Towards Sustainable Mining

Tailings Management Protocol

Version date: February 2019
 TAILINGS MANAGEMENT PROTOCOL – FEBRUARY 2019

CHANGES IN THE FEBRUARY 2019 VERSION OF

THE TAILINGS MANAGEMENT PROTOCOL

The previous version of the Tailings Management Protocol (the Protocol), dated November
2017, included requirements for emergency preparedness as part of Indicator 5 and
referred to Developing an Operation, Maintenance, and Surveillance Manual for Tailings
and Water Management Facilities (the OMS Guide). Guidance on emergency
preparedness has been moved to A Guide to the Management of Tailings Facilities (the
Tailings Guide, Version 3.1, dated February 2019).

To reflect this change in the guidance, Protocol requirements for emergency preparedness
have been moved to Indicator 2 and now refer to the Tailings Guide. This is the only
material change in the February 2019 version of the Protocol.

Other changes in the February 2019 version include:

• Clearer descriptions of performance criteria for the Indicators described in the
Protocol. These revisions do not impact what is required to obtain Level A or better
for each Indicator.
• A new section that explains:
o the relationship between the Protocol and the Table of Conformance;
o how the Protocol is to be used; and
o the basis for determining conformance with the Tailings Guide and the
OMS.
• A new section that clarifies that it is at the discretion of the company to determine
how best to organize various documents described in the Tailings Guide and OMS
Guide.
• An expanded glossary of terms.

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TSM ASSESSMENT PROTOCOL

A Tool for Assessing Tailings Management Performance

Purpose
Towards Sustainable Mining® (TSM®), launched in 2004, is an initiative of the Mining
Association of Canada (MAC) designed to enable mining companies to meet society’s
needs for minerals, metals and energy products in the most socially, economically and
environmentally responsible way. TSM includes performance Protocols and specific,
measurable performance Indicators for:

• Aboriginal and community outreach;

• energy use and greenhouse gas emissions management;
• tailings management;
• biodiversity conservation management;
• safety and health;
• crisis management and communications planning;
• preventing child and forced labour; and
• water stewardship.

The Tailings Management Protocol (the Protocol) provides five Indicators to measure the
quality and comprehensiveness of systems for tailings management, specifically tailings
facility-specific:

• tailings management systems;

• emergency response plans (ERPs) and emergency preparedness plans (EPPs);
and
• operations, maintenance, and surveillance (OMS) manuals.

The Protocol is supported by two documents prepared by MAC:

• A Guide to the Management of Tailings Facilities (the Tailings Guide); and

• Developing an Operation, Maintenance, and Surveillance Manual for Tailings and
Water Management Facilities (the OMS Guide).

These guides provide further specificity on expectations to meet performance Indicators

described in the Protocol.

The Protocol provides a measure of the level of implementation of tailings management

practices as part of the TSM initiative. It is not, in itself, a guarantee of the effectiveness of
tailings management activities.

Performance Indicators
The Protocol describes five performance Indicators:
1. Tailings management policy and commitment
2. Tailings management system and emergency preparedness
3. Assigned accountability and responsibility for tailings management

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4. Annual tailings management review

5. Operation, maintenance, and surveillance (OMS) manual

While the Protocol focuses on the management of tailings facilities and internal
accountability and review mechanisms, an additional component of good practice in
tailings management is community engagement. TSM addresses tailings related
community engagement as part of a broader topic of engagement regarding risks to
communities and engagement requirements related to risks posed by tailings facilities are
included in the TSM Aboriginal and Community Outreach Protocol. Indicator 2 of that
Protocol requires companies to have processes in place to engage with communities of
interest (COI) on credible risks to the public that are associated with company activities,
including tailings management. Specific topics for engagement should be determined
through dialogue with COI.

Structure and Use of the Protocol

The main body of the Protocol describes the purpose of each of the Indicators and the criteria
for the performance rating levels used in TSM: Levels C, B, A, AA, and AAA.

To obtain a Level A or higher, criteria for Indicators 1 through 4 refer to elements that must be
“in conformance with the Tailings Guide”, and criteria for Indicator 5 refer to the OMS Guide. A
Table of Conformance has been developed and is available for download in Microsoft
Excel. This table identifies aspects of the Tailings Guide and the OMS Guide to be
implemented to be “in conformance” with the Guides. A company would not be in
conformance with the Guides if there is:

• an absence of a complete program area (e.g., risk assessment, training processes,

independent review); or
• a chronic deficiency of a single program area (e.g. routine exceedance of
performance criteria, surveillance requirements frequently missed).

