The American Industrial Hygiene Association (AIHA) this week provided comments to the Mine Safety and Health Administration (MSHA) on its proposed rule regarding miners’ exposure to respirable coal mine dust (published in the Federal Register on October 19, 2010).

“AIHA has the same concerns as MSHA when it comes to the increase in black lung disease among the nation’s coal miners,” said AIHA President Michael T. Brandt, DrPH, CIH, PMP, in a written statement. “In reviewing the most recent data from NIOSH, it appears that even younger miners are showing evidence of advanced and debilitating lung disease from excessive dust exposure. AIHA supports the proposal that would lower the existing concentration limits for respirable coal mine dust in the hopes that this lower limit would better manage the health of these coal miners.

However, Brandt said his organization objected to the MSHA’s bid to expand the requirements of certified persons who perform dust sampling and who maintain and calibrate sampling equipment. Under the proposal, individuals must be certified by passing an MSHA examination to demonstrate competency in respirable coal mine dust after completing an MSHA course of instruction.

”AIHA maintains that a certified industrial hygienist (CIH) is already qualified to conduct this sampling and should not be required to maintain a separate MSHA certification nor should the CIH be required to attend an MSHA instruction course,” said Brandt.

“It is well recognized that a certified industrial hygienist is imminently qualified to conduct this sampling without the need of further instruction or certification. A CIH must have a college degree with 60 semester hours in undergraduate or graduate level courses in science, math, engineering and science based technology, four years broad based professional industrial hygiene experience, college or continuing education courses in IH fundamentals, controls and technology; as well as inclusion of air sampling and instrumentation covered on the CIH examination.”

Brandt said that requiring CIHs to get additional instruction and certification would incur unnecessary costs, and urged the MSHA to recognize certified industrial hygienists as having met the requirements to conduct air sampling of respirable coal mine dust.

The MSHA announced Monday that, due to requests from interested parties, it has extended the comment period on the proposed rule until May 31st. It was originally scheduled to end May 2.

"Our goal to end black lung is a long-standing one and was one of the commitments I made when I came to MSHA," said Joseph A. Main, assistant secretary of labor for mine safety and health. "Not surprisingly, there has been an overwhelming response to this proposed rule. The additional time hopefully will give everyone who wants to comment the opportunity to do so."

All comments must be received or postmarked by midnight EDT on May 31. They must be marked "RIN 1219- AB64" and may be sent to MSHA electronically; by fax to 202-693-9441; by mail to MSHA, Office of Standards, Regulations and Variances, 1100 Wilson Blvd., Room 2350, Arlington, VA 22209-3939; or hand delivered to the same address.