EFFECTIVE DATE: 4/28/2011 EXPIRATION DATE: 3/31/2013 

 (Reissue of P09-V-01) 

PROGRAM POLICY LETTER NO. P11-V-13 

FROM: KEVIN G. STRICKLIN

 Administrator for

 Coal Mine Safety and Health

 LINDA F. ZEILER

 Acting Director of Technical Support

SUBJECT: Guidance for Compliance with Post-Accident Two-Way 

 Communications and Electronic Tracking Requirements of the

 Mine Improvement and New Emergency Response Act (MINER

 Act) 

Scope

This program policy letter (PPL) is intended for Mine Safety and Health Administration 

(MSHA) personnel, equipment manufacturers, repair facilities, underground coal mine 

operators and independent contractors, miners’ representatives, and other interested 

parties. 

Purpose

This PPL is a general statement of policy that provides mine operators guidance in

implementing: (1) alternatives to fully wireless post-accident two-way communication

between underground and surface personnel and (2) electronic tracking systems, both

of which are required by the MINER Act. The two-way communication alternatives (or 

“partially wireless” systems) include infrastructure underground to provide untethered 

communications with miners.
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Policy

The following guidance is provided to assist mine operators in developing postaccident two-way communication between underground and surface personnel and 

electronic tracking for their Emergency Response Plans (ERPs), as required by the 

MINER Act. The MINER Act requires, by June 15, 2009, a plan be submitted that 

provides for a post-accident communication system between underground personnel 

and surface personnel via a wireless two-way medium and an electronic tracking ystem 

that permits surface personnel to determine the location of any persons trapped 

underground. If these provisions cannot be adopted, the MINER Act requires that 

ERPs must set forth an alternative means of compliance that approximates, “as closely 

as possible, the degree of functional utility and safety protection provided by the 

wireless two-way medium and tracking system” referenced. 

With respect to tracking, because electronic systems currently are available and MSHA 

approved, new ERPs and revisions to existing ERPs should provide for electronic 

tracking of persons underground. 

However, because fully wireless communications technology is not sufficiently 

developed at this time to permit use throughout the industry, this guidance addresses

acceptable alternatives to fully wireless communication systems. New ERPs and 

revisions to existing ERPs should provide for alternatives to fully wireless 

communication systems.

This guidance represents MSHA’s current thinking with respect to two-way 

communication and electronic tracking for use in mine emergencies. It does not create 

or confer any rights for any person nor does it operate to bind mine operators or any 

other members of the public. Mine operators can use an alternative approach or system 

to provide two-way communication or electronic tracking, if the approach or system 

satisfies the requirements of applicable statutes and regulations. If you are a mine 

operator, miners’ representative, or miner and want to discuss another approach or 

system, you may contact the MSHA District Manager for the area in which the mine is 

located. Other interested parties may contact the individuals identified in this PPL. 

References to the District Manager in this PPL refer to the Agency’s existing 

consultative process for approving mine plans, as opposed to the process for 

enforcement decisions related to citations. 

Two-Way Communication System

In accordance with Section 2 of the MINER Act, until fully wireless systems are 

available, operators must set forth in their Emergency Response Plans the reasons that 

they are proposing alternative systems, that is, that wireless systems are not available,

and provide an alternative that approximates, as closely as possible, the degree of 
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functional utility and safety protection provided by a wireless two-way 

communications system. While operators and District Managers must consider minespecific circumstances in determining appropriate two-way communications systems, 

this guidance outlines the features MSHA believes would best approximate the 

functional utility and safety protections of a fully wireless system, given the limitations 

of current technology. As noted, operators and others may propose other approaches

or systems, and the District Manager will exercise his discretion in evaluating them. 

Communications systems that are already in use may need to be updated to comply 

with the MINER Act requirements to approximate the utility and safety protections of a 

fully wireless system.

