Formalizing Artisanal Gold Mining under the Minamata Convention: Previewing the Challenge in Sub-Saharan Africa

Gavin Hilson,A* Tara Rava Zolnikov,B Daisy Ramirez Ortiz,C Cynthia KumahD

A Surrey Business School, Faculty of Arts and Social Sciences, University of Surrey, Alexander Fleming Rd, Guildford GU2 7XH, United Kingdom

B School of Health and Human Services Community Health, National University, San Diego, CA 92123, United States

C Department of Epidemiology, Florida International University, Miami, FL 33199, United States

D School of Public Service and Governance, Ghana Institute of Management and Public Administration, P. O. Box AH50, Accra, Ghana

* Corresponding author, Email: g.m.hilson@surrey.ac.uk (G. Hilson)

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Highlights

The Minamata Convention on Mercury was launched to curb emissions of mercury worldwide

The Convention focuses heavily on artisanal and small-scale mining (ASM) – low-tech mineral extraction and processing

The analysis explores how the Convention is being implemented in sub-Saharan Africa, where most ASM is found in the informal sector

The Convention requires ratifying countries to produce National Action Plans, which must include a plan for formalizing ASM

The cases of Ghana, Mali and Sierra Leone cast light on how African governments have responded to the challenge

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Abstract

This article contributes to a growing body of literature which explores how the Minamata Convention on Mercury is influencing the development of artisanal and small-scale mining (ASM) – low-tech mineral extraction and processing – in sub-Saharan Africa. Conceived to raise awareness of the environmental impact of mercury and to minimize its use in industry, the Convention focuses heavily on ASM, the largest source of anthropogenic emissions of mercury worldwide. Article 7 of the Convention requires ratifying countries with ‘more than significant quantities of ASGM [artisanal and small-scale gold mining]’ to draft comprehensive National Action Plans (NAPs) that outline training programs for the handling of mercury and strategies for reducing emissions from artisanal and small-scale gold mines. The focus here, however, is on one point in particular, the importance of which, thus far, has been largely-overlooked: the need for ratifying countries to include in their NAPs ‘Steps to facilitate the formalization or regulation of the artisanal and small-scale gold mining sector’. In sub-Saharan Africa, where most ASM activities are found in the informal ‘space’, this promises to be a contentious issue moving forward. The article explains why this is the case, drawing heavily on findings from research being conducted in Ghana, Sierra Leone and Mali, three of the region’s most dynamic ASM economies.

Keywords: small-scale gold mining; formalization; Minamata Convention on Mercury; global health; policy

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1. Introduction

On 19 October 2013, the Minamata Convention on Mercury, a global treaty conceived to reduce global emissions of mercury, was adopted. The product of three years of extensive negotiation and debate among representatives from nearly 140 countries, the intervention was hailed by many at the time as a victory for the environment. It officially came into force on 16 August 2017 (Gustin et al., 2016).

The Convention, which ‘draws attention to a global and ubiquitous metal [i.e. mercury] that, while naturally occurring, has broad uses in everyday objects and is released to the atmosphere, soil and water from a variety of sources’,1 focuses heavily on artisanal and small-scale mining (ASM), the low-tech, labour-intensive mineral extraction and processing activity widespread in developing countries. If the goal is to protect the environment, as is stated, this attention is warranted because globally, ASM is the largest source of anthropogenic mercury emissions (37 percent). An estimated 15 million operators scattered across 70 countries release in the range of 1400-1600 tonnes of mercury every year (Gibb and O’Leary, 2014; UNEP, 2013; Veiga et al., 2014). After amalgamating their gold, most of these miners discharge excess mercury into the natural environment where, as several timely reviews have captured over the years (e.g. Wren, 1986; Stein et al., 1996; Selin, 2011), it methylates and bioaccumulates, posing a range of health-related threats to humans and wildlife.

The Convention has spawned vibrant debate over the environmental impacts of mercury use in ASM. But this dialogue has overshadowed comprehensive analysis of the sector’s economic importance in some of poorest areas of the world, particularly sub-Saharan Africa. As several studies published over the past decade (e.g. Maconachie, 2011; Maconachie and Hilson, 2011; Kamlongera, 2013; Hirons, 2014; Ferring et al., 2016) highlight, here, ASM provides an income to millions of otherwise-unemployed people directly and creates millions of more jobs in the upstream and downstream activities it spawns. Documentation of the economic importance of ASM in sub-Saharan Africa, however, did little to discourage many of the region’s governments from embracing and ratifying the Convention (Table 1). These countries are now required, in accordance with Article 7, Paragraph 3 (Annex C), to develop a National Action Plan (NAP) which must detail, inter alia, national objectives and strategies for reducing mercury emissions at artisanal and small-scale gold mines, as well as outline plans for engaging relevant stakeholders (Sippl, 2015). Spiegel et al. (2015) were among the first authors to weigh in on how the Convention stands to impact the lives of the growing numbers of ASM operators in sub-Saharan Africa. The authors called for mineral policies to be overhauled, alongside efforts to implement NAPs, with a view toward implementing programs which recognize the resource rights of these ‘marginalized’ individuals.

The purpose of this article is to further this debate by examining in greater depth a subject that promises to become increasingly contentious during the three-year period ratifying countries are given to produce their NAPs: the formalization of ASM. To date, most African governments have been reluctant to embrace the livelihoods dimension of ASM in its entirety, unmoved by the barrage of calls (see e.g. Barry, 1996; ILO, 1999; Hentschel et al., 2002; AMV, 2009) made over the years by donors and scholars to do so. They have also been slow to recognize how access to steady supplies of inexpensive mercury, which facilitates ASM activity, ultimately sustains the livelihoods of tens of millions of otherwise-impoverished rural African families. The requirement for ratifying governments to outline, in NAPs, ‘Steps to facilitate the formalization or regulation of the artisanal and small-scale gold mining sector’ (Article 7, Paragraph 3), however, could spark a radical change in

1 ‘Minamata Convention on Mercury’, www.unenvironment.org/ar/node/10992 (Accessed 12 December 2017).

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regulatory stance and policy approach. For Spiegel et al. (2015), Article 7’s reference to formalization is a ‘complex but symbolically important measure that could benefit ASGM [artisanal and small-scale gold mining] communities’, and seen as possibly being a ‘defining moment where policymakers commit not merely to technical approaches for hazard reduction, but also to the promotion of equitable opportunities and rights in mining communities’ (p. 7). But it is unlikely that the Minamata Secretariat2 included a requirement to outline steps to formalize ASM because it was looking to pressure governments into embracing the livelihoods dimension of the sector. It was rather inserted because the ‘Regularization of artisanal miners is a necessary process in the early stages of engagement because it provides a legal framework to deal with ASM and opens the way to formalization’ (World Bank, 2009, p. 2). In the case of the Minamata Convention, establishing a platform for regulation and support is essential if mercury emissions are to be monitored and ultimately reduced at small-scale gold mines.

