Regulatory implications of airborne respirable free silica variability in underground coal mines

The respirable dust standard for respirable free crystalline silica in underground coal mines is expressed as milligrams per cubic meter (mg/m3) of respirable dust and is determined by the silica content of the dust. The Mine Safety and Health Administration (MSHA) regulates silica exposure by determining and enforcing compliance with the respirable dust standard for each active mine section. The MSHA strategy for regulation is examined in the context of respirable free crystalline silica and dust data. Deficiencies of the strategy include the same enforcement efforts regardless of compliance history, inappropriate treatment of data, and emphasis on short-term variability of silica content. These deficiencies result in inadequate enforcement in chronically dusty mines, "game playing" with optional samples, and an overall approach that does not focus on the long-term impact of silica exposure on lung health. Alternative approaches include enforcement efforts proportional to compliance history, use of a moving average silica content, and more statistically sound approaches to data interpretation.