1. General Considerations - An alternative to a fully wireless communications 

system used to meet the requirements of the MINER Act for post-accident 

communication either can be a system used for day-to-day operations or a stored

system used in the event of an accident. Examples of currently available 

technologies that may be capable of best approximating a fully wireless 

communications system include, but are not limited to, leaky feeder, wireless or 

wired node-based systems, and medium frequency systems. Any alternative 

system generally should: 

a. Have an untethered device that miners can use to communicate with the 

surface. The untethered device should be readily accessible to each group 

of miners working or traveling together and to any individual miner 

working or traveling alone.

b. Provide communication in the form of two-way voice and/or two-way 

text messages. If used, pre-programmed text messages should be capable 

of providing information to the surface necessary to determine the status 

of miners and the conditions in the mine, as well as providing the 

necessary emergency response information to miners. 

c. Provide an audible, visual, and/or vibrating alarm that is activated by an 

incoming signal. The alarm should be distinguishable from the 

surrounding environment.

d. Be capable of sending an emergency message to each of the untethered 

devices. 

e. Be installed to prevent interference with blasting circuits and other 

electrical systems.

2. Coverage Area 

a. The system must provide coverage throughout each working section in a 

mine.

b. The system also generally should provide continuous coverage along the 

escapeways and a coverage zone both inby and outby strategic areas of 

the mine. Strategic areas are those areas where miners are normally 

required to work or likely to congregate in an emergency and can include
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belt drives and transfer points, power centers, loading points, refuge 

alternatives, SCSR caches and other areas identified by the District 

Manager. While a coverage zone of 200 feet inby and 200 feet outby 

strategic areas normally should be adequate, the District Manager may 

require longer or shorter distances given circumstances specific to the 

mine. 

c. The District Manager may approve alternative coverage areas to those 

areas identified in 2(b), such as adjacent entries, for reasons such as radio 

frequency interference or other factors that may reduce the coverage area 

at the identified strategic areas.

d. Miners should follow an established check-in/check-out procedure or an 

equivalent procedure when assigned to work in bleeders or other remote 

areas of the mine that are not provided with communications coverage. 

e. Communications for refuge alternatives must be provided as required 

under 30 C.F.R. §75.1600-3. 

3. Permissibility – The communication system must be approved by MSHA to 

comply with 30 C.F.R. part 23 and applicable policies. 

4. Standby Power for Underground Components and Devices

a. Stationary components (infrastructure) generally should be equipped with 

a standby power source capable of providing sufficient power to facilitate 

evacuation and rescue in the event the line power fails or is cut off. In 

many mining situations, at least 24 hours of standby power based on a 5% 

transmit time, 5% receive time, and 90% idle time duty cycle (denoted as 

5/5/90) should be adequate, but mine- specific conditions may warrant 

more or less standby power capability. The system should display 

whether it is operating on-line or with standby power and give an 

indication of the state of charge of standby power.

b. Untethered devices, such as hand-held radios, generally should provide

sufficient power to facilitate evacuation and rescue following an accident. 

In many mining situations, at least 4 hours of operation in addition to the 

normal shift duration (12-hour minimum total duration) based on a 

5/5/90 duty cycle should be adequate, but mine-specific conditions may 

warrant more or less capability. This total operation time can be achieved 

via spare portable devices or cached batteries if the device is approved for 

battery replacement in the hazardous area. 

5. Surface Considerations

a. The surface portion of the communication system generally should

include a line-powered surface component with a standby power source 

to ensure continued operation in the event the line power is interrupted. 
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b. The communication system should be configured to allow communication 

between underground personnel and the communication facility required 

under 30 C.F.R. § 75.1600-1 where a person who is always on duty when 

miners are underground can receive incoming messages and respond 

immediately in the event of an emergency. The person should be trained 

in the operation of the communication system and knowledgeable of the 

mine’s Emergency Response Plan.

c. The communication system can be monitored from a remote site. 

However, the mine site must have full system capability.

6. Survivability

a. The post-accident communication system generally should provide 

redundant signal pathways to the surface component. The system should 

display pathway interruptions and system malfunctions.

i. Redundancy means that the system can maintain communications 

with the surface when a single pathway is disrupted. Disruption 

can include major events in an entry or component failure. 

ii. Redundancy can be achieved by multiple systems installed in 

multiple entries, or one system with multiple pathways to the 

surface; provided that a failure in one system or pathway does not 

affect the other system or pathway. 

b. If system components must be installed in areas vulnerable to damage 

(such as in front of seals), protection against forces that could cause 

damage should be provided. 

