To,
The Under Secretary to the Government of India,
Ministry of Labour and Employment,
Industrial Safety and Health-II Section,
Shram Shakti Bhawan, Rafi Marg, New Delhi-110001
Subject: Objections or suggestions regarding Mines Vocational Training Rules, 2019
D/S,
| Clause in the draft rule (for ready reference) |  |
| Suggestion/ objection | In Clause 1, & to clarify things, it should be like “These rules shall apply to all persons employed or to be employed in a mine including transfer from one mine to other mine”, and also there is no need to exempt anybody from training however training hours/ day may vary for different category of persons, why? because every mine, whether underground or opencast is somewhat different in terms of everything like geological parameters, mining conditions, operation, machine, mining culture etc. Sir, There is strong need to train the management persons also because as I said, each and every mines is operational based on its own feasibility report, environment report, permission from different agencies to operate a mine and have different Mining operation phase, different mine conditions. Suppose, when a manager is being deputed to manage any unknown mine then he doesn’t know his new assigned mine’s reports/ parameters like mentioned above. He is just being pushed into the production line somehow without knowing the entire reports/ things & in result have to pretend that he knows everything, maybe one’s experience matters but not for specific reports and data, someone has to know for better mine management. Mine manager or any management person or supervisor is not a magical man that he would know each and everything without reading the reports of that specific mine so if training schedule for mine manager will be there then management will be bound to follow the rule and ultimately a better quality of mine manager be there for managing a mine. I have seen many Junior level or mid-level management people specifically from mining side (including me) in production line that they doesn’t know anything about different permission letters from different agencies and mentioned conditions require to operate that mine and this is the situation then how someone better manage the mine. If people are not allowed to read the permission letter for depillaring operation, how that people will justify his statutory duty. |
| Clause in the draft rule (for ready reference) |  |
| Suggestion/ objection | Training scheme or any changes from time to time should be prepared & uploaded to its own website by Chief Inspector and Regional inspector of mines, why? Because, office of DGMS keeps records of each and every mines data and in that way it is better to draw a scheme based on that. Also, it will be uniform for all the mines. |
| Clause in the draft rule (for ready reference) |  |
| Suggestion/ objection | DGMS should open its own training centre for maintain the standard and also for those small mine having no option to combine with other owner’s training centre or don’t want to invest in training centre etc. |
| Suggestion/ objection | Basic First Aid training to each and every individual should be added so that each person that are employed or to be employed in a mine will get proper training about CPR, finger cut, burn, electric shock treatment, basic one. |
To view this draft Rule click this link
"DRAFT MINES VOCATIONAL TRAINING RULES"