CEO Blog - June 14, 2012
Thursday, June 14 2012 15:18

Question: Does Comstock Mining also need to have Standard Operating Procedures (SOPs) and other controls in place to manage processing?  NOTE: This inquiry came with the following background question through our contact page: “When we (in the pharmaceutical industry) run processes we need to have stringent guidelines, safety measures, and documentation to prove the safety and efficacy of our drugs. We must show the FDA that we have the proper quality controls in place to catch a problem which in turn helps put the public into a more comfortable state knowing everything is in place.” The question continued by emphasizing the value of using company metrics (e.g. accident-free work hours) to motivate the workforce to keep “precision in the forefront of their mind.”

Answer:  Our answer is an emphatic YES! Since early 2010, our transformational efforts have moved us toward a systemic organizational design built for reliability (and hence predictability), stability and speed.  This is how we define Quality and it is a relentless effort of continuous improvement.

Although not regulated by the FDA, mining may be one of the most regulated operations on this planet, answering to County, State, and Federal regulators.  Frankly, we have not only designed a system to handle these complexities but something capable of much, much more than that.  We consider compliance with minimum standards as “necessary but not sufficient” for our organizational objectives and the goals we have established.  Instead, we expect to perform at levels well in excess of legal requirements. Philosophically, we aspire to achieve sustainable wealth by maximizing speed and reliability in the most ethical and socially responsible manner.  We endeavor to generate this wealth through a self-sustaining network of geological, historical, environmental and, of course always, economic activities.

We operate as a sustainable system


Everything we do at Comstock Mining is informed and inspired by a sustainable and systemic approach to managing. Our operating methodology, The DecalogueTM, leads us to see ourselves as part of a system (or network) of interdependent people and processes. This system includes not only our suppliers and customers, but also our community and our environment.  Therefore, whatever we do must benefit not only the company shareholders, but also all of our stakeholders, including our covenant with the territory. Our goal is not just to be safe, but also to be an active contributor to the wealth and wellbeing of the entire Comstock community. In order to do this, we must understand the interdependencies in our system and the impact of our daily actions.

Our Quality system

How do we practically do that? It starts with our ‘Playbook.’ The Playbook is a ‘map’ (think flowcharts) that describes our processes, how they are linked, who does what when, and the expected measureable outcomes of all these activities. The Playbook allows us to permeate the organization with Quality so that we can operate reliably, predictably and responsibly. It is the foundational document for the daily decisions and actions that occur in our system. In addition to this ‘map,’ we also need a mechanism to measure whether our decisions and actions are reliably taking us towards the company goal. We do this by understanding, with statistical tools, the variation that affects our processes. Managing Quality at Comstock Mining means using Statistical Process Control, as defined by W. Edwards Deming, to measure, monitor and improve the processes we have mapped. Our Quality system, based on the DecalogueTM, provides us the ongoing mechanism to design, validate and test all of our improvement activities.

Results of our Quality system

We expect our Quality system to generate an ethical, transparent, environmentally enhancing, safe and sustainable chain of efforts.  We believe that the only meaningful way for any organization to prosper is to become an active channel for the development and distribution of products and services that help people to live better. This is the only truly sustainable role for any organization in today’s interconnected world. As we transition, as stated in the question, “from explorer, to engineer to producer” we expect responsible mining to be a powerful economic engine for improving the quality of life in the historic Comstock district.

We are simultaneously achieving a self-sustaining, predictable, quality system capable of delivering geological, historical and environmental achievements while positioning our Company for maximum sustainable wealth from the richness of our Comstock properties.  This isn’t our fathers’ mining venture.  We’re modern, we’re Nevadan and we’re proud of it.

 Kindest regards,

 Corrado De Gasperis

President and CEO