LETTER TO THE EDITOR — Chemists also deserve professional licensure

I had the opportunity to review the TSE-OSC Interim Report on Setting New Standards in Mining. As a professional chemist who has done mining research as well as metallurgical and mineralogical assaying, I found this report a good first step in setting the benchmark in mining standards. The concerns I raise are not with the content of this report but with the observations, conclusions and recommendations that are absent.

One of my concerns is that the report breaks down the mining process into its respective components and makes recommendations for each little area of responsibility. It doesn’t consider what needs to be done to ensure that the Canadian mining industry works, from cradle to grave, as a cohesive unit. Ideally, the sharing of information between professional scientists and sanity checks by each scientist ensure accountability, integrity and due diligence in the mining process.

The process of bringing a mine on-line is complex. Thousands of correct decisions must be made by a multitude of professionals before a mine can start production. Only through an integrative perspective, can one truly appreciate the managerial and business dynamics involved in this process. A holistic approach, from prospecting to producing mine concentrate, ensures that there is a common thread between the many professionals who touch this process and the responsibilities they share. Basic business principles such as due diligence strengthen this thread.

The report recommendations clearly state the need for geologists to be licensed in Ontario. This recommendation is good because licensure raises professional and ethical standards, thereby imparting greater protection to the (investing) public through stewardship and accountability of that profession.

What is notably absent is a similar recommendation about the lab manager or chemist who signs off on the mineralogical assays that will ultimately determine the fate of that potential mine. The licensing of geological engineers and geologists, but not chemists, sends a clear message that the role of chemistry in this process is secondary to geology or engineering. Professionally, it places the chemist at a disadvantage when follow-up and investigation are required outside the lab. In contrast, the professional chemist in an integrated mining company has much broader responsibilities, enabling him to [communicate] with the geologist, engineer or other chemists before results are disclosed.

The only way to ensure that a lab professional will meet a minimum professional standard is through licensure. The TSE-OSC Task Force does recommend that those chemical labs doing mineralogical assay work be accredited. This recommendation is excellent. But when it comes to setting world-class mining standards (which is the intent of this report), assay lab accreditation represents the nadir and not the zenith. Licensing a lab and not the individuals managing a lab is like licensing a car but not the driver. Besides, the lab accreditation process is based on an honor system. The process assumes that individuals who manage labs will conduct themselves in an ethical manner when seeking accreditation.

Lab accreditation hinges on check sampling, which is a process whereby a recognized authority delivers reference standards as mineralogical unknowns to the prospective lab. Based on the accuracy and precision of results from the lab (as well as site audits), accreditation will be given to the lab in question. The concern is that it is assumed that the lab receiving the accreditation actually does the check sample tests. In reality, marginal labs that may not have the testing capabilities will likely contract out this testing to another lab with more experience or technology to avoid loss of accreditation status. The only way to curtail such dubious conduct is to instill professional values such as due diligence, accountability and deontology in the chemists that manage lab conduct.

Good science is premised on seeking the truth by asking the right questions. This noble goal must not be compromised because verity promotes vitality in any profession. Individuals find work rewarding only when they know there is integrity in all they do. Chemists and other scientists are often “encouraged” to sign-off on incomplete or questionable scientific data so that a product can be released or a process can continue. I can cite many examples where the health and (financial) welfare of the unsuspecting public has been compromised because of bad science.

This report recommends that geologists be regulated through licensure. By consciously ignoring the licensure of chemists, this report fails to recognize the added value that chemists bring to Canada’s mining industry. Until provincial governments regulate the right to practise chemistry, the minimum standard of competency of this central science will remain ethereal at best. Society and the investing public will continue to be subjected to bad science.

George Brown, C.Chem

Aurora, Ont.