From requirement to field: how to implement GISTM to truly reduce risk.

GISTM as an operational transformation, documentary non-compliance.

Effectively implementing the Global Industry Standard on Tailings Management (GISTM) is not a matter of mere compliance with documentation. It is a risk-driven operational transformation with direct implications for production decisions, maintenance priorities, execution discipline, and, above all, the ability to respond before early warning signs escalate into loss of control. In other words, the difference between "passing the audit" and "avoiding an event" lies not in the existence of policies, manuals, or organizational charts. It lies in the quality with which an organization translates requirements into verifiable critical controls, actionable triggers, and rapid decisions, especially under pressure.

Start with the truth of the field and build a realistic baseline.

A robust deployment program needs to start with the point most organizations avoid: the truth of the field. Before standardizing documents, it's necessary to establish a realistic risk baseline. This includes defining which structures should be prioritized, typically those with the highest potential energy, greatest exposure of people, and greatest sensitivity to water and operational variability. It also includes identifying which critical controls effectively exist today and which are merely implicit intentions. This step requires systematic field inspections (walkdowns) with integrated participation from geotechnics, operations, maintenance, and safety, because the most relevant gaps rarely appear in reports. They appear in silted drains, interrupted access, inconsistent inspection routines, instrumentation with low availability, and, mainly, in decisions that fall "halfway" between data and action. The expected result is not a well-written document. The result is a prioritized, objective, and traceable list of vulnerabilities, with an initial action backlog and a clear understanding of where the potentially exposed population (people at risk) is located and which credible scenarios dominate the risk.

The backbone: failure mode, signs, controls, evidence, and response.

With the baseline established, the implementation needs to build its backbone: the chain between failure mode, leading indicators, critical controls, evidence, and response. This chain separates real governance from performative governance. For each prioritized structure, the work must define credible failure modes, including uncomfortable ones, such as fast and non-linear mechanisms. Then, it must translate these failure modes into observable early indicators, through instrumentation and inspection, and into critical controls that act as physical and operational barriers. In parallel, each critical control must have a performance standard: what it means to "be working," how to measure it, how often to measure it, what tolerance to accept, and what consequence to apply when it does not meet the standard. Without a performance standard, control becomes opinion. With a performance standard, it becomes discipline and traceability.

In the GISTM model, technical risk is not delegable. The organization can delegate analyses and recommendations, but the acceptance of residual risk always falls on whoever controls resources, priorities, and production.

TARP with a "tooth": reducing the time between detection and action.

From this point, the focus shifts to reducing the time between detection and action, which is the interval in which many events materialize. This is where the trigger action response plan (TARP) with a "tooth" comes in. A mature TARP is not a conceptual traffic light. It is a decision-making mechanism that connects calibrated thresholds to the operation with actions that change the system's condition. This includes operational constraints, reduced disposal rates, water diversions, drainage interventions, shutdowns, and, when applicable, triggers that initiate formal escalation to the accountable executive. To function, TARP needs three elements that organizations often neglect: explicit authority, short response times, and predefined actions that are operationally feasible. If a TARP does not foresee, at some level, the real possibility of reducing production or stopping an activity, it tends to exist only for auditing purposes. Consequently, it fails precisely when it is most needed.

If a TARP (Target Assessment Report) does not foresee, at some level, the real possibility of restricting or interrupting an activity, it does not control risk. It only describes intent.

WHO "on the ground": transforming critical controls into repeatable routine.

The next step is to transform critical controls into repeatable routines through a "ground-level" operations, maintenance, and surveillance manual (OMS). Large programs fail when they confuse OMS with a lengthy manual. In practice, effective OMS is an execution system. It involves inspections focused on water, drainage, geometry, and signs of degradation. It involves minimum standards of geotechnical housekeeping. It requires direct integration with preventive maintenance. Furthermore, it demands a unique recording mechanism that converts anomalies into actions with an owner, deadline, and evidence of closure. The managerial point here is simple and uncompromising: an anomaly without an owner and without a deadline is a risk accepted by omission. Therefore, the OMS must operate as a disciplined flow (execution pipeline), with detection, recording, prioritization by criticality, execution, verification, and organizational learning.

