Book - A Guide To Audit & Assessment of Tailings Facility Management, MAC 2011

A Guide to
Audit and Assessment of

Tailings Facility Management
2011
A Guide
to Audit and Assessment of
Tailings Facility Management
2011 Mining Association of Canada

1105-350 Sparks Street
Ottawa, Ontario K1R 7S8
www.mining.ca
Foreword
It is with pleasure that I present, on behalf of the members of The Mining Association of
Canada (MAC), A Guide to Audit and Assessment of Tailings Facility Management.
The Guide complements our companion publications on tailings management:
n A Guide to the Management of Tailings Facilities, updated in 2011; and
n Developing an Operation, Maintenance and Surveillance Manual for Tailings
and Water Management Facilities, 2003.
The tailings management series is integral to MACs Towards Sustainable Mining (TSM)
initiative, and forms the basis for the tailings management performance indicators under
TSM.
This Guide is, as with the others in the series, the result of collaboration by members of a
team of Canadian mining industry practitioners and experts on the MAC Tailings Working
Group (TWG). We owe a debt of gratitude to the team members for the skill, expertise,
dedication and enthusiasm that they brought to the task of building consensus in dealing
with such complex subject matter. We also acknowledge the efforts of the many individu-
als and companies that have implemented comprehensive tailings management systems
across Canada and around the worldsince the original management guide was published
in 1998. This Guide builds upon many years of experience gained in implementing the
tailings management framework, as well as the knowledge and expertise of audit and
assessment practitioners in the field.
The Guide has been designed to meet the needs of the mining industry. It encourages and
provides a means of measuring safe and environmentally responsible management of
tailings facilities. I trust that the industry and others will find it a useful contribution to
continual improvement in this area.
Pierre Gratton
President & CEO
The Mining Association of Canada
A Guide to Audit and Assessment of Tailings Facility Management i

Preface
In 1998, The Mining Association of Canada (MAC) published A Guide to the Management
of Tailings Facilities. This was followed, first, in 2003 by the publication of Developing
an Operation, Maintenance and Surveillance Manual for Tailings and Water Manage-
ment Facilities and, now, by this publication, A Guide to Audit and Assessment of
Tailings Facility Management. Together the three guides provide a strong message to
tailings facility owners, operators and contractors: that the key to safe and environmen-
tally responsible management of tailings is consistent application of sound engineering
capability within an effective management framework, from initial site selection and
design, through construction and operations, to eventual decommissioning and closure.
The purpose of this Guide is to provide protocols for the audit and assessment of
conformance with the tailings management framework presented in A Guide to the
Management of Tailings Facilities (updated 2011 edition). It describes protocols both for
an audit of tailings facility management and for an additional, qualitative assessment of
that management.
Since MACs first tailings management guide was published, the tailings management
framework has been applied at mining operations across Canada and around the world.
Experience gained through the implementation and verification of tailings manage-
ment systems, and through operating, maintenance and surveillance manuals, has been
incorporated into both this Guide and a concurrent update to the original A Guide to the
Management of Tailings Facilities.
Since 1998, MAC has also embarked upon the Towards Sustainable Mining (TSM)
initiative. The tailings management framework is integral to TSM and forms the basis of
the tailings management performance indicators under TSM. The audit and assessment
protocols recommended herein complement the TSM tailings management assessment
protocol.
This Guide, like its companion guides, was prepared through a collaborative effort by
representatives of the Canadian mining industry who participate on the MAC Tailings
Working Group. MAC acknowledges and thanks all members of the Tailings Working
Group, past and present.
A Guide to Audit and Assessment of Tailings Facility Management iii

Table of Contents
1. INTRODUCTION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1
2. VERIFICATION THROUGH AUDIT OR ASSESSMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1
3. TAILINGS MANAGEMENT SYSTEM AUDIT. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1
Policy and Commitment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1
Roles and Responsibilities. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-1
Objectives. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-2
Managing for Compliance. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-2
Managing Risk . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-3
Managing Change. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-3
Resources and Scheduling. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-4
Emergency Preparedness and Response. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-4
Operational Control. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-5
Financial Control. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-5
Documentation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-6
Training, Awareness and Competency. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-6
Communication. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-7
Checking and Corrective Action. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-7
Management Review for Continual Improvement. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-8
4. TAILINGS MANAGEMENT SYSTEM ASSESSMENT. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1
Preamble. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1
Policy and Commitment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-1
Roles and Responsibilities. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-2
Objectives. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-4
Managing for Compliance. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-5
Managing Risk . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-6
Managing Change. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-8
Resources and Scheduling. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-10
Emergency Preparedness and Response. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-11
Operational Control. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-13
Financial Control. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-15
Documentation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-16
Training, Awareness and Competency. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-17
Communication. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-19
Checking and Corrective Action. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-20
Management Review for Continual Improvement. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-22
ANNEXES. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-1
A1 Approach to Audit and Assessment. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A1-1
A2 Sources of Information. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A2-1
iv The Mining Association of Canada

Chapter 1 Introduction 1
Tailings facilities are site-specific complex systems that have unique environmental and
physical characteristics. They pose significant environmental and business risks that
must be effectively managed for the long term. The mining industry has the technology
and resources to safely site, design, construct, operate, decommission and close tailings u A tailings facility
facilities, but there remains a need to continually improve their management in a consis- includes the collective
tent, safe and environmentally responsible manner through the full life cycle. structures, components
and equipment pertaining
The Mining Association of Canada (MAC) has published the tailings management series to tailings impoundment
of guides to help companies develop and implement comprehensive tailings management and management, includ
ing dams and reservoirs,
systems.
other related facilities
The first in the series, A Guide to the Management of Tailings Facilities, originally and appurtenances.
published in 1998, has been updated in 2011 to reflect the commitment to continual
improvement embodied in the tailings management framework. It recommends imple- u Tailings Manage-
menting a comprehensive tailings management framework to manage risk while integrat- ment System: a docu
ing environmental and safety considerations into each stage of the life cycle of a tailings mented set of processes
and practices that enable
facility, from initial site selection, through construction and operation, to eventual
an organization to man
decommissioning and closure. age its tailings safely and
The second guide, Developing an Operation, Maintenance and Surveillance Manual environmentally respon
sibly while increasing its
for Tailings and Water Management Facilities, was published in 2003. Building on the operating efficiency.
management guide, it outlines the information that a site-specific operation, maintenance
and surveillance (OMS) manual should contain to ensure that operating methods and
decisions are properly documented for ongoing reference.
The purpose of this third handbook is to provide protocols for verifying conformance
with the tailings management framework presented in A Guide to the Management of
Tailings Facilities. It describes protocols for both an audit of tailings facility management
and an additional qualitative assessment of that management. It is intended to be used by
internal and/or independent auditors, facility management and corporate management.
Applying these audit and assessment protocols can:
a) assist facility and corporate management to evaluate the implementation and
effectiveness of a tailings management system, to reduce risk, and to drive
continuous improvement; and
b) provide assurance to a companys CEO, Board of Directors and Communities of
Interest that tailings facilities are being effectively managed in conformance with
the MAC tailings management framework.
A Guide to Audit and Assessment of Tailings Facility Management 1-1

1 Introduction
The application of the protocols also provides a process to ensure that tailings facility
management is being implemented comprehensively and effectively. This can benefit an
organization by:
n increasing the awareness and understanding of tailings management issues by
managers and employees;
n improving the facility managements ability to achieve tailings management
objectives;
n providing a basis for and demonstrating due diligence in risk management;
n affirming compliance with regulatory requirements;
n reducing potential liability; and
n demonstrating a commitment to continual improvement.
Any areas of potential risk or weakness in management system design or implementation,
as identified during a management system audit or assessment, will warrant follow-up.
Both protocols recommended in this Guide are practical tools. They can be applied to
audits and assessments of tailings management throughout the life cycle of a tailings
facility, from initial site selection and design, through construction and operation,
to decommissioning and closure. Note, however, that audits and assessments are not
intended to directly assess the safety of dams or any other technical aspect of a facility.
These factors should be the subject of separate, specific technical or safety reviews within
an overall tailings management system.
Audits and assessments of tailings management are specialized activities, and the
processes and requirements for each are more fully elaborated upon in the following
chapters.
1-2 The Mining Association of Canada

Chapter 2 Verification Through Audit or Assessment 2
In this Guide, the terms audit and assessment describe two distinct protocols that,
when employed, can provide assurance that tailings facilities are being managed ef-
fectively and are in accordance with the tailings management framework presented in
A Guide to the Management of Tailings Facilities. The recommended protocols provide
guidance on the approach and methodology of verification to be implemented either
as an audit or as a more extended assessment. This guidance provides the information
necessary to design a detailed plan for an audit or assessment, customized to site-specific
needs.
n An audit is the formal, systematic and documented examination of an
organizations or facilitys conformance with explicit, agreed, prescribed criteria,
which are often requirements stipulated in law or regulation or, in the case of this
Guide, the MAC tailings management framework.
An audit is not based on opinion, nor is it designed to determine the root cause
of deficiencies or to evaluate management system effectiveness.
n An assessment goes beyond measuring against stipulated criteria (as in an
audit) to incorporate professional judgment in evaluating the effectiveness,
implementation, application and maintenance of a management system.
An assessment is driven by a concern for the quality of system design and
management process implementation. It can identify system deficiencies and
determine their root cause to provide a basis for improving the process.
This Guide has been designed to assist in the audit or assessment of application of the
MAC tailings management framework, which was originally introduced and has been
recently updated in A Guide to the Management of Tailings Facilities. The two protocols
address each aspect of the tailings management framework:
n Policy and Commitment
n Planning
Roles and responsibilities
Objectives
Managing for compliance
Managing risk
Managing change
Resources and scheduling
Emergency preparedness and response

2 Verification Through Audit or Assessment
n Implementation
Operational control, including OMS and monitoring
Financial control
Documentation
Training, awareness and competency
Communications
n Checking and Corrective Action
n Management Review
The Guide presents the two complementary protocols in separate, parallel chapters that
address the above-listed aspects of the tailings management framework.
Audit (Chapter 3):
n outlines the purpose and objective of audit; and
n provides specific questions to test conformance with the MAC Tailings
Management Framework.
Assessment (Chapter 4):
n outlines the purpose and objective of assessment;
n provides specific investigative checks to guide additional qualitative assessment of
the management system; and
n provides guidance to the rating of management process effectiveness through
examples of management process markers that meet the minimum accepted
threshold expectations or that may be regarded as demonstrating leadership as a
best practice.
The protocols are presented as a series of questions for audit and guiding statements for
assessment:
n What elements of a tailings management system are in place?
n How are they organized and implemented?
n Who has responsibility and accountability?
Annexes to the Guide provide additional background and information:
n an approach to audit and assessment; and
n typical sources of information and evidence.

