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December 20, 2007 

The Honorable Elaine L. Chao 

Secretary of Labor 

Washington, D.C. 20210 

The Honorable Michael O. Leavitt 

The Secretary of Health and Human Services 

Washington, D.C. 20201 

Senator Edward M. Kennedy, Chairman and 

Senator Michael B. Enzi, Ranking Member 

The Committee on Health, Education, Labor, and Pensions 

428 Senate Dirksen Office Building 

Washington, DC 20510D 

Representative George Miller, Chairman and 

Representative Howard P. "Buck" McKeon, Ranking Member 

The Committee on Education and Workforce of the House of Representatives 

2181 Rayburn House Office Building 

Washington, DC 20515 

Dear Madam and Sirs: 

We are pleased to transmit to you the report of the Technical Study Panel on the 

Utilization of Belt Air and The Composition and Fire Retardant Properties of Belt 

Materials in Underground Coal Mining. 

The report, which is the final product of the Technical Study Panel, contains the 

Panel’s consensus recommendations. These recommendations are the result of 

many hours of discussion and debate and reflect our best judgment on how to 

ensure the safety and health of our nation’s coal miners. 
 4

We believe that the recommendations contained in this report are worthy of serious 

and immediate attention. 

Sincerely, 

_______________________ 

Dr. Jürgen F. Brune 

_______________________ 

Dr. Felipe Calizaya 

_______________________ 

Mr. Thomas P. Mucho 

_______________________ 

Dr. Jerry C. Tien 

_______________________ 

Dr. James L. Weeks 
 5

EXECUTIVE SUMMARY 

The Technical Study Panel on the Utilization of Belt Air and the Composition and 

Fire Retardant Properties of Belt Materials in Underground Coal Mining (hereafter 

referred to as the Panel or the TSP) was established by Section 11 of the Mine 

Improvement and New Emergency Response Act of 2006 (MINER Act). The Panel 

was charged with providing “independent scientific and engineering review and 

recommendations with respect to the utilization of belt air and the composition and 

fire retardant properties of belt materials in underground coal mining.” The TSP 

was impaneled by the Honorable Elaine L. Chao and commenced its work on 

January 9, 2007. At this first meeting, Mr. Richard E. Stickler, Assistant Secretary of 

Labor for Mine Safety and Health, asked the Panel to report on many issues 

including how recent technological advances could be applied to atmospheric 

monitoring systems, point-type heat sensors, current state of fire-resistant vs. 

fireproof belt materials, and belt fire suppression systems to improve miner safety. 

In addition, Mr. Stickler asked the Panel to review belt air velocity limitations. 

The Panel members attended 12 days of public meetings over a nine-month period. 

Three of the public meetings were scheduled for the Panel to hear from technical 

experts and those persons or organizations interested in providing input. The 

meetings were held in Coraopolis, Pennsylvania with emphasis on belt fires, belt 

maintenance, belt flammability and toxicity, ventilation, and escape issues; in Salt 

Lake City with emphasis on ground control and convergence issues; and in 

Birmingham with emphasis on fire detection, sensors and atmospheric monitoring 

systems. 

National Institute for Occupational Safety and Health (NIOSH) researchers, Mine 

Safety and Health Administration (MSHA) personnel, representatives of the major 

belt conveyor manufacturers and a representative of the National Mining 

Association provided discussions at the Coraopolis meeting. In Salt Lake City, Utah, 

MSHA district managers and ventilation specialists, a member of the Aracoma Mine 

No. 1 investigation team, a representative of the Bureau of Land Management, and 

industry and consulting representatives of the Utah Mining Association and the 

Colorado Mining Association made presentations. In Birmingham, Alabama, 

atmospheric monitoring system representatives, NIOSH researchers, representatives 

of coal mining companies, and UMWA workers from two Alabama mining 

companies made presentations. In addition, a staff member of The Center for 

Regulatory Effectiveness also presented comments to the Panel. In conjunction with 

the meetings in Salt Lake City and Birmingham, three-member subcommittees of the 

Technical Study Panel made field visits to the Skyline Mine, the Aberdeen Mine, and 

the Jim Walter Resources Mine No. 4. The mine visits were scheduled to see firsthand the mining conditions under which belt air was being utilized as an additional 

source of intake air for working sections. 
 6

The analysis of belt air usage issues was initiated by the Panel working in threeperson subcommittees. Each subcommittee was assigned a block of topics and 

charged with proposing recommendations to be considered by the entire Panel. On 

September 17-19, 2007, the Panel held its final public meeting in Reston, Virginia, to 

evaluate and vote on the recommendations. The Panel members engaged in 

discussions of each draft recommendation, negotiated changes in wording or 

emphasis of some recommendations, combined other recommendations, and then 

voted on each of the redrafted recommendations. It is important to emphasize that 

all 20 recommendations were passed by unanimous (6-0) votes of the Panel. 

The basic recommendations on belt entry air used in working sections are 

summarized below. However, it should be noted that the recommendations are 

coupled to other recommendations to ensure that belt air used to ventilate working 

sections is as safe as or safer than not using belt entry air to ventilate working 

sections. The two basic recommendations are summarized as follows: 

● The Panel recommends that the mines using belt entry air to ventilate 

working sections must be held to a higher standard that involves the use of 

o an atmospheric monitoring system (AMS) and/or other suitable 

monitoring instruments to detect smoke, CO and other signs of a belt 

fire early and reliably, 

o belt conveyor materials that meet the flame resistance requirements 

specified in the NIOSH/MSHA-developed Belt Evaluation Laboratory 

Test (BELT) and other test standards recommended by the Panel, and 

o more rigorous inspection procedures by MSHA inspectors. 

● The Panel recommends that MSHA evaluate the use of belt entry air coursed 

to the working sections as part of the approval process of the mine ventilation 

plan. The District Manager must, as part of this recommendation, take 

special care to evaluate whether the belt air can be routed to working sections 

in a manner that is as safe as or safer than not using belt entry air to ventilate 

working sections. 

Perhaps the most important safety recommendation made by the Panel was the 

recommendation that deals with the application of improved belt flammability 

standards to belt materials use in U.S. underground coal mines. The aim of the 

BELT is to prevent belt entry fires and not merely to suppress them. The Panel 

found that belt fires continue to occur on MSHA-accepted belts, that the BELT 

standard more closely resembles real in-mine conditions, and that underground 

mining conveyor belt flammability standards world-wide are more stringent than 

the standard applied in the United States. Thus the Panel recommends that the 

more rigorous BELT standards should be applied to belt materials used in 
 7

underground coal mines. Other recommendations that pertain to belt conveyor 

usage and maintenance are outlined in the four paragraphs below: 

● Because frictional heating is a common cause of belt fires, the Panel 

recommends that MSHA evaluate a drum friction test. This test would be 

mandated for a period of two years to determine if such a test would 

contribute to conveyor belt safety beyond that provided by the BELT. This 

test could then be incorporated into flame test acceptance requirements if 

MSHA determines that such a test would benefit miner safety. 

● Because belt fires also occur in mines that do not use belt entries for face 

ventilation and because the application of a different flame-resistant 

acceptance standard for conveyor belting in those underground coal mines 

that do not use belt air to ventilate working sections would be an untenable 

situation, the Panel recommends that MSHA extend the protection provided 

by the BELT and other belt flammability standards recommended in this 

report to all underground coal mines. 

● Because of the number of reportable fires in belt conveyor entries, the Panel 

recommends that MSHA rigorously enforce existing standards on conveyor 

belt maintenance and fire protection. This recommendation applies to 

general housekeeping, training of the belt, belt fire suppression systems, 

firefighting equipment, sensors and alarm systems, and training of personnel 

for fighting mine fires. 

● Because of the number of different belt testing standards used throughout the 

mining world, the Panel recommends that MSHA staff involved in belt fire 

resistance testing establish contacts and maintain dialogue with their 

counterparts in other key mining countries with the goal of working toward 

more universal standards. 

A considerable amount of Panel time and thought was given to the efficacy of 

atmospheric monitoring systems including the level of training the AMS operator 

receives, the specific tasks assigned to the AMS operator, and the type of electronic 

sensors used in such a system. The AMS-related recommendations are: 

● That all AMS operators be certified and that the highest priority of the AMS 

operator must be the proper operation of and response to the AMS, 

● That regular, periodic reviews of the AMS records be conducted by MSHA to 

analyze type and number of false alarms and measures taken by the operators 

to minimize the occurrences of such false alarms, 

● That diesel-discriminating sensors be required in mines where diesel engine 

usage was resulting in excessive numbers of false alarms, 
 8

● That rulemaking be initiated for discontinuing point-type heat sensors used 

for fire detection in belt entries, 

● That rulemaking be initiated to require the use of smoke detectors, and 

● That rulemaking be initiated to revise 30 CFR §§ 75.1100-1103 to update the 

rules, particularly those in § 75.1103, and take advantage of more effective 

modern technology. 

The Technical Study Panel also considered a significant number of related topics 

that are peripheral to the use of belt entry air to ventilate working sections. These 

topics have importance because they affect the mine ventilation efficiency, the mine 

atmosphere, the possibility of escape, or the inspection of mines where belt entry air 

is used to ventilate working sections. Relating to these topics, the Panel 

unanimously makes these recommendations for mines that ventilate working 

sections using belt entry air: 

● That the ventilation air velocity be between 100 feet per minute and 1000 feet 

per minute in the belt entry with certain exceptions, 

● That existing lifeline requirements be improved and made uniform 

throughout the U.S. to indicate the existence of doors, SCSR caches, and 

impediments to travel, 

● That existing escapeway design, escape planning, and training of miners be 

improved, 

● That dust concentrations be better controlled in working sections, 

● That methane concentrations in working sections are not increased by 

methane concentrations in belt entries being vented into working sections, 

and 

● That MSHA mine inspectors perform their inspection duties with greater 

efficiency and reduced chance of overlooking safety hazards. 

The Panel also recommends that research be conducted on alternate methods of 

enhancing escape, methods of reducing leakage through improved ventilation 

designs, and possible use of booster fans in underground coal mining operations. 

The underground coal mines of the future are likely to be deeper than today’s mines 

and with increasing depth, ground control problems become more significant. It is 

imperative that research be performed to help our mining operations deal with the 

conditions that need to be addressed in the future. 

Finally, the Panel suggests that Congress consider increased funding for MSHA and 

NIOSH to implement these recommendations. Many of the measures that the 

Technical Study Panel is suggesting will require additional resources such as 

inspection personnel, research equipment and personnel, and support services. 

Increased funding will help ensure the success of any additional measures taken to 
 9

increase mine safety and keep the new safety measures from diluting the 

enforcement of existing regulations. 
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TABLE of CONTENTS 

I. INTRODUCTION..................................................................... 13 

II. GOALS OF THE TECHNICAL STUDY PANEL.............................. 19 

III. REPORT OF PANEL ACTIVITIES................................................ 23 

IV. PANEL AND SUBCOMMITTEE WORK AGENDA.......................... 39 

V. OUTLINE AND DISCUSSION OF PANEL RECOMMENDATIONS.... 41 

APPENDICES 

A. Charter.................................................................................... 104 

B. Federal Register Notice Establishing of the Panel............................... 107 

C. Background of Panel Members..................................................... 110 

D. List of Materials Provided to Panel Members......,,,.......................... 111 
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REPORT OF THE TECHNICAL STUDY PANEL ON THE UTILIZATION OF BELT 

AIR AND THE COMPOSITION AND FIRE RETARDANT PROPERTIES OF BELT 

MATERIALS IN UNDERGROUND COAL MINING 

I. INTRODUCTION 

The Technical Study Panel on the Utilization of Belt Air and the Composition and 

Fire Retardant Properties of Belt Materials in Underground Coal Mining was created 

under Section 11 of the Mine Improvement and New Emergency Response Act of 

2006 (MINER Act)(Public Law 109-236), and was chartered under the provisions of 

the Federal Advisory Committee Act (FACA). [See the Technical Study Panel’s 

Charter, included as Appendix A of this Report; and the Federal Register Notice of 

Establishment of the Panel (71 FR 77069, December 22, 2006), included as Appendix 

B of this Report]. 

Congress established this Technical Study Panel (referred to in this document as the 

'Panel' or the ‘TSP’) to provide independent scientific and engineering review and 

recommendations with respect to the utilization of belt air and the composition and 

fire retardant properties of belt materials in underground coal mining. Membership 

of the Panel was composed of— 

“(1) two individuals... appointed by the Secretary of Health and Human Services, in 

consultation with the Director of the National Institute for Occupational Safety and 

Health and the Associate Director of the Office of Mine Safety; 

(2) two individuals... appointed by the Secretary of Labor, in consultation with the 

Assistant Secretary for Mine Safety and Health; and 

(3) two individuals, one appointed jointly by the majority leaders of the Senate and 

House of Representatives and one appointed jointly by the minority leaders of the 

Senate and House of Representatives....” 

Congress determined that at least four of the six individuals appointed to the Panel 

must possess a masters or doctoral level degree in mining engineering or another 

scientific field demonstrably related to the subject matter. No individual appointed 

to the Panel could be an employee of any coal or other mine, or of any labor 

organization, or of any State or Federal agency primarily responsible for regulating 

the mining industry. 

The Panel’s charge was to prepare and submit to the Secretary of Labor, the 

Secretary of Health and Human Services, the Committee on Health, Education, 

Labor, and Pensions of the Senate, and the Committee on Education and the 

Workforce of the House of Representatives a report concerning the utilization of belt 
 14

air and the composition and fire retardant properties of belt materials in 

underground coal mining. This report is due by December 20, 2007, within a year 

of the Panel members’ appointments. 

In the course of its deliberations, the Panel requested extensive material which was 

provided, primarily by MSHA and NIOSH. See Appendix D of this Report for a list 

of materials provided to the Panel. In addition, speakers having technical expertise 

in mine ventilation, conveyor belt composition, and other pertinent areas presented 

information and responded to questions by members of the Panel. 

The Panel is indebted to the miners at the Skyline Mine and the Aberdeen Mine in 

Utah and JWR No. 4 Mine in Alabama who provided valuable information during 

the Panel's visits. The Panel also wishes to thank members of the public, including 

both labor and industry, who attended the Panel’s meetings and demonstrated a 

genuine interest in the health and safety of the nation's miners. 

Staff experts from MSHA and NIOSH were present at each TSP meeting to assist the 

Panel as necessary. The Panel heard presentations from manufacturers of conveyor 

belts and atmospheric monitoring systems (AMS), as well as industry and labor 

representatives. MSHA and NIOSH technical staff made presentations to the Panel 

on a number of related health and safety concerns. Specifically, the Panel heard 

from the following parties: 

1) MSHA personnel, who addressed belt air history and regulations, belt 

flammability, use of belt air—health aspects, laboratory-scale flammability testing 

and belt fire historical data, the Aracoma Alma Mine No. 1 accident investigation 

report, and MSHA Coal Mine Safety and Health District Managers and senior 

ventilation specialists on their experience with belt air issues; 

2) NIOSH personnel, who addressed belt flammability research (large and 

laboratory-scale studies), belt toxicity issues, using belt air at the face/ belt velocity 

limits, mine escape issues, belt fire detection sensors and state-of-the-art smoke 

sensors, effective training techniques for emergency response preparedness (for 

AMS operators and in general for underground); 

3) Miners who are members of the United Mine Workers of America (UMWA); 

4) Representatives of the National Mining Association (NMA), Colorado Mining 

Association, Utah Mining Association (including Hamid Maleki, Ph.D. - President, 

Maleki Technologies, Inc.), the Alabama Mining Association, and mine operators 

during mine tours; 

5) Belt manufacturers: Goodyear, Fenner-Dunlop, and Phoenix; 
 15

6) Engineers who have knowledge of western mine ground control and convergence 

issues and two- entry versus other multiple entry systems (Agapito and Associates); 

7) AMS manufacturers: American Mine Research, Conspec Controls, Pyott-Boone, 

and Rel-Tek Corporation; 

 

8) Jim Walter Resources, who addressed a mine operator-developed AMS and 

conducted a mine tour; 

9) Bureau of Land Management, Utah State Office; and 

10) The Center for Regulatory Effectiveness 

The Panel members attended 12 days of public meetings over a nine-month period. 

They also toured the Skyline Mine and the Aberdeen Mine in Utah and JWR No. 4 

Mine in Alabama to obtain additional first-hand experience with the issues 

surrounding the safe use of belt air and flame-resistant conveyor belting. 

The Panel meetings were conducted by the Chair, Dr. Jan M. Mutmansky. Notice of 

each meeting was duly published in the Federal Register (FR). Each meeting was open 

to and attended by members of the public. Time was made available for members of 

the public to address the Panel each day during all but the first and last meetings. A 

verbatim transcript of each meeting was created. The background material and all of 

the presentations and associated documents, including the transcripts, were made 

available to the public. The official record of the meetings is housed at MSHA 

headquarters. Members of the public can review these documents at: Office of 

Standards, Regulations, and Variances, Mine Safety and Health Administration, 

1100 Wilson Boulevard, Room 2350, Arlington, Virginia 22209. In addition, the 

documents are posted on the Agency’s single source webpage titled “The Technical 

Study Panel on the Utilization of Belt Air and the Composition and Fire Retardant 

Properties of Belt Materials in Underground Coal Mining Single Source Page.” The 

Single Source page is located at http://www.msha.gov/BeltAir/BeltAir.asp. 

 

In the course of addressing the issues, the Panel considered a significant amount of 

data and information. This background material encompassed the entire belt air 

rulemaking record, including the proposed and final rules; the Report of the Advisory 

Committee on the Use of Air in the Belt Entry to Ventilate the Production (Face) Area at 

Underground Coal Mines and Related Provisions (1992 Advisory Committee report); 

MSHA’s Belt Entry Ventilation Review: Report of Findings and Recommendations 

(BEVR); extensive presentations and comments submitted during the meetings; a 

number of studies conducted by research organizations, primarily NIOSH; and 

historical data from MSHA on belt fire incidence. To enable the Panel to address 
 16

thoroughly the large volume of material and the wide range of issues, the Panel 

established subcommittees to address AMS, conveyor belt issues, fire safety, 

training, and escapeways. (See Appendix E.) For brevity, this Report is limited to 

summary documentation and discussions supporting the conclusions and 

recommendations and is not meant to be a treatise of the deliberations of the Panel. 

Consistent with the requirements of the MINER Act, the membership of the Panel 

was as follows: 

Selected for Appointment by the Secretary of Health and Human Services: 

 Dr. Jürgen F. Brune, Director, Spokane Research Laboratory, National 

Institute for Occupational Safety and Health, Spokane, Washington. 

 Dr. Felipe Calizaya, Associate Professor, University of Utah, Mining 

Engineering, Salt Lake City, Utah. 

Selected for Appointment by the Secretary of Labor: 

 Dr. Jan M. Mutmansky, Professor Emeritus of Mining Engineering, the 

Pennsylvania State University, University Park, Pennsylvania. 

 Dr. Jerry C. Tien, Associate Professor, Department of Mining Engineering, 

University of Missouri-Rolla, Rolla, Missouri. 

Selected for Appointment Jointly by the Majority Leaders of the Senate and House of 

Representatives: 

 Mr. Thomas P. Mucho, Thomas P. Mucho & Associates, Inc., Mining 

Consultancy, Washington, Pennsylvania. 

Selected for Appointment Jointly by the Minority Leaders of the Senate and House 

of Representatives: 

 Dr. James L. Weeks, Director, Evergreen Consulting, LLC, Silver Spring, 

Maryland. 
 17

Staff assistance was provided to the Panel by MSHA and NIOSH. A list of staff 

members follows: 

MSHA Staff

Linda F. Zeiler, Designated Federal Officer 

Deputy Director, Technical Support 

Arlington, Virginia 

Roslyn Fontaine 

Program Specialist, Technical Support 

Arlington, Virginia 

William J. Francart, P.E. 

Mining Engineer, Technical Support 

Pittsburgh Safety and Health Technology Center 

Ventilation Division 

Pittsburgh, Pennsylvania 

Hazel Haycraft 

Management and Program Analyst, Technical Support 

Arlington, Virginia 

Kevin Hedrick 

Electrical Engineer, Technical Support 

Approval and Certification Center 

Electrical Safety Division 

Triadelphia, West Virginia 

Michael Hockenberry 

Fire Protection Engineer, Technical Support 

Approval and Certification Center 

Mechanical and Engineering Safety Division 

Triadelphia, West Virginia 

Jennifer Honor, Esq. 

Attorney for Standards and Legal Advice 

Office of the Solicitor, Mine Safety and Health Division 

Arlington, Virginia 

Debra Janes 

Regulatory Specialist 

Office of Standards, Regulations and Variances 

Arlington, Virginia 
 18

Michael G. Kalich 

Senior Mining Engineer, Coal Mine Safety and Health 

Safety Division 

Arlington, Virginia 

William P. Knepp 

Assistant District Manager for Technical Services, Coal Mine Safety and Health 

District 9 

Denver, Colorado 

Mark Schultz 

Mining Engineer, Technical Support 

Pittsburgh Safety and Health Technology Center 

Dust Division 

Pittsburgh, Pennsylvania 

John Seiler, P.E. 

Supervisory General Engineer, Technical Support 

Pittsburgh Safety and Health Technology Center 

Physical and Toxic Agents Division 

Pittsburgh, Pennsylvania 

Trina Tate 

Secretary for the Director, Technical Support 

Arlington, Virginia 

Harry Verakis 

General Engineer, Technical Support 

Approval and Certification Center 

Office of the Center Chief 

Triadelphia, West Virginia 

Matthew Ward, Esq. 

Attorney for Standards and Legal Advice 

Office of the Solicitor, Mine Safety and Health Division 

Arlington, Virginia 

 

NIOSH Staff

Robert Timko 

Dust and Diesel Monitoring Team Manager 

Bruceton Research Center 

Pittsburgh, Pennsylvania 
 19

II. GOALS OF THE TECHNICAL STUDY PANEL 

The Technical Study Panel on the Utilization of Belt Air and the Composition and 

Fire Retardant Properties of Belt Materials in Underground Coal Mining (Panel) was 

created under Section 11 of the Mine Improvement and New Emergency Response 

Act of 2006, also known as the MINER Act (Public Law 109-236). The Congress 

established the Panel to provide independent scientific and engineering review and 

recommendations with respect to the utilization of belt air and the composition and 

fire retardant properties of belt materials in underground coal mining. Relative to 

their mandate, Mr. Richard E. Stickler, Assistant Secretary of Labor for Mine Safety 

and Health, asked the Panel to focus on a variety of issues including on how recent 

technological advances in atmospheric monitoring systems, point-type heat sensors, 

fire-resistant versus fireproof belt materials, and belt fire suppression systems could 

be used to improve miner safety. In addition, Mr. Stickler asked the TSP to review 

the belt air velocity limitations. 

During the initial meetings of the Panel, the tasks to be undertaken were assumed to 

include the manner in which belt air is used in working sections and the variables 

that ensure the safety of miners in these working sections. This includes belt entry 

and conveyor belt maintenance, the possible use of smoke detectors in belt entries, 

the use of diesel discriminating sensors for intelligent detection of fires in belt 

entries, the training of atmospheric monitoring system (AMS) operators, escapeways 

for working sections where belt air is used at the face, lifelines for escape purposes, 

point-feeding systems for ventilation of belt conveyors when using belt air in 

working sections, respirable dust and methane transport to working sections, 

inspection of working sections utilizing belt air for ventilating working faces, and 

research that may help in producing safer ventilation plans for working sections. In 

each of these subtasks, the Panel attempted to keep their investigations within the 

scope outlined by Congress. 

History of Belt Air Utilization

In initiating the study of this problem, the Panel reviewed the history of belt air 

usage in the working section, the changes in the technology of coal mining that 

instigated changes in the regulations, and the previous studies of belt air usage 

through the presentations at its first meeting on January 9, 2007. A summary of the 

historical background is presented by listing of the primary events in the belt air 

history below. For a more detailed history, readers may refer to the reports issued 

by the Belt Entry Ventilation Review Committee (MSHA, 1989) and by the Belt Air 

Advisory Committee (Belt Air Advisory Committee, 1992). The major events in the 

belt air history in U.S. coal mines are as follows: 
 20

Pre-1969 The Pennsylvania Bituminous Coal Mine Act of 1961, 52 P.S. §701-

242(c) require that the belt entry must be separated from the intake and 

return but did not require that the air be diverted directly to the return. 

1969 The Federal Coal Mine Health and Safety Act of 1969 was passed and 

requires that the belt air be separated from the intake and return air 

courses and the quantity be limited to the amount necessary to provide 

an adequate supply of oxygen and keep the methane below 1.0 

percent. At this time, the requirement was that the belt air be diverted 

directly to the return. Mines opened prior to the effective date of the 

Act were exempted. 

1975 The first successful petition for modification permitting belt air usage 

at the face was granted, opening the door to increased use of belt entry 

air in the working section. 

1975-2003 About 172 petitions for modification were granted to allow mines the 

use of belt entry ventilation air in the working section. 

1989 The Belt Entry Ventilation Review Committee, consisting of MSHA 

employees, finds the use of belt air to be at least as safe as other 

ventilation methods if a CO monitoring system is used. They also 

recommend that the use of pipe overcasts to carry belt air to the return 

be discontinued. They provide additional recommendations to make 

the practice of using belt entry air safer. 

1992 The Belt Air Advisory Committee, an independent committee of 

government, academic, and industry personnel, concludes that belt 

haulage entries can be safely used as intake air courses providing that 

an early warning fire system is in place and the miners are properly 

trained. The committee also outlines additional practices to ensure 

safe use of belt entry air. 

2003 MSHA proposed a rule to eliminate the petition for modification 

process for the use of belt entry air in the working section for mines 

with three or more entries in longwall mines and most other mines. 

Public hearings are held to provide input on the proposal. 

2004 MSHA promulgated the final rule on belt air, allowing the use of belt 

entry air in the working section in most mines. The rule also requires 

that mines opened prior to the effective date of the 1969 Act must also 

comply with the final rule. 
 21

2006 The mine fire of January 19 at the Aracoma Coal Company Alma Mine 

No. 1 to some degree reopened the question about the safety of using 

belt entry ventilation air in working sections. 

2006 Congress passes the MINER Act of 2006 which requires the 

establishment of a Technical Study Panel on the Utilization of Belt Air 

and the Composition and Fire Retardant Properties of Belt Materials in 

Underground Coal Mining. 

The history provided the Panel with a sense of the importance of the belt air rule in 

mine safety and set the stage for establishing the Panel goals. 

Outline of Panel Goals

The Panel interpreted the MINER Act, the charge to the committee by Secretary of 

Labor Elaine L. Chao, and the comments of Assistant Secretary of Labor Richard E. 

Stickler in defining the problems to be evaluated. It was clear that there were two 

primary questions to be answered. The first is the question of whether belt entry 

ventilation air should be permitted to be coursed to the working section to 

supplement the primary intake ventilation air. The second primary question is what 

requirements should be enforced on belt flammability and use of the AMS to reduce 

the hazards of carrying combustion products to the working face in mines using belt 

air at the face. There were also many auxiliary questions that were to be considered 

to ensure that the belt air utilization was carried out without endangering the 

miners. These included proper use of sensors to control the hazards, minimum and 

maximum velocity of air in the belt entries, control of dust and gas from the belt 

entry, proper utilization of escapeways and lifelines, training of miners and AMS 

operators, design of point-feeding systems, maintenance of the belt conveyor and 

the belt entry, inspection of mines utilizing belt air in the working sections, and 

research that would help in making the mining of coal safer as time moves forward. 

Many of these questions continue to be of importance because of the many 

technological changes that occur over time in mining systems, in the characteristics 

of underground coal mines, and in the many technologies that serve the mining 

community. In attempting to provide answers to the questions that must be 

answered in this study, the Panel listened to experts and the public comments on the 

issues. However, the Panel’s decision-making was initiated only after all of the data 

gathering and public input meetings were completed. Until that time, the Panel 

members refrained from discussions related to decision making and discussed only 

the specifics of the data and input provided by MSHA, the invited speakers, and the 

members of the public who addressed the Panel. The next section of the report 

provides a summary of the four public meetings that were held during the data 

gathering phase of the Panel activities. 
 22

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III. REPORT OF PANEL ACTIVITIES 

The Panel met in Washington, D.C.; Coraopolis, Pennsylvania; Salt Lake City, Utah; 

Birmingham, Alabama; and Reston, Virginia. Panel members visited underground 

coal mines in Utah and Alabama. 

First Meeting

The first meeting of the Panel was held on January 9 and 10, 2007, in Washington, 

D.C. At the beginning of the meeting, MSHA provided references to the Panel that 

included the Belt Entry Ventilation Review (BEVR) Report (MSHA 1989), the 

Department of Labor’s Belt Air Advisory Committee Report (Belt Air Advisory 

Committee, 1992) , the final belt air rule (MSHA, 2004) , the 2006 MINER Act, the 

Panel’s charter, and other relevant documents (a list can be found in Appendix D). 

In addition to the Panel and staff, 20 members of the public were in attendance 

during the two day meeting. 

Mr. Richard E. Stickler, Assistant Secretary of Labor for Mine Safety and Health, 

welcomed the Panel members and introduced them as part of his opening statement. 

The Panel members elected Dr. Jan Mutmansky as Panel chairman by voice vote. 

Dr. Jeff Kohler, Associate Director for Mining in the Office of Mining and 

Construction Safety and Health for the National Institute for Occupational Safety 

and Health (NIOSH), presented to the Panel a packet of information that contained 

more than 85 relevant reports and publications on belt air and conveyor belt issues. 

Many of these reports and publications were published by the former U.S. Bureau of 

Mines, NIOSH, and MSHA. 

Bill Knepp, Assistant District Manager for Technical Services in MSHA’s District 9, 

and Bill Francart, Mining Engineer at MSHA’s Pittsburgh Safety and Health 

Technology Center, made presentations on the history of the belt air issue and 

rulemaking in MSHA. Mike Kalich, a Senior Mining Engineer with MSHA’s Coal 

Mine Safety and Health Safety Division, presented a discussion of the background 

and history of MSHA's belt air final rule and issues surrounding industry 

compliance with the rule. Mark Schultz, a Supervisory Mining Engineer at MSHA’s 

Pittsburgh Safety and Health Technology Center, made a presentation on the health 

aspects of the use of belt air, specifically how the use of belt air affects dust levels in 

working sections. Harry Verakis, General Engineer with MSHA’s Approval and 

Certification Center in Triadelphia, West Virginia, gave a presentation on conveyor 

belt flammability. 
 24

Second Meeting

The second meeting of the Panel was held in Coraopolis, PA on March 28-30, 2007. 

