We encourage GTS to ensure its applicability to current as well as new mines. Focusing exclusively on design of new mines, while extremely important, will not mitigate the risks to ecosystems, livelihoods and human lives from existing, operating facilities that may be poised to fail. Given that the GTR originated in the desire by co-conveners to “prevent the next Brumadinho” catastrophe, this consideration must not be neglected.
We recognize that the GTS scope of work does not seek “to exclude certain technologies” or practices. But if the Standard and the process are, in fact, seeking a “step change in performance” that would ensure the safety of communities, workers and the environment from risks posed by TSFs, then technologies that have been identified by multiple jurisdictions to increase these risks must be re-evaluated and discouraged rather than replicated.
We appreciate the efforts of the Expert Panel in preparing this Standard, and would urge them to be as specific as possible with requirements, rather than leaving grey areas or including optional measures. Where safety is optional, unfortunately, it is an easier choice to opt out of it. Thus, terms like “periodically,” “consider,” “appropriate” should be replaced with concrete and measurable indicators, with provisions for exceptions in extraordinary circumstances.
Finally, we hope that the Standard will be accompanied by implementation guidelines prepared by the independent Expert Panel and overseen by a multi-stakeholder governance structure. We are concerned by the notion that implementation and audit guidelines would be prepared by an industry-led body running parallel to this process. Relatedly, we ask that the process Global Tailings Standard process be truly independent in the next phases of review, consultation and finalization of the Standard.