Non-conformances that represent an administrative issue or a non-repetitive finding that

does not directly affect safety, environment or quality (e.g., minor gap in training records,
irregularity in inspection records, etc.) should not prevent a company from achieving a
Level A for a tailings facility for the relevant indicator. Professional judgment must be
applied in assessing the significance of identified non-conformances.

Thus, use of the Table of Conformance is required to assess performance against the five
Indicators.

Please note that TSM is applied on a facility-specific basis, meaning it is applied to a mine
site as a whole. For mines sites with more than one tailings facility, the performance of
those tailings facilities is assessed collectively against the Indicators and criteria described
in the Protocol. For a mine site as a whole to obtain a specific TSM performance rating
level for tailings management (e.g., Level A for Indicator 2), performance of all individual
tailings facilities within the mine site must meet that level or higher.

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The Protocol includes three appendices:

Appendix 1: Frequently Asked Questions. Users should refer to this appendix as a first
step in addressing any questions that may have about the Indicators and use of the
Protocol.

Appendix 2: Glossary. Provides definitions of various terms used in the Protocol.

Definitions are harmonized with those in the Tailings Guide and the OMS Guide.

Appendix 3: TSM Self-Assessment Checklist. Users may apply this checklist to assist in
assessing their performance level for each of the Indicators. However, use of this checklist
is not required.

Action Plans
Companies that have not achieved a minimum of a Level A for all five Indicators are
required to describe in their company profile section of MAC’s annual TSM Progress
Report actions that the company intends to take to achieve a Level A for all five Indicators.

These action plans should address at a minimum:

• identified gaps in Indicators where the company has not achieved a Level A;
• specific actions the company will take to reach a Level A; and
• timeline for implementing actions (note: actions must be implemented within three
years).

Organization of Relevant Documentation

The Protocol and Guides refer to a range of documentation that a company must develop
and implement to obtain a Level A or higher for each Indicator. However, the structure of
the Protocol and Guides should not be interpreted as a prescription of how this
documentation must be organized. How these documents are organized is at the
discretion of the company, taking into account the site-specific circumstances, including
the characteristics and life cycle phase of each of tailings facility.

For Indicator 1: A company does not need to develop a stand-alone policy or commitment
specific to tailings management. The requirement for a tailings management policy and/or
commitments can be met within an overarching company operations or environmental
policy, provided that:

• the policy contains specific references to tailings management policies and/or

commitments as described in the Tailings Guide; and
• the company can demonstrate that it is adhering to the policy and/or commitments.

For Indicator 2: A tailings management system does not require stand-alone

documentation. A tailings management system will likely prove most effective and resilient
if incorporated into broader site-wide environmental management systems (EMS). In such
cases, the company would need to be able to demonstrate that the tailings management
component of the EMS is in conformance with the tailings management framework

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described in the Tailings Guide, as per Indicator 2. There is no requirement that the EMS
as a whole be in conformance with the Tailings Guide or be considered in assessing
performance against the criteria for this Indicator.

Similarly, stand-alone ERP and EPP documents specific to a tailings facility are not
required. An ERP and an EPP may be separate, or they may be combined. There may be
a separate ERP and EPP for tailings management, or these may be included in a site-wide
ERP and EPP that covers all aspects of the mine site. They may be included in the OMS
manual for the tailings facility or may be separate from the OMS manual.

For Indicator 4: In cases where the tailings management system is incorporated into a
site-wide EMS, there is no requirement that the scope of the annual tailings management
review address the full scope of the EMS. For the purpose of this Protocol, only the tailings
management component of the EMS needs to be addressed.

For all Indicators: Some mine sites (a facility as defined for TSM reporting) have more
than one tailings facility. In such cases, there is no need for separate documentation for
each tailings facility. Regardless of how the company organizes necessary documentation,
it is necessary that the tailings management system, ERP, EPP, and OMS manual
specifically address the performance objectives, risk profile, and risk management plan of
each tailings facility. The company needs to be able to demonstrate that it has measures
in place that are appropriate to the management of each distinct tailings facility, and in
conformance with the Tailings Guide and OMS Guide as per the Indicators in the Protocol.

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INDICATOR 1: TAILINGS MANAGEMENT POLICY AND

COMMITMENT

Purpose
To confirm that companies have established and effectively communicated a policy and/or
commitments that express intention, commitments and principles in relation to tailings
management.

Tailings Management Policy and Commitment: Assessment Criteria

LEVEL CRITERIA

C The company has not met all Level B criteria.

The company has developed a policy and/or commitments that specifically

address tailings management, but has not met all requirements for a Level A.
B
The company has developed an action plan to meet all requirements for a Level
A.
An internal audit has been conducted and determined that:
• The policy and/or commitments are:
o in conformance with the Tailings Guide;
o approved by senior management; and
o endorsed at the governance level.

