SITUATION ANALYSIS OF THE SMALL-SCALE GOLD ... - WWF

nature, mode of occurrence and quantity, can be mined by simple means and techniques
that are economically feasible.” This definition is problematic because nowhere is it
explained what “simple” means in this context.
The retention of the dual classificatory scheme is contrary to the gist of the explanatory
note, which observes that more advanced techniques and heavy equipment are being used
increasingly in the SSM sub-sector. In section 4.3 we already pointed out that by using
the dual classification system the term SSM would not distinguish the different ways of
working and the environmental impact they have.
From an environmental and regulatory perspective we perhaps need to introduce at least
three or perhaps four categories to classify operations in the field, or types of operations
that may be introduced in the future. In section 4.3 we already discussed a scheme with
four categories and suggested some modifications. In this section we will elaborate
further on this scheme. Let us look at the classificatory issues that have to be dealt with in
greater detail. The following categories are reviewed:
V-SSM
SSM
MSM
LSM
The smallest types of operations are gold panning, rock extraction and crushing by hand
(with an iron mortar and pestle), electronic mining (with a metal detector). The
environmental impact of a gold panner, manual miner or electronic miner is usually very
limited. One warning is warranted. Thousands of manual miners could produce a
significant environmental impact, such as at Serra Pelada in Brazil. From a regulatory
perspective, this activity could be described as very SSM, and the amount of ore
processed per year by one person would typically not exceed 250 tons. We could include
partially mechanized SSM, manual ore extraction that uses a 2” or 3” pump to wash the
ore in a sluice box, in this category. The amount of ore processed per person would be
slightly higher, perhaps between 250 and 500 tpy. One partially mechanized operation
has a limited environmental impact, but when a large number of miners are involved, this
activity has the potential to be quite devastating from an environmental perspective. This
has happened in the past and the cumulative environmental impact was extremely high.
We can do two things, classify manual mining as V-SSM and partially mechanized
mining as SSM, or consider both V-SSM. We would suggest that for reasons of
regulatory efficiency these two categories be classified together as very small-scale or
artisanal mining.
In Noetstaller‟s scheme SSM mining was defined as operations processing between
10,000 and 100,000 tpy run-of-mill ore. The problem with this categorization is that we
do not have an appropriate class to accommodate hydraulic mining. It makes no sense to
equate these operations with gold panning. Because the volume of slurry that is processed
is so high, hydraulic mining always has a significant environmental impact. The amount
of slurry and tailings by far exceeds anything that could be produced by partially
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