Tailings Dams Review Boards and Inspection Reports
Apr 22nd, 2020
Tailings dams review boards and inspection Reports exist because of a voluntary effort by the mining industry to improve and mitigate dams “issues”. In addition, mining companies are under pressure to be more transparent on their “issues”. We discuss below the term “issue”.
UNEP 2017 report and more recently Church of England initiative and ICMM “global code” are all expressions of this growing pressure.
Thus, mining companies are requesting the publication of Tailings dams review boards and inspection Reports. Publication opens the door to immediate scrutiny and thus to an increase in all actors’ liabilities. The main actors are the mining companies, the review board members and the inspectors. That increase of liability, especially due to frivolous challenges, is the major difference between publishing and not publishing those reports. Indeed, in case of serious accidents reports and studies are generally the object of subpoena. As a result their authors get involved in the proceedings anyways.
Liabilities in tailings dams review boards and inspection reports
Review Boards have to give expert advice on dams and their “issues”. We have seen review boards getting involved in modifying parameters of geotechnical analyses or inundation studies. At Riskope we believe that involvement is not within the scope of a review board and certainly exposes the members to undue liabilities.
Inspection teams have an “audit style” approach and mostly deliver factual observations. However, we have seen inspection reports qualifying the “safety” of a dam, or even “risks”, as a result of their observations. That is, again, a detrimental behavior from an inspector’s liability point of view.
Inaction from the mining company can obviously result in potential liabilities. In our practice we note that although some advice and observations may not be what the owners would like to hear, in the great majority of cases, the advice and observations are followed by actions. Only very seldom we have seen correspondences addressing negligent inaction by the owner.
Now it is time to discuss why we selected the term “issue”. We did it to remain generic. Indeed, it is often unclear if tailings dams review boards and inspection reports end-up addressing dams risks or hazards and oftentimes, as we just noted, they go out of scope, unduly exposing themselves.
Furthermore, we have seen many of those reports which, for example:
A road-map to a better working environment
At Riskope we believe that one way to avoid undesirable exposures lies in adopting a clear technical glossary and adopting a workflow where each step has very clear scope.
The figure below shows where site inspection and audit style review should sit in the flow. At Riskope we think the ultimate goal of site inspections and audit style reviews is not to make declarations on the “issues”. It is instead to provide a set of “concrete” Key Performance Indicators (KPIs) enabling transparent, quantitative risk analysis.
The role of the review board should be to ask for specific enhancements of data and inspection results with the ultimate goal of reducing uncertainties on the KPIs. The review board should then oversee the mitigative roadmap preparation ensuring the overall flow remains unbiased and conflict of interest-free.
How are KPIs used in the workflow?
Quantitative risk assessment methodologies (ORE2_Tailings) use the KPIs to avoid numerous pitfalls of common practice approaches. These KPIs cover the life of the dam system from inception and converge on the four “families” of causality:
- investigation,
- design,
- construction and finally
- operations and maintenance (including monitoring).
At Riskope we consider causality analysis a fundamental enhancement in the process. Indeed it avoids a number of biases and arbitrary choices.
As it can be seen the in the figure, probability of failure resulting from the composition of the KPIs evolves all along the dam life while it maintains a certain level of uncertainties
Data allow to evaluate consequences. Finally the probability of failure and consequences of the failure allow to evaluate the risk of the structure.
Closing remarks
In a world where “secrecy” is not anymore possible or desirable, it is time to change old habits in the name of ethics and best professional practices. Protection against legal challenges to review board members and inspectors comes from:
- clearly stating the scope of their work and
- rigorously abiding to that scope,
- using clear glossary.
In a “beautiful world” it is time to see a unified approach to risk assessment, and road map to mitigation. One that uses quantifiable KPIs. One that transparently shows the risks of the structures to everyone, including the gains yielded by virtuous actions taken by the owners. The unified approach could then display the results in the dashboard of initiatives like Responsible Mining, for the benefit of everyone.
Contact us to see how a deployment of ORE2_Tailings on your dam portfolio would set you at the forefront of ethical, responsible and profitable and competitive mining.
Tagged with: dam safety KPI, Inspection Reports, liabilities, responsible mining, Tailings Dams, tailings dams review
Category: Consequences, Hazard, Optimum Risk Estimates, ORE2_Tailings, Probabilities, Risk analysis, Risk management
Congratulations.
Great report on Tailing Management and Closure.