Relook at Small Scale Mining laws and Regulations to address problems with Irresponsible Mining

Executive Summary
Day in, day out is the public outcry for a stop of or a ban on Artisanal and Small Scale Mining due to the associated irresponsible mining with the resultant massive destruction of the environment especially pollution of rivers and the air and the destructions of farms and forest cover.

A critical thinking on the underlying issues, norms and dynamics in the Small Scale Mining Sector will tell that there is the urgent need to relook at the Small Scale Mining Laws, thus Ghana’s consideration or definition of Small Scale Mining which has resulted in allowing Companies belonging to tycoons and or influential persons with their foreign collaborators to operate with sophisticated technology and substantial expenditure in Small Scale Mining and operating in Forest areas. These acts outpaced laws on Small Scale Mining and protection of forest cover.

The permissibility by Ghana for Companies belonging to tycoons to operate Small Scale Mining with sophisticated technology and substantial expenditure is in conflict with the global definition of Small Scale Mining which tells that Small Scale Mining is by usage of simple tools in a labor-intensive mining project especially by poor persons as a strategy for survival or livelihood. Hence, relook at the law is necessary.

Furthermore, the use of Limited Liabilty Companies for Small Scale Mining by Ghanaian tycoons is a mismatch with the terms or language of the operator of Small Scale Mining as a person and not a Company throughout in the Small Scale Mining Law. Check the laws on Small Scale Mining from Section 81 to Section 99 of the Minerals and Mining Law 2006 (Act 703) and you will see that it deals with a person and not a Company hence it is absurd to allow Limited Liability Companies to operate in Small Scale Mining otherwise need to amend it to add offences and punishments for an offending Company.

This is problematic because Section 99 on Offences of Small Scale Mining and the Punishments for breaches of Small Scale Mining law speaks of a person and no mentioning of a Company. Thus no punishment is provided for an offending Company at Section 99 (on offences and punishment) of Minerals and Mining Act 900 of 2015, which is the associated amendment of Section 99 of the Minerals and Mining 2006 (Act 703) for a Company which happens to breach the Small Scale Mining laws from Sections 81 to 98.

This situation renders the use of Limited Liabilities Companies to operate Small Scale Mining as an absurdity, since neither the Limited Liability Company nor the Owner can be charged under the Offenses at Section 99 since it indicate that a committer of a Small Scale Mining offence as a person and not a Company, hence the punishments include imprisonment for the offender. Punishment for Small Scale Mining at Section 99 is by Court Competent Jurisdiction. But punishment for Mining Companies is pronounced by the Sector Minister without going to Court. The offending Company may be asked to rectify a problem at own cost, payment of compensation, or a fine or cancellation of Mining Rights as pertain under the Large Scale Mining Law, the punishment for an offence is by the Sector Minister

There were/ are also issues of foreigners involved in Small Scale Mining Sector either by Support Services as provided by Minerals and Mining Regulation Support Services Regulation 2012 (Act 2174). Another problem is foreigners involved in Gold purchases and exporting from the Small Scale Mining Sector. Hence foreigners promoting the rot cannot be over emphasized.

This situations as stated above demand an immediate relook at the Small Scale Mining laws for a denial of foreigners from working within the Small Scale Mining Sector. Ghanaian tycoons should be denied from operating Small Scale Mining.

So restrict Small Scale Mining to Community Small Scale Mining as required of the originator of Small Scale Mining that is the PNDC and totally deny Ghanaian Tycoons and their Companies and Foreigners from operating Small Scale Mining. Rather make Ghanaian tycoons and their Companies to operate under Large Scale Mining Sector or a new category as Medium Scale Mining Sector.

Small Scale Mining Background or Underlying issues

Small Scale Mining as a strategy for survival or livelihood using manual or labor-intensive method emanated globally from the Stone Age era. The operators of Small Scale Mining regard the gold or salt as God sent for them to escape from their poverty misery, so it has spiritual connotations. Thus Small Scale Mining existed before the establishment of the Gold Coast Colony which saw the British Colonial Masters banning Small Scale Mining in 1905, which was then coined in broken English as Galamasey meaning gather and Sell. Despite the banning of Small Scale Mining it persisted underground up to 1986.