A • The company has a process in place to ensure that the policy and/or
commitments are:
o communicated to employees;
o understood to a degree appropriate to their roles and responsibilities by
employees, contractors and consultants whose activities may affect
tailings management either directly or indirectly; and
o implemented with budget allocation.
An external audit has been conducted and determined that all requirements for
AA
a Level A have been met.
The external audit for Level AA included an evaluation of the effectiveness of
AAA
the policy and/or commitments and their implementation.

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Tailings Management Policy and Commitment: Frequently Asked Questions

# FAQ PAGE

Can a company effectively implement a tailings management system

1
without having a tailings management policy in place?
What are some examples of employees or contractors whose activities
2
may affect tailings management either directly or indirectly?
5 What is an audit?
6 What is an evaluation of effectiveness?
7 What is meant by the governance level of the company?
8 How long are audits valid?

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INDICATOR 2: TAILINGS MANAGEMENT SYSTEM AND

EMERGENCY PREPAREDNESS

Purpose
To confirm that companies have:
• developed and implemented a tailings management system in conformance with
the tailings management framework described in the Tailings Guide; and
• developed and tested emergency response plans (ERPs) and emergency
preparedness plans (EPPs) in conformance with the Tailings Guide.

Tailings Management System and Emergency Preparedness: Assessment Criteria

LEVEL CRITERIA

C The company has not met all Level B criteria.

The company has:
• developed and implemented a tailings management system, but that
system is not in conformance with the Tailings Guide; or
• conducted a gap analysis comparing existing tailings management
practices against the Tailings Guide and determined that existing practices
for the tailings facility are not in conformance with the Tailings Guide.

B And, the company has:

• developed an ERP and an EPP for the tailings facility but both are not in
conformance with the Tailings Guide; or
• developed an ERP and an EPP for the tailings facility which are in
conformance with the Tailings Guide, but both have not been tested.

The company has developed an action plan to meet all requirements for a Level
A.
An internal audit has been conducted and determined that the company has:
• developed and implemented a tailings management system that is in
conformance with the Tailings Guide;
A
• developed an ERP and an EPP for the tailings facility that are both in
conformance with the Tailings Guide; and
• tested both the ERP and the EPP.
An external audit has been conducted and determined that all requirements for
AA
a Level A have been met.
The external audit for Level AA included an evaluation of the effectiveness of
the:
AAA
• development and implementation of the tailings management system; and
• development and testing of the ERP and the EPP.

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Tailings Management System and Emergency Preparedness: Frequently Asked

Questions

# FAQ PAGE

Can a company effectively implement a tailings management system

1 without having a tailings management policy and/or commitments in
place?
5 What is an audit?
6 What is an evaluation of effectiveness?
8 How long are audits valid?

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INDICATOR 3: ASSIGNED ACCOUNTABILITY AND

RESPONSIBILITY FOR TAILINGS MANAGEMENT

Purpose
To confirm that accountability for tailings management is assigned to an Accountable
Executive Officer (e.g., CEO, COO, or Vice President), and that an appropriate
management structure and resources are in place to provide assurance to the company
that tailings are managed responsibly.

Assigned Accountability and Responsibility for Tailings Management:

Assessment Criteria

LEVEL CRITERIA

C The company has not met all Level B criteria.

The company has defined and documented accountability and responsibility for
tailings management, but all requirements for a Level A have not been met.
B
The company has developed an action plan to meet all requirements for a Level
A.
An internal audit has been conducted and determined that:
• accountability for tailings management has been assigned by the Board or
Governance Level to an Accountable Executive Officer;
• the Accountable Executive Officer has a direct reporting relationship to the
A Board, a Board committee, or the Governance Level;
• responsibility and authority for tailings management have been delegated in
writing to qualified personnel; and
• delegation of responsibility and authority for tailings management is in
conformance with the Tailings Guide.
An external audit has been conducted and determined that all requirements for
AA
a Level A have been met.
The external audit for Level AA included an evaluation of the effectiveness of
the:
AAA • assignment of accountability for tailings management to the Accountable
Executive Officer; and
• delegation of responsibility and authority for tailings management.

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Assigned Accountability and Responsibility for Tailings Management:

Frequently Asked Questions

# FAQ PAGE

3 How can a company demonstrate whether personnel are qualified?

What are examples of actions that should be the responsibility of the
4 Accountable Executive Officer to demonstrate accountability for tailings
management?
5 What is an audit?
6 What is an evaluation of effectiveness?
8 How long are audits valid?