The discussion that follows provides an initial glimpse from the country level of how African governments are responding to the requirement to include in their NAPs steps for formalizing ASM. It draws heavily on findings from research being conducted in Ghana, Mali and Sierra Leone, the locations of some of the most sizable and eclectic ASM economies in sub-Saharan Africa.3 The paper captures how far removed policymakers and to some extent, donors, are from the dynamics of the sector’s activities and the day-to-day challenges faced by ASM operators.

2. Mercury Management at African Small-Scale Gold Mines: A Historical Snapshot

The way in which donors and policymakers have interpreted informality in the context of ASM is most closely aligned with the ‘legalist school’ (Chen, 2007).4 As UN officials explain (UNEP, 2012), echoing the position of the World Bank (World Bank, 2009), formalization of ASM is a process:

…that seeks to integrate [artisanal and small-scale gold mining] ASGM into the formal economy. The process of formalization includes the development or adaptation of mining (and other) laws or policies to address the challenges of ASGM. A well-designed formalization process generates the enabling conditions for accountability within the sector so that it can ultimately be integrated into the formal economy. Formalization can only be successfully achieved if programmes and public policy deal with the different dimensions of ASGM activities simultaneously and in an integrated way. Legalization is just one dimension of the process of formalization. [ p. 2]

In sub-Saharan Africa, mercury management strategy in ASM has been shaped heavily by actions taken to facilitate the formalization of the sector’s operations.

2 The NAP is an obligation for Parties to the Minamata Convention who reportedly have 'more than insignificant ASGM using mercury' in their territory. They are coordinated through the Minamata Secretariat, whilst funds are distributed by the Global Environmental Facility (GEF). Under the GEF, there are three implementing agencies for NAPs, each of which oversees their development: UNEP, UNIDO and UNDP. The NAPs are mostly executed by in-country ‘project coordinators’ – in most cases, a national ministry – which report to the implementing agencies.3 Of the three countries, Sierra Leone has the least developed artisanal and small-scale gold mining sector. Most of the gold being mined in the country is ‘free’, occurring alluvially and not requiring the application of mercury to recover. But there are recent reports of mercury use in the north of the country, and growing concern that it will migrate elsewhere. The use of mercury in Sierra Leone, however, is nowhere near as widespread as it is in Ghana or even Mali.4 The legalist school, headed by Hernando De Soto (De Soto, 1989), believe, inter alia, that costs, bureaucracy and complex regulations stifle formalization.

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The first comprehensive exercises undertaken in the region to combat mercury pollution at sites were fairly-autonomous. They were executed outside of, as opposed to alongside, host countries’ rural development programs and in some cases, independently of other donor-led work on ASM. When grafted on to the crude timeline for ASM assistance (Figure 1) outlined by Jennings (2003), these efforts punctuate a lengthy period dominated by strategies focused mostly on delivering technical support to operators and equipping them with environmental knowledge.

Table 1: Number of people engaged in ASM and status of the Minamata Convention on Mercury in selected countries in sub-Saharan Africa

Country Estimated ASM Population

Estimated Number of Dependents

Ratifying, Acceptance (A), Approval (AA), Ascension (a)

Angola 150,000 900,000 -Benin - - 07 Nov 2016Botswana 12,700 - 03 Jun 2016(a)Burkina Faso 200,000 1,000,000 10 Apr 2017 (a)Burundi 6,000–7,000 85,000 to 160,000 -Cameroon - - -Central African Republic 400,000 2,400,000 -Chad 100,000 600,000 24 Sep 2015Côte d’Ivoire 100,000 600,000 -Democratic Republic of Congo

200,000 1,200,000 -

Djibouti - - 23 Sep 2014Eritrea 400,000 2,400,000 -Ethiopia 500,000 3,000,000 -Gabon 5,000-10,000 - 24 Sep 2014 (A)Gambia - - 07 Nov 2016Ghana 1,100,000 4,400,000 23 Mar 2017Guinea 300,000 1,500,000 21 Oct 2014Guinea-Bissau - - -Lesotho - - 12 Nov 2014(a)Liberia 100,000 600,000 -Madagascar 500,000 2,500,000 13 May 2015Malawi 40,000 - -Mali 400,000 2,400,000 27 May 2016Mauritania - - 18 Aug 2015Mauritius - - 21 Sep 2017Mozambique 100,000 1,200,000 -Namibia 8,000-10,000 - 06 Sep 2017(a)Niger 450,000 2,700,000 09 Jun 2017Nigeria 500,000 2,500,000 -Rwanda - - 29 Jun 2017(a)Senegal 67,000 - 03 Mar 2016Seychelles - - 13 Jan 2015South Africa 20,000 - -Sierra Leone 300,000 1,800,000 1 Nov 2016South Sudan 200,000 1,200,000 -Swaziland - - 21 Sep 2016(a)Tanzania 1,500,000 9,000,000 -Togo - - 03/02/2017Uganda 150,000 900,000 -

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Zambia 25,000-50,000 - 11 Mar 2016Zimbabwe 500,000 3,000,000 -

Source: Data extracted from Hilson, 2016 and http://www.mercuryconvention.org/

Figure 1: Timeline for ASM assistance

Source: Adapted from Jennings, 2003

By the late-1980s and early-1990s, the mercury pollution problem in ASM was beginning to be examined more closely by policymakers, donors, the NGO community and the public, having been brought to their attention by scholars monitoring the gold rush in the Amazon at the time. A sizable body of work emerged (e.g. Pfeiffer et al., 1989; Malm et al., 1990) which detailed the contamination pathways of the methylated pockets of mercury generated by burgeoning ASM activity in the soils, vegetation and waterbodies in and around the Amazon rainforest. These efforts no doubt provided inspiration for parallel investigation (e.g. Porcella et al., 1997; Van Straaten, 2000) in sub-Saharan Africa.

The initial work undertaken in sub-Saharan Africa to combat mercury pollution at ASM sites was heavily concentrated in Ghana, Tanzania and Zimbabwe. In the 1990s, each country had in place fairly-advanced regulatory structures for ASM. They would, as a result, develop a unique comradery around ASM issues, each dispatching government officials throughout the decade and well into the 2000s to one another’s territories in a bid to ‘learn’ and ‘share’ best practices. The work undertaken in Ghana was funded by the German Technical Cooperative (GTZ), and included a fairly-comprehensive socio-economic analysis and a separate environmental study of ASM activities, each undertaken by local consultants (Boateng et al., 1993; Jumah, 1993), and the launch of a (now-defunct) equipment hiring scheme for miners (Amankwah and Anim-Sackey, 2003). The GTZ work served as a primer for interventions made under the World Bank-funded US$12.3 million Mining Sector Development and Environment Project, which, broadly, sought to improve the quality and strengthen the capacity of Ghana’s mining sector institutions (World Bank, 1995). A similar exercise was undertaken in Tanzania where, in 1994, the World Bank launched the US$12.5 million Mineral Sector Development Technical Assistance Project (World Bank, 1994). One of the goals of this project

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was ‘improving productivity and environmental and social ability of artisanal and small-scale miners’. It relied heavily on data retrieved from a baseline survey (Tan Discovery, 1996) conducted in eight mining zones (a study in which 108 sites across 37 administrative districts were visited). Under the project, training programs for miners on environmental issues were financed, more efficient technologies were disseminated, and operations were monitored.

