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KEYNOTE ADDRESS: ENVIRONMENTAL AND SUSTAINABILITY ASPECTS OF GOLD MINING 1

IntroductionOne of the significant positive contributors toenvironmental management and sustainability in goldmining is the sound and effective management of cyanide.Cyanide is a key contributor to the efficiency of goldextraction from ore and its optimal use impacts upon safety,health, and environment (SHE) within mining operations.Within the industry, it is debatable whether cyanidemanagement is seen as the most important SHE aspect to beconsidered. However, public perceptions about cyanide arehighly emotive and driven by limited understanding andknowledge of the substance, as well as its use in suicidesand as a genocidal agent during World War II (Arminfo2001–2005, Environment Australia, 2003).

There is a wide-ranging and ongoing debate aboutenvironmental and sustainability issues relating to goldmining. This paper will discuss only some aspects of thisdebate which relate to cyanide management and usage.

Environment and gold miningThe environmental impact of cyanide is highly variable.Cyanide is produced naturally in the environment, bybacteria, algae, fungi, fruits and numerous species of plants,and via incomplete combustion during forest fires andburning of man-made materials such as nylon (InternationalCyanide Management Code for the Gold Mining Industry2006-4). Global cyanide production is estimated to beapproximately 1.4 million tonnes per annum (Fawell,2007), of which approximately 18% is used in mining.(Logsdon et al, 1999)

The use of cyanide in gold extraction processes canintroduce significant quantities of cyanide and its derivativesinto the environment, if not properly managed throughout itslife cycle in the mine operations. However, optimization ofthe use of, and quantities of cyanide used, along with goodproduct stewardship, can minimize the negativeenvironmental effects of cyanide upon the environment.(Logsdon, et al 1999)

HOOGERVORST, A. Keynote Address: Environmental and sustainability aspects of gold mining with particular reference to the integrating influences ofcyanide code compliance. World Gold Conference 2009, The Southern African Institute of Mining and Metallurgy, 2009.

Keynote Address: Environmental and sustainability aspects ofgold mining with particular reference to the integrating

influences of cyanide code compliance

A. HOOGERVORSTEagle Environmental, South Africa

Cyanide is a key contributor to the efficiency of gold extraction. Public perceptions of cyanide areemotive and following some publicised incidents involving cyanide, the gold mining industryestablished a voluntary cyanide code for the manufacture, transport and use of cyanide in theproduction of gold. The paper describes the development of the code, its content and the thirdparty auditing of the code as a means of establishing and maintaining benchmark standards. Inadhering to the cyanide code requirements, there are overlaps with other management systemssuch as ISO 14001 and OHASA 18001 and the paper seeks to show how existing mine systemscan readily accommodate cyanide code compliance and that operating and auditing the cyanidecode can assist in the integration of mine heath, safety and environmental management systems.

Cyanide facts

• Cyanide is made up of two elements, carbon and nitrogen• Cyanide is a naturally occurring substance found in some 2000 natural sources including food and other higher plants, algae, fungi, insects, bacteria, and

arthropods. • Cyanide is manufactured primarily as gaseous hydrogen cyanide and solid sodium and potassium cyanide• Cyanide is a toxic substance and can be lethal if ingested or inhaled in sufficient quantities. It can also be absorbed through the skin.• Cyanide is described as having a ‘bitter almond’ smell but, anecdotally, up to 40% of individuals cannot smell it. • Cyanide is not bio-accumulative and very small amounts of cyanide in the form of vitamin B-12 (cyanocobalamin) are needed as part of a healthy diet.• Cyanide compounds are also found in vehicle exhaust, cigarette smoke and road and table salt.• Other non-mining uses of cyanide include: paper, textiles and plastics manufacture, electroplating, metal cleaning, pest and vermin extermination,

photographic chemicals, and pharmaceutical products.

Sources: Logsdon , et al 1999; Fawell, 2007; Australian Government, Department of the Environment, Water Heritage and the Arts, 2006; Centers forDisease Control and Prevention, 2004.

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WORLD GOLD CONFERENCE 20092

Sustainability and gold miningOptimal cyanide use and management can contributepositively to the overall sustainability equation in mining. Ifcyanide is managed within the confines of the miningoperation and either returned to the process for reuse orneutralized or destroyed before leaving the operation, itresults in one hazardous chemical stream which is beingmanaged sustainably.

Furthermore, if the amount of cyanide used andphysically present on site, is reduced, then the potentialrisks to the environment, as well as the potential humanexposure pathways are reduced. (Logsdon M, et al, 1999).

