both, to 

"that part of an electric system used for conveying energy to the point of utilization from a 

source or from one or more main receiving stations." Work on distribution circuits and 

equipment poses great hazards to personnel performing it. Equipment such as battery cap lamps, 

telephones or telephone circuits, approved battery flashlights, approved methane detectors, 

atmospheric monitoring systems, post accident communication and tracking systems and electric 

circuits on board surface mobile equipment powered by internal combustion gasoline engine are 

not considered distribution equipment (This does not include electric motors powered by 

generator sets onboard large surface equipment, such as shovels, draglines, and off-highway haul 

trucks). Work on and repair and maintenance of such electric equipment does not pose the same 

hazard as work on distribution circuits and equipment. Consequently, a qualified person would 

not be required to install, repair, or maintain these types of circuits and equipment. 
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Although §§ 75.512 and 77.502 require that all electric equipment be examined, tested, and 

properly maintained by a qualified person and do not distinguish between "distribution circuits or 

equipment" and other electric equipment, the Mine Safety and Health Administration (MSHA), 

through a memorandum issued in 1999 to the District Managers, exempted the equipment listed 

above from being repaired and maintained by qualified persons as long as the persons 

performing the work are properly trained in such work. These circuits and equipment, however, 

are required to be examined and tested at least weekly as specified in § 75.512-2 and monthly as 

specified in § 77.502-2. A record of this examination and test is not required. Additionally, 

although methane monitoring systems and methane monitors are electric equipment, they are not 

required to be maintained by a qualified person. Section 75.342(a)(4)(i) requires using persons 

properly trained in the maintenance, calibration, and permissibility of methane monitors to 

calibrate and maintain these devices. Section 75.351(o) requires that records be made by 

individuals designated by the operator, and § 75.351(q) requires training for AMS operators and 

does not require these operators to be qualified in accordance with §§ 75.153 or 77.103, as 

applicable. 

Individuals working on the equipment listed above, however, must be properly trained in the 

maintenance, repair, calibration and any other tasks they are performing on these types of 

equipment. For example, these individuals must be trained in the permissibility requirements to 

ensure that permissible equipment is maintained in permissible condition.

Background

Questions were raised regarding the applicability of §§ 75.511, 75.512, 77.501 and 77.502 to 

equipment such as cap lamps and methane detectors. Specifically, MSHA was asked whether 

persons performing work or maintenance on this equipment are required to be qualified in 

accordance with §§ 75.153 or 77.103, as applicable, and whether this type of equipment is 

"distribution" equipment. 

Authority

The Federal Mine Safety and Health Act of 1977, as amended, 30 U.S.C. § 801 et seq., the 

MINER Act, and 30 C.F.R. §§ 75.511, 75. 512, 77.501 and 77.502. 

Internet Availability

This PPL may be viewed on the World Wide Web by accessing the MSHA Home Page at 

(http://www.msha.gov) under MSHA’s Major Laws, Regulations and Policies choose 

“Compliance Information (PIBs, PILs, the PPM, and More” and select “Program Policy Letters”.

Issuing Office and Contact Person

Coal Mine Safety and Health, Safety Division

Rodney Adamson, (202) 693-9549

E-mail: adamson.rodney@dol.gov
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Distribution

MSHA Program Policy Manual Holders (w/attachments)

Coal Mine Operators 

Miners' Representatives 

Special Interest Groups