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INDICATOR 4: ANNUAL TAILINGS MANAGEMENT REVIEW

Purpose
To confirm that there is an annual review of tailings management that is reported to the
Accountable Executive Officer to ensure corporate governance over tailings management
and to ensure that the company is satisfied that the tailings management organizational
structures and systems are effective and continue to meet the needs of the organization.

Annual Tailings Management Review: Assessment Criteria

LEVEL CRITERIA

C The company has not met all Level B criteria.

The company has conducted periodic, documented reviews of tailings
management for the tailings facility, but all requirements for a Level A have not
B been met.
The company has developed an action plan to meet all requirements for a Level
A.
An internal audit has been conducted and determined that the company
conducts reviews of tailings management for the tailings facility:
A
• on an annual basis; and
• in conformance with the Tailings Guide.
External audit has been conducted and determined that all requirements for a
AA
Level A have been met.
The external audit for Level AA included an evaluation of the effectiveness of
AAA
the annual tailings management reviews.

Annual Tailings Management Review: Frequently Asked Questions

# FAQ PAGE

5 What is an audit?
6 What is an evaluation of effectiveness?
8 How long are audits valid?

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INDICATOR 5: OMS MANUAL

Purpose
To confirm that the company has developed and implemented a tailings facility-specific
OMS manual in conformance with the OMS Guide to facilitate implementation of the
tailings management system (Indicator 2).

OMS Manual: Assessment Criteria

LEVEL CRITERIA

C The company has not met all Level B criteria.

An OMS manual has been developed for the tailings facility but it is not in
conformance with the OMS Guide.
B
The company has developed an action plan to meet all requirements for a Level
A.
An internal audit has been conducted and determined that an OMS manual has
A been developed and implemented for the tailings facility that is in conformance
with the OMS Guide.
An external audit has been conducted and determined that an OMS manual
AA has been developed and implemented for the tailings facility that is in
conformance with the OMS Guide.
The external audit for Level AA included an evaluation of the effectiveness of
AAA
the development and implementation of the OMS manual.

OMS Manual: Frequently Asked Questions

# FAQ PAGE

5 What is an audit?
6 What is an evaluation of effectiveness?
8 How long are audits valid?

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APPENDIX 1: FREQUENTLY ASKED QUESTIONS

1. Can a company effectively implement a tailings management system without

having a tailings management policy and/or commitments in place?
No. There is a direct link between Indicators 1 and 2 of the Protocol. A company must
have a tailings management policy and/or commitments in place in order to effectively
implement a tailings management system, since the policy is part of the management
system. A company cannot achieve a Level A for Indicator 2 (Tailings Management
System) if it has not achieved a Level A or higher for Indicator 1 (Tailings Management
Policy).

2. What are some examples of employees or contractors whose activities may affect
tailings management either directly or indirectly?
Examples of personnel whose activities may directly affect tailings management include
mill managers, tailings pipeline inspectors, and employees undertaking any operation,
maintenance, or surveillance activities. An example of personnel whose activities may
indirectly affect tailings management is procurement personnel who order parts or services
related to tailings management.

3. How can a company demonstrate whether personnel are qualified?

Considerations for determining whether a person is qualified include, but are not limited to:
• previous training, including as appropriate formal education
• previous experience in performing the task/activity
• degree of relevant knowledge
• regulatory, professional, or industry- definitions of “qualified”

4. What are examples of actions that should be the responsibility of the Accountable
Executive Officer to demonstrate accountability for tailings management?
Examples of actions the Accountable Executive Officer can take to demonstrate
accountability for tailings management could include:
• ensuring that the senior management team and/or Board or governance level are
appropriately informed on tailings management issues;
• reviewing risk assessment results;
• participating in tailings reviews;
• reviewing and approving adequate resources for tailings management;
• participating in independent tailings review meetings; and
• participating in crisis management planning simulation exercises.

5. What is an audit?
An audit is a formal, systematic and documented examination of a tailings facility’s
conformance with explicit, agreed, prescribed criteria, often requirements stipulated in law
or in the company’s tailings management system. Audits evaluate and report on the
degree of conformance with stipulated criteria, based on the systematic collection and
documentation of relevant evidence. Audits involve some degree of judgment but are not
designed to determine root cause of deficiencies, or to evaluate management system
effectiveness.

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Internal audits are conducted by employees of the company with appropriate knowledge
and competencies who are independent, impartial, and objective with respect to the
management of the tailings facility being audited. For example, they could work at other
tailings facilities in the corporate portfolio or that could work at the corporate level.

External audits are conducted by auditors who are external to the company being audited.
Auditors maintain an objective viewpoint throughout the audit process to ensure that
findings and conclusions are based only on the evidence. (Adapted from ISO 19011).

