American Mining Congress v. Mine Safety &amp; Health AdministrationAmerican Mining Congress v. Mine Safety &amp; Health Administration American Mining Congress v. Mine Safety & Health Administration American Mining Congress v. Mine Safety & Health Administration, 995 F.2d 1106 (1993) is a decision by the United States Court of Appeals for the District of Columbia Circuit concerning the issues of administrative law and agency oversight. Overview. In this case, a miners' organizations petitioned for review of Program Policy Letters (PPL) of Mine Safety and Health Administration, stating agency's position that certain x-ray readings qualified as diagnoses of lung disease within meaning of agency reporting regulations. Holding. The Court was called upon to determine whether the PPL on the  issue of x-rays was an interpretive rule, in which case it would be valid, or a legislative rule, in which case it would be invalid (for not being enacted in accordance with the Administrative Procedure Act). The Court used a four-part test to determine whether the rule was legislative (an affirmative answer to any one means the rule is legislative): American Mining Congress v. Mine Safety & Health Administration American Mining Congress v. Mine Safety & Health Administration, 995 F.2d 1106 (1993) is a decision by the United States Court of Appeals for the District of Columbia Circuit concerning the