Notes on Global Tailings Standard Draft for Public Consultation
Nov 20th, 2019
In follow-up to Aidan Davy’s (ICMM) keynote session at TMW2019, here are our Notes on Global Tailings Standard Draft for Public Consultation. To this date the three co-conveners (UNEP, ICMM and PRI) reportedly did not endorse the draft.
Positive Notes on Global Tailings Standard Draft for Public Consultation
We found the current draft to be an overall well written document. It encompasses important points on:
not seen in other “standards”. In the particular aspect of conflict of interest we salute the ideas of incentivizing whistlerblowers and risk mitigation. However we think the draft should also tackle the remuneration aspects we discussed back in 2013 in a paper entitled Can we stop misrepresenting reality to the public? (Oboni, F., Oboni, C., Zabolotniuk, S., Can We Stop Misrepresenting Reality to the Public?, CIM 2013, Toronto)
Need for enhancements in the glossary
Like we have noted lately, again and again, when reviewing papers by various authors and the Church of England initiative the glossary and language are extremely important to avoid transforming research efforts into fake news.
Our Notes on Global Tailings Standard Draft for Public Consultation include the following.
- Need to define safe and secure.
- The text misuses the word risk, i.e. as a synonym of likelihood or probability.
- The draft promotes risk reduction and consequences minimization. This is improper language as risk is the combination of probability and consequences. It seems like risk is a synonym of probability, which is wrong and highly misleading.
- In Requirement 1.3 need to define the adjective “credible”. Too many biased decisions occur because of lack of clarity in this aspect
- Requirement 7.4 says the OMS should follow best practices… where can we see these best practices? Are the best practices the ones many are using today? We would call those common practice. And are we happy with the results of those common practices? We are certainly not!
- Annex 1, Glossary: need to define risk, safety, likelihood as well as probability, FoS, etc.
- The draft uses terms like likelihood, probability, catastrophic loss without defining them.
- It even asks for negligible likelihood of failure, without any explanation. How can one get to negligible likelihood if one uses FoS as a proxy? Explanations are important to avoid “creative” numbers. There is an ample basis of knowledge stating this can be fallacious if important KPIs are missing! And what is negligible? The same as a nuclear reactor? Or the same as a hydro dam?
- There are demands to reduce risk to the fullest extent possible. No definition of possible and risk is oftentimes improperly used, resulting in misleading confusions.
- The draft invokes best management practices and to apply rigorous technical controls. However, definitions are missing leaving ample room to interpretation and word plays, which have shown to be nefarious.
- Requirement 6.2 uses the Factor of Safety (FoS) again! The FoS is not a proxy variable for what is asked. Too much room for interpretation and misleading information arise from that.
- Same remark in Requirement 6.3.
- The 3 years review frequency should be justified. Why three years?
- Requirement 9.1 potential credible failure. The term “credible” has again to be defined. Following hazardous industry consensus, credible is anything down to one in a million. Is that what the draft standards requires?
- Requirement 11.1 risk assessment using best practice. Here again, what is best practices? The notoriously poorly applied FMEA with their baggage of arbitrary matrices?
Need for enhancements in the formulation
The draft defines what an inactive vs. closed and active dam is, which is great. However, we think it does not give enough emphasis to the differences, especially when it gets to mitigative decision making.
From Annex 2, Consequence Classification we read that like in common practice the Consequence Classification is assigned based in the most severe consequence among the pre-defined loss categories. This is a blatant mistake because a dam that would have a mix of non extreme consequences would be disregarded, because the sum of the consequences dimensions is disregarded “by rule”.
Furthermore, from Table 1 Extreme classification we see that “by rule” the system does not allow any distinction once the “extreme” rating is attained. This sums up to a designed lack of granularity which precludes rational prioritization of dams inventories. Like “unfortunately usual”, decision makers will find themselves afflicted by a “overwhelming syndrome” with many of their dams “in the red” and not enough granularity to prioritize them. This is a similar situation to the “200 yellow syndrome” we have explained so many times to our clients using common practice risk assessments!
In Table 1 it also seems very odd to see in the category Very high 10 to 100 casualties, paired with 50 households lost and non recoverable (50 houses with 2 people (min!) makes already 100, certainly not 10… and one has to assume fragile failure and night time…). Also 200 households disrupted would likely generate more than 100 casualties considering that 1m deep tailings even at relatively low velocity kills a person.
Table 2 is incomplete as it does not state which FoS (Factor of Safety) or probability of failure for seismic events. We note that many dams have failed because of minor events as there are highly non-linear relationships under play, as we have discussed in our book.
Annex 3 seems oversimplified given that tailings are the result of production and we think it would be worth to at least show the interaction.
Closing Notes on Global Tailings Standard Draft for Public Consultation
Due to all the Notes on Global Tailings Standard Draft for Public Consultation, at Riskope we think the present draft will not change the status quo in any significant manner and even be, for some aspects, counterproductive.
It will be counterproductive because it will not offer decision makers ways to prioritize their mitigative efforts . It will actually put them in a “all red” situation which will actually incentivise plays of words and escamotages. After all “zero tolerance” is not what nuclear or hydro-industry strive for. Aviation neither. Asking for that is again a form of “lying to the public” that will boomerang on the industry.
This will also result in mis-triages. We can see well designed and operated tailings dams, with a probability of failure comparable to large hydro-dams, that this code would flag as “bad apples”. They would end-up together with many other that actually are “bad apples”, which is obviously wrong. Confusion will result and public will once again lose confidence with nefarious repercussions on Social License to Operate (SLO). Money going into “false bad apples” will be obviously misplaced! Some serious house cleaning and rethinking of some formulations are necessary.
Tagged with: Global Tailings Standard, risks and tailings stewardship, Tailings Management Risks
Category: Consequences, Hazard, Mitigations, Probabilities, Risk analysis, Risk management, Tolerance/Acceptability