6. What is an evaluation of effectiveness?

An evaluation of effectiveness goes beyond determining whether a condition has been met
and includes an assessment of whether tailings management is achieving the intended
results. It considers both the extent to which planned activities have been realized, and the
extent to which performance objectives and indicators have been achieved.

Criteria to be examined will depend on the scope of the evaluation. Typical sources of
information that should be considered when evaluating tailings management effectiveness
include changes in internal or external conditions that could affect tailings management
and achievement of performance objectives.
Performance results and trends that should be evaluated to determine the effectiveness of
tailings management include:
• the extent to which performance objectives and indicators have been achieved;
• the extent to which planned activities have been implemented as intended;
• fulfilment of conformance obligations;
• non-conformities and corrective actions;
• surveillance results;
• adequacy of resources to support achievement of performance objectives;
• feedback from practitioners and end users; and
• any additional relevant information or feedback from COI.

7. What is meant by the governance level of the company?

The company Board of Directors (or a sub-committee of the Board of Directors) is
considered the governance level of a company, the level at which the highest-level
corporate decisions are made, particularly regarding organizational and financial
resources. For companies headquartered outside of the country in which the tailings
facility is located that do not have a Board of Directors based in that country, the
governance level would be equivalent to the highest-level committee or board that
provides oversight and review of tailings management activities within that country.

Endorsement of the tailings management policy and/or commitments at the governance

level will vary from company to company. For example, a Board resolution adopting the
policy will be appropriate for some companies, while others will fulfill this requirement
through a presentation on the tailings management policy to a sub-committee of the Board
of Directors.

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8. How long are audits valid?

Internal and external audits remain valid up to a maximum of three years. In addition,
detailed assessments of conformance with the Table of Conformance remain valid until
there is a material change in tailings management.

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APPENDIX 2: GLOSSARY

Accountability: The answerability of an individual for their own performance and that of
any personnel they direct, and for the completion of specified deliverables or tasks in
accordance with defined expectations. An accountable person may delegate responsibility
for completion of the deliverable or task, but not the accountability.

Accountable Executive Officer: An executive-level person (e.g., CEO, COO, Vice

President) designated by the Board of Directors or Governance Level, who is accountable
for tailings management, and the development and implementation of the systems needed
for responsible tailings management. This accountability cannot be delegated. This Officer
has a direct reporting relationship to the Board, a Board committee, or the Governance
level and:

• needs to be aware of key outcomes of tailings facility risk assessments and how
these risks are being managed;
• has accountability and responsibility for putting in place an appropriate
management structure;
• delegates responsibility and authority for tailings management and defines the
personnel responsibilities, authority, and reporting relationships to implement the
systems needed for responsible tailings management through all phases in the
tailings facility life cycle; and
• demonstrates to the Board of Directors/Governance level whether tailings are
managed responsibly.

Authority: The power to make decisions, assign responsibilities, or delegate some or all
authority, as appropriate. The ability to act on behalf of the Owner.

Communities of Interest (COI): All individuals and groups who have an interest in, or
believe they may be affected by, decisions respecting the management of operations.
They include, but are not restricted to:

• employees;
• Aboriginal or Indigenous peoples;
• mining community members;
• suppliers;
• neighbours;
• customers;
• contractors;
• environmental organizations and other non-governmental organizations;
• governments;
• the financial community; and
• shareholders.

Company: The Tailings Guide uses the term “Owner” rather than “company.” The
definition of “company” for the purpose of this Protocol is the same as “Owner” as defined
in the Tailings Guide: Owner is the company, partnership, or individual who has legal
possession or is the legal holder of a tailings facility under law in the applicable jurisdiction

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where the facility is located. For example, the company, partnership or individual that owns
the mine or ore processing facility from which tailings and water are generated is the
owner of those tailings and can be considered the Owner of the tailings facility.

In the case of joint ventures or similar projects, they may be more than one company involved
in Ownership. In such cases, the Owner would comprise all companies that are represented on
the Board of Directors and are involved in decision-making.

Continual improvement: The process of implementing incremental improvements and

standardization to achieve better environmental and management system performance.

Emergency: A situation that poses an impending or immediate risk to health, life,

property, the environment and which requires urgent intervention to prevent or limit the
expected adverse outcomes.

Maintenance: Includes preventative, predictive, and corrective activities carried out to

provide continued proper operation of all infrastructure (e.g., civil, mechanical, electrical,
instrumentation, etc.), or to adjust infrastructure to ensure operation in conformance with
performance objectives.