At first, in both countries, activities undertaken to combat mercury pollution in ASM were integrated into the broader technical programs financed by the World Bank. In Ghana, World Bank officials acknowledged that ‘Some 4 to 5 tons of mercury are estimated to be released each year at the present level of small-scale mining activity’ (World Bank, 1995, p. 16); this prompted GTZ to introduce subsidized retorts,5 which were demonstrated by government officials to miners in several localities. In Tanzania, monies were put aside to finance an on-site technology demonstration program, conceived to educate miners about environment and health concerns, and to disseminate equipment, including mercury retorts (World Bank, 1994). In Zimbabwe, however, several projects were implemented around this time which targeted the mercury pollution problem in ASM specifically: the Shamva Mining Centre, funded by GTZ, the European Union and the Intermediate Technology and Development Group (ITDG), established to provide a ‘base’ for miners to crush their ore and amalgamate their gold in an enclosed environment; field testing of locally-fabricated retorts, also financed by ITDG; and a series of training seminars, funded and organized by the UK Department for International Development (DFID) and conducted in partnership with the Zimbabwe Geological Survey Department, for miners (UNECA, 2003).

But in all three countries, formalization was not seen to be a necessary first step for launching and carrying out these projects effectively and positioning governments to tackle the mercury pollution problem at ASM sites more generally. This was somewhat surprising given what was confirmed in each country at the outset: that costly payments for licenses and/or bureaucratic registration processes were impeding the formalization of ASM. Notably, in Tanzania, according to findings from the World Bank-funded socioeconomic study (Tan Discovery, 1996), the number of registered mineral claims handled by the Mines Division of the Mineral Resources Department increased from 425 in 1991 to 4123 in 1995. It was reported that there were insufficient facilities and budgetary funds (the Songea office, for example, did not have a vehicle but was asked to monitor localities such as Tunduru, where there were an estimated 200,000 artisanal miners and which is located 300 km away) on-hand for local government officers to carry out their day-to-day tasks and because of the backlog of paperwork, prospective licensees were forced to wait up to 12 months for decisions on their application. The World Bank-funded study in Ghana (Boateng et al., 1993) yielded similar results, reporting that travel to the country capital of Accra to sell gold, which incurred high transportation costs and hotel bills, and posed a series of risks, was encouraging smuggling and illicit trading within the country.

The policy response, however, was to strengthen institutional support for the ASM sector and provide services for licensed operators. Significantly, these moves were not made to address the abovementioned concerns raised in Ghana and Tanzania, and similar views being voiced at the time by other commentators (e.g. Davidson, 1993; UN, 1996) about bureaucratic licensing schemes and costly registration fees stifling the formalization of ASM activities in sub-Saharan Africa. They were rather made to support what was widely believed to be a sector comprised mostly of enterprising businesspeople, the dominant view of ASM at the time. Noetsaller’s (1987) pioneering report, Small-Scale Mining: A Review of the Issues, published on behalf of the World Bank, laid the

5 A retort, is a simple system assembled with a closed crucible connected to a condenser, designed so that mercury from gold amalgam evaporates when heated.

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foundation for this policy position. The document is punctuated with snippets of text which portray ASM in an entrepreneurial light, including ‘In contrast to large-scale industry, the small enterprise segment has consistently been identified as a fertile ground for the growth of indigenous entrepreneurship’ (p. 16), and ‘Rapid mine development means quick returns for the entrepreneur’ (p. 17). Views such as these would inform the design of A Strategy for African Mining (World Bank, 1992), the World Bank’s blueprint for mining sector reform in sub-Saharan Africa. This landmark document not only projected ASM in the region as an entrepreneurial venture but even went as far as to argue that it should be viewed in the same light as foreign large-scale multinationals, stating that ‘There is no good reason to create differential access to mineral rights for different classes of mining investor’, and that ‘A state mining enterprise should compete on the same terms as a privately-owned company, foreign on the same terms as national, large companies under the same rules as small ones’ (p. 22). Most African governments have relied heavily on A Strategy for African Mining as a guide for implementing mining sector reforms.

The government response in both Tanzania and Ghana was to launch a dedicated ASM project. In the former, the Small-Scale Mining Development Office of the Ministry of Energy was set up to ‘legalize the informal segment of the sub-sector and to progressively transform artisanal operations, health and safety standards and to eliminate undesirable environmental practices in all high-density artisanal and small scale mining districts’, and to ‘Enhance productivity and mineral recovery through the introduction of appropriate mining and processing equipment, combined with basic technical and business training’ (Tan Discovery, 1996, p. 3). In the latter, GTZ funded the Small-Scale Mining Project, an institutional arrangement established to undertake ‘an analysis of the needs of the sub-sector’, and which ‘identified the main constraints and initiated pilot testing of improved mining and processing techniques and equipment’ (World Bank, 1995, p. 8). A similar approach was taken in Zimbabwe, where, in 1991, to harness the entrepreneurial spirit in ASM, the central government passed the Mining (Alluvial Gold) (Public Streams) Regulations, which officially legalized gold panning in the country. It then proceeded to authorize local government offices (the Rural District Councils or RDCs) to issue panning permits to ‘approved’ local persons, cooperatives and partnerships. Many RDCs were also used as bases for demonstrating and distributing retorts and mercury-free technologies (Maponga and Ngorima, 2003). In all three countries, however, registered operators were targeted, presumably because it was believed that they would transfer knowledge to colleagues, and that the services and equipment made available to licensees – assay laboratories, crushers and pumps – would facilitate marked mechanization in, and improved productivity of, the sector.

