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Mine Water and the Environment (2021) 40:6–15

https://doi.org/10.1007/s10230-021-00750-w

TECHNICAL ARTICLE

Integrated Risk Management in Mining Waste Facilities


Gustavo Ramos Dantés dos Reis1   · José Carlos de Oliveira2 · Marcus Vinicius Abrahão Porto Silva3

Received: 17 February 2020 / Accepted: 14 January 2021 / Published online: 14 February 2021
© Springer-Verlag GmbH Germany, part of Springer Nature 2021

Abstract
The Mining Association of Canada (MAC) was the first in the world to develop an externally verified performance system
for sustainable mining. This paper proposes adopting a management model that integrates the principles described in the
MAC models for safe management of mining tailings facilities, including governance structure and decision making, to
systematically and rigorously implement the other principles described in the International Organization for Standardization
(ISO 14001) Environmental Management Systems standard and MAC Tailings Guide (MAC 2019a) in an integrated manner.

Keywords  Tailings facilities · Management systems · Risk-based approach

Introduction of their management system standards. This and other key


changes were incorporated in the new versions of the ISO
“Tailings dams can be considered to be one of the three 9001 (Quality) (2015a) and 14001 (Environment) (2015b)
main risks to the business of any mining company. Gener- standards published in 2015 for greater alignment with busi-
ally, they are the second or third, after the risks inherent ness strategies, management of changes in the organization,
to the price of ore or metal” (Bittar 2016). Over the years, and adoption of the risk-based approach, according to which:
the International Organization for Standardization (ISO) has
developed a series of management system standards for top- • The risk involved must be considered when establishing,
ics such as quality and the environment, as well as business implementing and maintaining each process, activity, and
continuity and information security. All of these manage- the management system itself;
ment systems had very different structures, despite shar- • The degree of formality and rigor required to have confi-
ing certain common characteristics, which can make their dence in the processes is a function of the risk involved—
implementation difficult and complex. To face this chal- the greater the criticality and the potential consequences
lenge, ISO sought ways to create an identical structure, in of a failure in the process, the stricter the criteria, meth-
terms of text, terminology, and common definitions, for all ods used, and controls implemented must be.

The Mining Association of Canada (MAC), when pub-


* Gustavo Ramos Dantés dos Reis lishing the first edition of their Tailings Guide in 1998, did
gustavo.dantes@jmendo.com.br so in response to a series of international incidents that
José Carlos de Oliveira occurred throughout the 1990s at mining tailings dams. The
josecarlos@aliancaconsultores.com Tailings Guide has undergone revisions and developments
Marcus Vinicius Abrahão Porto Silva since then, more and more in line with the ISO 14001 (ISO
vinicius@aliancaconsultores.com 2015c) standard, in addition to introducing, in its most recent
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edition (version 3.1, published in February 2019), new
Associate Consultant, J. Mendo Consultoria,
Rua Ministro Orozimbo Nonato 442 ‑ Sala 416,
key concepts, among them the risk-based approach. How-
Nova Lima‑MG 34006‑053, Brazil ever, compared to the ISO model, the structure proposed
2
Owner Partner, Aliança Consultoria, Rua João Camilo de
by (MAC 2019a) presents, in addition to four overarching
Camargo, EHS and Q Instructor of UNICAMP Extension principles that permeate the entire management structure,
Course, 389–Sala 6, Hortolândia/SP 13184‑290, Brazil some elements that although also found in ISO standards,
3
Owner Partner, Aliança Consultoria, Rua João Camilo de deserved more attention. These will be emphasized in this
Camargo, 389–Sala 6, Hortolândia/SP 13184‑290, Brazil article aiming to demonstrate how their integration with the

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Mine Water and the Environment (2021) 40:6–15 7

