1219-0026 Supporting Statement 2025

Ground Control for Surface Coal Mines and Surface Work Areas of Underground Coal Mines

OMB Control Number: 1219-0026

OMB Expiration Date: 7/31/2025

Supporting Statement for Ground Control for Surface Coal Mines and

Surface Work Areas of Underground Coal Mines

Paperwork Reduction Act Submission

This information collection request (ICR) seeks to extend, without change, a currently approved information collection.

OMB Control Number: 1219-0026

Information Collection Request Title: Ground Control for Surface Coal Mines and Surface Work Areas of Underground Coal Mines

Type of OMB Review: Extension

Authority:

Part 77 Mandatory Safety Standards, Surface Coal Mines and Surface Work Areas of Underground Coal Mines

Subpart K Ground Control

30 CFR 77.1000 Highwalls, pits and spoil banks; plans.

30 CFR 77.1000-1 Filing of plan.

Collection Instruments(s): Operators may develop ground control plans using any method they choose.

General Instructions

A Supporting Statement, including the text of the notice to the public required by 5 CFR 1320.5(a)(i)(iv) and its actual or estimated date of publication in the Federal Register, must accompany each request for approval of a collection of information. The Supporting Statement must be prepared in the format described below and must contain the information specified in Section A below. If an item is not applicable, provide a brief explanation. When the question “Does this ICR contain surveys, censuses or employ statistical methods” is checked "Yes", Section B of the Supporting Statement must be completed. OMB reserves the right to require the submission of additional information with respect to any request for approval.

Specific Instructions

A. Justification

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.

Section 103(h) of the Federal Mine Safety and Health Act of 1977 Mine Act as amended, 30 U.S.C. 813(h), authorizes the Mine Safety and Health Administration (MSHA) to collect information necessary to carry out its duty in protecting the safety and health of miners. Further, section 101(a) of the Mine Act, 30 U.S.C. 811(a), authorizes the Secretary of Labor (Secretary) to develop, promulgate, and revise as may be appropriate, improved mandatory health or safety standards for the protection of life and prevention of injuries in coal, metal, and nonmetal mines.

In order to fulfill the statutory mandates to promote miners’ health and safety, MSHA requires the collection of information under the information collection request entitled Ground Control for Surface Coal Mines and Surface Work Areas of Underground Coal Mines. The information collection is intended to ensure that mine operators are properly maintaining the highwalls, pits, and spoil banks of surface coal mines and underground coal mines with surface work areas so that a safe environment is provided for mine employees, management, and others who visit the mine property. Mine operators are required to (1) develop ground control plans for highwalls, pits, and spoil banks and (2) submit the ground control plans:

I. Develop Ground Control Plans of Highwalls, Pits and Spoil Banks

Under 30 CFR 77.1000, each operator must establish and follow a ground control plan for the safe control of all highwalls, pits and spoil banks, which must be consistent with prudent engineering design and will insure safe working conditions. The mining methods employed by the operator must be selected to insure highwall and spoil bank stability.

II. Submit Ground Control Plans

Under 30 CFR 77.1000-1, the mine operator must file a copy of the ground control plan, and revisions thereof, with the MSHA District Office in which the mine is located and must identify the name and location of the mine; the MSHA identification number if known; and the name and address of the mine operator.

2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.

MSHA uses the information provided by the mine operator in the ground control plans to ensure that mine operators are properly maintaining the highwalls, pits, and spoil banks of surface coal mines and underground coal mines with surface work areas so that a safe environment is provided for mine employees, management, and others who visit the mine property.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.

Mine operators may develop ground control plans using computer-aided design (CAD) drawings and may retain the records using computer technology (although this is not required). They also have the option of submitting their ground control plans by email. No improved information technology has been identified that would reduce the existing burden.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.

No similar or duplicate information is available or submitted to MSHA. MSHA knows of no other federal, state, or local agency that has a similar paperwork requirement relating to ground control that would duplicate this requirement. All other agencies that inspect coal mines accept and use the ground control plans required by MSHA.

5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.

