1.4 Deficiencies in current monitoring and auditing practices

While focusing on leading practice, it is useful to understand the key deficiencies of past monitoring and auditing practices in order to avoid repeating them. Commonly encountered deficiencies include:

  • lack of a clearly defined purpose for the monitoring program and/or audit process, leading to unsatisfactory outcomes, wasted resources and potential conflict with stakeholders because expectations are not met
  • dysfunctional feedback loops, meaning that data is not analysed or the analyses are not used to enable continuous improvement
  • performance measures that are too narrow and fail to include adequate socioeconomic and environmental perspectives
  • an inappropriate level of public reporting, meaning that the purpose, context and findings from monitoring and auditing programs are not clearly understood
  • monitoring plans that are not able to evolve through the life of the mining operation because key elements remain largely focused on start-up issues
  • adequate baseline data not being obtained to enable the effective identification or management of long-term issues
  • not adequately dealing with problems relating to the alteration and destruction of monitoring infrastructure (for example, inadequate planning to avoid or otherwise address this, not documenting infrastructure changes to enable the explanation of vagaries in the dataset)
  • inadequate attention to data quality control
  • inadequate maintenance of records following planned or unplanned changes in monitoring methods or monitoring infrastructure or equipment
  • time frames for review that reflect regulatory requirements but are not consistent with changes to site operations or suitable for proactively addressing developing site issues
  • annual monitoring reports that are treated as a regulatory compliance requirement only, with an inadequate level of technical interpretation to proactively identify and manage developing site issues and/or are not integrated with the continuous improvement process on site
  • inappropriate or inadequate use of risk assessment methods to provide an additional mechanism to identify changing monitoring needs.
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