DIRTY PRECIOUS METALS

Dumping European toxic waste in Tsumeb, Namibia Dirty Precious Metals Report from a fact inding mission on the Dundee Precious Metals smelter facility in Tsumeb, Namibia January 2016

Contents The Global Capitals and the Multinational Extractivism ...... 4 Background to DPM operations ...... 5 Meeting (or rather not meeting) the Namibian authorities ...... 9 The arsenic issue as the big white elephant in the room ...... 10 The missing tonnage of arsenic ...... 16 Cases from the past where the words did not match the reality ...... 17 Export Processing Zone (EPZ) ...... 18 Last but Not Least!...... 19 Sollutions And Roles: ...... 21 Global view on the industry: ...... 23 Human stories behind the Tsumeb smelter ...... 24 Annex 1 – Arsenic and arsenic trioxide: the king of poisons and the poison of kings ...... 25 Peruvian copper ...... 27 Tsumeb smelter products / Source: DPM / ...... 27

Authors Daniel Popov Genady Kondarev Bertchen Kohrs Fidanka Bacheva-MacGrath

CEE Bankwatch Network, Earthlife Namibia and Za Zemiata – Friends Of The Earth Bulgaria, 2016

This report is realised with the inancial assistance of EU. The content of this report does not relect the oicial opinion of the European Union. Responsibility for the information and views expressed in the report lies entirely with the authors. The Global Chelopech Mine – Bulgarian (production of copper concentrate – which is actually complex ore Dirty Precious Metals concentrate containing number of rare earth and Capitals and the above all GOLD, roughly 100 000 tons of concentrate Multinational per year) Report from a fact inding mission on the Dundee Precious Metals smelter facility in Tsumeb, Namibia Extractivism DPM Bulgaria is registered in The January 2016 Netherlands The subject of this report is not a usual environmental laggard. Here we take a closer look at the activities of a mining company considered to be an environmental and social champion by the European Bank for Reconstruction and Development (EBRD). Dundee Corp (USA) DPM working exclusively with Louis Dundee Precious Metals (DPM) is a Canadian registered international mining company, listed on owner of Dundee Dreyfus Commodities, Switzerland the stock exchange of Toronto, with operations in Bulgaria (Chelopech mine), Armenia (Kapan Precious Metals – buyer of all the Bulgarian concentrate, mine) and Namibia (Tsumeb Smelter). The company currently has plans for new mines in Bulgar- (Canada – Listed on Toronto sourcing more dirty concentrate for the ia and Serbia. Stock Exchange) smelter in Namibia from around the world

One of the other big sources of concentrates is Background to DPM operations Another 70 000 +

Colquijirca Mine tons come from in Pasco Provice, During the totalitarian regime in Bulgaria of ore in 2008 to more than 2 million tons in other sources Peru owned by the Chelopech mine was a state owned en- 2014. including local Buenaventura 25-30 sources from terprise. The product, in the form of copper The Krumovgrad project (also in Bulgaria) was 000 tons per year – Namibia and concentrate, was treated at the Pirdop smelter announced in 2005, with an environmental im- the valuable in this neighboring concentrate is mostly together with concentrates from other nearby pact assessment (EIA) for ore processing and countries or the silver content) mines – Elacite and Asarel. Following a major metal extraction involving the cyanide leaching from the global markets accident with the smelter tailing pond in 1988, method. Strong opposition from local commu- the Bulgarian government decided to stop nities and environmental NGOs resulted in a the processing of the Chelopech concentrate delay and signiicant changes to the project, in Pirdop due to its high arsenic content. The reducing the scale of the mine, improving the ban was regulated with a Council of Ministers tailings facility and bringing about the elimina- decree in April 1, 1990. tion of the cyanide technology. As of now the Following privatisation, DPM acquired the mine project has acquired most of the necessary in 2003 and since then has overseen contin- national licenses, but operations have not yet Tsumeb Smelter – Namibia (owned uously increasing production from 900 tons started. by DPM – processes dirty copper concentrates from Chelopech mine, Bulgaria, Colquijirca mine, Peru and from other sources around the world; Situated in Export Processing Zone = 0 corporate tax to Namibia) The Namibia Custom Smelter (NCS or the Tsumeb smelter) is a major commercial smelter Copyright© Free Maps.com Vector located in Tsumeb, in the north central part of Namibia. The smelter has been in operation Some of the main products of the smelter in Tsumeb: since the 1960s. It is primarily used for the pro- cessing of copper and is one of the few smelt- ers in the world suitable for the treatment of • Black copper that is nearly pure copper but inhouse dust that contains it is stored in sugar complex arsenic and lead bearing concentrates. containing all the gold, silver and other rare bags, 4200 tons is the reined arsenic trioxide Tsumeb smelter in Namibia was acquired by earths that are marketable for Louis Dreyfus; most which gets marketed in Malaysia and DPM in 2010 from Weatherly Mining Interna- It is clean from the arsenic and can be sold for South Africa for treatment of wood and pesti- tional. Louis Dreyfus Commodities Metals Suisse further processing to many places cide in agriculture which is also a bad practise SA has exclusive rights to purchase the Chelo- pech concentrate for toll processing through • Arsenic trioxide – Byproduct of the smelting • Sulphur Acid – an acid plant was installed to the smelter and an exclusive arrangement to of dirty concentrates – our calculations show utilize the sulphuric gases that were previously further supply concentrate feed for toll pro- that DPM produces more then 10 000 tons vented and causing environmental and health cessing at the smelter through to and including ot the toxic material; The biggest part of it is damage to the Tsumeb regions; Sulphuric acid 2020. left in a designated dumpside in Tsumeb as is sold to the uranium mines in Namibia;

4 5 A question mark The Bulgarian partners of CEE Bankwatch ield gold mine at Krumovgrad in Bulgaria. In our understanding of sustainable manage- Network have, for ten years, monitored some Through pressure exercised by civil society and ment of the environment and responsibility in of DPM’s projects. Together with other local the common sense of DPM management, this the entire chain of production, after the acqui- Bulgarian activists we have been commenting project was reduced signiicantly in scale and sition of the Tsumeb smelter and the widely on or directly opposing many of the compa- thus too its environmental impact. Following spread advertising about the planned improve- ny’s activities in Bulgaria and Armenia, starting protests a change of the initially envisaged ments, we decided to take a closer look at this with the irst investment proposal in 2005 for technology was introduced. The cyanide leach- project, particularly as the annual reports of a greenield open pit gold mine project in Kru- ing plans were given up, preventing the import, the company state that most of the modiica- movgrad, Bulgaria. use and dumping of hundreds of tonnes of tions to the facility have already been fulilled. We followed this with opposition to an invest- cyanide in Bulgaria. In 2010, DPM closed the deal for the Tsumeb ment proposal in 2008 for a cyanide leaching In the case of Chelopech, apart from giving up smelter, paying about $3.5m (N$33m) for an technology for gold extraction in the Chelo- the cyanide leaching, the extracted concen- ageing and run-down smelter, surrounded by pech mine in Bulgaria. A number of environ- trate is now loaded on rail within the prem- millions of tons of mining waste. More im- mental issues were part of our focus through- ises of the company instead of polluting the portantly, the deal came with a so-called out this period, including the former bad environs of Zlatica train station as in the early ‘grandfather clause’ endorsed by Namibia’s state of the tailings dam and the transport of years of operations. Environmental Commissioner, Teoilus concentrate from Chelopech mine which was All these problems were overcome in a process Nghitila: DPM would not be held responsi- causing pollution and dust at the Zlatitsa rail- that can be described as many and varied – ble for any environmental problems caused way station. We also had the chance to check sometimes in an atmosphere of cooperation prior to the date of purchase.1 the conditions around the zinc and silver mine and dialogue; at other times we witnessed to- The following main observations and, in some in Kapan, Armenia and we became familiar tal denial and a hostile attitude from the com- cases, comparison with the company’s be- with certain social issues related to all of these pany. The latter were cases when progress was haviour in Bulgaria comes as result of our trip projects achieved thanks to pressure and persistence to Namibia between 10th and 21st August There was much attention given to the green- from civil society activists. 2015.

