Managing the risks of small-scale mining

Ghana has had a comparatively good mining record over the years – but for the upsurge of the activities of illegal miners, popularly called (Galamsey) in recent times.

Thus, the death of sixteen miners (believed to be illegal miners) last week has once more raised the need for appropriate policy interventions and enforcement to curb the harmful effects of illegal mining across the country. Reports say the miners died after inhaling smoke from a blast, near the Chinese-owned Shaanxi Mining Ghana in the Upper East Region.

A survivor told journalists that they received warning of an impending blast in one of the company’s mining pits, but ignored it. According to the source, the illegal miners were convinced the blast would be minor as previous ones had been.

Statistics indicate that the safety record of the Chinese company is appalling, and the earlier government agencies take action to prevent future accidents, the better.

Duty of care

With the evolution of the Corporate Manslaughter and Corporate Homicide Act 2007 (c.19) in Britain, for instance, corporate bodies in the public and private sectors are now accountable and owe the relevant duty of care to their employees – and even those not directly employed. I am not sure what pertains under Ghana’s legal system, but in Britain the provision of a safe system for working in a mine is an obligation of the owner – who, if he/she appoints an agent to perform it, remains vicariously responsible for the agent’s negligence. Therefore, I think the Ministry of Lands and Natural Resources and its agency, the Minerals Commission, should thoroughly investigate this accident and crack the whip where possible.

 Blessing or curse

The liberalisation of laws on mining in 1989 legalised artisanal and small-scale mining with the primary aim of providing employment for the people. It was also meant to increase government revenue; but this has become a curse rather than a blessing.

Small-scale mining in Ghana has been defined to include the exploitation of some mineral deposits, using rudimentary tools at low-level production with minimal capital investment. This definition was given meaning from the Mining and Minerals Law 1986 PNDCL 153 Part X, section 77, clause 1, which states that: “where the sector Minister considers that it is in the public interest to encourage prospecting and mining of minerals in any area of land by methods not involving substantial expenditure or the use of specialised technology, he/she may by notice in the gazette designate that area for small-scale mining operations and prescribe the mineral to be mined”. This was replaced by the Minerals and Mining Act 2006, Act 703, Sections 81-99.

Sadly, over the years large tracts of arable land have been degraded, forest reserves encroached upon, water-bodies polluted, while social vices have been on the ascendancy in communities with high populations of artisanal and small-scale miners.  Thus, the impunity with which the environment is being destroyed has become an albatross on the neck of the current government.

Consequently, a moratorium was put in place on the 1st of April 2017 to temporarily suspend artisanal and small-scale mining operations for a year. The issuance of new licences to ASM was also put on hold, notwithstanding its political consequences.

Faced with the negative effects of small-scale mining, the current government – with support of the World Bank – established the Multilateral Mining Integrated Project (MMIP) to tackle the issues by using a project management approach. In my view, this is a well-thought-out social intervention that will promote sustainability in the small-scale mining sector.

Factors encouraging illegal mining

Though small-scale mining in Ghana is the preserve of Ghanaians, currently, foreign nationals dominate and finance the illegal activities with Ghanaians as collaborators. Some of the foreigners come from West Africa, Europe and Asia, among others.

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The factors that encourage illegal small-scale mining include the following: (a) relatively high gold price which makes marginal gold deposits economical for illegal small-scale miners;

(b) illegal mining appears to be more lucrative than other small-scale poverty alleviation ventures;

(c) greed and “get-wealth-quick‟ mentality;

(d) connivance of some chiefs, landowners and opinion leaders with foreigners operating in remote areas (and areas not designated for mining activities, e.g. river-bodies, forest reserves etc.);

(e) Ghanaians fronting for foreigners to operate in the small-scale mining sub sector;

(f) political interference and corruption;

(g) perceived complexity of licensing process;

(h) introduction of mechanised methods of mining and processing; and i) weak enforcement by relevant institutions

Contribution to economy

Despite its negative effectives, government and its development partners have never underestimated the significant role Artisanal and Small-Scale Mining (ASM) sub-sector plays in the socio-economic development of the country. The sector contributes significantly to foreign exchange earnings, generates both direct and indirect employment for many people countrywide; hence, its recognisably role in government’s poverty reduction strategies. For example, total gold production by small-scale miners rose from an estimated 2.2% in 1989 to 31% of the national production in 2016.

The 31% gold production includes contribution from both legal and illegal miners. It is a fact that, despite this high percentage of gold production, current and previous governments have not had it easy taxing these miners, whether at the local or national level.


These and many other benefits notwithstanding, the ASM sector is plagued with numerous short- and long-term challenges: including land degradation, water-pollution, serious negative health impacts (e.g. dust, mercury, noise), uncontrolled use of mercury in amalgamation, crime and a host of others.

