Bringing health impact assessment to the Mongolian resource sector: a story of successful diffusion

Abstract

Following the 2009 signing of the stability agreement between the Mongolian Government and Canadian mining company Turquoise Hill Resources (formerly known as Ivanhoe Mines), researchers from Simon Fraser University secured funding from the Canadian Institutes for Health Research to conduct applied knowledge translation (KT) research that introduces health impact assessment (HIA) to Mongolia's rapidly emerging resource sector. HIA is a highly regarded informed decision-making tool that helps to identify, assess and mitigate (or promote) potential positive and negative human health impacts of policies, projects and programs. We engaged in a series of knowledge synthesis, KT and dissemination activities with key public and private sector stakeholders as well as community representatives. Our goals were to develop consensus on a socially and culturally appropriate approach to equity-focused HIA, draw on this consensus to develop a contextualized HIA toolkit, build local HIA capacity based on this toolkit, strengthen the HIA regulatory environment and provide evidence-based support for efforts to institutionalize HIA in the resource sector. These efforts have resulted in the inclusion of HIA in the environmental impact assessment law of Mongolia, and the focus has now shifted from KT to further supporting HIA institutionalization and practice.

Keywords::

• health impact assessment
• environmental impact assessment
• mining and health
• mining in Mongolia
• social determinants of health

Introduction

Resource exploitation is currently a major economic development issue in Mongolia, with Canadian companies playing a major role in the sector. Findings from the International Symposium on Mining and Health held in 2009 in Ulaanbaatar revealed the need for measures to help anticipate and manage potential negative health impacts of mining while keeping up with a rapidly growing extractive industry. Mining has become a central topic of public and political discourse in Mongolia, with considerable concern expressed by the general public and local communities as to the perceived harms and benefits of mining development (Janes et al. 2011). As the main driver of the Mongolian economy, mining development has the potential to provide rural employment, shore up deteriorating rural infrastructure and support local community development. In addition to those positive impacts, it also poses significant environmental, social and cultural risks that could exacerbate, rather than mitigate, urban/rural social inequalities (World Bank 2006). Over time, there has been an increasing recognition that non-health sectors’ activities play a major role in determining health outcomes, specifically; social factors so-called social determinants of health have been recognized as ‘underlying causes of health conditions’. Social determinants of health, which is one of the three areas of public health activity that health impact assessment (HIA) was originated from (Harris-Roxas et al. 2012), can be significantly affected by sub-standard mining activities.

HIA represents one of the most useful tools for translating knowledge about the impacts of development on population and community health. It promotes informed decisions and policies, calls for and applies an evidence-based approach and requires intersectoral partnerships. Using an HIA, government officials, academics, community and industry representatives, and other stakeholders can work to enhance the positive impacts of a policy, program or project and mitigate any negative impacts (Snyder et al. 2011). The development of contextually salient HIA methodologies foregrounding equity and effective community engagement was determined to offer the best approach to meet the increased needs of managing the potential negative impacts of the mining sector (Spickett et al. 2012).

In the absence of regulations requiring HIA of mining activities, there is a danger that mining, and associated large development and industrial projects, will develop in ways that severely undermine health and health equity among Mongolians. Many of these projects are connected closely to overall, ongoing development in Mongolia, demonstrating that a comprehensive response to the effects of mining must include assessment of the impacts of activities outside the scope of mining. Given the recent growth in population, industrial development, and urbanization together with the interest from international mining companies in the resources of the country, it is important for Mongolia to have tools such as HIA in place in order to take advantage of economic growth while improving health and well-being outcomes for the population. (Spickett et al. 2012)

Prior to the launch of our project, we conducted a review of both published and gray literature in order to compile a set of HIA international best practices and knowledge. The review particularly aimed to compare the different HIA training materials and identify those materials most appropriate for employment in low- and middle-income country (LMIC) settings, such as Mongolia. A number of key training materials were identified that cover the basics of HIA methods and could be revised to incorporate examples from local contexts to make them contextually appropriate and useable in LMIC contexts, including Mongolia. We undertook this two-phased, evidence-based, policy-level intervention study to catalyze public, private and civil sector support in Mongolia toward the development and feasibility testing of an HIA methodology, as well as relevant training, for the mining sector that applies a social determinants and health equity framework. We aimed to facilitate efforts to make HIA a mandatory process by advocating its importance and utility to a number of high-level decision-makers. The intervention also aimed to raise awareness among relevant stakeholders, such as central and local government officials within and outside the health sector and mining executives, of the concept of HIA and its importance for large development projects, with the aim to improve and expand HIA practice.

