Legal FrameworkGoverning
Cyanidation Processin Mineral Extraction
in TanzaniaAn Examination of its Nature and
Effectiveness with a Case Study ofMedium Scale Gold Mining in
Nyakagwe Geita District
Gilbert NZAMBA
1
Mineral and Petroleum Law Research SeriesJune 2015
Centre for Mineral and Petroleum Law (CMPL)St. Augustine University of Tanzania
CHAPTER ONE
GENERAL INTRODUCTION
1.0 Introduction
Gold mining is one of the economic activities conducted in different regions of Tanzania
such as Geita, Shinyanga, Mwanza and Tabora. From the early time1 mostly the method
used in Gold extraction was the local method of crushing the mineral ore and gravity
separation of Gold from sand. In 2000s there emerged another modern chemical method
in Gold processing known as cyanidation which involves the use of deadly, toxic and
poisonous chemical substances known as cyanide.2 This has led to the improved
production in Gold mining in Tanzania because low grade ores and ores that cannot be
readily treated through simple physical processes such as crushing and gravity separation
can now be extracted using cyanide.
1.1 Background to the Study
Cyanidation in Tanzania is one of the modern and emerging processes in mineral
processing especially to small scale miners and local medium scale miners. The use of
cyanide has resulted to the effective production of gold especially to medium scale
1From the 1960s during the colonial era and also post independent period.2 The cyanidation process is currently conducted by all small scale miners, medium scale miners and largescale miners in Tanzania.
2
miners and therefore increases the wealth of the miners and the development of mineral
sector in Tanzania. The authorization and licensing of the use of cyanide in Tanzania is
governed by law and therefore cyanide can legally be used in the extraction of Gold in
Tanzania.3
The forms of mining particularly those that use toxic materials such as cyanide are
beginning to get the attention of the public. This is because internationally, many
countries have started to ban the use of cyanide in Gold and Silver Mining.4 In reaction
to cyanide accidents, international communities are beginning to speak out against
cyanide leach mining. Most notably, voters in Montana passed an initiative in
November 1998 banning cyanide heap-leach mining. The initiative, now state law,
prohibits the development of new open-pit cyanide leach mines. This initiative was a
response to the dismal track record of open pit cyanide leach mining in Montana and the
failure of the state to adequately regulate such mines.5
1.2 Statement of the Problem
It is obvious that cyanidation is conducted by medium scale gold miners in Tanzania and
through cyanidation they have improved Gold production and resulted in the
development of mineral sectors in Tanzania. But it is widely known that cyanide is a
major contributor to environmental damage.6 The question is whether there is an adequate
legal framework to regulate the use of cyanide in mineral processing? This is the problem
which this research seeks to address.
3 The Mining Act of 2010, The environmental management Act of 2004.4 Like Czech republic, Greece, turkey, Germany, Hungary Costa Rica Argentina, Ecuador and Montana.5 http://meic.org/issues/mining-in-montana/hardrock-and-cyanide-mining-in-montana/ban-on-cyanide-mining-in-montana-with-initiative-137/ - accessed on 1st June, 2015.6 Land pollution, water pollution and air pollution.
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1.3 Research Objectives
1.3.1 General Objective
To find out if there is an adequate legal framework to deal with the process of cyanidation
in gold production
1.3.2 Specific Objectives
(a) To find out if there is adequate framework for protection of the environment in the
context of mining.
(b) To find out if the current framework on environmental health and safety covers
matters of cyanidation.
(c) To examine the effectiveness of environmental laws in management of cyanide in
gold production.
(d) To pinpoint the authorization and licensing of cyanidation in Tanzania
(e) To examine the environmental effects of cyanidation in mining areas.
1.4 Research Question
i. To what extent the mineral laws regulate cyanidation to medium scale miners?ii. What are the challenges facing the implementation of the laws on cyanidation in
minerals processing?
1.5 Scope of the Study
The study is intended to focus on the laws governing cyanidation processes and
environmental management in mineral processing specifically to medium scale miners in
Nyakagwe Geita. However the outcome of this study may be considered analysis of the
whole country.
1.6 Significance or Justification of the Study
4
The study is planned to reveal the legal challenges pertaining to Cyanidation in mineral
processing and environmental management. The findings significant for the fulfillment of
the requirement for the award of the Bachelor of laws. Other significance is to create
awareness to the medium scale miners on the impacts of cyanide to the environment also
to prove knowledge on the public on the legal framework governing cyanidation
processes.
1.7 Research Methodology
The researcher uses various ways of collecting data as follows;
1.7.1 Research Design
The researcher use qualitative method. Qualitative method has been used to specific
groups of people such as medium scale miners.
1.7.2 Sampling Design
In regard to the need of this research report the researcher has used both purposive and
simple random sampling Pursuant to purposive techniques the researcher had consulted
the medium scale miners who conduct their activities at Nyakagwe Geita.
1.7.3 Data Collection
The data which have been collected are both primary data and secondary data. And the
following methods had aided the data collection.
1.7.3.1 Interview
The researcher used this method to interview the medium scale miners and the officials of
the village government authority at Nyakagwe field area in Geita. Also other personnel
carrying different activities on the field area at Nyakagwe Geita
1.7.3.2 Documentary Review
5
This method have been employed to collect information from various sources generally
documentary in nature from the library such as written reports, books, cases, journals,
publications, articles, online sources and different databases.
1.7.3.3 Questionnaire
A questionnaire was advantageous because it helped to get good information, for if a
respondent get it, will have a time to think of the questions and give good answers which
will be helpful to the research. The researcher has used this method to collect information
and data from the field area at Nyakagwe
1.7.4 Data Analysis
The data obtained by the researcher in the study analyze quantitative analysis on
knowledge about the impacts of cyanide to the environment.
1.8 Literature Review
LA FLÈCHE, Erik Richer (2012), The Mining Law Review, 1st Ed, London, Law
Business Research Ltd. The Author in this work has tied to pinpoint the legal framework
and the overall picture of mining activities in Tanzania and other countries.7 The author
has failed to focus on the legal framework that governs the cyanidation process as the
leading technology in different countries especially in Tanzania today. Therefore this
book is of much importance since it provides a detailed content on the legal framework
governing mining activities in Tanzania.
Louka Elli, (2006) International Environmental Law Fairness, Effectiveness, and World
Order, New York, Cambridge University Press. In this book the Author has exhausted
the international principles governing environmental management. In Tanzania
7LA FLÈCHE, Erik Richer(2012), The Mining Law Review,1st Ed, London, Law Business Research LtdAt p. 220 to p 228.
