The Evolution of Imminent Danger Orders – [Webinar Recording]

On October 26, 2017, Nick Scala of Conn Maciel Carey’s national MSHA Practice, presented a webinar regarding The Evolution of Imminent Danger Orders.

Imminent Danger Snip

The last several years, MSHA has issued 107(A) Imminent Danger orders with increased frequency. On the surface, these orders seem self-explanatory, yet the agency has been moving beyond the common assumption that these orders can only be issued when death or serious injury is imminent.. For example, some inspectors are issuing Imminent Danger orders under circumstances operators consider much less severe, and the Federal Mine Safety and Health Review Commission has been upholding them.

This webinar discussed how MSHA’s application and enforcement of imminent danger orders have evolved at the close of Assistant Secretary Joe Main’s tenure, including how and why Commission decisions have bolstered this trend.

During this webinar, participants learned about:

  • How Imminent Danger order are defined;

  • MSHA support of the use of 107(A) orders by inspectors; and

  • Federal Mine Safety and Health Review Commission and Federal Court decisions shaping the 107(A) landscape.

Here is a link to a recording of the webinar with slides and audio. This was the ninth webinar event in the 2017 Conn Maciel Carey MSHA Webinar Series. Plan to join us for the remaining webinar in the 2017 series, send an email to to be registered for the remaining MSHA webinars.


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