ISO management systems existing in organizations could Context of the Organization


be facilitated: accountability and responsibility; critical
controls; operation, maintenance, and surveillance manu- The revision of the ISO 9001 (2015a) and 14001 (2015b)
als; emergency preparedness; performance evaluation; and standards in 2015 introduced some important changes, in
assurance. On the other hand, considering the importance addition to their high-level structure. The need to discuss
and criticality of the theme for the safety of tailings dams, the context of the organization was introduced in both stand-
the engineering projects theme (elaboration and construc- ards, as an activity of observation, evaluation, and analysis,
tion) will be approached here with a focus different from to determine positive and negative influential factors. This
that normally found in ISO 9001, where it is seen from the activity should consider and understand the stakeholders’
ISO perspective of products and services. Figure 1, adapted needs and expectations.
from ISO 9001 (ISO 2015b), ISO 14001(ISO 2015c), and It is important to understand that this is an excellent
ISO 45001 (ISO 2018), shows the framework of a manage- opportunity to bring questions about tailings disposal struc-
ment system according to the ISO model. Figure 2, in turn, ture to the most strategic level of the organization. Senior
shows the elements of a tailings management framework, management must necessarily carry out this critical review
adapted from the MAC Tailings Guide 3.1 (MAC 2019a). periodically, as set out in the standards, addressing the
themes related to tailings disposal structures. In the Tailings
Guide (MAC 2019a), such questions related to the context
Differences in the MAC Guides and ISO of the organization were not explicitly considered, but this
Standards and the Main Points of Attention is a specific requirement to should be met by any organiza-
tion that has management systems based on ISO 9001 (ISO
The standards of ISO management systems are restricted to 2015b), ISO 14001 (ISO 2015c), and, most recently, the
establishing what must be done by an organization to estab- ISO 45001 (2018) standard.
lish, implement, control, and maintain the processes neces-
sary to ensure the intended results of a management system, Accountability and Responsibility
be it environmental, quality or whatever. MAC guides, like
the Tailings Guide or OMS (Operation, Maintenance, and According to (Bittar 2016) “… the responsibility upon the
Surveillance) Guide (MAC 2019b), provide guidance on dam safety is the company itself. This type of risk cannot
how to do it. be transferred or outsourced. Currently there are compa-
nies in the market that make various services related to

Fig. 1  ISO framework for man-


agement systems Support and Operaon
- Resources
- Competence
- Awareness
EXTERNAL - Communica on
AND - Documented informa on
INTERNAL
ISSUES
- Opera onal planning and control
- Control of externally provided
processes, products and services Do
- Emergency preparedness and response

Plan
Leadership
Planning - Leadership and Performance Evaluaon
CONTEXT

- Ac ons to address risks and commitment - Monitoring, measurement,


opportuni es - Policy analysis and evalua on
- Objec ves and planning to achieve - Roles, responsibili es and - Internal audit
them authori es - Management review
- Planning of changes - Consulta on and
par cipa on of workers
Check
Act
Improvement
- Incidents, nonconformity and correc ve ac on
- Con nual improvement INTENDED
OUTCOMES
NEEDS AND
EXPECTATIONS OF
INTERESTED
PARTIES Adapted from
ISO 9001 and 14001:2015,
SCOPE OF MANAGEMENT SYSTEM ISO 45001:2018

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8 Mine Water and the Environment (2021) 40:6–15

Fig. 2  Elements of tailings
Implemenng the Tailings Do
management framework Management Framework
Plan - Operaon, Maintenance, and
Surveillance Manual (OMS)
Planning
- Emergency Preparedness
- Risk management
- Checklists
- Performance objecves
- Accountability and responsibility
• Governance level
• Accountable execuve officer
• Responsible person(s)
• Engineer-of-Record (EoR)
• Independent Reviewer(s)
- Management process Check
• Conformance management
• Managing change Performance Evaluaon
• Controls
o Crical controls Policy and Commitment Assurance
o Quality management - Audits
o Operaon, Maintenance, - Evaluaon of Effecveness
and Surveillance Manuals - Independent Review
(OMS)
• Resources
o Financial control
o Control of documented
informaon
o Training and competence
o Communicaons Adapted from MAC
Tailings Guide 3.1
Act
Management Review for Connual
Improvement

