EFFECTIVE DATE: 5/6/2011 EXPIRATION DATE: 3/31/2013

(Reissue of P08-V-4)

PROGRAM POLICY LETTER NO. P11-V-14 

FROM: LINDA F. ZEILER

 Acting Director of Technical Support

 KEVIN G. STRICKLIN

 Administrator for

 Coal Mine Safety and Health

SUBJECT: Water Sprinkler Fire Protection of Underground Belt Conveyors

 and Belt Takeup Storage Units

Scope

This Program Policy Letter (PPL) applies to all miners, miners’ representatives, Coal 

Mine Safety and Health (CMS&H) enforcement personnel, and underground coal mine 

operators.

Purpose

The purpose of this PPL is to clarify the requirements of Title 30 Code of Federal 

Regulations (30 C.F.R.) Sections 75.1101-7 and 75.1101-8 concerning the installation 

requirements for water sprinkler systems and arrangement of sprinklers on 

underground belt conveyors and belt takeup storage units. This PPL also clarifies the 

intent of the Mine Safety and Health Administration’s (MSHA) Program Policy Manual

(PPM) Volume V, Section 75.1101-8 regarding sprinkler systems arrangement of 

sprinklers. MSHA has determined that some belt takeup storage units do not have 

adequate fire protection because belt conveyor takeup storage units are not provided 

with sufficient protection and the wide belts may shield the sprinkler from suppressing 

a belt fire.

MSHA will be inspecting all belt takeup storage units to assure that adequate fire 

protection is afforded. This PPL is intended to answer questions, eliminate 
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inconsistencies, and provide guidance to enforcement personnel and the mining 

industry.

Policy

The standards contained in 30 C.F.R. 75.1101 are derived from the statutory provisions 

311(f) of the Act to prevent and contain fires primarily in underground belt entries 

where the danger of fire is particularly great; the rollers and bearings can get hot; the 

belt itself can burn; oil and grease are present; coal is transported on the belt; and the 

belt can slip. For these reasons, a fire protection system is required. When sprinklers 

are chosen as the method of protection, all of these reasons support having sprinkler 

protection over the entire length of both storage type and non-storage type belt takeup 

units since these units have all of the above hazards. The cited standard requires that at 

least one sprinkler be installed above each belt drive, belt takeup, electrical control, and 

gear reducing unit.

This PPL addresses the key elements for compliance with the requirements for water 

sprinkler systems and arrangements of sprinklers for underground belt conveyors and 

belt takeup storage units.

1.) Two or more branch lines, at least one of which shall be above the top belt 

and one between the top and bottom belt, shall be installed in each sprinkler 

system to provide a uniform discharge of water to the belt. Wider belt

conveyor installations may require more than one branch line directly over 

the top belt and between the top and bottom belts in order to provide a 

uniform discharge of water to the entire width of the belt surface.

2.) The water discharged from the sprinklers shall be directed at both the upper 

and bottom surfaces of the top belt and to the entire upper surface of the 

bottom belt. The water discharge rate from the sprinkler system shall be a 

minimum of 0.25 gallons per minute per square foot of the top belt surface.

3.) Each sprinkler system shall provide protection for the motor drive belt 

takeup storage unit, electrical controls, gear reduction unit, and the 50 feet of 

fire resistant belt, or 150 feet of nonfire-resistant belt adjacent to the belt 

drive.

4.) In accordance with 30 C.F.R. 75.1101-7(a), each sprinkler system must be 

 installed, to the extent practicable, in accordance with NFPA 13, “Standard

 for the Installation of Sprinkler Systems.” NFPA 13 is the National Fire

 Protection Association consensus standard for installation of fire protection

 sprinkler systems. Among other things, this consensus standard provides

 guidance on locating sprinklers, dealing with horizontal or vertical

 obstructions to sprinkler discharge water, specifying allowable types of pipes
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 and fittings, and presenting methods for determining minimum pipes sizes.

 The phrase “to the extent practicable” in the regulation should be interpreted

 to mean that all appropriate installation rules in the consensus standard 

 should be followed except where there is a compelling technical or physical

 reason requiring alternate methods or arrangements.

Unless MSHA has granted a petition for modification, the mine operator must comply 

with the standard.

Background

There has been inconsistency as to whether and what type of fire suppression over belt 

takeup storage units is required by the standard. Due to the increased width of 

conveyor belting, the increased length of belt takeup storage units, and the use of larger 

storage units as the result of the advance of belt conveyor technology, the potential 

exists that some sprinkler arrangements could be shielded from suppressing a belt fire 

and fail to satisfy the standard. The mining community has raised questions regarding 

fire protection requirements for underground belt takeup and belt storage units with 

respect to the adequacy of fire protection. The current standards specifically require

each sprinkler system provide a uniform discharge of water to the belt surfaces which 

includes belt takeup storage units. Mine operators must assure that compliance is 

achieved. 

Authority

The Federal Mine Safety and Health Act of 1977 and 30 C.F.R. Part 75.1101-7 and 30 

C.F.R. 75.1101-8. 

Filing Instructions

This PPL should be filed behind the tab marked "Program Policy Letters" at the back of 

Volume V of the Program Policy Manual.

Internet Availability

This PPL may be viewed on the Internet by accessing the MSHA Home Page 

(http://www.msha.gov) by choosing “Compliance Info” and “Program Policy Letters.”

Issuing Office and Contact Persons

Coal Mine Safety and Health, Safety Division

Michael Kalich, (202) 693-9714

E-mail: kalich.michael@dol.gov

Technical Support – Approval & Certification Center

Derrick M. Tjernlund, (304) 547-2301

E-mail: tjernlund.derrick@dol.gov
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Distribution

Underground Coal Mine Operators

Miners’ Representatives

Independent Contractors

Mining Product Manufacturers

Special Interest Groups

Coal and All-Volume Program Policy Manual Holders