1: Lack of suicient information about the smelter in Tsumeb

“Our dealing with employees, governments, stakeholders and communities are open, hon- est and transparent. We set and uphold the 2. At a meeting in January with Mr Niko- highest ethical standards and business practic- lay Hristov, the Senior Vice President for es.” DPM Sustainability report 2014 sustainable business development, we Perhaps the most astonishing fact identiied requested information about the EIA docu- months before and during the mission is the mentation. Such information was promised lack of any meaningful information about the but never disclosed. The second attempt project in Tsumeb, although transparency is to request it was via e-mail in March – ad- stated as one of the core values in the DPM dressed again to Mr. Hristov and also Mr. last sustainability report. We faced complete Hans Nolte – Vice President and General secrecy, escalating to paranoid behaviour Manager of DPM Tsumeb. A third e-mail when we appeared at the smelter gates. and request for a meeting was sent in July. As a response it was explained that a new 1. The company’s website shows diferent website was being prepared and the head technical and non-technical documents on oice in Toronto “… is busy to update it” the projects in Chelopech and Krumovgrad. for the release of such documents. The However, at the Tsumeb section, a very meeting with Mr Nolte that we request- modest one page of information about the ed was initially kindly turned down, with country and the smelter’s history is published. the explanation that the management in View to the More interesting is the fact that in the begin- Tsumeb was very busy and was unable to Ground level of ning of 2015 the technical description of the meet us before August 15th. We suggest- the Chelopech diferent facilities was listed, though surpris- ed to reschedule our travel and arrive on mine in Bulgaria ingly disappeared soon after we irst shared August 17th and then we were informed and the tailing with the management of DPM our interest to that access to outsiders in the smelter is not ponds of the see the smelter in person. allowed until further authorisation. mine

1The following main observations and, in some cases, comparison with the company’s be- haviour in Bulgaria comes as result of our trip to Namibia between 10th and 21st August 2015. 6 7 We tried also to look for any documentation both sides were having a rather diplomatic at the DPM Information Center in Tsumeb, conversation. We clearly pointed out that it yet as the person in charge was absent we was not our intention to enter the smelter and could not access any documents. We were have a tour, but to meet someone who could provided with abundant information about show us documents and speak with us. the funding of local projects around the community. The projects are worth about 4 Furthermore, the next day after the attempted m NAD (approximately EUR 350 000 which visit to the smelter site, our host at the organ- DPM is distributing through the Community isation Earthlife received an anonymous email Trust Fund. explaining that Bankwatch has twisted the facts related to Dundee Precious Metals oper- From the Information Center we were ations in the past and that Earthlife Namibia directed to two relevant environmental should be careful about cooperating with experts in the smelter and this seemed like Bankwatch as this may hurt the reputation our last chance to meet someone from the of Earthlife. The letter ended with a melodra- smelter even though a site tour would not matic explanation about why the author has be possible. We arrived at the smelter front to remain anonymous. Of course such a letter oice and requested a meeting with staf of could be sent by anyone, including people the environmental department. Instead the who want to turn civil activist against DPM yet chief of security was called. strange letters are not unusual when activists Meeting (or rather not meeting) investigate DPM operations. He explained again that it was not possi- This email, as well as the comments on our the Namibian authorities ble to meet Mr Nolte and that most of the visit by Nikolay Hristov, are published in the environmental people in the smelter were Annexes at the end of this report. A very diferent question and the subject of not present but that he would make an at- major concern for society as a whole is why • Second e-mail request on 30.07.2015 tempt to arrange a meeting with the Public A decade of experience with DMP shows that public authorities have the same relex to hide followed by attempts at phone communica- Relations Department. After a quarter of the company is very open and proactive to and protect information connected to mining tion; an hour we were invited in and instead of maintain dialogue with NGOs for example and processing operations from the public being lead to the Public Relations desk we when it is opting for a loan from EBRD for who pays their salaries. • Three requests for a meeting and access to were brought into the room of the secu- example and is required to have proper public As stated in the Environmental Management information to the Secretary of the Environ- rity. The door was closed, the Chief Secu- hearings and demonstrate dialogue with civil Act 7/2007 of the Republic of Namibia in Art. mental Commissioner and mobile phone rity oicer stood behind his desk while a society. The company is also very open and 17 (g) and (h), the Environmental Commission- communication on 11, 12 and 13.08.2015. second security person stood to block the discursive about what it considers to be its er should maintain a register of the undertak- exit of the room. The Chief Security oicer good deeds and initiatives. It is quite diferent, en Environmental Assessments and the issued • Oicial e-mail request for a meeting and explained that after many phone calls to all however, when eforts at dialogue touch on Environmental Clearance Certiicates and “a access to information sent on 16.08.2015, the people in charge in Tsumeb, Bulgaria substantial issues such as social justice, tax copy of the record must be made available for followed by attempts at mobile phone com- and Canada he had to inform us that “…they issues, the byproducts of DPM’s operations, public inspection at the oice of the Environ- munication. know us very well”, that we cannot come to the lifecycle of products and byproducts, and mental Commissioner during oice hours” Art. the smelter without an appointment. the value chain. 38 (3). We have experienced many times the same administrative obstacles with the Bulgarian au- It was then explained to us that no meet- Generally this is not surprising behaviour for a thorities regarding mining projects, including ing would be happening and that he had mining company – they don’t appreciate prop- We were very disappointed that neither CEE DPM projects. In Bulgaria the issue was partial- received instructions to escort us out of er control because the nature of the business Bankwatch Network before and during the ly overcome by the obligation to publicise EIA the smelter area. He also asked us whether is such that any mining operation is diicult, if visit in Namibia, nor our Namibian colleagues decisions online. Sometimes the responsible we realised that currently we were on the not almost impossible, to comply with modern of Earthlife Namibia and the Legal Assistance authorities hold up the public release of cer- territory of the smelter and asked us if we environmental and social standards. This is Center were able to exercise their legal rights tain EIA decisions just to reduce the period for have been photographing around, and if he of course no reason to give up demands for despite numerous attempts to contact the En- Court appeal, which generally is 14 days after could check our footage. We denied access mining companies to constantly improve their vironmental Commissioner oice, namely: issuing the document, in this way impeding to our footage and then we were escort- standards. Moreover, it is urgent that govern- the public’s right to justice. Still we are ighting ed to our car and left to leave. This bitter ments and societies reconsider how much • Oicial e-mail request for a meeting and to impose the obligation to publish online the welcome to the smelter was far from the mining we actually need – the focus has to shift access to information sent on 24.03.2015 entire EIA documentation during the consul- claimed “…open, honest and transparent…” towards resource eiciency rather than con- to the e-mail addresses of Environmental tation process and keep it public after that. way of dealing with stakeholders. stant over-exploitation of new raw resources. Commissioner, Deputy Environmental Com- DPM has adopted this good practice with the missioner and Deputy Director of the Envi- Krumovgrad project, which is why it is disap- In further correspondence from October 2015 ronmental assessment department listed at pointing to see a regression in the company’s we were accused by the company of behav- the webpage of the Ministry of Environment standards regarding the project in Tsumeb. ing rudely with the security personnel, while and Tourism, followed by attempts for it should be visible from the videotapes that phone communication;

