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Safety and productivity in coal mining—How to make both the top priority  19

           provision violated, the potential impact of it on workers, and the negligence level of
           the operator in not complying. Each provision violated is given a separate citation. In
           this chapter, a normalized measure (C/100IH), representing the number of citations
           per 100 inspector hours, is used to track the level of noncompliance. Once the negli-
           gence and impact aspects of a citation are judged by the inspector, and supported by
           the administration, as elevated (by a codified, legal definition), the citation is desig-
           nated as Significant and Substantial (S&S). S&S fundamentally means the
           noncompliance was serious (some level of negligence) and could have injured or
           killed one or more miners working in or near the location where it occurred. In some
           situations, where the negligence and impact on workers was judged extreme and too
           dangerous for miners to continue to work in the affected area, the citation is designated
           as a withdrawal order, or unwarranted failure to comply with the specific provision.
           These latter two normalized metrics are indicated as S&S/100IH and O/100IH in the
           tables later. The total number of citations, including nonelevated ones, is not given.
           The raw data are available online [11].
              Table 2.8 presents the elevated citation metrics for large surface mines. The coal sup-
           pliers’ performance for S&S/100IH was better than the national average for this mine-
           size category in 4 of 6 years, while the metric for 2008 was near the national average and
           the metric for 2011 was reasonably close to the national average. For O/100IH, the sup-
           pliers’ performance was better than the national average in 5 of 6 years, and close to the
           national average in 2009. Overall, those suppliers evaluated in the aforementioned AEP
           study performed very well on compliance with coal mine regulations.
              For underground coal mines, Table 2.9 indicates that AEP coal suppliers’ S&S/
           100IH performance was better than the national average in 5 of 6 years, and very near
           the national average in 2009. Further, the performance steadily improved during the
           period 2009–20, which is remarkable. For O/100IH, results were even better as sup-
           pliers’ performance was superior to the national average in all 6 years while demon-
           strating a steady decline from 2009 through 2013, with the exception of 2012.
              Together, Tables 2.8 and 2.9 show that concerted effort of coal suppliers to comply
           with regulations, and the superior citation results, even in a major-disaster year (2010),
           were significant. The added influence of pressure to maintain market share (desire to
           provide coal to a major power company embracing sustainability principles), coupled


            Table 2.8 Suppliers’ citation measures vs. national rates for large
            surface mines

            Year      S&S/100IH     % of difference   O/100IH     % of difference

            2008      4.30          3.6               0.22         38.9
            2009      3.28           2.9              0.20        8.2
            2010      2.87           13.8             0.19         19.7
            2011      4.45          13.8              0.23         28.8
            2012      3.69           1.6              0.22         35.1
            2013      3.47           26.3             0.20         13.0
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