Franciska Lake and Jacky Burke. Photos courtesy of SRK Consulting
Tailings facility owners are facing the challenge of how to practically integrate social impacts with the systems that manage tailings – as required by the Global Industry Standard for Tailings Management (GISTM). In fact, building social engagement into tailings management is the first topic addressed in the 2020 standard, requiring mines to ”respect the rights of project-affected people and meaningfully engage them at all phases of the tailings facility lifecycle, including closure.”
For a start, according to the GISTM, meaningful engagement requires a range of formalized systems, procedures and monitoring of the mine’s environmental and social management system (ESMS). However, a key hurdle on most mining sites is the typical separation of the more “technical” tailings systems from environmental, social and governance (ESG) systems.
Mines will generally have an ESMS that puts into operation several of the ESG requirements of the GISTM, while there is also a tailings management system (TMS) that executes both the engineering and governance considerations of the GISTM. The current challenge is to integrate the ESMS with the TMS in a way that is practical and effective.
Indeed, the ESMS itself has both environmental and social components that are often not adequately integrated within the mining operation. They are usually managed as separate entities, and often within different departments. While environmental issues may fall under the safety, health and environment department, social management may fall under a community engagement or social performance department.
There are, of course, many different disciplines and skill sets involved in each function – and each team has its own day-to-day responsibilities and imperatives. Conformance to the GISTM will require strong interaction and integration between the disciplines and various systems dealing with engineering, social and environmental monitoring, risk management and change management.
Driving this integration is the growing urgency on the compliance front, as International Council on Mining and Metals members are working towards a looming conformance deadline. Mines that operate their TSFs with extreme or very high consequence ratings must comply with the GISTM by August 2023.
Key to the paradigm shift essential to the GISTM will be the elevation of social engagement from being intermittent to being ongoing. Focused engagement is often associated with permitting, as part of the regulatory public participation process during environmental authorization processes and water use licensing applications.
Engagement with affected people should instead be meaningful and ongoing throughout the lifecycle of a TSF – with integration into the regular routines of tailings and environmental management.
A four-step process for effective implementation of the GISTM
As the cross-cutting demands of the GISTM may present challenges, we propose a four-step process to provide a framework in which mines can structure and evaluate their progress. Importantly, the steps need to be iterative and ongoing throughout the life of the tailings facility.
1. Knowledge sharing, training and awareness: The aim is to build mutual understanding among the respective experts of a mine’s environmental, social and tailings management teams on their roles and functions within the context of the site operation and the risks posed.
It is critical that this first step involves tailings engineers and operators in collaboration with environment and social management personnel to facilitate the integration process. This collaborative group needs to share how site-specific risks are currently being dealt with by the ESMS and TMS, and find opportunities to engage affected people on identified tailings facilities.
2. A critical review of systems for gaps and opportunities: This step lays the groundwork for the mines to comply with the GISTM requirements through reviews and internal audits. It conducts a critical review of the ESMS and TMS, looks at specific areas for improvement and integration, and identifies gaps in its conformance with the GISTM.
3. Upgrading of data systems to highlight targets and trigger action: This step is underpinned by step two. Data systems must be able to set performance targets and to act if the targets are not met. Along with specifying people responsible for each variable being monitored, the system would also need to include reporting frameworks and schedules in line with what the GISTM requires.
4. Strategies for ongoing collaboration and development: This step could involve, for example, regular meetings of a forum of GISTM disciplines on the mine. This forum shares lessons learned and keeps everyone informed of risks and corrective actions.
Applying the four-step approach demands considerable effort and commitment by mine personnel, especially being an iterative process where adaptation and adjustment would always be required. With the GISTM firmly embraced by the sector, and with investors and regulators alike watching its implementation closely, it is vital that mines invest the necessary resources and time to ensure conformance to the GISTM.
Franciska Lake is a partner and principal environmental scientist and Jacky Burke is a principal environmental consultant, both at SRK Consulting.