Environmental risk assessment as the basis for mine closure at Iscor Mining

Environmental Risk Assessment and Management (ERAM) is an approach, which is rapidly gaining popularity in South Africa. However, there are many different interpretations of the concepts and principles of ERAM and, unfortunately, a number of prevailing interpretations and wrong applications undermine the essential strengths of the riskbased approach. Examples of these misapplications are the application of the risk-based approach to: ➤ propagate the viewpoint of ‘limiting the risk of being prosecuted by the regulating authorities’. Applying the risk-based approach only to drive minimum legal/regulatory compliance management will most probably not cover all the uncertainties and associated risks, which will ultimately determine the granting of final closure. This mutation of the riskbased approach cannot be seen as the proper application of ERAM and is merely minimum compliance with the law under a different guise. It is also important to note that this approach does not protect one against common law claims which may be successfully pursued despite compliance with all regulations ➤ persuade regulators to accept lesser action than dictated by minimum standards, by arguing that the lesser action reduces the site-specific risk to an acceptable level. Caution should be taken in the application of the risk-based approach for this purpose. The focus should not be on obtaining relaxed standards, but rather to identify, quantify and manage the real risks ultimately prohibiting mine closure. Should sitespecific standards be changed in the process, this should be viewed as a spinoff and not the aim. Mutating the riskbased approach has the inherent danger that regulating authorities could perceive all risk-based approaches as techniques supporting operators in doing less than is required to responsibly protect the environment on a sustainable basis. Environmental risk assessment as the basis for mine closure at Iscor Mining