Baseline Information

for the National Action Plan on Artisanal and

Small - Scale Gold Mining: Ghana
 How is ASGM organized in Ghana?

Legal and regulatory status

ASGM is legal and recognised in Ghana through
the Minerals and Mining Act, 2006, Act 703
and the National Mining Policy, 2014. The
Policy, Act and subsidiary legislations provides
for the regulation, licensing, fiscal regime and
designation of mining areas. Only Ghanaians
of age18 years and above can be granted Small
scale mining license. ASGM is regulated by the
Ministry of Lands and Natural Resources through
the Minerals Commission. The Commission’s
mandate is to regulate and manage mineral resources, and to coordinate and implement policies
relating to mining. Other institutions such as the Environmental Protection Agency and Geological Survey
Department play key roles in issuing environmental permits and providing geological data for miners
respectively. The Precious Minerals Marketing Corporation (PMMC) is responsible for the purchase of gold
produced by small-scale miners and performs other functions such as to grade, assay, value and process
precious minerals and appoint licensed buyers for the purchase of precious minerals produced by small-
scale miners.

To enhance the regulation and management of the ASGM sector,

the Minerals Commission has established nine mining district
This document was produced in the framework of the project entitled: “Contributing to the
centres in designated mining areas. The district centres are in
preparation/implementation of the Minamata Convention on Mercury, with a focus on developing
Tarkwa, Asankragwa, Bibiani, Assin Foso, Akim Oda, Dunkwa on-
strategies for phasing out mercury-added products and on reducing mercury use in Artisanal and
Offin, Konongo, Wa and Bolgatanga. The centres are manned
Small Scale Gold Mining through development of National Action Plans.” July 2014-December
by District Officers who provide technical extension services
2017, of the European Environmental Bureau/Zero Mercury Working Group (EEB/ZMWG), funded by
including information sharing, provision of advice, and assistance
the European Commission (EC) through the Food and Agriculture Organization (FAO) of the United
and training in best practices for mining, processing, marketing,
Nations (UN).
environmental sustainability and health and safety. The biggest
Friends of the Nation (FoN) acknowledges financial support by the FAO/EC via the EEB/ZMWG for ASGM operations occur in Tarkwa, Dunkwa, Asankragwa, Bolgatanga
this document. The sole responsibility for the content of this document lies with FoN. The FAO/EC are and Akim-Oda.
not responsible for any use that may be made of information contained therein.
In every designated small-scale mining area, there are established
District Mining Committees to assist District offices to effectively monitor, promote and develop mining
operations. Currently, there are 38 District Mining Committees in the nine mining District centres.
Licensing
ASGM license is granted by the Minister responsible for Mines to a person, a group of persons, a
cooperative society or a company. The license is for a period not more than five years from the date of
issue in the first instance and may be renewed on expiry. The size of the area in respect of which a license
may be granted for small-scale mining shall not exceed 25 acres. After the acquisition of Small-scale
mining license, a prospective miner is required to receive an
Environmental Permit from the Environmental Protection Agency
which is renewed every two years. Miners are not required to
undertake Environmental Impact Assessment before permits are
issued. There about 1,000 small-scale mining licenses (Minerals
Commission). The Minerals Commission charges about GHS
850 (US$ 200) for a small-scale mining license whiles the EPA
charges is GHS 6,000 (US$1,435) for environmental permit fee.

How many small-scale gold miners work in Ghana? What are the usual gold mining practices employed?

