1 REPORT ON ENVIRONMENTAL MANAGEMENT CONSULTANCY Prepared by Paulette Bynoe (PhD) in association with Denise Simmons (MSc) and Jewel Liddell (MSc) December 2009 2 Table of Contents Page Number 1.0 Introduction……………………………………………………………………………..3 2.0 Highlights of Outputs of Phases…………………………………………………….4 3.0 General Observations and recommendations…………………………………….8 4.0 Conclusion……………………………………………………………………………….9 3 1.0 Introduction In recognition of the pivotal role of the mining sector in the Guyana economy, as well as the need to promote sustainable development, the Guyana Geology and Mines Commission (GGMC) has taken decisive actions to build its institutional capacity to carry out its legal mandate more effectively and efficiently. In this context, the Commission engaged Dr. Paulette Bynoe, Environmental Consultant, in association with Ms Denise Simmons and Ms Jewel Liddell, to undertake the Environmental Management Consultancy. The general objectives of the Consultancy were as follows: To train GGMC Officers, as trainers, in specific aspects of environmental impact assessment, social impact assessment and environmental management systems, as related to the Prospecting and Mining Permits, Claim License, the Environmental Management Agreement and the Mining Amendment Regulations (2005), emphasising improvement of the ability of GGMC officers to transfer their knowledge in this area to miners effectively to bring about necessary change in attitude and behaviour. To sensitise Small and Medium Scale miners on issues related to Environmental Impact Assessment and Social Impact assessment of mining activities. (The focus of this training will be on getting miners to understand the processes involved and the issues taken into consideration in these assessments and the implication of these considerations for the day to day activities of the miner.) To train Miners in Environmental Management and in developing appropriate Environmental Management Systems for small and medium scale mining operations considering the need to meet the requirements of the Environmental Management Agreement and the Mining Amendment Regulations (2005), thus promoting responsible and environmentally friendly mining. Recommend training required to raise their knowledge to the standard acceptable for all parties to function effectively as managers of the environment in their respective capacities The project was divided into five phases, as outlined below: Phase 1: Assessment of GGMC officers and miners in Environmental impact Assessment, Social impact assessment and, Environmental Management Systems and their use in environmental management. Phase 2: Prepare training materials for GGMC officers and miners and submit to the Commission for review and approval. Phase 3: Conduct training for GGMC officers as trainers in Environmental Impact Assessment and Social Impact Assessment and Environmental Management Systems and prepare them for sharing their knowledge with miners of various social and educational backgrounds. Phase 4: Supervise the training of miners by newly trained GGMC officers as they use skills acquired in Phase 3 above. 4 Phase 5: 2.0 Prepare final reports on the training including a draft environmental management system for small and medium scale mining and recommendations for sustained good environmental management at this scale of operation. Highlights of Outputs of Phases Phase 1: Assessment of GGMC officers and miners Prior to the development of training materials, a pre-assessment exercise involving 30 GGMC Officers and 160 miners from four (4) districts1 between February and March 2009, was conducted. Special attention was given to awareness, knowledge and understanding of GGMC officers and miners of concepts and issues related to: environmental impact assessment, social impact assessment, environmental management systems, and general environmental management techniques. Additionally, the appraisal sought to determine the attitudes and practice of these officers and miners in relation to their job descriptions/responsibilities, and livelihood activities, respectively. In each case, a detailed analysis of the survey results was done and specific recommendations were made for the development of training materials. Phase 2: Prepare training materials GGMC officers and miners Based on results of the analysis of the survey done among GGMC officers, the main topics that were covered in the training materials included: 1 Concept and benefits of an EIA: Phases/steps of an EIA ; The concept and benefits of social impact assessment; Critical issues for consideration during the a SIA of mining operations; Concepts of environmental management and environmental management systems; The application of EIAs in decision making; The EIA process with respect to time; Benefits of using a retort; and Ways of improving environmental performance with respect to job descriptions. The coverage of each district (2, 3, 4 and 5) was based on the production of gold. 5 On the other hand, the results of the survey among miners suggested that their training materials should focus on the following