A pragmatic technical basis and change management that protects the operational envelope.

In parallel, the organization needs to consolidate a sufficient technical basis to make decisions through pragmatic design basis reports (DBRs) and safety and operating basis reports (or dam safety review, DSRs), as well as an objective management of change (MOC) process. A recurring source of fragility in geotechnical structures is operating outside the baseline without realizing it. Water changes, layouts change, rates change, materials change, and production priorities change. When these changes are not treated as material changes, the organization loses control of its own operating envelope. Therefore, a robust GIS™ program defines clear material change triggers and establishes a lean and decisional MOC. This process should answer direct questions: what has changed, what is the impact on failure modes and critical controls, what temporary trade-offs are acceptable, and who approves them. In relevant situations, the flow should escalate to the engineer of record (EoR) and to the accountable executive. The maturity benchmark here is straightforward. If the operation cannot say "how far can I go" based on clear operational limits, the structure is being driven by habit, not engineering.

Addressing the normalization of deviance through effective accountability.

A non-theatrical implementation also needs to address the most common and corrosive governance problem: the normalization of deviation. Therefore, the deviation accountability report (DAR) should be treated as a decision-making and accountability tool, not as a historical record. Relevant deviations need to be characterized and assessed for risk. They need to be accompanied by coherent temporary risk controls. They must be resolved definitively within a timeframe commensurate with their criticality. A critical deviation without compensation represents, in practice, an immediate constraint. When the deviation requires a trade-off with production, the accountable executive must act as the real decision-maker. This is the essence of the GISTM model: governance is proven by the unpopular decision made early, not by the report signed late.

Emergency preparedness and response as a tried and learned system

Even with well-defined barriers, the system must be prepared for when controls fail. Emergency response cannot be a set of slides. An effective emergency preparedness and response plan (EPRP) is born from credible scenarios, integrates with TARP triggers, validates critical resources such as communication, routes, rendezvous points, and interfaces with authorities, and is tested in simulations that measure times and expose failures. What matters is not just conducting the simulation. What matters is demonstrating post-simulation improvements and closure of the generated actions. Readiness without learning does not mature; it only repeats the same mistakes with more confidence.

Management cadence to sustain the program and avoid regression.

To sustain the program and avoid regression, deployment must be tied to a lean and relentless management cadence. At the site level, a short daily routine should cover alerts and actions of the day. At the management level, weekly governance should ensure closure of pending issues and blocking decisions (risk-based constraints). At the executive and engineering levels, monthly governance, with an accountable executive and engineer of record (EoR), should reassess risk, deviations, resources, constraints, and material changes. The difference between maturity and collapse, in practice, usually lies in the persistence of this cadence for months. It is not in the intensity of a "deployment project" for a few weeks.

Independent performance-oriented warranty, not documentation-driven.

Closing the initial cycle requires an independent assurance component focused on what truly matters. Instead of starting with the question "does the document exist?", the question should be "is the critical control functioning?" and "did the system respond when there was a signal?". This demands operational evidence: real-world cases of TARP application, decision traces, response times, critical pending items and their age, anomaly recurrence, instrumentation availability, drainage integrity, and adherence to the MOC in relevant changes. These indicators translate governance into performance and make visible the main silent risk: the accumulation of technical liabilities under the guise of normality.

Event-avoiding deployment: requirements such as system performance.

In short, the implementation of GISTM that prevents events is one that treats requirements as a performance system, not as a document package. The program begins in the field, builds a clear chain of risk and control, establishes actionable TARPs with real authority, transforms OMS into a disciplined routine of detection and closure, controls material changes with rapid decisions, addresses deviations with effective accountability, trains readiness with realism and learning, and sustains all of this with management cadence and independent assurance oriented towards critical controls. The result is not just compliance. The result is operational predictability, shorter response times, reduced variability, and an organization capable of acting early, before the problem becomes unmanageable.

Effective governance is not proven when everything is stable. It is proven by unpopular decisions made early, based on evidence, before the option to act disappears.