Document(s) 9 de 14

For the past 20 years, the environmental impacts of mining have been a growing concern. In Brazil, this concern was reflected in the passage of the 1981 National Environmental Policy. This legislation consolidated existing regulations and created an administrative structure to implement them. At about the same time, a major expansion occurred in both formal and informal gold mining. The emergence of the garimpo (artisanal) phenomenon, particularly in the informal sector, was primarily due to the dramatic increase in the gold price in the late 1970s and to the high unemployment at that time.

This paper provides an overview of the gold-mining sector in Brazil. It examines the environmental effects of the technologies used, identifies factors in the environmental behaviour of formal gold-mining companies, and suggests how the regulatory regime can be enhanced to minimize the effects of gold mining on the environment.

This research was done from April 1990 to October 1992. It involved the use of both secondary sources (reports, articles, books, and statistics) and direct interviews with government officials, nongovernmental agencies, mining-company executives, and prominent members of the garimpo community.

History

Although gold was known to be present in Brazil in the 16th century, commercial exploitation only began a century later with the discovery of rich deposits in the states of Minas Gerais, Goiás, and Mato Grosso. In the 18th century, production in these areas (and others) made Brazil the largest producer of gold in the world. During this time, output was 830 t, or 58.4% of the global output, which was about 1 421 t (Berbert 1988).

Table 1. Investments in exploitation of gold and mining, 1981–90.a
Year	Gold		Miningb
	(million USD)	(%)	(million USD)
1981	50.2	25.1	200.0
1982	52.8	24.1	218.8
1983	31.2	23.3	133.8
1984	68.5	39.4	173.0
1985	50.0	41.4	120.9
1986	34.4	39.2	87.8
1987	60.5	31.4	192.4
1988	87.8	65.8	133.4
1989	48.2	55.4	87.0
1990	30.0	50.0	60.0
Source: DNPM–DEM (n.d.), SIPEM Project, Mineral Yearbook. Note: USD, United States dollars. aConstant price, 1990+ 100, obtained on basis of the current values in national currency, converted at the official rate of exchange (indexed by the US General Price Index). bExcluding petroleum and natural gas but including gold.

However, production declined from the middle of the 18th century, mainly because the rich alluvial deposits of Minas Gerais were exhausted. Technical problems related to the development of underground mines contributed to this decline. After Brazil's independence in 1822, the country was opened to foreign investment, and about 50 gold-mining companies were established. Most were unsuccessful; by 1888, the beginning of the republican period, only four remained in operation. Of these, only one, St John d'El Rey Mining Company, is still in operation; it is now named Mineração Morro Velho S.A. (Maron and Silva 1984).

In 1931–1980, Brazil produced only 305 t of gold, about 0.6% of global production (Berbert 1988). However, this situation changed with increasing gold prices and the collapse of the Bretton Woods agreement. With the ensuing gold rush — the greatest in Brazilian history — Brazil rejoined the world's major gold producers.

The development of the formal gold-mining sector

As a result of the gold rush, the investment in mining exploration and development in the formal sector in 1981–90 (Table 1) totaled 1.407 trillion United States dollars (USD), or about 20% of the total mineral-sector investment in that period (excluding petroleum and natural-gas investment) (DNPM–DEM n.d.).

Table 2. Estimated industrial (formal) gold production by economic group, 1993.
Economic group	Production
	(t)	(%)
Compañía Vale do Rio Doce	134	30.0
Bozzano Simonsen–Inco–TVXa	131	29.5
RTZ–Autram–Cobem	55	12.4
Amira Gencor	45	10.1
Others	80	18.0
Source: DEM–DNPM (n.d.). aIn June 1993, Inco sold its controlling share of TVX Gold, whose chair is based in Brazil (Anon. 1993; Haliechuck 1993).

These investments in formal mining resulted in the discovery of about 25 gold deposits with economic potential (Mackenzie and Dogget 1991). Several new companies were formed to develop these, principally Compañía Vale do Rio Doce (CVRD) (1984), São Bento Mineração S.A. (1986), Rio Paracatu Mineração S.A. (1987), and Marex Mining (1987). The old Mineração Morro Velho S.A. also increased its capacity and formed two new companies, Jacobina Mining and Commercialisation (1983) and Serra Grande Mineração (1984). After the expansion of the 1980s, a period of consolidation occurred. By 1991, the sector had 27 companies; a number of these belonged to one of four economic groups:

• The Brazilian state-owned company;
• Bozzano Simonsen Group, associated with the South African Anglo American Corporation and the Canadian Inco–TVX incorporation;¹
• RTZ (United Kingdom)–Autram-Cobem; or
• Amira–Gencor (South Africa).

