Int. J. Miner. Process. 64 Ž2002.

19–41
www.elsevier.comrlocaterijminpro

Environmental management system implementation

in the mining industry: a key to achieving
cleaner production
Gavin Hilson a,) , Vishal Nayee b
a
EnÕironmental Policy and Management Group (EPMG), Imperial College Centre for EnÕironmental
Technology, Royal School of Mines, Prince Consort Road, London SW7 2BP, UK
b
Freudenberg Management Consultants Inc., 4057 Jefton Crescent, Mississauga, Ontario, Canada L5L 1Z2

Received 20 September 2000; received in revised form 5 July 2001; accepted 5 July 2001

Abstract

This article examines the business practicality of integrating an environmental management

system ŽEMS. into mining and related operations, describes how it can contribute to cleaner
production ŽCP. in the industry, and provides guidelines to facilitate implementation. An EMS,
which is the component of the overall management system that includes organizational proce-
dures, environmental responsibilities, and processes, can help a mining company comply with
environmental regulations, identify technical and economic benefits, and ensure that corporate
environmental policies are adopted and followed. To date, a number of multinational Žmining.
corporations—namely, the companies with economical and technological flexibility—have imple-
mented comprehensive EMSs at sites, the key in such cases being the formation of working
partnerships with administrative bodies and international organizations. A number of other mine
sites worldwide, however, despite having important environmental management practices such as
audits and policies in place, have received insufficient assistance andror simply lack the requisite
resources to integrate an effective EMS into operations. The article sketches a series of guidelines
for mining companies keen on adopting comprehensive EMSs at sites, and argues that to facilitate
widespread EMS implementation throughout the industry, expanded inputs are needed from
governments, international environmental organizations, educational facilities, and the companies
themselves. More specifically, regional governments must provide assistance to the more re-
source-deficient operations, local universities must provide the necessary EMS educational
assistance to local miners and finance environmental technology demonstration projects, and

)
Corresponding author.
E-mail address: g.hilson@ic.ac.uk ŽG. Hilson..

0301-7516r02r$ - see front matter q 2002 Elsevier Science B.V. All rights reserved.
PII: S 0 3 0 1 - 7 5 1 6 Ž 0 1 . 0 0 0 7 1 - 0
20 G. Hilson, V. Nayeer Int. J. Miner. Process. 64 (2002) 19–41

international organizations must help disseminate valuable EMS information to mine managers
and technical staff. q 2002 Elsevier Science B.V. All rights reserved.

Keywords: environment; efficiency; environmental monitoring

1. Introduction

There is a burgeoning literature that examines in detail the business practicality of

integrating an environmental management system ŽEMS. into industrial operations. In
short, an EMS, which is the component of the overall management system that includes
organizational procedures, environmental responsibilities, and processes, helps an indus-
try comply with environmental regulations, identify technical and economic benefits,
and ensure that environmental policies are adopted and followed ŽBarrow, 1999.. Unlike
the conventional stand-alone environmental auditing and review processes, which tend
only to assess the environmental situation of an enterprise at the time at which they are
carried out, an EMS ensures that an organization’s environmental targets and objectives
are being effectively pursued. In fact, an EMS links audits, reviews, and other important
environmental management processes through a network of management actions, proce-
dures, documentations, and records, and is designed with the purpose of promoting
continuous environmental improvement.
In the case of mining and allied operations, which are typically confronted with
serious environmental complications and face the challenge of having to satisfy a
diverse group of stakeholder demands, the implementation of an EMS is a necessary
step toward achieving industrial cleaner production ŽCP.. Several mines worldwide Žsee,
e.g. WMC, 2001; Homestake Mining, 2001; Delta Gold, 2001. already have a compre-
hensive EMS in place, and in many cases, management credits it as being a principal
factor behind industrial environmental improvements Žsee, e.g. Cambior, 2000; Noranda,
2001.. Further, it has helped to put many of these operations in a better position to
anticipate problems with waste and avoid costly environmental cleanup. Some mining
companies Žsee, e.g. Falconbridge, 2000; Rio Tinto, 2001. have even gone one step
further by obtaining international EMS certification—in most cases, that of the Interna-
tional Standards Organization ŽISO., ISO 14001—at selected properties, which requires
that specific procedures be in place for environmental monitoring, assessment and
measurement purposes.
The majority of mines that have implemented a comprehensive EMS, certified or
uncertified, are owned wholly or partly by multinational corporations, which have the
financial and technological flexibility to ascertain its precise application and potential
business benefits, and have the means to readily integrate it into industrial operations.
What tends to be overlooked, however, is the fact that a number of other mining
properties already have in place important system elements and management procedures
that would allow for the convenient incorporation of environmental issues and eventual
implementation of an EMS. For example, many sites have an environmental officer that
is responsible for ensuring compliance with set environmental regulations. In addition, at
a number of mines, environmental audits, impact appraisals and reviews are conducted
periodically to assess environmental performance. Multinational mining companies have
 G. Hilson, V. Nayeer Int. J. Miner. Process. 64 (2002) 19–41 21

already taken these and other existing environmental elements, along with newly
developed environmental strategies, and have designed and implemented comprehensive
EMSs at properties around the globe. The remaining companies, due to a shortage of
financial, technological, and informational resources, have not, and therefore require
assistance for effective EMS design and integration. An increased input from govern-
mental groups, educational facilities, and international organizations, however, could
help management of these properties design comprehensive EMSs, and hence contribute
to prolonged CP in what has long been perceived as one of the world’s most polluting
industries.
The purpose of this paper is to examine in detail the applications and potential
benefits of a mining EMS, and to provide guidance to facilitate its implementation. The
paper begins by providing a general overview of the utility of EMSs in industry. Next,
the paper discusses the business practicality of integrating an EMS into mining and
related industrial operations, and outlines guidelines for implementation. A discussion is
then presented that profiles some of the steps taken by the Canadian and Australian
governments to facilitate improved environmental management in their mining indus-
tries, along with some of the recent efforts made by individual Canadian and Australian
companies to implement EMSs at mines. The paper concludes by prescribing some
recommendations that could improve the overall quality of existing mining EMSs, and
which would further assist other mine properties in implementing practical EMS
designs.

