The Ontario Mining Association’s Environment Committee is committed to helping its members improve the industry’s overall environmental performance by exploring, promoting and sharing best practices and technologies, with the goal of ensuring the social, economic and environmental sustainability of the industry.
The OMA encourages and supports its members to act responsibly by preventing or minimizing any adverse environmental impact arising from their activities, which include exploration, mining, processing and decommissioning.
Drew Lampman, the committee’s current chair, joined Omya Canada Inc, a calcium carbonate industrial mineral producer in Perth, 13 years ago as a project engineer. From the start he was involved with the usage of water and monitoring levels around the plant site. Over the years, his involvement with water matters increased and five years ago he became the environmental coordinator/manager for the site. Much of his work involved following the requirements for the operation’s permits, so it wasn’t much of a stretch for him to start applying for air and water permits as opposed to just following their conditions. This experience made him the ideal choice for eventually chairing the OMA’s Environment Committee.
The committee was formed in 1972 to address environmental issues related to the operation and closure of mines in Ontario. The main mandate is still the operation and closure of mines, but Lampman adds, “A lot of the work now is about information sharing on upcoming or proposed legislation, trying to be proactive rather than just complying with the legislation, which we obviously try to do.”
With this in mind, it is the objective of OMA members to collectively pursue excellence in environmental performance by incorporating the following principles into their activities and processes:
• Assessing and managing environmental risks;
• Preventing pollution;
• Complying with and moving beyond legal compliance requirements;
• Continually improving environmental performance.
According to Lampman, when new legislation or regulations are proposed, the OMA submits its comments to the government, noting the positive aspects of the proposal and offering suggestions for improvement, particularly in cases when the changes have the potential to negatively impact the sector with no improvement in environmental performance. The committee monitors the Environmental Bill of Rights and tries to provide constructive comments on regulations that affect the mining industry.
Formulating Recommendations to Government
When a new piece of legislation is proposed, the OMA will forward the proposal to member companies for their information. The proposed legislation is discussed in-house and a draft response incorporating the suggested improvements that members would like to see goes out for review amongst everyone on the Environment Committee, as well as the OMA president and staff. Following a final review, the written response is submitted to the government.
In some instances, the OMA also makes presentations to a Parliamentary Committee, which is reviewing a legislative proposal. Chris Hodgson, OMA president, typically presents the industry position, with help from Adrianna Stech, manager environment and sustainability, and/or Lesley Hymers, OMA environment and education specialist.
In addition, OMA member companies often send representatives to Queen’s Park, who provide expert input and information on the practical implications of the new legislation. This allows member companies to be directly involved in the consultation process, which frequently requires multiple meetings with policymakers, ministerial staff, other stakeholders and members of the community. Typically, the OMA is engaged in consultations on a number of files. As an example, Drew Lampman recently contributed to discussions on the Toxics Reduction Act and Ontario Regulation 419/05 Air Pollution – Local Air Quality when he, along with representatives of Vale and Xstrata, sat down with the Minister of the Environment in June.
“It was a valuable experience to sit down with the minister as well as directors of the programs and give our thoughts on where the proposed legislation didn’t make practical sense at a facility level. We feel we were able to demonstrate that, as written, the legislation would take up a tremendous amount of industry and government resources, without really benefitting the environment.” Contributions like these are meant to help the government address the unintended consequences of legislation and achieve its intended goals in the most efficient way without sacrificing industry competitiveness.
The efforts of the committee to change proposed legislation or regulations are sometimes successful. One example that Lampman gives relates to water permit renewals. The Ministry of the Environment was proposing to deny a company’s right to take water if its permit expired during the renewal application review period. At the behest of the OMA, through the Environmental Committee, this was changed, allowing the original permit to remain effective until the renewal review was completed, provided that the renewal application had been submitted at least 90 days in advance of the permit expiry. This sounds like a small victory, but this type of win – improving a bureaucratic process that impedes operations and achieves no environmental gain – is very important to the OMA Environment Committee. Accumulating these types of wins will ultimately improve both the business climate and the environment in Ontario.
Any association member company may send a representative to committee meetings. Typically, 20 to 30 people attend the commit¬tee quarterly meetings. Attendance is usually split 50-50 between mineral producing companies and the mining service sector (consulting companies, suppliers, etc).
Vast amounts of legislation must be dealt with in the environmental area. It is the task of the committee and the OMA to keep members informed about new legislation and changes to existing legislation. How is this monitoring accomplished? According to Lampman, many of the member companies are ISO 14001 certified. This certification is the environmental manage¬ment tool that enables an organization of any size or type to:
• Identify and control the environmental impact of its activities, products or services;
• Improve its environmental performance continually;
• Implement a systematic approach to setting environmental objectives and targets, to achieving these and to demonstrating that they have been achieved.
Companies’ legal obligations include compliance with regulations, keeping up to date on standards, knowing what is applicable to their company, and properly monitoring and measuring effluents to know that they are at acceptable levels.
The OMA is great for that. It often hears about proposed legislation before it is posted on various government web sites, and it lets members know that changes are coming. Part of the OMA’s role is to monitor proposed legislation for the industry. “They are the industry’s eyes and ears at Queen’s Park.” The process of change is not adversarial and Queen’s Park sometimes asks for the OMA’s participation in the drafting stage of new legislation. “Our main goal is to keep the process as cooperative as possible with the govern¬ment of the day.” says Lampman.
