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Best Management Practices 

 
Author: Jack Caldwell

Summary

This review talks about Best Management Practices in mining. Topics covered include BMPs in uranium and coal mining, stormwater management, erosion, sustainable mining, code of practice, and legal implications.

INTRODUCTION

If you cannot calculate by equation or computer the optimum thing to do, call whatever you want to do a Best Practice or at least a Good Practice, and you will get the respect you deserve.

In surface water management and in erosion control, almost everything that needs to be done is done in terms of established and proven practice. If the past practice is successful, it gets to be called a best management or good practice and is accepted by the regulators as the way to go.

There is a great deal of validity in the concept of implementing Best Management Practices (BMPs) on mines where it is difficult, if not outright impossible, to analyze or model engineering approaches that have proven successful at a similar mine. Thus it is proper, prudent, and cost-effective to define, document, and implement proven & successful BMPs of most mines.

Sadly, most BMPs relate only to surface water, erosion control, and closure of mine waste facilities. For the rest you have to rely on good old-fashioned engineering: calculate, model, design, select, and construct.

Hence in this review, we look at the world of mining-related BMPs. Let us know if we miss yours.

BACKGROUND

A mining professor I know told me that the four pillars of mining are:
  • Theory as embodies in equations, graphs, and computer codes
  • Law & regulations, as embodied in statutes, regulations, and codes
  • Experience as embodied in books, technical papers, and guidance manuals.
  • Judgment as embodied in engineers, managers, and the expensive consultants you find on every mine.

As we shall show in this review, best management practices are but a sub-sub-set of experience. We should never confuse BMPs with good books, good computer codes, or even smart consultants. BMPs are a valid attempt to crystallize successful past practice that is validated not by theory or calculation but is validated simply by the observation that it worked in the past. And the fact that there really is nothing else you can do to do it better.

Do not confuse best practice with state-of-the art practice. Few mines can afford to implement state-of-the-art practice. And it is seldom necessary. What is needed on the typical mine is to get the job done safely and cost-effectively. And that seldom requires state-of-the-art practice. It is well to know what is state-of-the-art, but you must make practical and reasonable decisions as to what is necessary and safe at your mine based on an understanding of the mine-specifics.

CYANIDE BMPs

Ultimately the best example of a mining-related management code is the International Cyanide Management Code for the Manufacture, Transport and Use of Cyanide in the Production of Gold. Never forget it or fail to implement it. Thus let us proceed to a more detailed examination of what a BMP, Good Practice, and/or Management Practice is.

WIKIPEDIA DEFINITION

Because it is so good and succinct, I quote this definition of Best Practice from Wikipedia:

Best Practice is an idea that asserts that there is a technique, method, process, activity, incentive or reward that is more effective at delivering a particular outcome than any other technique, method, process, etc. The idea is that with proper processes, checks, and testing, a desired outcome can be delivered with fewer problems and unforeseen complications. Best practices can also be defined as the most efficient (least amount of effort) and effective (best results) way of accomplishing a task, based on repeatable procedures that have proven themselves over time for large numbers of people.

Despite the need to improve on processes as times change and things evolve, Best Practice is considered by some as a business buzzword used to describe the process of developing and following a standard way of doing things that multiple organizations can use for management, policy, and especially software systems.

Best Practice is, however, often a misused term. It is frequently used to support politically correct ideals which, in reality take no account of individual need or circumstances. In this sense the ensuing practice is far from 'best' when the resulting effects are contrary to the real ideal situation. It is also used to prevent challenges to rules and systems that are, in reality, not best practice.

As the term has become more popular, some organizations have begun using "best practices" to refer to what are in fact "rules," causing a linguistic drift in which a new term such as "good ideas" is needed to refer to what would previously have been called "best practices."

SAP GLOBAL

The best set of BMPs for mining I found on the web is SAP Global. They describe BMPs thus:

For the past three decades, SAP has collaborated with our most successful partners and customers to develop what has become one of our key packages, SAP Best Practices, a source of knowledge informed by our proven expertise and values and provided to our customers without surcharge. In applying our best practices, your organization can access the content and the methodologies you need to cost-effectively implement our technology. Our best practices can help you control costs, reduce risk, and drive more value from your SAP solutions. With SAP Best Practices, you can benefit from:

  • A proven methodology that leverages a reusable prototype approach to implementation.
  • Thoroughly documented scenarios that detail both business and technical perspectives.
  • Proven pre-configurations for SAP solutions.
  • Guidelines for adapting SAP techniques to meet your organization's specific requirements, and using those techniques to develop customized SAP or other hosted solutions.

Currently their BMPs are for Australian mining practice. They appear to cover most aspect of business management as applied to mining. Here is a list of some BMP topics they claim to cover: contract to invoice with commodity pricing; bulk transport; production planning and control; processing and blending operations; preventative maintenance; remote location supply management.

I could not actually access any of their BMPs, so must leave you to investigate further and judge for yourself.

URANIUM MINING

In the twentieth century, The International Atomic Energy Agency put out best management practice guides for the uranium industry. One example is the 1998 Guidebook on Good Practice in the Management of Uranium Mining and Mill Operations and the Preparation for their Closure. These days they have snappier titles and no emphasis on good practice which in the uranium industry has lost some of its allure as a justification for doing things a particular way.

