Although there is a Mining Environmental Management plan that aims to develop actions in a relatively simultaneous manner throughout the country, ten of the 23 provinces did not sign the necessary agreements to carry out these initiatives.

The data is contained in a report of the General Audit of the Nation (AGN), approved this year, which analyzed the execution of several aspects of the "Environmental Management Program for Sustainable Production in the Productive Sector". These are actions designed to be implemented over a period of six years, financed by a US $ 50 million loan from the Inter-American Development Bank (IDB) in 2007, aimed at ensuring that activities related to the use and exploitation of Resources are environmentally friendly.

Within this framework, the AGN examined in a timely manner the subprogram Mining Environmental Management (GEAMIN), implemented by the Ministry of Mining of the Nation, which reports to the Ministry of Federal Planning, and which provided funds for 25.7 million dollars.

The Audit stated that, at the time of its investigation, the provinces that had not initialed the agreements related to the plans in question were: Tierra del Fuego, Santa Cruz, Chubut, Cordoba, Tucumán, San Luis, Santa Fe, Entre Ríos, Corrientes And Misiones.

The report contains two similar opinions on this situation; On the one hand, although the Ministry of Mining itself said that the lack of signature of agreements "was not significant," he acknowledged that "it will be in the future." In the same vein, the General Coordinator of the GEAMIN subprogram stated, adding that the backlog in the headings "has caused deviations in relation to the execution deadlines, but not with the targets set for the initiative as a whole."

Degraded Areas

One of the objectives planned in the program was that, by the end of the fourth year of execution (2012), an inventory (cadastre) of the degraded mining areas should be carried out, including the so-called mining environmental liabilities (MAP). The latter task included an in situ characterization of pollution sources in eight degraded areas considered to be priority because of their impact on the environment and health of affected communities.

According to the AGN, as a pilot experience, it was intended to begin with three areas to carry out remediation and investment projects aimed at eliminating environmental liabilities, recording everything in a Technical Manual that is then used in other mining environmental liabilities.

The three areas selected for the pilot experiences were the former Metal Huasi smelter, in Abra Pampa, Jujuy; The former smelter of the Gonzalito mine, in San Antonio Oeste, Rio Negro; And the tailings of the exploitation of sulfates, in Calingasta, San Juan. All this work would be extended in each province and then derived in a National Cadastre.

The Audit adds that, for that, a company, Cesel Ingenieros, was hired to deliver Phase I of the Final Report in August 2012, in which it expressed the methodology and procedures for data collection, including an on-site verification. Which allows for obtaining truthful and concrete information.

The research says that already in the second half of 2012 the training courses for the provincial survey were carried out and the information systems were installed. However, it was observed that the survey and recording of data in the information systems were still "pending to integrate the provincial cadaster and to form the National Cadaster".

Abra Pampa and the Community Demand

The National Audit Office dedicated a section of its report to what happened at the former Metal Huasi smelter in the town of Abra Pampa, Jujuy province.

This farm, which had worked for some three decades until its closure in 1990, remained in those days on the outskirts of the town, "but over the years, Abra Pampa was growing and Metal Huasi was inside", recounts the work "The main problem is that it constitutes a source of exposure to lead to arsenic, both of very important toxicity, being the main routes of entry respiratory, digestive and also by contact. (In that sense), the population most at risk are children and women of reproductive age and the health effects are neurological and cognitive".

In view of this situation, the company Cesel Ingenieros convened, within the framework of its survey tasks, workshops with the community in order to promote citizen participation and exchange information. There were four meetings, plus a meeting with IDB officials, in which the neighbors requested the anticipation of works of removal and transfer of slags from Abra Pampa, and the so-called remediation works, such as an amphitheater in the former smelter; A sports center in Barrio 12 de Octubre and revegetation and reforestation tasks in the areas of Tabladitas I and II stream.

On this, the AGN noted that "between October 2011 and May 2012, partial remediation works were carried out at the request of the community", such as the removal of slag and contaminated soils from the 12 de Octubre neighborhood, on the margins of the Arroyo Tabladitas and other impacted areas of Abra Pampa; The process of encapsulation of these materials at the El Aguilar Mine and the closure of the pre-existing security cell at that site.

According to the auditors, "the final phase of the remediation work was pending" demolition of facilities, machinery, metal scrap Metal Huasi, final disposal in hazardous waste conditions at the El Aguilar Mine; The execution of the works of use chosen by the inhabitants of the locality of Abra Pampa, like the amphitheater and the sports center; And a new treatment to the areas that remain contaminated after slag removal.

Likewise, "afterwards (from the works) samples were taken at sites remedied to verify the presence of lead between June and July 2012, and the result was that high lead levels persisted", completed the control body.

