How Data Transparency in the SIGBM Affects Your Company’s Valuation
With the opening of the deadline for submitting the Declaration of Stability Condition (DCE), the mineral sector turns its attention to the technical validation of tailings disposal structures. In the current scenario, viewing the DCE merely as a seasonal commitment in March is a limited perspective. Currently, it functions as the final step of an uninterrupted control flow, where operational safety is built and documented fortnight by fortnight.
Submission Cycles: Internal vs. External
It is important to remember that the stability process is continuous and divided into two complementary stages throughout the year:
- March: Internal Consulting DCE Campaign. Focuses on the perspective of the entrepreneur’s own technical team or their regular consultancy.
- September: External DCE Campaign. The rigor is increased with the mandatory audit performed by a third-party company, independent of the daily operation.
Who Is Obligated to Submit the DCE?
The obligation of the DCE does not fall on any and all mineral operations, but rather on enterprises that have structures included in the National Dam Safety Policy (PNSB).
According to Law No. 12,334/2010 and the updates of Law No. 14,066/2020, a structure obligatorily enters the inspection radar if it presents at least one of the following characteristics:
| Framing Criterion | Limit Established by Legislation |
| Embankment Height | Greater than or equal to 15 meters |
| Reservoir Capacity | Greater than or equal to 3,000,000 m³ |
| Contained Waste | Classified as Hazardous (Technical Standards) |
| Associated Potential Damage | Classified as Medium or High |
| Risk Category | Defined as High by the inspection agency |
In addition to these criteria, the legislation makes the elaboration of the Emergency Action Plan mandatory for all mining tailings dams.
From the Report to the Algorithm
Through the SIGBM, the ANM has consolidated the conformity assessment in an integrated and data-driven manner. This means that the DCE is not an isolated document; it must reflect the consistency of the information submitted throughout the year by the Regular Inspection Extracts (EIR).
Any divergence between the routine monitoring (fortnightly) and the final declaration (biannual) can signal technical inconsistencies in the system, increasing the need for priority inspections and detailed audits by the Agency.
Resolution No. 175/2024 and Technical Independence
This data cross-referencing dynamic requires the input that feeds the system to be impartial. It is in this scenario that Technical Independence, reinforced by Resolution No. 175/2024, becomes a pillar of credibility for the miner.
Article 46 of the regulation establishes a clear segregation of responsibilities: the professional who issues the Declaration of Conformity and Operability (DCO) of the PAEBM cannot have participated in the elaboration of the Safety Plan or the Hypothetical Dam Break Study. This requirement for distinct perspectives aims to guarantee an impartial analysis, challenging mining companies to manage multidisciplinary and independent teams.
March Window: The Responsibility of Internal Consulting
The deadline from March 1 to 31 is dedicated to the Internal Consulting DCE. This is the moment when the technical team attests to the physical safety of the structure and validates whether the fortnightly reported data supports the declared stability.
The central points of attention for this cycle include the validation of minimum safety indexes (Article 23) and the periodic reassessment of drained stacks regarding liquefaction susceptibility. It is essential to remember that failure to submit on time results in the automatic interdiction of the structure via the system and immediate reclassification to the High Risk Category.
Beyond the Fine: Compliance as a Business Value
For the mineral manager, the regularity of the DCE transcends the barrier of administrative sanctions. A structure with uncertified stability directly impacts the financial health of the business, compromising the mining company’s valuation and its ability to attract investments or access credit lines. In a market guided by transparency and governance criteria, dam safety has consolidated itself as a critical indicator of economic viability and institutional responsibility.
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