These groups (Table 2) were responsible for 82% (365 t) of the total formal-sector gold-mining output of Brazil in 1993.

Labour force in formal mining

In 1989, the formal mining sector in Brazil directly employed 8 744 workers (excluding subcontractors). In contrast, there were about 350 000 garimpeiros (prospectors) at this time. Technologies that economize on labour help to explain the decreased number of workers in industrial mining. For instance, in 1985 the output of Mina Grande, one of the oldest mines of Morro Velho, was 0.75 t of ore per worker's shift. By contrast, in 1982, the new mines of Cuiabá–Raposos, which are part of the Morro Velho mining group, produced 4 t of ore per worker's shift in surface operations and 3 t of ore per worker's shift in underground operations (Brasil Mineral 1985).

In businesses that count on the participation of outside capital, the new technologies in the production process are usually introduced by the foreign partner. The Cuiabá–Raposos mines, already cited, is an example. To drill deep shafts, the company replaced its manual drilling machines by modern equipment that reduced the number of workers employed and the time required to excavate the gold. In this case, shaft-sinking technology was introduced by Shaft Sinkers Ltd of South Africa, a subsidiary of the joint-venture partner, Anglo American (Minérios: extração e processamento 1991).

Health and safety

Underground conditions in the older mines leave much to be desired, with high injury rates, poor ventilation, and evidence of high rates of silicosis among the workers. According to the Miners Union of Nova Lima (state of Minas Gerais), where the largest mining complex of Morro Velho is located, about 40 accidents occur every month; in the 1980s, about 80 miners died from work-related accidents. According to the Institute of Social Welfare in Nova Lima (Morro Velho's headquarters), 4 miners die from silicosis and 13 new cases are reported every month, on average (Ribeiro 1990).

The problems of occupational health and safety have been a source of tension between workers and management, principally at Morro Velho, whose old mines provide precarious health conditions. Mining companies are more interested in increasing their profits than in taking responsibility for directly managing the mass of workers. This attitude has led the mines to use subcontractors for the manual labour, principally in the mining phase, which has some operations similar to those in civil construction. For example, in Rio Paracatu, 62% of the firm's 1 152 workers were subcontractors.²

Environmental

The Rio Paracatu mining operation is a case of environmental awareness coupled with financial success. At this open-pit mine, 0.6 g Au/t is recovered by using the carbon-in-leach technique.

However, the more refractory ores of São Bento led the principals (Amira and Unamgem Mining and Metallurgy) to adopt sophisticated technology developed by their joint-venture partner, Gencor (of South Africa). The firm has adopted both pressure oxidation and biological oxidation techniques, and once their teething troubles are overcome, these processes should give only minor environmental problems (Reis et al. 1991).

Some firms have also adopted new technology for the cyanidation step — the carbon-in-pulp and heap-leaching systems. Among the firms using these techniques are Rio Paracatu, Morro Velho, CVRD, Xapetuba Mining, Jacobina Mining and Commercialisation, and Serra Grande. In every case, closed-circuit flowsheets are used to ensure environmental protection. In addition, electronic monitoring and control equipment has been installed in a number of these plants, further strengthening environmental security.

Garimpo gold mining in Brazil

The leap in the gold prices at the end of the 1970s led to an upsurge in informal mining activity exceeding that of the gold rush of the previous century. Up to this time, informal mining had been limited largely to the Tapajós district (in the Amazon region to the south of the state of Pará). In 1973, only 5.9 t of gold was produced by the garimpeiros, and 5 years later this had increased to 18 t (Araújo Neto 1991).

The rate of garimpeiros' discoveries increased greatly after this time, with alluvial gold deposits discovered in Alta Floresta, in Mato Grosso (1979); Rio Madeira, in Rondônia (1979); Serra Pelada, in Pará (1980); Cumaru and Tucumã, in Pará (1981); Apiacas and Juruena, in Mato Grosso (1981); Catrimani and Uraricoera, in Roraima (1987); and several other sites (Mackenzie and Dogget 1991). Additionally, output considerably increased at existing garimpos sites, such as Paruari and Tapajós, in Pará; Gurupi, in Maranhão; and Lourenço, in Amapá.