Prior to the meeting, MSHA provided numerous documents to the Panel covering 

such topics as the use of belt air and violations related to the use of conveyor belts. 

These documents are listed in Appendix D. The agenda for the second meeting 

addressed belt flammability and toxicity research conducted by NIOSH, 

presentations by belt manufacturers, MSHA laboratory-scale flammability testing 

and belt fire historical data, belt air velocity limits, mine escape issues, comments by 

the National Mining Association (NMA), and a discussion of the 1992 Belt Air 

Advisory Committee report. A question and answer session followed each 

discussion. Twenty-three members of the public attended the three-day meeting. 

On the first day of the meeting, Mr. Timko, the Manager of NIOSH’s Dust and 

Diesel Monitoring Team, presented an overview of NIOSH research on the use of 

belt air, belt entries, conveyor belt flammability, and related issues, including 

ground and dust control and mine escape. Chuck Lazzara discussed belt 

flammability research, including large-scale gallery fire tests and laboratory-scale 

studies (e.g., the belt evaluation laboratory test, also known as the BELT). He also 

addressed fire suppression systems along belt lines. C. David Litton discussed the 

related issues of belt fume and smoke toxicity. Mr. Litton stated that smoke from a 

fire causes a visibility hazard well before a toxicity hazard develops. 

Three conveyor belt manufacturers presented information on contemporary belt 

composition, construction, testing, and flammability. The three companies were 

Goodyear, Fenner-Dunlop, and Phoenix. The conveyor belt panel included the 

following: 

- David J. Maguire, Director, Global Technology Engineered Products, The 

Goodyear Tire and Rubber Company, Akron, Ohio. 

- Geoff Normanton, Vice President, Technology, Fenner-Dunlop Americas, 

Scottdale, Georgia. 

- Brian Rothery, C.Chem M.R.S.C., Head of Development and Quality 

Assurance, Fenner-Dunlop, Europe, United Kingdom. 

- Bernd Küsel, Executive Vice President, Phoenix Conveyor Belt Systems, 

GMBH, Hamburg, Germany. 

They addressed improvements in belt quality, performance (durability), and safety 

over the past 15 years, since the publication of the 1992 Belt Air Advisory Committee 

Report. Many of the belts manufactured currently have improved flammability 

resistance that exceeds the flame test of conveyor belting specified in MSHA’s 

regulations at 30 CFR § 18.65. Over the last 15 years the flame retardant added to 

rubber materials has been upgraded. Manufacturers make thicker and stronger 

conveyor belts that are more durable. In part, this move to stronger, more flame-
 25

resistant belts has been driven by international standards that are more stringent 

than the existing MSHA standard. The BELT originally developed by the U.S. 

Bureau of Mines (USBM) and MSHA as a laboratory-scale flammability test, has 

been used as the basis of similar European standards. A more flame-resistant belt 

will still burn if there is enough coal dust and grease to start a fire. Thus, 

maintenance of the belt line is very important. 

Goodyear has not sold any belts in the U.S. that meet the BELT requirements. 

However, in order to sell conveyor belts in China, they have to meet full-scale 

gallery tests. Goodyear manufactures large quantities of these belts for sale in China. 

Fenner-Dunlop has operations in many countries that mine coal and, due to 

different standards; the products it makes can differ in flame resistance, depending 

on the market. 

Phoenix does not produce conveyor belts in the U.S. currently, yet is a major 

supplier of MSHA-accepted textile belts to the production coal fields. It also supplies 

steel cord belts for slope and drift conveyors, and has been active in the U.S. coal 

mines for about 10 years. Mr. Küsel estimated that self-extinguishing belts would 

cost 10 to 30 percent more than existing MSHA-accepted belting. Phoenix stated that 

the benefits of increased safety and better operation and performance of selfextinguishing belts compensate for their increased costs. 

 

On the second day of the meeting, Harry Verakis, Senior Projects Engineer at 

MSHA’s Approval and Certification Center (A&CC), presented information on the 

BELT method and on studies that were conducted in support of the test in the late 

1980s and 1990s. Terry Bentley, Acting Special Assistant to the Administrator of 

Coal Mine Safety and Health, presented historical belt fire data. Robert Krog, a 

NIOSH Associate Service Fellow from Pittsburgh spoke on using belt air at the face 

in three-entry mines and belt velocity limits. Dr. Fred Kissell, formerly of NIOSH, 

spoke on factors that affect escape from underground coal mines during fires. Tom 

McNider of JWR spoke on behalf of the NMA. 

On the third day of the meeting, Dr. Raja Ramani, Emeritus Professor of Mining 

Engineering at Pennsylvania State University, addressed the development and 

recommendations of the 1992 Belt Air Advisory Committee. 

Third Meeting

The third meeting of the Panel was held in Salt Lake City, Utah on May 16 and 17, 

2007. The agenda for the meeting focused on the issues of MSHA’s experience with 

belt air ventilation and ground control issues in deep Western mines. A question 
 26

and answer session followed each discussion. Twenty-five members of the public 

were in attendance. 

Prior to the beginning of the third meeting, three Panel members, Dr. Mutmansky, 

Dr. Tien, and Dr. Weeks, and MSHA staff visited the Skyline Mine and the 

Aberdeen Mine in Utah. These mines are two-entry mines that, as part of their 

granted petitions for modifications, use belt air to ventilate working sections. They 

are also deep mines, with the Aberdeen Mine reaching a maximum depth of mining 

of 2900 feet. 

On the first day of the meeting, a group of MSHA District Managers, Assistant 

District Managers, and ventilation specialists spoke about their experience with belt 

air issues and answered Panel members’ questions. MSHA staff included: 

- Kevin Stricklin, Administrator for Coal Mine Safety and Health (CMS&H), 

Arlington, Virginia. 

- Bill Knepp, Assistant District Manager for Technical Services, CMS&H 

District 9, Denver, Colorado. 

- Bill Francart, Mining Engineer at the Pittsburgh Safety and Health 

Technology Center, Pittsburgh, Pennsylvania. 

- Carlos Mosley, Assistant District Manager, CMS&H District 3, Morgantown, 

West Virginia. 

- Allyn Davis, District Manager, CMS&H District 9, Denver, Colorado. 

- Bill Reitze, Supervisory Mining Engineer, CMS&H District 9, Denver, 

Colorado. 

- Bill Crocco, Accident Investigations, Analysis and Prevention Manager for 

CMS&H, Arlington, Virginia. 

After the Panel’s questions were answered, Bill Francart reported on MSHA’s 

Aracoma Alma Mine No. 1 accident investigation and answered questions. 

 

Public input late on the first day included comments from the Bureau of Land 

Management (BLM) and the Colorado Mining Association. Jeff McKenzie and Steve 

Rigby of the Utah State Office of the BLM spoke about the responsibility of the 

agency for leasing of coal deposits that are on Federal property (referred to as 

“federal coal”) to the mine operators in Utah. There are ten operating coal mines in 

the state that have some federal coal. Of seven longwall mines, six operate under a 

two-entry system on development and retreat due to deep cover conditions that 

affect ground control. They stated that two-entry mining is the only proven safe 

method available to recover these coal reserves. 

Link Derick spoke on behalf of the Colorado Mining Association saying that 

underground coal mines have safely utilized belt air for many years. He said that 

continued use of belt air for ventilating working faces, coupled with the 
 27

improvements in atmospheric monitoring systems, only enhance miner safety. Mr. 

Derick encouraged the panel to support its continued use. 

On the second day of the meeting, Gary L. Skaggs of Agapito Associates, Inc., spoke 

at the request of the Panel concerning western mine ground control and 

convergence issues and two-entry versus other multiple-entry mining systems. 

Next to present was a group representing the Utah Mining Association, which 

included: 

 - David Litvin, President. 

 - Laine Adair, General Manager of UtahAmerican Energy. 

 - George Kenzy, Senior Mining Engineer with Arch Coal. 

 - Kevin Tuttle, Safety Manager at Deer Creek Mine of Energy West. 

 - Charles Reynolds, President and General Manager from CW Mining. 

- Wendell Christensen, Electrical Maintenance Manager from 

UtahAmerican Energy. 

 - James Poulson, a Safety Manager for UtahAmerican Energy. 

 - Gary Leaming, Safety Manager for SUFCO Mine. 

 - Carl Pollastro, Director of Technical Services for Interwest Mining. 

 - Doug Johnson, Corporate Services Director for UtahAmerican Energy. 

Dr. Hamid Maleki, President, Maleki Technologies, Inc. spoke on behalf of the Utah 

Mining Association concerning the severe ground control issues involved in mining 

coal in deep Utah mines, including a discussion on stiff, yield, and barrier pillars 

and the alternate panel-barrier gateroad system. Dr. Maleki summarized that the use 

of a two-entry yield pillar system in high bump-prone environments significantly 

reduces the risk of pillar bursting, bump-prone related roof falls, and floor heave. 

David Litvin moderated the remainder of presentations of several Utah coal 

operators who discussed the need in Utah for the continued use of the belt air twoentry system due to the deep mining depths and the surrounding geology. 

Laine Adair presented additional information on the geology of Utah and the need 

to mine using a two-entry method due to the deep cover. He summarized MSHA’s 

Two-Entry Task Force report issued in 1985, which concluded that the two-entry 

mining system with additional requirements is the safest overall design for mining 

in the Wasatch and Book Cliff coal fields. Some of the requirements included the 

use of AMS and belt air to ventilate working sections. If three-entry systems were 

used to mine these deep coal deposits, there would be better ventilation; however, 

ground control problems could result in bad roof, cave-ins, floor heave, rib 

sloughage, and compromised escapeways. A two-entry system results in 
 28

significantly improved gateroad systems. Escapeway ventilation is also better than 

if a three-entry system is used. 

George Kenzy spoke about his experience with the safety of longwall gateroad 

development as it relates to roof and rib control, ventilation, and AMS. His 

experience with both two-entry and three-entry gateroads indicates that the use of 

belt air in both mains and ingate roads has resulted in the increased use of AMS. He 

also stated rock dusting the beltlines increased dust exposures to miners in the 

working faces, unless dusting was reserved for the off shift, the idle shifts, and 

dampened curtains were used. He said that on the longwall, flooded-bed scrubbers 

were used at the crusher and on the stage loader, as well as on the section dump 

point to pro-actively control potential dust sources in these areas. The current 

generation of AMS monitors the atmosphere throughout the mine, active and 

inactive workings, and reacts quickly to any upset condition at any location 

underground. The use of sensor packages called diesel discriminators provides the 

ability to differentiate between carbon monoxide sources, whether related to diesel 

usage, cutting and welding, or fire. 

Kevin Tuttle summarized the history of legislation, petitions, and rulemaking as 

they relate to belt air usage. He stated that doing away with the belt air standard 

could put a burden on many mines using belt air either through the previously 

approved petition process or the belt air standard. The belt air standard provides 

protection when using the point-feed system. 

Charles Reynolds testified that the ground control conditions are responsible for 

bounces and bumps in his mine. Fewer entries mined results in more stable ground 

conditions, providing less potential for floor heaves, rib rolls, rib cutters, roof 

failures, overrides, and pillar bursts. He stated that his company’s studies and 

experience with many mines in Utah have shown that using belt air provides the 

following general safety improvements. First, additional air to the working face can 

increase the total air quantity in the working section and reduce leakage. This helps 

to reduce methane levels, dust, and diesel emissions. Second, the comprehensive 

AMS requirements of the two-entry petitions are much more effective in providing 

additional protection to miners at all times. Finally, the use of belt air provides two 

escapeways in intake air, rather than escaping through return air. 

Wendell Christensen discussed the maturation of AMS technology. Mine monitoring 

systems have matured from initial carbon monoxide and methane sensors 25 years 

ago to systems that now interface with environmental monitors, powerline 

communication equipment, and processors to monitor and control the mine. This 

includes state-of-the-art graphical interfaces, fiber optic trunk lines, and radio and 

wireless technology that can monitor more than 32,000 points in a single mine. He 

emphasized that current systems now include continual self-diagnostic capabilities. 
 29

The system monitors its own status and reports if there are any problems with it. 

The mine-wide monitoring system also has the ability to control devices 

underground, stopping conveyor belts and removing electrical power from selected 

areas. The system is monitored by an individual trained to respond to alarms, and to 

analyze conditions that may indicate possible problems before they have a chance to 

escalate into alarm conditions. 

James Poulson emphasized that the elimination of the belt air standard would be 

adverse to the safety of Utah’s underground miners. He stated that from a safety 

perspective, overall miner safety is improved when belt air can be used at the 

working face, due to the control of ground conditions, dust, and dangerous gases. 

Operators who want to use two-entry mining systems must file petitions to modify 

the existing standard. If granted, these petitions obligate the operator to implement a 

number of additional requirements. 

 

Gary Leaming described the practice of ventilating working sections using belt air. 

He said that using belt air increases quantities of air reaching the working face 

without greatly increasing pressure on the ventilating system. He added that using 

the belt entry as an intake air source provides a second intake escapeway which is 

more valuable than a return escapeway in the event of an emergency. Many mines 

also supply firefighting water to their working sections through the belt entry. 

Hooking up and routing fire hoses is safer and accomplished quickly in a smokefree atmosphere, which intake air more than likely will provide. 

Carl Pollastro spoke on the ability to maintain a gateroad that is safe and effective 

for both development and retreat mining depending on the use of either a two- or 

three-entry development. His conclusion was that with two-entry development the 

mine can be maintained in a safer condition than with three-entry systems because 

multi-seam mining involves severe ground control issues since the top seam is 

mined first followed by deeper seams that are mined in sequence. 

 

Doug Johnson addressed the ventilation aspects of two-entry gateroads and belt air 

at the face. He outlined the following five points as the advantages of two-entry 

mining in Utah. First, two-entry development has proven itself over more than 50 

years as a successful way to mine the deep reserves in Utah. Second, using belt air is 

an important component of two-entry mining. Third, modern AMS systems are 

reliable, dependable, and comprehensive. Fourth, the existing belt air requirements 

result in a safe and healthy environment for underground miners, if the rules are 

followed. And finally, the use of belt air, if systems are properly maintained and 

operated, offers benefits in the event of a fire due to increased fire-fighting 

capabilities. 
 30

Fourth Meeting

The fourth meeting of the Panel was held in Birmingham, Alabama, on June 20 and 

21, 2007. The meeting in Birmingham included discussions on AMS, including belt 

fire detection sensors and state-of-the-art smoke sensors. A question and answer 

session followed each discussion. Thirty-seven members of the public were in 

attendance. 

Prior to the beginning of the fourth meeting, three Panel members, Dr. Brune, Dr. 

Calizaya, and Mr. Mucho, and MSHA staff visited the Jim Walter Resource's No. 4 

Mine. This mine was one of the first mines to use belt air to ventilate working 

sections under a petition for modification granted in 1979. 

On the first day of the meeting, a panel of AMS manufacturers gave presentations 

and answered questions asked by Panel members. These manufacturers included: 

- David Graf, Manager of Business Development, American Mine Research 

(AMR). 

- Bob Saxton, General Manager, AMR. 

- Jim Gunnoe, Engineering Manager, AMR. 

- Doug Coon, Sales and Engineering Director, Pyott-Boone Electronics. 

- Al Ketler, President and CEO, Rel-Tek Corporation. 

 - Rob Albinger, Vice President, Conspec Controls. 

These manufacturers discussed the systems they make, sell, and install in 

underground coal mines. Currently Rel-Tek and Conspec systems can use an 

Ethernet connection and fiber optic cable. This allows the use of off-the-shelf 

software packages. Two of the companies have ionization smoke monitors, and two 

of them are researching the use of a photo-electric smoke monitor. 

A couple of different variations of smoke monitors exist: a regular stand-alone 

smoke monitor and a carbon monoxide/smoke combination monitor that uses 

ionization technology. The companies also make diesel discriminating and 

hydrogen discriminating sensors to reduce the incidence of nuisance alarms from 

diesel equipment or electric charging stations, respectively. In response to a Panel 

question concerning which sensor provides better early detection, a manufacturer 

stated that generally, a smoke sensor is a good alternate fire detection device for belt 

entries. A manufacturer stated that a combination of sensors would be better than 

either because the system would have the benefits of both. There's an additional 

cost because there are two sensors, two channels (Input/Output), and two telemetry 

events. 
 31

A manufacturer stated that based on its testing and communication with customers, 

smoke sensors, regardless of type (ionization or optical), can be either unreliable or 

maintenance nightmares. A Panel member responded that from NIOSH experience, 

all optical sensors have issues with mine dust, float dust, and rock dust. Belt entries 

tend to be heavily rock dusted. That is a problem in any optical system. If rock dust 

gets into the system, the system can compensate to a certain degree; however, the 

receptor elements will eventually clog up and need to be cleaned. 

The manufacturer stated that air moving at 50 feet per minute could take, depending 

on the location of the fire, up to 20 minutes to reach a sensor. The sensors can detect 

a fire before flame appears. Furthermore, hydrogen, methane, carbon monoxide, 

carbon dioxide, and oxygen are all odorless and tasteless gases. The sensors could 

already be in alert or alarm status by the time miners smell the products of 

combustion. 

All manufacturers agreed that qualified people are needed to operate and maintain 

the monitoring system. One stated that probably 10 to 20 percent of mines are 

probably having difficulty in maintaining their AMS the way manufacturers would 

like to see them maintained. 

After the AMS manufacturers completed their discussions, personnel from Jim 

Walter Resources (JWR) gave presentations on the JWR Mine No. 4 tour, JWR Mine 

No.4 Mine belt air issues, and JWR’s AMS. The panel from JWR included: 

- Tom McNider, General Manager for Mining Engineering for JWR. 

- Keith Pylar, Safety Associate at Jim Walter Resource's No. 7 mine. 

- Randy Watts, Manager of Electrical Engineering for JWR. 

Tom McNider stated that the use of belt air in eastern mines is primarily due to the 

need for increased ventilation for methane and dust control. Although JWR’s mines 

have been using degasification systems for years, there is still a great need to use all 

available air courses to carry as much intake (ventilation) air to the working face. 

JWR’s No. 7 mine operates two fans in parallel on each return shaft in order to 

provide adequate ventilation to control the remaining methane liberation. All the 

mines that operate in Alabama’s Blue Creek seam use belt air at the face. The 

amount of air that is needed in these mines requires large pressure differentials from 

intake to return, using all available air courses. To restrict the ventilation on the belt 

air course with a regulator such as a bulkhead would create high air velocity across 

the bulkhead and creates a float dust and respirable dust problem. Also, restricting 

the belt air course pressurizes it and creates leakage from the belt to the primary 

intake escapeway, potentially contaminating the escapeway. 
 32

Mr. McNider stated that strata control is a secondary issue to ventilation in eastern 

coal mines. The most effective way to ventilate gassy mines that require large 

quantities of air is to use all available air courses and have positive, one-way 

ventilation on the belt. Respirable dust on the belt lines, another concern in high 

velocities, has not been a problem at JWR’s mines and can be controlled through 

water sprays and proper chutes. 

Keith Pylar testified that he believes that coal mining that uses belt air to ventilate 

working faces is safe. An advantage to using belt air is that the JWR mine-wide 

monitoring system has been able to detect smoldering situations, bearings going out 

on rollers, hot rollers, and unaligned belts well before a fire develops. Early 

detection, notification of affected miners, and action to address the problem 

enhances the safety of the miners at the mine. The other advantage of using the belt 

air on the face is that even though it is not dedicated as an escapeway, it gives 

miners another intake entry to use to get out of the mine in an emergency. 

Randy Watts stated that JWR’s early experiences with AMSs caused the company to 

design, seek and obtain MSHA approval of their own AMS. Their system uses 

JWR-generated software and fiber optic cable. The system is fast and tolerant to 

noise. It uses a structured query language (SQL) database to store information. 

Underground hardware includes an individual address for each device. A complete 

scan of every address on the system is performed every one or two seconds. Sensor 

readings are scanned every one and a half seconds, as is the status of each sensor to 

assure that they are working as they're designed. The system has built-in 

redundancy, with two computers running in parallel at all times, with one computer 

doing all of the scanning. JWR uses the term "Mine-Wide Monitoring System," rather 

than just "AMS system" because the system not only monitors atmospheric 

conditions; but also much of the other equipment in the mine. The AMS screen 

continuously shows the status of all the carbon monoxide sensors on all the 

underground belts. 

Mr. Watts also stated that the system would not be effective if it were not for the 

people who monitor and maintain the system. In their control room, AMS operators, 

are all experienced miners and certified foremen, and have all the tools they need, 

including the mine map, computers, video, two-way communications, and access to 

the technicians that they need at any time to assure that the system operates 

correctly. These technical personnel address any problems that the AMS operators 

may have; therefore the AMS operators do not have to know how to troubleshoot 

the system. 

JWR supports a higher specification belt, but it must meet the operational needs of 

the mines and be durable enough to withstand the rigors of underground use. They 

currently use a National Coal Board NCB 158 belt. Before this belt, JWR primarily 

used a PVC belt, which was not as durable and did not perform adequately. In 1992, 
 33

the BELT specification was proposed, and JWR tried a higher grade belt. It was a 

rubber belt with a specific compound added to meet the BELT flame-resistant 

specifications. That belt also had an operational problem; there were numerous 

points where the belt would run out of alignment and create shavings that would 

drop onto the footwall and result in AMS alarms, an operational hazard. 

The National Mining Association (NMA) and Alabama Coal Association panel 

included the following individuals: 

- Bruce Watzman, Vice President of the NMA. 

- Pramod Thakur, Manager of Coal Seam Degasification for CONSOL Energy. 

- David Decker, General Manager of the Brooks Run Mining Company. 

- Patrick Leedy, Manager of Engineering for Lone Mountain Processing, 

Incorporated. 

- Greg Dotson, Mine Manager at Mingo Logan Coal Company. 

- Bill Olsen, Safety Director at Mountain Coal Company's West Elk Mine. 

- Jim Poulson, Manager of Safety at Utah American Energy, Inc. 

- Gary Hartsog, President of Alpha Engineering Services. 

Bruce Watzman stated that belt air has been, and continues to be, a safe practice to 

improve the working conditions for miners at the face. He said that operators 

demonstrated at the Salt Lake City meeting the absolute necessity and safety 

advantages of using belt air to reduce the number of injuries and to sufficiently 

dilute, render harmless, and carry away methane and dust from the working face in 

two-entry mines. JWR and other mine operators have demonstrated that the use of 

belt air is equally essential to control methane and dust where ventilation resistances 

preclude doing so in its absence. 

Dr. Pramod Thakur stated that belt air traveling in the same entries as water flow 

provides a safer and faster access to water lines in an emergency. He concluded that 

belt air should be used to ventilate working faces because it makes underground 

coal mining and escape from longwall face fires much safer.

David Decker stated that the ability to use belt air to ventilate active faces provides 

flexibility that enhances mining in a mature coal field. The use of belt air allows the 

company to minimize roof control issues associated with greater entry widths and 

number of entries, by using the belt entry to provide a greater overall volume of air 

with fewer entries. There is also more air pressure at the face, less total pressure, less 

leakage between airways, and a better ventilation balance. In conjunction with the 

use of AMSs, it is a safe way to ventilate coal mines and provide a higher pressure 

and volume where it's needed the most, at the mine face. 
 34

Patrick Leedy also spoke about the issues involved with multi-seam mining. He 

stated that this was an important reason to allow belt air to be used at the working 

face.

Greg Dotson stated that belt air gives additional air to help dilute the methane and 

harmful gases and it enhances their ventilation system, helps mines overcome 

geologic challenges, and is safe when used with AMS. 

Bill Olsen supported the comments from the NMA, Colorado Mining Association, 

Utah Coal Operators, and the Alabama Coal Association and their member 

companies. Mr. Olsen’s mine experiences deep cover, high horizontal stress, faults, 

spars, and multi-seam mining. Two of the most difficult challenges are maintaining 

methane concentrations at acceptable levels and reducing the potential for 

spontaneous combustion throughout the mine. Fan pressures would have to be 

increased to over 15 inches water gauge in order to maintain an equivalent air 

quantity in the section. Mr. Olsen stated his belief that the increased pressure 

differential, specifically across the pillars and gobs, increases the likelihood for 

spontaneous combustion to occur as the air passes through the natural cleats and 

fractures of the pillars and within the caved area where there is a demonstrated 

history of spontaneous combustion. AMS sensors detect fires at the incipient stages 

as compared to point-type heat sensors still used in mines where belt air is not used. 

Mr. Olsen stated that fire fighting capabilities in the belt entry are enhanced when 

belt air is used. Use of belt air allows fire fighting to be conducted from the upwind 

side with the air flow and water flow in the same direction, minimizing the potential 

for damage to the water supply line. It also allows for the alternate escapeway to be 

ventilated with intake air, rather than using a neutral or return air split for 

escapeway purposes. He also stated that methane levels and the potential for 

spontaneous combustion have been reduced by the use of belt air. 

Jim Poulson stated that ground control, dust control, dilution of dangerous gases, 

and overall miners' safety are improved when belt air is used at the working face. 

He also provided dust sampling data and comparisons of two-entry mining systems 

to multiple-entry mining systems, including the following chart compiled by the 

Utah mine operators, which demonstrates the reduction in reportable roof falls per 

1000 feet for two-entry versus three entry gateroads in Utah mines . 
 35

Comparison of Two-Entry vs. Three-Entry Gateroads 

 No. of Reportable 

 Reportable Roof Falls 

Mine Name No. Entries Feet of Gateroads Roof Falls per 1000 feet 

Skyline Mine No. 2 2 43,110 0 0.000 

Skyline Mine No. 3 2 24,596 0 0.000 

Cottonwood 2 99,453 9 0.090 

Trail Mountain 2 106,019 5 0.047 

Deer Creek 2 362,635 3 0.008 

West Ridge 2 91,074 0 0.000 

Aberdeen 2 99,211 0 0.000 

Crandal l 2 83,686 0 0.000 

South Crandall 2 12,145 0 0.000 

 Total 921,929 17 0.018 

Skyline Mine No. 1 3 293,058 16 0.055 

Skyline Mine No. 2 3 226,723 21 0.093 

Skyline Mine No. 3 3 226,723 25 0.110 

West Ridge 3 0 0 0.000 

Aberdeen (at > 1,500” cover) 3 0 0 0.000 

Crandall (at > 1,500” cover) 3 0 0 0.000 

South Crandall 3 3,793 0 0.000 

 Total 749,696 62 0.083 

Gary Hartsog stated that the use of belt air is important, and sometimes critical, to 

the coal mining industry. He stated that the use of belt air is not for every mine. It is, 

however, an extremely important tool and an option that needs to be available with 

proper monitoring and safeguards for all mines, and most especially for those mines 

with the more difficult conditions and greater distances to ventilate. 

Mr. Hartsog also stated that longwall gate development consists of driving three- or 

four-entry gateroads for some distance until a block of coal has been isolated for 

mining with the longwall. These gateroads can become difficult to ventilate, 

especially if there is significant methane liberation. The use of belt air in the 

working face allows leakage to be minimized between the intake and the belt entry 

and more intake air to be delivered to the working faces. 

During the public comment phase on the first day of the meeting in Birmingham, 

Dave Maguire, the Director of Technology for Goodyear Engineer Products, 

reported to the Panel the results of research on submitting Goodyear’s halogen-free 

and halogenated belts to flame-testing using the BELT standard. Mr. Maguire also 

reported on smoke density and toxicity of the gases and particulates emitted during 

the flame tests. 
 36

On the second day of the meeting, C. David Litton of NIOSH gave a presentation on 

belt fire detection sensors and state-of-the-art smoke sensors. He recommended that 

mines that do not use diesel equipment could install simple inexpensive smoke 

detectors. 

Launa Mallett of NIOSH’s Pittsburgh Research Laboratory provided information on 

effective training techniques for emergency response preparedness (specifically for 

AMS operators and in general terms for all underground miners). Dr. Mallett stated 

that emergency decision-making involves the following steps: detection of the 

problem, definition/diagnosis, consideration of options, choosing from options, and 

execution of the decision. She stated that the process is impacted by miners’ skills, 

knowledge, and attitudes, uncertainty, stress, and the complexity of the situation. 

Lastly, she outlined the potential content for Emergency Response Training, which 

should include routine functioning of the system, diagnosing non-routine situations, 

giving and receiving emergency warnings, and the impact of stress during and after 

emergencies. 

The United Mine Workers of America (UMWA) panel included the following 

speakers: 

- Joe Weldon, Chairman of the Safety Committee for Shoal Creek Mine, 

Drummond Coal Company 

- Dwight Cagle, a union miner at JWR’s No. 7 Mine, 

- Larry Turner, UMWA safety representative at the JWR No. 4 Mine, 

- Glen Loggins, UMWA Safety Committee member for JWR’s No. 4 Mine, and 

- Tom Wilson, UMWA International Representative. 

Mr. Weldon spoke about the duties of AMS operators at his mine. The AMS 

operators do far more than just monitor the AMS. AMS operators receive calls on a 

number of issues that are unrelated to the operation and monitoring of the AMS. 

They also have to monitor the operation of the fans at the mines and receive calls on 

the mine pager phone with people traveling to and from different areas of the mines. 

He also said that if there is an accident in the mine, the AMS operator notifies the 

paramedics and the ambulance service or the Medevac. The AMS operator also 

monitors the carbon monoxide sensors and relays any messages to the proper 

people. Mr. Weldon stated the UMWA position that a mine needs a responsible 

person whose sole job is to monitor the AMS to ensure the health and safety of each 

and every person in this mine and who is trained and certified to do so. This action 

would result in a reduction of miners’ exposure to smoke or gas is in the mines in 

the event of a fire or an explosion. Also, the withdrawal time would be less, and the 

probability of someone surviving these events would be greater. 
 37

Mr. Cagle spoke on training, maintenance, and fire prevention. He stated that the 

best AMS in the world is useless and will not benefit the miners unless it is properly 

installed, monitored, and maintained. At his mine, the AMS operators are carbon 

monoxide technicians. Each AMS operator is also a responsible person under 

MSHA’s standards. Mr. Cagle also said the UMWA would like to see an additional 

person employed to assist with the duties assigned to the AMS operator positions, 

because one person can not handle all of these tasks. He also thought that more 

AMS operators should be required due to the use of belt air, fire-resistant belts, and 

the installation of more sensors. 

 

Mr. Turner addressed the number of citations for float coal dust accumulations. 