Management system: Processes and procedures that collectively provide a systematic

framework for ensuring that tasks are performed correctly, consistently and effectively to
achieve a specified outcome and to drive continual improvement in performance. A
systems approach to management requires an assessment of what needs to be done,
planning to achieve the objective, implementation of the plan, and review of performance
in meeting the set objective. A management system also considers necessary personnel,
resources and documentation requirements. Other definitions associated with
management systems are:

Policy: The expression of management’s commitment to a particular issue area that

presents the stance of the company to interested external parties.
Practice: Documented approaches to carrying out a task.
Procedure: A documented description of how a task is to be carried out.

Operation: Includes activities related to the transport, placement, and permanent storage
of tailings and, where applicable, process water, effluents and residues, and the recycling
of process water. The term “operation” applies throughout all phases of the life cycle of a
tailings facility and is not limited to the operations and ongoing construction phase of the
life cycle when tailings are being actively placed in the facility. As a result, operation also
includes reclamation and related activities.

Responsibility: The duty or obligation of an individual or organization to perform an

assigned duty or task in accordance with defined expectations, and which has a
consequence if expectations are not met. An individual or organization with responsibility
is accountable to the person that delegated that responsibility to them.

Surveillance: includes the inspection and monitoring (i.e., collection of qualitative and
quantitative observations and data) of activities and infrastructure related to tailings
management. Surveillance also includes the timely documentation, analysis, and
communication of surveillance results, to inform decision making and verify whether

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performance objectives and risk management objectives, including critical controls, are
being met.

Tailings facility: The collective engineered structures, components and equipment

involved in the management of tailings solids, other mine waste managed with tailings
(e.g., waste rock, water treatment residues), and any water managed in tailings facilities,
including pore fluid, any pond(s), and surface water and runoff. This may include
structures, components and equipment for:

• classification of tailings through water content management (e.g., cyclones,

thickeners, filter presses);
• transporting tailings to the tailings facility (e.g., pipelines, flumes, conveyors,
trucks);
• containment of tailings and associated water (e.g., dams, dykes, stacks, liner
systems, cover systems);
• management of seepage (e.g., underdrains, collection ponds, pumping wells);
• water reclaim systems (e.g., pumping to the ore processing facility); management
of surface water releases from the tailings facility (e.g., diversions, decant
structures, spillways, outlets, flumes, water treatment);
• structures, components and equipment for the surveillance and maintenance of
tailings facilities; and
• mechanical and electrical controls, and power supply associated with the above.

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APPENDIX 3: TSM SELF-ASSESSMENT CHECKLIST

Tailings Management
Tailings
Company Name:
Facility Name:
Assessed By: Date Submitted:

Supporting Documentation / Evidence:

NAME OF DOCUMENT LOCATION

Interviewees:
NAME POSITION NAME POSITION

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INDICATOR 1: TAILINGS MANAGEMENT POLICY AND COMMITMENT

QUESTION Y N DESCRIPTION & EVIDENCE

Has the company developed a policy and/or

commitments that specifically address tailings
management, but all requirements for a Level
A are not met?
Has the company developed an action plan to
INDICATOR 1

meet all requirements for a Level A?

LEVEL B

If you have answered “Yes” to all of the Level B questions, assess company at a Level B.

If you have not answered “Yes” to all of the Level B questions, assess the company at a Level C,
unless you answered “no” because all requirements for a Level A have been met.
Has an internal audit been conducted and
determined that the following requirements
have been met?
Is a tailings management policy and/or
commitments in place that is in
conformance with the Tailings Guide?
Is the policy and/or commitments approved
by senior management?
Is the policy and/or commitments endorsed
at the governance level?
Is the policy and/or commitments
communicated to employees?
Do employees, contractors and
consultants whose activities may affect
tailings management, either directly or
indirectly, understand the policy to a
degree appropriate to their roles and
responsibilities?
INDICATOR 1 INDICATOR 1 INDICATOR 1

Is the policy and/or commitments

LEVEL A

implemented with budget allocation?

If you have answered “Yes” to all of the Level A questions, continue to the Level AA questions. If you
have not answered “Yes” to all of the Level A questions, assess the company at a Level B.
Has an external audit been conducted and
determined that all requirements for a Level A
LEVEL AA

have been met?

If you have answered “Yes” to the Level AA question, continue to the Level AAA question. If you have
not answered “Yes” to the Level AA question, assess the company at a Level A.
Did the external audit for Level AA include an
LEVEL AAA

evaluation of the effectiveness of the policy

and/or commitments for tailings management?
If you have answered “Yes” to the Level AAA question, assess the company at a Level AAA. If you
have not answered “Yes” to the Level AAA question, assess the company at a Level AA.

