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Accepted Manuscript

Title: Future strategies for tackling mercury pollution in the


artisanal gold mining sector: Making the Minamata
Convention work
Author: Martin Clifford
PII:
DOI:
Reference:

S0016-3287(14)00079-2
http://dx.doi.org/doi:10.1016/j.futures.2014.05.001
JFTR 1930

To appear in:
Received date:
Revised date:
Accepted date:

10-8-2013
28-4-2014
3-5-2014

Please cite this article as: Dr.M. Clifford, Future strategies for tackling mercury pollution
in the artisanal gold mining sector: Making the Minamata Convention work, Futures
(2014), http://dx.doi.org/10.1016/j.futures.2014.05.001
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Future strategies for tackling mercury pollution in the artisanal gold mining sector:
Making the Minamata Convention work

A global treaty on tackling emissions of mercury the Minamata Convention will be


ratified later this year. The Convention, which incorporates efforts to stem emissions of
mercury accountable to artisanal gold mining, is likely to result in a new wave of mercury
pollution abatement projects in the sector
The paper provides a discussion of previous initiatives, highlighting their ineffectiveness in

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achieving significant change in use and emissions of mercury from artisanal mining

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operations

Given the above, the article goes on to suggest more progressive ways of understanding and
approaching mercury pollution abatement efforts in the small-scale mining sector. It is

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suggested that these should be based around sociological, humanistic conceptualisation of

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this persistent issue.


Abstract

The recently ratified Minamata Convention is an international treaty aimed at reducing the trade,
use and emissions of mercury. Specific attention is paid in the document to mercury contamination
that has accompanied the expansion of artisanal and small-scale gold mining (ASGM) in many

developing countries. In addressing these articles, the Convention looks to initiate new wave of
policymaking and extension projects in coming years, as signatory countries work to stem emissions

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from the ASGM sector. If these efforts are to be effective, however, designers must first overcome the
barriers and challenges posed by a legacy of failed efforts aimed at educating small-scale
prospectors about the environmental and health implications of extensive mercury use and cleaner
technologies. In order to do so, a reconceptualisation in approach toward mercury pollution in the
sector will be necessary. There are some positive signs that academics and policymakers alike are
steadily reaching a new consensus on how to tackle the issue more effectively. A strong case can be
made for a humanistic understanding of this persistent issue, and it is critical that such new
perspectives are carried forward, not only under the Minamata Convention, but more generally.
Introduction

On 19 January 2013, the fifth session of the Intergovernmental Negotiating Committee to Prepare a
Global Legally Binding Instrument on Mercury (ICN5) concluded in Geneva (IISD 2013). Following a
week of discussions and all-night negotiations on the final day, a new global treaty on the trade, use
and emission of mercury was produced: The Minamata Convention on Mercury (Kinver 2013).
Mercury is a toxic environmental contaminant and has its management has been a major global
environmental concern over the last half century. Within the Convention, specific attention is given to
the intimate association of artisanal and small-scale gold mining (ASGM) with the consumption and

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emissions of the mercury, which is having undeniable impacts globally. Its ratification at the end of
2013 is likely to spawn a new wave of interventions aimed at confronting the widespread
contamination that has accompanied a rapid expansion of ASGM in many developing countries.
The largest initiative in a long line of exercises attempting to abate mercury pollution from ASGM, the
Global Mercury Project (GMP), concluded in 2008. A spate of publications and critical reflections over
its mixed results has since emerged. Significantly, however, it has brought international efforts aimed

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at abating mercury contamination to a standstill. This hiatus, and the drafting of the Convention,
presents a suitable stage at which to take stock of how effective approaches towards tackling mercury
pollution in ASGM have been. It is also an opportune time to consider what form future interventions

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might take. An argument is made here for a reorientated approach toward tackling the problem, a

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view shaped heavily by the literature as well as the authors own experience.
The Minamata Convention and the artisanal gold mining sector

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The Convention takes its name from the Japanese town which, along with Niigata, was the site of the
first recorded mass poisoning caused by mercury. This took place from the mid-1950s until the 1960s
(Counter & Buchanan 2004, Ishikawa & Ikegaki 1980, UNEP 2013).1 The events here stimulated over

half a century of research into the dynamics and impacts of anthropogenic mercury use and emissions.
A mounting body of incidents and research has detailed the damage caused by mercury compounds
throughout the world (see Hilson & Clifford 2010, WHO 2003, WHO1991). As painfully illustrated by

