Article 29 should specify a certification scheme is not a replacement for a company’s responsibility or for government oversight
Additional criteria for certification schemes in Annex IV including they be equally governed multi-stakeholder initiatives, provide access to a grievance mechanism and require publicly noticed third-party audits that are published in their entirety
The Initiative for Responsible Mining Assurance (IRMA) is pleased to announce that the French miner Eramet has committed to a third-party independent assessment of its Grande Côte Opérations (GCO) site against the IRMA Standard for Responsible Mining. GCO is a Senegalese subsidiary of the Eramet Group that specializes in the recovery of ilmenite, leucoxene, rutile, and zircon. The mine and its two processing plants have been in service since 2014.
In making its own announcement, Eramet declared “After this first external audit in Senegal, Eramet aims to engage all its mining sites in this independent verification process by 2027.”
SCS Global Services, an IRMA-approved certification body, will be carrying out the assessment, which includes a desk review (stage 1) followed by an onsite audit (stage 2). After SCS’s draft audit report is reviewed by IRMA and GCO, GCO may release the report or has the option to take up to twelve months to implement a Corrective Action Plan before the audit firm assigns a Performance Level.
Stakeholder Engagement in the Assessment
Interested stakeholders and members of the public can sign up to receive updates about the GCO independent assessment (e.g., the timing of the stage 2 onsite visit, link to public summary of audit results). 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 Global Services regarding the social and environmental performance of the GCO mine (in particular, how the performance of the mine site measures against the IRMA Standard for Responsible Mining).
Stakeholders of the GCO mine may also contact SCS Global Services if they are interested in being interviewed as part of the assessment process.
Stakeholder comments and expressions of interest in being interviewed as part of the audit process can also be submitted by email or mail to:
SCS Global Services
2000 Powell St. #600 Emeryville, California, USA 94608
feedback@scsglobalservices.com
Please share this announcement, and feel free to contact SCS Global directly to provide names and contact information for other GCO stakeholders who may be interested in knowing about and participating in the mine site assessment process.
For more information
On the GCO Mine Site Assessment, contact IRMA’s Director of Assurance: msmith@responsiblemining.net
For general information on the IRMA mine site assessment and certification process, visit the IRMA website.
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!
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.
On September 11 in South Africa about 500km southwest of Johannesburg, the tailings dam failed at the Jagersfontein mine waste impoundment. Three people were killed, four more are still missing, and 40 were hospitalized.
This is a tragedy, and all the more so because it was predictable.
IRMA Board member Meshack Mbangula of Mining Affected Communities United in Action and other MACUA leaders are currently in the region, gathering the perspectives of communities. Meshack shares that some are still without water, electricity, sewage management, and with road blockages limiting children’s access to school.
From the world’s repeated recent experience with mine waste disasters, we know that poor tailings facility designs, aging facilities, and increasing frequency of extreme weather associated with climate change will combine to cause more mine waste tragedies around the world for communities living near mining operations.
We can act to minimize that threat. We join with others asking three questions:
How can we prevent the construction of new mining waste facilities with this type of risk to fail?
How can we provide sufficient funds for communities and governments to protect public safety from these mine waste risks even when mine ownership changes?
The unbelievably difficult question of how to put protection of human life first at the thousands of places around the world where these dams already exist?
Meshack Mbangula of Mining Affected Communities United in Action and IRMA board member, witnessing the Jagersfontein tailings spill aftermath. Credit: MACUA
The disaster, and reports of years of community effort to raise concern and attention to the risks, shows the importance of ongoing community involvement in addressing a mine’s impacts – for as long as the mine’s impacts exist.
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.
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.
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:
Recognize the importance of equal governance in multi-stakeholder leadership, engagement, and public access to information.
Adopt a holistic lens to mining sector management, including a wide range of environmental and social factors.
Use the IRMA Standard for Responsible Mining to assess gaps in domestic legal frameworks, and incorporate best practices on international to local levels.
Promote an inclusive, participatory, transparent rights-based approach to relationships between mines and communities, with access to remedy.
Use IRMA standards and audit reports to guide more responsible sourcing of mined materials.
Encourage mines to engage in IRMA, which connects market value with environmental and social responsibility, and encourages continuing improvement while striving toward best practice.
Identify and act on opportunities for the U.S. to be a “first mover” on responsible sourcing of mined materials, due diligence, and circularity.
Foster innovation, strategic planning, and meaningful engagement of workers, communities, NGOs, companies, and investors in the “green” transition
Collaborate with other governments to enhance environmental and social performance and transparency of the mining sector and supply chains.
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.
