ISD calls for stronger community preparedness and independent assurance in tailings governance

New ISD analysis argues that the consequences of a tailings failure are shaped not only by engineering, but by what communities know, whether warnings reach them, and whether emergency systems have ever been tested with the people they are meant to protect.

The Institute for Social Dialogue (ISD) is calling for the social dimensions of tailings risk to receive the same level of scrutiny as engineering design, monitoring and technical assurance.

The call follows the release of ISD’s new insights paper, The Social Layer of Tailings Risk, and builds on The Fence Line Decides, a presentation delivered by ISD Programmes Manager Brown Motsau at the Mining Tailings Conference. Together, the two pieces make a central argument: tailings facilities may fail geotechnically, but the scale of the human consequences is also shaped by preparedness, disclosure, community participation and the quality of the relationships surrounding the facility.

The risk does not end at the wall

ISD’s research examines tailings failures including Merriespruit, Brumadinho and Jagersfontein and identifies a recurring social pattern despite very different engineering circumstances. Communities and workers closest to facilities have repeatedly faced limited warning, inadequate access to risk information, weak channels for escalating concerns and emergency systems that had not been sufficiently exercised with the people exposed to the consequences.

The paper argues that the engineering question does not end the moment a facility is declared technically compliant. Beyond the toe of the facility are homes, farms, schools, clinics, roads, water systems and people whose ability to act in an emergency depends on what happened long before the emergency itself.

Brown Motsau’s conference presentation framed the issue in equally practical terms: communities living along the fence line should not be treated simply as recipients of information. Under the Global Industry Standard on Tailings Management, meaningful engagement should contribute to the knowledge base, risk decisions, emergency planning and continuing disclosure.

“Tailings facilities fail geotechnically. They are governed socially.”

Brown Motsau, Programmes Manager, Institute for Social Dialogue

Forty-one per cent of the Standard is social performance

One of the most significant findings highlighted by ISD is that 41 per cent of the requirements in the Global Industry Standard on Tailings Management relate to social performance across its six topic areas.

The Standard begins with affected communities and includes requirements relating to meaningful engagement, grievance mechanisms, social context, human exposure and vulnerability, engagement with first responders and local authorities, community-focused readiness, recovery participation and public disclosure.

This means community engagement is not an optional communications exercise added after technical work has been completed. It forms part of the risk architecture itself.

The Fence Line Decides presentation focuses particularly on Principles 1 and 15. Principle 1 requires operators to respect the rights of project-affected people and meaningfully engage them throughout the tailings facility lifecycle. Principle 15 focuses on public disclosure and access to information in support of accountability.

Fifteen minutes can change the outcome

ISD’s paper points to peer-reviewed modelling of the 2019 Brumadinho disaster to demonstrate the potential significance of warning time. The modelling assessed 502 people in the run-out path and estimated 456 deaths with no warning. Five minutes of warning was modelled to save between 200 and 270 lives, while 15 minutes of warning produced zero modelled deaths.

For ISD, this is not simply an emergency communications statistic. Those minutes have to be created in advance through functioning social infrastructure: clear trigger protocols, alarms that people can hear and recognise, routes that communities have practised, identified assembly points, coordination with municipalities and first responders, and trusted information channels.

South Africa’s regulatory gap requires attention

ISD’s analysis also identifies an important gap between regulatory compliance and downstream community readiness. According to the Institute’s review of the South African framework, there is no general statutory requirement compelling an operator to provide households below a tailings facility with its consequence classification, inundation footprint or emergency plan.

Duties are distributed across water regulation, mining regulation and municipal disaster management. ISD’s concern is that significant information can move upward through institutions without necessarily reaching people living in the potential run-out path.

The Fence Line Decides presentation similarly argues that South African legislation provides an important regulatory floor, while the Global Industry Standard on Tailings Management currently asks more of operators in relation to affected communities, participation and disclosure.

ISD stresses that this is not an argument against the mining industry, nor a claim that South African tailings practice is uniformly poor. The Institute’s position is that a specific social assurance gap deserves more systematic attention alongside existing technical assurance.

From compliance to evidence

To support operators in addressing this gap, ISD has developed a Downstream Assurance Review that evaluates social readiness across six areas: knowledge of who is actually exposed; disclosure and community understanding; functioning channels for community voice and grievances; emergency preparedness; interface with municipalities and disaster management structures; and recovery and remedy arrangements.

The approach distinguishes between what is merely asserted, what is documented, what has actually been exercised, and what has been independently verified. ISD argues that the critical distance between having a plan and testing that plan with the people it is intended to protect is where preparedness becomes real.

The conference presentation complements this with a practical five-step approach for operators: map exposure independently, convene independently, co-build the knowledge base, institutionalise the feedback loop, and price trust into planning for retreatment and closure.

A shared responsibility

ISD is calling for a stronger working relationship between mining companies, regulators, municipalities, first responders and mining-affected communities.

The Institute believes stronger tailings governance requires more than additional consultation. It requires independently convened dialogue, accessible risk information, functioning grievance mechanisms, rehearsed emergency preparedness and evidence that communities themselves understand what to do if an emergency occurs.

The central question for boards and tailings teams should therefore not only be whether the wall is technically safe. It should also be whether the people below it are genuinely prepared.

About the Institute for Social Dialogue

The Institute for Social Dialogue (ISD) is an independent, non-partisan organisation working between mining companies, mining-affected communities, government, municipalities and civil society. ISD supports the sector through independent research, neutral convening, facilitated dialogue, community participation, independent verification, grievance resolution, institutional accountability and practical reform.

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