Chapter 3 Tailings Management System Audit 3
Policy and Commitment Policy and Commitment
Roles and
Purpose: to verify that a tailings management policy has been established that expresses intentions, Responsibilities
commitments and principles in relation to tailings management.
Is there a policy statement that describes the commitment to tailings management?

Is it signed and dated by current senior management?
Does the policy include commitments to:
n implementing the principles outlined in the MAC tailings management
framework;
n locating, designing, constructing, operating, decommissioning and closing tailings
facilities in a manner such that:
all structures are stable;
u Executive account
all solids and water are managed within designated areas; and ability for tailings
all aspects of tailings management comply with regulatory requirements and management is necessary
to signal the importance
conform with sound engineering practice, company standards, the MAC
of tailings facilities to our
TSM Guiding Principles, the MAC tailings management framework, and business and the adverse
commitments to Communities of Interest; impacts that improper
tailings management
n taking responsibility for implementing this framework through the commitments practices may have on
and actions of its employees; the environment and our
n consulting with Communities of Interest, taking into account their considerations reputation.
relating to the tailings facility management; and It is expected that the
executive officer will
n establishing an ongoing program of review and continual improvement to manage delegate responsibility
health, safety and environmental risks associated with tailings facilities? for tailings management,
budgetary issues and
other tailings-related
Roles and Responsibilities functions to operations
and other senior corporate
personnel, while retaining
Purpose: to verify that responsibilities and accountabilities for tailings management are specified, that all overall accountability for
employees are aware of their respective roles, and that a tailings management reporting structure the management of tail
has been established. ings and its outcomes.
Has overall accountability for tailings management been assigned to an executive officer
(CEO or COO) of the company, with responsibility for ensuring that an appropriate
management structure is in place?
Have both the corporation and its Communities of Interest been provided assurance that
tailings facilities are managed responsibly?

3 Tailings Management System Audit
Roles and Have roles, responsibilities, budgetary authority and reporting relationships been:
Responsibilities
n defined;
Objectives
n assigned; and
Managing for
Compliance n communicated
to implement the tailings management framework through all stages in the facility life
cycle?
u Tailings facility plans Objectives

typically address:
l objectives, targets and Purpose: to verify that objectives and targets for effective tailings management through all stages of the life
performance measures; cycle have been established and provide a basis for planning to manage tailings in conformance with
l permits and approvals; the tailings management policy.
l communication
procedures among Are objectives and targets established for the tailings facility?
the team with senior
management and n Do they deal with all phases of the facility life cycle, including eventual closure?
with Communities of n Are they consistent with regulatory requirements, company standards, the MAC
Interest;
tailings management framework, commitments to Communities of Interest, and
l site selection and char sound engineering and environmental practices?
acterization criteria;
Are the tailings facility plans also in accordance with regulatory requirements, company
l safety, environmental
and engineering design standards, the MAC tailings management framework, commitments to Communities of
criteria; Interest, and sound engineering and environmental practices?
l construction, operating, Have Communities of Interest been consulted to identify appropriate community expec-
decommissioning and tations for tailings facilities?
closure procedures;
l requirements for docu Does the closure plan address:
mentation, including
n protection of public health and safety;
as-built records;
l maintenance, surveil n mitigation of negative environmental impacts; and
lance, inspection, n acceptable post-closure use within a feasible technical and economic framework?
reporting and review
requirements; and
l knowledge and skills Managing for Compliance
requirements.
Purpose: to verify that the requirements of applicable regulations, permits and other commitments are
understood by and communicated to all facility employees, and that there are management
processes in place to ensure compliance.

Tailings Management System Audit 3
Are the legal requirements for, and actions needed to ensure compliance of, the tailings Managing for
facility known, documented and communicated to facility employees? Compliance
Managing Risk
Are processes and procedures in place to ensure measurement and compliance?
Managing Change
Is there evidence that the facility is in compliance with legal requirements?
Have objectives and management plans been established to address compliance issues,
including for the reporting on non-compliance?
Managing Risk
Purpose: to verify that there is a risk management plan that addresses risks associated with a tailings facility
throughout its life cycle.
Is there a formal risk management plan in place?

Does the risk management plan include:
n a definition of acceptable risk in the context of the facility;
n a formal risk assessment that identifies, evaluates and ranks possible triggers and
failure modes associated with the tailings facility throughout its life cycle;
n processes and procedures to minimize the likelihood of adverse safety or
environmental impacts and to detect and respond to potential failures at the
facility? (See also the section on emergency preparedness and response.)
Managing Change
Purpose: to verify that processes and procedures are in place to ensure that the integrity is maintained of both
the tailings management system and the approved facility designs and plans, and that:
temporary or permanent modifications or alterations to physical plant, design,
construction, operation, controls, personnel, procedures; or
changed regulations, operating conditions or other requirements
do not introduce new, unacceptable, and/or unmanaged environmental, health or safety risks into
the operation of the tailings facility or affect the integrity of the facility.
Have processes and procedures been established and documented:

n to ensure that the integrity of both the management system and the approved
facility designs and plans is maintained during implementation; and
n to manage changes made to approved personnel, roles and responsibilities,
designs and plans?

Managing Change Has a process been established to identify, evaluate the impact of, approve and document
Resources and changes made to approved plans or designs?
Scheduling
Has a process been established to identify, evaluate the impact of, and document changes
Emergency to legal requirements?
Preparedness and
Response Are procedures updated to incorporate changes?
Resources and Scheduling

Purpose: to verify that human, physical and financial resources essential to implementing the tailings facility
management are defined and allocated.
Have the resources and schedule required to manage tailings effectively and safely been
defined and allocated, including:
n staffing;
n design and review support;
n specialized skills development;
n technology and equipment; and
n financial resources?
Have adequate human and financial resources been allocated for decommissioning and
closure?
Emergency Preparedness and Response

Purpose: to verify that procedures and resources to effectively respond to reasonably foreseeable emergency
situations associated with a tailings facility are defined and in place.
Have the tailings facility and its related operations been systematically examined to
identify possible accident or emergency situations, such as through the risk management
plan?
Have procedures been developed and documented for response to emergency situations
as they arise, and to prevent and mitigate potential impacts?
Are the emergency preparedness and response plans consistent with identified possible
emergency situations?
Are employees trained in emergency response?

Have the emergency preparedness and response plans been communicated to internal Emergency
and external interested and affected parties? Preparedness and
Response
Are the emergency preparedness and response plans tested on a regular basis, and are the Operational Control
results of such tests documented and reported?
Financial Control
Operational Control
Purpose: to verify that effective operational controls are in place to implement the tailings management plans,
to achieve compliance and objectives, and to manage risks throughout the facility life cycle.
Are operational controls in place to ensure:

n implementation is in accordance with legal requirements, approved designs,
plans, sound engineering and environmental practices, and the MAC tailings
management framework, including:
assembling a qualified team with assigned responsibilities;
routinely and regularly inspecting, monitoring, testing, recording, evaluating
and reporting key characteristics and performance parameters of the tailings
facility;
calibrating equipment;
identifying existing or emergent problems; and
t racking performance and compliance with legal requirements, targets and
objectives;
n all required permits and approvals are acquired and maintained; and
n contingency plans and emergency preparedness and response plans are
implemented and tested periodically?
Are procedures in place to detect, document and correct non-conformance with plans
and deviations from operational procedures, objectives and targets?
Financial Control
Purpose: to verify that financial resources allocated to tailings management are effectively applied to ongoing
operation, maintenance and surveillance of the tailings facility.
Have financial resources, commensurate with the defined objectives and needs, been
allocated for tailings management?

