environmental management system implementation in the mining industry: a key to achieving cleaner...

Ž .Int. J. Miner. Process. 64 2002 19–41www.elsevier.comrlocaterijminpro

Environmental management system implementationin the mining industry: a key to achieving

cleaner production

Gavin Hilson a,), Vishal Nayee b

a ( )EnÕironmental Policy and Management Group EPMG , Imperial College Centre for EnÕironmentalTechnology, Royal School of Mines, Prince Consort Road, London SW7 2BP, UK

b Freudenberg Management Consultants Inc., 4057 Jefton Crescent, Mississauga, Ontario, Canada L5L 1Z2

Received 20 September 2000; received in revised form 5 July 2001; accepted 5 July 2001

Abstract

This article examines the business practicality of integrating an environmental managementŽ .system EMS into mining and related operations, describes how it can contribute to cleaner

Ž .production CP in the industry, and provides guidelines to facilitate implementation. An EMS,which is the component of the overall management system that includes organizational proce-dures, environmental responsibilities, and processes, can help a mining company comply withenvironmental regulations, identify technical and economic benefits, and ensure that corporate

Ž .environmental policies are adopted and followed. To date, a number of multinational miningcorporations—namely, the companies with economical and technological flexibility—have imple-mented comprehensive EMSs at sites, the key in such cases being the formation of workingpartnerships with administrative bodies and international organizations. A number of other minesites worldwide, however, despite having important environmental management practices such asaudits and policies in place, have received insufficient assistance andror simply lack the requisiteresources to integrate an effective EMS into operations. The article sketches a series of guidelinesfor mining companies keen on adopting comprehensive EMSs at sites, and argues that to facilitatewidespread EMS implementation throughout the industry, expanded inputs are needed fromgovernments, international environmental organizations, educational facilities, and the companiesthemselves. More specifically, regional governments must provide assistance to the more re-source-deficient operations, local universities must provide the necessary EMS educationalassistance to local miners and finance environmental technology demonstration projects, and

) Corresponding author.Ž .E-mail address: [email protected] G. Hilson .

0301-7516r02r$ - see front matter q2002 Elsevier Science B.V. All rights reserved.Ž .PII: S0301-7516 01 00071-0

( )G. Hilson, V. Nayeer Int. J. Miner. Process. 64 2002 19–4120

international organizations must help disseminate valuable EMS information to mine managersand technical staff. q 2002 Elsevier Science B.V. All rights reserved.

Keywords: environment; efficiency; environmental monitoring

1. Introduction

There is a burgeoning literature that examines in detail the business practicality ofŽ .integrating an environmental management system EMS into industrial operations. In

short, an EMS, which is the component of the overall management system that includesorganizational procedures, environmental responsibilities, and processes, helps an indus-try comply with environmental regulations, identify technical and economic benefits,

Ž .and ensure that environmental policies are adopted and followed Barrow, 1999 . Unlikethe conventional stand-alone environmental auditing and review processes, which tendonly to assess the environmental situation of an enterprise at the time at which they arecarried out, an EMS ensures that an organization’s environmental targets and objectivesare being effectively pursued. In fact, an EMS links audits, reviews, and other importantenvironmental management processes through a network of management actions, proce-dures, documentations, and records, and is designed with the purpose of promotingcontinuous environmental improvement.

In the case of mining and allied operations, which are typically confronted withserious environmental complications and face the challenge of having to satisfy adiverse group of stakeholder demands, the implementation of an EMS is a necessary

Ž . Žstep toward achieving industrial cleaner production CP . Several mines worldwide see,.e.g. WMC, 2001; Homestake Mining, 2001; Delta Gold, 2001 already have a compre-

hensive EMS in place, and in many cases, management credits it as being a principalŽfactor behind industrial environmental improvements see, e.g. Cambior, 2000; Noranda,

.2001 . Further, it has helped to put many of these operations in a better position toanticipate problems with waste and avoid costly environmental cleanup. Some mining

Ž .companies see, e.g. Falconbridge, 2000; Rio Tinto, 2001 have even gone one stepfurther by obtaining international EMS certification—in most cases, that of the Interna-

Ž .tional Standards Organization ISO , ISO 14001—at selected properties, which requiresthat specific procedures be in place for environmental monitoring, assessment andmeasurement purposes.

The majority of mines that have implemented a comprehensive EMS, certified oruncertified, are owned wholly or partly by multinational corporations, which have thefinancial and technological flexibility to ascertain its precise application and potentialbusiness benefits, and have the means to readily integrate it into industrial operations.What tends to be overlooked, however, is the fact that a number of other miningproperties already have in place important system elements and management proceduresthat would allow for the convenient incorporation of environmental issues and eventualimplementation of an EMS. For example, many sites have an environmental officer thatis responsible for ensuring compliance with set environmental regulations. In addition, ata number of mines, environmental audits, impact appraisals and reviews are conductedperiodically to assess environmental performance. Multinational mining companies have

( )G. Hilson, V. Nayeer Int. J. Miner. Process. 64 2002 19–41 21

already taken these and other existing environmental elements, along with newlydeveloped environmental strategies, and have designed and implemented comprehensiveEMSs at properties around the globe. The remaining companies, due to a shortage offinancial, technological, and informational resources, have not, and therefore requireassistance for effective EMS design and integration. An increased input from govern-mental groups, educational facilities, and international organizations, however, couldhelp management of these properties design comprehensive EMSs, and hence contributeto prolonged CP in what has long been perceived as one of the world’s most pollutingindustries.

The purpose of this paper is to examine in detail the applications and potentialbenefits of a mining EMS, and to provide guidance to facilitate its implementation. Thepaper begins by providing a general overview of the utility of EMSs in industry. Next,the paper discusses the business practicality of integrating an EMS into mining andrelated industrial operations, and outlines guidelines for implementation. A discussion isthen presented that profiles some of the steps taken by the Canadian and Australiangovernments to facilitate improved environmental management in their mining indus-tries, along with some of the recent efforts made by individual Canadian and Australiancompanies to implement EMSs at mines. The paper concludes by prescribing somerecommendations that could improve the overall quality of existing mining EMSs, andwhich would further assist other mine properties in implementing practical EMSdesigns.

