Monthly Archives: May 2024

Complaints

Complaints and the IRMA System

This week IRMA posted the first complaints being processed through the IRMA Issues Resolution System. One (IRMA-2024-001) filed by the SIRGE Coalition (Securing Indigenous Peoples’ Rights In The Green Economy), and another (IRMA-2024-002) by the environmental advocacy NGO (and IRMA Board Member) Earthworks, both complaints question how the audit firm ERM CVS assessed the conformity of Albemarle’s Salar de Atacama lithium operation in northern Chile with IRMA’s Free Prior and Informed Consent (FPIC) requirements, and how evidence was weighed and assessed in reaching audit findings.

Although the larger goal is to make mining more responsible – overall and particularly at IRMA audited mines – the means to do that is by providing unprecedented transparency to all stakeholders so that they can open dialogues that incentivize better operational practices. These complaints are exactly that: stakeholders using the information provided by IRMA audits to examine a mine’s practices and ask why they were measured as they were.

It’s important to note that all actors directly or indirectly associated with these complaints are learning how to do their work better. Although the IRMA Standard has been around since 2018, the Albemarle operation was the first lithium operation audited against the Standard, and just the third mine audited overall. The audit firm, the mining company, and IRMA itself are learning how to the IRMA system works in practice and how we can improve it.

In the near future, IRMA and the audit firm will meet, after which point we will get back to the complainants with next steps. As we process these complaints we will update their pages to keep stakeholders current about how the Issues Resolution System is working, and to allow the opportunity for all concerned to keep IRMA true to our core principles.

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Standards

Update on Standard for Responsible Mining 2.0

As we announced back in October, IRMA is comprehensively revising the 2018 IRMA Standard for Responsible Mining (1.0). This revision process allows IRMA to:

  • Remain accountable to all sectors
  • Remain up-to-date with best practice
  • Add clarity and strengthen auditability
  • Add consistency, and
  • Fill in gaps

Seeking as much as possible to align with ISEAL’s Code of Good Practice for Sustainability Systems, this revision process is informed by:

  • 5 years of ongoing stakeholder engagement
  • Experiences from the initial IRMA third-party audits
  • Review of other standards and initiatives
  • Increased public awareness and evolving expectations of best practice
  • Review of emerging issues garnering international discussions
  • Changes to relevant legislation across the full scope of the standard
  • Comments on previous drafts (IRMA-Ready, Mineral Processing, Chain of Custody)
  • Targeted engagement activities on specific topics
  • IRMA Expert working groups, and
  • Public consultation

Unlike the Standard 1.0 which only covers mineral extraction operations, the  IRMA Standard 2.0 is expected to also cover development, exploration, and mineral processing: the IRMA Standard for Responsible Mining and Mineral Processing. Separately we will launch a Chain of Custody Standard.

Public Comments Received for the 1st Draft of IRMA Standard 2.0

The 90 day public consultation lasted from October 26 through January 26. During that time we:

  • Hosted 2 introductory webinars attended by 150 participants
  • Hosted 20 live topic consultation webinars — across multiple time zones — attended by 180 unique participants
  • Received 2,500+ discrete comments from 82 organizations, and
  • Allowed for additional engagement and feedback outside the formal process

The sector and geographic distributions of these 82 commenting organizations are shown below:

Regions from which Standard 2.0 public comments were submitted

 

Sectors from which IRMA received public comments on Standard 2.0 draft

Of the 28 chapters in first draft Standard 2.0, the most-commented upon were (in alphabetical order):

  • Biodiversity, Ecosystem Services and Protected Areas
  • Community and Stakeholder Engagement
  • ESIA (Environmental and Social Impact Assessment and Management)
  • Fair Labor and Terms of Work
  • Gender Equality and Gender Protections (new)
  • GHG and Energy Consumption
  • Human Rights Due Diligence
  • Indigenous Peoples and FPIC
  • Occupational Health and Safety
  • Waste and Materials Management
  • Water Management

Public Comments Received for the second draft of the Chain of Custody Standard

A first draft was released for public comment in 2021. The 90 day public consultation for the second draft lasted from October 26 through January 26. During that time we:

Timeline

As included in the graphic below, the IRMA Secretariat is currently processing all the public comments received. Although subject to the approval of the IRMA Board of Directors, it is envisaged to release a 2nd draft for public comment in the second half of 2024. We hope to launch the actual Standard 2.0 – once approved by the IRMA Board of Directors – towards the end of 2024, thus triggering a transition period (duration to be decided and approved by the Board) between versions 1.0 and the 2.0 for all the entities and sites engaged (and seeking to engage) in the IRMA System.

Standard 2.0 revision timeline

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