During the Economy Recovery Program in the later 1980s under the auspices of the World Bank, the PNDC enacted the parent Small Scale Mining Law at Section 77 of the Minerals and Mining Law 1986 (PNDC Law 153) and lifted the ban and thus legalized or formalized Small Scale Mining (Galamasey in local parlance) so as part of poverty reductions measures.

So, in 1988 the PNDC introduced a Program of Actions to Mitigate the Social Cost of Adjustment (PAMSCAD) conceived as a series of Small Scale Projects originating from the local level in line with the Philosophy of application of participatory method in decision making on economic and social policies. PAMSCAD in effect was a safety net for Communities vulnerable to the effects of the economic reforms. The finance or funding for PAMSCAD came from the World Bank and Other Donors.

In 1989, in attempt to actualize or fulfil the philosophy or principle of PAMSCAD in the participatory decision making process, the PNDC enacted the Small Scale Gold Mining Law 1989 (PNDCL218) for the Precious Minerals like Gold, this was followed by the Precious Minerals and Marketing Company Law 1989 (PNDCL219) with the monopoly or exclusive right to buy and export Gold from the Small Scale Mining Sector.

Note that for small scale salt mining project as part of PAMSCAD, the PNDC enacted the PNDC Law 287 for the people of Ada Songhor Lagoon and other areas. For the Small Scale Gold Mining, the PNDC in 1989 enacted the PNDC Law 218 at section 21 etc, gave a strong caveat that Small Scale Mining is a method of mining which does not involve the use of sophisticated technology nor the use of substantial expenditure. Furthermore, Small Scale Mining will only be allowed if and only if it is in the interest of the affected Community. Now one may ask how the Chinese became involved or interested in Small Scale Mining and what is the interpretation of Small Scale Mining at Section 21 of PNDC Law 218 and is it in consonance/agreement with the global definition of Small Scale Mining.

Minerals in Ghana especially Gold, was first decreed as the property of the citizens of Ghana by the first Head State of Ghana namely Dr Nkrumah, with socialism ideology and vested the minerals in the Head of State in trust and on behalf of the people.

This idea or policy that the gold belongs to the citizens of Ghana was upheld by the PNDC due to its socialism ideology, so to ensure that the Gold and other Precious Minerals were/are accounted for by all Small Scale Miners to the State as well as selling the Precious Mineral to the State as soon as possible, was the reason that made the PNDC to establish the Precious Minerals Marketing Company (PMMC) in 1989 with PNDCL 219.

The PNDC introduced Small Scale Mining in 1986 at Section77 of the Minerals and Mining Law 1986 (Act 153) for rural people. The formalization of the law was followed with separate laws for Gold and Salt in subsequent years. In 1988 the PNDC introduced a Program of Actions to Mitigate the Social Cost of Adjustment (PAMSCAD) conceived as a series of Small Scale Projects originating from the local level in line with the Philosophy of application of participatory method in decision making on economic and social policies. PAMSCAD in effect was a safety net for Communities vulnerable to the effects of the economic reforms. The finance or funding for PAMSCAD came from the World Bank and Other Donors.

As part of realization of the idea of PAMSCAD, the PNDC enacted the Small Scale Gold Mining Law 1989 (PNDC Law 218). This law gave a caveat that is a meaning method which does not involve sophisticated equipment and o Substantial Expenditure to be done by only Ghanaians and it will only be allowed if and only if it is in the interest of the affected Community. Another Small Scale Mining Law PNDC Law 287 for mining salt. Both PNDCLaw 218 and PNDC Law 287 were regarded as Galamasey or Indigenous Mining Laws. Artisanal and Small Scale Mining or Galamasey was therefore conducted by manual or labor-intensive method with a great number of women also as Galamasey Operators

PNDCL 219 gave PMMC the exclusive right or monopoly to buy and export gold from the Small Scale Mining Sector and bring back to Ghana100 percent of the sales in dollars. This was the situation up to 2015 when a bad law was enacted as part of Minerals and Minerals Amendment Law 2015 (Act 900) and changed the narrative with PMMC, a Marketing Company made to be a mere Laboratory for assaying gold and gave the role of buying and exporting gold to greedy private bullion exporting Companies for them to keep 80 percent outside Ghana and bring only 20 percent of the sales in dollars to Ghana. Hmm a Capitalist ideology by persons with Socialist ideology speaks of something fishy.

