CENTRE FOR ENERGY, PETROLEUM AND MINERAL LAW AND POLICY

STATEMENT OF ORIGINALITY I.D. STUDENT: PROGRAMME: MODULE: 110004699 MBA. International Oil and Gas Management Code CP 52003 Name: Environmental Law and Policy for Natural Resources and Energy. Mining In Ghana, Environmental Issues And The Law: A Case of Cyanide Spillage.

TITLE OF THE RESEARCH PAPER: ABSTRACT:

The mining industry has contributed significantly to the socio-economic development of Ghana. Mining accounts for 5% of the country's GDP and minerals make up 37% of total exports, of which gold contributes over 90% of the total mineral exports. Thus, the main focus of Ghana's mining and minerals development industry remains focused on gold. Ghana is Africa's 2nd largest gold producer, producing 70 t in 2003. The purpose of the study is to critically examine the extent to which the discharge of cyanide used in gold extraction have polluted the environment in relation to the existing laws and how effective they are in regulating the industry. The studies employed an analytical

approach to evaluate the effectiveness of the law regulatory agencies such as the Ministry of Lands, Forestry & Mines, Environmental Protection Agency (EPA) and other bodies in the enforcement of the mining laws in dealing with cyanide and other forms of pollution by the mining companies. The studies however found out that there is lack of stringent mining and environmental regulations coupled with the absence of strict enforcement of existing regulations, which have left many of the mining communities saddled with polluted environments that threaten their very existence.

WORD COUNT:

4510

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_______________________ 13 MAY - 2011

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Table of Content

CONTENT

PAGES

Abbreviations.. 3

SECTION 1 1.1 Introduction .....4-5

SECTION 2 2.0 BACKGROUND 2.1Contribution of Mining to the Economic of Ghana.6-7

2.2 Use of Cyanide in Gold Extraction .....7-8

2.3 Cyanide Pollution in Mining Communities........8-10

SECTION 3 3.1 Analysis..10-12

3.2 Findings.......13

SECTION 4 4.1 Conclusion...13-14

BIBLIOGRAPHY....15-16

Abbreviations

ERP EIS SIA MHAA GDP UNCLOS PNDCL ATSDR MINCOM EPA BGL NGGL GNA ENS IEL EEZ UNCLOS UN

Economic Recovery Programme Environmental Impact assessment Social Impact Assessment Mining Health Area Act Gross Domestic Product United Nations Convention on the Law of the Sea Proventional National Defense Council Law Agency for Toxic Substances and Disease Registry Minerals Commission Environmental Protection Agency Bogoso Gold Limited Newmont Ghana Gold Limited. Ghana News Agency Environmental News Service International Environmental Law Exclusive Economic Zone United Nations Convention on the Law of the sea. United Nations

SECTION 1 1.1 INTRODUCTION: Mining is an industrial activity that involves the extraction of minerals from the surface of the earth for various reasons and purposes. Mining of minerals specifically gold in Ghana dates back to the nineteenth century and have since become part of national economic assets and regulations. For example mining and minerals were a specific and integral part of the Economic Recovery Programme (ERP) in 1983. New legislation was promulgated, financial incentives were introduced, new state institutions were set up to regulate the activities of mining in the country and major rehabilitation of state-owned mines was created. The paper seeks to find out why the use of cyanide in the extraction of gold and it impact on the environment. When mining is the topic, the environment is never far behind. In the analysis of any potential mining operations, whether the benefits of the mine are greater the environmental cost is often the first question asked1. The inception of large scale mining companies which are characterized by the use of heavy and ultra-modern equipments and technology in the extraction industry have changed the face of miming in the country.

The aim of the paper is to explore the devastating effect of cyanide on the mining communities in Ghana and also examine and analyze the effectiveness of the law in regulating the mining sector to ensure that these mining companies abide by the environmental and social impact assessment and the industrial guidelines outlined and contained in their policy statement and penalties leveled against cyanide spillage. Mining, by its nature, poses major environmental challenges. It creates large volumes of waste products, for example, overburden, waste rock, tailings, acid mine drainage, airborne dust, and other contaminants. These by-products are deposited on land and in the air and water, in some cases harming human health, damaging property, and affecting fish and wildlife2.