Background to the cyanide code and goldmining

‘…The ‘International Cyanide Management Code For theManufacture, Transport, and Use of Cyanide In theProduction of Gold’ (The Cyanide Code) was developed bya multi-stakeholder Steering Committee under the guidanceof the United Nations Environmental Program (UNEP) andthe then International Council on Metals and theEnvironment (ICME)…’ (International CyanideManagement Code for the Gold Mining Industry 2006-1).The primary industry ‘driver’ behind establishing theCyanide Code was a highly publicized accidental release oflarge amounts of cyanide and tailings from the Baia Maregold mine in Romania in January 2000 (Greenwald N, 2005).

‘…The Code is a voluntary industry program designed toassist the global gold mining industry in improving itsmanagement of cyanide. The Code is intended to reduce thepotential exposure of workers and communities to harmfulconcentrations of cyanide‚ to limit releases of cyanide tothe environment‚ and to enhance response actions in theevent of an exposure or release.

The Code was developed to improve the management ofcyanide at gold mines. Spills and other incidents involvingcyanide solutions at gold mines, such as the January 2000incident at a Romanian gold mine, demonstrated to the goldmining industry‚ governments and the public that bettermanagement of cyanide was needed‚ particularly atoperations with limited experience or in countries lackingadequate regulatory programmes.

The Code was developed under the auspices of the UnitedNations Environment Programme (UNEP) and theInternational Council on Metals & the Environment(ICME). In May 2000‚ at a joint UNEP/ICME-sponsoredinternational workshop in Paris‚ cyanide producers‚financial institutions‚ regulatory personnel‚ gold miningcompanies and environmental advocacy organizations fromaround the world met and recommended that a multi-stakeholder steering committee be formed by participantsfrom the gold mining industry‚ governments‚ non-governmental organizations‚ labour‚ cyanide producers andfinancial institutions to deliberate on appropriate factors toinclude and to develop a code. This project represents thefirst time that such a multi-stakeholder group has workedcooperatively to generate an international‚ globally basedvoluntary programme for improvement of an industryactivity….’ (International Cyanide Management Code forthe Gold Mining Industry, 2006–2).

The cyanide codeThe Cyanide Code (International Cyanide ManagementCode, 2008) consists of nine principles: production;

transportation, handling and storage; operations;decommissioning; worker safety; emergency response;training; and dialogue. Each principle includes anywherebetween one and nine standards of practice. Companies‘sign-up’to the Code and commit to complying with theprinciples of the Code. Code signatories then register theirvarious operations and have three years in which todemonstrate compliance to the Code through a third partyaudit. Thereafter, the sites are required to be recertifiedevery three years. (International Cyanide ManagementCode, 2008)

The Code does not spell out how the sites must adhere tothe Code but rather expects them to incorporate complianceto the Code into the various management systems thatoperations may be using.

The Cyanide Code is a voluntary industry code whichwas developed by the industry and key stakeholders toreduce cyanide risk in the gold mining sector and therebyestablish minimum standards which could be appliedglobally, without conflicting with individual national legalrequirements. In some cases, the Code exceeds countrylegal requirements and in others, country legal requirementsmay go beyond the Code’s requirements. As a third partyICMI auditor, I have observed that in the majority of cases,the application of Code requirements has uplifted sitestandards and resulted in a reduction of cyanide risk, asfurther commented upon by site management and operators.

Third party auditing of the Cyanide CodeThe Cyanide Code requires that operations of companiesthat are signatories to the Code must be audited byindependent third parties to determine if they can becertified as in compliance with the Code's principles andstandards of practice. (International Cyanide ManagementCode for the Gold Mining Industry 2006-3). The Code hasdefined audit protocols, auditor guidance documents andreport templates to ensure a degree of consistency inauditing and audit reporting.

On completion of the audit, the auditor must submit adetailed audit findings report (Detailed Report) whichincludes evidence of compliance and the conclusions aboutthe operation’s compliance status. The Detailed Report isthe confidential property of the operation audited and maynot be released by the ICMI without the express writtenconsent of the signatory and audited operation. Thesummary audit report (Summary Report) contains thesummarized conclusions of the compliance status and ismade available to the public on the ICMI website(International Cyanide Management Code 2008).

The audit reports will find one of three compliance levels:full compliance, substantial compliance and non-compliance. Full compliance and non-compliance are selfexplanatory. A substantial compliance finding may be madewhere there are one or more negative answers toverification protocol questions.

Three criteria must be satisfied in order for a finding ofsubstantial compliance to be made:

• The operation must have made a good-faith effort tocomply

• The deficiency must be readily correctable • There can be no immediate or substantial risk to health,

safety or environment from a situation found insubstantial compliance.



A finding of substantial compliance must beaccompanied by a corrective action plan to deal with thedeficiencies within a period of one year. The correctiveactions must enable the operation to have its substantialcompliance upgraded to a full compliance. In formal terms,operations that are found in substantial compliance areconditionally certified subject to their implementing acorrective action plan and coming into full compliance(Auditor Guidance for Use of the Gold Mine OperationsVerification Protocol, 2008).