risk management and safety management for tailings dams, • Owner’s board of directors or governance level;
including companies that provide implementation of safety • Accountable executive officer;
management systems services. Even in such cases, regardless • Responsible person(s);
of the use of specialized consultants or engineering com- • Engineer-of-record (EoR); and.
panies, it is crucial to understand that the dam safety is an • Independent reviewer(s).
internal affair and should be "signed" by the senior manage-
ment of mining companies.” In the same publication we find: According to the Tailings Guide (MAC 2019a), and
“The failure of a tailings deposit must be considered and consistent with (Bittar 2016), the responsibility for deci-
formalized as one of the main business risks of a mining com- sions related to tailings management rests with the Board
pany. Given the scale of the problem, it should be treated with of Directors or the Governance Level of the owner of the
the highest levels of the organization and with high rigor.” tailings facility, depending on the size and of the organi-
The OMS Guide (MAC 2019b), Appendix 6 recognizes zation’s structure. The Tailings Guide clarifies the con-
that “one of the essential elements of effective tailings man- tent of each of the above functions and, in the case of the
agement is how the various individuals involved in tail- last, which is one of the four overarching principles of
ings management relate to one another in their day-to-day the management structure it proposes, and details (MAC
function”. 2019a, Appendix 4) the characteristics and objectives
The ISO 14001 (ISO 2015c), ISO 9001 (ISO 2015b), and of this function. Consistent with the provisions of the
ISO 45001 (ISO 2018) standards, used as references in this ISO standards cited above, as good practice for estab-
article, are restricted to determining that the responsibili- lishing a formal process that describes the relationships
ties and authorities for the relevant roles in the management between functions, the OMS Guide (2019b), Appendix 6
system be assigned, communicated, and understood in the recommends the use of the responsibility assignment
organization. MAC goes further, and while recognizing that matrix (R = responsible, A = accountable, C = consulted,
circumstances vary and, therefore, the organizational and I = informed) or RACI. “A RACI matrix is a delegation
governance structure must be adapted for each company and tool used to identify each task, milestone, or decision
tailings facility, establishes that responsibilities, account- point, and develop, document and communicate roles and
ability, and authorities be clearly defined, documented, and responsibilities for each”.
communicated for at least the following functions:

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Mine Water and the Environment (2021) 40:6–15 9