This absurdity must be stopped. If PMMC had a funding problem, nothing prevented PMMC to use the COCOBOARD method of financing the purchase of cocoa through syndicate loans. Otherwise Bank of Ghana should give loan in Ghana Cedis to PMMC to buy the gold in Cedis and pay back the loan in Dollar equivalent by the principle of mutualism that is scratch my back and I would scratch your back.

This bad Law needs to be repealed immediately, because the likelihood of some greedy Bullion Exporting Companies sponsoring the rot in the Small Scale Mining for them to make more dollars cannot be ruled out. It also noted that this policy contravenes the Constitutional provision that the Gold belongs to the State or the citizens of Ghana, so the appropriate Agency to buy and export the Gold is the State through the PMMC as decreed by the regime of the PNDC, with socialism philosophy.

Once again, let me say that the global definition of Small Scale Mining is a mining operation by millions of people including women and children using simple tools to mine with the notion that the mineral gold or salt is a gift from God for them to escape from their poverty misery. So, the global definition of Small Scale Mining, tells that Small Scale Mining is the same as Galamasey, a broken English or local parlance term which stands for Gather and Sell which is an indigenous strategy for poverty alleviation and rural development by Communities endowed with minerals which the British Colonial Masters termed as Artisanal and Small Scale Mining. Hence the urgent need to relook at the Small Scale Mining Laws and prevent tycoons who can buy expensive assets from operating Small Scale Mining, an operation by the very poor. .

A research would revealed that Small Scale Mining or Galamasey an indigenous mining activity of our ancestors has come to stay as part of our way of life (culture) and it should be preserved through win-win solutions for coexistence. So let us replace Small Scale Mining License with introduction of Community Small Scale Mining Permit (with the does and don’ts) to be acquired by interested Mining Communities and the inclusion of the Chief or his Rep as active participant is necessary for the Chief to monitor and control effectively the Mining activities personally or by his Rep. Thus create a shared Responsibility.

The Community Small Scale Mining Permits should be issued if and only if it is in the interest of the Community to conduct Small Scale Mining as required in PNDC Law for Small Scale Mining, hence the applicant should be the Chief of the interested Community or his Rep as the Risk Owner to be issued by the Sector Minister or his Rep say the Officer in charge (OIC) of District Minerals Commission Center with the endorsement of the Chief before final endorsement by the DCE. Individual Mining Permit or ID card with the does and the don’ts should be issued by the Rep of the Chief to individual miners

So, our failure to relook at the Small Scale Mining Law and Regulations for corrective actions to include adoption of among others a win-win solution for coexistence has been the reason why we are yet to achieve the desire impact or success in dealing with the issues of the environmental hazards emanating from the mining sector since 2009.

The use of aggression (the ‘Builsa way’’) with the Military and Demo have not helped us in the past. Hence these two methods alone would not address the problem. So the answer is a holistic and multifaceted approach to be done at the same time. The solutions can be obtained as stated through a proper brainstorming on the underlying issues, norms, dynamics etc in the Small Scale Mining Sector and this will enable us to be clear and coherent in the battlefield for success through the application of the First Principle of War, that is Selection and Maintenance of Aim, this requires the maintenance of momentum or perseverance which is also known as the Principle of Business Success.

Solutions exist and could be obtained if and only if we conduct a proper risk assessment on the Small Scale Mining Sector for us to come out with control measures in order to reduce the associated risks in the Small Scale Mining Sector to the barest minimum.

So, Let us stop muddling the waters or confusing the situation with our daily screaming for a ban on Galamasey or a ban on Small Scale mining, as well as by demo on the street we should rather brainstorm or think outside the box to obtain the answers. We can obtain the answers by reviewing the factors contributing to the woes of Ghana.

Causes of the Woes of Ghana
A critical thinking on the issues especially the laws will tell that Ghana’s woe in the Mining Sector is due to three issues. Firstly, due to the passage of an ambiguous Small Scale Mining Law in 2006 by the Parliament in the Regime of President Kofour. This Small Scale Law enacted in 2006 as stated in Act 703 was supposed to be amalgamation of previous Small Scale Mining Laws before 2006 ,unfortunately, it was not so. Members of Parliament in 2006 failed to note or consider the exact intention of the originators for lifting over 100 years ban on Small Scale Mining (banned in 1906) which was to recognize Galamasey as Small Scale Mining, read section 77 of the Minerals and Mining law 1986 (PNDC Law 153) and or section21 of the Small Scale Gold Mining Law 1989 (PNDC Law 218) and PNDC 287 on Small Scale Salt Mining. It must be made clear that the people at Ada Songhor are doing Galamasey Salt Mining (Gather and sell salt) and thus competing Electrochem Ghana Ltd under the McDan Group for raw salt.

Secondly, the passage of a Regulations on Support Services in 2012 that is Minerals and Mining Support Services Regulations 2012 (2174) which gave lucrative avenue for the Chinese and their Ghanaians accomplices to turn Ghana into a crime Scene through the importation of thousands of Sophisticated Technology (skills equipment etc) mainly Excavators and Chafang machines from China for Small Scale Mining is one of the major woes.

Lastly, another very bad law was enacted in 2015 as part of the Minerals and Mining (Amendment) Act 2015 (Act 900) and abrogated the Precious Minerals Marketing Company’s monopoly of buying and exporting gold from the Small Scale Mining Sector. The bad law gave this role to Private Bullion Exporting Companies to export and keep 80 percent of the export sales outside Ghana and only bring 20 percent to Ghana. It is a bad law like LI2174 of 2012 as stated above, since it also afforded a profitable window for the direct involvement of Foreigners in the Small Scale Mining Sector as against the Small Scale Mining Law which prohibits foreigners in the Small Scale Mining Sector, it is envisaged that some greedy Bullion Exporters were involved and may still be involved in sponsoring illegal mining for them to get more gold to generate more wealth.

So, it is very clear that the situation in the Small Scale Mining is highly problematic and against the interest of Ghana especially the use of sophisticated equipment and we are told that some Small Scale Mining Companies had /have over 70 excavators on their Sites for surface mining. Thus 30 excavators more than the total of number of 30 Excavators owned by all the Large Scale Mining Companies. The 2020 Auditor General Report on Small Scale Mining speaks volume of all the Licensed Small Scale Miners committed illegal mining since 1999 by not posting reclamation bond for backfilling their pits and reforestation of the disturbed areas. Hence they infringed Environmental Assessment Law 1999 (LI1652), hence Small Scale Mining is Ghana’s woe.

So the use of sophisticated technology and the involvement of foreigners outpaced laws on the Small Scale Mining which were enacted by the PNDC aimed at regulating the indigenous or native or traditional Small Scale Mining as part of PAMSCAD. So as expected the regimes of the PNDC and the combination of NDC1 and NDC2 under Chairman Rawlings and President Rawlings respectively maintained the laws on Small Scale Mining as enacted by the PNDC. This may be the reason that aside Mining Companies, there was no public outcry against activities of Small Scale Miners from 1989 to 2009. That is 20 years after the introduction of Small Scale Mining Activities in 1989.

It should be noted that it was effective 2008 that the public began to realize the effects of Small Scale Mining due to the use of sophisticated Technology by Ghanaians and their Chinese Collaborators. So, the regimes of Executive Presidents and their associated Parliaments in the Post-Rawlings regime off PNDC and NDC1 and NDC2 that is effective the Administration of President Kofour to the Administration of President Nana Addo should share the blame for the potential existential threat as occasioned by Small Scale Mining with bad Small Scale Mining policies and Laws and the associated regulations from 2006 to 2024.

The massive destruction of the environment is attributed to the mining activities of some of the over 300 licensed Small Scale Miners or Ghanaians who were sent to China to understudy the mining operations and they used their Mining Licenses lured and invited their Chinese friends to come and partner with them in Small Scale Mining. This happened effective the Regime of President Kofour.

Fortunately, for the licensed Ghanaian Small Scale Miners and their Chinese friends and unfortunately for Ghana, Parliament enacted an ambiguous Small Scale Mining Law in the Minerals and Mining Act 2006 (Act 703) as section 81 to section 99 thus gave an open cheque for the Ghanaians and their foreign partners to do irresponsible mining (read the 2020 Repot of the Auditor General on Small Scale Mining).

The matter was made worst with the passage of the Minerals and Mining Support Services Regulation 2012(LI 2174) as stated above, it gave a window for the Chinese to bring thousands of sophisticated technology etc for Small Scale Mining. Another problematic law part is the one that allowed private Companies in buying and exporting of gold as in the Minerals and Mining Amendment Law 2015 (Act 900), lastly, the law on mining in forest that is Regulation 2022 (LI2462) also compounded or multiplied the woes of Ghana.