Parallel to this upsurge, the amount of gold sold on the black market increased disproportionately. Table 3 shows how the official and unofficial outputs diverged after the mid-1970s; the two outputs corresponded only from 1990 on, following the flotation of Brazilian currency (DEM–DNPM n.d.).

Table 3. Gold output of garimpos, 1973–90.
Year	%	(A) Official (t)	(B) Estimate (t)	Difference (B÷A) (%)
1973	1.2	5.9	4.7	79.7
1974	1.1	9.0	7.9	87.8
1975	1.5	9.6	8.1	84.3
1976	2.5	9.9	7.7	77.8
1977	1.6	12.1	10.5	86.8
1978	5.4	18.0	12.6	70.0
1979	1.1	31.7	30.6	96.5
1980	9.7	35.9	26.2	73.0
1981	12.9	37.6	24.7	65.7
1982	20.9	41.0	20.1	49.0
1983	47.5	63.6	16.1	25.3
1984	30.6	55.0	24.2	44.4
1985	22.2	65.0	42.8	65.8
1986	14.8	75.0	60.2	80.3
1987	22.7	78.0	55.3	71.0
1988	34.3	90.0	55.7	61.9
1989	29.5	80.0	50.5	63.1
1990	—	55.0	55.0	—
1991	—	41.9	41.9	—
Source: 1973–80, Araújo Neto (1991); 1981–91, DEM–DNPM (n.d.).

A number of researchers attributed this boom principally to socioeconomic factors (Salomão 1984; Cota et al. 1986; Susczynski 1988). They considered rural-settlement policies and the failure of agrarian reform as being key factors. The situation was exacerbated by the series of economic crises that struck Brazil after 1973 (the first oil shock) and worsened in 1979–83 (the second oil shock). A further factor was extensive highway construction in the 1960s and particularly in the 1970s, which facilitated migratory movements to the Amazon region, where garimpo activity is concentrated. Such highways included the Belém–Brasília, the Transamazônica, the Cuiabá–Porto Velho, the Cuiabá–Santarém, and sections of the Perimetral Norte.

The introduction of new technology and its social effects on garimpos operations

In addition to the opening up of new areas for production, the surge in garimpo output in the late 1970s was driven by new technologies. Thus, garimpos operations became more intensive, as well as more extensive. In particular, pumps were introduced, as were various types of crushers.

This mechanization, albeit limited, meant that a new category of miner appeared: an entrepreneur who had the capital to purchase and maintain the machinery. Such people became site bosses, and the wealth they accumulated gave them much economic, political, and social clout. By 1988, they were powerful enough to influence the wording of the new Constitution; indeed, by 1990, the garimpeiros represented a significant voting block, particularly in the Amazonia region.

As a result, for the first time, artisanal mining was addressed in the Constitution, and garimpo activity ceased to be seen as an illegal form of mining exploitation. It was defined according to the mineral sought and the type of deposit. The Constitution also assured the miners the mineral rights to the deposits they were exploiting (art. 174, para, 4, regulated by law No. 7805/89). It also established the right to form cooperatives with a status equivalent to a formal mine (art. 174, para. 3).

The environmental effects of garimpos activities

The technical improvements secured by the garimpeiros were all directed at mining more ore; the gold-recovery processes were still limited to gravity concentration and amalgamation. However, the environmental effects of this modest mechanization were severe, with deforestation, siltation, and land sterilization occurring over wide areas (Silva et al. 1989; Silva 1991). As by-products of this increased activity, the incidence of infectious diseases, such as malaria, increased greatly among the indigenous people living near the garimpos, in particular the Yanomamis. This tribe has inhabited the region north of the state of Roraima for several thousand years, and contact with the garimpeiros has led to a serious corruption and decline of their culture.

According to medical examinations done by the National Health Foundation of Roraima between January and May 1991, 50.3% of the 9 588 Yanomamis examined had malaria; 25% of these had virulent forms for which no satisfactory cure has been found. The garimpeiros suffer as much as the indigenous people from this disease. According to data from the Brazilian Ministry of Health (1990), more than 99% of the cases in Brazil occur in the Amazon region, with 70% of these in the 30 districts where garimpo activity is ongoing. Of the 560 143 positive blood smears, 376 554 were from the inhabitants of these districts (DMMH 1991).