2. Utility of an environmental management system (EMS)

An environmental management system ŽEMS. is a set of organizational procedures,

responsibilities, processes, and necessary means to implement corporate environmental
policies ŽBegley, 1996., and is a component of management that features organizational
structure, planning activities, practices and resources for development ŽFresner, 1998..
Taken simply, an EMS is an industrial tool that enables an organization to systematically
control its level of environmental performance, and which helps management identify
potential environmental impacts arising from activities, set appropriate environmental
objectives, establish programs to achieve corporate environmental goals, and review
activities to ensure that corporate environmental policy objectives are being properly
carried out ŽBergeron, 1997.. In recent years, international EMS standards—most
notably those of the International Standards Organization ŽISO 14001. —have emerged
that serve as guidance for companies seeking to implement an EMS; a wide range of
environmentally progressive industries have since implemented certified EMSs. How-
ever, as is explained in this section of the paper, an EMS does not necessarily have to be
certified to be effective, but must feature the necessary environmental management tools
for CP and address polluting areas of operation.

2.1. EnÕironmental management systems (EMSs) and cleaner production (CP)

It is important to first clarify that a de facto definition of cleaner production ŽCP.

does not exist simply because it does not involve the incorporation of a clear-cut set of
22 G. Hilson, V. Nayeer Int. J. Miner. Process. 64 (2002) 19–41

generic technologies, and that its technical components may be sector- or even firm-
specific ŽChristie et al., 1995.. One of the earliest and perhaps most referenced definition
is that of the United Nations Environmental Program ŽUNEP., which defines CP as Athe
continuous application of an integrated preventive environmental strategyB that requires
Achanging attitudes, responsible environmental management and evaluating technology
optionsB ŽUNEP, 2001.. A number of other general definitions have long since emerged
Že.g. Huisingh and Baas, 1991; Jackson, 1994; Wang, 1999., as well as Žindustrial.
context-specific interpretations Že.g. Vanselaar, 1995; Getzner, 1999; Van Berkel, 1999.
that tend to address certain technology andror training components. Because of the
industrial specificity of this paper, no definition found in the literature can be adopted;
therefore, for the purposes of the discussion that follows, CP is defined as a superior
level of environmental performance, which can only be achieved through improved
strategy and housekeeping, sound process control, optimized plant layout, and the
implementation of efficient management techniques.
Attaining CP requires adopting an improved managerial strategy—namely a Alateral
thinking approachB ŽChristie et al., 1995. —and implementing processes and products
that are designed from their inception to minimize risks to the environment and human
health.
It is argued in this paper that implementation of a well-crafted EMS is a key to
achieving CP because it features elements that facilitate environmental improvements,
and helps to coordinate the individual industrial technological and managerial processes
capable of contributing to improved Ženvironmental. performance. Whether within the
framework of a specific standard or scheme, or as an independent initiative within a
specific organization, the EMS is a major influence on business thinking and attitudes to
the management of environmental matters ŽHunt and Johnson, 1995., and in promoting
further environmental improvements in a wide range of industrial areas Žsee Fig. 1..
Further, it can stimulate a gradual shift from conventional, often ineffective, end-of-pipe
pollution control approaches toward cleaner technologies and improved process, and
product designs that utilize resources more efficiently ŽBergeron, 1997..
Integrating important system elements into an organized setup improves the environ-
mental efficiency of operations, which in turn leads to CP ŽHillary, 1997.. For example,
to monitor environmental performance, the EMS standards mandate that audits and
reviews be completed on a regular basis. The results obtained play a pivotal role in the
management system as they provide the organization with a track record of environmen-
tal performance. As junior management and staff acknowledge deficiencies within the
company, they are communicated to senior management and then remedied. Perhaps
more significant than each individual system element, however, is the fact that effective
design and implementation of an EMS involves the participation and cooperation of
each staff member. It is therefore critical for management to communicate and motivate
each employee, and identify his or her function in the EMS.

2.2. International EMS certification

The management of a number of companies worldwide has gone one step further to
obtain international certification for EMSs. The most common and widely recognized
 G. Hilson, V. Nayeer Int. J. Miner. Process. 64 (2002) 19–41 23

Fig. 1. Environmental management systems and CP Žmodified from Russ, 1997..

EMS certification is ISO 14001, which is awarded by ISO-accredited certification

bodies. The main advantage of the standard is that it is homogenous internationally, and
that globally, individuals are familiar with its process of certification, along with the
AqualitiesB of an ISO 14001 certified company; a certified EMS is one that would pass
certification standards measured by an independent body. Simply put, an ISO 14001
certified mining company in North America would have a similar EMS to that of a
mining company in South Africa. Certification can be expensive, however, and the
requirements for conformity can be beyond the budgetary means of a small company. In
fact, given the costs of registration, combined with the costs of consultancy expertise, it
is unrealistic to assume that any small operation—in this case, a mine—would be able
to certify its EMS without outside assistance.
24 G. Hilson, V. Nayeer Int. J. Miner. Process. 64 (2002) 19–41

It is important to clarify that an EMS need not be certified to be effective, and that
many mining companies worldwide have opted only to use the ISO standards as general
guidelines for developing EMSs at sites. In short, a company does not require certifica-
tion to have an effective EMS in place, but that management should follow ISO 14001
when designing and implementing EMSs because it targets the prevention of negative
environmental impacts, emphasizes environmentally friendly product design, encourages
solid documentation, and is overall, a proactive preventative strategy that mandates
companies to set objectives and targets, and to incorporate strategies for continual
environmental improvements ŽHammer, 1997.. However, ISO certification does not
enable an outside party to determine if one organization is more Aeco-friendlyB than
another. More to the point, a certified EMS does not guarantee improvement: ISO 14001
is merely a framework, and an organization must have the pertinent elements in place to
ensure that it effectively functions.
As already noted, occasionally, a company may be unable to invest the capital needed
for ISO 14001 certification, in which case it commonly follows the ISO principles when
developing and implementing an EMS. An issue more specific to mining, however, is
the fact that a number of companies have elected not to adopt an ISO 14001 certified
EMS because it has limited utility in marketing and regulatory compliance strategy. The
ISO standards are increasingly proving to be an integral marketing tool in the manufac-
turing sector because of escalated demands for green consumerism. In fact, it could be
effectively argued that nowadays, the backbone of green consumerism is an ISO
certified EMS. The management of a mining company, on the other hand, is largely
unconcerned with ISO certification of sites because it does not provide anywhere near
the Acompetitive edgeB it gives to companies operating within the secondary and tertiary
industrial sectors. However, as is explained in the next section of this paper, in order to
be effective, a mining EMS must feature several key elements, and companies must
follow specific guidelines for proper implementation.

