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MSHA Part 46 vs Part 48 regulations - What's the difference? Mine safety & health expert and former MSHA inspector, Kim Redding, goes over the basics of MSHA Part 46 vs Part 48 Standards.
You have a new job on a mine. Great. Now what? The first is to determine if you need Part 46 or Part 48 training.
The health and safety topics covered in Part 46 and Part 48 can be very similar. The difference is in the execution; who can train your company, how you can fulfill the training requirements, and the MSHA compliance regulations are very different.
You could save thousands of dollars in fines and days of training with a definitive answer.
But how do you determine whether you need MSHA Part 46 vs Part 48 training courses? MSHA’s regulations are dense, vague, and generally unhelpful.
That’s why the Mine Safety Center’s expert Kim Redding built the MSHA Part 46 vs Part 48 tool.
Instead of wading through page after page of legalese, all you need to do is answer a few simple questions. Why wait? Why waste time? Get an answer and start moving forward.
MSHA Training For Busy People
Dominic Vilona
Kim Redding
Mine Safety Expert
Both Part 46 and Part 48 regulations require the same length and frequency of training. Anyone that needs New Miner certification must complete 24 hours of MSHA training.
Annual refresher training must last at least 8 hours.
The only exception to these time requirements is a New Miner who will work in the underground areas at an underground mine. This special type of Part 48 training lasts 40 hours.
Part 48 trainers must have an MSHA blue card. Blue Card trainers must pass a very difficult test to become certified MSHA trainers. Once they pass this test, Blue Card trainers can sign MSHA 5000-23 forms. But this comes with huge liability. Every Blue Card trainer signs 5000-23 forms under the penalty of jail time.
With few exceptions, Part 48 requirements cannot be completed through online training. This is because the Part 48 regulation was written in the 1970’s, before online training was invented. This means you will need to find a certified Blue Card trainer to conduct your course in person.
The blue card trainer should help you fill out a 5000-23 form when training is complete.
Part 46 is a much newer and less rigid regulation than Part 48.
The Part 46 regulation allows for many more training options, including online training. This flexibility can be a huge benefit to companies- particularly smaller mines and contractors. You can conduct your company’s MSHA training in small sections throughout the year or all at once. Whenever works with your busy schedule.
Part 46 companies must designate at least one person (known as the “Competent Person”) as responsible for Health and Safety. This person must verify all MSHA training is complete and keep every record as required by MSHA regulations.
Workers that are Part 48 trained can go on Part 46 operations. But miners and contractors that take Part 46 MSHA training are not considered “trained” on a Part 48 mine site. These workers are considered “New Miners” and must complete the 24 hours of Part 48 New Miner training in order to work on a Part 48 site.
Part 46 safety instructors do not need to be MSHA certified or approved. Trainers only need to be "deemed competent to perform training." What does that mean? If you feel a person at your company is competent to conduct training, they can. The only requirement is they are listed on the first page of your MSHA Safety Training Plan.