8 9 90 years of mining became a small hill that sift- is rapid at irst by excretion in the urine, but a The arsenic issue as the big white elephant ed its noxious contents over a radius of up to certain amount (30-40% in the case of repeat- 6km with every stir of the wind. On bad days, ed exposure) is incorporated into the bones, in the room everyone has a little cough, and one’s nostrils muscles, skin, hair and nails (all tissues rich in sting when passing downwind from the plant. keratin) and eliminated over a period of weeks Owing to the current lack of technical docu- this information vanished from the company’s or months.More on the health efects of arse- mentation and information on the smelter website, we were able to read the following: And then there is what DPM calls “a nuisance nic can be found at the end of this report. operations and technologies it is impossible factor” in a pamphlet in its press kit: the DPM started the export of the Chelopech to correctly assess the environmental and “Arsenic Plant venting of excess sulphuric gases in the early concentrate and processing thereof at the health impacts of the Tsumeb operations. We Concentrates and other secondary ma- evenings, clearly visible as a cloud against the Tsumeb smelter in 2007 when the facility was have had to add pieces to the puzzle through a lights of the now-heavily guarded premises still owned by Weatherly Mining Internation- check of some older documents and compare terial processed at the Tsumeb Smelter are traditionally relatively high in arsenic. where the wearing of full PPE (personal protec- al. Somewhere around 2008 the smelter was with new indings from our trip. 2 The arsenic passes through the smelter tive equipment) gear is obligatory.” working mostly with the Bulgarian concentrate Also, in the 2014 DPM Sustainability Report as the local mines were more or less liqui- Usually copper ore deposits are associated and is captured from the of-gases in the (p.63) it is stated: “After the copper concen- dated. Local experts explained to us that the with high arsenic content. The Chelopech ore baghouses. Baghouse dusts with high ar- trate has been smelted, the extracted arsenic smelter is designed to work with concentrate has one of the highest levels of arsenic content is classiied as hazardous waste”, and (p.61) “A with arsenic levels between 2.5 and 3%. This compared to other copper deposits worldwide. senic levels are used as feedstock into the by-product of extracting arsenic from concen- was achieved through blending the local con- This high content of arsenic and the associated arsenic plant. Baghouse dusts that can- trate is arsenic trioxide which is produced and centrates that were high in arsenic (the mines diiculties of the environmental management not be processed in the arsenic plant will sold by Tsumeb to customers in Malaysia and Knusib Springs and Tsumeb west mine 8% of this chemical element have lead to the strict be disposed of in the waste disposal site. South Africa.” arsenic) with concentrate low in arsenic from prohibition of this product being further treat- The arsenic plant is used to produce arse- Arsenic and the majority of its chemical the Kombat mine (0.39 % of arsenic). The im- ed in Bulgaria after a severe environmental products are not harmless. According to EU ported concentrate nearly triples those levels accident at the tailings dam of the copper nic trioxide from dusts recovered during Regulation, diarsenic trioxide is a category 1 and once the switch was done to the process- smelter of Pirdop in 1988. the smelting process. Four single hearth carcinogen and Substance of Very High Con- ing of higher arsenic containing concentrate, Godfrey roasters are used to convert the cern (SVHC) “that may have serious and often complaints from workers started pouring The estimations from the Chelopech EIA doc- material into arsenic trioxide, which is irreversible efects on human health and the in.Especially in 2010, widespread and serious umentation from 2008 show 5-6% of arsenic sold for the manufacture of pesticides environment”3. Being an amphoteric oxide health complaints from workers in the smelter content at the complex copper concentrate. the arsenic dioxide dissolves readily in alka- started. The issue was reported widely in the The same document evaluates the total re- and wood treatment.” line solutions and less so in acids. The arsenic national media4 and the scandal has grown to serve of arsenic at the deposit to be 99 446 t. As reported in New African Magazine in Janu- trioxide is readily absorbed by the digestive the point where the government has had to (the estimations were made in 2005). It is de- ary 2014: system: toxic efects are also well known upon intercede. scribed that only 0.05% of the arsenic is left in inhalation or upon skin contact. Elimination The basic reaction of the authorities was to the tailings of Chelopech (or about 50 t.) which “Following the US ban on arsenic in treating means that already for years and for years to wood in 2003, the market for arsenic has shrunk. DPM is thus stuck with excess produc- come around 100 000 tonnes of arsenic are 2 http://newafricanmagazine.com/tsumeb-is-dancing-with-wolves-namibia/#sthash.08qwXovb.dpuf - 3 and will be extracted, processed, stored and/ tion. According to the company’s public rela http://echa.europa.eu/documents/10162/13640/draft_axiv_bd_diarsenic_trioxide_20100701_en.pdf 4 or released in some form elsewhere around tions oicer, Jim Kastelic, DPM still supplies cli- http://www.thevillager.com.na/articles/93/-Tsumeb-copper-miners--sufer-from-arsenic--efects/ the world by the inal year of the mine which is ents in Italy and Malaysia, “but the market isn’t projected to be 2025. huge,” he said. As a result, DPM is now forced to store excess arsenic production on-site in a Currently half of the processed copper concen- specially-prepared pit, along with other haz- trate in Tsumeb comes from Chelopech, the ardous materials coming from the demolition of the former copper baghouse and packed in other half (so called third party concentrate) comes from other sources and one of them is large plastic bags normally used for the trans- the Peruvian mining company El Brocal whose portation of sugar. “A government-approved concentrate contains even more arsenic than storage site,” Kastelic assured this writer. the Chelopech concentrate. The new pit, lined with ive-centimetre-thick non-permeable liner, is however now much According to a presentation dating from closer and situated higher to the actual town. 2011 (“Cleaning the Air – Health And Envi- Although hidden behind the small ridge behind ronmental Management Improvements in Tsumeb, it is clearly visible with GoogleEarth the Tsumeb Smelter”, 12.09.2011, by Hans maps. A closer inspection revealed that many Nolte), the arsenic content in the copper bags, their plastic already ravaged by Namib- concentrate processed in Tsumeb smelter is ia’s relentless sun, have already started split- as high as 5.2%. The arsenic content in the ting open. Peruvian concentrate is stated to be 7.2%. It is however a major improvement on the pre- As an explanation of the arsenic facility, before vious method of disposal: an open pit that in