3. Components of a mining EMS and benefits to implementation

Mining and allied industries are confronted with the challenge of having to control a
wide range of potentially serious environmental problems such as acid mine drainage
ŽAMD., chronic soil erosion, tailings contamination, and heavy metals overloading.
Many mines face additional complications in the form of toxic chemical additives such
as mercury, cyanide, and surfactants, which are often used in mineral concentration
processes. Given the need to perform accordingly in regulatory environments, combined
with a need to satisfy the demands of community and external stakeholder groups, it is
in the best interest of mining operations to ensure that environmental impacts are
minimized. To systematically address the environmental effects of operations, a number
of mining companies have implemented EMSs, many of which predate the publication
of notable international EMS guidelines ŽRichards, 1996.. The discussion that follows
outlines the necessary features of a mining EMS, its benefits, and the steps that must be
followed for effective implementation.
 G. Hilson, V. Nayeer Int. J. Miner. Process. 64 (2002) 19–41 25

3.1. Requisite features of a mining EMS

The key to implementing a successful mining EMS is a full commitment by

management. As explained by the EPA Ž1995., top, middle, and junior management
must make this commitment, and it must be evident to the workforce. The mining EMS
alone can only potentially add another dimension, as its effectiveness as a tool for CP is
contingent upon employee awareness and the actions taken to minimize environmental
and social impacts. To successfully integrate a mining EMS into operations, manage-
ment must address the following:
Ž1. Identify appropriate procedures, reports and meetings—essentially, the skeletal
framework of the EMS. Tasks must be assigned upfront to various individuals and
groups and each process in the system must be identified.
Ž2. Provide employees and management with immediate EMS training—implement-
ing an EMS requires input from workers at all levels of operation. Each must be
educated and trained on important environmental management system procedures such
as auditing and reporting.
Ž3. Familiarize employees with the system—it is important to explain to employees
why the EMS has been adopted, and what the merits to implementation are. A thorough
understanding of its applications and benefits are keys to encouraging employees to use
the system.
Ž4. Ensure that EMS-related problems are remedied quickly—all systems experience
problems at one point or another. Contingency plans must therefore be drafted in the
event of an EMS AmalfunctionB. It is essential that management identifies priority
problems, and provides a listing of remedial strategies to those problems.
Ž5. Ensuring that people have sufficient time and resources to implement the
EMS—the key is to keep the mining EMS simple and brief, specifically something that
can be maintained with relative ease. Basic education is essential because employees
will be green, and must therefore be trained incrementally; the EMS can become more
complex in time with further training.
A mining EMS can cover all aspects of operations, from exploration to closure.
Unfortunately, international standards, which are designed generically and, hence, only
provide general guidance, lend little in the way of methods to implement a practical
industry-specific EMS—in this case, for mining. It is suggested here, however, that an
effective mining EMS features the following key components Žadapted from Industry
and Environment, 1997.: an organizational commitment to mining environmental man-
agement; a corporate mining environmental policy that addresses the environmental
goals of the mine; environmental impact assessment procedures for tailings manage-
ment, reclamation and chemical usage; strategies for community mine consultation and
involvement on important environmental issues; objectives and targets Žcorporate perfor-
mance indicators. for each environmental problem Žacid mine drainage, metals, chemical
effluents, etc..; procedures for documentation, and records of remediation and mitigation
efforts; policies for operational and emergency procedures at the mine; environmental
training, including topical contents and procedures; procedures for environmental im-
pact, regulatory and legal compliance, and environmental review audits; and methods for
emission and performance monitoring and measurement. Regular reviews of the EMS
26 G. Hilson, V. Nayeer Int. J. Miner. Process. 64 (2002) 19–41

must also be conducted to ensure that each element is designed for continuous
environmental improvement, and to determine if modifications are required. Internally, a
review group should be formed—consisting of people responsible for environmental
management and stakeholder relations—that should periodically assess the applicability
of EMS procedures, the adequacy of reporting systems, and the fittingness of delegated
responsibilities. Additionally, an external expert should be hired to regularly audit the
EMS, which, more often than not, leads to more effective solutions and the identification
of potential problems that were overlooked initially because of familiarity ŽEPA, 1995..
Table 1 outlines more clearly how each mining EMS component contributes to CP.
A number of mining companies, particularly those headquartered in developed
countries, have implemented EMSs at sites around the world. Although adherence to
international standards, generally, has helped the industry develop practical EMS
designs, a number of these companies appear to have designed and implemented
comprehensive EMSs that foster CP with minimal aid from guidelines such as ISO
14000. In each case, management has followed an environmental action plan that
features a number of tasks, including Žadapted from Wilkinson, 1997.: establishing
realistic response time frames and committing to timely action at every stage of any
mining decision-making process; establishing a mine permitting process for pollutants;
ensuring that environmental decisions are based upon best available practices Žusing
guidance from mining associations and governments.; allowing qualified and experi-
enced mining professionals to make reasoned judgments about environmental manage-
ment practices, technologies and auditing procedures; providing technical training and
professional mentors for administrators; establishing sustained environmental quality
and quality of life as key evaluation criteria for mining environmental decisions; and
committing to making decisions that meet established environmental and socioeconomic
goals while resolving public issues. Once each of these key issues has been properly
addressed, mine management must design the EMS to feature most or all of the
components outlined in Table 1.