Minamata, the element has proven to be a severe environmental contaminant capable of causing
physiological damage even in small quantities (WHO 2003). Accordingly, there have been

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considerable efforts made to control uses of mercury over the last 50 years. The fact that emissions
may be widely dispersed and mercurys long environmental lifetime have been central arguments in
advocating international action and agreements.
The Minamata Convention is the latest example of attempts of this nature. It admirably aims to
ensure that the city has a more favourable association with mercury. The next step following the
herculean task of penning the document in Geneva came in October 2013, when international
representatives returned to Minamata itself to sign and ratify the treaty. The intent of the Convention
is to attain a global, legally binding treaty translated into national laws... [which] would catalyze and
drive concerted international action on mercury (UNEP 2013: 5). The treaty contains 35 articles
relating to various policy and technical issues on reducing use and emissions of mercury. Prominent
among these is the international regulation of the informal sector of artisanal and small-scale gold
mining (IISD 2013).

1 In excess of 53,000 individuals were affected and at least 1700 people died (UNEP 2013) through the consumption of
mercury-contaminated fish and shellfish (Ishikawa & Ikegawi 1980, Japanese Ministry of the Environment 2013) which it was
later revealed had been caused by the release of industrial wastewater rich in the metal from a nearby chemical plant. The
symptoms of those affected (cognitive, neurological and motorological disorders of varied forms and levels of severity),
characteristic of mercury exposure in general, are now also generically known after the city: Minamata disease.

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The ASGM sector is undoubtedly one of largest areas of concern with respect to global mercury use
and emissions. The updated UNEP Mercury Assessment gives annual estimates of 727 tonnes of
mercury emitted to air from ASGM operations worldwide, and 800 tonnes to land and water (UNEP
2013). The sector accounts for 35% of anthropogenic emissions and is the largest global intentional
use source of the metal. The 2010 figure is twice that given in 2005. This is partly due to the expansion
of the sector and partly to access to better-quality information, especially in the case of activities in
West Africa (UNEP 2013). The Blacksmith Institute, which consistently ranks mercury pollution from

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ASGM in its Top 10 Toxic Pollution Problems, estimates2 that over 4.2 million are at risk of exposure
(Blacksmith Institute 2013). The impacts of ASGM mercury emissions have been catalogued in an
extensive body of studies (e.g. see reviews by Eisler 2003, Wolfe et al. 1998, or Berzas Nervado et al.

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2010). The growing link between the ASGM sector and mercury was highlighted by a World Health

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Organisation representative attending the ICN5 meeting, who noted that:

A number of activities had been under way for some time to address the health and
environmental impacts of mercury... and [that] the greatest gains, by a large margin, would be

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made by addressing emissions and artisanal and small-scale gold mining. [UNEP 2013: 7]
Each signatory country to the Minamata Convention that has more than insignificant ASGM activity3

is required to submit a national action plan no later than three years after ratification and must
review progress every three years following this. Action plans incorporate (UNEP 2013):
Moves to be taken towards eliminating particularly polluting mining practices;

Formalising and regulating ASM sectors;

Baseline estimates of mercury use and practices;

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Strategies for promoting reduction in and managing emissions and trade;

Public health strategy which includes gathering of health information, awareness-raising; and
Strategies for providing information to artisanal and small-scale gold miners.

How large an impact the Minimata Convention may play in relation to mercury use in ASGM in terms
of policymaking and capacity-building in target countries or on the ground intervention and
assistance work in artisanal mining communities around the globe is yet unclear (McClanahan 2013).
Certainly, even a cursory examination of the ICN proceedings gives cause for some concern. For
instance, there was wrangling over definitions and, crucially, funding sources. The three years that
countries housing significant AGSM activity have been given to draft a national action plan, let alone
implement it, also mean that some of the potential impacts of the project will not be apparent for
some years.

2
3

This is an extremely conservative guess given it only bases this on 200 sites worldwide: there are many more
The conference was attended by every country with sizeable ASM populations, with the notable exception of Ghana

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Moreover, the types of policymaking and action stipulated via the Convention have already been
attempted in the vast majority of signatory countries that have sizeable ASGM activity. The idea
behind creating an internationally agreed upon, legally-binding framework for tackling mercury with
artisanal mining as an explicit target is new, however. The number of signatory nations and influential
bodies behind the Convention also suggest that there is significant scope for action. At the very least, it
is likely to catalyse a new wave of efforts aimed at stemming mercury pollution associated with the
the issues, it is instructive to examine the success of previous approaches.