10 11 require the reduction by half of the quan- interviewed, no inancial compensation has posure and the conclusions are very clear: tities of the processed concentrate by the been granted to those people who sacri- “When assuming a linear dose–response smelter until improvements were in place iced their health without being informed relationship, a safe level for inhalation ex- (the production curtailment was lifted by the about the high risks they took while working posure cannot be recommended.”6 Further- Namibian government in December 2013). A for the smelter and especially after the in- more, “A safe level of arsenic in air cannot health study was conducted by the National troduction of the new concentrate with high be established,” and “No new tolerable Institute for Occupational Health of South arsenic content. The lack of proper inancial intake level could be established.”7. Africa supported by the Namibian Ministry of compensation made receiving systematic However, as well described in these guide- Environment and Tourism. The samples for medical treatment impossible. Workers lines, people working in or living around the study were taken in March and July 2013 claimed that health checks were done smelters, pesticides fabrics or wood treat- and the evaluation shows clearly high levels every two months during the time of the ment fabrics are the most afected and at of arsenic in the blood and the urine of the Ongopolo complex (the larger complex of the highest health risk. Numbers have to workers. The conclusions are: “Urinary arsenic mines and the smelter that existed before be disclosed and further in depth analysis levels were high showing widespread excessive Weatherly took over). Now health checks and tests of the population have to be per- absorption of arsenic. This problem is known are done every six months and workers do formed to present the real picture. to the NCS (Namibian Custom Smelter) man- not have access to their actual results when agement, workers and occupational health they want them – especially the urine tests. 3. Even if these measures result in better Smelter service providers”. They only get the oral opinion of the doctor health and environmental conditions by re- Another question mark hangs over the dou- that everything is OK. This issue was risen ducing the level of pollution, we don’t know bling of the smelter capacity: When the restric- before us by workers who quit or were the inal assessment since the capacity of tion on the quantities of the processed con- dismissed from the smelter in 2012 and the smelter has increased almost threefold centrate ended in December 2013, the capacity 2013. Not disclosing actual results with the to 198,000 tons of concentrate in 2014, thus of the plant was increased from 100-130,000 workers is against the law. inducing much bigger quantities of harmful tons of concentrate per year to 240,000 tons. It substances. is forecasted that this increase will soon reach 2. It is not clear what will be the positive ef- 260,000 tons per year (although DPM has fect of the undertaken measures. We don’t We have already shared our very raw report achieved only up to 200, 00 tonnes of actual know the efect of the individual protection with the EBRD – one of the creditors of DPM. processing of concentrates so far). How the measures since the company does not The EBRD claims its new loans for Dundee government permitted this increase without all publish regular studies about the arsenic explicitly exclude the Tsumeb smelter. the environmental improvements, considering levels in the urine of workers. Nor do we that this can only lead to increased levels of know the efect of the technological up- Yet normally the EBRD claims they help pro- pollution, remains a mystery to us. grades of the facility since there is no public vide improvements in the environmental During our visit in Tsumeb we conducted access to the Environmental Assessment of standards of those companies which are their several interviews with ex-workers afected those improvements nor the Environmental customers? Why does the EBRD keep a strict by the arsenic absorption and local activists Management Plan. We don’t even know if ring-fencing for a revolving credit to DPM? The campaigning for adequate health monitoring such documents exist. The advertising of a short reply we received from the EBRD is that and proper compensations. During the inter- “Fugitive Emissions Project”5 states that: “As it is satisied with the fact that the levels of views various evidence of illnesses and deaths a result of the FEP upgrades we have seen arsenic in the urine of the workers has been caused by arsenic were shared with us. These meaningful reductions in both inhalable dropping lately. This is not an appropriate people are still looking for legal assistance arsenic levels and arsenic in urine averag- answer – there should be a igure describing A r e which is crucial for the achievement of their es across the workforce. Average levels of the drop, from one igure to the latest igure, s it goals. these metrics are well within either rele- and a comparison with the pre-Dundee and en p s Meanwhile, in 2010, DPM acquired 100% of vant Namibian or international guidelines.” the pre-Chelopech ore situation. If a company ic dum NCS and started a programme for technolog- Furthermore: “Completing an engineering takes over in a bad situation, makes it worse ical improvement of the facility including the hazardous waste disposal site for the safe and then manages to get back to the bad introduction of proper individual protection disposal of baghouse dust and other waste situation, to claim this was an improvement is measures of the workers through personnel from the acid plant.” simply not acceptable. protective equipment. ential area We are highly sceptical about such PR tricks sid Special attention is required for the Re Despite these positive developments, and statements as arsenic, a category one issue of the arsenic dumping onsite. serious questions still remain carcinogen, does not have “relevant lev- els” or “international guidelines” on it. The The capacity of the arsenic plant is much small- unanswered: guidelines of World Health Organisation or the European Commission provide informa- er than the incoming quantities. Many appli- 1. Denial of social responsibility from tion about arsenic levels in air, water, food cations of arsenic related to wood treatment and agriculture are currently in a global phase Weatherly and DPM regarding the afected or soil under diferent circumstances and workers – some of those people died and out process due to rising health concerns what is recommend for diferent exposures, many others still need systematic medical but there are no safe levels of arsenic ex- about the arsenic compounds used in those treatment. According to the ex-workers we industries.

12 5 P. 54 of 2014 DPM Sustainability report 6 http://www.euro.who.int/__data/assets/pdf_ile/0005/74732/ 13 E71922.pdf?ua=1 7 http://www.who.int/ipcs/features/arsenic.pdf?ua=1 The dumpsite for the hazardous material processing of the smelter and how this its the (called, in a milder manner, “baghouse dusts” future plan to clean up the place. by the company) is illed at accelerated rates. Walvis Bay HarbourCity The dumpsite – from what was visible from Part of the arsenic is left at the ordinary tail- some distance – has a membrane insulation ings dam where it is “suppressed” by NaCl (salt) of the ground but no cover above. The former irrigation. We have to relate that the arsenic workers explained how the arsenic dust is trioxide is not the only product of the fabric, illed in nylon bags which probably are collect- but also the crude arsenic is a direct result of ed in the bigger bags visible in the picture. The the smelting process being released into the bigger bags are not made of special material working environment. Apart from the environ- – they all have the label “Hullets – White Sugar” mental and health issues caused by the arsenic and we learned that they are obtained from a dump, this activity also directly breaches the local warehouse. Constitution of the Republic of Namibia, Art. With great certainty we would allege that this is 95 on promotion of the welfare of the people not a proper toxic waste disposal site, neither through “…in particular, the Government shall could it be a long term solution for the disposal provide measures against the dumping or Coal of arsenic. There have been far too many cases recycling of foreign nuclear and toxic waste at of companies which simply desert a location Namibian territory”. leaving their toxic waste behind, so the Namib- ian government should not accept promises Furthermore, a very pressing concern is the for a solution in the distant future. A stricter simple fact that even this dumpsite is running Copper Concentrate and public arsenic management plan has to out of capacity. This is visible from the follow- be introduced. Further information is needed ing pictures – the dump site at the beginning of as to why the bags are buried in ash from the 2012, then in 2013, and now in 2015: Our question to DPM is simple: what is next? How does the company plan to treat the ar- senic once the space in the current dumpsite is exhausted. Considering the pace at which this site has been illed up, we would think the capacity will be fully utilized in less than one year’s time. If the DPM plans to turn Tsumeb Smelter into the preferred global plant for the treatment of complex concentrates, what is its long term strategy to treat such hazardous byproducts?

Storage and transportation of the concentrate Another questionable issue is the storage of the complex concentrate. The company 2011 - construction 2012 reports proudly the covered warehouses on Burgas port as an example of environmental responsibility, yet the same concentrate is stored in the Walvis Bay port in an open air warehouse – the Walvis Bay Bulk Terminal. The concentrate is placed right next to coal piles which security staf at the port said are also destined to go to the smelter in Tsumeb. During our visit in August we witnessed piles of concentrate exposed to the ocean winds. The workers were loading the concentrate and the coal onto rail wagons and trucks without wearing respirators or any other speciic indi- vidual protection gear. White piles were stored nearby and we were told that this was actually sea salt for export and for consumption. The Bay workers 2013 bulk terminal is just a few hundred metres 2015 away from a residential area. loading coal

