Sign Letter to Secretary Su
The Honorable Julie Su
Acting U.S. Secretary of Labor
Frances Perkins Building
200 Constitution Avenue NW
Washington, D.C., U.S.
Re: Failure of your Mine Safety and Health Administration (MSHA) to effectively enforce egress regulations at Cayuga Salt Mine in upstate New York
Dear Secretary Su:
Cayuga Lake Environmental Action Now (CLEAN) is a citizen group working to protect Cayuga Lake from industrial contamination including salt from Cayuga Salt Mine, coal ash leachate from Cayuga Operating Company, and PFAS compounds flowing into the lake.
We are writing to share our concern with you about MSHA’s failure to effectively enforce Federal Law 30 CFR § 57.11050a in the Cayuga Salt Mine.
Cargill, reportedly North America’s largest private corporation, employs about 200 people for its Cayuga Salt Mine in Lansing, New York. Three shifts of miners work in the mine up to 363 days of the year, barring shutdowns for seismic events or MSHA-imposed closures for needed maintenance and repairs.
Federal Law 30 CFR § 57.11050a (see attached MSDA brochure) requires operators of underground non-metal mines to provide miners with: (bolding added for emphasis)
two or more separate, properly maintained escapeways to the surface from the lowest levels which are so positioned that damage to one shall not lessen the effectiveness of the others.
A 2017 Cargill map of Cayuga Mine shows the southern end of NW3, the only tunnel that exists for miners to use to exit from current active mining faces at the north end of Cayuga Mine.
There are four rows of small yielding pillars within the <400-foot-wide NW3 tunnel that create a total of five parallel lanes within the tunnel. (Each black dot represents a small yielding pillar that measures about 12’x18’ by ten feet tall.) It is simply not reasonable for MSHA and Cargill to be treating each lane within the NW3 tunnel as a separate escapeway. A fire, explosion, or mine collapse in one or more lanes could readily “lessen the effectiveness of the others.”
We recommend that MSHA be instructed to review this dangerous situation. We hope for the safety of Cargill’s miners that going forward MSHA will only allow mining where Federal Law 30 CFR § 57.11050a can be meaningfully implemented.