The Mine Safety and Health Administration (MSHA) policy of assigning single independent contractor identification (ID) numbers to commercial explosives companies who conduct blasting and other services at multiple mine sites has an unfair and inequitable impact on those companies.
Under current MSHA policy, if a parent corporation had ten subsidiaries separately formed and organized as LLCs operating in different regions across the United States, then each of the ten subsidiaries conducting blasting operations and services (each at different mine sites) would be assigned to share a single ID number despite the fact that each would qualify as an “independent contractor” pursuant to 30 CFR 45.2(c). Further regulation at 30 CFR 45.3 clearly states that “any independent contractor may obtain a permanent MSHA identification number.”
Assignment of single ID numbers to multiple subsidiaries conducting independent contractor operations at multiple mine sites results in unfair computation, accumulation and multiplication of violations and penalties for any citation received at any of the sites where a service has been contracted.
It is requested that MSHA amend its policy to comport with regulations to recognize that any subsidiary, LLC, joint venture, or other separate operating unit qualifies as an independent contractor and therefore has the right to obtain a permanent identification number separate from other subsidiaries and the parent corporation.
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