14 15 The missing tonnage of arsenic Cases from the past where the words did In 2014 DPM processed 101,000 tons of copper 3,200 is exported to Malaysia and 600 tons concentrate from the Chelopech mine and go to South Africa. We believe this is purely a not match the reality 97,000 tons of concentrate from other sourc- PR statement which takes into account only es. The processing of roughly 100,000 tons of the reined arsenic trioxide produced in the During many years of work on and with DPM, er situations as with our input and request on 9 copper concentrate coming from the Chelo- arsenic plant of the Tsumeb smelter, which is we have noticed a number of signiicant the Krumovgrad EIA procedure , or the request pech mine and containing 5.2% of arsenic what the company considers a “marketable mismatches between the statements of the for information about the Tsumeb projects means 5,200 tons of crude arsenic per year. product”. The rest is mixed within the so-called company in the media and the reality in docu- – our recommendations are rejected as irrel- If this quantity oxidizes fully (in the furnaces, in-house dust or is emitted from the smelter as ments. evant, we are not an interested party on the along with the other ores) to arsenic trioxide, fugitive emissions. For example, we made a number of objections smelter project and we are not given access to the output mass of that by-product would be Our calculation takes into account only the when high level oicials of the company stated any documents. approximately 30% larger. This means that concentrate coming from Bulgaria and from in the media that the cyanide leaching facility Statements such as the following show clear- the Bulgarian concentrate alone might result Peru – an estimated 125,000 tons of concen- in Chelopech “will not have any harmful emis- ly that the Krumovgrad EIA report and the in quantities of arsenic trioxide of up to 6,800 trate altogether. Whatever other concentrate sions”. A more detailed look at the EIA or the granted national environmental permit were tons per year. is sourced, and no matter where it comes from IPPC documentation revealed that there will not in line with international good standards The concentrate that comes from Peru is to feed the annual processing of 200,000 tons be emissions of hydrogen cyanide – a poison- and one of the main reasons is the reluctance even dirtier – with arsenic content of 7.2%. If of concentrate for the smelter in Tsumeb, the ous compound, and a chemical weapon with of the company to apply our recommendation Tsumeb processes 25,000 tons from the Peru- remaining 70-75,000 tons can only further a grave record in the past (it was used in the provided during the oicial public consultation vian copper a year this is 1,800 tons of crude aggravate this number. German extermination camps during World procedure. arsenic or over 2,300 tons of arsenic trioxide if War II under the name Zyklon B). Indeed the this quantity is fully oxidized. This would make projected emissions were not huge quantities, “The European Bank for Reconstruction 9,100 tons of the highly toxic substance. but the company could not claim that there are no harmful emissions. and Development (“EBRD”) acts as en- This already does not match the recent state- vironmental agent with respect to the ment made by DPM in the Namibian press8 Cadmium We faced a similar situation in Tsumeb with where they claim that they produce 4,200 Twenty tons of cadmium are a the local newspaper “Etosha” from July with Company’s RCF. According to the EBRD’s tons of arsenic trioxide per year, out of which byproduct from the Chelopech the headline ‘Arsenic plant – GO’. The article is Environmental and Social Policy (2008), mine. It is not clearly stated in about the sulphuric acid plant which does not and it’s associated Performance Require- solve or impact the arsenic management issue. the reports what is happening ments (“PRs”), a project of this type and 8 ‘Namibia: We Spent N$5 Billion to Improve Enviro Controls – with this byproduct and how it Weather this is journalistic misinterpretation Dundee’, New Era, 25 November 2015, http://allafrica.com/sto- is managed. or misleading information coming from the PR scale requires a full Environmental and ries/201511251776.html department of the company, it is apparent that Social Impact Assessment (“ESIA”). The the locals are being left behind a curtain of dis- project underwent a national environ- information and the highly uncertain assump- mental impact assessment (“EIA”) in 2010 tion that the solution is just around the corner. The company’s strategy for public consulta- and an environmental permit No. 18-8, tions is being conducted in what we consider 11/2011 was issued and entered to force 10 000+ to be an extremely manipulative manner. in March 2013. Following an indepen- tons is the quantity of arsenic When the company needs NGOs to expose trioxide produced according to the dent review of the EIA reports, the EBRD high standards on transparency and open calculations of Bankwatch annually required a number of supplementary communication, as was the recent case of the public consultations on the application environmental and social studies and for a new loan to the EBRD regarding the documents to meet the EBRD PRs and Krumovgrad project, they are very willing to international good practices.” 10 spread and share documents, to refer to CEE 4200 Bankwatch member groups in Bulgaria – Za This enduring b17ehaviour shows that the tons is the quantity of Zemiata and CEIE – as interested parties, to company does know about standards on pub- arsenic trioxide produced invite us for meetings when polished presenta- lic information and consultation and uses them in the smelter annually tions are held and present the results in front when it is beneicial, but is not willing to adjust according to DPM of the bank. projects in line with civil society requests. Yet we encounter the opposite behavior in oth-

3800 9 Link to Krumovgrad article tons is the arsenic 10 Page 53 of 2014 DPM Annual report trioxide marketed to Malaysia and South Africa annually according the the statements of DPM

17 Last but Not Least! Comparing the company’s behaviour in terms between toxic and non-toxic forms of arsenic, of the transparency and cooperation experi- the report notes that 50 μg/g should not be enced in Bulgaria, in Namibia we have thus far used as a threshold without more detailed seen a drastic decline in corporate standards. tests, but that values above 100 μg/g “generally This is probably partially due to the lack of indicate excessive absorption of inorganic [i.e. systematic public monitoring from genuine toxic] arsenic (but may be explained by organic NGOs. Certainly the low institutional control [non-toxic] arsenic […]).” over the company’s operations is contributing to the problem generally. Namibia is a young Whichever one of these levels is being con- Export Processing Zone (EPZ) democracy, governance is sufering from a lack sulted, the Tsumeb smelter workers average of proper standards and laws that are not yet arsenic concentration was by far higher than In 1995, the Government of the Republic of in place and in cases there are evidences for any level that could be deemed safe. 1082 Namibia adopted the Export Processing Zones Proponents of tax competition have never the presence of double standards in relation DPM employees at the time, urinary arsenic (EPZ) Act (Act No. 9 of 1995) as a legal frame- answered the crucial question of how far it to extractive industries and other industrial levels of above 300 μg/g were measured in work for promoting export-led industrialisation should be allowed to go before it compromises projects which is still to be properly tackled. all sections of the smelter except the Slagmill. of the extremely primary sector-driven nation- the functioning of a viable and equitable tax 69% of the people tested exceeded the level al economy. EPZ enterprises are exempted regime. Taken to its logical extreme, unregulat- DPM might not disclose fully the amount of of 100 μg/g. The most afected 3.5% of cases from: ed tax competition will inevitably lead to a race arsenic trioxide produced in the smelter annu- even reached levels between 507 and 1357 to the bottom, meaning that ally. However the very simple math behind our μg/g. As a reference value for over-exposure Corporate income tax; governments will be forced to cut tax rates on calculations shows it is very likely that there the report uses the Biological Exposure Indi- Duties and value-added tax (VAT) on machin- corporate proits to zero and subsidise those is much more left behind compared to the ces (BEI) set by diferent institutions. A BEI is a ery, equipment and raw materials imported companies choosing to invest in their coun- oicially stated by the company spokesperson reference for recommended concentrations of into Namibia for manufacturing purposes. tries. Alina Garisses. hazardous substances. As the report notes, the South African BEI (deined by the Department The only taxes payable are the individual This is already happening in some countries. The health tests of current and former work- of Labour) lies at 50 μg/g. Most other industrial income taxes on employees’ income as well as The implications of this for tax regimes and ers in the smelter from 2012 tested over 1700 standards are signiicantly lower. the 10% withholding tax (non-resident share- democratic forms of government around people. Since basic urine tests don’t distinguish holders) on declared dividends. the world are dire. Indeed, this is one of the In addition, EPZ enterprises are allowed to biggest threats to freedom the world may hold foreign currency accounts at commercial now face. The problems that capital light, tax banks in order to repatriate their capital and avoidance and tax competition pose for poorer Pictures from the Namibian proits. countries have been exacerbated by what press from 2012 spreading the appears to have been a failure on the part of word of the whistle blowers in The Tsumeb smelter operates as an EPZ multilateral Tsumeb enterprise, as deined by Namibia’s EPZ Act, institutions to protect the tax regimes of devel- and therefore does not pay corporation tax in oping countries when promoting trade liberali- Namibia. sation policies.

