6.1 Mount Polley Panel: Lesson Learned
67
regard the Panel emphasized the need for (1) comprehensive assessments of potential
geotechnical problems; (2) a detailed evaluation of all potential failure modes; and
(3) a management scheme for all residual risk. This highlights the need to base design
decisions and approvals on a thorough identification assessment of risks within the
context of the multidimensional aspects of the consequences (see Chap. 12) and the
complexity of failure modes (Chaps. 9–11), as will be discussed further in this book.
6.2 Mount Polley Auditor General: Lessons Learned
The Auditor General’s report does not elaborate on the general principles stated above
but it does identify the need for a rigorous and disciplined risk-based approach by the
regulator in keeping with the objective to protect the public from significant risks. If
one starts with the premise that the public needs to be informed about the potential
risks, it logically follows that the regulator need to be informed, permit applications
need to be justified on the basis of risk tolerance and designs, and operating plans
must explicitly identify and address residual risks. Such an approach would provide a
solid basis for a strong compliance and enforcement program, which in itself would
ensure a higher level of risk identification and management in the design of new
mines and periodic permit amendments and would help focus ongoing compliance
activities on the issues of importance.
Another contribution of the Auditor General’s report relates to the degree of
reliance that a government places on the information provided by engineers of record
(EoRs) or qualified professionals retained by a company and the standards used to
support their submissions. In particular, the report notes that an over reliance on
qualified professionals was observed and that the acceptance of the industry design
standard, as provided by the Canadian Dam Association’s Dam Safety Guidelines
(CDA 2007), was inadequate to guide both inspectors and industry. Both of these
issues point to the need for government to have the ability to undertake or commission
independent reviews, particularly those related to risk identification and management.
6.3 Samarco Panel: Lesson Learned
The first question that is raised by the Fundão Panel’s report (Sect. 2.2) is related to
the high level of detail and study that was required to analyse and understand what
went wrong. That is, is an equivalent level of examination required for the initial
design of a tailings dam and for subsequent modifications or changes to a design?
The obvious answer to that question is that it would depend on the significance of the
hazards that such designs or changes would be exposed to or generate. This answer
can only be provided by the requirement for comprehensive change management
procedures supported by rigorous risk assessment methodologies.
67
regard the Panel emphasized the need for (1) comprehensive assessments of potential
geotechnical problems; (2) a detailed evaluation of all potential failure modes; and
(3) a management scheme for all residual risk. This highlights the need to base design
decisions and approvals on a thorough identification assessment of risks within the
context of the multidimensional aspects of the consequences (see Chap. 12) and the
complexity of failure modes (Chaps. 9–11), as will be discussed further in this book.
6.2 Mount Polley Auditor General: Lessons Learned
The Auditor General’s report does not elaborate on the general principles stated above
but it does identify the need for a rigorous and disciplined risk-based approach by the
regulator in keeping with the objective to protect the public from significant risks. If
one starts with the premise that the public needs to be informed about the potential
risks, it logically follows that the regulator need to be informed, permit applications
need to be justified on the basis of risk tolerance and designs, and operating plans
must explicitly identify and address residual risks. Such an approach would provide a
solid basis for a strong compliance and enforcement program, which in itself would
ensure a higher level of risk identification and management in the design of new
mines and periodic permit amendments and would help focus ongoing compliance
activities on the issues of importance.
Another contribution of the Auditor General’s report relates to the degree of
reliance that a government places on the information provided by engineers of record
(EoRs) or qualified professionals retained by a company and the standards used to
support their submissions. In particular, the report notes that an over reliance on
qualified professionals was observed and that the acceptance of the industry design
standard, as provided by the Canadian Dam Association’s Dam Safety Guidelines
(CDA 2007), was inadequate to guide both inspectors and industry. Both of these
issues point to the need for government to have the ability to undertake or commission
independent reviews, particularly those related to risk identification and management.
6.3 Samarco Panel: Lesson Learned
The first question that is raised by the Fundão Panel’s report (Sect. 2.2) is related to
the high level of detail and study that was required to analyse and understand what
went wrong. That is, is an equivalent level of examination required for the initial
design of a tailings dam and for subsequent modifications or changes to a design?
The obvious answer to that question is that it would depend on the significance of the
hazards that such designs or changes would be exposed to or generate. This answer
can only be provided by the requirement for comprehensive change management
procedures supported by rigorous risk assessment methodologies.