GOVERNMENT OF RWANDA

RWANDA ENVIRONMENT MANAGEMENT

AUTHORITY

SECTOR SPECIFIC ENVIRONMENTAL AUDIT

GUIDELINE FOR
MINING PROJECTS

June 2014

i
 TABLE OF CONTENTS

TABLE OF CONTENTS .................................................................................................................................. i

LIST OF TABLES .......................................................................................................................................... iv
LIST OF FIGURES ........................................................................................................................................ iv
FOREWORD .................................................................................................................................................. v
LIST OF ACRONYMS.................................................................................................................................... vi
GLOSSARY AND DEFINITIONS................................................................................................................... vii
1. INTRODUCTION TO ENVIRONMENTAL AUDIT GUIDELINES FOR MINING PROJECTS ................ 10
1.1 Nature and Scope of the Guideline ................................................................ 10
1.2 Purpose of the EA Guideline ...................................................................... 10
1.2.1 Rationale and target audience of the guidelines ........................................... 10
1.2.2 User’s Guide .......................................................................................................... 10
Users of the EM & AG ........................................................................................................ 11
1.3 Structure and Content of EM & AG ................................................................ 12
1.4 Environmental Monitoring ........................................................................... 12
1.4.1 Definition of Environmental Monitoring ........................................................... 12
1.4.2 Principles of Monitoring ...................................................................................... 12
1.4.3 Objectives of Monitoring..................................................................................... 12
1.4.4 Types of Monitoring ............................................................................................. 13
1.4.5 Monitoring Process ............................................................................................... 13
1.5 Environmental Auditing .............................................................................. 13
1.5.1 Definition of Environment Audit........................................................................ 14
1.5.2 Objectives of Environmental Audit ................................................................... 14
1.5.3 Scope of Environmental Audit ........................................................................... 14
1.5.4 Audit Criteria ........................................................................................................ 15
1.5.5 Importance of Environmental Audit ................................................................. 15
1.5.6 Types of Audits ..................................................................................................... 15
1.5.7 Environmental Auditors ....................................................................................... 15
1.5.8 Linkage of EA to the EIA ..................................................................................... 16
1.5.9 Roles and Responsibilities in EA ........................................................................ 16
1.5.10 Environmental Audit Process......................................................................... 16
1.5.11 Environmental Audit Procedure .................................................................... 16
2. POLICY, LEGAL AND INSTITUTIONAL FRAMEWORK FOR ENVIRONMENTAL AUDIT ................. 24
2.1 International Context of Environmental Assessment ........................................... 24
2.2 Rwandan Policies Relating to Environmental Audits ............................................ 24
2.2.1 The Mining Policy 2009 ........................................................................................ 24
2.2.2 National Environment Policy 2003 .................................................................... 25
2.2.3 Other relevant Policies ....................................................................................... 26

i
 2.3 Legal Framework ..................................................................................... 26
2.3.1 The Constitution of the Republic of Rwanda 2003......................................... 26
2.3.2 Organic Law N° 04/2005 of 08/04/2005 Determining the Modalities of
Protection, Conservation and Promotion of Environment in Rwanda ...................... 26
2.3.3 Other relevant laws ................................................................................................. 27
2.4 Institutional Responsibility .......................................................................... 28
2.4.1 Management and Administration of the Guidelines .......................................... 28
2.3.3 Roles and Responsibilities of Different Stakeholders in Environmental
Audit 29
3. AN OVERVIEW OF THE MINING SECTOR AND ENVIRONMENTAL IN RWANDA ........................... 33
3.1 Background to the Mining Sector in Rwanda ..................................................... 33
3.2 Minerals Mined in Rwanda ........................................................................... 33
3.3 Impacts of mining Activities ........................................................................ 34
3.4 Mining Licence Requirements....................................................................... 34
3.5 Procedure for obtaining Exploration & Exploitation Licenses ................................. 34
4. SPECIFIC ENVIRONMENT AUDIT GUIDELINES FOR MINING PROJECTS ...................................... 35
4.1 Choosing and designing the audit .................................................................. 35
4.2 Step one: Key questions while Auditing Mining Activities ...................................... 36
4.3 Audit of mining on Air Pollution .................................................................... 46
4.3.1 Air Quality Criteria............................................................................................... 46
4.3.2 Air Quality Monitoring Program Review ........................................................... 46
4.4 Audit of mining on Water Pollution ................................................................ 46
4.4.1 Measures in place to address water pollution ................................................ 47
4.4.2 Identification and dissemination of risks of polluted water ........................ 47
4.4.3 Impact of measure to control water pollution ............................................... 47
4.4.4 Sustainability of monitoring and assessment of quality of water ................... 47
4.4.5 Inventory of water resources and assessment of quality of water ............. 48
4.4.6 Planning, implementation and monitoring of programmes addressing water
pollution............................................................................................................................... 48
4.5 Audit of mining on Waste Management ........................................................... 48
4.5.1 Waste sorting and disposal ................................................................................. 49
4.5.2 Waste transport and tracking ............................................................................ 49
4.5.3 Management strategy effectiveness ................................................................. 49
4.5.4 Site inspection and waste management plan review ........................................ 49
4.6 Audit of mining for biodiversity ........................................................................ 50
4.6.1 Status/Inventory of Biodiversity and important ................................................ 50
4.6.2 Impacts on biodiversity typically associated with mining ................................ 50
4.6.3 Environmental impact assessment and biodiversity .......................................... 51
4.6.4 Managing impacts on biodiversity at different stages of the mining life cycle
............................................................................................................................................... 53

ii
 4.6.5 Land Environmental on mining audit ................................................................... 54
4.7 Climate Change on Mining Audit ................................................................... 54
4.7.1 Climate change risk and opportunities ............................................................ 54
4.7.2 Comprehensive management system to address climate adaptation ............ 55
4.8 Mining Safety Audit................................................................................... 55
4.8.1 Welding hazard in surface mines and quarries ............................................... 55
4.8.2 Stockpiles and dumps hazards ........................................................................... 56
4.8.3 Noise control in mines quarries and tunnels ................................................... 56
4.8.4 Safe operation of mobile plant .......................................................................... 57
4.8.5 Isolated and lockout within the mines quarries and tunnels ....................... 58
4.8.6 Environmental and Social Impacts of Mining Activities ................................. 58
5 GUIDELINE FOR PREPARING AN ENVIRONMENTAL AUDIT REPORT ........................................... 60
5. 1 Purpose of This Specific Guideline .................................................................... 60
5.1.1Definition of an Environmental Audit Report ....................................................... 60
5.1.2 Objectives of an Environmental Audit Report .................................................... 61
5.1.4 Preparation and Submission of the Environmental Audit Report .................... 61
5.1.5 Table of Contents .................................................................................................... 62
REFERENCES .............................................................................................................................................. 71
ANNEXURES ................................................................................................................................................ 73
Annex 1: Mining Projects that require Environmental Auditing (EA) ................................. 73
Annex 2: Contents of the Audit Report ................................................................... 75
Annex 3: Audit Checklist on Occupational Health and Safety Management System ................ 76
Annex 4: Social Audit & Compliance Assessment Checklist ............................................ 78
Annex 5: Surface Atmospheric Audit Checklists .......................................................... 84
Annex 6: Surface Atmospheric Audit Checklist ........................................................... 87
Annex 7: Fire Prevention Audit Checklist ................................................................. 93
Annex 8: Mineral Exploration Audit Checklist ............................................................ 98
Annex 9: Noise Audit Checklist ............................................................................ 108
Annex 10: Stockpiles and Dump Audit Checklist ........................................................ 110
Annex 11: Water Pollution Audit Checklist .............................................................. 112
Annex 12: Ventilation Management Audit Checklist .................................................... 113
Annex 12: Quarry system Audit ............................................................................ 120
Annex 13a: Summary of responses from lead Agencies ................................................ 130
Annex 13b: Summary of responses from developers ................................................... 132
Annex 13c: Summary of response from some practioners ............................................. 133
Annex 14: Generic Terms of Reference for Environment Audit of Mining Projects ................ 138
Annex 15: Stages in the mining process .................................................................. 143

iii
LIST OF TABLES

Table 1: Types of Environmental Audit ................................................................................................ 15

Table 2: Roles and Responsibilities of Key Stakeholders .................................................................. 16

Table 3: Basic steps for choosing a topic and approach for an environmental audit on minerals
and mining ................................................................................................................................................. 35

Table 4: Links between mining threats on the environment, society and the economy, their
causes and consequences ....................................................................................................................... 36

Table 5: Environmental audit topics and approaches (mining and mineral processing) ............. 45

Table 6: Sources of Potential Environmental Impacts by phase ...................................................... 59

Table 7: Standard Table of Contents .................................................................................................... 63

LIST OF FIGURES

Figure 1: Five pillars of the Mining Policy ........................................................................................... 25

iv
 FOREWORD

The overall goal of the Environment Management Policy for Rwanda seeks to maintain
environmental quality and resource productivity on a long-term basis while promoting sustainable
social and economic development. One of the key objectives of the policy is to integrate
environmental concerns into all development policies, planning and activities at all levels, and to
encourage participation by the people during the development process. With specific reference to
the conduct of Environmental Audit (EA), the policy’s objective is to provide a system of EA and
environmental monitoring so that negative impacts arising from a implementing a development
project could be mitigated.
The Rwanda Organic Law as well as the Ministerial Order No. 004/2008 of 15/08/2008, all
establish list of works, activities and projects that have to undertake an environmental impact
assessment which includes agriculture projects. It is therefore a requirement that EA be
conducted for the on-going activities that are likely to have significant impacts on the
environment and to ensure compliance to EIA-certificate conditions and environmental laws. For
the on-going projects that do not have EIA certificate of approval, EA will help to ensure that they
comply to minimum requirement for environmental compliancy. In line with these, in 2006 REMA
produced EIA General EIA Guidelines that are meant to guide the EIA process in the country and in
2012 also produced Sector specific EIA guidelines.
It is appreciated, however, that these national documents do not provide sufficient detail on how
to carry out EA in specific sectors which in this case, this Sector Specific EA Guidelines for mining
Projects have been developed to facilitate the EA process within sectors handling Mining.
The Sector Specific EA Guidelines for Mining Projects, like the General EIA Guidelines, put
emphasis on public consultation during the EA process as a way of ensuring public input into the
EA of Mining projects covers issues of concerns in their surroundings. The preparation process for
this Specific Sector EA Guidelines for Mining projects has ensured existence of harmony with the
REMA General EIA Guidelines. Effort has also been made to ensure that no inconsistencies exist
between these guidelines and those of the development partners on matters of Mining projects
development and operations.
The guidelines present procedures for conducting EAs of Mining projects where the purpose of
each step in the EA process is clearly described. These procedures have been hinged on REMA
General EIA Guidelines.
It must be emphasized that although Sector Specific EA Guidelines for Mining Projects have
attempted to comprehensively describe mining process and related activities, the full range of
environmental and social issues may not have been covered. It is therefore important that, the EA
studies should consider specific aspects of the mining projects, the baseline environment as well
as wider sector issues without focusing in the confines of what is outlined in these Guidelines. The
key is to identify all relevant environmental issues, focus the assessment on the most significant
ones.
I wish to emphasize that, these Guidelines are to facilitate the ease of auditing on-going mining
projects by providing practical guidance and a platform from which to encourage creative and
constructive thinking on the complex issues that characterize operations of mining projects and
their related developments. It is then my sincere hope that these EA Guidelines will provide the
much needed guidance on how to adequately assess the biophysical, social-economic, health and
cultural impacts of mining projects.
I wish you good reading!

DIRECTOR GENERAL

v
 LIST OF ACRONYMS
CDP Carbon Disclosure Project
CO2 Carbondioxide
CP Cleaner Production
Cu Copper
EA Environmental Audit
EDPRS Economic Development and Poverty Reduction Strategy
EIA Environment Impact Assessment
EM&AG Environmental Monitoring and Audit guidelines
EMS Environmental Management Systems
FAO United Nations Food and Mining Organisation
GEF Global Environment Facility
GoR Government of Rwanda
IRST Institute for Scientific and Technological Research
ISAR Rwanda Institute for Science and Agricultural Research
KIST Kigali Institute of Science, Technology
MIGEPROFE Ministry of Gender and Family Promotion
MINAGRI Ministry of Agriculture and Animal Resources
MINALOC Ministry of Local Government
MINECOFIN Ministry of Finance and Economic Planning
MINEDUC Ministry of Education
MINICOM Ministry of, Commerce, and Mining
MINIJUST Ministry of Justice
MININFRA Ministry of Infrastructure
MINIRENA Ministry of Natural Resources
MINISANTE Ministry of Health
Mn Manganese
NGOs Non-Governmental Organizations
NUR National University of Rwanda
Pb Lead
RBS Rwanda Bureau of Standards
REMA Rwanda Environmental Management Authority
RNRA Rwanda Natural Resources Authority
SFB Institute of Management
SnO2 Cassiterite
Ta2O5 Colombo-tantalite
ToR Terms of References
UNDP United Nations Development Programme
UNEP United Nations Environment Programme
UNFPA United Nations Population Funds
UNICEF United Nations Children’s Fund
UP Umutara Polytechnic
USAID U.S. Agency for International Development
WB World Bank
WO3 Wolframite
Zn Zinc

vi
 GLOSSARY AND DEFINITIONS
Definition of terms used in Environmental Audit drawn from EA guidelines for Rwanda (REMA,
2009)

Audit conclusion: Professional judgment or opinion expressed by an auditor about the subject
matter of the audit, based on and limited to reasoning the auditor has applied to audit findings.

Audit criteria: Policies, practices, procedures or requirements against which the auditor compares
collected audit evidence about the subject matter.

Audit Evidence: Verifiable information, records or statements of fact. Audit evidence, which can
be qualitative or quantitative, is used by the auditor to determine whether audit criteria are met.
Audit evidence is typically based on interviews, examinations of documents, observation of
activities and conditions existing results of measurements and tests or other means within the
scope of the audit.

Audit Findings: Results of the evaluation of the collected audit evidence compared against the
agreed audit criteria.

Auditee: Organization to be audited

Auditor (Environmental): Person qualified to perform environmental audits.

Clients: Organization commissioning the audit. The client may be the auditee, or any other
organization which has the regulatory or contractual right to commission an audit.

Degree: Recognized national or international degree, or equivalent qualification, normally

obtained after secondary education, through a minimum of three years formal full time or
equivalent part time study.

Developer: Any person who has proposed or has undertaken to implement a project a project in
the public or private sector.

Environmental audit: Systematic, documented verification process of objectively obtaining and

evaluating audit evidence to determine whether specified environmental activities, events,
conditions, management systems, or information about these matters conform to audit criteria,
and communicating the results of this process to the client.

Environmental management system audit criteria: Policies, practices, procedures or

requirements and, if applicable, any additional EMS requirements against which the auditor
compares collected audit evidence about the organization’s environmental management system.

Environmental management system audit: Systematic, documented verification process of

objectively obtaining and evaluating audit evidence to determine whether an organization’s
environmental management system conforms to the environmental management system audit
criteria, and communicating the results of this process to the client.

Environmental management System: That part of the overall management system which includes
the organizational structure, planning activities, responsibilities, practices, procedures, processes
and resources for developing, implementing, achieving, reviewing and maintaining an
environmental policy.

vii
Exploitation: extraction of mineral and fossil substances in a bid to use them, and a set of
operations which prepare, precede and accompany it or are subsequent to it.

First Party: An audit by an organization on itself (an internal audit).

Leaching: In mining, the use of cyanide in water, or other chemical, that is applied on top of
finely crushed ore to dissolve and extract the desired metal (typically gold).

Lead auditor (Environmental): Person qualified to manage and perform environmental audits.
She/he leads the team of auditors.
License: prospecting license, search license and mine exploitation license.

Mine: an excavation made in the earth to extract minerals

Mineral: a naturally occurring inorganic element or compound having an orderly internal structure
and a characteristic chemical composition, crystal form, and physical properties

Mining: the activity, occupation and mining concerned with the extraction of minerals

Ore: a mineral deposit that has sufficient utility and value to be mined at a profit.

Organization: Company, corporation, firm, enterprise, institution or association, or part thereof,

whether incorporated or not, public or private, that has its own function(s) and administration.

Prospecting: exploratory operations which based on general geological features, consist in

carrying out superficial or profound investigations in a bid to discover and provide information on
the indications or concentrations of mineral or fossil substances.

Quarry: mineral or fossil substance not concerned with concession from the legal point of view.
Technically, it is an open cast mine.
Requirements may include but are not limited to standards, guidelines, specified organizational
requirements and legislative or regulatory requirements.

Research: any set of superficial or profound works and scientific, technical and applied studies
executed in a bid to identify mineral ore, its economic potential and how to exploit it.

Rock: any naturally formed aggregate of one or more types of mineral particles

Second Party: An audit by one organization, working on its own behalf, on another. This is
usually an audit on a supplier by a customer.

Small mine: exploitation of which the size is considered small in relation to the reserves,
investments, and production and mechanisation level.

Subject matter: Specified environmental activity, event, condition, management system and/ or
information about these matters.

Technical expert: A person who provides specific knowledge or expertise to the audit team, but
who does not participate as an auditor.

Third Party: An audit by an independent organization (The third party) against the appropriate
standard.

viii
Waste: the material associated with an ore deposit that must be mined to get at the ore and must
then be discarded. Gangue is a particular type of waste.

ix
 1. INTRODUCTION TO ENVIRONMENTAL AUDIT GUIDELINES FOR
MINING PROJECTS
1.1 Nature and Scope of the Guideline

These Environmental Monitoring and Audit guidelines (EM & AG) are specific set of guidelines for
monitoring and auditing environmental issues arising from implementation of mining projects.
The EM & AG have been developed following the general Environmental Audit guidelines
developed by REMA (2009). The EM & AG are administrative directives meant to guide
Environmental Audits and Monitoring of mining projects in Rwanda. The guidelines should be used
together with any other relevant environmental management instruments developed by REMA, and
other relevant laws, regulations and measures that regulate mining activities

1.2 Purpose of the EA Guideline

The purpose of the environmental monitoring and auditing guidelines (EM & AG) for mining
projects is to ensure that implementation of mining projects adheres to all relevant environmental
laws, regulations, standards, plans and policies, and that environmental management tools
developed following the Environment Impact Assessment (EIA)are used effectively. In conducting
the EM & AG the ultimate aim is to identify and correct environmental concerns that arise with
the implementation of the project, whether identified or not during the EIA process. The EM & AG
involve evaluating of the impact of mining production facilities and activities to the biophysical
and socioeconomic environment and to make overall recommendations for improving the
operating and environmental conditions and long-term sustainability of those facilities and
activities where it is needed. The goal of EM & AG is to establish if proponents of projects are
complying with environmental requirements and enforcing legislation

1.2.1 Rationale and target audience of the guidelines

The EM & AG is used in assessing compliance of the following:

a. Ministry of Natural Resources (MINIRENA) as an organisation complies with relevant

policies, legislation and regulations;
b. Mining projects / activities / programmes comply with the relevant policies, legislation
and regulations; and
c. External parties, including private mining project implementers comply with conditions
prescribed by REMA and RNRA for safeguarding the environment.

The EM & AG will be used by REMA, RNRA and MINIRENA officials responsible for environmental
functions in the Mining Sector; and will provide environmental decision-support tool to the
officials and proponents of the projects while instituting and ensuring corrective action.
Preventative measures can thereafter be implemented. The EM & AG are intended to promote
environmental best practice, legal compliance, protection of the resource, and promote
sustainable development and sustainable use of natural resources for agricultural production.

1.2.2 User’s Guide

The Environmental Monitoring and Audit Guidelines for Mining Sector are designed following the
generic environment audit guidelines developed by the Rwanda Environment Management
Authority (REMA, 2009). This particular set of guidelines describes the process / procedure to be
followed when monitoring or conducting an audit of mining projects. Also, the EM & AG are
designed as a protocol that can be adapted for MINIRENA’s roles at a strategic level, as an

10
impactor or as a regulator. This set of guidelines was developed specifically to systematically
document, and to conduct periodic and objective evaluation of how activities and processes of
ongoing mining projects comply with the approved environmental management plan of the
specific projects and with sound environmental management practices. The goal is to ensure safe
and healthy environment at all stages of the mining project operations, as well as at the
decommissioning.The checklists are included to provide guidance to the user. The user must firstly
establish whether he/she will be monitoring or auditing in the following roles:

i) Monitoring or auditing MINIRENA and RNRA for compliance from a strategic perspective i.e.
at a Policy and Strategy level.
ii) Monitoring or auditing internal development projects where MINIRENA and RNRA are the
developer (or Impactor) that is MINIRENA and RNRA have an impact on the environment.
iii) Monitoring or auditing internal MINIRENA and RNRA activities which are not development
projects but have an impact on the environment from operations and maintenance
perspective such as mining extraction, where such activities have impact on the
environment.
iv) Monitoring and auditing external parties where MINIRENA and RNRA are the Regulator such
as private commercial production facilities, protection of the natural resource (minerals),
where MINIRENA and RNRA have a management function.
v) Once the User has established the context in which the monitoring and/or auditing will be
undertaken, the necessary checklists and the relevant steps of the protocols must be
consulted.
vi) Land use Planning/zoning functions at RNRA
vii) Local Government Authorities;
viii)Standards and Certification officials at RBS
ix) Stakeholders affected by the mining projects;
x) Community representatives and/ or interested persons.

Users of the EM & AG

The EM & AG should be used by suitably qualified and designated persons following the terms and
qualifications set out in the general Environmental Audit Guidelines (REMA, 2009). Various types of
monitoring can occur at a strategic, programme and project level. The EM & AG are designed
such that they can be used to monitor external parties for compliance with conditions prescribed
by MINIRENA, RNRA and REMA. The EM & AG should be used by MINIRENA, RNRA and REMA staff
responsible for ensuring the following either at Head Office or at the District Office:

 MINIRENA, RNRA and REMA are compliant with environmental legislation, policy and
regulations.
 MINIRENA, RNRA and REMA internal environmental objectives, goals and targets are being met.
 MINIRENA, RNRA and REMA have met all performance compliance requirements.
 Compliance by external parties to MINIRENA, RNRA and REMA requirements.

Likewise, the EM & AG is designed such that it can be used by MINIRENA, RNRA and REMA officials
responsible for auditing external parties in terms of RNRA and REMA management functions
namely compliance to EIA or Environment Clearance Permit conditions. The frequency for
conducting an internal audit must be reasonable and practicable to allow for continuous
improvement, a minimum of once a year is an accepted norm provided that ongoing monitoring is
instituted. An external party should audit MINIRENA, RNRA and REMA at least once every three
years. The external auditor may choose to use the EM & AG. It is imperative that the protocols
and checklists are used by appropriately qualified officials as the documents presented in this Sub
Series is designed to assist the officials but not to make a decision for the official, the

11
interpretation of all monitoring data and auditing findings remains the responsibility of the
official.

1.3 Structure and Content of EM & AG

The EM & AG has four chapters with a number of annexures. The first chapter includes four
sections. The first section provides an introduction to the EM & AG including the aim and purpose
of monitoring and auditing. The second section contains document user information on who should
use the EM & AG, how should it be used and when should it be used. The third section consists of a
definition of monitoring, the types of monitoring, a monitoring process for mining projects, and a
guideline for writing a monitoring report and guidance on instituting corrective action for
continual improvement. The fourth section consists of a definition of auditing, the types of
auditing, auditing process for mining projects, a guideline for writing an auditing report and
guidance on instituting corrective action for continual improvement. Chapter three includes 3 key
areas covering elaborate protocols / guidelines for environmental monitoring and auditing of
projects in crops, animal resources and fisheries and aquaculture subsectors respectively.

1.4 Environmental Monitoring

1.4.1 Definition of Environmental Monitoring

Monitoring is an activity undertaken to provide specific information on the characteristics and

functioning of environmental and social variables in space and time. Environmental monitoring
compares impacts predicted in an EIA with those which actually occur during and after
implementation, in order to assess whether the impact prediction process performs satisfactorily.
Environmental monitoring is essential for:

 Ensuring that impacts do not exceed legal standards

 Checking the implementation of mitigation measures in the manner described in the EIA report
 Providing early warning of potential environmental damage.

The frequency of monitoring will vary from project to project, depending on the nature of the
project and the severity of the environmental impacts.

1.4.2 Principles of Monitoring

The EIA monitoring process is intended to generate meaningful information and improve
implementation of mitigation measures. Monitoring must accomplish the following:-
 Carefully determine the indicators to be used in monitoring activities
 Collect meaningful and relevant information
 Apply measurable criteria in relation to chosen indicators
 Pass objective judgements on the information collected
 Draw tangible conclusions based on the processing of information and objective
judgements
 Facilitate rational decision-making based on the conclusions drawn.

1.4.3 Objectives of Monitoring

Monitoring is put in place to achieve the following:

 Verify impact predictions;

 Check success of mitigation measures (progress of actions undertaken);

12
  Adherence to approved plan of action;
 Compliance with conditions of approval;
 Success of management plan to meet environmental needs and standards;
 Enable corrective action to be taken promptly if there is a major unpredicted
environmental impacts

1.4.4 Types of Monitoring

Monitoring activities include the following types:

a) Baseline Monitoring: A survey should be conducted of basic environmental parameters in the

area surrounding the proposed project before construction begins, so that subsequent
monitoring can assess changes in those parameters over time against the baseline.
b) Impact Monitoring: The ecological, health and socio-economic parameters within the project
area must be measured during the project construction and operational phases in order to
detect environmental changes which may have occurred as a result of project implementation.
c) Compliance Monitoring: Employs a periodic sampling method, or continuous recording of
specific environmental quality indicators or pollution levels to ensure project compliance with
recommended environmental protection standards.

1.4.5 Monitoring Process

1.4.5.1 Selection of Impact Indicators

Impact monitoring should not be limited to a few programme components. Appropriate

environmental indicators need to be selected so that monitoring covers all programme
components. If some programme components are potentially more significant than others in
causing adverse environmental impacts, emphasis should be given to monitoring the selected
indicators for these significant components.

1.4.5.2 Monitoring Report Content and Format

The proponent shall make a monitoring report and will include the following:

 Name and address of proponent

 Project Title
 Date of Implementation
 Date of the last report with a summary of findings, actions undertaken and results of these
actions
 Details of environmental parameters to be monitored
 Result of the actual monitoring exercise

1.4.5.3 Decision Making

REMA and the lead agency (MINIRENA) shall review the content of the monitoring report and,
where necessary order a proponent to take necessary measures to correct or improve the
environmental performance of the project. If the proponent fails to comply with the order, the
authorities shall involve the relevant provisions of the Act.

1.5 Environmental Auditing

13
1.5.1 Definition of Environment Audit

REMA has adopted the definition of Environment Audit as laid out in the Environmental Impact
Assessment (EIA) guidelines for Rwanda (REMA 2006) as: “the systematic documentation and
periodic and objective evaluation of protection and management of the environment and the
conservation and sustainable use of natural resources”.

1.5.2 Objectives of Environmental Audit

Environmental audit is a management tool for evaluation of how well Environmental Management
Systems (EMS) are performing with the aim of preventing environmental damage; assessing
compliance with regulatory requirements; facilitating control of environmental practices by a
company/enterprise or facility management; and placing environmental information in the public
domain. Environmental auditing is used to:

i) Facilitate management and control of environmental practices;

ii) Assess compliance with relevant statutory and regulatory requirements;
iii) Raise awareness of and commitment to environmental policy by project staff, the
community and other concerned parties;
iv) Maintain environmental health and safety standards, while continuously exploring
opportunities for improvement;
v) Evaluate Environment Management System and Plan for the project;
vi) Collect data on environmental, operational and social practices, control procedures and
environmental compliance mechanisms;
vii) On-site evaluation of occupational health and safety practices to determine compliance
with national standards;
viii)Conduct a site environmental and health risk assessment to determine risks posed to the
surrounding communities;
ix) Identify feasible, cost-effective mitigation and/or corrective measures and opportunities
for overall improvement environmental and social management practices.

1.5.3 Scope of Environmental Audit

The scope describes the extent and boundaries of the audit in terms of factors such as physical
location, specific project activities, timing and organizational activities as well as the manner of
reporting. The scope of the audit is determined by the client and the lead auditor. The auditee
should normally be consulted when determining the scope of the audit. Any subsequent changes
to the audit scope need the agreement between the client and the lead auditor. The resources
and time committed to the audit should be sufficient to meet its intended scope. The scope of
the audit should be finalised at a preliminary meeting with the company (Client/auditee). The
scope of the audit included all the operations, processes, and activities carried out at the
different projects sites:

 An assessment of the current status of each facility or project

 Compliance of the different projects with their respective conditions of approval of their
EIAs
 Operational constraints and concerns were also included.
 Marketing strategies and the markets targeted for compost.
 Economic and technical indicators at each facility outlining the constraints, benefits, and
challenges of the different projects
 Evaluation of measures and approaches put in place to ensuring protection of ecosystem
services

14
  Environmental health and safety measures

1.5.4 Audit Criteria

The audit criteria are a set of policies, procedures and requirements against which audit evidence
is compared and include the provisions within the laws and regulations as set out in the national
standards and limits put in place to safeguard the environment. Policy, Legal and Institutional
Framework is discussed under Chapter 2 of these guidelines.

1.5.5 Importance of Environmental Audit

Environmental auditing is a management tool comprising of a systematic, periodic and objective

evaluation of how effective environmental management is performing in safeguarding the
environment. It is a precautionary and a proactive environmental management tool. The audit
assesses actual environmental impact, the accuracy of prediction, the effectiveness of
environmental impact mitigation and enhancement measures, and the functioning of monitoring
mechanisms. Environmental audit helps in pollution control, improved production, safety and
health and conservation of natural resources and the environment. Its overall objective is to
ensure the achievement of sustainable socio-economic development.

1.5.6 Types of Audits

The audit should be undertaken after the project has been operational for some time and
following set or agreed to routine. These guidelines provide for two categories of environmental
audit, namely control audit and self-audit which are undertaken by the Authority and the
proponent respectively. Within the two categories the following types of EA are conducted:

Table 1: Types of Environmental Audit

Environmental Environmental management system audits evaluate the effectiveness of
management environmental management and performance systems based on stated
system audit objectives. It also determines whether the systems have been designed and
implemented to meet management objectives. There is need for
formalization of the audit in relations to an international standard, e.g.,
ISO 14000.
Compliance audit These EA&AG provide for two types of compliance audits, regulatory and
performance. Regulatory Compliance Audit evaluates current operations
and controls to determine applicable regulatory requirements, resulting in
a statement of the compliance status. Performance Audit determines
whether actual environmental management conforms to stated objectives
Site Site Property/Facility Audit determines the environmental risks associated
property/facility with financing, purchasing and sale, and for insurance of property and
audit facilities for mining projects.
Environmental Environmental assessment audit determines whether the contents of an
assessment audit environmental statement are correct and comprehensive.

1.5.7 Environmental Auditors

Self-audits will be carried out by both internal and external auditors commissioned by the
proponent or MINIRENA/RNRA. The auditors must have been registered with REMA. However
Control audits, must be undertaken by the REMA.

15
1.5.8 Linkage of EA to the EIA

Environmental Auditing is based on baseline information generated during the EIA process.
Existing projects that have not been subjected to EIA are to be audited on the basis of information
to be generated over a period of time. The Environmental Audit process entails the steps outlined
below:

 Examining the effectiveness of EIA as a decision-making tool

 Ensuring that conditions set in the environmental management plan have been complied with.
 Examining the performance of agencies concerned with management of projects
 Examining environmental impacts arising from project implementation
 Examining the accuracy of predictions by comparing actual against predicted environmental
impacts.