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The legacy of tackling Hg pollution in ASM

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ASGM. In order to suggest what might constitute the most appropriate future strategies for tackling

Despite the claim that it is time to act upon mercury (UNEP 2013), the reality is that there is been a

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long history of interventions at various levels that have attempted to stem its use in the ASGM sector.
A multitude of multilateral and bilateral donors, NGOs and researchers have, in fact, spent millions of
dollars on projects in various countries attempting to minimise emissions and introduce safer practice

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over the past 25 years. What remains clear, however, is that despite such significant levels of activity,
mercury use remains prevalent in the sector.

Exactly why the numerous initiatives conducted over the years have yielded so little impact has been
the source of significant debate for over a decade (see Clifford 2010, Hilson et al. 2007, Hilson 2002,
Spiegel et al. 2006). For example, efforts made to restrict supply and trade have been an important

focus of policymaking, and look to remain so under the Minamata Convention. Veiga et al. (2006:
445) describe how policymakers have adopt[ed] a similar approach to that most successfully used to

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combat drug trafficking:

Reduce consumption with awareness campaigns, and simultaneously hinder traffic and easy
access. Better control of Hg use... should also be accompanied by an increase in the price of Hg.
[Italics in original]

An underlying assumption has often been that restricted supply and increased prices of mercury will
pressure miners into using alternative methods. But despite penned legislation and initiatives, in the
foreseeable future, it is hard to envisage any other scenario than mercury remaining a plentiful
commodity for artisanal gold miners: alternative sources and a healthy black market will ensure a
continued availability despite any restrictions (UNEP 2006).4 Supplying a trade involving 15 million
people and accounting for at least 20% of annual world gold supplies is big business by anyones
standards. Furthermore, given historically, the high prices for gold, any hike in price is going to be
inconvenient rather than prohibitive to buyers and suppliers or make their operations uneconomical.
At the national level, in nearly all instances, legislation already exists in countries with significant
ASGM activity that prohibits or outlines strict rules over the use of mercury in artisanal mining. Yet,
4

Something noted by delegates at the ICN5 conference (UNEP 2013: 21)

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mercury is freely available and is extensively, often liberally, used by small-scale prospectors: clear
signs that such policies cannot be enforced. Attempts to extinguish supply routes of mercury to ASGM
sites is, then, likely to remain largely unenforceable for the foreseeable future.
Things have been similarly challenging in reducing consumption Reducing artisanal miners
consumption of mercury through educational and technical projects at the end of a significant amount
of global mercury tradehas been similarly challenging. As indicated above, various attempts have been

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made, with the backing of Western countries, NGOs, and international institutions that are now
promising the latest wave of intervention as part of the Minamata Convention, to encourage miners to
adopt environmentally-friendlier practices. These approaches have, however, been criticised as

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sporadic, technically-focused, and driven from the top down with little collaboration with target
communities (Hilson et al. 2007). A legacy of ineffective strategies has meant that the vast majority of

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artisanal miners worldwide remain largely unaware of, or incorrectly informed about, the potential
dangers of mercury or of ways in which to go about reducing their exposure and emissions. Moreover,
there is a lack of information relating to general dynamics as well as the use and practices of mercury

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in the sector, and its human and environmental health impacts. This is extremely limiting in
understanding ASGM communities and implementing effective policies and interventions (Hilson &

Maponga 2004).

The emphasis in the Minamata Conventions action plans towards gathering data on mercury use and
practices is, therefore, undeniably a welcome notion but will require providing significant assistance

to national authorities given their noted limited capacity. The question posed by Hilson et al. (2007:
276) as to why, given the importance of tackling the problem at the source, does there continue to be

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an acute shortage of funding for initiatives aimed at educating and training miners about mercurys
toxicity? still remains valid. This oversight may be amended viaThis lack of intervention may be
somewhat addressed through stipulations for educational strategies underlined by the Convention,
which may result in a new phase of mercury pollution abatement projects. It is critical, however, that
the types of failed approaches described above are not repeated in the next phase of action and must,
as argued in the following section, be built upon a new progressive momentum that appears to be
building in ASGM-mercury research.