The view that ASM is populated mostly by skilled, enterprising individuals, and moves made to institute regulations and policy apparatuses which reflect this position, has influenced efforts to tackle the sector’s mercury pollution problem in sub-Saharan Africa. Specifically, a conscious decision to target licensed miners has meant that the informal ‘spaces’ which contain the bulk of the region’s ASM population and ‘the worst environmental of offenders’ (MIME, 2002, p. 58-59) have gone overlooked. This has proved to be a significant oversight because in all corners of sub-Saharan Africa, these informal ‘spaces’ have, in recent decades, become popular destinations for nonminers in search of supplementary income. Whilst the view that ASM is poverty-driven was beginning to be debated at the time (Labonne, 1994; Barry, 1996), African policymakers and many of the donors financing support services for the sector were reluctant to embrace the idea completely. But it is unlikely that even the most forward-thinking governments could have anticipated how structural adjustment lending, a centrepiece of donor strategy in the 1980s and 1990s, would create such a sizable pool of redundant labourers in sub-Saharan Africa in the manufacturing and public sectors

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who would eventually turn to ASM out of desperation for income.6 Nor could they have predicted how sweeping agricultural reforms would cripple so many of the region’s subsistence farm families, leading many to ‘branch out’ into ASM out of desperation, in many cases to acquire funds to purchase crucial agricultural inputs such as fertilizers (e.g. Maconachie and Binns, 2007; Fanthorpe and Maconachie, 2010; Kamlongera, 2013; Hilson and Garforth, 2013; Pijpers, 2014). The 36 countries in sub-Saharan Africa that were in the process of overhauling or implementing legislative and policy frameworks for ASM in the mid-1990s were, in the spirit of A Strategy for African Mining, doing so with the aspiring entrepreneur in mind, not to cater to the more sizable poverty-driven groups. These policy and regulatory apparatuses would further cement the boundaries of the informal ASM ‘spaces’ found in sub-Saharan Africa today, and into which many poverty-driven people continue to move.

Dialogue around ASM being ‘poverty-driven’ and having an overlooked livelihoods dimension failed to change policy. By the time the UN launched the multimillion dollar Global Mercury Project (GMP) – which, before Minamata, was the most comprehensive undertaking made to tackle mercury pollution at small-scale gold mines to date – in August 2002, the problem was, to paraphrase Jennings (2003), still being viewed and treated as a technical and environmental issue. The reconnaissance exercises being carried out on ASM livelihoods in the early-2000s across sub-Saharan Africa by other branches of the UN and bilateral agencies (Labonne, 2003; Mwaipopo et al., 2004) were conducted independently of mercury-related work and, more significantly, outside of the region’s rural development policy architecture. With host governments failing to recognize how embedded ASM is across rural sub-Saharan Africa, it is unlikely that any discussion about how access to mercury drives the region’s rural economies would have been embraced at this time. The GMP and most of the complementary mercury-related work carried out in Ghana, Zimbabwe and Tanzania would, consequently, become illustrative examples of what ILO officials, commenting nearly 20 years ago, referred to as ‘projects to assist small-scale mining’ with ‘relatively short-lived success’ because of ‘the low priority given by [their] governments to small-scale mining’ (ILO, 1999, np).

Will the Minamata Convention usher in a radical change in approach? As indicated at the outset of this paper, it demands that ratifying countries outline ‘Steps to facilitate the formalization or regulation of the artisanal and small-scale gold mining sector’. This should force host governments to embrace beyond superficial policy treatment the livelihoods ‘dimension’ of ASM, in this case paying closer attention to the long-neglected socioeconomic side of mercury use, in particular how it is supplied and distributed; the need to educate operators on how to use it safely; sensitization of populations to alternatives; and how, given the sector’s links with agriculture (it enabling rural families to purchase crucial farm inputs), steady supplies of it sustains rural populations. It should force host governments to study more closely the dynamics of the informal ASM ‘spaces’ now populated by eclectic groups of operators to identify ways to bring individuals into the legal domain and establish a platform needed to ensure the effective execution of NAPs.

The challenge promises to be enormous. In the early 1990s, when the first comprehensive steps were being taken to address the mercury pollution problem at ASM sites in sub-Saharan Africa, there were reports (see e.g. Chachage et al., 1993; World Bank, 1994) of informal ‘spaces’ having

6 Structural adjustment loans are comprehensive financial packages awarded by the World Bank and International Monetary Fund to developing countries. They have been criticized because in exchange for the funding and in order to prequalify for any additional lending, recipient countries must make sweeping policy changes, including deregulating their markets, devaluing their currency, and privatizing parastatals and other state assets.

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proliferated, containing, in many cases, hundreds of thousands of unlicensed operators. In rural sub-Saharan Africa, these deeply-entrenched ‘spaces’ are now controlled by a series of middlemen, chiefs and local government officials, who have every reason to prevent the formalization of the sector.

3. Formalization of Small-Scale Gold Mining under the Minamata Convention: The Case of West Africa

Whilst certainly time-consuming and laborious, the tasks needed to be undertaken as part of a NAP (see Clifford, 2014; Spiegel et al., 2015) seem straightforward. Formulating ‘Steps to facilitate the formalization or regulation of the artisanal and small-scale gold mining sector’, however, presents an entirely different challenge. Spiegel (2016) reflects on what this would entail in Cambodia, a sizable ASM economy in Asia. The author points out that the Convention’s ASM formalization mandate ‘stands at odds with a second spatial governance strategy – the current prioritization of larger-scale companies’ concessions’, and that ‘In most mineral-rich regions of Cambodia’, this has led to ‘mining and/or mineral exploration rights’ being ‘granted to established foreign or local companies (in some cases overlapping with other companies’ land concessions), raising questions about whether there are practical possibilities for licensing ASM’ (p. 560). Similar developments have taken place across West Africa, where mining policies have what Hilson (2017a) refers to as a large-scale ‘bias’: exuding a preference for foreign-financed, industrial mineral extraction and processing. In all corners of sub-Saharan Africa, this ‘bias’ has pushed ASM into the informal sector. As pointed out, throughout the region, an array of actors, including traditional leaders, corrupt policemen, local government officials, and middlemen (ILO, 1999; Hilson et al., 2014), are benefitting from the sector being in this largely-unlicensed state and therefore, have little to gain from it being formalized.

Drawing on findings from research being carried out in Ghana, Mali and Sierra Leone, the locations of three of the more dynamic ASM economies in sub-Saharan Africa today, this section of the paper builds on this analysis. In addition to key donors in charge of managing the ASM ‘space’ of the Convention, interviews were conducted with representatives from the national and international executing agencies for each of the three countries, as well as policymakers. Reflecting on data from these interviews, the discussion that follows weighs in on what formulating ‘Steps to facilitate the formalization or regulation of the artisanal and small-scale gold mining sector’ has meant for Ghana, Mali and Sierra Leone. The research undertaken in these countries has, thus far, unearthed two potential concerns, each of which is discussed below: 1) the lack of an institutional framework to facilitate formalization; and 2) the political will to make this happen.

3.1 Laying the Institutional Bedrock

For NAPs to materialize and be implemented effectively, institutional bedrock needs to be laid in countries where ASM activity is ‘more than insignificant’. The Secretariat has already initiated this but the concern moving forward is whether the most appropriate institutional partners have been selected.