6
international laws are also applicable8 in management of the environmental issues and
therefore the international principles should be used in the management of cyanide in
gold Processing.
LAITOS, Jan G, (2013) Cyanide, Mining and the Environment, Pace Environmental
Law Review vol. 30, University of Denver Sturm College of Law. Professor Laitos in
his article tries to elaborate on the overall process of cyanidation and the impacts caused
by the said process to the environment. He tries also to explain on the processes
alternative to the use of cyanide in gold processing, and the same may be applied in
Tanzania as well.
8 Under Art. 63 (3) of The Constitution of The United Republic of Tanzania of 1977.
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CHAPTER TWO
CONCEPTUAL AND HISTORICAL REVIEW OF CYANIDATION
2.1 The Meaning of Cyanide?
Cyanide is the deadly, toxic and poisonous chemical which is mostly used in gold
processing.9 In mining industry cyanide is a toxic chemical primarily used for extracting
gold from ores, and therefore sodium cyanide is one of the most toxic chemical reagents
used by the medium scale gold miners for dissolution of gold in mineral processing. The
reason that cyanide is so widely used in gold mining is that it is one of the very few
chemical reagents that will dissolve gold in water, using only oxygen from the air as an
oxidizing agent. Other chemicals such as thiosulfate, thiourea and halide-leaching
systems will work but only in much higher concentrations using much stronger oxidizing
agents.10
2.2 The Processes Before Cyanidation
The main processes that are carried out by medium scale gold miners before cyanidation
are mainly crushing the mineral ore by using crashing machines and gravity separation by
using the pans.11 During gravity separation mercury is used as well to separate gold from
sand. This is done on cyanidation plants to reduce a huge quantity of cyanide to be used
later because it is very expensive.
2.3 Cyanidation Process in Gold Mining
Cyanidation or heap and dump leaching is the term given to the hydrometallurgical
technique of extracting metals by passing a solution through a pile of ore. The9 The sixth schedule of the Act No. 3 of 2006 mention cyanide (NaCN) as a highly toxic chemical.10Karl Heinz spits and John Trudinger, (2008), mining and the environment from ore to metal, Austria,
Taylor and Francis Group.11 The panning method on extraction of gold mainly conducted by small scale gold miners in Tanzania.
8
leachate12 reacts chemically with the ore, dissolving metals out of the host material,
producing a “pregnant" solution. After the solution has passed through the pile, it is
collected and transported to a recovery plant where the valuable metals are removed from
the solution.
The leaching process is now used in Tanzania as an economical method of extracting
valuable minerals from the host ore and has been commonly used to recover gold. Heap
leaching for the recovery of gold was developed as an economic recovery method for low
grade ores especially to the medium scale gold miners at Nyakagwe.
2.3 The History of Cyanidation in Tanzania
Tanzania is one of the great gold producers in Africa today. This has been geared by the
technological advancement in Gold mining industry especially the use of chemicals in
mineral processing. Historical records show that Southern Africa countries such as
Zimbabwe, South Africa, and Tanzania have engaged in mining and smelting for more
than a millennium, trading gold with the Arabic world, India, and elsewhere in . In Africa
cyanidation was greatly conducted in South Africa by the big gold mining companies
from 1980s,13 but cyanidation in Tanzania has risen since the first large scale Gold mines
begun operation in 1990s.14 And it has been the vision of the government of Tanzania that
by the year 2025 the mineral sector will be contributing 10% of the country GDP.
Therefore the medium scale gold miners in Nyakagwe acquired the knowledge and
technology from those big mining companies especially from Bulyanhulu Gold Mines15
and Geita Gold Mines.16
12 Sodium cyanide.13 Most of these companies were the foreign companies from the western countries.14 Anglo Gold Ashanti and Barrick Gold Corporation. 15 Performing its mining activities at Kakola in Geita region.16 Located at Geita
9
2.4 Authorization and Licensing of Cyanidation
There are several requirements that a person is required to undergo so as to perform
cyanidation in Tanzania. Since cyanidation is one of the technologies employed in gold
processing, therefore a person is also required to act within the ambit of Section 59 to
section 63.17Any person interested in mineral processing may apply to the commissioner
for mineral for a license for processing minerals.18 The application must be in a
prescribed form with the prescribed fee, environmental management plan, process plant
layout, procurement haulage and processing inputs plan, compensation and resettlement
plan and such other documents as may be required.19 if the Commissioner is satisfied on
the mentioned criteria shall issue a license with conditions and the license is valid for a
period not exceeding ten (10) years and is subject to renewal.20 Ever since cyanidation
involves the use of chemicals such as sodium cyanide, therefore a certificate from the
ministerial board for the government chemist laboratory agency21 is issued to legalize the
use of cyanide in mineral processing.22 The board may ban or restrict the use of cyanide
chemicals where it proves that handling and use of cyanide is dangerous to the life of
human beings or environment.23
2.5 The Environmental Impacts of Cyanidation
Environmental hazards of cyanide usage and conflicts in relation to mining originate
from different sources, like water contamination, air contamination, soil contamination,
17 Of The Mining Act No 14 Of 201018 S.60 ibid.19 S.60(2) ibid.20 S.60(4) ibid.21S.29 of Act no 3 of 2003.22 S.30 ibid.23 Ibid.
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impacts on the wildlife, human rights violations. The good example can be drawn from
North Mara Gold Mine vicinity which is direct exposed to the environmental pollution
from cyanidation process.24
2.5.1 Water Pollution
Water issues, water quality and the availability of water resources are undoubtedly most
threatened from gold mining operations. The accidental release of material containing
high concentrations of cyanide results in the death and/or contamination of most of the
aquatic life of affected rivers, along with serious health effects on human beings and
animals, and leaves water unsuitable to drink. Even though a majority of mining
operators agree that cyanide degrades and disappears in water and, as an organic
compound, through the effect of sunlight, it also easily combines with living organisms,
and thus accumulates in the environment along with heavy metals such as those coming
from soil leaching after deforestation. For example water pollution claims have been
made to Geita Gold Mine and North Mara Gold Mine at some points discharged wastes
into nearby rivers that are used as source of drinking water by the community25
2.5.2 Air pollution
Airborne emissions occur during each stage of mining. Mining operations mobilize large
amounts of material and small size particles are easily dispersed by the wind. Mines are
responsible for emitting large amounts of dust into their surroundings, and this sector
remains one of the most demanding in terms of energy needs and thus has a high impact
on the global environment. Example, a gold mining industry pollutants are produced by
24 Manfred FB et el ,(2009), A level of heavy metals and cyanide in Soil sediments and water from thevicinity of North Mara Gold Mine in Tarime District, Tanzania, A report presented to CCT, at p. 2.25 ibid at p. 3.