issues: the importance of preserving the health of the environment during development; environmental impacts associated with mining activities and measures to mitigate these impacts; the Environmental Bond; using mercury correctly; benefits and limitations of cyanide; using a retort; the importance of wearing protective gear; use and storage of mercury; and environmentally friendly/sound ways of mining. Training materials for both target groups were prepared, submitted and revised after receipt of comprehensive feedback from the Client (GGMC). Upon receipt of agreement from the Client, plans were made for the conduct of the training workshop for the GGMC officers. Phase 3: Conduct training for GGMC officers as trainers A four-day training workshop for twenty-one officers of the Guyana Geology and Mines Commission (GGMC), and one officer of the Guyana Gold and Diamond Miners Association (GGDMA) was held at the Omai Training Centre on September 21-24, 2009. The training workshop aimed at enhancing the officers’ knowledge and skills to act in the capacity of trainers in specific aspects of environmental management. The specific objectives of the training workshop were: 1. To train GGMC Officers, as trainers in specific aspects of environmental impact assessment and social impact assessment as related to the Prospecting and Mining Permits, Claim License, the Environmental Management Agreement and the Mining Amendment Regulations (2005); 2. To improve the ability of GGMC officers to transfer effectively their knowledge in areas identified in Objective 1 to miners, with the view to transforming the behaviour and attitude of the latter group; and 3. To provide an opportunity for GGMC officers to contribute to the development of appropriate Environmental Management Systems for small and medium scale mining operations. 6 The following comments and recommendations were made by participants. Comments Great workshop. More time was required to utilize techniques and methods in assessing EIA. Selection of gender appropriate for delivery of content. Good delivery of content by Consultants. Insufficient time to adhere to objectives of workshop. Inappropriate venue for the conduct of the workshop. Presentations were simple, creative and informative. Too much information to assimilate in such a short time. The presenters were extremely knowledgeable and professional. Recommendations More time should be allocated for such a workshop. Workshop should focus more on real life situations. This workshop proves GGMC commitment to environmentally friendly mining. However, the Joint Workplace Health and Safety Committee need to enforce law. Better venue is needed in the future. Training should be ongoing to improve knowledge in environmental management. No post assessment in the future. A post- evaluation was conducted since it was considered useful in ascertaining the level of awareness and knowledge of GGMC officers with regards environmental management, environmental impact assessment and environmental management systems following the training. Importantly, this test assisted in evaluating the impact of the training provided to the GGMC officers in the areas mentioned above. Overall, 72.7% of the officers demonstrated satisfactory to excellent performance. Phase 4: Supervise the training of miners by newly trained GGMC officers Three (3) training sessions were held for miners by GGMC officers. These sessions were facilitated by the Consultants and were held on November 27 and December 6, 2007 in Tamakay, Frenchman and Mahdia. On average, the sessions were of approximately 1 ½ hour and involved presentations delivered by the officers, following by very animated discussions on issues that were pertinent to their mining operations. During the training sessions the assigned GGMC officer explained the concepts of Environmental Management and environmental management systems to miners. Further, miners were educated on the steps involved in developing an EMS and how to implement such a system into their operation, as well as the benefits 7 associated with such management systems. The regulatory and legislative framework that governs the mining sector was discussed at the training workshops and miners were made aware of the sections that are applicable to their operations. Phase 5: Prepare final reports on the training including a draft environmental management system for small and medium scale mining and recommendations for sustained good environmental management at this scale of operation. Comprehensive reports for all tasks related to the Consultancy were prepared and submitted for review and feedback, if necessary. Additionally, an Environmental Management System (EMS) Framework for Small and Medium Scale Miners was prepared and submitted to the GGMC. Importantly, the EMS framework was developed in conjunction with the GGMC officers who were given an opportunity to make an input during working group sessions of the training programme mentioned under Phase II of the Consultancy. The main elements of the EMS are: Establish environmental policy supported by top management; Identification of environmental aspects and significant impacts; Identification of legal and other requirements; Environmental goals, objectives and targets that support the policy; An environmental management plan; Definition of roles, responsibilities and authorities; Training and awareness procedures; Process for communication of the EMS to all interested parties; Document and operational control procedures; Procedures for emergency response; Procedures for monitoring and measuring operations that can have a significant impact on the environment; Procedures to correct nonconformance; Record management procedures; A programme for auditing and corrective action; and Procedures for management review. 