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The IRMA Standard – A Tool For U.S. Mining Law Reform

IRMA a Tool for U.S. Mining Law Reform_Examples of Gaps in U.S. Framework - coverOn Tuesday August 30, the IRMA Secretariat submitted a letter to the Biden Administration’s Interagency Working Group (IWG) on mining reform.

The letter provides examples of areas where there are gaps between the good practices in the IRMA Mining Standard and the U.S. legal framework governing the mining sector. Although not comprehensive, the examples identify areas where gaps can be addressed to ensure conformity with good international practice.

These examples are based on a preliminary review of the U.S. legal framework. A requirement-by-requirement comparison between the IRMA Standard and the U.S. legal framework would be necessary to identify all the gaps, and could guide the work of the IWG and support recommendations for improvements to the U.S. legal framework. We recommend that such a study be funded and completed to inform IWG efforts.

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Carrizal Mine Surveillance Assessment Update

The Initiative for Responsible Mining Assurance (IRMA) is pleased to announce the upcoming third-party independent surveillance assessment of the Carrizal Mine against the IRMA Standard for Responsible Mining. The Carrizal Mine is located near Zimapan in the Hidalgo province of Mexico. The on-site portion of the surveillance audit will occur 24-27 August 2022.

What is a Surveillance Audit?

A surveillance audit is a mid-cycle verification to ensure no material negative changes have occurred at a site. It is not a re-assessment of all IRMA requirements. Surveillance audits follow much of the same process as a certification audit and include document review, on site-assessment, and community and stakeholder engagement. An IRMA surveillance audit confirms continued performance against critical requirements, verifies ongoing regulatory compliance processes, and evaluates progress on corrective actions. It also follows up on stakeholder input received since the prior audit and areas of risk identified in the previous audit and confirms no major changes have occurred that would impact the previously assessed achievement level.

ERM CVS is the IRMA-approved certification body carrying out the surveillance assessment.

Stakeholder Engagement in the Assessment

Interested stakeholders and members of the public can sign up to receive updates about the Carrizal mine assessment. The Mines Under Assessment page of IRMA’s website will also provide up-to-date information on all assessments.

Mine site stakeholders are invited to submit comments to ERM CVS on the social and environmental performance of the Carrizal Mine (in particular, how the mine measures against the IRMA Standard for Responsible Mining).

Carrizal Mine stakeholders may also contact ERM CVS if they are interested in being interviewed as part of the assessment process or being notified of the publication of the public report.

Stakeholder comments and expressions of interest in being interviewed as part of the audit process should be submitted by email to post@ermcvs.com.

Email: visit the ERM CVS website for this information and more on the audit.

Please forward this announcement, and feel free to contact ERM CVS directly to provide names and contact information for other mine site stakeholders who may be interested in knowing about and participating in the mine site assessment process.

For more information

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IRMA Mining Engagement Update – Aug 2022

As of August 2022, 62 mining companies are now engaged in IRMA representing 74 sites:

  • 62 sites are self-assessing under the IRMA Standard, the first step before an independent audit;
  • 11 sites are piloting the draft IRMA exploration (IRMA Ready) or mineral processing standard self-assessments
  • 2 independent audit reports have been released — Anglo American’s Unki mine in Zimbabwe, and Carrizal’s Zimapán mine in Mexico;
  • 11 audits are under way — 9 initial audits (Argentina, Brazil, Chile, South Africa), and 2 surveillance audits (Mexico, Zimbabwe)
  • They are located in 23 countries:
    1. Argentina
    2. Australia
    3. Brazil
    4. Canada
    5. Chile
    6. Colombia
    7. Dominican Rep.
    8. Finland
    9. France
    10. Indonesia
    11. Liberia
    12. Mexico
    13. Mozambique
    14. New Caledonia
    15. Panama
    16. Philippines
    17. Russia
    18. South Africa
    19. Spain
    20. Sri Lanka
    21. Ukraine
    22. United States
    23. Zimbabwe
  • They encompass 27 minerals:
    1. Aggregate
    2. Barite
    3. Bastnaesite
    4. Chrome
    5. Cobalt
    6. Copper
    7. Clay
    8. Diamonds
    9. Gold
    10. Graphite
    11. Iron
    12. Lead
    13. Limestone
    14. Lithium
    15. Magnesium
    16. Mineral sands
    17. Nickel
    18. Palladium
    19. Platinum
    20. Rhodium
    21. Sand
    22. Silver
    23. Strontium
    24. Titanium
    25. Vanadium
    26. Zinc
    27. Zirconium
    28. Rare Earth elements
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Unki audit picture with Anglo IRMA SCS logosUnki audit picture with Anglo IRMA SCS logosBlog

Unki Mine Surveillance Assessment Update

The Initiative for Responsible Mining Assurance (IRMA) is pleased to announce the completion of the on-site portion of the third-party independent surveillance assessment of the Unki platinum group metals (PGM) mine against the IRMA Standard for Responsible Mining. The Unki mine, located in the Midlands province of Zimbabwe, is operated by Anglo American Platinum. The on-site surveillance assessment occurred Aug 3-5.