Legal issues related to tax are increasingly Faced with dramatic falls in their tax incomes, being discussed and diferent measures to governments have responded by raising VAT overcome tax injustice are being undertaken rates and globally. generally shifting the tax burden onto poorer Faced with the pressures of globalised capital and middle income households. The process movements and loudly voiced threats from has accelerated since 2008, with disturbing corporations that they will relocate unless giv- implications for inequality and social stability. en concessions on ‘light-touch’ regulation and lower taxes, governments around the world According to the Economic Policy Institute in its have responded by engaging in tax competi- book Rethinking Growth Strategies, “If coun- tion to attract and retain investment capital. tries are to beneit from globalisation, govern- Some states with limited economic options ments must regain the capacity to tax their have made tax competition a central part of citizens as well as businesses operating within their development strategy. This inevitably their borders, and to use the revenues to undermines the growth prospects of other inance infrastructure, essential public services countries, as investments are attracted away and necessary wealth redistribution.” from them, and has stimulated a race to the bottom.

18 19 In the Republikein newspaper, DPM claimed parts and upgrades of the smelter – namely in early December that the exposure to inhal- acid plant and the waste water treatment able arsenic has been reduced by half in 2014. plant – but we get no clarity whether there These claims have so far not been substantiat- are documents tackling the sensitive topic on ed with publicly available documents, let alone arsenic. Moreover there seems to be no overall with results from new health tests. But even if environmental impact assessment of a smelt- such reductions were achieved and efective, er which is functioning at more than doubled Sollutions And Roles: almost one third of the workforce would still capacity in the last 6 years and processing be above the critical level of 100 μg/g. [1] more that twice dirtier copper concentrates Considering the speciic case of Tsumeb we recommend the diferent compared to the past. We remind that it is a stakeholders to undertake actions in the name of the public health and The 2013 preliminary health report states standard to make a new environmental impact the sound environmental future of Tsumeb and the region. several times that more detailed analysis will assessment when big changes are introduces be presented in a inal report. If DPM’s claims and doubling the capacity with all the required about its success in reducing arsenic pollu- upgrades is undoubtedly a serious change. tion are supported by this report, why is it not Dundee Precious Metals should: being made public? Does such a report exist at all? The people in Tsumeb that we interviewed Disclose all available environmental docu- Consider disaster management plan in case during our visit had not seen or heard of it. mentation on the smelter in Tsumeb of emergency related to the dump-site and other severe event that might afect Tsumeb The company has failed in its social responsi- Disclose the real quantity of arsenic trioxide and the region bility to seriously afected workers and refused left on spot in Tsumeb proper inancial compensation which would Agree with the government what would be allow appropriate medical treatment for these Consider the long term management of the required and whose responsibility it would people. The proper care of afected workers is quantities of arsenic trioxide produce, the be to maintain the dump-site in case of required by law even when health conditions lifespan of the dump-site, cases of severe change of ownership of the smelter or fail- are inherited from work for previous operators disaster (include unusual climate events ure of DMP in Namibia or globally – a change of ownership cannot be used as an that happen much more often nowadays excuse to deny workers proper treatment for with the climate change compared to the Accelerate and tighten the standards on the conditions which are derived from the hazard- usual consideration of the engineers of such loading and unloading at Walvis Bay bulk ous environment in the smelter. It is disap- facilities) terminal pointing that instead the company prefers to disburse money to the community through its Community Trust which, as such instruments in Chelopech, Krumovgrad and Tsumeb at the national level have shown, are tools to gain Namibian Government some public sympathy and exercise economic inluence over local authorities, small business- Transparency is issue Number One that de- tal and health price from the moment of it’s es. serve change in the attitude of the Namibian launch in the 70s. It is unrealistinc to think that Government. Secrecy when in comes to public the smelter will be there forever to provide European Bank For Reconstructions and health is unacceptable. We have been very the daily bread in Tsumeb and the region. The Development has failed to consider the life-cy- disappointed that the Government does not government has to assist the local commu- cle of the raw material produced by Dundee follow the legislation in the country on what nity in their search of economic alternatives. Precious Metals. “Environmental Impact should be public domain. Bankwatch is ready A programme for diversiication of the local Assessments (EIAs) have been completed by to take the issue of non-disclosure to court. economy of Tsumeb and the region should be DPM as required by Namibian legislation for a at place including micro-grant schemes, start- number of infrastructure upgrades including The government of Namibia has to quickly up schemes for the take of of small business the acid plant and the waste water treatment and urgently reconsider the Export Processing initiatives and cooperatives, education, train- plant. These have followed the EIA process Zone regime of the smelter in Tsumeb. Na- ings and skill-sharing in the ields of entre- as required in Namibia, which includes pub- mibia is the country where the biggest envi- preneurship and business management, local lic participation. A new site-wide EIA will be ronmental heritage of the processing of the economy, business cooperation between small undertaken this year and will also be subject poisonous copper concentrates is happening scale businesses. to public consultation and authority review. All and in the same time it seems that the country completed EIAs are lodged with the Ministry of is getting the lowest share. The bet on public The Government has to intensify the control Environmental Afairs and Tourism. We un- health and the environment is too high with over the freight procedures and practices of derstand that the EIAs can be requested from all the quantities of arsenic trioxide left behind Dundee Precious Metals – this includes the so the Republic of Namibia should not accept loading and unloading of concentrates and this authority.” The way we understand this Pictures of workers from the Tsumeb Smelter peanuts for this sacriice. coal at Walvis Bay bulk terminal and the road response of EBRD means there are envi- with severe skin rushes and the prescribed and rail transportation of concentrate, coal ronmental impact assessments only on certain medical treatment The smelter is accumulating high environmen- and processing by products from the smelter.