Financial Control Has a financial control system been implemented to track capital and operating costs of
Documentation tailings management?
Training, Awareness and Are financial controls and cost provisions reviewed regularly?
Competency
Documentation
Purpose: to verify that current information on tailings management is made available to employees for
carrying out their responsibilities, that records relating to the tailings management are maintained,
that appropriate information is available for training employees, and that records are maintained to
demonstrate due diligence in tailings management.
Is there a document management system, for both electronic and hard copy, to ensure
that key aspects of tailings management are documented?
Are required documents periodically reviewed, revised or updated?
Does the system include a document control program to ensure that:
n current versions of documents, including as-built drawings, are located at readily
accessible, identified locations; and
n obsolete versions of documents are promptly removed from use and retained in a
secure place to provide a historical record?
Training, Awareness and Competency

Purpose: to verify that procedures are in place to ensure that personnel employed in tailings management are
competent, have a full understanding of the requirements of the facility operation and management,
and are aware of impacts that may result from the facility.
Are the personnel who are employed for tailings facility design, construction, operation,
decommissioning and closure qualified by virtue of education, experience, training, and/
or testing?
Is appropriate training provided to all personnel, including contractors and suppliers,
whose work may significantly affect the tailings facility, specifically addressing:
n facility management plans, permits and approval requirements;
n the importance of conformance with design, operational controls and change
management procedures;
n potential risks;

n significant actual and potential environmental impacts; Training, Awareness and
Competency
n emergency preparedness and response requirements; and
Communication
n individual roles and responsibilities in achieving conformance with the
Checking and Corrective
requirements? Action
Communication
Purpose: to verify that procedures are in place for appropriate two-way communication of significant
information and decisions with all relevant personnel, including senior management, and for open
and effective communication of performance and significant issues respecting tailings management
with Communities of Interest.
Are documented procedures implemented for communications among all personnel who
have roles and responsibilities in implementing the tailings management plan?
Do the communications procedures address reporting significant information and deci-
sions regarding the management and performance of tailings facilities to senior manage-
ment and to Communities of Interest?
Checking and Corrective Action

Purpose: to verify that procedures are in place for periodic checking of the tailings management system to
ensure policies and commitments are being met, objectives and targets are being attained, and
plans and procedures are being followed, and, where there is a non-conformance, that there is
appropriate response.
Are procedures in place for periodic formal inspection and review of the entire tailings
facility, to:
n measure progress towards attainment of objectives and targets;
n confirm facility operation in compliance with regulatory requirements and in
conformance with plans and commitments;
n review existing or emergent problems;
n re-visit the facility design, construction, operation, decommissioning and closure
plans and programs;
n update the evaluation of downstream risks, the overall risk assessment and the
risk management plan;
n evaluate performance in the management of tailings;

Checking and Corrective n evaluate the need for changes or updates to risk management plans, contingency
Action plans and emergency preparedness and response plans;
Management Review for
n identify items requiring corrective action; and
Continual Improvement
n communicate promptly the results of such inspection and review to senior
management?
Is the schedule for formal inspection and review documented, and is it appropriate for
the level of identified risk?
Are procedures in place to ensure timely corrective action to non-conformances,
including:
n development of action plans; and
n assignment of accountability, responsibility and timelines for completion?
Management Review for Continual Improvement

Purpose: to verify that the tailings management system is reviewed annually, that it remains effective and
that it drives continual improvement in performance.
Is there an annual corporate review of tailings management to:

n evaluate the performance of the tailings management system, considering
inspection, audit and assessment reports, changing circumstances, monitoring
results, spills and other incidents, recommendations, and the commitment to
continual improvement;
n evaluate the continuing adequacy of, and need for changes to, policies and
objectives and performance of the tailings management system; and
n address the need for changes to commitments to Communities of Interest.
Are the results of the annual review of tailings management reported to the accountable
executive officer?

Chapter 4 Tailings Management System Assessment 4
Preamble Preamble
Policy and Commitment
An assessment of a tailings management system builds on and extends the audit pro-
cess, from an essential evaluation of conformance with the MAC tailings management
framework to a qualitative assessment of the effectiveness, implementation, application
and maintenance of actual tailings management processes. The assessment protocol
thus begins with and includes the audit protocol questions presented in Chapter 3. The
responses to those questions provide a starting point for the recommended additional
checks presented in this chapter, which are designed to elicit qualitative information on
the underlying management processes.

Purpose: to evaluate the effectiveness, implementation, application and maintenance of policies and
commitments for tailings management.
In addition to the questions posed for this aspect of the tailings management system
included in the Audit Protocol (Chapter 3), undertake the following reviews and
evaluations.
Review the process for developing, implementing, maintaining and reviewing the tailings
management policy. Evaluate how the policy:
n was developed;
n aligns with the organizations overall business strategy and vision;
n expresses the level of commitment expected;
n is reviewed and how often it is updated by senior management; and
n is communicated to and how well it is understood by employees.
Also evaluate how Communities of Interest have been involved in the development and
review of the policy, including their level of involvement and how the policy is made
available to them.

4 Tailings Management System Assessment

Roles and
Responsibilities Meets Threshold Expectations Leadership Position
The facility has formal policy and commitments It is formally demonstrated that the implementation
consistent with the MAC tailings management of corporate policy and commitments on tailings
framework as presented in A Guide to the Manage is consistent with the MAC tailings management
ment of Tailings Facilities, perhaps embedded within framework.
overall site management policies, endorsed by senior The tailings management policy and commitments
management and effectively implemented. Budgets are consistent and aligned with the companys
are allocated specifically for tailings management. overall business strategy and vision.
The policy statement is current and signed by senior The policy statement is a living document, reflects
management. business risks and is formally and periodically
The process for regularly reviewing the policy is reviewed and revised, particularly in the event of
informal. significant incidents.
Independent validation of corporate policy and com-
mitments on tailings has been implemented.
Roles and Responsibilities

Purpose: to evaluate the effectiveness, implementation, application and maintenance of the assignment of
roles, responsibilities and accountabilities with respect to tailings management to ensure that all
employees are aware of their respective roles and that a tailings management reporting structure
has bee established.
evaluations.
Identify the executive officer assigned overall accountability for tailings management.
Review how that accountability has been assigned.
Evaluate how the tailings management structure implemented by the executive officer
provides assurance to the corporation and its Communities of Interest that tailings facili-
ties are managed responsibly.
Evaluate how roles, responsibilities, budgetary authority and reporting relationships have
been assigned for:
n establishing tailings facility objectives and targets;
n maintaining awareness of current legislation and other requirements, future
regulatory trends, and compliance with regulatory and other requirements;

Tailings Management System Assessment 4
n managing risk; Roles and
Responsibilities
n managing change;
n ensuring adequate human, technological, and financial resources are assigned to
locate, design, operate, decommission and close tailings facilities in accordance
with the policy and objectives;
n establishing operational controls, including adherence to them;
n conducting training and evaluating the competencies of tailings management
personnel;
n maintaining documented procedures, including the OMS manual, and important
records;
n establishing and maintaining document control systems;
n receiving, evaluating and responding to information requests from employees and
Communities of Interest;
n communicating important information to employees and Communities of Interest;
n identifying and evaluating non-conformance and implementing corrective and
preventive action;
n conducting management reviews for continual improvement; and
n developing, implementing and maintaining emergency preparedness and
response.
Evaluate how roles, responsibilities, accountabilities, and authority levels are communi-
cated to affected personnel.
Evaluate how the organization manages potential for overlaps or conflicts between
individuals and assigned roles, responsibilities, accountabilities and authority levels.
Evaluate how departures from established standards or requirements are made:
n who has assigned authority to grant such departures; and
n what processes ensure that departures from established standards or requirements
are reported and documented?

Roles and
Responsibilities Roles and Responsibilities
Objectives Meets Threshold Expectations Leadership Position
Formal assignment of specific responsibilities and The executive officer assigned overall account-
accountabilities for tailings management to an ability for tailings management actively promotes
executive officer (CEO or COO) of the company, with responsible management of tailings through the
responsibility to ensure that an appropriate tailings tailings management system to provide assurance to
management system is in place to provide assurance the corporation and its Communities of Interest that
that tailings facilities are managed responsibly. tailings facilities are managed responsibly.
Tailings management team has clearly defined and The company can demonstrate that the roles, re-
documented roles, responsibilities and accountabili- sponsibilities and accountabilities of staff have been
ties to implement the framework through all stages in assigned and are well understood.
the tailings facility life cycle. The executive officer participates directly in consulta-
tions with Communities of Interest to underscore the
commitment for responsible tailings management.
Objectives
Purpose: to evaluate the effectiveness, implementation, application and maintenance of established
objectives and targets for tailings management in conformance with the tailings management policy
and commitments through all stages of the life cycle.
included in the Tailings Management System Audit protocol (Chapter 3), undertake the
following reviews and evaluations.
Review the process used for establishing objectives and targets for the tailings facility, in
line with stated policy.
Identify who is responsible and accountable for setting objectives and targets for tailings
management.
Evaluate the processes used to ensure that tailings facility objectives, targets and plans,
including closure plans, are:
n prioritized in relation to the results of risk assessments;
n applied to maintain compliance with relevant regulatory requirements,
company standards, the MAC tailings management framework, commitments to
Communities of Interest, and sound engineering and environmental practices;
n meaningful and measurable;

n tracked using meaningful and measurable indicators; Objectives
n developed in association with the employees who are responsible for achieving Managing for
Compliance
them;
n communicated to those individuals who are expected to achieve them;
n aligned with the views of external Communities of Interest;
n regularly reviewed and correlated to performance, and then revised, as necessary,
to reflect desired improvements in tailings facility performance; and
n reviewed and revised to reflect significant lessons leaned from incidents.
Objectives
Meets Threshold Expectations Leadership Position
Objectives, targets and action plans are set for Objectives for tailings management are established
tailings management through an annual, informal using similar processes to those for a business plan.
planning process. They are strategic in scope, measurable, tracked, and
Objectives are developed based on identified signifi- take into account stakeholder needs, risks posed to
cant risks, regulatory requirements and commitments, the business, business opportunities that could be
and decommissioning and closure requirements. realized through effective tailings management, and
the business strategic plan.
Measurable tailings management objectives are
incorporated and tracked in the business strategic Objectives are kept current through periodic review,
plan, and accountability for delivery is assigned and targets and action plans are correspondingly
updated.
The objectives include consideration of sustainable
development, climate change, life-cycle analysis, and
future scenario planning.
Managing for Compliance

