The case for a reclamation designer of record Straker, J.; McKenna, G.
The term “engineer of record” (EOR) refers to the engineer responsible for design and construction of a project. Use of an EOR has spread to tailings storage facilities (TSFs). The 2014 failure of the Mount Polley TSF resulted in reviews and adjustment to practice at the site, provincial, national, and international levels. In 2017, the Mining Association of Canada released its third edition of A Guide to the Management of Tailings Facilities, which introduced the concept of designation of EORs for TSFs to verify that facilities have been designed to applicable objectives, guidelines, standards, and legal requirements, and constructed throughout their lifecycles in accordance with the design intent and performance objectives. This adoption of the EOR model for TSFs is due to the occurrence of high-profile/high-consequence TSF failures. However, this application is complex, in that TSFs are often built over many decades, have many phases (e.g., ongoing construction, operations, and closure), and have many opportunities for construction and operations to deviate from design. We argue the need for a parallel adoption of a “reclamation designer of record” (RDOR) for reclamation of mine sites or individual facilities within mine sites. Although reclamation “failure” is not associated with the high-consequence off-site/downstream effects of TSF failures, there are significant public commitments by government and industry related to reclamation, and reclamation liabilities are generally substantial and growing. Reclamation projects share many of the complexities of TSFs, e.g., they are conducted over decades, are first designed during permitting but are completed during operations and closure, and require change-management processes to adjust for operations deviating from designs. The RDOR would be employed or retained by mine operators and have the authority and accountability to design a reclamation project to applicable objectives and requirements, and to provide oversight to ensure that project completion conforms to design intent.
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