Public Information, Rm. 6808
Bureau of Public Affairs
U.S. Department of State
Washington, D.C. 20520-6810 AskPublicAffairs@state.gov
Re: The U.S. and Minerals Security Partnership Should Require IRMA when Selecting a Standard for Critical Minerals Projects
Dear Colleagues,
On January 23rd Jose Fernandez announced that the U.S. and other members of the Minerals Security Partnership (MSP) are carefully selecting a set of critical minerals projects to support and are identifying a set of standards companies and countries will need to meet to receive related assistance.
The U.S. and the MSP should require the Initiative for Responsible Mining Assurance (IRMA) because it is a standard and system equally governed by private and public sectors, unique from industry trade association standards.
IRMA is a multi-stakeholder coalition that brought leaders from diverse sectors together in 2006 to craft the world’s first shared definition of what it means to mine responsibly: the IRMA Standard for Responsible Mining. The IRMA Standard is the result of a comprehensive process spanning more than ten years, including a public consultation process incorporating 1,400 comments from more than 100 different individuals and organizations.
IRMA members include six major automakers, leading jewelers, a wind energy company, mining companies, the world’s two largest global trade unions, leading human rights and environmental advocates, indigenous leaders, leaders of mine-affected communities, and increasing engagement from the investor and finance sector.
Not all standards for the mining sector are equal. Various sets of principles and standards are promulgated by industry trade associations and may identify as multi-stakeholder but do not provide an equal seat at the table for NGOs, affected communities, and labor alongside the private sector. The level of detail in the standards varies widely, as does the quality of assessment and reporting—ranging from company self-reporting with no public reports to independent third-party audits resulting in transparent public reports. Local stakeholders and rights holders may or may not know in advance that an assessment will occur or even be provided with an opportunity to share their experience and opinions.
IRMA stands out from industry trade association standards because it is recognized across stakeholder sectors and has already been recognized by multiple MSP members. The United Kingdom’s 2022 Critical Minerals Strategy references IRMA as a globally recognized framework for responsible mining.[1] In 2021, the White House referenced IRMA in its 100-Day Review on Building Resilient Supply Chains, noting that IRMA is a possible “method for U.S. companies and the Federal Government to ensure that minerals are being sourced from mines with robust environmental, social, and financial responsibility practices.”[2] The European Parliament referenced the IRMA Standard in its 2021 strategy for critical raw materials.[3] The Government of Australia called IRMA a “no regrets approach” in its 2020 study of certifications and strategies to increase competitiveness of Australian battery materials for use in the EV sector in Europe.[4]
IRMA is the only standard for the mining sector that fully embodies the Biden Administration’s environmental justice goals. This is because IRMA is the only standard for the mining sector that:
is equally governed by directly affected communities, NGOs, labor unions, mining companies, purchasing companies, and the investor and finance sector;
requires public notice in advance of an audit so that local stakeholders and rights holders can prepare to engage in the audit;
is applicable globally and covers all mined materials (apart from thermal coal, uranium, and deep seabed mining projects);
includes the full range of environmental and social issues related to industrial-scale mines;
requires detailed public reports made available at no cost to the public, with scoring and rationale on over 26 topics across over 400 requirements; and
has demonstrated credibility with civil society and labor unions.
IRMA is built on best practice norms. Existing international systems and frameworks form the basis of requirements in the IRMA Standard and are assessed in IRMA audits. These include but are not limited to the Extractive Industries Transparency Initiative (EITI), the International Cyanide Management Code, International Finance Corporation (IFC) Performance Standards, International Labour Organization Conventions, International Union for Conservation of Nature (IUCN) Protected Area Management Categories, the Minamata Convention on Mercury, OECD Due Diligence Guidance, UNESCO Biosphere Reserves, the United Nations Guiding Principles on Business and Human Rights, and the Voluntary Principles on Security and Human Rights.
IRMA requires completion of an independent third-party audit before any public claims may be made related to IRMA achievement. The IRMA system enables companies to clearly communicate their performance across a holistic set of best practices and work toward continuous improvement in environmental and social responsibility.