3.2. Benefits to implementing a mining EMS

Given the wide range of environmental complications that can result from mining and
related processes, successful integration of comprehensive EMSs into operations could
serve to significantly benefit this industrial sector by better enabling companies to
address environmental concerns through proper allocation of resources, assignment of
responsibilities, and ongoing evaluation of practices, procedures and processes. Al-
though a number of authors have outlined the specific advantages to implementing an
EMS, for mines, there are three basic benefits Žadopted from Schiffman et al., 1997..
First, with an EMS, mine personnel are better able to systematically examine all
industrial processes and activities for their potential impacts on the environment, identify
legal requirements, and to evaluate alternatives and hidden costs. When a company
introduces an EMS, it establishes a corporate environmental policy that reflects the
commitment of top management to comply with applicable laws and to continuous
environmental improvement ŽBegley, 1996.. Its specificity requires management to
 G. Hilson, V. Nayeer Int. J. Miner. Process. 64 (2002) 19–41 27

Table 1
Requisite components of a mining EMS and potential roleŽs. in CP
Mining EMS component ContributionŽs. to CP
Organizational commitment v The most significant feature of a mining EMS,

without which the EMS’s potential benefits may

not be fully realized.
v Serves to provide direction for all levels of operation.

Environmental policy v Serves to inform the community and its employees about

the company’s intentions with respect

to the environment.
Environmental impact assessment v Delineates strategies to minimize and control adverse

environmental effects.
v Determines the initial objectives, targets and

procedures that the min must achieve or implement.

Community consultation v Creates trust and confidence with relevant

stakeholder groups.
v May lead to decrease in public criticisms and

adverse publicity.
Objectives and targets v Aiming for best practice or CP requires establishing

precise targets and objectives, which facilitate

environmental improvement.
Environmental management plan v Details the methods the mine will use to achieve

the stated environmental targets and objectives.

Documentation v Serves as a reference for both management and staff.

Operational and emergency procedures v Integral planning strategies that outline what must

be done in the event of an environmental accident.

v Assists in worker training, and allows individual

workers experiences to be shared with personnel.

Responsibilities and reporting structure v Ensures that practices are carried out in a

timely fashion.
Training v Enhances environmental awareness.

v Informs staff of CP goals.

v Provides the workforce with the skills and

motivation to implement an EMS.

Environmental impact, compliance and v Serve to identify existing and potential problems.

review audits v Assess the impacts of waste discharges on the

environment and community.

v Determine the quality of environmental objectives,

and hence the desired outcomes of the EMS.

Emission and performance monitoring v Regular reviews of the company’s environmental

performance ensures that procedures are appropriate,

due diligence requirements are satisfied, and
ensures that environmental goals are being attained.

outline all applicable legislative requirements and ensure that the company is continually
up-to-date on all legal amendments—requirements that force senior management to be
aware of the most pertinent legislation.
Once mine management has recognized the legislative requirements, the EMS can
then be used as guidance in developing targets and goals to ensure that those legal
28 G. Hilson, V. Nayeer Int. J. Miner. Process. 64 (2002) 19–41

requirements are continually being met. For example, if the mine is subject to a specific
water chemical discharge limit, the EMS would first help to identify the legal require-
ment, and management would then develop goals, targets and action plans to ensure
compliance. In short, the EMS provides staff with a better understanding of environmen-
tal impacts, a thorough knowledge of the pertinent legislature, and a proactive action
plan to ensure that the required targets are met.
The second major benefit is that a mining EMS makes practical business sense, and
despite potentially being costly in the beginning, usually pays for itself over the long
term through reduced operating costs and improved efficiency 1. Thanks in large part to a
burgeoning literature ŽCrognale, 1997; Cochin, 1998; Voien, 1998; Bhat, 1999., the
relationship between environmental management AtoolsB —namely audits, permitting
systems, reviews, life-cycle assessments and environmental impact statements—and
reduced corporate costs is now well known. For example, environmental audits, which
are viewed as crucial elements in coordinated ongoing environmental protection pro-
grams, help to safeguard the environment, and increase employee awareness of environ-
mental policies and responsibilities ŽBhat, 1993., keys to preventing costly environmen-
tal accidents. Similarly, life-cycle assessments, which are simply analytical tools that
evaluate the environmental consequences of a product, process, or activity across its
entire life cycle, are increasingly being used by industry for the purpose of obtaining
comprehensive perspectives of the interactions between an activity and the environment,
and providing a method to systematically identify opportunities for improvement and
reducing capital costs ŽGloria et al., 1995.. In short, by integrating these and related
AtoolsB into its EMS, a mining operation puts itself in a better position to anticipate
problems with waste, avoid unnecessary cleanup costs and regulatory fines, reduce its
discharges of toxic effluent, avoid tailings pond spills and leaks, and minimize usage of
raw materials.
The third major benefit is that implementation of a mining EMS enables an operation
to plan for environmental issues and shift from a AreactiveB environmental mode, where
it continuously responds to regulatory AfiresB, to a AproactiveB mode. For mines, such a
shift can play a pivotal role in improving relations with regulatory bodies, community
groups, and other external stakeholder parties, which often demand a strong corporate
commitment to environmental issues. Interestingly, there is evidence that courts, regula-
tory agencies, enforcement groups, municipalities, lending institutions, and financial
groups view activity that responds to EMS conformance requirements as an indication of
diligence ŽPlaut, 1998.. Quite simply, if a mining company demonstrates that it is aware
of its legislative requirements, and if it has goals, targets, and action plans in place to
commit to compliance, there is less chance for infraction. Perhaps more significantly,
however, is that such can improve relations with community groups, a major challenge
for any operating mine. As Rondinelli and Berry Ž2000. explain, by implementing an
EMS, a company has a greater chance of achieving positive relations with stakeholder

1
As was alluded to earlier, a mining company lacking the requisite resources would be unable to implement
the EMS without outside assistance but with financial support, could reap major economic rewards over the
long term as a result of improved environmental performance that could offset these initial expenses.
 G. Hilson, V. Nayeer Int. J. Miner. Process. 64 (2002) 19–41 29

groups, which are more likely to assume that it has proactively ensured that it has
reduced environmental exposure, that it is in compliance with governmental legislation,
and that it has taken the necessary steps to ensure that it has minimized its overall risk to
the environment. Building a strong reputation for corporate citizenship through EMS
implementation can benefit the mining company by granting it greater access to capital,
reducing its operating costs, improving its financial performance, and enhancing its
brand image.