( )2. Utility of an environmental management system EMS

Ž .An environmental management system EMS is a set of organizational procedures,responsibilities, processes, and necessary means to implement corporate environmental

Ž .policies Begley, 1996 , and is a component of management that features organizationalŽ .structure, planning activities, practices and resources for development Fresner, 1998 .

Taken simply, an EMS is an industrial tool that enables an organization to systematicallycontrol its level of environmental performance, and which helps management identifypotential environmental impacts arising from activities, set appropriate environmentalobjectives, establish programs to achieve corporate environmental goals, and reviewactivities to ensure that corporate environmental policy objectives are being properly

Ž .carried out Bergeron, 1997 . In recent years, international EMS standards—mostŽ .notably those of the International Standards Organization ISO 14001 —have emerged

that serve as guidance for companies seeking to implement an EMS; a wide range ofenvironmentally progressive industries have since implemented certified EMSs. How-ever, as is explained in this section of the paper, an EMS does not necessarily have to becertified to be effective, but must feature the necessary environmental management toolsfor CP and address polluting areas of operation.

( ) ( )2.1. EnÕironmental management systems EMSs and cleaner production CP

Ž .It is important to first clarify that a de facto definition of cleaner production CPdoes not exist simply because it does not involve the incorporation of a clear-cut set of


generic technologies, and that its technical components may be sector- or even firm-Ž .specific Christie et al., 1995 . One of the earliest and perhaps most referenced definition

Ž .is that of the United Nations Environmental Program UNEP , which defines CP as Athecontinuous application of an integrated preventive environmental strategyB that requiresAchanging attitudes, responsible environmental management and evaluating technology

Ž .optionsB UNEP, 2001 . A number of other general definitions have long since emergedŽ . Ž .e.g. Huisingh and Baas, 1991; Jackson, 1994; Wang, 1999 , as well as industrial

Ž .context-specific interpretations e.g. Vanselaar, 1995; Getzner, 1999; Van Berkel, 1999that tend to address certain technology andror training components. Because of theindustrial specificity of this paper, no definition found in the literature can be adopted;therefore, for the purposes of the discussion that follows, CP is defined as a superiorlevel of environmental performance, which can only be achieved through improvedstrategy and housekeeping, sound process control, optimized plant layout, and theimplementation of efficient management techniques.

Attaining CP requires adopting an improved managerial strategy—namely a AlateralŽ .thinking approachB Christie et al., 1995 —and implementing processes and products

that are designed from their inception to minimize risks to the environment and humanhealth.

It is argued in this paper that implementation of a well-crafted EMS is a key toachieving CP because it features elements that facilitate environmental improvements,and helps to coordinate the individual industrial technological and managerial processes

Ž .capable of contributing to improved environmental performance. Whether within theframework of a specific standard or scheme, or as an independent initiative within aspecific organization, the EMS is a major influence on business thinking and attitudes to

Ž .the management of environmental matters Hunt and Johnson, 1995 , and in promotingŽ .further environmental improvements in a wide range of industrial areas see Fig. 1 .

Further, it can stimulate a gradual shift from conventional, often ineffective, end-of-pipepollution control approaches toward cleaner technologies and improved process, and

Ž .product designs that utilize resources more efficiently Bergeron, 1997 .Integrating important system elements into an organized setup improves the environ-

Ž .mental efficiency of operations, which in turn leads to CP Hillary, 1997 . For example,to monitor environmental performance, the EMS standards mandate that audits andreviews be completed on a regular basis. The results obtained play a pivotal role in themanagement system as they provide the organization with a track record of environmen-tal performance. As junior management and staff acknowledge deficiencies within thecompany, they are communicated to senior management and then remedied. Perhapsmore significant than each individual system element, however, is the fact that effectivedesign and implementation of an EMS involves the participation and cooperation ofeach staff member. It is therefore critical for management to communicate and motivateeach employee, and identify his or her function in the EMS.

2.2. International EMS certification

The management of a number of companies worldwide has gone one step further toobtain international certification for EMSs. The most common and widely recognized


Ž .Fig. 1. Environmental management systems and CP modified from Russ, 1997 .

EMS certification is ISO 14001, which is awarded by ISO-accredited certificationbodies. The main advantage of the standard is that it is homogenous internationally, andthat globally, individuals are familiar with its process of certification, along with theAqualitiesB of an ISO 14001 certified company; a certified EMS is one that would passcertification standards measured by an independent body. Simply put, an ISO 14001certified mining company in North America would have a similar EMS to that of amining company in South Africa. Certification can be expensive, however, and therequirements for conformity can be beyond the budgetary means of a small company. Infact, given the costs of registration, combined with the costs of consultancy expertise, itis unrealistic to assume that any small operation—in this case, a mine—would be ableto certify its EMS without outside assistance.


It is important to clarify that an EMS need not be certified to be effective, and thatmany mining companies worldwide have opted only to use the ISO standards as generalguidelines for developing EMSs at sites. In short, a company does not require certifica-tion to have an effective EMS in place, but that management should follow ISO 14001when designing and implementing EMSs because it targets the prevention of negativeenvironmental impacts, emphasizes environmentally friendly product design, encouragessolid documentation, and is overall, a proactive preventative strategy that mandatescompanies to set objectives and targets, and to incorporate strategies for continual

Ž .environmental improvements Hammer, 1997 . However, ISO certification does notenable an outside party to determine if one organization is more Aeco-friendlyB thananother. More to the point, a certified EMS does not guarantee improvement: ISO 14001is merely a framework, and an organization must have the pertinent elements in place toensure that it effectively functions.

