In this article, we outline the technical requirements, the contents of the Resumption Project, and the regulatory risks associated with the process.
The resumption of mining activities after a temporary suspension or stay of proceedings requires prior authorization (favorable statement) from the National Mining Agency (ANM). Restarting operations without the regulatory agency’s approval constitutes a violation and exposes the asset to administrative sanctions.
1. Maintenance of the Mine During Suspension
A temporary suspension does not exempt the titleholder from conservation obligations. To prevent the characterization of abandonment of mining activity, maintaining the following routines is mandatory:
- Access Control and Safety: Securing access points, asset protection, and deactivating electrical circuits.
- Water and Environmental Management: Maintaining the drainage system and continuous monitoring of effluents, air, and the water table.
- Asset Integrity: Preventive maintenance of remaining equipment and installations.
2. Requirements for the Resumption Project
The application must be filed within the period of validity of the authorized suspension, accompanied by the Project for Resumption of Mining Operations. The document requires:
- Geotechnical and Structural Assessment: Stability diagnosis of working faces, slopes, and pillars, alongside operational testing of machinery and installations.
- Drainage and Dewatering Plan: Dewatering project for pits and galleries, as well as updating the drainage system in accordance with valid water permits.
- Safety and Licensing Compliance: Updating the Risk Management Program (PGR) and the Occupational Health Medical Control Program (PCMSO), pursuant to the Regulatory Mining Norms (NRMs), and verifying the validity of environmental licenses.
- Revision of the PAE and PFM: Adjustment of the Plan of Economic Exploitation (PAE) and the Mine Closure Plan (PFM) should changes occur in production scale, mining method, or the beneficiation process.
3. Sanctions and Regulatory Risks
Resumption operations initiated without prior approval from the ANM constitute a direct violation of the NRMs, subjecting the titleholder to fines and immediate precautionary measures, such as the mandatory shutdown or suspension of activities.
Conversely, an untimely request filed outside the validity period of the suspension, or failing to effectively restart operations, generates warnings and pecuniary penalties. Continued inaction six months after the issuance of a fine may lead to the forfeiture of the mining title.
Regulatory compliance throughout the resumption process prevents compulsory shutdowns and secures the maintenance of the mining concession.
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