JWR mines have crews that are dedicated to cleaning the belt lines; but, for a variety 

of reasons, high levels of dust occur. He stated that there should be stricter 

regulations on how much air could be on a particular belt taking air to working 

sections and that citations be increased if there is a pattern of violation. Also, he 

stated that AMS sensors should be installed along all belts, not just those that take 

intake air to the working sections, and that since the monitoring systems are not 

perfect, then other requirements need to be put into place such as flame-resistant 

belt material, and placement of sensors through the mine for optimal monitoring. 

Mr. Loggins stated that there is a need for more training on how to evacuate mines 

expeditiously. The current rule requires that when an alarm occurs, work crews are 

to retreat outby the alarming sensor. He stated that the fire could be outby that 

sensor due to the required 1000 foot spacing and that when an alarm occurs, miners 

should be trained to evacuate all the way to the surface. He stated that all miners, 

AMS operators, and foremen need training in this area. 

Mr. Wilson spoke on issues surrounding the safe use of belt air to ventilate working 

faces since its use can expose miners to the following hazards: products of 

combustion, reduced number of escape routes, and higher levels of respirable dust 

and methane. Mr. Wilson stated that if these hazards are not controlled, the use of 

belt air reduces the protection afforded miners under the existing rule. He stated it 

was essential to control fuels, sources of ignition, and air to prevent fires to ensure a 

means of detecting and controlling fires should they occur and a means to escape. 

He stated that some of these conditions can be controlled, but not eliminated, by 

using flame-resistant belts and lubricants, by monitoring and controlling methane, 

and removal of combustibles. He stated that the Panel address the following 

recommendations: flame-resistant belts and lubricants, noncombustible standing 

roof support, better design of belt headers and transfers, improved automatic fire 

suppression systems, assure required belt maintenance, increased dust controls, 

existence of physical and pressure separation between the intake escapeway and the 

conveyor belt entry, standardized installation of AMS components (including the 

actual location of sensors), and training. 
 38

Public comment was provided by Mr. Bruce Levinson of the Center on Regulatory 

Effectiveness and Mr. Dale Byram of Jim Walter Resources, Inc. 

Mr. Levinson discussed how other agencies’ standards address the issue of flameresistance and smoke. These agencies include the Federal Railway Administration, 

the Federal Aviation Administration., the National Aeronautics and Space 

Administration, the State Department, the Department of Energy’s Sandia National 

Laboratory, and the Department of the Navy. These agencies use both flameresistant and smoke-density standards; such as ASTM 162 and E662a. Materials 

used by these agencies are required and tested to be self-extinguishing and nonpropagating. Also, a variety of countries; including, Australia, France, Italy, Japan, 

Korea, New Zealand, and the United Kingdom have all moved to halogen-free 

materials in cable construction. The U.S. standards are weaker than almost all other 

international standards in addressing three issues: fire resistance, smoke density, 

and toxicity. 

 

Mr. Byram spoke to clarify the duties and responsibilities of AMS operators and 

miners who work for Jim Walter Resources. After the AMS operator is notified of an 

emergency, a salaried support person is made available to handle all other calls and 

business while the AMS operator focuses strictly on dealing with the emergency. 

Fifth Meeting

The fifth, and final, meeting of the Panel was held in Reston, Virginia on September 

17-19, 2007. Twelve members of the public were in attendance. The panel 

discussed 21 draft recommendations. The Panel ended the meeting with 20 final 

recommendations. All 20 final recommendations were passed by a unanimous 6-0 

vote. These recommendations and their supporting discussions are contained in 

section V of this report. 
 39

IV. THE PANEL AND SUBCOMMITTEE WORK AGENDA 

The Panel began the decision-making phase of its activity in a closed meeting held 

following the conclusion of the public meeting in Birmingham, Alabama. At that 

time, the Chairman presented a list of suggested topics to be considered by 

subcommittees. These topics were as follows: belt fire-resistance certification 

requirements, other belt testing requirements (friction tests, static charges, etc.), 

maintenance requirements on belts, coordination of belt testing requirements with 

other mining countries, sensor technology assessment, sensor spacing, smoke 

density monitor utilization, fire vs. diesel discrimination, early warning system 

design, AMS operator training, use of belt air at the face (yes or no), review of belt 

air petitions, primary escapeway static pressure, belt and track in single or separate 

airways, leakage issues, lifeline requirements, dust and gas control at the face, 

escapeways, minimum/maximum velocity, early warning system training, SCSR 

training, MSHA/NIOSH cooperation, communication systems improvement, and 

SCSR improvements. 

These topics were organized into five categories. The Panel discussed the topics and 

decided to reduce the number of topics to be considered because some of the topics 

were considered to be outside the scope of the Panel’s charge. The Department of 

Labor solicitors aided the Panel in defining the scope of the charge and made 

suggestions to help the Panel focus on the topics to be addressed. This resulted in 

the topics being arranged into four categories. The Chairman then made 

suggestions as to who would serve on each subcommittee and who would serve as 

the Chairman of each subcommittee. All decisions as to subcommittee makeup and 

the chairman of each subcommittee were made by consensus. The initial decisionmaking was conducted in three-person subcommittees. The four subcommittees 

and the members of each subcommittee are provided below with the chairman of 

each subcommittee listed first: 

(1) The Belt Characteristics Subcommittee (T. Mucho, J. Weeks, and J. Brune) 

(2) The AMS Technology Utilization Subcommittee (T. Mucho, J. Weeks, and J. 

Brune) 

 

(3) The Ventilation Issues Subcommittee (J. Mutmansky, F. Calizaya, and J. Tien) 

(4) The Training Subcommittee (J. Mutmansky, F. Calizaya, and J. Tien) 

Much of the work in the subcommittees was conducted via e-mail with the chairman 

of each subcommittee setting the agenda and the order in which topics were 

considered. The suggested topics for each of the subcommittees was advisory only 

and the individual subcommittees used their discretion to add, alter, or combine 
 40

topics within their subcommittee’s list. The subcommittee members were permitted 

to contact members of the Panel outside their subcommittee on a person-to-person 

basis to ask questions or request data. This discretion was exercised a number of 

times to allow for a free exchange of data and technical information. 

During the process of subcommittee deliberations, the Designated Federal Officer 

and members of the MSHA staff were contacted numerous times to request data on 

mining operations, safety statistics, publications from the MSHA and NIOSH 

libraries, opinions of the Department of Labor solicitors, and interpretations and 

opinions of the MSHA technical personnel. All requests of the Panel were 

addressed promptly. 

The work of formulating and voting on recommendations was completed within the 

subcommittees over a period of about eleven weeks. The Chairman of the Panel 

encouraged the members of the subcommittee to work toward recommendations 

that could be presented to the entire Panel with unanimous support of the 

subcommittee. All recommendations presented to the Panel on September 17, 2007, 

came with the full support of the subcommittee members. 

As part of the subcommittee duties, the subcommittee chairman appointed one 

member of the committee to write a discussion section that outlines the 

recommendation’s logic and provides supporting arguments and documents that 

pertain to the recommendation. These discussion sections were then circulated to 

the subcommittee members to gather their comments and provide a discussion that 

would satisfy each member of the subcommittee. 

When the subcommittee work was completed, 21 recommendations were forwarded 

for consideration of the entire Panel. From September 17 through September 19, the 

Panel completed its final meeting in Reston, Virginia. The Panel initiated discussion 

of all 21 recommendations, one at a time. In each case, the member of the Panel who 

wrote the discussion section for the recommendation presented the arguments in 

favor of the recommendation and answered questions presented by other members 

of the Panel. Refinement of the wording of the recommendations was common. In 

addition, some of the recommendations were combined to satisfy Panel members 

and to move toward unanimous concurrence. In the final voting on the first two 

days of the meeting, 20 recommendations were passed by the Panel, each with a 

unanimous 6-0 vote of the Panel in favor of the recommendation. On the third day 

of the meeting, the Panel reworked the discussion sections to reflect the opinions of 

the Panel and to strengthen the logic of each recommendation. The entire transcript 

of the final meeting in Reston is available on the MSHA website 

(http://www.msha.gov/BeltAir/BeltAir.asp). The recommendations of the Panel 

and the discussions of each recommendation are presented in the next section of this 

report. 
 41

V. OUTLINE AND DISCUSSION OF PANEL RECOMMENDATIONS 

This section of the Report presents the 20 recommendations passed by the Panel and 

the discussions in support of each recommendation. It is not meant to be exhaustive 

of all Panel discussion of the recommendations. The reader is referred to the 

transcripts of the Panel meetings for the full discussion by the Technical Study 

Panel. The Panel emphasizes that the discussion portion of the report should carry 

equal weight with the captioned portion of the recommendations and cautions 

against using isolated statements taken out of context and altering the intent of the 

Panel. 

Readers of this report should note that the references cited in the Discussion section 

of each Recommendation are provided immediately after the Discussion for 

convenience purposes. The references at the end of the report are all of the materials 

provided to the Panel for study. 
 42

THIS PAGE LEFT BLANK 
 43

RECOMMENDATION NUMBER 1 - CONVEYOR BELT FLAMMABILITY 

TESTING AND APPROVAL 

The Technical Study Panel strongly recommends that MSHA move post-haste to 

revise (as suggested elsewhere in this report) and re-propose and implement the 

Proposed Rule - Requirements for Approval of Flame-Resistant Conveyor Belts 

(Federal Register, Dec. 24, 1992, Vol. 57, No. 248) that was withdrawn in 2002 

(Federal Register, July 15, 2002, Vol. 67, No. 135). The objective is to significantly 

reduce the frequency and hazard of conveyor belt fires in mines that elect to 

course belt air to the working face. The Panel believes that current requirements 

for testing and approval of flame-resistant conveyor belt have proven to be 

outdated and inadequate to provide an acceptable level of flame resistance and, 

therefore, safety for U.S. miners, based on both the historical record of conveyor 

belt fires in the U.S. and in comparison to general standards of the global 

mining community. 

Discussion 

Preventing Belt Fires 

Section 303(y)(1) of the Mine Act of 1977, an interim mandatory safety standard for 

underground coal mines, provided that entries with conveyor belts should not be 

used to ventilate working places. The rationale behind this prohibition is that if 

there is a fire in a belt entry, the products of combustion will go directly to the face 

area where miners work and it will contaminate the belt entry as a potential 

escapeway. 

Inadequate maintenance is a contributing factor to the occurrence of belt fires, 

resulting in the accumulation of fuels and creation of sources of ignition. The most 

common source of ignition is frictional heating. It can occur if idler rollers seize or if 

the belt becomes misaligned. There are thousands of load-bearing rollers for each 

mile of belt and if any one breaks or seizes, a belt continuing to pass over the roller 

can cause frictional heating. Frictional heating has also occurred if belts become 

misaligned and rub against adjacent structures, rib, roof, or floor. Heat generated by 

friction may be sufficient to ignite grease, accumulated coal dust, or other 

combustible materials. When the belt stops, there may be sufficient heat to ignite the 

belt itself. Other sources of ignition include sparks from welding or from 

malfunctioning electrical equipment. Fuel for combustion can be the belt, coal or 

coal dust, lubricants, or other combustible materials such as wood, trash, etc. 

Poor maintenance on the belt and of the belt entry itself is an important underlying 

cause of fires on belt entries in other ways too, contributing both fuels and sources of 

ignition. Since freshly cut coal is carried by the belt, float coal dust is common in 
 44

belt entries. If it is not removed on a regular basis, it may become fuel for a fire. 

Other combustible materials may accumulate. If the ribs of a belt entry are not 

adequately rock-dusted, the coal that constitutes these ribs may also ignite. 

Citations for such violations (e.g., accumulation of combustible materials, 

inadequate belt maintenance, failure to rock-dust, and others) are common. 

Accumulation of combustible materials (30 CFR § 75.400) was, in fact, the most 

frequent of all citations in 2006. The numbers of citations for violations pertaining to 

belt maintenance in 2006 were as follows: 

 CFR Section Belt Maintenance Related Violation No. of Citations

 75.400 Accumulation of combustible materials 8201 

 75.1104 Accumulation of combustible materials 599 

 75.1725 (a) Machinery & equipment 1566 

 75.402 Rock dusting 197 

Criteria for New Standards under the Mine Acts of 1969 and 1977 

The interim mandatory standard that prohibited the use of belt entries for 

ventilating working sections (Sec. 303 (y)(1)) was intended to prevent smoke from 

belt fires from reaching the face areas where miners work. Prior to MSHA's 

promulgation of its final belt air rule, mine operators petitioned to modify this 

standard in order to use belt entries for face ventilation. Most of these petitions 

were granted. Then in 1988, MSHA proposed a rule that would modify much of the 

ventilation standards for underground coal mines and included provisions for the 

use of belt air under limited conditions (MSHA, 1988). This culminated in a final 

rule in 2004 (69 Fed. Reg. 17480, April 2, 2004). Did this rule satisfy the requirements 

of Sec. 101 (a)(9) of the Mine Act? It is not the purpose of this Panel to answer that 

question. Indeed, the District of Columbia Court of Appeals rejected the UMWA 

challenge to MSHA’s final rule allowing operators to use belt air to ventilate 

working sections and rendered a decision that, " . . . the Secretary compared the 

safety of the work environment created by compliance with the new Belt Air Rule 

with the previous interim standard . . . [and] MSHA followed with a section-bysection analysis to demonstrate that through new technological advances and the 

interrelationship between the various existing and new standards under the new 

Belt Air Rule, the new rule maintained or improved miner safety." International 

Union, United Mine Workers of America v. Mine Safety and Health Administration, 407 

F.3d 1250, 1256 (May 24, 2005). Nevertheless, the statutory requirements provide a 

useful framework for discussion. 

Section 101(a)(9) of the Mine Act prohibits any new standard from reducing the 

protection afforded miners by the existing standard. In this case, the standard that 
 45

was superseded was the interim mandatory standard in the Mine Act that prohibits 

the use of a belt entry from ventilating active working places (Section 303(y)(1)). The 

purpose of this prohibition is to prevent smoke from a fire in a belt entry from 

reaching the working section. While the MSHA rule (30 CFR §§ 75.350-351) requires 

improved methods of fire detection and thus improves the rapidity of fire 

suppression, it does little to prevent fires in belt entries and thereby, little to prevent 

smoke from contaminating a working section. Accordingly, we make several 

recommendations that are designed to prevent fires in belt entries: improve the 

criteria for testing and accepting flame-resistant belts, add a drum friction test for 

accepting belts, and improve maintenance in belt entries. These are all discussed in 

more detail in this and in other sections. Elsewhere, we also suggest that if a mine 

operator intends to use a belt entry to ventilate a working section there should be 

specific gains in mine safety to offset the loss inherent in allowing smoke from a belt 

fire to be carried to a working section. 

Preventing Fires in Belt Entries by Using Fire-Resistant Belts 

In a belt entry, there are abundant sources of fuel (coal, the belt, trash, lubricants, 

wood posts), sources of ignition (frictional heating, sparks from welding or 

malfunctioning electrical components) and an abundant source of air. That is, the 

belt entry has all the necessary and sufficient conditions for a fire to occur. Yet 

with this knowledge, it is also possible to prevent fires in belt entries by applying the 

conventional approach to fire prevention, i.e., by removing fuel, sources of ignition, 

or oxygen. 

One such application is to require that belts be fire or flame resistant. The current 

test protocol for evaluating belt material for flammability is described in 30 CFR 

§ 18.65. It is commonly referred to as the 2G test because it was previously part of 

Schedule 2G (Verakis, 1993). Though its date is listed as 1968, it derives from a test 

protocol developed in 1955 as Schedule 28(3) (Verakis, 1989; USBM, 1955; Polack, 

1956). This was confirmed by testimony provided to this Panel (see Pittsburgh 

transcript on the MSHA website). Presently, the 30 CFR § 75.1108 requires that “On 

and after March 30, 1970, all conveyor belts acquired for use underground shall meet 

the requirements to be established by the Secretary for flame-resistant conveyor 

belts.” 30 CFR § 18.65(d) specifies the laboratory testing procedures for conveyor 

belt material fire resistance. 

The current Schedule 2G testing for fire-resistant belting is performed using small 

belt samples 6 inches long by 0.5 inches wide. A sample is positioned horizontally 

in a test cabinet, with the transverse axis inclined at 45 degrees. One end is exposed 

to the flame from a Bunsen type burner in still air. After one minute, the burner 

flame is removed and a ventilating fan turned on to provide an air current of 300 

fpm. The duration of the belt sample flame and afterglow is measured. A belt 
 46

passes the test if 4 samples of the same belt do not exhibit either duration of flame 

exceeding an average of 1 minute, or duration of afterglow exceeding an average of 

3 minutes. 

 

In developing Schedule 28(3), the Bureau of Mines reviewed tests for fire resistance 

used in the UK, Germany, France, and the Netherlands as well as tests by DuPont, 

the Rubber Manufacturers Association, and the American Society for Testing 

Materials (Standard D635-44) and in the end, adopted the ASTM test with some 

modifications. The criteria for making this selection were not described, and there 

was no reference to its relevance to in-mine conditions. Although the Bureau of 

Mines evaluated a drum- friction test, as used by the British National Coal Board, it 

was not included in the final test protocol (Polack, 1956). 

It is reasonable to expect that if a belt is “fire-resistant,” it should not burn in an 

underground mine. By this criterion, the 2G test has not been successful. Belt fires 

have persisted and are well documented in underground coal mines from at least 

1970. The frequency of fires in haulage entries (track, trolley, and belt entries) was 

assessed in 1990 (Luzik and Desautels, 1990) to aid in the construction and 

placement of water lines in underground coal mines. Of the 293 mine fires reported 

from 1970 to 1988, 65 (22%) occurred in belt entries. During this time period, there 

was a transition from track haulage to belt haulage and, as a result, fires in belt 

entries became more numerous in the second half of this time period compared to 

the first half. Of the fires in belt entries, 22 (34%) occurred as a result of frictional 

ignition, and the causes of 18 (28%) were unknown. 

A similar report was prepared in 2004 in order to provide MSHA and NIOSH with a 

“ ... better understanding of the causes and hazards of mine fires ... ” (DeRosa, 

2004). From 1990 to 1999, there were a total of 87 reported fires in underground coal 

mines. These fires were classified in a variety of ways including by the source of 

ignition and by the burning material, both of which are pertinent to an assessment of 

belts as a source of ignition and as a fuel. Of these fires, 15 (17%) resulted from 

frictional ignition and for 13 (15%), the belt itself was the principal fuel. The 

proportion that occurred as a result of frictional ignition was slightly less than the 

proportion reported from 1970 to 1988 (17% vs. 22%). 

In neither of these reports did the investigators mention the belt material, whether 

natural rubber, synthetic rubber (styrene-butadiene [SBR]), chloroprene (neoprene), 

or polyvinyl chloride (PVC) or the fabric core. In all cases, belts were accepted as 

flame-resistant. As part of the investigation of mine fires, sections of the affected 

belt are tested again for flame resistance. 

In addition to these demonstrable shortcomings, engineers at the Bureau of Mines 

criticized the 2G test for its lack of similarity with in-mine conditions as early as 1967 
 47

and developed a testing protocol in its experimental mine and in an experimental 

gallery. (Mitchell et al., 1967). The gallery test was conducted using a four-foot 

diameter corrugated steel pipe, 60 feet long, and ventilated with an exhaust fan on 

top of a 20-foot-high stack. The belt sections for both the experimental mine and the 

test gallery were 15 feet long and were 10 in., 30 in., or 42 in. wide. They varied in 

thickness from 1/8 to 3/8 inch. (Belts currently used in mines are significantly 

wider and thicker than these belts, used forty years ago.) These experimental 

conditions were significantly different from those used in the 2G test and more 

closely resembled in-mine conditions. They also produced different results. 

Belts were new and typical of those used in coal mines.1 They were made of rubber, 

neoprene, or PVC. In general, all ignited but flame propagation was significantly 

slower for the neoprene and PVC belts than for the rubber belts. The investigators 

found that many belts marked as “fire resistant” under the 2G test in fact burned. 

Ignition and flame propagation varied with the intensity of the ignition source (a 

propane burner), air velocity, and thickness of the belt. 

Mitchell and other researchers continued their investigations, examining the 

association of flame propagation with air velocity, belt width, and cross-sectional 

area of the test apparatus (Mitchell et al., 1967; Kuchta et al., 1981). They found, 

among other matters, that air velocity greater than 100 fpm increased flame 

propagation, that there was no relation of propagation with belt width, and that 

propagation was associated with the cross-sectional area of the test gallery. Of 

relevance to the use of belt entries for ventilation, they suggested (pg. 8) that “In 

practice, consideration might be given to limiting air flow in belt installations.” 

Given the manifest deficiencies of the 2G test, the Bureau of Mines, in cooperation 

with MSHA’s Approval and Certification Center, developed a test that more closely 

resembled an underground mine (the so-called, full-scale gallery test) and based on 

that experience, developed a scaled-down laboratory-based test. The laboratorybased test used an apparatus that was smaller than the full-scale gallery test and 

larger than that used in the 2G test and, for this reason, was sometimes referred to as 

the intermediate-scale test. It has been evaluated, revised, and re-evaluated many 

times. 

Experiments similar to those undertaken by Mitchell et al., indeed many using the 

same apparatus continued at the Bureau of Mines, followed, often in collaboration 

with the MSHA Approval and Certification Center. (Sapko et al., 1981). Perzak et 

al. (1982) developed a single flammability index (FI) for each type of belt that 

combined findings on each test. Verakis (1989) presented results of the full-scale test 

 

1 Mitchell et al. also reported on experiments in the Netherlands in 1949 that showed that 

flammability was increased on used belts, belts under tension, and thin belts. 
 48

and preliminary results using the laboratory scale test. The two tests were in 

substantial agreement and noted, among other findings, there was a maximum 

flame propagation at an air velocity of 1.5 m/sec (= 300 fpm), that none of six SBR 

belts passed, about half of the PVC belts passed (14 passed, 12 failed), most of the 

neoprene belts passed (18 passed, six failed) and few of the composite belts passed 

(three passed, 20 failed). MSHA’s Approval and Certification Center developed test 

evaluation criteria for belt manufacturers (Verakis, 1989; Verakis and Dalzell, 1988). 

In preparation for rule-making adopting these tests, MSHA described the test on 

which both MSHA and the Bureau of Mines had been collaborating (Verakis, 1993; 

Luzik, 1989). Lazzara and Perzak (1990) compared results of experiments with the 

full-scale gallery with a laboratory-scale test and found they gave the same results 

on 19 different styles of belt. 

The Belt Evaluation Laboratory Test (BELT) 

Testimony before the Panel detailed that the BELT (See also Lazzara and Perzak 

1990; Verakis, 1991; USBM, 1989) was developed by the U.S. Bureau of Mines, in 

cooperation with MSHA, to address the limitations of the 2G test by providing for a 

sample size and test conditions that lead to results that align more closely with those 

of the full-scale gallery test. Yet, the test is conducted in a relatively simple 

laboratory setting that does not require a full-scale belt fire gallery. 

Presentations to this Panel showed that belts that pass this 2G small-scale test 

procedure do not pass the flammability testing under more realistic large-scale 

conditions. In fact, it has been demonstrated that belt materials that pass the 30 CFR 

§ 18.65 test may burn completely in a full-scale belt gallery test conducted at the 

NIOSH (former USBM) Lake Lynn Laboratory, as recounted to the Panel by expert 

presenters (also see Lazzara and Perzak, 1987; Lazzara and Perzak 1990). In that 

series of tests, 13 synthetic rubber belts and eight PVC belts were tested in 42-inch 

wide by 3/8 to 1 inch thick configurations. Nineteen of these 21 belts passed the 30 

CFR § 18.65 test but only two rubber and four PVC belts exhibited fire-resistant 

behavior, i.e. limiting fire damage to the ignition area. Fifteen belts failed the largescale belt fire gallery test, showing that the fire damage extended to the end of the 

30-foot test sample and leaving no portion of the sample undamaged across the 

entire belt width. Over the next decade, the Belt Evaluation Laboratory Test (BELT) 

was refined, revised, and validated and the Bureau of Mines issued its Technology 

News announcing the test complete with drawings and test methods (USBM, 1989; 

USBM, 1991; USBM, 1989). 

The BELT is conducted in a 5.5-foot-long by 1.5-foot-square ventilated tunnel. The 

belt material sample size is 5 feet long by 9 inches wide. The sample is ignited by 

applying a gas burner to the front edge of the belt sample with the flames 

distributed equally on the top and bottom surfaces of the sample. After five 
 49

minutes, the burner is removed, and the belt sample allowed to burn until the 

flames are out. A belt passes the BELT if, in three separate trials, there remains a 

portion of the 5-foot sample that is undamaged across its entire width. If, in any of 

the three trials, fire damage extends to the end of the sample, the conveyor belt 

formulation fails the test. Comparison testing showed excellent agreement for 19 of 

the belts between the pass/fail results of the large-scale fire gallery test and the 

BELT. The USBM concluded that conveyor belts that pass the BELT have improved 

fire resistance. MSHA (1999) determined that the introduction of more stringent 

BELT fire resistance requirement would not have a significant economic impact on 

the mining industry, including consideration of the impact on small mines and on 

small manufacturers. MSHA (1999) further concluded that “serious risk of fires in 

the belt entry will be reduced, as would the potential for disaster” if all belts used in 

underground mines were using conveyor belts that pass the BELT criteria. 

This BELT was evaluated by Canadian and British investigators and found to 

produce results that are in agreement with methods used there. The Canadian 

evaluation found “good correlation with MSHA on a series of three rubber/fabric 

belts” (Mintz, 1993; Mintz, 1995) but that passing or failure of rubber/steel cord and 

PVC belts was dependent on belt thickness. This was a useful finding, suggesting 

that belt thickness be considered in the belt approval and use process. This test 

apparatus was also evaluated by investigators in the UK to test conveyor belting for 

flammability since a full-scale test facility in the UK had closed (Yardley et al., 2004). 

These investigators suggested that the BELT, with modified ignition geometry, serve 

as a substitute for its propane gallery test. 

 

Based on the BELT, MSHA published its proposed rule in 1992 (MSHA, 1992). This 

notice of proposed rule-making was independent of any rule change concerned with 

using belt entries for face ventilation. MSHA’s Belt Entry Ventilation Review 

(BEVR) concluded “Fire hazards to miners can be reduced by the use of improved 

belt materials. Additionally, belt entry fires can be prevented through belt 

maintenance, belt entry clean-up, and rock-dusting” (pg. 2) but did not recommend 

use of “improved belt materials,” recommending instead, “Increased emphasis 

should be placed on belt maintenance, belt entry clean-up, and rock-dusting” (pg. 3). 

MSHA’s Belt Air Advisory Committee (BAAC) concluded that “. . . current 

standards (i.e., 30 CFR § 18.65) and testing for conveyor belt material are 

inadequate” (pg. 74) then went on and “... strongly recommends that MSHA 

develop approval criteria for the following: conveyor belting installed in all 

underground coal mines ...” (pg. ii). They based this recommendation, in part, on 

the conclusion that improved fire-resistant conveyor belts, if used in all mines, 

would significantly reduce the risk of serious belt fires and that other effects (of air 

flow and fire sensing mechanisms) were “... second-order effects compared to the 

results that would be achieved through the use of fire-resistant conveyor belt 
 50

material” (pg. 74). The Panel agrees. It is better to prevent fires than to limit 

attention to detecting and suppressing them. 

But ten years after it proposed a rule to improve the flame-resistance of conveyor 

belting, MSHA withdrew it (MSHA, 2002) and did not address belt flammability 

testing in its belt air proposed rule (MSHA, 2003). The principal rationale for not 

proposing an improved test for belt flammability was that the frequency of belt fires 

had decreased. But this depends on how the numbers are interpreted. It is true that 

the number of belt fires had decreased over the past decade, but the rate (i.e., the 

number of fires per thousand mines) has remained constant, owing in part to high 

variability (Francart, 2006). During this same time period, however, underground 

coal production has increased so that the number of belt fires per 100 million tons 

has decreased, although there was high variability from year to year (p = 0.02, 

adjusted R2 = 0.19). 

The MSHA Belt Air Standard 

MSHA’s principal response to products of combustion going to the face when using 

the belt entry for face ventilation has been to require mine operators who use the 

belt entry for this purpose to use Atmospheric Monitoring Systems (AMS) (Mine 

Safety and Health Administration, 2004). Available devices can detect heat, smoke, 

and carbon monoxide. As discussed elsewhere in this report, the CO detector has 

emerged as the best detector. Early problems with false alarms have essentially 

been solved both by setting alert and alarm levels in relation to the ambient 

concentration of CO and by integrating devices to simultaneously discriminate CO 

in diesel exhaust from CO from a fire (by measuring the concentration of oxides of 

nitrogen which occur in diesel exhaust but not otherwise in mines)(Edwards et al., 

2003; Edwards et al., 1999). 

But what does the AMS system provide? The most basic protection provided by 

AMS systems is to give early warning of fires. By “early” we mean before a fire is 

detected by other means, e.g., by smell or sight. In principle, how “early” detection 

occurs can be measured in minutes, but to our knowledge, there are no estimates. 

MSHA reports on detection of 75 reportable fires in belt entries (i.e., at least 30 

minutes from the time they were detected under 30 CFR Part 50 regulations), 

showed that in all circumstances when they were in use, the AMS systems detected 

the fire (MSHA, 2003). In contrast, when point-type heat sensors (PTHS) were in 

use, fires were often detected by sight or smell, illustrating one serious weakness of 

the PTHS-based systems. However, in 13 non-reportable fires using atmospheric 

monitoring systems, six were detected by sight or smell rather than by the AMS 

system (MSHA, 2003). This series is hardly a representative sample because 

reporting of non-reportable fires is voluntary, even though it was solicited. 

Nevertheless, it suggests that there are circumstances under which the AMS does 
 51

not in fact provide warning before a fire is detected by sight or smell, i.e., it does not 

provide an early warning.2

There are no estimates, to our knowledge, of the duration or distribution of the time 

interval between detecting a fire by the atmospheric monitoring system or by sight 

or smell. It is likely to be highly variable because it depends on a person being in a 

position to smell the smoke (i.e., inby the fire), the sense of smell is highly variable 

between individuals, and smell is a wholly subjective test. 

The atmospheric monitoring system provides, however, other advantages. In 

addition to early detection, AMS detectors are placed at set intervals along the belt 

entry making it possible to identify the location of a fire with greater precision than 

can a miner. And it is linked to a communications system making it possible to 

warn miners, to withdraw them from dangerous areas, and to coordinate fire control 

efforts. When a trained AMS operator reacts decisively to an early detection, 

additional time is gained both for escape and fire control. How much time is gained 

is not clear. 