Increased gold output means increased use of mercury. No direct measurements of use have been made, but very little mercury is recovered from the amalgamation process the garimpeiros use (despite the availability of simple and cheap technology). Hacon (1990) compiled the results of Brazilian studies (Lacerda et al. 1987; Martinelli et al. 1988; Couto et al. 1989; Pfeiffer et al. 1989; Malm et al. 1990) and found levels well above the limits established by the World Health Organization and Brazilian public-health agencies. The studies also revealed that mercury contamination reached not only the population groups endogenous to garimpos sites but also exogenous groups, an indication of the extent of the contamination.

Environmental regulations

Although Brazil has had environmental regulations since the 1930s, they were not consolidated into a general, formal code. However, during the late 1970s, when gold production increased rapidly (Table 4), environmental legislation increased correspondingly. This stage began in 1981, when the National Environmental Policy was approved. This law was presented in detail in June 1983. The administration of this law and the promulgation of environmental laws by the states was dealt with by the Sistema Nacional de Meio Ambiente (SISNAMA, national system for the environment) (law No. 6938/81 and decree No. 88351/83).

At both the state level and the federal level, new environmental laws that dealt with the relationship between mining and the environment were passed. At the federal level, the Comisión Nacional del Medio Ambiente (CONAMA, national commission for the environment) — the consultative and deliberative body of SISNAMA — approved a number of important resolutions. These required presentation of an environmental licence issued by an acceptable environmental authority. This in turn required companies to undertake estudios de impacto ambiental (EIAs, environmental-impact studies) and relatórios de impacto ambiental (RIMAs, environmental-impact reports) (CONAMA resolutions No. 01, 23 January 1988, and No. 09, 16 December 1990).

The 1988 Constitution also set out guidelines governing the relationship between mining and the environment: these provisions included the obligatory preparation of EIAs before initiation of mining or activities with the potential to cause significant environmental degradation (art. 255, para. 3, item IV). They also required garimpo mining operations controlled by cooperatives to take due account of the environment (art. 174, para. 3).

Table 4. Brazilian formal and garimpo production, 1973–91.
Year	Formal production		Garimpo production
	t	%	t	%
1973	5.1	46.4	5.9	53.6
1974	4.8	34.8	9.0	65.2
1975	3.9	28.9	9.6	71.1
1976	3.7	27.2	9.9	72.8
1977	3.8	23.9	12.1	76.1
1978	4.0	18.2	18.0	81.8
1979	3.3	9.4	31.7	90.6
1980	4.1	10.0	35.9	90.0
1981	4.4	9.8	37.6	90.0
1982	4.6	10.1	41.0	89.9
1983	6.2	8.9	63.6	91.1
1984	6.7	10.9	55.0	89.1
1985	7.6	10.5	65.0	89.5
1986	9.3	11.0	75.0	89.0
1987	13.1	14.4	78.8	85.6
1988	22.2	19.8	90.0	80.2
1989	22.9	22.3	80.0	77.7
1990	29.9	45.2	55.0	64.8
1991	34.0	44.8	41.9	55.2
Source: 1973–77, Araújo Neto (1991); 1978–91, DEM–DNPM (n.d.).

In 1989, regulations on art. 174, paras. 3 and 4 of the Constitution were issued, creating the Garimpo Mining Permit (law No. 7805, 18 July 1989). This, among other provisions, made the granting of mining rights dependent on submission of the environmental licence to the appropriate environmental authority (arts. 2 and 18). It also made garimpos mining activities that damaged the environment subject to a series of penalties (arts. 20 and 22).

At the state level, some units began to define specific regulations and to create state environmental agencies, following directives of the National Environmental Policy. Among the gold-mining states, Minas Gerais — the state with the traditional mining region — was the first to set up structures for managing the environmental problems related to mining. There, beginning in 1981, a series of decisions of the Conselho de Política Ambiental (state council for environmental policy) led to regulations governing mining activities with the potential for damaging the environment. Of all the gold-producing states, Minas Gerais has the most controls on environmental impacts of mining. (It also produces the highest volume of industrial gold: 15.4 t, or 51% of Brazil's total production of industrial gold in 1990.) The formal mines and the garimpeiros differ in their response to these regulations, for reasons set out below.

