5.4 Environmental audits

Within the broad category of environmental audits there are several types of audit that might apply to a mining operation.

An environmental performance audit is directed at verifying a mine’s environmental status against specific, predetermined audit criteria. The audit program objectives should articulate senior management’s or the board’s expectations for the audit program. The audit scope should address:

  • the geographical and/or business system focus of the audit
  • the subjects or topics to be audited, the thoroughness or depth of the audit, and the scheduling and frequency of the audit
  • general criteria against which the audit will be conducted and findings established.

An environmental management system (EMS) audit is a specific type of environmental performance audit in which the audit scope is defined as the EMS or selected parts of it, and the audit criteria are the internal environmental policies, procedures, standards, codes of practice and so on that underpin the EMS. The EMS audit is designed to determine whether the mining operation is doing what it says it will do in its documentation of the EMS, and whether the EMS has been effectively implemented throughout the mine or that part of the mine selected for the audit. An EMS audit may assess conformance with a standard, such as ISO 14001:2004, or the mining company’s specific EMS criteria (which might or might not be based on ISO 14001:2004).

A compliance audit assesses a mine’s compliance against selected criteria derived from legislation; regulations; licence, permit, approval or lease conditions; or other legal requirements. It may also include voluntary requirements to which the organisation subscribes, such as Enduring value or the International Cyanide Management Code for the Manufacture, Transport and Use of Cyanide in the Production of Gold.

Compliance audits may be statutory, mandatory or voluntary. Most multinational mining companies require periodic compliance audits to be conducted against regulatory requirements and internal policies and procedures, by either internal auditors or external auditors (or both) who report the significant results to management at the mine site and to head office. Results from multiple sites are compiled into a report for senior management and the board.

In April 2008, the Western Australian Department of Environment and Conservation introduced a condition requiring the submission of annual audit compliance reports by the holders of certain licences under the Environmental Protection Act 1986. The compliance reports enhance audited self-management by occupiers of prescribed premises (including mines) and help licensees to ensure greater compliance with their licence conditions. The department makes all the compliance reports submitted by industry publicly available.

Many audits labelled as energy audits are nothing more than a generalised assessment of a mine’s energy use based on tariffs or an investigation of a particular subsystem within a mine. An effective energy audit needs to examine not only the major energy end-use equipment but also the operations, maintenance and management processes of the facility and the energy sources. The energy audit is a detailed examination of how the facility uses energy, what it pays for that energy and where the energy comes from (including the security of energy supply and renewable energy sources). It should result in a set of recommendations to reduce energy costs through both equipment and operational changes. A series of energy audit tools is available from the Department of the Environment.12

A waste audit is essentially a study of all wastes generated by a mine; however, it may be restricted to a particular operation on the mine site, such as a coal handling and preparation plant or the mineral processing plant on a metalliferous mine. The audit must go beyond measuring the quantity of waste and identifying its composition to identifying the underlying reasons and operational factors for waste generation, including purchasing policies and procedures; how the wastes are stored, handled and transported; and the methods of waste reuse, recycling and disposal. A mine operator may also conduct a waste audit of the mine’s waste disposal contractors to ensure that only licensed waste disposal contractors are used, that the destination of the waste is a licensed waste disposal or recycling facility, that all waste transport and disposal is correctly documented, that record keeping complies with regulatory requirements, and that the mine is in compliance with all waste regulatory requirements.

Environmental site audits (also called environmental site assessments) are generally undertaken for the purposes of commercial real estate transactions, for due diligence purposes or to meet regulatory requirements, including gaining certification that a site is ‘fit for use’. In many jurisdictions around the world, it is compulsory to identify contaminated sites, report their presence to regulatory authorities, register them as contaminated (or potentially contaminated), remediate them if that is necessary to protect community health and safety or environmental amenity, and certify that they are suitable for their existing, planned or potential uses. This can be a lengthy and generally expensive process, and there are many standards and guidelines relating to site assessments (see ‘Further reading’). AS/NZS ISO 14015:2003 Environmental management—environmental assessment of sites and organizations (EASO) is the accepted international standard, and guidance information on contaminated site investigations is available from the National Environment Protection Council and most state and territory governments. The National Environment Protection (Assessment of Site Contamination) Measure published by the council was amended in 2013 and is the basis for site contamination assessment throughout Australia.13

Environmental security has become a major issue worldwide. A facility that stores, uses or transports dangerous goods in significant quantities must be aware of security risks and take measures to protect the goods from malicious or accidental events that may harm the environment or human health and safety. An environmental security audit is an essential part of this risk assessment, especially for mines that transport and use bulk quantities of substances such as cyanide, ammonium nitrate, acids, sodium hydroxide and certain toxic chemicals used in the processing of minerals. As well as raw materials, any materials that could cause significant harm if discharged into the environment, such as radioactive products (for example, yellowcake), mineral concentrates and wastes (such as used oil) need to be assessed. The environmental security audit may include vulnerability assessments of critical infrastructure facilities, combined with a gap analysis of environmental, health and safety information and security management systems. The transport of dangerous substances through sensitive environments, such as wetlands, river crossings, national parks, conservation areas, towns and villages, is an essential component of the environmental security audit.

The International Cyanide Management Code for the Manufacture, Transport and Use of Cyanide in the Production of Gold was developed as a voluntary industry code under the direction of a multi-stakeholder steering committee, the members of which were chosen by the United Nations Environment Programme and the International Council on Metals and the Environment. The code encourages improvement on an industry-wide basis by aggressively promoting participation in the code and by requiring signatories to the code to take appropriate action to manage cyanide responsibly. The International Cyanide Management Institute was established to administer the code.

The code focuses exclusively on the safe management of cyanide and cyanidation mill tailings and leach solutions. It addresses the production, transport, storage and use of cyanide and the decommissioning of cyanide facilities. It includes requirements related to financial assurance, accident prevention, emergency response, training, public reporting, stakeholder involvement and verification procedures. The code is composed of two major elements: the principles, which broadly state commitments that signatories make to manage cyanide in a responsible manner; and the standards of practice, which identify the performance goals and objectives that must be met to comply with each principle. Relevant documents can be viewed and downloaded from the code’s website.14

Footnotes

12, 13 See Energy audit tools, http://pandora.nla.gov.au/pan/65500/20061117-0000/www.greenhouse.gov.au/challenge/members/energyaudittools.html.

14 International Cyanide Management Code, http://www.cyanidecode.org/.

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