We recognize that there are many potential entry points to reduce mercury in ASGM activities around the world. Some of the more common potential entry points currently being addressed are illustrated in Table 1.
Table 1. Potential entry points for addressing mercury contamination of people and nature from ASGM activities.
Potential Entry Point
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Example Engagement[1]
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Government articulation of commitments to the international convention specifically addressing ASGM contributions to mercury contamination[2]
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Minamata Convention – Minamata Initial Assessments and National Action Plans https://mercuryconvention.org/en/about
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Government enforcement of existing laws connected to ASGM and mercury1
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Minamata Convention – National Implementation Plans – Link
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IPLC engagement with governments to meet legal obligations1
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Sinangoe community in Ecuador: https://coicamazonia.org/lucha-historica-de-la-comunidad-ai-cofan-de-sinangoe-por-sus-territorios-y-derechos-como-pueblos-originarios/
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Formalization of ASGM sector and gold supply chain reforms
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Funding provided by the Global Environment Facility (GEF) Trust Fund (https://www.thegef.org/what-we-do/topics/mercury). Artisanal Gold Council (https://artisanalgold.org/), Planet Gold (https://www.planetgold.org/)
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Technological Innovations
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Conservation X Labs’s Artisanal mining grand challenge https://www.artisanalminingchallenge.com/
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Protected area management and law enforcement
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Frankfurt Zoological Society https://fzs.org/en/news/expert-opinion-illegal-gold-mining/
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Outreach, education, capacity building at the community level
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World Wildlife Fund http://awsassets.panda.org/downloads/healthy_rivers_healthy_people.pdf
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Research and Monitoring
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Biodiversity Research Institute’s Center for Mercury Studies https://briwildlife.org/hgcenter/; Centro de Innovación Cientifica Amazónica (CINCIA) https://cincia.wfu.edu/en/
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In our generic ToC, the first impact pathway recognizes that individual countries will have a variety of existing laws and policies that address mercury contamination. These could be specific to mercury (bans or regulation on use) or more general to heavy metal contamination (e.g., regulation of wastewater discharge). As an alternative to banning mercury use and ASGM, governments may have policies that seek to formalize and regulate the ASGM sector, including promoting the use of mercury-free technology (Planet Gold 2023). Policies could also be indirectly related to ASGM, including logging regulations in countries where deforestation is often caused by ASGM activity (Caballero Espejo et al. 2018). Enforcement of these laws and policies will require actions focused on technical skills and support, such as early warning systems to collect and synthesize data on spatial and temporal trends in ASGM activity and related deforestation; monitoring of mercury contamination levels in people and wildlife; training for enforcement officials; and access to mercury-free ASGM technologies.
If effective, these actions should lead to increased institutional and technical capacity within regulating bodies, resulting in improved enforcement of existing laws and policies, and ultimately a reduction in mercury pollution of ecosystems and people. However, it is well-established that many environmental policies are only weakly enforced (Hiriart et al. 2011), and so multiple enabling conditions must be present for this pathway to be effective. In addition to institutional and technical capacity, it is essential to have financial support, political will for enforcement, awareness by the regulated community, credible monitoring systems in place, and reasonable livelihood alternatives for mining communities.
The second policy impact pathway is via the Minamata Convention, which entered into force in 2017. The Convention is a multilateral environmental agreement aimed at reducing and ultimately eliminating global mercury pollution. It is named after Minamata Bay on the west coast of Kyushu Island in Japan, where from 1932-1968, the Chisso Corporation’s chemical factory released wastewater heavily contaminated with the toxic form of mercury (methylmercury) into the Hyakken Harbour, contaminating fish in the bay. The local community was highly dependent on this fishery and it is estimated that 2,252 people were impacted, resulting in 1,043 deaths (Harada 1995). It was not until 1956 that the disease was linked to mercury contamination. ASGM presents a real risk that many “Minamata Bays” are now happening simultaneously around the world. To reverse this increasing risk, much more organized, aligned, and coordinated efforts are needed, thus necessitating the use of a generic ToC to guide these global efforts.
To date, the Minamata Convention has 146 Contracting Party nations, including many of the countries with significant ASGM activity, and it requires they develop strategies, take actions, and report on progress related to mercury emissions from ASGM and other industries from which mercury is released (e.g., coal fired power plants, chlor-alkali production, batteries). The Convention also provides technical assistance, information exchange, public awareness, and research and monitoring (Minamata Convention 2023).