Purpose: to evaluate the effectiveness, implementation, application and maintenance of management
processes to ensure compliance with applicable regulations, permits and other commitments,
and to ensure that these are communicated to all employees who are responsible for compliance.
evaluations.
Review the processes and procedures that are used to:
n identify and track changes to legal and other requirements with which the facility
must comply; and

Managing for n ensure compliance with permit conditions (e.g., monitoring frequency, reporting
Compliance schedule, documentation).
Managing Risk
Evaluate how the compliance processes and procedures:
n assign responsibility for maintaining current awareness of legal and other
requirements;
n ensure that the tailings or water management facility incorporates legal and other
requirements into its objectives;
n communicate legal and other requirements to those expected to comply with
them; and
n ensure the completion of periodic environmental, health and safety compliance
audits.
Managing for Compliance
Compliance and associated monitoring requirements Compliance is consistently achieved and strong
are documented and well integrated into operating systems are in place.
procedures. Compliance status is routinely and transparently
Action plans are in place to ensure that calibration of reported to the public.
equipment, monitoring effectiveness, and compli- Permit needs are identified early. Permit development
ance; accountability for delivery is assigned. and negotiation process is streamlined.
Compliance exceptions are minor and are addressed There is active participation in development of
in a timely manner. regulatory agenda.
Regulatory developments are tracked on an ongoing In all jurisdictions, including those without a strong
basis and communicated through the organization to regulatory framework, the facility applies technically
those responsible for compliance. proven measures to protect the health and safety of
their employees, contractors and communities and
seeks to minimize the impact of their operations on
the environment and biodiversity, through all stages
of development, from exploration to closure.
Managing Risk
Purpose: to evaluate the effectiveness, implementation, application and maintenance of the risk management
plans to ensure management of risks associated with a tailings facility throughout its life cycle.
evaluations.

Review the risk management system. Evaluate how it addresses: Managing Risk
n hazard identification, risk assessment and risk management, including the

definition of unacceptable risk;
n appropriateness of the hazard identification methodology for the facility and its
unique issues (e.g., what-if, what-if-checklist, potential problem analyses, failure
mode effects analysis, hazard and operability studies);
n training for personnel involved in risk management (e.g., issue identification, risk
assessment, ranking);
n ranking and prioritizing risks, setting action thresholds (risk tolerance) and
communicating the results of risk assessments;
n maintenance of a risk register to ensure that issues raised are not eliminated
until actions are taken or the risk reassessed and found to be below an acceptable
threshold;
u Effective risk assess
n recommendations for mitigation of unacceptable risks; and
ment is the cornerstone of
n ensuring that risk assessments are current and adequately reflect current a management system for
conditions, operations and processes. the design, construction,
operation, decommission
ing and closure of tailings
Managing Risk facilities.
A formal hazard identification, risk assessment and The process addresses the full range of relevant
risk management program is in place for the facility, health, safety and environmental risks, including
including mitigating, contingency and emergency emerging issues. Business management has a
plans to deal with significant risks throughout the full detailed understanding of the health, safety and
life cycle. environmental risks it faces.
Methodologies used are appropriate to the risks be- The process is incorporated into routine decision
ing considered and are documented. making, requiring business managers to consider
The process covers the major health, safety and tailings management risks for operations, business
environment risks, and ensures that new or changing and strategic planning.
risks are identified and appropriately evaluated. Rigorous, well-documented assessments of tailings
Hazards or issues are assessed, ranked and prioritized management risks yield highly reliable, replicable
for normal operating conditions, shut down and startup results well accepted by business managers.
and reasonably foreseeable emergency situations.
Communities of Interest are consulted to inform them
of the risk profile and risk management plans.
Tailings management risk information is generally
timely for business decision making.

Managing Change Managing Change

Purpose: to evaluate the effectiveness, implementation, application and maintenance of processes and
procedures to manage change in the tailings facility management, to ensure that temporary or
permanent modifications do not introduce new, unacceptable, and/or unmanaged environmental,
health or safety risks into the operation of the tailings facility or affect the integrity of the facility.
evaluations.
Determine who has been assigned the responsibility for:
n filing change requests;
n training employees; and
n updating process safety information and operating procedures, and ensuring the
conduct of necessary reviews.
Review the management of change process. Evaluate how it:
n defines change;
n sets the scope of the management of change process (i.e., what is included, at what
level, and what is not);
n involves all necessary employees (including environmental and permitting
functions);
n links the management of change process to the facility risk identification and
management process;
n requires risk assessments to ensure that changes are not introducing new risks,
including recommendations for action to mitigate risk;
n confirms that risk assessments and mitigation actions are documented;
n identifies authority levels required to:
approve
changes in design, construction, operation, or decommissioning of
tailings facilities;
review work orders and purchase orders,
grant extensions to temporary changes; and
make emergency changes;
n ensures that permits, site plans, process and instrumentation diagrams and
documentation of operating procedures, etc., are kept current and reflect changes
made;

n requires that action plans to mitigate risks are followed up to ensure that planned Managing Change
actions were actually carried out;
n includes a process to ensure that temporary changes are time limited;
n grants extensions to time-limited temporary changes, and makes provision for
emergency changes;
n requires that employees affected by the changes are informed of them; and
n ensures that major changes result in updating the training materials, and if
needed, retraining of affected employees.
Managing Change
There is a formal process in place that defines There is evidence that management of change proce-
changes subject to change management procedures dures are consistently followed.
and that provides direction on managing the risks Communities of Interest are consulted to inform them
that may be associated with changes to processes, of change management procedures.
plans, procedures, equipment and controls.
There is a defined time limit for temporary changes
and clear definition of idle and redundant plans.
Changes are subject to a formal approval by a quali-
fied individual with designated accountability.
Change approvals take into account possible impacts
on the integrity of the facility and current approved
designs and permits.
Operating instructions, training manuals and other
documents are modified, as necessary, to reflect the
result of changes, and these changes are communi-
cated to all who have a need to know.
There is a systematic process for maintaining site
plans and process and instrumentation diagrams for
all process modifications and additions, and these are
readily accessible in hard or electronic copy.
Formal hand-over and commissioning procedures are
in place.
The change management procedures are kept current.

Resources and Resources and Scheduling

Scheduling
Purpose: to evaluate the effectiveness, implementation, application and maintenance of the definition and
allocation of human, physical and financial resources essential to the implementation of tailings
facility management.
evaluations.
Review how human, physical and financial resource requirements to manage the tail-
ings facility in conformance with the policy, objectives and targets are identified and
allocated.
Evaluate how progress is tracked against the schedule.
Resources and Scheduling
There is formal designation of the essential resources The tailings facility is managed as a discrete busi-
and schedule required to effectively and efficiently ness unit, with specific assignment of resources,
implement tailings management. accountabilities and reporting.
Resources and scheduling requirements are reviewed Where possible, Communities of Interest are aware
regularly. of this formal designation, review and assignment.
The resources and scheduling designated in the Any company cost cutting or downsizing considers
resource plan are actually assigned to the facility and risk management for tailings.
tracked.

Emergency Preparedness and Response Emergency
Preparedness and
Response
Purpose: to evaluate the effectiveness, implementation, application and maintenance of procedures and
resources to respond to reasonably foreseeable emergency situations associated with tailings
facilities.
evaluations.
Review the emergency preparedness and response procedures, and allocated resources.
Evaluate how they:
n ensure emergency situations that could be reasonably anticipated to occur are
identified, including potential on-site and off-site related impacts;
n ensure that the emergency preparedness and response plans are consistent with
identified emergency situations;
n ensure that contractors, visitors, emergency response personnel, mutual aid teams,
etc. have been trained on their responsibilities and designated actions under the
emergency plan; and
n ensure that all emergency contact services numbers are kept up-to-date, readily
available and listed in a prominent part of the plan.
Evaluate how the emergency preparedness plan for the tailings facility has been:
n integrated into the overall emergency preparedness and response plans for the
broader mine site: and
n is periodically tested and updated.
Evaluate how the facility enters into and manages agreements with other organizations
(e.g., fire, rescue, police) as appropriate to provide equipment and assistance during an
emergency. For example, has the facility adopted the recommendations of the UNEP
Guidance for the Mining Industry in raising Awareness and Preparedness for Emergen-
cies at the Local Level (APELL)?
Determine if an emergency mutual assistance agreement has been effected with other
operators in the region.

Emergency
Preparedness and Emergency Preparedness and Response
Response
The facility operations are systematically examined to The facility emergency response plan is tested by
identify potential accidents or emergency situations. means of simulated incidents involving external
There are formal procedures for preventing and emergency services and the community, particularly
mitigating the potential impacts and for responding downstream water users or inhabitants.
to emergency situations as they arise. Communities of Interest provide input into the
Employees are trained in emergency response. development of the facility emergency response plan,
and the plan is regularly reviewed with Communities
The emergency preparedness and response plan
of Interest.
has been communicated to internal and external
interested and affected parties.
The facility emergency response plan is coordinated
with overall corporate emergency preparedness and
crisis management plans.
Effective coordination exists with local authorities
and off-site response and service providers.
Communities of Interest are informed of the plan,
how it is implemented and how it may involve local
communities.
The emergency preparedness and response plan
is regularly tested, the plan is updated to reflect
site changes and lessons learned, and the results
documented.