Critical Controls 9001 (ISO 2015b) applies the title quality management to
products and services, it is also perfectly applicable to the
The concept of critical controls is introduced in the Tailings management of tailings facilities.
Guide (MAC 2019a), relative to the operational controls
provided for in the ISO standards. In the context of waste
Quality Management
management, critical controls are a subset of risk controls
that prevent high consequence events or mitigate the con-
The main objective of clause 8.3 of ISO 9001 (ISO 2015b),
sequences of those events. The absence or failure of a criti-
Design and Development of Products and Services, is to
cal control would significantly increase the risk, despite the
define a process that establishes the characteristics of prod-
existence of other controls. Critical controls can be techni-
ucts and services, to ensure that their supply meets the needs
cal, operational, or governance based.
and expectations of customers, whether these are implicit,
The Tailings Guide (MAC 2019a) provides step-by-step
explicit, or even unknown. We propose a model for the appli-
instructions for the management of critical controls. Accord-
cation of this clause, with all its sub-clauses, to ensure a
ing to ISO 14001 (ISO 2015c), outsourced processes must
more comprehensive management of tailings disposal struc-
be carefully controlled. This is especially relevant in the case
tures in mining activities (Table 1).
of tailings disposal structures, in which there is a high inci-
dence of external contracting in the construction and rais-
ing of dams. As stated in ISO 9001 (ISO 2015b), under the Emergency Preparedness
title of Control of Processes, Products and Services Provided
Externally, “the organization shall determine and apply When publishing version 3.1 of the Tailings Guide, (MAC
criteria for the evaluation, selection, monitoring of perfor- 2019a) stated that the most significant change was the
mance, and re-evaluation of external providers, based on rewriting of Sect. 5.2—Emergency Preparedness. This sec-
their ability to provide processes or products and services in tion was modified to provide more detailed guidance for the
accordance with requirements.” This requirement deserves preparation of emergency response plans (ERP) and emer-
specific attention, as it is extremely relevant for managing gency preparedness plans (EPP).
the safety of tailings facilities. It is also worth mentioning An ERP, according to MAC, describes the measures that
that “the establishment of controls must ensure that environ- the company and, in some cases, external stakeholders,
mental requirements are treated in the design and develop- will take to prepare for an emergency and respond to it, if it
ment process, considering each stage of the life cycle”. ISO occurs. While some aspects of an ERP may involve external
45001 (ISO 2018), in turn, is explicit in the approach of the stakeholders, it is intended to be an internal document. For
hierarchy of controls for establishing, implementing, and emergencies that may result in impacts downstream on the
maintaining a process to eliminate hazards and reduce risk. environment, infrastructure, or security, an EPP is devel-
Regarding risk controls, MAC considers it necessary to oped for external use, with information from communities of
document these controls and describes pre-established man- interest (COI), including local authorities (e.g. first respond-
agement actions to maintain or regain control over a given ers and municipal governments) and regulatory bodies.
situation. According to MAC, a tailings management system In providing detailed guidance for the preparation of
provides a general structure, but a specific operation, main- these plans, (MAC 2019a) also provides supplementary
tenance, and monitoring (OMS manual) (MAC 2019b) is guidelines, such as those related to integration with other
required for each tailings installation, to make this structure emergency plans at the site level and linking to other docu-
work well on a daily basis. MAC has published a document ments (e.g. OMS Manual, crisis management plan, com-
that provides detailed guidance on the development and munication plan), dealing with flood risks, assessments, and
implementation of OMS manuals (MAC 2019b). The OMS simulations.
Guide recommends justification, organization, and content The ISO 14001 (ISO 2015c) and ISO 45001 (ISO 2018)
for developing a site-specific OMS Manual. standards, in turn, deal with emergency preparedness and
According to the Tailings Guide (MAC 2019a), the response in a much less profound way. These rules, in short,
OMS manual must include or refer to other specific plans establish that companies must plan actions to prevent or
for various aspects of tailings management, such as: tail- mitigate adverse impacts resulting from emergency situa-
ings transportation and disposal plan; water management tions, in addition to preparing to respond to such situations,
plan; and closure plan. Appendix 6 (MAC 2019a) provides if they occur, and should periodically test planned response
guidance for preparing these plans. The Tailings Guide also actions, where feasible, critically analysing and reviewing
defends the need for a management system to include issues the planned response processes and actions, particularly
associated with quality management, as a tool to ensure that after emergency situations or tests have occurred, in addition
all specifications have been adequately met. Although ISO

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Table 1  A model for applying clause 8.3 of ISO 9001 (2015a) to the management of tailings facilities
Sub-clauses of 8.3 Statement Application to tailings facilities

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8.3.2 Design and development planning: (a) The nature, duration, and complexity of design and devel- In the planning phase, consider all the technical characteristics of the
In determining the stages and controls for design opment activities tailings disposal structure, its nature, scale and impacts, as well as the
and development, the organization shall con- complexity of each stage of design and development, in the life cycle of
sider: the structure
(b) The required process stages, including applicable design In planning design and development, consider all stages of the life cycle of
and development reviews the tailings facility and the stages of critical analysis, involving all of those
responsible for each stage
(c) The required design and development verification and In the planning phase, it is very important to define the criteria for verifying
validation activities and validating the design and development of the tailings disposal struc-
ture. This step includes verification and validation of activities that may
put the structure at or increase the risk, such as dam raising processes
(d) The responsibilities and authorities involved in design and Those responsible for each stage and who have decision-making authority
development process must be defined. The RACI matrix tool can be used. It is very important
that people with responsibility and authority are aware of the conse-
quences of not fulfilling their roles throughout the facility life cycle;
regulatory requirements must also be considered
(e) The internal and external resource needs for the design and In the planning phase, the necessary resources must be identified, consider-
development of products and services ing the entire facility life cycle. These resources are financial, qualified
personnel to be involved in each stage and adequate machinery, software
and equipment
(f) The need to control interfaces between persons involved in In the planning phase of construction of tailings disposal structures, all
the design and development process existing interfaces must be identified and controlled, both internally and
externally to the organization
(g) The need for involvement of customers and users in the Consider how all stakeholders will be affected or may affect the construc-
design and development process tion of a tailings disposal structure, during the entire facility life cycle
during the planning phase
(h) The requirements for subsequent provision of products and Although a tailings disposal structure is not classified as an organization’s
services product or service, it is important that it establishes all the necessary
requirements for the intended use of the structure
(i) The level of control expected for design and development Still during the design and development planning phase, it is necessary
process by customers and other relevant interested parties to establish what level of control is expected to ensure the safety of the
tailings disposal structure throughout the project’s life cycle, especially
considering the need and opportunity for changes in the design, ensuring
revisiting all original or modified technical documentation
It is necessary to ensure that all discussions and decisions taken, with the
knowledge of the interested parties, have been considered in the definition
of controls
(j) The documented information needed to demonstrate that Ensure that all documented information necessary to guarantee the safety of
design and development requirements have been met the tailings disposal structure has been generated and can demonstrate that
the design and development requirements are met
Mine Water and the Environment (2021) 40:6–15
Table 1  (continued)
Sub-clauses of 8.3 Statement Application to tailings facilities

