Insight |
last three years”, and gave a company perspective of implementing the standard. Kroon explained that they had discovered gaps in conformance in relation to risk management, internal audits and social performance - specifically in relation to off-site emergency response where emergency drills with certain communities were scheduled but had not yet taken place. While there were also gaps in recovery planning too which had only been covered briefly before but was now “updated and beefed up”. “It might not look like it from a first glance,” Kroon said, “but actually interpreting the GISTM requirements in real life situations can be bit of a challenge. Most of the time it is clear and straight forward but sometimes it’s not clear what it looks like or what’s good enough. And in some cases, we’re still working through that.” Kroon gave the example of ‘meaningful engagement’
Top: A tailings dam built to contain byproducts of gold mining
Above: A new global registry of tailings storage facilities is being developed
Below: The aftermath of the Mariana tailings dam failure in Brazil © Renan Martelli da Rosa /
Shutterstock.com
Bottom: Recent incidents include the failure of Jagersfontein tailings dam in South Africa during 2022
where the standard requires the need to demonstrate that project-affected people are meaningfully engaged. “But,” she pointed out, “this is a two-way street and we’re wondering what happens if a community does not want to talk about tailings facilities or failure and doesn’t provide any feedback or information. “This can happen,” Kroon said, “as some communities have very different priorities. Perhaps the better way is to say at what point are those communities meaningfully engaged?” The question was also brought up about when communities need to be engaged if future discussions internally within a company are looking to potentially raise an existing facility in maybe 20-25 years’ time. This could impact communities, that the company currently does not have relationships with, due to extension of the inundation zone.
“At what point do we start engaging communities, considering all the uncertainties involved in the early planning stages of such infrastructure?” Kroon asked. “Is it okay to wait until the permitting stage or is that too late?” Kroon also discussed other grey areas such as gathering information on local communities, free prior informed consent and pre-emptive resettlement. “The standard says when other measures to reduce consequences have been exhausted and pre-emptive resettlement cannot be avoided, the operator shall demonstrate conformance with international standards for involuntary resettlement. While the conformance protocol states If analysis shows residual risk to downstream communities remains unacceptable after consideration of mitigation measures, pre-emptive resettlement is needed,” Kroon explained. “The question here is which consequence types are we looking at? We’ve taken it to mean loss of life consequences only, and so are currently not looking into potential impacts on livelihood. While another question is- unacceptable to whom? To us? Or the communities, authorities, or society at large?” she asked. Detailing the approach her company has taken
in order to conform with the standard, Kroon says there is still uncertainty about whether this is enough or not. She spoke about emergency responses and how tailings storage failures are the least of some authorities’ worries as they may be located in areas where they are “more focused on more frequently occurring natural disasters”, while others may not have the capacity to respond due to lack of funding. In some cases Anglo American has even had governments
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pushing back or slowing down the company’s planned emergency preparedness “So at what point are we trying or doing enough?”
Kroon asked. “We obviously need to maintain good relationships with these authorities and so have to be careful and balanced when dealing with this.” These were just a sample of some of the issues Anglo American has come up against in its journey when trying to implement GISTM. There are said to be a lot more grey areas and there’s a need for a risk-based approach informed by knowledgeable experts. Kroon believes the biggest challenge across industry is having these documents and plans in place versus their actual implementation and prioritising efforts based on risk. “Are we solving this for an audit or for effective tailings management and an emergency response?” kroon asked. “There’s no question about it that the GISTM has improved cross-functional collaboration, led to much better assessment of social and environmental impacts, and being better prepared in case something does go wrong. But if we’re developing evidence for audit this is not only expensive but removes money and effort away from activities that will improve tailings management and emergency response. You can have all documents in place and signed off and essentially tick GISTM boxes, but that does not mean those documents are helpful or clear enough in practice and in an emergency.”
Effort and intensity
Reflections on these first GISTM disclosures, UNEP and PRI said there has been considerable efforts and investments by ICMM member companies and inevitably with a new global standard there will be variations in interpretation. However, this has strongly reinforced the need to establish an independent Global Tailings Management Institute to support the industry to further develop greater consistency in application and conformance within future reporting. Specifically it adds there is a need for: Stronger guidance on the format of reporting and the level of detail to be included in disclosures. Companies need to strive for greater consistency in reporting and focus on the key detail, particularly with the number of TSFs to be reported on by Aug 2025.
Independent auditing/verification to be a part of the conformance assessment. Reviews of audit protocols are needed to continue to drive towards a cultural change in tailings management. Continued promotion of the standard and its adoption by the many companies who are yet to commit to applying the GISTM
Aidan Davy is the Chief Operating Officer and Director of the Environment Programme at the ICMM. He spoke about the “extraordinary level of collaboration and exchange” that is taking place and was unthinkable five years ago. However he added that “we didn’t anticipate the significant effort and intensity” it would take to implement the standard. Agreeing that it is complex and challenging to implement, Davy added that important learning is taking place and the value of this and the desired positive outcome of implementing the standard cannot be underestimated. He recommended that any company in the early stages of their journey towards
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