Global Industry Standard on Tailings Management
Aug 19th, 2020
On Wednesday August 5th ICMM, UNEP and PRI launched the Global Industry Standard on Tailings Management. In this blogpost we offer some comments on the Global Industry Standard on Tailings Management.
We salute this initiative that we have supported already at draft level. Indeed, at that time we wrote our comments and notes via email and online portal. That was following the public Consultation invitation which gathered a total of 629 responses.
The consultation report
We found the Global Tailings Review Consultation on the Draft Global Tailings Standard report highly interesting. It reveals a somewhat mixed feelings of the respondents. Of course, this is normal with such an endeavor. In addition, the consultation report explains point by point how the edits of the draft to cope with the comments of the respondents.
Mixed feelings about the Global Industry Standard on Tailings Management
The mixed feelings are evident when considering that, for example, 58 respondents indicated that the Standard does not address all aspects of tailings facility management adequately. They cited concerns about clarity and definitions, in particular for risk and Consequence Classification) but also other aspects. Among these:
One needs to compare those 58 negatives with 47 positive replies, a confirmation of the mixed feeling we cited above.
We will not enter in the discussion of the text modifications of the Global Standard draft as we are aiming in a different direction.
Future Application Manual and differentiation between new and existing tailings facilities
Also, we understand that Prof. N. Morgenstern is preparing a guide or manual on how to apply the standard. This comes as a reaction to concerns about the vagueness of the standard. Indeed, respondents stated the standard requires detailing ‘how’ to do things, rather than what is required.
We also note that the Standard now differentiates between new and existing facilities, acknowledging that implementation for existing facilities can be impractical or impossible. In particular for existing facilities the following points are now present:
- Operators should periodically review TSFs to minimise risk and improve environmental outcomes. This also applies to expansion projects.
- If an upgrade of a TSF is not viable or feasible, measures to reduce both the probability and the consequences aiming at reducing risk to as low as reasonably practicable (ALARP) level should be implemented. Decisions will be risk-informed and operators should carry them out as soon as reasonably practicable.
- On an annual basis the operator will publish a summary of risk assessment findings,
Our additional comments on the Global Industry Standard on Tailings Management
Before we go any further let’s take a minute to analyze the frequency of a selection of key words in the Standard. The word cloud below graphically expresses the relative importance of the selected keywords in the text.
Anyone can see that the word “Risk” is at the forefront, more frequent than Engineer of Records (EoR) or Independent Talings Review Board (ITRB). If we group up the words, we can define the following four classes:
- Risk 82
- Knowledge and monitoring 109
- Key professional and reviews 110
- Failure and consequences 141
We find it very odd that there is no risk specialist in the list of key professionals. Yet, it has been proven and also other publications and Terry Eldridge “film” that risk assessment and risk-informed decision-making support should not be improvised.
Thus, we understand concerns by consultation respondents when they state, for example that the Standard:
- is not promoting the highest possible standards and leaves too much room for interpretation.
- Does not define how risk is calculated and in particular the interaction of risk and risk calculation with affected communities.
- Is not emphasizing enough the importance of understanding risk and the proper calculation of risk and finally
- will lead to a loss of focus on the highest risk TSFs in a portfolio, undermining the Standard’s ability to reduce risk.
When we read a recent piece from South Africa stating that miners need more engineers to meet the Global Industry Standard on Tailings Management requirements and timing we immediately made the following notes:
- The first thing mining companies have to do is to evaluate and prioritize their portfolios of TSFs.
- That should be achieved by hiring competent risk assessors, not necessarily scores of new engineers which, by the way are rather scarce, if skilled.
- The COVID situation with its travel restriction, complex geo-political situations should incite to seek new methodologies relying on modern monitoring techniques and data acquisition and finally allowing to perform preliminary quantitative risk assessments “quasi” remotely.
- With the yearly summary requirement added to the need to assess all existing dams, a methodology allowing swift analyses of entire portfolios, updatable and accommodating monitoring data as they become available is paramount.
At Riskope we are perfectly armed to support these endeavors. Call us.
Tagged with: Global industry standard, ICMM, risk, Tailings Management, TSF, UNEP
Category: Consequences, Hazard, Mitigations, Optimum Risk Estimates, Probabilities, Risk analysis, Risk management