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heavy metals from waste rock piles, cyanide and other gaseous materials such as Sulphur
Dioxide, Carbon monoxide and Carbon Dioxide.26
2.5.3 Soil pollution
Soils are contaminated by heavy metals and by substances containing cyanide or
mercury, either directly on the mining facility site, or via contaminated waters and air
pollution coming from the mined ground. Soil erosion caused by soil washing processes,
and aggravated by deforestation, can result in the release of noxious substances from the
earth, which in turn contaminate downstream rivers and lakes. For example, in 2008 it
was reported that there was a higher level of heavy metals in the soil and plants collected
in Nyakabale village in the vicinity of Geita Gold Mines.27
2.5.4 Flora and Fauna
Wildlife is affected by mining through the removal of the vegetation and topsoil, by the
displacement of fauna, by the release of pollutant sand by the generation of noise. And
finally, gold mines often cause human rights violations, for example by forcing evictions
and destroying the land and water that affected communities highly depend on. For
example in June 2009, The Daily News (local magazine) reported that the GGM
Authority admitted over the pollutant leak from tailing ponds into rivers, farms and
pasture land.28
26 Manfred FB et el ,(2009), A level of heavy metals and cyanide in Soil sediments and water from thevicinity of North Mara Gold Mine in Tarime District, Tanzania, A report presented to CCT, at p. 527 ibid at p. 3.28 Manfred FB et el ,(2009), A level of heavy metals and cyanide in Soil sediments and water from thevicinity of North Mara Gold Mine in Tarime District, Tanzania, A report presented to CCT, at p. 15.
12
Another incidence was reported in June 2009 by Tanzania Daima (local magazine) where
five people got sick after eating fish from Tighite river caused by the pollution at Mara
River Conservation.29
2.6 The Laws Regulating Cyanidation
The environmental laws on cyanidation are both principal legislation and Regulations.
2.6.1 The Environmental Management Act of 2004
The environmental management Act, 200430 is the law which provide for legal and
institutional framework for sustainable management of environment, to outline principles
for management, impact and risk assessments, prevention and control of pollution, waste
management, environmental quality standards, public participation, compliance and
enforcement. Though the provisions of the said law do not provide any thing specifically
on cyanidation in Gold mining, in one way or another, the said law governs
environmental management on cyanidation process in gold processing in Tanzania.31
The National Environment Management Council (NEMC) came into being in 1983,
NEMC was established with a broad mandate in response to the national need for such an
institution to oversee environmental management issues and also implement the
resolutions of the Stockholm conference (1972), which called upon all nations to
establish and strengthen national environmental Councils to advise governments and the
international community on environmental issues.
The environmental management Act, 2004 provide for the right to clean, safe and healthy
environment, but also place the duty to protect the environment32 and also the right to
29 ibid.30 Act No 20 of 2004.31ibid.32 S.6 Act No 20 of 2004.
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bring an action on environment.33 The said law also provide for an environmental impacts
assessment.34 By performing regular environmental impacts assessment pollution caused
by cyanidation in Gold processing will be highly reduced since the law provide for
general prohibition of pollution.35 The law under Part IX provides for management of
waste in general and it also provide for general penalty and sanctions for any person who
commits an offence against any provisions of this law.36 Therefore cyanidation impliedly
is mostly connected to the environment and hence this law will be dully applicable in
management of cyanide in gold processing.
2.6.2 The Environmental Impact Assessment and Audit Regulations, 2005.
The Environmental Impact Assessment and Audit Regulations, 200537 this regulation
provides for a compulsory environmental Impacts assessment to project likely to have
significant adverse environmental impacts and that in-depth study is required to
determine the scale, extent and significance of the impacts and to identify appropriate
mitigation measures. Mining is mentioned also as the project which require
environmental Impacts Assessment and hence cyanidation also should be treated within
the ambit of this regulation.38
2.6.3 Environmental Management (Water Quality Standards) Regulations, 2007.
33 S.5 ibid.34 Part VI ibid.35 S.106 ibid.36 S.191 ibid.37 G.N. No. 349 of 200538 Under item 16(iv) of the first schedule to The Environmental Impact Assessment and Audit
Regulations, 2005.
14
Environmental Management (Water Quality Standards) Regulations, 200739 the
regulation mentions cyanide as one of the toxic pollutant of water and also mention
cyanide as one of six chemicals and physical limits for quality of drinking water
supplies.40 Therefore cyanidation process should be conducted without polluting the
water as per this regulation since the process in mineral processing involves the use of
water.
2.6.4 The Environmental Management (Hazardous Waste Control and
Management) Regulations, 2009
The Environmental Management (Hazardous Waste Control and Management)
Regulations, 200941 this regulation explains on the categories of wastes controlled under
these regulations.42 The regulation mention both inorganic cyanide and organic cyanide as
one of the stream waste having constituents as wastes which may contain either inorganic
or organic constituents.43 This law adopted the principles of the Basel Convention on
the Control of Trans boundary Movements of Hazardous Wastes and Their
Disposal.44
2.6.5 The Environmental Management (Soil Quality Standards) Regulations, 2007.
The Environmental Management (Soil Quality Standards) Regulations, 200745 the
regulation provide that it is the duty of The National Environmental Standards
Committee of Tanzania Bureau of Standards to prescribe guidelines to ensure that
39 GN No. 239 published on 2007.40Sixth schedule of Environmental Management (Water Quality Standards) Regulations, 2007.41 GN No. 264 published on 2009.42Adapted from the Basel and Bamako conventions43 Second schedule of The Environmental Management (Hazardous Waste Control and Management)Regulations, 2008.44 Concluded in 1989, and came into force 1992 to which the United Republic is a party.45 GN No. 238 published on 2007.
15
anthropogenic activities such as mining, agricultural activities, as well as solid and
liquid waste disposal do not degrade the soils in setting minimum soil standard.46 The
regulation also provides for proper management of soil and discourages the degradation
of soils resulting from dumping, or disposal of chemicals into soil the common practice
performed in cyanidation.