Mcmahon, G., Remy, F. Large Mines and the Environment ( Canada, International Development Research Centre, Ottawa, ON, Canada K1G 3H9 & The World Bank 1818 H Street, N.W., Washington, DC 20433,USA, 2001).page 21. 2 Eggert. G. R Mining and the Environment: International Perspectives on public policy (Washington DC, USA, 1616 P Street, NW, Washington, DC 20036-1400, 1994) 4

This research paper adopted an analytical approach to examine the existence of mining laws and identified the law enforcing agencies and their effectiveness in regulating the mining industry with respect to liabilities, penalties and compensations leveled against mining companies as a result of cyanide pollution in the gold mining communities in Ghana. This method enables the research to measure the effectiveness of the law regulating bodies or agencies in implementing mining policies.

The country has very good laws and the application of these laws would have promoted development in the country but environmental laws in Ghana are not working. For example Mining Health Areas Act (MHAA), 1925 which stated that The Minister may make, alter, or revoke an order declaring that an area used for mining, or adjacent to a mine, shall be a mining health area which shall be regulated in accordance with Regulations made under section 4 of the Art3. Has not seen the light of day.

This Act was enacted as the Mining Health Areas Ordinance, 1925 (No. 19 of 1925). It came into force on 1st July, 1926. It was Cap. 49 of the 1951 Edition. 2. Amended by section 4 of the Mining Health Areas Amendment and Extension Law, 1935 (No. 20 of 1935). 3. Substituted by section 5 (1) of the Mining Health Areas Amendment and Extension Law, 1935 (No. 20 of 1935). 5

SECTION 2

2.0 BACKGROUND

2.1 Contribution of Mining to the Economy of Ghana The contribution of mining to the socio-economic development of the country cannot be over emphasized. Mining sector both small and large scale companies employ about 90% of the active labour force of the population in the mining communities and also provide indirect services to the communities. Food venders and shops are opened near the mining companies providing services to the miners. The country currently has thirteen large-scale mining companies producing gold, diamonds, bauxite and manganese, and, there are also over three hundred registered small scale mining groups and ninety nine support service companies. Example of these mining companies include AngloGold Ashanti (Ghana) Limited: Newmont: Gold Fields Ghana Ltd.: Golden Star Resources Ltd.: Abosso Goldfields Ltd.: AXMIN Inc. Birim Goldfields Inc. Adamus Resources Ltd.: Red Back Mining Inc. Several other organisations are involved in producing building and industrial minerals in the country4. In 2005, the mining industry paid $26.76 million to the government as royalty, which increased to $38.46 million in 2006 an $53.80 in 2007. The sector also contributes 6.44 percent to Ghanas GDP and boasts of a labour force of 17,500. In addition producing members of the GCM voluntarily contributed about US$9.8 million to their host communities in 2006. This represents about 26% of mineral royalties paid by these companies in that year. The GCM points to the creation of ancillary jobs, infrastructural development and discharge of CSR as some of the significant contributions of the industry to the sustainable development of mining communities5.

Mining Portal of Ghana: Active Mining Companies with web site at http://www.ghana.mining.org/ghweb/en/links/mines.html last visited on 2nd much 2011. 5 Emmanuel K. Boon, Frederick A., Corporate social responsibility in Ghana: lessons from the mining sector. IAIA09 Conference Proceedings', Impact Assessment and Human Well-Being 29th Annual Conference of the International Association for Impact Assessment, 16-22 May 2009, Accra International Conference Centre, Accra, Ghana 6

Mining accounts for 5% of the country's Gross Domestic Product (GDP) and minerals make up 37% of total exports, of which gold contributes over 90% of the total mineral exports. Thus, the main focus of Ghana's mining and minerals development industry remains focused on gold6. Ghana is Africa's 2nd largest gold producer, producing 70 t in 2003. Gold production reached 2,143t. in 2005. Production is dominated by home-grown Ashanti Gold Fields, which produced nearly half at 37 t7. The Ghana Chamber Mines (GCM) also points to the creation of ancillary jobs, infrastructural development and discharge of C Cooperate Social Responsibility as some of the significant contributions of the industry to the sustainable development of mining communities in the country.