Operational Control Operational Control
Purpose: to evaluate the effectiveness, implementation, application and maintenance of operational controls
to achieve compliance and objectives, and to manage risks throughout the facility life cycle.
evaluations.
Review the operational controls in place at the tailings facility, especially as they relate to
priority risks and environmental impacts, including:
n engineering controls;
n administrative measures;
n personal protective equipment; and
n other measures, such as standard or specified operating procedures.
Evaluate how the operational controls:
n are developed, authorized, approved and implemented;
n specify roles, responsibilities, accountabilities and authorities;
n are integrated into employee training;
n address startup, shutdown, emergency shutdown, and startup after an emergency
shutdown;
n are documented; and
n are periodically reviewed, audited and/or inspected.
Evaluate how non-conformance with operational controls is managed.
Review the document control procedures related to operational controls and verify that
document management requirements are being met.

Operational Control
Operational Control
Effective controls are in place to manage risks, There is validated implementation of:
including health, safety and environmental require- n e ffective controls to manage risks, achieve
ments, to achieve compliance and objectives, and to compliance and objectives, and provide
provide effective tailings management throughout the effective tailings management throughout the
facility life cycle. facility life cycle
The facility has a tailings OMS manual in confor- n a n OMS manual in conformance with
mance with Developing an Operation, Maintenance Developing an Operation, Maintenance and
and Surveillance Manual for Tailings and Water Surveillance Manual for Tailings and Water
Management Facilities that is fully implemented; Management Facilities;
roles and responsibilities for operating personnel
n a formal annual review of the OMS manual to
are documented; formal training plans for personnel
ensure that it truly reflects current condi-
are implemented; clear lines of reporting are defined
tions, particularly in the event of significant
between operators, maintenance, surveillance and
incidents;
management personnel; and emergency prepared-
ness and response plans are documented. n a n annual management review of the overall
tailings management policy; and
Tailings management standards and procedures are
consistent with other operating procedures. While n e mergency preparedness and response plans
they may be stand-alone documents, for example, testing.
contained in a tailings OMS manual, there has been Employees are engaged in developing, reviewing and
an attempt to ensure that they are relevant to the line updating the operational controls.
organization and to operational realities. Tailings management standards and procedures are
Procedures are subject to a formal approvals process integrated into, and are seamless with, standard
that involves line management. operating procedures and work instructions for
Operational controls and responses are routinely managing operations.
tested.
Communities of Interest are informed of pertinent
operational controls as well as pertinent changes to
operational controls and procedures.

Financial Control Financial Control
Purpose: to evaluate the effectiveness, implementation, application and maintenance of financial controls
for ongoing operation, maintenance and surveillance of the tailings facility, including for eventual
decommissioning and closure.
evaluations.
Review the allocation and tracking of financial resources for tailings management.
Evaluate how:
n the financial resources to meet tailings facility policy, objectives and targets are
identified and allocated;
n the costs for tailings management are tracked against budget; and
n financial resources for the decommissioning and closure of the tailings facility are
allocated.
Verify that asset retirement obligation estimates are completed and submitted.
Financial Control
Sufficient financial resources have been allocated The organizations capital and operating budget
for ongoing facility design, construction, operation, decision-making process includes input from
maintenance and surveillance, as well as for eventual individuals who are responsible for operating and
decommissioning and closure. maintaining the tailings management system.
A financial control system to track capital and The tailings facility is managed as a discrete busi-
operating costs of tailings management has been ness unit, with specific cost codes and budgeting
implemented. of tailings-related resources.
Financial controls and cost provisions are reviewed
regularly.

Documentation Documentation
Purpose: to evaluate the effectiveness, implementation, application and maintenance of documentation and
information management to ensure that employees have current information available to carry
out their responsibilities, that records relating to the tailings management are maintained, that
appropriate information is available for training employees, and that records are maintained to
demonstrate due diligence in tailings management.
evaluations.
Review the tailings management system documentation and the OMS manual.
Evaluate how the documentation and information management procedures:
n identify the important records and documents to control;
n establish roles and responsibilities for records and document control;
n ensure that only the most current version of procedures is available; and
n ensure that obsolete documents are archived for future reference and preservation
of knowledge.
Documentation
Facility plans, as-built drawings, procedures and There is validation that documentation of facility
processes required for the management of tailings plans, as-built drawings, procedures and pro-
facilities, as described in A Guide to the Manage cesses are prepared and kept up-to-date.
ment of Tailings Facilities, are prepared and kept Information technology is used to efficiently man-
up-to-date and immediately available to all who age tailings management records.
have need to access them.
Document control systems are consistent across
Records are kept to track achievement of targets, the facility.
objectives and regulatory compliance at the tailings
facility.
Documents are periodically reviewed to ensure that
they remain current.

Documentation
Documentation (continued)
Training, Awareness and
Meets Threshold Expectations Leadership Position Competency
There are procedures for controlling documents relat-

ing to tailings management to ensure that:
n t he current version of a document is available
and in use;
n obsolete documents are removed from use;
n superseded documents are archived; and
n a n appropriate repository is designated for
documents necessary to be kept post-closure.
Communities of Interest are informed of pertinent
documentation that supports demonstration of the
facility due diligence.

Purpose: to evaluate the effectiveness, implementation, application and maintenance of personnel training
and experience to ensure a full understanding of the requirements of the facility operation and
management and to be aware of the impacts that may result from the facility.
evaluations.
Review how:
n competency requirements are developed for each job at the tailings facility
(knowledge, training, physical capability etc.); and
n deficiencies in required competencies are identified.
Evaluate how the competency and training program addresses:
n overall site requirements for tailings management;
n job specific requirements;
n site-specific orientation;
n the need to understand tailings facility management plans, permits and approval
requirements;
n the importance of conforming to design;

Training, Awareness and n the identification and management of risk;

Competency
n the identification of significant environmental impacts; and
n emergency preparedness and response requirements.
Evaluate the way in which required training is provided, including:
n how the training is provided (i.e., external or internal courses);
n how the competencies of the trainers are assessed;
n what training materials are used;
n how training materials are developed and kept current;
n how the effectiveness of delivered training is assessed (written exams, observation
on the job etc.); and
n how the requirement for refresher training is assessed.
Evaluate how contractors, new or transferred-in employees, become aware of
requirements.
Evaluate how training is documented and communicated.
Compentency
Formal job descriptions for all work in tailings man- There is demonstration that tailings personnel have
agement are in place. the appropriate competencies on the basis of educa-
A formal training plan exists that addresses training tion, training or experience, including an understand-
needs assessment for all personnel including, as ing of the potential consequences of departure from
appropriate, contractors and consultants working on procedures. Records demonstrating these competen-
tailings management. This includes specific environ- cies are retained.
ment, health and safety aspects for each job. Awareness activities are fostered in a learning envi-
Qualified personnel are employed for tailings facility ronment, beyond basic competency training needs.
design, construction, operation and closure. Employees are actively involved in the ongoing
Processes are in place to test competency and to development and upgrading both of determining
determine training needs. competency needs and of training programs.
Training is delivered according to the plan, including

refresher training.
The job descriptions, training, course materials and
the training plan are kept current.

Communication Communication
Purpose: to evaluate the effectiveness, implementation, application and maintenance of communication
procedures to ensure appropriate two-way communication of significant information and decisions
with all relevant personnel, including senior management, and for open and effective communication
of performance and significant issues respecting tailings management with Communities of Interest.
evaluations.
Review the procedures for the timely communication of relevant information about the
tailings facility (e.g., policy, objectives and targets, operational controls, and overall tail-
ings performance including safety, health, and environmental information) to employees
and Communities of Interest.
Evaluate how:
n the communications system provides for two-way exchanges of views and
information;
n the responsibility for ensuring effective communication has been assigned;
n records of relevant communications to employees and Communities of Interest are
kept;
n the views of employees and Communities of Interest are considered in decisions
about tailings management; and
n decisions regarding tailings management are reported back to employees and the
Communities of Interest.
Communication
Formal procedures are established and maintained There is validation that procedures for commu-
for two-way communication of significant information nication of significant information and decisions,
and decisions to all relevant personnel, including operating procedures and changes to procedures and
senior management. reporting systems are in place, including procedures
The communication procedures include operating for communications with Communities of Interest.
procedures and changes to procedures, company Information technology is used to efficiently manage
standards and expectations, and external require- communications, making it immediately available to
ments, including regulatory requirements. all who have need to access it.

Communication
Communication (continued)
Checking and Corrective
Action Meets Threshold Expectations Leadership Position
Reporting systems are in place to ensure that defi-

ciencies or problems are promptly addressed and key
performance indicators are tracked and reported.
Procedures for communicating with Communities of
Interest are defined.
Formal, effective, two-way communication processes
are established with Communities of Interest to
ensure that their concerns are understood and acted
upon, and to provide them with information on op-
erational issues and performance related to tailings
management.

Purpose: to evaluate the effectiveness, implementation, application and maintenance of procedures for
periodic checking of the tailings management system to ensure policies and commitments are being
met, objectives and targets are being attained, and plans and procedures are being followed and,
where there is a non-conformance, that there is appropriate response.
evaluations.
Review defined procedures for conducting periodic reviews and audits (internal or
external) of the tailings management system and reporting of the results to senior
management.
Evaluate whether and how the periodic reviews and audits:
n address all the elements of the tailings management system and operations,
maintenance, and surveillance manual;
n are conducted by personnel appropriately trained in review and audit procedures;
n address compliance with regulatory requirements, conformance with operational
controls, degree of attainment of objectives and targets, and adequacy of
monitoring and measuring equipment calibration; and
n document results.

