The Global Tailings Review Consultation

Introduction

At Traverse, we recently completed one of our most exciting consultations. The Global Tailings Review, and the new Standard for tailings facilities that it has produced, will have a global social impact and will save lives. We are very proud to have played our part in making it happen.

On 25th January 2019, the dam at the tailings storage facility at Vale’s Corrego do Feijão mine in Brumadinho, Brazil collapsed. 11.7 million cubic meters of mining waste surged through the mine site towards the local town and countryside below, resulting in over five miles of destruction. As of 5th August 2020, 259 people have been confirmed dead, and 11 remain missing.

Following this catastrophic disaster, the International Council on Mining and Metals (ICMM), the United Nations Environment Programme (UNEP) and the Principles for Responsible Investment (PRI) co-convened the Global Tailings Review (GTR) to establish an international standard on tailings management. In November 2019, the draft Standard (comprising 17 Principles, each made up of a number of auditable Requirements) was produced in seven languages: English, French, Spanish, Portuguese, Japanese, Chinese and Russian. The standard was then put out to global consultation from 15th November 2019 until 1st January 2020 to gather feedback from a variety of stakeholders to strengthen the Standard.

Traverse was very pleased to be awrded the contract to support this consultation by the GTR team by:

• Helping to develop the wording and structure of the consultation questions;
• Developing an online web portal for consultation submissions;
• Processing all data received through the portal, email and other consultation channels (including in-country workshops);
• Analysing and reporting on the responses received, including outputs from several in-country engagement sessions undertaken by the Global Tailings Review team.

Methodology

Responses

Webform set up

Traverse created an online portal for web submissions in the seven languages, mirroring the structure of the survey across each and working with the GTR team to ensure that presentation and translation was accurate and logical across each version.

The first page of the portal allowed respondents to select the language in which the content was presented and for their response. Respondents were invited to respond to questions in four sections:

• Identity and demographics of the respondent;
• Overall views on the Standard;
• Views on each of the 17 Principles and their respective Requirements; and
• Suggestions for the accompanying Report, which would contain important messages and recommendations for operators and interested stakeholders.

Respondents were also able to upload additional files to support or accompany their response.

Email

Responses were also received to a project email address, managed by the GTR team, and passed to Traverse for processing and analysis.

In-country workshops

The GTR team ran a total of 21 workshops with a wide range of stakeholder types across Australia, Chile, China, Ghana, Kazakhstan and South Africa.

Profile and treatment of responses

In total, the consultation received 202 online and email submissions, as well as responses from in-country workshops consisting of 427 participants. Responses were received from 32 countries, with the largest numbers from Australia, Canada, the United States of America and the United Kingdom.

Due to the nature of the consultation, responses were, on average, far longer and more technical than typical public consultations. Some respondents submitted entire copies of the draft Standard, with accompanying comments made in tracked changes.

As responses were received in multiple languages, we worked closely with the GTR team who were able to provide translations of non-English responses and attachments, which were then imported into our analysis software, Magpie, with careful tracking to ensure nothing was missed.

Analysis

A dedicated team of analysts read and coded all submissions. They developed a qualitative coding framework, capturing the sentiment of what each respondent was saying in each part of their submission. The coding framework was grouped by Principle, with a small number of cross-cutting themes and sub-themes.

When analysing responses on each Principle, responses to closed questions allowed analysts to see which Requirements each respondent had identified as being relevant for their comments.

The GTR team were given access to the analysis in real time, via Traverse’s online consultation platform, Magpie. This allowed them to track and understand the emerging views and begin to consider them before the final report was delivered.

Reporting

Two types of reporting were used for this consultation.

Tabular reports

We produced tabular reports showing every coded piece of text received, along with which Principle and Requirement(s) the text was referring to, and, where relevant, theme and sub-theme of the comments. This allowed the GTR team to easily filter the hundreds of thousands of words received to just those relevant to any specific Requirement in the Standard. We produced multiple tabular reports in this style, starting from early on in the consultation, giving the GTR team early insight into the analysis findings.

­The text from the original responses was linked to the relevant Principle and Requirement in one of two ways:

• Respondents could indicate for themselves which Requirements their comments pertained to in a closed question. Where respondents did this, we linked the closed and open question data together.
• Where respondents had not done this, we used formulae to look for references to requirement numbers in the text respondents had written. If a requirement number was found, this was added to the tabular report.

Narrative report

We also produced a full narrative report of the findings. As with all our consultation reports, this was done by carefully reviewing all the coded text, broken down by theme and code, and summarising in a narrative. The narrative report was unique among our reports, as the GTR team wrote a response to each chapter of findings, indicating how those findings had been used to update the draft Standard. Both writing teams worked carefully together to ensure the final report was a clear, fair and detailed account of what was asked, what was said, and what happened as a result.

Project management

As this was a high-profile piece of work within the global mining sector, there were considerable pressures on the programme and requirements that had to be accommodated during the project. As such it was necessary to review and adapt our approach and programme for analysis and reporting in response to changing priorities and requirements. We worked collaboratively with the GTR team to both understand the requirements, ensure that the Board’s views and inputs were considered and that the outputs would meet the needs of the wider project.

Impact

The consultation led to an updated, final, version of the Standard which was launched on 5th August 2020.

The consultation, and the new Standard that has resulted from it, has achieved many things, including:

• The Standard enshrines free prior and informed consent (FPIC) for landowners – often local and indigenous people. Operators are required to work to obtain FPIC for new tailings facilities on the land of local and indigenous people. 
• Community-focused emergency preparedness measures are now a requirement for any mining operation. 
• Communities now have a document which they can use to hold mining Operators to account. 
• Having a consultation and publishing not just the document but all of the responses with consent has helped give legitimacy to the process. 
• It has raised the profile of the issues at hand and started conversations about the rights of communities and the responsibilities of tailings facilities operators.  

We felt, and the GTR team agreed, that this has been a very effective and productive working relationship that supported the delivery of an final product informed by the views of those most affected and would form the basis of  ongoing positive social impact.