1.5.9 Roles and Responsibilities in EA

Table 2: Roles and Responsibilities of Key Stakeholders

REMA  Determining the need for and time of audit;
 Defining objectives of the audit;
 Approving the environmental audit criteria;
 Approving the audit plan and scope.
 Receiving and reviewing the audit reports.
 Ensuring follow-up actions on recommendations of the audit reports.
 Where necessary require a lead agency to undertake audit.
Proponent /  Informing the employees about the objectives and scope of the audit
Developer  Providing facilities needed by the audit team to ensure an efficient and
effective audit process.
 Conducting self-audit
 Implementing recommendations in audit reports and instructions and
orders by the Authority.

1.5.10 Environmental Audit Process

Environmental audit will be conducted in accordance with audit plans prepared by proponents in
consultation with REMA.

Box 1: Contents of the Audit Plan

An audit plan should include the following:

 The audit objectives and scope;

 The audit criteria;
 Identification of proponent’s organizational and functional units to be audited;
 Identification of the functions and/or individuals within the proponent’s organization and
their responsibilities
 Time frame for audit activities
 Report content and format

1.5.11 Environmental Audit Procedure

The EA procedure is involves three phases: pre-audit activities; on-site activities; and, post-audit
activities.

16
A. Pre-Audit activities

Pre-audit activities include various preparatory works. Having known the project/facility to
be audited, preliminary information on the project/facility is to be obtained through
a questionnaire. The information includes:

 Location of the project with surrounding land uses,

 climatic conditions,
 Business or activities (e.g. project/facility, mining, mines, manufacturing industries,
outputs/products),
 Raw materials used (e.g. natural resources like water, minerals, fuel wood, non-renewable
fuels, etc.)
 details on water utilization, energy utilisation
 Waste generation and disposal (wastewater, solid wastes, other categories like hazardous,
etc.),
 Gaseous emissions, and
 Organizational set-up and policies of the enterprise or company for environmental
management

The preliminary information received on the project should be reviewed to identify main areas of
concern and determine the composition of the audit team. Thereafter it is required to
prepare and organize audit team and resources, and allocate specific tasks to team members.
Resources such as the sampling and monitoring equipment and laboratory facilities for analysis
should be checked if available at site or else arrangements should be made for their availability
through external sources such as private or government laboratories or loan from other industries.
The process for selecting audit team members should ensure that the audit team possesses the
overall experience and expertise needed to carry out the audit; consideration should be given to:

 Qualifications.
 The type of organization, processes, activities or functions being audited.
 The number, language skills and expertise of the individual audit team members.
 Any potential conflict of interest between the audit team members and the auditee.
 Requirements of clients, and certification and accreditation bodies.

The Audit team should be carefully selected to cover various aspects of the audit. The team
should include but not limited to:

 Employees from production.

 Quality control/laboratory.
 Research and development
 Pollution control operations.
 Technical staff for monitoring and analysis of waste samples and the environment.
 An environment specialist.

The number of people may vary depending on the size and complexity of the facility or project
being audited. In addition, the team should be sufficiently detached to provide an independent
view. The members should be in a way that they would not hesitate bringing out even
criticism, owing to obligations with the supervisor. It is important to have well-defined and
systematic procedures, which are known and understood by all concerned. The duration of the
audit may vary from days to months depending on the nature of the project or facility to be
audited. Effectiveness of the audit is a direct result of: the qualification; expertise; confidence;
training and proficiency of the personnel who conduct the audits. The team must be able to
understand regulatory requirements, relevant control technologies and their

17
operations and process. In effect, they should have capability to examine; question; sample and
analyse environmental materials and interpret the data.
The EA visit programme should be introduced to the project/facility mentioning that the
environmental audit should not be considered as a raid but a means of improving environmental
management. The prior information to the project/facility helps the EA team convince the senior
management and staff at various levels of the purpose of audit and the cooperation they have
to extent to the audit team. The staff should not feel that the audit would lead to surfacing
problems and hence would be subjected to criticism by the management. They should be
clear about the purpose and objectives of the audit and how beneficial it would be for
the project/facility. This would also increase employee’s awareness towards environmental
management and promote input and support for the audit.

A1. Preliminary document review

At the beginning of the audit process, the lead auditor should review the organization’s
documentation such as environmental policy statements, programmes, records or manuals for
meeting its environment requirements. In doing so, use should be made of all appropriate
background information on the auditee’s organisation. If the documentation is judged to be
inadequate to carry out the audit, the client should be informed. Additional resources should not
be spent until further instructions have been received from the client. Key pre-audit information
includes:

 A map of site and its locality.

 A brief history of the site and activities carried out.
 A summary of current organisational structure.
 A list of personnel who would be available for interview e.g. general or production
manager, officers responsible for environment.
 A list of key environmental issues from management point of view.
 Environmental policy and other information relevant to the environment e.g. corporate
objectives, targets, guidelines, and environmental reports.
 Previews of environmental reviews or audit reports.
 Restrictions on audit team such as restricted access to parts or safety requirements.
 Process flow diagrams.
 Copy of Environmental Impact Statement (EIS) relating to site.

Other relevant information includes: awareness and training of staff and monitoring procedures in
place

B. Preparing the audit

i) Audit plan

The audit plan should be designed to be flexible in order to permit changes in emphasis based on
information gathered during the audit, and to permit effective use of resources. The plan should
include the following wherever applicable:

 The audit objectives and scope. The audit criteria. (Legislation, best practices, motivating
factors, local pressures, societal concerns and expectations).
 The auditee’s organisational and functional units to be audited.
 The functions and /or individuals within the auditee’s organisation having significant direct
responsibilities regarding the auditee’s environmental management.
 Elements of the auditee’s environmental practices that are of high audit priority.

18
  The procedures for auditing the auditee’s environmental management elements as
appropriate for the auditee’s organisation.
 The working and reporting languages of the audit.
 Reference documents.
 The expected time and duration for major audit activities.
 The dates and places where the audit is to be conducted.
 Composition of the Audit Team.
 The schedule of meetings to be held with the auditee’s management.
 Confidentiality requirements.
 Report content, format and structure, expected date of issue and distribution of the audit
report.
 Document retention requirements.
 The sections of the public affected and to be consulted.

The audit plan should be communicated to the client or auditee and the auditors. The client
should review and approve the plan. If the Client or auditee objects any provisions in the audit
plan, such objections should be made known to the lead auditor. They should be resolved between
the lead auditor, the auditee and or the client before conducting the audit. Any revised audit
plan should be agreed between the parties concerned before or during execution of the audit.

ii) Audit Team Assignments

As appropriate, each audit team member should be assigned specific terms of references (ToR) to
cover functions, or activities to audit and be instructed on the audit procedure to follow. Such
assignments should be made by the lead auditor in consultation with the audit team members
concerned. During the audit, the lead auditor may make changes to the work assignments to
ensure the optimal achievement of the audit objectives.

iii) Working documents

The working document required to facilitate the auditor’s investigations may include:

 Forms for documenting supporting evidence and audit findings.

 Procedures and checklists used for evaluating environmental management practices.
 Records of meetings.

Working documents should be maintained at least until audit completion, those involving
confidential or proprietary information should be suitably safeguarded by the audit team
members.

i) Conduct of the Audit at the site

Following agreement on audit plan and programme, the audit team led by their team leader can
start to conduct the EA on site. The sequence of EA activities that will take place at the client’s
facility include the following:

19
Opening Meeting The purpose of an opening meeting is to:
between Audit
Team and  Introduce the members of the audit team to the auditee’s
Management management;
 explain and review the scope, objective and audit plan and agree on an
audit time table;
 provide a short summary of the methods and procedures to be used to
conduct the audit;
 establish the official communication links between the audit team and
the auditee;
 confirm that the resources and facilities needed by the audit team are
available;
 confirm the time and date for the closing meeting;
 promote the active participation by the auditee;
 review relevant site safety and emergency procedures for the audit
team; and,
 resolve misunderstandings or fill any gaps in the pre-audit information.
Collecting of Audit Sufficient audit evidence should be collected to be able to determine
evidence whether the auditee’s environmental practices conforms to the audit
criteria. Audit evidence should be collected through interviews,
examination of documents and observation of activities and conditions.
Indications of nonconformity to the audit criteria inspections should be
recorded. Information gathered through interviews should be verified by
acquiring supporting information from independent sources, such as
observations, records and results of existing measurements. Non verifiable
statements should be identified as such. Auditors should examine the basis
of relevant sampling programmes and the procedures for ensuring effective
quality control of sampling and measurement processes. Information
gathering is normally, assisted by the use of audit protocol/and or
checklists found in Annexures.

An example for evidence collection for irrigation scheme at site can be

summarized to include:

 Identifying all key activities important for environmental management.

 Deriving water balance between the different users, and between the
intake and effluent from the scheme.
 Review the data on water quality evidence, and where necessary
conduct sampling to verify the results.
 Monitoring of water intake, use and discharge in terms of quantity and
quality characteristics.
 Evaluating performance of pollution control equipment/system.
 Evaluation of state and performance of irrigation infrastructure.
 Determining compliance with statutory environmental requirements
 Evaluation of performance of agrochemical use management.
 Assessing environmental quality.
 Assessing the governance system of the users, and socioeconomic
survey of the attendant communities to establish any existing or
potential conflict area that may impact the environment and proper
functioning of the scheme.
 Review of the safety and occupation safeguards in place.
 Review of the overall management of the scheme.
 Holding discussions with the management and finally preparing the

20
 draft report.
Audit findings The audit team should review all of their audit evidence to determine
where the environmental practices do not conform to the audit criteria.
The audit team should then ensure that audit findings of nonconformity
are documented in a clear, concise manner and supported by audit
evidence. Audit findings should be reviewed with the responsible auditee
manager with a view to obtaining acknowledgement of the factual basis of
all findings of nonconformity. If within the agreed scope, details of audit
findings of conformity may also be documented, but with due care to avoid
implication of absolute assurance.
Closing Meeting After completion of the evidence collection phase and prior to preparing
an audit report, the auditors should hold a meeting with the auditee’s
management and those responsible for the functions audited. The main
purpose of this meeting is to present audit findings to the auditee in such a
manner to obtain their clear understanding and acknowledgement of the
factual basis of the findings. Disagreements should be resolved, if possible
before the lead auditor issues the report. Final decisions on the
significance and description of the audit findings ultimately rest with the
lead auditor, though the auditee or client still may disagree with these
findings.

On-site activities for all other categories of project (e.g. infrastructure, mining, mines, etc.) can
be carefully selected after carrying out thorough pre-audit assignments. Interviews should be
carried out with various cross-sections of the staff engaged in running the facility or project so as
to understand different operational mechanisms. Having a fair idea on the operational process,
reconnaissance surveys should be made to be familiar with layout of the site and
process operations, and to understand possible impact on the surrounding environment.

Post Audit Activities

After the fieldwork has been completed there are a number of post-audit activities that should
take place to complete the audit process. They are: (1) conduct debriefing, (2) develop the audit
report, and (4) develop an action plan to address audit findings

Conduct audit debriefing

This provides an opportunity to informally review the audit findings together with the
project/facility officials before writing the audit report. This helps to clear up issues and confirm
accuracy of information and also helps the audit team to identify any additional data or
information needed to complete analysis. Attendance of audit debriefing should include the
following: senior management, legal officer, key project supervisors, and other staff who have
significant responsibilities at the facility.

21
Develop Audit Report

Audit report is the document in which the findings of the audit team are presented with respect to
compliance status of the facility. It may also include recommendations for follow up actions and
suggested changes in the operation of the facility for better environmental management. There
are several philosophies and attitudes concerning the format and purpose of audit report.
However, there are several common elements of good audit reports that are generally accepted
principles or common denominators that are embraced including: establishing a consistent format,
be clear and concise; assure legal review of the report.

The draft report should be presented before the senior management and various points should
be thoroughly discussed. The management should put forward their views. The participation of
the management and their acceptance of various observations and recommendations make the
task of implementation meaningful. A detailed guideline on how to prepare and environmental
audit report is provided in chapter 5.

Action Plans

The recommendations include measures for best practicable environmental management. If

the annual burden, i.e. the annualized capital cost of the control measures and their operating
cost, for the implementation of all the recommendations, is high and the investment not feasible
for the facility, then these recommendations should be implemented in phases. Priorities should
be fixed and action plans with time-frame should be formulated in consultation with REMA. For
example, compliance agreements can be signed with REMA to phase out environmental
management commitments to mitigate environmental impacts of the operation of the enterprise.

In formulating an Audit Action Plan for effective performance and environmental improvement,
the proponent shall specify the following:-
• What should be done
• Who must do it
• Time frame
• Budget
• Implementation programme
• Reporting
• Monitoring

22
Follow-up Actions

Follow-up actions should be taken to check the progress of implementation of recommendations.

The Environment Division of the facility should meet the other Divisional heads periodically to
review the progress. A summary of the Environmental Audit procedure described above is provided
by Figure 1 as a quick reference.

Distribution of Report

The audit report should be sent to the client (REMA or any other person mandated) by the lead
auditor. Distribution of the audit report should be determined by the client in accordance with
the audit plan. The audited organisation (auditee) should receive a copy of the audit report.
Audit reports are the sole property of the client and confidentiality should be respected and
appropriately safeguarded by the auditors and all report recipients. The audit report should be
issued within the agreed time period in accordance with the audit plan. If this is not possible, the
reasons for the delay should be formally communicated to both the audited organisation and a
revised issue date established.
Document retention

All working documents and draft and final reports pertaining to the audit should be retained by
agreement between the audited organisation or client, the lead auditor and in accordance with
any applicable requirements. REMA should decide on who will receive the audit reports for review
before the final decision on the document is made. It is normal practice to involve sector lead
agencies in the review of EA reports.

Cost of audit

The cost of the EA process is borne by the audited project owner as indicated in Article 69 of the
Organic Law (No 04/2005 of 08/04/2005) for EIA.
Post audit orders
The Authority may issue an improvement order for the carrying out of corrective measures for
mitigating the environmental degradations revealed during any audit study.
Inspections
An inspector may, at reasonable times, enter on any land, premises or facility of a project for the
purposes of inspection, to examine records and to make enquiries on the project. A person who
refuses to answer questions, refuses to avail documents or refuses to give other information
legitimately sought by the inspector commits an offence.
Audit petition by public
A member of the public may, after showing reasonable cause in writing, petition the Authority to
cause an audit to be carried out on any project.

23
 2. POLICY, LEGAL AND INSTITUTIONAL FRAMEWORK FOR
ENVIRONMENTAL AUDIT
2.1 International Context of Environmental Assessment

Environmental Audit (EA) operates within the global concept of sustainable socio-economic
development. The mining sector is increasingly subject to international law, encompassing a wide
range of conventions, protocols, declarations, treaties, standards, codes, and recommendations
relating to environmental, social and economic norms. Thus achievement of EA in the mining
sector requires compliance to international environmental Declarations which include the
Stockholm Declaration (1972), the Rio Declaration, Johannesburg Declaration (2002), the Rio
Declaration (2012). EA achievement also requires compliance to commitment to Conventions
which Rwanda is a party which include the Ramsar Convention on Wetlands of International
Importance (1971 ratified in (2003), the Vienna Convention for the Protection of the Ozone Layer
(1985) ratified in 2003, Montreal Protocol on Substances that Deplete the Ozone Layer, 1987
ratified in 2003, , the Convention on Biological Diversity and its Habitat of (1992) ratified in 1995,
Cartagena Protocol on Biosafety (2000) ratified in 2003, the United Nations Framework Convention
on Climate Change (1992) ratified in 1995, the United Nations Framework Convention on Climate
Change (1992) ratified in 2004, the Rotterdam Convention on the establishment of international
procedures agreed by states on commercial transactions of agricultural pesticides and other
poisonous products of 1998 ratified in( 2003), the Kyoto Protocol to the Framework Convention on
Climate (1997 ),the Bonn Convention on Conservation of Migratory Species of Wild Animals (1979)
ratified in (2003),the Washington Agreement on International Trade in endangered Species of Wild
Flora and Fauna of 1973 ratified in (1980), the Stockholm Convention on Persistent Organic
Pollutant ( 2001) ratified in 2004 , Basel Convention on the Control of Transboundary Movements
of Hazardous Wastes and their Disposal ( 1989) ratified 2003 .

EA also provides a framework for promotion of efficient decision-making in ensuring compliance

to environmental statutory requirements. EA enables implementation of EMS/EMP that ensures
environmental safeguards to mitigate significant negative impacts, avoid ecological damage and
large-scale irreversible loss of natural resource. It is an invaluable tool for environmental
management of implemented projects to ensure environmental safeguards by employing various
environmental management techniques such as Cleaner Production (CP), recycling, reuse and
sustainable consumption to ensure resource conservation and prevention of environmental
degradation.

2.2 Rwandan Policies Relating to Environmental Audits

The government in recognition of the need to protect the environment from adverse impact of
developmental activities requires the conduct of EIA and Environmental Audit (EA) of projects that
have significant effect on the environment. In 2006 the General Guidelines and Procedure for
Environment Impact Assessment was published to streamline the conduct of EIA and appraisal of
EIA reports in Rwanda. The Environmental Audit Guidelines streamline the conduct of
Environmental Audit in Rwanda for the improvement in project management to ensure a clean and
healthy environment for sustainable development. They are intended to serve developers,
agencies and individuals involved in the EA process.

There are relevant policies, laws, regulations that need to be taken into account while carrying
Environmental Audit in Rwanda. The policies that are relevant include the following:

2.2.1 The Mining Policy 2009

24
The Rwandan mining sector is currently in a state of transition. It has recently transformed from a
publicly-run to a private mining and at the same time is moving from a regional trading mining to
a local extraction and exporting mining. The focus of this policy is on cementing and hastening
this transition, recognizing the significant potential in the many products that could be made
available locally and building on recent progress. Since 2004, the existing regulation in mining
sector has been updating resulting in a promulgation of the revised “Mining Policy” in 2009.

The Mining Policy sets out clearly a framework of five strategic pillars that stem from an analysis
of the major constraints facing the mining. These pillars are effectively the desired outcomes of
the Mining Policy and should have a range of social, economic and environmental impacts.

Figure 1: Five pillars of the Mining Policy

The coordination of the mining sector is currently led by two institutions. MINIRENA has
responsibility for setting policy and preparing legislation, while RNRA has responsibility for
implementing the policy and regulation

2.2.2 National Environment Policy 2003

The overall objective of the National Environment Policy is to the improvement of human well-
being, the judicious utilization of natural resources and the protection and rational management
of ecosystems for a sustainable development. The Policy is premised on a number of guiding
principles which include economic growth based on a more rational utilization of resources and
consideration of the environmental dimension. It emphasizes improved management of the
environment at both central and local levels consistent with the policy on decentralisation and
good governance. The Environment Policy (2003) sets the overall goals for environmental
management in Rwanda. The government has ensured that all national policies reflected in Vision
2020 (GoR 2002) taking into account environmental protection as a priority (REMA 2007).
Environment is treated as a sector and a cross cutting issue in the Economic Development and
Poverty Reduction Strategy (EDPRS) document (MINECOFIN, 2007). The environment policy
provides for institutional and legal reforms. The implementation of environmental management
strategies employs Sector Wide Approach (SWAP), which brings with it the advantage of synergies
among the different development actors.

25
2.2.3 Other relevant Policies

Other relevant policies include the following:

 The Rwanda Vision 2020 gives as strategic actions inter alia institute the principle of
precaution to mitigate the negative effects caused to the environment by the
socioeconomic activities, to institute the “polluter pays” principle as well as preventive
and penal measures to ensure the safeguard of the environment and to require the
environmental impact study of any development project.
 National Land Policy 2002 is premised on the National Development Strategy of Rwanda
(Vision 2020). It calls for rational use and sound management of national land resources
and be based on master plans. It provides for land tenure systems, guiding principles of
land management, an effective & efficient land registry, and land transactions.
 National Gender Policy, 2010 highlights the principals that will guide sectoral policies and
programmes in the integration of gender issues in their respective social, cultural,
economic and political planning and programming.
 The Policy on Cultural Heritage, 2008 provides that cultural heritage must be the basis and
driving force to national development. Its management, conservation and development
should be tailored towards promotion of cultural tourism; environmental protection,
rational use of local natural resources and ecotourism development.
 The National Water Resources Management Policy 2011 aims at fair and sustainable access
to water, improvement of the management of water resources.
 The Health Sector Policy 2005 is aimed at improving the quality of and demand for services
in the control of disease through hygiene promotion.
 The National Human Settlement Policy 2007 is to improve the settlement conditions of the
urban population.
 The National Investment Strategy 2002 encourages the private sector to participate in the
provision water and sanitation systems in urban and rural areas at affordable prices for the
citizen.

2.3 Legal Framework

The laws that are relevant include the following:

2.3.1 The Constitution of the Republic of Rwanda 2003

The Constitution provides for the protection and sustainable management of the environment and
encourages rational use of natural resources.

2.3.2 Organic Law N° 04/2005 of 08/04/2005 Determining the Modalities of Protection,

Conservation and Promotion of Environment in Rwanda

The Organic Law is the most critical law which determines the modalities of protecting,
conserving and promoting the environment in Rwanda. Statements under specific and general
obligations in the Organic law imply collective efforts in environment management that calls for a
holistic that can be achieved by applying tools like EIA and EA. The relevant articles to
Environmental Audit are:

i) Article 3: Every person has the duty to protect, conserve and promote environment.
The State has a responsibility of protecting, conserving and promoting the
environment.

26
 ii) Article 6: Every person in Rwanda has a fundamental right to live in a healthy and
balanced environment. He or she also has the obligation to contribute individually or
collectively to the conservation of natural heritage, historical and socio-cultural
activities.
iii) Article 7: States the principles for Conservation and rational use of environment and
natural resources. (Conservation and rational use of environmental and natural
resources.).
iv) Article 8: 10 to 60 lists projects and activities that are subject to regulation by the
national laws of Rwanda.
v) Articles 49 to 59) provides specific obligations of the State for environmental
management.
vi) Articles 60 to 62 provides specific obligations of decentralized entities for
environmental management
vii) Article 65 of the Organic Law provides that a project cannot receive authorization for
implementation unless issued with a certificate of clearance (EIA Certificate of
Authorization).
viii) Article 67 requires that projects, programmes and policies that may affect the
environment shall be subjected to environmental impact assessment before obtaining
authorization for implementation.
ix) Article 69 stipulates that the environmental impact assessment shall be examined and
approved by the Rwanda Environmental Management Authority or any other person
given a written authorization by the Authority.

2.3.3 Other relevant laws

Other laws that are relevant to environmental audit which include the following:

 The Law No. 57/2008 of 10/09/2008 Law Relating to the Prohibition of Manufacture,
Importation, Use and Sale of Polythene Bags in Rwanda 2008 which prohibits the
manufacturing, usage, importation and sale of polythene bags in Rwanda.
 The Ministerial Order No. 003/2008 of 15/08/2008 sets out the requirements and
procedure for EIA including the selection of experts to conduct the EIA study.
 The Ministerial Order N°004/2008 of 15/08/2008 establishing the list of works, activities
and projects that have to undertake an environmental impact assessment highlights some
projects as follows; construction and repair of international and national roads, large
bridges, industries, factories, hydro-dams and electrical lines, public dams for water
conservation, rain water harvesting for agricultural activities and artificial lakes, large
hotels public building which accommodate more than one hundred daily, extraction of
mines and public land fills among others.
 Ministerial Decree No. 005/2008 (15/08/2008) laying down detailed inspection of
companies (industries) or activities which generate environmental pollution;
 Ministerial Decree No. 006/2008 (15/08/2008) regulating imports and exports of
substances that deplete the ozone layer and products and equipment containing such
substances;
 The Law No. 53/2010 of 25/01/2011 Establishing Rwanda Natural Resources Authority and
Determining Its Mission, Organisation and Functioning
 The Ministerial Order N°007/2008 of 15/08/2008 Establishing the List of Protected Animal
and Plant Species. This Order establishes the list of protected animal and plant species.
 Law Establishing the Rwanda Water and Sanitation Corporation, Law No.43/2008 of
09/09/2008 establishes the Rwanda Water and sanitation corporation with the purpose of
promotion of sanitation services in districts and in the city of Kigali in collaboration with
other institutions.

27
  Organic Law Determining the Use and Management of Land in Rwanda, 2005 The Law
provides for the land tenure system in Rwanda.
 The Law Relating to Expropriation in the Public Interest, Law No. 18/2007 of 19/04/2007
The Law determines the procedures relating to expropriation in the public interest.
 Law Establishing and Organizing the Real Property Valuation Profession in Rwanda, Law
No.17/2010 of 12/05/2010 this law aids the law on expropriation in terms of undertaking
valuation.
 The Environmental Impact Assessment Guidelines, 2006 provide which provide guidelines
and requirements for EIA in Rwanda. Projects with identified adverse impacts on
environment
 The Ministerial order N°002/2008 of 01/4/2008 determining modalities of land registration
defines the modalities for land registration, including the establishment of a Register of
Land Titles, procedures for the registration of titles to land and other interests in land,
transfers of title to land and other transactions related to land, and related matters.

2.4 Institutional Responsibility

2.4.1 Management and Administration of the Guidelines

The lead government ministry in charge of the environment is the Ministry of Natural Resources
(MINIRENA). It is mandated to ensure the protection and conservation of the environment and
ensure optimal and rational utilization of natural resources for sustainable national development.
Specifically, it is mandated do the following:

1. Develop and disseminate the sector policies, strategies and programs through:

 elaboration and dissemination of national policies, strategies and programs that aim at
conserving the environment and ensuring optimal and rational utilization of natural
resources;
 development of strategies to promote partnership and enhance capacity of private sector
and attract operators to invest in activities of environment and natural resources for
sustainable economic development;
 exhaustive assessment of Rwanda ground and surface natural resources and establish
appropriate mechanisms for their national extraction and promotion;
 Regulating the sector and related sub-sectors through the development of development of
laws and regulations to ensure rational utilization of natural resources and ensure
protection of the environment and conservation of natural ecosystems;
 Developing institutional and human resources capacities in the sector of environment and
natural resources and sub-sectors.

2. Monitor and evaluate the implementation of sector and sub-sectors policies, strategies and
programs through:

 Setting up and implementation of appropriate mechanisms and systems for monitoring

and evaluation of environment and climate change situation in the country as well as in
the region;
 Monitoring and assessing the implementation and mainstreaming of policies and laws that
enhance the protection of environment and the rational utilization of natural resources in
all cross-cutting sectors in the country;
 Monitoring the sector performance indicators and consolidating the data from
decentralized institutions;

28
  Submitting to the government periodic and annual reports on the impact of the sector
policies, strategies, programs and projects on sustainable national social economic
development.

3. Overseeing the institutions under supervision through:

 Guidance and orientations on the implementation of specific programs to be realized by

the institutions under supervision and Local Governments;
 Supervision and orientations on functioning of sector public institutions and promote
synergies between various actors intervening in the sector.

4. Mobilizing resources for the development of the sector and related programs through:

 Coordination of activities of mobilizing resources and supervise actions to ensure their

rational utilization in the sector development;
 Mechanisms put in place for promoting and development in the sector.

To implement MINIRENA sectoral strategies other Ministries are involved such as the Ministry of
Mining, and Animal Resources (MINAGRI), the Ministry of, Commerce, and Mining (MINICOM), the
Ministry of Infrastructure (MININFRA), Ministry of Local Government, (MINALOC), Ministry of
Finance and Economic Planning (MINECOFIN), Ministry of Justice (MINIJUST), Ministry of Gender
and Family Promotion (MIGEPROFE), Ministry of Health (MINISANTE), Ministry of Education
(MINEDUC) are all involved to ensure sustainable development in line with the efforts of achieving
Millennium Development Goals (MINECOFIN, 2007). Public institutions such as National Parks
(ORTPN), Rwanda Bureau of Standards (RBS), as well as higher teaching and research institutes
such as the University of Rwanda (UR) which has been recently created and gathering all formers
public higher learning institutions like National University of Rwanda (NUR), Kigali Institute of
Science, Technology (KIST), ISAE, Umutara Polytechnic (UP) and the Institute of Management
(SFB), Rwanda Institute for Science and Agricultural Research (ISAR), Institute for Scientific and
Technological Research (IRST) also are important institutions for environmental management in
Rwanda.

REMA established under article 65 of the Organic Law No 04/2005 of 08/04/2005 is mandated to
coordinate and oversee all aspects of environmental management for sustainable development. It
is the principal agency with the mandate and legal remit for implementing provisions of the law
for safeguarding the environment. One of the key functions of REMA is the implementation of
Environmental Impact Assessment (EIA) and Environmental Audit (EA). EIA and EA are tools for the
prevention and control of environmental impacts of development projects. Article 66 provides for
the establishment of committees responsible for conservation and protecting the environment at
the Provincial, City of Kigali, District, Town, Municipality, Sector and the Cell levels. The
organization, functioning and their responsibilities are determined by Prime Minister’s Order.

There are also both International and Non-Governmental Organizations (NGOs) and Parastatal
agencies that are involved in environmental management activities in Rwanda. These
organisations include among others the Global Environment Facility (GEF), United Nations
Environment Programme (UNEP), United Nations Development Programme (UNDP), United Nations
Food and Mining Organisation (FAO), United Nations Children’s Fund (UNICEF), United Nations
Population Funds (UNFPA) World Bank (WB), USAID.

2.3.3 Roles and Responsibilities of Different Stakeholders in Environmental Audit

The EA process involves many stakeholders as indicated below.

29
(i) The Rwanda Development Board (RDB)

The RDB is established as a specialized organ under Organic Law No. 53/2008 of 02/09/2008
Establishing Rwanda Development Board and Determining its Responsibilities and Functioning. It
approves the whole EIA process from screening, preparation and approval of terms of reference,
review and issuance of the EIA approval certificate. It is the first point of contact for a developer
and should be well versed with the EIA process and the government and other agencies that need
to be consulted as each case may require.

(ii) REMA

REMA has a responsibility to organise the EA procedure by guiding the EA process, reviewing EA
reports based on the terms of reference (ToR) and taking decisions on the EA reports and the
audited projects, activities or programs. REMA is also responsible for monitoring implementation
of environmental protection measures recommended by EA reports. In addition REMA’s
responsibility relevant to EA is to:

a) Take stock and conduct comprehensive environmental audits and investigations, to

prepare and publish biannual reports on the state of natural resources in Rwanda.
b) Review and approve environmental audit reports of any field of socio economic activities
undertaken by any agency.
c) ensure monitoring and evaluation of development programs in order to control observance
of proper safeguards in the planning and execution of all development projects, including
those already in existence, that have or are likely to have significant impact on the
environment.
d) Participate in the set-up of procedures and safeguards for the prevention of accidents and
phenomena which may cause environmental degradation and propose remedial measures
where accidents and those phenomena occur.
e) render advice and technical support, where possible, to entities engaged in natural
resource management and environmental protection

(iii) Client (auditee or developer)

The developer has direct responsibility for the project and should provide necessary information
about the project at all stages of the EA process. Developers hire experts to undertake EA studies
on their behalf. Developers have the responsibility to implement the environmental management
plan including mitigation measures as proposed in the EA report and carry out periodical
environmental monitoring and auditing. Specific responsibilities of the auditee or client include
but not limited to:

 Determining the need for the audit;

 Defining the objectives of the audit;
 Determining the scope of the audit together with the lead auditor;
 Selecting the auditors/audit firm;
 Approving the audit criteria;
 Approving the audit plan;
 Providing the authority and resources to conduct the audit;
 Informing employees about the objectives and scope of the audit as necessary;
 Obtaining full cooperation from employees and initiating the EA process;
 Appointing appropriate competent staff including a coordinator to accompany and assist
the audit team;
 Providing access to facilities, personnel, relevant information and records as requested by
the auditors;

30
  Cooperating with auditors to permit the audit objectives to be achieved; and,
 Receiving and reviewing the audit report.