Once a Contracting Party nation has ratified the Convention, it must complete a Minamata Initial Assessment (MIA), which includes inventories of mercury and mercury compounds; sources of emissions and releases; overview of structure, institutions, and legislation available to implement the Convention; identification of populations at risk; current understanding by workers and the public; and a plan for implementation of priority actions for reducing mercury in the environment. When MIAs find that ASGM activities are significant sources of mercury, the countries must produce a National Action Plan (NAP) to address this specific source. Ideally, this is followed by a National Implementation Plan (NIP) for carrying out the actions needed to implement the plans.
The ToC for this policy pathway involves supporting Contracting Party nations in completing MIAs, developing NAPs where ASGM is significant, and ultimately implementing interventions (articulated in NIPs) to ultimately reduce mercury use and contamination. Many of the actions for this pathway are similar (if not identical) to those of the first impact pathway, including those to secure necessary technical and financial support. In some cases, the national laws and policies may already exist for NAP implementation, as in pathway (1). In other cases, new laws and policies must be developed to address the findings of the MIA and objectives of the NAP. Like pathway (1), enabling conditions must exist or be developed to ensure implementation and enforcement.
Linking national responses to global conventions is a well-known approach (e.g., Convention on Biodiversity); however, explicit linkages to participation of indigenous people and local communities is more of an emerging strategy. Thus, the third policy impact pathway defines explicit and purposeful engagement with the many IPLC who are directly impacted by ASGM, either by consuming fish and breathing air that is contaminated with mercury from ASGM, or who themselves participate in ASGM. These affected populations can play a powerful role in engaging with governments to meet their legal obligations made under various laws and policies.
Certain enabling conditions of the IPLC sector facilitate their effective participation (Zhang et al. 2023). Strong tenure security gives communities legal standing over the resource in question (e.g., land tenure where ASGM is being practiced illegally on indigenous territories; mineral rights where there is a question of who can mine; fisheries rights for contaminated food supplies). They also require leadership capacity and access to decision-making platforms to have their voices heard. And finally, communities who may see ASGM as a lucrative opportunity need livelihood alternatives that are culturally appropriate and can ensure a reasonable standard of living (Karres et al. 2022; Zhang et al. 2023). This could include sustainable ASGM that is done without the use of mercury and without extensive habitat destruction (Planet Gold 2023).
In addition to engaging directly with governments in decision-making arenas, indigenous people bring important skills and lessons including knowledge of the rivers, lakes, and forests where ASGM takes place and the fish and other affected species and could be important contributors to monitoring systems that must sample these remote areas. There are powerful examples of indigenous people developing guardian patrol programs to track illegal activities within their territories (e.g., in Ecuador: https://coicamazonia.org/lucha-historica-de-la-comunidad-ai-cofan-de-sinangoe-por-sus-territorios-y-derechos-como-pueblos-originarios/ and Brazil https://www.weareguardiansfilm.com/). Similarly, monitoring the health of local communities could also be an important indicator of the Minamata Convention’s overall impact. For example, decreasing trends in mercury contamination among indigenous communities have been documented recently in the Arctic (Adlard et al. 2021). However, not only are there no comparable trend data in the tropics that we are aware of, the increase in ASGM activity suggests that trends could be the opposite across the tropics, highlighting the need for investing in more baseline monitoring that is also suggested by the Minamata Convention.
In the absence of basic information on the sources and amounts of mercury contamination in a country, and the identification of appropriate interventions to reduce contamination supported by the national and local governments, it is difficult to envision the informed development of appropriate interventions and associated ToCs that will lead to desired outcomes of reducing or eliminating mercury contamination. Supporting the active engagement of countries with the Minamata Convention is one entry point that can work within an existing policy structure to improve the information and planning needed to better address the impacts of mercury contamination from ASGM.
For example, the most recent Global Mercury Assessment (UNEP 2019) estimates that approximately 83% of South America’s mercury emissions are from ASGM activity. Colombia, Ecuador and Peru each signed the Minamata Convention in 2013, while Peru and Ecuador became parties to the convention in 2017, and Colombia followed in 2019 (Minamata Convention 2023). Their participation in the convention has helped to advance collecting information on the sources of mercury contamination, developing plans for appropriate interventions, and establishing mechanisms to track implementation.
Regarding mercury contamination, Colombia released its first national report in 2017 summarizing the results of the MIA process (UNIDO 2017), which concluded the top two sources of mercury emissions and releases into the environment came from the mining sector: 1) gold extraction with mercury amalgamation (331,551 kg Hg/year, or 55.7%); and 2) primary metal production excluding gold amalgamation (159,105 Kg Hg/year, or 26.7%). These two mining sources accounted for a total of 82.4% of all the mercury emissions and releases into the environment. Regarding mercury release directly into air and water, one factor emerged as the dominant input for both – gold extraction with mercury amalgamation (198,931 kg Hg/year or 86.9% for air and 66, 310 kg Hg/year or 80.6% for water). Mining was also estimated to be a dominant driver of mercury releases to soil (66,310 kg Hg/year or 29.8%).