STORMWATER MANAGEMENT

On the typical mine, stormwater management is the activity that most benefits from the concept of best management practice. Here is a focused discussion of the topic:

Best Management Practices (BMP) are structural and nonstructuralstormwatermanagement control measures taken to mitigate changes to both quantity and quality ofrunoffcaused through changes to land use. Generally BMPs focus on increased impervious surfaces from development. BMPs are designed to reduce volume, peak flows, and/ or non-point source pollution throughevapotranspiration,infiltration, detention, and filtration or biological and chemical actions. Examples of Structural BMPS include bioinfiltration or bioretentionrain gardens,pervious concreteand porous asphalt, infiltration trenches, andgreen roofs. These practices are generally used in Low Impact Development applicationsLID. Information is available through theVillanovaUrban Stormwater Partnership website, the Pennsylvania Stormwater BMP Manual, and the EPA Urban Stormwater BMP Study.

Additional resources are available at the Oregon Bureau of Development Services and the Municipal Research and Services Center of Washington. ForesterPress has books on BMPs, sediment erosion, solid waste, and stormwater management.

EROSION BMPs

The U.S. Environmental Protection Agency (EPA) has available a fine suite of BMPs for erosion control. If erosion control is an issue at your mine, you will be well served knowing these BMP and implementing them.

MINING BMPs - GENERAL

The Idaho Department of Lands In 1992 put out a set of BMPs for mining. While obviously outdated, a quick look at these BMP is a good introduction to approaches that may be applied at your mine's dumps, piles, impoundments, and drillholes.

MINING BMPs - COAL MINES

Coal mine BMPs related primarily to mine surface water and geochemistry are available at an EPA site. See also the BMP resources for coal mining at the Kentucky Division of Water site.

RECLAIMED MINE LAND BMPs

The Colorado Division of Minerals & Geology has the e-Volume Best Practices in Abandoned Mine Land Reclamation. Washington has Best Management Practices for Reclaiming Surface Mines in Washington and Oregon. Neither is exhaustive; neither of much practical use in real-life situations; both provide an excuse to do something, anything, and justify it by reference to a book.

SUSTAINABLE MINING

While I have not the faintest idea what sustainable mining is, I must refer you to the Good Practice - Sustainable Development in the Mining and Minerals Sector site where you will find a slew of e-volumes including classics titles like Stewardship: Leading Practice Sustainable Development Program for the Mining Industry.

ICMM

The International Council on Mining & Metals (ICMM) prefers the term Good Practice to Best Practice. At their site are links to many e-publications that in one way or another describe good/best mining practices. Their guidance manual range from advice on how to control AIDs in mine workers to the closure of worked-out mines. ICMM's publications are generally produced in association with real miners. Their documents are well-written and easy to read. I bet they are generally easy to implement if you have the need and willpower. Try for example Good Practice Guidance for Mining and Biodiversity.

UNDERGROUND MINING

Here are some references that touch on best practices in underground mining:

CODE OF PRACTICE

A code of practice should not be confused with a best practice or even good practice. Being in a code, generally make the practice mandatory rather than optional. As is stated in the New Zealand Code of Practice - Applicable Standards for Underground Mining and Associated Operations (2008):
The purpose of this document is to provide guidance to responsible persons in the mining industry on how to meet their general duty of care responsibilities under the Workplace Health and Safety act 1995. Failure to observe a provision of an approved code of practice is not, in itself, a breach of the Act. However, an approved code of practice is admissible in evidence in legal proceedings in which it is alleged that a person with a duty of care under the Act has failed to comply with the Act.

Or as stated in the Australian Code of Practice for Exploration in Environmentally Sensitive Areas (1995):

The aim of this Code of Practice is to promote responsible land-use practices while gathering geological information during mineral exploration which minimize environmental impacts and preserves future land use opportunities.

Incidentally, the Australians love codes of practice. See for example also the Code of Practice on Radiation Protection and Radioactive Management in Mining and Mineral Processing.

LEGAL IMPLICATIONS

Be careful in designating anything best practice. If you implement the practice and something goes wrong, you deserve to be attacked in a court of law for hype & imprudence and maybe even negligence. In legal theory there is no such thing as best. There is only what is reasonable and necessary in a specific case. Obviously if something goes wrong when you are implementing a best practice, then by observation, it is not the best practice and you were negligent in implementing it without giving thought to the specifics of your mine.

That is why you will find the term BMP generally applied these days only to erosion control and surface water management. By definition things always go wrong in these fields when it rains too much. The point is however they did the best they could given the money and technology.

In other areas of mining, some organizations use the word Good Practice. That leaves you less vulnerable to a legal claim if you implement the good practice and things still go wrong. I would not rely on it in the face of a good lawyer.

The term standard management practice is dangerous in a legal context. If all you can be bothered to do is standard old stuff, you clearly did not take the specifics of your mine into account. Ergo you are prima face liable if something goes wrong.

The point of all this is that practices, best, good, common, standard, or whatever you choose to call them, are at best just another source of information. You are obligated as a miner to think through the problems of your mine and do the necessary and reasonable things to prevent injury and mishap. Anything less and you are liable. So do not elevate BMP or anything similar to an altar and do not worship them and do not implement them without critical enquiry. For at the worst they may be just Dangerous Management Practice.

FINAL THOUGHTS

As does SAP, so I suspect in the future will go other companies. We can look forward to the day when you buy a CD or download a file, give it to a junior engineer, tell them to implement it, and the engineering, design, purchasing, procurement, construction, operation, and closure is done seamlessly and in full accord with the best practices world-wide. As a manager all you have to do is monitor for deviations from company policy and goals.

As for the junior engineer, all they have to do is turn on the computer and out will spew a sequential series of instructions about actions to take and how to respond to events. This will be even better than the so-called, never-come-to-fruition expert systems that used to excite me so.

Generation and sale of BMP for all aspects of mining is a vast open opportunity for academics, retired professionals, entrepreneurs, and snake-oil salesmen alike. We will watch its future with interest.

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