However objective, systematic, and comprehensive it is, the only improvement 

provided by an AMS is early warning of a fire. Smoke from a belt fire will

contaminate the face, with or without the AMS. The mine operator and miners still 

have to find the fire, bring it under control, evacuate anybody who is inby, and 

decide whether to evacuate the mine. The atmospheric monitoring system does not 

prevent fires from occurring: it does not result in controlling combustible materials or 

sources of ignition, and it does not prevent the products of combustion from being 

conveyed to the face. And like all mine entries, belt entries will have an abundant 

supply of air. 

One implication of this line of reasoning is that the reporting requirement should be 

changed so that all fires (from the moment they are detected) are reported. This 

would require development of objective and unambiguous criteria for determining 

what, in practice, constituted a “fire.” If the duration of reported fires is included in 

the report, it would be possible to maintain continuity in data for fires that last more 

than thirty minutes, as was (until recently) required in the past (30 CFR § 50.20-5(a)). 

Now, reportable fires in underground mines are those that last more than ten 

minutes from discovery. 

 

2 At the Aracoma fire, smoke and glowing embers were seen approximately nine minutes before the 

AMS system detected elevated levels of CO (Mine Safety and Health Administration, 2007, pp. 10-11). 

In that situation, the AMS system failed to provide “early” fire detection. 
 52

Fire Resistance Standards in Other Countries 

Testimony and the documentation provided to the Panel demonstrate that there are 

a number of different standards and tests required for mine conveyor belts in the 

majority of other coal-producing countries. Manufacturers have adapted their 

product lines to meet specific belt designs that adhere to the relevant standards and 

tests specific to the country where the belt is sold. The following table (Küsel, 2007) 

notes different types of tests and whether or not these types of tests are used in the 

countries noted. 

It is obvious from the comparison that the requirements for belt fire resistance in the 

United States are among the lowest in the world with only a small-scale Bunsen 

burner laboratory test required. 

All other countries require a drum friction test and most countries also require a 

larger-scale propane grate burner test. A large-scale gallery test is only required in 

Europe but a laboratory-scale gallery test is required in both Europe and Russia. 

This test is similar to the BELT developed in the United States. 

Considering the foregoing discussion of conveyor belt fires, the potential impact in 

belt air mines, and the inadequacy of current U.S. standards and testing compared 

with most other major coal producing countries, the Technical Study Panel strongly 

recommends that MSHA move immediately to revise 30 CFR § 18.65 to include the 

BELT either as a regulation under part 18 or as a separate regulation section. This 

would significantly reduce the frequency and hazard of conveyor belt fires in all 
 53

U.S. underground coal mines, not just those that use belt air to ventilate working 

faces. 

Conclusion

All members of the Panel affirmed the recommendation.

References

DeRosa, M. (2004). Analysis of Mine Fires for All U.S. Underground and Surface 

Coal Mining Categories: 1990-1999. Information Circular 9470; DHHS 

(NIOSH) Publication No. 2004-167. National Institute for Occupational Safety 

and Health, Centers for Disease Control and Prevention. Pittsburgh, 

Pennsylvania. 43 pages. 

Edwards, J., Franks, R., Friel, G., Lazzara, C., & Opferman, J. (1999). Mine fire 

detection in the presence of diesel emissions. Proc Eighth U.S. Mine 

Ventilation Symposium. University of Missouri-Rolla Press (Pp. 295-301), 

Press, Rolla, Missouri. 

Edwards, J., Franks, R., Friel, G., Lazzara, C., & Opferman, J. (2003). In mine 

evaluation of discriminating mine fire sensors. In: E. DeSouza, (ed.), 

Proceedings of the North American/Ninth U.S. Mine Ventilation Symposium 

(June 8-12, 2002), Kingston, Ontario, Canada. (Pp. 527-532). A.A.Balkema 

Publishers, Lisse, Netherlands. 

Federal Mine Safety and Health Act of 1977, Public Law 91-173, as amended by 

Public Law 95-164. 

Francart, W. (2006). Reducing belt entry fires in underground coal mines. In: 

Mutmansky J and Ramani R. (eds.) U.S./North American Mine Ventilation 

Symposium, (Pp. 303-308). London, Taylor & Francis Publishers. 

Kuchta, J., Sapko, M., Perzak, J., & Mura, K. (1981). Improved fire resistance test 

method for belt materials. Fire Technology 17:120-130. 

Küsel B. (2007). International comparison of fire resistant conveyor belt tests. 

PHOENIX Conveyor Belt Systems GmbH, Hamburg, Germany, testimony 

before the Technical Study Panel, March 16, 2007, Coraopolis, Pennsylvania. 

Lazzara, C. & Perzak, F. (1987). Effect of ventilation on conveyor belt fires. 

Proceedings of Symposium on Safety in Coal Mining, Paper 7.5, (18 pages). 

Pretoria, South Africa. 
 54

Lazzara, C. & Perzak, F. (1990). Conveyor belt flammability studies. Proceedings of 

Twenty-first Annual Institute on Coal Mining Health Safety and Research, 

August 28, 1990, (Pp. 119-129). Blacksburg, Virginia. 

Luzik, S. (1989). Past, present, and future fire resistant requirements for materials 

used in underground coal mines. Fire Safety Problems Leading to Current 

Needs and Future Opportunities, Electrical/Electronics Building and 

Construction Textiles and Furnishings Key Flammability Issues. Paper 

Presented at Camelback Inn, Scottsdale, Arizona on October 15-18, 1989, (Pp 

61-73.) Fire Retardant Chemicals Association. 

Luzik, S. & Desautels, L. (1990). Coal Mine Fires Involving Track and Belt Entries, 

1970-1988. Report No. 09-323-90 dated November 19, 1990, Industrial Safety 

Division, Bruceton Safety Technology Center, Mine Safety and Health 

Administration, Pittsburgh, Pennsylvania. 26 pages. 

Mine Safety and Health Administration. Section 18.65 - Flame test of conveyor 

belting and hose. Title 30 Code of Federal Regulations. 

Mine Safety and Health Administration. (1988). Safety Standards for Underground 

Coal Mine Ventilation, Proposed Rule. Federal Register, 53 (January 27, 1988): 

2382-2424. 

Mine Safety and Health Administration. (1992). Requirements for Approval of 

Flame-Resistant Conveyor Belts, Proposed rule. Federal Register, 57(December 

24, 1992): 61524-61535. 

Mine Safety and Health Administration. (1999). Updated preliminary regulatory 

impact analysis and regulatory flexibility analysis, proposed rule on 30 CFR 

75:1108 and 75:1108-1. RIN 1219-AA92. December, Arlington, Virginia. 95 

pages. 

Mine Safety and Health Administration. (2002). Requirements for Approval of 

Flame-Resistant Conveyor Belts; Proposed Rule; Withdrawal. Federal Register

67(July 15, 2002): 46431-46432. 

Mine Safety and Health Administration. (2003). Underground Coal Mine 

Ventilation -- Safety Standards for the Use of a Belt Entry as an Intake Air 

Course to Ventilate Working Sections and Areas Where Mechanized Mining 

Equipment is Being Installed or Removed; Proposed Rule. Federal Register

68(January 27, 2003): 3936-3968. 
 55

Mine Safety and Health Administration. (2004). Underground Coal Mine 

Ventilation -- Safety Standards for the Use of a Belt Entry as an Intake Air 

Course to Ventilate Working Sections and Areas Where Mechanized Mining 

Equipment is Being Installed or Removed; Final Rule. Federal Register 69(April 

2, 2004): 17480-17530. 

Mine Safety and Health Administration. (2007). Report of Investigation, Fatal 

Underground Coal Mine Fire, January 19, 2006, Aracoma Alma Mine #1, 

Aracoma Coal Company, Inc., Stollings, Logan County, West Virginia, I.D. 

No. 46-08801. Coal Mine Safety and Health, Arlington, Virginia. 164 pages. 

Mintz K. (1993). Evaluation of the U.S. mid-scale apparatus for measuring the 

flammability of conveyor belting - Part II. MRL 92-089(TR), Ottawa, Canada, 

Canadian Centre for Minerals and Energy Technology (Mining Research 

Laboratories). 36 pages. 

Mintz, K. (1995). Evaluation of laboratory gallery fire tests of conveyor belting. Fire 

and Materials. 19(1): 19-27. 

Mitchell, D., Murphy, E, Smith, A, & Polack, S. (1967). Fire hazard of conveyor belts. 

Report of Investigation, RI 7053, U.S. Bureau of Mines, Pittsburgh, 

Pennsylvania. 19 pages. 

Mitchell, D., Smith, A., Polack, S., & Murphy, E. ( 1967). Flame propagation on 

conveyor belts. U.S. Bureau of Mines. Pittsburgh, Pennsylvania. 12 pages. 

Perzak, F., Spencer, E., & Sapko, M. (1982). Testing of fire-resistant conveyor belting. 

Canadian Mining and Metallurgical Bulletin 75:115-119. 

Polack, S. (1956). Research to develop a schedule for testing conveyor belts for fire 

resistance. Ninth International Conference of Directors of Safety in Mines 

Research. June 28-July 4, 1956, (29 pages). Heerlen, Netherlands and Brussels, 

Belgium. 

Sapko, M., Mura, K., Furno, A., & Kuchta, J. (1981). Fire resistance test method for 

conveyor belts. Report of Investigation RI 8521. U.S. Bureau of Mines, 

Pittsburgh, Pennsylvania. 31 pages. 

U.S. Bureau of Mines. (1955). Fire-resistant conveyor belts: Tests for permissibility; 

Fees. S 28. Schedule. 5 pages. 
 56

U.S. Bureau of Mines. (1989). Laboratory-Scale Fire Tunnel Test for Conveyor Test 

Equipment and Procedure in Fire Testing Procedures and Construction 

Drawings For the Belt Evaluation Laboratory Test. Bureau of Mines, 9 pages. 

 U.S. Bureau of Mines. (1991). New Flammability Test for Conveyor Belting. 

Technology News 377, Pittsburgh, Pennsylvania, 2 pages. 

Verakis H. (1989). Fire hazard evaluation of mine conveyor belts. IN: 3rd 

International Conference on Polymers in Mining, University of Lancaster, 

United Kingdom, The Plastics and Rubber Institute, September 26, 1989. 9 

pages. 

Verakis H. (1991). Reducing the fire hazard of mine conveyor belts. IN: 5th U.S. 

Mine Ventilation Symposium. Wang YJ.(ed.), Department of Mining 

Engineering, WV University, (Pp. 69-75). Morgantown, West Virginia. 

Verakis H. (1993). New test for evaluating the flame resistance of conveyor belts. 

Seminar on Belt Conveyors, Design, and Development, June 25, 1993, 

University of Wisconsin, (Pp. 1-13). Milwaukee, Center for Continuing 

Education Chicago, Illinois. 

Verakis, H. 2007. Conveyor Belt Fire Test Methods—A Review and Analysis. 

Technical Support, A&CC, Triadelphia, West Virginia, August, 32 pages. 

Verakis, H. & Dalzell, R. (1988). Impact of entry air velocity on fire hazard of mine 

conveyor belts. Fourth International Mining Ventilation Conference. (Pp. 375-

381). Brisbane, Queensland, Australia. 

Yardley, E., Williams, M., Wymark, S., & Stace, L. (2004). Development of a smallscale fire propagation test for conveyor belts. Mining Technology (Trans Inst 

Min Metall A) 113:A73-A82. 
 57

RECOMMENDATION NUMBER 2 - Other Belt Tests 

The Technical Study Panel recommends that MSHA adopt a drum friction test to 

be utilized for a period of two years to evaluate and assess the contribution to 

conveyor belt fire safety of such a test. Continuance of this test would be based 

on the MSHA evaluation at the end of this time period. 

Discussion 

Frictional ignitions are a common source of belt fires, accounting for approximately 

20% of all belt fires. Therefore, it is appropriate to test belts specifically for this type 

of ignition potential, as is done in most other coal-mining countries. 

Drum Friction Tests 

Drum Friction Tests for conveyor belts are widely-used tests that simulates a belt 

slipping over a jammed pulley or a pulley rotating under a stationary belt. Friction 

creates large amounts of heat which the belt has to dissipate. The test is passed if the 

belt surface temperature remains below a certain temperature and no flame or glow 

is visible. Unlike the proposed BELT, which gages the resistance of a belt to 

propagate flame, the drum friction test purports to measure the affinity for a belt to 

self ignite or ignite other materials in the frictional setting described above. In the 

U.S. in 1955, a drum friction test was included, along with a flame test, under 

Schedule 28 for the acceptance of fire resistant conveyor belts. However, a drum 

friction test was not included when Schedule 28 was consolidated into Schedule 2G 

(Title 30, Code of Federal Regulations, Part 18) and approved on March 19, 1968. 

Apparently, there were issues with the U.S. drum friction test (Verakis, 2007). 

However, other countries have developed drum friction tests in the interim which, 

along with their experiences, may provide a template for adopting a drum friction 

test methodology and procedures that would address past issues. The Panel is 

recommending that that a drum friction test be assessed to determine if it could 

complement the recommended BELT method. These two tests evaluate different 

belt properties: the flame gallery test presumes belt ignition (indeed, it causes 

ignition) and evaluates the degree and extent of flame propagation, while the drum 

friction test evaluates a belt’s ignitability from friction. Frictional ignition depends 

on belt surface properties (related to friction) and its ability to dissipate heat, among 

others. Given the frequency of frictional ignition (e.g., the Aracoma fire), belts 

should be tested specifically for this feature. 

The Panel feels that the main objective of a fire resistant belt is to ensure that a belt 

would not ignite from frictional heating or other heat source and that if ignited, an 

existing fire would not be propagated by the belt itself irrespective of the original 

source of the heating. The BELT exposes the belt to a gas flame which is turned off 
 58

after the end of the belt has been lit to demonstrate that the flames will extinguish 

quickly and would not propagate along the belt with the original heat source 

removed. The drum friction test would test whether the belt would ignite having 

been subjected to frictional heating. 

Other Conveyor Belt Tests 

The Propane Burner Test (EN 12881 et al.) is a large-scale test that also demonstrates 

whether conveyor belts propagate fire. For this test, a belt specimen (1.5 - 2.5 m long 

x 1200 mm wide) is ignited by a propane burner. After the ignition source has been 

removed, the flames must self-extinguish and a defined undamaged length must 

remain. These test conditions are similar to those used by USBM (NIOSH) for their 

full-scale belt flammability test. The belt sample size lies between that for a full scale 

(10 m long) and the BELT (1.67 m). 

The Laboratory Scale Gallery Test (DIN 22100 and 22118) subjects a 1200 mm long x 

120 mm wide belt specimen is placed over a propane burner. Very similar to the 

BELT, after the ignition source has been removed, the flames must self-extinguish 

and a defined undamaged length must remain. 

A number of other countries also use some type of static electricity test. These were 

also examined and considered by the Panel. However, no evidence has been shown 

in U.S. mines that conveyor belts pose an electrostatic hazard.i

 

All of the above tests seem to be adequate gages of belt fire resistance, however, the 

Panel feels that the correlation between the BELT and the full scale gallery tests 

performed by the USBM is evidence that the BELT laboratory scale gallery test, 

along with a drum friction test, will sufficiently determine whether a belt is fireresistant for use in U.S. underground coal mines. 

Conclusion

All members of the Panel affirmed the recommendation.

References

Küsel B. (2007). International comparison of fire resistant conveyor belt tests. 

PHOENIX Conveyor Belt Systems GmbH, Hamburg, Germany, testimony 

before the Technical Study Panel, March 16, 2007, Coraopolis, Pennsylvania. 

Lazzara, C. & Perzak, F. (1987). Effect of ventilation on conveyor belt fires. 

Proceedings of Symposium on Safety in Coal Mining, Paper 7.5, (15 pages). 

Pretoria, South Africa. 
 59

Lazzara, C. & Perzak, F. (1990). Conveyor belt flammability studies. Proceedings of 

Twenty-first Annual Institute on Coal Mining Health Safety and Research, 

August 28, 1990, (Pp. 119-129). Blacksburg, Virginia. 

Mine Safety and Health Administration. (1999). Updated preliminary regulatory 

impact analysis and regulatory flexibility analysis, proposed rule on 30 CFR 

75:1108 and 75:1108-1. RIN 1219-AA92. December, Arlington, Virginia. 95 

pages. 

 

Mintz, K. (1995). Evaluation of laboratory gallery fire tests of conveyor belting. Fire 

and Materials . 19(1): 19-27. 

U.S. Bureau of Mines. (1989). Laboratory-Scale Fire Tunnel Test for Conveyor Test 

Equipment and Procedure in Fire Testing Procedures and Construction 

Drawings For the Belt Evaluation Laboratory Test. Bureau of Mines. 9 pages. 

Verakis H. (1991). Reducing the fire hazard of mine conveyor belts. IN: 5th U.S. 

Mine Ventilation Symposium. Wang YJ. (ed.), Department of Mining 

Engineering, WV University, (Pp. 69-75). Morgantown, West Virginia. 

Verakis, H. 2007. Conveyor Belt Fire Test Methods—A Review and Analysis. 

Technical Support, A&CC, Triadelphia, West Virginia, August, 32 pages. 

______________ 

1 Verakis, H. (2007) Conveyor Belt Fire Test Methods—A Review and Analysis. 

August, 32 pages. 
 60

RECOMMENDATION NUMBER 3 – IMPROVED FIRE RESISTANCE 

STANDARDS FOR ALL UNDERGROUND COAL MINES 

The Panel feels strongly that the conveyor belt flame-resistance testing and 

standards recommendation in this report for mines that course belt air to the 

working section shall also be extended by MSHA to all underground U.S. coal 

mines. 

Discussion 

It is obvious from the previous discussion of conveyor belt flame resistance by the 

Panel and from the testimony and facts presented to the Panel that current U.S. 

conveyor belt flame-resistance testing and standards are inadequate to correctly 

determine the full-scale fire resistance of conveyor belt and below global mining 

conveyor belt flame-resistance testing and standards. Therefore, it is only 

reasonable that all U.S. underground coal miners should be afforded the same 

measure of conveyor belt fire safety as that recommended for belt air mines. 

Improving the fire resistance of belt material such that the belt passes the BELT is an 

important step towards preventing belt fires at all mines, not just those that direct 

belt air towards the working section. Permitting belts of less flame-resistant 

properties in mines that ventilate belt air outby would miss an important 

opportunity to prevent belt fires in the first place. 

Allowing belts of different types in the same mine depending on whether the belt air 

flows toward the face or away from the face would be confusing and unmanageable 

from a logistics and maintenance perspective. 

Conclusion

All members of the Panel affirmed the recommendation. 
 61

RECOMMENDATION NUMBER 4 – COORDINATING BELT TESTING WITH 

OTHER COUNTRIES 

The Panel recommends that those in MSHA who perform or are involved in belt 

fire resistance testing and approval establish contacts and maintain dialogue 

with their counterparts in other key mining countries. 

Discussion 

The Panel contemplated a recommendation in this area to recommend strong 

coordination with global mining conveyor belt testing and standards. However, 

noting that the European Community has not been able to accomplish this given the 

impetus to do so that they have, the Panel did not believe a meaningful, practical 

recommendation could be made. The Panel acknowledges that this is and always 

has been done to some degree by MSHA, but by this recommendation would like to 

ensure regular discourse and exchange regarding conveyor belt testing, acceptance, 

and fire experience with other key mining countries. 

Conclusion

All members of the Panel affirmed the recommendation.
 62

RECOMMENDATION NUMBER 5 – BELT ENTRY AND CONVEYOR BELT 

MAINTENANCE 

The Technical Study Panel strongly recommends that the Federal Mine Safety 

and Health Administration (MSHA) rigorously enforce existing standards on 

underground conveyor belt maintenance and fire protection. The Panel 

anticipates that rigorous enforcement by MSHA will result in more consistent 

compliance by all operators to these standards. This applies especially with 

regard to the availability and functionality of belt fire suppression systems; the 

availability and proper working order of firefighting equipment; the function of 

smoke, carbon monoxide and other sensors and alarm systems designed to detect 

fires in belt entries; and the training of mine personnel for fighting mine fires, 

such as conveyor belts. This also applies to the other conveyor belt fire 

prevention and maintenance items noted in the discussion section. 

MSHA should pay particular attention to required examinations of the belt lines 

by mine examiners and ensure (1) each belt line is kept in good working order at 

all times to prevent belts from rubbing stands, (2) damaged rollers are replaced 

immediately, (3) belt lines are adequately rock dusted, and (4) flammable 

materials such as fine coal, coal dust, oil, grease and trash are not permitted to 

accumulate along belt lines. 

Discussion 

Prevention of belt fires is a critical element in improving miners’ safety. Proper belt 

maintenance and regular inspections will reduce the likelihood for fires due to bad 

rollers, poor belt alignment and other malfunctions. 

The Aracoma fire in 2006 (MSHA, 2007) “occurred as a result of frictional heating 

when the longwall belt became misaligned in the 9 Headgate longwall belt takeup 

storage unit. This frictional heating ignited accumulated combustible materials.” 

Root causes for this fire were, among others, neglect in belt maintenance in that ”the 

mine operator failed to maintain the 9 Headgate longwall belt in a safe operating 

condition and did not remove it from service as required.” Furthermore, “mine 

examiners did not identify existing hazardous conditions.“ 

The Panel stresses the need for adequate visual inspection by walking all belt lines 

as required in 30 CFR § 75.362 (2)(b) “During each shift that coal is produced, a 

certified person shall examine for hazardous conditions along each belt conveyor 

haulageway where a belt conveyor is operated.” 

Examiners must ensure that the belt is properly aligned and trained to prevent 

frictional heating where the belt rubs against stands or other structure elements. 

The need to ensure proper alignment is amply illustrated in the Aracoma fire. The 
 63

underlying question is why neither the operator nor the MSHA inspectors took the 

required action to fix the misaligned belt before the fire. This is not a subtle or 

obscure problem and the belt was known to be misaligned before the fire. 

Damaged rollers must be identified so that they can be replaced as soon as possible 

before the damage leads to frictional heating that can result in a fire. 

No accumulations of combustible materials such as coal, oil, grease or trash can be 

permitted. Operators should use flame-resistant grease and other lubricants. 

Fire detection and suppression systems and equipment must be tested in accordance 

with 30 CFR §§ 75.1101 and 75.1103, and MSHA PPL No. P06-V-5. 

Conclusion

All members of the Panel affirmed the recommendation. 

References

Küsel, B. (2007) International Comparison of Fire Resistant Conveyor Belts, 

PHOENIX Conveyor Belt Systems GmbH, Hamburg, Germany, testimony 

before the Technical Study Panel, March 16, 2007. 

Lazzara, C. & Perzak, F. (1987). Effect of ventilation on conveyor belt fires. 

Proceedings of Symposium on Safety in Coal Mining, Paper 7.5, (15 pages). 

Pretoria, South Africa. 

Lazzara, C. & Perzak, F. (1990). Conveyor belt flammability studies. Proceedings of 

Twenty-first Annual Institute on Coal Mining Health Safety and Research, 

August 28, 1990, (Pp. 119-129), Blacksburg, Virginia. 

Mine Safety and Health Administration. (1999). Updated preliminary regulatory 

impact analysis and regulatory flexibility analysis, proposed rule on 30 CFR 

75:1108 and 75:1108-1. RIN 1219-AA92. December, Arlington, Virginia. 95 

pages. 

Mine Safety and Health Administration. (2006). Water Sprinkler Fire Protection of 

Underground Belt Conveyors and Belt Takeup Storage Units. Program Policy 

Letter NO. P06-V-5PPL, signed by Ray McKinney, Administrator for Coal 

Mine Safety and Health, Effective Date: 06/16/06, 3 pages. 

Mine Safety and Health Administration. (2007). Report of Investigation, Fatal 

Underground Coal Mine Fire, January 19, 2006, Aracoma Alma Mine #1, 
 64

Aracoma Coal Company, Inc., Stollings, Logan County, West Virginia, I.D. 

No. 46-08801. Coal Mine Safety and Health, Arlington, Virginia. 164 pages. 

Mintz, K. (1995). Evaluation of laboratory gallery fire tests of conveyor belting. Fire 

and Materials. 19(1): 19-27. 

U.S. Bureau of Mines, Fire Testing Procedures and Construction Drawings for the 

Belt Evaluation Laboratory Test. Guidelines developed for the Mine Safety 

and Health Administration Approval and Certification Center, March 1989, 9 

pages. 

Verakis, H. C., Reducing the Fire Hazards of Mine Conveyor Belts, Proceedings of 

the 5th U.S. Mine Ventilation Symposium, West Virginia University, June 

1991, (Pp. 69-73). Morgantown, West Virginia. 
 65

RECOMMENDATION NUMBER 6 - SPECIAL REQUIREMENTS FOR THE USE OF 

BELT AIR 

The Panel recommends that the mines using belt air on a working section must 

be held to a higher standard that involves use of (1) an atmospheric monitoring 

system (AMS) and suitable monitoring instruments, (2) belt materials that meet 

the BELT and other test standards recommended by this Panel, and (3) more 

vigorous inspection procedures by MSHA inspectors. In addition, we 

recommend that the BELT and other test standards recommended by this Panel 

be applied to all belt conveyors used in underground coal mines. 

Discussion 

The possible use of belt ventilation air in a working section has been an important 

consideration in the U.S. coal industry for several decades. A number of technical 

studies have previously been completed studying safety issues surrounding the use 

of belt air in a working section. The Belt Air Ventilation Review completed by 

MSHA personnel (MSHA, 1989) was the first comprehensive review of this concept. 

This was followed a few years later by the review of the Belt Air Advisory 

Committee (Belt Air Advisory Committee, 1992). In each case, the concept of using 

belt air in the working section was considered to be sound in some situations. 

However, both reports specified that where belt air is used in the working section, 

extra measures need to be implemented to better protect the workers in case a fire 

would occur in the belt entry. The primary requirement was that an atmospheric 

monitoring system (AMS) would be implemented in each mine to detect the 

existence of a fire or other CO-producing conditions. 

Initially, the belt air could be used in a working section only after the mine 

petitioned MSHA and presented arguments that indicated their belief that the 

miners would be safer using the belt air. After a number of years of using this plan, 

new rules were adopted in 2004 (MSHA, 2004) that permitted mines with three or 

more entries to use belt air in the working section without going through the 

petition process. 

A close review of the safety statistics for belt air usage shows that quite a few fires 

have occurred in belt conveyor entries over the years. Based on MSHA data, the 

number of conveyor belt reportable fires between 1980 and 2006 was 65 with 

frictional heating, flame cutting and welding, and electrical malfunctions being the 

primary causes (Lazzara, 2007). Three deaths over that time period were associated 

with belt fires. The first occurred in 1986 at the Florence No. 1 Mine. In that belt 

fire, a miner died of a heart attack while fighting the belt fire. In 2006, the belt fire at 

the Aracoma Coal Company Alma Mine No. 1 resulted in the deaths of two miners. 

The belt air at the Alma Mine No. 1 was used in the working section, but the 
 66

primary causes of the two deaths were a variety of other failures, not the fact that 

belt air was used in the working section (MSHA, 2007). The Technical Study Panel 

concludes that belt fires are a significant hazard and that belt air cannot be readily 

used in the working section without proper design of the ventilation system and 

careful monitoring of the belts. 

The Technical Study Panel recognizes that a valid argument for the use of belt air in 

the working sections in coal mines can be made in a number of specific mining 

situations that occur in U.S. underground coal mines. The first of these situations is 

in western coal mining operations where deep cover and bump-prone coal seams 

are being mined. In these mines, the coals are often extracted by longwalls where the 

geologic and rock mechanics problems make it difficult to mine the coal using more 

than two entries in the headgate and tailgate entry systems. These difficult 

conditions and the amounts of methane gas encountered at the working faces make 

the mining process more dangerous without using belt air at the face because three 

entries (instead of two) would ordinarily be required to supply sufficient ventilation 

air to the face. Under these conditions, bumps and roof control problems in the 

headgate entries, at the working face, and in the tailgate entries would most 

assuredly be more hazardous to miners on the section than the possible hazards 

added due to use of belt air at the face. This conclusion assumes that the belt air is 

properly monitored and that mine management is dedicated to keeping the 

ventilation and AMS working as designed. 

The second situation where belt air usage in the working section is deemed to be 

justifiable is in the deeper high-methane mines found in some of the eastern states. 

These mines have methane emission rates that challenge the ventilation systems 

even after more than half of the in-seam methane has been removed via 

degasification techniques. In these mines, the added ventilation air provided by the 

belt entry most likely reduces the overall hazards of mining operation. Once again, 

the mining company must be held to a higher standard of safety if the use of belt air 

in the working section is to be safer than not using the belt air. 

In mines outside these two categories, it is not always obvious that belt air should be 

used. The reason for this conclusion is very simple. The use of belt air in the 

working section enables combustion products produced by fires or explosions in the 

belt conveyor entry to reach the working section. If using belt air in the working 

section does not eliminate or reduce other conditions deemed to be more hazardous, 

there is no justification for using belt air in the working section. The Technical Study 

Panel therefore suggests that the process for granting permission to use belt air in 

the working section become part of the ventilation plan review. In addition, the 

Panel recommends that the MSHA District Manager be charged with the 

responsibility of carefully scrutinizing each plan for use of belt air in the working 

section and denying those that do not have evidence of a safer mining environment 
 67

than not using belt air at the face. In addition, the Technical Study Panel 

recommends that the District Manager be charged with delivering a decision on the 

ventilation plan within six months. 

In summary, the Technical Study Panel concludes that the use of belt air in the 

working section must be associated only with mines where using belt air is safer 

than not using belt air in the working section and where higher standards of safety 

are applied when using belt air. 

Conclusion

All members of the Panel affirmed the recommendation.

References

Belt Air Advisory Committee. (1992). Final Report of the Department of Labor’s 

Advisory Committee on the Use of Belt Air to Ventilate the Production (Face) 

areas of Underground Coal Mines and Related Provisions, U.S. Department 

of Labor, 82 pages plus Appendices. 

Lazzara, C. (2007). Conveyor Belt Flammability Tests. Presentation to the Technical 

Study Panel on March 28, 2007. 

Mine Safety and Health Administration. (1989). Belt Entry Ventilation Review: 

Report of Findings and Recommendations, U.S. Department of Labor, 42 

pages plus Appendices. 