An analysis of the environmental behaviour of formal and garimpo gold mining

There is clear differentiation between the environmental impacts caused by formal mining and those caused by garimpos activities. The formal mining, despite having the potential to cause serious occupational health and safety problems (mainly when the miners are underground), damages the environment less than garimpo mining. The more predatory behaviour of the garimpeiros can be attributed to various factors, discussed in the following subsections.

Scale of operations

The main businesses in Brazil's formal mining sector are large state firms and firms with private national and foreign investors. Large mining companies exploiting a highly profitable mineral will have the resources to adopt good environmental practices.

Such companies more often have a better environmental profile than the garimpeiros and are familiar with the technologies involved: for example, Rio Paracatu, connected with the British conglomerate, Rio Tinto Zinc, and the Brazilian state-owned CVRD (Birkin 1989; Mining Journal 1990).³ São Bento, connected with the South African firm Gencor, has adopted Gencor's environmental practices.

Besides investing in methods for minimizing environmental degradation, some businesses have adopted compensatory environmental strategies, such as the creation of reserves of fauna and flora in areas they own. CVRD has also invested in improvements to community installations to it gain better public acceptance.

In contrast to the big formal operations, the garimpos sites are of a small or medium scale. They are financed by native investors, who are largely unconcerned about the environment and are without the same motivation for adopting practices less damaging to it. In addition, the majority of the site bosses operate in regions where they do not own the property on the surface and therefore have little interest in investing in the conservation and protection of this asset.

Company locations versus garimpo mobility

Formal gold-mining operations are planned to last many years and require lots of capital. This makes these mines visible and accessible to control and supervision by the social elites in the country, by the communities, and by the government and nongovernmental environmental agencies. A good number of these mines are near urban areas that in many cases predate the projects, so they are more vulnerable to community pressure and social control. They are also subject to more control because they are in states where government environmental agencies are more structured, as in Minas Gerais. In addition, formal gold-mining projects are subject to more social control because they are large and in the majority of cases connected with large economic conglomerates. Various denunciations by the community have been registered with the environmental agencies.⁴

Supervision and control of the garimpos sites are much more complex. The locations are numerous (estimated at 2 000 in just Pará) and difficult to reach, and this activity is distinguished by its mobility. The mobility is reinforced by the small size of the deposits (the work at each site is generally of short duration), by the small investments required to mount the infrastructure directly at the mining site, and by the ease with which machines and equipment can be transported from one site to another.

Also, the majority of the sites for garimpo gold mining are in the Amazon region (which produced 79.5 t of garimpo gold in 1989). In this region, government environmental agencies are not well equipped to control the pollution, and at times the voices of the victims of pollution are confused with those of the polluters themselves. This is because the garimpeiros and the people living in the gold-prospecting areas are both harshly affected by the environmental pollution the mining provokes. The effects of pollution are also strongly felt in the communities that tend to spring up around the garimpos to provide the social and the economic activities needed to develop this activity.

Technological dualism

Most of the formal mining companies began to operate in the 1980s and were able to use technologies with high economic performance, developed mainly in the 1970s. These technologies basically increased productivity by reducing the use of manual labour and inputs in general, and their introduction was accompanied by a parallel development of techniques and processes to minimize environmental impacts. These impacts were related to the use of dangerous products and to the release of toxic elements (contained in the mineral) during the treatment process.

The formal mining companies' adoption of methods less damaging to the environment was also bolstered by the possibility of incorporating some technologies to reconcile the best economic performance with the best environmental performance. For instance, SO₂ from roasting plants is collected to produce sulfuric acid. Although the market for this acid is not always favourable, its production helps to reduce the cost of environmental protection (Morro Velho). Another example is the technique of backfilling, which makes possible the best use of solid wastes. After the ore is processed above ground, the waste material is returned to the mined-out areas. This reduces the expense of underground timbering and provides an alternative to leaving the waste material in tailings dams (São Bento and Morro Velho).