2.7 The Mineral Laws on Cyanidation
2.7.1 The mining Act of 2010
This is the law governing all the mining activities in Tanzania including Gold mining to
medium scale miners in Tanzania. The law provides for mineral licenses such as Division
A – prospecting licenses and retention licenses, Division B – special mining licenses and
mining licenses, Division C – primary mining licenses and Division D – processing,
smelting and refining licenses. Ever since cyanidation is one of the technology employed
in mineral, it is regulated by this law even though there is no an express provision
concerning cyanidation in Gold processing to medium scale miners.
2.7.2 Regulations to the mining Act of 2010
Six Mining Regulations have been established under the Mining Act of 2010 to regulate
mining activities in the country these are:
The Mining (Environmental Protection for Small Scale Mining)Regulations, 2010
The Mining (Mineral Beneficiation) Regulations, 2010
The Mining (Mineral Rights) Regulations, 2010
The Mining (Mineral Trading) Regulations, 2010
46Regulation 4 (e) of the Environmental Management (Soil Quality Standards) Regulations, 2007.
16
The Mining (Radioactive Minerals) Regulations, 2010
The Mining (Safety Occupational Health and Environmental Protection)
Regulations, 2010
In all those regulations there is no any provision providing for cyanidation in Gold
Processing especially to medium scale gold miners in Tanzania but those regulations
impliedly are made applicable to cyanidation in Gold Processing.
2.7.3 The Tanzania Mineral Policy of 2009
This policy was formulated as a result of an evaluation conducted during the 10 years of
implementation of the Mineral Policy of 1997. The Mineral Policy of 2009 aims at
integration of the mineral sector with other sectors of the economy, improving the
economic environment for investment, maximizing benefits from mining, improving the
legal environment, strengthening the capacity for administration of the mineral sector,
developing small-scale mining operations, promoting and facilitating the addition of
value to minerals; and strengthening environmental management health and safety
measures. The government remains the regulator and facilitator of the mineral sector, and
will participate strategically in mining projects.47from the first provision of the policy to
the final provision there is no any provision on cyanidation in Gold processing but the
policy only provide for the environmental management, health and safety during the
mining activity.
2.8 The International Environmental Laws on Cyanidation.
47 LA FLÈCHE, Erik Richer (2012), The Mining Law Review, 1st Ed, London, Law Business ResearchLtd at p.220.
17
There are several international Principles on environment which impliedly use to control
the management of cyanide in Tanzania. These Principles have been adopted from the
international convention by which Tanzania is a member state.48
2.8.1 Polluter Pays Principle and Equitable Sharing of Cost
The polluter pays principle was enunciated clearly in the international arena. The
principle basically demands for the person who is in charge of polluting activities to be
financially responsible for the damage s/he causes. Some commentators have underlined
that the principle has merely a rhetoric value because most polluters will be able to pass
the costs of pollution onto consumers. Also, in most cases, it is difficult to identify the
polluter. Since these international laws forms part of our lows then the said principle is
applicable in cyanidation process gold in Tanzania.49
2.8.2 International Code of Cyanide
The Cyanide Code is a voluntary initiative for the gold mining industry and the producers
and transporters of the cyanide used in gold mining. It is intended to complement an
operation’s existing regulatory requirements. Compliance with the rules, regulations and
laws of the applicable political jurisdiction is necessary. The Cyanide Code focuses
exclusively on the safe management of cyanide that is produced, transported and used for
the recovery of gold, and on mill tailings and leach solutions. The Cyanide Code
originally was developed for gold mining operations, and addresses production, transport,
storage, and use of cyanide and the decommissioning of cyanide facilities. It also
includes requirements related to financial assurance, accident prevention, emergency
response, training, public reporting, stakeholder involvement and verification procedures.
48Supra note 27.49 S.7 of the Environmental management Act of 2004.
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Cyanide producers and transporters are subject to the applicable portions of the Cyanide
Code identified in their respective Verification Protocols.50 Therefore all the companies
performing cyanidation in Tanzania are to be within the ambit of the international cyanide
code because it protects workers, communities and the environment from adverse effects
of cyanide, to improve cyanide management, to be used by large and small gold mining
companies, cyanide manufacturers and transporters, to serve as a form of assurance for
interested parties including regulators, financiers, communities and non-governmental
organizations, to be applied internationally, in both developed and developing countries.51
2.9 The Involvement of Governmental Departments on Management of Cyanide
The government is the first organ of the state that is responsible in management of
cyanide. In Tanzania there are several governmental departments which are responsible in
management of cyanide in cyanidation of gold to medium scale miners. These
departments are such as the local government, the Tanzania mineral audit Agency
(TMAA) and the national environmental management council.
2.9.1 The Local Government Authorities
The local government authorities are established by the law.52 This law provides for the
establishment of the standing committees to manage the environment.53There several
authorities under the local authorities responsible in management of cyanide such as the
municipal council, district council, ward council and the village council.54 For example it
is the duty of the local government authority to deal with proper management of
50 http://www.cyanidecode.org/about-cyanide-code/cyanide-code#sthash.NDTMEcek.dpu f- accessed on12th of November, 2014.
51 MIKE D. Adams (2005) Developments in Mineral Processing, Vol. 15 Published by Elsevier B.V. at pg185.
52 The local government (districts authorities) Act No.2 of 1982.53 S.107 ibid.54 S.36 of Environmental Management Act of 2004.
19
hazardous waste55 therefore it is the duty of local government authority to deal with any
waste with cyanide waste inclusively within its jurisdictions.
2.9.2 The Tanzania Mineral Audit Agency (TMAA)
The TMAA is an agency of the government established on 6th November, 200956 the
Government established the Tanzania Minerals Audit Agency (TMAA), which is a semi-
autonomous Institution TMAA took over the functions previously undertaken by the
Minerals Auditing Section (commonly called GAP) in the Minerals Department under the
Ministry of Energy and Minerals. In relation to cyanidation the agency has several role
and functions as follows;
To monitor and audit quality and quantity of minerals produced and exported by
large, medium and small scale miners; to determine revenue generated to facilitate
collection of payable royalty.
To monitor and audit environmental management, environmental budget and
expenditure for progressive rehabilitation and mine closure.
To examine and monitor implementation of feasibility reports; mining programs
and plans, annual mining performance reports; and environmental management
plans and reports of mining companies.
2.9.3 The National Environment Management Council (NEMC)
The enactment of Environmental Management Act No. 20 of 2004 (EMA, 2004) by
Parliament in October 2004, repealed the National Environmental Management Act57 and
re-established NEMC. EMA 2004 provides for a legal and institutional framework for
sustainable management of the environment, prevention and control pollution, waste
management, environmental quality standards, public participation, environmental
55 S.134 ibid.56 Established through Government Notice No. 362 under the Executive Agencies Act, Cap. 245.57Act No.19 of 1983.