Review the program to ensure continuing adequacy of calibration and maintenance of Checking and Corrective
monitoring equipment. Action
Evaluate the assignment of roles, responsibilities, and authorities to investigate and

address non-conformance within the tailings management system (e.g., audit findings,
inspection results, non-compliance with regulatory and other requirements, missed
objectives and targets, etc.).
Review the procedures for action plans dealing with non-conformance and how it is
managed.
Evaluate how these procedures address:
n identifying and investigating non-conformance;
n identifying the immediate and root cause of non-conformance;
n taking action to correct non-conformance and follow-up to ensure actions were
effective; and
n ensuring that the actions carried out to mitigate non-conformance results in
updating the tailings procedures and materials, and informing or retraining
employees as appropriate.
Procedures are in place to regularly and routinely The checking and correction action processes are
inspect, monitor, test, record, evaluate and report key regularly, frequently and formally validated. This
characteristics of the tailings facility. includes performing systematic audits commensurate
Inspections are systematic and formalized, using with the identified risk of the facility.
checklists or other means to guide the inspection team. Communities of Interest are provided with opportuni-
Procedures are in place to detect non-conformance ties to be involved in the checking processes, where
with regulatory requirements, plans, design, con- appropriate.
struction, operation, decommissioning and closure
of tailings facilities, deviations from operational
controls and objectives and targets.
Processes are in place to report non-conformance
promptly and to take appropriate corrective action
including developing action plans.

Management Review for Management Review for Continual Improvement

Purpose: to evaluate the effectiveness, implementation, application and maintenance of the annual review
of tailings management so that it remains effective and is driving continual improvement in
performance.
evaluations.
Review the process for planning and conducting annual reviews of tailings management.
Examine records of these reviews and evaluate:
n the scope and frequency of review;
n how the results of the reviews are documented, communicated and acted upon;
n how the results of the reviews are communicated to the accountable executive
officer and corporate management;
n how the reviews evaluate:
performance of the tailings management system;
c ompliance with regulatory requirements and conformance with corporate
standards, design criteria, closure and reclamation plans;
future performance objectives;
risk management requirements, including change management; and
audit and inspection results;
n processes in place to ensure that reviews address continual improvement to:
applicable policies;
operational controls;
training; and
resource management.

Management Review for
Management Review for Continual Improvement Continual Improvement
To drive continual improvement in performance, senior There is validation that the tailings management
management conducts a formal, annual review of: policies, objectives and management system perfor-
n t he adequacy of tailings management policies mance are subject to formal annual senior manage-
and objectives; and ment review for continual improvement.
n t he performance of the tailings management The company has shared the management review
system. and entered into meaningful dialogue with Com-
munities of Interest with respect to annual senior
management review of the tailings management
system.
Action plans to address identified deficiencies are
developed soon after completion of the management
review. Responsibilities for completion are assigned
and there is a follow-up process.

A Annexes
Annex 1: Approach to Audit and Assessment

Annex 2: Sources of Information
A-1 The Mining Association of Canada

Annex 1 Approach to Audit and Assessment A1
This section presents general guidance on audit and assessment processes; Introduction
it is not specifically part of the audit protocol.
Introduction
In an effective management system audit or assessment, consensus is obtained between
the audit or assessment team and the operation being verified, and the final report repre-
sents a true reflection of the implementation of the management system and its effective-
ness in meeting the needs of the operation.
To achieve these results, the team must be well qualified and experienced, the audit or
assessment program must be well planned and professionally executed, and the audit or
assessment and reporting must be open and transparent.
Verification, either by way of audit or assessment, involves:
n pre-audit or pre-assessment activities
n on-site audit and assessment activities (which follow a five-step process as
illustrated in the following figure); and
n report preparation and distribution.
Figure: Typical Audit or Assessment Schematic
A Guide to Audit and Assessment of Tailings Facility Management A1-1

A1 Approach to Audit and Assessment
Pre-Audit or Pre- Pre-Audit or Pre-Assessment Activities

Assessment Activities
Audit or Assessment Audit or Assessment Program Planning and Considerations
Program Planning and Before committing resources to an audit or assessment initiative, it is important to care-
Considerations
fully evaluate the context in which the audit or assessment program will be conducted.
Objectives To use resources efficiently, to ensure that effort is not wasted or misdirected and to avoid
Scope liability, there are some fundamental issues that must be resolved.
Audit or Assessment Objectives
Team
The starting point in designing a tailings management audit or assessment program is
to understand fully the objectives. What is the audit or assessment expected to achieve?
What questions is it intended to answer?
The audit or assessment leader needs to know who the principal clients of the audit or
assessment are and must ensure that their needs and expectations are considered. There
may be multiple clients being served by an audit or assessment, and their requirements
may be very different.
Audit and assessment programs represent a significant investment for an organization,
both in terms of finances and human resources. Not only is there a cost associated with
fielding an audit or assessment team, but the audit or assessment process takes person-
nel away from their primary responsibilities, which can have an impact on production.
The responsible audit or assessment manager will therefore seek to maximize the return
on the investment that is being made in the verification. The audit or assessment can
be designed to meet its primary objectives and also to address special concerns of local
facility management, thus providing added value. It may provide a useful learning
experience for team members or it may be a means to transfer knowledge of how issues
have been successfully resolved across the organization.
Scope
Before embarking on an audit or assessment program, it is important that the scope
and focus are clearly thought through. How scope and focus are defined will depend,
of course, on the reasons for carrying out the audit or assessment. In particular, it is
important to establish upfront whether the verification is an audit against stipulated
criteria (the MAC tailings management framework) or a more broadly directed qualitative
assessment of the tailings management.
Audit or Assessment Team

Audits and assessments must be carried out by an individual or team who are inde-
pendent, impartial and objective with regard to the evaluated site. They must have the
following competencies:
n credibility with management;
A1-2 The Mining Association of Canada

Approach to Audit and Assessment A1
n credibility with intended audience; Pre-Audit or Pre-
n knowledge of and experience in audit and assessment processes;
Audit or Assessment
n knowledge of and experience in relevant mining processes; and Team
n understanding of:
the MAC tailings management framework;
benchmarks;
regulatory/permitting concepts;
tailings/water facility engineering concepts;
management systems;
risk management; and
socio-economic factors.
Where the audit or assessment is performed by a team, a team leader must be designated
who will have additional specific responsibilities, including establishing the audit or
assessment plan. The plan should contain the following information:
n objectives;
n duties and responsibilities of each of the members of the audit or assessment team;
n audit or assessment criteria;
n resources required;
n the proposed audit or assessment schedule; and
n protocols.
The protocol presented in this document provides a plan for the audit and assessment
of an organizations tailings/water management practices. It also provides a format
for assigning specific tasks to individual members of an audit or assessment team, for
comparing what was accomplished during the audit or assessment and for summarizing
and recording the work in progress and work to be completed. All members of the audit
or assessment team should be very familiar with the sections of the protocol for which
they will be responsible before they go on site.
A major advantage of using a comprehensive audit or assessment protocol is to ensure
consistency in the process and to compare results between mining operations. This is
particularly important where audit or assessment team membership is rotated.
Not every audit or assessment will follow every step outlined in the protocol, and modi-
fying the procedure will be necessary to suit each case. No matter how comprehensive or
detailed a protocol may be, it must be regarded as a guide, not a rigid tool. Every audit or

Pre-Audit or Pre- assessment poses its own challenges, and the team should be prepared to be flexible and
Assessment Activities use good judgment in determining which elements of the protocol apply in each case.
Audit or Assessment No audit or assessment guide can be fully comprehensive and predict all local require-
Team ments, and therefore the team must be alert to important issues that are not addressed by
Pre-Audit or the guide.
Pre-Assessment
Questionnaire Pre-Audit or Pre-Assessment Questionnaire
Other Pre-Audit or Pre- Audits and assessments can be very disruptive to operations and can take away from
Assessment Activities other duties of the highly qualified people who will execute them. It therefore makes
good business sense to try to minimize the time spent on site, which requires the team to
be well prepared before commencing the fieldwork.
A pre-audit or pre-assessment questionnaire can help in the preparation. The question-
naire should be sent to the site at least two weeks before (and preferably earlier) the audit
or assessment begins, and it should request information on the organizational structure of
the facility (personnel who are responsible for various aspects of tailings management),
the layout and nature of the operations, and special hazards, such as asbestos or ionizing
radiation, that may be on site.
Other Pre-Audit or Pre-Assessment Activities

