P. 0.Box 1488 Paonia, CO 81428 * 970-527-4135 * Fax 970-527-2234
Marvin W. Nichols Jr.
1100 Wilson Blvd.
Arlington Virginia 22209
By email firstname.lastname@example.org
The following are the comments of Rowie Resources Limited on Verification of Underground
Coal Mine Operators Dust Control Plans and Compliance Sampling for Respirable Dust.
1. 	These rules are very complex, and in their current form we believe that they are almost
know what is
to bc in compliance with them. In
listening to comments at the hearing in Grand Junction it was pretty clear that none of the
speakers understood the rules they were commenting on. The rules need to be re-written
in a much simpler form.
2. 	 Bowie Resources takes
position that MSHA should take the responsibility for all
respirable dust sampling. This includes the requirement of plan verification.
3. 	 Bowie resources believes that the future of respirable coal mine dust sampling is in the
Personal Dust Monitors. We are of the opinion that all parties involved in the protection
of the health of coal
will insist that the
are developed and used in the
underground coal mines. We also
that this will be accomplished in the short term
rather than long term. With this in mind we see the proposed rules as a stopgap measure
that does not have much of a future and new rules will be forthcoming to require their
use. We believe that the current proposed rules should not become effective. They should
be withdrawn until the
We do not believe that a single shift sample will
the health protection of the
miners. The currently proposed rules will allow MSHA to take over the responsibility for
dust sampling by lowering the commitment of resources by MSHA to get the job done.
They will allow MSIIA to bc
to defend citations written on a single sample but
single shift sampling will not better define the exposure of miners to respirable dust.
the required production level at the loth