(iv) Environmental Audit Experts (Auditors)

EA experts are professionals registered with REMA to undertake Environmental Audits. They help
the developer to carry out EA, design mitigation measures, prepare EA report, and design
environmental management and monitoring plans. Auditors comprise a lead auditor and auditors
that constitute the EA study team each with the following responsibilities:

Lead auditor: his/her responsibilities should cover:

 Determining the scope of the audit in consultation with the client and REMA;
 Getting the relevant background information to meet the objectives of the audits;
 Ensuring that the requirements for the audit are followed as indicated by the EA
guidelines;
 Forming the EA study team;
 Directing the EA process activities in accordance with the guidelines on general principles;
 Planning and supervision of the EA process and representing the EA team;
 Reporting to the client and REMA on the EA process activities and conclusions;
 Making recommendations to the client (if agreed upon) in the scope of the EA.

Auditor: his/her responsibilities should cover:

 Following the direction of and supporting the lead auditor in the EA process;
 Carrying out assigned tasks objectively, effectively and efficiently within the EA scope.
 Collecting and analysing sufficient audit evidence to determine findings and reach audit
conclusions.
 Preparation of the EA document under the direction of the lead auditor.

(v) Lead Agencies

Lead agencies such as government ministries or departments have the responsibility for
management and protection of environmental resources, public health and socio-economic
development. Lead agencies have the responsibility to take part in EA of projects under their
sectors. They provide valuable technical information to EA experts during EA studies and are
involved in the review process.

(vi) The Districts

Districts are responsible for planning environmental management activities and the
implementation of decentralised activities.

(vii) The Public

Environmental Audits are generally considered as private and confidential because many
organisations see public scrutiny as intimidating and fear the outcome may affect company image.
However the public can be helpful during the audit by highlighting areas that are of priority
concern to them. Local communities close to a facility can assist in monitoring compliance. The
community can report to REMA any observable or felt impacts of a facility deemed harmful to
them and the environment.

(viii) International Funding Organisations

All international funding organisations require EIA for their supported projects. They therefore
expect the funded projects to follow the EIA recommendations that include an EMS/EMP consisting
of monitoring and periodical Environmental Audits.

31
(ix) Academic Institutions
Members of academic institutions are commonly co-opted on EA Technical Committees. They also
institutionalise environmental education in their curricula. Courses on Environmental audits can
be taught both at undergraduate and post graduate levels.

32
 3. AN OVERVIEW OF THE MINING SECTOR AND ENVIRONMENTAL IN
RWANDA
3.1 Background to the Mining Sector in Rwanda

The Rwandan Government is striving to build a well regulated and standardized mining sector to
ensure rational utilization of mineral resources for sustainable national development. Mining in
Rwanda mainly refers to the 3T minerals (tin, tungsten, and tantalum ores) which are associated
with a geologically favorable environment (the Kibaran system) stretching from Burundi through
Rwanda to southern Uganda, and encompassing wide parts of the eastern provinces of the DR
Congo. The region is known for additional potential of other minerals, in particular gold. About
20,000 miners are employed in the national mining sector through approximately 250 mining and
exploration companies. In 2012, mining has been the number two forex earner with an aggregated
value of US$ 137m.

While the mining sector is thus of critical importance for the development of Rwanda, it is also
facing considerable challenges: the artisanal, partly informal nature of many mining activities
which poses challenges on efficient regulation, as well as regional risks for conflict associations
with parts of the eastern DRC, which has caused a stigmatization of minerals originating from the
Great Lakes region. In order for the mining sector to meet its goals within the EDPRS, a number of
measures including building domestic mineral extraction and processing capacity; developing a
service hub for mineral processing for the sub region and enhancing locally produced construction
materials need to be undertaken. These will have the potential to promote private sector
participation in exploration, mining and processing, and promote value addition of quarry products
to reduce the importing of construction materials. Compliance with Government regulations and
policies remains one of the most forceful drivers of environmental performance for most
companies, as it requires them to take mandatory actions or meet set standards. Strengthening
the efforts for integration of environmental issues in the sector has been done through conducting
SEAs, EIAs, the use of standards, or other regulatory mechanisms to contribute to sustainable
development.

These EA Guidelines for Mining Sector will therefore support operationalization of the existing
policy and legal instruments including SEA for policy reviews and EIA for effective project
implementation. Further, reinforce the regulatory environment to guide the private sector in
contributing to the financing of environmental management and protection, especially where it
concerns preventive actions that mitigate the impact of their development activities.

3.2 Minerals Mined in Rwanda

The key minerals currently being mined and traded in Rwanda are cassiterite (SnO2), wolframite
(WO3), Colombo-tantalite (Ta2O5) and gold. Other key minerals include ambrigonite, beryl and
semi-precious stones such as tourmaline, topaz, corundum, chiastorite, amethyst, sapphires, opal,
agate and flint. They occur as primary, alluvial or elluvial deposits. Construction materials which
can be used in their primary state or given a higher value are abundant. These include;
amphibolites, granites and quartzites, volcanic rocks, clay, sand and gravel.

Mining resources such as dolomite, mining sand (glass and foundry), kaolin for ceramic and
paper, quartz and feldspar exist in substantial amounts. Resources which can be used in soil
upgrade for agriculture include; travertine, peat and trachytes. Energy substances that need
development in the sector include peat and geothermal potential. Strong indications of
polymetallic (Cu, Zn, Pb, Mn) hydrothermal sediment-hosted stock work and/or replacement
mineralization was identified. The size of the prospective areas is considerable, reaching 100 km2.

33
3.3 Impacts of mining Activities

Mining activities often impact significantly on the environment. For instance:

 Sand harvesting and quarrying are already showing some significant environmental impacts,
including resource depletion, energy consumption, waste generation and emissions of air
pollutants.
 The dangers to human life and health associated with mining include the displacement of
people, land use changes, dust and noise pollution.
 Preparation of ores which uses a lot of water constitutes a major pollutant of stream water in
Rwanda. For example, the waters draining the mining sectors of Rutongo and Gatumba pollute
the rivers of Nyabarongo and Nyabugogo by sediments of clay and sand which they transport
over long distances. It is this considerable mineral load which partly gives them the brown
colour that is characteristic of the rivers in Rwanda.
 Mining and quarrying produce massive rejects which appear in nature in the form of enormous
lots of earth and rocks.
 Erosion from rain water transports the mineral residue towards the valleys where streams are
filled and covered by the residue which may be toxic to biodiversity.

3.4 Mining Licence Requirements

The following Licenses are required for miners/developers before mining takes place;

 Prospecting license (for 2 years, non-renewable)

 Research license (for 4 years, renewable once)
 Mining/exploitation license (for 5 years, renewable if the deposit lasts)
 Concession license (for 30 years, renewable if the deposit is still economic).

3.5 Procedure for obtaining Exploration & Exploitation Licenses

a) Exploration license - the following documents/Conditions are required;

 Establish a Rwandan company
 Digital map of area being applied for
 Business and action plans.
 Application letter.

b) Exploitation (Mining) License – the following documents/Conditions are required;

 Establish a Rwandan company.
 Digital map of the area being applied for
 Research License
 Business and action plans
 Certificate of environment impact assessment (EIA)
 Application letter.

Annex 1 provides a list of mining activities that require Environmental Audits. The five stages in
the life of a mine are summarized in Annex 13.

34
4. SPECIFIC ENVIRONMENT AUDIT GUIDELINES FOR MINING PROJECTS
4.1 Choosing and designing the audit

This chapter is designed to help auditors make sense of all impacts that may arise due to mining
activities. This chapter mainly includes the following four basic steps as shown in the Table 3
below.

Step 1: Identify the environmental threats of mining

Step 2: Identity the government’s responses to these threats and relevant players
Step 3: Choose audit topics and priorities
Step 4: Decide on audit approaches: scoping the audit

Table 3: Basic steps for choosing a topic and approach for an environmental audit on minerals and mining
Step 1: Are there any mineral and mining activities in the country? What are the main threats
to the environment caused by mineral and mining? (identify the mining stages and threats to
environment)
General Reduction of Other pollution impacts
environmental biodiversity
impacts
Potential water Depletion of Damage to historic and cultural resources
problems / natural resources
pollutants
Possible air or soil Occupational Land degradation
contaminants health impacts
Step 2: What are the government responses and who are the players? (Adequate stakeholders
analysis should be done)
WHAT WHO HOW
Environmental Environmental By enforcing and monitoring the compliance with the
policy design and regulation agencies regulations
regulations
Dealing with acid Research initiatives Installing a water treatment plant, Passing the water
drainage and programmes through an artificial wetland in which organic matter,
e.g. Mine, Drainage bacteria and algae work together to filter, absorb
and precipitate out heavy metal ions and reduce
acidity
Tailings storage The mining Good design, close consistent routine attention over
facilities. company a long period; Ensure that all designs are based on
Land-use planning the highest design standards possible; Have an
and management international system certification for designers or at
(Agenda 21); least some formal pronouncement by engineering
surveillance; bodies as to the minimum qualifications for
resource-fees undertaking such task.
(royalties)
Step 3: Choose audit topics and prioritize
Potential water problem pollutants; possible air or soil contaminants; general environmental
impacts; other pollution impacts
Step 4: What audit approach to use?
Financial Performance Public education
management and measurement and
regularity results
Compliance with Accountability, Reporting to client and public

35
agreements, laws coordinator and
and policies capacity
Policy coherence Scientific research
and monitoring

These steps are often included in the planning stage of an audit but they are not carried out
explicitly. We recommend that in the mining audit the steps should be followed. These steps
should be used to define the objectives, scope, and criteria of a single audit on minerals and
mining. During the planning stage auditors are advised to understand the environmental problem
and governmental responses in mitigating the negative consequences in the respective country.
Further, auditors should prioritize and limit the audit area. We elaborate on the four steps below.

4.2 Step one: Key questions while Auditing Mining Activities

Key Question: What kind of environmental problems arise?

Environmental problems differ from one type of mineral to another. However, there are some
common environmental impacts e.g. loss of habitat. Auditors could consider the activities involved
at every stage of the mining process – in other words, the prime drivers of the environmental
problems. They could include:

 exploration – drilling and exploration excavations,

 project development – construction of roads and buildings, erection of treatment plants,
overburden stripping and placing,
 mine operation – heap-leaching of tailing dumps, bio-leaching of surface heaps or deposits
and solution mining of buried deposits,
 beneficiation – on-site processing may include combination to reduce particle size, or
flotation using selected chemicals, and
 mine closure –incompatible landscape features and contamination of soil or water.

Key Question: What are the short and long-term effects on the environment, economy and
society?

The main affected sectors are the land and human settlement sectors, because mining displaces
people, undermines their livelihoods, and causes significant changes in population dynamics. The
other environmental problems affect the water sector – water is polluted and becomes scarce.
Another sector highly affected by mining activities is the health sector – people living in and near
mining complexes get affected by the pollutants. On the other hand, the planning and
development sector also is not left untouched. Infrastructure facilities such as roads, hospitals,
and schools are improved by mining companies. Employment opportunities are enhanced but there
is also economic disparity, cost of living increases, and frustration among the people in and near
the mining area.

Table 4: Links between mining threats on the environment, society and the economy, their causes and
consequences
Threat to the Causes Consequences
environment
General  Destruction of natural habitat at  Large – scale waste disposal
environment the mining site processing site operations may present a risk of
impacts and at waste disposal sites. catastrophic failure of tailings
Ecology and  Destruction of adjacent habitats dams or heaps, collapse of dump

36
biodiversity as is result of emissions and
Resources issues discharges.
Social concerns  Changes in river, groundwater
regime and ecology due to flow
modification.
 Alteration in water tables
 Changes in landform
 Land degradation due to
inadequate rehabilitation after
closure or lack of it.
 Land instability.
 Danger from failure of structures
and dams.
 Abandoned equipment, plants,
building and waste.
 Resettlement
Potential water  Suspended solids and sediment
problems / from runoff and processing
pollutants operations.
Hydrogeology  Acids from various processes.
and water  Heavy metals from waste and
quality concentrates around the site;
sulphate, thiosulphate,
polythionates, etc., from acid
drainage; arsenic and other salts
from oxidised mine waters.
 Mercury if used in the process, or
from ores.
 Cyanide if used in leaching
processes.
 Oil and fuel from ancillary
operations.
Possible air  Dust from the site or from
contaminants processing.
Air quality  Natural gas from underground
mines.
 Heavy metals, organics.
Other pollution  Drainage from mining sites.
impacts  Pollution from mining operations
Occupational and in riverbeds.
public health  Effluent from minerals processing
concerns operations.
 Sewage effluent from the site.
 Oil and fuel spills.
 Soil contamination from
treatment residues and spillage
of chemicals.
 Leaching of pollutants from
tailings, disposal areas and
contaminated soils.
 Air emissions from minerals
processing operations.
heaps, such failure may lead to
major loss of life at the site or in
nearby communities i.e. loss of
natural habitat, loss of rare and
endangered species.
 Loss of agricultural land and
forestry resources.
 Loss of livelihood and cultural
heritage or religious sites.
 Effects on indigenous people
 Oxidation of iron content adds
discoloration and deoxygenating of
waters due to the problems of
metal toxicity.
 Excessive discharge will damage
natural ecosystems and affect local
fisheries and may deprive
downstream population of a clean
water supply.
 Wildlife habitat loss.
 Alienation of land.
 Re-vegetation failure.
 Effects on surface and ground
water resources.
 Pollutants disease or death.
 Increase potential for respiratory
disorders.
 Hazards from process chemicals or
explosive.
 Severe poisoning – potential
increase in disease vectors.
 Alienation of land as a result of the
generation of slag.
37
  Dust emissions from sites close to
living areas or habitats, and
sulphur dioxide emissions to air
discharge of toxic chemicals such
as sulphuric acid and ammonia
used during processing.

Step 2: Identify the government’s response

In general, governments play an important role in protecting the environment in many ways. They
“mainstream” environmental matters into the economy, i.e. by integrating environmental issues
in the development planning process. Essentially, the government makes the environment feature
in decision making, and in the formulation, implementation and evaluation of policies, strategies,
programmes and projects. SAIs do not audit the environment, they audit the impact of
government policy and programmes. They need, therefore, to understand what the government is
doing to mitigate or prevent environmental threats through programmes and policy tools. In
identifying the government’s response, the auditor has to know if the government has mapped the
environmental, social and economic problems related to mining, through national commitments,
policies, programmes, monitoring, and enforcement of its regulations.

Key Question: What is government doing about environmental threats of mining and minerals? Are
there obligations that will influence national policies? Can they be used as audit Criteria?
National laws related to mining can apply across the full spectrum of the mining life cycle, from
initial ownership and access rights for exploratory purposes, through mining and processing, to the
use of the end product or disposal of waste materials. Governments have a variety of legal powers
and tools that they can use to address environmental problems and activities. Legal powers
include legislation (acts of parliament or congress), regulations, permits, licence bylaws, and
ordinances. Governments have different roles and responsibilities over the whole mining process,
including environmental issues associated with mining.

Environmental regulations
Environmental laws and regulations have the primary goal of ensuring the protection of
communities’ ecological and social values. They provide a stable framework within which
investment and operational decisions can be made. The environmental approach of state-owned
enterprises can reflect inefficient operating regimes, excess capacity, breakdowns and shutdowns,
and poor management procedures that often contribute to worsening pollution. This is true,
because environmental degradation is greatest in operations working with obsolete technology,
limited capital, and poor human resource management. It is also relevant for small-scale mining
operations. Matters covered by environmental regulation may include:

 environmental impact assessment or other environmental planning,

 nature conservation, national parks, protection of flora and fauna, endangered species,
 cultural heritage, indigenous cultures, landscape protection, and scientific sites,
 water quality protection,
 clean air laws to limit air emissions and human exposure,
 control of soil contamination and land protection from weeds and pests, and
 other issues, such as noise, waste disposal, and chemicals control sometimes regulated by
environmental laws. Mining legislation may include regulatory provisions relating to
 safety of structures and operations, limiting exposure to chemical hazards,
 wastewater retention and treatment, management of contaminated runoff,
 soil erosion control and re-vegetation during and after operation, and
 solid waste disposal; and restoration of sites and disposal of equipment. Of the matters
generally covered by environmental regulation, the major issues for mining companies are

38
 emissions (effluent and air emission standards); habitat and wildlife protection; and
rehabilitation and mine safety, including tailings dams.

Regulatory controls and instruments

The instruments available to governments for influencing environmental practices in the mineral
mining can be divided into the following three categories:

 environmental regulations (administrative regulations),

 education and training, and
 economic instruments

Key question: Do the environmental regulations include provision for mining? Is there EIA
requirement for mining? Is it followed? Are the regulations efficiently enforced?
In order to encourage a high level of government accountability and achieve continuous
improvements, a regulatory system should advocate a pollution reduction ethos and involve
negotiation between the government agency and the mining company on acceptable standards.
Prescriptive regulations can be unduly restrictive and quickly become out-dated in the face of
advances in technology. The Government’s role is to establish the standards and to enforce them
through monitoring operations and levying penalties on operators that do not observe them.
Command and control mechanisms tend to rely on administrative agencies and judicial systems for
enforcement. Thus, in countries where a system of environmental regulations and standards does
not yet exist, the mining company must itself ensure that all likely issues are competently
addressed. The disadvantage of this approach is that mining compliance with environmental
requirements might not be achieved.

Education and training

Legal provisions must be enforced if they are to be meaningful, and enforcement problems often
result from shortages of adequately trained staff and equipment. Hence, the importance of
education and training programmes (particularly and increasingly proactive programmes of
research, information, education and training, incentives and awards for good performance)
should be undertaken to supplement the regulatory approach. These programmes can be very
effective in small operations, such as small-scale mining. The mining licence and permit fees in
many countries are established so as to recoup at least some of the costs of these programmes.

Mining codes
Mining is unique among mining activities in requiring a set of regulations of its own, usually
embodied in a mining law or mining code. A country’s mining code is the combination of statutes,
regulations and agreements that govern the allocation, tenure, and operation of mining rights.
Separate legislation usually covers foreign investment, taxation, foreign exchange, labor, and
environmental and other regulatory matters. Increasingly, environmental protection is included in
mining legislation and so has to be viewed as part of the mining operation, alongside exploration,
mining, metallurgical processing, and marketing.

Institutional issues
It is becoming more common for environmental ministries to focus on the development of
environmental protection criteria and standards, the approval of planning procedures, and the
review of Environmental Impact Assessments (EIAs), while mining ministries undertake the
implementation work of administering plant permits, regulating discharges, and supervising
rehabilitation bonds. Appropriate practices should be identified and required outcomes and
objectives should be clearly defined. These practices and objectives then need to be promoted at

39
the different levels of Government to ensure consistency of approach and effective policy
coordination between Government agencies. In addition, the role of the various Ministries
concerned, such as Finance, Planning, Environment, Land Resources and Labor, needs to be
clearly defined in relation to mining operations, thus avoiding duplication of functions. It is
essential to adopt a coordinated approach towards environmental policy and its implementation
by the various Government agencies involved.

Policies and programmes

Governments can formulate environmental policies. Policies tend to set directions, but are usually
not prescriptive or enforceable. A policy might be a statement of intent or of a desired outcome.
In some cases, policies can be supported by specific procedures (action plans) and (funded)
programmes. For instance, governments can have a number of enacted policies, strategies,
programmes and legislation to address environmental concerns. However, successfully
implementing programmes requires that they have enough monetary resources, skilled people,
goals and authority. Governments should set performance measurements for implementing their
policies or programmes.

The national budget

There are a number of tools that can help to ensure the integration of environmental concerns in
the planning process. These are discussed below:

Environmental policy instruments

The national budget is one of the tools the government can use to implement policy. How
effectively the environment is mainstreamed into various budgetary provisions, implicitly or
explicitly, is ultimately the measure of how effectively or otherwise the government can effect
environmental conservation in mining areas.

Environmental assessments of mining activities

Another policy instrument that helps to balance the imperatives of economic development and
environmental conservation is the Environmental Assessment (EA). EAs are observed at two levels;
the Strategic Environmental Impact Assessment (SEA) and the Environmental Impact Assessment
(EIA). According to the UNEP, Environmental Impact Assessment (EIA) as a systematic process to
identify, predict and evaluate the environmental effects of proposed actions in order to aid
decision making regarding the significant environmental consequences of projects, developments
and programmes. EIA helps the stakeholders with the identification of the environmental, social
and economic impacts of a proposed development before a decision is taking on whether or not to
proceed. Particular attention is given in EIA practice to preventing, mitigating and offsetting the
significant adverse effects of proposed undertakings. National laws require every mining project
to conduct an EIA/study before the mining project begins. Normally, the decision about whether
the proposed project will proceed is based on the EIA report. Among other things, the EIA report
should include the following objectives:

 To meet the environmental requirements and directives under statutory and legislative
instruments such as acts and regulations, standards, international agreements etc.
 To provide a single document that will satisfy the various authorities that are concerned
with the regulation of the environmental impacts of mining.
 To describe the relevant baseline environmental conditions at and around the proposed
site.
 To describe briefly the mining method and associated activities so that an assessment can
be made of the significant impacts that the project is likely to have on the environment
during and after mining.
 To describe how the negative environmental impacts will be managed and how the positive
impacts will be maximized.

40
  To set out the environmental management criteria that will be used during the life of the
project so that the stated and agreed land capability and closure objectives can be
achieved and a closure certificate issued.
 To indicate that resources will be made available to implement the environmental
management programme On the other hand the Strategic Environmental Assessment (SEA)
according to the UNEP refers to a formal, systematic process to analyze and address the
environmental effects of policies, plans and programmes and other strategic initiatives.
This process applies primarily to development-related initiatives that are known or likely
to have significant environmental effects, notably those initiated individually in sectors,
such as mining sector, or collectively through spatial or land use change. As with EIA, SEA
includes social, health and other consequences of a proposed action and their relationship
to sustainable development concepts and strategies.

Why is SEA important?

SEA extends the aims and principles of EIA to the higher levels of decision-making when major
alternatives are still open and there is far greater scope than at the project level to integrate
environmental considerations into development goals and objectives. In addition, SEA can provide
early warning of large scale and cumulative effects, including those resulting from a number of
smaller-scale projects that individually would fall under thresholds for triggering a project EIA.

How does SEA compare to or differ from EIA?

Some of the distinctive characteristics of SEA compared to EIA include:

 Greater uncertainty about the effects of a policy as compared to a project (concrete

actions);
 Broader range of environmental consequences to be considered (from implications to
impacts);
 Wider set of linkages and trade-offs with economic and social issues (e.g. a national
energy policy or plan compared to a power station); and
 Larger scale/ longer time frames to take account of environmental effects and
consequences (e.g. implications of CO2 emissions for climate change). Yet SEA and EIA also
have many similarities and a common foundation. SEA has developed largely as a response
to the levels and types of decision-making not covered by EIA. In doing so, SEA has
derived, adapted and implemented EIA arrangements, procedure and methodology,
particularly at the plan and programme level. Other process models also have been
adapted, particularly at the policy level where integrative appraisal and environmental
“tests” compress the basic steps followed in EIA, such as screening and reporting.

Challenges for environmental assessments

The challenges posed to environmental assessments of mining projects are twofold. First, to
ensure that environmental, social and health costs of the proposed mining project are given
adequate consideration in determining the economic viability and acceptability of alternative
project scenarios. Secondly, to ensure that adequate control, mitigation or protection measures
are incorporated in proposed mining project design, implementation and mining decommissioning
plans. This requires both effective environmental legislation and enforcement by regulatory
institutions, and sound environmental management practices by private and public sector mine
operators.

Step 3: Choose audit topics and priorities

The important thing is to define the focus of the audit examination. Step 3 includes detailed
information (including possible audit criteria, players, and researchable questions) on the
following possible audit topics:

41
  general environmental impact,
 potential water pollutants,
 possible air contaminants, and
 other pollution impacts.

It is up to the SAI to choose the audit topic and set priorities, which would answer the following
questions:

Key Question: What are the risks relating to the environment and government’s commitment?
The SAI will need to carry out a risk analysis in order to determine whether its action will be
appropriate and useful. When assessing threats to the environment caused by mining, the auditor
should consider the quantum of the actual and potential impact on the environment, society, and
the economy. When ascertaining the damage to the environment, the auditor should question how
reversible that damage is. Irreversible damage is especially risky. Furthermore, the auditor should
consider how intensive the damage is, because it is a priority to address and prevent acute
threats. Generally, auditors rely on their government’s assessments. Nevertheless, if needs arise,
they may ask assistance from experts in the field. It is also important for the auditor to examine
the government’s response regarding the identified environmental threats and its capacity to
meet targets. The auditor should also consider the government’s behavior in terms of abiding by
the principles.

Key Question: Are the topics auditable?

First and foremost, the auditor should consider and decide whether there are suitable sources of
criteria against which to conduct the audit.

 Has the government signed international agreements relating to mining and processing
minerals, and implemented the international obligations in its country?
 Has the government enacted laws and regulations in relation to mining and minerals
activities?
 Has the government made policy statements on the issue?
 Are environmental threats caused by minerals and mining included in national budgets?
 Does the government receive external funding from international organizations?

After determining where their action will be most useful and choosing the topic, auditors can start
planning the audit.

Step 4: Decide on audit approaches (scoping the audit)

Step 4 is the last step. For this last step, the auditor needs to select an audit approach and choose
audit objectives, audit criteria, lines of enquiry and methodology for the audit. Normally
governments have a variety of legal powers and tools that they can use to address environmental
problems and activities. Legal powers include legislation (acts of parliament or congress),
regulations, permits, licenses, bylaws, and ordinances. Governments have different roles and
responsibilities over the whole mining process, including environmental issues associated with
mining. The standards applied to the conduct of audits looking at environmental issues for mining
and minerals activities should be no different than any other audit. An environmental audit of
mining will require the usual four phases of any audit - planning, field work, reporting and follow
up. The essential objectives of making a difference, and promoting accountability and best
practice remain unchanged. A successful audit will often revolve around some basic questions of
management.

 Is there anyone in charge?

42
  Is there adequate planning that includes mile stones, performance measures, goals and
expected results?
 Does the organization have sufficient expertise at hand to discharge the responsibilities it
is charged with?
 How well are the various organizations working together?
 Is accountability clearly defined? Is reporting clear, relevant, understandable and timely,
does it include results?
 Is there adequate measurement of results against goals and targets?
 Is the relevant information being used to make sound decisions?
 Does the organization have adequate arrangements in place to assess how effective their
actions are, and if so, what the results have been?

The following are some possible areas of Auditing in mining projects.

Financial management and regularity

Using traditional financial audit techniques, auditors can investigate the use of public funds in
projects and programmes that focus on conservation of the environment in relation to minerals
and mining. Are the funds spent on environmental conservation in relation to minerals and mining
programmes correctly administered, according to spending authorities and regulations?
• Are adequate financial resources allocated to protection programmes?
• Is the disbursement of funds monitored?
• Against what criteria is the disbursement of funds measured?
• Do official trade-offs exist in policies? If so, how do the estimated benefits balance
against the losses in environmental conservations caused by minerals and mining?

Compliance with agreements, laws, and policies

An audit of environmental conservation in relation to processing minerals and mining can address
the consistency of government strategies, actions, and programmes with laws and regulations, or
with the international conventions, to which the country is a signatory. It may answer the
question: Is the government meeting commitments it made in treaties, laws, policies and
programmes? The following are some lines of enquiry.

 Are there international agreements that protect the environment against the
environmental threats caused by processing minerals and mining within the country?
 Is the country following the rules and agreements determined by the international
conventions that it is a signatory to?
 Has the government enacted laws and regulations to implement its international
commitments and domestic policies?
 Are there any conflicts or gaps between national policies on environmental conservation
against processing minerals and mining and the country’s environmental laws?
 Are environmental laws and regulations being adequately enforced?
 Is there any conflict between national policies and the international conventions that the
country is a signatory to?

Compliance with national and international obligations

International agreements and conventions on mining are important instruments when it comes to
preventing damage to the environment: It is therefore imperative that SAIs keep parliamentarians
informed of how well executive governments fulfill their international obligations in this respect.
In its most basic form, the audit of compliance with international obligations can address whether
the government is ensuring that the international obligations ratified by the country are fully
implemented in national laws and regulations. Furthermore, it is important to evaluate how
effectively the obligations are fulfilled and whether required measurement and reporting systems
are in place and providing correct and timely information. The audit of international obligations is

43
an area in which it is especially useful for SAIs to co-operate. Such co-operation might yield
economies of scale because SAIs can help each other in the formulation of good audit questions
and the collection of background information. It might also be useful for countries – and for the
environment – to get an unbiased view of how well a participant is performing relative to other
participants or to a group of such countries.

Policy
Auditing the impact of policies and programmes on environmental conservation against the
environmental threats inherent in processing minerals and mining can be valuable. Interesting
lines of enquiry include:

 Are government policies being complied with?

 Has the government developed policies that address the environmental pollutions caused
by mining sector in the country?
 Do the policies deal with the most important threats?
 Have general policies on minerals and mining and environmental conservations been
addressed, specified and executed in laws and other legal instruments such as plans and
budgets?
 What kinds of changes can be suggested that would make national policies achieve better
results?
 Are government programmes efficient?

Performance measurement and results (agencies and government programmes)

Audits of environmental conservation for processing minerals and mining can assess the
performance of government programme’s actions to deal with threats to, and ensure the
conservation of, the environment. SAIs may wish to evaluate the traditional three “E”s –
effectiveness, efficiency, and economy – of the programmes. They may also wish to assess the
processes used to define and measure success and the results of these processes. Such
assessments can be achieved by answering the following questions:

 Have the relevant agencies defined expected results for their programmes?
 Have they developed indicators and measures for the results and are the indicators and
measures being monitored and tracked?
 Is the data used to measure performance reliable?
 Are the policies and programmes on environmental conservation for processing minerals
and mining achieving their objectives and intended results?
 Why are policies and programmes not achieving their objectives and intended results, and
how can the causes be countered?

Public education
National and international environmental protection programmes often have a public education
component. Large sums of money can be spent even though the success of these programmes has
not been measured. SAIs can include, among others, the following lines of enquiry:

 Is the government allocating appropriate funds for public outreach and education at each
phase (formulation, planning implementation, and evaluation) of a policy?
 Is the government encouraging the public and private sector to protect the environment
against unmanageable mineral processing and mining in terms of polluting the
environment?
 Has the government integrated the mineral processing and mining environmental concerns
into its public outreach strategies?
 Is the government measuring its public outreach results?

44
Accountability, coordination and capacity
Because environmental conservation topics cut across many government entities and other
players, SAIs could assess how departments and agencies have demonstrated good governance. For
instance, whether they can meet their responsibilities for environmental programmes and actions,
and whether they have mechanisms to coordinate those actions. The assessment can be achieved
through answering the following questions.