3.3. Guidelines to implementing a comprehensiÕe mining EMS

Few mines will start from zero when crafting their EMS, and once the core elements
and important subsidiary components are in place, a four-step framework must be
followed for effective implementation Žadopted from Kryger and Dyndgaard, 2000..
After important corporate environmental policies are drafted that outline the environ-
mental objectives of the mine, and environmental reviews are conducted to determine
initial environmental performance, management must first begin a critical planning
stage. Here, based upon conclusions drawn from audits, all relevant environmental
aspects must be identified along with the existing environmental strengths and weak-
nesses of the mine, and plans must be devised to outline how the mine intends to
respond to current and anticipated environmental issues from both a technological and
administrative perspective. Further, at this stage, the environmental responsibilities of all
levels of the workforce must be assigned, and external stakeholder parties and govern-
mental groups must be informed of corporate goals and strategies. The mine must then
proceed to determine and develop necessary procedures, and commit whatever resources
are needed to implement the corporate environmental strategy.
The second step is the EMS action plan and is principally a task for top management.
It involves assessing corporate environmental objectives, analyzing environmental poli-
cies, assigning final responsibilities, and determining EMS implementation actions. As
Hale Ž1995. explains, many enterprises mistakenly begin implementation immediately
following an initial environmental diagnosis without critically reviewing objectives and
policies. Top management must therefore first refine pertinent environmental objectives
and actions, and should conduct multiple environmental reviews before implementing
the EMS. Further, it is practical for management to develop some kind of environmental
reporting scheme at this stage to keep stakeholder parties informed about the overall
structure of the EMS, its goals, and the responsibilities of selected personnel. From this
point onward, the onus is on the miners and mine operators to ensure that responsible
actions are carried out within the constraints of corporate commitments ŽNicholls, 1997..
The third step is eÕaluation, the primary purpose of which is to assess the mine’s
actual environmental performance against the stated environmental polices, objectives
and targets that comprise the EMS action plan. Once important procedures have been
implemented, mine management must continually assess the effectiveness of each. For
example, are these techniques, both individually and collectively, improving the environ-
mental efficiency of the mine and hence contributing to CP? Further, how can certain
procedures be improved? Evaluation can be accomplished using the rudimentary audit-
ing strategies, or by using more advanced monitoring and control tools. What must also
30 G. Hilson, V. Nayeer Int. J. Miner. Process. 64 (2002) 19–41

be developed at this stage is a practical mining EMS training program. A number of

authors Že.g. Aboulnag, 1998; Dodd, 1997. suggest that companies should implement an
EMS training plan concurrently with the EMS action plan. Given the potentially wide
range of training required for all levels of staff at a mine, however, mine management is
advised to implement the training program after the EMS is fully evaluated for
weaknesses, although there should be some idea of a framework for a practical mining

Fig. 2. Suggested guidelines to implementing a practical mining EMS.

 G. Hilson, V. Nayeer Int. J. Miner. Process. 64 (2002) 19–41 31

EMS training program from the outset. By providing only minimal training up until the
initial evaluation, significant time and money could be saved since critical environmen-
tal and operational issues are almost always overlooked from the beginning. At the
conclusion of important evaluations, the EMS training program should then be fully
implemented, and all outside environmental training expertise should be hired.
The fourth and final stage is correctiÕe action. As indicated earlier, the goal of an
EMS that fosters CP is continuous environmental improvement, which requires manage-
ment to ensure that the EMS continues to be responsive to changing circumstances such
as new scientific knowledge, changing national and international markets for products,
currency fluctuations, marked changes in the environmental regulatory arena, or changes
in stakeholder demands. A periodic environmental review will enable management to
ascertain what major adjustments need to be made to the mining EMS. The primary aim
at this point is to continue improving the mine’s environmental performance, whether it
means making adjustments to existing programs and policies, implementing more
environmentally sound technology, or introducing a new process entirely. As Kryger and
Dyndgaard Ž2000. explain, the AimprovementB can be as simple as exercising better
control of an existing procedure, developing a more improved technique, or a redefining
of environmental goals and objectives. Fig. 2 provides a concise overview of the four
important stages required for successful implementation of a mining EMS, and high-
lights the major activities of each.
In sum, these four steps—critical planning, development of an action plan, evalua-
tion, and corrective action—must be followed to implement a mining EMS.

4. Discussion: examples from Canada and Australia

The paper thus far has discussed the characteristics and benefits of a mining EMS.
Further, it has examined how it can contribute to CP in the industry, and has provided
guidelines to facilitate implementation. In this section of the paper, some examples are
provided that highlight how the actions of governments have helped to facilitate mining
EMS implementation. Some of the experiences selected multinational mining companies
have had in implementing EMSs at sites are also discussed.
It is important to first note that in a number of countries, governments have helped to
steer mining companies toward improved environmental management; more specifically,
they have laid important ŽEMS. groundwork for the industry. For example, in Canada,
the government has long worked with the Mining Association of Canada ŽMAC., the
national body of the Canadian mining industry, to provide guidance to Canadian mining
companies in the area of environmental management. MAC was the first national mining
association to develop an environmental policy, which was released in 1989 and updated
in 1995, and in 1996, produced an accompanying Environmental Management Frame-
work. Collectively, the policy and the Framework have provided much needed guidance
for implementing a mining EMS, and of the companies that have subscribed to both,
most have improved environmentally in a number of key areas including energy
efficiency, water management, technology utilization, pollution, community communica-
tion and research ŽMiller, 1997; MAC, 1998..
32 G. Hilson, V. Nayeer Int. J. Miner. Process. 64 (2002) 19–41

