Was the Environmental Assessment Adequate? - Mining and the Environment: From Ore to Metal - page 503

targets set by mining companies such as mill throughput per day, mill efi ciency, or cost
per tonne of ore mined. Typical environmental objectives could be zero release of acid
rock drainage, recycling of all waste oils, water conservation by minimizing water con-
sumption per tonne of ore mined, or a reduction of greenhouse gas emissions over time.
Environmental Liability Audits are external and often form part of the 'due diligence'
process used in acquisition/divestitures and mergers in order to identify potential environ-
mental liabilities and the cost of correction or redemption. These costs are then introduced
into the terms of the i nancial agreement negotiated by the parties. Such audits are under-
taken on behalf of mining companies; investors, including IFC and EBRD; insurance
companies, including OPIC and EFIC; and government privatization agencies.
Environmental Management System Audits are internal and/or external audits designed
to regularly test applied management practices for compliance with the requirements of
a formal environmental management system such as ISO 14000 EMS. Environmental
Management System Audits follow a strict protocol, which is very much determined by
the applied management system. A common mine audit is not a complete environmental
management system audit, neither should it be. A complete environmental management
system audit would provide a thorough, systematic evaluation of all elements of a mine's
implementation of an environmental management system, which would not necessarily
provide a true rel ection of the mine's environmental performance.
Mine audits differ from common auditing not only because of the magnitude of min-
ing operations and the often unique locations in which they are sited, but also because of
the controversy and agitation by NGOs, whereby operations can unexpectedly i nd them-
selves in the public spotlight. Mining and mineral processing operations are particularly
susceptible to this because of the scale of land disturbance, potential for large and harmful
discharges to the environment, emotive land use conl icts and health risks, and the general
negative perception that mining tends to receive.
Three parties participate in an audit. The auditee is the operation being audited. The
client is the organization that requires the audit to be conducted. This can be the auditee
itself, the auditee's holding company or its Board of Directors, a i nancial institution, or in
some instances public authorities. Finally there is the audit team led by a lead auditor.

Mine audits differ from common
auditing not only because of the
magnitude of mining operations
and the often unique locations
in which they are sited, but also
because of the controversy and
agitation by NGOs.

Audit Matters and Criteria

Mining audits need to focus on the signii cant issues: e.g. resettlement and land compen-
sation, social investment, resource conservation and recovery, tailings disposal and waste
rock management, potential loss of biodiversity, rehabilitation and mine closure, applied
management practice, and other controversial issues raised by NGOs and the media. Of
course, assessing compliance with the host country's environmental regulations pertaining
to these issues is essential. Mine audits are not the typical 'nuts and bolts' audits as applied
to say manufacturing; they require a throughout understanding of the mining industry so
that the signii cant issues are appropriately addressed.
Whatever is being audited - e.g. activities covered by legislation, EMS, mine waste man-
agement practices - is referred to as the subject matter of the audit. The policies, procedures,
guidelines, industry standards or other requirements such as EIA commitments against which
the subject matter of the audit is checked are called audit criteria . Other audit criteria, of
course, are the Equator Principles or mining sector specii c industry codes such as the cyanide
code (see Chapter Seven). The audit criteria in a legislative compliance audit will be predomi-
nantly the environmental legislation of the host country plus commitments made in the EIA.
The subject matters of the audit will be the environmentally relevant components and activities

Mining audits need to focus on
the signifi cant issues.