The struggles donors and host governments have had – once again, paraphrasing Jennings (2003) – with detaching themselves from a purely-technical and environment-led development agenda for ASM has undoubtedly influenced the approaches pursued under Minamata to tackle mercury pollution at sites. The Secretariat has made a conscious effort to brand the development of NAPs as environmental policy exercises, as reflected by its choice of institutional partners as the ‘national executing agency’:

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Well, in terms of who we choose to work with in the government, I mean, a lot, well the default I suppose is whatever ministry the government is involved in the intergovernmental process of the Minamata Convention. That’s usually the Ministry of the Environment. That’s our first contact…7

Ghana (the Environmental Protection Agency or EPA), Sierra Leone (Environmental Protection Agency or EPA) and Mali (Le Ministre de l'Environnement et de l'Assainissement du Mali) have all followed this script. The problem, however, is that none of these agencies regulates or licenses ASM, and therefore, is in no position to identify plausible steps to formalize activities.

In Ghana, small-scale gold mining licenses are awarded by the Minerals Commission, which has nine district centres across the country. Each centre is tasked with monitoring ASM activities in its ‘jurisdiction’ and is a first point of contact for prospective licensees, their staff overseeing the completion of all necessary paperwork concerning site plans, after which completed application packages are sent to decision-makers in the country capital of Accra. Aside from administering a controversial Environmental Impact Assessment (EIA), the Mining Division of the Ghana EPA has no regulatory responsibilities for ASM. But whilst it makes little sense for the EPA to be the national executing agency for the NAP, what is even more inexplicable is that it is the organization’s Chemicals Division, not its Mining Division, which has been assigned this task. An official at the Chemicals Division was asked during an interview about whether its staff dialogues with the Mining Division of the EPA and the Minerals Commission on Minamata-related issues:

The Minerals Commission is part of the stakeholder groups but we do not work with them. When it comes to the implementation, maybe then we will work with them. But for now, just stakeholder consultation…for EIAs but I am not sure what they do. It is not the remit of this office to do this.8

Is the Chemicals Division, despite having little expertise in this area, being asked to formulate ‘ Steps to facilitate the formalization or regulation of the artisanal and small-scale gold mining sector’?

But whilst in Ghana, the problem appears to be a disconnect between agencies, in Sierra Leone, there is a conflict. Although not referring to Sierra Leone specifically, a donor official explained in an interview that, ‘One example of a difficult situation I guess we’re working with an African Government on a NAP and we’re trying to instil the need to be inter-ministerial and coordinate but this ministry of environment it doesn’t come naturally so for example at the beginning so just getting them to invite the right people to the inception workshop from different ministries is a challenge, getting them to seek the expert consultants they need, even if it is not an employ of their ministry, it’s been a challenge’.9 This, however, is precisely what is happening in the country: officials at the National Minerals Agency (NMA), responsible ‘for administration and regulation of the minerals sector’,10 and the executives at the EPA are struggling to work with one another on most mining-related matters. The problem stems from the NMA being starved for resources and generating menial finance through licensing, and the EPA chasing mining and mineral exploration companies for large fees for EIAs. The latter’s pursuit of these monies has hampered the former’s ability to make timely decisions on licenses, which, along with a general clash in personalities between upper management, has led to friction between the two organizations.

7 Interview, donor official, Geneva.8 Interview, EPA official, Accra.9 Interview, donor official, Geneva.10 ‘Ministry of Mines and Mineral Resources’, https://slminerals.org/about-national-minerals-agency/ (Accessed 3 January 2017).

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The Minamata Convention could lead to even further friction between the organizations. On the one hand, there is the NMA, which, through its regional offices, is responsible for administering ‘artisanal mining licenses’ and monitoring their activities. Its officers, however, do not believe that the environmental impacts in this sector warrant a critical ‘rethink’ of monitoring and regulatory strategy:

You are not required to do an EIA for artisanal…For the artisanal, if you are using simple tools like pickaxe and shovel, we are not anticipating much environmental damage.11

Yet, despite these claims, NMA officials possess little knowledge of the whereabouts of informal artisanal gold mining activities. Diamond mining continues to be the focal point of the country’s extractive industries portfolio and the main preoccupation of the NMA, so much so that most of the gold being extracted in the country on an artisanal scale is being smuggled into neighbouring Guinea, with little resistance.12 The NMA has shown very little interest in developing and supporting the country’s artisanal gold mining activities let alone monitoring them, and even if they did commit to collecting data on the sector, they are not, as one official put it in an interview, in a position to do so because ‘Our regional offices are not up to where we want them’ and ‘[need] to be capacitated to do the job’.13

On the other hand, it appears that officials at the EPA see the situation very differently, perhaps because they have identified yet another opportunity to generate finance through permitting. Presently, the organization has no regulatory responsibilities in the artisanal mining ‘space’; it is the more advanced ‘small-scale mining’ which it monitors and issues EIAs to. But the Minamata Convention could usher in change in this area and, consequently, strain the relationship between the EPA and NMA even further. When queried about the formalization issue, one official expressed enthusiasm about the idea of working toward ‘Transforming the sector into a legal activity by developing guidelines, regulations and issuing licences of minimal fees’.14 At this point, however, neither the EPA nor the NMA, with their limited resources and other commitments, are in a position to identify tangible ‘Steps to facilitate the formalization or regulation of the artisanal and small-scale gold mining sector’ on their own. Moving forward, some type of working partnership will need to be forged and resources pooled, but with both unwilling to work with one another, this is unlikely to happen in the short-term.  Another challenge that will need to be addressed is the lack of coordination. For a problem (mercury pollution at artisanal and small-scale gold mines) that persists regionwide and which is being perpetrated by actors both within and outside of sub-Saharan Africa, the approach taken to formulate NAPs is fragmented. West Africa is no exception: despite being interconnected in many ways, each country that has ratified the Convention is formulating its own NAP in relative isolation. It begins with geology; it is one of the world’s most gold-rich territories, boasting combined production and reserves of close to 10,000 metric tons (Goldfarb and André-Mayer, 2017). Deposits are heavily concentrated in a series of greenstone belts, and can support a range of operations, from artisanal and small-scale setups, through to capital-intensive, foreign-owned large-scale projects. This abundance of gold-rich terrain, however, has created markets for opportunistic merchants who sell and distribute equipment and supplies of mercury, and has stimulated mass movements of

11 Interview, NMA official, Freetown.12 ‘Sierra Leone’s “cheap gold” entices the gullible’, https://www.reuters.com/article/uk-sierraleone-fraud/sierra-leones-cheap-gold-entices-the-gullible-idUKTRE7112F920110202 (Accessed 12 December 2017).13 Interview, EPA official, Freetown.14 Interview, EPA official, Freetown.

