Cyanide Code Recertification - The Three-Year Challenge

"The International Cyanide Management Code (the Code) is a voluntary industry program for gold miners and associated cyanide transporters and cyanide producers. By becoming a signatory, a company commits to follow the CodeÆs principles and implement its standards of practice.Signatories are required to undergo an initial certification audit within three years and a recertification audit every subsequent three years. Recertification audits evaluate compliance over the preceding three-year period. This approach presents a number of challenges. Golder Associates has undertaken in excess of 75 initial certification audits and 25 recertification audits; more than any other audit firm. This paper outlines some of the challenges identified and lessons learnt from the recertification audit process. Central to the process is the challenge for organisations to maintain commitment to compliance over the full three-year period and effectively address deficiencies or non-conformances that may have occurred during that period in a prompt manner.The International Cyanide Management Institute (ICMI) provides guidance in evaluating deficiencies or non-conformances, which requires consideration of the æcauseÆ, ædurationÆ and æongoing compliance effortsÆ and an assessment of the concept of ægood faithÆ in response actions. Golder AssociatesÆ experience with the recertification process highlights some common deficiencies with Code compliance programs, such as: system breakdowns (leading to ineffective communication between departments or loss of information) exceedance of discharge limits inadequate inspections, maintenance activities and associated record-keeping.Such deficiencies can be attributed to: personnel changes organisational changes or structures management systems (eg integrated or standalone) awareness and interpretation of Code requirements transparency of management decisions with Code implications.We have identified that ongoing programed assessment is an effective strategy in maintaining Code compliance.CITATION:Beazley, R J and Woods, M C, 2013. Cyanide code recertification - the three-year challenge, in Proceedings World Gold 2013, pp 247-254 (The Australasian Institute of Mining and Metallurgy: Melbourne)."