A critique of MSHA procedures for determination of permissible respirable coal mine dust containing free silica.

The literature in selected technical subject areas related to the Mine Safety and Health Administration's (MSHA) respirable mine dust control policy was critically reviewed. Specific topics included: (1) the technical aspects of respirable dust sampling, (2) the development of a sampling strategy and (3) currently used analytical techniques for free silica content of respirable coal mine dust. The 2.0 Lpm MSHA respirable dust sampling flow rate does not conform with published results which indicate that to simulate existing pulmonary particle deposition models, the sampling flow rate should range from 1.4 to 1.7 Lpm. MSHA's sampling strategy focuses on controlling respirable coal mine dust with both area and personal samples of workers in selected occupations or activities. Many uncertainties are encountered as area samples are used to estimate personal exposures. Although all of the analytical methods for crystalline free silica are sufficiently sensitive to be able to detect and quantitate free silica at environmentally significant concentrations, they are all plagued with similar difficulties. Analytical standards representing the various forms of silica are not available. Available analytical methods do not differentiate among polymorphs of silica. Recommendations are presented to resolve identified problem areas.