The information collection provisions apply to all mine operators, both large and small. Congress intended that the Secretary enforce the law at all mining operations within the Agency’s jurisdiction regardless of size and that information collection and recordkeeping requirements be consistent with efficient and effective enforcement of the Mine Act. [S. Rep. No. 95-181 (1977)]. Section 103(e) of the Mine Act, 30 U.S.C. 813(e), directs the Secretary not to impose an unreasonable burden on small businesses when obtaining any information under the Mine Act. MSHA considered the burden on small mines when developing the collection and believes that the information collection requirements are imposed on all mining operators and do not have a significant impact on a substantial number of small business or other small entities.

Information is available on the MSHA website to assist with compliance regarding ground control plans.

• Program Information Bulletin No. P11-02: Filing of Ground Control Plans for Surface Coal Mines, available at https://arlweb.msha.gov/regs/complian/PIB/2011/pib11-02.asp;

6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

If the collection is not conducted and ground control plans are not submitted to MSHA, the Agency would not be able to effectively determine whether mine operators are taking appropriate actions to maintain stable highwalls, pits, and spoil banks in order to protect the health and safety of miners.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

• Requiring respondents to report information to the agency more often than quarterly;

• Requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;

• Requiring respondents to submit more than an original and two copies of any document;

• Requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records, for more than three years;

• In connection with a statistical survey, that is not designed to produce valid and reliable results that can be generalized to the universe of study;

• Requiring the use of a statistical data classification that has not been reviewed and approved by OMB;

• That includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or

• Requiring respondents to submit proprietary trade secrets, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.

This collection of information is consistent with the requirements in 5 CFR 1320.5.

8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.

Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.

Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years - even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

In accordance with 5 CFR 1320.8(d), MSHA will publish the proposed information collection requirements in the Federal Register, notify the public that the information collection requirements are being reviewed in accordance with the Paperwork Reduction Act of 1995, and provide 60 days for the public to submit comments. MSHA published a 60-day Federal Register notice on December 27, 2024 (88 FR 105633). MSHA received two comments. Comment from Trinity Nolen does not need any action from MSHA because the comment only stated “Interested!”. Comment from Kennedy Jones provided suggested for adjustments ground control.

Kennedy Jones’s comment:

I wish to propose adjustments to the plan regarding ground control for surface coal mines and surface work areas of underground coal mines (Docket No. MSHA-2024-0067). Ensuring mine stability and worker safety is critical. While the collection of information on ground control plans is necessary, the Mine Safety and Health Administration (MSHA) should consider ways to streamline the process to reduce unnecessary burdens on mine operators. Allowing electronic submissions, providing standardized templates, and implementing a simplified attestation process for unchanged plans could improve efficiency without compromising safety.

Additionally, greater transparency in assessing these plans and the frequency of required updates would enhance compliance and effectiveness. I commend MSHA’s commitment to safety and encourage the agency to consider these suggestions to balance regulatory oversight with practical implementation.

MSHA’s response to Kennedy Jones:

MSHA encourages operators to submit all plans electronically to the district appointed to their facility location. Operators can contact their district for the submittal process. Electronic submittals have been in operation for many years and allows MSHA to streamline the intake process and distribute to the appropriate reviewers.

By using the electronic submittal, this reduces time and financial burdens the operator normally would accrue from printing, trimming and folding of maps in triplicate, as well as the expensive cost of plotter paper and plotter ink, as well as time taken for re-ordering and reducing required space for stocking the paper.

Although templates can be used in some instances, Ground Control Plans are diverse projects. No one surface facility is the same, whether it’s a multiple seam facility or a single seam, no one template will be able to ascertain the correct data.

This is why MSHA allows the operator to create their own Ground Control Plans, following the regulation requirements, to implement all information needed for their facility.

By following the standards found in 77.1000 – 77.1013, the operator will be able to create their Ground Control Plan that is unique to their location, weather, geological conditions, seam and overburden thicknesses, and mining methods.

Additionally, the operator can detail their plan utilizing the current Program Policy Manual (PPM), Interpretation, Application, and Guidelines on Enforcement of 30 CFR for Part 77, Subpart K – Ground Control. This PPM details five standards which can increase safety precautions in the Ground Control Plan.

