CONTACT: Lindsay Newland Bowker, Bowker Associates firstname.lastname@example.org
DATE Of Release: December 5, 2016
Today ICMM ( “The International Council on Mining & Metals”) issued its report on Tailings Management. Written by Golder Associates who played a major role in the PR for Mt Polley and Samarco, the report is on behalf of ICMM’s 23 members who are the largest miners in the world controlling more than 2/3 of all production globally.
It is really more a PR document assuring investors and the public that its 23 large members have been following and continue to follow all best practice standards for tailings design and management. There is nothing in it that recognizes the elevated levels of catastrophic tailings loss globally not just as forecast but as evidenced in the record . There is nothing offered that addresses root causes or solutions.from Icold ( 21 years ago)
Pretty much as expected from ICC and from Golder and a very different story than Golder tells when its client is evaluating mines and miners for the World Bank or the IFC.
It is on a parr with the superficial response and reassurance given by BC MOM in its directed re evaluation of all B.C Tailings Facilities. What was actually directed and the information actually produced did nothing to actually assess the level of risk in BC MOM’s standing operating already permitted TSF’s
FALSELY STATES HISTORIC RECORD OF CATASTROPHIC FAILURES
It falsely states the historic record on TSF failures still quoting that tired old worn out 21 year old ICOLD stat that the mining industry insists on as its meme : “2 significant failures occur per year”. In the most recent decade the actual number is 3.4 per year. The stats are clear that more than 1 catastrophic failure occurs per year and that number is on the rise to an expected 13 total just for the decade 2010 to 2020. 9 occurred for the decade 2006-2015. In addition to that there were 25 other significant incidents ,” 9 “serious failures” and 16 “other failures” this decade just ended 12/31/2015. This totals 34 “significant events” in the most recent decade or 3.4 per year not the “2 significant events” per year stated by Golder. Using methods with proven predictive accuracy and solid roots in actuarial science,Bowker Associates accurately predicted the 9 catastrophic failures for this decade ( 2006-2015) we are predicting 15 catastrophic failures for the decade 2016-2025 many in the range of severity between Mt Polley and Samarco.
If ICMM’s model is taken up as a standard for the legal frameworks of mining globally or as standards for responsible self governance we can expect these drastically elevating trends of catastrophic failures to rise even more steeply with ever greater non remediable consequence.
The ICMM/Golder “report” gives a cursory and poorly informed examination of root causes of failure again based on ICOLD’s 21 year old report, selecting only 3 out of the total 18 catastrophic failures since 1996 ICMM/Golder systematically avoid the many authoritative deeply informed reviews of cause of failure especially Blight et. al’s re- review Merriespruitt which summed up a better list of root causes of failure.
These roots of failure, as Golder and each of ICMM’s members knows include
- a brain drain in the industry;
- incompetence in understanding and applying available technology;
- global shifts which have determinant long term adverse financial viability at the nation level
- the proof that the “economics of scale” metric no longer works at the very low grade levels where head grades and discovery fgrades converge.
- A dramatic and debilitating 23% loss in productivity industr wide between 2004 and 2013 according to McKinsey
- That grade is now “king” and the mining industry has entered an entirely new era where old assumptions, old industry standards and even the body of existing “best knowledge” no longer apply. Deloitte and many others naming this.
ICMM/Golder cite three main national systems of guidance as containing a complete and thorough reference on “best knowledge/ best practice” and specifiy that adoption of any of these systems as corporate policy on Tailings Management would satisfy the ICMM commitment: ANCOLD( Australian National System), MAC/CDA( Canadian National Systems) and SANS(South African National System. They identify 6 additional provisions not explicit in these three framework standards that must additionally be incorporated in company policy to meet the ICMM commitment. The 6 provisions are essentially what constitutes BHP’s recently announced “reforms ” in tailings management.
The venerable Dirk Van Zyl , commenting for mining media, was not enthusiastic noting that the protocol does not encompass the root causes of the Samarco failure. Coverage in main stream business and mining news has been sparse and also without enthusiasm.
GOLDER/ICMM IGNORING FACT OF ENTIRELY NEW ERA IN MINING
Golder / ICMM ignore the facts of this new era which began about 10 years ago even as they have intentionally orchestrated their version of the new era at increased global risk of failures by over producing to intentionally drive out smaller mines, intentionally cause them to fail. ICMM and its membership have their own version of a new era governed by their membership, a few large miners who can better manipulate supply, demand and thereby better control price. The outfall of that ICCM plan is dramatic and precipitous escalation of public risk and consequence in the intentionally squeezed mines which will be left to fail or spun off to speculative avaricious foreign investors who want a foothold for other business opportunities. ( somewhere I have the article by Cecelia Jasmine of Info Mine/mining.com actually quoting this from ICMM)
Essentially in this intellectually thin document Golder ICMM cling to the old model and try to minimize any expectations of needed changes and new directions in business fundamentals among their 23 dominant metals producing members.
This clinging to worn out no longer valid old ways,old assumptions and old models is apparent in several notable quotes for which there is no excuse and no defense and which frame the cornerstone of the approach and decalarations
(1) They essentially say that all that exists as best knowledge needs no expansion, addition, or fundamental change to stem the ever rising trend of catastrophic failures
“Existing published guidance and standards documentation fully embrace the knowledge required to prevent such failures. The shortcoming lies not in the state of knowledge, but rather in the efficacy with which that knowledge is applied. Therefore, efforts moving forward should focus on improved implementation and verification of controls, rather than restatement of them.
There are numerous clearly established trends which desperately need addressing to prevent catastropic loss and stem its ever rising trend of annual frequency and severity of loss: the increasing levels of fines in lower grades that preclude the use of alternatives of slurry deposition which the Mt Polley Dam Committee has declared to be “outmoded technology”, the proportion of major producers with older TSF’s at maximum design capacity and height, the increasing deviation between predicted and actual performance of processing and production measures and on financial feasibility,the work of Bernhrad Dold on how ARD emerges in tailings, the absence of adequate in house competence to oversee or even evaluate the competence of outside consultants, a severe shortage of competence industry wide.
2. Ignoring the actual vastness of this leading edge and in some cases long established “best knowledge” more deeply mapping the circumstances and attributes which have manifested and will continue to manifest in catastrophic failure ICCM Golder cite adherence to a few very vaguely developed standards and guidelines like ANCOLD, MAP/CDA and SANS as evidencing sustainable performance
A year ago an international coalition of responsible mining advocates wrote to ICMM urging their members to undertake reforms and formally adopt the guidance of the Mt Polley Dam Committee and a loss prevention risk management response to the alarming rise of catastrophic failures post 1995 mapped by Lindsay Bowker and Co-author David Chambers in July 2015. .
Earthworks and the international coalition is still considering what response to make.to this ICMM “report” completely avoiding every issue raised by the International Coalition.
Lindsay Newland Bowker, CPCU, ARM Environmental Risk Manager
Science & Research In The Public Interest
15 Cove Meadow Rd.
Stonington, Maine 04681
Additional background and links on ICMM’s Tailings Initiative and Policy
- Annoucement that this study would be undertaken. Includes a list of all members and contact info at ICMM