What should an auditable record for the ANM include?

An auditable record for the ANM (Colombia’s National Mining Agency) is one that lets a third party reconstruct what happened in the operation, when it happened and what evidence supports it, without relying on the team’s testimony. In practice it requires five attributes: identified origin, reliable date, declared method, provable integrity and continuity without gaps. A file without those elements may be useful internally, but it does not hold up under an inspection.

What makes a record “auditable”?

The difference between a file and an auditable record is not in the content, but in the guarantees that come with it:

• Origin: it is known who or which equipment generated the data, and at which physical point.
• Timing: the date of the record is verifiable and cannot be edited at will.
• Method: it is declared how the data was obtained and with what expected accuracy.
• Integrity: it can be shown that the file has not changed since it was created, or every change is recorded.
• Continuity: there are no unexplained gaps in the time series.

This is not an arbitrary list: the Código de Minas (Ley 685 de 2001, Colombia’s Mining Code) already requires up-to-date records and inventories of production at the mine mouth and at stockpile sites, so that the volumes of raw ore and of ore delivered to the processing plant can be established at any time. The law requires the record; these five attributes determine whether that record actually holds up under an inspection or only exists on paper.

What specific elements should it contain?

For a mining operation, an auditable operational record usually includes:

• Periodic site surveys with date, method, reference system and declared coverage.
• Calculation of volumes moved between consecutive periods, with the base surface used.
• Georeferenced visual evidence of the state of faces, waste dumps, roads and deposits.
• Event log: incidents, suspensions, design changes, with date and person responsible.
• Reconciliation of declared production vs. measured volume, with an explanation of the differences.
• Stability monitoring records for deposits and waste dumps, where applicable.
• Chain-of-custody traceability of the material, linked to the operator’s traceability scheme.
• Version control of plans and models, stating which version was in force in each period.

On the stability monitoring of deposits: Colombia does not yet have a binding technical regulation dedicated to tailings dams (unlike countries such as Chile). What exists is a proposal of good-practice guidelines from the Ministerio de Minas y Energía (Ministry of Mines and Energy) (2020), which recommends physical and chemical stability monitoring throughout the life cycle of the deposit. In practice, the specific requirement usually comes from the specific conditions of each project’s Licencia Ambiental (environmental license), not from a single generic rule, so it is worth confirming, case by case, exactly what the current license requires.

How long must records be kept?

Colombian mining regulations do not define a fixed number of years for the production record. The obligation to keep those records is indefinite in practical terms: it runs for as long as the concession contract lasts (up to 30 years) and extends to the subsequent closure obligations. The practical recommendation is still to keep the entire historical series: its value as evidence grows over time, because it shows behavior and not only a point-in-time state, and no rule allows discarding it while the title remains in force.

How do most operations prepare today?

By reconstructing. When a visit is announced, the team gathers scattered plans, photos without metadata and spreadsheets with assumptions nobody remembers. The result is a package that answers the form but does not withstand second-level questions.

The real cost of that reconstruction is rarely measured: weeks of technical staff diverted from the operation, plus exposure to findings that cannot be refuted for lack of contemporaneous evidence.

What changes with systematic capture?

When the site is measured at a fixed cadence and the products are stored with complete metadata, preparation stops being a project and becomes a query. The question “what did the north slope look like in March?” is answered in minutes, with dated evidence, instead of with an estimate.

That is the point: auditability is not produced at the end; it builds up during the operation.

Frequently asked questions

Is there a Colombian rule that sets how long mining records must be kept?

There is no specific period in years. The obligation to keep production records up to date comes from the Código de Minas and runs, in practice, for as long as the mining title and its closure obligations last.

Is it mandatory to monitor the stability of a tailings deposit in Colombia?

There is not yet a single binding technical regulation for that. The specific requirement depends on the specific conditions of each project’s Licencia Ambiental.

If you want to review how defensible your operation’s current record is, write to us at hello@bluberri.io.