EFFECTIVE DATE: 3/7/2011 EXPIRATION DATE: 3/31/2013

(Reissue of P09-V-12)

PROGRAM POLICY LETTER NO. P11-V-3

FROM: KEVIN G. STRICKLIN 

 Administrator for 

 Coal Mine Safety and Health 

SUBJECT: 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 highvoltage 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
2

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. 

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. 
3

Internet Availability

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

at (http://www.msha.gov) choosing "Compliance Info," then choosing "Program Policy 

Letters." 

Issuing Office and Contact Person

Coal Mine Safety and Health, Safety Division

John Arrington, (202) 693-9549

E-mail: arrington.john@dol.gov

Distribution

MSHA Program Policy Manual Holders (w/attachments)

Coal Mine Operators 

Miners' Representatives 

Special Interest Groups