ICMI Cyanide Management Code Presentation

Transcription

1 ICMI Cyanide Management Code Presentation Presentation: A Technical Auditors perspective on lessons learned from the initial certification audits, recertification audits and pre operational design reviews

2 1. Initial Certification 1.1. Gap analyses observations and lessons 1.2. Pre audits observations and lessons 1.3. Certification Audits observations and lessons 2. Recertification 2.1. Health Check Audits - observations and lessons 2.2. Re-certification audits - Lessons Learned 3. Pre operational design reviews - Lessons Learned 4. Examples of issues experienced during audits 4.1. Principle 1: Production 4.2. Principle 2 Transport 4.3. Principle 3 Handling and Storage 4.4. Principle 4: Operations 4.5. Principle 5: Decommissioning 4.6. Principle 6: Worker Safety 4.7. Principle 7: Emergency Response 4.8. Principle 8: Training 4.9. Principle 9: Dialogue 5. Conclusions

3 Initial Certification Gap analyses observations and lessons * Planning gap audit - implementation plan costing resourcing execution * Understanding - the Code and training of cyanide champions and personnel * Site specific conditions - climatic, topography, infrastructure, communities, medical support, legal, environmental, political * Age and design of plants - Certification strategy, funding and resourcing * WAD cyanide management - principles to be well understood: WAD Cyanide, standards, compliance points, degradation, sampling procedures, sampling frequency, analytical procedures, data management and interpretation, costs, logistics. * Inspections - structured, including process and engineering * QA/QC and design records: old plants records, competent persons report in lieu of QA/QC records * Historical / Legacy issues need to be considered

4 Initial Certification Pre audits observations and lessons -Readiness check 6 to 10 months before the Certification Audit -Check understanding, interpretation and implementation of the Code before the certification audit -Staff turnover is causing gaps in the Code implementation process - Highlights potential deal breakers

5 Initial Certification Certification Audits observations and lessons Support from top management is critical in the process Quantify your gap and plan to be ready at the time of the audit Integrate with current existing systems to prevent expensive and time consuming duplication of systems, most current systems need upgrading to conform to the Cyanide Code Principles and Standards Management and management control systems are crucial to the successful implementation of the Cyanide Code. Continuous improvement best practice updating and implementation need to be part of the management policy to maintain and improve Code compliance * Cyanide optimisation importance is generally under-estimated * Document control and quality of documentation needs more attention

6 Recertification Health Check Audits - observations and lessons * A mid term short health check audit is useful to identify fatal flaws in terms of Code implementation: Check that implementation of systems, procedures, inspections, and processes has followed on from the commitments and evidence given at the ICMI certification audit. * Personnel turnover, communication breakdown, other issues requiring urgent attention result in continuity issues with systems, document control, inspections, record keeping, continuous improvement.

7 Recertification Re-certification audits - Lessons Learned * Personnel 4. Cyanide turnover risk assessment model * Drop the ball other more pressing issues * Paper exercises vs. best practice implementation * Environmental risks and consequences underestimated * Ore changes requiring different process parameters and controls and resulting in increased tailings cyanide species contents * Proactive management is important, especially the use of change management, management control and information systems, risk analyses, ore characterisation, procedure reviews * Emergency drills to test the emergency response plans and procedures

8 Pre operational design reviews - Lessons Learned Cyanide management Code Principles and conceptual design is not always well understood by clients, designers and project managers A Cyanide Management Plan to guide the project development process in terms of the ICMI Cyanide Code is a useful tool Review of process concepts, HAZOPS, Test work, appropriate mechanical and civil designs, Control philosophy for Code compliance Do it right from the beginning - prevent costly corrective action later on Consider site specific conditions and requirements in the whole design Fix the drawing vs. post construction and commissioning re-engineering Design teams exposure to Code Principles is important Cost savings short and long term

9 Examples of issues experienced during audits Principle 1: Production Main issues: Contract detail - not reading the Code Unplanned interruptions of supply Other Distributors

10 Principle 2 Transport Main issues: Contract not detailing responsibilities Changing transporters Route Risk assessment close and on Mine property

11 Principle 3 Handling and Storage Main Issues: Design and materials of construction corrosion Drawings sign off Professional Persons report for older plants Condition of bunds and design of tank foundations drawings Security Empty container management

12 Main issues: Principle 4: Operations Procedures and their reviews Cyanide optimisation Probabilistic Water Balance WAD cyanide management WAD sampling and analytical methods Tank foundations and secondary containment Structural professional Engineers reports

13 Main issues: Principle 5: Decommissioning Understanding of the difference between decommissioning, decontamination and demolition in the Mine closure plans Cost estimate process for line items

14 Main issues: Principle 6: Worker Safety Understanding the cyanide risks to humans and how to manage risks Cyanide antidote kit replacement and locations Emergency drills Change management

15 Principle 7: Emergency Response Main issues: Complexity and user friendliness of emergency plans Training of ERP Emergency drills Communication with stakeholders Local response agencies ability to assist Emergency environmental response and monitoring

16 Main issues: Principle 8: Training Differences between cyanide awareness, task and emergency training Proving competence: evaluate the effectiveness of cyanide training

17 Main issues: Principle 9: Dialogue Identification of zone of influence and stakeholder lists Uncertainty of community response to cyanide information Make appropriate operational and environmental information regarding Cyanide available to stakeholders differences in various countries

18 5. Conclusions Noticed a definite improvement in cyanide management and condition of plants over the last 7 years ICMI Cyanide Code Principles are universal and covers Mine systems as well Better understanding of cyanide is clear Staff turnover and continuity affects Code Management Human exposure risks are better managed Environmental release risks may need more attention Security issues increasing

19 5. Conclusions Ongoing support from top management essential Normal, Abnormal and emergency scenarios Change Management not rigorously used Don t drop the ball! between certification audits Cyanide Code Management is a Corporate Multidisciplinary responsibility

20 Questions