Tailings risk management – an integrated approach

Broad awareness of catastrophic tailings disasters means it is no longer acceptable for miners to only improve risk management after disaster has struck.

In the case of tailings and liquid containment risk management, there have been 2 main interconnected drivers for risk improvement in recent times:

- Global dam disasters, such as Samarco, Brumadinho and more recently, Andavilque
- The Global Industry Standard on Tailings Management (GISTM), against which all members of the International Council on Mining and Minerals must prove conformance by August 2025. (Non-members should also consider the standard leading practice.)

The ERM International team is highly experienced in tailings risk management. We have been on the ground in the aftermath of major catastrophes as a core part of investigation and remediation teams.

We have also helped executive teams and boards understand the internal and external causes of tailings storage facility (TSF) failures, and their organisation’s risk, emergency and crisis management maturity.

GISTM raises a conformance requirement, but it also presents an opportunity to drive leading practice.

At ERM International, we are working with our clients to leverage their GISTM efforts for sustainable, practical and longer lasting improvement. Here’s how.

An integrated framework across the asset lifecycle

ERM International has developed an 8-element framework that we apply across 6 stages of the mining lifecycle.

This approach ensures we help our clients to continuously address tailings risk through both a site and corporate lens, optimising risk management effectiveness from mine or asset planning through to post-closure requirements.

Holistic support across 6 stages of the mining lifecycle

Each of the 6 mining lifecycle stages has distinct tailings risk requirements. These span both technical and strategic considerations:

Planning: alignment of strategic decisions around dam location and construction with a company’s risk appetite and ESG objectives. We do this via a comprehensive technical and non-technical risk assessment process to ensure resilience.
Design and construct: understanding credible failure modes by applying multidisciplinary risk techniques. We do to inform the design of specific controls for effective TSF risk management from inception, and establish robust risk governance, assurance and emergency management.
Operate and improve: developing and implementing the right critical controls that address credible failure modes. We then undertake regular, independent validation of critical controls and governance system robustness to meet GISTM conformance expectations through robust risk reviews.
Care and maintenance: managing ongoing risk exposure as production slows or ceases. We do this using fit-for-purpose controls, regular assurance and effective governance proportionate to the residual threat. We also ensure sufficient and capable resources are still available.
Rehab/closure: executing the TSF closure strategy that achieves ALARP across financial, safety, environment, community and reputational consequence categories. We do this by following risk-based criteria established in earlier phases to guide required work. For residual threats, we facilitate disciplined risk analysis and some controls to continue in perpetuity.
Post closure: transitioning to safely closed with an evidence-based conclusion that is validated with a robust risk review, alongside ongoing monitoring, maintenance and a level of emergency readiness. We may continue periodic reviews and assurance to verify the TSF’s safe closure.

A comprehensive framework across 8 elements of risk management

Informed by years of real life, on-the-ground experience, our tailings risk management framework helps clients understand their TSF risks at both a corporate and site level, and everything in between. We apply our framework at each stage of the TSF lifecycle.

As you can see in our diagram, our comprehensive approach integrates the 6 key elements of the ICMM Tailings Governance Framework, enabling GISTM conformance. However, our clients can also go beyond conformance to implement leading-practice tailings risk management.

Our overarching premise is that companies must understand their TSF risks at both a corporate and a site level. Critical gaps at one asset can leave a company vulnerable across their entire global portfolio.

That’s why our framework weaves together facility-specific risk knowledge and technical assessments to create a portfolio-level risk understanding. We overlay corporate governance; control standards; organisational capability; and risk-based assurance, monitoring and reporting to deliver effective tailings risk management.

A solution across single facilities and an entire portfolio

We offer clients a multi-stage GISTM conformance solution at single facilities and across an entire portfolio.

Our single facility approach:

Identifies initial gaps or non-conformances
Addresses more complex non-conformances
Implements repeatable, streamlined approaches for future validations.

Meanwhile, our portfolio-wide assessments are prioritised and scheduled to enable budget and workload planning, over a year and across years.

A unique tailings risk team

Combining expertise, pragmatism and independence, ERM International promotes tailings risk management effectiveness beyond compliance. We believe we are uniquely positioned to support clients across all 3 pillars.

Traditional audit firms offer independence but may lack tailings capability. Traditional engineering firms have the expertise, but perhaps not the independence. Very few providers would have the depth and breadth of our real-world experience to offer pragmatic solutions that deliver effectiveness beyond compliance.