As already noted, occasionally, a company may be unable to invest the capital neededfor ISO 14001 certification, in which case it commonly follows the ISO principles whendeveloping and implementing an EMS. An issue more specific to mining, however, isthe fact that a number of companies have elected not to adopt an ISO 14001 certifiedEMS because it has limited utility in marketing and regulatory compliance strategy. TheISO standards are increasingly proving to be an integral marketing tool in the manufac-turing sector because of escalated demands for green consumerism. In fact, it could beeffectively argued that nowadays, the backbone of green consumerism is an ISOcertified EMS. The management of a mining company, on the other hand, is largelyunconcerned with ISO certification of sites because it does not provide anywhere nearthe Acompetitive edgeB it gives to companies operating within the secondary and tertiaryindustrial sectors. However, as is explained in the next section of this paper, in order tobe effective, a mining EMS must feature several key elements, and companies mustfollow specific guidelines for proper implementation.

3. Components of a mining EMS and benefits to implementation

Mining and allied industries are confronted with the challenge of having to control awide range of potentially serious environmental problems such as acid mine drainageŽ .AMD , chronic soil erosion, tailings contamination, and heavy metals overloading.Many mines face additional complications in the form of toxic chemical additives suchas mercury, cyanide, and surfactants, which are often used in mineral concentrationprocesses. Given the need to perform accordingly in regulatory environments, combinedwith a need to satisfy the demands of community and external stakeholder groups, it isin the best interest of mining operations to ensure that environmental impacts areminimized. To systematically address the environmental effects of operations, a numberof mining companies have implemented EMSs, many of which predate the publication

Ž .of notable international EMS guidelines Richards, 1996 . The discussion that followsoutlines the necessary features of a mining EMS, its benefits, and the steps that must befollowed for effective implementation.


3.1. Requisite features of a mining EMS

The key to implementing a successful mining EMS is a full commitment byŽ .management. As explained by the EPA 1995 , top, middle, and junior management

must make this commitment, and it must be evident to the workforce. The mining EMSalone can only potentially add another dimension, as its effectiveness as a tool for CP iscontingent upon employee awareness and the actions taken to minimize environmentaland social impacts. To successfully integrate a mining EMS into operations, manage-ment must address the following:

Ž .1 Identify appropriate procedures, reports and meetings—essentially, the skeletalframework of the EMS. Tasks must be assigned upfront to various individuals andgroups and each process in the system must be identified.

Ž .2 Provide employees and management with immediate EMS training—implement-ing an EMS requires input from workers at all levels of operation. Each must beeducated and trained on important environmental management system procedures suchas auditing and reporting.

Ž .3 Familiarize employees with the system—it is important to explain to employeeswhy the EMS has been adopted, and what the merits to implementation are. A thoroughunderstanding of its applications and benefits are keys to encouraging employees to usethe system.

Ž .4 Ensure that EMS-related problems are remedied quickly—all systems experienceproblems at one point or another. Contingency plans must therefore be drafted in theevent of an EMS AmalfunctionB. It is essential that management identifies priorityproblems, and provides a listing of remedial strategies to those problems.

Ž .5 Ensuring that people have sufficient time and resources to implement theEMS—the key is to keep the mining EMS simple and brief, specifically something thatcan be maintained with relative ease. Basic education is essential because employeeswill be green, and must therefore be trained incrementally; the EMS can become morecomplex in time with further training.

A mining EMS can cover all aspects of operations, from exploration to closure.Unfortunately, international standards, which are designed generically and, hence, onlyprovide general guidance, lend little in the way of methods to implement a practicalindustry-specific EMS—in this case, for mining. It is suggested here, however, that an

Žeffective mining EMS features the following key components adapted from Industry.and Environment, 1997 : an organizational commitment to mining environmental man-

agement; a corporate mining environmental policy that addresses the environmentalgoals of the mine; environmental impact assessment procedures for tailings manage-ment, reclamation and chemical usage; strategies for community mine consultation and

Žinvolvement on important environmental issues; objectives and targets corporate perfor-. Žmance indicators for each environmental problem acid mine drainage, metals, chemical

.effluents, etc. ; procedures for documentation, and records of remediation and mitigationefforts; policies for operational and emergency procedures at the mine; environmentaltraining, including topical contents and procedures; procedures for environmental im-pact, regulatory and legal compliance, and environmental review audits; and methods foremission and performance monitoring and measurement. Regular reviews of the EMS


must also be conducted to ensure that each element is designed for continuousenvironmental improvement, and to determine if modifications are required. Internally, areview group should be formed—consisting of people responsible for environmentalmanagement and stakeholder relations—that should periodically assess the applicabilityof EMS procedures, the adequacy of reporting systems, and the fittingness of delegatedresponsibilities. Additionally, an external expert should be hired to regularly audit theEMS, which, more often than not, leads to more effective solutions and the identification

Ž .of potential problems that were overlooked initially because of familiarity EPA, 1995 .Table 1 outlines more clearly how each mining EMS component contributes to CP.

A number of mining companies, particularly those headquartered in developedcountries, have implemented EMSs at sites around the world. Although adherence tointernational standards, generally, has helped the industry develop practical EMSdesigns, a number of these companies appear to have designed and implementedcomprehensive EMSs that foster CP with minimal aid from guidelines such as ISO14000. In each case, management has followed an environmental action plan that

Ž .features a number of tasks, including adapted from Wilkinson, 1997 : establishingrealistic response time frames and committing to timely action at every stage of anymining decision-making process; establishing a mine permitting process for pollutants;

Žensuring that environmental decisions are based upon best available practices using.guidance from mining associations and governments ; allowing qualified and experi-

enced mining professionals to make reasoned judgments about environmental manage-ment practices, technologies and auditing procedures; providing technical training andprofessional mentors for administrators; establishing sustained environmental qualityand quality of life as key evaluation criteria for mining environmental decisions; andcommitting to making decisions that meet established environmental and socioeconomicgoals while resolving public issues. Once each of these key issues has been properlyaddressed, mine management must design the EMS to feature most or all of thecomponents outlined in Table 1.

