Are you new to the mining world? Are you just coming back to mining? Do you just need to do your annual mine safety training? You may be wondering what training you need to do. Navigating the requirements of MSHA training can be challenging. Especially when it comes to understanding the differences between MSHA Part 46 and MSHA Part 48.
If you do the wrong training, they may not let you on the mine site–but don’t worry. In this article, we’ll outline which training you need based upon where you are working. We will also explore key differences between these two training programs and the specific requirements for each.
Before we get into it, let’s cover our bases.
Do I Need Part 46 or Part 48 Training?
The type of MSHA training you need—Part 46 or Part 48—depends on the type of mining operation where you’ll be working. Part 46 training is required for workers in surface non-metal mines such as sand, gravel, stone, and cement operations. Part 48 training, on the other hand, is necessary for workers in both surface and underground metal and non-metal mines, as well as in coal mines. Additionally, Part 48 trainings can only be taught by a Blue Card Certified trainer.
How Do You Know If You Are a New Miner or Experienced Miner?
Do you meet these requirements? An experienced miner is a person who:
- Is employed as a miner on April 14, 1999; or
- Has at least 12 months of cumulative surface mining or equivalent experience on or before October 2, 2000; or
- Began employment as a miner after April 14, 1999, but before October 2, 2000 and who has received new miner training under § 48.25 or under the proposed requirements published April 14, 1999; or
- Is employed as a miner on or after October 2, 2000 who has completed 24 hours of new miner training under § 46.5 of this part or under § 48.25 of this title and who has at least 12 cumulative months of surface mining or equivalent experience (MSHA, 2017).
Determining whether a miner is considered experienced is straightforward: if they have worked for at least 12 months and completed 40 hours of training, they are classified as experienced. For experienced miners, the 8-hour annual refresher training ensures that they stay up-to-date with safety protocols and regulatory changes.
How Long is MSHA Training?
The length of MSHA training varies depending on whether a miner is new or experienced. Both MSHA Part 46 and MSHA Part 48 require new miners to complete 24 hours of training. Initial training is crucial for equipping miners with the knowledge and skills they need to work safely in their specific mining environment. After the initial training, all miners—whether under Part 46 or Part 48—must complete an 8-hour refresher course every 12 months.
MSHA Part 46 Training
MSHA Part 46 Training is for those working in “shell dredging or employed at sand, gravel, surface stone, surface clay, colloidal phosphate, surface limestone, marble, granite, sandstone, slate, shale, traprock, kaolin, cement, feldspar, and lime mines (MSHA, 2017).” Are you working in one of those mine types? If you are, continue reading in this section. If not you can skip to the next section.
The primary goal of MSHA Part 46 Training is to ensure that miners understand the safety protocols and procedures necessary to maintain a safe working environment. This training program is distinct from MSHA Part 48. That is required for underground mines and surface mines that extract coal, metals, and other materials.
The training requirements under Part 46 vary depending on the miner’s experience level. New miners must complete 24 hours of training. The first four hours are required before starting work at the mine. The remaining 20 hours can be completed while working under the supervision of an experienced miner. On the other hand, experienced miners are required to complete an 8-hour refresher course annually to maintain their certification.
Who Can Give Part 46 Training?
MSHA says that a competent person can give part 46 training. Who is a competent person? “A competent person is a person who is designated by the production operator or independent contractor who has the ability, training, knowledge, or experience to provide training to miners in his or her area of expertise. The competent person must be able to effectively communicate the training subject to miners, and evaluate whether the training given to miners is effective (MSHA, 2001).” Basically anyone can be deemed a competent person by either the production operator or an independent contractor with knowledge and experience in mining. They don’t have to be approved by MSHA like they do for Part 48 training.
