IRMA Standard for Responsible Mining (Draft 2.0)
Flagged Issues

During the public comment period on draft v.2.0 of the IRMA Standard for Responsible Mining, the IRMA Steering Committee sought assistance in resolving challenging issues for which there is either a difference in opinion between stakeholder perspectives or the topics are ones that remain challenging for the broader world community..

We marked these types of challenges with a pink flag. You can search the Standard document for these flags by using the search term flag, or look for the pink flags in Chapters 2.1, 2.9, 2.12, 3.1, 3.2, 3.3, 3.7, 3.9, 3.10 and 4.2.

Additionally, there were four other topics on which IRMA sought input:

Artisanal Mining

IRMA is not planning on certifying artisanal mining operations. However, IRMA received comments from several stakeholders suggesting the need to include requirements for industrial-scale operations that have the potential to affect artisanal mining.

  • We are interested in hearing from stakeholders regarding best practice for industrial scale mines that interface with artisanal mines/miners
  • We are also interested in hearing from stakeholders with expertise in this subject area who might be willing to participate in a working group that would help IRMA draft best practice requirements for the ISM/ASM interface to be included in the IRMA Standard.
  • Note:  Any new requirements related to ISM/ASM will be released for public comment.

Small-to-Medium Sized Operations/Operators

IRMA is seeking to remove barriers that may prevent small-to-medium-sized companies from proposing mine sites for IRMA certification. IRMA recognizes that smaller companies may be less well resourced, and/or may not have the experience or systems in place that larger companies may have to carry out some of the requirements in the IRMA Standard. For example, companies with only a few mines may not have the experience with human rights or biodiversity assessments, either due to the geographical location or the regulatory expectations. Consequently, IRMA is considering potential approaches for creating flexibility for small companies. For example, IRMA could extend timelines for small-to-medium-sized companies to meet particular requirements. Such an approach would not lower the overall performance bar, but would provide greater flexibility for those companies to achieve IRMA certification.

  • We are interested in hearing from stakeholders regarding their opinions on whether IRMA should consider creating more flexibility for smaller enterprises, and if so, what sort of approaches might be considered that still ensure that those companies meet IRMA’s high performance bar.

Disclosure of Information

There are numerous requirements throughout the draft Standard for materials to be made public (e.g., assessments, monitoring data, etc.). The IRMA Steering Committee is in the process of reviewing all of the disclosure-related requirements in the Standard and is seeking a way to balance transparency in the reporting of information while not creating a reporting load that is overly burdensome for companies.

Also, presently, many of the requirements specifically state that a company must post certain information on its website. IRMA is considering whether it might make more sense to have a central repository for IRMA disclosures (e.g., the IRMA website), rather than having each company create a place on its own website for IRMA-related information. IRMA recognizes, however, that web-based materials are not appropriate for all stakeholders. So we want to be sensitive to the ability of all stakeholders to access information that is of critical importance to them.

  • IRMA welcomes any comments on the types of information that stakeholders and companies think should or should not be required to be reported (including in what format, and to whom), as well as input on whether a central repository for information from IRMA-certified mines would be a helpful tool for companies and interested stakeholders.

Timing of Certification

There are some requirements within the IRMA Standard that cannot be met once a mining operation has reached a certain stage – in other words, an operator cannot “turn back the clock” to change actions that have already occurred, nor can it meet time-dependent requirements that did not take place at the appropriate time. IRMA seeks to make its certification system available to any company that can demonstrate that is achieving the social and environmental objectives of the IRMA Standard.

The IRMA Steering Committee is actively considering how best to address non-compliances with the IRMA Standard that occurred during a mine’s early stages of development. In some chapters, readers will notice that the Scope of Application section has information on “New versus Existing Mines.” Where present, that subsection recognizes that some requirements in the chapter cannot be applied retroactively at existing mines, and clarifies how IRMA expects companies to demonstrate that they still meet the intent of the social and environmental objectives of the chapter.

  • We acknowledge that further attention (and guidance to companies and auditors) may be needed, and invite comments on this topic from stakeholders, including operators who may wish to seek IRMA certification for existing mines.
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