According to the Project Appraisal and Implementation Document (PAID), government’s main headache in managing the issues associated with artisanal and small-scale mining is how to develop a strategy that promotes orderly, viable and sustainable small-scale mining sectors in the mining communities. These issues are complex and numerous, involving:

(a) Conflict: this is common between large-scale operators working within a formal, regulated land tenure framework, and some small-scale miners illegally working on land over which they have no legal entitlement (though they may claim to have some historical entitlement);

(b) Difficulty in accessing land: small-scale miners often have difficulty in accessing land appropriate to their type of mining practices. They experience a lack of capital needed to allow even rudimentary production efficiencies, leading to resultant debt bondage and poverty traps.

(c) Inadequate marketing of minerals produced: unregulated, inefficient – and often illegal – pricing and distribution mechanisms and practices contribute further to commercial inefficiencies, often facilitating associations by miners involved in human rights violations;

(d) Poor working conditions: the sector is characterised by poor health and safety practices. The poor safety practices are responsible for the frequent fatalities at mining sites.

(e) Poor environmental conditions: environmental degradation is common, with artisanal miners seldom rehabilitating the areas they have mined. The uncontrolled and unsafe use of mercury in the processing phase is of concern, given its bio–accumulation tendencies in the eco-system;

(f) Emergence of vulnerable groups: the sector often includes a large proportion of people from vulnerable groups – such as women, children and migrants – culminating in labour exploitation, including a lack of respect for basic rights of workers in the sector;

(g) Lack of effective regulation and enforcement: there are substantive legislative hurdles characterised by either a lack of regulation, ambiguous legislation or a lack of appropriate legal framework; and, consequently, with virtually no enforcement regime;

The PAID document notes that these challenges can best be addressed by adopting a multi-stakeholder approach, in consultation with the artisanal and small-scale miners themselves, NGOs and development agencies. This requires that government plays a lead-role in addressing the issues.

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The theory of change

The theory of change underlying government and World Bank intervention is prudent and farsighted. ‘Theory of change’ describes the general approach or strategy for achieving an organisation’s intended impact.


In the case of the MMIP, the theory of Change Underpinning the Project is as follows: (i) IF sustained awareness creation is undertaken; and (ii) IF alternative livelihood opportunities are created, coupled with the identification of suitable areas for prospecting; and (iii) IF operators are organised into cooperatives (mining-based organisations) and assisted with extension of technical services; and (iv) IF the rule of law is allowed to operate; (v) THEN jobs will be created and sustainable livelihood of mining communities assured;  (vi) AND THEN illegal mining would be sanitised under some concession arrangements and the environment protected (degradation minimised and water pollution stopped), and sanity brought into the mining sector; resulting ultimately in poverty alleviation. These will be achieved with a good logical model driving the change. ‘Logical model’ is a set of activities and outputs an organisation undertakes to attain its planned outcomes.

Communications strategy

One of the logical models necessary to achieve Theory of Change is the communications strategy of the MMIP.  The PAID states that the communications strategy will structure the creation and delivery of strong messages that are clear, consistent and coordinated through the building of a brand identity for this national initiative.

The objective of the communication strategy is to create awareness, inform and educate the public about the dangers of illegal mining activities and solicit the cooperation of all stakeholders for the smooth implementation of the MMIP to control illegal mining activities and associated negative impacts.  MLNR expects to increase the knowledge and understanding of the benefits that the MMIP brings to Ghanaians for all stakeholders.

When successfully implemented, the communications framework will create awareness, confer understanding, change attitudes and perceptions of illegal miners, motivate action and boost recognition and positive perceptions of the MMIP project among stakeholders, leverage the position of the government of Ghana (GoG), Ministry of Land and Natural Resources (MLNR) and Implementing Agencies (IAs).

Specifically, the following objectives will be achieved: (i) sensitise and increase public awareness on the effects of illegal mining activities on lands, water-bodies and the environments; (ii) promote and support sustainable mining processes and practices within the small-scale mining sector; (iii) create awareness about alternative livelihood programmes that the MMIP provides and encourage beneficiaries and stakeholders to understand, participate and support the programme; (iv) work with print and electronic media to emphasise the improved quality of life created by the MMIP activities; and (v) develop and distribute timely, effective publicity, news and feature articles about the MMIP.

It is a near universal truth that a well-thought-out communication strategy such as the MMIP can play a decisive role in promoting human development in today’s new climate of social change. As the world moves toward greater democracy and decentralisation, participation, inclusion and empowerment, conditions are becoming more favourable for people to start steering their own course of change. Only a well-planned and expertly implemented communications strategy communication will enable project beneficiaries to become the principal actors.


Ministry of Lands and Natural Resources (2017) Project Appraisal and Implementation Document (PAID). Government of Ghana

(***The writer is a Development and Communications management Specialist, and a Social Justice Advocate.  All views expressed in this article are my personal views and do not represent those of any organisation(s). (Email: Mobile: 0202642504 0243327586/0264327586) 

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