The use of the pressure-oxidation autoclave, which uses compressed oxygen (harmless to the environment) as its basic input, and of biotechnology for the metallurgical process is currently small scale, as is the use of most of the technologies that, with regard to the specific characteristics of ore exploitation, reconcile good economic performance with good environmental performance (São Bento) (Brazil Mineral 1985; Ribeiro 1989).⁵

According to specialists who work in formal gold mining, the incorporation of new technologies is not brought about through a technological dependency; rather, assimilation of the technology by domestic technicians is related to the existence in Brazil of good educational institutions for mining.⁶

Rio Paracatu, besides incorporating more ecologically sustainable technological processes, adopted new administrative practices. Environmental management (including management of occupational health and safety) is now shared among all employees, as well as the manual labourers (who are subcontractors).⁷

The garimpos mining activities, on the other hand, developed in a labour-intensive and highly polluting framework, with technologies that demanded little capital. Because the garimpos are small- and medium-scale undertakings, they expand by using mechanical and semimechanical technologies for rapid and easy extraction of gold, with little or no attention to the efficiency of the operation or to environmental management. The very organizational structure of garimpos activities is also a serious obstacle to the introduction of more suitable technologies. For instance, difficulties for environmental control are created by the existence of a variety of operational systems in the same gold deposit, with a variety of production technologies (dredges, mills, high-powered hoses, etc.) managed by different garimpos bosses.

Environmental regulations

Until 1983, only four industrial gold-mining companies operated in Brazil, and only one, Morro Velho, was dedicated exclusively to the production of this metal. The other firms produced gold as a by-product of the mining and refining of other minerals (Maron and Silva 1984).

Today, about 30 companies are operating, and almost all began when the a new set of environmental regulations, directed at various sectors of economic activity, including the mining sector, was introduced. Consequently, only Morro Velho, which had operated with conventional methods and without environmental concerns, had to restructure itself to comply with these environmental requirements. The new firms on the national scene could incorporate technologies to meet the environmental regulations at the beginning of their operations. These firms had reduced expenses for environmental control because the cost of prevention is less than the cost of repairing damage.

The businesses were strongly motivated to follow the environmental regulations because they were essentially obligated to: the legal requirement to present the environmental licence (issued by the appropriate environmental agency in DNPM) to receive the rights to mine and to begin operations pressured the firms to carry out EIAs and RIMAs. Furthermore, some financing agencies, such as the National Economic and Social Development Bank, began to require environmental licences before giving credit to the companies, which broadened the range of environmental supervision.

Before the implementation of the new environmental regulations, basically only one mining business operated in Brazil, Morro Velho, which had been in existence for more than a century. In the process of refining the gold ore, this company released toxic gases (SO2), destroying all of the vegetation downwind of its chimneys. The firm also threatened the water supplies because it had no type of holding dams for the rejected materials (Maron and Silva 1984). Only in 1980, with increasing environmental and community pressure, did Morro Velho begin to adopt methods of environmental control. These included dams for holding the rejected material, a new refining plant, and a plant to manufacture sulfuric acid (to avoid the release of SO2 into the atmosphere). In addition, the company carried out programs to monitor the quality of air and water and a deposit of slimes containing arsenic (Brazil Mineral 1989).⁸

Despite these measures, Morro Velho still carries heavy environmental liabilities. Because it used conventional technologies and paid no attention to the environment for more than 100 years, serious problems are still unsolved. For example, for decades the company deposited waste materials with high levels of arsenic alongside the Cardoso river. With time, the material compacted, and now it is around and under urban buildings.⁹

The introduction of the new environmental regulations had little impact on the investment decisions of the other industrial mining companies, though, as most of these were just entering the market when these regulations were being adopted. The increase in gold prices that occurred at the same time was responsible for the expansion of these companies.

Although these environmental regulations had little effect on company investments, they did affect organizational structure and the configuration of the companies' mining and processing projects. All of these companies contracted their own personnel or outside consultants specialized in environmental issues, and the question of the environment came to be seen as a key element to be incorporated into gold-mining projects.

The new environmental regulations had very little impact on the garimpos, in contrast, despite the fact that these prospecting sites were also obligated — even by the Constitution — to adopt measures to preserve the environment. Such measures were never adopted by the garimpos, however, because of the very nature of their activities, such as

• The short period between initial operation and exhaustion of deposits;
• The mobility of garimpeiros;
• The disregard for obtaining environmental licences as a requirement for credit (the garimpeiros operate within an informal economy);
• The expansion of garimpos into areas independently of the granting of formal mining and implementation rights;
• The heterogeneous nature of the mining techniques used in a contiguous area and the consequent difficulties in standardizing technologies and environmental recovery measures;
• The lack of dissemination of nonpolluting technologies;
• The lack of technical assistance; and
• The unsuitability of environmental legislation, which imposes the same environmental controls on garimpos as on large-scale mining companies, despite the evident differences between the two.