A study by Sanchez Ž1998. confirms that a number of Canadian mining companies in

the nonferrous sector have begun proactively implementing an EMS because of in-
creased governmental input, regulation and pressure. Another study undertaken by
Annandale Ž2000., in which the executives of 34 different Canadian mining companies
were interviewed, indicates that organizational learning, types of regulation, stakeholder
influence, jurisdictional culture, and corporate culture are primary reasons why many
ŽCanadian mining companies. have taken proactive stances toward environmental
regulations. For example, Noranda, an international mining and metals company with
operations and offices in 20 countries, following 12 years of comprehensive company-
wide auditing, completely redesigned its corporate safety and health auditing system. As
explained in its most recent annual environmental report ŽNoranda, 1999., the traditional
system, which was based on cyclical compliance-based audits undertaken every 3 years
by teams of Noranda auditors, was replaced with a new Environment, Safety and Health
Assurance Process that better integrates auditing with each operation’s environment,
safety and health ŽESH. management framework. Based upon ISO 14001 principles, it
requires each operation to develop and implement a framework that will allow it to carry
out its commitment to continually improve in the areas of environment, safety and
health. To facilitate implementation, Noranda operations have been divided into three
tiers. Tier One operations, principally those with existing environment, safety and health
management ŽESH. frameworks, are required to further develop self-evaluation proce-
dures, to train employees to conduct these evaluations, and report on the results.
Throughout 1999, external teams of Noranda auditors evaluated these systems to
determine if they had been properly implemented and were functioning accordingly. Tier
Two operations are required to develop the elements of an ESH management framework
and, if necessary, conduct a gap analysis to identify any issues requiring attention;
management framework audits began at these operations in 2000. Tier Three operations
include those sites that are either new to Noranda or still require support in developing
and implementing a management framework. The traditional auditing program will be
maintained for these operations as the transition toward the implementation of an ESH
management framework continues.
In another case, Falconbridge, a Canadian producer of nickel, copper, cobalt, and
platinum group metals, 50.1% of which is now owned by Noranda, has set a goal to
have all operations implement an ISO 14001 certified EMS by the end of 2001. Its
Falcondo plant in the Dominican Republic, in 1999, became the first mine operation in
the world to achieve ISO certification. Management laid important groundwork for its
site-specific EMSs with implementation of a Code of Ethics, and a Risk Management
Framework. Management contends that integrating ISO certified EMSs into operations
helps to minimize pollution, improve monitoring, and enables better measurement of
impacts ŽFalconbridge, 2000.. Similarly, Rio Algom, a Toronto-based producer of
copper, uranium, molybdenum, and coal, with mines in Canada, the United States,
Chile, and Argentina, now has in place an environment, health and safety ŽEHS.
management system. The EHS system was finalized in 1999, and supporting baseline
assessment and auditing procedures were developed at their four wholly owned sites:
Atlas Ideal Metals, Vincent Metals Goods, Cerro Colorado, and Rio Algom Mining. A
main reason for developing the EHS management system was to assure stakeholders that
 G. Hilson, V. Nayeer Int. J. Miner. Process. 64 (2002) 19–41 33

the company is identifying, managing and containing EHS risk. Management claims that
each site-specific EHS management system will improve corporate environmental
management as well as socioeconomic relations ŽRio Algom, 1999, 2000.. One final
example is ALCAN Aluminum, the world’s second leading producer of aluminum. The
company’s first step toward implementing an EMS was in 1978, when it first outlined an
environmental commitment that later led to the development of a corporate environmen-
tal policy. As is explained in its most recent annual environmental report ŽALCAN,
2000., with the creation of the Environmental Committee of the Board of Directors in
1992, ALCAN formalized the incorporation of environmental management into the
company’s highest level of decision-making. ALCAN’s Lochaber smelter at Fort
William, Scotland became the first UK smelter to satisfy the requirements for BS7750
EMS standards. Moreover, its work with the ISO has been a key building block in
developing a system that fits its organization while sharing the elements common to all
internationally: a commitment by employees to continual improvement; a determination
to capitalize on aluminum’s unique properties; and a pledge to make the environment an
equal among other business objectives. ŽALCAN, 2000.. A great number of other
Canadian mining companies including Placer Dome, INCO, Barrick Gold and Teck have
accomplished similar feats in the area of EMS design and implementation.
The Australian case, however, perhaps best exemplifies the impact a government can
have in facilitating improved mining environmental management and ultimately,
widespread industrial EMS implementation. The Minerals Council of Australia—the
national association of the Australian minerals industry—through launching a number of
projects in several key areas of mining environmental management, has made the
greatest contribution. The most recent effort has been the launching of an environmental
management code ŽAustralian Minerals Industry Code for Environmental Management,
1998a,b. for its mining industry, which marked a significant step toward addressing
environmental performance and public accountability at minerals operations. The Code
did undergo a substantial review process in 1999, which involved extensive consultation,
but in 2000, a revised Code was drafted, the signatories to which commit to its
implementation by ŽMinerals Council of Australia, 2000a.:

1. Accepting environmental responsibilities for all actions.

2. Strengthening relationships with surrounding mine communities.
3. Integrating environmental management into operations.
4. Minimizing the environmental impacts of activities.
5. Encouraging responsible production and use of products.
6. Continually improving environmental performance.
7. Communicating environmental performance.

The Australian minerals industry has Aconceived the Code as a way to demonstrate
its commitment to excellence in environmental managementB, and contends that it
Aachieves the twin objectives of improved environmental performance and communica-
tion of that performance to the communityB ŽMinerals Council of Australia, 2000b..
There are at least 43 signatory companies Žover 300 operations. that have committed to
the new Code because pledging to it could result in a wealth of benefits, none more
34 G. Hilson, V. Nayeer Int. J. Miner. Process. 64 (2002) 19–41

important than the increased confidence of Australian regulatory agencies. A commit-

ment to the Code also has the potential to help companies increase their standing with
insurers and ethical bodies, helps the industry establish benchmarks of excellence in
environmental management and helps to transfer environmental technology, and aids
signatories in building strong relations with communities and external stakeholder
parties ŽMinerals Council of Australia, 1999.. Most importantly, from the perspective of
the mining EMS, the Code is of enormous utility because it requires signatories to
conduct a regular audit of their EMS.
In August 1998, an Interim Guidance Note was published ŽAustralian Minerals
Industry Code for Environmental Management, 1998a,b. to aid companies implement
the principles, systems, and processes of the Australian Minerals Industry Code for
Environmental Management. The critical areas covered include:

