Comment on ETS for Emergency Evacuations

Mine Site Technologies Pty Limited ABN 93 002 961 953 Australia: USA: Mine Site Technologies Pty Limited Mine Site Technologies (USA) Inc. 25-27 Whiting Street 10250 CR 3050 Artarmon NSW 2064 Rolla Missouri 65401 AUSTRALIA UNITED STATES OF AMERICA Tel: +61-2-9437 4399 Tel: 573-364 1356 Fax: +61-2-9437 5866 Fax: 573-364 0059 Email: mst@minesite.com.au Email: mst-usa@minesite.com.au Mr Marvin W. Nichols, Jr. Office of Standards, Regulations and Variances Mine Safety and Health Administration Room 2313 110 Wilson Blvd. Arlington, Virginia 22209-3939 RE: Comments on ETS on Emergency Evacuations Dear Sir, As the Emergency Temporary Standard (ETS) on Emergency Evacuations, recently implemented by MSHA, may impact on communication technologies supplied by our company, and are in fact specifically referred to in the ETS, we would like to make the following comments about our experiences in other mining countries, particularly Australia. We understand the ETS stems from the investigations into the Jim Walter Resources No. 5 Mine explosion in 2001 and fire/explosions at Willow Creek Coal mine in July 2000, which resulted in the death of 14 miners. In both instances MSHA’s investigations concluded that an immediate evacuation of all personnel would have reduced the number of lives lost. The fact that rescue efforts had led other people into danger is true, but reading the accounts ...