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PROGRAM POLICY LETTER NO. P08-V-4 FROM: MARK E. SKILES Director of Technical Support KEVIN G. STRICKLIN Administrator for Coal Mine Safety and Health SUBJECT: Water Sprinkler Fire Protection of Underground Belt Conveyors and Belt Takeup Storage Units Scope This Program Policy Letter (PPL) applies to all miners, miners' representatives, Coal Mine Safety and Health (CMS&H) enforcement personnel, and underground coal mine operators. Purpose The purpose of this PPL is to clarify the requirements of Title 30 Code of Federal Regulations (30 CFR) Sections 75.1101-7 and 75.1101-8 concerning the installation requirements for water sprinkler systems and arrangement of sprinklers on underground belt conveyors and belt takeup storage units. This PPL also clarifies the intent of the Mine Safety and Health Administration's (MSHA) Program Policy Manual (PPM) Volume V, Section 75.1101-8 regarding sprinkler systems arrangement of sprinklers. MSHA has determined that some belt takeup storage units do not have adequate fire protection because belt conveyor takeup storage units are not provided with sufficient protection and the wide belts may shield the sprinkler from suppressing a belt fire. MSHA will be inspecting all belt takeup storage units to assure that adequate fire protection is afforded. This PPL is intended to answer questions, eliminate inconsistencies, and provide guidance to enforcement personnel and the mining industry Policy The standards contained in 30 CFR 75.1101 are derived from the statutory provisions 311(f) of the Act to prevent and contain fires primarily in underground belt entries where the danger of fire is particularly great; the rollers and bearings can get hot; the belt itself can burn; oil and grease are present; coal is transported on the belt; and the belt can slip. For these reasons, a fire protection system is required. When sprinklers are chosen as the method of protection, all of these reasons support having sprinkler protection over the entire length of both storage type and non-storage type belt takeup units since these units have all of the above hazards. The cited standard requires that at least one sprinkler be installed above each belt drive, belt takeup, electrical control, and gear reducing unit. This PPL addresses the key elements for compliance with the requirements for water sprinkler systems and arrangements of sprinklers for underground belt conveyors and belt takeup storage units.
Background There has been inconsistency as to whether and what type of fire suppression over belt takeup storage units is required by the standard. Due to the increased width of conveyor belting, the increased length of belt takeup storage units, and the use of larger storage units as the result of the advance of belt conveyor technology, the potential exists that some sprinkler arrangements could be shielded from suppressing a belt fire and fail to satisfy the standard. The mining community has raised questions regarding fire protection requirements for underground belt takeup and belt storage units with respect to the adequacy of fire protection. The current standards specifically require each sprinkler system provide a uniform discharge of water to the belt surfaces which includes belt takeup storage units. Mine operators must assure that compliance is achieved. Authority The Federal Mine Safety and Health Act of 1977 and 30 CFR Part 75.1101-7 and 30 CFR 75.1101-8. Filing Instructions This PPL should be filed behind the tab marked "Program Policy Letters" at the back of Volume V of the Program Policy Manual. Internet Availability This PPL may be viewed on the Internet by accessing the MSHA Home Page (http://www.msha.gov) by choosing "Compliance Info" and "Program Policy Letters." Issuing Office and Contact Persons Coal Mine Safety and Health, Safety Division Salwa ElBassioni, (202) 693-9525 E-mail: el-bassioni.salwa@dol.gov Technical Support - Approval & Certification Center Derrick M. Tjernlund, (304) 547-2301 E-mail: tjernlund.derrick@dol.gov Distribution Underground Coal Mine Operators Miners' Representatives Independent Contractors Mining Product Manufacturers Special Interest Groups Coal and All-Volume Program Policy Manual Holders |
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