1. Policy and commitment: determine if the company has formally adopted an

environmental policy consistent with the Code; evaluate implementation efforts;
and evaluate the environmental management responsibilities of various staff.
2. Organization and resources: review the management structure to determine if it is
rationally designed and evaluate the responsibilities of staff.
3. Communications and public policyroutreach: interview staff and managers to
determine if systems are in place for reporting pertinent environmental informa-
tion, and evaluate the quality and effectiveness of existing informationrcom-
munication systems.
4. Environmental issues and risks: determine if the organization has the appropriate
systems in place to identify, characterize and evaluate the significance of the
relevant environmental issues and risks associated with its activities.
5. Legal and other requirements: verify through interviewing that the organization
has systems in place to ensure compliance with regulatory demands.
6. Objectives and targets: determine whether the organization has established a set
of environmental objectives and targets, and has informed staff of its goals.
7. Management programs and plans: evaluate the quality of the management pro-
grams and plans the organization has implemented Žor is planning to implement.
to meet its environmental objectives and targets.
8. Operational control: evaluate standard operating procedures to verify that the
organization has provided clear guidance to its managing operations and other
activities that have the potential to impede progress toward environmental targets
and goals.
9. Training, awareness and competence: simply determine whether the company has
identified training needs in key environmental areas, that it has determined the
scope of the training, and that it has hired the appropriate training instructors.
10. Emergency preparedness and response: determine if the organization has fitting
response procedures in place, and the extent to which employees are involved in
developing contingency plans.
11. Documentation and records: determine whether the organization has documented
the core elements of the mining EMS Že.g. policy, risks, targets, programs, etc..,
 G. Hilson, V. Nayeer Int. J. Miner. Process. 64 (2002) 19–41 35

and verify that appropriate measures are in place to ensure continuous environ-
mental improvement.
12. Performance assessment and improvement: verify that the organization conducts
comprehensive environmental audits.

The audit must Averify that management and employee roles are clearly defined, that
senior managers are assigned responsibility to oversee compliance and establish imple-
mentation plans for the EMS, and determine whether environmental staff are conducting
routine site inspections and tracking legalrregulatory requirementsB ŽAustralian Miner-
als Industry Code for Environmental Management, 1998a,b.. From the standpoint of CP,
signatories pledge to continuous Ženvironmental. improvement in operations through
Aimplementing management strategies to meet current and anticipated performance
standards, and regularly reviewing objectives in the light of changing needs and
expectationsB ŽAustralian Minerals Industry Code for Environmental Management,
1998a,b.. Management, therefore, must audit to assess openness to clean technology
transfer, contribution to, and awareness of scientific research, and must evaluate whether
performance targets are consistent with the objectives for continual improvement.
These efforts in turn have helped several Australian mining companies improve the
environmental management of operations, and have helped guide them in implementing
EMSs. For example, Australian Goldfields, a founding signatory to the Australian
Minerals Industry Code for Environmental Management, began drafting EMS require-
ments in 1998 and 1999 using the ISO 14000 series as guidance. As is noted in their
annual environmental report ŽGoldfields, 1999., each mine will eventually have its own
EMS, although the present level of development and implementation varies across the
sites: the development of the EMS at its Kundana property commenced in August 1999,
whereas the Henty property had already drafted an EMS in October 1998 that was
scheduled for completion in November 1999. Although at this point, it is very early to
show direct links between the EMS and improved environmental performance, it is clear
from the design of each that in time, CP will be achieved. At the Henty site, for
example, employees and contractors must complete an environmental training course
presented by personnel that includes an introductory video, an explanation of environ-
mental aspects and regulatory requirements, and a site tour. Further, employees are
encouraged to participate in daily production and meetings, and small awards are given
to people who perform AbeyondB expectations. At the Paddington site, an environmental
introduction is given, ongoing training is incorporated into an awareness program, and
employees must complete a weekly allotment of training and education. Environmental
affirmations are included in communication meetings as well as part of the awareness
program. In another case, Normandy Mining, which is Australia’s leading producer of
gold, is modifying several of its EMS components to more heavily account for CP and
continuous environmental improvement. During the past 2 years, the corporate auditing
and assessment procedure has been significantly restructured, and now includes an
annual five-star assessment process, three-yearly detailed audits, three-yearly compli-
ance audits, and an annual verification process. The assessment process is now consis-
tent with ISO 14001. Additionally, at selected sites, management is in the process for
combining environment, health and safety management systems.
36 G. Hilson, V. Nayeer Int. J. Miner. Process. 64 (2002) 19–41

The management of a number of other Australian companies, however, has only

recently realized the practicality of a mining EMS. For example, WMC, an Australian-
based minerals producer with business interests in 19 countries, and the world’s third
largest producer of nickel, has only very recently begun developing an EMS based upon
the international standard ISO 14001. Further, the company only recently incorporated
the requirements of the Australian Minerals Industry Code for Environmental Manage-
ment. These new guidelines were developed primarily to help environmental profession-
als advise operation managers on environmental issues more accordingly, and to assure
the executive that environmental issues are being handled responsible. Although at
different stages in introducing the system across operations, the goal is to have in place a
comprehensive setup by December 2000 ŽWMC, 1998.. Similarly, MIM Holdings, an
Australian-based producer of copper, gold, zinc–lead–silver, and coal, has pledged to
the Australian Minerals Industry Code for Environmental Management, but is still in the
developmental stage with its EMS. Management is basing the system upon ISO 14001
principles, and at each site, is planning to allocate employee responsibilities in site
management compliance registers ŽMIM, 1999.. Kalgororlie Consolidated Gold Mines,
which manages Australia’s largest gold mining and milling complex, is also in the
process of developing an EMS based upon ISO 14001 principles, and in 1997, signed
onto the Australian Minerals Industry Code for Environmental Management ŽKalgoorlie,
1999..
In summary, it has largely been the efforts of government that has made EMS
implementation possible at several Canadian and Australian mining properties. By
constantly pressuring the industry to improve environmentally, many of the necessary
preliminary steps for EMS design were taken, after which mine management began
conceptualizing many of the benefits to EMS implementation.