3.2. Benefits to implementing a mining EMS

Given the wide range of environmental complications that can result from mining andrelated processes, successful integration of comprehensive EMSs into operations couldserve to significantly benefit this industrial sector by better enabling companies toaddress environmental concerns through proper allocation of resources, assignment ofresponsibilities, and ongoing evaluation of practices, procedures and processes. Al-though a number of authors have outlined the specific advantages to implementing an

Ž .EMS, for mines, there are three basic benefits adopted from Schiffman et al., 1997 .First, with an EMS, mine personnel are better able to systematically examine allindustrial processes and activities for their potential impacts on the environment, identifylegal requirements, and to evaluate alternatives and hidden costs. When a companyintroduces an EMS, it establishes a corporate environmental policy that reflects thecommitment of top management to comply with applicable laws and to continuous

Ž .environmental improvement Begley, 1996 . Its specificity requires management to


Table 1Ž .Requisite components of a mining EMS and potential role s in CP

Ž .Mining EMS component Contribution s to CP

vOrganizational commitment The most significant feature of a mining EMS,without which the EMS’s potential benefits maynot be fully realized.v Serves to provide direction for all levels of operation.vEnvironmental policy Serves to inform the community and its employees aboutthe company’s intentions with respectto the environment.vEnvironmental impact assessment Delineates strategies to minimize and control adverseenvironmental effects.v Determines the initial objectives, targets andprocedures that the min must achieve or implement.vCommunity consultation Creates trust and confidence with relevantstakeholder groups.v May lead to decrease in public criticisms andadverse publicity.vObjectives and targets Aiming for best practice or CP requires establishingprecise targets and objectives, which facilitateenvironmental improvement.vEnvironmental management plan Details the methods the mine will use to achievethe stated environmental targets and objectives.vDocumentation Serves as a reference for both management and staff.vOperational and emergency procedures Integral planning strategies that outline what mustbe done in the event of an environmental accident.v Assists in worker training, and allows individualworkers experiences to be shared with personnel.vResponsibilities and reporting structure Ensures that practices are carried out in atimely fashion.vTraining Enhances environmental awareness.v Informs staff of CP goals.v Provides the workforce with the skills andmotivation to implement an EMS.vEnvironmental impact, compliance and Serve to identify existing and potential problems.vreview audits Assess the impacts of waste discharges on theenvironment and community.v Determine the quality of environmental objectives,and hence the desired outcomes of the EMS.vEmission and performance monitoring Regular reviews of the company’s environmentalperformance ensures that procedures are appropriate,due diligence requirements are satisfied, andensures that environmental goals are being attained.

outline all applicable legislative requirements and ensure that the company is continuallyup-to-date on all legal amendments—requirements that force senior management to beaware of the most pertinent legislation.

Once mine management has recognized the legislative requirements, the EMS canthen be used as guidance in developing targets and goals to ensure that those legal


requirements are continually being met. For example, if the mine is subject to a specificwater chemical discharge limit, the EMS would first help to identify the legal require-ment, and management would then develop goals, targets and action plans to ensurecompliance. In short, the EMS provides staff with a better understanding of environmen-tal impacts, a thorough knowledge of the pertinent legislature, and a proactive actionplan to ensure that the required targets are met.

The second major benefit is that a mining EMS makes practical business sense, anddespite potentially being costly in the beginning, usually pays for itself over the longterm through reduced operating costs and improved efficiency1. Thanks in large part to a

Ž .burgeoning literature Crognale, 1997; Cochin, 1998; Voien, 1998; Bhat, 1999 , therelationship between environmental management AtoolsB—namely audits, permittingsystems, reviews, life-cycle assessments and environmental impact statements—andreduced corporate costs is now well known. For example, environmental audits, whichare viewed as crucial elements in coordinated ongoing environmental protection pro-grams, help to safeguard the environment, and increase employee awareness of environ-

Ž .mental policies and responsibilities Bhat, 1993 , keys to preventing costly environmen-tal accidents. Similarly, life-cycle assessments, which are simply analytical tools thatevaluate the environmental consequences of a product, process, or activity across itsentire life cycle, are increasingly being used by industry for the purpose of obtainingcomprehensive perspectives of the interactions between an activity and the environment,and providing a method to systematically identify opportunities for improvement and

Ž .reducing capital costs Gloria et al., 1995 . In short, by integrating these and relatedAtoolsB into its EMS, a mining operation puts itself in a better position to anticipateproblems with waste, avoid unnecessary cleanup costs and regulatory fines, reduce itsdischarges of toxic effluent, avoid tailings pond spills and leaks, and minimize usage ofraw materials.

The third major benefit is that implementation of a mining EMS enables an operationto plan for environmental issues and shift from a AreactiveB environmental mode, whereit continuously responds to regulatory AfiresB, to a AproactiveB mode. For mines, such ashift can play a pivotal role in improving relations with regulatory bodies, communitygroups, and other external stakeholder parties, which often demand a strong corporatecommitment to environmental issues. Interestingly, there is evidence that courts, regula-tory agencies, enforcement groups, municipalities, lending institutions, and financialgroups view activity that responds to EMS conformance requirements as an indication of

Ž .diligence Plaut, 1998 . Quite simply, if a mining company demonstrates that it is awareof its legislative requirements, and if it has goals, targets, and action plans in place tocommit to compliance, there is less chance for infraction. Perhaps more significantly,however, is that such can improve relations with community groups, a major challenge

Ž .for any operating mine. As Rondinelli and Berry 2000 explain, by implementing anEMS, a company has a greater chance of achieving positive relations with stakeholder

1 As was alluded to earlier, a mining company lacking the requisite resources would be unable to implementthe EMS without outside assistance but with financial support, could reap major economic rewards over thelong term as a result of improved environmental performance that could offset these initial expenses.


groups, which are more likely to assume that it has proactively ensured that it hasreduced environmental exposure, that it is in compliance with governmental legislation,and that it has taken the necessary steps to ensure that it has minimized its overall risk tothe environment. Building a strong reputation for corporate citizenship through EMSimplementation can benefit the mining company by granting it greater access to capital,reducing its operating costs, improving its financial performance, and enhancing itsbrand image.

