8
achieving the goal of minimizing harm. A lack of
integration could lead to:
• A more disjointed approach to tailings management
with ineffective coordination of activities between
different groups with roles and responsibilities
related to tailings management.
• Greater potential for breakdowns in communications.
• Increased potential for:
– Short-term, ad hoc decisions that compromise
long-term objectives for tailings management.
– Decisions based on incomplete or inaccurate infor-
mation, or that do not properly take all relevant
considerations into account.
This difference can be illustrated by how TSM and the
GISTM approach the critical topic of managing change.
The GISTM has a requirement (R6.5) for the implementa-
tion of a change management system. However, this require-
ment is not linked to the requirement to establish a tailings
management system (R8.2). The Plan-Do-Check-Act cycle
of the tailings management system provides a driver to help
identify changes (Check), develop action plans to address
or assess those changes (Act), and update plans, processes,
and systems as necessary to help ensure effective implemen-
tation of changes (Plan).
In addition, R6.5 of the GISTM is focused on techni-
cal aspects of design, construction, operating, and moni-
toring and does not address changes related to governance
(e.g., ownership), nor does it address changes identified in
other GISTM requirements, such as changes to climate or
the social, environmental and local economic context – the
puzzle pieces don’t connect. Conversely, the TSM require-
ments for managing change (Tailings Guide Section 4.5)
explicitly address a range of potential changes, both gov-
ernance and technical, and integration into the tailings
management system helps ensure that changes related to
any components integrated into the tailings management
system will be identified and addressed.
Another dimension to this difference in integration
is the TSM requirement for annual management reviews
which addresses the Act element of the Plan-Do-Check-
Act cycle of the tailings management system (Indicator 5 of
the Tailings Management Protocol, Tailings Guide Section
7). This requirement builds upon performance evaluation
(Check – Tailings Guide Section 6) and integrates the out-
comes from assurance mechanisms such as independent
review. It requires owners to consider technical perfor-
mance of the tailings facility and evaluate the effectiveness
of the tailings management system, plans for emergency
preparedness, the OMS manual, and a range of other com-
ponents. It also requires owners to identify gaps or weak-
nesses as well as opportunities for continual improvement,
with the development of action plans to be developed and
implemented in subsequent Plan-Do-Check-Act cycles.
Thus, the annual management review not only looks at the
state of current performance, it requires owners to ask “how
can we do better” and to develop action plans – it drives
continual improvement.
While the GISTM has many different requirements for
reviews of various components, and a requirement (R7.5)
to report the results of monitoring programs at least annu-
ally, there is nothing in the GISTM that could be consid-
ered equivalent to Indicator 5 of the Tailings Management
Protocol, either in terms of the breadth of information inte-
grated into the review, or the manner in which Indicator
5 drives action plan development and thus continual
improvement. Again, the GISTM has the elements, but
does not connect the puzzle pieces.
MAC’s analysis has identified additional strengths of
each standard relative to the other, which are summarized
in Tables 1 and 2.
Table 1. Strengths of the GISTM compared to TSM, based
on MAC’s analysis. Note that, as part of MAC’s ongoing
review of the TSM requirements and guidance for tailings
management, all of these aspects are being considered
GISTM TSM
Stronger and more
detailed requirements
related to tailings facility
design.
TSM does not currently address
tailings facility design, apart from
requiring that design-related
information be documented.
Historically, TSM has not
addressed design because it is
addressed in guidance from the
Canadian Dam Association.
More detailed and
explicit requirements for
disclosure of information
related to tailings
management.
TSM includes requirements for
disclosure in the Indigenous and
Community Relationships Protocol,
but there are no disclosure
requirements specific to tailings
management.
Strong requirements
specific to community
engagement related to
tailings management.
TSM takes a site-wide approach to
community engagement. Although
this approach is preferable and
is a strength of TSM as a whole,
the current requirements can be
met without adequate community
engagement specific to tailings
management.
achieving the goal of minimizing harm. A lack of
integration could lead to:
• A more disjointed approach to tailings management
with ineffective coordination of activities between
different groups with roles and responsibilities
related to tailings management.
• Greater potential for breakdowns in communications.
• Increased potential for:
– Short-term, ad hoc decisions that compromise
long-term objectives for tailings management.
– Decisions based on incomplete or inaccurate infor-
mation, or that do not properly take all relevant
considerations into account.
This difference can be illustrated by how TSM and the
GISTM approach the critical topic of managing change.
The GISTM has a requirement (R6.5) for the implementa-
tion of a change management system. However, this require-
ment is not linked to the requirement to establish a tailings
management system (R8.2). The Plan-Do-Check-Act cycle
of the tailings management system provides a driver to help
identify changes (Check), develop action plans to address
or assess those changes (Act), and update plans, processes,
and systems as necessary to help ensure effective implemen-
tation of changes (Plan).
In addition, R6.5 of the GISTM is focused on techni-
cal aspects of design, construction, operating, and moni-
toring and does not address changes related to governance
(e.g., ownership), nor does it address changes identified in
other GISTM requirements, such as changes to climate or
the social, environmental and local economic context – the
puzzle pieces don’t connect. Conversely, the TSM require-
ments for managing change (Tailings Guide Section 4.5)
explicitly address a range of potential changes, both gov-
ernance and technical, and integration into the tailings
management system helps ensure that changes related to
any components integrated into the tailings management
system will be identified and addressed.
Another dimension to this difference in integration
is the TSM requirement for annual management reviews
which addresses the Act element of the Plan-Do-Check-
Act cycle of the tailings management system (Indicator 5 of
the Tailings Management Protocol, Tailings Guide Section
7). This requirement builds upon performance evaluation
(Check – Tailings Guide Section 6) and integrates the out-
comes from assurance mechanisms such as independent
review. It requires owners to consider technical perfor-
mance of the tailings facility and evaluate the effectiveness
of the tailings management system, plans for emergency
preparedness, the OMS manual, and a range of other com-
ponents. It also requires owners to identify gaps or weak-
nesses as well as opportunities for continual improvement,
with the development of action plans to be developed and
implemented in subsequent Plan-Do-Check-Act cycles.
Thus, the annual management review not only looks at the
state of current performance, it requires owners to ask “how
can we do better” and to develop action plans – it drives
continual improvement.
While the GISTM has many different requirements for
reviews of various components, and a requirement (R7.5)
to report the results of monitoring programs at least annu-
ally, there is nothing in the GISTM that could be consid-
ered equivalent to Indicator 5 of the Tailings Management
Protocol, either in terms of the breadth of information inte-
grated into the review, or the manner in which Indicator
5 drives action plan development and thus continual
improvement. Again, the GISTM has the elements, but
does not connect the puzzle pieces.
MAC’s analysis has identified additional strengths of
each standard relative to the other, which are summarized
in Tables 1 and 2.
Table 1. Strengths of the GISTM compared to TSM, based
on MAC’s analysis. Note that, as part of MAC’s ongoing
review of the TSM requirements and guidance for tailings
management, all of these aspects are being considered
GISTM TSM
Stronger and more
detailed requirements
related to tailings facility
design.
TSM does not currently address
tailings facility design, apart from
requiring that design-related
information be documented.
Historically, TSM has not
addressed design because it is
addressed in guidance from the
Canadian Dam Association.
More detailed and
explicit requirements for
disclosure of information
related to tailings
management.
TSM includes requirements for
disclosure in the Indigenous and
Community Relationships Protocol,
but there are no disclosure
requirements specific to tailings
management.
Strong requirements
specific to community
engagement related to
tailings management.
TSM takes a site-wide approach to
community engagement. Although
this approach is preferable and
is a strength of TSM as a whole,
the current requirements can be
met without adequate community
engagement specific to tailings
management.