The ICMI has published an auditor guidance document(Auditor Guidance for Use of the Gold Mine OperationsVerification Protocol, 2008) which spells out guidancenotes on the questions asked in the audit protocol under thenine principles. This guidance document is of considerableassistance to both auditors and auditees, in both preparingfor the audit and in interpreting the ‘on-the-ground’conditions during a third party audit. However, the Codewas, of necessity, written as a global ‘one-size-fits-all’code and there are many instances where auditor judgementis required to interpret both the spirit and word ofcompliance. ‘Auditor judgement’ is made easier when sitescan provide a line of evidence and logic which shows howthe spirit of the Code was addressed and how it wasinterpreted in the light of local conditions. Understandingthe logic behind the options and the influences such as localconditions and local legislation is a great aid to the auditorwhen making an ‘auditor judgement’.

The Code requires, amongst others things, that the leadauditor for an ICMI certification audit must be ‘…certifiedas a professional environmental, health or safety auditor bya self-regulating professional organization…, (AuditorCriteria, 2007). Lead auditors will have different operatingpractices but one practice that I use is that the evidence trailthat I leave in my reports must be sufficient that shouldanother auditor follow that same evidence trail, he or sheshould come to the same conclusions, based upon theguidance issued by the ICMI in its documentation. This isparticularly important if auditor judgement is exercised andthere should be some dispute about the findings at a laterstage.

The Code does have provision for an appeal by anystakeholders against the finding of a third party audit (orauditor credentials, or certification or de-certification ofoperations) in a formal dispute resolution procedure(Dispute Resolution Procedure, 2005). The procedure is athree stage process which includes mediation andarbitration. It is very important that the evidence trails forthird party audits are thorough and consistent. It is for thisreason, that the ICMI has developed a ‘completenessreview’ process, which is part ofs submitted to the ICMI forcompleteness review. The purpose of this review is not toquestion the findings of the auditor but to ensure that thesummary report contains an adequate and complete, self-contained, summary of the audit so that (a) the publishedsummary report can be understood in context by any casualstakeholder who reads it on the website, and (b) so thattogether, the detailed report and summary reports containsufficient accurate and appropriate information to bedefendable in the case of dispute.

Cyanide code integration of health, safety andenvironmental management

The Cyanide Code recognizes that there are many differentmanagement systems models that may be used in gold

mines which will overlap with cyanide management tovarying degrees. The auditor guidance document (AuditorGuidance for Use of the Gold Mine Operations VerificationProtocol 2008) recognizes the existence of systems such asISO 14001, and EMAS (Eco-Management and AuditScheme) but signatories are not required to use thesevarious systems. As long as they can demonstrate to thesatisfaction of their ICMI auditor that they have a system,or systems, in place which manage cyanide according to therequirements of the principles of the Code, they can achievecompliance to the Code.

Some have suggested that the Cyanide Code is anotheradministrative load on an already overloaded requirementfor systems, procedures and paperwork. This is notnecessarily the case. Figure 1 shows the ICMI Coderequirements on the left and the generic systems that onetypically finds in gold mines. It is easy to draw up a list ofdifferent components of mine management systems andthen draw lines to link them to the Cyanide Code principleswhich require evidence to illustrate responses.

Figure 2 illustrates how the different mine managementsystems link to the principles of the Cyanide Code throughthe drawing of lines. For example, the purple lines showthat the Code principles of production and transportation,link to aspects in mine management systems such asprocurement and asset protection. Similarly, the Codeprinciple of worker safety links to aspects in the minemanagement systems such as ISO/OHASA systems; humanresources; change management; health, safety andenvironment; and emergency preparedness.

The diagram is not necessarily complete and is ageneralized model to give an indication of the differentcomponents that could be found in a typical minemanagement system or nest of management systems.

ConclusionsThe Cyanide Code is an important focus upon cyanide-specific issues in gold processing, waste management, minehealth, safety and environment, chemical stewardship andother linked mine processes. By using the audit protocolswhich form a part of the minimum standards certificationagainst the Cyanide Code, mines can not only utilize thosesystems for sound cyanide management but test their othermine systems such as ISO 14001, OHASA 18001 and ISO9001, using cyanide as a topic or item focal point.

NoteThe opinions expressed in this paper are those of the author anddo not in any way reflect the official policy of the InternationalCyanide Management Institute, unless specifically quoted fromofficial ICMI documents or ICMI website.

AcknowledgementsI would like to acknowledge with grateful thanks andadmiration, my cyanide technical auditor partner, Mr DawieViljoen of Afritech Technical and Management Services,with whom I have shared some eighty Cyanide Code gapanalyses, pre-audits and certification audits and who hastaught me an immeasurable amount about cyanide, goldplants, gold processing and gold processing operations, butstill has to persuade me on the merits of flying in a smallprivate plane….



