The Industrial Minerals Association – North America (IMA-NA) would like to see MSHA’s regulations at 30 CFR 56/57.12028, regarding annual verification testing for electrical grounding systems, revised. The rule provides:
Continuity and resistance of grounding systems shall be tested immediately after installation, repair, and modification; and annually thereafter. A record of the resistance measured during the most recent tests shall be made available on a request by the Secretary or his duly authorized representative.
The costs associated with the annual testing requirement are substantial and the expected benefits are questionable. The need for annual verification of grounding systems may be appropriate for actual mine sites where grounding may not be as durable or protected as it is within a fixed facility or building. However, many MSHA-regulated sites are fixed facilities and are classified as “mines” only by extension of the statutory definition. The electrical systems serving these facilities are designed, engineered, and constructed according to prevailing law and code, and the intent of the rule is inconsistent with practical application for fixed facilities. The regulation already requires testing immediately following installation, repair, and modification. IMA-NA would like to see the annual testing requirement eliminated. Alternatively, we would like to see the testing requirement changed from annual testing to testing no more frequently than once every five years.