8.3.3 Design and development input: (a) Functional performance requirements As input to the design and development, it is necessary to consider func-
The organization shall determine the requirements tional performance requirements, such as the: physical, chemical, and
essential for the specific types of products and geological characteristics to be established; positive and negative impacts
services to be designed and developed. The to the stakeholders; and expected performance for the entire facility life
organization shall consider: cycle
(b) Information derived from previous similar design and Collect information on the performance of similar structures, including
development activities considering performance characteristics higher or lower than planned
(c) Statutory and regulatory requirements Identify statutory and regulatory requirements, available in all legal spheres.
Include the need to comply with technical standards and legal require-
ments at all levels
Mine Water and the Environment (2021) 40:6–15

(d) Standards or code of practice that the organization has Include information on codes and values of the owner’s company, usually
committed to implement assumed by large organizations and how they impact the design and devel-
opment of tailings dams
(e) Potential consequences of failure due to the nature of the Conduct a detailed and complete risk analysis, identifying the potential
products and services consequences of failures due to the nature of the facility. In addition to the
risks inherent in the process, risks such as sabotage and terrorist actions
must be considered
Input shall be adequate for design and development purpose, It is important to ensure that all input information has been identified,
complete and unambiguous reviewed, and that formal decisions have been recorded, ensuring the
Conflicting design and development inputs shall be resolved absence of ambiguities and conflicts that may affect the design and devel-
The organization shall retain documented information on opment and the expected performance of the tailings facility. All docu-
design and development inputs ments used in the design and development, especially those that informed
decision-making, are retained during the facility life cycle. It is important
to ensure that they are readily available

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Table 1  (continued)
Sub-clauses of 8.3 Statement Application to tailings facilities

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8.3.4 Design and development controls (a) Define the results to be achieved In the design and development control stage, ensure that the planned results
The organization shall apply controls to the design are defined, with those responsible already formally communicated for
and each stage, including commissioning/decommissioning of the tailings
development process to: facility
(b) Conduct reviews to evaluate whether the results of design Ensure that the critical analysis provided for in the design and development
and development meet the requirements planning phase are carried out, involving those responsible for each stage,
to ensure compliance with the specified requirements, including regula-
tory requirements
(c) Conduct verification activities to ensure that the design and Verification activities must ensure that the design and development outputs
development outputs meet the input requirements met the requirements defined in the input, i.e. the organization must
review the result of the design and development, formalize this output, and
compare it with what was established. This is fundamental information for
decision making on the project’s continuity and development
(d) Conduct validation activities to ensure that the resulting The validation activities must focus on the tailings disposal structure result-
products and services meet the requirement for the specified ing from the design and development, and must allow demonstrating that
application or intended use the results satisfy the requirements for the specified application or the
intended use, that is, that they satisfy the needs and expectations of the
interested parties. Validation must be completed before delivery of the
structure and the participation of interested parties is recommended
(e) Take necessary actions on problems determined during the The problems identified in the verification and validation phases must be
reviews, or verification and validation activities solved before the operation phase of the tailings disposal structure. Deci-
sions made about solving problems should be recorded and retained
(f) Retain documented information of these activities All documented information must be controlled, retained, and preferably,
readily available
Mine Water and the Environment (2021) 40:6–15
Table 1  (continued)
Sub-clauses of 8.3 Statement Application to tailings facilities