20
compliance and enforcement. Furthermore, it gives NEMC mandates to undertake
enforcement, compliance, review and monitoring of environmental impacts assessments,
research, facilitate public participation in environmental decision-making, raise
environmental awareness and collect and disseminate environmental information.
Therefore cyanidation processes in gold processing is also regulated by this agency.
2.9.4 Ministerial Advisory Board for the Government Chemist Laboratory Agency
This board is established under the Executive Agencies Act.58 So far the cyanidation in
gold processing involves the use of highly toxic chemicals such as sodium cyanide the
board is responsible to control transportation, storage and dealing in chemicals according
to the provisions of the Industrial and Consumer Chemicals (Management and Control)
Act, 2003. The board is responsible as well to issues certificates to deal with
chemicals.59Therefore this board is responsible in management of cyanide to medium
scale gold miners at Nyakagwe. No any medium scale gold miners can commence the
cyanidation processes without exhausting all the requirements and processes to deal with
chemicals as provided by the Industrial and Consumer Chemicals (Management and
Control) Act, 2003 and its regulations.60
CHAPTER THREE
FINDINGS AND ANALYSIS OF THE REGULATION OF THE USE OF
CYANIDATION
58 S.6 of the Executive Agencies Act Cap 245 RE 2002. 59 S.29 of The Industrial and Consumer Chemicals (Management And Control) Act, 2003.60 The Industrial and Consumer Chemicals (Management And Control) Regulations, GN NO.344 of 2004.
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3.1. Introduction
This chapter analyses the use of cyanidation in the mineral processing by the medium
scale miners in Nyakagwe area within Geita Region. The research gives out the finding
relating to the legal regime governing cyanidation in mineral processing.
3.2 The Involvement of the Local Authorities in Management of Cyanide.
The Local Government (District Authority) Act61 establishes the local authorities from the
village/Mtaa to town and municipal. The village authority is empowered with the
management of the environment within their local limits.62
In most cases mining activities are carried out in rural areas and in villages where local
communities live. Cyanide is used in mineral processing and being a harmful chemical
to the environment it requires attention to both medium scale miners and local
authorities to control and manage the environmental damages which are likely to be
caused by it use.
In Nyakagwe village where medium scale miners in gold processing operates, is the
victim of the use of cyanide, where the respondent, Mr. Kazungu the Chairman of the
village government averred that he is not aware of the involvement of the village council
in the management of Cyanide,63 he said that, to them what they provide in to locate to
the medium scale miners the area for buildings the cyanidation plant which must be at
least 1 km away from the residents; area64. That the license to operate cyanidation plants
and its environmental impact assessment are not done by the village authority and the not
61 Act No.7 of 1982.62 S. 40 of the Environmental Management Act.63 S. 41 Ibid, Gives power to the Environmental Management Committee such as to initiate inquires andinvestigation on any violation of the provision of the Environmental Management Act.64 See appendix III which show that the processing plant is within the residential area something which isvery dangerous to the health of the community.
22
involved either. The researcher consulted the villagers who also responded that they
understand that the cyanide use by the medium scale miners are harmful to the
environment but they have no control of how the cyanide should be used in a way that it
cannot cause damage to the environment.65
3.3 Pollution
On land pollution, the research found that, the mineral processing leave huge heap of soil
that contains cyanide chemicals in it, which have been in tailings after gold have been
recovered from the pregnant soil commonly known as Makapi.66 Since the entire process
involve the mixing up of soil with cyanide chemical, then “Makapi” which contains
some substance of cyanide, are dumped anywhere without treatment or recycling
procedures.67 When it rains the water soak into that heap of soil and start flowing down
steam to pond, rivers and streams of water which are used by local in habitants for
domestic purpose.68
3.4 Environmental Protection
The researcher found that there were no environmental protection plan by the local
authorities because they have no awareness and environmental education as far as
management of cyanide is concerned. The whole process of cyanidation in Nyakagwe is
done in the poor condition and there is no plan by the medium scale minors to protect the
environment the tailings are not covered, no proper waste disposal infrastructure, and
above all, there is no treatment of soil offloaded from tailings.69
65 S. 176 of the Environmental Management Act.66 See appendix IV which show the heap of soil from tailings 67 S. 11 (4) (f) the Industrial and consumer chemicals (management and control) Act of 200368 See Appendix V which shows the erosion on the heap of soil which contain cyanide chemical 69 S. 196 (1) of the Environmental Management Act Provides for the Protection Order against activitiesadverse on the Environment.
23
3.5 The Management of Cyanide by the Medium Scale Miners
The miners must obtain the certificate to deal with cyanide from the board which is
responsible for grant a renewal suspension and revocation of licenses under the law.70
Therefore nobody should process the minerals without processing that certificate.
However the researcher find that most of the medium scale miners process and deal with
cyanide without processing the certificate from the board the practice is most of them use
the certificate owned by other registered medium scale sold miners, as if they are one
company while in real sense they are separate companies.
Cyanide are chemicals that are imported from outside Tanzania, by authorized
transporters, transported and stored by the authorized companies in the ambit of the
cyanide code.71 The medium scale miners are required to purchase cyanide from those
authorized companies, and those companies are obliged to transport the chemicals to the
processing plant under their control. But the practice is deferent, as the researcher found
that, most of the medium scale miners transport cyanide using their own vehicles
especially from Mwanza city to Nyakagwe in Geita Region without any indicator or
precaution that cyanide is being transported.
The handling of cyanide needs extra care, as it is poisonous, deadly and high toxic
chemical. The medium scale miners in Nyakagwe, however store cyanide in unsecured
rooms,72 the handling of the chemical during use is done by unqualified personnel who
70 S.29 the Industrial and consumer chemicals (management and control) Act of 2003.71 Adams D. (2005) Development in Mineral Processing, VOl.15.p 182-198.72 See appendix VII which shows a laboratory in which chemicals are stored and prepared in one of theprocessing site at Nyakagwe.
24
have no laboratory qualification.73 These create the likelihood of this deadly chemical to
cause effects to human life and environment in general.
3.6 The Effectiveness of the Existing Laws on Cyanidation in Nyakagwe
The laws governing cyanidation are the mineral laws and the environmental laws
The laws are not effective as they do not provide for cyanidation. The mining Act 2010
only provide for the licensing of processing plants, while the environmental laws provide
for maximum protection of the environment of which does not reflect the real situation in
the processing plants in Nyakagwe where there is no public participation in
environmental decision, making no enforcement of laws on environment and no review
and monitoring of environmental impact assessment, worse enough there is no
environmental awareness.
