6
P7: Design, implement, and operate monitoring sys-
tems to manage risk at all phases of the facility life-
cycle, including closure.
• Management and governance
P8: Establish policies, systems, and accountabilities
to support the safety and integrity of the tailings
facility.
P9: Appoint and empower an Engineer of Record.
P10: Establish and implement levels of review as part
of a strong quality and risk management system for
all phases of the tailings facility lifecycle, including
closure.
P11: Develop an organizational culture that pro-
motes learning, communication, and early problem
recognition.
P12: Establish a process for reporting and addressing
concerns and implement whistleblower protections.
• Emergency response and long-term recovery
P13: Prepare for emergency response to tailings facil-
ity failures.
P14: Prepare for long-term recovery in the event of
catastrophic failure.
• Public disclosure and access to information
P15: Publicly disclose and provide access to infor-
mation about the tailings facility to support public
accountability.
While the scope of the GISTM is broad, the level of detail
varies between requirements. Some provide little detail,
such as the requirement to develop and implement OMS
manuals, while others, such as the requirements for public
disclosure of information, are very detailed.
The GISTM is being implemented by ICMM mem-
bers and some other companies. ICMM members commit-
ted to implementation by August 2023 for facilities with
very high or extreme consequence classification (ICMM
2020). The ICMM developed conformance protocols to
help members assess progress on implementing the GISTM
and demonstrate conformance (ICMM 2021a,b). For each
requirement, a protocol describes conformance criteria and
provides examples.
A Global Tailings Management Institute (GTMI) is
being established to oversee implementation of the GISTM,
including third-party verification and public reporting
(Church of England Pensions Board 2024). Development
of the Institute was announced in late 2021 by UNEP and
the PRI. At the time of writing, the GTMI had not yet
been formally established, but this process was expected to
be initiated in the near future (Davy 2024). Establishment
of the GTMI will help to resolve outstanding questions
regarding GISTM implementation, including:
• How performance will be measured and evalu-
ated, including whether the ICMM Conformance
Protocols will be accepted for use?
• How results will be verified by third parties?
• How results will be reported and made public?
• Will the GISTM continue to evolve and if so, how?
COMPARISON OF TSM AND THE GISTM
MAC has conducted extensive analysis comparing the
requirements of the GISTM with the requirements in the
TSM Tailings Management Protocol and other TSM proto-
cols with requirements relevant to tailings management,
specifically the Indigenous and Community Relationships
Protocol, the Climate Change Protocol (which includes
requirements related to climate change adaptation), the
Water Stewardship Protocol, and the Crisis Management
and Communications Planning Protocol (MAC 2024, TSM
Initiative 2024b). Initially, this analysis focused on iden-
tifying alignment and similarity between TSM and the
GISTM, as well as gaps in TSM relative to the GISTM.
This analysis informed updates to the TSM requirements
and guidance for tailings management completed in 2021
and 2022, as described above. Further analysis focused
on better understanding the strengths and weaknesses of
each standard, including the strengths of TSM compared
to the GISTM and identifying gaps in the GISTM rela-
tive to TSM. This analysis also considered the experience
of MAC members who are also ICMM members and are
implementing both standards. This analysis is informing
the second phase of the review of the TSM requirements
and guidance for tailings management, launched in 2023.
The key outcomes of this analysis conducted by MAC are
summarized below.
Similarities Between the GISTM and TSM
There is a high degree of alignment between the GISTM and
TSM, and the GISTM reflects many governance concepts
first introduced in TSM, such as the role of the Accountable
Executive (Accountable Executive Officer in TSM) and the
Responsible Tailings Facility Engineer (Responsible Person
in TSM) as well as requirements to develop and implement
tailings management systems and OMS manuals.
These two standards have similar objectives for tailings
management, with the GISTM having a goal of zero harm
to people and the environment with zero tolerance for
P7: Design, implement, and operate monitoring sys-
tems to manage risk at all phases of the facility life-
cycle, including closure.
• Management and governance
P8: Establish policies, systems, and accountabilities
to support the safety and integrity of the tailings
facility.
P9: Appoint and empower an Engineer of Record.
P10: Establish and implement levels of review as part
of a strong quality and risk management system for
all phases of the tailings facility lifecycle, including
closure.
P11: Develop an organizational culture that pro-
motes learning, communication, and early problem
recognition.
P12: Establish a process for reporting and addressing
concerns and implement whistleblower protections.
• Emergency response and long-term recovery
P13: Prepare for emergency response to tailings facil-
ity failures.
P14: Prepare for long-term recovery in the event of
catastrophic failure.
• Public disclosure and access to information
P15: Publicly disclose and provide access to infor-
mation about the tailings facility to support public
accountability.
While the scope of the GISTM is broad, the level of detail
varies between requirements. Some provide little detail,
such as the requirement to develop and implement OMS
manuals, while others, such as the requirements for public
disclosure of information, are very detailed.
The GISTM is being implemented by ICMM mem-
bers and some other companies. ICMM members commit-
ted to implementation by August 2023 for facilities with
very high or extreme consequence classification (ICMM
2020). The ICMM developed conformance protocols to
help members assess progress on implementing the GISTM
and demonstrate conformance (ICMM 2021a,b). For each
requirement, a protocol describes conformance criteria and
provides examples.
A Global Tailings Management Institute (GTMI) is
being established to oversee implementation of the GISTM,
including third-party verification and public reporting
(Church of England Pensions Board 2024). Development
of the Institute was announced in late 2021 by UNEP and
the PRI. At the time of writing, the GTMI had not yet
been formally established, but this process was expected to
be initiated in the near future (Davy 2024). Establishment
of the GTMI will help to resolve outstanding questions
regarding GISTM implementation, including:
• How performance will be measured and evalu-
ated, including whether the ICMM Conformance
Protocols will be accepted for use?
• How results will be verified by third parties?
• How results will be reported and made public?
• Will the GISTM continue to evolve and if so, how?
COMPARISON OF TSM AND THE GISTM
MAC has conducted extensive analysis comparing the
requirements of the GISTM with the requirements in the
TSM Tailings Management Protocol and other TSM proto-
cols with requirements relevant to tailings management,
specifically the Indigenous and Community Relationships
Protocol, the Climate Change Protocol (which includes
requirements related to climate change adaptation), the
Water Stewardship Protocol, and the Crisis Management
and Communications Planning Protocol (MAC 2024, TSM
Initiative 2024b). Initially, this analysis focused on iden-
tifying alignment and similarity between TSM and the
GISTM, as well as gaps in TSM relative to the GISTM.
This analysis informed updates to the TSM requirements
and guidance for tailings management completed in 2021
and 2022, as described above. Further analysis focused
on better understanding the strengths and weaknesses of
each standard, including the strengths of TSM compared
to the GISTM and identifying gaps in the GISTM rela-
tive to TSM. This analysis also considered the experience
of MAC members who are also ICMM members and are
implementing both standards. This analysis is informing
the second phase of the review of the TSM requirements
and guidance for tailings management, launched in 2023.
The key outcomes of this analysis conducted by MAC are
summarized below.
Similarities Between the GISTM and TSM
There is a high degree of alignment between the GISTM and
TSM, and the GISTM reflects many governance concepts
first introduced in TSM, such as the role of the Accountable
Executive (Accountable Executive Officer in TSM) and the
Responsible Tailings Facility Engineer (Responsible Person
in TSM) as well as requirements to develop and implement
tailings management systems and OMS manuals.
These two standards have similar objectives for tailings
management, with the GISTM having a goal of zero harm
to people and the environment with zero tolerance for