IRMA’s equal governance model upholds a standard and system that creates confidence and value across all stakeholder sectors and greater trust across supply chains. The U.S. and MSP should support and incentivize the IRMA Standard and system because of its unique accountability to all sectors and alignment with the MSP’s commitment to “adhere to the highest environmental, social, and governance standards.”[5]
[4] UTS Institute for Sustainable Futures and the University of Melbourne, Certification and LCA of Australian Batter Materials – Drivers and Options: Scene Setting Project Prepared for Future Battery Industries CRC, Future Battery Industries CRC, Australian Government Department of Industry, Innovation and Science Business Cooperative Research Centres Program, August 2020, https://fbicrc.com.au/wp-content/uploads/2020/10/Certification-of-Au-Battery-Materials-WEB-INTERACTIVE-SEPT-2020.pdf.
9 Feb 2023 | 08:00 a.m. – 09:15 a.m.
SunSquare Cape Town City Bowl
23 Buitengracht St., Cape Town
Join us for a breakfast discussion with public and private sector representatives about how they are using the Initiative for Responsible Mining Assurance (IRMA) to improve environmental and social management in the mining sector.
From critical materials for the energy transition and electric vehicles to materials for jewelry, electronics, household goods, and beyond, IRMA is a tool governed by and with benefits for all sectors.
Governed equally by NGOs, affected communities, labor unions, mining companies, purchasing companies, and investors, IRMA is used to conduct site-level assessments, increase transparency through independent third-party audits and reporting, and improve legal frameworks.
Our Panelists Include:
Kristi Disney Bruckner, IRMA Senior Policy Advisor
Sarah Makumbe, Anglo American Responsible Mining Program Manager
Nyaradzo Mutonhori, Zimbabwe Environmental Law Association (ZELA) Programmes Manager
Vuyisile Ncube, Earthworks Making Clean Energy Clean, Just, and Equitable Advocate
Please join us for this informal breakfast. It is open to all and free to attend, but space is limited!
As we welcome the new year, we are thrilled to welcome three new board members:
Community Sector: Pavel Sulyandziga, Russia
Pavel Sulyandziga
Pavel is an Indigenous leader and human rights activist from the Bikin River valley in Siberia. He is dedicated to protecting indigenous communities, whose rights are often violated by business. Pavel has a PhD in Economics and is President of the International Indigenous Fund for Development and Solidarity “Batani” (Batani Foundation). He’s currently a Visiting Scholar at Dartmouth College (US) and at Law School University of Maine and was a member of the United Nations Permanent Forum on Indigenous Issues (2005 – 2010) and Member of the United Nations Working Group on Business and Human Rights (2011 -2018). He joins Meshack Mbangula of Mining Affected Communities United in Action (MACUA) in representing the Community Sector.
Labor Sector: Meg Gingrich, Canada
Meg Gingrich is Assistant to the National Director of United Steelworkers (USW) Canada. For ten years she’s been on staff at USW Canada’s National Office, first as a researcher and now as the Assistant to the National Director. In that position she’s the senior administrative and policy advisor to the USW in Canada, with lead responsibility on issues relating to trade, industrial policy, and strategic planning. She’s also the central liaison on these issues with the leadership of USW United States. Meg is also the President of Blue Green Canada, which was co-founded in 2008 along with Environmental Defence as a joint labour-environment-community coalition. She joins Glen Mpufane of IndustriALL Global Union in representing the Labor Sector.
Purchaser Sector: Claudia Becker, Germany
Claudia Becker
Claudia is BMW Group’s Expert on Raw Material Strategy and Sustainable Supply Chain Management. Claudia has been working for the BMW Group since 2012 in operational and strategic purchasing functions. In 2016 she joined BMW’s responsible sourcing team with a focus on due diligence in mineral supply chains. Claudia works closely with supply chain partners and represents BMW in various international and cross-industry initiatives, such as Drive Sustainability, RMI and the GBA. Before joining the BMW Group, Claudia worked in the sector of international development cooperation including for the Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ) in Cambodia on sustainable urban development. Claudia has an academic background in Geography from the University of Bonn with a focus on development cooperation, sustainability, and urbanism. Claudia joins J.J. Messner de Latour of Microsoft in representing the Purchasing Sector.