20 21 Municipality of Tsumeb

Consider and introduce to the local community municipality has no inluence and power to ex- emergency plan in case of unexpected disas- ercise any control over the doings of the smelt- ter related to release of arsenic trioxide from er and the municipal experts admit that “it is the dump-site; Assess the potential impact all in the hands of the central government” on underground waters as the hydrological - this power balance have to change in favor of Global view on the industry: and geological structure of the region is very the municipality and the citizens of Tsumeb complex and connected through underground We need a solution – a profound change in the way extractivism is complex of long cavers; The municipality together with the citizens of making business and in the way we as mankind produce and consume Tsumeb have to develop and maintain their resources. There has to be more serious set of international framework The Municipality of Tsumeb has to broaden the own environmental monitoring on the main and practices tackling the endless growth and expansion appetite of the involvement of the local community into the pollutants related to the operations of the extractive industries. issues related to the control over the following Tsumeb smelter. The laboratory should be ma- of environmental, social and health standards nipulation proven and open for control from by the operator of the smelter. Currently the the active citizens of Tsumeb. Our pledge to the investors: Do not invest in that fail painfully with such task ending with gold and other precious metals, divest or in the introduction of hateful regimes and even certain cases remain cautious investor. Most more severe double standards and even worse EBRD of the mined gold rests in treasuries – this social and environmental disasters. This is the accounts for up to 70% of the mined gold. It is reason why such ideas have to be considered The role of European bank Of Reconstruction on Namibian territory or if the the deiciencies just an investment a commodity which many very carefully. As a minimum though the full and Development is to put is softly – crucial. are too big and there is no way the long term people consider a safe thing to put their mon- social and environmental price of extractive First of all EBRD is responsible for the mess management of the pollution is not possible, ey into but gold has been considered a new and processing projects should be completely caused in Tsumeb and should demand mitiga- or the conclusion is that just the business od investment bubble by many economists in the disclosed to the local communities and local tion measures for the long term management DPM cannot be sustainable and is not sustain- recent years. Rising the prices of gold due to communities should be empowered and their of the pollutants produced due to the support able by deinition, then EBRD should recon- high demand also makes feasible to use more right to ight-back and reject such projects on for the operations of the Bulgarian mine. sider their credit facility. EBRD should already complex and risky mining techniques or serves their territory should be respected. reconsider any funding for the development of as an incentive for proit driven companies EBRD has to demand transparency from DPM greenield projects by DPM such as the project to do their best to put the dirt of gold min- International Financial Institutions such as and disclosure of the relevant environmen- in Krumovgrad. ing under the carpet. Nowadays gold doesn’t EBRD have to consider and accept change in tal documentation. If there is lack of certain get sifted by hand in the rivers as in the past. their investment policy. They have to consid- documents and overall EIA of the increased EBRD should reconsider funding for greenield Companies are often lucky to get 5 g of gold er the entire life-cycle of materials that are capacity and pollution from the smelter EBRD mining and progress to totally avoid support- per ton of rock. It is estimated that on average extracted and processed and drift away from is in the best position as EU public institution ing of greenield mining. We would say this 520 000 t of rock have to be crushed to extract investments in greenield mining and other to demand the deiciencies to be compensated change should have been introduced with the a ton of gold. In comparison a ton of steel is investments that serve greenield mining in a timely manner; last changes of the EBRD investment policy produces from 10 t of iron ore. It is true that projects such as processing plants. The entire – but the best moment is the next planned we use gold and other rare earths in electron- public portfolios have to be focused on sup- If there is evidence that DPM have downgrad- changes and the sooner the better ics and all those technologies have become an port of game changing projects – exclusively ed the quantities of arsenic trioxide dumped integral part of our lives but is recycled most of sustainable business which includes resource the gold and resources can be retrieved from eiciency, transition to renewable energy and the e-waste of the electronics. Counting on sustainable farming. resource eiciency more then on extractivism is a bright vision for the future but it requires Consumers should have the right to know Citizens of Tsumeb and NGOs in Namibia tackling serious challenges which have creat- what stands behind the products they buy ed social collisions in the past. The modern – labeling products that come from recycled Should demand rights to more active involve- the municipality do not take action on that. economy counts on surpluses and constant sources or indicating what is left behind the ment from their municipality and should unite supply of raw material to the markets. If the contents of a product is important and should and work together so that they are not the People and NGOs should never swallow the extraction of raw materials stops this will make become standard practice. The practice of lonely victims of the most important economic cases of deteriorated health due to the work the materials inite to the economy, it will also labelling energy class of consumer products player in the region of the smelter – check and cross-check with open the possibility for investors to buy large proved very successful in Europe and should independent doctors, if necessary seek for quantities in order to speculate and rise the be translated to other ields of our consump- Look for ways to diversify the local economy the help of legal assistance from Namibian or prices tremendously. Closing this loopholes tion of resources. After all consumers have the through community initiatives so that DPM is international NGOs globally has been a challenge in many other right to know what results in their consump- no longer the main source of money for the areas. Considering that putting extractive in- tion and consumers choice has always been city – such as cooperatives, craftworks Cross check and demand regular access to dustries on halt means introducing of planned the biggest game changer. information from the Namibian Government economy to certain areas of the economic consumers choice has always been the biggest Consider their own emergency plan for arsenic on the above-listed issues life. And the past and the present are full of game changer. disaster especially if DPM, the Government of examples of wanna-be-socialist government

22 23 Human stories Annex 1 – Arsenic and arsenic trioxide: behind the Tsumeb smelter the king of poisons and the poison of kings

What people in Tsumeb should know about arsenic trioxide Meet Oscar Kakungha - He is a 34 years old man who used to work for DPM in Tsumeb Please, check whether there are plans in the The fatal human dose for ingested arse- until 2nd March 2015 (suspended from the municipality in case of accident related to spill nic trioxide is 70 to 180 milligrams (mg) or smelter already in October 2014). According to of arsenic trioxide power and contamination about 600 micrograms per kilograms (kg)/ his story the problems in the smelter started of ground waters. These plans should be pub- day [ATSDR 2007]. This means that one gram back around 2008 with the irst material [con- lic and people should be aware of the danger, of arsenic trioxide may kill between 6 and 14 centrate] coming from the mine in Chelopech, the risk and how they are supposed to react people. A ton of the compound is enough to Bulgaria. Initially the material was blended in case of emergency to protect themselves kill 6 to 14 million people. Even an average of with the local extracted ore from Otjihase and the others. Be aware it is not enough if that is roughly the Bulgarian and the Namib- mine, Tsumeb west mine, Kombat mine and the municipality of the company answer that ian population combined. If the initial data Tchudi mine. When the Chelopech concen- there are plans – they need to be public and that before the changes in the ownership the trate was initially introduced the treat was not deinitely not kept secret if they are request- smelter produced 300 tons of arsenic trioxide immediately felt as the material was blended ed by the citizens. per month and the smelter now uses twice as with the local concentrate. The former own- Workers should always ask about the actual dirty concentrate and has more than doubled er of the mining complex and the smelter, medical data – especially related to the ar- the production capacity then the amount is Weatherly International, closed the mines with senic levels in urine. No such data should be monstrous – more than 1000 tons per month. the onset of the inancial crisis. In 2010 DPM kept hidden from workers. took over the smelter. The problems with the http://www.pesticideinfo.org/Detail_Chemical. working conditions in the plant became severe. http://www.atsdr.cdc.gov/csem/csem.as- jsp?Rec_Id=PC33821 The Mineworkers Union of Namibia (MUN) was p?csem=1&po=12 afraid to voice concerns and Oscar suspects former employees of the smelter. they never reported the issues to the govern- DMP strictly prohibits cell phones and cameras ment. In 2012 Oscar was elected as secretary on the territory of their operations. Oscar took People in Tsumeb should be aware • Paresthesia (feeling of numbness, tingling, of the local branch of MUN. He insisted on an footage of DMP’s arsenic dump-site and used of the symptoms of poisoning with burning in diferent parts of the body such inspection from the Headquarters of MUN – this to signal to the government the arsenic arsenical compounds: ingers, hands, toes, or feet) they came and went back with no follow up. problem which was piling up in Tsumeb. The • Paresis (partial motor paralysis) Oscar alerted SWAPO Youth League and the government did not respond to Oscar, instead • Ataxia (lack of voluntary coordination of • Garlic odour of breath and faeces, metallic Namibian Union of Workers. The pressure on he was suspended as an employee of the muscle movements that includes gait ab- taste in mouth. the government increased and a health check smelter in October 2014 and ired in March normality. It is implying dysfunction of the • Adverse GI efects predominate with vom- was organised and included 1722 current and 2015. He remains unemployed to date. parts of the nervous system that coordinate iting, abdominal pain and rice-water or movement). bloody diarrhea. GI efects may also include • Inability to coordinate voluntary muscular inlammation, vesicle formation and even- movements. tual sloughing of the mucosa in the mouth, • Subcutaneous edema in face, eyelids, and pharynx and esophagus. Johannes Amutenya is now 30 years old. ankles (abnormally large luid volume • Central nervous system efects are com- He used to work in the Tsumeb smelter for a resulting in mild to severe swelling in these mon: headache, dizziness, drowsiness and relatively short time. When DPM took over the parts of the body). confusion. smelter the issues with the newly introduced • Stomatitis (inlamed and sore mouth which • Symptoms may progress to include muscle concentrates became severe. The health tests can lead to disruption of a person’s ability weakness and spasms, hypothermia, lethar- that used to be done every two months be- to eat, talk, and sleep) gy, delirium, coma and convulsions. Chronic fore were now scheduled only twice a year. • White striations across the nails (called exposure to inorganic arsenic compounds Johannes was not allowed to have his actual Mees lines) and sometimes loss of nails or may lead to: health results – the doctor was ensuring him hair. • Muscle weakness, fatigue, anorexia, weight that everything was OK. Johannes decided to • Liver problems resulting in hepatomegaly loss. have an independent health check with a doc- (is swelling of the liver beyond its normal • Hyperpigmentation (spots on the skin), hy- tor from South Africa. When he got his tests size.), icterus (a yellowish pigmentation of perkeratosis (top layer os the skin dies out done with an x-ray of the lungs, the doctor the skin and the whites of the eyes by high and peals, skin rush) pointed to a shadow on the x-ray picture and blood bilirubin levels.), cirrhosis (a condition • Peripheral neuropathy (weakness, numb- told him, “You are too young to kill yourself in which the liver does not function proper- ness and pain, usually in your hands and with that job.” Johannes quit in 2011. ly due to long-term damage). feet but also afect other areas of the body.) • Renal toxicity leading to oliguria (low output

