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About the Code

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Questions and Answers About the Code

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What is the "International Cyanide Management Code For The Manufacture‚ Transport and Use of Cyanide in the Production of Gold" (the "Code")?
Why was the Code developed?
How was the Code developed?
How was the development of the Code funded?
Why is cyanide used in gold mining? What is the mining industry doing to find alternatives to cyanide?
What percentage of global cyanide usage is by the gold mining industry?
Will all gold mines using cyanide comply with the Code?
How is the Code administered?
How does a company adopt and implement the Code?
What results when a company becomes a signatory to the Code?
Must a company that is signatory to the Code have all its gold mining operations certified as in compliance with the Code?
Who will ensure that companies follow the Code?
What qualifications are Code auditors required to have?
Will audit reports be made public?
Are there penalties for non-compliance with the Code? Is it truly enforceable?
Why is the Code limited to gold mining even though cyanide is used in other industries?
Are cyanide manufacturers and transporters signatories to the Code?
Are there charter members? Who are they?
Does the Code address all potential health‚ safety and environmental issues associated with gold mining?
Had the Code been in place‚ would it have prevented the Baia Mare spill?
Does the Code include requirements or criteria regarding where a gold mine using cyanide can be located?
Why does the Code include routine monitoring requirements and numerical limits for free and weak acid dissociable (WAD) cyanide but not for other forms of cyanide including total cyanide‚ cyanate‚ thiocyanate‚ cyanogens and strong metal-cyanide complexes such as iron and cobalt cyanides?
How does the Code address closure costs and financial assurance?
Does the Code establish mixing zones to dilute the concentration of cyanide discharged to surface water?
Does the Code address the risk to nearby communities from the release of hydrogen cyanide gas (HCN) from cyanide facilities at gold mines such as heap leach pads?
Will the code be updated at some point? Who will oversee that process?

1. What is the "International Cyanide Management Code For The Manufacture‚ Transport and Use of Cyanide in the Production of Gold" (the "Code")?

The Code is a voluntary industry program designed to assist the global gold mining industry in improving its management of cyanide. The Code is intended to reduce the potential exposure of workers and communities to harmful concentrations of cyanide‚ to limit releases of cyanide to the environment‚ and to enhance response actions in the event of an exposure or release.

The Code was developed to improve the management of cyanide at gold mines. Spills and other incidents involving cyanide solutions at gold mines such as the January 2000 incident at a Romanian gold mine demonstrated to the gold mining industry‚ governments and the public that better management of cyanide was needed‚ particularly at operations with limited experience or in countries lacking adequate regulatory programs.

The Code was developed under the auspices of the United Nations Environment Programme (UNEP) and the International Council on Metals & the Environment (ICME). In May 2000‚ at a joint UNEP/ICME-sponsored international workshop in Paris‚ cyanide producers‚ financial institutions‚ regulatory personnel‚ gold mining companies and environmental advocacy organizations from around the world met and recommended that a multi-stakeholder Steering Committee be formed by participants from the gold mining industry‚ governments‚ non-governmental organizations‚ labor‚ cyanide producers and financial institutions to deliberate on appropriate factors to include and to develop a Code. This project represents the first time that such a multi-stakeholder group has worked cooperatively to generate an international‚ globally based voluntary program for improvement of an industry activity.

The development of the Code was funded exclusively through contributions of gold mining companies and cyanide producers. The funds covered the cost of Steering Committee meetings (including transportation for some Committee members)‚ research and drafting of the Code‚ expenses for some stakeholders’ presentations to the Steering Committee‚ expert review of the Code‚ creation of a Code web site‚ Code promotion and initial costs of creating a management structure to administer the Code.

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5. Why is cyanide used in gold mining? What is the mining industry doing to find alternatives to cyanide?