Following this baseline assessment, a second government-backed study revealed significant mercury contamination in the local communities, fish, water and soils of the middle Caquetá River Basin (MOI 2019). This study was the result of concern expressed by the Puerto Zábalo - Los Monos Resguardo to the National Natural Parks of Colombia to better understand the impact of gold mining activity in the Caquetá area and its effects on the fishery resource and the implications for the health of its inhabitants. This report supports the results of the Global Mercury Assessment (UNEP 2019) and Colombia MIA (UNIDO 2017) that ASGM activities are the primary source of mercury contamination.
The work needed to develop the plans necessary to address significant sources of contamination and complex strategies to reduce their impacts on people and nature need the support of local and national governments to establish the enabling conditions needed for success, for which the Minamata Convention provides an enabling structure. In South America, Ecuador submitted its National Action Plan (NAP) to address ASGM-derived mercury contamination in 2019, while Peru also submitted its National Implementation Plan (NIP) to address all sources of mercury contamination in 2019 – one of only three countries in the world to do so.
In the third policy impact pathway that we present, civil society organizations and governments collaborate with IPLC by supporting their endeavors through financing, providing data on amounts and sources of mercury contamination, capacity-building, funding for health care services and training on how to recognize the symptoms of mercury contamination, and information on how to make healthier choices to avoid eating contaminated fish. This work is best done following the lead of the communities, due to the social and economic complexity of ASGM in the landscapes in which they live. In the case where the community is participating in ASGM, civil society organizations and governments can support their transition to a more sustainable ASGM or other livelihood options through financing and capacity building for technology transfer.
Developing a situation analysis for detailing a ToC can refine that strategy in several ways. It can assist in identifying the enabling conditions under which strategies are more likely to be effective (e.g., Boshoven et al. 2020). It can help in the development of a monitoring, evaluation, and learning program and in selecting indicators (e.g., Effective Evaluation (EE) component of Minamata Convention). It can be used to identify assumptions and prioritize research needed to test those assumptions. And it can assist in defining and prioritizing the individual actions needed to be taken.
The complex socio-political context of mercury contamination from ASGM points to a need to develop situation analyses and ToC for improving the effectiveness of interventions. By constructing a generic ToC first, we highlight that our emphasis on key policy-related outcomes and impacts can’t be achieved in isolation. In our example, we illustrate that for the policy actions to be successful, there will need to be engagement and participation of local communities, which is a gap in many national policies. Furthermore, we suggest that multiple strategies from different synergistic entry points are needed to be effective in reducing, and ultimately eliminating this pervasive threat to nature and people.
We recognize that developing a generic ToC is simply a tool to facilitate engagement with stakeholders on reducing the threat of mercury contamination. Once a decision is made to adopt the generic ToC to guide decision-making, one important next step is to conduct a return-on-investment (ROI) or tradeoff analysis to shape which entry point or points will be selected, taking into consideration the local, national, and global contexts as well as the capacities of the implementer. Providing additional guidance on how to shape this next step in decision-making is a current gap in the knowledge and understanding about how best to address mercury contamination in ASGM activities around the world, especially considering the substantial variability in data and knowledge and local contexts that shape ASGM activities in different countries.
There are, of course, limitations to the ToC introduced here. The scope of this analysis was on reducing mercury contamination from ASGM, not the reduction of ASGM itself. In addition to contributing to mercury contamination, ASGM has other negative impacts including deforestation, soil degradation, erosion, river sedimentation, and more specific actions to address these threats is needed.
Perhaps the most important aspect of the ToC introduced here is the recognition that engagement of indigenous people and local communities is an essential component to the success of any policy approach. These populations are an integral part of the policy entry point’s impact since these communities experience both the health and socioeconomic impacts of ASGM and mercury contamination. We emphasize the role taken by these communities in engaging with governments to help design and implement more effective laws and policies to address the threat of mercury from ASGM. And yet we also recognize there are many factors that result in high levels of social complexity. For example, in the Amazon, some community members may be small-scale gold miners using mercury, some fishers who may oppose the activity, while others are both miners and fishers (Escobar-Camacho and Rosero-López, pers comm). With consistently high gold prices, easily available sources of mercury, and the low-tech method using mercury for extraction, relying on ASGM as an income stream is a reasonable livelihood decision. This complexity only highlights the need to ensure full engagement of these affected communities.
[1] List is illustrative and not meant to be exhaustive. Some organizations engage in multiple entry points.
[2] Discussed in this paper