24 25 of urine), proteinuria (excess of serum • Injury to blood-forming tissues may cause proteins in the urine - the urine becomes anemia (decrease in the amount of red Peruvian copper foamy), pneumaturia (air bubbles in the blood cells (RBCs) or hemoglobin in the urine), and hematuria (blood in the urine). blood which results lowered ability of the The copper that feeds into the smelter of All those might be a sign for a kidney stone blood to carry oxygen where the feeling of Tsumeb seems to be the second biggest or a tumor in the urinary tract. fatigue comes from as a symptom), leu- source of business for the smelter. Dirtier than • Heart problems - EKG abnormalities (irreg- copenia (decrease in the number of white the Bulgarian copper concetrate it also attract- ular heart beat - arrhythmia) and peripheral blood cells (leukocytes) found in the blood, ed our attention. vascular disease (PVD - circulation disorders which places individuals at increased risk of The Peruvian copper smelted at Tsumeb that afect blood vessels distant from the diferent kinds of infections as the body has comes from a deposit operated by Sociedad heart - veins and arteries that supply the lowered ability to confront the microbes Minera El Brocal S.A.A. arms, legs, and organs located below your that enter it) and thrombocytopenia (rela- Sociedad Minera El Brocal S.A.A. is a subsidiary 11 stomach) tive decrease of thrombocytes – the blood of Minas Buenaventura public limited compa- • Hematologic abnormalities (disorders which cells that help the injurees to stop bleeding ny incorporated in Peru. primarily afect the blood). and close). El Brocal company operates the Colquijirca • Cardiovascular efects include shock, cyano- • Cancer – arsenic exposure causes cancer. mine which consists of three polymetallic sis (appearance of a blue or purple color- Cancer rates have to be followed in the re- deposits: ation of the skin or mucous membranes gion of exposure to check whether the rate the Tajo Norte deposit, which contains zinc, due to the tissues near the skin surface is higher compared to the national average silver and lead ore; having low oxygen saturation). the Marcapunta deposit, which contains an auriferous mineralization in breccia oxides, a nonarsenic copper chalcosite mineralization, and an arsenic copper enargite mineralization as a continuation of the mineralized mantles of the Marcapunta Norte; and the San Gregorio deposit, which contains zinc. Source: El Brocal’s 2014 Annual report12 Colquijirca mine

NOTE! PREVENT DISPERSION OF DUST! AVOID General First Aid: IN ALL CASES CONSULT A ALL CONTACT! AVOID EXPOSURE OF (PREGNANT) DOCTOR! WOMEN! Tsumeb smelter products / Source: DPM / Route of Symptoms First Aid Exposure DPMT contracted 300,000 tons of complex copper concentrates with third Inhalation Burning sensation. Cough. Dizziness. Fresh air rest. Refer for medical party suppliers, via LDC, in 2014. The third party concentrates will be de- Headache. Shortness of breath. Sore throat. attention. livered to Namibia alongside Chelopech copper concentrates for smelting Weakness. Chest pain. Symptoms may be at the Tsumeb facility. delayed (see Notes). (See Ingestion). Currently, half of the smelter’s business comes from Dundee’s Chelo- Skin Dry skin. Redness. Skin burns. Pain. Blisters. Remove contaminated clothes. pech mine in Bulgaria. Additional business is solicited from Peru, Greece, Rinse and then wash skin with Russia, Poland and various African countries, such as Botswana and the water and soap. Refer for medical Democratic Republic of Congo. attention. Eyes Redness. Pain. Severe deep burns. Conjunc- First rinse with plenty of water for Final product from smelting: tivitis. several minutes (remove contact lenses if easily possible) then take 1. Blister copper (partly puriied porous copper with a blistered sur- to a doctor. face formed during smelting), some sources say that blister copper is nearly pure containing between 98.5 and 99.5 percent copper and up Ingestion Abdominal cramps. Abdominal pain. Burn- Rinse mouth. Induce vomiting to 0.8 percent oxygen.13 ing sensation. Diarrhoea. Nausea. Vomiting. (ONLY IN CONSCIOUS PERSONS!). Muscular cramps. Shock. Death. Rest. Refer for medical attention. 2. Arsenic trioxide (As2O3) Notes Physical properties depend on crystalline form of the substance. Depending for ICSC on the degree of exposure periodic medical examination is indicated. Speciic Information treatment is necessary in case of poisoning with this substance; the appropri- 11 http://www.buenaventura.com/ Buenaventura is Peru’s largest publicly-traded precious metals company and a major holder of mining ate means with instructions must be available. The symptoms of acute poison- rights in Peru. The company is engaged in the mining, processing, development and exploration of gold, silver and other metals via whol- ly-owned mines, as well as through its participation in joint exploration projects. Buenaventura is the operator of several mines in Peru. ing appear ½ to 1 hour after the exposure but may be delayed many hours. No Wholly owned: Orcopampa, Uchucchacua, Julcani, Mallay y Breapampa. Controlling interest: La Zanja, Tantahuatay y El Brocal. Buenaventu- odour warning if toxic concentrations are present. Do NOT take working clothes ra has minority interests in other mining companies: Yanacocha (43.65%), one of the most important gold mines in Latin America, in part- nership with Newmont Mining. Cerro Verde (19.6%), an important Peruvian copper producer operated by Freeport McMoran. The company home. The recommendations on this Card also apply to inorganic trivalent has been listed on the Lima Stock Exchange since 1971, and on the New York Stock Exchange since 1996. Buenaventura is an open stock arsenic compounds (arsenites). company incorporated under the laws of Peru, and was originally established in 1953 as a company (sociedad anónima). 12 See: http://www.bvl.com.pe/inf_corporativa61700_QlJPQ0FMQzE.html 13 See: https://www.britannica.com/technology/blister-copper

26 27 Authors Daniel Popov Genady Kondarev Bertchen Kohrs Fidanka Bacheva-MacGrath

CEE Bankwatch Network, Earthlife Namibia and Za Zemiata – Friends Of The Earth Bulgaria, 2016