Cyanide effectively and efficiently extracts gold from ore. While a number of other chemicals are available to extract gold‚ such as chloride bromide‚ thiourea‚ and thiosulfate‚ these form less stable complexes with gold and thus require more aggressive conditions and oxidants to dissolve the gold. The alternative chemicals are generally more expensive to use and also present risks to health and the environment that are similar to or greater than that presented by cyanide. The industry continues to search for cost-effective and environmentally friendly alternatives to cyanide. See Cyanide Facts for more information.

Of the approximately 1.4 million tons of hydrogen cyanide produced annually worldwide‚ about 13% is used to produce cyanide reagents for gold processing. The remaining 87% is used in other industrial applications which include the production of plastics‚ adhesives‚ fire retardants‚ cosmetics‚ pharmaceuticals‚ food processing and as an anti-caking additive for table and road salts.

Adoption and implementation of the Code is voluntary. Political jurisdictions lacking comprehensive regulations for the management of cyanide used in gold mining may find provisions in the Code helpful in developing their own regulatory programs.

8. How is the Code administered?

The International Cyanide Management Institute (ICMI) administers the Code. It is a non-profit corporation with a multi-stakeholder Board of Directors. ICMI's prime responsibilities are to:

encourage companies to adopt the Code and bring their operations into compliance with its Principles and Standards of Practice;
promote the Code within the gold mining industry and with other stakeholders;
develop sources of funding for Institute activities;
work with governments‚ NGOs‚ financial interests and others to foster widespread adoption and support of the Code; and
periodically review the Code and revise it as necessary to improve implementation and incorporate new advances in cyanide management

Companies agree to adoption of the Code by becoming Signatories and committing to bring their designated gold mining operations into compliance with the Code within three years. The name of the Signatory company and its operations will be identified on the Code website at Code Signatories to allow the public to track its progress towards certification. Each certified operation will be identified and its Summary Audit Report‚ Auditor Credentials Form and if applicable‚ Action Plan‚ will be available on the Code Signatories page. The audit process will be repeated at a minimum of every three years.

The company's operations are audited by an independent third-party auditor meeting the Code's criteria and using its Verification Protocol. The auditor will determine if the operation meets the Code's Principles and Standards of Practice and should be certified as being in compliance with the Code. Operations found in full compliance with the Code are certified and a Summary Audit Report and Auditor Credentials Form are posted on the ICMI web site. Operations found in substantial but not full compliance with the Code are conditionally certified and must develop and implement a Corrective Action Plan to achieve full compliance. A Summary Audit Report‚ Auditor Credentials Form and the Corrective Action Plan are posted on the ICMI web site. The operation becomes certified once implementation of the Corrective Action Plan is confirmed by the auditor.

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11. Must a company that is signatory to the Code have all its gold mining operations certified as in compliance with the Code?

Companies with multiple operations can select those they wish to certify as in compliance with the Code. This allows a company to seek certification of most of its operations even if one or more cannot be brought into compliance. This is especially important as the industry consolidates and companies acquire older properties that may not yet have reached the end of their productive life. Any benefits derived from compliance with the Code accrue to the certified operation‚ not the signatory company. The Code web site will list all of a signatory company's operations and indicate which it intends on certifying.

Companies that become Code signatories commit to periodic independent third party audits to determine whether their operations can be certified as in compliance with the Code's Principles and Standards of Practice. Audits will be conducted using Verification Protocols developed by the International Cyanide Management Institute (ICMI) by auditors meeting ICMI criteria. Copies of the Audit Protocols and Auditor Criteria are available elsewhere on this site. Summaries of the operation's audit results also will be posted on the web site. Audits will be conducted for initial certification and at three-year intervals thereafter and will include a site inspection and a review of applicable documents and records.

The International Cyanide Management Institute (ICMI) has developed criteria for the level of expertise and experience necessary for Code auditors and prohibiting conflicts of interest with the audited company. The lead auditor must also be a professional auditor certified by an organization meeting ICMI's requirements. The Auditor Criteria (PDF) are available for review on this site.

Once audits have been conducted‚ summaries of the audit results will be available for public review on the Certified Operations page.

