Mine Safety: Reports and Key Studies Support the Scientific Conclusions Underlying the Proposed Exposure Limit for Respirable Coal Mine Dust

Correspondence issued by the Government Accountability Office with an abstract that begins "Our evaluation of the reports MSHA used to support its proposal and the key scientific studies on which the reports were based shows that they support the conclusion that lowering the PEL from 2.0 mg/m3 to 1.0 mg/m3 would reduce miners risk of disease. The reports and key studies concluded that miners cumulative exposure to coal mine dust at the current PEL over their working lives places them at an increased risk of developing CWP, progressive massive fibrosis, and decreased lung function, among other adverse health outcomes. To mitigate the limitations and biases in the data, the researchers took reasonable steps, such as using multiple x-ray specialists to reduce the risk of misclassifying disease and making adjustments to coal mine dust samples where bias was suspected. In addition to addressing the limitations and biases in the data, researchers used appropriate analytical methods to conclude that lowering the existing PEL would decrease miners risk of developing black lung disease. For example, in addition to taking steps to precisely estimate a miners cumulative exposure, the researchers accounted for several factors in their analysessuch as the age of the miners, the carbon content of the coal (coal rank), and other factors known to be associated with the diseaseto better estimate the effect of cumulative exposure to coal mine dust. Further, the other studies we identified generally supported the conclusion that reducing the PEL would reduce miners risk of disease.