As we welcome Claudia, Meg, and Pavel to the IRMA board, we reflect with appreciation on the invaluable contributions of those who have served IRMA’s governance since its founding: Dewa Mavhinga, Mike Kowalski, Anisa Kamadoli Costa, Samara Rudolph, Joan Krajewski, Ephi Banaynal dela Cruz, Susan Posnock, Joe Drexler, Mark Rowlinson, Alan Knight, Nuskmata, Larson Bill, Loretta Williams, and many more to whom we owe deep appreciation for their work.
New Year, Same Unique Governance Model
While there are other multi-stakeholder, extraction-related and metals-related standards, IRMA’s governance model is unique: equal governing authority shared between six sectors with an interest in mining. For any board vote, if the two representatives from any given sector oppose a motion, the vote fails even if all other board members are in support. To our knowledge, the IRMA board is the only place in the world where communities, labor, and civil society have an equal voice alongside mining companies and other multinational corporations.
Looking Forward
2023 will be an important year in advancing IRMA’s vision: a world where the mining industry respects the human rights and aspirations of affected communities, provides safe, healthy and supportive workplaces, minimizes harm to the environment, and leaves positive legacies.
Our work to create financial value for mines independently assessed against the world’s most robust mining standard will take a major leap forward. Audit reports for at least ten mine sites will be released in 2023, including the first lithium mines assessed in IRMA. 2023 will also see the IRMA Standard expand to include exploration and development, before mines are operating, and also mineral processing operations, as well as updating the current Standard for active mining operations.
We do this work to integrate learning from the first mine audits, and to create value for an evolving definition of “best practices”, shared across stakeholder sectors, for environmental and social responsibility. As with all of IRMA’s work, this is only possible through the engagement of all affected stakeholders and we welcome your engagement.
At the end of October, the IRMA Secretariat had our first in-person annual planning retreat since the onset of the COVID pandemic. At the retreat’s opening, those in attendance shared with one another why we work for IRMA. Below we share those reasons with you.
“Industrialized societies used mined materials every day but most people don’t know much about mining, the places these materials come from, and the impacts of extraction. Among the people who know the issues well, there is deeply broken trust between companies and affected communities. It’s meaningful to work with diverse stakeholders and indigenous rights holders committed to addressing these issues in a respectful way and working together to reduce harm.” — Aimee Boulanger, Executive Director
“I work for IRMA because in a time of peak political will to improve environmental and social performance in the mining sector, the IRMA Standard for Responsible Mining provides a detailed roadmap informed by over a decade of input across sectors. The IRMA Standard is an excellent tool for assessing and improving legal frameworks as well as mine site performance, promoting the level of protections and transparency so greatly needed in this era of energy transition.” — Kristi Disney Bruckner, Senior Policy Advisor
“Since the beginning of my career, I have believed business—when managed responsibly—can have substantial, positive impacts in the places it operates, from source point to end consumer. IRMA provides a clear path for companies along the mineral value chain to perform at a higher level and align with the expectations of customers and civil society alike.” — Rebecca Burton, Director of Corporate Engagement
“The IRMA Standards have the potential to bridge the gaps between mining policies and the demands of various stakeholders impacted by resource extraction. As a part of the IRMA Secretariat, I have the unique opportunity to work together with some of the most passionate people to reach the full potential of the IRMA mission and vision in a manner that gives an equal voice to all stakeholders.” — Adan Olivares Castro, Special Projects Coordinator for Latin America
“As traditional means of protecting communities and the environment are increasingly hamstrung by bad faith actors, I believe that IRMA is the best way to help the most people and the ecosystems we all rely upon by encouraging mining companies to operate more responsibly — and showing them how.” — Alan Septoff, Information Systems & Communications Director
“We live in a world that requires metals to address today’s needs and provide solutions for tomorrow. I am inspired every day to have the opportunity to support a holistic and honest assessment of the impact of mining on people and the planet, and I am humbled with the opportunity to set expectations for best practice mining that honors the diverse interests and rights of stakeholders.” — Michelle Smith, Director of Standards & Assurance
“As the demand for mined materials and natural resources increase, the IRMA team is navigating a better way for the mining industry and finding solutions for best practices which includes the critical work of reducing impacts and harm to affected communities and the environment. This is approached with great passion, intelligence and respect for all our stakeholders, and I am proud to be part of making such meaningful and positive changes for the world.” — Kristen Vissers, Program Coordinator
In response to practical difficulties obtaining financial surety for mine closure and post closure as defined by the IRMA Standard, IRMA has modified 2.6.4.1 which is a critical requirement in the IRMA standard and must be substantially or fully met in order to achieve IRMA 50 or higher.