 Are the roles, responsibilities, and accountability of relevant entities (for example,
ministries and departments) clearly defined?
 Are all necessary mechanisms to coordinate action in place?
 Do the entities have adequate financial and human resources to carry out their roles and
responsibilities?
 Have the entities developed robust internal management system?

Scientific research and monitoring

The government’s capacity to undertake research and monitor the level of pollution in the air;
water; land degradation and human health effects from minerals and mining activities ought to be
examined. In many countries this responsibility is legally defined. The following are suggested
lines of enquiry.

 Does the government have the scientific knowledge (in-house or consultant-based) to

prioritize its action on the threats to the environment resulting from processing minerals
and mining?
 Are there adequate systems in place to monitor the status of levels of pollutants in the air,
water, land and human health as a result of processing minerals and mining?
 Is the government developing and maintaining database on mining’s environmental effects
either in house or with research Institutions?
 Is information shared between the national and international monitoring systems?
 Does the public have access to information on monitoring activities?

Reporting
The reporting requirements of public policies can be an important source of audit evidence. For
example, many international environmental agreements require that national governments report
to United Nations agencies or other international agencies (E.g. donor agencies). In addition,
regulated entities within a country may be required to report to regulatory agencies that in turn,
may report to their Parliament or equivalent.

Proper monitoring, reporting and accountability processes – which include collecting data,
performing analysis and reporting findings – should be in place. SAIs can ensure that such reports
and performance comply with appropriate standards, rules, and regulations. SAIs may consider:

 How are departments and agencies reporting their results?

 Are departments and agencies meeting international and national reporting obligations?

Summary of Audit Approaches

Table 5 summarizes the many possible ways auditors can combine mineral processing and mining
environmental topics and audit approaches. An environmental audit of mineral processing and
mining may cover more than one of the listed topics and more than one audit approach can be
used for each audit topic.

Table 5: Environmental audit topics and approaches (mining and mineral processing)

45
 Audit approaches (Lines of enquiry)
Financial Compliance, Science
Performance Accountability,
management agreements, Research
Policy measurement coordination
and laws and and
and results and capacity
regularity policies Monitoring
General
environmental
impacts
Possible air or
soil
contaminants
Potential
water
problems /
pollutants
Other
pollution
impacts

4.3 Audit of mining on Air Pollution

4.3.1 Air Quality Criteria

The air quality criteria applicable to mining sector as outlined in the development consent should
take in consideration sediment control and total suspend particulate matter.

 The long term impact assessment criteria for particulate matter such as total suspended
particulate matter with criterion of 90µg/m³ and particulate matter less than 10µm with
criterion of 30µg/m³, on annual averaging period. Also deposited dust should be test in the
same averaging period particularly on testing maximum increase in deposited dust level
around 2g/m²/month and maximum total deposited dust level around 4g/m²/month.
 The short term impact assessment criteria for particulate matter such as particulate
matter less than 10 µm on 24 hour as averaging period with criterion of 50µm/m³.

4.3.2 Air Quality Monitoring Program Review

The monitoring of air quality should be conducted at sites. The monitoring undertakes includes:
 Dust deposition monitoring
 Microscopic (visual) analysis of deposition samples
 Monitoring of the concentrations of Total Suspended Particulate(TSP)
 Monitoring of the concentration of particulate matter less than 10 µm

The air quality monitoring program should be generally reviewed on the triennial basis as part of
the triennial Independent Environment Audit process where a detailed review on the air quality
data can be associated with the community complaints. This could be helpful for compliance
levels achieved at each of the dust monitoring sites for reviewed including recommendations for
removal of number of monitoring dust deposition gauges to be decided.

4.4 Audit of mining on Water Pollution

46
4.4.1 Measures in place to address water pollution

Adequate policies, legislation and programmes in Rwanda are well formulated and effective
institutions are put on place for pollution prevention, treatment and restoration of polluted water
rivers, lakes and groundwater. Audit question to be address are:

 Has prevention of polluted water in rivers, lakes and groundwater been addressed in any
policy?
 Has treatment of polluted water been addressed in any policy?
 Has restoration of polluted water in rivers, lakes and groundwater been addressed in any
policy?
 Do existing policies addressing pollution prevention, treatment and restoration of polluted
water in rivers, lakes and groundwater?
 Did regular and periodic meeting take places at the national water assessment authority?
 Did regular and periodic meeting take place at district water quality review committee?
 Agencies have been clearly identified for implementing and monitoring programmes for
prevention and control of surface water and groundwater pollution?
 Regulatory bodies been setup to fix water quality standards for groundwater and surface
water?

4.4.2 Identification and dissemination of risks of polluted water

Water is essential to life on our planet. A prerequisite of sustainable development must be to

ensure uncontaminated streams, rivers, lakes and oceans. Mining affects fresh water through
heavy use of water in processing ore, and through water pollution from discharged mine effluent
and seepage from tailings and waste rock impoundments. Mining by its nature consumes, diverts
and can seriously pollute water resources?

Major sources of water discharge from mining and four main types of mining impacts on water
quality:

 Acid Mine Drainage

 Heavy Metal Contamination & leaching
 Processing Chemicals Pollution
 Erosion and Sedimentation

4.4.3 Impact of measure to control water pollution

The impact should demonstrate whether programmes controlling the pollution will succeeded to
reduce it level in groundwater and surface water and at the end restore the water quality.
Audit question to be address are assess:

 Water quality as result of the implementation of programmes for control of water

pollution?
 Measureable improvements in ecological or biological indices exist in lakes, rivers and
groundwater?
 Demonstrable reduction of persistent organic pollutants in food chain?
 Improved hydrologic balance due to increase in the number of hectare of tree as a result
of reforestation programs?

4.4.4 Sustainability of monitoring and assessment of quality of water

47
Sustainability of monitoring measure to assess the water quality need to address a specific
programme in line with the principles of Integrated Water Resources Management. Audit question
to be address are:

 Did integration of policies, decisions and cost across sectoral interests related to mining
water pollution on the river basin scale in place?
 Did long term commitment from different agencies like funding agencies, implementing
agencies, monitoring agencies are involved in the removal of pollution from rivers and
lakes?
 Before any initiation of mining activities, did a survey to quantify pollution caused by
small, medium and large units undertaken to all rivers?
 Did the survey lead to prepare a list of the most polluted rivers in the zone?
 Is select rivers classified as polluted based on the total pollution load only?
 Is some test been conducted on groundwater all over the district to identify contaminants
like arsenic, nitrate, salinity, acidification, presence of pathogens and fluoride?

4.4.5 Inventory of water resources and assessment of quality of water

It important to make a precise inventory of water resources addressing the quality of water to
know if a risks of polluted water to health of living organisms and the impact on environment has
been adequately assessed and finally if the risks has been effectively disseminated to the
impacted target group. Audit question to be address are:

 Whether risks to human health from water borne diseases and water based diseases as a
result of pollution of rivers and lakes been assessed?
 Whether risks to human health from high concentration of nutrients as a result of pollution
of rivers, lakes and groundwater have been assessed?
 Whether there is any mechanism put in place for regular reporting of impacts on health
from drinking of polluted waters of rivers, lakes and groundwater?
 Whether there is any mechanism put in place for regular dissemination of health risks from
polluted waters of rivers, lakes and groundwater to the public?
 Whether there is any mechanism put in place for dissemination of health risks from
polluted hotspots to the public?

4.4.6 Planning, implementation and monitoring of programmes addressing water pollution

The planning, the implementation and the monitoring of water pollution programmes for
prevention, treatment and restoration of polluted water in rivers, lakes and groundwater must
been planned, implemented and monitored efficiently and effectively. Audit question to be
address are:
 Whether planning for current programmes for control of pollution of groundwater and
surface water was based on accurate/recent/reliable pollution related data?
 Were specific activities identified under programmes for reduction of pollution of rivers,
lakes and groundwater by the major sources of pollution?
 Was the matter of ensuring minimum flow in rivers taken up?
 Was a policy or regulatory framework for riparian and floodplain areas for rivers are plan
to contain pollution?
 Was the reduction of full pollution load of selected lakes addressed and calculated
currently?
 Was the increase in population in coming years taken into consideration?

4.5 Audit of mining on Waste Management

48
4.5.1 Waste sorting and disposal

The waste management plan (WMP) should address the management of waste with the operation
of the mine and associated infrastructure. Waste sorting is limited on site with the majority of the
general and recyclable waste being off site at a approved waste management facility. Waste is
classified into groups that pose similar risks to the environment and human health according to
protection of environment operations. Six waste classes are used to better facilitated
management and appropriate disposal. These are:

 General solid waste ( putrescible)

 General solid waste ( non- putrescible)
 Restricted solid waste
 Liquid waste
 Hazardous waste
 Special waste

4.5.2 Waste transport and tracking

Transportation of all waste generated at mining operation should be managed by a licensed waste
contractor in accordance with the relevant waste legislation. Tracking of this waste will be carried
out in accordance with requirement of the protection the environment operation regulation. The
company undertakes audits of the licensed waste contractor to ensure the waste is being
transported and tracked in accordance with the requirements.

4.5.3 Management strategy effectiveness

The management strategies discussed above have been implemented to minimize the volume of
disposal waste generated, will ensure that its waste contractors employ the most appropriate
technologies and procedures required to minimize waste production and treat it in the most
suitable manner. The contractors will be regularly audited.
The effectiveness of the existing controls is reviewed on an annual basis as part of the
environmental aspects and impacts register review.

4.5.4 Site inspection and waste management plan review

Waste generation and disposal will continue to be closely monitored to ensure that it is being
managed as effectively as possible. The ways in which waste related issues are monitored include:

 Record keeping
 Waste Contractor audits
 Site inspections

The record keeping specified waste movements relating to generating. Storage and disposal of
mining , hazardous and class A wastes to be retained for 3 years. A spreadsheet is maintained
detailing the types and volumes of waste that have been removed. This data must be used in
various reports.

Waste contractor audits are undertaken on a regular basis. These audits are undertaken to ensure
that the waste contractors utilized to meet the waste management requirements as per the
relevant legislation detailed in the management plan. Regular site inspections are undertaken by
site personnel to ensure that waste management practices on the site are being in accordance
with the requirements of this management plan. These inspections identify issues with regards to
waste segregation and /or inappropriate waste disposal prior to the waste being removed from the

49
site. Waste management issues identified during these site inspections along with any follow-up
actions are documented via the site reporting process. The waste management plan will be
reviewed on a triennial basis or when required.

4.6 Audit of mining for biodiversity

4.6.1 Status/Inventory of Biodiversity and important

Biodiversity refers to the full range of living organisms in terrestrial, marine and other aquatic
ecosystems, and the ecological complexes of which they are apart. It is the genes, species,
ecosystems, land or seascapes, as well as the ecological and evolutionary processes that allow
these elements of biodiversity to persist over time. The biodiversity underpins the diverse
ecosystems that deliver ecosystem services that are of benefit to people, including the provision
of basic services and goods such as clean air, water, food, medicine and fiber; as well as more
complex services that regulate and mitigate the climate, protect from natural disaster.

4.6.1.1 Relevance to mining mining

In country like Rwanda, the mining mining is a long-standing and pivotal driver of economy. But
mining and related activities have had significant impacts on biodiversity and ecosystem services;
often potentially causing irreversible and often large scale habitat loss, at times across large areas
or areas important to the provision of important ecosystem services, particularly water related
services. Although the legacy of the mining mining is not always good when it comes to social and
environmental impacts, opportunities exist at every stage of the mining life cycle to reduce the
impacts of mining on land use, greenhouse gas emissions, water and biodiversity, and increase the
benefits to nearby communities.

The mining mining is itself dependent on key resource inputs such as water, the provision of which
depends on health and integrity of ecosystems. Additional to these often overlooked benefits,
there are other opportunities for mining sector linked to investing in biodiversity. Green mining
initiatives and more environmentally-friendly projects are likely to become more economically
viable as investors continue to examine the sustainability of companies and mine more carefully.
Furthermore, opportunities to invest in renewable energy, alternative land use options and
partnerships with neighboring communities and other stakeholders could improve the
sustainability of a mine, and offer future business opportunities.

4.6.1.2 Mining and biodiversity: the scope and structure of the guideline
The guideline describes the principles, tools and information that should inform the consideration
of biodiversity in the mining life cycle to support the sustainable use of the country’s mineral
resources. This guideline takes into considerations the impact of mining on the environment and
provides information on how biodiversity factor act on the life cycle of a mining project.
4.6.2 Impacts on biodiversity typically associated with mining

The impacts on biodiversity typically associated with mining vary significantly depending on the
type of mining. Different types of mining include opencast, underground, and alluvial mining for
each example, each of which has very different levels of impact on biodiversity. Additionally,
each stage of the mining project can have adverse effects on the environment and biodiversity.
When the mine closes activities that result in biodiversity impacts may draw to an end and the
disturbance footprint of the mine needs to be rehabilitated. There may be long-term or latent
impacts that continue to impacts on biodiversity and ecosystem services after mine closure.
Impacts of mining and related activities on biodiversity can be grouped into four broad categories.
Impacts may be: Direct, Indirect, Induced, Cumulative.

50
Direct impacts are those impacts directly linked to the project (e.g. clearing of land, extraction of
water, contamination, sedimentation etc.);

Indirect impacts are those impacts resulting from the project that may occur beyond or
downstream of the boundaries of the project site and/or after the project activities has ceased
(e.g. migration of pollutants from waste site, reduce flow in downstream rivers);

Induced impacts are impacts that are not directly attributable to the project, but are anticipated
to occur because of the presence of project (e.g. impacts of associated industries, establishment
of residential settlements with increased pressure on biodiversity);

Cumulative impacts are those impacts from the project combined with the impacts from past,
existing and reasonably foreseeable future projects that would affect the same biodiversity or
natural resources (e.g. a number of mines in the same catchment or ecosystem type collectively
affected water quality or flow, or impacting the same local endemic species).

4.6.2.1 Biodiversity and risk

Mining companies are generally aware of the possible obstacle that areas of high biodiversity value
can pose to mining projects, but even in cases where direct biodiversity risks are assessed, failure
to fully consider the interdependencies between mining, biodiversity and society into the
assessment of the impacts can result in a failure to identify significant risks associated with a
proposed mining project.

The issues of maintaining a social license (avoiding facing significant opposition from interested
and affected parties) to operate can be affected by environmental performance with safety and
land disputes has become a more significant risk that it was previously. The public want to hold
companies responsible and this can affect investment confidence, doesn’t matter if it happened a
long time ago, at another mine, or even to another company.

The types of risks to companies include regulatory risk (non-compliance with environmental
legislation which is not only costly but poses additional risks such as operation delays or
stoppages, licenses being revoked or loss of investment), reputational risk, liability risk, credit risk
etc.

4.6.3 Environmental impact assessment and biodiversity

Using good practice of Environmental Impact Assessment (EIA) to identify, assess and evaluate
impacts on biodiversity is the fourth principle important for integrating biodiversity information
into decision making about mining. EIA is the process of evaluating the likely impacts of a
proposed project or development on the environment, taking into account inter-related socio-
economic, cultural and human-health impacts, both beneficial and adverse. The effective
engagement with relevant stakeholders is a precondition for a good practice EIA. The EIA is a
fundamental input into the Environmental Management Plan, which is a main tool for managing
environmental impacts. It is important that the proponent integrate biodiversity information into
the three broad requirements:

 Establish baseline information on the affected environment to determine protection,

remedial measures and environmental management objectives
 Investigates, assess and evaluated the impact of mining on the environment, socio-
economic conditions and national heritage
 Describe how actions/activities/ processes which cause pollution or environmental
degradation and mitigation of pollutants are to be mitigated (modified, remedied,
controlled or stopped).

51
4.6.3.1 Defining boundaries of responsibility for mitigation
Mining companies are responsible for any environmental damage, pollution or ecological
degradation caused by their activities” inside and outside the boundaries of the area to which
such right, permit or permission relates”. For this reason, it is important that the identification,
assessment, evaluation and mitigation of impact are robust and defensible. Mitigation measures
required of companies may comprise:

 Avoidance, minimization and rehabilitation (primarily on the site and in areas of ancillary
activities or facilities, but many involve monitoring and adaptive management in areas
downstream or in the area of influence of the activity).
 Biodiversity offsets

Over and above these clear responsibilities, it is appropriate to note that mining companies may
plan to operate in highly sensitive biodiversity settings where there are external (non-mining)
threats to biodiversity and ecosystem services, where they run the reputational risk of being
associated with these bigger drivers of biodiversity loss. In these situations, it may be beneficial to
the mining company to engage with local communities and conservation organization/agencies to
seek collective ways of addressing on-going threats through supporting local or regional initiatives,
thereby helping to minimize the proponent’s cumulative impacts.

4.6.3.2 Robust environmental management that applies the mitigation hierarchy

In planning any mining-related activities, the EMP is the main tool for specifying how the mining or
prospecting operation’s environmental impacts are to be mitigated and managed. The EMP must
therefore meet good practice standards and satisfy legal requirements. There are number of
generic requirements namely:

 Establish baseline information on the affected environment to determine its importance

and sensitivity. Identify appropriate mitigation measures and environmental management
objectives.
 Investigate, assess and evaluate the impacts of the proposed activity on the environment,
socio-economic conditions and national heritage
 Identify appropriate mitigation measures for potentially significant impacts
 Develop a schedule to implement mitigation measures for prevention, management and
remediation of impacts (describing how pollution, environmental degradation and /or
migration of pollutants are to be controlled, contained or remedied).
 Cover all stages of the proposed activity (including environmental objectives and specific
goals for rehabilitation and mine closure)
 Develop an implementation action plan (including specific responsibilities and timelines)
to achieve goals and objectives of environmental management during mining construction,
operation and closure.
 Monitor and report on performance and compliance
 Provide an estimate of costs for rehabilitation and management of negative environmental
impact (the latter may include provision for securing and managing biodiversity offsets)
 Prepare an environmental awareness plan for employees, addressing impact and risk
management.

To ensure that biodiversity is considered properly an EMP must meet the above requirements.

4.5.3.3 Planning with the end in mind

Planning with the mine closure in mind and comprehensive considering the social, environmental
and economic costs and benefits of mining is important in order to achieve sustainable
development of Rwanda’s mineral and natural resources. As such environmental objectives and

52
specific goals for rehabilitation and mine closure and the implementation plan to achieve these
goals (closure plan) are a requirement. Some of the requirement of a closure plan with
consideration of how biodiversity aspects should be addressed as:

 A description of the closure objectives and how these related to prospecting or mine
operation and its environmental and social setting
 A summary of the results of the environmental risk report and details of identified residual
and latent impacts
 A description of methods to decommission each prospecting and mining component and
the mitigation or management strategy to avoid, minimize and manage residual or latent
impacts
 Details of any long-term management and maintenance expected
 Details of proposed closure costs and financial provision for monitoring, maintenance and
post closure management
 Record of interested and affected persons consulted

An important component of closure is adequate financial provision for managing latent and
residual environmental impacts; closure plans must specifically address the financial provisions for
monitoring, maintenance and post closure management, which should include amongst others,
rehabilitation costs associated with commitments on restoring impacted ecosystems.

4.6.4 Managing impacts on biodiversity at different stages of the mining life cycle

4.6.4.1 Prospecting or exploration: integrating biodiversity

Prospecting is the systematic and iterative process of locating a mineral deposit by narrowing
down areas of promising mineral potential with the aim of identifying and defining a financially
exploitable ore body or mineral resource. Prospecting can include excavation, trenching, pitting
and drilling, bulk sampling and testing and any other prospecting method. The prospecting stage is
an important one for mining companies, as it is generally near the end of this stage that a mining
company is determining whether or not a mining project will be feasible and will aim to develop a
bankable feasibility study based on their findings. A prospecting EMP is required as part of the
rights approval process. Relevant information’s on the potentially significant impacts on
biodiversity and ecosystem services must be gathered as the basis for assessing impacts and
providing adequate and appropriate mitigation measures.

4.6.4.2 Mining or production: integrating biodiversity

The mining or production stage in the mining life cycle is where the greatest environmental
impacts are likely to occur. This stage is sometimes dealt with as two separate stages,
construction and operation, but are treated together here because by the time construction
begins, all necessary authorizations must have been approved as have the EMP that will direct the
management of impacts on biodiversity and ecosystem services.
It is a legal requirement that this stage commences only once all of the required authorizations
have been approved, including the water use license and any environmental authorizations for
associated activities. For mining companies at this stage potential limitations for project
development should have been identified, including the likelihood of potentially significant
impacts on biodiversity priority areas.

4.6.4.3 Decommissioning and closure: integrating biodiversity

Closure refers to the process for ensuring that mining operations are closed in an environmentally
responsible manner, usually with the dual objectives of ensuring sustainable post-mining land uses
and remedying negative impacts on biodiversity and ecosystem services.
The decommissioning and closure stage is the culmination of the closure plan implementation. It is
the period to remedy adverse impacts of mining on biodiversity and/or to improve ecosystem

53
services for local communities where thses have not been done as concurrent with mining. Part of
closure involves rehabilitating the mined environment presenting an opportunity to remedy
negative impacts on biodiversity and contribute to local and regional conservation initiatives and
to help improve ecosystem services.

4.6.5 Land Environmental on mining audit

Erosion control
It is recommended that the erosion and sediment control plan be revised and the inclusion of
reference to other relevant management plans. Although the air quality management address
each requirement, the erosion and sediment control should again report with annual average
period on total suspended particulate matter (TSP) and particulate matter less than 10 µg/m²
(PM10). It also recommended formalizing the approach using inferred TSP results based on
measured PM10 data.

Action suggested improving rehabilitation areas

It is recommended general improvements to topsoil stockpiles management could be achieved by
implemented the following actions:

 Test the topsoil to determine the chemical and biological amelioration requirements of the
topsoil
 Monitor for weed establishment and spray any weeds that have established on the
stockpiles
 Shape the stockpiles with a maximum batter grade of 1(v):3(h).
 Apply amelioration (gypsum, compost etc.) and rip into the topsoil at the time of
stockpiling
 Consider removing contour bank already vegetated areas to minimize potential for future
tunnel erosion/gully erosion.

4.7 Climate Change on Mining Audit

4.7.1 Climate change risk and opportunities

Mining company disclosures of climate of climate change risks and opportunities to the carbon
disclosure project (CDP) one of the largest repositories of company reporting on climate change.
The Risk and opportunities include:

 Disturbance to mine infrastructure and operations for examples as a risk, heavy rain and
increased of erosion may affect slope stability but as an opportunity warming ambient
temperature in the Arctic will make easier to operate reduce heating cost.
 Changing access to supply chains and distributions routes, for example as a risk se level
rise and frequent storms may affect port availability but as an opportunity rising
temperature will keep northern sea channels free of ice.
 Challenges to worker health and safety conditions for example as a risk flooding may
affect employee safety on site and on roads
 Challenges to environmental management and mitigation for example as a risk, water
scarcity and hotter temperatures will make it more difficult to reestablish vegetative
cover, and will put stress on other environmental mitigation measures in some regions. But
as opportunity, increased CO2 and longer growing seasons will benefit re-vegetation efforts
during reclamation and after closure
 More pressure points with community relations as a risk for example community water
infrastructure and watershed restorations projects may be required to mitigate
reputational risks and to meet needs of all users but opportunity could be for meaningful

54
 engagement with local communities and other key stakeholders, particularly regarding
collaboration on land, mining, and water management.
 Exploration and future growth may be restricted by expanded protections for biodiversity
threatened by climate change and for forested areas that serve as carbon sinks while as an
opportunity demand for other commodities may increase due to new applications,
particularly related to energy efficiency.

4.7.2 Comprehensive management system to address climate adaptation

Based on identified risks and opportunities, adaptive responses can be grouped as:
- Value protection, ensuring resilience of physical assets and planning responses to
maintain business as usual
- Value creation, devising solutions that contribute to the ability to pursue new revenue
generating opportunities and help suppliers, stakeholders, and customers adapt to a
changing climate.

4.8 Mining Safety Audit

4.8.1 Welding hazard in surface mines and quarries

Welding and gas cutting activities create a range of both well-know and subtle hazards, which can
impact upon the health and safety of employees. These can have immediate consequences or have
consequences that may surface only in the longer term. Welding hazards:
 Fire and explosions
 Burns
 Fumes
 Electric shock
 Compressed gases
 Hazardous substances
 Toxic gases
 Suffocation
 Radiation
 Heat stress
 Dust
 Noise and vibration
 Manual handling

The safe use of welding and cutting gases and equipment:

- Storage of Gas bottles:

o Cylinder should be correctly labeled, properly secured against fall and stored
upright in a well-ventilated area
o Cylinders should be returned to safe storage after use, ensuring that valves are
tightly closed
o Acetylene gas cylinders and oxygen cylinders should be stored separately
o Gas cylinders should be kept away from combustible materials, oils or grease,
electrical apparatus and any source of heat
o Gas cylinders should be regulated examined for signs of defects, rusting or
leakage
o Empty cylinders should be managed as if they were full
- Handling of Gas bottles
o Never lift a cylinder by the valve cap of guard
o Leave valve protection caps/guards in place when cylinders are not in use

55
 o Do not use cylinders as rollers or supports or for any other purpose tan to
contain the gas supplied
- Operators should knows
o The correct assembly procedures for attaching equipment to gas cylinders
o The correct procedures and materials used for leak testing
o Never to crack a fuel gas cylinder valve and release near source of ignition
- Preparation of metals for welding pose a series of specific hazards each required
control
o Abrasive blasting poses hazards to the eyes need to be carried out in a well-
ventilated area
o Use of degreasing chemical may be exposure to the solvent vapor which may be
flammable and explosive
o Contaminated surfaces when coatings on metals are heated it should be
assumed that decomposition products are toxic
- Key elements of safe welding in confined spaces include the following
o Access and emergency rescue
o Ventilation
o Atmospheric testing,
o Arc Flash
o Fire protection

4.8.2 Stockpiles and dumps hazards

Injuries to persons engaged in or associated with the operations of tipping on stockpiles or

dumping of overburden in mines and quarries are usually serious and often fatal. The hazards of
working stockpiles and dumps are generally associated with the nature of:

 The material being stockpiled or dumped

 The configuration and placement of the stockpiles or dump
 The mobile equipment being used
 The immediate and overhead environment
 The degree of moisture and drainage of the stockpile or dump
 The method of material retrieval and undetonated explosives

Nature of the mined material being stockpiled or dumped can be divided into two broad
categories:

 Generally unstable which do not compact to form a stable surface

 Generally stable loading products which can be compacted

The factors determining the sitting and design are:

 The nature of the mined material

 The ground used
 The volume of the product
 Area available and required
 Other potential hazards such as no stockpile should be formed under or on top of powers
lines
 Environmental considerations

4.8.3 Noise control in mines quarries and tunnels

56
Noise is generally described as unwanted sound, but in the context of hazard management, it is
sound at a level or intensity that has the potential to permanently damage a person’s hearing.
The risk of damage to a person’s hearing is determined, not only by sound intensity but also by the
length of exposure time. This means it is the total amount of sound energy received at the ear
that determines how damaging the noise will be. In any workplace the potential hazard of noise
can be evaluated by conducting surveys:

- Preliminary surveys identify areas in a place of work where noise likely to or actually
exceed the exposure limits
- Details surveys provide an assessment of the noise environment establishing whether or
not the workplace exceeds the exposure limits. A detailed assessment is required:
o Where complex noise sources are present
o If there is doubt whether the noise levels exceed the exposure limit
o If there is any reason to believe that noise levels are, o may exceed the
exposure limits
Noise controls principles should be based on
- Identify the source
- Determine the transmission pathways
- Consider the receivers
- Distances considerations
- Addition of noise from several sources
- Sound insulation
- Sound absorption
Noise administrative controls may include:
- Avoiding purchasing hazards by adopting a “ buy quiet” policy
- Establishment of job procedures that will reduce employee exposure ( job rotation)
- Setting targets for noise levels in existing work areas
- Protection of visitors on site
- Monitoring employees by initial audiogram and regular repeats
- Use of warning signs
- Use of hearing protection related to designated hearing protection areas
Noise engineering controls may include:
- Enclosure of machines, where it is not possible to prevent or reduce the noise at its
source, it may be necessary to enclose the entire machine
- Attenuation of structure-borne sound, preventing transmission of vibration from
machines to the load-bearing structure
o Large heavy machines should be mounted on foundation which are completely
separated from building or others structures
o Place other machines on a stable foundation and where possible use an elastic
separation such as rubber blocks or steels springs.
- Attenuation by using absorbents, hard surfaces on the selling, floor and walls of an
enclosed processing plant or workshop will reflects back nearly all the sound reaching
them
- Sound insulated rooms, cabins should be constructed of materials with good sound
attenuation properties.

4.8.4 Safe operation of mobile plant

The safe control and operation of mobile plant require a reasonable level of physical and mental
fitness. Both at initial selection and throughout sustained employment, these requirements should
be defined and maintained. Employers should continue to monitor and assess operators at regular

57
intervals to ensure the operator maintains the required standards; where the operator’s
performance has deteriorated, retraining should take place immediately to prevent accidents.
Authorization to operate:

- No person should operate mobile plant without written authorization to Operate from
their employer
- This authorization should be issued only after training is satisfactorily completed in
respected of each mobile plant as named on the authorization
Ongoing demonstration of practical skills by the operator should be observable:
- Daily inspection
- Operation
- Controls
- Hazards
Safe start procedure include:-
- Never attempt to start engines except from an approved operator’s position
- Check for warming tags
- Place directional controls in neutral, disengage clutch on manual transmission
equipped machines, or apply brake on power shift or automatic transmission equipped
machines, start engine
- If it is necessary to start an enclosed area, provide adequate ventilation. Exhaust
fumes can kill.
- Do not start or operate a machine or any of its attachments from any place other than
the designated operator’s position
- Consider operating the horn prior to starting to warm people in the vicinity

4.8.5 Isolated and lockout within the mines quarries and tunnels

The purposed of having isolation and lockout procedures is to render plant or equipment
inoperable i.e. to isolated the source of energy, which, if released could activate any moving
parts. Mobile plant which is either unserviceable or under repair will require isolation and lockout
procedures Static plant that has moving part will require isolation and lockout procedures for
general operation, service, and maintenance periods. Basic steps to isolation and locking out are:

 Identify the plan that needs to be isolated and locked out

 Shut off the plant or equipment. All moving parts must come to complete stop. (First
ensure that no other hazards are created by the act of shutting down the plant)
 Identify and de-activate the main energy-isolating device for each energy source
 Attach both a personal lock and tag to the lockout mechanism of the energy-isolating
device. Ensure that all parts and attachment are secured against inadvertent movement.
 Isolated tags for mobile plant or equipment.

4.8.6 Environmental and Social Impacts of Mining Activities

Every Mining activity is associated with significant environmental and social impacts as summaries
under Table 6 below.

58
Table 6: Sources of Potential Environmental Impacts by phase

59
5 GUIDELINE FOR PREPARING AN ENVIRONMENTAL AUDIT REPORT

After going through the steps outlined in section 1.5 and undertaking an audit, an Environmental
Audit Report (EAR) should be compiled along with recommendations. The final report may if
necessary, be sent to the top management for comments so as to make further modifications. The
following provides a guide to preparing am EAR.

5. 1 Purpose of This Specific Guideline

This section of the guideline outlines the requirements for developing an Environmental Audit
Report for submission to REMA for review and approval. It is intended to provide guidance to
project proponents, facility owners, and consultants on the preparation of an appropriate report
following an environmental audit that should have been undertaken following the steps outlined in
Section 1.5. Particularly, this guidance document provides an overview of the proper format and
contents of an EAR to meet REMA’s requirements, help the proponent/consultant prepare this
report, make the review process easier and consistent for REMA.

