Discussion - Inaccuracy Of Area Sampling For Measuring The Dust Exposure Of Mining-Machine Operators In Coal Mines - Technical Papers, Mining Engineering, February 2002, Vol. 54, No. 2 pp. 33-39 – Kissell, F. N., Sacks, H. K.

Discussion by J.L. Weeks Discussion I wish to comment on Kissell and Sacks's paper "Inaccuracy of area sampling for measuring the dust exposure of mining machine operators in coal mines." It is well established in industrial hygiene that area sampling is not an accurate measure of personal exposure. To measure personal exposure, one must use a personal sampler. Kissell and Sacks, using data from coal mining, reached the same conclusion. This is the right answer but it is the wrong question. This issue arises because the machine-mounted respirable dust continuous monitor (MMRDCM) is being considered to monitor coal-miners' exposure to respirable dust. This device may be mounted on a continuous mining machine, and it would take a modified area sample. I refer to it as "modified" because a mining machine is not really a fixed location, as is the typical area sample. The concern with whether this machine would provide an accurate estimate of the machine-operator's exposure, however, overlooks important features of the MMRDCM. Specifically, it displays dust concentration as it occurs and at the place where it is needed, not 10 days later, as is the case with the current system. Used in this way, it allows for timely intervention to control exposure to dust and it leads to greater first-hand knowledge of specific conditions and mining practices that result in excess exposure. If one knows the dust level is excessive at the time the dust is being generated, it is possible to use known and effective methods of dust control to reduce exposure. By measuring again, one can determine whether control methods have worked. This is a generic procedure followed in any industrial process: measure, adjust and measure again. It leads to more effective and more efficient dust control and is preferred to taking a sample, waiting 10 days for the results and then trying to apply that information to a situation that no longer exists. The MMRDCM also records the dust level automatically, and it runs continuously, making it harder to tamper with. Dust monitoring in underground coal mines has been corrupted by some operators having submitted fraudulent samples (and being convicted on criminal charges because of it), weakening the credibility of the current system. The MMRDCM is, in part, a response to this corruption, and an effort to focus attention on dust levels and dust controls rather than on the perpetrators of fraud. Use of the MMRDCM is an evolutionary change from the current system. With the current system, one takes a personal sample of exposure of the "designated occupation" (DO, defined at 30 CFR 70.2 (f)), the occupation regularly exposed to the highest level of dust on a section. Typically, on sections using continuous mining machines, this is the mining-machine operator. The rationale behind DO sampling rests on some of the findings that Kissell and Sacks report. They reviewed several studies that showed that dust concentration varies with location on a mining section and that there is a concentration gradient with the highest concentration occurring closest to the face. The logic behind DO sampling strategy is that if the dust concentration at the place where it is highest is below the exposure limit, then concentration elsewhere on the section is also below the limit. In this way, one will have achieved the objective or keeping dust concentration below the exposure limit for all miners on the section by measuring the exposure of only one miner. The