TSM ASSESSMENT PROTOCOL

Transcription

1 TSM ASSESSMENT PROTOCOL A Tool for Assessin Tailins Manaement Performance Introduction Launched in 2004, Towards Sustainable Minin (TSM) is an initiative of The Minin Association of Canada desined to enhance the industry s reputation by improvin its performance. MAC members subscribe to TSM uidin principles, a set of commitments that addresses all areas of our industry s performance. These uidin principles are backed by specific performance indicators, which member companies bean reportin aainst in These indicators are desined to identify the industry s current performance in key performance areas, and point to actions that could be taken to improve it. Areas for which performance indicators have been developed include tailins manaement, enery use and reenhouse as emissions manaement, external outreach and corporate crisis manaement plannin. This document provides a tool to assist companies in the assessment of the standard of tailins manaement currently bein implemented by their sites, in conformance with the TSM tailins manaement performance indicators. It enables key performance indicators to be sereated, and performance improvements for each indicator tracked year to year. The use of this protocol also enhances the consistency of assessments conducted across companies. In addition, this tool has been desined to enable external verification of company performance, consistent with the TSM verification system and the initiative s commitment to transparency and accountability. Assessin Tailins Manaement Implementation Tailins manaement has been an area of sinificant focus by The Minin Association of Canada, first throuh a Board Task Force and subsequently throuh the Tailins Workin Group. This focus has led to the preparation and publication of: A Guide to the Manaement of Tailins Facilities (1998, updated in 2008 and to be published in 2009); Developin an Operation, Maintenance and Surveillance Manual for Tailins and Water Manaement Facilities (published in 2003); and A Guide to Audit and Assessment of Tailins Facility Manaement (to be published in 2009). This effort reflects reconition by The Minin Association of Canada of the risk posed by tailins facilities, and the importance of ensurin their environmentally responsible manaement. The purpose of the assessment protocol is to provide uidance to the member companies in completin their evaluation of tailins manaement aainst TSM indicators. Completion of this protocol will benefit from expertise both in auditin and systems assessment, and in minin and tailins manaement. While completion of this assessment protocol will indicate a level of implementation of tailins manaement systems in support of the TSM initiative, it will not, of itself, provide a measure of stability or uarantee safety of tailins facilities. Minin Association of Canada Tailins Manaement Assessment Protocol Dec

2 Performance Indicators Five performance indicators have been established. 1. Tailins manaement policy and commitment 2. Tailins manaement system 3. Assined accountability and responsibility for tailins manaement 4. Annual tailins manaement review 5. Operation, maintenance and surveillance (OMS) manual A base assumption is made that all MAC members are in compliance with all leal and reulatory requirements. Five levels of performance are identified for each indicator. Criteria further define performance at each level, as illustrated below. Tailins Manaement Performance Assessment Criteria Level Criteria 1 No systems in place; activities tend to be reactive; procedures may exist but they are not interated into policies and manaement systems 2 Procedures exist but they are not fully consistent or documented; systems/ processes planned and bein developed 3 Systems/processes, in conformance with the tailins manaement framework as presented in MAC s A Guide to the Manaement of Tailins Facilities are developed and implemented 4 Systems/processes have been formally verified throuh internal, independent audit or assessment 5 Excellence and leadership is demonstrated throuh validation by external, independent audit or assessment Specific criteria for each performance indicator are provided in subsequent tables, to enable the assessor to determine an appropriate level of performance (Levels 1-5). The assessor is required to select the level that most clearly represents the status of the operation. Only one level can be selected for each element, and it can be chosen only if all criteria for that level and all precedin levels have been met. Where a performance element or indicator is not relevant, then an Assessment of N/A should be assined. Minin Association of Canada Tailins Manaement Assessment Protocol Dec