CHAPTER FOUR
CONCLUSION AND RECOMMENDATIONS
4.1 General Observation
73 See appendix VI which shows unqualified personnel mixing up chemicals read for cyanidation.
25
The mineral processing done by medium scale gold miners at Nyakagwe is very risky and
it is conducted in the manner that the environment is highly polluted; the personal or
employers working in the processing areas are not provided with environmental
education. Not only that environmental monitoring by the NEMC and the ministerial
advisory board for the government chemist laboratory agency74 is very is very poor to the
extent that the environments are lost to be damaged. But also the involvement of the local
government standing committees on environment75 as provided by the Local Government
(District Authority )Act76 on the management of cyanide is not that much effective to
protect the environment at Nyakagwe.
4.2 Conclusion
Cyanidation to mediums scale gold miners is not well governed because there is no
consolidated legal framework governing cyanidation in mineral processing in Tanzania.
So many scattered laws and government departments and agencies are involved in
monitoring cyanidation, a practice which limits the effective monitoring and management
of cyanidation in mineral processing. Cyanidation today is the leading technology in gold
production to both medium scale and large scale gold mineral in Tanzania. If cyanidation
to medium scales gold miners shall be left uncontrolled as observed in this study it may
result to serious environmental pollution
4.3 Recommendations
Several recommendations have been put forward by the researcher as follows:-
4.3.1 Enactment of Independent Laws Governing Cyanidation in Tanzania
74 Constituted under section 6 of the Executive Agencies Act Cap 245.75 S.38 of the Environmental Management Act.76 S.107 of Act No .7 of 1982.
26
So far the mineral laws provide for the licenses in mineral processing, but do not contain
any provision dealing with monitoring of the cyanidation plants.77
The task of monitoring on matters of environmental impact assessment is left to the
national environmental management council (NEMC) using the environmental laws.78 the
task to provide for the certificate to deal with toxic chemicals, such as cyanide is left to
the Board,79 this brings about confusion on how to deal and govern cyanidation in mineral
processing, therefore a consolidated law should be enacted to put together all the
procedures, licenses, authorization, environmental protection and management in general
from those scattered laws governing cyanidation. A good example can be drawn from
South Africa where they have a single instrument used to regulated and manage cyanide
in mineral processing.80 This instrument focuses exclusively on the management of
cyanide and cyanidation mill tailings and leach solutions.
4.3.2 The Recycling of Cyanide Wastes and Treatment of Toxic
So far the wastes which pollute the environment are the heap of soil, from tailings which
contains some content of cyanide. Before issuing of a certificate to deal with chemicals, it
is a legal requirement for the Board to consider whether adequate measures have been
taken to prevent or minimized harm to human beings including adequate waste treatment
facilities.81 Therefore, the government in general should ensure that, the wastes are
effectively treated or recycled by CIP.82
4.3.3 Alternative to the Use of Cyanide in Gold Processing
77 The Mining Act of 2010 and its Regulations. 78 Environmental Management Act and its Regulation.79 Supra Note 56.80 Guideline for the Compilation of a Mandatory Code of Practice on Cyanide Management.81 S. 17(e)of Industrial and Consumers Chemical s (Management and Control)Act, 2003.82 Carbon –in-pulp(a technology to recover gold from wastes from cyanidation.(‘Makapi’).
27
The major impetus in seeking alternative reagent to cyanide arises from the
environmental hazard posed by cyanide toxicity, with numerous environmental groups
throughout the world actively pursuing a ban on its use. The use of cyanide in Gold
processing to medium scale gold miners are especially in the focus of public attention
because of serious environmental pollution. Internationally several countries such as
(Czech republic, Greece, Turkey, Germany, Hungary Costa Rica Argentina, Ecuador and
some states of the united states of America such as Montana83 have banned cyanide reach
technology in Gold and silver mining. Therefore, for maximum protection of the
environmental cyanide should be discouraged in mineral processing to medium scale
gold miners and any other technology which is very friendly to the environment should
be embarked upon.
BIBLIOGRAPHY
BOOKS
BILL Sullivan, (2013), Mining Law & Regulatory Practice in Indonesia; A Primary
Reference Source, John Wiley & Sons Singapore Pte. Ltd.
83 www.heraldonline.com/news/local/article12310709.html accessed on 17/05/2015.
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DAVID Dzombak. A, (et al) (2006) Cyanide in Water and Soil; Chemistry, Risk and
Management, CRC Press, Taylor & Francis Group.
ELLI Louka, (2006), International Environmental Law Fairness, Effectiveness, and
World Order, Cambridge university press.
FABIO Tronchetti, (2009), The Exploitation of Natural Resources of the Moon and
Other Celestial Bodies; A Proposal for a Legal Regime, USA, Martinus NIJHOFF
Publishers,
FRED Bell D. and LAURANCE Donnelly. J, (2006), Mining and its Impact on the
Environment, Taylor & Francis, 2 Park Square, Milton Park, Abingdon, Oxon OX14
4RN
JERROLD Marcus. J, (1997), Mining Environmental Handbook; Effects of Mining on
the Environment and American Environmental Controls on Mining, Landon, Imperial
College Press.
JOHN Olin. M, (2011), Mining and The Environment; International Perspectives on
Public Policy, New York, Rout ledge Taylor & Francis Group.
KAREN Makuch.E (2012), Environmental and Energy Law, UK, Blackwell Publishing
Ltd.
KARL Heinz spits and JOHN Trudinger, (2008), Mining and the Environment from Ore
to Metal, Austria,
KARLHEINZ Spitz and JOHN Trudinger, (2008) Mining and the Environment from
Ore To Metal, Taylor & Francis Group, LLC.
LA FLÈCHE, Erik Richer (2012), The Mining Law Review,1st Ed, London, Law
Business Research Ltd
29
LAURA Westra, (2006), Environmental Justice and the Rights of Unborn and Future
Generations; Law, Environmental Harm and the Right to Health, in the UK and USA.,
Earthscan,
Louka Elli, (2006), International Environmental Law Fairness, Effectiveness, and
World Order, New York, Cambridge University Press.
MARK Logsdon. J, KAREN Hagelstein and TERRY Mudder.I, (1999) The
Management of Cyanide in Gold Extraction, CANADA, International Council on
Metals and the Environment (ICME),.
MOHAMMED Bekhechi. A and JEAN-Roger M, (2002), The Legal and Regulatory
Framework for Environmental Impact Assessments: A Study of Selected Countries in
Sub-Saharan Africa, Washington, D.C. The World Bank.