With this modification, the requirement for “financial surety instruments” — which by definition exclude corporate guarantees and self-bonding — is replaced with “financial assurance mechanisms.” This allows a broader range of acceptable means to guarantee the costs associated with third-part mine closure and post-closure.
The IRMA Secretariat made this change with the concurrence of the IRMA Board and external expert feedback. This is a temporary adaptation that will be reconsidered in the planned revision of the IRMA Standard expected in late 2023.
This announcement was posted by SCS Global Services in local press and the community 30 days in advance of the on-site audit as required by the IRMA Assessment process.
On-site, independent audit under the IRMA Standard for Responsible Mining
Livent Fenix Lithium Mine, Salar del Hombre Muerto, Catamarca, Argentina
Between November 28 and December 2, 2022, SCS Global Services (SCS) will commence an independent audit of Livent’s Fenix lithium operation to evaluate its performance under the Initiative for Responsible Mining Assurance (IRMA) Standard for Responsible Mining. IRMA is a voluntary assessment system that provides a set of best practice standards and participatory stakeholder engagement requirements created to improve mining operations’ environmental and social performance. Livent (NYSE: LTHM) is an IRMA member.
The third-party, independent audit provides stakeholders, including community members, workers, organized labor, government representatives, and other interested parties, the opportunity to give feedback on the mine’s environmental, health, safety, and community performance. SCS will use stakeholder comments to help determine how the Livent Fenix operation performs relative to the IRMA Standard.
Stakeholders are invited to submit written comments to coincide with the on-site audit. Stakeholders may also contact SCS if they would like to be interviewed. Interviews will take place virtually (telephone or videoconference) or in person, considering Covid-19 precautions. Stakeholder comments, questions, and interview requests can be made through the link below; commenters’ identities and remarks are kept confidential upon request.
Upon completion of the Livent Fenix audit, IRMA will publish the independent audit results and present an overall achievement score: IRMA Transparency, IRMA 50, IRMA 75, or IRMA 100. Only mines achieving IRMA 100 are “certified” under the IRMA Standard.
SCS is an IRMA-approved certification body with head offices in Emeryville, California. For more information about SCS, please visit www.scsglobalservices.com.
The IRMA Standard is the world’s most comprehensive mining standard for industrial-scale mines and the only one equally governed by all stakeholders: mining companies, mineral purchasers, investors, organized labor, communities, and civil society NGOs. Mine site verification under the IRMA Standard is voluntary. For more information on the IRMA Standard requirements and certification, visit www.responsiblemining.net.
Este anuncio fue publicado por SCS Global Services en la prensa local y en la comunidad 30 días antes de la auditoría in situ según lo exige el proceso de evaluación de IRMA.
Auditoría independiente in situ según la Norma IRMA para la Minería Responsable
Mina de litio de Livent en Fénix, Salar del Hombre Muerto, Catamarca, Argentina
Entre el 28 de noviembre y el 2 de diciembre de 2022, SCS Global Services (SCS) iniciará una auditoría independiente de la operación de litio Fénix de Livent para evaluar su desempeño según el Estándar para la Minería Responsable de la Iniciativa para el Aseguramiento de la Minería Responsable (IRMA). IRMA es un sistema de evaluación voluntaria que proporciona un conjunto de normas de mejores prácticas y requisitos de participación de las partes interesadas creados para mejorar el desempeño ambiental y social de las operaciones mineras. Livent (NYSE: LTHM) es miembro de IRMA.
La auditoría independiente de terceros ofrece a las partes interesadas, incluidos los miembros de la comunidad, los trabajadores, los sindicatos, los representantes del gobierno y otras partes interesadas, la oportunidad de dar su opinión sobre el desempeño ambiental, de salud, de seguridad y de la comunidad de la mina. SCS utilizará los comentarios de las partes interesadas para ayudar a determinar el rendimiento de la operación de Livent en Fénix en relación con la norma IRMA.
