Extractives & Minerals Processing
Public Comment Analysis
Public Comment Period Closed
The current standards for the Metals & Mining and Coal Operations industries within the Extractives & Minerals Processing Sector are being evaluated for potential revision to ensure the set of disclosures fully captures the risks associated with company management of tailings storage facilities (TSF). The project also aims to improve global applicability of the standards.
Tailings are mining operations waste, usually stored in ponds or dams, frequently covering very large land areas. Impoundments for tailings can present a significant threat if they collapse, potentially leading to the loss of life and/or damage to property and ecosystems, which bears significant financial implications. Recent catastrophic failures of TSFs include Imperial Metal’s 2014 release of waste slurry in Canada’s Polley Lake, a 2015 dam failure in Mariana, Brazil (a Vale/BHP joint venture), which entailed $6 billion in expenditures to restore the environment and affected communities, and Vale’s tragic January 2019 dam collapse in Brumadinho, which resulted in a $4.95 billion loss for the company in the first quarter after the disaster.
Since the SASB standards were codified in November 2018, there has been a significant evolution of investor interest and corporate disclosure related to tailings facilities management. Management of tailings facilities has been included in the SASB standards for the Metals & Mining and Coal Operations industries since SASB developed its first, provisional exposure draft for these industries in 2014. However, as global investors continue to express interest in the topic and evaluate the utility of various existing and proposed reporting frameworks, we believe there is opportunity to improve the industry standards in this area. We can even see some Oil & Gas – Exploration & Production industry companies, that own or operate tailings storage facilities management, benefiting from improved transparency on the subject, given the investor interest and materiality of the topic.
- Phase 1 - Initial Research
- Phase 2 - Stakeholder Consultation
- Phase 3 - Post-Consultation Analysis
- Phase 4 - Exposure Draft Development
- Phase 5 - Public Comment Period
- Phase 6 - Public Comment Analysis
- Phase 7 - Completed
Staff has analyzed public comment letters, which included conducting additional consultations and research to better understand the implications of market feedback and how it could impact any future standards updates.
Staff is developing a post-exposure draft of the relevant standards.
Published Documents & Supplemental Materials
- Summary of Public Comments – Tailings Management in Extractives, July 2021, PDF
- Project Update and Call for Feedback: Tailings Management in Extractives, March 2020, online blog
- Briefing Document, April 2020, PDF
- Today in Market Feedback: Tailings Management in Extractives, September 2020, online blog
- Tailings Management Project Enters Public Comment Period, December 2020, online blog
- Today in Market Feedback: Tailings Management Revisited, July 2021, online blog
Public Comment Letters
Comment letters are received as part of the public comment period between December 17, 2020 and March 17, 2021. Comment letters are posted in the order of receipt. Please note that it can take up to two weeks for comment letters to be posted.
- Teck Resources, 02-17-2021
- ING Bank, 02-22-2021
- Canadian Natural Resources, 02-25-2021
- Golden Star Resources, 03-09-2021
- International Council on Mining and Metals, 03-10-2021
- Earthworks, 03-15-2021
- Church of England Pension Board, 03-17-2021
- Earth Resource Investments AG, 03-17-2021
- Equinox Gold Corp, 03-17-2021
- Freeport-McMoRan, 03-17-2021
- Michael Proulx, MGA, 03-17-2021
- Nutrien, 03-17-2021
- Suncor Energy Inc, 03-17-2021
- The Goldfield Corporation, 03-17-2021
- Kinross Gold Corporation, 03-18-2021
Board Materials & Decisions
Board Meeting Outcomes
- Staff presented the results of the recently concluded public comment period, in which 15 public comment letters were received from a range of market participants.
- The Board discussed a theme arising out of public comments centered on the appropriate level of alignment between the SASB Standards and the Global Industry Standard on Tailings Management (GISTM). Board members noted the differing objectives between the SASB Standards and the GISTM, which the Board generally agreed indicates careful consideration around alignment. However, the Board remained generally supportive of continued alignment with GISTM, when consistent with the SASB Conceptual Framework, and expressed caution around unnecessary divergence.
- The Board discussed a second theme observed in public comments centered on definitions for the the terms “material findings” and “significant incidents.” The discussion focused on challenges related to the lack of clear definitions for these terms. Board members provided a range of suggestions for staff to consider as it advances forward.
- Next steps for the project include continuing deliberations on any further revisions to the exposure draft and continuing to engage with market participants to ultimately inform the staff recommendations to the Board.
- Staff presented metrics developed for the two disclosure topics under the project’s scope – Waste & Hazardous Materials Management and Tailings Storage Facilitates Management. Metrics were modeled for the Metals & Mining Industry and would be modified for Coal Operations Industry appropriately.
- The Board discussed open issues such as the lack of globally accepted definitions of hazardous waste and materials; the preferred format of disclosure for the Tailings Storage Facilities Management topic – aggregate per company vs. tabular per site; and options for defining “material findings” that may result from companies’ dam safety reviews.
- Next steps in the project will consist of developing exposure drafts for both industries and submitting those to the Standards Board for a vote in the coming weeks
- The Board discussed a preliminary decision to add a new Tailings Management disclosure topic to the Metals & Mining and Coal Operations industry standards. The new topic will fall under SASB’s Leadership & Governance sustainability dimension and will be associated with the Critical Risk Incident Management general issue category. The Board expressed support for this preliminary decision with no Board members expressing significant concerns or reservations at this point.
- The preliminary decision included maintaining the Waste & Hazardous Materials Management disclosure topics in the two industry standards, but narrowing their scope to industrial waste issues as risks related to tailings facilities will be addressed in the new disclosure topics cited above.
- Staff will continue research and consultation in further support of metrics development based on the preliminary decisions on disclosure topics made by the Board. Staff plans to present the Board with a proposed exposure draft for both industries within the next three months, though notes timing implications of third-party market initiatives on tailings that may impact the
- The Board unanimously agreed to add a project on Tailings Management in Extractives to its standard setting agenda.
- The project will evaluate the issue of tailings facility management in the Metals & Mining and Coal Operations industry standards, including the scope of the Waste & Hazardous Materials Management topic and its corresponding accounting metrics.
For a full list of past and upcoming Standards Board meetings, as well as associated materials, please visit our Board Meetings Calendar & Archive.
The staff has prepared this summary for informational purposes only. Any Standards Board decisions are tentative and do not change current accounting. Official positions of SASB are determined only after extensive due process and deliberations.