Not so long ago, we were giving some thought to the MSHA Part 48 Approved Instructor.

And that led us to give some thought to the three-day, Instructor Training sessions that MSHA leads so that people can become Part 48 Approved Instructors and, in turn, deliver Part 48 training to mine site employees (and contractors, etc.).

We were fortunate enough to get Jeff Duncan, the Director of Educational Policy and Development at MSHA, to give up some of his own time to tell us more about that program. We’re thankful to Jeff for being so generous with his time to do that.

So below we’ve got the highlights of that discussion with Mr. Jeff Duncan of MSHA. We hope you find it interesting and that it sheds more light on the role for of the MSHA Approved Instructor for Part 48.
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There are many different aspects of MSHA Part 46 compliance training. Recordkeeping is one of those.

It’s easy enough to see WHY there are recordkeeping and documentation requirements. Regulators have to know what’s been done and what hasn’t been done. Even if you don’t LIKE doing this, the logic is fair enough. You get it.

That doesn’t mean that creating, storing, and later retrieving all those records is especially fun. And if you’re a safety manager, I’d be willing to bet it’s not your favorite part of your job.

In fact, I recently gave a presentation at MSHA’s annual TRAM conference, and I asked this very question to the 40-or so people who attended the presentation. I learned that basically nobody really enjoyed doing this; that nearly everyone felt they spent more time doing this than they wanted to; and that most everyone was a little unsure if their records were perfect or if they could quickly retrieve specific training records (the one person who said she COULD quickly retrieve specific different types of training records admitted that her confidence came at the cost of a LOT of time working with Excel spreadsheets).

But online, computerized systems can help ease this recordkeeping and documentation challenge. They’ll help you spend less time creating, storing, and retrieving training records and other documentation. This means you can spend more of your time on safety training, safety audits, safety observations, in safety meetings….well, you get the idea. You can spend more of your time doing stuff that is more productive.

In this article, you’ll learn more about some ways that online systems can save you time, headache, frustration, and even money on all this recordkeeping. Read on for the full story.

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If you’re new to safety, the different roles and titles can get a little confusing.

Actually, that’s true even if you’ve been kickin’ around in safety for a while.

Things get even more confusing if you’re trying to keep up with roles that are specially defined by regulators in certain circumstances. For example, OSHA and MSHA mean different things when they refer to “competent persons.”

And things can get still more confusing when one regulator uses two different terms for something that’s pretty similar. For example, MSHA refers to Part 46 trainers as “competent persons” but to Part 48 trainers as “MSHA-approved instructors.”

Confused yet?

If so, we’ll get you back on solid ground shortly, we promise. Read on to clarify what we just talked about.

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If you’re an operator or a production-operator at a surface mine in the U.S., you know you’ve got to provide safety training for your miners. (If this is news to you, we’ll give you some relevant news and definitions about that in just a second.)

In addition, the production-operator and a contracting company share responsibility for making sure that contract employees working at a mine site get safety training as well. We’ve covered that all in our recent MSHA Part 46 Training Requirements for Contractors article.

But in addition to that, you’ve also got to provide safety training to your employees who are not miners. And that’s what we’re going to explain in this article.

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