Section I: Background Information

An environmental audit is a tool used by REMA to provide oversight of the management of

environmental impacts from mining development and operation activities. The EAR is a summary
report that provides the findings from the environmental audit. The EAR is required to be
submitted to REMA for review and approval on a periodic basis as outlined in a permit, a
Construction Environmental Management Plan (CEMP), an Operation Environmental Management
Plan (OEMP), or another REMA required document. The following sections provide more detail on
the definition, objectives, and preparation and submission requirements of an EAR.

5.1.1Definition of an Environmental Audit Report

An EAR documents an independent, accurate, and detailed assessment of environmental

performance of an mining facility. An EAR describes the project or process being audited, lists the
environmental audit findings associated with that project or facility, details the audit procedures
that were followed, and identifies the relevant environmental requirements that were used during
the assessment. The EAR is used to assess the implementation of a project’s or facility’s
Environmental Management System (EMS) and compliance with REMA issued permits, certificates,
licences, or approved plans (e.g., CEMP, OEMP). Accordingly, audit reports should be clear, timely,
concise, and objective; provide a fair summary of all the relevant facts; and demonstrate
conformity with the related REMA approved environmental studies. Audit issues that have been
reported should be properly analysed and concluded, and all reported findings and conclusions
should be supported by adequate, reliable, and fair audit evidence.

60
5.1.2 Objectives of an Environmental Audit Report
The objective of an EAR is to provide interested parties (e.g., REMA, RNRA, MINIRENA, and RDB)
clear indication of the environmental performance of the project or facility for the period covered
by the audit. The primary objectives of the EAR are as follows:

 Provide an objective analysis of the environmental impacts arising from an mining project
or facility
 Establish that the requirements of the No Objection Certificate (NOC), CEMP, OEMP, and
other Environmental Impact Assessment (EIA) are appropriately implemented
 Determine that mitigation measures are effective in minimising or removing environmental
impacts
 Identify opportunities and make recommendations for improvements in environmental
performance of the mining project or facility
 Provide the information required to develop an Environmental Action Plan (EAP) in the
event of any significant findings of negative impacts to the environment
 Provide an objective, third-party report that meets REMA’s requirements.

The findings and recommendations of the audit effort should be documented clearly and concisely
in the EAR. The usefulness of an EAR is measured by how well the problems are identified,
evaluated, documented, and addressed by adequate and straightforward mitigation measures and
corrective actions.

5.1.4 Preparation and Submission of the Environmental Audit Report

The proponent of a project or the facility owner is responsible for the EAR, which must be
prepared and submitted by a REMA approved and registered consultant. A list of registered
consultants can be obtained from the REMA website, and it is updated annually. The
environmental audit must be conducted according to the scheduled frequency outlined by REMA in
the facility/project permit, NOC, CEMP, OEMP, or other directive, and the EAR must be submitted
to REMA within the period and time specified in the general environment audit guidelines for
Rwanda (REMA 2009).

The audit report is prepared under the direction of the lead auditor, who is responsible for its
accuracy and completeness. The topics to be addressed in the audit report should be those
determined in the audit plan. Any changes desired at the time of preparation of the report should
be agreed by the parties concerned. The report should include a detailed Environmental
Management Plan (EMP) that incorporates costs and liability issues.

Section II of this Specific Guideline provides an overview of minimum contents and required format
of the EAR. This framework of information presented should be followed for all EARs submitted;
however, depending on the scope of the audit and particular issues identified, some sections of an
EAR may be expanded or contracted as is relevant to the mining project or facility issues being
audited.

Section II. Environmental Audit Report Contents and Format

The audit report should be dated and signed by the lead auditor and key team members. The EAR
should communicate the relevant information clearly and concisely and therefore, should contain
the audit findings with reference to supporting evidence. The audit report should therefore:

61
  Be presented to make information accessible to the non-specialist, avoiding technical
terminology where possible
 Have information presented in summary table format to the extent possible and use quality
maps, charts, diagrams, and other visual aids whenever possible
 Be presented in a logical and easy-to-understand manner, with a clear Table of Contents to
allow the reader to find and assimilate information quickly.
 Present information without bias and discuss issues with the appropriate emphasis
regarding their importance as in the overall context of the environmental audit.

In addition, the audit report should:

 Highlight both the positive and the negative
 Identify inefficiencies within current practice.
 Be clear and concise
 Minimize subjective statements
 Specify obvious deficiencies and indicate priorities for improvement.
 Suggest the potential cost effective improvements
 Seek agreement with site management
 Bear in mind potential user of the report
The following sections describe the minimum content and format requirements for an EAR.

 The identification of the organisation audited or the client.

 The agreed objectives, scope and plan of the audit.
 The agreed criteria
 The period covered by the audit and the date(s) the audit was conducted.
 The identification of the auditee’s representatives who participated in the audit.
 Statement on the confidential nature of the contents if applicable.
 The distribution list for the audit report.
 A summary of the audit process including any obstacles encountered.
 Audit conclusions such as: Conformance to the audit criteria; whether the system is
properly implemented and maintained; and whether the internal management review
process is able to ensure the continuing suitability and effectiveness of the operations.
 Prioritised recommendations which should include: Estimation of cost; Resources;
Requirements and optimum time for introduction; monitoring of implementation and next
review dates.

5.1.5 Table of Contents

The EAR should have a title page and a Table of Contents. This Table of Contents should adhere to
the layout provided in Table 7. Note that the length and detail of the EAR may vary depending on
the size and nature of the project or mining facility being audited, or on the objectives and scope
of the audit (e.g., whether it is an initial, surveillance, special audit); however, it is recommended
that the EAR follow the format indicated as closely as possible. Following the format will allow
REMA to provide a prompt and expeditious report review and minimise the potential for any
submittals and clarifications that may be subsequently needed.

62
Table 7: Standard Table of Contents
Table of Contents
List of Tables
List of Figures
List of Abbreviations
Definitions of Terms
Chapter 1 Executive Summary 1.1 Project Title and Project Proponent

1.2 Description of the Audited Mining Project or Facility

1.3 Description of the Environment

Chapter 2 Introduction 2.1 Audit Scope, Objectives, and Criteria, including a list
1.4 Summary of Findings
of reference documents against which the audit is
conducted.

2.2 Auditors and Auditees, including the specific roles

Chapter 3 Site Activity 3.1 Mining Facilities and activities
2.3 Reference Documents
3.2 Neighboring Facilities and activities
3.3 Description of audit approach and methodology

Chapter 4 Audit Findings 4.1 Environmental Management Systems and Management

Commitment

4.2 Previous Audit Results

Chapter 5 Conclusions and 5.1
4.3 Conclusions
Non-conformances and Observations
Recommendations 5.2
4.4 Recommendations
Summary of Corrective Action Status

Environmental Audit Report Annexes

Annex 1 Photographic Record
Annex 2 Audit Checklist(s)
Annex 3 Supporting Documents
Annex 4 Audit Qualifications

*The Table of Contents should also include lists of tables and figures included within the body of
the document.

List of Tables

This section should include a list of all the tables presented within the main body of the EAR and
should indicate table numbers, table titles, and associated page numbers.

List of Figures

This section should include a list of all the figures presented within the main body of the EAR and
should indicate figure numbers, figure titles, and associated page numbers.

63
Reference Information

In addition to the Table of Contents, the EAR should provide reference tables that allow for quick
reference to abbreviations and definitions.

List of Abbreviations

This section should include a list of abbreviations and acronyms used in the EAR. This list should be
presented in a format similar to that on page vii of this Technical Guidance Document.

Definitions of Terms

This section should include a list of terms used in the EAR and their definitions. This information
should be presented in a format similar to that used on page viii of this Technical Guidance
Document.

Chapter 1: Executive Summary

Should summarise the overall scope and objective of the audit, the effectiveness of the project
EMS, the status of environmental performance, and the significant audit findings. With regard to
audit scope, the REMA approved or REMA issued document that is the basis for the audit should be
identified with the directive title and date (e.g mining permit, EIA, CEMP, OEMP). Any changes in
directives since the last audit should be identified and described (i.e., changes to CEMP).

The summary of the EMS should touch on the strengths and weaknesses of the management system,
comment on particular highlights of the audit, and include an overview of any findings that
represent non-conformity and/or significant areas of concern.

The Executive Summary should concisely and clearly state the conclusions of the audit regarding
conformance of the project’s EMS against the REMA requirements and any recommendations or
corrective actions that are needed.

The Executive Summary should include the following specific sections:

1.1 Project Title and Project Proponent

This section should include the name, address, telephone number, and fax number of the
proponent’s firm; the name and designation of the contact person who is responsible for the
project EMS; and the project’s title.

1.2 Description of the Audited Project or Mining Facility

This section should contain short descriptions of the overall project or facility and the breakdown
of any phases or project/facility components, if applicable. The descriptions should be brief, yet
provide enough information for readers to understand the location, size, nature, and activity or
function of the project or facility. Descriptions should include information on the relevant
management structures and workforce, all inputs and outputs (mining facility), and ancillary
operations such as transport services, materials storage, and processing operations.

1.3 Description of the Environment

64
This section should include brief descriptions of the project’s or facility’s surroundings and on-site
environment, including the natural and built environment, sensitive receptors, local ecology
(noting any sites of special interest or conservation value), and socio-economic or cultural factors
that may have a bearing on the environmental impacts of the project or facility.

1.4 Summary of Audit Findings

The following information and findings should be described in this section:


A summary of non-conformances and observations identified during the audit (the use of
tables is recommended)
 A list of non-conformances and observations, which are still on-going and not yet closed,
that were identified in the previous audit reports
 The environmental impacts or issues observed during the course of the audit
 The overall effectiveness of existing environmental mitigation measures and management
practices
 Conclusions and recommendations, including any corrective actions required or taken
Chapter 2: Introduction

Should provide information on the audit scope, objectives, and the criteria used as the basis for
the audit; identify background documents relevant to audit; identify the audit team members and
those representatives of the project or facility involved in the audit; and describe the audit
itinerary. Sections 2.1 through 2.3 of this chapter describe the specific information that should be
included in the Introduction.

2.1 Audit Scope, Objectives, and Criteria

This section should describe the audit objectives, scope, and criteria used for the audit. This
section would indicate the scope of the audit (e.g., if the audit covered the full development
project or facility, covered all environmental media or components, or was specifically targeted to
an issue or physical area of concern). The criteria on which the audit is based should be itemised
and clearly identified (e.g., an EIA, CEMP, OEMP, mining permit, operating permit) with titles and
dates. This section should also indicate if there have been changes in requirements applicable to
the facility or project since the last audit or if there were specific issues from former audits that
would be considered.

The typical scope items that should be described in the EAR for all projects and facilities include
documentation and records, training, monitoring programmes and results, internal audits and
inspections, incidents and complaints, and audit activities. The specific information that should be
included for those items is discussed below.

Documentation and Records

The EAR should provide comments on the documentation and control of records, including CEMP
and OEMP documents, permits, training records, environmental programme plans and procedures,
audit and inspection reports, and other records.

Training

65
The EAR should describe and provide comments on the environmental training programmes that
are being implemented in accordance with CEMP or OEMP requirements.

Monitoring Programmes and Results

The EAR should identify monitoring programmes that are being implemented on the project and
provide comment on whether monitoring is being performed in accordance with CEMP or OEMP
requirements.

Internal Audits and Inspections

The EAR should provide comment on the internal audit and inspection programmes that are being
implemented to meet regulatory requirements.

Incidents and Complaints

The EAR should provide comment on the procedures followed for responding to incidents and/or
complaints and include a description of any follow up on specific complaints or emergency
response incidents.

Audit Activities

Audit activities include descriptions of audit interviewees and the timing and audit methodologies
used. This section would also include comments on the site conditions during the time of the audit,
highlight any adverse conditions or unusual observations made, and identify areas of the site
visited. The audit activities should focus on implementation of the environmental programmes,
procedures, and measures identified in the CEMP or OEMP. Depending on the nature, size and location
of the mining facility, the typical environmental management plans that would be evaluated in the
audit and discussed in the EAR are as follows:

 Mining technologies used

 Mining plan
 Water Quality Control Plan
 Waste Management Plan
 Soil and Groundwater Contamination Control Plan
 Terrestrial Ecology Control Plan
 Noise and Vibration Control Plan
 Traffic Management Plan
 Erosion and Sediment Control Plan
 Other Environmental Programmes.
2.2 Auditors and Auditees

This section should identify the personnel of the proponent, the facility, or consultant organisation
that performed the audit (audit team). This section should also list the project or facility
representatives who were key contacts for the audit and describe their roles and responsibilities
with regard to the audit.

2.3 Reference Documents

66
This section should include a list of documentation reviewed prior to the audit (e.g., CEMP,
previous EARs, environmental assessments, permits, complaints). This section should also identify
the requirements on which the audit is based, indicating the title, version, and date of any
documents that contain site-specific environmental requirements. If changes to the requirements
since the last audit were noted, then these should be described, relevant to the current audit
scope and objectives.

Chapter 3: Site Activity Summary

This chapter should include detailed descriptions of the activities and processes that were being
conducted onsite during the audit. Contents of this chapter will depend on whether the audit is of
an individual mining facility or an mining estate e.g an mining zone. For mining facilities, this
chapter should provide a general description of production processes, production levels, ancillary
operations, and any other information that would relate to the activities or operations that would
impact or contribute to environmental issues or concerns within the scope of the audit. Sections
3.1 and 3.2 below provide more information on the contents of this chapter.

3.1 Mining Facilities

It is important to note that this section will be similar to the previous audit report for mining
facilities and should focus on changes to operations that have occurred since the last audit. With
regard to facility audits, the following information should be included in this section.

Main operations

This information would include descriptions of the type of facility (e.g. chemical
storage/distribution, mineral storage, mining technology etc), the type of operations conducted,
(e.g water consumption etc). These descriptions should be concise and brief enough to provide the
reader with an understanding of the size and complexity of the operations conducted onsite, both
in comparison to facility capacity and in relation to other similar type facilities.

Ancillary operations

This information would include any particular operations that are not part of the main facility
operations that would have impact or contribute significantly to the facility’s potential
environmental impacts. This information would include operations such as vehicle or equipment
servicing, large electrical switch yards, and large chemical storage or staging areas, ware housing
etc.

Environmental control operations

The EAR should describe any specific engineered or work practise controls that are in place to
mitigate environmental pollution that would be within the scope of the audit (e.g., wastewater
treatment plant, air pollution–control devices, cleaner production mechanisms).

Chapter 4: Audit Findings

This chapter should provide an overview of audit findings, including any analysis of the non-
conformances noted. In particular, this chapter should describe findings regarding the

67
implementation of EMSs and the resolution (or non-resolution) of previous audit findings and
thoroughly discuss individual audit findings. The preferable format for presenting the individual
audit findings is in tabular form, which includes whether the finding has been addressed by
corrective action. Sections 4.1 through 4.4 below provide more information on the contents of
this chapter.

4.1 Environmental Management Systems and Management Commitment

This section should provide comments on the facility’s or proponent’s procedures for determining,
setting, and communicating environmental policies and objectives, as well as the overall
commitment of senior management to meeting environmental requirements. Included in this
discussion would be the facility’s or proponent’s efforts to monitor, measure, and report
environmental performance.

4.2 Previous Audit Results

The EAR should provide comments on the facility’s or proponent’s mechanisms to determine the
root causes of any previously identified environmental problems and on the effectiveness of the
actions taken to correct such situations and prevent their recurrence. This section should also
comment on the sufficiency of the facility’s or proponent’s formal processes for implementing and
tracking corrective and preventive actions.

4.3 Non-conformances and Observations

This section should contain a table identifying non-conformances and observations identified
during the current audit, sorted by priority, and should include the following information:

 Description of each non-conformance or observation, including a unique reference number

for each non-conformance or observation to ease follow-up in subsequent audit reports and
to help in tracking the corrective action status
 Date of occurrence
 Audit criterion or the specific NOC, CEMP, OEMP, or regulatory requirement applicable to
the non-conformance
 Relative priority or significance of the finding with respect to REMA and regulatory
requirements (e.g., major, minor, observation)
 Details (e.g., coordinates) regarding where the non-conformity or observation was found
 Subcontractor that caused the non-conformance (if applicable)

The description of the non-conformances should be concise, yet be sufficiently broad or supported
by documentation, photographs, or other information (to be included in the EAR annex) to allow
project or facility management to address the issue and REMA to assess adequate resolution of the
issue.

4.4 Summary of Corrective Action Status

68
This section should include a summary table that provides details on the corrective action(s) taken
and/or planned in response to non-conformances and/or the observations identified in Section 4.3
above. This section should also include any corrective actions planned or taken to address non-
conformances identified in recent previous audits, particularly those that have been or are ongoing
issues at the site or facility. In particular, the Corrective Action Plan summary should include the
type of any required corrective action, the current status (e.g. open, closed) of corrective
action(s), the date of planned closure, and the date of actual closure as a result of conducting the
audit follow-up. This section should provide comments on the auditor’s observation on the
capability and commitment of the site/facility management to resolve the issues.

It is important to note that REMA may require the facility or project to develop an EAP if issues are
identified in the audit that are considered to be repetitive or are ongoing issues, or problems that
present significant concern for environmental impact. The EAP is a Corrective Action Plan that
must be submitted and approved by REMA and requires formal reporting of the resolution of the
issues.

Conclusions and Recommendations

Chapter 5 should include the conclusions of the audit with regard to the status of the conformity of
the site or facility EMS with the CEMP, OEMP, or other requirements, as well as the effectiveness of
the EMS in meeting environmental objectives.

The EAR should make recommendations to address any significant non-conformances or

deficiencies, including allocating priorities for corrective action. Any recommendations should be
specific and detailed enough to allow REMA and facility/project management the ability to
evaluate the feasibility and appropriateness of implementing the recommendation. Types of
recommendations might include further investigation of an issue or implementation of emissions
control technology or environmental pollution control best management practices. The emphasis of
recommendations should be on removing the source of the problem rather than the use of
command-and-control (or end-of-pipe) technology.

Environmental Audit Report Annexes

The annexes of the EAR should include all information necessary to support the findings of the
audit that are not provided in the main text of the EAR. Typical annexes should include the
following information:

Annex 1: Photographic Record—should include evidence available to support non-conformities

identified in the report and/or corrective actions taken.

69
Annex 2: Audit Checklist(s)—should include reference materials such as checklist(s) or audit
protocol used by auditors.

Annex 3: Supporting Documents—should include other documents that support or provide

necessary clarity for audit findings or recommended corrective actions. These documents may
include internal audit/inspection reports, monitoring reports, site or facility maps, technology
descriptions, equipment specifications, waste transfer notes, Material Safety Data Sheets,
reference materials for regulatory requirements, and/or best management practices.

Annex 4: Auditor Qualifications—should include information about the audit team members who
provided evidence of knowledge and capability to conduct the environmental audit.

Note: Additional annexes should be added as needed to support Environment, Health, and Safety
documentation and log templates for inspection, auditing, monitoring, maintenance, and training.

Additional Checklists have been annexed to aid in carrying out environmental audits for mining
activities. These include:

Annex 3 Audit Checklist on Occupational Health and Safety Management System

Annex 4 Social Audit & Compliance Assessment Checklist
Annex 5 Surface Atmospheric Audit Checklists
Annex 6 Surface Atmospheric Audit Checklist
Annex 7 Fire Prevention Audit Checklist
Annex 8 Mineral Exploration Audit Checklist
Annex 9 Noise Audit Audit Checklist
Annex 10 Stockpiles and Dump Audit Checklist
Annex 11 Water Pollution Audit Checklist
Annex 12 Ventilation Management Audit Checklist
Annex 13 Quarry audit checklist

70
 REFERENCES

1. REMA 2006, Rwanda State of Environment And Outlook

2. Guidelines for Environmental Impact Assessment for Mining Projects in Rwanda, Republic Of
Rwanda, June 2012
3. BGR Support for Mineral Certification in the African Great Lakes Region,2012
4. United Efforts to Promote Good Governance and Due Diligence in the Rwandan Mining Sector_
RNRA/GMD, May 2013
5. Breaking new ground: mining, minerals and sustainable development: Earthscan Publications
Ltd., London, 2002
6. Environmental Code of Practice for Metal Mines - Global Report on Artisanal and Small-Scale
Mining, commdev.org/files/804_file_global_report_on_artisanal.pdf
7. Environmental management of mine sites: training manual. 1994. Collation: 1v. (Loose-leaf).
ISBN: 92-802-1446-5. Notes-M: Technical report series / UNEP-IEO; no.30
8. George, 1992.international law and mineral resources, a series of papers prepared for The
United Nations Conference on Trade and Development (UNCTAD). University of Denver College
of law published by Unctad. 2002
9. Guidelines for preparing environmental impact assessment reports for mining projects. Volume
no. 1 September 2003. Department of mines. Republic of Botswana
10. Haidula A. F., Ellmies R., Kayumba F., (2011). Environmental monitoring of small scale mining
areas in Rwanda. Technical report. REMA
11. Indigenous Peoples, Mining, and International Law Marcos A. Orellana,. January 2002.
www.iied.org/pubs/display.php?o=G00529
12. Mining and Environment, Special Issue 2000,. Mining and Sustainable Development II:
Challenges and Perspectives. Author: www.unep.org/PDF/Print%20Catalogue%20-04/18-
Mining.pdf
13. jed.sagepub.com/cgi/content/refs/11/2/149Hilson, G, 2002. The environmental impact of
small-scale gold mining in Ghana: identifying problems and possible solutions, The
Geographical Journal, Article date: March 1, 2002.
14. MINECOFIN. (2000) Rwanda Vision 2020, 2000. Ministry of Finance and Economic Planning,
Government of Rwanda (GoR), Kigali, Rwanda, July 2000.
15. Mining in Rwanda, 2012 edition, Vol:1 (2012)
16. Mining Policy, MINIRENA, 2010
17. MINELA (2005) Organic Law No 04/2005 0f 08/04/2005 determining the modalities of
protection, conservation and promotion of Environment in Rwanda, Kigali: Government of
Rwanda.
18. MINIRENA. (2010). Mining policy. Government of Rwanda. Kigali, Rwanda.
19. Nsengimana H., Bizimana J.P., Sezirahiga Y., (2011). A study on air pollution wiyh refence to
Kigali city and vehicular emissions. Final report. REMA
20. Opportunities for Mineral Resources Exploration and Development, RNRA/GDM, 2013
21. Potential Dimension Stones Mining in Rwanda, 2010
22. REMA. (2009) Rwanda state of the Environment and Outlook Report; Rwanda Environment
Management Authority (REMA), Kigali, Rwanda.
23. Rwanda Biodiversity Policy, 2011. Republic of Rwanda
24. Small-Scale Mining in Africa: Tackling Pressing Environmental, London: United Nations
University, Zed Books. The Journal of Environment & Development, Vol. 11, No. 2, 149-174
(2002) DOI: 10.1177/10796502011002003
25. Steve B. James, R. Kippers, P.E., 2002. Technical Report on Underground Hard-Rock Mining:
26. Subsidence and Hydrologic Environmental Impacts. enter for Science in Public Participation
Bozeman, www.csp2.org

71
27. Thomas H, Felix H. , (2002) Global Report on Artisanal & Small-Scale Mining; Michael Priester
(Germany) Projekt-Consult GmbH

28. UNEP, 2000, Mining and Environment, Volume 23 Special Issue 2000, Mining and sustainable
development II Challenges and perspectives.
www.unep.fr/media/review/vol23si/vol23si.htm#contents

29. World Resources Institute, Mining and Critical Ecosystems: Mapping the Risks,
http://pdf.wri.org/mining_background_literature_review.pdf

30. Yakovleva, N., (2005) corporate social responsibility in the mining industries. ashgate:
aldershot, hampshire, England; Burlington

72
 ANNEXURES

Annex 1: Mining Projects that require Environmental Auditing (EA)

Note: This list gives only the categories of projects that may require EA. Whether a project will
significantly affect the environment or not depends on a number of factors, including the scale,
geographical location and nature of the project. The categorization is based on the Guidelines for
Environmental Impact Assessment for Mining Projects in Rwanda, Republic Of Rwanda, June 2012

Categories of Mining Projects according to Environmental Impact levels are classified into 3
categories as follows:

1. Impact Level 1 (IL 1): Projects not requiring limited environmental analysis

Projects in this category are considered to have a low risk of serious environmental impacts,
which can easily be identified through a Project Brief. For potential impacts of these projects,
mitigation measures can be integrated in the project design without necessarily requiring a
detailed EIA. Hence, after a period of public input the project passes directly to decisionmaking
level. Mining projects in this category are believed to have minimal adverse impacts, which can
easily be identified in a Project Brief. They are classified as small mining projects and include:

 Research and prospecting projects on land surface area not exceeding 100 Hectares;
 the mining activities will not disturb more than 10ha of land or 5 ha of riverine area;
 the mining activities are not, or will not be, carried out in environmentally sensitive
 areas; mining activities for alluvial; clay pit; dimension stone; hard rock; opal or shallow
pit mining.
 Small scale (artisanal) mining activities in less ecologically sensitive areas;
 Limited exploitation of sand, stones, clay and gravel in non ecologically sensitive areas.

Mining projects will be categorised under impact level 1 (IL 1) if the screening process determines
that the proposed project fulfils the following conditions:

i) Potential residual impacts on the environment are likely to be minor, of little significance
and easily mitigated.
ii) Reliable means exist for ensuring that impact management measures can and will be
adequately planned and implemented.
iii) The project will not displace significant numbers of people, families or communities.
iv) The project is not located in, and will not affect:

environmentally-sensitive areas such as: National parks; Wetlands; Important

archaeological, historical and cultural sites; habitats of rare or endangered flora or
fauna species; natural forests;
 Productive agricultural land
 Areas protected under legislation
 Areas containing unique or outstanding scenery
 Mountains or developments on or near steep hill slopes
 Lakes and rivers;
 Areas important for vulnerable groups such as fishing communities;
 Areas near high population concentrations or mining activities where further
development could create significant cumulative environmental problems
 Ground water re-charge areas or drainage basins.
v) The project will not result in and/or:
 a) Policy initiatives which may affect the environment

73
  b) Major changes in land tenure
 c) Changes in water use through irrigation, drainage promotion or dams, changes in
fishing practices.
vi) The project will not cause:
 a) Adverse socioeconomic impact
 b) Land degradation
 c) Water pollution
 d) Air pollution
 e) Damage to wildlife and habitats
 f) Adverse impact on climate and hydrological cycle
 g) Creation of by-products, residual or waste materials which require handling and
disposal in a manner that is not regulated by existing authorities.
vii) The project will not cause significant public concern because of potential environmental
changes. The following are guiding principles:

 Is the impact positive, or harmful?

 What is the scale of the impact in terms of area, numbers of people or wildlife
affected?
 What is the intensity of the impact?
 What will be the duration of the impact?
 Will there be cumulative effects from the impact?
 Are the effects politically controversial?
Have the main economic, ecological and social costs been quantified?
 Will the impact vary by social group or gender?
 Is there any international or trans-boundary impact due to the proposed projects?
viii)The project will not necessitate further development activity, which is likely to have a
significant impact on the environment.

2. IL 2: Projects not requiring a full EIA but necessitate further level of assessment

This category represents projects believed to have adverse, but not irreversible environmental
impacts and mitigation and management measures can be readily designed and incorporated into
the project. Mining projects in this category are classified as medium sized. The EIA process for
these projects is similar to that of IL3 projects.

3. IL 3: Projects requiring a full EIA

This category involves projects for which it is evident that there will be significant and adverse
environmental impacts whose mitigation measures cannot readily be prescribed, and thus, must
undergo through a complete EIA process. Mining projects in this category are regarded as high
risk. This category involves projects for which it is evident that there will be significant and
adverse environmental impacts whose mitigation measures cannot readily be prescribed, and thus,
must undergo detailed EIA process.

74
Annex 2: Contents of the Audit Report

The audit report should contain all audit findings and a summary, including the following:

 The proponents name and address

 Project title
 Objective, scope and criteria of the audit;
 The audit team members;
 An executive summary of the audit process including any problems encountered during the
process
 Project site
 Project description;
 Review of all relevant environmental law and regulatory frameworks on health, safety,
environmental standards and sustainable use of natural resources;
 Verification of the level of compliance by the proponent with the conditions of the
environmental management plan;
 Evaluation of the proponent’s knowledge and awareness of and responsibility for the
application of relevant legislation;
 Review of all project documentation related to infrastructural facilities and designs;
 Examination of monitoring programmes, parameters, and procedures for control and
corrective actions in case of emergencies;
 Examination of records of incidents and accidents and the likelihood of future occurrence
of the incidents and accidents;
 Inspection of all buildings, premises and yards used for agricultural production and
processing purposes including stores, quarantine, and handling facilities in which
manufacturing, testing, transportation takes place within and without the project area, as
well as areas where shortage and disposal of goods is carried out, and give a record of all
significant environmental risks associated with such activities;
 Examination of public views on health and safety issues, especially from potentially
affected communities as well as project employees; and
 List of health and environmental concerns of past and on-going activities.

75
Annex 3: Audit Checklist on Occupational Health and Safety Management System

Occupational Health and Safety Management Systems are designed to assist organisations improve
their management of health and safety. In doing so, it helps to establish safer working
environments that will protect people at work by eliminating, or better managing, health and
safety hazards. This approach is consistent with the general requirements of health and safety
legislation. The following checklist helps an Auditor make a quick and easy evaluation of existing
health and safety management system and identify its strengths and weaknesses. The Auditor
needs to score the organisation against each of the following statements. This diagnosis can be
carried out by an individual or a small team. Score each question from 1 to 5 as indicated below
and then use the total to compare to the coloured line at the bottom of the table.

0 Nothing in place to show that this occurs
1. Little evidence exists to show this occurs
and it is likely to be overlooked on many
occasions
2. Some evidence exists that things are in
place but there are significant gaps in
implementation
3. A fair amount of evidence exists but there is still
some way to go until everything is in place
4. A significant amount of evidence is in place to
demonstrate that this occurs but more could be
done to ensure that it will happen on a consistent
basis
5. There is significant evidence to demonstrate that
this occurs and you have confidence that
appropriate actions will occur when needed

Score (0 to 5)
1. We have a formal health and safety policy that sets clear responsibilities, goals and
objectives for all sections of our organisation and for all persons including the CEO, line
management and employees.
2. We have a health and safety action plan (including timeframes and responsibilities) that
shows what we are trying to achieve and we have communicated this to all employees.
3. We have provided adequate resources to successfully implement our health and safety plan.
4. We have reviewed our legal obligations for health and safety and checked that we comply
with them.
5. Our employees are consulted about health and safety and involved in identifying and
resolving health and safety issues.
6. Our organisation has identified all workplace hazards both physical and psychological eg.
stress, occupational violence, etc through a collaborative process and has reduced the risk
associated with these hazards to an acceptable level.
7. All of our employees, including supervisors and managers, are trained in the health and
safety requirements relevant to their position.
8. We have an induction process that ensures the health and safety of new employees.
9. We have developed documented work procedures for all hazardous tasks and we monitor
and enforce compliance with them.
10. We have identified possible emergency situations that may occur, and have trained our
employees in the procedures to effectively respond to them.
11. We have appropriate first aid resources (trained first aiders, kits, eye wash stations etc.)
that meet the needs of our organization.
12. We record any injuries and incidents and investigate the causes to prevent recurrence.
13. We conduct regular inspections of our workplace to identify hazards and to check that our
hazard control measures are working.
14. We specify our health and safety requirements before purchasing goods or using the services
of contractors and verify that these requirements are met.
15. We have a health and safety manual, that includes our safe work procedures, and these are
known and used by our employees.