In this paper, we aim (1) to contribute to the body of knowledge and evidence on international HIA practice regulations and (2) to shed light on some HIA implementation challenges that are likely common to extractive industries across many LMICs, particularly the HIA institutionalization issue. To achieve these aims, we reflect upon the history of dissemination, diffusion and uptake of HIA of mining developments in Mongolia; analyze multiple stakeholders’ positions based on their power, will and relevance to HIA adoption; discuss barriers and facilitators to the full adoption of HIA by Mongolian stakeholders for the purpose of managing the potentially negative health impacts of mining projects; and describe the elements of our approach, including context, that appear to have resulted to date in a successful outcome.

Methods

The research methods were informed by the principles of knowledge translation (KT) developed by the Canadian Institutes for Health Research (CIHR 2012) and Canada's International Development Research Centre (Campbell 2008), which were applied to strategies and interventions aimed at establishing effective multi-sectoral partnerships among academics, researchers, decision-makers and policy users based principally on integrated models of KT.

Our specific study methods involved the following:

• Identifying a team of experts and decision-makers with an interest in HIA in the mining sector and who represent various interests among the potential knowledge-using communities (public, private and non-governmental sectors).

• Assembling team members in person for a series of workshops to identify questions and knowledge needs; adapting these to the local social, cultural and policy-making context; assessing and evaluating barriers to potential application of HIA tools and products; and identifying points of policy intervention and tailoring messages accordingly.

• Engaging in wider consultation activities to present and discuss a contextualized and equity-focused HIA tool with a broad pool of knowledge users.

• Monitoring and evaluating project results.

Objectives

The study was a preliminary, evidence-based, policy-level intervention study designed to catalyze public, private and civil sector support in the development and feasibility testing of an HIA methodology for the Mongolian mining sector that applied a social determinants and health equity framework. The specific primary goals of this intervention were to do the following.

Phase 1 goals

• Form a new, international research team that integrates Canadian health research expertise in social determinants of health frameworks and mining impact assessments in indigenous communities, with population health research stakeholders in Mongolia for the purposes of addressing global health inequities related to the growth of Mongolia's mining sector.

• Work with international stakeholders in Mongolia to develop consensus on a methodology and tools for implementing a social determinants of health and equity-focused HIA that is relevant to Mongolian communities, the international policy-making environment and the international mining sector.

• Test the newly developed HIA methodology and tools using one mining project as a case study to demonstrate how a social determinants and equity-focused HIA might work in practice.

Based on promising results from Phase 1 of the research, we obtained additional funding to continue our KT efforts.

Phase 2 goals

• Raise awareness among relevant stakeholders, such as decision-makers, central and local government officials, and mining executives of HIA, and its importance in managing negative impacts of mining.

• Build sustained national HIA capacity by conducting a series of training activities among key practitioners within the health and environment sectors.

• Provide evidence-based support for, and encourage ongoing efforts to expand, the 2006 Mongolia Minerals Law to include regulatory language that would strengthen and broaden required impact assessments.

Anticipated outcomes and roll-out of the study:

• Upon completion of Phase 1 of the project, the project team envisioned to be positioned to develop full-scale, multi-year research proposals to evaluate the impact of these intervention efforts on policies and programs in the mining sector, and on health outcomes.

• Expand the HIA methodology beyond the mining sector to encompass other types of economic development more generally, especially in rural areas.

• Link this bilateral partnership with other social and health equity-focused projects in Canada and internationally.

Ethical considerations

The research project achieved low-risk ethical approval from the Ethical Review Board of Simon Fraser University of Canada and Scientific Review Committee of Mongolian Ministry of Health. All related protocols were approved accordingly.

Discussion

The promising initial results of Phase 1, and especially the approach we have applied in achieving them, are generalizable beyond Mongolia and beyond the mining sector. Developing and gaining approval for the use of contextually appropriate materials, while a necessary first step for introducing HIA, is in and of itself insufficient to ensure its use and application. We identified that further dissemination measures focusing on implementation and outcome steps, developing the means for building local capacity around HIA, and considering the structural and institutional elements required for effective, transparent and accountable use of HIA were necessary. During Phase 2 of the project, we expanded the implementation of interventions by: (A) further dissemination of HIA tools and methodologies to those in relevant ministries, affected communities, non-governmental organizations and mining companies; to sectors other than mining, in particular large infrastructure projects such as railway and road development; and to international audiences, particularly in LMIC settings affected by the scale-up of resource extraction activities. Experiences of Mongolian HIA uptake in the mining sector have been shared in multiple HIA and International Association for Impact Assessment (IAIA) international conferences and (B) the development of relevant supporting structures and resources based on international best practices to support the uptake and use of the HIA tools and methodologies that were developed in Phase 1 of the project.