There is no authoritative estimate of the actual number of people engaged in ASGM in Ghana. This is The extraction methods in Ghana can be categorized into the following three groups: shallow alluvial
expected to be addressed by the recent announcement by the Minerals Commission to register all small- mining; deep alluvial mining; and hard rock (lode) mining. Shallow alluvial mining techniques, which are
scale miners in Ghana. Studies however suggest that there are about 500,000 to 1,000,000 small-scale popularly called “dig and wash”, are used to mine shallow alluvial deposits usually found in valleys or low
gold miners nationwide (Hilson, 2010). It is noteworthy that in all the nine mining districts where the lying areas. Such deposits have depths not exceeding three metres. Deep alluvial mining techniques are
Minerals Commission operates district offices, there are some associations or co-operatives of ASGM used to mine deep alluvial deposits found along the banks of major rivers such as the Ankobra, Tano, and
operators. There also exists a Ghana National Association of Small Scale Miners (GNASSM) which serves as Offin and certain older river courses.
the advocacy voice for small-scale miners.
These methods involve excavating a pit and digging until the gold bearing gravel horizon, which is
typically located at depths of 7 to 12 metres, is reached. Hard rock mining techniques are adapted to mine
Contribution of ASGM to the Ghanaian Economy gold bearing reefs, which can be located close to the surface or deep-seated. In cases where the ore is
ASGM contributes significantly to the formal and hard, explosives are commonly used, despite being prohibited.
informal economy of Ghana. The sector’s contribution
On the other hand, the tools used for mining and mineral processing methods can be classified into
to gold production rose from 2.2% in 1989 to 35.4%
artisanal, semi-mechanized and mechanized. The artisanal mining practices mainly employs manual
in 2014 accounting for almost 1,500,000 ounces
methods by using simple equipment like shovels, pick-axes, pans, chisels and hammers. Semi-
(Minerals Commission). The sector is fast growing
mechanized and mechanized operations are characterized by the use of excavators, jaw crushers, hammer
and supports directly and indirectly the livelihoods of
mills, ball mills and modified corn mills. Mining methods are mainly shallow alluvial, deep alluvial and
many people mostly in rural areas. Miners also take
hard rock (lode).
up diverse roles from general labourers to skilled
machinists, supervisors and bookkeepers.
What are the usual gold processing methods? Lack of geological data and limited access to viable lands
One of the major challenges of the small-scale mining sector is the lack of geological data and
The commonly used processing method especially for free milling ores is gravity concentration using information with respect to minable deposits for legally registered small-scale miners. As a result most
sluicing. This involves sluicing of mined material on a sluice box to obtain gold concentrates. In recent miners carry out ad hoc operations, largely by guesswork and trial and error resulting in investment losses
times, mechanized processing methods are being employed using sizing trommels and Knelson for small-scale miners, low mineral recovery and low government revenue. Consequently, most of the
concentrators for processing to obtain gold concentrates. After concentration mercury is added to gold legally registered small scale miners leave their concessions and operate illegally on concessions of larger
concentrates and mixed to form an amalgam, which is then heated to separate the gold. mining companies.

Current regulations do not permit the use of cyanide or other leaching techniques for small scale miners,
but they are used in some mining areas in the Eastern and Northern regions of Ghana. Cyanide is Ecosystem Destruction and Environmental Degradation
widely used in neighbouring countries of Burkina Faso and Mali. The recovery rate of gold in ASGM is Some ASGM operations contribute to devastating impacts on the
approximately 30-40%. environment and ecosystems. These effects include; deforestation
and land degradation from clearing of the mining sites, over-
stripping of overburden and burning of bushes. Some ASGM
operators mine in forest areas sometimes clearing portions of the
forest or logging some of the trees contributing to rapid reduction
What are the main issues and challenges with regulating of the forest cover.

ASGM practices in Ghana? Water pollution is another major impact of ASGM; panning
processes on the river banks, beds and the surrounding areas
Despite the sustained and growing importance of ASM in Ghana as well as its many positive economic discharge huge amounts of loose silt and heavy metals into the
and development characteristics, the sector continues to be overshadowed by the negative environmental river system. Normally such rivers which are sources of drinking
and social impacts associated with operations which stem, in large part, from the fact that the majority of water for surrounding communities become polluted with high
small-scale miners operate illegally and informally, without the security of a license. levels of suspended particles, fuel, mercury, and other obnoxious
chemicals. Eventually these are washed into the water bodies that
serve communities and aquatic life; increasing the risk of siltation,
Long and cumbersome licensing procedure
flooding and drying up of water resources.
The licensing regime has been described as
burdensome and overly time consuming. In
Dangerous nature of the work
addition, the licensing procedure of the ASM
sector can take a year or more to complete. Due to the un-regularized nature of the ASGM most of the miners work under harmful and poor working
The licensing is bureaucratic and an important conditions, especially, they do not wear proper protective gears so the miners are therefore exposed to
reason why most operators in the ASM dangers, harmful chemicals, etc. One of the major concerns is the high number of avoidable injuries and
sector have not been moved onto the legal deaths recorded in the ASGM sector each year. Injuries and death of workers caused by collapsing pits
framework. According to some ASM operators, are very common. Other decent work deficits of the ASGM include child labor involving the use of under-
obtaining an environmental permit alone (one age children used for the mining activities. There are also cases of prostitution, drug abuse and other
of several steps to become legal ASM operator) dangerous practices at the mine sites.
usually takes several months and sometimes
over a year.
Mercury use and exposure How much mercury is used in ASGM in Ghana?
ASGM is one of the most significant sources of mercury release into the environment. In Ghana, most
While there are no data available in ComTrade for imports of mercury to Ghana, Ghana government data
artisanal gold miners combine mercury with gold concentrate to form an amalgam. The amalgam is later
indicate that in 2011, 2012 and 2013 approximately 19.26MT, 9.6MT and 2.5 MT of mercury respectively
heated with blow torches or over an open flame to evaporate the mercury, leaving small gold pieces
was legally imported into Ghana.
(ore). The gaseous mercury is inhaled by the miners and often by their immediate family, including their
children. The inhalation of elemental mercury vapors can cause neurological and behavioral disorders The major use of mercury in Ghana is in gold processing by both legal and illegal small-scale gold miners.
such as tremors, emotional instability, insomnia, memory loss, neuromuscular changes and headaches. Mercury is used mainly within the gold belt of the seven regions namely, Western, Brong –Ahafo, Central,
They can also harm the kidneys and thyroid glands. High exposures have also led to deaths. Eastern, Ashanti, Upper East and Upper West.