76
16. We have obtained current Material Safety Data Sheets for all the chemicals we use and we
make them available in the workplace.
17. The materials we use are stored safely to minimise manual handling and to prevent spills or
undesirable chemical reactions.
18. We maintain our plant and equipment according to a schedule and we keep maintenance
records.
19. We regularly audit our organization’s occupational health and safety management system,
review the results and take action to address areas that need improvement.
20. We have a process to collect, file and retain our health and safety records.
Now check how your total score compares to the following scale:
TOTAL SCORE
Poor Improving Towards
managing safety

0 20 40 60 80
100

77
Annex 4: Social Audit & Compliance Assessment Checklist

Social Audit & Compliance Assessment Report

Audit Date(s): Job No.:

Child Labour / Young Labour

No. Requirements Result Comments /
Audit
findings
1. Does the facility have a copy of valid laws and regulations on child
labour & young worker or understand its requirements?
2. Does the facility have a written policy on prohibiting child labor and
communicate this to all employees?
3. What is the legal minimum age of employees?
4. Does the youngest age of employees at the facility comply with local
legal requirements?
5. Does the facility have effective procedures to verify the age of
employee at the time of recruitment?
6. If Historical Child Labour identified, has proper remedial actions &
corrective actions been taken?
7. Does the facility have a written policy on young worker protection
and communicate this to all employees?
8. Are young workers protective in accordance with the law? (E.g.
registration, overtime hours, night work, physical examinations,
hazardous work, etc.)
HIV and Gender Related Issues (Health Clinics & Workplace)
1. What is the HIV prevalence (total, children<15years (disaggregated
by gender), adults aged 15-49years, women aged > 15years)?
2. What is the number of death recorded due to AIDS or AIDS-associated
diseases (e.g. TB)?
3. What is the number of orphan’s due to AIDS (aged 0 – 17)?
4. What is the number of pregnant women with HIV?
5. Does the facility have a copy of an HIV and AIDS workplace policy?
6. What is the number of people living with HIV (disaggregated gender)?
7. What is the number of reached with education and awareness?
8. What is the number of people accessing VCT services?
9. What proportion of employees/employers who know their HIV status?
10. What is the number of people trained on HIV and AIDS?
11. What is the number of people on ARVs?
12. How are condoms distributed and usage levels?
13. What’s the number of people accessing services for treatment of
opportunistic infections?
14. What are the number of day’s sick leave and compassionate leave for
AIDS-related reasons?
Forced Labour
1. Does the facility have a copy of valid laws and regulations on forced
labour or understand its requirements?
2. Does the facility have a written policy on Forced Labour and
communicate this to all employees?
3. Are workers provided employment contract and issued with written
copies?

78
4. Are employees required to lodge deposits such as illegal withholding
of salary, training fee, employment broker fee, fee for tools, fee for
uniforms, or original documents such as ID papers?
5. Is any evidence identified on the use of forced labour / prison labour
/ bonded labour?
6. Is any physical method used to limit freedom of employees during
working hours such as surveillance cameras, security guards or
locked exit(s)?
7. When employees are in dormitories, is there any restriction placed
on employees' freedom of movement?
8. Are employees forced to work overtime?
9. Are employees permitted time-off with doctor’s certificate or note
when sick or for maternity?
10. Are employees permitted to leave employment after giving
reasonable notice?
A. Health & Safety
1. Does the facility have a copy of valid laws and regulation on health
and safety or understand its requirements?
2. Is there written and adequate health and safety policy properly
communicated?
3. Is a senior management representative for health & safety
appointed?
4. Is safety committee established with members representing the
various shifts, functions and levels?
5. Is there an appropriate health and safety risk assessment for all
areas and job functions?
6. Are training and awareness programs on health and safety arranged
regularly for all employees?
7. Are all site buildings (including both production & dormitory)
maintained in good condition in both physical surface and structure,
and inspected with certificate?
8. Does the facility have a suitable working environment in respect of
ventilation, temperature, lighting, cleanliness, and tidiness?
9. Is potable water accessible and adequate at each facility floor?
10. Are workers provided with clean toilet facilities, which are private,
segregated for men and women, and adequate in number?
Fire safety (Including production & dormitory & canteen area)
1. Does the facility have valid fire inspection certificates issued by local
fire service authority?
2. Does the number of fire extinguishers meet local legal requirements?
Are they properly located?
3. Are all fire extinguishers inspected and tested regularly and ready to
use at all times?
4. Is fire and hazard early warning system such as smoke detector
installed and regularly tested?
5. Is an effective fire extinguishing system i.e. fire hydrant/fire hose or
sprinkler installed at each facility floor, inspected and maintained
properly?
6. Are documented fire drills conducted regularly and at least once a
year?
7. Are fire exits and escape routes adequate at each facility floor, and
easy of access?

79
8. Are exits and fire exits identified with sign or indicator lamps?
9. Are adequate emergency lighting system installed at each facility
floor?
10. Did any fire accident take place in the past 12 months at the facility?
Machinery safety & special equipment’s
1. Are adequate guarding or devices installed for moving/rotating parts
of machine, pulleys and belts or any other dangerous parts of
machines?
2. Are signs available which prohibit loose clothing, jewelry, and long
hair near moving machinery?
3. Does the factory perform regular preventive maintenance for the
machines including safety devices?
4. Are open stairs and platforms guarded by handrails?
5. Does the facility have valid inspection certificates and/or permits for
boilers, elevators, forklifts, pressure vessels and other special
equipment’s per local regulation?
6. Are the operators of above-mentioned equipment trained and
qualified per local regulation?
7. Is vehicles speed properly controlled in the facility area?
Electricity safety
1. Are all electricians qualified per local regulations?
2. Are electrical safety procedures implemented effectively to ensure
safety precautions such as grounding, discharging, and testing to be
taken?
3. Are all the electrical wires installed in fully acceptable condition and
adequately protected?
4. Are electrical installations checked monthly and repairs carried out
by competent electrician?
5. Are welding operators trained and qualified per local regulations?
6. Is hot work permit procedure implemented for welding, cutting and
open flame operation at the facility?
Chemical management
1. Is there a written procedure for safely storage and handling of
dangerous/hazardous chemicals?
2. Is a current dangerous/hazardous chemical inventory available?
3. Are all chemical containers properly labeled?
4. Are dangerous/hazardous chemical properly stored with secondary
containers, explosive-proof lamps, fire extinguishers, ventilation
fans equipped?
5. Are emergency eyewash stations provided at the chemical
storage/operating area?
6. Are MSDS available at the chemical storage/operating area?
7. Is adequate ventilation system including LEV equipped where
chemicals (e.g., solvents, solder) existed?
Occupational health management
1. As necessary, are air quality test and/or noise test performed at
workshops as per legal requirements?
2. Does the factory arrange occupational health examinations to the
workers exposed to hazardous environment?
Personal protective equipment
1. If the use of personal protective equipment (PPE), such as goggles,

80
 masks, safety shoes, earplugs, etc. is required to control safety
hazards, is the equipment correctly and consistently used by
employees where required?
2. Is this PPE at disposal of the workers free of charge?
3. Are signs and warnings posted in the corresponding areas reminding
employees to wear PPE?
Work related accidents management
1. Does the factory keep accident / injury / illness records?
2. Are corrective actions taken to prevent recurrence of work related
accidents?
First aid
1. Are adequate first aid kits located at each floor and marked with
signs?
2. Is there adequate employees trained on first aid?
3. If required by local law, is an in-house clinic/first aid station
established with competent doctor/first aider employed at the
facility?
Accommodation/Dormitory & Canteen
1. Are dormitories NOT physically connected with the production
and/or warehouse buildings?
2. Are the sleeping quarters separated for men and women?
3. Does the space per employee meet local laws?
4. Are there adequate bathrooms available to employees at dormitory?
5. Are sanitary areas clean and hygienic with available washing
facilities?
6. Are recreation areas available at the dormitory?
7. Are kitchen & canteen hygienic with adequate facilities & legal
permit?
8. Are adequate evidences identified (such as health examination) that
employees working in kitchen are suitable to food service?
9. Is any pest control program established and implemented effectively
at kitchen & canteen area?
Freedom of Association
1. Does the facility have a copy of valid laws and regulations on trade
union and freedom of association or understand its requirements?
2. Does the facility have a written policy on freedom of association and
communicate this to all employees?
3. Is employees' right to form and join free trade unions and employees'
associations acknowledged by the management and employees?
4. Is there a trade union formed at the facility? Pls. specify the name of
the union.
5. If restricted by law or if there is no formal employees union, does
the facility facilitate parallel means such as employee committee?
6. Do employees elect their own representatives / spokesperson(s)? If
Yes, specify name and title.
7. Are there regularly scheduled meetings between employee
representatives and management, and are meeting minutes on file?
8. Do employees' representatives have access to members at
workplace?
9. Does the facility have a written policy and procedure to protect
employees' representatives, union supporters and/or Union

81
 representatives from retaliation?
10. For non-unionized facility, are fair and effective mechanisms to
ventilate and resolve grievances of employees in place?
11. Has the facility experienced a strike, walkout, demonstration, or
other significant conflict with employees within the last 12 months?
Discrimination
1. Does the facility have a copy of valid laws and regulations on non-
discrimination or understand its requirements?
2. Does the facility have a written policy concerning discrimination and
communicate this to all employees?
3. Is any evidence identified on discrimination in hiring, promotion,
compensation, welfare, dismissal, retirement, etc. based on gender,
age, pregnancy, marital status, race, religion, disability, union
membership, political affiliation,
etc.?
4. Is there any evidence of sexual harassment, especially of young
female employees?
5. Do employees have access to and are familiar with procedures for
filing complaints about discrimination?
Disciplinary Practice
1. Does the facility have a copy of valid laws and regulations on
disciplinary practices or understand its requirements?
2. Does the facility have documented disciplinary rules?
3. Are the disciplinary rules communicated to all employees?
4. Are the disciplinary rules fair, reasonable and legal or validated by
local government authority?
5. Are the employee's disciplinary actions recorded?
6. Are deductions from pay for infractions / breaking of rules legal?
7. Does any evidence exist for mental / physical coercion?
8. Do employees have access to appeal in case of infractions / breaking
of rules?
Working Hours
1. Does the facility have a copy of valid laws and regulations on
working hours or understand its requirements?
2. Does the facility establish a written policy on working hours
(including overtime requirements if any), rest and vacations as per
legal requirements AND is the policy communicated to all
employees?
3. Are all working hours of employees recorded accurately &
documented completely?
4. Are employees' overtime exceed legal requirements?
5. Do the employees have at least one day (24 consecutive hours) in
seven days? If answer is no, then what is the longest period of
consecutive days that employees work?
6. Do employees have adequate time for rest & meal breaks?
7. Does the facility have any valid written approval or permit on extra
overtime hours from local labour authority?
Wages & Compensation
1. Does the facility have a copy of valid laws and regulations on
compensation and benefits or understand its requirements?
2. Does the facility establish a written policy on compensation and

82
 benefits as per legal requirements and communicate this to all
employees?
3. Do all employees' wages meet local minimum wages (including
trainees / apprentices / employees in probation period, dispatched
workers, student workers, etc.)?
4. Are the employees paid the legally required overtime wages?
5. Are legal benefits (social insurance, paid annual leave, maternity
leave, high temperature allowance, etc.) provided to employees?
6. Are the deductions from employees' wages fair, reasonable and
legal?
7. Is extra work to fulfill production target demanded without
payment?
8. Is rework paid for piece rate employees?
9. Is all compensation paid to employees themselves in cash/
cheque/direct to bank or any other method convenient to
employees?
10. Are wage slips given to employees and they understand the wage-
break up?
11. Is the payment frequency never exceed one working month?
Environment
1. Does the facility have a copy of valid laws and regulations on
environment protection or understand its requirements?
2. Does the facility have an environmental policy signed by top
management?
3. Does the facility management appoint a qualified management
representative with defined roles and responsibilities on
implementing environmental policy and practices?
4. Does the facility management conduct environmental impact analysis
on its operation and put in place mechanism to minimize the
negative impact on environment?
5. Does the facility have put in place environmental emergency
procedures related to risk identified (repotting, tank fulfilling,
chemical use)?
6. Are the employees provided with adequate and necessary
environmental awareness for both their specific job function and
general safety?
7. Does the facility have all approvals, permits and licenses required by
local laws or regulations?
8. Does the facility have proper waste water, gas, etc. treatment
before releasing?
9. Does the facility monitor the emission of waste water, gas, noise,
etc. as per legal requirements?
10. Does the facility segregate, store and dispose hazardous waste
properly?
11. Has an energy survey /assessment (e.g. electricity, heat, water,)
been undertaken?
12. Has an energy efficiency plan been launched to reduce resources
use?

83
Annex 5: Surface Atmospheric Audit Checklists

Point Standard Standard Comments

Met
1. Ventilation Management Plan
1.1 The principal employer has developed and implemented a
ventilation management plan.
1.2 The ventilation management plan identifies the
atmospheric contaminants present.
1.3 The ventilation management plan identifies the
contaminant control methods for each atmospheric
contaminant present.
1.4 The ventilation management plan includes the appropriate
PPE to be worn for each atmospheric contaminant where
peak or STEL exposures are likely.
1.5 The ventilation management plan includes a programme
for the monitoring and assessment of the atmospheric
contaminant exposure of significantly exposed employees
on a routine basis.
1.6 The ventilation management plan requires that exposure
assessment results are reported to all relevant personnel
in an effective, timely and documented manner.
1.7 The ventilation management plan includes a system for
the identification, reporting, rectification and employee
notification requirements of all ventilation and
atmospheric contaminant defects.
2. Ventilation Personnel
2.1 The manager has appointed a surface ventilation officer or
the mine is exempt by written directive issued by the
district inspector.
2.2 The district inspector was notified in writing of the
appointment.
2.3 The surface ventilation officer is appropriately trained and
qualified.
2.4 The surface ventilation officer has the authority in
consultation with management to close down operations in
areas where dangerous atmospheric contaminant levels
are identified.
2.5 Ventilation technicians undertaking measurements of air
and atmospheric contaminants are adequately trained.
2.6 Mine supervisors, employees and contractors receive basic
training in atmospheric contaminant control, suppression
and respiratory protection requirements.
2.7 Where gas monitoring equipment is installed, mine
supervisors, employees and contractors receive training in
the identification, control, awareness of alarms and PPE
requirements for normal and emergency situations.
3. Measuring Equipment

84
3.1 The mine has ventilation instrumentation in house, or
provided by an external provider, to conduct the required
air pressure and flow measurements.
3.2 The mine has measuring equipment in house, or provided
by an external provider, to measure the atmospheric
contaminants anticipated to occur.
3.3 The mine has equipment to measure the levels of oxygen
and gases where any toxic, asphyxiant or explosive gases
are anticipated to occur.
3.4 All measuring equipment is calibrated and maintained to
manufacturers’ specifications.
3.5 When ventilation or gas measuring equipment is sent for
calibration or repair, alternative equipment is made
available.
3.6 A record is kept of each item of calibrated equipment that
includes the latest date of calibration, the calibration
factors and the next due date.
3.7 A procedure exists to ensure that where indicator tubes
are used, the tubes are stored as recommended by the
manufacturer and the use-by-date has not expired.
4. Ventilation Record Keeping
4.3 The surface ventilation officer has access to the latest
applicable Australian Standards.
4.4 The surface ventilation officer has access to the latest
version of the Australia Safety and Compensation Council
(ASCC) “Guidance Note on the Membrane Filter Method for
Estimating Airborne Asbestos Fibres”.
4.5 A ventilation log book has been established.
4.6 The records indicate that inspections occur at regular
intervals for the presence and control of atmospheric
contaminants in workplaces.
4.7 The records indicate the Contam quarterly sampling quota
is carried out and reported in accordance with the
statutory requirements.
4.8 The records indicate that the monitoring and assessment
of the contaminant exposure of significantly exposed
employees occurs on a routine basis.
4.9 Sampling and personal exposure assessment results are
reported to all relevant personnel in an effective, timely
and documented manner
4.10 Contaminant sampling results taken over the last year to
evaluate operator exposure are all below the exposure
standard for both normal and extended shifts.
4.11 Sampling for respirable dust is carried out in accordance
with the required method.
4.12 Sampling for organic vapours is carried out in accordance
with the required method.
4.13 Sampling for inhalable dust is carried out in accordance
with the required method.
4.14 Sampling for asbestos fibres is carried out in accordance
with the required method.

85
4.15 The records include reports on the means and
effectiveness of all dust suppression and collection
equipment.
4.16 The records include reports on the means and
effectiveness of all fume hoods and fume extraction
equipment.
4.17 Ventilation and contaminant measurements are
documented and retained.
4.18 Each entry in the ventilation record book is dated, signed
and kept in area chronological order.
4.19 There is a procedure for the reporting and rectification of
ventilation and contaminant issues.

5. Atmospheric Contaminant Control

Point Standard Standard Comments
Met
5.1 Each dust suppression system is operated and maintained in
an effective operating condition.
5.2 Each dust extraction system is operated and maintained in an
effective operating condition.
5.3 Each dust enclosure system is operated and maintained in an
effective operating condition.
5.4 Each contaminant extraction system is operated and
maintained in an effective operating condition.
5.5 All hoods and appliances fitted to vessels used for the
chemical treatment of minerals or mineral substances are
operated and maintained in an effective operating condition.
5.6 All hoods and appliances fitted to capture hot gases from
smelting operations are operated and maintained in an
effective operating condition.
5.7 Where hoods and appliances are installed to remove
atmospheric contaminants the discharge outlet is at a
sufficient height to avoid contamination of other workplaces.

86
Annex 6: Surface Atmospheric Audit Checklist

Point Standard Standard Comments

Met
1.1 Exploration and mine production drilling equipment is fitted
with dust control devices which effectively control the
emission of dust at each source during drilling operations.
1.2 Precautions are taken to protect samplers from exposure to
dust during drilling and sampling operations.
1.3 The emission of dust is effectively controlled during truck
loading operations.
1.4 The emission of dust is effectively controlled along each open
pit road and vehicle operating area.
1.5 The emission of dust is effectively controlled during dumping
operations.
1.6 The emission of dust is effectively controlled at all stockpile
areas, stockpile stacking operations, stockpile tunnels and
material reclaim operations.
1.7 The emission of dust is effectively controlled at all crushing
and screening plant.
1.8 Spillage and dust build up around the crushing and screening
plant and on equipment surfaces is kept under control.
1.9 The emission of dust is effectively controlled along all
conveying equipment.
1.10 Spillage and dust build up around the conveyors and on
equipment surfaces is kept under control.
1.11 The emission of dust is effectively controlled within all
process operations.
1.12 Spillage and dust build up around plant and on equipment
surfaces is kept under control.
1.13 The emission of dust is effectively controlled within sample
preparation and analysis areas.
1.14 Spillage and dust build up in the sample preparation area and
on equipment surfaces is kept under control.
1.15 The air pressure in hand held airguns used for cleaning is
adequately reduced to prevent excessive dust generation.
1.16 Compressed air for cleaning is used carefully within the dust
capture enclosure so as not to generate dust in the workplace.
1.17 Compressed air is not used for cleaning where high risk
hazardous substances are added or present in the sample.
1.18 Compressed air is not used for cleaning the body or clothing of
employees.
1.19 The emission of dust is effectively controlled within product
bagging and packaging areas.
1.20 Spillage and dust build up in the bagging and packaging area
and on equipment surfaces is kept under control.
1.21 The emission of dust is effectively controlled at truck loading
and unloading areas.
1.22 Spillage and dust build up in the truck loading and unloading
areas and on equipment surfaces is kept under control.

87
1.23 The emission of dust is effectively controlled at train loading
and unloading areas.
1.24 Spillage and dust build up in the train loading and unloading
areas and on equipment surfaces is kept under control.
1.25 The emission of dust is effectively controlled at road train
loading and unloading areas.
1.26 Spillage and dust build up in the road train loading and
unloading areas and on equipment surfaces is kept under
control.
1.27 The emission of dust is effectively controlled at ship loading
and unloading operations.
1.28 Spillage and dust build up in the ship loading and unloading
operations and on equipment surfaces is kept under control.
1.29 Spillage and dust build up on all internal building structures is
kept under control.
1.30 Measures are taken to minimise dust pick up during strong
winds.
1.31 Water of acceptable quality is used for dust suppression.

2. Naturally Occurring Hazardous Gases

Point Standard Standard Comments
Met
2.1 A hazardous gas management plan has been developed and
implemented.
2.2 The District Inspector of Mines is notified in writing of the
precautions taken to monitor and control the presence of the
hazardous gases.
2.3 Employees are notified of the precautions taken to monitor
and control the formation and emission of the hazardous gases
present.
2.4 Monitoring devices are installed which give a warning when
the peak or STEL level of any hazardous gas is being
approached.
2.5 Where gas monitoring equipment is installed, adequate
notices are displayed to inform employees of the meaning of
the monitor alarm and the actions to be taken.

3. Process Atmospheric Contaminants

Point Standard Standard Comments
Met
3.1 There is a register of all hazardous substances used or
produced at the mine.
3.2 Material safety data sheets for all hazardous substances and
atmospheric contaminants present are available and readily
accessible to all employees.
3.3 There is a written procedure to minimise and control the level
of each hazardous substance and associated airborne
atmospheric contaminant released into the workplace.
3.4 The procedure for handling, usage and storage of hazardous
substances is in accordance with the instructions contained in
the Material Safety Data Sheets.

88
3.5 The method used to reduce exposure to each hazardous
substance is in accordance with the recognised hierarchy of
control.
3.6 The presence of a hazardous substance and associated
atmospheric contaminant in an enclosed system is identified to
all employees exposed to the risk.
3.7 Smoking is prohibited in all workplaces where organic or
volatile solvents are used.
3.8 Smoking is prohibited in all workplaces where flammable
vapours are present.

4. Asbestos
Point Standard Standard Comments
Met
4.1 Restrictions are placed on the use of asbestos and asbestos
products.
4.2 There is a register of asbestos containing material on site.
4.3 A system is established to identify the presence of naturally
occurring asbestos contamination.
4.4 An asbestos management plan has been developed and
implemented.
4.5 The District Inspector of Mines is notified in writing of the
presence of contaminant asbestos.
4.6 Asbestos removal work is carried out in accordance with the
procedures specified in the Code of Practice for the Safe
Removal of Asbestos (NOHSC:CP002-1988) published by the
ASCC.
4.7 The District Inspector of Mines is notified in writing of the
removal of asbestos prior to the work commencing.
4.8 Smoking is prohibited in all workplaces where the air is likely
to contain asbestos.

89
5. Biological Monitoring
Point Standard Standard Comments
Met
5.1 Biological monitoring is undertaken where employees who are
engaged in specified occupational exposure work are exposed
to hazardous substances and there is a reasonable likelihood
that accepted values might be exceeded.
5.2 There is an adequate health surveillance procedure in place
for each specified occupational exposure work to regularly
monitor those employees requiring biological monitoring.
5.3 The arrangement and cost of the biological monitoring is
organised and borne by the employer.
5.4 The biological monitoring results obtained from each
employee are retained as confidential records by the
employer.
5.5 Where biological monitoring identifies employee exposure
levels are near or above prescribed safe limits remedial
action is taken.

6. Thermal Comfort
Point Standard Standard Comments
Met
6.1 All production drilling equipment is fitted with a fully enclosed
air conditioned cabin.
6.2 All mobile equipment is fitted with a fully enclosed air
conditioned cabin.
6.3 Crusher and screening plant control cabins are equipped with a
means of heating and cooling.
6.4 Process plant rooms and cabins are equipped with a means of
heating and cooling.
6.5 The climate control equipment is working effectively in vehicle
and fixed enclosed cabins.
6.6 Air conditioner filters are regularly checked and cleaned.
6.7 Vehicle and fixed enclosed rooms/cabins are effectively sealed
to prevent the entry of contaminants.
6.8 Adequate ventilation air changes are provided to each enclosed
operator control room and cabin.
6.9 The interior of each vehicle and fixed enclosed rooms/cabin is in
a clean condition.
6.10 Stockpile tunnel temperatures and air velocities are monitored
and controlled.
6.11 Where employees are required to work for extended periods
exposed to the elements, safe systems of work have been
developed.
6.12 Cooling towers, evaporative condensers, warm water systems or
other plant or devices which promote the growth of
microorganisms have sufficient controls to prevent the growth of
those organisms.
6.13 Refrigeration Plants of a size greater than 100kW(R) have
management procedures and are fitted with monitoring devices
to detect and deal with the leakage of refrigerant.

90
7. Personal Protective Equipment
Point Standard Standard Comments
Met
7.1 A site wide risk assessment has established the tasks which
require respiratory protection devices to be used.
7.2 There is a program to select the appropriate respiratory
protection for a person.
7.3 Respiratory protection devices are freely available and
employees are aware of where and how to obtain the correct
device.
7.4 Employees are fit tested for the type of respirator issued to
them.
7.5 Employees are required to be clean shaven where required to
wear a half, full or disposable face piece respiratory
protection equipment (RPE).
7.6 Employees are trained in the use of the respirator provided.
7.7 There is a maintenance program for non-disposable
respiratory protection.
7.8 Respirators are cleaned, maintained and stored as specified in
the maintenance program.

8. Confined Spaces
Point Standard Standard Comments
Met
8.1 The confined space entry procedure requires atmospheric
testing to be carried out prior to and during entry into the
confined space where atmospheric contaminants are present
or likely to be introduced into the confined space.
8.2 The permit to dig procedure requires atmospheric testing to be
carried out prior to and during employee entry into a narrow
surface excavation or trench where the presence of high
specific gravity hazardous atmospheric contaminants in the
ground is suspected or known.

91
9. Abrasive Blasting

Point Standard Standard Comments

Met
9.1 Abrasive blasting work is carried out in accordance with the
WorkSafe Western Australian Commission code of practice for
abrasive blasting.
9.2 Material used for abrasive blasting contains less than 5% silica
by weight.
9.3 Material used for abrasive blasting contains less than 1% of
any one of the following - arsenic, beryllium, lead, cadmium,
nickel, antimony, cobalt, chromium or tin.
9.4 Material used for abrasive blasting contains no radioactive
substance as defined in the Radiation Safety Act 1975.
9.5 Recycled dry abrasive blasting material is treated to remove
respirable dust or other adverse material.
9.6 The person operating the abrasive blasting machine wears an
airline respirator of the hood or helmet type and the
appropriate PPE.
9.7 The air supply to the airline respirator is of acceptable
breathable quality, pressure and temperature.
9.8 The abrasive blasting machine is fitted with an automatic cut-
off device.

92
Annex 7: Fire Prevention Audit Checklist

Point Standard Standard Comments

Met
1. Fire Prevention Plan
1.1 The mine has prepared an underground fire prevention and
control plan.
1.2 The plan has been developed through a process of risk
assessment.
1.3 The plan describes the fire risks present at the mine.
1.4 The plan describes the methods by which the fire risks are
managed.
1.5 There is a program for conducting fire emergency drills for
underground employees.
2. Resource requirements
2.1 Current fire fighting infrastructure and equipment is
marked on an underground plan.
2.2 Underground communications equipment is marked on an
underground plan.
2.3 Fresh air bases, refuge chambers and escape ways are
marked on an underground plan.
2.4 Current ventilation circuits are marked on an underground
plan.
2.5 Air doors, stoppings, fans, regulators and ventilating
devices are marked on an underground plan.
2.6 The potential for ventilating air flow modifications, by
means of primary fan operational adjustments, has been
predetermined and documented.
2.7 There is an automated alarm system that can indicate the
presence of an underground fire by monitoring the mine
ventilating air exhaust.
2.8 There is a system in place to enable all persons working
underground to be promptly accounted for in the event of
an emergency.
2.9 A means of transporting fire fighting equipment
underground is provided.
2.10 Mutual aid agreements are in place with other mines.
3. Personnel and training
3.1 All underground personnel are instructed in how to use the
emergency communications systems available.
3.2 All underground personnel are trained in how to respond to
an outbreak of fire.
3.3 All underground personnel are trained in the evacuation
procedures.
3.4 Training for underground mobile equipment operators
includes awareness of the types of fires likely on mobile
equipment and the methods used to control and fight them.
3.5 Training for underground fixed equipment operators
includes awareness of the types of fires likely on fixed
equipment and the methods used to control and fight them.

93
3.6 Only competent persons may use hot work equipment
underground.
4. Flammable / combustible liquids and materials underground
4.1 The District Inspector of Mines has been notified in writing
of the location and details of each diesel fuel service and
storage facility constructed underground.
4.2 Diesel fuel service and storage facilities are located
underground such as to minimise the risk of hazards from
that facility.
4.3 Diesel fuel service and storage facilities are constructed
underground such as to minimise the risk of hazards from
that facility.
4.4 Diesel fuel service and storage facilities located
underground are ventilated such as to minimise the risk of
hazards from that facility.
4.5 Diesel fuel service and storage facilities that are
constructed underground conform to the relevant
Australian Standards.
4.6 Where diesel fuel is reticulated from the surface to
underground storage facilities, static electricity build up,
due to fluid flow, is prevented.
4.7 Only purpose-built clearly labelled containers, which do not
leak, are used to transport diesel fuel underground.
4.8 Diesel tank storage facilities located underground are
bunded with a capacity of 150% of the largest tank present.
4.9 The quantity of diesel fuel stored underground does not
exceed that required for one week of work underground.
4.10 Flammable / combustible liquids and materials are stored
and / or dispensed with 'no smoking', ‘no naked flame’ signs
displayed.
4.11 Spill containment equipment is available at those locations
where flammable / combustible liquids are dispensed and
any spillage is immediately cleaned up.
4.12 Waste liquids and materials that are flammable /
combustible are collected and removed to surface on a
regular basis.
4.13 An automatic fixed fire suppression system is installed at
each location where oils, fuels and lubricants are stored or
dispensed underground.
4.14 Automatic fixed fire suppression systems can be manually
operated from a safe location.
5. Underground mobile equipment

94
5.1 Underground mobile equipment that is fuelled underground is fitted with
“fast fill” type fuelling systems.
5.2 Each diesel engined unit that is used underground and is turbocharged or
rated at 125 kW or more, and each loader or grader that is used
underground, is equipped with an AFFF or FFFP fire suppression system
with a minimum of 2 activators.
5.3 Remotely controlled underground mobile equipment is fitted with remote
activation of the on board fire suppression system from the operator’s
remote control unit.
5.4 Underground loading and hauling equipment is fitted with brake
temperature indicators.
5.5 The pre-start check of underground mobile equipment includes an
inspection for potential fire hazards.
5.6 There is a system in place for the regular inspection of underground
mobile equipment for potential fire risks, by a competent person.
5.7 The scheduled service fire risk inspection includes a check of the integrity
of fuel and hydraulic lines, the condition of electrical wiring, and the
integrity of emergency shut down systems.

5.8 The scheduled service fire risk inspection includes a check of the integrity
of the shielding of the fuel and oil hoses in the vicinity of the exhaust and
turbo charger.

5.9 The scheduled service fire risk inspection includes a check of the battery
installation for rigidity, tight terminal clamps, cleanliness, etc.