5. Recommendations and conclusions

While the aims of this paper have been to discuss the benefits to implementing a
mining EMS, to provide guidance to facilitate implementation, and to present practical
accompanying case study material, it is important to clarify that in order to make
widespread mining EMS implementation a reality, a number of key areas must be
further researched. It is suggested here that with increased government effort, expanded
mining industry partnerships with international agencies, and increased input from
academic and government research units, even the smallest, most resource-deficient
mining operations would be in improved positions to implement comprehensive EMSs.
First, it is imperative that the methods and techniques used for disseminating vital EMS
information to Junior mining companies are improved. AJunior miningB, generally, is
used as a label for the smaller exploration and mineral processing corporations and
operations of developed countries that are heavily influenced by mineral price fluctua-
tions, and are recognized as the most financially volatile and high-risk portion of the
industry. It is therefore particularly challenging for these parties, which lack both the
money and resources to anticipate environmental change, to implement leading-edge
 G. Hilson, V. Nayeer Int. J. Miner. Process. 64 (2002) 19–41 37

environmental practices. Though selected administrative groups—namely governmental

bodies, mining associations and mining institutes—in large mineral producing nations
such as Canada, Australia, South Africa, and the United States have successfully
communicated to multinational corporations the merits of a mining EMS, and in turn
have facilitated and initiated implementation, at the same time, they have neglected to
reach these small- and medium-sized mining companies, many of which already have
important environmental management tools in place, but obviously lack the finances,
educational material and technological know-how to design and implement an effective
EMS. This group must be equipped with the requisite educational, informational, and
technological assistance to achieve higher levels of environmental performance. Signifi-
cant environmental improvements can be made at these operations if EMSs are
implemented, and governments must bridge information, technologic, and economic
gaps, and provide Junior mining operations with the means—namely information and
training—to design EMSs. Incentives such as tax breaks, levies, payback schemes, and
interest-free loans can be provided to these operations.
A second recommendation, which is applicable to mines of all sizes, is for mine
management to place greater emphasis on developing and implementing high-quality
Žmining. EMS training programs. An integral part of any EMS is training because for
the system to work as designed, staff must understand their jobs and how their positions
impact the environment. Within an EMS, mine management must be trained on a
continual basis to ensure that the most up-to-date information is disseminated to each
employee. Training could range from education on safety standards, to updates on
regulations. Familiarizing employees with environmental issues best prepares the opera-
tion to deal with occurrences as they arise. The action plan can involve using the tools
provided to further prevent environmental hazards, or can simply mean that the
employee contacts officials, fire departments, or advisory bodies. As long as individuals
are prepared, however, the chances of any uncontrollable problem occurring are
minimized. It is therefore imperative for top management to commit to the design and
continual improvement of an in-company EMS program that involves the participation
of all staff members Žthough it is impractical to assume that mining companies,
individually, are capable of improving the quality of their EMS training programs
without outside input.. There could be merit in forging additional partnerships with both
local authoritative bodies and international agencies, which have the means of dissemi-
nating valuable CP information, and are equipped with professionals capable of design-
ing practical EMS training programs. Further, these bodies have the knowledge and
capabilities of financing demonstration and dissemination programs in important areas
such as policy-making, health and safety, environmental technology, and database
management, which, in the end, could serve to improve the quality of any existing
mining EMS.
A final recommendation is that governments and the industry itself should encourage
wider participation from academic research units in mining EMS research. Given that so
many mining academic research units exist, the majority of which already have
environmental management research programs in place, it would be beneficial to the
industry if EMS research were incorporated into research agendas. Emphasis should be
placed on EMS training, environmental technology implementation, coursework, envi-
38 G. Hilson, V. Nayeer Int. J. Miner. Process. 64 (2002) 19–41

ronmental auditing practices, and education. In fact, it is suggested that universities offer
the following four types of coursework options Žadapted from Van Berkel, 2000.:

1. Orientation or introductory courses—quintessentially, courses that emphasize the

basic principals of mining environmental management, environmental protection
and regulatory compliance.
2. Environmental integration and disciplinary courses—courses that emphasize the
particular facets of environmental management including, inter alia, training,
technology use, auditing and assessment. These courses can be tailored to the
requirements of the EMS.
3. Specialist environmental courses—since the EMS mandates that certain personnel
undertake specialist environmental management tasks Že.g. reporting, documenta-
tion, auditing, etc.., coursework can be designed to train engineers, managers and
scientists in these areas.
4. Environment relevant interdisciplinary project work—establishing Ahands-onB
training courses, whereby trainees engage in fieldwork or are trained outside of the
classroom in the Aindustrial environmentB, gaining first-hand experience about
various EMS responsibilities.

Mines could provide local units with grants to either expand existing departments or
to conduct stand-alone studies in exchange for this EMS training and research. This
would create a win–win scenario, since mines would receive relevant EMS educational
material, and universities would obtain funding for research.
In conclusion, it has been argued in this paper that implementation of an EMS is a
key to achieving CP in the mining industry, since it helps an operation comply with
environmental regulations, identify technical and economic benefits, and ensure that
corporate environmental policies are adopted and followed. An EMS features a series of
organizational procedures, environmental responsibilities, and processes that, unlike
stand-alone environmental management processes, which tend only to assess the envi-
ronmental situation of an enterprise at the time at which they are carried out, effectively
ensure that a mine’s environmental targets and objectives are attained. Although to date,
it has been mainly the large mining companies that have implemented EMSs at sites,
with increased government effort, expanded mining industry partnerships with interna-
tional agencies, and increased input from academic and government research units, even
the smallest mining operations would be in excellent positions to implement comprehen-
sive EMSs.

Acknowledgements

The authors would like to thank Professor Peter King for inviting this review of
environmental management systems in the mining industry. The authors would also like
to thank three anonymous reviewers for their helpful commentary on earlier versions of
this article. Needless to say, any errors this article may contain are the sole responsibility
of the authors.
 G. Hilson, V. Nayeer Int. J. Miner. Process. 64 (2002) 19–41 39

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