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Section: 56.4201a5
Date: 07/22/2013
District: SE
Negligence: High
Injury or Illness: Unlikely
Injury or illness could be expected to be: Lost Workdays or Restricted Only
Significant and Substantial: No

Condition or Practice: The pit Hitachi EX-1100 Super diesel shovel dry chemical fire suppression
system (Ansul LT-A-101 Model 30) has not been inspected in over twelve
months. An inspection schedule based on the manufacturer's specifications or
the equivalent shall be established for individual components of a system and
followed to determine that the system remains functional to prevent injury to
the shovel operator during an emergency such as a fire. The shovel was last
used for production in December 2012. The shovel was purchased in August 1994
and its fire suppression system was inspected once or twice since. There are
no mitigating circumstances as to why the fire suppression system has not been

Action to Terminate: The fire suppression system's cylinders have been disconnected
and taken out-of-service. A 10-lb. ABC multi-purpose dry chemical fire
extinguisher is on the shovel and available for use in an emergency whenever the shovel is operated. The shovel operator understands.

Why this concerns you: We had a 10lb ABC extinguisher on the machine for the operators escape. However, it was removed because we where not operating at this time. When in operation there is always an extinguisher on the machine. We explained that theft was an issue at this remote mine, but that was not taken into consideration. Just feel like it was an citation for the sake of issuing a citation. The only one we got during the inspection.

Abatement Suggestions From Industry

Unfortunately, the inspector was correct in siting this standard due to strict liability. That stated, if the machine was last used in December of 2012, you could have tagged it out which would have prevented him from inspecting it under 56.14100 and the subsequent MSHA Handbook Series Number: PH09-IV-1. It's a little more detailed than this and the proper wording on the tag is critical. Drop me a line ([email protected]) and I'll shoot the information your way for free. Steve
- posted on 08/01/2013

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