3 The oal of each MAC member is to achieve, at a minimum, a consistent 3 rankin on the TSM Tailins Manaement assessment and, havin achieved this, to work towards demonstration of these best practices throuh internal and/or external audit or assessment (levels 4 and 5 ). Facility-level Assessments Respondents are expected to provide facility-level assessments for each specified indicator, as approved by the MAC Board. Facility-level reportin has been found to be the most reliable, informative and useful approach for performance evaluation. The Tailins Manaement Contact and Reportin Form has been desined to facilitate assessment on a facility by facility basis. This will provide consistency with other MAC data collection. Structure of the Assessment Protocols For each indicator, the protocol provides: A statement of purpose that expresses the spirit and intent of the indicator Assessment criteria for each level of performance Supportin uidelines to help the assessor to understand the eneral scope of each indicator and to act as a framework for reviewin documentation and conductin interviews necessary for the assessment of the company s (or facility s) performance Minin Association of Canada Tailins Manaement Assessment Protocol Dec

4 1. TAILINGS MANAGEMENT POLICY AND COMMITMENT Purpose: To confirm that companies have established a policy and commitment that expresses intention, commitments and principles in relation to tailins manaement. Tailins Manaement Policy and Commitment - Assessment Criteria Level Criteria 1 No formal tailins manaement policy and commitment developed. Policy and commitment assumed to be covered by overall site manaement policies, but these do not specifically address tailins manaement. 2 Tailins manaement policy and commitment in place, but not in conformance with MAC s A Guide to the Manaement of Tailins Facilities; or in preparation, to be in conformance with MAC s A Guide to the Manaement of Tailins Facilities. 3 Effective implementation: Policy and commitment in conformance with MAC s A Guide to the Manaement of Tailins Facilities, developed and/or reviewed in consultation with COI, endorsed by senior manaement, and implemented with budet allocation. 4* Internal audit or assessment: Formal internal, independent audit or assessment that the tailins manaement policy and commitment is in conformance with MAC s A Guide to the Manaement of Tailins Facilities. 5* External audit or assessment: Formal external, independent audit or assessment that the tailins manaement policy and commitment is in conformance with MAC s A Guide to the Manaement of Tailins Facilities. * Audit or assessment results remain valid for up to a maximum of three (3) years, providin the company makes a statement, sined by the executive officer accountable for tailins manaement, supported by annual manaement reviews, that the tailins manaement performance indicator implementation has been maintained or improved in the intervenin period. Minin Association of Canada Tailins Manaement Assessment Protocol Dec

5 Tailins Manaement Policy and Commitment Supportin Guidelines Throuh interview and review of documentation, determine: That the company has established and maintains a policy and commitment respectin tailins manaement in conformance with MAC s A Guide to the Manaement of Tailins Facilities. That the policy and commitment accurately reflects the existin commitments and views of senior manaement reardin expected tailins manaement performance. That there has been consultation with COI in developin and/or reviewin the policy and commitment. That the policy and commitment has been implemented, as demonstrated by allocation of budet and resources. Manaers and employees appear to be familiar with the policy and commitment and understand its basic intent. How manaement and employee awareness of the policy and commitment is maintained over time, and the specific means employed. That the policy and commitment establishes an onoin proram of review and continual improvement. What audit or assessment processes are in place to ensure that the policy and commitment is in conformance with MAC s A Guide to the Manaement of Tailins Facilities. Whether an internal or external audit or assessment of the tailins manaement policy and commitment has been carried out within the last three years. Minin Association of Canada Tailins Manaement Assessment Protocol Dec