Se invita a las partes interesadas a presentar comentarios por escrito coincidiendo con la auditoría in situ. Las partes interesadas también pueden ponerse en contacto con el SCS si desean ser entrevistadas. Las entrevistas tendrán lugar de forma virtual (teléfono o videoconferencia) o en persona, teniendo en cuenta las precauciones de Covid-19. Los comentarios, las preguntas y las solicitudes de entrevista de las partes interesadas pueden hacerse a través del enlace que figura a continuación; la identidad y las observaciones de los comentaristas se mantendrán confidenciales si así se solicita.
Enlace: https://info.scsglobalservices.com/irmacomentarios
Una vez finalizada la auditoría de Livent en Fénix, IRMA publicará los resultados de la auditoría independiente y presentará una puntuación global de logro: Transparencia IRMA, IRMA 50, IRMA 75 o IRMA 100. Sólo las minas que alcanzan el nivel IRMA 100 están “certificadas” por la norma IRMA.
SCS es un organismo de certificación aprobado por IRMA con sede en Emeryville, California. Para más información sobre SCS, visite www.scsglobalservices.com.
Acerca de IRMA
La Norma IRMA es la norma minera más completa del mundo para las minas a escala industrial y la única que se rige por igual por todas las partes interesadas: empresas mineras, compradores de minerales, inversores, trabajadores organizados, comunidades y ONG de la sociedad civil. La verificación de los emplazamientos mineros según la Norma IRMA es voluntaria. Para obtener más información sobre los requisitos y la certificación de la Norma IRMA, visite www.responsiblemining.net.
At the invitation of Indonesia’s Coordinating Ministry for Maritime and Investment Affairs, IRMA participated in a series of meetings held September 5-9 in Jakarta to introduce the IRMA Standard and system to a wide range of sectors with interest in mineral development and processing. Represented by Senior Policy Advisor Kristi Disney Bruckner, the meetings occurred following requests from members of IRMA’s Buyers Group for engagement in Indonesia, calling on mine sites to complete independent, third-party audits.
Indonesia’s Coordinating Ministry for Maritime and Investment Affairs, EITI Indonesia, Eramet, and others collaborated to host a full-day Introducing the Initiative for Responsible Mining Assurance (IRMA) to Indonesian Mining Companies forum on September 6th. Over 140 participants attended the event, including representatives of more than 25 companies with experience in nickel, aluminum, steel, coal, and other sectors. Participants also included representatives of the Ministry of Energy and Mineral Resources, Environment and Forestry, Finance, and Investment; the National Standardization Agency; state-owned enterprises; French and U.S. Embassies; and NGOs Publish What You Pay, Action for Ecology and People Emancipation (AEER), and others; media; consultants; academics; investors; and purchasing companies. Speakers at the event included representatives of Eramet, IRMA, the Coordinating Ministry for Maritime and Investment Affairs, the EITI Secretariat, and Ørsted.
IRMA participated in a separate NGO Roundtable on September 7th, attended by Publish What You Pay, Keanekaragaman Hayati (Indonesian Biodiversity Foundation), Yayasan Konservasi Alam Nusantara (Indonesian Nature Conservation Foundation, YKAN), Auriga Nusantara, World Resources Indonesia, Peduli Konservasi Alam (Movement for Nature Conservation, PEKI), Konservasi Indonesia (Conservation Indonesia), Wetlands International Indonesia, and AEER.
IRMA also held ad hoc meetings throughout the week with representatives of NGOs, government, and companies.
Indonesia is a major producer of nickel and other materials needed for EVs and is key to the energy transition. The recent history of mining in Indonesia includes environmental harm and human rights violations, particularly in Papua Province. Addressing those harms, preventing future harm, and ensuring equitable distribution of benefits requires responsible management of the mining sector.
The Indonesian government’s invitation and its completion of a gap analysis between the country’s legal framework and the IRMA Standard for Responsible Mining signal recognition of the IRMA Standard as a model to capture the increasing market value of environmental and social responsibility. IRMA is a tool available to all Indonesian stakeholders–government, NGOs, affected communities, organized labor, mining companies, purchasing companies, and investors–to promote more responsible environmental and social management in the mining sector. IRMA’s engagement in Indonesia supports efforts to improve governance of the mining sector and bring Indonesian mines into IRMA’s independent, third-party audit and transparent reporting process. These steps can promote good governance from national to mine site levels, benefitting diverse stakeholders and rights holders in Indonesia.
As of February 2023, 69 mining companies are now engaged in IRMA representing 83 sites:
