Creating a Credible Mine Closure Plan Guided by TSM, GISTM, CMSI, and ICMM Frameworks

As mine planners and closure practitioners, a challenge we often see is the application of multiple standards and frameworks across site operations. A site may be reporting under the Mining Association of Canada’s Towards Sustainable Mining (TSM), working toward conformance with the Global Industry Standard on Tailings Management (GISTM), and referencing the International Council on Mining and Metals (ICMM) Integrated Mine Closure principles, all while trying to answer fundamental community questions about what the land will become after mining ends. The Consolidated Mining Standard Initiative (CMSI) is working to address this by bringing together the aforementioned frameworks into a single global standard (CMSI, 2026).

In our experience, when operators try to satisfy overlapping standards, they generate large volumes of documentation but may still struggle to meet the competing priorities of regulators, communities, and investors. We know each standard is strong, but how do we address the challenge of bringing them together at the site level?

In this month’s Conversation on Closure, we explore how to navigate the gaps and overlaps among CMSI, TSM, GISTM, and ICMM guidance and standards to create an integrated mine closure framework anchored in a clear closure vision, adaptive risk-based management, and independent technical reviews. This approach helps operators move beyond compliance toward a credible and transitional process that regulators, rightsholders, community members, and investors can understand and trust.

The Standards Landscape for Mine Closure Planning

The industry developed each standard to meet a shared set of concerns, including:

eroding community trust (the result of major tailings failures);
rising investor expectations for responsible mining performance;
growing community pressure for transparent mine and closure planning; and
planning for post-mining land use (PMLU) that respects local values and desires.

At their core, each framework shares the intent to prevent catastrophic failures, support the long-term stability of landforms and water systems, and promote transparency regarding closure responsibilities and costs.

Earlier this year, one of our articles, Collaboration for Critical Minerals, explored how the principles of each framework support the responsible production of critical minerals. As we experience the increasing need for critical metals and minerals, the points of convergence across TSM, GISTM, ICMM, and CMSI are significant and crucial to meeting the driving forces of social license to operate. This includes:

early and ongoing closure planning;
clear governance and accountability;
integrated risk assessment and adaptive management; and
transparent roles for independent review and stakeholder engagement.

Different terminology for similar concepts, or overlapping standards in reporting or assurance requirements, contribute to the challenges operators often face when navigating differing guidance between standards. Since closure planning typically requires interdisciplinary collaboration among the operator’s environment, tailings management, operations, legal, and community engagement teams, different disciplines may map these obligations related to CMSI, TSM, GISTM, and ICMM separately, resulting in duplication of efforts.

Gap analyses and action lists can remain as standalone documents that sit alongside, rather than within, core planning processes. As a result, teams sometimes treat actions as responses to individual findings and occurrences rather than explicitly linking them to a single, comprehensive plan.

We often see that the operator’s internal teams work in the language of standards and technical requirements, while the people most affected by the operations and closure focus on practical and effective outcomes, such as what the land will be used for, who will pay for it, and who will look after it long after closure of the mining operations. Despite completion of formal checklists, without a clear closure narrative, building and maintaining trust can remain challenging.

Creating a Shared Closure Vision

Closure vision is a shared understanding built from interdisciplinary teams that answers three questions with the future in mind:

What will this land be used for?
How will it be kept safe and stable?
How will it fit into the surrounding community once mining ends?

By deliberately focusing on outcomes that people can relate to rather than on technical details, we can prioritize transparency about what is known, what is uncertain, and how decisions and management will be revisited and reiterated over time.

For example, to support closure planning for a site in British Columbia, Canada, we developed the closure vision through a series of workshops and technical reviews that brought together ecologists, local residents, Indigenous rightsholders, and engineers. Together, we identified a PMLU that incorporated traditional uses, established a revegetation plan to support these uses, and developed an early conceptual governance structure to keep the community informed and involved as conditions were monitored and evolved over time.

The closure vision serves as the anchor that aligns multiple frameworks, strategies, and disciplines into a single, consistent storyline.

Early-stage site assessments should prioritize closure as an integrated process rather than a compliance exercise. In our experience, closure intent often exists implicitly within design assumptions, risk registers, or failure modes and effects analysis (FMEA) assessments. The common gap is the lack of an articulated shared vision.

A well-framed shared closure vision is reflected in a common understanding of what the site will become after mining. This guides an integrated approach to post-mining land use, design assumptions for managing tailings and mine rock, ecological completion criteria, and long-term water management objectives.

In a technical paper published through the British Columbia Technical and Research Committee on Reclamation, Okane supported Skeena Resources at the Eskay Creek Project to co-develop a mine closure and progressive reclamation strategy with the Tahltan Nation (Baisley et al., 2023). Our collaborative approach helped strengthen the closure concept by grounding design decisions in climate change resilience, ecosystem function, and understanding of long-term traditional land use.

The input we received directly informed revegetation prescriptions that recognize climate change, plant communities, and key species for wildlife at distinct life stages. Our collaboration with the Tahltan Nation also informed successional pathways and soil stabilization to better support resilient plant communities and long-term land-use objectives.

The approach we took demonstrated effective closure planning by integrating rightsholders’ aspirations into tangible design choices, supporting the process with visual tools and clear alternatives, and formally tracking and revisiting feedback as the closure design evolved, allowing participants to see how their input influenced outcomes.

On a separate project in British Columbia, we collaborated with Indigenous rightsholders, community members, regulators, and site operators to develop a co-designed vision for reclamation and land use. We gathered each perspective and concern, and translated them into aspects of a closure vision that define a positive outcome. Our team compiled practical, measurable mine closure goals and objectives that considered Indigenous rightsholder land stewardship principles and the local health and safety regulatory code.

Adaptive Management and Strategic Risk Assessment

Site efficacy rises when operators approach TSM, GISTM, CMSI, and ICMM as different lenses on similar risks. Instead of maintaining separate workstreams, teams work together to map to a single closure risk framework that links governance, technical risk, monitoring, and engagement. This strategy allows assurance activities, independent review, and reporting to reinforce one another rather than duplicating efforts.

When developing or refining closure risk registers, it’s important to consider risks that extend beyond physical risks, including:

long-term landform performance;
water quality and quantity;
climate resilience;
post-mining land use considerations;
regulatory approvals; and
financial exposure.

Capturing these aspects together helps minimize situations in which technically stable designs struggle to meet social, environmental, or regulatory expectations.

For several projects Okane has worked on, monitoring data, particularly related to water quality trends or landform performance, has prompted adjustments to cover designs, drainage controls, or closure sequencing.

For more on how monitoring plans, adaptive management, and trigger action response plans work together, see our Conversation on Closure regarding Adaptive Management Frameworks for Integrated Mine Closure.

Okane’s Approach

At Okane, we collaborate closely with our clients, regulators, and community members to develop a responsible, credible, and executable closure plan that adheres to the TSM, GISTM, CMSI, and ICMM frameworks.

For regulators, credibility comes from a clear line of sight between closure objectives, design criteria, risk assessment, monitoring programs, and adaptive management triggers. The closure process needs to demonstrate how we actively manage uncertainty and verify performance over time.

For communities, we adapt that same process by focusing on practical outcomes, such as what preparing for successful closure looks like, how we manage risks day-to-day, and how responsibilities for residual risks could transition after mining.

For investors, we find that clear explanations of how closure risks are identified, monitored, and actively managed over time resonate most strongly. By tying closure liabilities to defined design assumptions, monitoring programs, and adaptive management triggers, we demonstrate that these risks are understood, tracked, and actively managed, rather than deferred uncertainties.

We build trust when we translate the required standards into a coherent closure story, backed by data, risk logic, and subject matter expertise. A credible transition process is one of the most valuable assets a mining company can hold once the last ton is mined.

To align your mine and closure plans with an integrated, standards-based approach, contact us at info@okaneconsultants.com.

References

Baisley, A., Morin, N., Fisher, N., O’Kane, M., & Clark, M. (2023). Embodying progressive reclamation beyond closure – Challenging the concept of “end land use”. Proceedings of the 2023 British Columbia Mine Reclamation Symposium, Prince George, British Columbia, Canada. https://open.library.ubc.ca/media/download/pdf/59367/1.0437476/3

Consolidated Mining Standard Initiative. (2026). Consolidated Mining Standard Initiative. https://miningstandardinitiative.org/

Global Tailings Review. (n.d.). Global Industry Standard on Tailings Management. https://globaltailingsreview.org/global-industry-standard/

International Council on Mining and Metals. (2025). Integrated Mine Closure: Good Practice Guide. https://www.icmm.com/integrated-mine-closure

Towards Sustainable Mining. (2026). The TSM Initiative. https://mining.ca/towards-sustainable-mining/