6 2. TAILINGS MANAGEMENT SYSTEM Purpose: To confirm that companies have a tailins manaement system in conformance with the tailins manaement framework in MAC s A Guide to the Manaement of Tailins Facilities to provide a formal systematic structure for the assessment of risks, settin of oals and objectives, consultation with COI, implementin activities to achieve oals, assinment of responsibilities, and assurance processes to ensure that tailins facilities are manaed effectively. Tailins Manaement System - Assessment Criteria Level Criteria 1 No formal tailins manaement system developed or implemented. 2 Tailins manaement system implemented but not in conformance with the tailins manaement framework in MAC s A Guide to the Manaement of Tailins Facilities; or Gap analysis of existin manaement practices aainst the MAC tailins manaement framework prepared. Development of a tailins manaement system in conformance with the tailins manaement framework in MAC s A Guide to the Manaement of Tailins Facilities underway. 3 Effective implementation: Tailins manaement system, in conformance with the tailins manaement framework in MAC s A Guide to the Manaement of Tailins Facilities, developed and/or reviewed in consultation with COI, and implemented. 4* Internal audit or assessment: Formal internal, independent audit or assessment that the implementation of the tailins manaement system is in conformance with the tailins manaement framework in MAC s A Guide to the Manaement of Tailins Facilities. 5* External audit or assessment: Formal external, independent audit or assessment that the implementation of the tailins manaement system is in conformance with the tailins manaement framework in MAC s A Guide to the Manaement of Tailins Facilities. * Audit or assessment results remain valid for up to a maximum of three (3) years, providin the company makes a statement, sined by the executive officer accountable for tailins manaement, supported by annual manaement reviews, that the tailins manaement performance indicator implementation has been maintained or improved in the intervenin period. Minin Association of Canada Tailins Manaement Assessment Protocol Dec

7 Tailins Manaement System Supportin Guidelines Throuh interview and review of documentation, determine: That a tailins manaement system is in place that is in conformance with the tailins manaement framework in MAC s A Guide to the Manaement of Tailins Facilities. That there has been consultation with COI in the development and/or review of the tailins manaement system. That the tailins manaement system is reviewed annually to ensure it remains current and effective, and if the reviews are reported to senior manaement. What audit or assessment processes are in place to ensure that the tailins manaement system is in conformance with the tailins manaement framework in MAC s A Guide to the Manaement of Tailins Facilities. Whether an internal or external audit or assessment of the tailins manaement system has been carried out within the last three years. Minin Association of Canada Tailins Manaement Assessment Protocol Dec

8 3. ASSIGNED ACCOUNTABILITY AND RESPONSIBILITY FOR TAILINGS MANAGEMENT Purpose: Executive accountability for tailins manaement is necessary to sinal the importance of tailins facilities to our business and the adverse impacts improper tailins manaement practices have on the environment and our reputation. This indicator confirms that companies have an executive officer (CEO or COO) who has overall accountability to ensure that an appropriate manaement structure is in place to provide assurance to the corporation and its COIs that tailins are manaed responsibly. It is expected that the executive officer will deleate responsibility for tailins manaement, budetary issues and other tailinsrelated functions to operations and/or corporate personnel, while retainin ultimate accountability for the manaement of tailins and its outcomes. Assined Accountability and Responsibility for Tailins Manaement - Assessment Criteria Level Criteria 1 No formal assinment of accountability to an executive officer. No formal deleation of responsibility for tailins-related issues and performance. 2 Formal assinment of accountability to an executive officer. No formal deleation of responsibility for tailins-related issues and performance. 3 Effective implementation: Accountability formally assined to an executive officer. Responsibility, budetary authority and accountability for implementation of, and reportin on, the tailins manaement system in conformance with the tailins manaement framework in MAC s A Guide to the Manaement of Tailins Facilities formally deleated to operations and/or corporate personnel. 4* Internal audit or assessment: Formal internal, independent audit or assessment: of the assinment of accountability to an executive officer; and that the responsibility, budet authority and accountability for the tailins manaement system in conformance with the tailins manaement framework in MAC s A Guide to the Manaement of Tailins Facilities * Audit or assessment results remain valid for up to a maximum of three (3) years, providin the company makes a statement, sined by the executive officer accountable for tailins manaement, supported by annual manaement reviews, that the tailins manaement performance indicator implementation has been maintained or improved in the intervenin period. Minin Association of Canada Tailins Manaement Assessment Protocol Dec