3.3. Guidelines to implementing a comprehensiÕe mining EMS

Few mines will start from zero when crafting their EMS, and once the core elementsand important subsidiary components are in place, a four-step framework must be

Ž .followed for effective implementation adopted from Kryger and Dyndgaard, 2000 .After important corporate environmental policies are drafted that outline the environ-mental objectives of the mine, and environmental reviews are conducted to determineinitial environmental performance, management must first begin a critical planningstage. Here, based upon conclusions drawn from audits, all relevant environmentalaspects must be identified along with the existing environmental strengths and weak-nesses of the mine, and plans must be devised to outline how the mine intends torespond to current and anticipated environmental issues from both a technological andadministrative perspective. Further, at this stage, the environmental responsibilities of alllevels of the workforce must be assigned, and external stakeholder parties and govern-mental groups must be informed of corporate goals and strategies. The mine must thenproceed to determine and develop necessary procedures, and commit whatever resourcesare needed to implement the corporate environmental strategy.

The second step is the EMS action plan and is principally a task for top management.It involves assessing corporate environmental objectives, analyzing environmental poli-cies, assigning final responsibilities, and determining EMS implementation actions. As

Ž .Hale 1995 explains, many enterprises mistakenly begin implementation immediatelyfollowing an initial environmental diagnosis without critically reviewing objectives andpolicies. Top management must therefore first refine pertinent environmental objectivesand actions, and should conduct multiple environmental reviews before implementingthe EMS. Further, it is practical for management to develop some kind of environmentalreporting scheme at this stage to keep stakeholder parties informed about the overallstructure of the EMS, its goals, and the responsibilities of selected personnel. From thispoint onward, the onus is on the miners and mine operators to ensure that responsible

Ž .actions are carried out within the constraints of corporate commitments Nicholls, 1997 .The third step is eÕaluation, the primary purpose of which is to assess the mine’s

actual environmental performance against the stated environmental polices, objectivesand targets that comprise the EMS action plan. Once important procedures have beenimplemented, mine management must continually assess the effectiveness of each. Forexample, are these techniques, both individually and collectively, improving the environ-mental efficiency of the mine and hence contributing to CP? Further, how can certainprocedures be improved? Evaluation can be accomplished using the rudimentary audit-ing strategies, or by using more advanced monitoring and control tools. What must also


be developed at this stage is a practical mining EMS training program. A number ofŽ .authors e.g. Aboulnag, 1998; Dodd, 1997 suggest that companies should implement an

EMS training plan concurrently with the EMS action plan. Given the potentially widerange of training required for all levels of staff at a mine, however, mine management isadvised to implement the training program after the EMS is fully evaluated forweaknesses, although there should be some idea of a framework for a practical mining

Fig. 2. Suggested guidelines to implementing a practical mining EMS.


EMS training program from the outset. By providing only minimal training up until theinitial evaluation, significant time and money could be saved since critical environmen-tal and operational issues are almost always overlooked from the beginning. At theconclusion of important evaluations, the EMS training program should then be fullyimplemented, and all outside environmental training expertise should be hired.

The fourth and final stage is correctiÕe action. As indicated earlier, the goal of anEMS that fosters CP is continuous environmental improvement, which requires manage-ment to ensure that the EMS continues to be responsive to changing circumstances suchas new scientific knowledge, changing national and international markets for products,currency fluctuations, marked changes in the environmental regulatory arena, or changesin stakeholder demands. A periodic environmental review will enable management toascertain what major adjustments need to be made to the mining EMS. The primary aimat this point is to continue improving the mine’s environmental performance, whether itmeans making adjustments to existing programs and policies, implementing moreenvironmentally sound technology, or introducing a new process entirely. As Kryger and

Ž .Dyndgaard 2000 explain, the AimprovementB can be as simple as exercising bettercontrol of an existing procedure, developing a more improved technique, or a redefiningof environmental goals and objectives. Fig. 2 provides a concise overview of the fourimportant stages required for successful implementation of a mining EMS, and high-lights the major activities of each.

In sum, these four steps—critical planning, development of an action plan, evalua-tion, and corrective action—must be followed to implement a mining EMS.

4. Discussion: examples from Canada and Australia

The paper thus far has discussed the characteristics and benefits of a mining EMS.Further, it has examined how it can contribute to CP in the industry, and has providedguidelines to facilitate implementation. In this section of the paper, some examples areprovided that highlight how the actions of governments have helped to facilitate miningEMS implementation. Some of the experiences selected multinational mining companieshave had in implementing EMSs at sites are also discussed.

It is important to first note that in a number of countries, governments have helped tosteer mining companies toward improved environmental management; more specifically,

Ž .they have laid important EMS groundwork for the industry. For example, in Canada,Ž .the government has long worked with the Mining Association of Canada MAC , the

national body of the Canadian mining industry, to provide guidance to Canadian miningcompanies in the area of environmental management. MAC was the first national miningassociation to develop an environmental policy, which was released in 1989 and updatedin 1995, and in 1996, produced an accompanying Environmental Management Frame-work. Collectively, the policy and the Framework have provided much needed guidancefor implementing a mining EMS, and of the companies that have subscribed to both,most have improved environmentally in a number of key areas including energyefficiency, water management, technology utilization, pollution, community communica-

Ž .tion and research Miller, 1997; MAC, 1998 .