Final comments and suggestions

The environmental degradation generated by gold mining is concentrated in the garimpos areas, where problems of pollution have reached significant proportions and there is little indication of change in the near future.

The garimpo workers are more predatory with regard to natural resources than the formal-sector mining companies are. The principal reason for this is that the large corporations have much more capital and can more easily absorb the cost of advanced technologies for gold production. The garimpeiros have much less capital to adopt environmental technology. This problem is intensified by the fact that these workers are seldom qualified (but are just people who have escaped the widespread unemployment in the country), in contrast to the highly qualified people employed in formal gold mining.

The environmental regulations also influenced the big businesses to adopt practices that are less detrimental to the environment. The predominantly preventive and coercive character of these regulations also stimulated permanent innovations in environmental control. For these businesses, then, the regulations played a relevant role in the adoption of practices that are ecologically less offensive, but these regulations were practically meaningless at the garimpos sites.

If any legal norm is to be observed, it must be suitable for the target organizations; government entities responsible for elaborating the norm and executing inspection must be technically prepared for their task; and the necessary social, political, and economic forces must be present to ensure the feasibility of execution. This is anything but the case at the garimpos mining sites. The legal norms are inadequate; the entities responsible for application of the norms are poorly equipped for their task; and the social, economic, and political forces are more favourable to maintain the status quo in garimpo mining than to transforming this activity into an ecologically less degrading form of production.

Adoption of environmentally more sustainable practices at Brazilian garimpos is impeded by

• The existence of a growing contingent of unemployed workers, generated by the ever-worsening Brazilian economic crisis;
• The power of the social groups that flourish and solidify around the garimpos;
• The importance of the garimpeiros at election time;
• The mobility of these operations and the difficulties this causes for inspection entities; and
• The fact that institutional normalization of these activities would demand extra costs on such items as environmental licences, taxes, and other administrative expenditures.

In this framework, the curtailment of environmental degradation provoked by gold mining in Brazil is fundamentally a question of mitigating the grave social and economic problems that afflict Brazilian society. As well as the creation of job opportunities for the underemployed labour now at the garimpos, the following measures are suggested:

1. Improve the structure and preparation of government entities responsible for formulating mineral and environmental policies so that they can more efficiently design and elaborate norms.
2. Develop, improve, and disseminate alternative, nonpolluting technologies for the garimpos and small- and medium-scale gold-mining companies.
3. Provide incentives and technical assistance for transformation of some garimpos into small- and medium-scale mining companies, structured to meet environmental-protection demands.
4. Adapt environmental legislation to the specific characteristics of garimpos and small- and medium-scale gold-mining companies.
5. Develop and disseminate technologies that substitute less dangerous products for highly toxic inputs.
6. Provide environmental education programs for garimpeiros and for communities near the prospecting areas.
7. Adopt methods to minimize the occupational health and safety problems in the state and formal-sector mining firms, principally in the underground mines.

¹ In June 1993, Inco Ltd sold its control block in TVX Gold, which holds interests in six gold and silver mines in Canada, the United States, and South America, including Brazil. TVX Gold was created in 1991 through the merger of gold assets held by Inco, and after the sale, TVX Gold's chair, Eike Batista, who is based in Brazil, became the largest single shareholder, with 13% stake (Haliechuck 1993; Wall Street Journal 1993). [BACK]

² Interview at Rio Paracatu Mineração, 1991. [BACK]

³ Also, interviews at Departmento Nacional de Produção Mineral (DNPM, national department of mineral production) and CVRD. [BACK]

⁴ Interview at Fundação Estadual do Meio Ambiente (FEAM, state foundation for the environment), 1992. [BACK]

⁵ Also, interviews with the director of São Bento and technicians at Fundação Centro Tecnológia (CETEC, central technological foundation) and FEAM, 1991 and 1992. [BACK]

⁶ Interviews at DNPM and FEAM and with independent consultants in the mining sector. [BACK]

⁷ Interviews with technicians of Rio Paracatu, 1991. [BACK]

⁸ Also, interviews with technicians at DNPM, CETEC, and FEAM, 1992. [BACK]

⁹ Interview with technicians at FEAM, 1992. [BACK]

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