The spread of COVID-19 around the country has disrupted our normal routines including the way our official work responsibilities are completed. As we prepare for the annual SMARA compliance requirements, it can be expected that certain compliance activities may need to be modified, or at a minimum planned for, to remain in line with public health recommendations and State orders.
To date, the Department of Conservation (DOC) has not made changes to the required due dates of Mining Operation Annual Reports (Form MRRC-2, due July 1) or the completion of lead agency annual site inspections during the pandemic. Although we all hope the COVID-19 pandemic ends quickly, it should be expected that your next inspection may be completed differently than it has in previous years.
To avoid situations that may disrupt operations or the inspection, below are six suggestions to prepare for your annual SMARA inspection:
1. Contact the appropriate lead agency in advance of the inspection date that was identified on your previous Annual Report to discuss how the inspection will be completed. Identify areas of concern, who will attend, transportation, safety procedures and the use of Personal Protective Equipment (PPE) including Health Department recommended face coverings/hand sanitation, etc.
2. Try to minimize the number of inspection participants; this includes participants from the operator’s staff as well as participants that are conducting the inspection – operators should encourage lead agencies to bring only those who are essential for reviewing SMARA compliance.
3. Provide a map showing the inspection route and location of planned stops.
4. Conduct a health and safety meeting prior to the inspection. Cover the procedures that will be followed by all attendees.
5. If separate vehicles will be utilized by attendees, the opportunity to discuss the project between stops will not be available. Utilize the stops to provide project details and ask questions.
6. Request an inspection debrief at the conclusion of the field visit. Select a location where social distancing recommendations can be practiced by all attendees.
Site inspections will not go away. Communication, planning and preparation will help complete this process smoothly and efficiently.