5.10 The scheduled service fire risk inspection includes a check of the fire
suppression systems and extinguishers fitted to the item of underground
mobile equipment.

6. Underground fixed mechanical installations

95
Point Standard Standard Comments
Met
6.1 Underground conveyor systems are monitored for abnormal
operating conditions that could result in a fire.
6.2 Underground conveyor haulage ways have a fixed fire
detection / suppression system installed that is designed for
automatic operation and also has provision for manual
operation.
6.3 Underground fixed equipment condition monitoring and fire
detection / suppression systems are maintained.
6.4 Underground conveyor belts are of a flame resistant type.
6.5 Underground belt driven equipment e.g. pumps, is routinely
checked for drive belt tightness.
6.6 Underground areas with fixed mechanical equipment
installed and operating have appropriate portable fire
extinguishers located in the intake airway.

7. Underground Fixed Electrical Installations

Point Standard Standard Comments
Met
7.1 There are documented standards for the installation of
electrical equipment and cables, such that damage by
mobile equipment or from other types of impact, is
prevented or minimised.
7.2 Underground oil filled electrical equipment installations are
constructed so as to contain any leaks.
7.3 Only non-flammable coolants are used in underground
electrical equipment installations.
7.4 Where underground fixed electrical installations are within
fenced enclosures, appropriate portable fire extinguishers
are located outside of the fence, in the intake airway.
7.5 Only non-flammable sprays are used in the maintenance and
cleaning of underground electrical equipment.

96
8. Underground Air Compressors
Point Standard Standard Comments
Met
8.1 Stationary and skid mounted air compressors installed
underground comply with AS 4297.
8.2 Air compressors used underground and driven by a diesel
engine are liquid cooled.
8.3 Where an air compressor used underground is driven by a
diesel engine, the engine is provided with an automatic fire
suppression system.
8.4 Air compressors used underground are fitted with a heat
sensor in the discharge port which will initiate an alarm and
then shut down at 150 degrees Celsius.
8.5 Where an air compressor used underground is unattended, it
is located in a return ventilation airway behind an air
control device.

9. Underground Workshops
Point Standard Standard Comments
Met
9.1 There are at least 2 clearly marked exits from each
underground workshop.
9.2 Appropriate fire fighting appliances are provided in
underground workshops.
9.3 Class dedicated storage cabinets are used to store the
hazardous substances used in the workshop.
9.4 All compressed gas cylinders and associated equipment are
checked for leaks.

10. Maintenance and Operating Procedures Underground

Point Standard Standard Comments
Met
10.1 A hot work permit system is in place for all such work
underground work not carried out in a workshop.
10.2 Maintenance procedures identify associated fire hazards.
10.3 Both mobile equipment and fixed fire suppression systems are
tested and maintained in accordance with the manufacturer’s
specifications.
10.4 There is an inspection and maintenance procedure for fire
hydrants, extinguishers and signs.
10.5 Operating procedures require that a vehicle that experiences a
flat tyre underground is then only driven a short distance to a
location where a new tyre can be fitted.
10.6 Operating procedures require that trackless units are not left
unattended unless the engine or power supply has been
switched off.

97
Annex 8: Mineral Exploration Audit Checklist

1 Site preparation
Point Standard Standard Comments
met
1.1 Tracks to the drill site are suitable for drilling, support and
emergency vehicle access.
1.2 There are designated escape routes.
1.3 Access routes to the drill site are clearly marked.
1.4 A traffic management plan has been implemented,
including the designation of parking areas.
1.5 The prepared ground and/or constructed drill pad are level
and stable.
1.6 The drill site is clear.
1.7 Overhead powerlines, overhanging vegetation, underground
services and other obstructions have been clearly
identified.
1.8 The drill rig, service vehicles and plant are positioned to
minimise exposure to hazards.
1.9 Where required, edge protection is in place for the drill
site.
1.10 Sumps have been constructed to contain all drilling fluids.
1.11 Sumps are barricaded.
1.12 Safety and warning signs are present, clear, legible and
suitably located.

2 Safety Controls
Point Standard Standard Comments
met
2.1 At least two emergency stops are installed for the drill rig,
and there is a testing regime in place.
2.2 All sources of potential energy are identified and isolated
when performing maintenance or repairs.
2.3 All sources of stored energy are identified and isolated
when performing maintenance or repairs on pressurised
systems.
2.4 Fire-fighting resources are readily accessible at work areas
where there is a risk of fire.
2.5 Where practicable, an automatic fire suppression system is
installed on each item of plant.
2.6 All vehicles at the site are parked in a fundamentally safe
way.

98
3 Rotating and moving parts
Point Standard Standard Comments
met
3.1 A risk assessment has been conducted to identify any
hazards associated with rotating and moving parts, and
assess the risks of an employee being exposed to those
hazards.
3.2 An audit has been conducted to ensure all practical
measures have been taken to control risks associated with
rotating and moving parts.
3.3 Where required, an action plan with due dates and
responsibilities has been developed for the installation,
modification or replacement of guarding.
3.4 A competent person regularly reviews drilling operations to
ensure the adequacy of guarding and systems of work for
rotating and moving parts.

99
4 Compressed air systems
Point Standard Standard Comments
met
4.1 Hoses, couplings, seals and air lines are appropriately rated
for the compressed air system being used.
4.2 Where practicable, engineered systems with designated
connection points are installed.
4.3 At least one emergency stop is installed for each auxiliary
compressor unit, and there is a testing regime in place.
4.4 An air pressure relief system is installed for each
compressed air line.
4.5 A competent person regularly inspects the compressed air
system, and takes immediate corrective action where
necessary.
4.6 Air receivers and pressure relief valves are regularly
inspected, tested and certified by a competent person.
4.7 Fit-for-purpose restraining devices are installed on each
compressed air hose.
4.8 The anchor points for restraining devices are appropriately
rated and fit-for-purpose.
4.9 Blockages in compressed air systems are removed according
to a safe system of work.
4.10 There is a preventative maintenance program in place for
compressed air systems.
4.11 Access to high-risk areas associated with compressed air
systems is restricted.
4.12 Compressed air is only used for appropriate purposes.

5 Hydraulic systems
Point Standard Standard Comments
met
5.1 Pipework, hoses, couplings, seals and hydraulic lines are
appropriately rated for the hydraulic system in use.
5.2 Where practicable, non-flammable and non-toxic hydraulic
fluids are used.
5.3 Where practicable, engineered systems are installed and
hydraulic hoses and lines are shielded against wear.
5.4 Where practicable, screens are installed or hoses and lines
configured to minimise interaction with hot components or
electrical sources.
5.5 A competent person regularly inspects the hydraulic system,
and takes immediate corrective action where necessary.
5.6 There is a safe system of work to search for or confirm
hydraulic leaks that does not involve the use of hands or
fingers.
5.7 There is a preventative maintenance program in place for
hydraulic systems.
5.8 Access is restricted to high-risk areas associated with hydraulic
systems.

100
6 Hazardous substances and dangerous goods
Point Standard Standard Comments
met
6.1 The hazardous substances and dangerous goods inventory is
maintained and reviewed regularly, and reduced where
practicable.
6.2 Current material safety data sheets (MSDSs) are available
for all products used on site.
6.3 Control and response measures are in place to manage the
uncontrolled release of hazardous substances and dangerous
goods.
6.4 Containers, hoses, couplings, seals and lines are rated for
the substance in use.
6.5 Hazardous substances and dangerous goods are stored and
handled safely.
6.6 Screens are installed or hoses and lines configured to avoid
interaction of flammable substances with hot components
and ignition or electrical sources.
6.7 Where practicable, self-bunded containers, bunded pallets
or portable bunds are used for hazardous substances or
dangerous goods.
6.8 Appropriate fire-fighting equipment is available where
flammable substances are used.
6.9 There is a preventative maintenance program in place for
all flammable substance systems.
6.10 Sufficient spill response equipment is available to deal with
a complete failure of the largest container of hazardous
substances or dangerous goods.
6.11 All spills of hazardous substances or dangerous goods are
cleaned up and cleaning aids disposed of appropriately.
6.12 Appropriate personal protective clothing and equipment
(PPE) is provided to avoid contact when handling hazardous
substances or dangerous goods.

7 Electricity
Point Standard Standard Comments
met
7.1 Electrical work is undertaken by licensed electricians.
7.2 Electrical equipment and installations are correctly isolated
before maintenance or repair work commences.
7.3 Safety switches and residual current devices (RCDs) are used.
7.4 Voltage reducing devices (VRDs) are used on welding equipment.
7.5 There is an electrical inspection, testing and tagging program in
place to ensure electrical equipment and safety devices are
maintained in good working order by a competent person.
7.6 Electrical equipment is rated for the expected working
conditions.

101
7.7 The site plan allows for the appropriate placement of electrical
equipment and cables.
7.8 There is a safe system of work for using electrical equipment
and systems under all conditions likely to be encountered.

8 Manual tasks
Point Standard Standard Comments
met
8.1 Where practicable, hazardous manual tasks are eliminated
or mitigated through the use of engineering controls.
8.2 There is a safe system of work to reduce the risk of injury to
personnel from hazardous manual tasks associated with
drilling activities.
8.3 There is a safe system of workto reduce the risk of injury to
personnel from hazardous manual tasks associated with
handling loads.
8.4 There is a safe system of workto reduce the risk of injury to
personnel from hazardous manual tasks associated with
using hand tools, plant and equipment.
8.5 There is a safe system of workto reduce the risk of injury to
personnel from hazardous manual tasks associated with tyre
changing and repairs.
8.6 There is a safe system of work to reduce the risk where
personnel are likely to be exposed to repetitive tasks or
vibration.
8.7 Non-engineered, modified tooling is not used.
8.8 There is a safe system of workto ensure work at night can be
performed safely.

9 Working at height

102
Point Standard Standard Comments
met
9.1 Where practicable, working at height hazards are
eliminated through the use of engineering controls.
9.2 There is a safe system of work for working at height,
including rescue plans.
9.3 Where practicable, alternative means of access are
provided rather than working at height.
9.4 Areas of fall risk are controlled with edge protection,
handrails or other engineering controls.
9.5 There is a fall protection system in place for tasks that
involve working at height.

10 Falling objects
Point Standard Standard Comments
met
10.1 A competent person regularly inspects rig components, and
takes immediate corrective action to eliminate the hazard of
falling objects.
10.2 There is a preventative maintenance program in place for rig
components.
10.3 Where practicable, components with high risk of falling are
secured with a restraint.
10.4 There is a safe system of work for tasks that involve working at
height.
10.5 Work tasks are planned and “working at height” toolkits used to
minimise the requirement for tooling deployed at height.
10.6 Where practicable, attachment points are provided to secure
tools with a lanyard.
10.7 Drop zones are adequately delineated to restrict access.

11 Working in hot environments

Point Standard Standard Comments
met
11.1 There is a system in place to prevent heat-related illness.
11.2 All personnel are aware of the underlying causes of heat
strain, recognise its symptoms and know how to respond.
11.3 Personnel at risk from heat stress are monitored for signs of
heat strain.
11.4 Where practicable, weather protection and cool rest and
recovery areas are provided.
11.5 There is a safe system of work for new employees and those
returning to work after a break to acclimatise to working in
hot environments.
11.6 Where practicable, hours of work are scheduled so that
physically demanding work is done in cooler periods of the
day.
11.7 All personnel are provided with clothing suitable for the
environment.

103
12 Fatigue and mental wellbeing
Point Standard Standard Comments
met
12.1 There is a safe system of work to prevent fatigue and
support mental wellbeing at the workplace.
12.2 There is a fatigue management plan for exploration
activities and all personnel are trained in its application.
12.3 All personnel are aware of the underlying causes of fatigue
and stress, can recognise the symptoms and know how to
respond.

13 Airborne contaminants and natural gases

Point Standard Standard Comments
met
13.1 There is a general dust management plan and all personnel are
trained in its application.
13.2 Where fibrous, radioactive or toxic minerals may be present,
the dust management plan incorporates a management plan for
them.
13.3 There is a safe system of work for monitoring and managing
hazardous gases released during drilling, and personnel are
trained in its application.
13.4 All personnel are aware of the likelihood of encountering
fibrous, radioactive or toxic metal-bearing minerals, and
hazardous gases and know how to respond.
13.5 Where practicable, wet drilling methods are used in areas
identified as high-risk for fibrous minerals and other airborne
contaminants.
13.6 Where practicable, dust produced by drilling is collected and
contained.
13.7 Where dust collection and containment are not practicable,
dust is directed away from areas where personnel may be
present.
13.8 All personnel exposed to atmospheric contaminants are fit
tested and trained in respirator use.
13.9 Disposable respirators are replaced regularly to prevent build-
up of dust.

104
14 Noise
Point Standard Standard Comments
met
14.1 There is a noise control plan.
14.2 New plant and equipment is engineered to maintain the
lowest possible level of noise.
14.3 Noise suppression devices and techniques are used.
14.4 Where the noise exposure standard could be exceeded,
hearing protection is provided to enable effective
communication.
14.5 Prominent signage delineates areas where hearing
protection is required.
14.6 Noise labels are attached to items of fixed plant, where
appropriate.
14.7 There is a hearing protection program in place and all
personnel know when and where hearing protection is
required and comply with the program.
14.8 All exposed personnel are fit tested and trained in hearing
protection use.

15 Ionising Radiation
Point Standard Standard Comments
met
15.1 A radiation management plan approved by the State Mining
Engineer and Radiological Council is in place for uranium,
thorium or mineral sands exploration, or where a nuclear
borehole logger is used.

16 Hot Work
Point Standard Standard Comments
met
16.1 There is a safe system of work for hot work.
16.2 Hot work is not undertaken when total fire ban conditions
exist.
16.3 Hot work is restricted to specially designated areas that,
where practicable, are within the line of sight of other crew
members.
16.4 Fuel and ignition sources are minimised at the work area.

17 Extreme weather and bushfires

Point Standard Standard Comments
met
17.1 Incident management and emergency response plans are in
place to deal with severe weather events and bushfires, and all
personnel know how to respond.
17.2 Severe weather events and bushfires are tracked and
monitored.

105
17.3 All personnel are aware of the likelihood of flooding or flash
flooding, and know how to respond.
17.4 There is a safe system of work so personnel are not exposed to
lightning strikes.
17.5 If there are signs of suspected lightning strike, plant and
equipment are checked for damage before use.
17.6 There is a safe system of work for crossing of watercourses.
17.7 There is a safe system of work to ensure loose objects are
appropriately anchored or secured and do not become
projectiles in high winds.

18 Light vehicle movement

Point Standard Standard Comments
met
18.1 The original equipment manufacturer (OEM)
recommendations for light vehicle inspection and
maintenance are followed.
18.2 Light vehicle modifications and load configurations are
assessed to determine their likely effect on stability and
profile, and address risks.
18.3 There is a safe system of work to manage the ground, road
and weather conditions likely to be encountered by light
vehicles.
18.4 Changes to ground, road and weather conditions that may
affect light vehicle movement are monitored.

19 Heavy vehicle movement

Point Standard Standard Comments
met
19.1 The OEM recommendations for rig movement are followed.
19.2 Rig modifications are assessed to determine their likely
effect on stability, design specifications and profile, and
address risks.
19.3 There is a safe system of work to manage the ground, road
and weather conditions likely to be encountered by heavy
vehicles.
19.4 Changes to ground, road and weather conditions that may
affect heavy vehicle movement are monitored.
19.5 There is a safe system of work for manoeuvring drill rigs and
equipment, including identifying the roles and
responsibilities of designated spotters.
19.6 There is a preventative maintenance program in place to
avoid in-transit damage to heavy vehicles.
19.7 After rig movements, a pre-start check of the rig and its
components is undertaken by a competent person.

20 Remoteness of exploration
Point Standard Standard Comments
met
20.1 There is a safe system of work to plan and monitor travel to and
from work in remote locations.

106
20.2 Communication, emergency response and incident management
plans are in place that reflect the remote conditions and address
operational needs, and ensure personnel are trained in their
application and how to use the equipment.
20.3 There is a safe system of work for selecting fit-for-purpose modes
of transport.

3.21 Housekeeping
Point Standard Standard Comments
met
21.1 The site plan allows for the orderly movement of personnel,
equipment and materials.
21.2 Tools and equipment are properly stored after use.
21.3 Daily inspections and clean-ups are undertaken.
21.4 There are designated areas for storage and rubbish disposal.
21.5 There are designated areas for eating and ablutions.
21.6 At the completion of drilling, drill holes are plugged and
rehabilitated and sumps filled.

107
Annex 9: Noise Audit Checklist

POINT STANDARD COMPLIANCE COMMENT

1. NOISE CONTROL POLICY

1.1 There is a written Policy Statement which sets out the
Noise Control Policy of the organisation.
1.2 The Noise Control Policy Statement is signed by the
responsible person.
1.3 The Noise Control Policy Statement is dated with the date
of issue.
1.4 The Noise Control Policy Statement states a date by which
it must be reviewed.
1.5 The Noise Control Policy Statement is prominently displayed
at numerous locations throughout the site.
1.6 The Noise Control Policy sets out specific noise exposure
goals for employees.
1.7 The Noise Control Policy declares management’s
commitment for selection and purchase of quiet
equipment.
1.8 The Noise Control Policy declares management’s
commitment for noise controls in temporary work areas.
1.9 The Noise Control Policy declares management’s
commitment for undertaking audiometric tests.
1.10 The Noise Control Policy declares management’s
commitment to provide the resources needed to achieve
the stated noise goals.
1.11 The Noise Control Policy contains general statements of the
roles and responsibility of the organisation employee and
contractors in implementing the policy.
1.12 Employees are provided with an overview of the
organisations noise control policy
2. NOISE REPORT
2.1 There is a current noise report.
2.2 Contractors are covered by a current noise report.
2.3 The State Mining Engineer has been notified of the report.
2.4 A copy of the notification form is included in the original
report.
2.5 A summary of noise control work undertaken previously is in
the report.
2.6 Noise measurement data is in the report.
2.7 Strategies to deal with noise sources by means of
engineering noise control are given in the report.
2.8 Recommendations for reduction of exposure time are in the
report.
2.9 Recommendations for selection of personal hearing
protectors are in the report.
2.10 Noise report is signed and dated by a noise officer.
2.11 Instrument calibration certificates are appended to the
report.
2.12 Floor plan contours are appended to the report.

108
2.13 Noise report is readily available to employees.
2.14 The contents of the noise report have been communicated
to employees.
3. NOISE CONTROL PLAN
3.1 There is a Noise Control Plan listing engineering and
administrative noise control measures identified in the
noise report.
3.2 The Noise Control Plan has been implemented.
3.3 The plan identifies the proposed noise control measures
based on appropriate ranking of noise problems.
3.4 The plan specifies dates when the documented actions are
to be completed.
3.5 The plan shows noise reduction resulted from
implementation of the documented actions.
3.6 The plan includes procedures for its review and update.
3.7 Regular progress reports are provided to the manager.
4. BUY QUIET PROCESS
4.1 There is a purchase specification which specifies maximum
acceptable noise emission values.
4.2 There is a noise test form used for obtaining information on
noise data from suppliers.
4.3 Noise is taken into account in the selection of any new
plant.
4.4 Noise emissions of any noisy plant are checked upon its
delivery / installation on site.
5. NOISE CONTROL MEASURES
5.1 There is a system for inspection and maintenance of noise
control equipment.
5.2 There is a procedure for reporting faults of control
equipment faults.
5.3 There is a system for the repair of reported equipment
faults.
5.4 There is a system to identify the need for control of
employee noise exposure in temporary work areas.
6. PERSONAL HEARING PROTECTORS
6.1 There is a system for purchase of hearing protectors with
recommended attenuation levels.
6.2 Employees are issued with hearing protectors having
recommended attenuation levels.
6.3 There is a system for regular checks of wearing rates and
practices
6.4 Facilities are readily available for the cleaning of reusable
protectors.
6.5 There is a system for prompt replacement of worn or
damaged protectors
7. SAFETY WARNING SIGNS
7.1 Noise hazard areas where hearing protection must be worn
are sign posted.
7.2 Safety warning signs for hearing protection are kept clean.

7.3 Where sign posting is not practicable, alternative

109
 arrangements are made to recognise circumstances in
which personal hearing protectors are required.
8. INFORMATION INSTRUCTION & TRAINING
8.1 The site induction includes a section on the site noise
hazards and the wearing of hearing protection.
8.2 Employees are provided with information on damage to
their hearing resulting from exposure to excessive noise
8.3 Employees are given instruction and training on the use,
fitting and care of personal hearing protectors.
8.4 Employees are provided with information on noise control
measures which are in use or are planned.
8.5 Instruction and training obtained by employees is recorded.

9. NOISE DOSIMETRY
9.1 There is a site noise dosimetry program implemented
aiming to assess employee exposure to noise
The Resources Safety recommended minimum sampling
9.2 frequency is included in the sampling program.
9.3 Employee noise exposure results are assessed and
corrective action undertaken if necessary.
9.4 Each employee sampled is provided with the result of their
noise exposure assessment.
9.5 The sampling results are submitted to the Resources Safety
for entry into the Mine Health database.

Annex 10: Stockpiles and Dump Audit Checklist

POINT STANDARD STANDARD COMMENTS

MET
1. STOCKPILE / DUMP DESIGN
1.1 The design is such that any future potential instability,
due to the physical properties of the material being
dumped, is minimised.
1.2 The design is such that any future potential instability
in dump material compaction, due to the size and
weight of the equipment used during construction, is
minimised.
1.3 The design is such that any future potential instability,
due to the natural terrain and stability of the ground
under the area of dump construction, is minimised. .
1.4 The design is such that any future potential instability,
due to the drainage characteristics of the material
being dumped, is minimised.
1.5 The design is such that any future potential instability,
due to the probable climatic conditions of the area, is
minimised.
1.6 The design is such that any future potential hazard, due
to the presence of hazardous material in the dump, is
minimised.

110
1.7 The design is such that the hazards of dust generation
from the dump are minimised.
1.8 The design is such that the hazards of contamination
from dump water drainage are minimised.
1.9 The design is such that any potential hazards from
dump instability, which could affect other
infrastructure, are minimised.

2. STOCKPILE / DUMP LAYOUT

2.1 Demarcated routes, for use during either/both day and
night, are provided to ideally separate traffic flows for
access to, and exit from, the tipping areas.
2.2 Effective route marking, for use during either/both
day and night, is provided to indicate the safe
approach to, and exit from, the tipping point.
2.3 Turning, reversing and tipping areas are of sufficient
size to permit manoeuvring by the largest equipment
that is intended to be used.
2.4 There is restricted access to the toe of the tipping
areas of waste / heap leach dumps.
2.5 Traffic control measures have been devised and
implemented.
2.6 Overhead powerlines do not pass over areas where
truck bodies may be elevated.

3. OPERATION
3.1 There are written procedures for dumping at all
specified locations, and for the different types of
equipment in use.
3.2 Operators of equipment are tested on their knowledge
of the relevant procedures before being authorised to
work in a specific area.
3.3 Where dumping is carried out over an edge (dump or
bin), and no spotter is used, hazards are reduced by
the use of engineered backstops (width v height), or
eliminated by tipping short and bulldozing.
3.4 Where dumping is carried out over an edge (dump or
bin), and no spotter is used, technology is used to
assist in achieving a safe operation.
3.5 Where dumping is carried out over an edge (dump or
bin), and no effective back stop has been provided, a
spotter must be used.
3.6 Where night time dumping is carried out, the work
area and dump edge are illuminated by stationary
lighting.
3.7 During each working shift the dump surfaces, edges
and faces are inspected by a competent person for any
evidence of instability.
3.8 There is a rising, or at least a flat, grade towards the
dump edge.

111
3.9 The dump tipping edges in use are straight with no
curves and the windrows/backstops are maintained in
height and profile.
3.10 There is regular maintenance of dump surfaces as well
as the access and exit routes.
3.11 There is control of dust generation by the use of water
trucks, spray systems, etc.
3.12 There is restricted access to tipping areas for light
vehicles and personnel on foot.
3.13 Simultaneous dumping over the edge of a stockpile
and loading out from its base is only carried out where
there is sufficient separation between the work
locations such that undermining of the dumping
location is not possible.
3.14 No dumping directly into bodies of water is carried
out.
3.15 Hazardous conditions are reported when observed and
remedial action is taken.
3.16 Spotters, if used, are required to be stationed in a
safe location.
3.17 Spotters, if used, are provided with weather
protection.
3.18 Spotters, if used, are protected from dust.
3.19 Spotters, if used, wear reflective clothing.
3.20 There is a standard code of signals for use between
spotters and truck operators.

Annex 11: Water Pollution Audit Checklist

Point Standard Standard Comments

Met

1. IDENTIFICATION OF SOURCE OF POLLUTION

1.1 Identification whether all causes/sources of pollution to the
river, lakes, groundwater are clear
1.2 Verification and quantification of the contribution of each
source of pollution
1.3 Confirmation if the risks to the health are a result of rivers,
lakes, groundwater and water source pollution.
1.4 Assessment whether the risks to the environment is a result of
pollution to water sources identified

2. PLANNING FOR THE CONTROL OF WATER POLLUTION

2.1 The manager has appointed a planning for control of pollution
based on accurate, recent and reliable data
2.2 The district authority was notified if planning for control of
pollution is based on assessment risk
2.3 The manager planned a control of pollution based on
assessment of requirement and availability of funds

112
3. CLEAR ALLOCATION OF RESPONSIBILITY AND ACCOUNTABILITY
3.1 The manager confirm whether there was allocation of
responsibility and accountability to agencies for planning
3.2 The manager indicated whether there was clear delineation
of responsibility and accountability to agencies implementing
the programs for the control of pollution
3.3 The district have clear delineation of agencies for monitoring
including monitoring after infrastructure for the control of
pollution were created
3.4 The district have clear delineation of regulatory agencies for
measurement and setting of standards for control of water
pollution

4. EFFECTIVE IMPLEMENTATION OF MEASURES TO CONTROL WATER POLLUTION

4.1 The manager indicated whether infrastructure for the control
of pollution created under the program for the control of
pollution as envisaged
4.2 The mine infrastructure is created for the control of pollution
being maintained as envisaged

5. MONITORING
5.1 Effective monitoring program implementation took place to
ensure that the program objectives were met.
5.2 The infrastructure created under the program for the control
of pollution was effectively monitoring to ensure that it met
set/designed performance parameters.
5.3 Regular and effective monitoring of pollution levels of
rivers/lakes/groundwater/water sources took place

6. UTILISATION OF FUNDS
6.1 Funds allocated to the district under the program for the
control of pollution were released timely to the implementing
agencies.
6.2 Funds were utilised economically and efficiently by the
district

7. IMPACT ANALYSIS
7.1 Confirmation whether there was improvement in water quality
as a result of implementation of the program for the control
of pollution
7.2 Identified whether external evaluation of the program for the
control of pollution was done

7.3 The performance of the infrastructure created for the control

of water pollution is per set / designed performance
parameters

Annex 12: Ventilation Management Audit Checklist

113
POINT STANDARD STANDARD MET COMMENTS

1. VENTILATION PERSONNEL
1.1 The manager has appointed an underground
ventilation officer for the mine.
1.2 The District Inspector of Mines was notified in
writing of the appointment.
1.3 The underground ventilation officer is
appropriately qualified.
1.4 The underground ventilation officer has the
authority, in consultation with management, to
close down operations in areas where inadequate
ventilation is identified.
1.5 Underground ventilation technicians, undertaking
measurements of air and atmospheric
contaminants on behalf of the underground
ventilation officer, are adequately trained.
1.6 Mine supervisors and operators receive basic mine
ventilation training.

2. AIR MEASURING EQUIPMENT

2.1 The mine has ventilation instruments to conduct
the required air pressure and flow measurements.
2.2 The mine has the appropriate measuring
equipment, provided in house or externally, to
measure the atmospheric contaminants
anticipated to occur.
2.3 The mine has equipment to measure the levels of
oxygen and gases when any toxic, asphyxiant, or
explosive gases are anticipated to occur.
2.4 The mine has wet and dry bulb instruments to
measure the temperature levels.
2.5 All measuring equipment is maintained and
calibrated to manufacturers’ specifications.
2.6 When ventilation instruments and gas measuring
equipment is sent away for calibration or repair,
alternative equipment is made available.
2.7 A record is kept for each item of calibrated
equipment that includes the latest date of
calibration, the calibration factors and the next
due date.
2.8 A procedure exists to ensure that where indicator
tubes are used, the tubes are stored as
recommended by the manufacturer and their use-
by-date has not expired.

3. AIR MEASUREMENT
3.1 There is a written procedure for the
measurement and recording of airflows.
3.2 Ventilation stations are selected with regard to
obtaining a reliable velocity reading.

114
3.3 The position of each ventilation station is clearly
marked underground.
3.4 The area of each ventilation station is accurately
determined by the survey department.
3.5 The mine has carried out an assessment of the
natural ventilation system.
3.6 Potential mine emergencies that may have an
effect on the ventilation system have been
modelled.
3.7 The mine emergency plan has contingencies in
place to deal with the effects on the mine
ventilation system from the potential mine
emergencies modelled.

4. VENTILATION RECORD KEEPING

4.1 The Underground ventilation officer has a current
copy of the Mines Safety and Inspection Act &
Regulations.
4.2 A copy of the current National Exposure
Standards NOHSC: 1003 is available at the mine.
4.3 The mine has a ventilation log book.
4.4 The mine ventilation log book indicates that
inspections and testing occur at the required
intervals for the various ventilation parameters,
fan surveys and atmospheric contaminants.
4.5 Each ventilation and contaminant measurement is
documented and retained at the mine.
4.6 Each entry in the ventilation record book is
dated, signed and kept in area chronological
order.
4.7 Each ventilation circuit has a diagram showing
the air flow balance.
4.8 There is a procedure for the reporting and
rectification of ventilation defects within the
ventilation system.
4.9 Mine ventilation performance and costs are
monitored and reviewed on a regular basis.

5. VENTILATION PLANS
5.1 The mine has ventilation plans which are updated
at intervals not exceeding 3 months.
5.2 The position of each ventilation station is clearly
marked on the plans.
5.3 The direction and volume of air flows are clearly
marked on the plans. (Intake air -blue, exhaust
air – red).
5.4 The positions of fans and air moving equipment
are clearly marked on the plans.
5.5 The positions of all ventilation control devices
are clearly marked on the plans.

115
5.6 The positions of all fresh air bases are clearly
marked on the plans.
5.7 The positions of all refuge chambers are clearly
marked on the plans.
5.8 The positions of all telephones (including
numbers) are clearly marked on the plans.
5.9 The positions of all second means of egress are
clearly marked on the plans.
5.10 The positions of fire extinguishers and water
hydrants are clearly marked on the plans.
5.11 An explanation key (legend) is provided on the
ventilation plans.
5.12 Mine plans containing current ventilation and
survey information are issued to the mine rescue
team.

6. FANS
6.1 Fan selection is based on the pressure
requirements for the mine parameters and the
volume requirements for the equipment to be
used.
6.2 Primary fans are equipped with the means to
determine the air pressure across the fan and the
air volume flowing through the fan.
6.3 Primary fans are equipped with vibration
monitoring instruments.
6.4 Fans are maintained in accordance with the
manufacturer’s requirements.
6.5 All fan air flow or damper adjustment controls
are locked to prevent tampering.
6.6 Surface fan installations are located in an area
that does not exhibit evidence of ground
subsidence or wall failure.
6.7 Surface fan installations have fire breaks around
them.
6.8 Primary fans located on the surface are equipped
with permanent lighting.
6.9 There is an alarm system in place to indicate a
primary fan failure.
6.10 There is a procedure in place to manage the
occurrence of a primary fan failure.
6.11 The installation of each surface primary fan is
such that recirculation of air is prevented.
6.12 Primary fans and circuit fans located underground
are equipped with permanent lighting.
6.13 Each auxiliary fan is installed at a location that is
free from obstruction and the fan is able to draw
from the purest source of air available.
6.14 The installation of each auxiliary fan is such that
the recirculation of air is minimised.