8.3.5 Design and development output: (a) Meet the input requirement The design and development outputs must meet the requirements estab-
The organization shall ensure that design and lished in the input phase, especially considering aspects such as legal and
development output: regulatory requirements, as well as the applicable technical standards
(b) Are adequate for the subsequent processes for provision of The exit phase of design and development must provide all the necessary
products and services information for the construction and operation of the tailings disposal
structure, as well as future decommissioning, after the end of the project’s
life cycle
(c) Include or reference monitoring and measuring require- Although not explicitly mentioned in previous sub-clauses, it is necessary
ments, as appropriate, and acceptance criteria to guarantee all stages of monitoring and measurement, as well as the
criteria for acceptance of results, always considering the use of valid and
recognized methodology, nationally and internationally
Mine Water and the Environment (2021) 40:6–15

(d) Specify the characteristics of the products and services that It is important to consider at this stage the specifications and characteristics
are essential for their intended purpose and their safe and essential for the purpose of the tailings disposal structure. Ensure that all
proper provision security information is formally established, and data book templates can
be used, with as-built drawings, among others. Ensure that these speci-
fications and essential information are available, including in situations
characterized as emergency
The organization shall retain documented information on All documentation necessary to ensure that the design and development
design and development output outputs have been met must be retained and controlled
8.3.6 Design and development changes: The (a) Design and development changes Design and development changes must be dealt with according to the
organization shall identify, review, and control rules established in the mechanism defined by the management system
changes made during, or subsequent to design itself, referring to change management. It is very important to ensure
and development of products and services, to that changes are only made if they are foreseen when entering design and
the extent necessary to ensure that there is no development and that they have gone through the corresponding verifica-
adverse impact on conformity to requirements. tion and validation steps
The organization shall retain documented infor- (b) The results of reviews Ensure that the results of the reviews are formally recorded and retained,
mation on: including the participation of those responsible and the decisions taken
(c) The authorization of the changes Ensure that those responsible for authorizing changes have been formally
defined in the planning and input phases of design and development
(d) Actions taken to prevent adverse impacts Ensure that the risk analysis has identified the points of greatest weakness in
the design and development and that actions have been defined to prevent /
mitigate adverse impacts

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14 Mine Water and the Environment (2021) 40:6–15

to providing relevant information and training for relevant independent reviews are covered in detail in Appendix 4
stakeholders. of the Tailings Guide (MAC 2019a).