7. Maintenance

a. The equipment manufacturer generally should provide a maintenance

schedule and checklist to the mine operator.

b. The mine operator should: 

i. Establish and follow a procedure to provide communications 

during system or component failures in the event that an accident 

occurs before the failure can be corrected. This procedure should 

include restoring at least 24 hours of standby power for the 

infrastructure. 

ii. Examine the infrastructure and verify on a weekly basis that it is 

maintained in proper operation condition. In the event of any 

failure that results in the loss off communication, repairs should be 

started immediately and the system restored to operating 

condition. A record of the examination should be kept and made 

available to an authorized representative of the Secretary and 

miners.

iii. Examine the untethered devices on a daily basis to verify that they 

are maintained in proper operating condition.

iv. Follow the manufacturer’s maintenance recommendations. 
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Electronic Tracking System

Approved electronic tracking systems are available. While operators and District 

Managers must consider mine-specific circumstances in determining an appropriate 

electronic tracking system, this guidance outlines features MSHA believes would 

provide the protection contemplated in the MINER Act in many underground coal 

mining environments. As noted, operators and others may propose alternative 

approaches or systems, and the District Manager will exercise his discretion in 

evaluating them. 

1. General Considerations - Plans must be submitted that provide for determining

the location of persons underground using an electronic tracking system

pursuant to 30 U.S.C. § 876(b)(2)(F)(ii).

2. Performance 

a. While the required capabilities of a particular tracking system will depend 

on mine-specific circumstances, an effective electronic tracking system 

generally should be capable of: 

i. Determining the location of miners on a working section to within 

200 feet. 

ii. Determining the location of miners in escapeways at intervals not 

exceeding 2000 feet. 

iii. Determining the location of miners within 200 feet of strategic 

locations. Strategic areas are those areas where miners are 

normally required to work or likely to congregate in an emergency 

and can include belt drives and transfer points, power centers, 

loading points, refuge alternatives, SCSR caches and other areas 

identified by the District Manager. 

iv. Determining the location of miners in belt entries at intervals not 

exceeding 4000 feet or at each manned belt drive if the distance 

between the drives is less than 4000 feet.

v. Determining direction of travel at key junctions in escapeways.

vi. Determining the identity of miners within 200 feet of refuge 

alternatives.

b. Electronic tracking systems generally should be installed to prevent 

interference with blasting circuits and other electrical systems. 

3. Permissibility – The tracking system must be approved by MSHA under 30 

C.F.R. part 23 and applicable policies. 

4. Standby Power for Underground Components
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a. Stationary components (infrastructure) should be capable of tracking 

persons underground during evacuation and rescue efforts, even upon 

loss of mine power. In many circumstances, the capacity to provide a 

minimum of 24 hours of continuous tracking operation after a power loss

should be sufficient. The system should display whether it is operating 

on-line or with standby power and give an indication of the state of 

charge of standby power. 

b. An individually-worn/carried tracking device (e.g., a tag) generally 

should provide a low power warning. To facilitate evacuation and rescue 

efforts, the individually-worn/carried tracking device should provide at 

least 4 hours of operation in addition to the normal shift duration (12-hour

total minimum duration). 

5. Capacity - Tracking system components (readers) must be capable of tracking the 

maximum number of persons, including visitors, expected to be in a coverage 

area. 

6. Scanning rate – In order to provide timely and relevant information, the tracking 

system generally should be capable of updating (refreshing) location data at least 

every 60 seconds.

7. Surface Considerations 

a. The surface portion of the tracking system should be equipped with 

standby power to ensure continuous operation in the event the line power 

is interrupted. 

b. The tracking system should be configured to allow monitoring the 

location of miners underground from the communication facility required 

under 30 C.F.R. § 75.1600-1 where a person is always on duty when 

miners are underground and should include the capability to display the 

location of all miners underground. The person on duty on the surface 

should be trained in the operation of the tracking system.

c. The tracking system can be monitored from a remote site. However the 

mine site must have full system capability.

d. The tracking system interface should display the last known location of a 

miner when the tracking device is not communicating with the system.

e. Each miner should be uniquely identified.

f. Location data should be associated with a time stamp.

g. Location data should be stored for two weeks so that it will be available 

for evacuation and rescue of persons underground, as well as for accident 

investigations. 