By utilizing the standards, electronic filing systems, and Program Policy Manuals, this allows each operator to create a Ground Control Plan tailored to their facility while being efficient and reducing cost.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

MSHA does not provide payment or gifts to respondents.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

Mine operators are given no assurances of confidentiality; however, the ground control plans submitted to the Agency are covered by the Privacy Act Systems of Records Notice, DOL/MSHA–1, Mine Safety and Health Administration Standardized Information System (MSIS), published on April 29, 2016 (81 FR 25766). Computerized and manual records are indexed by mine identification number. Computer safeguards are as described in the National Bureau of Standards Booklet, “Computer Security Guidelines for Implementing the Privacy Act of 1974.” Manual records are stored in locked file cabinets and are accessible only to authorized personnel during working hours.

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

There are no questions of a sensitive nature.

12. Provide estimates of the hour burden of the collection of information. The statement should:

• Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.

• If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens.

• Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included under Item 13.

Ground control plan information was obtained from the MSHA Report Center for calendar years 2021 through 2023. The total number of new ground control plans and addendums or revisions were determined over the three-year period and yearly averages for new plans and addendums or revisions were calculated. On average there were 206 new ground control plans per year and 143 addendums or revisions to existing ground control plans per year. The annual average of total ground control plans was 349.

Wage Rates Determinations¹

MSHA uses data from the May 2023 Occupational Employment and Wage Statistics (OEWS) published by the Bureau of Labor Statistics (BLS) for hourly wage rates² and adjusts the rates for benefits,³ wage inflation,⁴ and overhead costs.⁵ The occupations listed below in Table 12-1 are those that were determined to be relevant for the cost calculations.

Table 12-1. Hourly Wage Rates

Occupation	NAICS Code	Wage Rate	Benefit Multiplier	Inflation Multiplier	Overhead Cost Multiplier	Loaded Hourly Wage Rate
		A	B	C	D	A x B x C x D
Mining Engineer [a]	212100	$50.59	1.461	1.037	1.01	$77.41
Clerical Worker [b]	212100	$22.81	1.461	1.037	1.01	$34.91

Notes: MSHA uses the latest 4-quarter moving average 2023Q3-2024Q2 to determine that 31.6 percent of total loaded wages are benefits for private industry workers in construction, extraction, farming, fishing, and forestry occupations. The benefit multiplier is 1.461 = 1+(0.316/(1-0.316)). The inflation multiplier is determined by using the employment price index from the most current quarter, 2024Q2, divided by the base year and quarter of the OEWS employment and wage statistics, 2023Q2, for private industry workers in construction, extraction, farming, fishing, and forestry occupations, current dollar index. The inflation multiplier is 1.037 = 163.1/157.3. MSHA uses the overhead multiplier of 1.01.

[a] The Standard Occupation Codes (SOC) used for this occupation are (17-2071, 17-2081, 17-2112, 17-2141, and 17-2151).

[b] The Standard Occupation Codes (SOC) used for this occupation are (43-3031, 43-3051, 43-3061, 43-5071 and 43-9061).

Hour Burden

1. Develop Ground Control Plans of Highwalls, Pits and Spoil Banks

MSHA assumes that on average 206 new ground control plans and 143 revised plans are prepared for submission each year, and each plan is submitted by one mine in a year. MSHA estimates that it takes a mine engineer, earning $77.41 per hour, approximately 8 hours to develop a new ground control plan and approximately 5 hours to draft and submit a revised plan for approval.

Table 12-2. Estimated Annual Respondent Hour and Cost Burden, Develop New Plans and Revise Existing Plans (30 CFR 77.1000 and 77.1000-1)

Activity (Occupation)	Number of Respondents (Mines)	Number of Responses per Respondent	Total Responses (Plans)	Average Burden per Response (Hours)	Annual Burden (Hours)	Hourly Wage Rate	Burden Cost
Develop new ground control plans (Mine engineer)	206	1	206	8.00	1,648.00	$77.41	$127,571.68
Revise ground control plans (Mine engineer)	143	1	143	5.00	715.00	$71.41	$55,348.15
Subtotal (rounded)	349		349		2,363		$182,920

2. Submit Ground Control Plans

MSHA assumes an annual average of 349 new and revised ground control plans to be submitted every year. MSHA estimates that it takes a clerical worker, earning $34.91 per hour, approximately 6 minutes to submit each plan, including copying, filing, and mailing.