Part 46 New Miner Training
This is an interesting question because Part 46 has a small loophole for training. If an employee is newly hired and an inexperienced miner, then he can technically have 4 hours of miner training at a mine and start working as long as he gets all his training within 90 days (see section 46.5 for what has to be trained by what days). If that employee then went to another mine to work, he would still be considered an inexperienced new miner. He doesn’t have 24 hours of new miner training (don’t forget you also have to have 1 year of experience).
How Long is the Annual Refresher Training for Part 46?
Annual refresher training for experienced miners must be conducted every 12 months and is a minimum of 8 hours. Just make sure that the required topics are covered in the training plan.
Does It Matter If Your Mining Experience Was 5 years Ago?
If you meet the requirements of an experienced miner, you will always be an experienced miner. You will, however, have to have some additional training before returning to work. Typically, this is done in an annual refresher type training session, where newly hired experienced miner training is required. Most companies provide at least 8 hours of training for this.
MSHA Part 48 Training
MSHA Part 48 Training is mandatory for workers at underground mines and surface mines that extract coal, metal, and other specific materials. Similar to MSHA Part 46, this training is divided into two categories: new miner training and refresher training for experienced miners.
New miners under Part 48 are required to complete 24 hours of training. The first 4 hours must be completed before they can begin working at the mine. The remaining 20 hours can be completed on the job under supervision. Experienced miners must also complete an 8-hour refresher course annually to maintain their certification.
One important aspect of MSHA Part 48 Training is that it covers a broader range of hazards and safety procedures compared to Part 46. It reflects the increased risks associated with underground and certain surface mining operations.
What If I Work in Part 46 and Part 48 Surface Mines?
“MSHA will allow independent contractors who work at both Part 46 and Part 48 surface mining operations to comply with the training requirements of Part 48, instead of complying with both training rules. This will eliminate the need for developing two training plans and complying with two record-keeping requirements (MSHA, 2017).” This means that you only have to attend the part 48 training and not the part 46 training. For those who work as independent contractors in the mining industry, it’s important to understand that completing MSHA Part 48 training can meet the requirements for both Part 46 and Part 48 mining operations.
However, the reverse is not true. If you only complete MSHA Part 46 training, you will still need to undergo Part 48 training if your work involves underground mines or surface mines that extract coal, metals, or other regulated materials.
Who Can Give Part 48 Surface Mine Training?
MSHA part 48 training is required to be completed by someone who has been approved by MSHA. A non-approved person can also give the training as long as an approved instructor is present.
How Long is New Miner Training for Part 48 Surface Mines?
New miner training for Part 48 is the same time allotment of 24 hours as Part 46 new miner.
Key Differences Between Part 46 and Part 48
Understanding the differences between MSHA Part 46 and MSHA Part 48 training is crucial for anyone working in or managing mining operations.
To sum it up, the key differences between Part 46 and Part 48 MSHA training lie in the mining environments they cover, the training requirements, and who can conduct the training. Part 46 training is specific to surface non-metal mines like sand, gravel, and stone operations. It allows for a more flexible approach where competent persons designated by the mine operator can conduct the training.
Part 48 training applies to both surface and underground metal and non-metal mines, as well as coal mines, and has more stringent requirements. Including mandatory use of MSHA-approved trainers and a more formalized training structure. Additionally, Part 48 training requires more extensive initial and refresher training hours compared to Part 46.
If you’re an independent contractor, completing MSHA Part 48 training can cover you for both Part 46 and Part 48 operations, offering you more flexibility and ensuring comprehensive compliance.
Choosing The Right MSHA Training: Part 46 vs 48
Now that you have a clearer understanding of your requirements, it’s imperative to secure the right training to protect both yourself and your employees. By choosing the right training program and keeping up with annual refresher courses, you can ensure that your team is well-prepared to work safely and effectively in any mining environment.
If you would like to learn more about training and training plans or would like some assistance with your training or building training plans, feel free to reach out to us at MSHA Safety Services. We specialize in providing the best training and ensuring your MSHA training plans (Part 46 and Part 48) are ready to keep you and your employees safe and compliant.