2.2 Use of Cyanide in Gold Extraction High gold prices since the early 1980s have resulted in a dramatic rise in gold production. The most common method of gold extraction for large scale mines is also an environmentally dangerous method. Modern gold mining produces large volumes of toxic solids and liquids. With modern techniques, microscopic pieces of gold can be extracted from ore rocks, making unprofitable mines profitable8. In 1783 Swedish chemist Carl Wilhelm Scheele discovered that gold can be chemically dissolved by cyanide; a version of this process was later patented by Scottish metallurgist John MacArthur. The solvent form most commonly used is hydrogen cyanide (NaCN), which is typically diluted to around .035 percent for use in gold mining. The use and disposal of cyanide solutions used to dissolve and extract gold is another environmental concern. Cyanide is a well-known poison; hydrogen cyanide is acutely toxic to humans and, in its gaseous state, can be fatal at exposure levels of 100 to 300 parts per million (ppm). Cyanide is likewise harmful to wildlife such as mammals, birds, and fish which can have acute toxicity reactions to even low cyanide exposures.
6

Emmanuel K. Boon, Frederick A. supra notes 10. Emmanuel K. Boon, Frederick A. supra notes 10.

Chris Van de Ven, Gold extraction Using Cyanide Leaching, available at http://tc.engr.wisc.edu/uer/uer97/author4/index.html ( last visited 8th April, 2011) 7

Cyanide does not, however, accumulate or biomagnified, so prolonged exposure to sub-toxic levels does not, in most cases, appear to pose health risks.9 According to U.S Agency for Toxic Substances and Disease Registry (ATSDR).2006 and Department of Health and Human Services, Public Health Service Agency for Toxic Substances and Disease Registry Cyanide enters air, water, and soil from both natural processes and industrial activities. In air, cyanide is mainly found as gaseous hydrogen cyanide; a small amount is present as fine dust particles. The half-life (the time needed for half of the material to be removed) of hydrogen cyanide in the atmosphere is about 13 years. Most cyanide in surface water will form hydrogen cyanide and evaporate. Cyanide in water does not build up in the bodies of fish. Cyanides are fairly mobile in soil. Once in soil, cyanide can be removed through several processes. Some cyanide compounds in soil can form hydrogen cyanide and evaporate, whereas some cyanide compounds will be transformed into other chemical forms by microorganisms in soil. At the high concentrations, cyanide becomes toxic to soil microorganisms. Because these microorganisms can no longer change cyanide to other chemical forms, cyanide is able to pass through soil into underground water10.

2.3 Cyanide Pollution in Mining Communities. Pollution is more difficult to prevent in the mining sector than it is in the manufacturing sector because there is less control over the starting material and because mining waste is generally high volume, high toxicity waste. Even though mining wastes have been excluded from being regulated as hazardous wastes, it is clear that a large percentage of mining wastes is high toxicity and would otherwise qualify as hazardous under the Resource Conservation and Recovery act11. It is reported that on 5th May 1998 as a result of structural defect in the cyanide containment pond a major spillage occurred which affected a host of communities including Dokyiwa, Ewiase and others all suburbs of Obuasi (Ashante Region).
9

U.S. Geological Survey, Mineral Commodity Summaries, January 2007

Agency for Toxic Substances and Disease Registry (ATSDR).2006. Toxicological Profile for Cyanide (Update). Atlanta, GA: Anderson , K., Purcell k.S., International Conference on Pollution Prevention in Mining and mineral Processing, Snowmass Village, Colorado USA, august 24-27, 1993. Page 4.N.p 8
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It is also reported that a report by the District Environmental Committee to enable the mining company carry out remedial measures has disappeared from the offices of the District Assembly12.

It was reported on October 24, 2001 Environmental News Service (ENS) that Villages in the Wassa West District of Ghana's western region has been hit by the spillage of thousands of cubic metres of mine wastewater contaminated with cyanide and heavy metals. The cyanide-laced waste contaminated the River Asuman on October 16 when a tailings dam ruptured at a mine operation owned by the South African company, Goldfields Ltd. Hundreds of dead fish, crabs and birds could be seen littering the banks of the river. Others float on the surface of the river which is the only source of drinking water for Abekoase, Huni and surrounding villages. Virtually all life forms in the river and its tributaries have been decimated, and people's livelihoods are endangered. Scientists feared the cyanide and heavy metal residue from the spill could remain for decades posing a health and environmental threat to the people and wildlife in the area13.

