Implementing the Cyanide Code: Questions and Answers

Following are answers to questions that are frequently asked regarding Cyanide Code implementation, audits, compliance, and certification.

When becoming signatory to the Cyanide Code companies commit to notify ICMI of any significant cyanide incidents within 24 hours of an occurrence.  The criteria for significant cyanide incidents and expectations for their reporting are detailed in ICMI’s Signatory Application Form.  Operations or their parent company are expected to make initial notification to ICMI within 24 hours of occurrence of a significant cyanide incident.  This notification should include the date and nature of the incident, and the name and contact information of a company representative to respond to requests for additional information.  Further salient information, such as root cause, health, safety and environmental impacts, and any mitigation or remediation should be provided within seven days of the incident. 

Operations must maintain, test and calibrate their fixed and personal hydrogen cyanide monitoring equipment as recommended by the manufacturer.  Records of these activities must be retained for at least three years and be available for review by the auditor. Although through 2020 operations were expected to keep only 1 year of records, revisions to the Code’s documents in 2021 now state that these records must be retained for three years, in line with the Code’s expectations for retaining other records.

An operation can make information on cyanide events publicly available in a variety of ways, including in a company’s or corporation’s Annual Report or Health, Safety and Environmental report, on a company’s own website, or as part of applicable governmental reporting requirements, as long as these reports are public information.  However, the intent of the Code is that companies be transparent as to the number, location, extent, and effects of cyanide incidents.  Simple statistics, such as a statement that a company experienced three cyanide incidents in a year, without noting details such as the operations at which the incidents occurred, the nature of the incidents, or any impacts on workers or on natural resources would not meet the intent of the Code for public disclosure.  Similarly, reporting to a regulatory agency may not be sufficient, unless the agency also makes the information publicly available, such as upon request or via a publicly accessible website.

Within 90 days of the completion of the on-site portion of a certification audit, auditors must submit to ICMI electronic copies of the draft Detailed Audit Findings report and Summary Audit Report, along with both a hard and an electronic copy of their notarized Auditor Credentials Form.  The notarized Auditor Credential Form is the only document that ICMI requires in hard copy.