The prudent audit or assessment team leader will ensure that several other tasks have
been carried out before arriving on site:
n the most up-to-date regulations are available and have been considered in the
audit or assessment protocol;
n the latest versions of corporate policies and procedures are available, if they are
within the scope of the audit or assessment;
n the audit or assessment team has been picked with the right blend of skills to carry
out the job efficiently and effectively, with the audit or assessment team members
confirmed available on the dates scheduled for the verification;
n an audit or assessment plan that assigns responsibilities to team members has been
prepared so that everyone knows exactly what is expected of them;
n time and costs have been budgeted for each task so that, as the audit or assessment
progresses, it is clear whether things are on track or falling behind;
n special health or safety concerns have been addressed (e.g., special immunisation
requirements, high-altitude adjustments); and

n the logistics of getting the team on site, accommodated while carrying out the Pre-Audit or Pre-
work and home again have been checked and double-checked. This task is Assessment Activities
especially important if international travel is involved and if team members are Other Pre-Audit or Pre-
congregating from different home base locations. Assessment Activities
Planning and forethought can go a long way to making an audit or assessment a success On-Site Audit or
and an experience that benefits all those involved.
Opening Meeting
On-Site Audit or Assessment Activities
Site Tour
Opening Meeting Audit or Assessment
The opening meeting sets the tone for the whole audit or assessment. This meeting
affords the opportunity to introduce the audit or assessment team and to explain the
objectives of the audit or assessment. The scope and purpose should be very clearly
defined so that there are no surprises for the facility being verified. The meeting also
allows the audit or assessment team to become aware of local concerns or sensitivities
(e.g., labour relations issues) and ensures that the team is fully advised of safety rules or
special hazards on site.
The other main purposes of the opening meeting are to schedule initial interviews, define
documents that the audit or assessment team may wish to review and generally sort
out the logistics and arrangements for the verification. During the meeting, the facility
personnel and the audit or assessment team should establish how the reporting of results
will be handled, including end-of-day reviews.
Site Tour
Following the opening meeting, it is usual, and most effective, to carry out a brief tour of
the facility. The purpose of this tour is to orient the team to the layout of the facility and
to gain an appreciation of the nature and organization of the work being carried out.
Audit or Assessment
Step 1Understanding of management systems. It is not the intent, in conducting the
initial phase of an audit or assessment, to attempt to assess fully the effectiveness of tail-
ings management systems. Rather, the verifier should aim to understand:
n how the facility has evaluated the applicability of existing regulatory standards,
the MAC tailings management framework and other requirements to the facility;
n how the facility assesses and manages risks due to on-going operations, changes
and controls risk, including regulated activities;
n whether management roles and responsibilities are clearly understood;
n what types of programs or activities are in place in to familiarize employees with
tailings management information; and

On-Site Audit or n how the facility maintains and documents the effectiveness of its tailings
Assessment Activities management activities.
Audit or Assessment
Step 2Assessing internal controls. An assessment of the relative strengths and weak-
nesses of the tailings management systems allows the audit or assessment team to
prioritize its activities to focus first on inherently high-risk situations where the systems
in place are least robust.
Step 3Gathering audit or assessment evidence. The results of Step 2 (i.e., setting the
audit or assessment priorities by assessing the strengths and weaknesses of management
systems) provide the basic framework for the verifier to develop a sound and defensible
audit or assessment strategy. Once the team has determined the priorities, a strategy can
be developed on the basis of what resources are available, what needs to be done, how
the information is to be gathered, where audit or assessment testing is to be applied and
what sampling strategies are available. When gathering audit or assessment evidence,
each verifier should ensure that the information evaluated is representative of the
situation being assessed and is sufficient to verify compliance or to substantiate non-
compliance.
The verifier can use a range of techniques to confirm information. Visually examining
the facility and its operations and observing aspects of tailings management are often
the starting points. The time spent observing operations in the facility will readily
indicate whether the site is well organized and whether there is regard for safety and the
environment.
Much evidence comes from personal interviews with facility personnel. The audit or
assessment team can expect to interview a broad range of site people, including manage-
ment, safety and health professionals, and personnel on the shop floor. Questions asked
during these interviews allow the assessor to get a sense of the operating philosophy of
the organization:
n what processes are meant to be in place, and what activities are supposed to be
carried out;
n are these expectations communicated to and understood by line staff responsible
for carrying them by out; and
n what is actually being implemented?
Certainly, having effective communication skills (and particularly listening skills) is one
of the most important attributes of a successful verifier.

In an audit, most of the questions used are close-ended or leading (prompting only On-Site Audit or
yes or no responses). In an assessment, open-ended or how-do-you-know questions Assessment Activities
(prompting more detailed answers) are more typically used because the goal is to gain a Audit or Assessment
better sense of the activities and processes in place, along with a measure of effectiveness
of those processes in meeting the organizations objectives. (The chart bellow illustrates
examples of different types of questions.)
Type of Question Example

Close-ended Do you carry out monthly inspections of the dam?
How often do you inspect the dam?
Leading You conduct a monthly inspection of the dam dont you?
Open-ended What inspection processes do you have for the dam?
How-do-you-know How do you ensure the integrity of the dam?
After posing the questions, it is good practice to relate briefly to the interviewee what
you have learned from the interview. The interviewee should be given the opportunity to
volunteer relevant information that has not been covered in the questioning.
Step 4Evaluating the audit or assessment evidence. Throughout the audit or assess-
ment process, it is very important to maintain contact with other members of the team
to verify all the findings based on observations made. As fieldwork is completed, the
information gathered should be checked to ensure that it is relevant, free from bias, objec-
tive and persuasive. It should also be sufficient to support the objectives of the audit or
assessment and the conclusions reached.
Audit or assessment evidence should be confirmed by supporting documents and/or
observation. Activity or management responsibility required by MACs tailings manage-
ment framework and its OMS Guide must be documented in sufficient detail to verify
that it has been undertaken properly. Confirmation of findings can be achieved by:
n conducting further interviews;
n examining documents, reports and records;
n observing activities and conditions; and/or
n reviewing assay or test results.
A sufficient number of documented results, such as monitoring data, incident reports,
and inspection records, should be reviewed to ensure that a representative sample has
been considered.

On-Site Audit or Step 5Reporting audit or assessment findings. To ensure the smooth and effective
Assessment Activities conduct of the audit or assessment, an ongoing dialogue with facility personnel should
Audit or Assessment be maintained. End-of-day wrap-up meetings provide a very effective means of keeping
The Close-Out Meeting management informed of progress and can prevent unpleasant and unnecessary surprises
at the close-out meeting. The end-of-day meetings also help to keep the verifiers on track
Reporting Activities
(e.g., if the information received has been misinterpreted or the verifiers have been talk-
Audit or Assessment ing to people who do not have the correct information).
Report
The Close-Out Meeting
It is very important that the audit or assessment team leader and team members are well
prepared for their presentation, either oral or written, of the findings and observations.
In particular, all team members must agree on the findings to be presented before the
close-out meeting takes place. This is especially important where audit or assessment
teams have not worked together before, or where they are made up of a mixture of corpo-
rate, facility and outside verifiers.
The close-out meeting should be viewed as a final opportunity for open dialogue between
facility personnel and the audit or assessment team before the final report is written.
It provides an opportunity to test, one last time, the findings that have been made, and
gives the facility the opportunity to ensure that the contexts of the findings have been
properly understood by the verifiers. Disagreements in the facts being reported should
be noted and attempts should be made to resolve them.
Reporting Activities
Audit or Assessment Report
A completed tailings management audit or assessment must be finalized with a written
report. The structure and content of the report will vary depending on the nature of the
audit or assessment, its scope and purpose, and the client. For example, the report may
be intended to give advice and guidance to local facility personnel, or it may be part of
a corporate overview process, or it may be intended to provide assurance to boards of
directors and officers of a company that due diligence has been exercised in the manage-
ment of tailings facilities. It is strongly recommended that the audit or assessment team
leader have a clear conception of the purpose of the final report as well as an apprecia-
tion of how it will be structured before embarking upon the audit or assessment. The
report should be clear and concise, should provide the information needed by manage-
ment to initiate corrective action and should describe a record of the conduct of the audit
or assessment and its findings.

A typical audit or assessment report will have a five-part structure: Reporting Activities
n Executive summary. The executive summary should describe the most important Audit or Assessment
Report
findings in report, particularly those that may present significant liability or that
indicate a serious failing in the management systems. Report-Preparation
Considerations
n Introduction. The introduction should provide:
site identification and relevant description;
the duration and dates of the audit or assessment;
the objectives, scope and criteria of the verification;
identification of the people involved (those people on site and the audit or
assessment team members);
the methodology employed (i.e., the protocols used, types of document
reviewed, number of interviews conducted, etc.); and
a ny aspects included in the original scope of the audit or assessment that were
not addressed and the reasons why (e.g., lack of time, key information not
available).
n Findings. The findings section should provide a conclusion that summarizes
conformance, strengths and weaknesses in the implementation of the system.
Generally, it is helpful to clearly separate regulatory findings, progress against
items previously identified, findings of non-conformance with company policies,
standards and procedures and situations in which there is a lack of adherence
to generally accepted industrial standards or good practices. Documents and
evidence reviewed should be listed.
n Recommendations. Reporting recommendations is optional in compliance
auditing. However, in an assessment of management systems, any
recommendations to correct deficiencies or areas of weakness to drive continual
improvement should be included.
n Noteworthy strengths. Often, the audit or assessment report will highlight
particular strengths in management systems or processes. This section is
particularly important if a purpose of the assessment is to identify leading
practices that can be shared across a company or industry.
Report-Preparation Considerations
Findings presented in audit or assessment reports should be thorough, factual, clear,
concise and accurate. All statements should be supported by evidence presented in the
report, or should be readily defensible through reference to field notes. Wherever pos-
sible, specific information should be provided to put the finding in a proper context.