In 2004 and 17/05/2006 there was cyanide spillage into a river which serve as a major source of drinking water for the inhabitants of Dumase in Tarkwa.( Western Region) Failure by the company to inform the community on time and the use by them had serious health implications such as stomach and skin disorders, death of fishes and destruction of farmlands. From the report of the District Environmental Team, fish ponds and cocoa farms were the most affected. The said cocoa pods which got submerged in the flood water got rotten, young trees got scorched and were the worst affected. Other crops affected by the spillage included cassava, maize, plantain, cocoyam, pineapples, pepper, tomato, okro, beans cowpea, banana trees and yam. The spillage also did considerable harm to fish. All fish ponds in the affected area lost their fish stocks, the report added. A visit by the affected villages by the team revealed that some of the villagers
Kwasi Baffore Intsiful ,Public Interest Environmental Law Conference@ University of Oregon School of Law Eugene, Oregon (Feb 25 28, 2010). Available at th https://www.elaw.org/system/files/Elaw+presentation.ppt ( last visited 8 April, 2011) 13 Mike Anane, Cyanide spill Ghana s worst Environmental Disaster at http://www.reocities.com/siyanurlealtin/ghana.html last visited on 18th march, 2011 9
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were suffering from skin rashes. These skin diseases have been attributed to the cyanide pollution, although no medical evidence was available to confirm this. Following the insistence of the Environmental Team, the company agreed to compensate the farmers but asserted that it is a goodwill gesture rather than admittance of guilt14. Another case of cyanide spill by Newmont Ghana Gold Limited (NGGL) was recorded. This spill occurred at the processing plant when the tailings damp over flew it bank after a downpour of rain contaminating the source of drinking water of this communities. Information later revealed that many more people were affected by the cyanide spillage. The villages and hamlets that were affected included Adofoasa; Kontokrom; Bamfowaakrom; Akosua Gyakakrom; Bronikrom; Afua Serwaakrom; Kuma Gyakakrom; Yateaberee, Kyeikrom and Kantinkakrom all in the Asutifi District of the Brong Ahafo Region which is endowed with large deposit of gold ore and mines in the country. SECTION 3 3.1 Analysis There are very little international regulations relevant to mining operations. There is basically local regulation. This is because; the environmental effect/impact is localized. The only clearly International Environmental Law (IEL) dominating in the mining industry is deep sea mining. This is however, undeveloped because there are no exploration activities except within the coastal states territory of Papua New Guineas Exclusive Economic Zone (EEZ).

The regulation is primarily at national level supplemented by industrial guidelines. The most developed mining laws are in Europe at the regional level. They also have a liability regime. These are compulsory EC/EU directives that are binding on member states. There is also the UN Economic Commission for Europe. This is perhaps the most environmentally sensitive commission in the world.

Kwasi Baffore Intsiful ,Public Interest Environmental Law Conference@ University of Oregon School of Law Eugene, Oregon (Feb 25 28, 2010). Available at th https://www.elaw.org/system/files/Elaw+presentation.ppt ( last visited 8 April, 2011) 10

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International laws that emphasis the protection of the environment against pollution in relation to mining include the 1972 Stockholm convention principle 6: The discharge of toxic substances or of other substances and the release of heat, in such quantities or concentrations as to exceed the capacity of the environment to render them harmless, must be halted in order to ensure that serious or irreversible damage is not inflicted upon ecosystems. The just struggle of the peoples of ill countries against pollution should be supported15, 1972 world culture and natural heritage conventions, 1982 United Nations Convention on the law of the Sea (UNCLOS), 1992 Biodiversity convention and perhaps 1997 Kyoto protocol of climate change which emphasis human activities such as deforestation which contribute to global climate change16. The legislative framework for mining in Ghana is laid down in the Minerals and Mining Law, 1986, Provisional National Defense Council Law: PNDCL 153 (Law 153) as amended by the Minerals and Mining Amendment Act 1993, Act 475 (Act 475) and modified by the provisions of the Constitution of 1992 (the Constitution). Within this legal framework, the State is the owner of all minerals occurring in their natural state within Ghana's land and sea territory, including its Exclusive Economic Zone ( EEZ). All minerals in Ghana are vested in the President on behalf of and in trust for the people of Ghana. Thus, regardless of who owns the land upon or under which minerals are situated, the exercise of any mineral right requires, by law, a license to be granted by the Minister for Mines (the sector Minister) acts as an agent of the State for the exercise of powers relating to minerals. The powers conferred upon the Minister must be exercised contingent upon the advice of the Minerals Commission (MINCOM), which has the authority under the Constitution to regulate and manage the utilization of mineral resources and coordinate policies in relation to minerals17. Minerals export duty (abolition) act, 198718
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Stockholm Convention on Persistent Organic Pollutants, 16 June 1972, entered into force 23May 2001 available at http://www.unep.org/Documents.Multilingual/Default.Print.asp?documentid=97&articleid=1503(last visited 8th April 2011) 16 Birnie, P., Boyle A., Redgwell C., International law & the Environment (New York , USA, Oxford University Press ,2009) page 336 17 See Article 257(4-6) of the 1992 constitution of Ghana 18 See the Customs and Excise Regulations, 1973 (L.I. 838) as amended by the Customs and Excise Tariff (Amendment) Regulations, 1984 (L.I. 1309) are hereby further amended by the revocation of Tariff Numbers 3.2, 3.5, 3.6, and 3.7 and all particulars relating thereto 11