As a voluntary program‚ ICMI cannot impose penalties. However‚ an operation that is not in compliance with the Code's Principles and Standards of Practice cannot be certified. Further‚ non-compliance at an already certified site would result in its de-certification‚ and de-certification of the operation would be posted on this web site.

The Paris Workshop and its participants focused exclusively on the use and management of cyanide in gold mining. Funding for Code development and industry involvement came from the gold mining industry‚ cyanide suppliers and manufacturers.

As originally written‚ the Code applied only to gold mines using cyanide. However‚ the Code fosters the responsible production and transportation of cyanide through its provision for gold mining operations to purchase cyanide from producers that have demonstrated their commitment to the protection of their employees and the environment and have it transported to their sites by transporters that have made a similar demonstration.

The Code has been revised to allow cyanide manufacturers and transporters to become signatories. Principles and Standards of Practice of the Code that are applicable to cyanide production and transport‚ as well as additional Principles and Stanards developed specifically for these types of activities have been included in their respective Verification Protocols.

The Code is not a membership organization. Any gold mining operation using cyanide‚ cyanide producer for use in gold mining‚ or transporter of cyanide for use in gold mining can commit to follow the Code's Principles and Standards of Practice by becoming a Code Signatory.

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19. Does the Code address all potential health‚ safety and environmental issues associated with gold mining?

The Code addresses those issues related to the management of cyanide at gold mines that have been identified as being of most immediate concern. These include the production of cyanide; its transport from the producer to the mine; its on-site storage and use in the recovery of gold; decommissioning of cyanide facilities; financial assurance; accident prevention; worker health and safety; emergency response and training; community dialogue; public reporting; and stakeholder involvement.

This focus has resulted in the development of an international code in a timely manner and presents the opportunity for immediate improvement in the way cyanide is managed at these facilities. Other potential issues of concern related to mining‚ such as design and construction of tailings impoundments are currently being pursued through the development of independent codes by other international organizations.

As more gold mining companies become signatories and implement the Code at their operations‚ the frequency and severity of cyanide exposures and releases is expected to decrease and the capability of the operations to respond to those that do occur should improve. This will assure the public that operations certified as compliant with the Code have significantly limited the potential that their cyanide use will adversely impact human health or the environment.

It appears that full implementation of the Code could have contributed to the prevention of the Baia Mare accident. The Report of the Baia Mare Taskforce (established by the governments of Rumania and Hungary‚ the European Commission and the United Nations to evaluate the causes and impacts of the spill and measures to reduce the risks of such accidents occurring in the future) identified the following four causes of the spill:

There was no provision in the design of the tailings impoundment for discharge of excess water;
Construction of the impoundment did not follow the design specifications;
Monitoring of the pond level was insufficient to identify the water balance problem as it developed; and
The Romanian government did not provide sufficient oversight during the permitting process‚ especially with regard to the water balance.

Three of the four causes of the spill are directly related to the facility's water balance. The Code stresses the importance of the water balance and specifically requires that operating practices consider the ranges of anticipated precipitation and the potential impacts of the thawing of accumulated ice and snow within an impoundment and its upgradient watershed. How the facility addressed these parameters‚ as well as its monitoring techniques would have been reviewed during the Code verification audit. Additionally‚ the Code's provisions regarding preventive maintenance of equipment necessary to prevent unauthorized discharges would have required that pumping capacity was available when needed. It is likely that the spill would have been prevented had these water balance issues been identified during a Code Verification Audit and corrected as part of the Code Certification process.

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21. Does the Code include requirements or criteria regarding where a gold mine using cyanide can be located?

No. The Code does‚ however‚ set standards of performance for the management of cyanide that are applicable regardless of the location of a gold mining operation. It does not address the issue of site suitability. It should be noted that the Code's requirements are such that some potential mine site locations would present significant technical difficulties and increased costs to ensure compliance with the Code. For example‚ meeting the Code's requirements for an adequate water balance and related contingency measures will likely be much greater in areas where precipitation greatly exceeds evaporation than in very arid regions.