Solutions or the Way forward
Small Scale Mining as a Universal set has come to stay as concluded by the World Bank in a forum in May 1995. Small Scale Mining contains a number of subset amongst these subsets is an Artisanal and Small Scale Gold Mining or Indigenous or Traditional or Ancestral God Mining or Indigenous Salt Mining or Indigenous Diamond Mining, all these three are termed as Galamasey (Gather and Sell) in broken English or local parlance in Ghana by the operators since the arrival of the British Colonial Masters.

So a critical thinking on this situation will tell that the requirement of issuance of a Mining license to an interested qualified applicant before mining, conveys to the people in rural setting as akin to acquisition of a driving license individually before the person can drive a vehicle. Thus considering the global definition of Small Scale Mining as operation by, millions of poor people including women and children for survival, so asking them to acquire Mining License before mining is not the best since they are doing so for survival, so it is recommended that Community Mining Permit with the does and don’ts is the best tool.

So let us do away the need for mining license for Small Scale Mining which sounds as need for driving license before once can drive a vehicle as stated. Rather reset the interpretation of Small Scale Mining to read as at section 21 of PNDC Law 218 but this time replace the Mining License with Community Small Scale Mining Permit with does and don’ts to be obtained from the District Mineral Commission Office to be endorsed by the DCE and the Chief.

So when a Community through the Chief is granted a Community Small Scale Mining Permit, interested Individual Galamasey operators should be made to obtain an individual mining permit with the does and don’ts from the Chief as part of social license to ensure responsible mining. So that the DCE and the Chief/ other local leaders and with the field miners share the likely associated risks as risk owners, this may give a shared Responsibility mechanism as a good instrument to help contain the activities of Galamasey operators within boundaries.

No one should be allowed to be part of the Community Mining unless he or she is a resident or demo that he or she wants to be a resident and act as such. Thus he or she will drink the water and eat food items produced within the areas of Community Mining.

No one should be allowed to operate Small Scale Mining for more than 7 years. Operators must be provided skills by training in other business of trade for them to gradually navigate to acceptable Alternative Livelihood Projects of their choice with the State and the help of the World Bank and USAID providing necessary support,

Companies of tycoons or the influential persons and their foreign partners should be prevented from operating in Small Scale Mining. They should operate under a new category as Medium Scale Mining Sector and must be made to comply with local and International Standards as required of the large Scale Mining Companies. The standards should including policies on Mining, care of the Environment, Safety, and Health etc. Hence appointment of Mining Manager, Environmental Officers, Safety Officers, Medical Team. Gold production to be based on the Constitutional dogma of Probity, Transparency and Accountability.

A critical study on the Small Scale Mining Law from Section 81 to Sections 99 of the Minerals and Mining Law 2006 (Act 703) speaks of a person and not a company. Hence the offences and punishments at Section 99 of Act 703 speaks of imprisonment and a fine. So, allowing tycoons or the influential persons to operate Small Scale Mining through a vehicle of a Limited Liability Company is an absurdity if we really understand the scale mining law especially Section 99 of Act 703 and matters on Company law which says that a Limited Company can be sued and it can also sue. So issue of imprisonment not possible if the license was/is issued in the name of a Ltd liability Company.

So I wonder those calling for prosecuting of Atlas Mining Company Ltd or the owner or Akonta Mining Company Ltd or the owner have taken time to study the laws on Small Scale Mining. I envisaged that by the state of affairs prosecuting of Akonta Mining Company or the owner would not succeed in a Court of Competent jurisdiction.

So, the need for the relook at the Small Scale Mining law, so as to navigate the Mining Companies within the Small Scale Mining Sector to Large Scale Mining Sector as Junior Mining Companies otherwise create a new category as Medium Scale Mining Sector for the Ghanaian Mining Companies like Akonta Mining Companies to operate with the same standards as required of Large Scale Mining Companies. It should be noted that under the laws for Large Scale Mining Companies the power to determine and offence and to punish an offending Company is the immediate action by the Sector Minister through the Regulator. Punishment is either the Company is required to address the problem or the Company is fined that is payment of penalties or Compensation or cancellation of Mining Rights, or combinations. So no waste of time to go to Court for punishment like imprisonment as in the Small Scale Mining Law at Section 99 of Act 703. Example is the sad explosive disaster at Appiateh near Bogoso, for which the affected or Guilty Company was fined Six million Dollars by the Sector Minister for the incident/accident.