was enacted which aborted export duty on minerals exported from the country as an incentive to entice other mining companies to come and in invest in the mining industry of the country. Law 153 specifies the forms of mineral rights that the sector Minister is empowered to grant, the duration of the grant, the size of the concessions, and eligibility criteria for the grantee, as well as the procedure for application for mineral rights. The Law also spells out in broad terms the rights and obligations of a holder of a mineral right and the terms and conditions upon which each mineral right grant should be made. A mineral right granted is not transferable or tradable in any form except with the prior written consent of the sector Minister. Minerals and Mining Act, 2006, Act 703 entreat holders of mineral rights to have due regard to the effect of mining operations on the environment and to take such steps as may be necessary to prevent pollution of the environment as a result of such mineral operations. (Sect 18), Based on these provisions of the Constitution, the Parliament of Ghana passed the Environmental Protection Agency (EPA) Act, 1994 (Act 490). Under this Act, the Agency among others is to issue environmental permits and pollution abatement notices to ensure compliance with any laid down environmental impact assessment procedures in the planning and Execution of development projects, including compliance with existing projects. Pursuant to Act 490, the EPA has issued various subsidiary legislation dealing with issues such as environmental impact assessment, environmental audits and management plans. In 1994, the EPA in accordance with the National Environmental Policy (NEP) published the Mining and Environmental Guidelines meant to assist mining companies to operate in environmentally acceptable manner 19. The institutions and agencies responsible for the implementation of the mining and mineral laws in the country includes, the ministry for lands, forestry and natural resources, the Environmental Protection Agency which is answerable to the sector ministry and the body responsible for monitory and evaluating mining and environmental activities in the country, District, Municipal and Metropolitan Assemblies are also constitutionally mandated to enact By-laws to regulate Environmental activities in their areas of jurisdiction, Ghana Chamber of Mines a body set up to regulate the activities of the mining companies and other NonGovernmental Organizations ( NGOs) activities such as Greening Ghana Project. These are all bodies to oversee environmental activities in the country.

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Kwasi Baffore Intsiful. supra notes 14 12

3.2 Findings Couple actions were taken against some mining companies who faulted the rules and did not act in good faith and through gross negligence polluted the environment as result of tailings dams rapture and indiscriminate disposal of mining waste (cyanide) on the environment. For example on the 28th of September 2005, EPA ordered the Bogoso Gold Limited (BGL) to stop surface mining at Prestea due to failure of BGL to put in place mitigating measures contained in its environmental impact statement 20. The papered revealed that some of the Mining companies tried to cover up when there was a cyanide spill. An example can be said of Newmont Ghana Gold Limited (NGGL). The company responding to the Panel's observation set up to investigate the pollution caused by the cyanide spillage and its failure to keep samples of the spill and to immediately notify Government regulators of the spillage amounted to a coverup.

WACAM, human rights and mining advocacy a Nongovernmental Organization and the indigenous people alarmed the issue of cyanide spillage and informed the Law enforcing Agency to take serious actions. Newmont Ghana Gold Limited (NGGL) apologized for the cyanide spillage at its Ahafo Mine Project and accepted to pay the GH 7.0 million penalty the Ministerial Panel that evaluated the accident imposed on it. The Panel said GH 3.1 million of the amount should go to the affected communities. EPA was to receive GH 2.8 million while the Inspectorate Division of the Minerals Commission gets GH 1.05 million21.