Ž .A study by Sanchez 1998 confirms that a number of Canadian mining companies inthe nonferrous sector have begun proactively implementing an EMS because of in-creased governmental input, regulation and pressure. Another study undertaken by

Ž .Annandale 2000 , in which the executives of 34 different Canadian mining companieswere interviewed, indicates that organizational learning, types of regulation, stakeholderinfluence, jurisdictional culture, and corporate culture are primary reasons why manyŽ .Canadian mining companies have taken proactive stances toward environmentalregulations. For example, Noranda, an international mining and metals company withoperations and offices in 20 countries, following 12 years of comprehensive company-wide auditing, completely redesigned its corporate safety and health auditing system. As

Ž .explained in its most recent annual environmental report Noranda, 1999 , the traditionalsystem, which was based on cyclical compliance-based audits undertaken every 3 yearsby teams of Noranda auditors, was replaced with a new Environment, Safety and HealthAssurance Process that better integrates auditing with each operation’s environment,

Ž .safety and health ESH management framework. Based upon ISO 14001 principles, itrequires each operation to develop and implement a framework that will allow it to carryout its commitment to continually improve in the areas of environment, safety andhealth. To facilitate implementation, Noranda operations have been divided into threetiers. Tier One operations, principally those with existing environment, safety and health

Ž .management ESH frameworks, are required to further develop self-evaluation proce-dures, to train employees to conduct these evaluations, and report on the results.Throughout 1999, external teams of Noranda auditors evaluated these systems todetermine if they had been properly implemented and were functioning accordingly. TierTwo operations are required to develop the elements of an ESH management frameworkand, if necessary, conduct a gap analysis to identify any issues requiring attention;management framework audits began at these operations in 2000. Tier Three operationsinclude those sites that are either new to Noranda or still require support in developingand implementing a management framework. The traditional auditing program will bemaintained for these operations as the transition toward the implementation of an ESHmanagement framework continues.

In another case, Falconbridge, a Canadian producer of nickel, copper, cobalt, andplatinum group metals, 50.1% of which is now owned by Noranda, has set a goal tohave all operations implement an ISO 14001 certified EMS by the end of 2001. ItsFalcondo plant in the Dominican Republic, in 1999, became the first mine operation inthe world to achieve ISO certification. Management laid important groundwork for itssite-specific EMSs with implementation of a Code of Ethics, and a Risk ManagementFramework. Management contends that integrating ISO certified EMSs into operationshelps to minimize pollution, improve monitoring, and enables better measurement of

Ž .impacts Falconbridge, 2000 . Similarly, Rio Algom, a Toronto-based producer ofcopper, uranium, molybdenum, and coal, with mines in Canada, the United States,

Ž .Chile, and Argentina, now has in place an environment, health and safety EHSmanagement system. The EHS system was finalized in 1999, and supporting baselineassessment and auditing procedures were developed at their four wholly owned sites:Atlas Ideal Metals, Vincent Metals Goods, Cerro Colorado, and Rio Algom Mining. Amain reason for developing the EHS management system was to assure stakeholders that


the company is identifying, managing and containing EHS risk. Management claims thateach site-specific EHS management system will improve corporate environmental

Ž .management as well as socioeconomic relations Rio Algom, 1999, 2000 . One finalexample is ALCAN Aluminum, the world’s second leading producer of aluminum. Thecompany’s first step toward implementing an EMS was in 1978, when it first outlined anenvironmental commitment that later led to the development of a corporate environmen-

Žtal policy. As is explained in its most recent annual environmental report ALCAN,.2000 , with the creation of the Environmental Committee of the Board of Directors in

1992, ALCAN formalized the incorporation of environmental management into thecompany’s highest level of decision-making. ALCAN’s Lochaber smelter at FortWilliam, Scotland became the first UK smelter to satisfy the requirements for BS7750EMS standards. Moreover, its work with the ISO has been a key building block indeveloping a system that fits its organization while sharing the elements common to allinternationally: a commitment by employees to continual improvement; a determinationto capitalize on aluminum’s unique properties; and a pledge to make the environment an

Ž .equal among other business objectives. ALCAN, 2000 . A great number of otherCanadian mining companies including Placer Dome, INCO, Barrick Gold and Teck haveaccomplished similar feats in the area of EMS design and implementation.

The Australian case, however, perhaps best exemplifies the impact a government canhave in facilitating improved mining environmental management and ultimately,widespread industrial EMS implementation. The Minerals Council of Australia—thenational association of the Australian minerals industry—through launching a number ofprojects in several key areas of mining environmental management, has made thegreatest contribution. The most recent effort has been the launching of an environmental

Žmanagement code Australian Minerals Industry Code for Environmental Management,.1998a,b for its mining industry, which marked a significant step toward addressing

environmental performance and public accountability at minerals operations. The Codedid undergo a substantial review process in 1999, which involved extensive consultation,but in 2000, a revised Code was drafted, the signatories to which commit to its

Ž .implementation by Minerals Council of Australia, 2000a :

1. Accepting environmental responsibilities for all actions.2. Strengthening relationships with surrounding mine communities.3. Integrating environmental management into operations.4. Minimizing the environmental impacts of activities.5. Encouraging responsible production and use of products.6. Continually improving environmental performance.7. Communicating environmental performance.

The Australian minerals industry has Aconceived the Code as a way to demonstrateits commitment to excellence in environmental managementB, and contends that itAachieves the twin objectives of improved environmental performance and communica-

Ž .tion of that performance to the communityB Minerals Council of Australia, 2000b .Ž .There are at least 43 signatory companies over 300 operations that have committed to

the new Code because pledging to it could result in a wealth of benefits, none more


important than the increased confidence of Australian regulatory agencies. A commit-ment to the Code also has the potential to help companies increase their standing withinsurers and ethical bodies, helps the industry establish benchmarks of excellence inenvironmental management and helps to transfer environmental technology, and aidssignatories in building strong relations with communities and external stakeholder

Ž .parties Minerals Council of Australia, 1999 . Most importantly, from the perspective ofthe mining EMS, the Code is of enormous utility because it requires signatories toconduct a regular audit of their EMS.

