NI 43-101 assay laboratory accreditation

Since National Instrument (NI) 43-101 came into effect, a number of misconceptions about Canadian mining disclosure standards have come up. In this article, we attempt to clarify one area where NI 43-101 is often misunderstood.

Do I need to use an accredited laboratory to meet National Instrument 43-101’s Standards of Disclosure for Mineral Projects? Geologists, especially those planning overseas projects, often ask this question. The simple answer is no, but of course, it is not quite that simple.

The underlying objective of the regulations is to protect investors. In the past, there have been cases where favourable assays were reported by laboratories owned by the company, or its associates, that could not be duplicated at commercial laboratories. One might recall a series of scandals where “proprietary” assay methods were used for “non-assayable” gold. These are examples of situations the industry needs to prevent from recurring.

The first draft of NI 43-101 by the Mining Standards Task Force in 1999 proposed that all mineral assays be performed at accredited laboratories, but the final report omitted this requirement. It was likely eliminated because there is a poor cost benefit for remote commercial laboratories and most mine laboratories.

Many overseas laboratories cannot afford accreditation, especially due to the high cost of flying an assessor in to remote sites. These laboratories may be part of an international network of laboratories, where other operating units are accredited.

The non-accredited laboratories may use the same procedures as the accredited laboratories, including internal quality control. In many situations, company owned mine laboratories report assays that are used for mineral reserve estimations, but very few mine laboratories are accredited — usually because of the cost versus the perceived benefit.

The objective of the NI 43-101 standards is complete disclosure, so it is necessary to specify the name and location of the laboratory, ownership and accreditation status. Where a non-accredited laboratory is used, it is prudent to satisfy the reader of the report, whether a regulator or investor, that the laboratory is independently owned, maintains an internal quality control program and participates in international proficiency testing.

Quality control

A quality control program is also required to further improve confidence in assays. NI 43-101 standard, Australasian Joint Ore Reserves Committee (JORC), Canadian Institute of Mining, Metallurgy & Petroleum – Mineral Resources and Mineral Reserves (CIM-MRMR) and South African Mineral Resource Committee (SAMREC) guidelines all require that sample submissions include reference materials and barren samples as part of a quality control program.

The use of an accredited laboratory does not preclude the use of quality-control samples. The other requirement of a quality control program is that a selection of samples be submitted for check assays at a secondary laboratory. Although not a requirement, it can be useful to select a secondary laboratory that is accredited, so that if the check assays agree with the original assays, there is increased confidence in the assays from the non-accredited laboratory.

There are several types of laboratory accreditation, but the most common standards are set by the International Standards Organization (ISO), based in Geneva. You can often see signs advertising that companies ranging from carpet manufacturers to garbage disposal are ISO9001/9002 accredited. The ISO9001/ 9002 accreditations stress standardized procedures and documentation that contribute to consistent and reliable assays. Many of the commercial laboratories have moved to a more rigorous standard, ISO17025, which also requires traceability of results, participation in proficiency testing and may be specific to a restricted number of elements. A laboratory can lose its accreditation if it fails to report acceptable results in the proficiency tests in two consecutive rounds of testing. It should also be noted that the proficiency tests usually occur just twice a year, so a non-conforming laboratory could issue poor-quality results for a year before losing its accreditation.

The simple answer is that it is not necessary to use an accredited laboratory for assays that are included in technical reports or press releases that need to conform to NI 43-101 disclosure. On the other hand, it is necessary to satisfy regulators, company directors and investors that assays are a reliable estimate of grade. There are several ways to achieve confidence in assays, including the use of an accredited laboratory, but use of an accredited laboratory is not an NI 43-101 requirement.

—Lynda Bloom is the president of Toronto-based Analytical Solutions. Deborah McCombe is the chief mining consultant with the Ontario Securities Commission.