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22. Why does the Code include routine monitoring requirements and numerical limits for free and weak acid dissociable (WAD) cyanide but not for other forms of cyanide including total cyanide‚ cyanate‚ thiocyanate‚ cyanogens and strong metal-cyanide complexes such as iron and cobalt cyanides?

These are the forms of cyanide anticipated to be present in gold mining process solutions and wastes that have recognized and established human and environmental toxicity. As such‚ monitoring their concentrations in solutions that are available to wildlife or that may be discharged to the environment is necessary and appropriate.

Some forms of cyanide‚ including strong metal cyanide complexes such as iron and cobalt cyanides‚ are not sufficiently soluble to present any significant danger of toxicity. Cyanogen may be formed from the strong chemical oxidation of cyanide (e.g.‚ by treatment of free or WAD cyanide with sodium hypochlorite)‚ but is not typically present in gold mine process solutions or waste. Neither cyanate nor thiocyanate‚ which are approximately seven times less toxic than free cyanide‚ are anticipated to be present in toxic concentrations in gold mining wastes and effluent.

The Code requires that certified gold mining operations plan and implement procedures for effective decommissioning of cyanide facilities to protect human health‚ wildlife and livestock. Decommissioning is defined as the activities conducted at the cessation of gold production to treat‚ neutralize or otherwise manage cyanide reagent and process solutions remaining in storage and production facilities in preparation for closure so that they do not present a risk to people‚ wildlife or the environment due to their cyanide content. Decommissioning includes decontamination of equipment‚ removal of residual cyanide reagents‚ rinsing of heap leach pads and installation of measures necessary for control or management of surface or ground water‚ such as pumping and treatment systems that would operate during the facility's closure period.

The Code also requires that certified gold mining operations establish an assurance mechanism capable of fully funding cyanide-related decommissioning activities. If the political jurisdiction in which the operation is located has financial assurance requirements‚ then the Code accepts any financial instrument acceptable to the jurisdiction‚ as long as the amount is equal to or greater than the current estimated decommissioning cost. Where there is no otherwise applicable financial assurance requirement‚ the Code recognizes cash‚ bonds‚ letters of credit‚ insurance and accruals. The Code will also recognize a corporate guarantee if the operation provides a statement by a qualified financial auditor that it has sufficient financial strength to implement its decommissioning plan as demonstrated by an accepted financial evaluation methodology such as those described in the United States and Canadian mining and/or hazardous wastes disposal regulations.

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24. Does the Code establish mixing zones to dilute the concentration of cyanide discharged to surface water?

The Code does not establish mixing zones. However‚ since many jurisdictions incorporate mixing zones into an operation's authorization to discharge solutions to surface waters‚ the Code acknowledges them by allowing compliance with the Code's numerical standard for surface water downstream of a mixing zone that has been authorized by the applicable jurisdiction.

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25. Does the Code address the risk to nearby communities from the release of hydrogen cyanide gas (HCN) from cyanide facilities at gold mines such as heap leach pads?

There are several provisions in the Code that address the release of hydrogen cyanide (HCN) from the process solutions. One requirement is for maintaining of a sufficiently high pH of the solution to control the release of HCN‚ thereby protecting workers at the operation who are near the solutions and any nearby communities or people off the mine site. Provisions for emergency response planning also consider the risk of hydrogen cyanide evolution and release. The concentration of hydrogen cyanide in the air around a heap leach operation typically is such that personnel who routinely work around and on these facilities do not require protective equipment for hydrogen cyanide gas.

The International Cyanide Management Institute (ICMI) will monitor the Code's implementation and evaluate its effectiveness as it is adopted at gold mines around the world. The Institute will identify any technical or administrative problems or deficiencies that may exist with Code implementation and will determine when and how the Code should be revised and updated. This procedure is available on the Code Review and Revision page.

Last Updated: January 9, 2007