8 3.0 General Observations and Recommendations General observations and comments are provided below. The training was relevant in terms of its scope, coverage and applicability to the mining sector. However, some issues need to be resolved or addressed prior to the implementation of the EMS for small and medium scale miners. These include reclamation, definition of small and medium scale operation and the roles and responsibilities of specific categories of officers, for example, the Mining Technician. Further, there needs to be clear or standard guidelines on what reclamation is. There was some amount of disagreement on whether or not miners were reclaiming the land. GGMC officers should understand clearly the roles and responsibilities /job description when they are appointed. For the implementation of the EMS, it is suggested that time frames be set up in which miners will implement aspects of the EMS. Additionally, there is a need for officers to meet with miners in small groups to provide ongoing training in EMS. Miners must be made aware of the requirements of the Mining Amendment Regulations (2005) and Mining Act. During the training at Mahdia, a number of miners indicated that they never saw a copy of the Regulations. Monitoring and enforcement will need to be strengthened if the EMS is to be successful. Communication between officers in the field and those at the Head Office in Georgetown will have to be improved. A system must be established for officers to track offences committed by miners. Research into cleaner /new technologies that can be used in mining needs to be undertaken. The economic values of the reclamation and environmental bond need to be reviewed to reflect the real cost of restoring the environment. The GGMC should begin to inventorise existing mine sites. Future training workshops should be conducted for GGMC officers on two critical aspects: (i) monitoring, reporting and verification; and (ii) environmental management systems, in order to increase their capacity to provide guidance to the miners during the development and implementation of such systems. 9 4.0 One medium mining operation and small scale operation should be carefully selected as pilot projects for the demonstration of the EMS. GGMC officers should work with the miners to help adopt the framework that is being proposed in this document to reflect the local conditions. GGMC should designate a senior officer from Head Office, with requisite training, to guide the development of EMS in small and medium scale mines. This officer would provide technical expertise to the miners. GGMC should help build the capacity of miners, for example, by facilitating their use of the turbidity metre to monitor the water quality and to take precautionary steps to avoid any health risk. A point system should be developed to highlight good practices within the mining sector and to give recognition, as well as incentives (if practicable) to miners who have implemented the EMS. This can have a positive spin-off effect. Establishment of partnerships between medium -scale mining companies and small-scale miners that include training in more sustainable small-scale mining methods by mine engineers. Continued research should be undertaken by the GGMC, in collaboration with the University of Guyana, on the driving forces and consequences of medium and small-scale gold mining in Guyana. To this end, it may be useful for the GGMC and the School of Earth and Environmental Sciences to sign a Memorandum of Understanding on capacity building and research. Conclusion Mining comes with an environmental price tag that can be mitigated by means of appropriate technology and prudent management of the physical, socio-cultural and biological components of the environment. Thus, the Consultancy is a clear indication of the commitment of the GGMC Management to sustainable mining sector. The recognition of awareness, education and training as capacity building tools could not be over-emphasised. Importantly, there must be timely follow up activities to ensure that the information disseminated and the training received are correctly applied to the livelihood activities of miners. It is therefore necessary to have mine site checks and follow up programmes. This would reinforce the importance of sustainable environmental practices in the mining sector and enhance the effectiveness of the Consultancy.