Managing compliance is hard. When your high risk industry gets overlapping standards, it becomes even more complex to stay in continuous compliance.
Jean-Marc Léger from ERM recently pointed out, “Over the last twelve months, no less than three new benchmarks have been proposed to the international mining industry.” In September 2019, the World Gold Council presented its normative framework entitled ‘Responsible Gold Mining Principles’ to the gold mining industry. Before the end of the year, the IRMA standard or ‘Initiative for Responsible Mining Assurance’ identified itself as the ESG standard applicable to the entire industry. Finally, despite the obstacles caused by the pandemic, the International Council on Mining & Metals (ICMM), the United Nations Environment Programme (UNEP) and the Principles for Responsible Investment (PRI) published the ‘Global Industry Standard on Tailings Management’ on August 5, 2020.
Aside from the parallels that can be drawn with the catastrophic accidents at Brumadinho (2019), San Marco (2015), and, closer to home, Mount Polley (2014) with respect to tailings management, what can we make of the arrival of three new standards in such a short period of time? Equally importantly, how can we anticipate the reaction of these important economic players to the emergence of new voluntary standards?
Paperwork vs. Genuine Improvements
With any new set of requirements you inevitably receive a certain amount of paperwork. Of course the purpose of the regulation or standard is to improve your operations, but it is not always obvious how to modify your existing operations, systems, procedures and documentation to take into account these new standards. In addition to the standards mentioned above the mining industry is also working with the Cyanide Code and Towards Sustainable Mining.
Another (ex) ERM consultant, Scott Nadler, pointed out a similar challenge in the sustainability reporting space. The long and short of meeting all these standards is making sure that your underlying dates and systems are very, very clean. You need to be able to track and manage procedures and data without spending time searching through systems or databases. This is where it becomes so essential to do first things first.
Before engaging in complex sustainability or compliance efforts, take a step back and make sure you Know your Obligations. Take a hard look at ALL the requirements you have from all the organizations that can impact you. What are your External Obligations from regulators and industry bodies and what are the Internal Obligations that you have decided to adopt. Once you know this, you can then determine the data and information you need to ascertain your compliance. Our recent webinar on ISO 19600 laid out the steps in this process.
As with lean manufacturing, it is critical that you follow the 5S with your risk, quality, environmental, and health and safety information. Make sure your data and documents are:
- “Sorted into the appropriate places and categories”,
- “Set In order and easy to find”,
- “Shined and ready for use by your team members”,
- “Standardized so each document and data set can be easily interpreted by the right person” and,
- “Sustained so that your EHS and Quality data is always up-to-date”.
If you can do that, then new standards and reporting requirements should be a breeze.
Checklists prepared by Nimonik
Nimonik took the liberty of creating some user friendly checklists for these various mining standards, you can see them here:
- IRMA Standard (Critical Requirements)
- IRMA Standard (All Requirements)
- World Gold Council – Responsible Gold Mining Principles
- Global Industry Standard on Tailings Management
- TSM Safety and Health Protocol – Self Assessment Checklist
- TSM Energy and Greenhouse Gas Emissions Management Protocol – Self-Assessment Checklist
- TSM Crisis Management and Communications Planning Protocol – Self-Assessment Checklist
- TSM Water Stewardship Protocol – Self-Assessment Checklist
- TSM Tailings Management Protocol – Self-Assessment Checklist
- TSM Biodiversity Conservation Management Protocol – Self-Assessment Checklist
- TSM Indigenous and Community Relationships Protocol – Self-Assessment Checklist
- TSM Prevention of Child and Forced Labour Verification Protocol – Self-Assessment Checklist
- TSM Mine Closure Framework Checklist
- International Cyanide Management Institute – Cyanide Transportation Audit
- International Cyanide Management Institute – Cyanide Production Audit
- International Cyanide Management Institute – Mining Operations Audit
- International Cyanide Management Code – Implementation Guidance