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Force majeure can be declared by a company to deny contractual terms when an unforeseen event beyond the control of the company occurs.
Massey investor relations director Katharine Kenny told Dow Jones the unavailability of rail cars meant Massey was unable to meet some contracts with buyers.
Massey would not reveal which mines or how many tons of coal were subject to force majeure.
Rail shortcomings has been an ongoing problem for Massey, the company having to curtail shipments during January this year due to flooding of the Ohio River system and railroad car shortages.