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Mercury Risk Management: Position Statement

16 February 2009

ICMM recognises the importance of responsible management of mercury. ICMM members are not primary producers of mercury nor do they use it in the processing of ores. However, mercury is a naturally occurring element which is sometimes present in the ore that ICMM members process. As a result, pollution controls at some ICMM member companies’ operations may collect mercury as a by-product.

Mercury is a global pollutant and there are legitimate calls within the industry and from external stakeholders to manage it effectively. ICMM members are committed to control mercury emissions to the environment. In addition to recognising the potential impacts of mercury once it is released into the environment, ICMM fully recognises the potential risks associated with by-product mercury and endorses the need for its effective management.

Mercury is used widely and sometimes illegally by artisanal miners to assist with the extraction of gold. This use is almost entirely uncontrolled with direct emissions to the environment. Consistent with ICMM’s materials and environmental stewardship commitments, ICMM seeks to promote the responsible management of mercury by-product down the value chain in light of the potential environmental and human health impacts of a failure to responsibly manage such mercury.

Relationship Between the ICMM Mining Principles and Position Statements

All ICMM company members are expected to implement ICMM's Mining Principles as a condition of membership. Incorporating comprehensive environmental, social and governance requirements, robust site-level validation of performance expectations and credible assurance of corporate sustainability reports, ICMM’s Mining Principles seek to maximise benefits to host communities and minimise negative impacts to effectively manage societal challenges.

Principles of particular relevance to chemicals management are:

  • 4 – Risk Management

    Implement effective risk-management strategies and systems based on sound science and which account for stakeholder perceptions of risks.

  • 6 – Environmental Performance

    Pursue continual improvement in environmental performance issues, such as water stewardship, energy use and climate change.

  • 8 – Responsible Production

    Facilitate and support the knowledge-base and systems for responsible design, use, re-use, recycling and disposal of products containing metals and minerals.

Since 2003, Position Statements have been developed to clearly articulate member commitments on a number of critical industry challenges. Position Statements are endorsed by the ICMM Council and include specific commitments that members must implement, alongside the Performance Expectations.

This Position Statement sets out ICMM members’ approach to sound management of mercury related to their operations. While recognising that some ICMM members’ operations do contribute mercury releases to the environment, albeit only a minor incremental addition to the global load, ICMM members have agreed to the following position.

Recognition Statements

ICMM members recognise that:

  • Mercury is a metal that is transported globally in the atmosphere and has potential adverse human health and ecological effects.
  • Although the scientific understanding of mercury is still evolving, enough is known and understood to warrant taking action to reduce mercury releases to the environment.
  • No ICMM member company owns or operates primary mercury production facilities; however, there are aspects within some operations that contribute to the global mercury load through air emissions, supply to the global market of elemental mercury or mercury compounds recovered as a result of pollution control, naturally occurring mercury compounds in some products (eg minerals and concentrates), and recycling of mercury-bearing products (eg lamps and switches).
  • Significant progress has already been made in reducing mercury air emissions at ICMM members’ operations and by users of those products.
  • Mercury recovered from our environmental management activities is a preferred source of mercury over other sources (eg primary mercury mining) for use in applications that are necessary and important for sustainable development – particularly for economic development and improving social welfare in developing countries.
  • At such time when policy and economically viable long-term technological solutions for the retirement of mercury exist, the mercury supply from ICMM members’ operations can be integrated into a strategy of gradual reduction and elimination
  • Studies show that the informal sector of artisanal and small-scale gold mining (ASM) is a relatively large global consumer of elemental mercury and may be the source of significant mercury released to the environment every year
  • Within the socio-economic and political complexities of the ASM issue there are opportunities to contribute to more sustainable livelihoods in this sector through the transfer of technology that improves productivity and reduces reliance on mercury
  • Mercury is an issue that requires action at a global level and the importance of responsibly managing mercury in collaboration with key stakeholders.


In addition to existing commitments under ICMM's Mining Principles, and the Strategic Approach to International Chemicals Management (SAICM), ICMM company members will:

  1. Not open any mines designed to produce mercury as the primary product.
  2. Apply materials stewardship to promote the responsible management of the mercury produced from ICMM members’ operations including that which naturally occurs in our products.
  3. Identify and quantify point source mercury air emissions from our operations and minimise them through the application of cost effective best available technology, using a risk based approach.
  4. Report significant point source mercury air emissions from our operations consistent with our commitment to report in accordance with the GRI framework.
  5. Participate in government-led partnerships to transfer low- to no-mercury technologies into the ASM sector in locations where ICMM member companies have operations in close proximity to ASM activity such that livelihoods are enhanced through increased productivity and reduced impacts to human health.
  6. Through ICMM, encourage the development of sound science on the fate and transport of mercury as well as natural sources of mercury in the environment.
  7. Work on an integrated multi-stakeholder strategy through ICMM to reduce and eventually cease supplying mercury into the global market once policy and economically viable long-term technological solutions for the retirement of mercury are developed.