Milestones in Environmental Legislation
One of the larger environmental issues facing the industry in recent years was the introduc¬tion of the Municipal/Industrial Strategy for Abatement (MISA), which first came to the attention of the OMA in 1986. The MISA program was the provincial response to addressing levels of persistent toxic substances in industrial direct discharges entering Ontario’s waterways. The program focussed on nine industrial sectors, covering the major toxic polluters, including metal mining and industrial minerals.
Another seminal legislative initiative was the Spill Prevention and Contingency Plans Regulation that came into effect in 2007. In advance of the legislation being promulgated, the committee published an extensive spill prevention and contingency guideline that looked at virtually every activity in the mining production process (excluding underground develop¬ment) and identified activities like refueling of equipment, tracking and possible risk reduction methods. The approximately 200-page document on how to develop the spill contingency plan requirements was made available to member companies and the general public. That was the biggest issue the committee has dealt with during Lampman’s tenure on the committee.
At about the same time, Ontario Regulation 419/05, Air Pollution – Local Air Quality came into effect, requiring new emission modeling and lower limits. There is a phase-in program for Regulation 419, with compli¬ance dates determined by a facility’s industry code. Smelters have the shortest time frame to comply, metal mine sites were given the second shortest time to comply and industrial minerals were given the longest compliance time. Compliance extends to 2020, but requires the development of a plan for best management or methods to reduce emissions to the new stringent requirements. The OMA has ongoing input into the process. The Ministry of the Environment is still developing the regulations for several substances. The OMA Environment Committee is providing ongoing commentary on potential impacts to the industry.
Towards Greener Footprints
This is an environmental progress report that has been published twice in recent years by the OMA. Based on data from the National Pollutant Release Inventory (NPRI), the general trends indicate that environmental performance in Ontario’s mining industry has shown continuous improvement over the last decade.
Always looking for ways to improve communications, the committee conclud¬ed that the Towards Greener Footprints publications (2004, 2006) were a little too technical for the general public. The committee is still looking for ways to simplify them. According to Lampman, it is almost five years since the last one, so it is probably time to start looking at another update. An option being consid-ered for the next edition is to have the data and commentary distributed online.
Tom Peters Award
The Canadian Land Reclamation Association (CLRA), in cooperation with the OMA and the Ontario Ministry of Northern Development and Mines, established the Tom Peters Memorial Mine Reclamation Award.
The aim of the award is to encourage the pursuit of excellence in mine reclamation and to recognize and promote, to the mining industry and environmental community at large, outstanding achievement in the practice of mine reclamation in Ontario.
On June 15 of this year, the Penokean Hills Field Naturalists, the City of Elliot Lake and Rio Algom Limited were awarded the Tom Peters Memorial Mine Reclamation Award in acknowledgement of the project that turned the Milliken Tailings Management Area into the Sheriff Creek Sanctuary in Elliot Lake. Although the OMA environment committee is involved with the award, it does not select the winner. However, OMA member, Vale, finances the $5,000 scholarship offered to a Masters- or PhD-level student undertaking reclamation-related research involving a mine site in Ontario, which goes along with the award.
This year, the Tom Peters Memorial Mine Reclamation Award was presented at the general meeting of the Ontario Mining Association in North Bay and, again, at the annual mine reclamation symposium organized by the CLRA and the OMA in Elliot Lake. This symposium is held in conjunction with one of the OMA Environment Committee’s quarterly meetings, usually in June, and committee members try to visit the winning site.
Ongoing Committee Work
The committee will continue to work on industry best practices and guidelines similar to the spills manual, pertaining to issues such as dust control and water usage. At the September Committee meeting they will discuss matters relating to the Toxics Reduction Act, holding a workshop on how to prepare the required reports and plans under the legislation. Last year, 15 OMA members attended a mining-specific environmental auditing course conducted by the committee. The course included a full review of environment-related legislation, but specifically targeted mining activity.
Some committee work is ongoing, because issues have not been resolved. Lampman foresees an update to the Lakes and Rivers Improvement Act, as it reflects dam safety for tailings dams. There will be new risk manage¬ment activities and requirements when the Ministry of Natural Resources proposes new technical guidelines for dams. He thinks this will require significant effort from the committee and individual dam owners.
On the federal level, there will be new tailings reporting requirements related to the National Pollutant Release Inventory. Lampman thinks that there will be a fair bit of public dialogue related to this, as the new reporting requirements pertain to substances that are being released into mine tailings and the results may be easily misinterpreted by the general public. At issue are the vast quantities of naturally occurring substances in the tailings, compared to the relatively small amounts being released in the water and in the air. Whereas NPRI used to focus on water and air emissions, the shift to reporting on substances in tailings will result on numbers that are orders of magnitude bigger. Although nothing will change from an environmental impact point of view, the committee will have its hands full with combating the negative perception left by the NPRI reports.
The creation of the Environment Committee in 1972 was a response to the growing concern about how mining was affecting the world in which we live. Today, the industry is very proactive concerning the environment. As stated in the association’s 2006 issue of Towards Greener Footprints, it “strives to clean up legacy issues of the past, improve the way it operates to leave less of a mark on the land, prevent pollution, reduce energy consumption, and encour¬age greater recycling of metals. In short, the mining industry recognizes the inherent responsibilities that come with being able to conduct mining and mining related activities in Ontario.” OMA