ŽIn August 1998, an Interim Guidance Note was published Australian Minerals.Industry Code for Environmental Management, 1998a,b to aid companies implement

the principles, systems, and processes of the Australian Minerals Industry Code forEnvironmental Management. The critical areas covered include:

1. Policy and commitment: determine if the company has formally adopted anenvironmental policy consistent with the Code; evaluate implementation efforts;and evaluate the environmental management responsibilities of various staff.

2. Organization and resources: review the management structure to determine if it isrationally designed and evaluate the responsibilities of staff.

3. Communications and public policyroutreach: interview staff and managers todetermine if systems are in place for reporting pertinent environmental informa-tion, and evaluate the quality and effectiveness of existing informationrcom-munication systems.

4. Environmental issues and risks: determine if the organization has the appropriatesystems in place to identify, characterize and evaluate the significance of therelevant environmental issues and risks associated with its activities.

5. Legal and other requirements: verify through interviewing that the organizationhas systems in place to ensure compliance with regulatory demands.

6. Objectives and targets: determine whether the organization has established a setof environmental objectives and targets, and has informed staff of its goals.

7. Management programs and plans: evaluate the quality of the management pro-Ž .grams and plans the organization has implemented or is planning to implement

to meet its environmental objectives and targets.8. Operational control: evaluate standard operating procedures to verify that the

organization has provided clear guidance to its managing operations and otheractivities that have the potential to impede progress toward environmental targetsand goals.

9. Training, awareness and competence: simply determine whether the company hasidentified training needs in key environmental areas, that it has determined thescope of the training, and that it has hired the appropriate training instructors.

10. Emergency preparedness and response: determine if the organization has fittingresponse procedures in place, and the extent to which employees are involved indeveloping contingency plans.

11. Documentation and records: determine whether the organization has documentedŽ .the core elements of the mining EMS e.g. policy, risks, targets, programs, etc. ,


and verify that appropriate measures are in place to ensure continuous environ-mental improvement.

12. Performance assessment and improvement: verify that the organization conductscomprehensive environmental audits.

The audit must Averify that management and employee roles are clearly defined, thatsenior managers are assigned responsibility to oversee compliance and establish imple-mentation plans for the EMS, and determine whether environmental staff are conducting

Žroutine site inspections and tracking legalrregulatory requirementsB Australian Miner-.als Industry Code for Environmental Management, 1998a,b . From the standpoint of CP,

Ž .signatories pledge to continuous environmental improvement in operations throughAimplementing management strategies to meet current and anticipated performancestandards, and regularly reviewing objectives in the light of changing needs and

ŽexpectationsB Australian Minerals Industry Code for Environmental Management,.1998a,b . Management, therefore, must audit to assess openness to clean technology

transfer, contribution to, and awareness of scientific research, and must evaluate whetherperformance targets are consistent with the objectives for continual improvement.

These efforts in turn have helped several Australian mining companies improve theenvironmental management of operations, and have helped guide them in implementingEMSs. For example, Australian Goldfields, a founding signatory to the AustralianMinerals Industry Code for Environmental Management, began drafting EMS require-ments in 1998 and 1999 using the ISO 14000 series as guidance. As is noted in their

Ž .annual environmental report Goldfields, 1999 , each mine will eventually have its ownEMS, although the present level of development and implementation varies across thesites: the development of the EMS at its Kundana property commenced in August 1999,whereas the Henty property had already drafted an EMS in October 1998 that wasscheduled for completion in November 1999. Although at this point, it is very early toshow direct links between the EMS and improved environmental performance, it is clearfrom the design of each that in time, CP will be achieved. At the Henty site, forexample, employees and contractors must complete an environmental training coursepresented by personnel that includes an introductory video, an explanation of environ-mental aspects and regulatory requirements, and a site tour. Further, employees areencouraged to participate in daily production and meetings, and small awards are givento people who perform AbeyondB expectations. At the Paddington site, an environmentalintroduction is given, ongoing training is incorporated into an awareness program, andemployees must complete a weekly allotment of training and education. Environmentalaffirmations are included in communication meetings as well as part of the awarenessprogram. In another case, Normandy Mining, which is Australia’s leading producer ofgold, is modifying several of its EMS components to more heavily account for CP andcontinuous environmental improvement. During the past 2 years, the corporate auditingand assessment procedure has been significantly restructured, and now includes anannual five-star assessment process, three-yearly detailed audits, three-yearly compli-ance audits, and an annual verification process. The assessment process is now consis-tent with ISO 14001. Additionally, at selected sites, management is in the process forcombining environment, health and safety management systems.


The management of a number of other Australian companies, however, has onlyrecently realized the practicality of a mining EMS. For example, WMC, an Australian-based minerals producer with business interests in 19 countries, and the world’s thirdlargest producer of nickel, has only very recently begun developing an EMS based uponthe international standard ISO 14001. Further, the company only recently incorporatedthe requirements of the Australian Minerals Industry Code for Environmental Manage-ment. These new guidelines were developed primarily to help environmental profession-als advise operation managers on environmental issues more accordingly, and to assurethe executive that environmental issues are being handled responsible. Although atdifferent stages in introducing the system across operations, the goal is to have in place a

Ž .comprehensive setup by December 2000 WMC, 1998 . Similarly, MIM Holdings, anAustralian-based producer of copper, gold, zinc–lead–silver, and coal, has pledged tothe Australian Minerals Industry Code for Environmental Management, but is still in thedevelopmental stage with its EMS. Management is basing the system upon ISO 14001principles, and at each site, is planning to allocate employee responsibilities in site

Ž .management compliance registers MIM, 1999 . Kalgororlie Consolidated Gold Mines,which manages Australia’s largest gold mining and milling complex, is also in theprocess of developing an EMS based upon ISO 14001 principles, and in 1997, signed

Žonto the Australian Minerals Industry Code for Environmental Management Kalgoorlie,.1999 .