8. Survivability 
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a. If system components must be installed in areas vulnerable to damage 

(such as in front of seals), protection against forces that could cause 

damage should be provided. For example, protection could be provided 

by installing enclosures in recessed areas, around corners, or other areas 

that reduce potential for damage, or routing and protecting cables such 

that potential for damage is minimized. 

b. The MINER Act does not explicitly require redundancy for tracking 

systems, however, pursuant to Section 2 of the MINER Act, tracking 

systems must be “calculated to remain serviceable in a post-accident 

setting.” As system redundancy is one method for improving the 

likelihood of tracking capability following an accident, consideration 

should be given to the use of redundant signal pathways to the surface 

component as a means to better ensure survival of electronic tracking 

systems following an accident.

i. Redundancy means that the system can maintain communications 

with the surface when a single pathway is disrupted. Disruption 

can include major events in an entry or component failure. 

ii. Redundancy can be achieved by multiple systems installed in 

multiple entries, or one system with multiple pathways to the 

surface; provided that a failure in one system or pathway does not

affect the other system or pathway. 

c. Data storage should not be impacted by interruption of the data link 

between underground and surface components. 

d. The system should display pathway interruptions and system 

malfunctions.

9. Maintenance

a. The equipment manufacturer generally should provide a maintenance

schedule and checklist to the mine operator.

b. The mine operator generally should: 

i. Establish and follow a procedure to provide tracking during system 

or component failures in the event that an accident occurs before 

the failure can be corrected. This procedure should include 

restoring at least 24 hours of standby power for the infrastructure.

ii. Examine the infrastructure and verify on a weekly basis that it is 

maintained in proper operating condition. In the event of any 

failure that affects the tracking capability of the system, repairs 

should be started immediately and the system restored to operating 

condition. A record of the examination should be kept and made 

available to an authorized representative of the Secretary and 

miners.

iii. Examine on a daily basis the devices worn by miners to verify that 

they are maintained in proper operating condition. 
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iv. Follow the manufacturer’s maintenance recommendations. 

Background

The MINER Act of 2006 included the following requirement for communications and 

tracking systems: 

Not later than 3 years after the date of enactment of the Mine 

Improvement and New Emergency Response Act of 2006, a[n emergency 

response] plan shall, to be approved, provide for post accident 

communication between underground and surface personnel via a 

wireless two-way medium, and provide for an electronic tracking system 

permitting surface personnel to determine the location of any persons 

trapped underground or set forth within the plan the reasons such 

provisions can not be adopted. Where such plan sets forth the reasons 

such provisions can not be adopted, the plan shall also set forth the 

operator’s alternative means of compliance. Such alternative shall 

approximate, as closely as possible, the degree of functional utility and 

safety protection provided by the wireless two-way medium and tracking 

system referred to in this subpart. 

In addition, the MINER Act requires:

Consistent with available technology and with the physical constraints, if 

any, of the mine, the plan shall provide for above ground personnel to 

determine the current, or immediately pre-accident, location of all 

underground personnel. Any system so utilized shall be functional, 

reliable, and calculated to remain serviceable in a post-accident setting.

As technological advances are made and become available, MSHA will update this 

guidance, and District Managers will review existing Emergency Response Plans to 

consider the manner in which intervening advances in electronic tracking systems may 

enhance miners’ ability to evacuate or otherwise survive in an emergency. 

Authority

Section 316 of the Federal Mine Safety and Health Act of 1977, as amended, 30 U.S.C. § 

876; 30 C.F.R. part 23 and § 75.1600. 

Filing Instructions

This program policy letter should be filed behind the tab marked "Program Policy 

Letters" at the back of Volume II of the Program Policy Manual. 
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Internet Availability

This program policy letter may be viewed on the World Wide Web by accessing the 

MSHA home page (http://www.msha.gov) and choosing "Compliance Info" and 

"Program Policy Letters." A list of MSHA-approved two-way communications systems 

and a list of MSHA-approved electronic tracking systems may be found at

http://www.msha.gov/techsupp/PEDLocating/MSHAApprovedPEDproducts.pdf. 

Issuing Offices and Contact Persons

Technical Support, Approval and Certification Center 

David Chirdon, (304) 547-2026 

E-mail: chirdon.david@dol.gov

Coal Mine Safety and Health

John Arrington, (202) 693-9549 

E-mail: arrington.john@dol.gov 

Distribution

MSHA Program Policy Manual Holders

Manufacturers of Mining Equipment and Mine Equipment Repair Facilities 

Miners’ Representatives

Underground Mine Operators

Underground Independent Contractors

Special Interest Groups