**3. Additional differences between MAC guides and ISO standards**

We will now analyze other changes promoted in Version 3.2 of the Tailings Guide "see [2]", and also in Version 2.1 of the OMS Guide "see [5]", and their potential impact on the ease of integration between management models advocated in the article 'Integrated Risk Management in Mining Waste Facility' "see [1]", mentioned earlier in this text.

### **3.1 Policy and commitment**

To highlight, in the text added in Version 3.2 of the Tailings Guide "see [2]", in relation to the previous one, the emphasis given to the need for the Owner of the tailings facility to demonstrate commitment to a culture that promotes the early recognition of problems, and also with the response to emergencies and participation

in post-incident recovery, in collaboration with authorities and communities of interest (COI).

This in no way impacts the analysis made previously and the perspective of integrating management mechanisms.

### **3.2 Managing change**

To highlight, in the text added in Version 3.2 of the Tailings Guide "see [2]", in relation to the previous one, the emphasis given to the Engineer of Record (EoR) succession plan.

This in no way impacts the analysis made previously and the perspective of integrating management mechanisms.

### **3.3 Control of documented information**

The most significant change promoted in version 2.1 of the OMS Guide "see [5]" was precisely the transfer of the text existing in the second edition of this guide, then called 'Control of Documented Information', to the Tailings Guide. The text, in addition, was enriched in content, renamed 'Information Management', in turn subdivided into two requirements: 'Information to be Documented' and 'Control of Documented Information'. The text has been transferred from the OMS Guide to the Tailings Guide because the latter is applicable to documented information that goes beyond that contained in OMS manuals.

The text of the new 'Information to be Documented' requirement even spells out what information must be documented and updated throughout the tailings facility lifecycle, and references to the new Appendix 6 (Information to be Documented to Support Responsible Tailings Management) and Appendix 8 (Technical Considerations) of the Tailings Guide "see [2]", specifically with regard to the closure plan.

In terms of correspondence with the text of the ISO standards, the new text of the Tailings Guide presents itself as more aligned in the richness of details, containing specific characteristics of a specific management system for mining tailings facilities.

### **3.4 Training and competence**

To highlight, in the text added in Version 3.2 of the Tailings Guide "see [2]", in relation to the previous one, the importance given to the traceability of evidence of competence, in order to ensure that all relevant personnel receive the appropriate training.

This in no way impacts the analysis made previously and the perspective of integrating management mechanisms.

### **3.5 Communications**

Section 3.1.2 of the OMS Guide - second edition "see [7]", discussing Communications, was deleted and incorporated into Version 3.2 of the Tailings Guide "see [2]". The associated appendix (Appendix 7: Factors in Effective Communications, Governance, and the "Human Element" of Tailings Management) was also moved to the Tailings Guide, even with the same numbering.

The three ISO standards do not go as deep as the Tailings Guide on Communications aspects and, in a common way, define the need for the organization to establish, implement and maintain the necessary processes for internal and external communications, including: a) about what to communicate; b) when to communicate; c) with whom to communicate; d) how to communicate; e) who should communicate. The ISO 14001 "see [3]" and ISO 45001 "see [9]" standards

### *Integrating the Safety Management of Tailings Facilities to the ISO Model and to the Global… DOI: http://dx.doi.org/10.5772/intechopen.100020*

also emphasize the need to take into account legal obligations and ensure that the information communicated is consistent with that generated within the scope of the management system, and that it is reliable.

The Tailings Guide "see [2]", for its part, emphasizes the fact that timely communication of potential problems can be essential to achieving the goal of minimizing harm, and cites two main mechanisms for establishing a corporate culture that encourages people to report problems: establishing a confidential process to promptly receive, investigate and resolve issues; and the development and implementation of whistleblower protection mechanisms to ensure there are no retaliations.

It is also important to cite the content of the aforementioned Appendix 7, which presents a summary of 14 lessons learned on governance and communications, applicable to tailings management and dam safety, extracted, according to the Tailings Guide "see [6]", from the publication Martin, T. (2001) - Pearl Harbor: Lessons for the Dam Safety Community (presented at the annual conference of the Canadian Dam Association).

### **3.6 Management review for continual improvement**

The Tailings Guide text "see [2]" incorporated, as one of the inputs to periodic management reviews, the integration of tailings management activities with site-wide systems, such as, where applicable, a site-wide environmental and social management system.

This requirement meets the idea of integration of management mechanisms advocated by the authors.

Another addition made in version 3.2 of the Tailings Guide "see {2]" was the requirement that management review describe the current conditions related to the tailings facility, including a summary of construction activities since the last review, as well as any significant changes that have taken place since the last management review, including: an assessment of whether the tailings facility is continuing to meet the design intent; and a summary of any deviations from the design or expected conditions since the last management review, including an assessment of the cumulative impacts of those deviations.

Finally, to highlight an item added in version 3.2 of the Tailings Guide "see [2]", the list of changes that should be considered for the continuous improvement of the tailings management system: relevant new or emerging technologies, practices or knowledge related to tailings management.

Such particularities found in the Tailings Guide text in no way compromise the analysis made before and the perspective of integration of management mechanisms.

From the "Do" element of the Plan-Do-Check-Act (PDCA) cycle in version 3.1 of the Tailings Guide "see [6]", Section 5.3 was deleted, which described a checklist that could assist in the implementation of the tailings management framework throughout the life cycle. Appendix A.5.1 - Considerations for Managing Throughout the Life Cycle of a Tailings Facility, which included, in version 3.1 of the Tailings Guide "[6]", an illustrative sample of a master checklist, to be used as a tool for Owners in implementing the tailings management framework, has been deleted in version 3.2 "see [2]". The checklist has been replaced by MAC in the Tailings Guide by a Table of Conformance, as a reference for Gap Analysis in relation to the TSM® Tailings Management Protocol.

As part of the effort to bring TSM® into line with the standard, MAC has added a new supporting appendix (Appendix 6: Information to be Documented to Support Responsible Tailings Management) on information requirements related to: site characterization; design information; documentation on construction and as-built conditions; and closure plan.