Mine Safety and Health Administration. (2004). Underground Coal Mine 

Ventilation -- Safety Standards for the Use of a Belt Entry as an Intake Air 

Course to Ventilate Working Sections and Areas Where Mechanized Mining 

Equipment is Being Installed or Removed; Final Rule. Federal Register 69(April 

2, 2004): 17480-17530. 

Mine Safety and Health Administration. (2007). Report of Investigation, Fatal 

Underground Coal Mine Fire, January 19, 2006, Aracoma Alma Mine #1, 

Aracoma Coal Company, Inc., Stollings, Logan County, West Virginia, I.D. 

No. 46-08801. Coal Mine Safety and Health, Arlington, Virginia. 164 pages. 
 68

RECOMMENDATION NUMBER 7 - BELT AIR APPROVAL RECOMMENDATION 

The Panel recommends that MSHA evaluate the safety of the use of belt air 

coursed to the working face as part of the approval of the mine ventilation plan. 

The District Manager must take special care to evaluate whether the belt air can 

be routed to the working face in a manner that is safe for all miners involved. 

Discussion 

The Technical Study Panel recognizes that the conditional use of belt entry air in the 

working sections in underground coal mines in the United States has been a very 

helpful practice in certain coal regions where coal would not be able to be safely and 

easily mined without using belt entry air in the working section. 

Initially, the belt entry air could be used in a working section only after the mine 

petitioned MSHA for approval. MSHA’s approval was granted only after it was 

determined that the alternate method guaranteed no less than the same degree of 

protection afforded by the standard ventilation method, or that application of the 

existing standard will not result in a diminution of safety for miners. After over 20 

years of using this process, new rules were adopted in 2004 (MSHA, 2004) that 

permitted longwall mines with three or more entries to use belt air in the working 

section without going through the petition process. However, the Panel is 

convinced that not all mines with three-entry longwalls are safer when using belt 

entry air in the working section. Unless some significant hazards are avoided by 

using belt entry air at the working face, the safety of the miners may be diminished 

rather than improved. 

The Panel recognizes that a valid argument for using belt entry air in the working 

section can be made in at least two specific situations: (1) in western United States 

longwall mining operations where deep overburden and bump-prone coal seams 

require that the number of gateroad entries be minimized to significantly reduce the 

possibility of bumps, and (2) in deep, high-methane mines in the eastern United 

States coal fields where, even after systematic methane drainage, methane is still too 

high for mining operations to be both efficient and safe. The first of these situations 

involves reducing the hazard of coal bumps in the working sections. If the added 

hazard of using belt entry air in the working sections is demonstrably less than the 

hazards of coal bumps in the working section, then the use of belt entry air at the 

face is justifiable. The second situation is again justifiable only if the hazards of 

using belt entry air in the working sections are less than the added hazards of 

methane occurrences when not using belt entry air at the working sections. This 

conclusion assumes that the belt air is properly monitored and AMS properly 

installed. In these two situations, the added belt entry air would most likely reduce 

the overall hazards and provide a higher standard of safety. 
 69

A close examination of some of the belt air petitions provided to the Panel indicates 

that, after over a period of 20 years, the belt air petitioning application has become a 

routine process providing only general statements and requests without specific 

convincing justifications for using belt air. The Panel concludes that there is a 

considerable sense that the relaxed practice of allowing belt air usage in the working 

section is often failing to provide the same degree of protection as a ventilation 

system that does not use belt entry air in the working section. It appears that in some 

mines the 2004 rule may result in a diminution of safety in these coal mines. The 

Panel recommends that any plan for the use of belt entry air in coal mine working 

sections be considered as part of the ventilation plan approval. The District 

Manager should be charged with the responsibility of ensuring that the belt air used 

in the working sections provides no less than the same degree of protection as the 

alternative of not using belt entry air in the working section. The Panel felt that a 

District Manager with technical and mining expertise would be better able to judge 

the merit of belt air usage than an Administrative Law Judge who knows the law 

but does not know how to ventilate a mine. 

Conclusion

All members of the Panel affirmed the recommendation.

References

Mine Safety and Health Administration. (2004). Underground Coal Mine 

Ventilation -- Safety Standards for the Use of a Belt Entry as an Intake Air 

Course to Ventilate Working Sections and Areas Where Mechanized Mining 

Equipment is Being Installed or Removed; Final Rule. Federal Register 69(April 

2, 2004): 17480-17530. 

Technical Study Panel. (2007). Special Requirements for the Use of Belt Air (see 

Recommendation 6). 
 70

RECOMMENDATION NUMBER 8 – DISCONTINUING POINT-TYPE HEAT 

SENSORS 

Except as stated below, the Panel recommends that MSHA initiate rulemaking 

that would discontinue the use of point- type heat sensors currently required 

under 30 CFR § 75.1103-4(a)(1) for early warning and detection of conveyor belt 

fires in U.S. underground coal mines. The Panel does not recommend 

discontinuing the use of point-type heat sensors for activation of belt fire 

suppression systems. 

Discussion 

The Panel was requested in opening remarks by Richard Stickler, Assistant 

Secretary, MSHA, to provide their thoughts on the use of Atmospheric Monitoring 

Systems, or AMS, instead of point-type heat sensors for conveyor belt fire detection. 

Even a cursory technical review of point-type heat sensors by the Panel revealed 

their inherent inadequacies for early warning and reliable belt fire detection; e.g. the 

amount of heat required to activate the sensor (stage of fire), and the possible 

location relative to fire location (at 125-ft spacing ). Also a body of research 

performed comparing fire detection capabilities using AMS type sensors for 

conveyor belt fire detection (such as CO sensors) versus the traditional point-type 

heat sensors have consistently shown the superiority of the AMS sensors over pointtype heat sensors; see for example USBM RI’s 9412 (Conti and Litton 1992) and 9572 

(Conti and Litton 1995) . In addition, general coal mining industry experience with 

the various belt fire detection sensors has demonstrated the superiority of the AMS 

type sensors over point-type heat sensors. The Panel does not recommend 

discontinuing the use of point type for activation of belt fire suppression systems. 

While in belt air mines the requirement for AMS systems dictates the use of these 

types of sensors for conveyor belt fire detection, it is obvious to the Panel that the 

enhanced safety improvement that these systems bring to those mines should be a 

requirement for all U.S. underground coal mines. The Panel believes that the record 

is clear that the use of the less-effective point-type sensors should have already been 

discontinued in favor of the more reliable and earlier warning detection afforded by 

AMS based sensors. The Panel also notes that requiring the use of AMS systems for 

conveyor belt fire detection would greatly facilitate the use of these systems for 

other coal mine safety enhancements. 

Conclusion

All members of the Panel affirmed the recommendation.
 71

References

Conti, R. & Litton, C. (1992). Response of Underground Fire Sensors: an Evaluation. 

Report of Investigation RI 9412. U.S. Bureau of Mines, Pittsburgh, 

Pennsylvania, 13 pages.

 Conti, R. & Litton, C. (1995). A Comparison of Mine Fire Sensors. Report of 

Investigations RI 9572, NTIS stock number: PB96-115233, U.S. Bureau of 

Mines, Pittsburgh, Pennsylvania, 10 pages. 

Francart, W. (2006). Reducing belt entry fires in underground coal mines. In: 

Mutmansky J and Ramani R. (eds.) U.S./North American Mine Ventilation 

Symposium, (Pp. 303-308). London, Taylor & Francis Publishers. 

Mine Safety and Health Administration. Section 75.1103-4 - Automatic fire sensor 

and warning device systems; installation; minimum requirements. Title 30 

Code of Federal Regulations. 
 72

RECOMMENDATION NUMBER 9 – SMOKE SENSORS 

The Panel recommends that MSHA consider rulemaking that would require the 

use of smoke sensors, in addition to CO sensors, in mines that use belt air on the 

working section, to provide for earlier warning and possibly more reliable 

detection of conveyor belt fires in these mines. MSHA should also consider 

rulemaking to revise 30 CFR §§ 75.1100-1103, Fire Protection, which was 

promulgated in 1972, in order to take advantage of advances that have occurred 

in fire detection and fire prevention technology. 

Discussion 

The Panel heard presentations regarding fire detection and the early warning of 

conveyor belt fires. This generated considerable discussion regarding reliable fire 

detection and the need for as early warning of these events - even in the incipient 

stage - as possible. A considerable body of research has shown that smoke sensors 

can be more sensitive to the early detection of mine fires than the CO sensors 

currently used in most AMS systems (see the first seven references below). The 

advantages of smoke sensors over CO sensors for early warning is partly due to the 

origins/mode of the conveyor belt heating/fire and the materials involved, e.g. 

producing significant smoke but little CO. It is obvious that multiple sensor types, 

used in combination, could provide earlier and more reliable detection. Given the 

concern for these goals in belt air mines, MSHA should consider requiring the use of 

smoke sensors in addition to CO sensors at three locations on belt lines directing belt 

air to the face: 

(1) not more than 100 feet downwind of each belt drive unit, each tailpiece transfer 

point, and each belt take-up. If the belt drive, tailpiece, and/or take-up for a single 

transfer point are installed together in the same air course they may be monitored 

with one sensor located not more than 100 feet downwind of the last component; 

(2) at or near the mid-point of the belt line; and 

(3) at or near the working section belt tailpiece in the air stream ventilating the belt 

entry. In longwall mining systems the sensor must be located upwind in the belt 

entry at a distance no greater than 150 feet from the mixing point where intake air 

is mixed with the belt air at or near the tailpiece. 

The Panel recognizes that the use of smoke sensors has been limited in coal mining 

applications due to: 

 (1) the rigorous environment in which they would be used, e.g. changing and high 

humidity, dusts, rock dusting, etc., and 
 73

 (2) the response and susceptibility of the sensor due to the environment with 

conditions depending upon the smoke sensor type - for example, ionization or 

optical based. 

As a result, reliability and maintenance issues have been problematic with previous 

smoke sensors evaluated in coal mines, especially along conveyor belt entries. 

However, NIOSH testified that they are currently evaluating newer, commercial 

smoke sensors that are being used in other harsh industrial environments that have 

the potential to better address past reliability and service life issues. Other smoke 

sensors under development with an eye toward improved functionality in the 

underground environment may also be available in a reasonable time frame. As a 

result, the Panel recommends that MSHA require the use of smoke sensors as part of 

the AMS installed along conveyor belts in mines where belt air is coursed to the 

working face with some delayed effective date to permit in-mine evaluation of the 

newest generation of smoke sensors. MSHA could include a phased 

implementation date to permit in-mine evaluation of the newest generation of 

smoke sensors. The Panel also recognizes that mandating the use of smoke sensors 

will create a small, but needed, market to encourage commercial development of 

coal mine-worthy smoke sensors which could ultimately upgrade coal mine fire 

protection systems in the future. 

The Panel recommends modifying the existing requirement for AMS usage to 

include smoke sensors as well as CO sensors under 30 CFR § 75.351(c)(2). Also, we 

recommend that 30 CFR § 75.351(d)(2) and (e) that currently only require the use of 

either CO or smoke sensors be modified to require the use of both CO and smoke 

sensors. In addition, this Panel strongly recommends that MSHA undertake 

rulemaking to revise Subpart L of 30 CFR on Fire Protection given the enormous 

technological advances in fire detection and fire prevention technology that have 

occurred since this Subpart was promulgated 35 years ago in 1972. 

Conclusion

All members of the Panel affirmed the recommendation. 

References

Conti, R. & Litton, C. (1992). Response of Underground Fire Sensors: an 

Evaluation. Report of Investigation RI 9412, U.S. Bureau of Mines, Pittsburgh, 

Pennsylvania, 13 pages.

Conti, R. & Litton, C. (1995). A Comparison of Mine Fire Sensors. Report of 

Investigations RI 9572, NTIS stock number: PB96-115233, U.S. Bureau of 

Mines, Pittsburgh, Pennsylvania, 10 pages. 
 74

Edwards, J. & Friel, G. (1996). Comparative In-Mine Evaluation of Carbon 

Monoxide and Smoke Detectors. Report of Investigations RI 9622. NTIS stock 

number: PB96-165188, U.S. Bureau of Mines, Pittsburgh, Pennsylvania, 11 

pages. 

Edwards, J., Friel, G., Franks, R., & Opferman, J. (1997). Mine fire detection under 

zero airflow conditions. Proceedings of the 6th International Mine 

Ventilation Congress, Chapter 52, Ramani RV, ed., Feb; (Pp. 331-336). 

Littleton, CO: Society for Mining, Metallurgy, and Exploration, Inc., 

Edwards, J., Franks, R., Friel, G., Lazzara, C., & Opferman, J. (1999). Mine fire 

detection in the presence of diesel emissions. Proc Eighth U.S. Mine 

Ventilation Symposium. University of Missouri-Rolla Press, Jun; (Pp. 295-

301). Rolla, Missouri. 

Edwards, J., Franks, R., Friel, G., Lazzara, C., & Opferman, J. (2003). In-mine 

evaluation of discriminating mine fire sensors Mine Ventilation. In: E. 

DeSouza, (ed.), Proceedings of the North American/Ninth U.S. Mine 

Ventilation Symposium (June 8-12, 2002), Kingston, Ontario, Canada. (Pp. 

527-532). A. A. Balkema Publishers, Lisse, Netherlands. 

 

Morrow, G. & Litton, C. (1992). In-Mine Evaluation of Smoke Detectors. 

Information Circular 9311, U.S. Bureau of Mines, Pittsburgh, Pennsylvania, 13 

pages. 

______________________ 

1Transcript June 21, 2007. Technical Study Panel Meeting, Birmingham, AL, Dave 

Litton, NIOSH. 
 75

RECOMMENDATION NUMBER 10 – USE OF DIESEL DISCRIMINATING 

SENSORS 

The Panel recommends that MSHA perform regular, periodic reviews of the 

AMS records required by 30 CFR. § 75.351(o) at mines using belt air to ventilate 

working sections. During these reviews at mines that also use diesel equipment, 

MSHA should evaluate the number of occurrences of false alarms due to diesel 

exhaust. In those instances where such false alarms are excessive, MSHA should 

require the use of a system of diesel discriminating sensors. 

Discussion 

The Panel is aware that historically one of the problems in using a CO-based AMS is 

the occurrence of false alarms (i.e. not a real fire). The Panel is also aware that an 

excessive number of false alarms can be detrimental to mine safety in that miners 

can become complacent to alarms and not respond appropriately when an alarm 

actually requires quick reaction. Presentations and references provided to the Panel 

strongly indicate that technological advances in these systems since their 

introduction in underground coal mines have greatly reduced the occurrence of 

false alarms. However, information presented was unclear as to the occurrence of 

false alarms at underground mines that utilize diesel equipment that may or may 

not use diesel discriminating sensors as part of their AMS. Therefore, the Panel 

recommends that MSHA conduct regular, periodic reviews of the AMS records 

required by 30 CFR § 75.351(o) at mines using belt air to ventilate working sections. 

One of the objectives of the record review should be to note the number and source 

of false alarms. During these reviews at mines that also use diesel equipment, 

MSHA should note the number of occurrences of false alarms due to diesel exhaust 

interaction. In those instances where such false alarms are excessive, MSHA should 

require the use of diesel discriminating sensors, as part of the AMS. Requiring the 

use of diesel discriminating sensors at diesel mines, where the diesel interference 

results in excessive alarms, should result in the development of improved AMS 

system capabilities that minimize this common reason for false alarms. 

Conclusion

All members of the Panel affirmed the recommendation. 

_____________

1 Francart, W. (2003). MSHA Survey- Atmospheric Monitoring Systems in U.S. 

Underground Coal Mines. Preprint 05-27. SME Annual Mtg., Feb. 28-Mar. 2, 2005, 

Salt Lake City, Utah, 5 pages. 
 76

RECOMMENDATION NUMBER 11 – REVIEW OF AMS RECORDS 

The Panel recommends that MSHA perform regular, periodic reviews of the 

AMS records required by 30 CFR § 75.351(o) at mines using belt air to ventilate 

working sections. During these reviews, MSHA should evaluate the number of 

false alarms due to sensor or system malfunction or due to other gases such as 

hydrogen that may affect the function of carbon monoxide sensors. In those 

instances where such false alarms are excessive, MSHA shall require appropriate 

steps to improve system maintenance and durability and, as needed, installation 

of sensors that are not subject to influence from other gases. 

Discussion 

Similar to the discussion following Recommendation 10, it is important that both the 

mine operator and MSHA review the AMS records for false alarms and other system 

malfunctions. For example, if the ambient CO reading in a mine is 3 parts per 

million (ppm), a reading of zero ppm is equally indicative of a malfunction as a false 

alert of 9 ppm. Both conditions must be addressed by proper system maintenance, 

calibration and testing, and malfunctioning sensors must be replaced as soon as 

possible to ensure continuing protection by the AMS. 

The Panel suggests that the review of AMS records for false alarms be conducted at 

least quarterly, concurrent with regular MSHA inspections. 

Critical reviews of AMS records fulfill an important surveillance function as they 

indicate trends of both improving and worsening system information quality and 

document to both the mine operator and MSHA how well the system is being 

maintained. 

The Panel is aware that an excessive number of false alarms can be detrimental to 

mine safety in that miners can become complacent to alarms and not respond 

appropriately when an alarm actually requires quick reaction. Presentations and 

references provided to the Panel indicate that technological advances in these 

systems since their introduction in underground coal mines have greatly reduced 

the occurrence of false alarms. 

As indicated by Francart (2003), certain types of sensors produce cross sensitivities 

to the presence of other gases such as hydrogen, leading to false indications of the 

gas concentration that is to be measured. Also, AMS systems are complex in nature 

and require maintenance through specially trained personnel. 

Therefore, the Panel recommends that MSHA conduct regular, periodic reviews of 

the AMS records required by 30 CFR § 75.351 (o) at mines using belt air to ventilate 
 77

working sections. One of the objectives of the record review should be to note the 

number and source of false alarms. MSHA inspectors should require mine 

operators to tune, calibrate and maintain their AMS systems properly in order to 

reduce the number of false alarms to an acceptable minimum. This also includes 

appropriate communication between maintenance personnel, the AMS operator and 

mine personnel to create awareness about maintenance and testing operations 

performed on the AMS, such that alarms intentionally set off during calibration and 

testing are not misinterpreted as real alarms. 

Conclusion

All members of the Panel affirmed the recommendation.

______________________ 

1 Francart, W. (2003). MSHA Survey- Atmospheric Monitoring Systems in U.S. 

Underground Coal Mines. Preprint 05-27. SME Annual Mtg., Feb. 28-Mar. 2, 2005, 

Salt Lake City, Utah, 5 pages. 
 78

RECOMMENDATION NUMBER 12 - AMS OPERATOR TRAINING 

CERTIFICATION 

The Panel recommends that MSHA commence rulemaking that would require 

the qualification and certification of AMS operators as defined by 30 CFR § 

75.301. The highest priority of the AMS operator is operating the AMS. 

Discussion 

The Panel reviewed some of the recent mine emergency events involving AMS 

operations (most notably the Aracoma mine fire event of early 2006). One aspect 

that stood out in many of these events was the critical actions (or non-actions) of the 

AMS operator. In some cases, mine operators may also assign the AMS operator to 

be the “Responsible Person” required to take charge during mine emergencies under 

30 CFR § 75.1501 – Emergency evacuations. In general, AMS operators involved in 

emergencies discussed during the TSP meetings and in accident investigation 

reports reviewed by the Panelists have not had sufficient training to unequivocally 

handle mine emergencies that occurred. The Panel believes that it is imperative that 

the AMS operator have the background, experience, training, and authority to 

ensure that proper actions are taken in response to all AMS signals, including alerts, 

alarms, and malfunctions to provide the utmost assurance of safety of all affected 

miners. AMS operator duties and responsibilities are contained in 30 CFR § 75.351- 

Atmospheric monitoring systems and 30 CFR § 75.352 -Actions in response to AMS 

malfunction, alert, or alarm signals. Specifically, AMS operator training 

requirements are contained in 30 CFR § 75.351(q) - Training. It requires that “All 

AMS operators must be trained annually in the proper operation of the AMS. A 

record of the content of training, the person conducting the training, and the date 

the training was conducted, must be maintained at the mine for at least one year by 

the mine operator.” The Panel concludes that there is no system in place to ensure 

that the AMS operator understands and retains the training elements to 

appropriately react to situations that may impact miner safety. In addition, there are 

no minimum qualifications, knowledge, or experience required to perform these 

duties. The training of the AMS operators is critical, especially if the AMS operator 

is not the responsible person under 30 CFR § 75.1501 and there is a delay in 

establishing contact with the responsible person, as happened during the Sago mine 

explosion. Thus, MSHA should establish a plan for training, certification, and recertification of all AMS operators. 

The Panel notes that in the history of coal mine health and safety there is an 

established system of certification/qualification for miners directing or performing 

duties that directly relate to their safety or the safety of others, as required by 

existing 30 CFR § 75.100 – Certified person. This is true of mine foremen, assistant 

foremen, mine examiners, shot firers, machine runners, and the miners themselves. 
 79

This certification/qualification has generally been handled by some governmental 

agency charged with or involved in coal mine safety. Therefore, the Panel feels it 

only stands to reason that some governmental agency should in some manner 

certify that AMS operators, who have such a key role in maintaining miner safety, 

have the basic qualifications and knowledge to perform their duties and 

responsibilities. The Panel also notes that the same might be said for the responsible 

person required in 30 CFR § 75.1501. In addition to the training the AMS operator 

receives on the proper operation of the AMS system and the requirements contained 

in 30 CFR relating to AMS systems, the Panel would also recommend that for those 

AMS operators, who do not spend some days underground, that MSHA require that 

at least a day be spent on a semi-annual basis by such AMS operators to familiarize 

themselves with the physical underground mine environment, as well as the 

particular mine infrastructure installations and mining practices. 

During field trips by Panel members, issues were raised regarding AMS operators 

concerning the length of their work day, i.e., long shifts, and the number and type of 

other job duties assigned to them not related to the AMS system. This resulted in a 

number of discussions among panel members and questions to Panel meeting 

presenters regarding these topics. Given the individuality and variance of these 

issues among coal mining operations, the Panel could not determine specific 

recommendations to address these possible concerns. However, the Panel 

concluded that it should be clear, given the key safety role of the AMS operator, that 

the highest priority of the AMS operator is operating the AMS. 

Conclusion

All members of the Panel affirmed the recommendation.
 80

RECOMMENDATION NUMBER 13 - MINIMUM AND MAXIMUM AIR 

VELOCITIES 

Minimum Air Velocity: In mines using AMS as a condition for using the belt 

entry to ventilate working sections, the minimum air velocity in the belt entry 

should be 100 feet per minute (fpm). 

 Maximum Air Velocity: In mines using AMS as a condition for using the belt 

entry to ventilate working places, the maximum air velocity should be 1,000 feet 

per minute (fpm). 

The District Manager may approve exceptions to the minimum and maximum 

air velocity recommendations in the mine ventilation plan. 

Discussion 

The main issues considered for establishing a minimum air velocity of 100 fpm are: 

(1) the transport time for products of combustion to reach the CO or smoke sensors, 

(2) the possibility of methane layering near the roof in gassy mines, and (3) the loss 

of visibility due to fog formation within the belt entry. 

Since the main objective of having an AMS is to detect fires and methane, there 

should be a minimum air velocity to transport the products of combustion from the 

fire source to the sensor. If the air is not moving at this minimum velocity and in the 

direction intended, then detecting the fire will be delayed. Further, due to the 

buoyancy force, there is a strong propensity for the layering of methane and smoke 

at low air velocities. 

In gassy mine airways with low air velocities, methane layering can also be a major 

concern. Methane, due to its low specific gravity (0.55 in relation to air) may 

accumulate at or near the roof of an entry at low air velocities to the point that it 

may reach explosive levels. The problem has been investigated by numerous 

authors and all of whom suggested that it can be prevented by considering a 

suitable Layering Number in the ventilation system design (McPherson, 1993; 

Hartman et al., 1997). This number combines the effects of three variables: methane 

emission rate, air velocity and width of an airway. For horizontal openings, this 

layering number should be equal to 5 (Bakke and Leach, 1962). In nearly all cases, 

the methane emitted from the coal on the belt conveyor would be mixed by the 

ventilation air and the belt movement and thus will not layer. However, methane 

originating from roof fissures or other high-methane sources may be a problem in 

the conveyor entry. While the 100 fpm recommendation is primarily for CO 

detection purposes, the additional velocity will also help ensure that the methane 

will not layer. 
 81

In deep underground mines (with cover depths greater than 2,500 ft) heat becomes 

an important factor in determining the ventilation needs. In openings with low air 

velocities and suspended dust particles, the strata heat may excite the water 

molecules and cause fogging (a safety hazard for belt maintenance workers due to 

frequent occurrences of poor visibility). This problem is magnified in belt entries 

with various sources of dust. The problem can be overcome by maintaining the air 

velocity in the belt entry equal to or greater than 100 fpm. At higher air velocities 

both evaporation and mixing of fog droplets will take place, thus helping to 

dissipate the fog (Gillies and Schimmel, 1983). 

The main reason for establishing a maximum velocity of 1,000 fpm is the physical 

discomfort created by the dust particles to the mine personnel and the added 

possibility of re-entrainment of dust from the moving belt (McPherson, 1993). 

Excessive air velocities will entrain settled dust and transport it for long distances 

within an airway. In belt entries with several sources of dust (stage crusher, transfer 

points, etc.), the distance over which these particles are carried by the air stream 

depends on the air velocity and the aspect ratio of the particles. Coal dust particles 

of larger aspect ratio will remain suspended in the air at high velocities. When this 

air is used to ventilate working sections, it will increase the dust concentration and 

cause discomfort among the workers (see Recommendation 17). 

Another reason for limiting the maximum air velocity to 1000 fpm is the fact that 

when the belt entry is used to ventilate a working section, it is likely that the 

conveyor belt and the air current will be moving in opposite directions in the belt 

entry. This will increase the relative velocity of the air (sum of air velocity and belt 

velocity). This increased velocity will result in a greater entrainment of dust 

particles. It will also increase the concentration of respirable dust and may require 

limitations to prevent exposure to excess levels of respirable dust (see 

Recommendation 17). This effect can be reduced but not eliminated by establishing 

this maximum air velocity. 

Increasing air velocity in the belt entry not only reduces the transport time from a 

CO source to the AMS sensor, it also dilutes the concentration of the CO. This 

requires lower alert and alarm levels in the AMS in order to get the same level of 

sensitivity to detecting a fire in the entry. If the mine operator intends to implement 

an air velocity above 1000 fpm in a belt entry where the air is coursed to a working 

section, the Panel recommends that the operator should still be required to get 

approval in the mine ventilation plan as currently required (30 CFR § 75.350 (a)(2)). 

Increasing air velocity in the belt entry not only reduces transport time from a 

source of CO to the AMS, it also dilutes the concentration of CO. This requires lower 
 82

alert and alarm levels in the AMS in order to get the same level of sensitivity to 

detecting a fire in the entry. 

While the Panel wishes to limit the minimum and maximum air velocity on the belt 

conveyor where belt air is used in the working section, the Panel also recognizes that 

the maximum and minimum velocity recommended here may present some 

problems in certain areas of a coal mine. Specifically, we note that the minimum 

velocity may be hard to achieve in the outby air split near a point-feed regulator. In 

addition, the maximum air velocity can be exceeded where the air meets a partial 

obstruction like an airway constriction at an overcast or undercast. The Panel 

therefore recommends that the District Manager be granted the authority to approve 

exceptions to the minimum and maximum velocities in these two areas and other 

specific areas if the mine conditions warrant the exceptions and if the exceptions 

each apply to a limited region of the mine. 

 

Conclusion

All members of the Panel affirmed the recommendation.

References

Bakke, P. & Leach, S. (1962). Principles of formation and dispersion of methane roof 

layers and some remedial measures. The Mining Engineer, Paper 3925. July, 

121(22): 645-658. 

 

Hartman H., Mutmansky, J.., Ramani, R., & Wang, Y.J. (1997). Mine Ventilation and 

Air Conditioning, John Wiley & Sons, Inc., (Pp. 455-523). New York, New York. 

Gillies, A. & Schimmel F. (1983). Atmospheric fogging in underground mine 

airways. Mining Engineer, April, Pp. 336-342. 

McPherson, M. (1993). Subsurface Ventilation and Environmental Engineering,

Chapman & Hall, London, United Kingdom, Pp. 282-321. 
 83

RECOMMENDATION NUMBER 14 – ESCAPEWAYS AND LEAKAGE 

Primary escapeways should be designed, constructed, and maintained in 

accordance with the provisions of 30 CFR § 75.333 (b)-(d) to minimize the air 

leakage. 

Primary escapeways should be ventilated with intake air preferably and, to the 

extent possible, the primary escapeway should have a higher pressure than the 

belt entry. 

Discussion 

Primary and alternate escapeways should be designed and constructed to protect 

the integrity of the mine atmosphere in these airways. They should be located to 

follow the most direct safe route from a working section or panel to the surface. 

These escapeways should be effectively separated from each other and from other 

entries by permanent stoppings, doors and overcasts. Although these are physically 

separated from each other by means of stoppings and doors, the committee felt that 

the two escapeways may be side-by-side if the stoppings are adequately designed 

and maintained. 

Both primary and alternate escapeways should be maintained in travelable and safe 

conditions at all times. They should be kept free of potential sources of fire in 

accordance with the provisions of 30 CFR§ 75.380(f). The operator should develop a 

program for coal dust clean-up and equipment maintenance in both escapeways. 

Stoppings and doors (including personnel doors) along the escapeways should be 

clearly marked so that they can easily be identified. Consideration should be given 

to requiring that personnel doors along escapeways be structured to form an air lock 

when exceeding a certain force to open due to a pressure differential. For example 

when the pressure force on 3 ft x 4 ft personnel doors is greater than 125 lb, for 

safety reasons, these doors should be installed in pairs to form an airlock door (30 

CFR § 75.333(d)(3)). Further, these should be clearly marked and posted on the 

ventilation maps. 

To protect the integrity of the mine atmosphere underground, both escapeways 

should preferably be ventilated with intake air. This allows positive pressure 

differentials across the stoppings to be maintained, thus causing the leakage flow to 

move in the right direction from the escapeways to the adjacent entries. However, 

the Panel recognizes that with multiple fans in complex ventilation systems there 

will be cases of cross leakage flows of air from one entry to another. The negative 

effects of such cases should be minimized by improving the quality of the stoppings 
 84

and doors, i.e., by developing improved stopping and door designs, and utilizing 

state of the art construction techniques. 

