Unpacking the Mining Association of Canada’s Towards Sustainable Mining Program

Joan Kuyek, Ontarians for a Just Accountable Mineral Strategy

Ontarians for a Just Accountable Mining Strategy (OJAMS) is voluntary association of people from diverse communities and interests in Ontario that want to see a mineral strategy that

  • Sustains the environment and the resources for future generations,
  • Protects the public from the risks associated with mining, smelting and refining,
  • Heals the damage already caused by the industry,
  • Captures a fair share of the revenues generated by the industry for Ontarians and First Nations, and
  • Respects the rights of First Nations to free, prior, informed consent to development on their lands.

This paper provides a critique of the Mining Association of Canada Towards Sustainable Mining (TSM) initiative from the perspective of communities affected by mining impacts.

The TSM webpage describes the initiative’s objectives as follows:

[Towards Sustainable Mining]’s primary objectives are to drive performance improvement and, through demonstration of this improvement, to build trust with communities of interest. This means that communities need to understand TSM and trust the performance results that the mining companies report. To build this trust, the program includes a number of checks and balances to ensure that reported results present an accurate picture of each facility’s management system and performance.

We ask: to what extent is the TSM process worthy of that trust?


The Towards Sustainable Mining (TSM) initiative of the Mining Association of Canada (MAC) is one of the more sophisticated iterations of voluntary Corporate Social Responsibility (CSR) programs in the mining sector.

Introduced in 2004, TSM has now been evolving and in operation for fifteen years. Until 2018, it produced an annual public report on the TSM progress of MAC members. In 2019, MAC has decided to cease the annual report and instead have participating companies report directly on line. It has also updated and modified its “Guiding Principles”. (see Appendix A)

TSM is a voluntary Code of Conduct for mining companies. The standards and indicators are developed by the mining company association for their members. Although a company has to agree to participate in TSM in order to belong to MAC, after fifteen years of the program just over one half of MAC companies and their facilities report. They are only required to report on facilities in Canada. For those that do report, there is no penalty for poor grades and no failing grade at all.

Sustainable Mining is an oxymoron. Mining is not – and cannot be – sustainable, as it depletes the very resource it depends upon. It is a rapid, ferocious and continuous assault on the earth no matter how carefully it is done. It is a waste management industry, leaving behind massive amounts of tailings and waste rock that will, in most cases, be toxic and have to be managed forever in order to prevent them from poisoning aquifers and surface waters. The corporate members of the Mining Association of Canada are major contributors to global warming and climate breakdown, not only through their energy consumption and greenhouse gas (GHG) emissions, but also through the very products they produce, such as coal and other fossil fuels.

As the industry tells us repeatedly, we do need fossil fuels, minerals and metals, and our economy has been created around the extraction of oil, coal, industrial minerals, gems and metals. Transition to a sustainable economy – “one that meets the needs of the present without compromising the ability of future generations to meet their own needs” – means a massive paradigm shift away from activities like mining towards closed-loop ecologically responsible economies that heal the damage already done. It means challenging the very power and authority of the mining industry.

This report is organized as follows:

  • A History of Towards Sustainable Mining
  • Regulatory vs. voluntary standards
  • How the TSM process is structured
  • A critique of TSM assessments
  • Beyond the TSM: an ecosystems approach
  • Can the mining companies reporting to TSM be trusted? (company-specific critiques)

The full report is available for download here: