IRMA Standard for Responsible Mining (Draft 2.0)
Chapter 3.9 Cyanide

This chapter has been flagged. The IRMA Steering Committee is especially interested in hearing from stakeholders on this chapter, as we did not receive many comments on it during our previous comment period.

 

Background

Cyanide is an industrial chemical used in the processing of gold and silver at many mine sites and as a minor processing reagent at some base metal mines.  If released to the environment, or if improperly used in mineral processing, cyanide can pose a risk to workers, surrounding communities, aquatic resources and wildlife.

The International Cyanide Management Institute (ICMI) has developed a program for the gold mining industry to improve the life-cycle management of cyanide used in gold mining, to enhance the protection of human health, and to reduce the potential for environmental impacts.  Although the International Cyanide Management Code only provides for the certification of gold mines, the same principles can be applied to other types of mining operations that use cyanide for the extraction of commercial quantities of minerals.  This chapter builds on the ICMI Principles and Standards of Practice.

Objectives/Intent of this Chapter

To protect human health and the environment through the responsible management of cyanide.

Scope of Application

Chapter Relevance:  This chapter is applicable to operating companies that own, control or operate mining projects associated with the production, storage, use or transportation of cyanide; and to any mining project that requires the storage onsite of cyanide in bags or bulk containers, or that use cyanide in a mill process. This does not apply to cyanide for laboratory use or other de minimus testing purposes. It applies during operations and decommissioning of the associated facilities.

Mining projects must also maintain and provide documentation that cyanide producers and transporters supplying the mining projects are International Cyanide Management Code (Code) certified.

New vs. Existing MinesNew mines shall meet all of the requirements of this chapter. Existing mines are not required to meet the design/construction requirements in 3.9.2, unless new cyanide storage facilities, mixing, and process tanks are constructed after the IRMA Standard takes effect.

NOTES TO READERS ON MAJOR CHANGES TO THIS CHAPTER

  • Clarified that companies demonstrate that they have taken steps to ensure that cyanide producers and transporters supplying the mining project are certified by the Cyanide Code.
  • Clarified that companies conditionally-certified by ICMI are considered to be in compliance with the IRMA Standard.
  • The means of verification (MOV) have been removed from this version of the draft IRMA Standard. If you would prefer to review and comment on a version of the draft Standard that has the means of verification, you can download a pdf version of the Standard with MOV.
     

Cyanide Requirements

3.9.1.  Compliance with the International Cyanide Management Code (The Cyanide Code)

3.9.1.1.  If the operating company is eligible to be a signatory to the Cyanide Code,[1]  it shall obtain a certification of compliance in accordance with the requirements of the International Cyanide Management Institute (ICMI).[2]

3.9.1.2.  If the operating company is not eligible to become a signatory of the Cyanide Code, but the mining operation requires the storage onsite of cyanide in bags or bulk containers, or uses cyanide in a mill process, the company shall have its compliance with the code independently audited and verified by an auditor listed on the ICMI website.[3]

3.9.1.3.  The operating company shall demonstrate that it has take steps to ensure that cyanide producers and transporters supplying the mining project are certified by the Cyanide Code.

3.9.2.  Construction

3.9.2.1.  In addition to the requirements of the Cyanide Code, the following design criteria shall be met:[4]

a. Impermeable secondary containment for cyanide unloading, storage, mixing and process tanks shall be sized to hold a volume at least 110% of the largest tank within the containment and any piping draining back to the tank, and with additional capacity for the design storm event.

b. Pipelines containing process solution [5]  shall utilize secondary containment in combination with audible alarms, interlock systems, and/or sumps, as spill control measures.

3.9.3.  Discharges

3.9.3.1.  Discharges to a mixing zone shall not contain cyanide, either alone or in combination with other toxins, that will cause acute toxicity to resident or migratory species.

3.9.4.  Monitoring

3.9.4.1.  The operating company shall monitor discharges to surface or groundwaters for weak acid dissociable (WAD) cyanide.