ASSESSED LEVEL OF PERFORMANCE FOR INDICATOR 1 Level: _____________

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 TAILINGS MANAGEMENT PROTOCOL – FEBRUARY 2019

INDICATOR 2: TAILINGS MANAGEMENT SYSTEM AND EMERGENCY

PREPAREDNESS

QUESTION Y N DESCRIPTION & EVIDENCE

Has the company developed and implemented

a tailings management system, but that system
is not in conformance with the Tailings Guide?
Has the company conducted a gap analysis
comparing existing tailings management
practices against the Tailings Guide and
determined that existing practices are not in
conformance with the Tailings Guide?
Has the company developed an ERP and an
EPP for the tailings facility but both plans are
not in conformance with the Tailings Guide?
Has the company developed an ERP and an
EPP that are in conformance with the Tailings
Guide but both have not been tested?
Has the company developed an action plan to
INDICATOR 2

meet all requirements for a Level A?

If you have answered “Yes” to all of the Level B questions, assess the company at a Level B.
LEVEL B

If you have not answered “Yes” to all of the Level B questions, assess the company at a Level C,
unless you answered “no” because all requirements for a Level A have been met.
Has an internal audit been conducted and
determined that the following requirements
have been met?
Has the company developed and
implemented a tailings management
system in conformance with the Tailings
Guide?
Has the company developed an ERP and
an EPP that are both in conformance with
the Tailings Guide?
Has the company tested both the ERP and
the EPP?
If you have answered “Yes” to all of the Level A questions, continue to the Level AA questions. If you
INDICATOR 2 INDICATOR 2

have not answered “Yes” to all of the Level A questions, assess the company at a Level B.
LEVEL A

NOTE: A tailings management policy is an inherent component of the tailings management system,
and a company cannot achieve Level A for Indicator 2 without achieving Level A or higher for Indicator
1.
Has an external audit been conducted and
determined that all requirements for a Level A
LEVEL AA

have been met?

If you have answered “Yes” to the Level AA question, continue to the Level AAA questions. If you have
not answered “Yes” to the Level AA question, assess the company at a Level A.

TOWARDS SUSTAINABLE MINING© Page 23

 TAILINGS MANAGEMENT PROTOCOL – FEBRUARY 2019

QUESTION Y N DESCRIPTION & EVIDENCE

Did the external audit for Level AA include an

evaluation of the effectiveness of the
development and implementation of the tailings
management system?
Did the external audit for Level AA include an
INDICATOR 2

evaluation of the effectiveness of the

LEVEL AAA

development and testing of the ERP and the

EPP?
If you have answered “Yes” to all of the Level AAA questions, assess the company at a Level AAA. If
you have not answered “Yes” to all of the Level AAA questions, assess the company at a Level AA.

ASSESSED LEVEL OF PERFORMANCE FOR INDICATOR 2 Level: _____________

TOWARDS SUSTAINABLE MINING© Page 24

 TAILINGS MANAGEMENT PROTOCOL – FEBRUARY 2019

INDICATOR 3: ASSIGNED ACCOUNTABILITY AND RESPONSIBILITY FOR

TAILINGS MANAGEMENT

QUESTION Y N DESCRIPTION & EVIDENCE

Has the company defined and documented

accountability and responsibility for tailings
management, but not met all requirements for
a Level A?
Has the company developed an action plan to
INDICATOR 3

meet all requirements for a Level A?

If you have answered “Yes” to all of the Level B questions, assess the company at a Level B.
LEVEL B

If you have not answered “Yes” to all of the Level B questions, assess the company at a Level C,
unless you answered “no” because all requirements for a Level A have been met.
Has an internal audit been conducted and
determined that the following requirements
have been met?
Has the Board or Governance Level
assigned accountability for tailings
management to an Accountable Executive
Officer?
Does the Accountable Executive Officer
have a direct reporting relationship with the
Board, a Board committee, or the
Governance Level?
Has the company delegated responsibility
and authority for tailings management in
writing to qualified personnel?
INDICATOR 3 INDICATOR 3

Has the company delegated responsibility

and authority for tailings management in
LEVEL A

conformance with the Tailings Guide?

If you have answered “Yes” to all of the Level A questions, continue to the Level AA question. If you
have not answered “Yes” to all of the Level A questions, assess the company at a Level B.
Has an external audit been conducted and
determined that all requirements for a Level A
LEVEL AA

have been met?

If you have answered “Yes” to the Level AA question, continue to the Level AAA questions. If you have
not answered “Yes” to the Level AA question, assess the company at a Level A.
Did the external audit for Level AA include an
evaluation of the effectiveness of the
assignment of accountability for tailings
management to the Accountable Executive
Officer?
Did the external audit for Level AA include an
INDICATOR 3

evaluation of the effectiveness of the

LEVEL AAA

delegations of accountability, responsibility and

budget authority?
If you have answered “Yes” to the Level AAA questions, assess the company at a Level AAA. If you
have not answered “Yes” to the Level AAA questions, assess the company at a Level AA.