NICO Schrijver, (2008), Sovereignty Over Natural Resources; Balancing rights and
duties, New York, USA CAMBRIDGEUNIVERSITYPRESS.
RECHARD Barnes, (2009), Property Rights and Natural Resources, Hart Publishing,
Northern America.
JOURNALS
LAITOS, Jan G, (2013), ‘Cyanide, Mining and the Environment’, Pace Environmental
Law Review vol. 30, University of Denver Sturm College of Law.
MIKE D. Adams (2005), Developments in Mineral Processing, Vol. 15 Published by
Elsevier B.V.
30
MUDDER.T.I and BOTZ. M.M., ‘Cyanide and society: a critical review’, The
European Journal of Mineral Processing and Environmental Protection Vol. 4, No.
1, 1303-0868, 2004.
REPORT
Manfred FB et el, (2009), A level of heavy metals and cyanide in Soil sediments and
water from the vicinity of North Mara Gold Mine in Tarime District, Tanzania, A report
presented to CCT.
INTERNET SOURCE
http://meic.org/issues/mining-in-montana/hardrock-and-cyanide-mining-in-montana/ban-on-cyanide-mining-in-montana-with-initiative-137/ - accessed on 1st
June, 2015http://www.cyanidecode.org/about-cyanide-code/cyanide-
code#sthash.NDTMEcek.dpu f- accessed on 12th of November, 2014www.heraldonline.com/news/local/article12310709.html accessed on 17/05/2015
APPENDIX I
QUESTIONAIRE TO THE OWNERS OF THE MINING SITE
31
(DODOSO KWA WAMILIKI WA MGODI)
DATE …./03/2015
PLEASE RESPOND TO THE FOLLOWING QUESTIONS ACCORDING TO THE
INSTRUCTIONS GIVEN. (TAFADHARI JIBU MASWALI YAFUATAYO KWA
KUFUATA MAELEKEZO ULIYO PEWA.)
I. CHOSE THE BEST ANSWER BY TICKING THE CORRECT ANSWER.
(CHAGUA JIBU SAHIHI KWA KUWEKA ALAMA YA VEMA KWENYE
JIBU LILILO SAHIHI )
1.Do you know a chemical known as cyanide? (je? Unaifahamu kemikali iitwayo
sayanaidi?)
(A)YES..(ndiyo) ( )
(B) NO..(hapana) ( )
2.How often do you use cyanide in your daily activities in a mining site? (ni mara
ngapi huwa unitumia sayanaidi katika shughuli zako za kila siku hapa mgodini?)
(A)Very often ( mara nyingi zaidi) ( )
(B) Occasionally (mara chache) ( )
(C) I do not use cyanide (situmii sayanaidi) ( )
3.How often do you see the leakage of pipelines which contains cyanide solutions? (ni
mara ngapi umeona mabomba yenye mchanganyo wa sayanaidi yakivuja?)
(A)Very often ( mara nyingi zaidi) ( )
(B) Occasionally (mara chache) ( )
(C) I have never seen that (sijawahi ona kitu hicho) ( )
32
IF THE ANSWER IN QUESTION 3 IS (A) OR (B) RESPOND TO QUESTION 4, IF
YOUR ANSWER IS C DO NOT ANSWER QUESTION 4. KAMA JIBU NI (A) AMA
(B) KATIKA SWALI LA TATU BASI JIBU SWALI LA NNE, KAMA JIBU LAKO
NI (C) USIJIBU SWALI LA NNE.
4. How long does it take to fix those leakage on pipelines which contains cyanide
solution? (inachukua muda gani kutengeneza mabomba yanayo vuja yenye
mchanganyo wa sayanaidi?)
(A)More than a month(zaidi ya mwezi mmoja) ( )
(B) Within two weeks (ndani ya wiki mbili) ( )
(C) Within one week (ndani ya wiki moja) ( )
(D)As soon as the leakage is seen (mara tu nyufa inapoonekana) ( )
5. How often do you get educated on environmental protection either by seminar or any
other means? ( ni mara ngapi mmekuwa mkielimishwa kuhusu utunzaji wa
mazingira kwa semina au njia yeyote ile?)
(A)Very often ( mara nyingi zaidi) ( )
(B) Occasionally (mara chache) ( )
(C) I have never seen that (sijawahi ona kitu hicho) ( )
6.How often do you educate your employees on environmental protection either by
seminar or any other means. ( ni mara ngapi mmekuwa mkiwaelimisha wafanyakazi
wenu kuhusu utunzaji wa mazingira kwa semina au njia yeyote ile?)
(A)Very often ( mara nyingi zaidi) ( )
(B) Occasionally (mara chache) ( )
(C) we never do that (hatuwaelimishi) ( )
33
7. Has any worker or stranger being affected or died due to cyanide in your working
place? (kuna mfanyakazi yeyote au mtu mwingine aliyewahi kuathirika au kufariki
kwasababu ya kemikali ya sayanaidi katika eneo lako la kazi)
(A)It always happen(huwa inatokea mara kwa mara) ( )
(B) It ocassionally happen (huwa inatokea mara chache) ( )
(C) I have never seen that (sijawahi ona kitu hicho) ( )
8.How often is the environmental impact assesment team visit and inspect your working
places? (Ni mara ngapi timu ya wakaguzi wa mazingira hutembelea na kukagua eneo
lako la kazi?)
(A)Very often ( mara nyingi zaidi) ( )
(B) Occasionally (mara chache) ( )
(C) I have never seen that (sijawahi ona kitu hicho) ( )
II. FILL IN THE BLANKS BY WRITING RELEVANT ANSWERS.(JAZA
NAFASI ZILIZO ACHWA WAZI KWA KUJAZA MAJIBU SAHIHI)
9.Which category of personnel do you employ in your laboratories to prepare cyanide in
gold processing? (ni wataalam wa aina gani mnao waajiri katika maabara zenu ili
kuandaa kemikali ya sayanaidi katika shughuli zenu za uzalishaji wa dhahau?).
……………………………………………………………………………………………
……………………………………………………………………………………………
……………………………………………………………………………………………
……………………………………………………………………………………………
……………………………………………………………………………………………
34
10. How do the local authorities in coordination with small and medium scale miners
participate in proper management of cyanide at your mining sites? (Mamlaka za
serikali za mitaa zinashirikiana vipi na ninyi wachimbaji wadogo na wa kati
katika kuhakikisha kuna udhibiti sahihi wa matumizi ya sayanaidi katika migodi
yenu?).