The Neighbors Health

On the other hand, between January and February 2012 a multidisciplinary team of the IDB traveled to Abra Pampa to evaluate the implementation of the project. There they contacted the local population and observed that "the main demand of the community is related to the treatment of the impact on health". It was explained that the project is limited to the evaluation and remediation of environmental liabilities, as a way to contribute to the reduction of pollution, and that attention to the health issue transcends the functions of the Ministry of Mining. However, members of the multilateral body made a proposal for a future health plan and "contributed to a spectrometer not originally planned."

As for this spectrometer, it was acquired by the Executing Unit of the subprogram and delivered to the province of Jujuy during the second half of 2011. The equipment was installed in the Central Laboratory of the Ministry of Health Provincial. Between October and November 2012 began with the extraction of samples.

The AGN analyzed samples of 103 people between minors and adults, and observed that 24 studies were performed in children, where 4 cases were without data and the remaining 20 indicated blood lead values higher than those of reference.

For the adults, 79 studies were performed, and of that total, 65.8% showed higher values than the reference ones. With these results, the auditors note that while these studies are voluntary, and that the subprogram’s activity is aimed at suppressing the contaminant source, it is necessary to implement a "public awareness campaign on the importance of extraction of blood samples."

Who Runs the Subprogram?

In another part of its investigation, the Audit explained that the Secretary of Mining of the Government is in charge of carrying out the administrative-financial tasks for the execution of the initiative analyzed. To that end, it had to create an Executing Unit of the Subprogram (UES), which was even based on the contract with the IDB. This structure would have to have a general coordinator specializing in project management; A technical-operational coordinator to support; Three specialists (administrative and financial, procurement and contracting, and monitoring); and experts in the areas of mining environmental management and recovery of mining liabilities. That is to say that the total of the planned staff is of approximately 11 people. However, the auditors found only four people involved in coordination tasks. That is to say, "the structure of the Executing Unit of the Subprogram (UES) is smaller in quantity and professional profile than the one foreseen in the contract with the IDB". And it was also detected that the general coordinator is also in charge of coordinating two components of the subprogram."

In addition, the AGN listed other deficits. And "with respect to the contractual obligation with the IDB to publish the Progress Reports and Level of Execution every six months (of the initiative) on the website of the agency, only those corresponding to the first half of 2010 are included."

And it adds: "AGN's successive financial reports indicate the under-execution of the amounts planned each year, particularly notable in the first two (2008 and 2009)." For example, according to a report by the 2012 monitoring body, it states that from the start of the subprogram until 2011 inclusive, 12.76% of the total planned investments were executed and 17.08% of the amount scheduled up to that year. Antecedents of this situation had even been observed by the Internal Audit Unit of the Mining Secretariat itself in 2009.

Brick Activity and (Again) Health

Another of the components of the Environmental Management Management subprogram examined by the AGN was the Artisanal Ladrillera Activity.

The report explains that it is estimated that there are about 50,000 brick-makers nationwide, which contribute about 30% of the country's brick production. The program in question proposes the elaboration of a diagnosis by province and the proposal of an action plan to address the socio-environmental and technological problems of this activity. In addition, it provides for the training of artisan brick producers in the use of environmentally sustainable technologies, taking care of health and safety at work.

To achieve this goal, 900 technicians or teachers are planned to train as multipliers. In agreement with the IDB, in the meantime, training was planned in the provinces of Formosa, Chaco and San Juan, where "pilot" training centers will operate.

Among the observations of the Audit on this subject it is highlighted that "the process for the elaboration of bricks follows the method developed since the antiquity. It exploits a resource whose formation takes many years, so that its degradation is irreversible; The soil is exploited, the pasta is prepared, molded and cooked in ovens, which by the type of fuel they use generate different toxic gases and particles in suspension, polluting the atmosphere, bodies of water and of course the soil. The people who work in this activity because of the conditions, in which it is carried out, suffer respiratory diseases and skin pathologies. It is usually a family activity involving women with their minor children, a population most vulnerable to health damage. The ecosystem is altered because of the loss of native forests, the soil becomes unusable for other productive activities and when the plot has been exhausted, the furnace must be moved to another place.

"The objective of the program is to incorporate environmentally sustainable practices, improve the working conditions of producers in terms of health, safety, environment and productivity through training and introduction of eco- Efficient."

The monitoring body states that "by the second half of 2012, the Subprogram had the Comprehensive Diagnosis of Artisanal Litter Craft in Argentina1, with a plan of action and didactic materials for conducting training and awareness-raising courses." However, according to the research, "this diagnosis does not go into the impact of the activity on the health of workers, despite the fact that 72% of the producers surveyed perceived some degree of affectation of their health by the activity."

To complete, "delays in compliance" were observed by the provinces of Chaco and San Juan in the construction of the building and construction infrastructure of the training centers, which were planned for the training of the multiplier teachers.