Tokyo Airport 19.11.11 in between flights on our way back to France after one week of EHS audit for a giant global Mining company located ‘at the edge of world.
This is my last REACH blog post for Accenture. As of December 1st will be back to the Industry side of the house posting on EHS and Regulatory Compliance. But I cannot leave this consulting experience without talking about an EHS audit in New Caledonia for a global mining company.
As you know, mining companies have made significant progress with respect to environment, health and safety (EHS) practices over the past decade, despite difficult times in the past and a growing global competitive environment. The continuous effort of some leading companies is getting recognition from the international community including UNEP, NGOs and, EHS experts.
Although noticeable progress have been made, some market trends affect the EHS governance of these companies; notably, the increasing regional and global corporations of the mining landscape lead consolidation. We observe that the rapid increase of company size results in fewer EHS controls and audits at the industry site scale, which are vital to safeguard licenses to operate. This is the reason why most mining industry leaders engaged their companies in challenging ‘fast track’ programs to align their EHS operations’ strategic plans, to harmonize audit protocols and EHS performance assessment, and to identify global group best practices.
Confirming this fact, the second largest mining company in the world initiated an EHS program and implemented their own EHS norms. In order to help assess their site, they asked Accenture to perform an EHS & Compliance International diagnosis at their sites spread across 15 countries.
Our Accenture EHS expert network, including teams from North America, Europe and Oceania, Latin America, Africa and the Middle East, embarked on this EHS crusade worldwide. My team, composed of native French speakers, to better interpret local regulations and facilitate communication with local operators, was assigned the EHS diagnosis of their site based in New Caledonia.
Initially, we developed EHS checklists based on the New Caledonia Regulation to be used on site for interviewing the operating units. We also check processes and investigated the non-conformities to support local action plans. The identified non-conformities were qualified, related risks analyzed and then reported to the local site along with recommendations for improvement.
Based on the round of interviews with the workers, engineers, supervisors, directors, and the changes to New Caledonia EHS Regulations, all agreed that mining and refining sites of this island needed to plan and prepare for stricter compliance needs (e.g., waste handling, dangerous substances handling, classification and labeling).
These upcoming regulatory changes will impact site’s daily operations (procedures, management systems, etc.) and a proper stepwise EHS change management approach needs to be anticipated so that culture and operations move in parallel to achieve compliance.
The sharing of best practices across the mining group (and perhaps across mining companies) can help the mining players to move to the next stage and strengthen their action plan. These best practices can include the approach that best performers are using in the stricter regulatory areas.
Reflecting on this overall EHS assessment, it gave to the team some material to think about:
- How to ensure that the adequate regulatory screening is in place for better compliance,
- How to operate the progressive shift in culture change and the maintenance of the desired culture on site?
- How to select a skilled contractors workforce on site based, amongst other factors, on their EHS performances?
And for all of these elements above, the difficulties are reinforced by the geographic isolation of this environment…
These questions will not be answered directly as the scope of our work is was restricted to this first diagnosis. However, we could not stop thinking about solutions on our way home, inspired by the people we met and the excellent collaboration on site.
To finish, the two pictures I am taking with me while leaving Accenture:
- The arrival at the site’s harbor (as we commuted daily to the Prony Bay by boat) : a beautiful bay, surrounded by hills and nature - I have been told by one site Health & Safety engineer that it is not unusual to cross whales and tiger sharks in the water in this bay!
- Then stepping out of the boat to take the bus, the long steep road to finally catch sight of the smoke pouring out of the chimneys – a signal informing us of human activity in this lateritic landscape. It looks like technology is appearing out of nowhere.
And one question: do I need to punch my arm to feel that I am not dreaming?
… this is not a dream… as I get out of the bus and arrive to the office, I suddenly hear the site Health & Safety director, inviting our team for a debriefing of our findings of the previous day.
In brief, this is a place where the constant challenge for EHS operators is to find the right equilibrium between:
- The production optimization of the mining and refining operations;
- The preservation of the surrounding unique and fragile ecosystem;
- The safeguarding/improvement of the site’s health and safety performances;
- The establishment of sustainable relationships with the local communities through the management of the socio-economic needs.
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