ICMI Announces Revisions to Cyanide Code Documents Regarding New Requirement for the Use of Dye in High Strength Cyanide Solutions at Mining Operations

Today, the International Cyanide Management Institute (ICMI) posted revisions to Cyanide Code documents regarding a new requirement for the use of colorant dye in high strength cyanide solutions at mining operations. This action follows a December 2017 decision by the ICMI Board of Directors approving this change to the Cyanide Code program.

In late 2015, ICMI identified several possible program changes having the potential to strengthen the Cyanide Code program. Among the possible changes was whether to require or otherwise encourage the practice of adding dye to reagent cyanide as a means of visual identification of leaks or spills at mine sites or during transportation. Many chemical manufacturers add colorants, odoriferants and other indicators to dangerous chemicals that do not possess an obvious identifying characteristic. The purpose is to provide a quick and distinctive way for users to identify these substances.

The ICMI Board’s decision came after seeking stakeholder comments through a public process in 2017. Last August, ICMI announced via its website and mailing list that it was seeking comments on the proposed requirement for dye addition to high strength cyanide solutions. ICMI also publicized the consultation in the third quarter edition of its newsletter. Additionally, a letter was sent by ICMI to each of the mining company and cyanide manufacturer inviting them to comment on the proposal. All comments received by ICMI voiced support for the proposed change.

Under the program revisions, high strength cyanide solutions must contain dye for clear identification when out of proper containment and for clear differentiation with other solutions or rainwater that may be present. Dye must be added at concentrations so as to provide a clear visual indicator of high strength cyanide solutions. For adding dye, high strength cyanide solutions are defined as those having a minimum cyanide concentration of 15%. For solid cyanide, dye should be added prior to or at the time of mixing, so that the resultant cyanide solution is dyed. When liquid cyanide is delivered to an operation, the solution should be dyed prior to delivery. Responsibilities for dye addition should be clearly identified in operational documents and in supplier agreements, as noted under question 2(f) of Standard of Practice 3.2.

The following documents that implement the Cyanide Code program have been revised to incorporate the requirement:

Implementation Guidance for the International Cyanide Management Code (Implementation Guidance):  Guidance for dye addition has been included under Standards of Practice 2.1, 3.2, and 6.2 of the Implementation Guidance.
Auditor Guidance for Use of the Mining Operations Verification Protocol (Auditor Guidance): The requirement for dye addition has been incorporated through revisions to the following Standards of Practice:
Standard of Practice 2.1: Addition of a new item “c” under question 1;

Standard of Practice 3.2:  Addition of a new item “f”, under question 2, and addition of associated guidance;

Standard of Practice 6.2:  Addition of a new question “6”, and addition of associated guidance.

Mining Operations Verification Protocol and Mining Operations Pre-Operational Verification Protocol: The requirement has been incorporated through the following revisions:
Standard of Practice 2.1: Addition of a new item “c” under question 1;

Standard of Practice 3.2: Addition of a new item “f” under question 2;

Standard of Practice 6.2:  Addition of a new question “6”.

The requirement for dye will become effective and auditable as of July 1, 2019. Companies are encouraged to adopt this practice prior to that date, and for audits conducted prior to July 1, 2019, auditors are asked to note in their Detailed Audit Findings Report if the practice has already been adopted.

The Cyanide Code is a voluntary industry program for companies involved in the production of gold and/or silver using cyanide and companies producing and transporting this cyanide. It was developed under the aegis of the United Nations Environment Programme by a multi-stakeholder Steering Committee. The Cyanide Code is intended to complement an operation’s existing obligation to comply with the applicable laws and regulations of the political jurisdictions in which the operation is located.

ICMI has been established to administer the Cyanide Code, promote its adoption, evaluate its implementation, and manage the certification process. A detailed list of the operations covered by signatory companies’ applications, along with the full text of the Cyanide Code and its implementing and administrative documents, are available at www.cyanidecode.org.

Tuesday, February 6, 2018