Reporting Activities Distribution of Reports

Distribution of Reports A concern for the verifier is how to handle the distribution of the report, particularly
Audit or Assessment when it may contain information that is critical of performance or sensitive. Many
Papers managers worry that by disclosing deficiencies in a facilitys programs or reporting items
Follow-up of non-compliance with regulatory requirements individuals or the company may be put
at risk or incur liability. These concerns, while real, are not sufficient for a prudent em-
ployer to avoid determining the status of tailings management performance by means of
a well-managed audit or assessment program. Liability can be minimized by the corpora-
tion making a strong commitment to address issues of non-compliance in a forthright way
and to put in place corrective actions when deficiencies are observed and reported. Such
a commitment can be included in a corporate policy that requires an audit or assessment
report to automatically trigger the process for reviewing deficiencies and initiating correc-
tive action. The careful preparation of findings and prompt action to address deficiencies
are by far the best protection against liability and the most responsive approach.
The distribution of reports must be considered in the planning stages of the audit or
assessment. It is important to ensure that reports are not distributed too widely; the audit
or assessment program manager and audit or assessment leaders must be very clear on
who the client is, and must take direction from the client in the distribution of reports.
In many circumstances, it will not be the individual being verified who is the client
that commissioned the audit or assessment, and the individual being verified may not,
therefore, be the owner of the report.
Audit or Assessment Papers

The notebooks used during the audit or assessment constitute an important record of
the verifiers activities and findings while on site. Notes should be clearly written and
the pages should be dated and signed by the verifier. Any notes taken in working papers
should be accurate accounts of what was done and what observations were made. All
fact must be verified. The language used in notes should be prudent with no editorial
comments. All exhibits should be numbered and referenced to notes in the working
papers. As these records may be required at a later date, they should be carefully retained
in secure storage.
Follow-up
The follow-up of audit or assessment findings is the responsibility of the operator or the
client who commissioned the audit or assessment. Follow-up should not be the respon-
sibility of the audit or assessment team, or team leader, and, therefore, is not within the
scope of the audit or assessment.

Annex 2 Sources of Evidence A2
This section presents general guidance on audit or assessment processes; it Policy and Commitment
is not specifically part of the audit protocol. Roles and

Responsibilities
The information below suggests typical sources of evidence that can guide a verifier in
Objectives
undertaking an audit or assessment. It is arranged by the audit or assessment categories.

Written procedure or flowchart for reviewing the applicability of the tailings management
policy based on management reviews
The policy itself
Meeting minutes reviews, presentations, group meetings, ISO 14001 certification to verify
discussion on tailings policy, distribution of policy information
Interviews with tailings employees to verify their understanding of the policy and to
determine their views on managements commitment to fulfilling the terms of the policy,
demonstration of commitment, etc.
Roles and Responsibilities

Organization charts
Personnel job descriptions
Core competency reviews
Personnel performance reviews including objectives setting (if not confidential)
Job procedures and work instructions where roles and responsibilities may be discussed
Interviews with key personnel
Statements of accountabilities and authority levels (for action, approvals, budgets, spend-
ing limits)
Objectives
Written documentation of objectives-setting exercises (typically a list or meeting minutes)
Employee interviews
Consultants reports
Tailings facility policy
Training records

A2 Sources of Evidence
Managing for Managing for Compliance

Compliance
Services of a legal firm retained for the purpose
Managing Risk
Subscriptions to a legal and regulatory updating service
Managing Change
Written procedure describing how the tailings or water management facility maintains
current awareness of legal and other requirements
Industry association involvement
Interviews with tailings personnel
Regulatory non-compliance reports
Documented tasks associated with regulatory requirements, including timelines, and
responsibility assignment
Documentation of responsibilities for dissemination of legal and other requirements
Managing Risk
Corporate risk management policy
Risk management system documentation (e.g., how are risk assessments carried out, the
results ranked and actions plans formulated?)
Current and previous risk assessments
Interviews with personnel
Emergency preparedness plan
Operation, Maintenance and Surveillance manual
Relevant design documentscurrent and historical
Safety and incident records
Documented compliance with operational and regulatory requirements
Dam safety inspections and dam safety reviews
Managing Change
Documented procedures for the management of the risks potentially introduced through
changes or in personnel, equipment, process chemicals, process technology, or modifica-
tions thereof
If documented procedures do not exist, interviews with key personnel to determine
whether informal practices exist that serve a similar purpose
Training procedures and records

Sources of Evidence A2
Existing project documents such as operating procedures, permits, site plans, workplace Managing Change
inspection procedures, etc. to determine whether they have been updated to reflect Resources and
changes Scheduling
Former risk assessment to determine whether it has been updated to reflect changes Emergency
Preparedness and
(See the section Managing Risk to evaluate risk introduced through change.)
Response
Resources and Scheduling Operational Control
Operating and capital budgets Financial Control
Manpower and production schedules

Comparison of budget and actual cost reports
Asset retirement obligation estimates
Budgets that reflect objectives set for the tailings facility
Closure and decommissioning cost estimates
Interviews with key facility personnel
Emergency Preparedness and Response

Copies of emergency preparedness and response plans
Records of drills and practices and of reviews of drills
Telephone list contacts including off-site authorities
EPP training records
Communications with external emergency response agencies and affected parties
Inundation studies
Operational Control
Conformance with engineering standards
Interviews with key facility personnel
Comparison of significant risks, environmental impacts, and legal and other requirements
with corresponding operational controls
Examination of operational controls themselves
Financial Control
Operating and capital budgets
Financial performance tracking documents

A2 Sources of Evidence
Documentation Documentation
Training, Awareness and Written document control procedures
Competency
Interviews with key tailings facility personnel
Communication
Physical and electronic archives
Documents and records, including but not limited to:
n submissions to regulatory agencies
n permits and licences
n training records
n quality assurance/quality control reports, construction reports, photos, videos, etc.
n monitoring results
n unusual or special conditions
n as-built drawings
n dam surveillance and inspection records
n records of deviations
n design reports
n site operating manuals

Personnel interviews
Training needs assessments
Personnel performance reviews
Training modules
Operating and maintenance procedures
Training records including relevant test results
Communication
Documented communication procedures
Documentation of decisions, meetings, etc. Guide update to specifically note requirement
for documenting communication records
New employee, contractor and consultant briefing programs
Public communication of important issues on bulletin boards, e-mail, website and other
publicly accessible mediums

Sources of Evidence A2
Departmental, interdepartmental committees and team meeting minutes Communication
Company publications Checking and Corrective

Action
Public liaison committees, open houses and town meetings Management Review for
Documented audit/assessment procedures detailing audit/assessment scope, frequency,
methodology, requirements and reporting
Audit and assessment reports
Interviews with senior management to determine awareness of the contents of audit/as-
sessment reports
Audit/assessment training records/certificates to ensure competency of auditors
(for internal auditors)
Existence of performance metrics and tracking against same
Documented calibration procedures and records
Preventive maintenance procedures, schedules and records
Non-conformance reports
Investigation reports
Action plans to address non-conformances
Follow-up investigations to effectiveness of actions
Interim measures where permanent solutions must await resources
Reports to regulatory agencies
Management Review for Continual Improvement

Meeting minutes, schedules and agendas
Interviews with senior management and key personnel
Documentation from management reviews including presentations
Follow-up reviews on action items
System change documentation
Inspection and audit/assessment results

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A Guide to

Audit and Assessment of

2011 Mining Association of Canada

A Guide to Audit and Assessment of Tailings Facility Management i

A Guide to Audit and Assessment of Tailings Facility Management iii

iv The Mining Association of Canada

A Guide to Audit and Assessment of Tailings Facility Management 1-1

1-2 The Mining Association of Canada

A Guide to Audit and Assessment of Tailings Facility Management 2-1

2-2 The Mining Association of Canada

Is there a policy statement that describes the commitment to tailings management?

A Guide to Audit and Assessment of Tailings Facility Management 3-1

u Tailings facility plans Objectives

3-2 The Mining Association of Canada

Is there a formal risk management plan in place?

Have processes and procedures been established and documented:

A Guide to Audit and Assessment of Tailings Facility Management 3-3

Resources and Scheduling

Emergency Preparedness and Response

3-4 The Mining Association of Canada

Are operational controls in place to ensure:

A Guide to Audit and Assessment of Tailings Facility Management 3-5

Training, Awareness and Competency

3-6 The Mining Association of Canada

Checking and Corrective Action

A Guide to Audit and Assessment of Tailings Facility Management 3-7

Management Review for Continual Improvement

Is there an annual corporate review of tailings management to:

3-8 The Mining Association of Canada

Policy and Commitment

A Guide to Audit and Assessment of Tailings Facility Management 4-1

Policy and Commitment

Roles and Responsibilities

4-2 The Mining Association of Canada

A Guide to Audit and Assessment of Tailings Facility Management 4-3

4-4 The Mining Association of Canada

Meets Threshold Expectations Leadership Position

Managing for Compliance

A Guide to Audit and Assessment of Tailings Facility Management 4-5

Managing for Compliance

Meets Threshold Expectations Leadership Position

4-6 The Mining Association of Canada

n hazard identification, risk assessment and risk management, including the

Meets Threshold Expectations Leadership Position

A Guide to Audit and Assessment of Tailings Facility Management 4-7

Managing Change Managing Change

4-8 The Mining Association of Canada

Meets Threshold Expectations Leadership Position

A Guide to Audit and Assessment of Tailings Facility Management 4-9

Resources and Resources and Scheduling

Resources and Scheduling

Meets Threshold Expectations Leadership Position

4-10 The Mining Association of Canada

A Guide to Audit and Assessment of Tailings Facility Management 4-11

4-12 The Mining Association of Canada

A Guide to Audit and Assessment of Tailings Facility Management 4-13

Meets Threshold Expectations Leadership Position

4-14 The Mining Association of Canada

Meets Threshold Expectations Leadership Position

n hazard identification, risk assessment and risk management, including the

Training, Awareness and n the identification and management of risk;