……………………………………………………………………………………………
……………………………………………………………………………………………
……………………………………………………………………………………………
……………………………………………………………………………………………
11. What are the necessary licences that you need to have so as to carryout cyanidation
process in your area. (Ni vibali gani muhimu vinavyo hitajika ili kupata ridhaa ya
matumizi ya sayanaidi katika uandaaji wa dhahabu??)
i. ……………………………………………………………………………………
ii. ……………………………………………………………………………………
iii. ………………………………………………………………………………………
…………………………………………………………………………………
iv. ……………………………………………………………………………………
v. ……………………………………………………………………………………
vi. ……………………………………………………………………………………
vii. ……………………………………………………………………………………
viii. ……………………………………………………………………………………
ix. ……………………………………………………………………………………
35
12. Are there any consequences on failure to have the above licences? (kuna madhara
yeyote endapo mtu atashindwa kupata vibali hivyo?).
……………………………………………………………………………………………
……………………………………………………………………………………………
……………………………………………………………………………………………
……………………………………………………………………………………………
……………………………………………………………………………………………
……………………………………………………………………………………………
13. What measures do you take to protect the environment at your working place? (ni
hatua gani mnazichukua ili kutunza mazingira katika lako la kazi? ).
.............................................................................................................................................
.............................................................................................................................................
.............................................................................................................................................
.............................................................................................................................................
.............................................................................................................................................
14. Is there any possible technology that you can employ other than cyanidation in
mineral processing? (kuna maarifa mengine ambayo mnaweza kutumia tofauti na
matumizi ya kemikali ya sayanaidi katika uzalishaji wa dhahabu?).
15.What are your views in proper managememt of cyanide in relation to environmental
protection?(nini maoni yako katika udhibiti madhubuti wa sayanaidi ili kulinda
mazingira?).
36
APPENDIX II
AN EXTRACT OF THE QUESTIONAIRE TO WORKERS OF THE MINING
SITE
(DODOSO KWA WAFANYAKAZI WA MGODINI)
DATE …./03/2015
PLEASE RESPOND TO THE FOLLOWING QUESTIONS ACCORDING TO THE
INSTRUCTIONS GIVEN. (TAFADHARI JIBU MASWALI YAFUATAYO KWA
KUFUATA MAELEKEZO ULIYO PEWA.)
III. CHOOSE BY TICKING THE CORRECT ANSWER. (CHAGUA JIBU SAHIHI
KWA KUWEKA ALAMA YA VEMA KWENYE JIBU LILILO SAHIHI )
1. Do you know a chemical known as cyanide? (je? Unaifahamu kemikali iitwayo
sayanaidi?)
(C) YES. (ndiyo) ( )
(D)NO..(hapana) ( )
2. How often do you use cyanide in your daily activities in a mining site? (ni mara
ngapi huwa unitumia sayanaidi katika shughuli zako za kila siku hapa
mgodini?)
(D)Very often ( mara nyingi zaidi) ( )
(E) Occasionally (mara chache) ( )
(F) I do not use cyanide (situmii sayanaidi) ( )
3. How often do you see the leakage of pipelines which contains cyanide solutions?
(ni mara ngapi umeona mabomba yenye mchanganyo wa sayanaidi
yakivuja?)
37
(D)Very often ( mara nyingi zaidi) ( )
(E) Occasionally (mara chache) ( )
(F) I have never seen that (sijawahi ona kitu hicho) ( )
IF THE ANSWER IN QUESTION 3 IS (A) OR (B) RESPOND TO QUESTION 4, IF
YOUR ANSWER IS C DO NOT ANSWER QUESTION 4. KAMA JIBU NI (A) AMA
(B) KATIKA SWALI LA TATU BASI JIBU SWALI LA NNE, KAMA JIBU LAKO
NI (C) USIJIBU SWALI LA NNE.
4. How long does it take to fix those leakages on pipelines which contain cyanide
solution? (inachukua muda gani kutengeneza mabomba yanayo vuja yenye
mchanganyo wa sayanaidi?)
(E) More than a month(zaidi ya mwezi mmoja) ( )
(F) Within two weeks (ndani ya wiki mbili) ( )
(G)Within one week (ndani ya wiki moja) ( )
(H)As soon as the leakage is seen (mara tu nyufa inapoonekana) ( )
5. How often do you get educated on environmental protection either by seminar or
any other means? (ni mara ngapi mmekuwa mkielimishwa kuhusu utunzaji
wa mazingira kwa semina au njia yeyote ile?)
(D)Very often ( mara nyingi zaidi) ( )
(E) Occasionally (mara chache) ( )
(F) I have never seen that (sijawahi ona kitu hicho) ( )
6. Has any worker or stranger being affected or died due to cyanide in your working
place? (kuna mfanyakazi yeyote au mtu mwingine aliyewahi kuathirika au
kufariki kwasababu ya kemikali ya sayanaidi katika eneo lako la kazi)
38
(D)It always happen(huwa inatokea mara kwa mara) ( )
(E) It ocassionally happen (huwa inatokea mara chache) ( )
(F) I have never seen that (sijawahi ona kitu hicho) ( )
IV. FILL IN THE BLANKS BY WRITING RELEVANT ANSWERS.(JAZA
NAFASI ZILIZO ACHWA WAZI KWA KUJAZA MAJIBU SAHIHI)
7. What are the following procedures after removing the off loadings from tailings?
( ni hatua gani zinafuata baada ya kutoa makapi kwenye teilingi?)
.............................................................................................................................................
.............................................................................................................................................
.............................................................................................................................................
..............................
8. What measures or steps do you take to protect the tailings during the rainfall? (ni
hatua gani mnazo tumia kuyakinga ma teilingi hasa kipindi mvua
inaponyesha?)
.............................................................................................................................................
.............................................................................................................................................
.............................................................................................................................................
..............................
9. What measures do you take to protect the environment at your working place? (ni
hatua gani mnazichukua ili kutunza mazingira katika lako la kazi? )
.............................................................................................................................................
.............................................................................................................................................
.............................................................................................................................................
39
.............................................................................................................................................
........................................
APPENDIX III
A PHOTO SHOWING A CYANIDATION PLANT WITHIN THE RESIDENTIAL
AREAS
40
PERSONNEL MIXING CHEMICALS IN A CYANIDATION PROCESS
APPENDIX VII
A PICTURE SHOWING A LABORATORY IN WHICH CHEMICALS ARESTORED AND MIXED FOR CYANIDATION
44
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