Review & Revisions

The International Cyanide Management Code (hereinafter “the Cyanide Code”) and other documents or information sources referenced at www.cyanidecode.org are believed to be reliable and were prepared in good faith from information reasonably available to the drafters. However, no guarantee is made as to the accuracy or completeness of any of these other documents or information sources. No guarantee is made in connection with the application of the Cyanide Code, the additional documents available or the referenced materials to prevent hazards, accidents, incidents, or injury to employees and/or members of the public at any specific site where gold is extracted from ore by the cyanidation process. Compliance with this Cyanide Code is not intended to and does not replace, contravene or otherwise alter the requirements of any specific national, state or local governmental statutes, laws, regulations, ordinances, or other requirements regarding the matters included herein. Compliance with this Cyanide Code is entirely voluntary and is neither intended nor does it create, establish, or recognize any legally enforceable obligations or rights on the part of its signatories, supporters or any other parties.

Review and Revision of the Cyanide Code and its Related Documents

The International Cyanide Management Code represents best practice for management of cyanide used in the gold and silver mining industry. The Cyanide Code and its supporting documents must evolve as best practice for cyanide management evolves. Periodic technical review of the Cyanide Code is therefore necessary to ensure that it continues to represent best practices for cyanide management. The Cyanide Code's Principles, Standards of Practice, Implementation Guidance and other documents will be reviewed and updated as needed so that they continue to reflect the best currently available practices.

The International Cyanide Management Institute (ICMI), a new organization with new procedures, was created to implement the Cyanide Code. Revisions to the administrative elements of the Cyanide Code may be necessary as ICMI, the gold and silver mining industry, cyanide producers and transportation companies gain experience in its implementation. In particular, this administrative review is needed to ensure that the questions in the Verification Protocols are properly focused and that verification audits are being conducted consistently around the globe.

The ICMI Board of Directors is responsible for overseeing these technical and administrative reviews and authorizing revisions in the Cyanide Code and its supporting documents.

Ongoing Review

All stakeholders are encouraged to identify technical deficiencies and administrative problems that exist as the Cyanide Code is implemented and to advise ICMI at info@cyanidecode.org or otherwise through communication with the ICMI President. The President will advise the Board of Directors of these issues and the Board will direct the President to take whatever action it deems appropriate. These may include, but are not limited to:

  • Soliciting stakeholder input;
  • Placing the item on the agenda for discussion at a Board meeting;
  • Drafting a Cyanide Code revision for the Board's consideration;
  • Contracting for research on the issue and/or development of a Cyanide Code revision for the Board's discussion and/or consideration;
  • Taking no further action.

Issues to be considered by the Board will be posted on the Cyanide Code web site at least one month prior to the Board's meeting, along with an invitation for additional stakeholder comment. The Board will consider the issue, determine whether or not a revision to the Cyanide Code or its related documents is necessary, and direct the President to implement its decision pursuant to the procedures prescribed in ICMI's by-laws.

In addition to the process described above, the ICMI Board of Directors at its own initiative may direct the President to evaluate technical aspects of the Cyanide Code, determine if the Cyanide Code continues to represent best practice for cyanide management and make appropriate recommendations for areas that should be updated, or have such a review conducted by a technical consultant.

Initial Review

In July 2005, ICMI announced its intention to evaluate Verification Audit Reports used to determine compliance with the International Cyanide Management Code, to assess whether the Cyanide Code was being audited consistently. Specifically, ICMI wished to ascertain if additional auditor guidance, revisions to the Cyanide Code and related documents, or other administrative changes were needed to ensure that the Cyanide Code is verified consistently throughout the world. ICMI’s Review and Revision Policy called for this review once a sufficient number of reports had been submitted from different regions and different auditors “to ensure that the evaluation of operations during Cyanide Code verification audits, and the resulting certification decisions by the auditors are being done consistently across the globe.”

Consistent with the Review and Revision Policy, ICMI announced on its web site on June 12, 2009 that it had contracted with Fred Banta, an environmental consultant in Denver, Colorado to conduct this review. At that same time, ICMI also requested Cyanide Code stakeholders to submit any information that would be useful in evaluating the consistency of Cyanide Code audits; no comments were received.

Mr. Banta’s report, completed in the fourth quarter of 2009, concluded that the variability of audit reports was within an acceptable range and that based on his review, no additional auditor guidance, revisions to the Cyanide Code and related documents or other administrative changes are currently necessary. ICMI’s Board of Directors has authorized ICMI to make the report publicly available. The Board also requested ICMI staff to continue to monitor the variability of audit reports, particularly with respect to how they address management systems and emergency response capabilities, and to determine the need for a follow-up evaluation several years hence as Cyanide Code implementation becomes more routine.

The report can be accessed via this link.