Performance Evaluation
The Global Industrial Standard on Tailings
The essence of the difference between MAC’s Tailings Management and the Social Aspects
Guide approach and the ISO standards for monitoring,
measuring, analysing and evaluating management perfor- Recently, on Aug. 5, 2020, a series of principles and require-
mance is, in addition to the greater level of detail of a ments integrating social, environmental, and technical con-
guide (how to do it) in relation to a standard (what to do), siderations, was published under the title (Global Industry
already mentioned, is the fact that performance evaluation, Standard on Tailings Management 2020). The standard
according to MAC, should be supported by the use of a was developed through an independent process—a Global
site-specific OMS Manual (MAC 2019b). This determina- Tailings Review—jointly organized by the United Nations
tion facilitates the planning of the performance evaluation, Environment Program, the Principles for Responsible Invest-
even though it makes it more complex, given the level of ment, and the International Council on Mining and Metals.
detail that an OMS Manual requires. The standard establishes explicitly, in Requirement 6.1, the
mining company’s obligation to “Build, operate, moni-
tor and close the tailings facility according to the design
Assurance intent at all phases of the tailings facility lifecycle, using
qualified personnel and appropriate methodology, equip-
The corresponding requirement established in the ISO ment and procedures, data acquisition methods, the Tailings
standards to the Assurance item in the Tailings Guide Management System (TMS) and the overall Environmental
(MAC 2019a) would be for internal audits. The Assurance and Social Management System (ESMS) for the mine and
requirement of the Tailings Guide, however, is much more associated infrastructure”. The standard further defines
comprehensive, since it includes audits (both internal and in its Glossary (Annex 1) that “The TMS, and its various
external), as well as evaluation of effectiveness and inde- elements, must interact with other systems, such as the
pendent review(s). As defined in the Tailings Guide (MAC environmental and social management system (ESMS), the
2019a), audits involve some degree of judgment, but are operation-wide management system, and the regulatory sys-
not designed to determine the root cause of the deficien- tem. This systems interaction is fundamental to the effective
cies or to assess the effectiveness of the management sys- implementation of the Standard”.
tem. They are only a formal, systematic, and documented In some mining companies, notably the large ones, the
examination of the tailings facility conformity in rela- management of social responsibility is incorporated with
tion to explicit criteria, previously stipulated and agreed. management of quality, environment, occupational safety,
Audits assess and report the degree of compliance with and health. However, there is no ISO standard for social
the stipulated criteria, based on the collection and sys- responsibility management systems. In 2010, (ISO 2010)
tematic documentation of relevant evidence. The Tailings published ISO 26001 (ISO 2010) Guidance on Social
Guide addresses audits more with a focus on their content, Responsibility, which is not a management system standard,
while ISO standards devote more text to how to structure and is not structured in the plan-do-check-act (PDCA) model
an audit program.(MAC 2019a) establishes that to meet like all the management system standards published by ISO,
the Assurance requirement, the different proposed mecha- and is not even auditable and certifiable.
nisms should not be treated as options—all three (audits, The SA8000 (2014) standard (SAI 2014), published by
evaluation of effectiveness and independent review) must SAI—Social Accountability International, is the world’s
be used, as they serve different purposes. leading social certification program. It is based on interna-
Thus, the second mechanism (evaluation of effective- tionally recognized standards of decent work and national
ness) goes beyond determining whether a condition has laws. SA8000 (SAI 2014) applies a management-systems
been met, and includes an assessment of whether tailings approach to social performance and emphasizes continual
management is achieving the intended results. The Tail- improvement, not checklist-style auditing. This can facili-
ings Guide (MAC 2019a) proposes a list of results and tate the integrated approach advocated in this article, and
performance trends that should be evaluated to determine fulfill the goal of the (Global Industry Standard on Tailings
the effectiveness of tailings management. Management 2020).
The third Assurance mechanism established by MAC is
the independent review. As one of the four so-called over-
arching principles of the tailings management framework,

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Mine Water and the Environment (2021) 40:6–15 15

Conclusions ISO (International Organization for Standardization) (2015a) ISO


9000, Quality Management Systems, Fundamentals and Vocabu-
lary, International Organization for Standardization. Geneva,
Although the management framework for tailings facilities Switzerland. https​://www.iso.org/home.html
proposed by MAC is admittedly based on the ISO 14001 ISO (2010) ISO 26000 Guidance on Social Responsibility. Interna-
(2015b) standard, (ISO 2015c) there are particularities in the tional Organization for Standardization, Geneva, Switzerland.
https​://www.iso.org/home.html
content found in Tailings Guide (MAC 2019a), including the ISO (2015b) ISO 9001 Quality Management Systems, Requirements.
distribution of requirements in the PDCA cycle. This does International Organization for Standardization, Geneva, Switzer-
not prevent management under the Tailings Guide (MAC land. https​://www.iso.org/home.html
2019a) from being integrated with systems that already oper- ISO (2015c) ISO 14001 Environmental Management Systems —
Requirements with Guidance for Use. International Organization
ate under the ISO model in mining companies. This article for Standardization. Geneva, Switzerland. https​://www.iso.org/
promotes a comparative analysis of the ISO and MAC mod- home.html
els to facilitate integration, giving emphasis to the Design ISO (2018) ISO 45001 Occupational Health and Safety Management
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Global Industry Standard on Tailings Management (2020) Global
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