TOWARDS SUSTAINABLE MINING© Page 25

 TAILINGS MANAGEMENT PROTOCOL – FEBRUARY 2019

QUESTION Y N DESCRIPTION & EVIDENCE

ASSESSED LEVEL OF PERFORMANCE FOR INDICATOR 3 Level: _____________

INDICATOR 4: ANNUAL TAILINGS MANAGEMENT REVIEW

QUESTION Y N DESCRIPTION & EVIDENCE

Has the company conducted periodic,

documented reviews of tailings management
for the tailings facility, but all requirements for a
Level A have not been met?
INDICATOR 4

Has the company developed an action plan to

meet all requirements for a Level A?
LEVEL B

If you have answered “Yes” to all of the Level B questions, assess the company at a Level A. If you
have not answered “Yes” to all of the Level B questions, assess the company at a Level C, unless you
answered “no” because all requirements for a Level A have been met.
Has an internal audit been conducted and
determined that the following requirements
have been met for the tailings facilty?
Are tailings management reviews
conducted on an annual basis?
INDICATOR 4 INDICATOR 4 INDICATOR 4

Are tailings management reviews in

LEVEL A

conformance with the Tailings Guide?

If you have answered “Yes” to all of the Level A questions, continue to the Level AA question. If you
have not answered “Yes” to all of the Level A questions, assess the company at a Level B.
Has an external audit been conducted and
determined that all requirements for a Level A
LEVEL AA

have been met?

If you have answered “Yes” to the Level AA question, continue to the Level AAA question. If you have
not answered “Yes” to the Level AA question, assess the company at a Level A.
Did the external audit for Level AA include an
LEVEL AAA

evaluation of the effectiveness of the annual

tailings management reviews?
If you have answered “Yes” to the Level AAA question, assess the company at a Level AAA. If you
have not answered “Yes” to the Level AAA question, assess the company at a Level AA.

ASSESSED LEVEL OF PERFORMANCE FOR INDICATOR 4 Level: _____________

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 TAILINGS MANAGEMENT PROTOCOL – FEBRUARY 2019

INDICATOR 5: OMS MANUAL

QUESTION Y N DESCRIPTION & EVIDENCE

Has the company developed an OMS manual

for the tailings facility, but that OMS manual is
not in conformance with the OMS Guide?
Has the company developed an action plan to
INDICATOR 5

meet all requirements for a Level A?

If you have answered “Yes” to all of the Level B questions, assess the company at a Level B
LEVEL B

If you have not answered “Yes” to all of the Level B questions, assess the company at a Level C,
unless you answered “no” because all requirements for a Level A have been met.
Has an internal audit has been conducted and
INDICATOR 5

determined that an OMS manual has been

developed and implemented that is in
LEVEL A

conformance with the OMS Guide?

If you have answered “Yes” to the Level A question, continue to the Level AA question. If you have not
answered “Yes” to the Level A question, assess the company at a Level B.
Has an external audit has been conducted and
INDICATOR 5

determined that an OMS manual has been

developed and implemented that is in
LEVEL AA

conformance with the OMS Guide?

If you have answered “Yes” to the Level AA question, continue to the Level AAA question. If you have
not answered “Yes” to the Level AA question, assess the company at a Level A.
Did the external audit for Level AA include an
INDICATOR 5

evaluation of the effectiveness of the

LEVEL AAA

development and implementation of the OMS

manual?
If you have answered “Yes” to the Level AAA question, assess the company at a Level AAA. If you
have not answered “Yes” to the Level AAA question, assess the company at a Level AA.
ASSESSED LEVEL OF PERFORMANCE
Level: _____________
FOR INDICATOR 5

TOWARDS SUSTAINABLE MINING© Page 27

 For more information about the TSM initiative, visit:

The Mining Association of Canada

www.mining.ca/tsm

Quebec Mining Association

www.amq-inc.com

Finnish Mining Association

www.kaivosvastuu.fi/in-english

The Argentinean Chamber of Mining Entrepreneurs (CAEM)

www.caem.com.ar/hms/

Botswana Chamber of Mines

www.bcm.org.bw

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written permission from the Mining Association of Canada provided the source is fully acknowledged.
Reproduction of this publication for resale or other commercial purposes is prohibited without prior written
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Mining®, TSM®, and the diamond shaped figure arcs and quadrilaterals designs, are either registered
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