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Another commenter famous that § fifty seven. was pointless because mine operators have already got efficient mechanisms in place to establish and proper upkeep issues on diesel tools, together with emissions-related i’m a june girl i have 3 sides the quiet and sweet all over printed criss-cross tank top issues. Another commenter nervous that a quotation might be issued if an inspector believes an operator

i’m a june girl i have 3 sides the quiet and sweet all over printed criss-cross tank top

not be burdensome. For mine operators that don’t, this requirement will forestall unqualified individuals from performing improper maintenance procedures on this equipment, thereby stopping this equipment from generating probably extreme diesel emissions. In apply, the appropriateness of the coaching or experience of the upkeep personnel will be revealed by the efficiency of the equipment, each the diesel engine itself and any emission aftertreatment units. If MSHA finds a scenario the place maintenance seems to be shoddy, where the log indicates an engine has been in for restore with more frequency than should be required, or the place repairs have broken engine approval standing or emission management effectiveness, MSHA would ask the i’m a june girl i have 3 sides the quiet and sweet all over printed criss-cross tank top operator to supply evidence that the person who worked on the tools was correctly certified by virtue of coaching or expertise. These necessities are protecting to miners as a result of they drive mine operators to handle dpm emissions issues through a systematic and efficient program. The mixture of equipment tagging and logging helps insure issues will be recognized and resolved quickly. If both or both necessities were eliminated, mine operators can be much less more likely to receive well timed notice of a possible problem, and as soon as notified, would be much less motivated to promptly initiate the required examination and corrective measures. MSHA has concluded that the necessities in the proposal relative to tagged equipment logs are important to effectively controlling dpm, and have subsequently been retained within the last rule without change. They allow both the mine operator and MSHA to track emissions-associated problems on tools, and the actions taken by the mine operator to resolve the issues that occur. The logs are additionally necessary as a result of they provide a written report documenting when equipment was tagged, and the way the mine operator responded.

MSHA considers the provision for tagging equipment to be preferable to a system which permits equipment operators to simply notify their supervisor of a suspected emissions-associated downside, as a result of the presence of a tag serves as a caution sign to different miners working on or close to the tools, as well as a reminder to mine management that this piece of kit needs to be examined. Simply informing the supervisor does not present this ongoing visual indicator or reminder, and as miners and gear are reassigned to completely different jobs in several elements of a mine, data that’s communicated verbally can be simply forgotten. A main benefit of tagging is that the tag goes with the equipment throughout the mine, alerting all who come in contact with it of the potential dpm emissions drawback. In this sense, tagging requirements are particularly useful for cellular gear that travels from place to put all through the shift, and should have a number of operators over the course of a number of shifts. MSHA believes that the tools tagging necessities of §. and § fifty seven. are inherently and considerably different, to the extent that the §. requirement, even if modified to incorporate health hazards, couldn’t achieve the specified impact of §.. The function of § fifty seven. is to immediately take away tools from service if it poses a security hazard, whereas the purpose of §. is to establish a potential emissions-related problem that might require maintenance, but doesn’t justify immediate removal from service. Another necessary difference is that examinations under §. occur earlier than a bit of kit is positioned in operation on that shift, whereas § fifty seven. applies throughout a work shift. These fundamental variations would make any attempt to combine the rules overly complicated, which would defeat the commenter’s objective of simplifying the rule. Some commenters suggested that the tagging requirement in the last rule was utterly pointless as a result of its intent is already happy by current §., and that for the sake of simplicity, §. ought to be eradicated.

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