So, if I am right then, an immediate action to rectify the problem in the Small Scale Mining Sector to make owners of the Mining Companies to be more responsible by owing the risk and not the Company, which cannot be dealt by the bad law.

It is better to create a third nomenclature or class as Medium Scale Mining Sector for Ghanaians and their Companies to operate alone (solely) or with foreign partners. The Companies should be made to operate with rules and regulations akin to what pertain in the Large Scale Mining Sector which comply with both local and international standards including Safety, health and environmental policies and with a requirement of employment of a Mining Manager, Safety Officers, Environmental Officers and medical team with strict monitoring by Mining Inspectors and EPA Officers.

There should be also a proper accounting of the Gold through GRA official and or an officer from the Precious Minerals and Marketing Company (PMMC). Defaulters or offenders of the law and regulations must be by a fine or cancellation of Mining Rights/lease or both to be executed immediately by the Sector Minister same as for Large Scale Mining Companies.

It is recommended that the only difference between Large Scale Mining Sector and Medium Scale Mining Sector should be a lesser Capital threshold requirement for the rich or city dwellers like tycoons who want to create more wealth or become Millionaires or billionaires.

The above inputs therefore suggest the need to Revoke Mining Licenses so issued to Tycoons and give them mining rights or lease and navigate them to the Medium Scale Mining Sector, so that they can operate freely with their Chinese Collaborators.

Gold by Article 257 at Section 6 belongs to the people of Ghana hence no person, no mining Company no owner of a Mining Company should be allowed to Hoard or keep the gold obtained in mining privately at homes, offices etc without accounting to relevant State Institutions and selling same to the relevant State institution.

Before 2015, the right State Agency for buying and exporting gold from the Small Scale Mining Sector was Precious Minerals and Marketing Company (PMMC) as established by regime of the PNDC through Precious Minerals and Marketing Company Law PNDC Law 219 of 1989 with the monopoly or exclusive right for purchasing and exporting of Gold from the Small Scale Mining Sector. But in 2015, private Companies took over the buying and exporting of gold from the Small Scale Mining Sector. It is feared some greedy Bullion Exporters promoted the rot in the Small Scale Mining for more gold for export to earn more dollars. Parliament should therefore to repeal the bad law in Act 900 of 2015 and reset or restore the monopoly of PMMC. PMMC to be converted to Precious Minerals Board akin to COCOBOD and be responsible for buying and exporting gold from the Small Scale Miners and the from the proposed Medium Scale Mining Sector for Companies of Ghanaian tycoons etc

So let us by get Parliament to relook at the laws and regulations on the Small Scale Mining Sector for appropriate actions by the Executive Arm of Government and the Judiciary when a case on Small Scale Mining is brought before a Court of Competent jurisdiction.

Conclusion
To conclude Small Scale Mining is universal set with subsets in Precious Minerals and Industrial Minerals mining as part of survival or livelihood projects by rural communities using simple tools. Hence it is characterized as a mining sector with no probity, transparency and accountability of the gold obtained by miners so allowing Tycoons with their Companies and their foreign partners to operate in the Small Scale Miners Sector is not the best for the Country.

So tycoons and their businesses should be made to operate under Medium Scale Mining to comply with standards as required of Large Scale Mining Companies under the Ghana Chamber of Mines. These will enable the Sector Minister(s) to take immediate action on breaches either by a payment of a fine or cancellation of mining rights or lease.

Due to state of affairs in a community with rich deposits of minerals especially gold, diamond and salt and considering the population growth as well as a requirement to consider the needs for future generations, so asking every member or citizen interesting in mining to go for a mining license like a driving license before driving a car thus before he can mine by Galamasey or Small Scale Mining, is an absurdity.

So it is better to do away with license for Small Scale Mining rather replace it with Community permit system including Universal Community Permit from the Sector Minister or his authorized Rep for the Community Small Scale Mining matters. Interested individuals should be made to acquire individual permit as social license system from the DCE through the Chief to ensure shared responsibility. It is expected this ways may help bring sanity in the Mining Sector.