9 are formally deleated to operations and/or corporate personnel. Assined Accountability and Responsibility for Tailins Manaement - Assessment Criteria (continued) 5 * External audit or assessment: Formal external, independent audit or assessment: of the assinment of accountability to an executive officer; and that the responsibility, budet authority and accountability for the tailins manaement system in conformance with the tailins manaement framework in MAC s A Guide to the Manaement of Tailins Facilities has been formally deleated to operations and/or corporate personnel. Assined Accountability and Responsibility for Tailins Manaement Supportin Guidelines Throuh interview and review of documentation, determine: That an executive officer has been assined specific accountability for tailins manaement. That the accountable executive officer has formally deleated responsibility for tailins manaement, budetary issues and other tailins-related functions to operations and/or corporate personnel. What audit or assessment processes are in place to ensure that the tailins manaement accountability and responsibilities have been assined in conformance with the tailins manaement framework in MAC s A Guide to the Manaement of Tailins Facilities. Whether an internal or external audit or assessment of the assined accountability and responsibility for tailins manaement has been carried out within the last three years. * Audit or assessment results remain valid for up to a maximum of three (3) years, providin the company makes makes a statement, sined by the executive officer accountable for tailins manaement, supported by annual manaement reviews, that the tailins manaement performance indicator implementation has been maintained or improved in the intervenin period. Minin Association of Canada Tailins Manaement Assessment Protocol Dec

10 4. ANNUAL TAILINGS MANAGEMENT REVIEW Purpose: To confirm there is an annual corporate review of tailins manaement that is reported to the accountable executive officer to ensure that the corporation is satisfied that the tailins manaement structure and systems are effective and continue to meet the needs of the oranization. Annual Tailins Manaement Review Assessment Criteria Level Criteria 1 No formal, annual corporate review of tailins manaement reported to the accountable executive officer. Periodic, informal reviews of the tailins manaement system and performance at the facility level, but not in conformance with the tailins manaement framework in MAC s A Guide to the Manaement of Tailins Facilities. 2 No formal, annual corporate review of tailins manaement reported to the accountable executive officer. Periodic formal reviews of the tailins manaement system and performance at the facility level in conformance with the tailins manaement framework in MAC s A Guide to the Manaement of Tailins Facilities. 3 Effective implementation: formal annual corporate review of tailins manaement reported to the accountable executive officer. The review is in conformance with the tailins manaement framework in MAC s A Guide to the Manaement of Tailins Facilities. 4* Internal audit or assessment: Formal internal, independent audit or assessment: that the annual corporate review of tailins manaement is reported to the accountable executive officer; and that the review is in conformance with the tailins manaement framework in MAC s A Guide to the Manaement of Tailins Facilities. * Audit or assessment results remain valid for up to a maximum of three (3) years, providin the company makes a statement, sined by the executive officer accountable for tailins manaement, supported by annual manaement reviews, that the tailins manaement performance indicator implementation has been maintained or improved in the intervenin period. Minin Association of Canada Tailins Manaement Assessment Protocol Dec

11 Annual Tailins Manaement Review Assessment Criteria (continued) 5* External audit or assessment: Formal external, independent audit or assessment: that the annual corporate review of tailins manaement is reported to the accountable executive officer; and that the review is in conformance with the tailins manaement framework in MAC s A Guide to the Manaement of Tailins Facilities. Annual Tailins Manaement Review Supportin Guidelines Throuh interview and review of documentation, determine: That the company performs an annual corporate review of tailins manaement. That the results of the review are reported to the accountable executive officer. That the process employed for the annual corporate review of tailins manaement addresses requirements of the tailins manaement framework in MAC s A Guide to the Manaement of Tailins Facilities. That the annual corporate review of tailins manaement reported to the accountable executive officer has been subject to internal or external audit or assessment within the last three years. Minin Association of Canada Tailins Manaement Assessment Protocol Dec

