Environmental Impact Assessment - Mining and the Environment: From Ore to Metal - page 105

The mining company has overall
responsibility for environmental
performance even when the
activities are carried out by
contractors.

Numerous environmental and social impacts occur during construction. Mining com-
panies at times hide behind the Engineering Procurement and Construction (EPC) system,
and argue that contractually, the project is only 'handed over' to them after commissioning.
Regulators and people in local communities who may be affected by the construction
phase are not sensitive to or impressed by this 'handover' argument. The mining company
has overall responsibility for environmental performance even when the activities are car-
ried out by contractors. Accordingly, the mining company needs to ensure that contract
documents include the requirement for appropriate environmental management, and
also to maintain sufi cient oversight of construction operations to ensure that contractual
obligations are met. Negative perceptions towards the mining project developed through
poor environmental management during mine construction are difi cult to reverse,
even if subsequent environmental management of the project achieves the highest
standards.
Environmental management is greatly assisted by a formal environmental policy and
management system that guides mine personnel. The environmental management struc-
ture should clearly dei ne formal lines of responsibilities for maintaining legislative and
regulatory compliance, and for achieving environmental goals. Virtually all project staff
have environmental responsibilities. These responsibilities need to be well communicated,
documented in individual job descriptions and should be reviewed regularly. Where
appropriate, training should be provided to ensure that all staff are adequately trained to
carry out their environmental responsibilities.
Overall environmental responsibility should rest with senior management, separated
from day-to-day supervision of production. Environmental site personnel need to have
environmental expertise and skills. Dedicated personnel (in the sense of full-time, as well
as personally committed) with relevant expertise should be assigned to social programmes.
There should be adequate i nancial and personnel support to carry out the many tasks
related to environmental and social management. Regular reporting to top management
is essential, with direct access in situations that require immediate management decisions.
Periodic external audits, submitted to top management, should be carried out to evaluate
the effectiveness of management policies and practices.
Effective collaboration with production personnel is essential to successful environ-
mental management. Environmental and social performance policies need to be known
to and respected by all mine personnel; production personnel need to develop a feeling of
ownership for environmental targets. Ideally, as with safety and quality control, environ-
mental management should be a production responsibility, not classii ed merely as a support
function.
Environmental management should be designed to allow for effective and transpar-
ent communication with the public and with government agencies. Public environmen-
tal reporting has become a key element of major mining companies and is guided by the
Global Reporting Initiative (2000).
While mining operations rarely generate major accidents that endanger local commu-
nities, this has happened, most notably in the failure of tailings storages. Environmental
management should include the preparation of emergency plans for potentially hazard-
ous activities related to the mining operation. To the extent that they could be affected,
communities need to be apprised of such emergency preparedness plans. Tailings dis-
posal in particular stands out as hazardous, especially in regions with rugged terrain, high
seismicity and extreme rainfall events. The UNEP Industry and Environment Program
Activity Center has developed a Handbook on Awareness and Preparedness for Emergencies
at the Local Level (UNEP 2001) that can assist in the preparation of such plans.

Overall environmental
responsibility should rest with
senior management, separated
from day-to-day supervision of
production.