Since Towards Sustainable Mining (TSM) was launched in 2004, independent verification has evolved from an innovative approach into a central mechanism for establishing the credibility of mining performance.

Author: Denis Bernier, Eng., M.Env., CEA | SCEB Inc.
TSM verification and mining compliance • TSM verification service provider since 2006

Independent verification as a foundation for credibility

In 2006, when I began conducting TSM verifications, external verification of performance first assessed by the company itself was still a relatively new approach in the mining sector. Twenty years later, the principle has become firmly established: a performance claim gains credibility when it can be supported by evidence and examined by an independent third party.

This is precisely what has distinguished TSM from the outset. The program is not based solely on broad commitments; it translates those commitments into management and performance criteria assessed at the facility level, publicly reported, and periodically subject to external verification.

2004: Measure, report and verify

The Mining Association of Canada (MAC) launched Towards Sustainable Mining in 2004. At the time, the program included four protocols: tailings management; crisis management planning; external outreach; and energy use and greenhouse gas emissions management.

According to MAC, TSM was the first mining standard in the world to require facility-level performance reporting accompanied by external verification. That architecture is fundamental: it requires organizations to move from commitment to demonstrated performance.

2006: A pivotal year — and mine as well

In 2006, MAC member facilities completed their first round of external verification. That same year, participation in TSM became a condition of MAC membership. It was also in 2006 that I became a TSM verification service provider. My involvement with TSM therefore began at the point when independent verification became fully embedded in the program.

“TSM’s strength does not lie only in the number of protocols. It lies in the requirement to demonstrate performance and subject it to independent scrutiny.”

From 4 protocols to 9: A standard that has deepened over time

Since 2004, the scope of TSM has expanded considerably. Milestones documented by MAC illustrate the evolution of expectations for responsible mining management:

2011 — Introduction of protocols on biodiversity conservation management and safety and health.
2017 — Introduction of the protocol on preventing child and forced labour.
2019 — Introduction of the water stewardship protocol.
2021 — The climate performance framework evolved into the climate change protocol.
2023 — Introduction of the equitable, diverse and inclusive workplaces protocol and revision of the safety and health protocol into safe, healthy and respectful workplaces.

In 2026, MAC describes TSM as a system comprising 9 protocols and 34 environmental and social performance indicators. The current protocol titles themselves reflect this evolution: Indigenous and community relationships, climate change, biodiversity, water stewardship, workplaces, tailings management, and other management dimensions that have become essential to responsible mining.

Progressive internationalization

In 2015, the Finnish mining association became the first national mining association outside Canada to adopt TSM. The program subsequently expanded to several jurisdictions. MAC’s current page on global uptake indicates that TSM has expanded beyond Canada to nine other countries across six continents. This expansion matters: national contexts may differ, but the system’s core components — including facility-level reporting, independent verification, and multi-stakeholder governance — remain central to the model.

The constant: External verification

Verification remains one of TSM’s structural mechanisms. Facilities report their performance under the applicable protocols, and a qualified external verifier periodically examines the self-assessments and the supporting evidence. MAC requires external verification every three years. A verifier may change a rating when the available evidence does not support the reported assessment.

This distinction is essential: verification is not a mechanical confirmation of a declaration. It requires understanding the criteria, examining the design and implementation of management systems, testing evidence, documenting the reasoning, and exercising independent professional judgment.

What twenty years of verification change in practice

After twenty years of TSM practice, experience primarily brings the ability to distinguish quickly between what is merely documented and what is actually implemented, demonstrable, and sustainable. For a mining organization, this includes the ability to:

identify gaps between policies, procedures, and actual observable practices;
assess the quality, traceability, and sufficiency of evidence;
identify weaknesses in a management system before they become verification findings;
direct efforts toward robust management mechanisms rather than one-time audit preparation;
support continuous improvement that remains demonstrable from one verification cycle to the next.

In my view, this ability to read and assess management systems — more than simply knowing an assessment grid — is where the real value of verification experience lies.

What comes next?

Over 22 years, TSM has evolved from a four-protocol Canadian program into an internationally recognized framework comprising nine protocols and 34 indicators. At the same time, expectations regarding ESG information quality, data traceability, and independent assurance continue to increase.

The mining sector’s next step will therefore probably not be to disclose more, but to demonstrate better what is being disclosed — through coherent management systems, reliable evidence, and governance capable of sustaining performance over time.

This is the perspective from which I have carried out my role as a TSM verifier since 2006, alongside my practice as an engineer and Certified Environmental Auditor: providing an independent, structured, evidence-based assessment.

Next article: From TSM to the CMSI

TSM has helped structure the verification of responsible mining performance in Canada and internationally. But the standards landscape has now reached a new point of convergence: the Consolidated Mining Standard Initiative (CMSI).

Led jointly by The Copper Mark, the International Council on Mining and Metals (ICMM), the Mining Association of Canada, and the World Gold Council, the CMSI aims to consolidate the core elements of their four responsible mining standards into a single global standard, supported by a multi-stakeholder governance model and an assurance process.

“What will become of TSM’s key strengths within the CMSI — and what will this transition mean in practice for mining companies, verifiers, and stakeholders?”

That will be the focus of my next article: “From TSM to the CMSI: Toward a Common Global Language for Responsible Mining Performance.” I will examine the areas of continuity, structural changes, evolving assurance expectations, and transition issues for organizations already using TSM or The Copper Mark.

Note — As of September 3, 2026, the CMSI remains under development and finalization. The final public consultation was held from October 8 to November 17, 2025, and the final consultation report was published on March 16, 2026.

About the author

Denis Bernier, Eng., M.Env., CEA
SCEB Inc. — TSM verification, environmental compliance, and ESG management systems for the mining, industrial, and maritime sectors.

20 Years of TSM Verification:A Look Back at 22 Years of Responsible Mining Evolution