Figure 2. ICMI code and mine systems cross-linkages

Figure 1. ICMI code and mine systems relationships



Thanks also to Dawie Viljoen for permission to use andadapt his ICMI Code Systems Relationships diagram whichwe have used so frequently to explain linkages.

Acknowledgement and thanks to the InternationalCyanide Management Institute (ICMI) for the use of corematerials which form a vital part of the formal compliancerequirements for adhering to the ICMI Cyanide Code.

References and further reading

ARMINFO 2001-2005. Foundation-Stone of Nature,http://www.arminfo.info/cianid_eng.html, accessed on27 June 2009.

ATSDR, 2006 Agency for Toxic Substances and DiseaseRegistry, Cyanide Fact Sheet, July 2006, http://www.atsdr.cdc.gov/tfacts8.pdf , accessed on 27 June 2009.

Auditor Guidance for Use of the Gold Mine OperationsVerification Protocol 2008, August 2008,http://www.cyanidecode.org/pdf/RevisedAuditorGuidance.pdf , accessed on 27 June 2009.

Auditor Criteria 2007, January 2007, http://www.cyanidecode.org/pdf/7_AuditorCriteria.pdf , accessedon 27 June 2009.

Australian government, department of the environment,water heritage and the arts, 2006, Cyanide (inorganic)Compounds Fact Sheet, http://www.npi. gov.au/database/substance-info/profiles/ 29.html#sourcesof ,accessed on 27th June 2009

Centers for disease control and prevention 2004, ‘EmergencyPreparedness and Response—Facts about Cyanide’.http://www.bt.cdc.gov/agent/cyanide/basics/facts.asp,accessed on 27 June 2009.

Dispute Resolution Procedure 2005, November 2005,http://www.cyanidecode.org/pdf/Dispute_Resolution_Procedure.pdf accessed on 27 June 2009.

Environment Australia, 2003, ‘Best Practice EnvironmentalManagement in Mining—Cyanide Management’,

ISBN 0 642 549443, Commonwealth of Australia,157 p.

FAWELL, J.K. Cyanide in Drinking Water. BackgroundDocument for development of WHO Guidelines fordrinking-water quality, WHO/SDE /WSH/07.01/2.World Health Organisation Geneva, 2007, 18 p.

GREENWALD, N. 2005, Cyanide Management Code inPoverty Times #3—January 2005), UNEP/GRIDArendal, http://www.grida.no/publications/et/ep3/ ,accessed on 27 June 2009.

LOGSDON, M., HAGELSTEIN, K., and MUDDER, T.The Management of Cyanide in Gold Extraction,International Council on Metals and the Environment,Ontario, Canada, ISBN 1-895720-27-3, 1999.

International Cyanide Management Code 2008, August2008, http://www.cyanidecode.org/pdf/thecode.pdf ,accessed on 27 June 2009.

International Cyanide Management Code for the GoldMining Industry 2006-1. Overview Page, http://www.cyanidecode.org/about.php, accessed on 27 June2009.

International Cyanide Management Code for the GoldMining Industry 2006-2. Frequently Asked QuestionsPage, http://www.cyanidecode.org/about_faq.php#1,accessed on 27 June 2009.

International Cyanide Management Code for the GoldMining Industry 2006-3. Auditors and Auditingoverview Page http://www.cyanidecode.org/auditorauditing.php, accessed on 27 June 2009.

International Cyanide Management Code for the GoldMining Industry 2006-4. Environmental and HealthEffects of Cyanide, http://www.cyanidecode.org/cyanide_environmental.php, accessed on 27 June2009.

Arend HoogervorstManaging Partner, Eagle Environmental, South Africa

Arend Hoogervorst is an environmental scientist by training and has been involved withenvironmental matters in commerce and industry (including mining) in Africa for over 28 years.His experience includes working for local and central government in South Africa, the oil andchemical industry and more recently, consulting for commerce and industry and the mining sector.Arend has edited and published Eagle Bulletin, an environmental and sustainability newsletter forcommerce and industry, for 18 years. He produced the first Environment Diary in South Africa,was the founding author of the Enviropaedia (a South African environmental encyclopaedia andnetworking directory), and has written information booklets for the South African Department of

Environmental Affairs & Tourism on Environmental Auditing, Life Cycle Assessment, Environmental Reporting,Environmental Assessment and Trade, and Linking Environmental Impact Assessment and Environmental ManagementSystem. He is also a certified Principal Auditor (Environmental Management Systems) and an accredited ICMI Lead Auditor.He has been involved in ICMI Cyanide Code auditing since 2006 and has been Lead Auditor on some 21 ICMI complianceaudits covering mines, transporters and producers.


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