Is It Reasonable For MSHA To Request This Document?

Over the years, we have often discussed Mine Safety and Health Administration (MSHA) requests for documents and the issues mine operators and their supervisors consider when determining appropriate responses.

The topic of MSHA document requests is a recurring one for mine operators, not because operators keep needing to have their memories refreshed regarding the rules, but because the rules tend to keep shifting.

Ten to fifteen years ago, this discussion was a lot more black and white. At that time, operators could primarily focus on the mandatory documents that were required to be maintained pursuant to MSHA regulations (e.g., workplace examination sheets, documented preoperational inspections of mobile equipment (known as "pre-ops"), and training records) and not have a great deal of concern about the documents that fell outside of these categories.