Adam Matthews (left), Chair of Mining 2030 Investor Agenda and Global Tailings Initiative and CRIO of Church of England Pensions Board introduces the Summit.

Last week the Andrew Lees Trust (ALT UK) participated at the Global Tailings Summit (GTS), hosted by United Nations Environment Programme (UNEP) and the Church of England Pension Fund. The event was held over the fourth anniversary of the Brumadinho mine tailings dam disaster, which killed 272 people and left a legacy of social and environmental devastation.

The Trust requested an invitation to attend in order to raise questions about how the new Global Tailings Management Institute and the Global Investor Commission on Mining 2030 will address the dissonance between verbal commitments to the Global Industry Standard for Tailings Management (GISTM), made by mining corporations like Rio Tinto, and the realities on the ground, for example at Rio Tinto’s QMM mine in Madagascar.


According to Earthworks, mine tailings facilities, which contain the processed waste materials generated from mining metals and minerals, are failing with increasing frequency and severity.

The global standard (GISTM) was set up in 2020 to improve industry practice around mine tailings management, increase safety, adopt a zero harm policy and thereby prevent disasters like Brumadinho from occurring again. The newly launched Institute of last week aims to provide an independent auditing body to ensure compliance with the GISTM.

Rio Tinto is one of the largest mining companies in the world and has emphasised its role in helping to set up and promote the GISTM.

However, Rio Tinto’s commitment to the standard is under question at its QMM mine site in Madagascar where four tailings dam failures have occurred since 2010 with significant impacts on local communities.


The company claims it has “no tailings” and “no tailings dam” at QMM (AGM 2022), thereby raising questions as to how it will achieve the GISTM and any safety standards needed to protect the local communities living adjacent to the mine from tailings dam failures and mine process wastewater seeping and overflowing from the QMM mining basin.

Rio Tinto’s assertions about no tailings or dam at QMM contradict the Malagasy Government’s requirements under the mine’s environmental plan. This demands that QMM construct a berm 4m high and 30m wide in order to contain its mining basin waters and prevent them from entering the surrounding environment (e.g., downstream lakes). This structure has the operational function of a dam. The risks to the local communities if the tailings dam and its tailings are not safely managed are considerable.

Diagram of the QMM tailings dam – with english labels overlaying the original French version from the QMM Social and Environmental Management Plan (SEMP) 2014-2018, that was submitted to and approved by the Malagasy regulator, the National Office for the Environment (ONE).

Rio Tinto says it will reach compliance with GISTM at QMM by August 2023, but it is hard to see how this will be achieved if it does not admit that QMM has mine tailings nor a tailings dam.

Following two tailings dam failures at QMM in February and March 2022, and the release of a million cubic feet of mining basin water, hundreds of dead fish appeared downstream in lakes where local people fish for food and livelihoods. A fishing ban was imposed until the cause of the fish kills could be determined.

Collection of fish samples after the tailings dam failure in March 2022

Communities were plunged into food insecurity and lost their livelihoods as a result of the ban. Months of conflict ensued as villager’s usual survival strategies were compromised and they were left without sufficient aid and support to meet their daily needs. They were also scared to collect water from the local lake for drinking and domestic use, as is the practice for the majority of villagers living around the mine who still have no access to safe drinking water.

Multiple questions have been asked about the safety of the QMM tailings dam since 2017-2018, while the company was being held to account for breaching an environmental buffer zone and placing QMM mine tailings on the bed of adjacent Lake Besaroy, thereby exposing the local estuary system to mine contaminants, e.g., uranium and lead.

In addition to the breach, an independent risk assessment carried out by hydrology expert Dr Steven Emerman in 2018 deemed the risk of possible seepage and overflow from the QMM tailings dam to be “unacceptably high.”

Three of the four tailings dam failures have occurred at QMM since dam safety questions were raised with Rio Tinto about the QMM structure and tailings management.

Furthermore, in 2021, an analysis (Emerman 2021) of QMM’s Water Discharge Monitoring Data showed the “passive” or “natural” water management system at QMM appeared to be enhancing concentrations of contaminants in the mine’s settling ponds.

Rio Tinto conceded that the system was not working as expected and announced that QMM had, in fact, ceased discharging its mining basin waters as of August 2020 – a strategy only possible due to prolonged drought in the south.

The Anosy region, where the mine is located, is subject to frequent cyclones and heavy rainfall. In 2021, ALT UK and PWYP MG asked how the QMM strategy would work when the rains arrived? The answer came in 2022 with two tailings dam failures and an “exceptional release” of a million cubic metres of mining basin water (almost a billion litres).

The QMM mining basin and dredge

The concern about the extent to which contaminants from QMM mine tailings and process wastewater from the QMM mining basin is impacting local water quality has driven inquiry from local to international level since 2017.

Using QMM water data, independent studies by experts in hydrology and radioactivity identified elevated levels of uranium in the QMM mine basin, and elevated levels of uranium and lead downstream of the QMM mine 50 and 40 times, respectively, the WHO safe drinking water guidelines.


Villagers have reported a noticeable degradation of water quality since the QMM mine operations began. They complain of increased illness and health problems. Fisherfolk have reported significant loss of fish stocks and disappearance of certain fish species since 2009, with a resulting loss to their livelihoods and income. Land fertility around the mine has also reportedly fallen over the last ten years.