What is a Surveillance Audit?

A surveillance audit is a mid-cycle verification to ensure no material negative changes have occurred at a site. It is not a re-assessment of all IRMA requirements. Surveillance audits follow much of the same process as a certification audit and include document review, on site-assessment, and community and stakeholder engagement. An IRMA surveillance audit confirms continued performance against critical requirements, verifies ongoing regulatory compliance processes, and evaluates progress on corrective actions. It also follows up on stakeholder input received since the prior audit and areas of risk identified in the previous audit and confirms no major changes have occurred that would impact the previously assessed achievement level.

SCS Global Services (SCS) is the IRMA-approved certification body carrying out the surveillance assessment.

Stakeholder Engagement in the Assessment

Interested stakeholders and members of the public can sign up to receive updates about the Unki mine assessment. The Mines Under Assessment page of IRMA’s website will also provide up-to-date information on all assessments.

Mine site stakeholders are invited to submit comments to SCS on the social and environmental performance of the Unki mine (in particular, how the mine measures against the IRMA Standard for Responsible Mining).

Unki mine stakeholders may also contact SCS if they are interested in being interviewed as part of the assessment process or being notified of the publication of the public report.

Stakeholder comments and expressions of interest in being interviewed as part of the audit process should be submitted by email or mail to:

SCS Global Services
2000 Powell St. #600
Emeryville, California, USA 94608

Email: visit the SCS website for this information and more on the audit.

Please forward this announcement, and feel free to contact SCS directly to provide names and contact information for other mine site stakeholders who may be interested in knowing about and participating in the mine site assessment process.

For More Information

 

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Digging for Climate Change WebinarDigging for Climate Change WebinarBlog

Can miners achieve net-zero & satisfy growing demands?

In late July Mining Journal’s Digging for Climate Change hosted a panel discussion on the challenges involved with meeting net-zero ambitions while satisfying growing demand for raw materials.

Participants:

  • Aimee Boulanger, Executive Director, Initiative for Responsible Mining Assurance
  • Andrew van Zyl, Principal Consultant and Director, SRK Consulting
  • Kirsten Hund, Head of Carbon Neutrality, De Beers Group
  • Veronica Martinez, Senior Manager, Innovation and Climate Change, International Council on Mining and Metals

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U.S. State Department logoU.S. State Department logoBlog

IRMA presents to the U.S. State Department

Today IRMA executive director Aimee Boulanger, and senior policy advisor Kristi Disney Bruckner presented before the Department of State’s Clean Energy Resources Advisory Committee (CERAC). CERAC “advises the Department of State’s Bureau of Energy Resources on strategies, programs, and policies related to clean energy mineral supply chains.”

IRMA made nine recommendations to CERAC:

  1. Recognize the importance of equal governance in multi-stakeholder leadership, engagement, and public access to information.
  2. Adopt a holistic lens to mining sector management, including a wide range of environmental and social factors.
  3. Use the IRMA Standard for Responsible Mining to assess gaps in domestic legal frameworks, and incorporate best practices on international to local levels.
  4. Promote an inclusive, participatory, transparent rights-based approach to relationships between mines and communities, with access to remedy.
  5. Use IRMA standards and audit reports to guide more responsible sourcing of mined materials.
  6. Encourage mines to engage in IRMA, which connects market value with environmental and social responsibility, and encourages continuing improvement while striving toward best practice.
  7. Identify and act on opportunities for the U.S. to be a “first mover” on responsible sourcing of mined materials, due diligence, and circularity.
  8. Foster innovation, strategic planning, and meaningful engagement of workers, communities, NGOs, companies, and investors in the “green” transition
  9. Collaborate with other governments to enhance environmental and social performance and transparency of the mining sector and supply chains.
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Mining engagement with IRMA update

As of this June, 55 mining companies are now engaged in IRMA representing 72 sites:

  • 61 sites are self-assessing, the first step before an independent audit;
  • 2 independent audit reports have been released — Anglo American’s Unki mine in Zimbabwe, and Carrizal’s Zimapán mine in Mexico;
  • 11 audits are under way — 9 initial audits (Argentina, Brazil, Chile, South Africa), and 2 surveillance audits (Mexico, Zimbabwe)
  • They are located in 23 countries:
    1. Argentina
    2. Australia
    3. Brazil
    4. Canada
    5. Chile
    6. Colombia
    7. Dominican Rep.
    8. Finland
    9. France
    10. Indonesia
    11. Liberia
    12. Mexico
    13. Mozambique
    14. New Caledonia
    15. Panama
    16. Philippines
    17. Russia
    18. South Africa
    19. Spain
    20. Sri Lanka
    21. Ukraine
    22. United States
    23. Zimbabwe
  • They encompass 27 minerals:
    1. Aggregate
    2. Barite
    3. Bastnaesite
    4. Chrome
    5. Cobalt
    6. Copper
    7. Clay
    8. Diamonds
    9. Gold
    10. Graphite
    11. Iron
    12. Lead
    13. Limestone
    14. Lithium
    15. Magnesium
    16. Nickel
    17. Palladium
    18. Platinum
    19. Rhodium
    20. Sand
    21. Silver
    22. Strontium
    23. Titanium
    24. Vanadium
    25. Zinc
    26. Zirconium
    27. Rare Earth elements
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IRMA’s Deep Sea Mining position

In April 2021, via our newsletter IRMA notified our followers of our position on deep sea mining. Because deep sea mining is increasingly a topic of conversation of late, we are republishing that statement here:

IRMA was not developed to assess the unique risks associated with deep-sea mining and cannot be used to describe best practice for this type of extraction. As such, and in light of the need for ongoing research, the current inability to audit impacts, and a risk that IRMA’s Standard could be inappropriately applied if used in the deep-sea context, IRMA does not allow its system (whether self-assessments or audits) to be used by companies involved in deep-sea mining exploration. We will continue to stay abreast of developments related to this topic, providing applicable expertise and our unique multi-stakeholder perspective, as appropriate.

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IRMA’s Response to Russia’s Attacks on Ukraine

IRMA is deeply concerned with the terrible conflict in Ukraine. As we have both private sector and civil society organizations working with IRMA in the region, we have spent the last week reaching out to our participants, other multi-stakeholder standards systems, and experts in auditing. We welcome feedback from any stakeholder on our course of action.

  • IRMA civil society organizations focused on Russia, working for greater environmental and social responsibility in mining, are encouraged to continue to engage in IRMA.
  • Private sector purchasers and investors with concern for more responsible practices may continue to ask mining companies in Russia to measure their performance against the IRMA Standard.
  • For mining companies based in Russia, all effort at this time must be with the IRMA Mine Measure self-assessment tool, which can guide them on areas that may need improvements to protect social and environmental values. No external claims of IRMA achievement by companies using the tool will be allowed in the market. No mining companies in Russia have yet been independently audited against the IRMA Standard. We will not commence auditing in the region until there is greater stability and confidence that diverse stakeholders may safely engage in a robust independent audit. Additionally, a decision has been made to pause membership activities for Russian-based mining companies at this time.

We join the global community in heartache for the suffering at this time of violent conflict there and in other places around the world. We affirm IRMA’s core vision regardless of the geography: 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 position is an initial response and will evolve as appropriate with global circumstances and we welcome your feedback at info@responsiblemining.net.

UPDATE: 21 March 2022

Nornickel Statement

Nornickel is a Russia-based mining company that had pending membership status in IRMA and, as a result, was preparing for independent audit. IRMA has encouraged the company to continue to use the self-assessment tool to understand IRMA requirements and to seek opportunities for improved performance, and we hope to engage in an independent audit in the future. The company has shared with IRMA the following statement:

Nornickel has agreed to pause its pending membership status in IRMA, and will continue to work independently and will continue to use the IRMA Mine Measure self-assessment tool to prepare for independent audit to improve practices that reduce environmental and social impacts. We believe that the findings from this informal exercise will make a useful guide on how we can improve towards IRMA standards, while we are held on pause.

Batani Statement

Batani (International Indigenous Fund for development and solidarity) is a non-governmental organization and an IRMA Member. They have shared with IRMA the following statement:

Batani stands in solidarity with the people of Ukraine in their struggle for freedom, and we are extremely concerned about ensuring the rights of Indigenous peoples during the war on Ukrainian territory. This war has also created security issues for indigenous peoples living in Russia. As a result, Batani appreciates the steps IRMA has taken to pause the Nornickel audit until it can be done in a manner that ensures the safe engagement of communities affected by the Nornickel operations.

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