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capital and labour both within countries and across borders. Whilst more research is needed to understand fully the dynamics of these markets, based on claims and anecdotal evidence, there is reason to believe that mercury and Chinese-manufactured ASM technologies are arriving in Lomé, the capital of and a duty-free port in Togo, entering Ghana and migrating northward to Burkina Faso, and westward into Mali, Sierra Leone and Liberia (Figure 2). As it stands, the three study countries have the same ‘implementing agency’ (the United Nations Development Program) but each has a different international ‘executing agency’;15 for Mali, the Artisanal Gold Council,16 and for Ghana and Sierra Leone, UNITAR (Table 2). Each is likely to produce a comprehensive NAP; however, the concern is that because each has been produced independently, there will be a general underappreciation of these trans-border dynamics. Knowledge of these details is crucial for identifying sources of finance, mercury and labour in any ASM community in West Africa, and a key to developing steps to formalize the sector.17

Table 2: Minamata Institutional Framework in Ghana, Mali and Sierra Leone

Country GEF Project Coordinator

Implementing Agency

National Executing Agency

International Executing Agency

Sierra Leone UNEP UNEP EPA UNITAR

Mali UNEP UNEP

Le Ministre de l'Environnement et de l'Assainissement du Mali

Artisanal Gold Council

Ghana UNDP UNIDOEPA/National Resources Defence Council

UNITAR

The Convention is, as one donor official put it, ‘very clear in stating only the obligation to “develop steps to regulate or formalize the sector”, but it is not even speaking about developing a full strategy, let alone implementing it’.18 Formalization, however, is a necessary first step toward operationalizing the Minamata Convention at the country level because it establishes a – hitherto non-existent – platform for regulating and monitoring. It is the burgeoning ‘spaces’ in which ASM activities proliferate where mercury pollution poses the greatest threat. In the three study countries, the national ‘executing agency’ tasked with assembling NAPs seems far removed from the realities of artisanal mining. Neither is well-positioned to identify steps to formalize ASM.

15 An organization which carries out a range of work in the area of environmental protection (see https://www.nrdc.org/) 16 An organization that assists small-scale miners transition to mercury-free setups (see http://www.artisanalgold.org/our-approach/)17 Given the transboundary nature of the mercury pollution problem in the ASM sector, it is crucial that countries in West Africa, particularly those which share borders, work together during the early stages of the Minamata process, with the aim of producing NAPs which accurately reflect the realities on the ground. This is by no means a far-fetched possibility, as some West African countries have worked on mining issues in the past, the most illustrative example being the work undertaken by Mano River Union Countries (Côte d'Ivoire, Guinea, Liberia and Sierra Leone) as part of the Kimberley Process to curb the illicit flows of rough diamonds. There has also been dialogue between West African government about harmonizing taxes on minerals and working together to prevent the smuggling of gold and diamonds.18 Interview, donor official, Geneva.

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Figure 2: Migration of capital, labour and mercury flows in ASM in West Africa

Source: developed from the authors’ fieldwork and notes

3.2 Establishing a Platform for Formalization

In demanding that plans for formalizing ASM be included in NAPs, the assumption being made by donor officials is that host governments are able and more importantly, willing, to undertake the task. Acknowledging that costly licensing systems and bureaucratic registration systems are stifling the formalization of ASM activities, one explained in an interview that ‘During the negotiations at the Minamata Convention on ASGM, there was a lot of recognition that formalization is key in some ways is fundamental that criminalizing the sector doesn’t help in fact it makes things harder to engage with the sector’.19 Another expressed optimism over the governments of ratifying countries having recognized this:

I think a lot of people are recognizing that legalizing and making access to permitted mining works more effectively than trying to make it illegal and trying to chase miners…And I think some semi-decriminalizing was a part of a lot of this strategy…20

Most of the ASM licensing schemes implemented in sub-Saharan Africa to date, however, are complex, and despite repeated calls made over the past three decades to make these systems more user-friendly and pro-poor, little has changed.

The three study countries are no exception, but what is most surprising in these cases, is that despite being interconnected geologically and financially in many ways, each has a very different approach to formalization. At the one extreme is Ghana, which, at the time of writing, had a ban in

19 Interview, donor official, Geneva.20 Interview, donor official, Geneva.

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place on all ASM activities. Whilst a Minamata representative interviewed in Ghana acknowledged that, ‘For a long time, small-scale mining was an illegality,…[but] we realize that people depend on the sector, [and] that it brings revenues to Ghana’,21 a decision was taken in April 2017 to institute this ban, which led to a dispatching of military personnel to sites, a move made to tackle informality and to ‘restore sanity’ in the sector (Hilson, 2017b). Ghana has been singled out over the years as an illustrative example of where a combination of prohibitive licensing costs, a bureaucratic application process, and a shortage of available land to parcel out as registered concessions – manifestations of a large-scale ‘bias’ – has kept ASM in the informal economy (see Tschakert and Singha, 2007; Hilson et al., 2014; Patel et al., 2016). Here, a commitment to formalization would entail reversing the mining and development strategy that ringfences space for large-scale activities whilst marginalizing and criminalizing artisanal operators. This is unlikely to happen, at least in the short term.

At the other extreme are Sierra Leone and Mali, where it seems that the only place ASM can flourish is in the informal sector. There are two points worth noting, the first being that, like Ghana, here, ASM is not viewed as a priority area of development. In both countries, the awarding of permits and monitoring of activities is conducted by local agencies, giving rise to quasi-legal structures: in Mali, an autorisation d’exploitation is granted by a traditional authority to Malian nationals to work in designated ‘corridors of gold mining’,22 whilst in Sierra Leone, the regional NMA offices award artisanal mining licenses, as noted earlier.23

The second point is that, in Mali and Sierra Leone, there is also a large-scale mining ‘bias’. Both governments, choosing to overlook who mostly populates informal mining ‘spaces’, are of the view that an artisanal setup can ‘graduate’ to a ‘small-scale’ level, or transition from using, what one government described in an interview ‘basic tools and equipment, pick and shovel and thing’ to using ‘nice equipment’.24 Whilst the incentive in ‘graduating’ may be permission to use heavy machinery, in both Sierra Leone and Mali, obtaining the requisite permits to become recognized ‘small-scale miners’ is costly and laborious. In the case of the former, the most significant requirement is a time-consuming and costly EIA, and which must be approved by the Minister of Mines and Mineral Resources in the country capital of Bamako. For the latter, it is the need to possess an exploration permit or prospecting license, as well as completing a feasibility report. But being a part of predominantly poverty-driven masses, most artisanal miners are unable to ascend to the small-scale level in the way in which both countries’ officials seem to believe.

