3.1 Planning to manage risk

Leading practice monitoring extends beyond the base level of effort that may be required for assessing compliance with current licence or operating conditions. Leading practice monitoring is designed to be sensitive enough to detect trends in key parameters well before they go out of compliance, and to enable prompt responses to concerns or allegations of impact from third parties. In short, leading practice monitoring is risk based and proactive. It needs to be focused on the key environmental risks for the site, which will include operational and compliance risks as well as other potential stakeholder concerns. It also needs to adapt to the changing nature of those risks at each stage over the life of the mine, from exploration to closure (and beyond, for some aspects). A leading practice monitoring program can also be a valuable resource planning tool, helping to define the skill sets needed to manage the identified risks and to assist in adjusting to change during the life of the mine.

Monitoring that is only able to detect changes after a substantial impact has occurred cannot be used to manage systems to prevent impacts and minimise liabilities. A common misconception is that monitoring for compliance is all that is needed to prevent and to manage impacts. If the first measurement of change is one that fails compliance, it is too late to prevent the unwanted impact, as most compliance standards are set at the point where, if compliance is not met, impact is likely to occur.

Risk-based planning for monitoring involves understanding the nature and relevant sensitivities of the project, including environmental, political, socioeconomic and cultural contexts, and the processes by which mine operations could affect them. This enables appropriate and sufficiently sensitive parameters and end points to be selected and to be used to detect underlying trends before detrimental impacts occur.

The leading practice Risk management handbook (DIIS 2016a) includes examples of risk assessment that are applicable to risk planning and provides useful examples that can be adapted to suit a specific operation and context.

Risk planning maturity models (DIIS 2016a) are a useful framework that can be applied to other risks, such as health risks (Hancock 2010) and jurisdictional abandoned mine programs (Unger et al. 2012). Maturity models define characteristics of vulnerable through to resilient programs and are used to both evaluate progress and provide guidance on the next steps towards leading practice.

One method of integrating risk planning into the monitoring program is to develop a risk register that incorporates life-of-mine risks and associated monitoring with the performance criteria relevant to each. Separate risk registers can be developed for each phase of operations, from exploration to closure, and updated as the operation progresses. A risk register can provide both a framework to identify significant risks and the control measures to mitigate those risks (it is recommended as part of an EMS under ISO14001:2004, for example).

An environmental and social impact assessment (ESIA) will need to include a risk register with likelihood and consequence assessments and, ideally, a designed monitoring system to track changes in sensitive indicators of those risks. Some research may need to be carried out, either as a desktop study or in the field, if there is insufficient information to define or quantify potential impacts. The monitoring commitments made during the ESIA process need to be adhered to and revisited periodically in case changes are required (see Section 3.3). It is expected that the forthcoming revision of the Australian and New Zealand Environment and Conservation Council (ANZECC) water quality guidelines documents will place strong emphasis on the development of conceptual models that will highlight those risks and the selection of multiple sensitive indicators. Additionally, a weight-of-evidence approach to assessing the outcomes of monitoring of those indicators is also expected to be emphasised. Importantly, the water quality management framework will emphasise reviews of the indicators used, the conceptual model that the risks are identified from and the management systems in place so that monitoring is continuously improved and optimised (note that these principles are equally applicable to risks other than water quality).

The risk register can be developed through a number of mechanisms—for example, assessments by panels of experts with diverse skills, stakeholder consultation, or quantitative and semi-quantitative risk assessments. Effective leading practice risk assessment must have the appropriate skills–knowledge mix in the team developing it and high-level commitment to implementing the control measures once they are identified, supported by the budget and resources to take necessary actions.

The Risk management handbook in this series provides examples of each type of risk assessment. Further guidance is in the Australian and New Zealand Standard AS/NZS 4360:2004 Risk management and the Standards Australia handbook HB 203: 2012 Managing environment-related risk.

Standards Australia also provides guidance on managing specific risks in handbooks such as:

  • HB 205:2004 OHS risk management handbook
  • HB 231:2004 Information security risk management guidelines
  • HB 294:2006 National post-border weed risk management protocol.

The risk planning approach minimises monitoring effort that does not target the potential liabilities of the operation at each stage, but provides more than adequate warning of potentially detrimental trends, ensuring that appropriate datasets are available when issues arise and minimising the chance of being unable to defend claims for damages. The key is to have monitoring that facilitates managing risk for all stages of the operation.

There are risks associated with the gathering of appropriate information to solve problems and answer key questions. Additionally, there are risks associated with data management to ensure the continuity and accessibility of historical monitoring data. Both aspects must be addressed as part of the overall risk assessment and management processes.

Leading practice monitoring requires the risk assessment process to recognise and address implementation risks associated with the conduct of monitoring, such as the possibility that:

  • baseline monitoring is not carried out over a sufficiently representative time period or at an appropriate location to provide good-quality data upon which to base subsequent assessments
  • monitoring installations or equipment are destroyed by vandalism, fire, flood or feral animals, causing loss of data at critical times
  • unexpected changes to mining operations affect monitoring installations, equipment databases used to manage and interpret data change over time and old data becomes irretrievable
  • personnel who understand the critical elements of the monitoring program do not document procedures and, when they leave the company, new personnel are unable to manage the monitoring system to the standard required
  • monitoring data is reviewed annually but not over longer periods, so cumulative impacts go undetected
  • monitoring focuses on indirect measures of impact and therefore fails to detect the specific impacts that need to be measured (for example, focusing on monitoring particular fauna species when they may be affected by impacts on riparian vegetation caused by changes in stream hydrology and when the primary cause and all links need to be understood)
  • insufficient data points are obtained to conduct the necessary analyses and interpretation with an adequate degree of confidence, which can result in a misrepresentation of trends
  • good-quality monitoring data is not used for the purposes of adaptive management, continuous improvement, or both
  • meta-analysis of data is not carried out.
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