12 5. OMS MANUAL Purpose: To confirm that the facility has developed and implemented a tailins OMS manual in conformance with Developin an Operation, Maintenance and Surveillance Manual for Tailins and Water Manaement Facilities. OMS Manual Assessment Criteria Level Criteria 1 No OMS manual developed. 2 OMS manual developed, but not in conformance with MAC s Developin an Operatin, Maintenance and Surveillance Manual for Tailins and Water Manaement Facilities; or OMS manual, in conformance with MAC s Developin an Operatin, Maintenance and Surveillance Manual for Tailins and Water Manaement Facilities, in preparation; and Roles and responsibilities for facility personnel defined and documented. 3 Effective implementation: OMS manual developed and implemented in conformance with MAC s Developin an Operatin, Maintenance and Surveillance Manual for Tailins and Water Manaement Facilities. Emerency preparedness and response plans documented. * 4 Internal audit or assessment: Formal internal, independent audit or assessment that the development and implementation of the OMS manual are in conformance with MAC s Developin an Operatin, Maintenance and Surveillance Manual for Tailins and Water Manaement Facilities. Results of verification are reported to the annual corporate review of tailins manaement. * Emerency preparedness and response plans are interal to OMS manuals and to the safety and security of tailins facilities and surroundin communities. Please consult MAC s Developin an Operation, Maintenance and Surveillance Manual for Tailins and Water Manaement Facilities for more information on the development and testin of emerency preparedness and response plans. Audit or assessment results remain valid for up to a maximum of three (3) years, providin the company makes a statement, sined by the executive officer accountable for tailins manaement, supported by annual manaement reviews, that the tailins manaement performance indicator implementation has been maintained or improved in the intervenin period. Minin Association of Canada Tailins Manaement Assessment Protocol Dec

13 Emerency preparedness and response plans tested. OMS Manual Assessment Criteria (continued) 5 * External audit or assessment: Formal external, independent audit or assessment that the development and implementation of the OMS Manual are in conformance with MAC s Developin an Operatin, Maintenance and Surveillance Manual for Tailins and Water Manaement Facilities. Results of the external verification are reported to the annual corporate review of tailins manaement. OMS Manual Supportin Guidelines Throuh interview and review of documentation, determine: That an OMS manual has been prepared and implemented for tailins facilities. That the OMS manual is in conformance with the MAC uide Developin an Operation, Maintenance and Surveillance Manual for Tailins and Water Manaement Facilities. That the roles and responsibilities of facility personnel are defined. That the facility has audit or assessment processes in place to ensure that the requirements of its OMS manual are bein followed, that action plans are executed to address any deficiencies, and that the OMS manual implementation is reported to the annual corporate review of tailins manaement. Whether an internal or external audit or assessment of the OMS manual s conformance with MAC s Developin an Operatin, Maintenance and Surveillance Manual for Tailins and Water Manaement Facilities has been carried out within the last three years. That emerency preparedness and response plans are prepared, documented, and tested. * Audit or assessment results remain valid for up to a maximum of three (3) years, providin the company makes makes a statement, sined by the executive officer accountable for tailins manaement, supported by annual manaement reviews, that the tailins manaement performance indicator implementation has been maintained or improved in the intervenin period. Minin Association of Canada Tailins Manaement Assessment Protocol Dec

14 Frequently Asked Questions 1. What is a Community of Interest (COI)? COI include individuals and roups who have an interest in, or believe they may be affected by decisions respectin the manaement of operations. They include, but are not restricted to: employees Aboriinal or indienous peoples minin community members suppliers neihbours customers contractors environmental oranizations and other non-overnmental oranizations overnments the financial community, and shareholders. Companies are encouraed to refer to the TSM Assessment Protocol for External Outreach Performance, which includes performance indicators addressin the identification of COI. 2. What does COI consultation mean? Consultation is a process by which a company communicates with COI to understand their viewpoint(s), to inform them of company activities and performance, and to actively enae them in discussion and participation on issues of concern. Consultation on the development of a company s tailins manaement policy and statement of commitments (Indicator 1) and tailins manaement system (Indicator 2) are explicit elements of MAC s A Guide to the Manaement of Tailins Facilities. To meet consultation criteria in Indicators 1 and 2, companies should undertake efforts to consult with relevant COI as stated in the Guide. To achieve the Level 3 commitment on these two indicators, companies should be able to demonstrate that efforts were undertaken to identify and consult with COI at the local and site level, at a minimum. Companies are encouraed to refer to the TSM Assessment Protocol for External Outreach Performance, which includes four performance indicators and uidance addressin: COI identification process COI enaement and dialoue processes COI response mechanisms Reportin performance. Minin Association of Canada Tailins Manaement Assessment Protocol Dec