More specifically, documents such as equity-focused HIA tools and methodologies and minimum set of criteria for successful HIA were developed, translated and printed in Mongolian. HIA short-term training curricula and content were gathered and recommended to the School of Public Health of the Health Sciences University of Mongolia. Specific interventions included further knowledge synthesis of best practices in HIA implementation in LMIC settings, continued development and dissemination work with our multi-sectoral working group managed by the Mongolian Ministry of Health (MOH), an international workshop in Vancouver bringing together Canadian and Mongolian experts and knowledge users, focused ministry-level workshops in Mongolia, and monitoring and evaluation of short- and long-term impacts of these activities.

Key findings and achievements

The following is a discussion of our project's significant results. Here, we outline the key achievements from both phases of the research.

We developed a simplified equity-based HIA tool appropriate to the Mongolian mining sector. This was translated into Mongolian, and printed copies were disseminated to stakeholders. Well beyond the official ‘wrap-up’ of the project, the project team has continued to provide its technical support to the MOH in integrating HIA into environmental impact assessment (EIA) to create a more comprehensive methodology. With the use of this tool, four training sessions were conducted among potential HIA practitioners, private sector representatives, HIA working group members and other interested parties. The HIA tool was adapted from the respective HIA documents developed by the International Finance Corporation (IFC 2009) and the International Council on Mining and Minerals (ICMM 2010) in consultation with members of the technical working group, with careful consideration of their applicability to the Mongolian context through various hands-on exercises. We conducted a rapid HIA of mining-affected communities in the southern Gobi region, which included working at the community level (town hall meetings and key informant interviews), with government and with local representatives of major mining companies. At the end of Phase 1, the MOH hosted a dissemination meeting that brought together key stakeholders from our technical working group, additional invitees whom we identified from various affected sectors and members of the community where we summarized results and introduced the Mongolian mining sector HIA tool. This meeting involved most of the major television and daily newspaper outlets in Mongolia, which was the first good step in increasing public awareness of HIA. Similar dissemination activities were continued throughout Phase 2, targeting decision-makers, mining company executives and identified HIA practitioners, both within and outside the health sector.

The achievements of our research objectives were supported by two other concurrent events. In 2009, multinational corporations Rio Tinto and Ivanhoe Mines Ltd initiated the first-ever HIA in Mongolia for their massive copper–gold mine development, Oyu Tolgoi (OT), in Mongolia's southern Gobi province. The OT-HIA was successfully conducted by the Khukh Tenger Khugjil Consortium, which consisted of international experts and local professionals, and a Community Health, Safety and Security Plan was subsequently developed. The World Health Organization (WHO) also brought HIA expertise to Mongolia for awareness raising and capacity-building purposes, and is now seeking to initiate and support a high-level strategic HIA for the resource sector.

Synergies between our project and these two concurrent events led to revisions of the EIA law enacted by the Mongolian Parliament in May 2012, mandating inclusion of social and health impacts in the cumulative impact assessment process. Revisions to the EIA law give significant attention to HIA and urge mining companies to undertake HIA before seeking approval for extraction. Detailed HIA methods were also proposed as part of the 2013 EIA regulations following the 2012 EIA law amendment. These combined efforts have to date resulted in the inclusion of HIA and a broad human health focus, including a social determinants of health approach, in new environmental legislation and the development of an initial mining sector strategy for the Ministry of Health.

Although HIA in Mongolia is still in its relative infancy, inclusion of equity-based HIAs into legislative and regulatory language was a great accomplishment and direct result of our work; the Minister of Health was closely involved with enacting the new legislation. The Ministry of Health, in particular, has become aware of the value of an HIA approach and created the first ever HIA focal point position in the country within the Department of Public Health Policy Coordination to further the work we began with this initiative. Introducing the health-in-all-policies (HiAP)1 concept and making an effort to use HIA as a pioneer example across different sectors were probably the most important success of this phase of the study. It is believed that while implementation of HiAP can be done through many mechanisms, such as policy development, program management and service delivery (Collins & Koplan 2009), the most widely promoted and cited mechanism to implementing HiAP is HIA (Rose et al. 2012).

Another big step toward improved intersectoral collaboration was the signing of memoranda of understanding between the Ministries of Health and Environment and Nature to increase the rate of HIA adoption and to bridge the gap in coordination so that HIA could be better integrated into the existing EIA system. This was enabled through our project's numerous advocacy activities (Byambaa et al. 2012).

Efforts to more fully integrate HIA into EIA and social impact assessment are currently underway, with support from the World Bank, the Asian Development Bank and WHO. The research team is maintaining its commitment by currently analyzing the diffusion of this particular innovation – the equity-focused HIA – in Mongolia.

Remaining challenges

Despite significant steps forward, Mongolia still faces barriers regarding the implementation of HIA. Several questions remain around who will conduct and manage HIA, how to build capacity of local HIA practitioners and how to make HIA a regular process. Although these questions may in part be answered in reference to international best practices, with knowledge gained through practical experience in the Mongolian context, and through further discussions with relevant decision-makers and professionals, acknowledging specific contextual barriers and opportunities is very important.