A field study by Publish What You Pay Madagascar (PWYP MG) in 2022 captured the communities’ grievances and losses, including an estimated 45% loss of their usual annual revenues as a result of the detrimental impact of the QMM mine on local natural resources.

Fishing on the lakes and estuary around QMM for food and livelihoods

The 2022 tailings dam failures exacerbated local communities’ hardships as well as their frustration with QMM, and further eroded trust in the Rio Tinto joint venture in Madagascar, which has seen multiple outbreaks of conflict since operations began.

The conflict that followed the 2022 tailings dam failures was disturbing. In particular, to see QMM deny responsibility for the fish deaths and thereby distance itself from the ensuing community hardships.

Both publicly and internally Rio Tinto has claimed no environmental impact from the tailings dam failures. They have done this by citing two studies produced by the Malagasy water regulator, ANDEA, which collected fish and water samples after the dead fish appeared in March 2022.

The ANDEA studies were accessed by Andrew Lees Trust in collaboration with Malagasy civil society. They have been reviewed and critiqued by hydrology, mining and radioactivity experts, who highlight how the studies fail to provide data for various metals that should have been tested, e.g., mercury and lead, and that “conclusions drawn in the reports are not based on sufficient evidence” (Swanson 2022).

The ANDEA reports were never publicly issued by the Malagasy government. Nevertheless, Rio Tinto has referenced these reports to defend QMM’s position, even though they clearly lack scientific rigour, raising questions about the company’s international standards and integrity.

Radioactivity expert Dr Swanson provided her own independent analysis using all the available data, including from a previous QMM tailings dam failure with accompanying fish kills in 2018. She demonstrated that the most probable cause of the 2022 fish kills was the QMM mining basin water, being high in aluminium and with low pH – a combination that causes asphyxiation in fish. However, because some metals were not tested, questions remain.

One thing is more certain. After four years of demanding baseline water data for the region and being told by QMM there was none, the Trust’s research with PWYP MG uncovered a 2001 pre-mining water study in which data show there were no issues with uranium and lead levels in local waterways prior to mining (Hatch &Associates 2001).

Pre-mining chemical measurements of uranium in surface water around Mandena were mostly at readings of 0.0002 mg/l – 0.008 mg /l – and groundwater readings between 0.00005 – 0.00007 mg/l. The WHO safe guideline for uranium in drinking water is 0.03mg/l . Post-mining data include uranium in QMM mining basin water, process water and paddocks at maximum concentration of 2.029 mg /l . Downstream readings were highest near the QMM weir at 1.073 mg /l.

Rio Tinto has yet to answer to the comparison with pre-mining water indicators, as the company has repeatedly claimed that the elevated levels of uranium found downstream of QMM were all “naturally occurring.” The pre-mining baseline data shows this is not the case.

For the time being QMM focuses on the issue of the high aluminium and low pH in the process wastewater contained in the QMM mining basin. This is because QMM is not compliant for discharge levels of aluminium and cadmium in relation to Malagasy regulatory limits, so they cannot release their mining basin water without exceptional permission (as happened during the tailings dam failures in 2022).

There is no regulatory limit for uranium discharge in Madagascar and QMM’s pilot “treatment plant” for the high aluminium issue will not address high uranium and lead issues.

Access to information about the new pilot “treatment plant”, QMM water data, and other technical data has been an ongoing challenge for civil society, often taking months and anything up to a year or more of repeated prompts before QMM will release promised or requested information.

The difficulties to access data and reports from Rio Tinto/QMM bring the company’s transparency commitments to the GISTM into question.

For example, Rio Tinto/QMM promised that it would share the external evaluation of the tailings dam failures of 2022 with PWYP MG and ALT UK, and the findings with the Jesuits in Britain who raised questions at the Rio Tinto 2022 AGM. Almost one year later they still have not provided the report, but instead QMM issued summary papers to PWYP MG and ALT UK, which it claims present key findings:


These documents raise more questions than they answer, including how the “root cause” of a tailings dam failure and overflow incident is explained by the lack of inspection.

This and other pressing questions make it all the more urgent that QMM conform to the transparency commitments of the GISTM and other international standards.

The example of Rio Tinto’s subsidiary, QMM in Madagascar, offers a clear example of where the reality on the ground is not aligned with verbal commitments to the GISTM made by the parent company.

If companies like Rio Tinto, which positions itself to be a leader among the 26 ICMM members obligated to adhere to the GITSM and claiming to be at the forefront of change in the sector – if they do not adhere to the highest standards at all their operating sites, how will the remaining publicly listed mining companies be brought into line to accept and deliver improved practices and higher levels of responsibility and accountability?

The urgency of compliance – and the need for penalties for failure to comply – is all the more pertinent as the industry positions to increase mining exponentially to meet mineral demand for the energy transition.

Madagascar with its substantial mineral reserves against a backdrop of weak regulatory capacity, poor governance, high levels of poverty and human rights issues, risks to be one place where the absence of international standards such as the GISTM – or better still Safety First Guidelines for Responsible Mine Tailings Management – can only deepen hardships and catalyse conflict around mining.

Local Antanosy woman collects household water from the flooded areas around QMM after the mine tailings dam failure in March 2022 (Malina)
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