Remoulding approaches to tackle mercury use in ASM


Previous interventions have been ineffective in achieving tangible, sustained behavioural change in
artisanal miners use of mercury and introducing environmentally-friendlier practice. Approaches are
clearly in need of a reappraisal. Logically, given the criticisms outlined above, it is time to heed the
advice of those who have called for interventions that are ongoing, emphasise a holistic balance of
education and technical assistance, and reach as wide a demographic of ASGM communities as
possible. It is also essential that such projects are conducted with an understanding, collaborative,
sociologically-based outlookcontain an explicit consideration of the sociological dimensions of
mercury use and pollution in ASM. The case for a more humanistic approach towards tackling

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mercury pollution in ASMthe issue, already indirectly advocated by many, needs to be explicitly
accentuated within programmes and policymaking going forward. Two central tenets of this approach
is that the use of mercury by artisanal operators should be seen as: firstly, a rational decision that
nearly all would make in the same circumstances, given the lack of alternatives, even with awareness
of the risks (which does not apply to most miners); and secondly, a challenge, given that engineering a
change in behaviour will be an extremely difficult task that will require extended, enabling policies to

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be overhauled.
This is something that has been noted before. Hilson et al. (2007: 285), for example, argue that the
most effective mediums for disseminating information about retorts, mercury and the environment

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are the laborious, participatory training exercises that the government and donor agencies have
avoided sponsoring (also see Hilson 2006). Similarly, the importance of considering the cultural,

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social, economic and organizational context of miners (Hentschel et al. 2002: 47) in the development
of schemes and the importance of collaboration with communities (e.g. Hinton et al. 2003) were
highlighted around a decade ago. But agencies and even academics have been slow to incorporate and

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embrace such ideals into their work. A critical discussion of the nuanced ramifications of not instilling
baseline awareness and conducting continuous education have been relatively absent in the ASGM
literature thus far. The growing body of academic critique relating to the inadequacies of previous

mercury pollution abatement approaches should underpin future strategies.


Field-based evidence supports the assertion that most mining communities are starting from a non-

existent or extremely low level of understanding towards the dangers of mercury and
environmentally- friendlier practice. Clearly, it is unrealistic to expect someone who is unaware or

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unconvinced of the rationale being calls for changes in behaviour to begin to do so. Even when a group
is informed about the risks associated with practice, it is very challenging to influence behavioural
change.

Additionally, although mercury is fatal in cases of large exposures (WHO 2003), under normal
circumstances artisanal miners are exposed to frequent, lower dosages with less obvious symptoms
(Veiga and Baker 2004) which are often likely to be misdiagnosed (being similar to tuberculosis and
malaria, for instance: Hilson & Pardie 2006, Veiga and Baker 2004, WHO 2003) or may take many
years to present serious health symptoms.

Metaphorical examples can be drawn comparable to the situation artisanal miners face with mercury
with, for instance, being heavily reliant upon a car. This pollutes the environment, there are risks to
people and others involved in using one, and we would probably save money if we used it less or
changed to an alternative form of transport. But the immediate detrimental effects of using a car, such
as environmental degradation, are not immediately evident tangible to us. and Moreover, we gauge
the hazard risks, like the chances of an accident, acceptable enough to continue driving. Moreover, it
is convenient, often quicker than other methods and is what people are familiar with. People may not
know how to ride a bike or the provision of other transport may be poor.

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Similar comparisons could be drawn with behaviours such as drinking or smoking (omitting the
addictive elements of these). In fact, mercury use perhaps should be conceptualised akin to negative
health behaviour. Using this mindset, educators can then go on to think about the levels of significant
advocacy, available support and information, continual revision of approaches and enabling
legislation that has been enacted over decades in Western societies to achieve even a marginal change
in car usage or levels of smoking and drinking. Similar approaches are needed for conceptualising and

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tackling mercury pollution in ASGM. Even if reducing mercury emissions from the sector may
ultimately rely upon technical end points, it must have solid sociological underpinnings.

