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Based on our recent discussions with the operator, I believe that the <br /> mine management is now making a good-faith effort to improve conditions. <br /> The hiring of Mark Skiles and Jim Kiser reinforces the company commitment <br /> toward safety. Lost time due to accidents is now down 75 percent from <br /> 1987. <br /> Given all the above, I would like to encourage MSHA and the company to <br /> discuss development of short and long-term strategies to insure company <br /> compliance with federal mine safety standards. I would also suggest that <br /> state mining officials be involved and kept abreast of developments as <br /> appropriate. To guarantee substantive discussion, I suggest that MSHA <br /> include technical experts in ventilation and roof/rib control who are <br /> familiar with the mine and this type of mining environment from your <br /> Arlington, District 4 and District 7 offices. I would hope that <br /> Mid-Continent would include the mine and safety managers as well as their <br /> expert ventilation contractors. If requested, I will ask the Colorado <br /> School of Mines to provide experts for the discussions. The <br /> recommendations of these technical experts should then be reviewed by <br /> company and agency policy officials for a realistic assessment of the <br /> time and financial commitment necessary for implementation. <br /> The purpose of the discussion would be to develop by consensus a revised <br /> mine safety plan and implementation schedule, a procedure consistent with <br /> MSHA statutes. It would be my hope that this team of experts could <br /> establish mutually acceptable short and long-term safety improvements, <br /> maintenance schedules and miner training programs that will result in <br /> fewer safety problems in the mine. In order to allow operations to <br /> continue, short-term strategies must focus on the life-threatening <br /> issues. Long-term strategies can consider the other MSHA concerns that <br /> are violations of standards but that do not create hazardous situations. <br /> The discussions should also include a review of enforcement actions to <br /> date for consistency, adherence to MSHA policies and standards, <br /> compliance with the current approved mine plan, and benefit of MSHA <br /> actions to overall miner safety. In addition, I would ask MSHA to <br /> consider the usefulness of a resident inspector program at the mine to <br />