Mercury that is not inhaled during the burning process settles into the surrounding environment or The use of mercury for gold extraction from the ore (amalgamation) is widely practiced among many
circulates and deposits in areas far from the site, where it is absorbed and processed by a variety of living small-scale miners because it is easy to use, inexpensive, readily available, and highly effective at
organisms including fishes in the mercury-contaminated water bodies. This transforms elemental mercury capturing gold under field conditions.
into methylmercury.

Methylmercury is one of the most dangerous neurotoxins that contaminate the food chain through bio-
accumulation.

Where does mercury come from?

Mercury is not produced in Ghana, but gets into the country by legal
Is the use of mercury in ASGM legal in Ghana? and illegal means. When it is imported through legal means, it is
cleared through the Customs Division of the Ghana Revenue Authority
and quantities are documented. It is however known that the chemical
The use of mercury in ASGM in Ghana is
has also been smuggled into the country from neighbouring countries.
legal regulated by the Mercury Act, 1989,
In the past, mercury was imported to Ghana mainly from Germany,
PNDCL 217. Registered ASGM operators
United Kingdom, Spain, Canada and the Netherlands. However, since
and licensed traders can purchase and
2011 exports from the EU have been banned, so mercury has been
trade mercury legally through authorized
entering Ghana through other means.
dealers, such as the Precious Minerals
Marketing Corporation (PMMC) Ltd.
Mercury use, however, appears to be
greater than what is officially available,
suggesting a significant “black market”
for mercury. Mercury can be purchased at local stores or sourced from gold dealers. In some mining areas,
gold buyers provide mercury to miners as an incentive to buy their gold. Mercury is normally sold in
smaller quantities (about 5mL) and it is put into all sorts of containers including glass bottles, polythene
sachets, matchboxes etc. In many instances no special precautions are taken.
What are the exposures and health effects related Recommendations for Development of
to the use of mercury? the National Action Plan

Mercury is one of the most toxic metals. It bio-accumulates in the food chain and becomes increasingly
concentrated at higher levels. With global expansion of ASGM and pervasive mercury use in the sector, St a ke h o l d e r Pa r t i c i p a t i o n
ASGM accounts for an estimated 37% of global atmospheric mercury emissions, and released 727 tons Stakeholder participation in the design and
into the atmosphere in 2010. implementation is National Action Plan
(NAP) development is very critical. Having
Recent estimates indicate that the ASGM sector is the greatest mercury source worldwide and that
stakeholders involved from development
mercury use in this sector continues to grow. Mercury use in the ASGM poses great danger to the life
through to implementation will help to instill
of the miners, their families and communities living in the affected regions. Generally when mercury is
a sense of ownership of the process, making
used, the amalgam is burned in the open, without control, evaporating the mercury and leaving the gold
it easier to implement the changes proposed
behind. Mercury emissions from ASGM contribute to mercury contamination of local and global fisheries.
in the NAP. For example, the process should
The indiscriminate use of mercury in ASGM contributes to serious long-term environmental and health
involve multiple relevant ministries in the
problems. Mercury poisoning can lead to skin irritation, fever, headaches, nausea, irritability, fatigue,
government (e.g., environment, mining, health, labor) as well as their local government counterparts,
loss of speech and memory decline. Exposure to mercury can also lead to blindness, depression, kidney
small-scale miners or associations that represent their interests, NGOs, large-scale mining interests, health
disease, tremors, brain damage, serious birth defects and death.
specialists and providers, gold buyers, academia, and others. Mining communities and miners should also
There exists strong evidence of mercury contamination in biotic and abiotic samples in proximity to ASGM be involved so they could have personal connection to the issues and understand the intricacies of how
sites in Ghana. As outlined in the Natural Sciences review of the Integrated Assessment of Artisanal and ASGM functions in reality. Annex A provides a detailed list of the stakeholders that should be involved in
Small-scale Mining in Ghana, mercury levels have been reported in water (range: from below detection the NAP in Ghana.
limits to 50 μg/L), sediment (range: from below detection limits to 48.848 μg/g), soil (range: from below
detection limits to 185.938 μg/g), and left over refuse or tailings (range: 0.011 to 19.296 μg/g) collected Recommended actions to be included in the National Action Plan
from sites across Ghana, many of which are in close proximity to mining activities.
Through stakeholder consultations facilitated by Friends of the Nation with miners in Tarkwa, Assin Fosu,
Mpohor and Obuasi, the following recommendations were prioritised.
 STEPS AND STRATEGIES RECOMMENDED ACTIONS

