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 attempting to assure 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.
This is pretty much as expected from ICMM and from Golder who have become more a mega PR firm, a “fixer” for big miners in the wake of big disasters. Golder’s is very different voice when its client is the World Bank or the IFC.
This report 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
This report 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”. Historically and in the most recent decade the actual number is 3.4 per year. In 2016, there are already 5 “significant events”.
The “2 per year” comes from including pre-1936 decades for which ICOLD//WISE reporting was sparse and anectdotal(far left of chart above). The actual long term “significant incidents” rate from 1936 is 3.3, continuing the last two decades at about the same level (3.4). The real story is in the frequency of high severity events such as Mt. Polly and Samarco. In the last two decades that rate is 180% above the 80 year rate of 0.5/year at 0.9. For the coming decade, actuarial science puts the expected rate at 1.4 to 1.5 per year for failures with releases exceeding 1 million cubic meters. ( see trend lines, below)
Many will be in the range of severity between Mt Polley (25 million)and Samarco.(40 to 60 million)
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 industry 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.
Writing before Mt Polley right after Anglo, one the “ICMM 23” took a public hit from Chile on tailings and other violations, Jack Caldwell foreshadowed and summarized some of these same elements at work within Anglo.
After it audited several mining projects at Anglo Sur’s El Soldado, located 132 kilometres from Santiago in the district of Nogales, the authority detected multiple irregularities, including failing to fully preserve and relocate vegetation, ineffective wetland conservation plans and water management, lack of environmental monitoring, and tailings in in unpermitted areas”
Do they really have tailings in unpermitted areas? How can so large a mining company make so egregious a mistake?
Recall that Mike Davies (now VP Environmental Things for Teck) said that mining companies cut cost to the point that failures occur and then they take another look at costs and maybe adjust cost cutting and staff layoff. Maybe Anglo is at that point.
I know the past head of tailings for Anglo in South Africa quit because he was overworked: required to review at least one facility a week, including those worldwide. You cannot even travel to most of the mines in a week, net alone review their tailings operations.
“Tonight at the party for next week’s Heap Leach Conference, we discussed this story. One cynic told the story of McMillian Blodell in BC who decided it was cheaper to pay the fines than obey the laws. His opinion is that maybe this is what is happening in Chile. As he noted, $5 million is a hell of a lot less than $300 million or the cost of establishing wetlands and putting tailings in distant sites.
Jack Caldwell.September 23, 2013 I think Mining.com ( reprinted at Mining.com)
This is the basket of snakes the Golder concocted ICMM Tailings Management Report is trying to keep the lid on.
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 , a member of the ICMM expert review panel noted that ICMM did not address the root causes of the Samarco failure nevertheless congratulated them on what they had addressed.
-size:medium;”>Dirk van Zyl, a member of the expert panel that was constituted for the review, said
: “I am delighted that as a result of the review, CEOs of the world’s 23 leading mining companies committed to a new ICMM framework on how to further enhance the safe management of tailings dams.
“The review did not cover how or why the Samarco tailings dam failed, but takes lessons from the tragic event as well as from other tailing dam failures. It finds that a higher level of governance and assurance is key to confirming existing safety standards are implemented consistently.”
Coverage in main stream business and mining news has been sparse and without enthusiasm, analysis or comment.
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