The Act of Surveillance

The Act also established a surveillance system for assessing 9 prevalence of pneumoconiosis among underground coal miners, but this surveillance does not extend to surface coal miners. A study by CDC suggests that surface coal mine operators should monitor worker exposures closely to ensure that both respirable dust and silica are below recommended levels to prevent CWP15 . Clinicians should be aware of the risk for advanced pneumoconiosis among surface coal miners, in addition to underground coal miners, to facilitate prompt disease identification and intervention15 . Additionally, NIOSH recommends that surface coal miners be included in periodic health surveillance that is similar to that conducted for underground miners15 .

To prevent CWP in surface miners, operations should use effective dust monitoring and control methods to reduce respiratory hazards and emphasize the risk for advanced pneumoconiosis in worker training. CDCs National Institute for Occupational Safety and Health recommends that surface coal miners be included in periodic health surveillance15 . Enforcement strategies are not yet clear from the available documents. The development of a Green Permit system by numerous states and best management practices based on credible environmental management systems are potential applications for the mining industry17 . The permitting process is an increasing burden and cost to mining companies. A surface coal mining permit issued under the authority of the Surface Mining Control and Reclamation Act (SMCRA) -OSM has granted the WVDEP primary authority to administer the surface mining regulatory program in the state. Three other permits (approvals) issued under the authority of the Clean Water Act (CWA): Section 402 National Pollutant Discharge Elimination System (NPDES) permit for discharges from sediment control ponds and other drainage structures; a Section401 water quality certification from the state, assuring that the federal permits will not cause a violation of the state's water quality standards; and Section 404 permit for discharge of fill material in streams. Four federal agencies and one state agency have primary responsibility for mountain top mining operations: the Fish and Wild life Service (FWS), Environmental Protection Agency (EPA), Office of Surface Mining (OSM), US Army Corps of Engineers, and the West Virginia Division of Environmental Protection (WVDEP). Risk Communication Although the risks associated with coal dust is known and well documented, and policies are developed in response, it yet to be known if all these are well communicated through a suitable channel to those who need them the most. Without good communication, behavior change necessary to reduce exposure may be difficult.

In communicating the risk of coal mine dust, all stakeholders should be involved, not just the coal mine workers, but owners of mine companies, health service providers and even the communities too. This suggestion is similar to the conclusion of the CDC study15 which recommended that clinicians and miners should be aware of the risk for Coal Workers' Pneumoconiosis (CWP) and Progressive Massive Fibrosis (PMF) in surface coal mines as well as underground minesto facilitate prompt disease identification and preventive interventions.15 Inadequacies in the mandated coal mine dust regulations; failure to comply with or adequately enforce those regulations3 ; lack of disease 10 prevention innovations to accommodate changes in mining practices (e.g., thin-seam mining); and missed opportunities by miners to be screened for early disease and take action to reduce dust exposures3 . Further explanations, noted in other reports included longer hours being worked by today's coal miners3 ; excessive exposure to crystalline silica, perhaps associated with the mining of thinner seams of coal3 ; and lack of resources for dust control and miner/operator education, particularly in smaller mines3 are all management concerns in the control of CWP among miners in the Appalachia. Although coal mine workers are the focus of this write up, the community are also nervous that the increase on CWP cases may also mean an impending doom for their own health. The ensuing litigation and public controversy underlined the importance of communication between the coal industry and its primary stakeholders: employees and the community. Many of the comments at the public hearings conducted in connection with the Governor's task force and federal agency EIS indicated that the public did not feel included in the development of public policy regarding mountain top mining17 . Industry comments indicated that the public may have misperceived many of the engineering and economic constraints faced by the mining industry. Summary and conclusions: The current response to coal dust exposure limit is not sufficient. A tighter coal exposure limit has been proposed by MSHA but not yet effective. Added to this, there should be improved but feasible engineering controls which would create more effective barrier between miners and coal dust during mining process.

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