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Promisingly, there are signs that recognition for the need of such a conceptual shift has permeated
academic debates and is also gradually building within donor efforts. For example, in Jnsson et al.s

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(2013: 65) recent reflections on why adoption of mercury retorts5 has been relatively minimal at a
study site in Tanzania, several observations are made in line with the ideas presented above:

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Continuous exposure to the negative effects of mercury and associated morbidities and
mortalities combined with regular encouragement to adopt mercury abating technologies is
necessary in order to trigger a behavioural change among miners... While mercury is hazardous,

its effect on peoples health and the environment is not immediate. The current method where
gold is extracted through mercury-usage is easy to learn and practice. A livelihood in ASGM
involves several adversities and new technological changes, how- ever small they may be, can

appear insurmountable. This means that the importance of on-going awareness-raising through
training sessions, demonstrations, and other support measures can never be overestimated in

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facilitating a change in miners behaviour.

There are also signs that donors may be moving away from the technologically-focused interventions
made under previous exercises towards softer approaches. For instance, the Global Mercury Projects
Manual for Training Artisanal and Small-Scale Gold Miners, stresses that:
It is important to establish the link between learning information and changing behaviours...
Behaviour change to the point of habit development is very difficult, even if we know exactly why
it is a good idea. Understanding and being supportive over time of efforts to change, and
understanding failed attempts results in better sustainable change than in any way suggesting
that people are bad or hopeless for not changing. [Veiga et al. 2006: 1-2]
To find such sentiments in previous multilateral project documents before this point would be
incredibly difficult. The beginnings of a more progressive stance within projects such as the GMP

A retort is a distillation chamber for mercury vapour. The mercury-gold amalgam, which is usually burnt in the open, is
covered in a sealed compartment and exposed to heat (usually a fire or blowtorch). Mercury vapour volatilising from the heated
amalgam is trapped inside the chamber, where it is then cooled. This returns the metal to its natural liquid state, where it can be
recovered. This substantially reduces miners exposure to highly toxic mercury vapour. Importantly, it also allows mercury to be
reused for capturing further gold.
5

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must be carried forward into, and underlie and inform policymaking in, future initiatives like the
Minimata Convention.
Technical assistance remains essential, however. Just as the impact of technical assistance is severely
limited without underpinning education, the reverse is also true. Rather, criticisms can be aimed at
the typical overall position of technical aid within approaches. This has often been conducted without
sufficient community involvement and rarely in conjunction with educational strategies that would

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appear to be a necessary precursor to their general acceptance. But the lack of mechanisms through
which to promote the adoption of appropriate technologies such as retorts dictates that in the

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overwhelming percentage of cases miners cannot rather than will not adopt them.

But again, improved understandings that have occurred through empirical research and the

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experiences of projects like the GMP in recent years are certainly encouraging signs. Experimentation
with, and dissemination of, different types of retorts and novel, culturally attuned educational
strategies embraced by the GMP (e.g. Veiga & Baker 2004, Veiga et al. 2006, Spiegel et al. 2006,

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Shandro et al. 2009) should be built upon. These types of moves away from inappropriate one size fits
all blanket strategies to tackling mercury pollution are an indication of the increasing recognition of
the diversity of dynamics within mining communities. Tangible possibilities for improving results and

policymaking exist, but these approaches are still in their relative infancy in terms of reporting and
implementation. They should be taken forward in future approaches that might emerge from the

Convention, however.

There is also a much larger potential role that gold buyers could play in advocating changes in mining

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practices. Evidence for this comes from the authors recent work in Ghana. Buyers more often than
not sponsor operations and hold influence over miners, supplying mercury free of charge in exchange
for sales of gold, for example. As a consequence, the economic argument, often suggested as one of
the strongest cases for promoting the mercury recycling offered by retorts, does not apply to miners
where this common arrangement exists. Although buyers have, quite rightly, been maligned for their
exploitative relationship with miners and identified as a central part of cycle that keeps operators in
poverty and unable to engage in cleaner practice (Hilson & Pardie 2006), it is also they who have to
pay for expensive mercury; have, therefore, the most to gain from conserving and recycling the metal;
generally have the funds to invest in mercury abatement technologies; and often hold a powerful
position in local organisation of artisanal mining. The many artisanal mining locations where more
organised, centralised processing occurs and amalgam is formed and burnt under the supervision of
buyers or sponsors could be ideal locations for introducing retorts.
The case for conducting bottom up, simplistic educational and technical activities in mining
communities is further strengthened when the seeming desire on the part of miners to embrace
alternatives is considered. Support for the types of suggestions put forward by Hilson et al. (2007:
280) that operators in Ghanaian artisanal mining camps certainly showed no obvious signs of
pretending not to be informed about the environmental and health-related impacts of