1 Actions To Eliminate Worst Practices Of Mercury Exposure Demarcate areas for the processing of ore (mercury amalgamation) at
mining sites
Public education on the harmful effects of the use of mercury
Strict actions against unguarded use of mercury by ASGM Annex A: List of stakeholders to be involved in the
Support miners t o acquire PPEs for their operations
development and implementation of the NAP Government

Government should review mining laws to prohibit open burning of

Private Sector Civil Society Ministries

mercury amalgam

2 Steps to facilitate formalisation or regulation of the ASGM sector Undertake extensive geological investigation to identify viable lands and
allocate to ASGM miners

GOVERNMENT
Decentralise and streamline licensing processes and make the affordable
and accessible
Upscale Certification
Ministeries
Increase public education on the environmental and metallurgical best
practices of ASGM • Ministry of Environment Science and Technology
Improve access to geological information and viable lands and better • Ministry of Lands and Natural Resources
financing
• Ministry of Trade and Industry


Creation of more offices of the Minerals Commission and the EPA at the
district level to deal with small-scale mining issues
• Ministry of Justice and Attorney General’s Department
• Ministry of Local Government and Rural Development
Increase enforcement and monitoring to reduce illegal mining
• Ministry of Health
Create better financial incentives for investment in small-scale mining • Ministry of Employment and Labour Relation
(provision of equipment as hire purchase, access to viable lands)
• Ministry of Gender, Children and Social Protection
• Ministry of Finance
3 Strategies for promoting the reduction of emissions and relaese of, Promote the use mercury-free and mercury reduction gold recovery
exposure to mercury in ASGM, including mercury free-methods techniques such as Direct Smelting method, retorts
• Ministry of Chieftancy and Religious Affairs Departments and Agencies
Improve the thermex Retort to withstand high temperature Departments and Agencies
Establish Centralised Mercury Free Gold Recovery Plants
• Minerals Commission
Support the formalization and the regularization of ASGM
• Environmental Protection Agency
Designate / demarcate special sites for work on amalgam to control the • Geological Survey Department
use of mercury
• Ghana Health Service
Effective monitoring and control of mercury use
• National Development Planning Commission Water Resources Commission
Research into alternative methods and publicize the most effective
ways/methods
• Precious Mineral and Marketing Corporation
• Ghana Atomic Energy Commission
• Centre for Scientific and Industrial Research
4 Strategies for managing trade and diversion of mercury for use in ASGM Be strict on the importation of the mercury
Mercury trade and supply should be monitored by the security agencies
PRIVATE SECTOR
Miners should be educated on the use of mercury and its bad effects
• Ghana Chamber of Mines
5 Strategies for providing information to artisanal and small-scale gold Support NGOs, CSOs to increase public awareness on the Impact on
• Ghana National Association of Small-scale Miners
miners and affected communities Mercury, Minamata Convention and Mercury-free technology • Ghana Institute of Freight Forwarders
Use local media outlets to increase public awareness and provide • Gold buyers
information to miners • Gold jewelers
Use local drama and reader-friendly IEC material to reach out to miners

CIVIL SOCIETY
6 A public health strategy on the exposure of artisanal and Continuous training for health care workers of the effects of mercury to
small-scale gold miners and their communities to mercury enable recognize, diagnose and treat mercury poisoning. • NGOs (National and International)
Health centres and systems should have treatment protocols in place for
• Academia
mercury-related health effects, including exposure to mercury in ASGM. • Research Institutions
Effective intersectoral engagement between health and other relevant • Traditional Authorities
ministries and agencies on ASGM • Miners
Creation of special mercury labs on mining sites to control the emission of • National House of Chiefs
mercury pollution
Periodic medical screening in mining communities
References

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 Contact

Solomon Kusi Ampofo

Natural Resources Governance Coordinator
Friends of the Nation
Email: s.ampofo@fonghana.org; info@fonghana.org
Tel: +233-24-4055951