SECTION 4 4.1 Conclusion. The contribution of the mining sector to the socio economic development of the country cannot be over emphasized and the effect of cyanide spillage on the
Environmental News Services (ENS) 2010, Newmont Gold Mine to pay Ghana Millions for Cyanide Spill at http://www.ens.newswire.com/ens/jan2010/2010-01-22-01.html last visited 18th march, 2011. 21 WACAM, 02-11-2009, Cyanide Spill at gold mine kills many fish at th http://www.minesandcommunities.org/article.php?a=9597. Last visited 20 march, 2011. 13
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environment and how it affect the ecosystem and the lives of the mining communities as well as the role of law enforcing agencies have been explored. Numerous laws and regulations exit in the mining sector, these laws do not provide technical standards and measures but just a general application of the law. The laws are also silent on the social responsibility of the mining companies towards the communities in which they operate. There is no national policy framework that guides and enforces the implementation of Cooperate Social Responsibility (CSR) and other related services in the sector. Mining Companies are therefore not bound by law to implement CSR activities in the country. In other words, CSR activities are undertaken more in response to moral convictions rather than legal obligations. Lack of stringent mining and environmental regulations coupled with the absence of strict enforcement of existing laws, has left mining communities saddled with polluted environments that threaten their very existence.

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BIBLIOGRAPHY Primary Sources. Article 257, 1992 Constitution of Ghana. Customs and Excise Regulations, 1973 (L.I. 838) as amended by the Customs and Excise Tariff (Amendment) Regulations, 1984 (L.I. 1309) are hereby further amended by the revocation of Tariff Numbers 3.2, 3.5, 3.6, and 3.7 and all particulars relating thereto Health Areas Amendment and Extension Law, 1935 (No. 20 of 1935). 3. Substituted by section 5 (1) of the Mining Health Areas Amendment and Extension Law, 1935 (No. 20 of 1935). Mining Health Areas Ordinance, 1925 (No. 19 of 1925). It came into force on 1st July, 1926. It was Cap. 49 of the 1951 Edition. 2. Amended by section 4 of the Mining P.N.D.C.L.182, Minerals Export Duty (Abolition) Act, 1987 Secondary Sources: Books: Anderson , K., Purcell k.S., International Conference on Pollution Prevention in Mining and mineral Processing, (Snowmass Village, Colorado USA, NP) august 2427, 1993 Birnie, P., Boyle A., Redgwell C., International law & the Environment (New York , USA, Oxford University Press ,2009). Eggert. G. R Mining and the Environment: International Perspectives on public policy (Washington DC, USA, 1616 P Street, NW, Washington, DC 20036-1400, 1994) Mcmahon, G., Remy, F. Large Mines and the Environment ( Canada, International Development Research Centre, Ottawa, ON, Canada K1G 3H9 & The World Bank 1818 H Street, N.W., Washington, DC 20433,USA, 2001).(page 21).

Article: Agency for Toxic Substances and Disease Registry (ATSDR).2006. Toxicological Profile for Cyanide (Update). Atlanta, GA:

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Emmanuel K. Boon, Frederick A., Corporate social responsibility in Ghana: lessons from the mining sector. IAIA09 Conference Proceedings', Impact Assessment and Human Well-Being 29th Annual Conference of the International Association for Impact Assessment, 16-22 May 2009, Accra International Conference Centre, Accra, Ghana. Kwasi Baffore Intsiful ,Public Interest Environmental Law Conference@ University of Oregon School of Law Eugene, Oregon (Feb 25 28, 2010). U.S. Geological Survey, Mineral Commodity Summaries, January 2007. Internet Sources: Chris Van de Ven, Gold extraction Using Cyanide Leaching, available at http://tc.engr.wisc.edu/uer/uer97/author4/index.html (last visited 8th April, 2011) Environmental News Services (ENS) 2010, Newmont Gold Mine to pay Ghana Millions for Cyanide Spill at http://www.ens.newswire.com/ens/jan2010/2010-01-2201.html last visited 18th march, 2011. Mike Anane, Cyanide spill Ghanas worst Environmental Disaster at http://www.reocities.com/siyanurlealtin/ghana.html last visited on 18th march, 2011. Mining Portal of Ghana: Active Mining Companies with web site at http://www.ghana.mining.org/ghweb/en/links/mines.html last visited on 2nd much 2011 Stockholm Convention on Persistent Organic Pollutants, 16 June 1972, entered into force 23May 2001 available at http://www.unep.org/Documents.Multilingual/Default.Print.asp?documentid=97&arti cleid=1503 (last visited 8th April 2011)

WACAM, 02-11-2009, Cyanide Spill at gold mine kills many fish at http://www.minesandcommunities.org/article.php?a=9597. Last visited 20th march, 2011.

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