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amalgamation; on the contrary, the majority expressed interest in improving their knowledge about
the potential lethality of mercury was heavily reinforced by the authors own recent work in the
country. Miners consulted expressed concern when informed about the dangers of mercury,
enthusiastic about the process of retorting, and enjoyed open and collaborative interaction. Many, in
fact, independently called for further work to be conducted with them.
As Jnsson et al.s work (2013) work illustrates, nobody in development circles is under the illusion

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that selling the message of mercurys danger and alternative practice to miners is easy. But the simple
fact is that the vast percentage have been inadequately exposed to, involved in, or disenfranchised by
such initiatives. Yet, almost without exception in the authors recent experience, miners even those

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who had poor previous experiences with interventions welcomed and encouraged further education

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and involvement in technology demonstrations.

In summary, the logical starting point for future interventions must be doing the basics well: building
simple baseline knowledge surrounding the dangers of mercury and means to reduce exposure

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through a repeated, truthful, consistent, two-way dialogue to disseminate and sensitise mining
communities towards the dangers of mercury. This should be backed by, again, simple but reliable
and collaborative technical extension. More complex mercury pollution abatement projects are (if the

assertions above are upheld) evidently not going to work whilst target communities remain unaware,
misinformed, or unconvinced about why they should adopt them in the first instance. This may be an
unattractive proposition for donors eager to show concrete outcomes. But the failure of previous

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forward. It must at least be attempted.

approaches and the shifting rhetoric within debates indicates that this must constitute a better way

Discussion surrounding the topic has too often consisted of condemning appraisals of miners
willingness to embrace environmentally-friendly practices towards mercury use (e.g. Bawa 2010,
Eisler 2003). Yet, the truth is there has not been nearly enough appropriate intervention work to
make a discernible impact or draw accurate conclusions on the attitudes and ability of miners to
embrace mercury pollution abatement.
Conclusion

A resumption of projects aimed at tackling mercury emissions from ASGM emerging from the
Minimata Convention seems imminent. It also provides a real opportunity for both national
governments in their national action plans and donors and funding bodies in their support to reassess
their approaches. Previous approaches have clearly been largely ineffective; currently, all of the
available evidence points to the fact that most miners across the globe are largely unaware,
misinformed or unconvinced about the dangers of mercury. Moreover, they are widely oblivious to or
unable to access the means through which they can reduce emissions and risk of exposure.

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This paper has outlined the broad case for strategies emphasising a commitment to basic but
sustained engagements with artisanal mining communities in future approaches. Before anything
more complex is debated, it is essential to instil a basic level of knowledge and sensitise target
populations towards the benefits of changing their practice. It is then a necessity to have realistic,
appropriate and reliable systems in place to engage and support those who do wish to change. There is
a need to emphasise sociological understandings to what has been traditionally seen as ostensibly a
technical problem. If a more humanistic understanding of the dynamics of mercury use is taken, it is

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quite obvious that changing behaviour is going to be challenging. It will require repeated and
appropriate engagement and encouragement. This is something that has been amply demonstrated

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through the failure of short-term, technically-orientated approaches thus far.

For this to happen, however, the beginnings of a realignment in how policymakers perceive mercury

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pollution in the small-scale mining sector that has shown green shoots needs to be strongly taken
forward. If policymakers are serious on acting on mercury pollution in ASGM, the events following the
Minamata Convention and future efforts cannot yield the same strategies. The ways and means of

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approaching this persistent problem are up for some serious rethinking. Researchers have built an
expanding base of knowledge and experience over what has worked and (more often) failed. With the
human aspects of mercury pollution abatement in the ASGM sector finally beginning to be discussed

with the same amount of zeal as technologies, and the experimentation with novel approaches to
education, the chances of moving forward constructively will be great.

Through repeated, open and collaborative work by various partners, valuable experience is built on
both sides, methods can be refined, relationships can be established, and momentum can be built that

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cannot feasibly occur in the types of isolated projects that have characterised approaches thus far. If
anything has been learnt from previous attempts, it is that the intricacies of programmes and
strategies must be tailored according to the individual dynamics of a country or locations ASGM
sector. In theory, the ambitious outline for national action plans within the Minimata Convention
allows for this and is open to constructive inputs. It is essential, therefore, that the dedicated work of
progressive practitioners and researchers does not remain ignored when carrying approaches forward.

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