Overall, these questions remain unanswered and continued and concurrent efforts to further expand the adoption of HIA by Mongolian government leadership are needed to address these challenges. HIA institutionalization can lead to improved management of HIA and strengthen the local capacity of potential HIA practitioners. We encourage efforts to build on the current momentum of mandating HIA through Mongolia's EIA law and to enact this legislation. Also, further work to increase HIA awareness among high-level decision-makers and mining executives will hopefully facilitate the standardization of HIA practice.

Beyond these concerns about implementability and the potential institutional- and individual-level barriers that these concerns represent, a major barrier is the vested interests of mining companies. We have attempted to address this challenge by including strategic representatives of major international and Mongolian mining companies in the implementation of this project, as well as representatives from the major trade union, and employer groups. The mining companies have indicated great interest in and support of our activities, and we are optimistic that they will continue to act as key opinion leaders and change agents. Despite the fact that we were able to conduct many successful consultative meetings and training activities, we observed that sustaining built HIA capacity can be extremely difficult in a context like Mongolia where there is very high rate of turnover among government officials.

HIA is being added to the recent EIA law amendment as a hopeful mandatory step for mining companies prior to seeking formal operation approval, yet, HIA in Mongolia seems to be far removed from being a regularly used informed decision-making instrument in public health practice. Key barriers include: a lack of appreciation of HIA from mining companies, low national HIA capacity, little and/or poor routine baseline data, limited detailed HIA guidelines and, finally, no responsible agency mandated to order, approve, evaluate and oversee HIA.

Conclusion

Led by Canadian investors, the Mongolian mining sector is poised for rapid development. Mining revenues promise to significantly enhance Mongolian GDP, raising the population's expectations for an increased standard of living. Yet to date there has been relatively little attention given by government to develop methods to ensure that the benefits and risks of mining are distributed equitably among the population. Policy-level initiatives to broaden impact assessments are currently under consideration; evidence-based input is urgently needed.

In our effort to bring HIA into Mongolia, we engaged in a participatory process with the major stakeholders in the mining sector to develop and implement a health equity impact assessment methodology, to build national capacity as well as to undertake advocacy activities to make HIA a legally required process in the Mongolian mining sector. As a result of various policy-level initiatives to broaden impact assessments, HIA was formally included in the EIA amendment as a mandatory process mining companies must complete prior to obtaining licence to operate. An HIA tool was developed for the Mongolian mining sector. HIA approaches and methods have been included in new EIA and social impact assessment laws and regulations. The Ministry of Health has become aware of the value of an HIA approach. Finally, an HIA staff position has been created at the MOH to further the work we began with this initiative. HIA uptake efforts in the Mongolian mining sector are moving forward gradually, and consistent, ongoing involvement and support from all key stakeholders is needed in order to keep this momentum going and to reach the desired level of uptake.

A number of challenges to HIA implementation in Mongolia remain, many of which are applicable to other LMIC contexts due to similarities such as scarce resources, weak enforcement of regulatory systems, inadequate national capacity to carry out HIA and low political will to put a national agenda over that of multinational corporations. Continued and concurrent effort to further increase the adoption of HIA by government leadership is needed to address these challenges, particularly putting an increased emphasis on improving the enforcement of the existing law that requires HIA, and institutionalizing HIA so overall management and capacity can be built and maintained. Regardless of being integrated within EIA or implemented separately, the institutionalized and mandated HIA could be the most pertinent type of informed decision-making approach for managing and mitigating the negative health impacts of resource development sectors in LMICs. Our experience shows that such policy changes will likely only be achieved through consistent awareness raising and advocacy activities and consultations that aim to bring all appropriate parties into mutual consensus. Presenting HIA as a mutually important approach, which brings out both potential positive and negative impacts of a project, not as an extra barrier to the private sector, could increase the rate of HIA adoption.

Our successes in integrating HIA into mining projects in Mongolia can serve as a model for expanded HIA coverage and its inclusion in other development activities in the country, and also make it more likely that the now broader, compulsory requirements for impact assessment will be implemented. Beyond the specific Mongolian context and mining sector, our project has important implications for other LMIC settings where emerging resource extraction and related large-scale infrastructure development projects impact population health and where governments are likely to disregard corporate practices and regulations for the sake of attracting foreign investment.

Additional information

Funding

This project was funded through a Knowledge Translation Grant from the Canadian Institutes of Health Research. We would like to thank CIHR for their financial support.

Notes

^1. HiAP is a strategy which aims to include health considerations in policy-making across different sectors that influence health, such as transportation, agriculture, land use, housing, public safety and education (Kickbusch & Buckett 2010).