3.9.4.2.  If WAD cyanide is detected in discharges to surface waters, then the operating company shall also monitor total cyanide, free cyanide, and thiocyanate levels.

3.9.4.3.  If a mixing zone is utilized for the discharge to surface waters the operating company shall conduct whole effluent toxicity testing annually on the effluent to verify the absence of acute toxicity.[6]

3.9.5.  Reporting

3.9.5.1.  Cyanide water quality monitoring data shall be published on at least a quarterly basis on the mine or the operating company website in tabular format, and graphical format if available.

3.9.5.2.  If the operating company is a Cyanide Code signatory it shall include in its annual report or sustainability report a link to the company’s audit information and corrective actions published on the ICMI website.

Notes

The International Cyanide Management Institute (ICMI) Principles broadly state commitments that signatories make to manage cyanide in a responsible manner. Standards of Practice identify the performance goals and objectives that must be met in order to comply with the Principles. Separate Verification Protocols have been developed for cyanide production, transportation, and gold mining operations. Cyanide production, transportation, and gold mining operations are certified as being in compliance with the Code following an independent third-party audit (paid for by the operating company) verifying conformance with the Code’s Standards of Practice. Audit results are made public on the ICMI website to inform stakeholders of the status of cyanide management practices at certified operations. The IRMA Cyanide Standard requires the same auditing procedures, and certified auditors, as for the Cyanide Code.

Cross Reference to Other Chapters

 Chapter

 Issues

1.1—Legal Compliance As per Chapter 1.1, if there are host country laws governing cyanide transport, storage, use, etc., the company is required to abide by those laws. If IRMA requirements are more stringent than host country law, the company is required to also meet the IRMA requirements, as long as complying with them would not require the operating company to break the host country law.
2.2—Occupational Health and Safety Cyanide use is an occupational health and safety consideration, and its use, storage and transport may be included in the OHS risk assessment process.
2.3—Emergency Preparedness and Response The transportation of cyanide is a potential hazard to communities and the environment along transportation routes. Chapter 2.3 mandates emergency response planning for a spill, and requires coordination between the mine and emergency responders in adjacent communities.
2.7—Community Health and Safety The use of cyanide at mining operations may present a health risk to local communities, and may be analyzed during the community health and safety risk and impact assessment process.
2.13—Grievance Mechanism and Access to Other Remedies Stakeholders with complaints related to a operating company’s use of cyanide, can raise complaints through the company’s operational-level grievance mechanism. As per Chapter 2.13, the company is required to have a grievance mechanism available to stakeholders for filing complaints, and having them investigated and resolved in a timely manner.
3.1—Water Quality IRMA’s water quality criteria for cyanide discharge limits appear in Chapter 3.1, Tables 3.1a, 3.1b and 3.1c. If other approaches to water quality protection are taken as per Chapter 3.1, the cyanide discharge limits may differ from IRMA water quality criteria.
3.3—Mine Waste Management Chapter 3.3 contains references to effluent control for mine wastes containing cyanide (3.3.3.1), and monitoring and preventing impacts to wildlife from cyanide (3.3.11.1).
4.1—Environmental and Social Impact Assessment The potential impacts to nearby communities and the environment from cyanide may be examined as part of the ESIA, and mitigation strategies developed as a result.

 

Endnotes

1. International Cyanide Management Code. “Directory of Signatory Companies.”

2. An operating company whose ICMI certification is current, or conditionally current, at the time of an IRMA audit shall be considered in compliance with IRMA requirement 3.9.1.1.

3. This section does not apply to cyanide for laboratory use, or for other de minimis purposes.

4. This requirement applies to all storage facilities and mixing or processing tanks constructed at new mines, and new facilities and tanks constructed at existing mines.

5. Solution at a gold mine with a concentration of 0.5 mg/l WAD cyanide or greater. (ICMI. Cyanide Code)

6. Or, if the risk-based approach to water quality protection is used, the operating company many use other documented means deemed appropriate for verifying whether or not zones of acute toxicity exist. (See Chapter 3.1, Approach C, 3.1.7.2.b.)

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