If the sector is to be formalized, then this ‘bias’ will need to be confronted at some point. But will there be enough momentum to do so? In Ghana, it will require reversing a ban on all ASM activities, and changing the ‘mindset’ of a government that continues to prioritize large-scale mineral extraction and exploration, and which, at the time of writing, had awarded 68,325.78 km2 of its lands to companies operating in this ‘space’; in Mali, overhauling legislation that at present, empowers a large-scale mining company, once in possession of a research or exploitation permit, to remove those in possession of an autorisation d’exploitation from its concession; and in Sierra Leone, convincing a government that is paving the way for large-scale mine development, an approach epitomized effectively by claims made by one official in an interview that ‘of course [we want large-scale mining]…because we need investment [and] large-scale mining makes us more money’, 25 to reverse its course.

4. Conclusion

21 Interview, government official, Accra.22 See Article 57 of Order No 99-032/P-RM of the Mining Code of Mali.23 See Part X of the Mines and Minerals Act, 2009.24 Interview, government official, Freetown.25 Interview, government official, Freetown.

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This article has furthered the debate on the impacts of the Minamata Convention on ASM in sub-Saharan Africa by drawing attention to what promises to be a contentious issue: formalization. Development if this sector has never been viewed as a priority undertaking in sub-Saharan Africa, which could cause complications for ratifying countries required to produce NAPs. The paper has drawn on findings from research being carried out in Ghana, Mali and Sierra Leone – the locations of three of the region’s most dynamic and burgeoning small-scale gold mining economies – to make this case.

As a point of departure, there are two very significant issues worth noting, both of which concern the ‘project coordinators’. The first is the decision made by the Minamata Secretariat to select an environmental ministry as executing agencies for NAPs. Being an environmental problem, this decision may, on the surface, seem logical, but it also has the effect of restricting the focus on an issue which has many more dimensions. This change also runs the risk of politicizing the ministerial landscape, as may be the case in Sierra Leone and Ghana, where all responsibilities for regulating ASM lie with different agencies.

The second, and perhaps most disconcerting, issue relates to the national executing agencies themselves, specifically, why, given their lack of expertise on the ASM front, they would agree to taking on a leadership role in formulating NAPs. This concern was reinforced during interviews with government officials: with formalization being a key element of the NAPs, it is unclear – particularly with an environment-focused agenda – how individuals with so little knowledge of ASM could possibly identify plausible steps for achieving this. It would not be far-fetched to conclude that the decision to proceed, despite a lack of understanding of the sector’s dynamics, was finance-related. A nominal amount of US$200,000 is available for an initial assessment ‘that’s designed to help the country go through the process of what do we have legally, what problems with mercury do we have, do an inventory, set up the process to see what new legislation and regulations might be needed and hopefully, they have all of that drafted, and they are able to ratify the convention’, and for NAPs ‘they are a larger amount…, established with a basic amount of US$500,000 US dollars and the idea with that is that you would use the funds to develop a national action plan’.26

Although – and to paraphrase what one donor stated in an interview 27 – at this stage, ratifying countries with ‘more than insignificant’ ASM activity need only to identify steps to regularize the sector. Formalization provides the elusive platform needed to facilitate regulation and effective monitoring in the sector. Moving forward, how sub-Saharan Africa – a region of the world where most ASM activities are found in informal ‘spaces’ – embraces this challenge will go a long way toward shaping the Minamata Convention’s legacy.

26 Interview, donor official, Geneva.27 Interview, donor official, Geneva.

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-Acknowledgements

The authors would like to thank Jorden de Haan and two anonymous reviewers for their comments on an earlier draft of this paper. Funding for this research was provided by a small grant, ‘Rethinking' the Minamata Convention: Minimizing Mercury Pollution in Africa's Small-Scale Gold Mining Sector, awarded by the Higher Education Funding Council for England.

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References

Africa Mining Vision (AMV). 2009. Africa Mining Vision. African Union, Addis Ababa.

Amankwah, R., Amin-Sackey, C. 2003. Strategies for sustainable development of the small-scale gold mining and diamond industry of Ghana. Resources Policy 29: 131-138.

Barry, M. (ed.). 1996. Regularizing Informal Mining: A Summary of the Proceedings of the International Roundtable on Artisanal Mining. World Bank, Washington DC.

Boateng, D. A., Ofei-Aboagye, E., Nsiah, T.K. 1993. Socio-Economic Impact Study. Report prepared for the Ghana Minerals Commission and GTZ, Berlin.

Chachage, C.S.L., Ericsson, M., Gibbon, P. 1993. Mining and Structural Adjustment: Studies on Zimbabwe and Tanzania. Scandinavian Institute of African Studies, Uppsala.

Chen, M.A. 2007. Rethinking the Informal Economy: Linkages with the Formal Economy and the Formal Regulatory Environment. DESA Working Paper 46, UN Department of Economic and Social Affairs, Geneva.

Clifford, M. 2014. Future strategies for tackling mercury pollution in the artisanal gold mining sector: Making the Minamata Convention work. Futures 62: 106-112.

Davidson, J., 1993. The transformation and successful development of small-scale mining enterprises in developing countries. Natural Resources Forum 17(4): 315–326.

De Soto, H. 1989. The Other Path. Harper & Row Publishers, New York.

Fanthorpe and Maconachie (2010) Beyond the 'crisis of youth'? Mining, farming, and civil society in post-war Sierra Leone. African Affairs 109(435), 251-272.

Ferring, D., Hausermann, H., Effah, E. 2016. Site specific: Heterogeneity of small-scale gold mining in Ghana. The Extractive Industries and Society 3(1): 171-184.

Gibb, H., O’Leary, K. G. 2014. Mercury exposure and health impacts among individuals in the artisanal and small-scale gold mining community: a comprehensive review. Environmental Health Perspectives 122(7): 667-672.

Goldfarb, R.J., André-Mayer, A.S. 2017. West Africa Gold: Preface. Economic Geology 112: 1-2.

Hentschel, T., Hruschka, F., & Priester, M. 2002. Global report on artisanal and small-scale mining. Mining, Minerals and Sustainable (MMSD) Project, International Institute for Environment and Development, London.

Hilson, G. 2016. Farming, small-scale mining and rural livelihoods in Sub-Saharan Africa: a critical overview. The Extractive Industries and Society 3(2): 547-563.

Hilson, G. 2017a. Why is there a large-scale mining ‘bias’ in sub-Saharan Africa? Land Use Policy (accepted for publication). http://dx.doi.org/10.1016/j.landusepol.2017.02.013.

19

Hilson, G. 2017b. Shootings and burning excavators: Some rapid reflections of the Government of Ghana’s handling of the informal galamsey mining ‘menace’. Resources Policy 54: 109-116.