15 The External Outreach Protocol outlines a process for identifyin and consultin with COI beinnin with those havin local and site interest, extendin up to corporate and more eneral, issues-based interest. To achieve Level 3 for the first indicator, COI Identification Process, companies must demonstrate that they have a formal and documented system in place for identification of COI at the local or site level. 3. Does a tailins policy have to be a stand-alone document? No. MAC s A Guide to the Manaement of Tailins Facilities states (Section 2.1) that the requirement for a specific tailins policy can be met within an overarchin company operations or environmental policy if that policy contains specific reference to tailins manaement, which includes the policies and commitments as outlined [in the Guide]. 4. Can partial levels of performance be reported (e.. 2.5)? Only one level can be selected for each indicator, and it can be chosen only if all criteria for that level and all precedin levels have been met. Where a performance element or indicator is not relevant, then an Assessment of N/A should be assined. 5. How should the assessment be undertaken? It is recommended that the assessment be completed usin a process of interview, discussion and document review, includin representative site manaement, operations and environmental personnel. A level of expertise in auditin and systems assessment and some knowlede of and experience in the technical aspects of minin and tailins manaement is required. 6. How should split responsibilities be addressed? Where an operation is shared between two parties, e.. a joint venture, the two parties are encouraed to discuss amonst themselves who should complete the assessment, whether it should be undertaken jointly or divided so that the results reflect the appropriate activities of each company. 7. What does formal mean? The term formal is used frequently in the assessment, and usually in conjunction with system or process. Formalized systems, processes or activities are usually iven status throuh clear and precise requirements, documented as a written procedure. This means that the business can clearly and easily demonstrate that the process or system is in place. It would also typically require documented processes or an audit trail. 8. What is a system? A system, or manaement system represents processes and procedures that collectively provide a systematic framework for ensurin that tasks are performed correctly, consistently and effectively to achieve a specified outcome and to drive continual improvement in performance. A systems approach to manaement requires an assessment of what needs to be done, plannin to achieve the objective, implementation of the plan and review of performance in meetin the set objective. A manaement system Minin Association of Canada Tailins Manaement Assessment Protocol Dec

16 also considers necessary personnel, resources and documentation requirements. Other definitions associated with systems are: Policy: The formal expression of manaement s commitment to a particular issue area that presents the stance of the company to interested external parties. Practice: Informal, undocumented approaches to carryin out a task. Procedure: A formalized, documented description of how a task is to be carried out. 9. What does effective mean? Where the term effective is used, it requires the element to be fully operational in order that desired outcomes can be achieved. 10. What does audit or assessment mean? Audit or assessment of tailins facility manaement is undertaken to demonstrate conformance with MAC s A Guide to the Manaement of Tailins Facilities, to the standards recommended in MAC s draft A Guide to Audit and Assessment of Tailins Facility Manaement. It is conducted by a team which, althouh perhaps employed by the company, is in a position to be independent, impartial and objective with reard to the evaluated site or facility. This should not be confused with the verification system as described in the TSM Assessment Protocols, which is larely a desk-top exercise in which the TSM ratin self-assined by a facility or company aainst a iven indicator is verified. The TSM verification is not equivalent to an audit or assessment of tailins facility manaement as outlined in the precedin pararaph. MAC s A Guide to Audit and Assessment of Tailins Facility Manaement defines audit and assessment as follows: Audit is the formal, systematic and documented examination of an oranization s or facility s conformance with explicit, areed, prescribed criteria, often requirements stipulated in law or reulation or, in the case of this Guide, the MAC tailins manaement framework. Audits seek to evaluate and report on conformance or non-conformance with stipulated criteria based on the systematic collection and documentation of competent evidence. Audits are not based on opinion, nor are they desined to determine root cause of deficiencies, or to evaluate manaement system effectiveness. Assessment oes beyond measurin aainst stipulated criteria (audit), to incorporate professional judment in an evaluation of the effectiveness, implementation, application and maintenance of a manaement system. Assessment is driven by a concern for quality of system desin and manaement process implementation. It can identify system deficiencies and determine their root cause(s) to provide a basis for process improvement. 11. What does independent mean? Audit or assessment conducted by verifiers who are external to the activity bein audited or assessed and who are free from bias and conflict of interest. External audit or assessment must be conducted by verifiers who are also external to the company bein audited or assessed. Verifiers maintain an objective state of mind throuhout the verification process to ensure that findins and conclusions are based only on the evidence. (Adapted from ISO 19011) Minin Association of Canada Tailins Manaement Assessment Protocol Dec

