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By Somerville Todd

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AGENCY COMMENTS We obtained comments on a draft of this report from MSHA, the Department of Labor’s Office of the Solicitor, the Department of Health and Human Services, and the Federal Mine Safety and Health Review Commission. Their comments are reproduced in appendixes III, IV, and V. MSHA and the Solicitor also provided technical clarifications, which we incorporated as appropriate. MSHA, the Office of the Solicitor, the Department of Health and Human Services, and the Federal Mine Safety and Health Review Commission agreed with the recommendations addressed to each of their organizations.

MSHA noted that both agencies started the process of developing a memorandum of understanding in 2002 and stated that it will work with NIOSH to revitalize this effort and complete the process. MSHA, Labor’s Office of the Solicitor, and the Commission agreed with our recommendation for improving the penalty appeals process. Each of them agreed that there needs to be transparency in penalty determinations and that the specific rationale need to be provided when penalties are reduced from the levels originally proposed.

MSHA noted that this action may require regulatory changes. MSHA also explained that there are other avenues that instructors can use to stay current on mining issues, such as attending an annual conference dedicated to training resources for the industry. MSHA also recognized the need to improve the data it maintains on instructors and noted that it has plans to improve its tracking and dissemination of up-to-date information on approved instructors. In response to our recommendation that MSHA and NIOSH develop a memorandum of understanding, both agencies concurred with the need for a formal agreement and stated that such an agreement will help strengthen their coordination activities.

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