When the belt entry is ventilated with intake air and a fire occurs in the belt entry, 

the fresh air is at the back of the fire fighters and the flame and smoke flowing away 

from them. This situation protects the workers from toxic gases and allows keeping 

the fire fighting units in good and safe operating conditions (Bookshar, 2007). This 

increases the probability of success of the fire fighters to control the fire. 

Some air leakage through ventilation structures (stoppings, doors and/or overcasts) 

is unfortunately unavoidable, and is often characterized by a significant loss of fresh 

air to the return. In coal mines it often represents approximately 50 percent of the 

total quantity of air circulated by the main fan(s). When belt air is used for working 

section ventilation and is at a higher pressure than the escapeway, there is a risk of 

contaminating the escapeway with smoke and hazardous fumes from the belt entry. 

The risk is even greater when the stoppings are subject to deformations caused by 

external forces (geologic, pneumatic or due to concussion) inducing higher leakage 

rates. To reduce leakage from the belt entry to the escapeway, the stoppings and 

personnel doors in them should be constructed of non-combustible materials of 

sufficient strength, installed adequately, and maintained regularly. Additionally, reapplication of sealants to the stoppings and immediate surrounding strata may be 

considered. 

Main entry stoppings, especially those near the surface fans, should be constructed 

of solid concrete blocks or reinforced yielding stoppings. These structures should be 

lined with sealants applied to the entire face from the high pressure side. Because of 

their location in relation to the main fans, these stoppings are subject to higher 

pressure differentials, thus increasing the air leakage. To ameliorate these effects, 

these stoppings should be inspected regularly and repaired promptly. 

Studies have shown that by using these types of stoppings leakage rates as low as 

140 cfm/ 100 ft2/ in. water gauge can be achieved (Timko and Thimons, 1982; 

Dupree et al., 1993). 

For longwall panel entries, often located several miles away from main fans, thus 

having less pressure differentials across the stopping line, hollow cinder blocks or 

metal panel or yielding stoppings may be used. However, they still should be sealed 

from the high-pressure side. Ventilation surveys have shown that for yielding 

stoppings the leakage flow rate is in the order of 300 cfm/100 ft2/ in. water gauge 

(Kennedy, 1996). 

In underground mines, the continuous change in airway characteristics (increased 

mine resistance due to airways closing in as a result of convergence and increased 
 85

air traveling distance due to mine development) creates imbalances in the airflow 

distribution. In coal mines, these imbalances are corrected by adjusting regulators or 

point feeds at the expense of higher overall mine resistance. As the resistance is 

increased more fan pressure is required to ventilate a section or panel. More 

pressure induces more leakage. 

Conclusion

All members of the Panel affirmed the recommendation. 

References

Bookshar, W. (2007). Submission via E-mail to the Panel, June 28. 

Dupree, W., Schultz, M., & Francart, W. (1993). The Effect of Stopping Leakage on 

Intake Escapeway Integrity. Proceedings of the 6th U.S. Mine Ventilation 

Symposium, SME, (Pp. 13-17). Littleton Colorado. 

 

Kennedy, W. (1996). Practical Mine Ventilation, Intertec Publishing, (Pp. 37-55). 

Chicago, Illinois. 

Timko, R. & Thimons, E. (1982). Sulfur Hexafluoride as a Mine Ventilation Research 

Tool- Recent Field Applications. Research Investigation RI 8735, U.S. Bureau 

of Mines, Washington, D.C., 15 pages. 
 86

RECOMMENDATION NUMBER 15 – LIFELINES 

The Technical Study Panel endorses the lifeline regulations promulgated by 

MSHA (Federal Register, 2006) but is recommending two additional methods of 

strengthening the rules. First, the Panel recommends that all coal mine lifelines 

be standardized across the country with regard to the tactile signals attached to 

the lifeline. Second, the Panel recommends that three standardized tactile 

signals be designed to indicate (1) impediment to travel ahead (door, regulator, 

overcast, pool of water, etc.), (2) SCSR cache in the adjacent crosscut, and (3) to 

the doors located in the crosscut. 

Discussion 

The lifeline regulations published in the Federal Register (MSHA, 2006) are clearly 

logical additions to the safety measures now being implemented in U.S. coal mines. 

In particular, the directional nature of the cones, the reflective markers utilized, the 

flame-resistant nature of the lifelines, and the ability of the lifelines to lead escaping 

miners to the SCSR caches are all important positive attributes of the lifeline system. 

However, only a portion of the capability and potential of a lifeline system is being 

utilized, and the Technical Study Panel recommends that more of the possibilities be 

implemented in the lifeline regulations. 

The possibility that additional tactile signals to miners would be quite useful has 

been suggested in a NIOSH publication IC 9481 (Conti et al., 2005). In that 

publication, the authors mention that “we recommend that two directional 

indicators be mounted together on the lifeline approximately 6 to 10 feet from a 

door, regulator, etc.” This signal to escaping miners would clearly warn them of 

potential hazards ahead in their travel path. In addition to the hazards mentioned in 

the NIOSH publication, the tactile signal could also be used for water sumps, 

overcasts, and tripping hazards like haulage tracks. This suggestion by the NIOSH 

authors is quite logical and indicates the potential of using the lifeline for a variety 

of tactile signals. 

In considering the potential to add additional signals to the lifeline, the signals must 

provide clear tactile indications of the three important items suggested above. The 

signals may simply be cones placed back-to-back as suggested in IC 9481 or the 

regulations may call for the signals to be transmitted by touch to the miner using 

items attached to the line of a different shape (for example, 2-inch-diameter spheres). 

It would not be difficult to implement these additional signals on the line. One 

possible scheme would use the following attachments: 

(1) two back-to-back directional cones to indicate an impediment in the travel 

path, 
 87

(2) four back-to-back directional cones to indicate a door into an adjacent 

escapeway (plus an attached line leading to the door), and 

(3) six back-to-back directional cones to indicate a SCSR cache (plus an attached 

line leading to the cache). 

These signals should be researched for practicality and easy detection by both 

gloved and ungloved miners before they are implemented. 

With the attachment of additional signals to the lifeline, it becomes essential that the 

lifelines and the signals attached be standardized across the coal industry. Miners 

may work at several mines within their company and many change companies 

several times during their career. Standardization reduces the possibility of 

confusion in an emergency. In addition, the signals when standardized can be 

printed on reflective hat stickers to be placed inside the hard hats of working miners 

so that they will always have a readily available reference that can be read even in a 

smoky mine opening. 

In assessing the cost of implementing these recommendations, it appears that most 

of the costs are in the lifeline itself and that the added lifeline signals would result in 

only modest additional costs. The primary manufacturer of lifelines (Cambria 

Association for the Blind, Ebensburg, PA) has said that they have split cones that can 

be added after the lifelines are in place (Fuller, 2007). This should make the 

standardization quite achievable in mines that already have an alternate lifeline 

tactile system in place. In addition, standardizing the lifelines and the signals would 

allow more manufacturers to enter the market and may result in less expensive 

lifelines. Standardizing may thus reduce the costs of lifelines even if added features 

are being required in the regulations. 

Conclusion

All members of the Panel affirmed the recommendation.

References

Conti, R., Chasko, L., Wiehagen, W. & Lazzara, C. (2005). Fire Response 

Preparedness for Underground Mines. Information Circular 9481, NIOSH, 19 

pages. 

Fuller, P. (2007). Cambria Association of the Blind, Phone Conversation of July 31. 
 88

Mine Safety and Health Administration. (2006). Emergency Mine Evacuation, Final 

rule. Federal Register 71(December 8, 2006,):71430-71455. 
 89

RECOMMENDATION NUMBER 16 – POINT-FEEDING 

The Technical Study Panel recommends that when point-feeding from adjacent 

entries into the belt entry is performed to supplement air flow through the belt 

entry, as provided by 30 CFR § 75.350(d), those mines have an additional 

requirement to more quickly provide two separate escapeways in an emergency 

situation. Specifically, the Panel recommends that two CO sensors be placed in 

the primary escapeway outby every point-feed regulator with 1,000 feet of space 

between the two (if possible). We propose that if both of these monitors reach 

the CO alert level of the mine, or if one sensor reaches the alarm level, a warning 

signal be given at the regulator location. The AMS operator shall then have the 

ability and authority to remotely close or open the point-feed regulator after 

consulting with the responsible person. The section foreman in the affected 

section must also be notified so that checking on the cause of the problem and 

evacuation can be initiated in a quick and orderly manner. 

Discussion 

The field visits to mines, the testimony of rescue experts, and the study of mine 

ventilation systems have led the Technical Study Panel to conclude that the pointfeed procedure when using belt entry air in the working section can present 

significant problems for face workers if a fire were to occur in the primary intake 

outby the point-feed regulator. In some mines, the face area of a longwall may be 

up to 15,000 feet from the point-feed regulator (Fiscor, 2007). In a two-entry 

longwall section and in some other section layouts, this may result in both the 

primary and secondary escapeways being contaminated with CO and smoke before 

anyone can manually close the regulator. 

The testimony given by Dr. Fred Kissell at the Pittsburgh meeting of the Technical 

Study Panel supports an improvement over the current regulations in the closing of 

the point-feed regulator. In his presentation, Dr. Kissell stated that there were four 

common features that were often associated with fatal events involving mine fires. 

These features are: 

(1) delayed evacuation, 

(2) lack of lifelines, 

(3) confusion in locating escapeways, and 

(4) malfunction of SCSRs. 
 90

These conclusions are based on a variety of research efforts outlined in publications 

by Goodman and Kissell (1990), Kissell and Litton (1992), and Kissell, Timko, and 

Litton (1993). 

Items (2) and (4) in Dr. Kissell’s list are being better addressed by recent standards 

and, to a great extent, these problems should be less troublesome in future years. 

Features (1) and (3) can be better addressed by improved speed in initiating an 

escape and a better knowledge of which escapeway will be required in an escape. 

However, the seriousness of a delay in initiating an escape would be greatly reduced 

if the point-feed regulator were closed remotely and quickly in case of evidence of a 

fire in the intake because the closure would more adequately separate the two 

section escapeways without waiting for the section foremen to travel to the pointfeed regulator to determine the cause. In addition, the closing of the point-feed 

regulator is an indication that the primary intake is contaminated and that escape is 

required through the belt entry. This should provide valuable information so that 

the atmospheric monitoring system (AMS) operator and the section foreman can 

better choose the proper escape path. Thus, delays and confusion would both be 

lessened, though some negative effects of these elements may still exist. 

One positive aspect of this recommendation is that this problem can be adequately 

addressed by harnessing the technology already available in mines using belt air at 

the face, i.e., the AMS. The AMS can provide a means of detecting a fire or other 

CO-producing event in the primary escapeway and should produce very few 

nuisance events. AMS manufacturers have reported at the Birmingham meeting of 

the Technical Study Panel that oversight and control functions can be readily 

programmed as part of the normal functions of atmospheric monitoring. It appears 

to be technically feasible. 

The Technical Study Panel recommendation on the 1000-foot spacing of the two CO 

sensors to be located outby the point-feed regulator was made to eliminate some of 

the possible false alarms that may occur if a non-threatening source such as a piece 

of diesel equipment is responsible for the elevated CO readings. The recommended 

spacing may be impractical or impossible if the point-feed regulator is located near a 

shaft bottom or in certain other mine locations. The spacing should be adjustable to 

meet the layout of the individual mine layouts. 

It should be noted that in mine layouts where the secondary escapeway is located in 

a return entry beside the primary escapeway, such as in many three-entry longwall 

sections, the closing of the point-feed regulator does not provide the same 

improvement in safety for the section workers. In these mines, this recommended 

management of the point-feed regulator is not necessary. The usefulness of this 

recommendation will thus apply to a portion but not all mines. 
 91

It is necessary when considering the institution of a remotely activated system to 

evaluate any negative effects that may be produced by the remote activation. 

MSHA personnel have advised that the remote closure of the point-feed regulator 

may reduce air flow to the working section and raise the chance of methane buildup. 

For this reason, the remote closure should be affected only after checking with the 

section foreman so that he may remove his section personnel from the working face 

and deactivate the section power. Other possible secondary effects should also be 

evaluated before the remote closure plan is utilized. The Technical Study Panel 

recognizes the need for a thorough review of possible effects before instituting such 

a plan. 

Conclusion

All members of the Panel affirmed the recommendation. 

References

Goodman, G. & Kissell, F. (1990). Evaluating those factors that influence escape 

from coal mine fires. SME Transactions, 286: 1801-1805. 

Fiscor, S. (2007). U.S. Longwall Census. Coal Age, 112(2): 30-38. 

Kissell, F. & Litton, C. (1992). How smoke hinders escape from coal mine fires. 

Mining Engineering, 44(1): 79-83. 

Kissell, F., Timko. R., & Litton, C. (1993). Ranking factors impacting survival during 

coal mine fires. Mining Engineering, 45(8): 1077-1083. 
 92

RECOMMENDATION NUMBER 17 – RESPIRABLE DUST 

Respirable dust concentrations in the air coursed through a belt conveyor entry 

and used to ventilate working sections should be as low as feasible and must not 

exceed the current regulated concentration of 1.0 mg/m3. District managers shall 

have the authority to force improvements in dust control in the belt entry if the 

dust concentration exceeds an 8-hour TWA of 1.0 mg/m3 or is shown to be raising 

the concentration in the working section above the exposure limit. If the 

improvements are not effective, the District Manager shall have the authority to 

revoke the authorization to use belt air in the working section. 

Discussion 

The potential for a high concentration of dust in the belt airway contributing to an 

increased dust concentration in the downstream working sections exists in any 

system where belt air is coursed through a working section. The respirable dust 

concentrations normally found in belt entries using both operator and inspector 

samples averages 0.5 mg/m3 (Schultz, 2007). This average concentration of dust 

would suggest that the dust concentrations in the belt air coursed to the face would 

not normally be much of a problem. 

However, the variation in the average dust concentrations in Schultz’s data was 

quite high with operator samples taken in the belt entry showing a maximum of 

about 7.8 mg/m3 of respirable dust concentration and inspector samples showing 

dust concentrations as high as 2.0 mg/m3. This maximum concentration data, which 

may be a result of poor ventilation or poor dust controls in that particular area, 

shows a more problematic situation and the potential for the belt air to increase the 

average dust concentration in the working section. Considering that the primary 

intake entries must contribute at least 50% of the total air to the section (30 CFR 

73.350(b)), dust concentration calculations indicate that the belt air will not increase 

the average dust concentration at the face unless the belt air dust concentration is 

higher than that measured at the working face. 

To perform an analysis of the contribution of dust in the belt air used in the section, 

it is possible to derive a formula using basic principles of air flow (Haney, 1996). In 

Haney’s paper, the dust concentration of the intake air to the section, Ce, is 

calculated as follows: 

i b

i i b b

e Q Q

C Q C Q C

+

× + × = ( ) ( )

 (1) 

where: 

Ci = dust concentration in the main intake, mg/m3 

Cb = dust concentration in the belt entry, mg/m3
 93

Qi = intake air quantity, m3/s 

Qb = belt entry air quantity, m3/s 

This establishes the dust concentration at the intake to the section, but to determine 

whether the belt air is raising or lowering the dust concentration in the working 

section, it is necessary to determine the mass of dust that passes through that area 

and the contribution of the face equipment. The mass of dust that passes through 

the face (assuming that belt air is used at the face) is: 

Mf = Cf(Qi+Qb) (2) 

where: 

Mf = mass of dust passing through the face, mg/s 

Cf = dust concentration at the face when using belt entry air at the face, 

mg/m3 

The contribution of the face equipment to the total dust (in mg/s) can then be 

calculated as: 

Ms = Mf - (Ci×Qi) – (Cb×Qb) (3) 

The dust concentration in the face area if the belt air is not used at the face can then 

be calculated as: 

i b

s i i b

f Q Q

M C Q Q C −

+ × − = ( ( )) ' (4) 

This last calculated value of Cf

’

(for belt air not used at the face) can then be 

compared to the previous determined value of Cf (for belt air used at the face) to 

determine whether or not the dust concentration is increased or decreased by using 

belt air at the face. 

While the calculations are somewhat complicated and are only an approximation, it 

is often possible to come to conclusions based on a comparison of the belt entry air 

concentration and the dust concentration at the face when belt entry air is used at 

the face. If the belt entry air concentration is lower that that at the face (when using 

belt entry air at the face), then the belt entry air will not cause an increase in the dust 

concentration at the face. If the dust concentration of the belt entry air is higher than 

in the working section (when using belt entry air at the working face), it is then 

necessary to use equations (3) and (4) above to determine whether the belt air will 

increase or decrease the dust concentration at the working face. 

 
 94

If the belt air dust concentration is higher than that at the working face, it would be a 

clear indication that the dust controls on the belt may be in need of improvement. 

Because the principal source of dust in belt entries appears to be at transfer points, 

simple improvements such as better sprays and shrouds at the transfer points may 

bring down the dust concentrations. In addition, it may be possible to reduce the 

velocity of air in the belt airway and the amount of dust re-entrainment as a means 

of reducing the dust concentrations. Whatever improvements are possible through 

the use of engineering controls, the operator must be encouraged to implement them 

or to use air from a cleaner air source. 

Where the controls fail to bring the belt air dust concentrations to or below the 

average dust concentrations measured at the working face, it would be best for the 

health of the workers if the District Manager were to decide to divert the dust away 

from the face, i.e., terminate the use of belt air at the working face. This would be in 

accordance with the Federal Mine Safety & Health Act of 1977 where it states in 

Section 303(b) that “the Secretary or his authorized representative shall prescribe the 

maximum respirable dust level in the intake air courses in each coal mine in order to 

reduce such level to the lowest attainable level.” 

The words quoted from the 1977 Act may not have been directed toward the use of 

belt air at the face. However, they apply very well to the use of belt air at the face in 

terms of the general rule stated, i.e., that a mine should always strive to achieve the 

lowest attainable dust level. In a mine where use of belt air at the face is a 

possibility, the lowest attainable dust level may be associated with the use of belt air 

or it may be a result of not using the belt air at the face. The District Manager should 

have the freedom to reject the use of belt air at the face if it is an appropriate method 

of dust reduction. 

Conclusion

All members of the Panel affirmed the recommendation.

Reference

Haney. R. [after 1993]. Effect of belt air on dust levels in underground coal mines. 

Department of Labor, Mine Safety and Health Administration. Pittsburgh, 

Pennsylvania. 10 pages. 

Schultz, M. (2007). Response to Panel Questions in an E-mail of Feb. 2. 
 95

RECOMMENDATION NUMBER 18 – MINE METHANE 

The methane gas released from broken coal on the conveyor belt and from the 

belt entry presents a problem in some mines that can affect the ability to keep 

the methane gas below 1% at the working place. It is therefore recommended 

that the MSHA District Manager shall require adjustments to the ventilation 

system if the belt air is being utilized on the working section and is causing 

difficulty in keeping the methane below 1% in the working place. In addition, it 

is recommended that the District Manager regularly scrutinize any working 

section that has methane readings at or above 0.5% methane (measured 200 feet 

outby the tailpiece of the belt) to prevent the gas liberated on a conveyor belt or 

from the belt entry from increasing the methane content at the working place 

above 1.0%. 

Discussion 

Members of the Technical Study Panel inquired of MSHA staff members as to the 

number of continuous miner and longwall working faces that have problems with 

the methane being liberated on conveyor belts and then raising the methane content 

of the air on the working face. Data on that topic was rather sparse, but some of the 

MSHA personnel did have knowledge of specific mines where such problems 

existed. Mark Eslinger, Supervisory Mining Engineer at MSHA Coal Mine Safety 

and Health District 8, had general knowledge of one mine where the rib liberation 

caused the belt air to be quite high (Eslinger, 2007). At this mine, the air on the belt 

was reversed to ease the methane problems at the working face. Eslinger also made 

mention of a mine where methane contents of up to 5% were measured by 

inspectors in the belt entry. However, this mine did not use belt air at the face. 

Bill Knepp, Assistant District Manager, Technical Services, MSHA Coal Mine Safety 

and Health District 9, mentioned high methane contents in the belt entries at the 

mines of the Mid-Continent Coal and Coke Company near Carbondale, Colorado 

(Knepp, 2007). In those mines, the huge amounts of methane emitted and the 

amounts of ventilation air required in the longwall faces required monitoring of the 

methane on the belt entry to ensure better control of the methane at the working 

face. 

Additional information on the potential for gas liberated in the belt entry is found in 

the publication by Krog et al. (2006). It that study, the methane emitted by the four 

major sources on a longwall working section in Southwestern Pennsylvania was 

measured over a three-day period. The measurements showed that the methane in 

the belt entry from the broken coal and the rib contributed about 20% of the total 

methane that was generated on the working section. Because this mine had 

slowdown periods due to the methane content at the shearer, it was a candidate for 
 96

having the belt air put on an outby ventilation flow. This type of a mine using belt 

air at the face would likely have two choices for reducing the methane at the 

working face: reverse the air in the belt entry or institute a degasification system to 

reduce the methane. In some cases, particularly where the gas cannot be easily 

marketed, reversing the belt air may be both the safest and the most economical 

method of handling the methane. 

While the number of mines for which gas emissions in the belt entry are a significant 

problem may be small, the problem of gas emitted in the belt entry cannot be easily 

dismissed. Accordingly, the gas contents at the end of the belt entry should be 

carefully scrutinized in all mines using belt air at the working face to ensure that the 

methane contents at the face are kept at safe levels. 

Conclusion

All members of the Panel affirmed the recommendation. 

Reference

Eslinger, M. (2007). E-Mail to W. Francart Dated July 19. 

Knepp, W. (2007). Phone Conversation of July 2 with Jan Mutmansky. 

Krog, R., Schatzel, S., Garcia, F., & Marshall, J. (2006). Predicting methane emissions 

from longer longwall faces by analysis of emission contributors,” 

Proceedings, 11th U.S./North American Mine Ventilation Symposium, (Pp. 

383-392). Taylor & Francis, London, United Kingdom. 
 97

RECOMMENDATION NUMBER 19 - INSPECTIONS 

The Technical Study Panel considers the inspection of mines utilizing belt air in 

the working section as a priority that must be addressed. Accordingly, the Panel 

recommends that a more structured procedure be instituted to help mine 

inspectors complete their inspection duties with greater ease and efficiency and 

reduce chances of overlooking safety hazards. This recommendation is aimed at 

the mines using belt air in the working section, but can be applied to any 

underground coal mine. 

Discussion 

The impetus for this recommendation comes from a study of the Report of 

Investigation of the Aracoma Alma Mine #1 mine fire of January 19, 2006 (MSHA, 

2007). In that report, there is a large compilation of significant and substantial 

violations of federal mining regulations. Many of these violations should have been 

identified in the inspections that occurred prior to January 19 of 2006. With the 

potential for serious repercussions when using belt air at the face, the inspection of a 

mine in this category should have a list of required checks that must be made and 

measurements that must be accomplished to ensure that the belt air ventilation 

system is being safely used and the mine emergency evacuation and fire protection 

standards are strictly followed. 

Data gathering for the purpose of identifying the need for this recommendation was 

almost entirely performed by talking to MSHA personnel about inspection practices 

and procedures. The first contact on this topic was with Bill Knepp on July 2, 2007, 

and covered a number of topics including inspection procedures (Knepp, 2007). 

That conversation answered some questions, but left others unanswered. The topic 

was again taken up on August 9, 2007. 

The Aracoma Alma Mine Report of Investigation and discussion with MSHA 

personnel seem to indicate that more structured reporting procedures for MSHA 

inspectors may be in order for mines using belt air at the face (and perhaps for all 

underground coal mines). In 2006, MSHA attempted to adopt a computerized 

inspection tracking system as a means of better analyzing mine performances in 

keeping within the safety regulations. One MSHA manager (Dupree, 2007) reported 

that the tracking system ran into trouble because it was not user-friendly and 

inspectors were simply required to rewrite their underground notes taken during 

inspections. As a result, the computerized system was dropped and MSHA now 

uses the hand-written notes of the inspectors as the record of inspections. 

The Internal Review of MSHA’s Actions at the Aracoma Alma Mine #1 (MSHA, 

2007a) indicates that the current system of inspections does not have internal checks 
 98

to ensure that the inspection reports have covered all the essential facts needed to 

keep the belt air and many other important safety standards enforced. It is therefore 

recommended that MSHA develop and perfect a set of procedural requirements for 

inspectors of underground coal mines that requires the team of inspectors to 

respond to every inspection requirement. A research effort should be initiated to 

decide whether computerization can be implemented to ease the inspector’s job, 

particularly with regard to knowing exactly what is required in an inspection and 

entering his/her reports after each mine visit. The job of the inspector may become 

more complicated if this recommendation is adopted. Computerization may be one 

way of easing the burden as well as making the inspection process more effective in 

detecting problems and for easy system-wide data tracking. 

While computerization of the inspection procedure may take a considerable amount 

of time and effort to accomplish at the beginning, the regimentation of inspections 

requirements may be accomplished by computer-aided methods regardless or 

whether or not the reporting is computerized. MSHA personnel are clearly capable 

of outlining the inspection requirements for each type of coal mine (longwall vs. 

room-and-pillar, single-split versus double-split, belt-air mine vs. non-belt-air mine, 

etc.). Both the Aracoma Report of Investigation (MSHA, 2007) and the Internal 

Review (MSHA, 2007a) support the need for a strong effort to upgrade the 

inspection procedures utilized by MSHA. 

While the Technical Study Panel recognizes that the primary goal in our charge was 

to investigate the use of belt air in working sections, our suggestion that MSHA 

inspections be more structured can be applied to any underground coal mining 

system. It is our firm belief that more structured inspection procedures will help 

MSHA inspectors do their job and perform it in a more efficient manner. The 

Technical Study Panel therefore suggests that Congress may wish to implement 

more structured inspection procedures for all underground coal mining systems and 

that this process be initiated immediately. 

Conclusion

All members of the Panel affirmed the recommendation.

References

Dupree, A. (2007). Assistant District Manager, MSHA Coal Mine Safety and Health 

District 5, Phone Conversation of August 10. 

Knepp, W. (2007). Assistant District Manager, MSHA Coal Mine Safety and Health 

District 9, Phone Conversation of July 2. 
 99

Mine Safety and Health Administration. (2007). Report of Investigation, Fatal 

Underground Coal Mine Fire, January 19, 2006, Aracoma Alma Mine #1, 

Aracoma Coal Company, Inc., Stollings, Logan County, West Virginia, I.D. 

No. 46-08801. Coal Mine Safety and Health, Arlington, Virginia. 164 pages. 

 Mine Safety and Health Administration. (2007a). Internal Review of MSHA’s 

Actions at the Aracoma Alma Mine #1, Aracoma Coal Company, Inc., 

Stollings, Logan County, West Virginia, 181 pages. 
 100

RECOMMENDATION NUMBER 20 - RESEARCH 

The Technical Study Panel recommends that research utilizing ventilation 

modeling, engineering design and risk analysis be performed to investigate the 

following areas: 

(1) development of guidelines for improved escapeway design in various 

ventilation situations, 

(2) ways to reduce air leakage through ventilation controls, and 

(3) use of booster fans in underground coal mining operations. 

Discussion 

The use of point-feed regulators presents an inherent problem that may be 

addressed by changing the ventilation systems to eliminate the point-feeding 

concept. A number of systems are possible. Some alternatives are as follows: 

(1) using two intake air streams totally separated from the air intake points to the 

working sections, 

(2) implementing secondary escapeways in return entries when belt air is used at 

the face, 

(3) using belt conveyors in return entries of longwalls with both escapeways in 

intake air splits, and 

(4) using tertiary escapeways in certain mining systems. 

In alternative (1) above, the totally separated belt intake has a number of advantages 

with some dust and gas disadvantages also being possible. But the totally separated 

belt has a major escape advantage if a fire occurs on the belt. However, it is more 

difficult to fight a fire on the belt when the ventilation is in the outby direction. 

For alternative (2), the use of a return entry for escape has been utilized in coal 

mines at times. In a longwall system, the return may be a good escape route if the 

headgate entries are filled with smoke or other problems are causing the primary 

escapeway to be a poor avenue for egress. In such a situation, a return airway may 

be a wise choice for escape. One major disadvantage would be the difficulty of 

keeping the return escapeway clear of any falls or other impediments to escape and 

the difficulty of keeping ahead of the smoke in an escape attempt. 

The use of belt conveyors in the return is a practice that has been used in other parts 

of the world, but is used less frequently in the United States. One major appeal of 

this system is that the dust and/or methane generated on the belt conveyor system 
 101

is not carried to the face. In addition, the combustion products of a belt fire are 

carried away from the face, making a belt fire much less of a hazard. However, use 

of the belt in the return may require more maintenance to keep the entry free of roof 

problems and will normally result in more difficulties when attempting to fight a 

belt fire. 

The use of a tertiary escapeway may be the most prudent manner of improving 

escape probabilities in some mining systems. If both the primary and secondary 

escapeways are intakes and a major fire or explosion occurs in the intake, then a 

tertiary escapeway in the return air may be the safest escape path possible. 

The Technical Study Panel acknowledges that there may be some impractical 

suggestions in the list of topics above. However, it is important to realize that not 

many of the overall possibilities have been thoroughly evaluated. We have 

provided some alternatives that have departed from the norm in the hopes that we 

can improve underground safety in the future. Researching all the alternatives 

appears to be appropriate at this time. 

In addition to developing guidelines for improved escapeway designs, the Panel 

identified two other research topics: methods to reduce air leakage utilizing 

improved ventilation controls and use of booster fans in underground coal mines. 

In underground mines, the continuous change in airway characteristics due to 

airways closing in as a result of convergence and increased air traveling distance 

due to mine development creates imbalances in the airflow distribution. In coal 

mines, these imbalances are corrected by isolating mined out areas using permanent 

stoppings or installing regulators resulting in higher overall mine resistance. As the 

resistance is increased more fan pressure is required to ventilate a section or panel. 

More pressure induces more leakage. The leakage quantities can be reduced by 

improving the quality of these ventilation controls: stoppings, doors and regulators 

(Kennedy, 1996). Research is needed on durable stopping construction materials, 

improved designs and construction techniques for these controls, and most 

importantly, the development of environmentally friendly and cost effective sealant 

materials. 