Hilson, G., Garforth, C. 2013. ‘Everyone now is concentrating on the mining’: drivers and implications of rural economic transition in the Eastern Region of Ghana. The Journal of Development Studies 49(3): 348-364.

Hilson, G., Hilson, A., Adu-Darko, E. 2014. Chinese Participation in Ghana’s Informal Gold Mining Economy: Drivers, Implications and Clarifications. Journal of Rural Studies 34: 292-302.

Hirons, M. 2014. Shifting sand, shifting livelihoods? Reflections on a coastal gold rush in Ghana. Resources Policy 40: 83-89.

International Labour Organization (ILO). 1999. Social and Labour Issues in Small-Scale Mines. International Labour Organization (ILO, Geneva).

Jennings, N. 2003. Addressing labour and social issues in small-scale mining, pp. 140-148, in The Environmental and Socioeconomic Impacts of Artisanal and Small-Scale Mining in Developing Countries (ed. G.M. Hilson), A.A. Balkema, the Netherlands.

Jumah, A. 1993. Environmental Audit to Study the Effects of Small Scale Mining Activities on Vegetation. Report prepared for the Ghana Minerals Commission and GTZ, Berlin.

Kamlongera, P. J. 2013. The mining boom in Malawi: implications for community development. Community Development Journal 48(3): 377-390.

Labonne, B. 1994. Small- and medium-scale mining: The Harare seminar and guidelines. Natural Resources Forum 18(1): 13-16.

Labonne, B. 2003. Seminar on Artisanal and Small-scale Mining in Africa: Identifying Best Practices and Building the Sustainable Livelihoods of Communities, in The Environmental and Socioeconomic Impacts of Artisanal and Small-scale Mining in Developing Countries (ed. G.M. Hilson), pp. 131–50. A. A. Balkema, the Netherlands.

Maconachie, R. 2011. Re-agrarianizing livelihoods in post-conflict Sierra Leone? Mineral wealth and rural change in artisanal and small-scale mining communities. Journal of International Development 23(8):1054-1067

Maconachie, R., Binns, T. 2007. Mining farmers or farming miners? Journal of Rural Studies 23: 367–380

Maconachie, R., Hilson, G. 2011. Artisanal gold mining: A new frontier in post-conflict Sierra Leone? Journal of Development Studies 47(4): 595-616.

Malm, O., Pfeiffer, W. C., Souza, C. M., Reuther, R. 1990. Mercury pollution due to gold mining in the Madeira River basin, Brazil. Ambio 19(1): 11-15.

Maponga, O., Ngorima, C. 2003. Overcoming environmental problems in the gold panning sector through legislation and education: the Zimbabwean experience. Journal of Cleaner Production 11(2): 147-157.

20

MIME. 2002. Poverty Eradication & Sustainable Livelihoods: Focusing on Artisanal Mining Communities. Report prepared by MIME Consult for the United Nations Department for Economic and Social Affairs.

Mwaipopo, R., Mutagwaba, W., Nyange, D., Fisher, E. 2004. Increasing the contribution of artisanal and small-scale mining to poverty reduction in Tanzania. Department for International Development, London.

Noetstaller, R. 1987. Small-Scale Mining: A Review of the Issues. World Bank, Washington DC.

Patel, K., Rogan, J., Cuba, N., Bebbington, A. 2016. Evaluating conflict surrounding mineral extraction in Ghana: Assessing the spatial interactions of large and small-scale minig. The Extractive Industries and Society 3: 450-463.

Pfeiffer, W. C., de Lacerda, L. D., Malm, O., Souza, C. M. M., da Silveira, E. G., Bastos, W. R. 1989. Mercury concentrations in inland waters of gold-mining areas in Rondonia, Brazil. Science of the Total Environment 87: 233-240.

Pijpers, R. 2014. Crops and carats: Exploring the interconnectedness of mining and agriculture in Sub-Saharan Africa. Futures 62: 32-39.

Porcella, D. B., Ramel, C., Jernelov, A. 1997. Global mercury pollution and the role of gold mining: an overview. Water, Air, and Soil Pollution 97(3-4): 205-207.

Selin, N. E. 2011. Science and strategies to reduce mercury risks: a critical review. Journal of Environmental Monitoring 13(9): 2389-2399.

Sippl, K. 2015. Private and civil society governors of mercury pollution from artisanal and small-scale gold mining: A network analytic approach. The Extractive Industries and Society 2(2):198-208.

Spiegel, S, Keane, S, Metcalf, S, Veiga, M. 2015. Implications of the Minamata Convention on Mercury for informal gold mining in Sub-Saharan Africa: from global policy debates to grassroots implementation?: from global policy debates to grassroots implementation? Environment, Development and Sustainability 17(4): 765–785.

Spiegel, S.J. 2016. Land and ‘Space’ for Regulating Artisanal Mining in Cambodia: Visualizing an Environmental Governance Conundrum in Contested Territory. Land Use Policy 54: 559-573.

Tan Discovery. 1996. Final report on baseline survey and preparation of development strategy for small scale and artisanal mining program. Report prepared for the World Bank, Washington DC.

Tschakert, P., Singha, K. 2007. Contaminated identities: Mercury and marginalization in Ghana’s artisanal mining sector. Geoforum 38(6): 1304-1321.

United Nations (UN). 1996. Recent developments in small-scale mining: A Report of the Secretary-General of the United Nations. Natural Resources Forum 20(3): 215-225.

United Nations Environment Program (UNEP). 2012. Analysis of formalization approaches in the artisanal and small-scale gold mining sector based on experience in Ecuador, Mongolia, Peru, Tanzania, and Uganda. United Nations Environment Program, Nairobi.

21

United Nations Environment Program (UNEP). 2013. Mercury: Time to Act. United Nations Environment Program, Nairobi.

United Nations Economic Commission for Africa (UNECA). 2003. Compendium on best practices in small-scale mining in Africa. United Nations Economic Commission for Africa, Addis Ababa.

Van Straaten, P. 2000. Human exposure to mercury due to small scale gold mining in northern Tanzania. Science of the Total Environment 259(1-3): 45-53.

Veiga, M. M., Angeloci-Santos, G., Meech, J. A. 2014. Review of barriers to reduce mercury use in artisanal gold mining. The Extractive Industries and Society 1(2): 351-361.

World Bank. 1992. A Strategy for African Mining. World Bank, Washington DC.

World Bank. 1994. Tanzania – Mineral Sector Development Technical Assistance Project. World Bank, Washington DC.

World Bank. 1995. Ghana – Mining Sector Development and Environment Project Staff Appraisal . World Bank, Washington DC.

World Bank. 2009. Mining Together World Bank, Washington DC.

Wren, C. D. 1986. A review of metal accumulation and toxicity in wild mammals: I. Mercury. Environmental Research 40(1): 210-244.

22