17 12. What is a facility-level assessment? By facility-level assessments, it is intended that companies will complete an assessment and report on tailins manaement for each distinct operatin unit, or facility, of the company. It is reconized that companies may cateorize their facilities in different ways. 13. What is a tailins facility? MAC s A Guide to the Manaement of Tailins Facilities defines a tailins facility to include the collective structures, components and equipment pertainin to tailins impoundment and manaement, includin dams and reservoirs, other related facilities and appurtenances. 14. How does one assess facility-level performance when some of the indicators apply to company or corporate office responsibilities? The measurement of tailins manaement performance is done at a tailins facility as defined in MAC s A Guide to the Manaement of Tailins Facilities. Reportin is encouraed for each distinct operatin unit of the company, as noted in the response to Question 11. For clarity, if more than one tailins facility falls within the company s distinct operatin unit, results can be consolidated into a TSM facility-level assessment. Policies, prorams and resources are often provided or reinforced at the corporate level that uide or complement facility-level activities. An assessment of facility-level tailins manaement performance will need to take this into account. 15. Can corporate documentation be used to demonstrate commitment? Written senior manaement commitment at the corporate level (e.. a corporate policy) can be accepted as evidence durin a corporate and/or facility-level self-assessment or TSM verification if it is accompanied by evidence that the corporate commitment is bein applied and adhered to. There must be evidence of a link between the corporate documentation and facility-level practices. If this linkae is established, then the corporate documentation can be accepted as evidence of corporate and/or facility-level commitment. 16. Can a facility effectively implement a tailins manaement system without havin a tailins manaement policy in place? No. There is a direct linkae between Indicators 1 and 2 of this protocol. A facility must have a tailins manaement policy in place in order to effectively implement a tailins manaement system, since the policy provides direction and is part of the manaement system. A facility cannot achieve a Level 3 for Indicator 2 (Tailins Manaement System) if it has not achieved a Level 3 or hiher for Indicator 1 (Tailins Manaement Policy). Minin Association of Canada Tailins Manaement Assessment Protocol Dec

18 17. Can a company or facility achieve a Level 5 on satisfactory completion of an external audit or assessment, without havin completed a Level 4 internal audit or assessment? Yes, because the TSM Performance Indicator assessment is a snapshot in time of a company's or facility s status as relates to each specific performance indicator. Assinin a ratin of Level 4 or 5 is based on whether an audit or assessment is internal or external. A company or facility does not need to do an internal audit or assessment (qualifyin for a ratin of Level 4) before receivin a ratin of Level 5 for an external audit or assessment. 18. What if a company or facility receives an audit or assessment that indicates nonconformance with the Assessment Criteria? If the audit or assessment identifies a sinificant non-conformance, a ratin of Level 2 should be assined. Some examples of sinificant non-conformance miht include lack of or inadequate: documentation of key aspects; COI consultation; uidin policy and commitment; assinment of accountability and responsibility for tailins manaement; annual corporate review of tailins manaement. Professional judment must be applied in assessin the sinificance of identified non-conformances. Minin Association of Canada Tailins Manaement Assessment Protocol Dec