Another alternative to reduce leakage is to utilize booster fans. A booster fan, when 

sized and located properly, can not only be used to assist main surface fans but also 

reduce leakage and make more air available to ventilate the working areas. The 

main problem with booster fans is the possibility of uncontrolled recirculation in an 

inadequately designed system (Crocco, 2007). However, with the advent of reliable 

atmospheric monitoring systems and through their early detection capabilities that 

enables immediate system adjustments, booster fans can be effectively used to 

enhance the health and safety conditions in underground coal mines. Based on these 
 102

arguments, the Technical Study Panel recommends that MSHA start exploring the 

conditions under which booster fans can be used safely in underground coal mines, 

especially in deep mines with difficult conditions. This exploratory work should be 

completed in three years. In the future, deeper mines are inevitable and better 

technology should be explored and utilized. 

Conclusion

All members of the Panel affirmed the recommendation.

References

Crocco, W. (2007). Comments to the Panel at the Salt Lake City Meeting, Transcript 

of May 16, Pp. 82-85. 

 

Kennedy, W. (1996). Practical mine ventilation. Intertec Publishing, (Pp. 37-55). 

Chicago, Illinois. 
 103

APPENDICES 

A. Charter 

B. Federal Register Notice Establishing the Panel 

C. Background of Panel Members 

D. List of Materials Provided to Panel Members 
 104

A. Charter 

1. The Committee’s official designation. 

Technical Study Panel on the Utilization of Belt Air and the Composition and Fire 

Retardant Properties of Belt Materials in Underground Coal Mining. 

2. The Committee’s objectives and the scope of its activity. 

The Committee is established in accordance with the requirements of Section 11 of 

the Mine Improvement and New Emergency Response Act of 2006 (MINER Act) 

and the Federal Advisory Committee Act. The purpose of the Committee is to 

‘‘provide independent scientific and engineering review and recommendations 

with respect to the utilization of belt air and the composition and fire retardant 

properties of belt materials in underground coal mining.’’ (MINER Act, Sec. 11) 

3. The period of time necessary for the Committee to carry out its purposes. 

Not later than one year after the date 

on which all Committee members are appointed, the Committee must ‘‘prepare 

and submit ... a report concerning the utilization of belt air and the composition 

and fire retardant properties of belt materials in underground coal mining.’’ 

(MINER Act, Sec. 11) 

4. The agencies or officials to whom the Committee reports. 

The Committee submits a report to the Secretary of Labor, the Secretary of Health 

and Human Services, the Committee on Health, Education, Labor, and Pensions of 

the Senate, and the Committee on Education and Workforce of the House of 

Representatives. 

5. The agency responsible for providing necessary support for the Committee. 

The Mine Safety and Health Administration, U.S. Department of Labor, is 

primarily responsible for providing support for the Committee, including financial, 

organizational, and administrative. The National Institute for Occupational Safety 

and Health, Centers for Disease Control and Prevention, U.S. Department of 

Health and Human Services, may assist with compiling research and other 

scientific information. 

6. A description of the duties for which the Committee is responsible. 
 105

As required by Section 11 of the MINER Act, the Committee will provide 

independent scientific and engineering review and make recommendations in the 

form of a report with respect to the utilization of belt air and the composition and 

fire retardant properties of belt materials in underground coal mining. 

7. Membership. 

As required by Section 11 of the MINER Act, the Committee will be composed of 

the following: 

• Two individuals appointed by the Secretary of Health and Human Services, in 

consultation with the Director of the National Institute for Occupational Safety and 

Health and the Associate Director of the Office of Mine Safety; 

• Two individuals appointed by the Secretary of Labor, in consultation with the 

Assistant Secretary for Mine Safety and Health; and 

• Two individuals, one appointed jointly by the majority leaders of the Senate and 

House of Representatives and one appointed jointly by the minority leaders of the 

Senate and House of Representatives. Four of the six individuals listed above must 

possess a masters or doctoral level degree in mining engineering or another 

scientific field demonstrably related to the subject of the report. No individual 

appointed shall be an employee of any coal or other mine, or of any labor 

organization, or of any State or Federal agency primarily responsible for regulating 

the mining industry. 

8. Compensation. 

While carrying out the duties of the Committee, its members shall be entitled to 

receive compensation as a consultant, at an hourly rate equivalent of GS–15, step 

10. Employment is not expected to exceed 130 days per year. Committee members 

will also receive per diem in lieu of subsistence and travel expenses. 

9. The estimated annual costs to operate the Committee in dollars and person years. 

• Estimated annual operating cost: $600,000. 

• Estimated staff years: 4. 

10. The estimated number and frequency of Committee meetings. 

The Committee will meet at least three times before its termination date. The 

Agency estimates that each meeting will last approximately two to three days. 
 106

11. The Committee’s termination date. 

This Committee will terminate upon the submission of its report that must be 

finalized no later than one year after the date on which all members of the Panel 

are appointed, as required by Section 11 of the MINER Act. 

12. The date the charter is filed. 

The charter is filed on the date indicated below. 
 107

B. Federal Register Notice of Establishment of the Panel 
 108
 109
 110

C. Background of Members 

Selected for Appointment by the Secretary of Health and Human Services. 

 Dr. Jürgen F. Brune, Director, Spokane Research Laboratory, National 

Institute for Occupational Safety and Health, Spokane, Washington. 

 Dr. Felipe Calizaya, Associate Professor, University of Utah, Mining 

Engineering, Salt Lake City, Utah. 

Selected for Appointment by the Secretary of Labor. 

 Dr. Jan M. Mutmansky, Professor Emeritus of Mining Engineering, the 

Pennsylvania State University, University Park, Pennsylvania elected by his fellow 

Panel members to be Chairman. 

 Dr. Jerry C. Tien, Associate Professor, Department of Mining Engineering, 

University of Missouri-Rolla, Rolla, Missouri. 

Selected for Appointment Jointly by the Majority Leaders of the Senate and House of 

Representatives. 

 Mr. Thomas P. Mucho, Thomas P. Mucho & Associates, Inc., Mining 

Consultancy, Washington, Pennsylvania. 

Selected for Appointment Jointly by the Minority Leaders of the Senate and House 

of Representatives. 

 Dr. James L. Weeks, Director, Evergreen Consulting, LLC, Silver Spring, 

Maryland. 
 111

D. List of Materials Provided to Members of the Panel 

MEETING 1 - January 9 and 10, 2006 

Ronald Reagan Building and 

International Trade Center, 

Polaris Suite, 

1300 Pennsylvania Avenue, NW., 

Washington, DC 20004 

1. Mine Safety and Health Administration. (2006). Technical Study panel on the 

Utilization of Belt Air and the Composition and Fire Retardant Properties of 

Belt Materials in Underground Coal Mining. Notice of Meeting. Federal 

Register. 71(December 22, 2006): 77069-77071. 

2. Mine Safety and Health Administration. (2007). Technical Study panel on the 

Utilization of Belt Air and the Composition and Fire Retardant Properties of 

Belt Materials in Underground Coal Mining. Transcript of Proceedings. 

Polaris Suite, Ronald Reagan Building and International Trade Center, 1300 

Pennsylvania Avenue, N.W., Washington, D.C. January 9, 2007. 90 pages. 

3. Presentation: William Francart, P.E., Mining Engineer. Using Belt Air to 

Ventilate Active Working Areas. DOL/MSHA Pittsburgh Safety and Health 

Technology Center, Ventilation Division. January 9, 2007. 15 slides. 

4. Presentation: William Knepp, Assistant District Manager for Technical 

Services, District 9 Coal. Belt Air Federal Advisory Committee Briefing. 

Ronald Reagan Building, Washington, D.C. DOL/MSHA, Coal Mine Safety 

and Health, Denver, Colorado. January 9-10, 2007. 53 slides. 

5. Presentation: Michael Kalich, Senior Mining Engineer, Belt Air Federal 

Advisory Committee Briefing, Ronald Reagan Building, Washington, D.C. 

January 9-10, 2007. DOL/MSHA, Coal Mine Safety and Health, Safety 

Division, Arlington, VA. Slide 1 – 26. 

6. Mine Safety and Health Administration. (2007). Technical Study panel on 

the Utilization of Belt Air and the Composition and Fire Retardant Properties 

of Belt Materials in Underground Coal Mining. Transcript of Proceedings. 

Polaris Suite, Ronald Reagan Building and International Trade Center, 1300 

Pennsylvania Avenue, N.W., Washington., D.C., January 10, 2007. 118 pages. 

7. Presentation: Michael Kalich, Senior Mining Engineer, Belt Air Federal 

Advisory Committee Briefing, Ronald Reagan Building, Washington, D.C. 

January 9-10, 2007. DOL/MSHA, Coal Mine Safety and Health, Safety 

Division, Arlington, VA. Slide 27 – 43. 

8. Presentation: Mark Schultz, Supervisory Mining Engineer. Health Effects of 

Utilizing Belt Air in Underground Coal Mines. MSHA Technical Support, 

Pittsburgh Safety and Health Technology Center, Pittsburgh, PA. January 10, 

2007. 32 slides. 
 112

9. Harry Verakis, Senior Projects Engineer. Conveyor Belt Flammability. 

MSHA Technical Support, Triadelphia, WV. January 10, 2007. 40 slides. 

10. Federal Mine Safety and Health Act of 1977, Public Law 91-173, as amended 

by Public Law 95-164. (referred to as the 1977 Mine Act.) 

11. Mine Safety and Health Administration. (1988). Safety Standards for 

Underground Coal Mine Ventilation, Proposed Rule. Federal Register, 

53(January 27, 1988): 2382-2424. 

12. Mine Safety and Health Administration. (1989). Belt Entry Ventilation 

Review: Report of Findings and Recommendations. 101 pages. 

13. Mine Safety and Health Administration. (1992). Safety Standards for 

Underground Coal Mine Ventilation, Final Rule. Federal Register, 57(May 15, 

1992): 20868-20928. 

14. Department of Labor. (1992). Final Report of the Department of Labor’s 

Advisory Committee on the Use of Air in the Belt Entry to Ventilate the 

Production (Face) Areas of Underground Coal Mines and Related Provisions 

(Belt Air Advisory Committee). November 1992. 111 pages. 

15. Mine Safety and Health Administration. (1992). Requirements for Approval 

of Flame-Resistant Conveyor Belts, Proposed rule. Federal Register, 

57(December 24, 1992): 61524-61535. 

16. Mine Safety and Health Administration. (1994). Safety Standards for 

Underground Coal Mine Ventilation, Proposed Rule. Federal Register, 59 

(May 19, 1994): 26356-26399. 

17. Mine Safety and Health Administration. (1996). Safety Standards for 

Underground Coal Mine Ventilation, Final Rule. Federal Register, 61 (March 

11, 1996): 9764-9846. 

18. Mine Safety and Health Administration. (1999). Requirements for Approval 

of Flame-Resistant Conveyor Belts, Proposed rule; limited reopening of the 

record; request for public comments. Federal Register, 64(December 28, 1999): 

72617-72619. 

19. Mine Safety and Health Administration. (2003). Underground Coal Mine 

Ventilation-Safety Standards for the Use of a Belt Entry as an Intake Air 

Course To Ventilate Working Sections and Areas Where Mechanized Mining 

Equipment Is Being Installed or Removed, Proposed rule; notice of public 

hearings; notice of close of record. Federal Register, 68(January 27, 2003): 

3936-3968. 

20. Comments of the National Institute for Occupational Safety and Health to the 

DOL on The Mine Safety and Health Administration’s Report “Belt Entry 

Ventilation Review: Report of Findings and Recommendations” 30 CFR Part 

75. U.S. Department of Health and Human Services, Public Health Service, 

Centers for Disease Control, NIOSH, 11/22/89, 6 pages. 

21. Testimony to DOL of the National Institute for Occupational Safety and 

Health on The Mine Safety and Health Administration’s Report “Belt Entry 

Ventilation Review” 30 CFR Part 75. Presented at the MSHA Public Hearing 
 113

April 18, 1990, Reston, Virginia. J. Donald Miller, M.D., Assistant Surgeon 

General, Director, NIOSH. 22 pages. 

22. Schulte, P. Education and Information Division, NIOSH Comments to the 

2003 NPRM. National Institute for Occupational Safety and Health, Robert A. 

Taft Laboratories, Cincinnati, OH. March 27, 2003. 44 pages. 

23. Mine Safety and Health Administration. (2004). Compliance Guide for 

MSHA's Safety Standards for the Use of Belt Entry as an Intake Air Course to 

Ventilate Working Sections and Areas Where Mechanized Mining Equipment 

is Being Installed or Removed, September 2004. 45 pages. 

24. Mine Safety and Health Administration. 2004. Underground Coal Mine 

Ventilation-Safety Standards for the Use of a Belt Entry as an Intake Air 

Course To Ventilate Working Sections and Areas Where Mechanized Mining 

Equipment Is Being Installed or Removed, Final Rule. Federal Register, 

69(April 2, 2004): 17480- 17530. 

25. MINE IMPROVEMENT AND NEW EMERGENCY RESPONSE ACT OF 2006 

(MINER ACT) PL 109-236 (S 2803), June 15, 2006. 

26. Mine Safety and Health Administration. (2006). Technical Study Panel on the 

Utilization of Belt Air and the Composition and Fire Retardant Properties of 

Belt Materials in Underground Coal Mining, Notice of meeting. Federal 

Register, 71(December 22, 2006): 77069-77071. 

27. Comments of the National Institute for Occupational Safety and Health to the 

DOL on The Mine Safety and Health Administration’s Report “Belt Entry 

Ventilation Review: Report of Findings and Recommendations” 30 CFR Part 

75. U.S. Department of Health and Human Services, Public Health Service, 

Centers for Disease Control, NIOSH. 11/22/89. 6 pages. 

28. Testimony to DOL of the National Institute for Occupational Safety and 

Health on The Mine Safety and Health Administration’s Report “Belt Entry 

Ventilation Review” 30 CFR Part 75. Presented at the MSHA Public Hearing 

April 18, 1990, Reston, Virginia. J. Donald Miller, M.D., Assistant Surgeon 

General, Director, NIOSH. 22 pages. 

29. Comments of the National Institute for Occupational Safety and Health on 

the Mine Safety and Health Administration Proposed Rule Underground 

Coal Mine Ventilation-Safety Standards for the Use of a Belt Entry as an 

Intake Air Course to Ventilate Working Sections and Areas Where 

Mechanized Mining Equipment is Being Installed or Removed. 30 CFR 75. 

Department of Health and Human Services, Public Health Service, Centers 

for Disease Control and Prevention, NIOSH, March 28, 2003. 6 pages. 

30. Belt Air eDocket- MSHA web site at the following internet address: 

http://www.msha.gov/regs/comments/03-1307/beltairedocket.htm 

31. Comment from John C. Biechman of the National Fie Protection Association 

to MSHA concerning 68 FR 3939, Proposed rule, [belt air] dated on March 10, 

2003. 
 114

32. Comment from Charles Burggraf of RAG American Coal Holding, Inc. to 

MSHA Re’ Comments Concerning Use of Belt Entry as an Intake Air Course 

dated March 27, 2003. 

33. Comment from the United Mine Workers of America on the Proposed rule: 

Underground Coal Mine Ventilation-Safety Standards for the Use of a Belt 

Entry as an Intake Air Course to Ventilate Working Sections and Areas Where 

Mechanized Mining Equipment is Being Installed or Removed dated April 10, 

2003. 

34. Hearing submission by Twentymile Coal Company on Belt Entry as an Intake 

Air Course dated April 3, 2003. 

35. Hearing submission by Randy Bedilion, Safety Committeeman at RAG 

Cumberland Mine and a member of Local 2300 of the United Mine Workers 

of America dated April 10, 2003 

36. Hearing submission of United Mine Workers that includes UMWA’s report 

on the Jim Walter Resources #5 Coal Mine Disaster of September 23, 2001, 

UMWA JWR explosion Rep aa76-hear-4-birminghamal. 

37. Hearing submission by Keith Pylar dated April 28, 2003. 

38. Industry Comments: Comment on the Proposed Regulations on Belt Entry as 

an Intake Air Course received by MSHA on May 6, 2003 ( JWR aa76-

posthearingcomment-100); Comment received from A. Bill Olsen of Mountain 

Coal Company received by MSHA on May 16, 2003 (aa76-comm-101phc); 

Comment received from Kevin Tuttle of Deer Creek Mine dated June 20, 

2003 (AA76_COMM_102BELTAIR.pdf); and Comments of Kenneth May of 

Canyon Fuel Company dated June 27, 2003 (aa76-comm-105Beltentry.pdf). 

39. Union Comments: Comment on Belt Air from Joseph Main of the United 

Mine Workers of America dated June 23, 2003 (JWR UMWA Comments aa76-

comm-104beltair); and Comments of Joseph Main of the United Mine 

Workers of America dated June 30, 2003 (UMWA Exhibit 1 aa76-comm106.pdf) 

40. NMA Comments: NMA-BCOA Joseph Lamonica & Bruce Watzman dated 

June 30, 2003 (aa76-comm-103phc.pdf). 

41. Mine Safety and Health Administration. (2003). Underground Coal Mine 

Ventilation, Use of Belt Air, No. 30 CFR Part 75, Mount Garfield Room, 755 

Horizon Drive, Grand Junction, Colorado. April 3, 2003. 32 pages. 

42. Mine Safety and Health Administration . (2003). Public Hearing For 

Underground Coal Mine Ventilation – Safety Standards for the Use of a Belt 

Entry as an Intake Air Course to Ventilate Working Sections and Areas Where 

Mechanized Mining Equipment is Being Installed or Removed: Proposed 

Rule. Marriot Hotel, 200 Lee Street East, Charleston, WV. April 8, 2003. 60 

pages. 

43. Mine Safety and Health Administration. (2003). Underground Coal Mine 

Ventilation. Holiday Inn Meadowlands, 340 Racetrack Road, Gallery B, 

Washington, Pennsylvania. April 10, 2003. 83 pages. 
 115

44. Mine Safety and Health Administration (2003). Proposed Belt Air Rule for 

Underground Coal Mines. Holiday Inn North, 5000 10th Avenue, No., 

Birmingham, Alabama. April 29, 2003. 109 pages. 

45. Mine Safety and Health Administration. (2003). Proposed Belt Air Rule for 

Underground Coal Mines. Holiday Inn, 1950 Newton Pike, Lexington, 

Kentucky. May 1, 2003. 56 pages. 

46. Mine Safety and Health Administration . Code of Federal Regulations - 30 

CFR 75.350 

47. Mine Safety and Health Administration . Code of Federal Regulations - 30 

CFR 75.351 and 75.352 

48. Mine Safety and Health Administration. (1989). Belt Entry Ventilation 

Review: Report of Findings and Recommendations. 101 pages. 

49. Potts, J. and Jankowski, R. (1992). Dust Considerations When Using Belt 

Entry Air to Ventilate Work Areas. Report of Investigations RI-9426. U.S. 

Department of the Interior, Bureau of Mines. 17 pages. 

50. Haney. R. [after 1993]. Effect of Belt Air on Dust Levels in Underground Coal 

Mines. Department of Labor, Mine Safety and Health Administration. 

Pittsburgh, PA. 10 pages. 

51. Lazzara, C. and Perzak, F. (1987). Effect of Ventilation on Conveyor Belt 

Fires. Paper 7.5 in Symposium. Safety in Coal Mining (S.420), ISBN: 07988 

3066 2. Pretoria, South Africa. 5-8 October, 1987. 18 pages. 

52. Mine Safety and Health Administration. (2005). Underground Coal Mine 

Ventilation-Safety Standards for the Use of a Belt Entry as an Intake Air 

Course To Ventilate Working Sections and Areas Where Mechanized Mining 

Equipment Is Being Installed or Removed, Final rule; conforming to the 

Court’s opinion. Federal Register, 70(June 29, 2005): 37266. 

53. Mine Safety and Health Administration. Federal Register History for Final 

Rules and Proposed Rules in Progress. Webpage. 

http://www.msha.gov/REGS/HISTORY/Beltair.asp 

54. Mine Safety and Health Administration. (2004). Underground Coal Mine 

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55. Litton, et al. (1991). Fire Detection for Conveyor Belt Entries. Report of 

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56. Perzak et al. (1995). Hazards of Conveyor Belt Fires. Report of Investigations 

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58. Verakis, H. and Dalzell, R. (1988). Impact of Entry Air Velocity on the Fire 

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Brisbane, Queensland. July 1988, Page 375-381. 

59. Stricklin, K. and Haney, R. [after 1999]. Longwall Dust Control Practices. 

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60. Mine Safety and Health Administration. (2004). Compliance Guide for 

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61. Mine Safety and Health Administration. (2003). Underground Coal Mine 

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84. Mine Safety and Health Administration. (1992). Requirements for Approval 

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87. Edwards et al. (2006). CO Dispersion from a Coal Fire in a Mine Entry. 

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University Park, Pennsylvania, June 5-7, 2006. Mutmansky JM, Ramani RV. 

eds., London, U.K.: Taylor & Francis Group, June 2006. Pages 511-517. 

88. Luzik, S. and Desautles, L. (1990). Coal Mine Fires Involving Track and Belt 

Entries, 1970-1988. Report No. 09-323-90, Industrial Safety Division, Bruceton 

Safety Technology Center, Mine Safety and Health Administration, 

Pittsburgh, Pennsylvania. November 19, 1990. 26 pages. 

89. Edwards, J. and Friel, G. (1996). Comparative In-Mine Evaluation of Carbon 

Monoxide and Smoke Detectors. Report of Investigations 9622. Department 

of the Interior, Bureau of Mines. 15 pages. 

90. Friel et al. (1994). Effect of Dead-End Crosscuts on Contaminant Travel Time 

in Mine Entries. Report of Investigations 9517. Department of the Interior, 

Bureau of Mines. 23 pages. 

91. Edwards, J. and Morrow, G. (1995). Evaluation of Smoke Detectors for 

Mining Use. Report of Investigations RI-9586. Department of the Interior, 

Bureau of Mines. 25 pages. 

92. Weiss et al. (2006). Explosion Evaluation of Mine Ventilation Stoppings. 

Proceedings of the 11th U.S./North American Mine Ventilation Symposium, 

University Park, Pennsylvania, June 5-7, 2006. Mutmansky JM, Ramani RV. 

eds., London, U.K.: Taylor & Francis Group. June 2006. Pages 361-366. 

93. DeRosa, M. (2004). Analysis of Mine Fires for All U.S. Underground and 

Surface Coal Mining Categories: 1990-1999. Information Circular 9470. 

Department of Health and Human Services, Centers for Disease Control and 

Prevention, National Institute for Occupational Safety and Health, Pittsburgh 

Research Laboratory, Pittsburgh, PA. September 2004. 43 pages. 

94. Edwards et al. (2002). In-Mine Evaluation of Discriminating Mine Fire 

Sensors. In: E. DeSouza, ed. Proceedings of the North American/Ninth U.S. 
 119

Mine Ventilation Symposium (June 8-12, 2002, Kingston, Ontario, Canada). A. 

A. Balkema Publishers, Lisse, Netherlands. Pages. 527-532. 

95. Morrow, G. and Litton, C. (1992). In-Mine Evaluation of Smoke Detectors. 

Information Circular 9311. Department of the Interior, Bureau of Mines. 18 

pages. 

96. Edwards et al. (1999). Mine Fire Detection in the Presence of Diesel 

Emissions Proc Eighth U.S. Mine Ventilation Symposium. Rolla, MO: 

University of Missouri-Rolla, Press. Pages 295-301. 

97. Edwards et al. (1997). Mine Fire Detection Under Zero Air Flow Conditions. 

Proceedings of the 6th International Mine Ventilation Congress, Chapter 52, 

Ramani RV, ed., Littleton, CO: Society for Mining, Metallurgy, and 

Exploration, Inc. February 1997. Pages 331-336. 

98. DeRosa, M. (2004). Analysis of Mine Fires for All U.S. Underground and 

Surface Coal Mining Categories: 1990-1999. Information Circular 9470. 

Department of Health and Human Services, Centers for Disease Control and 

Prevention, National Institute for Occupational Safety and Health, Pittsburgh 

Research Laboratory, Pittsburgh, PA. September 2004. 43 pages. 

99. Lazzara et al. (1990). New Initiatives in the Prevention of Fires and 

Explosions in the USA Minesafe International, 1990 (Perth, Western Australia, 

September 10-14, 1990). Perth: Chamber of Mines and Energy of Western 

Australia. Pages 389-402. 

100. Krog et al. (2006). Predicting Methane Emissions by Analysis of Emission 

Contributors. Proceedings of the 11th U.S./North American Mine 

Ventilation Symposium, University Park, Pennsylvania, June 5-7, 2006. 

Mutmansky JM, Ramani RV. eds., London, U.K.: Taylor & Francis Group. 

June 2006. Pages 383-392. 

101. Edwards et al. (2004). Real-Time Neural Network Application to Mine Fire – 

Nuisance Emissions Discrimination. Mine Ventilation: Proc 10th U.S./North 

American Mine Ventilation Symposium (May 16-19, 2004, Anchorage, AK), 

Ganguli-R and Bandopadhyay-S, eds. A. A. Balkema Publishers, Lisse, 

Netherlands. May 2004. Page 425-431. 

102. Francart, W. (2006). Reducing Belt Entry Fires in Underground Coal Mines. 

11th U.S./North American Mine Ventilation Symposium 2006 –Mutmansky & 

Ramani (eds.). 6 pages. 

103. Smith et al. (1995). The Performance of Automatic Sprinkler Systems in the 

Extinguishment of incipient Conveyor Belt Fires under Ventilated Conditions. 

Chapter 34. Proceedings of the 7th U.S. Mine Ventilation Symposium, June 57, 

1995. Lexington, Kentucky. Underground Ventilation Committee of SME, a 

joint committee of the Coal Division and the Mining & Exploration Division, 

and the University of Kentucky. Society for Mining, Metallurgy, and 

Exploration, Inc. Littleton, Colorado. Pages 220-223. 

104. Two day meeting attendance sheets 

105. Agenda for the 2 day meeting 
 120

MEETING 2 – March 28 – 30, 2007 

Holiday Inn Pittsburgh Airport 

8256 University Blvd. 

Coraopolis, PA 15108-2591 

106. Mine Safety and Health Administration. (2007). Technical Study panel on the 

Utilization of Belt Air and the Composition and Fire Retardant Properties of 

Belt Materials in Underground Coal Mining. Notice of Meeting. Federal 

Register. Vol. 72. No 48. March 13, 2007. Page 11379-11380. 

107. TSP Belt Air Survey 2-07 - Coal Mine Safety and Health, 2003 AMS survey 

updated for 2006: 2003 AMS Survey/2006 AMS/belt air survey. 

108. TSP Belt Violations 4th quarter 2006 - Coal Mine Safety and Health, 4th quarter 

2006 violations of 75.400 and 75.1725(a). 

109. Conveyor belt questions – list of potential questions for conveyor belt 

manufacturers. 

110. Belt combustion toxicity – BCOA/UMWA Belt Q&A from 1995. 

111. Answer to panel dust questions – Schultz, M. Current dust concentrations in 

belt air intake and return samples for calendar year 2006. 

112. Francart 2006 Belt Fires Paper – Francart, W. (2006). Reducing belt entry fires 

in underground coal mines. Chapter 5 - 11th U.S. North American Mine 

Ventilation Symposium 2006 – Mutmansky & Ramani (eds). Pages 303-308. 

113. TSP Major Conveyor Belt Companies – MSHA/Tech Support, January 30, 

2006 – Listing of major conveyor belt companies with respect to underground 

coal mines. 

114. TSP2003 AMS Survey with 2006 update 59 Mines. 

115. Francart, W. (2005). MSHA Survey – Atmospheric Monitoring Systems in 

U.S. Underground Coal Mines. SME Annual Meeting, Feb. 28-Mar.2, 2005, 

Salt Lake City, Utah. 

116. Mine Safety and Health Administration. (1992). District 2, Accident 

Investigation Report (Underground Coal Mine), Non-Injury Mine Fire – Belt 

Conveyor, Dilworth Mine (I.D. No. 36 04281, Consolidation Coal Company, 

Rices Landing, Greene County, Pennsylvania. January 22, 1992. 19 pages. 

117. Mine Safety and Health Administration. (2003). Coal Mine Safety and 

Health, Report of Investigation, Underground Coal Mine Fire January 6, 2003, 

Mine 84, Eighty Four Mining Company, Eighty Four, Washington County, 

Pennsylvania, I.D. No. 36-00958, District 2, 319 Paintersville Road, Hunker 

Pennsylvania. April 9, 2003. 28 pages. 

118. Mine Safety and Health Administration. (2003). Coal Mine Safety and Health, 

Report of Investigation, Underground Coal Mine Fire, Non-Injury Mine Fire 

Accident, April 9 & 10, 2003, VP8, I.D. 44-03795, Island Creek Coal Company, 
 121

Mavisdale, Buchanan County, Virginia, District 5, P.O. Box 560, Wise County 

Plaza, Norton, Virginia. July 15, 2003. 31 pages. 

119. Mine Safety and Health Administration. (1988). Coal Mine Safety and 

Health, Report of Investigation, Underground Coal Mine Fire Marianna Mine 

No. 58 (I.D. No. 36-00957) BethEnergy Mines, Inc., Marianna Borough, 

Washington County, Pennsylvania. March 7, 1988. 80 pages. 

120. Mine Safety and Health Administration. (1995). Transcript Proposed 

Requirement for Approval of Flame Resistant Conveyor Belts, Part 14. 340 

Race Track Road, Washington, PA. May 2, 1995. 162 pages. 

121. Mine Safety and Health Administration. (1992). Belt Air Advisory 

Committee, Second Meeting, Volume I, Crown Sterling Suites, 2300 

Woodcrest Place, Birmingham, Alabama. Wednesday, April 22, 1992. 176 

pages. 

122. Mine Safety and Health Administration. (1992). Belt Air Advisory 

Committee, Second Meeting, Volume II, Crown Sterling Suites, 2300 

Woodcrest Place, Birmingham, Alabama. Thursday, April 23, 1992. 218 

pages. 

123. Mine Safety and Health Administration. (1992). Belt Air Advisory 

Committee, Third Meeting, Volume I, David L. Lawrence Convention Center, 

Room 9 North, Pittsburgh, Pennsylvania. Thursday, May 21, 1992. 217 pages. 

124. Mine Safety and Health Administration. (1992). Belt Air Advisory 

Committee, Third Meeting, Volume II, David L. Lawrence Convention 

Center, Room 9 North, Pittsburgh, Pennsylvania. Friday, May 22, 1992. 243 

pages. 

125. Mine Safety and Health Administration. (1992). Belt Air Advisory 

Committee, Fourth Meeting, Volume I, University of Kentucky, Mining and 

Mineral Resources Building, Room 102, Lexington, Kentucky. Monday, June 

1, 1992. 244 pages. 