Table 12-3. Estimated Annual Respondent Hour and Cost Burden, Submit Plans (30 CFR 77.1000-1)

Activity (Occupation)	Number of Respondents (Plans)	Number of Responses per Respondent	Total Responses (Submissions)	Average Burden per Response (Hours)	Annual Burden (Hours)	Hourly Wage Rate	Burden Cost
Submit Plans (Clerical worker)	349	1	349	0.10	34.90	$34.91	$1,218.36
Subtotal (rounded)	349		349		35		$1,218

Hour Burden Summary

The annual respondent hour and cost burden is summarized in the Summary Totals table below.

Table12-4. Estimated Annual Respondent or Recordkeeper Cost Burden, Summary Totals

Activity	Number of Respondents	Number of Responses per Respondent	Total Responses	Average Burden per Response (Hours)	Total Burden (Hours)	Hourly Wage Rate	Total Burden Cost
Develop new ground control plans	206	1	206	8.00	1,648.00	$77.41	$127,571.68
Revise ground control plans)	143	1	143	5.00	715.00	$77.41	$55,348.15
Submit Plans	349	1	349	0.10	34.90	$34.91	$1,218.36
Total (rounded)	349		349		2,398		$184,138

Note: The sum of the number of respondents and the sum of the number of responses might not add up to the total reported numbers in the table due to multiple people responding to the same activity.

13. Provide an estimate for the total annual cost burden to respondents or recordkeepers resulting from the collection of information. (Do not include the cost of any hour burden already reflected on the burden worksheet).

• The cost estimate should be split into two components: (a) a total capital and start-up cost component (annualized over its expected useful life) and (b) a total operation and maintenance and purchase of services component. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and record storage facilities.

• If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collections services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60-day pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate.

• Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.

MSHA assumes an annual average of 349 new and revised ground control plans to be submitted every year. MSHA estimates that the only recordkeeping cost associated with submitting ground control plans is the cost of copying and mailing the plans. MSHA assumes an average ground control plan contains 6 pages. The copying cost is $0.15 per page, and postage cost is $1.00 per plan.

Table 13-1. Estimated Annual Respondent or Recordkeeper Cost Burden, Submit Ground Control Plans (30 CFR 77.1000 and 77.1000-1)

Cost components	Number of Responses (Plans)	Unit Cost	Number of Units	Cost to Recordkeepers
Copy plans	349	$0.15	6	$314.10
Mail plans	349	$1.00	1	$349.00
Total (Rounded)	349			$663

14. Provide estimates of annualized costs to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information. Agencies may also aggregate cost estimates from Items 12, 13, and 14 in a single table.

MSHA uses data from the FedScope published by the Office of Personnel Management (OPM) for hourly wage rates of Federal employees and adjusts the rates for benefits and overhead. The occupations listed below in Table 14-1 are those that were determined to be relevant for the Federal government cost calculations.

Table 14-1. Federal Hourly Wage Rates

Occupation	Occupation Code	Mean Wage Rate	Benefit & Overhead Multiplier [a]	Loaded Hourly Wage Rate
		A	B	A x B
GS-12 MSHA Inspector [b]	1822	$47.55	1.586	$75.41

Note: Hourly wage rates developed from Office of Personnel Management (OPM) March 2024 FedScope Employment Cube, http://www.fedscope.opm.gov/.

[a] Benefit and overhead multiplier = 1 + (MSHA personnel benefits, travel and transportation, and rental expenses / MSHA personnel compensation) = (1+ ((76,679+20+5,309+5,932+17,577+71) / 180,071) (FY 2024 budget submission, use FY2023 Revised Enacted Budget: https://www.dol.gov/sites/dolgov/files/general/budget/2024/CBJ-2024-V2-13.pdf).

[b] Data search qualifiers are: Agency = DLMS, Occupation = 1822 (Mine Safety and Health Inspection), Work Schedule = Full-Time, Salary Grade = GS-12, Measure = Average Salary. The hourly wage is the annual salary divided by 2,087. In order to include the cost of benefits and overhead, MSHA multiplies the average annual salary by a Federal benefit and overhead multiplier for MSHA of 1.586. Rate equals $75.41 = (($99,228/ 2,087) x 1.586).