In summary, it has largely been the efforts of government that has made EMSimplementation possible at several Canadian and Australian mining properties. Byconstantly pressuring the industry to improve environmentally, many of the necessarypreliminary steps for EMS design were taken, after which mine management beganconceptualizing many of the benefits to EMS implementation.

5. Recommendations and conclusions

While the aims of this paper have been to discuss the benefits to implementing amining EMS, to provide guidance to facilitate implementation, and to present practicalaccompanying case study material, it is important to clarify that in order to makewidespread mining EMS implementation a reality, a number of key areas must befurther researched. It is suggested here that with increased government effort, expandedmining industry partnerships with international agencies, and increased input fromacademic and government research units, even the smallest, most resource-deficientmining operations would be in improved positions to implement comprehensive EMSs.First, it is imperative that the methods and techniques used for disseminating vital EMSinformation to Junior mining companies are improved. AJunior miningB, generally, isused as a label for the smaller exploration and mineral processing corporations andoperations of developed countries that are heavily influenced by mineral price fluctua-tions, and are recognized as the most financially volatile and high-risk portion of theindustry. It is therefore particularly challenging for these parties, which lack both themoney and resources to anticipate environmental change, to implement leading-edge


environmental practices. Though selected administrative groups—namely governmentalbodies, mining associations and mining institutes—in large mineral producing nationssuch as Canada, Australia, South Africa, and the United States have successfullycommunicated to multinational corporations the merits of a mining EMS, and in turnhave facilitated and initiated implementation, at the same time, they have neglected toreach these small- and medium-sized mining companies, many of which already haveimportant environmental management tools in place, but obviously lack the finances,educational material and technological know-how to design and implement an effectiveEMS. This group must be equipped with the requisite educational, informational, andtechnological assistance to achieve higher levels of environmental performance. Signifi-cant environmental improvements can be made at these operations if EMSs areimplemented, and governments must bridge information, technologic, and economicgaps, and provide Junior mining operations with the means—namely information andtraining—to design EMSs. Incentives such as tax breaks, levies, payback schemes, andinterest-free loans can be provided to these operations.

A second recommendation, which is applicable to mines of all sizes, is for minemanagement to place greater emphasis on developing and implementing high-qualityŽ .mining EMS training programs. An integral part of any EMS is training because forthe system to work as designed, staff must understand their jobs and how their positionsimpact the environment. Within an EMS, mine management must be trained on acontinual basis to ensure that the most up-to-date information is disseminated to eachemployee. Training could range from education on safety standards, to updates onregulations. Familiarizing employees with environmental issues best prepares the opera-tion to deal with occurrences as they arise. The action plan can involve using the toolsprovided to further prevent environmental hazards, or can simply mean that theemployee contacts officials, fire departments, or advisory bodies. As long as individualsare prepared, however, the chances of any uncontrollable problem occurring areminimized. It is therefore imperative for top management to commit to the design andcontinual improvement of an in-company EMS program that involves the participation

Žof all staff members though it is impractical to assume that mining companies,individually, are capable of improving the quality of their EMS training programs

.without outside input . There could be merit in forging additional partnerships with bothlocal authoritative bodies and international agencies, which have the means of dissemi-nating valuable CP information, and are equipped with professionals capable of design-ing practical EMS training programs. Further, these bodies have the knowledge andcapabilities of financing demonstration and dissemination programs in important areassuch as policy-making, health and safety, environmental technology, and databasemanagement, which, in the end, could serve to improve the quality of any existingmining EMS.

A final recommendation is that governments and the industry itself should encouragewider participation from academic research units in mining EMS research. Given that somany mining academic research units exist, the majority of which already haveenvironmental management research programs in place, it would be beneficial to theindustry if EMS research were incorporated into research agendas. Emphasis should beplaced on EMS training, environmental technology implementation, coursework, envi-


ronmental auditing practices, and education. In fact, it is suggested that universities offerŽ .the following four types of coursework options adapted from Van Berkel, 2000 :

1. Orientation or introductory courses—quintessentially, courses that emphasize thebasic principals of mining environmental management, environmental protectionand regulatory compliance.

2. Environmental integration and disciplinary courses—courses that emphasize theparticular facets of environmental management including, inter alia, training,technology use, auditing and assessment. These courses can be tailored to therequirements of the EMS.

3. Specialist environmental courses—since the EMS mandates that certain personnelŽundertake specialist environmental management tasks e.g. reporting, documenta-

.tion, auditing, etc. , coursework can be designed to train engineers, managers andscientists in these areas.

4. Environment relevant interdisciplinary project work—establishing Ahands-onBtraining courses, whereby trainees engage in fieldwork or are trained outside of theclassroom in the Aindustrial environmentB, gaining first-hand experience aboutvarious EMS responsibilities.

Mines could provide local units with grants to either expand existing departments orto conduct stand-alone studies in exchange for this EMS training and research. Thiswould create a win–win scenario, since mines would receive relevant EMS educationalmaterial, and universities would obtain funding for research.

In conclusion, it has been argued in this paper that implementation of an EMS is akey to achieving CP in the mining industry, since it helps an operation comply withenvironmental regulations, identify technical and economic benefits, and ensure thatcorporate environmental policies are adopted and followed. An EMS features a series oforganizational procedures, environmental responsibilities, and processes that, unlikestand-alone environmental management processes, which tend only to assess the envi-ronmental situation of an enterprise at the time at which they are carried out, effectivelyensure that a mine’s environmental targets and objectives are attained. Although to date,it has been mainly the large mining companies that have implemented EMSs at sites,with increased government effort, expanded mining industry partnerships with interna-tional agencies, and increased input from academic and government research units, eventhe smallest mining operations would be in excellent positions to implement comprehen-sive EMSs.

Acknowledgements

The authors would like to thank Professor Peter King for inviting this review ofenvironmental management systems in the mining industry. The authors would also liketo thank three anonymous reviewers for their helpful commentary on earlier versions ofthis article. Needless to say, any errors this article may contain are the sole responsibilityof the authors.


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