126. Mine Safety and Health Administration. (1992). Belt Air Advisory 

Committee, Fourth Meeting, Volume II, University of Kentucky, Mining and 

Mineral Resources Building, Room 102, Lexington, Kentucky. Tuesday, June 

2, 1992. 198 pages. 

127. Mine Safety and Health Administration. (1992). Belt Air Advisory 

Committee, Fifth Meeting, Volume I, Denver Ballroom, Suite 3, Marriott City 

Center, Denver, Colorado. Monday, August 3, 1992. 210 pages. 

128. Mine Safety and Health Administration. (1992). Belt Air Advisory 

Committee, Fifth Meeting, Volume II, Denver Ballroom, Suite 3, Marriott City 

Center, Denver, Colorado. Tuesday, August 4, 1992. 267 pages. 

129. Mine Safety and Health Administration. (1992). Belt Air Advisory 

Committee, Fifth Meeting, Volume III, Denver Ballroom, Suite 3, Marriott 

City Center, Denver, Colorado. Wednesday, August 5, 1992. 162 pages. 

130. Intake Belt DA Query Inspector 800-0 series (Inspector) – ADJUSTED.xls – 

data file. 
 122

131. Intake Belt DA Query Inspector 800-0 series (Inspector).xls – data file. 

132. Intake Belt DA Query Inspector 800-0 series – Adjusted. xls – data file. 

133. Intake Belt DA Query Operator 800-0 series1.xls. – data file. 

134. Return Belt DA Query Inspector 200-0 series – ADJUSTED.xls – data file. 

135. Return Belt DA Query Inspector 200-0 series.xls – data file. 

136. Return Belt DA Query Operator 200-0 series-Adjusted.xls – data file. 

137. Return Belt DA Query Operator 200-0 series.xls – data file. 

138. Mine Safety and Health Administration. (2007). Coal Mine Safety and 

Health, Report of Investigation, Fatal Underground Coal Mine Fire, January 

19, 2006, Aracoma Alma Mine #1, Aracoma Coal Company, Inc., Stollings, 

Logan County, West Virginia, I.D. No. 46-08801. Arlington, Virginia. 164 

pages. 

139. Mine Safety and Health Administration. (2007). Technical Study panel on the 

Utilization of Belt Air and the Composition and Fire Retardant Properties of 

Belt Materials in Underground Coal Mining. Transcript of Proceedings. 

Glenwood Room, Holiday Inn Pittsburgh Airport, 8256 University Blvd, 

Coraopolis, Pennsylvania. March 28, 2007. 187 pages. 

140. Presentation: Overview from NIOSH – Robert Timko, NIOSH, Manager of 

the Dust and Diesel Monitoring Team, Pittsburgh, PA . 

141. Presentation: Belt flammability research/ NIOSH large and laboratory scale 

studies – Chuck Lazzara, NIOSH, (Retired), includes a DVD with a short 

movie. 70 slides. 

142. Presentation: Belt toxicity issues - C. David Litton, NIOSH, Research 

Physicist, Pittsburgh PA. 24 slides. 

143. Presentation: Goodyear – David J. Maguire, Director, Global Technology 

Engineered Products, The Goodyear Tire and Rubber Company. 

144. Presentation: Fenner-Dunlop – Geoff Normanton, Vice President, 

Technology, Fenner-Dunlop, Conveyor Belting, Americas, Scottdale, Georgia 

(Slide 1-25). 

145. Presentation: Fenner-Dunlop –BRIAN Rothery, C.Chem M.R.S.C., Head of 

Development and Quality Assurance, Fenner-Dunlop, Conveyor Belting, 

Europe, United Kingdom (Slide 26 – 49). 

146. Presentation: Phoenix – Bernd Küsel, Executive Vice President, Phoenix 

Conveyor Belt Systems, GMBH, Hamburg, Germany. 

147. Mine Safety and Health Administration. (2007). Technical Study panel on the 

Utilization of Belt Air and the Composition and Fire Retardant Properties of 

Belt Materials in Underground Coal Mining. Transcript of Proceedings. 

Glenwood Room, Holiday Inn Pittsburgh Airport, 8256 University Blvd, 

Coraopolis, Pennsylvania. March 29, 2007. 190 pages. 

148. Presentation on laboratory-scale flammability testing – Harry Verakis, 

MSHA, Senior Projects Engineer, MSHA Technical Support, Triadelphia, WV. 

 148.1 Maas, W. 1949. Fire Hazards Due to Slipping Rubber Belt Conveyors. 

 Geologie En Mijnbouw, November. 11:309-312. 
 123

 148.2 Canadian Standards Association/Standards Council of Canada. 

 1987. Fire-Performance and Antistatic Requirements for Conveyor 

 Belting. CAN/CSA-M422-M87. May. Canadian Standards 

 Association, Ontario, Canada. 24 pages. 

149. Presentation on belt fire historical data – Terry Bentley, MSHA, Acting 

Special Assistant to the Administrator, Coal Mine Safety and Health, Chief of 

Safety, Safety Division, Arlington, VA. 

150. Presentation: Using belt air at the face/ belt velocity limits – Robert Krog, 

NIOSH, Associate Service Fellow, Pittsburgh PA 15236. 

151. Presentation: Factors that affect escape – Fred Kissell, NIOSH, (Retired). 

152. Presentation: Thomas McNider, James Walters Resources, On behalf of the 

National Mining Association, Birmingham, Alabama. 

153. Mine Safety and Health Administration. (2007). Technical Study panel on 

the Utilization of Belt Air and the Composition and Fire Retardant Properties 

of Belt Materials in Underground Coal Mining. Transcript of Proceedings. 

Glenwood Room, Holiday Inn Pittsburgh Airport, 8256 University Blvd, 

Coraopolis, Pennsylvania. March 30, 2007. 102 pages. 

154. Presentation: 1992 Belt Air Advisory Committee report – Raja V. Ramani, 

Ph.D., P.E.; Emeritus Professor of Mining Engineering, Penn State University. 

155. Carroll et al. (1988). Kinetic Modeling of Generation and Decay of HCl From 

Burning PVC. Journal of Vinyl Technology. Vol. 10, No. 3. September 1988. 

Page 106-110. 

156. De Rosa, M. (1994). Correlations of Hydrogen Chloride and Hydrogen 

Cyanide Concentrations Evolved During Combustion of Chlorine-and 

Nitrogen-Containing Materials. Report of Investigations 9521. United States 

Department of the Interior, Bureau of Mines. 19 pages. 

157. De Rosa, M. and Litton, C. (1991). Embedded Hydrogen Chloride and 

Smoke Particle Characteristics During Combustion of Polyvinyl Chloride and 

Chlorinated Mine Materials. Report of Investigations 9368. United States 

Department of the Interior, Bureau of Mines. 18 pages. 

158. Goodman, G. and Kissell, F. (1990). Evaluating those factors that influence 

escape from coal mine fires. Society for Mining, Metallurgy, and Exploration, 

Inc. Transactions Vol. 286, pages 1801-1805. 

159. Kissell, F. and Litton, C. (1992). How smoke hinders escape from coal mine 

fires. Mining Engineering. January. Pg 79-83. 

160. Kissell, F. and Timko, R. (1991). Pressurization of Intake Escapeways with 

Parachute Stoppings to Reduce Infiltration of Smoke. Chapter 4. In 

Proceedings of the 5th U.S. Mine Ventilation Symposium, June 3-5, 1991. Y.J. 

Wang, ed. Society for Mining, Metallurgy, and Exploration, Inc., Littleton, 

Colorado. Pages 28-34. 

161. Kissell et al. (1993). Ranking factors impacting survival during coal mine 

fires. Mining Engineering. August. Pg 1077-1083. 
 124

162. Küsel, B. (2006). Comparing fire standards on conveyor belts. Conveyors. 

March. American Longwall. Page 36, 38. 

163. Presentation: Lazzara, C. Conveyor Belt Flammability Tests. Unpublished. 

Presented during the March 2007 Technical Study Panel Meeting in 

Coraopolis, PA. 7 pages. 2007. 

164. Three day meeting attendance sheets 

165. Agenda for the 3 day meeting. 

166. Meeting submission by Dr. Ramani (copies of his slides) on 3/30/07. 

 

MEETING 3 – May 16 and 17, 2007 

Salt Lake Plaza Hotel at Temple Square 

122 West South Temple 

Salt Lake City, UT 84101 

167. Mine Safety and Health Administration. (2007). Technical Study panel on the 

Utilization of Belt Air and the Composition and Fire Retardant Properties of 

Belt Materials in Underground Coal Mining. Notice of Meeting. Federal 

Register. 72 (May 2, 2007): 24338-24339. 

168. Memo dated July 25, 1973 to Alex O’Rourke, John J. Somers, Frank C. Mann, 

and John W. Stevenson from R. W. Dalzell, Chief, Ventilation Group 

Concerning Ventilation belt entries. United States Department of the Interior, 

Mining Enforcement and Safety Administration, Pittsburgh Technical 

Support Center, Pittsburgh, PA. 9 pages. 

169. TSPBeltAirHits. April 5, 2007. Webtrends Default Report Special on the 

number of “hits” on the MSHA website concerning TSP-related materials. 

170. Smith et al. (1995). Performance of Automatic Sprinkler Systems for 

Extinguishing Incipient and Propagating Conveyor Belt Fires Under 

Ventilated Conditions. Report of Investigations 9538. United States 

Department of the Interior, Bureau of Mines, Pittsburgh Research Center, 

Pittsburgh, PA. 25 pages. 

171. Ryan et al. (1993). Effect of Pressure on Leakage of Automatic Sprinklers. 

Report of Investigations 9451. United States Department of the Interior, 

Bureau of Mines, Pittsburgh Research Center, Pittsburgh, PA. 18 pages 

172. Sapko et al. (1989). Water Barrier Performance in a Wide Mine Entry. Third 

International Colloquium on Dust Explosions, Oct. 23-28, 1988, Szczyrk, Poland. 

Archivum Combustionis. Vol. 9: No. 1/4, Page 389-403. 

173. Smith et al. (1994). The Effect of Underground Mining Conditions on the 

Activation of Automatic Sprinklers. Report of Investigations 9492. United 

States Department of the Interior, Bureau of Mines, Pittsburgh Research 

Center, Pittsburgh, PA. 17 pages. 
 125

174. Smith et al. (1993). The Effect of Ventilation on the Water Spray Pattern of 

Automatic Sprinkler Heads. Report of Investigations 9459. United States 

Department of the Interior, Bureau of Mines, Pittsburgh Research Center, 

Pittsburgh, PA. 16 pages. 

175. du Plesis et al. (2001). Evaluation of the Bagged Stone Dust Barrier 

Effectiveness in a Board and Pillar Mine. Chapter 81, Proceedings of the 7th

International Mine Ventilation Congress, Ed. Stanislaw Wasilewski, June 17-22, 

2001, Cracow, Poland. 8 pages. 

176. 2007-03-28: Response-Mutmansky, NIOSH communiqué 

177. 2007-03-28: Response – Tien, NIOSH communiqué 

178. 2007-03-28: Response-Weeks, NIOSH communiqué

179. Egan, M. (1994). Combustion Products from Thermal Decomposition of 

Electrical Cable Jackets and Splicing Materials draft submitted for publication 

on April 29, 1994. 34 pages.

180. The Nose vs Atmospheric Monitoring Systems, communiqué from Dave 

Litton

181. James F. Kohler, Branch Chief, Solid Minerals. Comments for the – Technical 

Study Panel on the Utilization of Belt Air and the Composition and Fire 

Retardant Properties of Belt Materials in Underground Coal Mining. United 

States Department of the Interior, Bureau of Land Management, Utah State 

Office, P.O Box 45155, Salt Lake City, UT 84145. Submitted May 11, 2007. 

182. Resume of Hamid Maleki, Ph.D., roof control expert 

183. Presentation: Laine Adair, Tuesday, May 15 at the Aberdeen Mine. same 

May 2, 2007 as the presentation on Thursday, May 17. 

184. Presentation: Pete Wyckoff, Arch Western Resources, LLC, Tuesday May 15, 

2007, West Elk Mine given at the Skyline Mine visit. 

185. Presentation: Gene DiClaudio, Arch Western Bituminous Group, Tuesday, 

May 15, 2007. 

186. Presentation: Wes Sorensen, Skyline Mine, Tuesday, May 15, 2007. 

187. Tjernlund, D. (2006). B.E.L.T. Method Evaluation of Aracoma Alma No. 1 

Conveyor Belt Samples Recovered After the January 19, 2006 Fatal Belt 

Conveyor Fire. PAR 0093903, U.S.DOL/MSHA. MSHA Technical Support 

Approval and Certification Center, Triadelphia, WV. May 9, 2006. 8 pages. 

188. MSHA Questions May 2007. Possible Questions for MSHA Panel. 

189. Mine Safety and Health Administration. (2007). Technical Study panel on 

the Utilization of Belt Air and the Composition and Fire Retardant Properties 

of Belt Materials in Underground Coal Mining. Transcript of Proceedings. 

Salt Lake Plaza Hotel, 122 West South Temple, Salt Lake City, Utah. May 16, 

2007. 185 pages. 

190. Presentation: William, Francart (MSHA), ARACOMA BAC OVERVIEW 

2.ppt 

191. Presentation: Jeff McKenzie, Bureau of Land Management – Utah State Office. 

192. Presentation: Link Derick, Colorado Mining Association. 
 126

193. Mine Safety and Health Administration. (2007). Technical Study panel on the 

Utilization of Belt Air and the Composition and Fire Retardant Properties of 

Belt Materials in Underground Coal Mining. Transcript of Proceedings. Salt 

Lake Plaza Hotel, 122 West South Temple, Salt Lake City, Utah. May 17, 

2007. 198 pages. 

194. Presentation: Gary L. Skaggs, Agapito Associates, Inc., 626-01 MSHA Two 

Entry Presentation May-17-07.ppt; 70 slides. 

195. Agapito, J. and Goodrich, R. Five Stress Factors Conducive to Bumps in 

Utah, USA, Coal Mines. Ninth International Congress on Rock Mechanics, 

Paris, France, 25–28 August 1999. Also was to be presented at the 19th

Conference on Ground Control in Mining, Morgantown, West Virginia, 

August 8-10, 2000. 8 pages. 

196. DeMarco et al. (1988). Characterization of Chain Pillar Stability in a Deep 

Western Coal Mine – Case Study. Society of Mining Engineers Prepring 88-

76. For presentation at the SME annual Meeting, Phoenix, Arizona, January 

25-28, 1988. 14 pages. 

197. Gilbride, L. and Hardy, M. (2004). Interpanel Barriers for Deep Western U.S. 

Longwall Mining. 23rd International Conference on Ground Control in 

Mining, Morgantown, West Virginia, August 3–5, 2004. 8 pages. 

198. Haramy, K. and Kneisley, R. (1990). Yield pillars for stress control in 

longwall mines – case study. International Journal of Mining and Geological 

Engineering. 8:287-304. 

199. Harvey, J. and Palacios, J. (1987). Two-Entry Development for Longwall 

Mining. December 10, 1987. Submitted by Gary Skaggs. 11 pages. 

200. Presentation: Utah Mining Association 1 – Hamid Maleki, President, Maleki 

Technologies, Inc. 

201. Presentation: Utah Mining Association 2 – David Litvin, President 

202. Presentation: Utah Mining Association 3 - Laine Adair – written statement 

203. Presentation: Utah Mining Association 4 – Laine Adair – incomplete 

presentation slides 

204. Presentation: Utah Mining Association 5 - George Kenzy 

205. Presentation: Utah Mining Association 6 - Kevin Tuttle 

206. Presentation: Utah Mining Association 7 - Charles Reynolds – no written 

statement 

207. Presentation: Utah Mining Association 8 - Wendell Christensen 

208. Presentation: Utah Mining Association 9 - James Poulson 

209. Presentation: Utah Mining Association 10 - Gary Leaming 

210. Presentation: Utah Mining Association 11 - Carl Pollastro – no written 

statement 

211. Presentation: Utah Mining Association 12 - Doug Johnson 

212. Two day meeting sign-in sheets 

213. Agenda for the 2 day meeting. 
 127

MEETING 4 – June 20 through 21 

Best Western Birmingham Airport Hotel, 

5216 Messer Airport Highway, 

Birmingham, AL 35212 

214. Mine Safety and Health Administration. (2007). Technical Study panel on the 

Utilization of Belt Air and the Composition and Fire Retardant Properties of 

Belt Materials in Underground Coal Mining. Notice of Meeting. Federal 

Register. 72(May 2, 2007): 31347-31348. 

215. Mine Safety and Health Administration. (1985). Two Entry Longwall Mining 

Systems. – A Technical Evaluation, Prepared for David Zegeer, Assistant 

Secretary for Mine Safety and Health, by the MSHA Task Force on Longwall 

Mining, R. L. Ferriter, Chairman. Arlington, Virginia. June 12, 1985. 112 

pages. 

216. Submission: Standard comparison (2007). Compilation of worldwide belt 

testing standards compiled by Tong Wang and Geoff Normanton of Fenner 

Dunlap, April 2007. 7 pages. 

217. Conti, R. and Litton, C. (1993). Effects of Stratification on CO levels from 

Mine Fires. 6th U.S. Mine Ventilation Symposium. Chapter 73, Pages 489-

494. 

218. Edwards, J. and Friel, G. (1996). Comparative In-Mine Evaluation of CO and 

Smoke Detection. USBM Report of Investigation 9622. 13 pages. 

219. Edwards et al. (2006). CO Dispersion from a Coal Fire in a Mine Entry. 11th 

U.S. Mine Ventilation Symposium. 7 pages. 

220. Warner, B. (1974). Suppression of Fires on Underground Coal Mine 

Conveyor Belts. Walter Kidde & Company, Inc. Belleville, N.J. USBM 

Contract Final Report (Contract No. H0122086). Department of the Interior, 

Bureau of Mines, Washington, D.C. September 13, 1974. 109 pages. 

221. Mitchell et al. (1967). Fire Hazard of Conveyor Belts. Report of Investigations 

RI-7053. U.S. Department of the Interior, Bureau of Mines. December 1967. 

19 pages. 

222. Mine Safety and Health Administration. (2007). Technical Study panel on 

the Utilization of Belt Air and the Composition and Fire Retardant Properties 

of Belt Materials in Underground Coal Mining. Transcript of Proceedings. 

Best Western Airport Hotel, 5216 Messer Airport Highway in Birmingham, 

Alabama. June 20, 2007. 373 pages. 

223. Presentation: American Mine Research (David Graf, Bob Saxton, and Jim 

Gunnoe) 

224. Presentation: Pyott-Boone (Doug Coon) 

225. Presentation: Rel-Tek Corporation (Al Ketler) 

226. Presentation: Conspec Controls (Rob Albinger) 

227. Presentation: Mine Tour, No. 4 Mine belt air issues (T. McNider) 
 128

 227(a) – Booklet of JWR presentations (incomplete) 

228. Presentation: JWR No. 7 Mine belt air issues (Keith Pylar) 

229. Presentation: AMS at JWR (Randy Watts/Tommy McNider) 

230. NMA- (Bruce Watzman) – only oral presentation 

231. CONSOL Energy- (Dr. Pramod Thakur) – only oral presentation 

232. Presentation: Alpha Natural Resources- (David Decker) 

 232(a) – copy of oral statement 

233. Presentation: Arch Coal- (Patrick Leedy, Greg Dotson, and Bill Olsen) 

234. Presentation: Utah American Energy, Incorporated (Jim Poulson) 

235. Presentation: Alpha Engineering Services-(Gary Hartsog) 

236. Presentation: Goodyear- (David McGuire) 

237. Mine Safety and Health Administration. (2007). Technical Study panel on the 

Utilization of Belt Air and the Composition and Fire Retardant Properties of 

Belt Materials in Underground Coal Mining. Transcript of Proceedings. Best 

Western Airport Hotel, 5216 Messer Airport Highway in Birmingham, 

Alabama. June 21, 2007. 226 pages. 

238. Presentation: C. David Litton; NIOSH on belt fire detection sensors and stateof-the-art smoke sensors. 

239. Morrow, G. and Litton, C. (1992). In-Mine Evaluation of Smoke Detectors. 

Information Circular 9311. U.S. Department of the Interior. Bureau of Mines, 

Pittsburgh, PA. 18 pages. 

240. Presentation: Launa Mallett; NIOSH , Effective training techniques for 

emergency response preparedness (for AMS operators and in general for 

underground miners) 

241. Vaught et al. (2000). Behavioral and Organizational Dimensions of 

Underground Mine Fires. Information Circular IC-9450. U.S. Department of 

Health and Human Services, Public Health Service, Centers for Disease 

Control and Prevention, National Institute for Occupational Safety and 

Health, Pittsburgh Research Laboratory, Pittsburgh, PA. May 2000. 240 

pages. 

242. Peters, R. (2002). Strategies for Improving Miners’ Training. Information 

Circular IC-9463. U.S. Department of Health and Human Services, Public 

Health Service, Centers for Disease Control and Prevention, National Institute 

for Occupational Safety and Health, Pittsburgh Research Laboratory, 

Pittsburgh, PA. September 2002. 57 pages. 

243. Vaught et al. (2004). An Oral History Analysis of Mine Emergency Response. 

Information Circular IC-9471. U.S. Department of Health and Human 

Services, Public Health Service, Centers for Disease Control and Prevention, 

National Institute for Occupational Safety and Health, Pittsburgh Research 

Laboratory, Pittsburgh, PA. April 2004. 77 pages. 

244. Mallett et al. (1999). The Emergency Communication Triangle. U.S. 

Department of Health and Human Services, Public Health Service, Centers 

for Disease Control and Prevention, National Institute for Occupational 
 129

Safety and Health, Pittsburgh Research Laboratory, Pittsburgh, PA.DHHS 

(NIOSH) Publication Number 99-157. October 1999. 17 pages. 

245. United Mine Workers of America – Joe Weldon, Dwight Cagle, Larry Turner, 

Glen Loggins, and Tome Wilson) – No written Comment] 

 245(a) - Mine Citation/Order 7688586 JWR #4 Mine, dated 9/6/2006. 1 page. 

246. Presentation: Center for Regulatory Effectiveness- (Bruce Levinson) 

247. Presentation: Jim Walter Resources- (Dale Byram) – No written statement 

248. Two day meeting sign-in sheets 

249. Agenda for the 2 day meeting. 

250. Comment from William B. Bookshar, P.E., Received by MSHA via email on 

July 1, 2007. 3 pages. 

251. Polack, S. (1956). Research to develop a schedule for testing conveyor belts 

for fire resistance. U.S. Department of the Interior, Bureau of Mines, 

Pittsburgh, Pennsylvania. Presented at 9th International Conference of 

Directors of Safety in Mines Research, Heerlen, Netherlands and Brussels, 

Belgium. June 28 – July 4, 1956. 29 pages. 

252. Verakis, H. (2007). Conveyor Belt Fire Test Methods—A Review and 

Analysis. MSHA Technical Support, Approval and Certification Center, 

Triadelphia, West Virginia. August 2007. 32 pages. 

253. Comment received by MSHA on 8/14/07 from Joseph A. Sbaffoni, Director 

of the Bureau of Mine Safety. Pennsylvania Department of Environmental 

Protection, Uniontown, PA, dated August 9, 2007. 3 pages. 

MEETING 5 – September 17 through 19 

Sheraton Reston Hotel 

11810 Sunrise Valley Drive, 

Reston, Virginia 20191 

254. Mine Safety and Health Administration. (2007). Technical Study panel on the 

Utilization of Belt Air and the Composition and Fire Retardant Properties of 

Belt Materials in Underground Coal Mining. Notice of Meeting. Federal 

Register. 72(August 1, 2007): 42132. 

255. Proposed Recommendations, Technical Study Panel. 

256. Mine Safety and Health Administration. (2007). Technical Study panel on the 

Utilization of Belt Air and the Composition and Fire Retardant Properties of 

Belt Materials in Underground Coal Mining. Transcript of Proceedings. 

Conference Room 5. Sheraton Reston, 11810 Sunrise Valley Drive, Reston, 

Virginia, 237 pages. September 17, 2007. 

257. Mine Safety and Health Administration. (2007). Technical Study panel on the 

Utilization of Belt Air and the Composition and Fire Retardant Properties of 

Belt Materials in Underground Coal Mining. Transcript of Proceedings. 
 130

Conference Room 5. Sheraton Reston, 11810 Sunrise Valley Drive, Reston, 

Virginia, September 18, 2007. 191 pages. 

258. Presentation: Dr. Felipe Calizaya’ - Draft recommendations 14, 15, and 16. 

259. Mine Safety and Health Administration. (2007). Technical Study panel on the 

Utilization of Belt Air and the Composition and Fire Retardant Properties of 

Belt Materials in Underground Coal Mining. Transcript of Proceedings. 

Conference Room 5. Sheraton Reston, 11810 Sunrise Valley Drive, Reston, 

Virginia, September 19, 2007. 164 pages. 

260. Final Recommendations, Technical Study Panel. 

261. Three day meeting sign-in sheets 

262. Conti et al. (2005). Fire Response Preparedness for Underground Mines. 

Information Circular IC-9481. Department of Health and Human Services, 

Centers for Disease Control and Prevention, National Institute for 

Occupational Safety and Health, Pittsburgh Research Laboratory, Pittsburgh, 

PA. December 2005. 25 pages. 

263. Mine Safety and Health Administration. (1992). Belt Air Advisory 

Committee, Sixth Meeting, Volume I, Ramada Renaissance Hotel, Gallery II 

Ballroom, 950 North Stafford Street, Arlington, Virginia. Wednesday, 

September 9, 1992. 265 pages. 

264. Mine Safety and Health Administration. (1992). Belt Air Advisory 

Committee, Sixth Meeting, Volume II, Ramada Renaissance Hotel, Gallery II 

Ballroom, 950 North Stafford Street, Arlington, Virginia. Thursday, 

September 10, 1992. 228 pages. 

265. Mine Safety and Health Administration. (1992). Belt Air Advisory 

Committee, Sixth Meeting, Volume III, Ramada Renaissance Hotel, Gallery II 

Ballroom, 950 North Stafford Street, Arlington, Virginia. Friday, September 

11, 1992. 157 pages. 

266. Krog et al. (2006). Predicting methane emissions from longwall faces by 

analysis of emission contributors. Proceedings, 11th U.S./North American 

Mine Ventilation Symposium, Taylor & Francis, London, pp. 383-392. 

267. Mine Safety and Health Administration. (1999). Updated Preliminary 

Regulatory Impact Analysis And Regulatory Flexibility Analysis, Proposed 

Rule on 30 CFR Part 14 and 30 CFR §§ 75.1108 and 75.1108-1, RIN 1219-AA92, 

Proposed Requirements for the Approval of Flame-Resistant Conveyor Belt 

Rule. December 1999. 95 pages. 

268. Mine Safety and Health Administration. (2007). Internal Review of MSHA’s 

Actions at the Aracoma Alma Mine #1, Aracoma Coal Company, Inc., 

Stollings, Logan County, West Virginia, June 28, 2007. 233 pages. 

269. Timko, R. and Thimons, E. (1982). Sulfur Hexafluoride as a Mine Ventilation 

Research Tool- Recent Field Applications. Research Investigation RI-8735, 

U.S. Bureau of Mines, Washington, DC, 19 pp. 

270. Fiscor, S. (2007). U.S. Longwall Census. Coal Age, Vol. 112, No. 2, pp. 30-38. 
 131

271. Fuller, P. (2007). Cambria Association of the Blind, Phone Conversation of 

July 31, 2007. 

272. Kissell, F. (2006). Handbook for Methane Control in Mining. IC 9486. 

Department of Health and Human Services, Centers for Disease Control and 

Prevention, National Institute for Occupational Safety and Health, Pittsburgh 

Research Laboratory, Pittsburgh, PA. June 2006. 191 pages. 

273. Mintz, K. (1995). Evaluation of Laboratory Gallery Fire Tests of Conveyor 

Belting, Fire and Materials, Vol. 19, No. 1, Page 19-27. 

274. Knepp, W. (2007). Assistant District Manager, MSHA Coal Mine Safety and 

Health District 9, Phone Conversation with Jan Mutmansky of July 2, 2007. 

275. Dupree, A. (2007). Assistant District Manager, MSHA Coal Mine Safety and 

Health District 5, Phone Conversation of August 10, 2007. 

276. Bakke, P. and Leach, S. (1962). Principles of Formation and Dispersion of 

Methane Roof Layers and Some Remedial Measures. The Mining Engineer, 

Paper Number 3924, July 1962. Page 645-658. 

277. McPherson M. (1993). Subsurface Ventilation and Environmental 

Engineering, Chapman & Hall, London, UK, pp. 282-321. 

278. Eslinger, M. (2007). E-Mail to W. Francart dated July 19. 

279. Dupree et al. (1993). The Effect of Stopping Leakage on Intake Escapeway 

Integrity. Proceedings of the 6th U.S. Mine Ventilation Symposium, SME, 

Littleton CO, Page 13-17. 

280. Kennedy, W. (1996). Practical Mine Ventilation, Intertec Publishing, Chicago, 

IL, Page 37-55. 

281. Hartman H., Mutmansky, J., Ramani, R., and Wang, Y. (1997). Mine 

Ventilation and Air Conditioning, John Wiley & Sons, Inc., New York, NY, 

Pages 455-523. 

282. Conti R., and Litton, C. (1992). Response of Underground Fire Sensors: an 

Evaluation. Research Investigation RI-9412. U.S. Department of the Interior, 

USBM, Pittsburgh, PA. 13 pages 

283. Sapko et al. (1981). Fire resistance test method for conveyor belts. Report of 

Investigation RI-8521. U.S. Bureau of Mines. Pittsburgh, PA. 31 pages. 

284. U.S. Bureau of Mines. (1955). Fire-resistant conveyor belts: Tests for 

permissibility; Fees. S 28. 5 pages. 

285. Gillies, A. and Schimmel, Finning, M. (1983). Atmospheric Fogging in 

Underground Mine Airways, Mining Engineer, April 1983. Pages 336-342. 

286. Mine Safety and Health Administration. (2006). Emergency Mine Evacuation, 

Final rule. Federal Register, 71(December 8, 2006): 71430-71455. 

287. Mine Safety and Health Administration. (2006). Water Sprinkler Fire 

Protection of Underground Belt Conveyors and Belt Takeup Storage Units. 

Program Policy Letter NO. P06-V-5PPL, signed by Ray McKinney, 

Administrator for Coal Mine Safety and Health, Effective Date: 06/16/06, 3 

pages. 
 132