April 12, 2010 | Mark Paradies

Monday Accident & Lessons Learned: Do Laws Improve Safety Performance?

A recent CNN report stated:

Two West Virginia mining accidents within 17 days in January 2006 killed 14 people and prompted Congress to pass the most sweeping mine safety legislation in 29 years.

The Mine Improvement and New Emergency Response (MINER) Act of 2006, along with tougher policies subsequently adopted by federal regulators, helped reduce mining fatalities to record low levels from 2007-2009.

The article says that the MINER Act of 2006 helped cause the “record low levels” of fatalities from 2007-2009. It states it like a fact. Yet it offers no proof that the MINER Act caused any improvement. After all, how long after the passage of a bill does it take for all the requirements to go into effect?

One part of the Act (sealing of abandoned areas) wasn’t required to be complied with until November of 2008.

Also, I would like to see what accidents in 2007-2009 were impacted by the improved rescue requirements of the MINER Act and how the requirements saved lives for each impacted accident.

But let’s just look at the statistics available and see if the improvements quoted are significant.

First, let’s plot the total number of mining fatalities in the US. I found these figures for total fatalities at the MSHA web site and graphed them in an XmR Chart (we teach this in the Advanced Trending Techniques Course):

Picture 31.png

According to this plot, we can’t prove a significant improvement based on total mining fatalities until we have less than 31 fatalities in a year.

Granted, this data is:

  • very limited,
  • combined (all mines), and
  • not corrected for the total number of mines or the total number of miners.

Let’s try another number that I could find at MSHA’s web site. The mining fatality rate (fatalities per 200,000 miner hours worked). For this plot I had more data (10 years to plot). Here is the graph…

Picture 32.png

Ahh … This is more interesting. Over 10 years we go from being slightly above the upper limit (significantly worse) to slightly below the lower limit (significantly better). But the data still doesn’t show WHY the trend is occurring. Therefore, we don’t know if it will continue.

For example, the economic downturn in 2008/2009 could have forced some of the weakest mines (worst safety performance) out of business. That could be the cause of the improved statistics independent of regulatory efforts.

Or, increased inspection could cause improved performance at the mines. So, let’s look at the number of Citations and Orders from the data in the first MSHA source above…

Picture 33.png

Hmmmm … This, too, is interesting. The number of citations and orders are up significantly over the past seven years. Once again, more data (perhaps 15 years) would be nice. But perhaps we are on to something.

Once again, remember, correlation does not prove causation. So inspections, citations, and orders could all be up, but mine safety could be improving for other reasons.

It would be interesting to see safety statistics on a per mine basis and see what is happening at the worst mines. Improvement at the worst mines can have a major impact on these statistics. Pareto Charts of mining fatalities by mine and operator would be very valuable. As we have seen in the past few weeks, one bad accident can have a significant impact on a year’s fatality statistics.

Targeting the biggest hazards (the worst performing mines) and getting their performance up to the level of the best performing mines should be a major initiative for MSHA and the mine owners. Pareto Charts could show us where we need to be focusing our regulatory and safety efforts.

So, this analysis should get you to THINK about what you read. Just because a news article says that a regulation has improved performance, don’t blindly believe it. Look at the statistics. Think about other potential causes. Review the data. Draw some Pareto Charts and Process Behavior Charts to help focus your analysis and prove significant changes.

If you are at a mining company and you want to learn best practices from inside and outside the mining industry, what should you do? Attend the TapRooT® Summit on October 27-29, 2010. The TapRooT® Summit always has some of the best mining operators in the world in attendance. Plus there are performance improvement experts and peers from a large variety of other industries willing to share their secrets of success.

Also, plan to attend the Advanced Trending Techniques Course just prior to the Summit (October 25-26) to learn to draw Pareto and Process Behavior Charts. These charts can be invaluable to targeting your improvement efforts and making your improvement program efficient and effective.

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