116
7. VENTILATION CONTROL DEVICES
7.1 Permanent ventilation control devices are of
robust construction.
7.2 Permanent ventilation control devices are free
from obstruction and easily accessible.
7.3 Air doors are designed and built to be self-closing
where practicable, and are able to be operated
easily.
7.4 Signs are displayed indicating whether air doors
should be left open or closed.
7.5 Regulators are provided with a means to prevent
tampering.
7.6 Any instruction regarding a change to a brattice
or regulator setting is recorded in the ventilation
log book.
7.7 Permanent ventilation control devices are
inspected regularly.
7.8 All temporary ventilation control devices such as
parachutes, brattices, etc., that are installed to
control airflow in a workplace, are inspected
each shift for damage and leakage.

8. VENTILATION SYSTEM OPERATION

8.1 There are no unnecessary activities in the vicinity
of the intake airways that could generate dust or
fumes.
8.2 Intake air velocities in roadways do not exceed 6
metres/second.
8.3 A means and procedure exists to provide dust
suppression in the main intake air roadway.
8.4 Parallel ventilation circuits are utilised at the
mine to ensure that atmospheric contaminant
levels in each workplace are minimised.
8.5 Airways at the mine are maintained free from
obstruction except for the purpose of control.
8.6 The volume of primary intake air to the mine
exceeds the total air volume requirement
specified for the diesel equipment operating in
the mine at any one time.
8.7 The volume of air flowing into each area of the
mine meets the legal requirement for the diesel
equipment operating in each of those areas at
any one time.
8.8 Ventilation ducting is maintained in a satisfactory
condition.
8.9 The ventilating airflow is arranged such that fresh
air sweeps the working place.
8.10 There is a procedure to be followed such that
each working place ventilated by a multiple duct
ventilation system is adequately ventilated.

117
8.11 There is barricading, with signage displayed, to
prevent unauthorised entry into temporary
unventilated areas.
8.12 The second means of egress from the mine is
protected from smoke contamination by the
installation of permanent control devices.
8.13 Specific areas within the mine with the potential
to generate large volumes of atmospheric
contaminants have a direct connection to the
primary exhaust ventilation circuit return airway.
8.14 A computer generated model of the mine
ventilation system has been developed.

9. CONTAMINANT CONTROL
9.1 A procedure exists to monitor and control the
formation or emission of toxic, asphyxiant and
explosive gases in the mine.
9.2 A procedure exists for drillers to follow in the
event of a gas inflow during drilling.
9.3 An evaluation of the potential for oxygen
depletion in the underground workings has been
carried out.
9.4 Procedures have been developed to manage the
hazards associated with sulphide dust explosions.
9.5 Procedures have been developed to manage the
hazards associated with stopes being filled with
tailings containing residual chemicals.
9.6 Procedures have been developed to manage the
release of ammonia gas due to the reaction
between ammonium nitrate and shotcrete.
9.7 Blast fumes are cleared from all rise face areas
by the use of a compressed air and pipe
arrangement following blasting operations.
9.8 A written procedure or instruction exists to
measure or evaluate the time for blasting fumes
to clear from an area.
9.9 The clearance of blasting fumes is checked by gas
monitoring before re-entry.
9.10 Contaminants are controlled in all workplaces
where blasting and loading operations take place.
9.11 Mine workings that have high working
temperatures have an adequate air velocity flow.
9.12 Where mine workings exhibit high working
temperatures, safe operating procedures have
been developed.
10. DIESEL EQUIPMENT

118
10.1 Enclosed cabins and cabin air conditioning
equipment are provided on all underground
trackless diesel equipment and for underground
crushers and remote controlled equipment
stations.
10.2 Air conditioner filters are regularly inspected,
cleaned and changed in accordance with the
manufacturer’s instructions.
10.3 Exhaust treatment devices are fitted to all
underground diesel engines that are turbo
charged or rated at 125 kW or greater.
10.4 Low sulphur, clean, diesel fuel is provided for
underground engines.
10.5 The engine burn efficiency and contaminant
emission of all underground diesel engines is
monitored on a frequent basis.
10.6 Workplace atmospheric conditions are monitored
for diesel particulates on a regular basis.
10.7 A register of all underground diesel units is
maintained on site.
10.8 The register details the relevant information and
ventilation requirements for each diesel unit.
11. DISUSED AREAS
11.1 Disused areas of the mine are isolated from the
primary ventilation system by an effective
barricade to prevent unwanted leakage of
ventilating air.
11.2 When an area of the mine has been isolated from
the ventilation system, a corresponding entry has
been made in the ventilation log book.
11.3 Disused areas of the mine are provided with an
effective barricade at every entrance to prevent
inadvertent entry.
11.4 Notices are displayed at every entrance to a
disused area forbidding entry to the area.
11.5 A procedure exists to re-establish ventilation in
disused areas before re-entry and work
recommences.

119
Annex 12: Quarry system Audit
Points Standard Standard Met Comments
1.1 There is a written policy
statement which sets out the
Safety and Health Policy of
the organisation

1.2 Senior managers accept their

responsibilities, with regard to
Safety and Health

1.3 Site management staff

encourage employees to
systematically improve work
processes to enhance Safety
and Health

1.4 Employees exhibit an

understanding of the
organisation’s Safety and
Health objectives

1.5 There is a formal program to

monitor occupational health
hazards that have been
identified

1.6 Contractors employed in the

enterprise are required to
comply with the principal
employer's Safety and Health
Policy

1.7 Personal protective

equipment (PPE)is available to
all employees at no cost

1.8 There is a system for the

repair of reported equipment
and plant faults

1.9 Availability of toilets on site

for workers

120
Points Standard Standard Met Comments
1.10 Formal procedures are in
place to investigate accidents,
occurrences and property
damage

1.11 There is an induction and

training process at the
enterprise

1.2 Safety and Health meetings

are held

1.13 Communications are available

between the mine and outside
emergency services

1.14 Management carries out its

statutory responsibilities in
respect of the recording and
reporting of occurrences and
potentially serious
occurrences.

1.15 Management carried out its

statutory responsibilities in
respect of the registration,
inspection and maintenance of
quarry.

1.16 Management carries out its

statutory responsibilities in
respect of the recording of
lost time injuries to worker

1.17 Management has caused a

noise report to be compiled.

1.18 Management maintains a

database recording each
employee's training history.

121
2. Explosive storage

Point Standard Standard Comments

Met
2.1 The magazine is located at
least 50 metres away from
any entrance to any
underground mine.
2.2 Explosives magazine is in
excess of 10 m from any
detonator magazine
2.3 Magazine is kept locked
except when stock movement
is occurring
2.4 Incompatible explosive
products are not stored
together
2.5 Incompatible explosive
products are not stored
together. No additional
unauthorised materials are
stored in the magazine
2.6 No explosives are stored loose
in the magazine
2.7 A responsible person has been
appointed to control the
magazine
2.8 Prominent “EXPLOSIVES” sign
displayed on magazine.

122
3. Blasting practice

Point Standard Standard Comments

Met
3.1 Blasts are planned and
designed to ensure good blast
results ie good
fragmentation, displacement
of muck pile and looseness.
3.2 Drilling patterns are laid out
accurately.
3.3 Occurrences such as any
accident or damage to
property by fly rock (or close
call) are recorded
3.4 Where noise, air blast and/or
ground vibration are a
problem, complaints are
recorded
3.5 Drilling is not carried out on a
bench face until it has been
checked for misfires
3.6 All means of entry to the
place of blasting are securely
guarded against entry by
persons, or warning notices
are erected to prevent entry
3.7 Any charge in a designated
blast which has not been
fired or has not exploded is
treated as misfire
3.8 A sufficient depth of each
blasthole is left uncharged to
permit adequate stemming
3.9 The depth and condition of
blastholes are checked prior
to charging

123
4. ISOLATION&TAGGING

Point Standard Standard Comments

Met
4.1 OUT OF SERVICE tags are used
to warn against the use of
areas which is unsafe to be
used or which may be
damaged if it is used
4.2 DANGER tags are used to
prohibit the use of an area
under which an employee is
undertaking work.
4.3 Each employee removes his
own DANGER tag after
completing the work and
prior to leaving the worksite
at the end of the shift
4.4 OUT OF SERVICE tags are
attached prior to removing
DANGER tags when work on is
not completed
4.5 The effectiveness of devices
used to isolate areas is
proved prior to attaching
DANGER or OUT OF SERVICE
tags

5. TIPPING ON STOCKPILES

124
Point Standard Standard Comments
Met
5.1 The design is such that
potential instability of the
dump is minimised
5.2 Day and night where
applicable effective route
marking is provided for
approach to tipping areas
5.3 There is a rising, or at least
flat, grade towards the dump
edge
5.4 There is control of dust
generation

6. EMERGENCY PLAN

Point Standard Standard Comments

Met
6.1 The operation has prepared
an emergency plan
6.2 The emergency plan is known
by the quarry personnel.
6.3 The emergency plan
identifies the types of
incidents which may affect
the enterprise.
6.4 On-site first aid services and
facilities are available at the
enterprise.
6.5 On-site fire fighting
resources, include trained
personnel.
6.6 The emergency plan includes
a means of visitor control.

125
7. OCCUPATIONAL HEALTH

Point Standard Standard Comments

Met
7.1 Occupational health hazards
have been identified.
7.2 Control measures are in place
to reduce occupational health
hazards identified.
7.3 Control measures in place to
reduce the occupational
health hazards are effective.
7.4 Employees have been
educated in the occupational
health hazards identified.
7.5 The exposure of employees to
the occupational health
hazards identified has been
evaluated.
7.6 Where necessary employees
wear appropriate personal
protective equipment to
reduce exposure to
occupational health hazards
identified.

8. MOBILE PLANT

126
Point Standard Standard Comments
Met
8.1 There is a system of
maintenance for mobile
plant.
8.2 A competent person is
appointed to supervise
maintenance.
8.3 Records are kept for
maintenance of mobile plant.
8.4 There is a procedure to
report operational faults on
mobile plant
8.5 The faults are rectified in an
acceptable time frame.
8.6 There is a document to show
that pre-start checks are
carried out for mobile plant
8.7 Mobile plant operators are
trained and assessed for
competency.
8.8 ROPS, where necessary, is
provided.
8.9 Mobile plant inspected in
operation, appeared to be in
satisfactory condition.
8.10 Radio communication from
mobile plant is provided.
8.11 There is a system to make
checks and approve short
term contractor’s mobile
plant.
8.12 The haul roads are
maintained in satisfactory
condition.

127
9. WORKSHOP

Point Standard Standard Comments

Met
9.1 A workshop facility is
provided for the maintenance
of fixed and mobile plant.
9.2 The facility is appropriate for
the types of tasks
undertaken.
9.3 The workshop facility is
maintained in a tidy
condition.
9.4 Signs are provided to warn of
possible eye, hearing and
other hazards.
9.5 Fire control equipment is
available at the workshop.
9.6 Machinery is maintained on a
regular basis.
9.7 Electrical tools and
equipment at the workshop is
periodically checked and
tagged
9.8 Electrical welding machines
are maintained in safe
condition
9.9 High pressure gas cylinders
are restrained.
9.10 High pressure gas hoses and
gauges are free from damage.
9.11 Proper material handling
equipment is provided for the
tasks undertaken.
9.12 Adequate lighting is available
for work to be carried out at
the workshop.

128
10. FIXED PLANT

Point Standard Standard Comments

Met
10.1 Fixed plant drives and moving
parts are suitably guarded.
10.2 Fixed plant has walkways and
platforms.
10.3 The walkways and platforms
provide access to major items
for both operation and
maintenance.
10.4 Guard railing is provided for
walkways and platforms.
10.5 Items of fixed plant have a
primary isolator.
10.6 The items of fixed plant have
a local isolator
10.7 The isolation switches are
labelled
10.8 The isolation switches have
provision for securing
isolation tags.
10.9 The hazards associated with
the manual cleaning of fixed
plant have been identified.
10.10 Procedures for the manual
cleaning of fixed plant ensure
that where a hazard exists
the plant directly involved is
stopped.

129
Annex 13a: Summary of responses from lead Agencies
KEY GUIDING QUESTIONS
1. Have you been involved in
Environmental Audits (EA) for
Mining Projects?
2. What were/are your roles and
responsibilities in undertaking EA?
3. Which key aspects would you like to
be considered in undertaking EA for
Mining projects?
4. What are the potential
environmental, social and health
impacts related to Mining Projects?
RESPONSES FROM KEY INFORMATS
 On-going mining inspection
 Inspecting how EMPs and EIA certificate
conditions have been implemented
 Respect of environmental laws
 Health of worker
 EIA approval
 Checking if rehabilitation is being done
 Check if mining companies conducted EIA
and implentation level
 How mining is done/exploitation
techniques
 Check water use in the mining areas
 Health insurance for workers
 Mining/exploitation techniques used by minors
 The rehabilitaiton of degraded areas
 Health working conditions of workers
 Environmental conditions of surrounding
human settlement /rivers/wetlands and
wetlands
 EMP implementation level
 EIA CERTIFICATE OF APPROVAL
 Insurance of workers in the mining areas
 Organization of mining site and mining plots
into phases and each phase rehabilitation done
 Rehabilitation progress reports
 Engaging all stakeholders during auidit
 Water use system of the mining site
 An office and sanitation facilities
 No rehabilitation of degraded areas
 In appropriate mining techniques different
from those recommended in in the EIA
reports
 Poor working conditions of workers hence
exponsing them to health risks (working
without PPEs)
 Pollutions of rivers, lakes and wetlands
 No protection equipment
 Mining close to wetland yet water realised
in the envirinment
 No rehabilitation as required
 Expropriation challenges in the mining
areas
 Expertize of the minors in the quarries is
very limited
130

5. How can these adverse impacts be
mitigated and or avoided?
6. Are there any legislation and
regulations related to environmental
management and Mining especially
environmental assessments? Obtain a
copy if any.
7. Propose the types of on field and off
field quality laboratory tests required
for an environmental audit.
8. In undertaking EA for Mining
projects and preparing the report,
which
Qualifications for EA experts would you
recommend being involved?
9. Propose any Mining activity that can
be visited to understand
environmental/social
aspects.
Challenges in the sector
Source: Key Informant Interviews. A list of participants is attached.
 No erosional control measures in place
 Mining in the human settlements causing
dust pollution
a) Improved coordination between Districts, REMA-
RNRA & RDB in the issueing of EIA certificates and
mining certificates in terms of coordinated
inspection framework
b) Department of mining to have the list of
exploration companies to do EIA certificates
c) The degrading minors to be given time to
rehabilitate and if they do not comply they should
be stopped
d) Conduting regular environmental audits
Environmental laws is very claer but there is
inadequate enforcement and monitoring of mining
activities
Water quality analysis
1. Civil engineer-Hydro-geologist
2. Environmentalist (Team leader
3. Terrestrial Ecologist
 Rebalitation of degraded areas by mining
firms
 Continues monitoring of phase by phase
activities of mining firms
No respect for District staff
RNRA interested in increased productivity and less
on environmental conservation
 illegal mining
 No health insurance and no rehabilitation
 No implementation of EIA
recommendations
 Diverting water and use it to wash
minerals and hence causes water pollution
 Mining companies using exploration
permits to conduct real mining and no EIA
done
 No offices for the mining companies
 Security of the inspection team is
important as some minors are aggressive
 Mining in rivers
131
Annex 13b: Summary of responses from developers
No KEY GUIDING QUESTIONS
1 What kind of mining activity are
dealing with in your business
2 What is your role and
responsibilities in an EA process
3 What are the mining activities/
Production processes that you are
involved in?
4 What are the main chemical inputs
you are using in your factory and
what stage
5 In your opinion and professional
experience, what impacts have you
observed as a result of processing
activities that affect environmental
components like a)surface/
groundwater, b)soil c)vegetation
and d)air?
6 How can this diverse impact be
mitigated or avoided?
7 What measures have you put in
place to comply with environmental
requirement/legislation in a)
designing, b)construction,
c)operation and d)decommissioning?
8 Which waste us generated by your
factory? How do you manage your
waste?
9 Which institution is responsible for
approving and monitoring activities
related to mining activities?
RESPONSES FROM KEY INFORMATS
Artisanal Mining
Follow up daily mining activities in progress
Tungsten
No chemicals used/ only blasting in underground tunnels
is applied
 waste management issues
 impact to biodiversity (removal of some
vegetation)
 deforestation

lowering the water table alteration of and
depletion of groundwater water regime
 soil erosion and salinization
 impact on habitat
 minimum Air pollution
 Construction of anti-erosive measures
 Replanting trees where cut(reforestation)
 Expropriate people who live close to the site
 They introduced the system buying wood instead
of burning trees
 They construct drains in order to drop water
from one point
 They planted new trees from nursery
 The waste generated by the factory is mixture of
sand and stones and some mineral particles
 Still we collect them (sand and stones) toward
the valley, but we are preparing to crash them
and use them to make roads and constructing
houses.
 RNRA under the GMD(Geology and Mine
Department)
132
10 What environmental and social
challenges do you encounter in
implementing environmental
management and monitoring plans
for mining activities?
 No environmental Challenge
 Socio challenge occurs when people from
outside come in their concession, cut trees
informally and this issue will be asked the Head
of the company in the auditing process.

11 As a mining company do you have a  No safety department

safety department or/and safety
company in your organization?

12 Do you wear the protective  Yes we do

equipments in your daily activities?

13 Do you conduct an environmental  No environmental Internal Audit

internal audit? How often?

14 Is there any environmental study  No study done before

conducted before mining activities
at this site?

Source: Key Informant Interviews. A list of participants is attached.

Annex 13c: Summary of response from some practioners

KEY GUIDING QUESTIONS RESPONSES FROM KEY INFORMATS

Have you been involved in any Generally there is overall environmental pollution as a result
EA for Agricultural Projects? of non environmental friendly practices, technologies and
What was your experience? inputs in mining, mining and Agriculture

Looking at the legal, policy and Yes

institutional framework for
Rwanda, do you feel it is
adequate to allow you as a
practitioner to adequately
undertake EAs for the
Mining sector?

What would you want improved
on?
What environmental & social
aspects would you like audited
during EA exercise?
Enforcement of the audit requirement for these sectors to
ensure that EMPs are implemented
-Soil and water pollution for agriculture
- Soil, water and ambient air quality monitoring (parameters:
dust - PM 10)
-Water, indoor and ambient air pollution for mining projects

Propose the types of on field On field test : Water quality testers

133
and off field quality laboratory
tests required for an
Environmental audit.
qualifications for EA experts
who have to conduct the Audit
for Mining Propose
Projects/Activities.
-PH
-TDS
Off-field: Water quality testers
-Heavy metals
-Radio activity
- Overall eco-toxicity
2)Soil quality testers for different parameters
3) Dust fall monitors
1. Environmental sciences (environmental management
and others)
2. Mining sciences (Geology and others)
3. Water quality expert

Source: Key Informant Interviews. A list of participants is attached.

134
A list of stakeholders consulted
TELEPHONE /
NO NAME ORGANISATION / COMPANY POSITION EMAIL
EMAIL
1. DUKUZIMANA MINICOM In charge of 0788646517 jpdukuzimana@yahoo.fr
J.PIERRE Manufacturing
2. MUTABAZI JEAN MINIRENA DEFOR 0788578911 mutjc@yahoo.fr
CLAUDE
3. HISHAMUNDA MINIRENA Environmental 0788899486 hialph@yahoo.fr
ALPHONSE Protection professional
4. UWIZEYE EMMANUEL MINIRENA Director of land and 0788505075 uwamanou@gmail.com
Mines
5. KAYUMBA JAMES RNRA Director of inspection 0782029993 higirokf@gmail.com
franciskanya@yahoo.fr
6. MUSHINZIMANA JMV MINIRENA IWRM/Expert 0788405138 jmushinze@yahoo.fr

7. MUTABAZI Rita Rwanda Resources Efficient and National Consultant 0788754800 ritamutabazi@yahoo.fr
Clemence Cleaner Production Centre
under PSF
8. NIYONZIMA STEVEN Rwanda Resources Efficient and National coordinator 0788306742 Niyosteven12@gmail.com
Cleaner Production Centre
under PSF
9. MBERA OLIVIER Rwanda Resources Efficient and National expert 0782461618 mberaolivier@gmail.com
Cleaner Production Centre
under PSF
10 District Agronomist
Hussen Kayonza officer 0788490193
11 MUGABO Charles Individual Consultant EIA- Expert 0788215484 cmugabo@gmail.com

12 MUKARUKUNDO REMA focal point

Eugenie BUGESERA 788607943 mukarueugenie@yahoo.fr
13 NGIRABAKUNZI REMA focal point
Octavien RWAMAGANA 788698007 noctavien@yahoo.fr
14 NSENGIMANA Environmental Officer
AIMABLE NYANZA District 788822928 hafaclo05@yahoo.fr
15

135
16
Jean Karara RDB Environmental Officer 0788422184 jdkarara@gmail.com
17 MUGABO Charles Individual Consultant EIA- Expert 0788215484 cmugabo@gmail.com

REMA focal point

18 BAVUGE Bernardin KAYONZA 788413796 babeus2020@yahoo.fr
MBONIGABA REMA focal point
19 Theoneste GATSIBO 788603106 mbonatheo@yahoo.com
RWINIKIZA BITITI REMA focal point
20 Fred KIREHE 788473716 bititifredy@yahoo.fr
REMA focal point
21 KABANDA Claude NGOMA 788417857 kabandum@gmail.com
MANIRAFASHA REMA focal point
22 Sylvestre BURERA 788555695 sylve82@yahoo.fr
REMA focal point
23 SAKUFI Damas GICUMBI 786094773 sakufida@yahoo.fr

24 LUTAGIRA Jackson GICUMBI Environmental Officer 0788596963

REMA focal point
25 HAKIZIMANA Smuel GAKENKE 788873008 hakizimanasaml@yahho.fr
REMA focal point
26 SALAMA Fides GASABO 788555670 sfides2000@yahoo.fr

27 MUKAMANA Phoebe GASABO Environmental Officer 0788583832

NSEKANABANGA J. REMA focal point
28 D'Amour KARONGI 788658803 nkizayo47@yahoo.fr
REMA focal point
29 HABYARIMANA Eric KARONGI 0788352413

30 SEBITEREKO Bustani KARONGI Environmental Officer 788940904

REMA focal point
31 KABALISA Appolon NYARUGURU 788513147 kababien@yahoo.fr
REMA focal point bimenyimanaremy@yahoo.
32 BIMENYIMANA Remy NGORORERO 788864413 com
REMA focal point
33 BYUKUSENGE Prisca NYAMASHEKE 788812628 sengaprisca@yahoo.fr
MUSABYIMANA REMA focal point
34 Ferdinand RUSIZI 788521883 musafred2000@yahoo.fr

136
35 KABANDA Olivier RUTSIRO Environmental Officer 788453248
REMA focal point
36 NDEKEZI Augustin RUTSIRO 788540241 ndekezi00@yahoo.fr

137
Annex 14: Generic Terms of Reference for Environment Audit of Mining Projects

Name of Project:………………………………………………………………………………….

Location…………………………………………………..Date……………….

1. Background

The government in recognition of the need to protect the environment from adverse impact of
developmental activities requires the conduct of EIA and Environmental Audit (EA) of projects that
have significant effect on the environment. In 2006 the General Guidelines and Procedure for
Environment Impact Assessment was published to streamline the conduct of EIA and appraisal of
EIA reports in Rwanda. This Environmental Audit Guidelines is to streamline the conduct of
Environmental Audit in Rwanda for the improvement in project management to ensure a clean and
healthy environment for sustainable development. The Environmental Audit Guidelines is
intended to serve developers, agencies and individuals involved in the EA process.” “The
Constitution of the Republic of Rwanda (2003) provides for the protection and sustainable
management of the environment and encourages rational use of natural resources. The
Environment Policy (2003) sets the overall goals for environmental management in Rwanda. The
policy emphasises improved management of the environment at both central and local levels
consistent with the policy on decentralisation and good governance. The government has ensured
that all national policies reflected in Vision 2020 (GoR 2002) take into account environmental
protection as a priority (REMA 2007). Environment is treated as a sector and a cross cutting issue
in the Economic Development and Poverty Reduction Strategy (EDPRS) document (MINECOFIN,
2007). The environment policy provides for institutional and legal reforms. The implementation of
environmental management strategies employs Sector Wide Approach (SWAP), which brings with it
the advantage of synergies among the different development actors. There are relevant policies,
laws, regulations that need to be consulted while carrying Environmental Audit in Rwanda. But the
most critical is the Organic Law (No 04/2005 of 08/04/2005) which determines the modalities of
protecting, conserving and promoting the environment in Rwanda. The relevant articles to
Environmental Audit are:

x) Article 3: Every person has the duty to protect, conserve and promote environment.
The State has a responsibility of protecting, conserving and promoting the
environment.

xi) Article 6: Every person in Rwanda has a fundamental right to live in a healthy and
balanced environment. He or she also has the obligation to contribute individually or
collectively to the conservation of natural heritage, historical and socio-cultural
activities

xii) Article 7: States the principles for Conservation and rational use of environment and
natural resources. (Conservation and rational use of environmental and natural
resources.)

138
 xiii) Article 8 : 10 to 60 lists projects and activities that are subject to regulation by the
national laws of Rwanda

xiv) Articles 49 to 59) provides specific obligations of the State for environmental
management

xv) Articles 60 to 62 provides specific obligations of decentralised entities for

environmental management
The Ministry of Natural Resources has the constitutional mandate for supervising and
monitoring Mining production and development activities. Under MINIRENA the Rwanda
Natural Resources Authority (RNRA) is responsible for natural resources management
activities, and REMA responsible for protection natural resources. REMA as the principal
agency on environment, working under the government ministry in charge of the
environment, the Ministry of Natural Resources (MINIRENA), is legally mandated and
required to ensure that the proponents of the Mining projects comply with the law and
adhere to established requirements and norms in regards to safeguarding the environment
when implementing Mining projects. Statements under specific and general obligations in
the Organic law(No 04/2005) imply collective efforts in environment management that
calls for a holistic approach that can be achieved by applying tools like EIA and EA.

In this regard, REMA requires the services of an Environmental Auditor to assess the environmental
performance and compliance to established regulations and norms of the aforementioned project.
The Environmental Auditor will follow the established Environmental Audit guidelines of REMA.

2. The need and purpose for Environmental Audit for the mining project

The economic activities of Mining sector put a strong pressure on the environment due to various
types of pollution, mainly through air and waste water pollution. Therefore putting in the practice
of the sustainable principles requires that Mining holdings be concern related to evidence and
controlling the impact of their activity on the environment and society.

The purpose of the environmental audit for Mining projects is to ensure that implementation of
Mining projects adheres to all relevant environmental laws, regulations, standards, plans and
policies, and that environmental management tools developed following the Environment Impact
Assessment (EIA) of the project, are used effectively to mitigate against environmental impacts. In
conducting the environmental audit the ultimate aim is to identify and correct environmental
concerns that arise with the implementation of the project, whether identified or not during the
EIA process. The environmental audit should make such recommendations that lead to improving
the operating and environmental conditions and long-term sustainability of those facilities and
activities of the project. The recommendations seek to ensure that proponents of projects comply
with environmental requirements and regulations in implementing the projects.

3. Objectives

139
 Environmental audit will evaluate how well Environmental Management Systems (EMS) is
performing with the aim of preventing environmental damage; assessing compliance with
regulatory requirements; facilitating control of environmental practices by the Mining
organization or facility management; and place environmental information in the public domain
for scrutiny and management. Environmental auditing is expected to:
 Facilitate management and control of environmental practices;
 Assess compliance with relevant statutory and regulatory requirements
 Raise awareness of and commitment to environmental policy by project staff, the
community and other concerned parties
 Maintain environmental health and safety standards, while continuously exploring
opportunities for improvement;

 Evaluate Environment Management System and Plan for the project

 Collect data on environmental, operational and social practices, control procedures and
environmental compliance mechanisms
 On-site evaluation of occupational health and safety practices to determine compliance
with national standards
 Conduct a site environmental and health risk assessment to determine risks posed to the
surrounding communities
 Identify feasible, cost-effective mitigation and/or corrective measures and opportunities
for overall improvement environmental and social management practices.

4. Tasks of the Consultant

When engaged Environmental Auditor will:

4.1 Obtain the required information from the project proponent. This may include, but not be
limited to, copies of BEIQ / IEE / EIA, relevant plans, drawings, social analyses, approval of
CEA and other government agencies, comments of the funding organization and the EMP as
applicable.

4.2 Review the above documents, discuss with the proponent as well as the surrounding
community and visit the location and environs of the project.
4.3 Check for conformity of the project in relation to the guidelines, conditions and comments
stipulated in item 4.1 above, or as per the previous audits carried on this project.

4.4 Highlight any deviations from the guidelines, conditions and comments stipulated in the
aforesaid documents and guide the proponent to prepare a revised EMP incorporating the
necessary mitigatory measures.

4.5 Document any adverse environmental impacts that were not anticipated in the BEIQ/IEE/EIA
that may have occurred during project construction and implementation.

4.6 Complete and submit the Environmental Audit Report to REMA. The report should follow the
format and contents set out in Environmental Audit Guidelines of Mining projects. But for
avoidance of doubt must contain among other things (i) description of the project, (ii) the

140
 list of documents reviewed, (iii) conformity to the EA guidelines for Mining projects,
conditions and comments stipulated in the documents reviewed, (iv) deviations from
guidelines, conditions and comments stipulated in the documents reviewed, (v) a revised
EMP incorporating the necessary mitigatory measures, and (vi) any unanticipated adverse
environmental and social impacts as well as any mitigation measures taken to address such
impacts.

4.7 Complete and submit a Physical Asset Verification Report to the REMA.

The report will conclude with the following declaration:

Declaration:

I, ...……………………….……………………………………………………… an Environmental Auditor registered

with the Rwanda Environment Management Authority (REMA), having conducted a review
of the documents listed in paragraph(s) ……. of this Environmental Audit Report, having
visited the project site and consulted relevant stakeholders, hereby confirm that I have
exercised due professional diligence in carrying out this assignment.

Name:

Signature: Date:

5.0. Qualifications of the Environmental Auditor

REMA is seeking a team of experts or firm registered with REMA with the relevant
experiences and qualifications in line with the standards and requirements for service
provision detailed in the Environmental Monitoring and Auditing Guidelines of REMA (REMA,
2014)

The team of experts should include the following:

1. Hydro-geologist
2. Environmentalist (Team leader)
3. Terrestrial Ecologist

Note: All Team members should posses a Masters Degree and with over 5 years working
experience. The team leader should be a registered Environmental Auditor with REMA

141
6.0 Submission of bids:
The both the technical and financial proposals, sealed in separate envelops, should be
submitted to REMA Head Office in Kigali before …………….. (time) on ……………. (date)
addressed to the Director General of REMA and clearly marked “Provision of Environmental
Auditing services.

142
Annex 15: Stages in the mining process

143
144