MSHA estimates that 206 new ground control plans and 143 revisions to existing ground control plans (349 total plans) will be filed each year. MSHA estimates that it will require a MSHA Inspector, GS-12, 30 minutes to review. As of March 2024, the average wage of a Safety Specialist, GS-12, is $75.41 per hour including benefits.

Table 14-2. Estimated Federal Hour and Cost Burden, Review Ground Control Plans (30 CFR 77.1000 and 77.1000-1)

Federal Occupation	Number of Responses (Plans)	Average Burden (Hours)	Total Burden (Hours)	Hourly Wage Rate	Total Burden Cost
GS-12 MSHA Inspector	349	0.50	174.5	$75.41	$13,159.05
Total (Rounded)	349		175		$13,159

15. Explain the reasons for any program changes or adjustments.

Number of Respondents: The estimated number of respondents has increased from 287 to 349 respondents (by 62 respondents). The increase is attributed to actual data taken from the MSHA Report Center rather than estimates made in the previous ICR.

Number of Responses: The estimated number of responses has increased from 287 to 349 responses (by 62 responses). The increase is due to the increase in respondents.

Annual Time Burden: The estimated annual time burden has increased from 1,962 to 2,398 (by 436 hours). The increase is due to the increase in respondents.

Annual Burden Costs: The estimated annual burden costs have increased from $138,744 to $184,138 (by $45,394). The increase is due to the increase in respondents.

Annual Other Burden Costs: Annual other burden costs have increased from $545 to $663 (by $118). The increase in cost burden is due to the increase in responses.

Federal Hours: The estimated annual federal hours have increased from 144 to 175 (by 31 hours). The increase in cost burden is due to the increase in responses.

Federal Costs: The estimated annual federal costs have increased from $8,867 to $13,159 (by $4,292). The increase in cost burden is due to the increase in responses.

Table 15-1. Summary of Changes

	Previous ICR	Currently Approved ICR	Difference
Number of Respondents	287	349	62
Number of Responses	287	349	62
Annual Time Burden	1,962	2,398	436
Annual Burden Costs	$138,744	$184,138	$45,394
Annual Other Burden Costs	$545	$663	$118
Federal Hours	144	175	31
Federal Costs	$8,867	$13,159	$4,292

16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.

MSHA does not intend to publish the results of this information collection.

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

MSHA is not seeking approval to not display the expiration date for OMB approval of this information collection and there is no form associated with this collection.

18. Explain each exception to the topics of the certification statement.

There is no certification exceptions identified with this information collection.

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS

As statistical analysis is not required by the regulation, questions 1 through 5 do not apply.

1 For all wage rates, including Federal wage rates, MSHA uses the relevant precision throughout the calculation to avoid compound rounding errors and rounds at the final rate value. Displayed intermediate calculation values are presented to explain the calculation and are representative, but the final rate value reflects the correct rounding and final estimate.

2 To obtain OEWS data, follow BLS’s directions in its Frequently Asked Questions: “E. How to get OEWS data. 4. What are the different ways to obtain OEWS estimates from this website?” at https://www.bls.gov/oes/oes_ques.htm. The average wage rate is calculated as the employment-weighted average of hourly mean wages for the occupation.

3 The benefit multiplier comes from BLS Employer Costs for Employee Compensation accessed by menu at http://data.bls.gov/cgi-bin/srgate or directly at http://download.bls.gov/pub/time.series/cm/cm.data.0.Current. Insert the data series CMU2030000405000D and CMU2030000405000P, Private Industry Total benefits for Construction, extraction, farming, fishing, and forestry occupations, which is divided by 100 to convert to a decimal value. MSHA uses the latest 4-quarter moving average to determine what percent of total loaded wages are benefits. MSHA computes the benefit multiplier with a number of detailed calculations, but it may be approximated with the formula 1 + (benefit percentage / (1-benefit percentage)).

4 Wage inflation is the change in Series ID: CIS2020000405000I; Seasonally adjusted; Series Title: Wages and salaries for Private industry workers in Construction, extraction, farming, fishing, and forestry occupations, Index. (https://data.bls.gov/cgi-bin/srgate ; Inflation Multiplier = (Current Quarter Cost Index Value / OEWS Wage Base Quarter Index Value).

5 MSHA uses an overhead rate of 1 percent. The mining environment generally involves very little overhead, especially costs associated with workers engaged in administrative or clerical tasks.

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