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Why Excel is not compliant with AMIRA P754 Code of Practice for Metal Accounting

John Vagenas, Managing Director, Metallurgical Systems and Gary Larking, Programme Manager, Metallurgical Systems
· 1400 words, 6 min read

In 2021 AusIMM partnered with Metallurgical Systems to help share expertise and improve outcomes for minerals processing plants.

In this article, John Vagenas FAusIMM and Gary Larking MAusIMM outline some of the pitfalls to be aware of when it comes to using spreadsheets to track and analyse a plant's activity. 

Mineral processing is not the same as it was thirty years ago.

Many internal and external factors have arisen which affect the way a mineral processing operation conducts its business. A case in point is the increasing pressure on, and risk to operations to comply with, emerging environmental, social and governance (ESG) compliance requirements.

Two to three decades ago, well before ESG had assumed the status it has today, Excel spreadsheets offered a reasonably sufficient way to track and analyse a plant’s activity. In fact, when the global not-for-profit organisation, Amira, first released its P754 Code of Practice for Metal Accounting (AMIRA P754) in October 2005, Excel was largely the only option.  

Today, modern metal accounting and plant information systems (such as Metallurgical Intelligence®) have been created using the latest database and data analytics technologies - in part to address the proven ESG (governance) limitations of Excel, and to exceed the stringent principles of AMIRA P754.

However, despite the rapid value creation and risk minimisation generated by structured successful global implementations of these innovative systems, Excel remains in use.

This article explores the nature of AMIRA P754 and illustrates how Excel has been proven to be non-compliant with this code in the years since its release and adoption in mineral processing plants.

What is the AMIRA P754 Code of Practice for Metal Accounting? 

Amira is an independent organisation that represents members from the resources industry. According to the Amira website, its aim is to enhance, sustain and deliver transformational research and development, innovation, and implementation to the benefit of society.  

In October 2005, Amira released the output of an extensive project to standardise metal accounting practices globally. Its goal was to raise the standard of corporate governance in the sector, which historically had ‘not generally been performed at a level required by currently acceptable corporate governance practices’ (Amira, 2007). The result was the AMIRA P754 Code of Practice for Metal Accounting, which includes 10 clear governance guidelines for best practices in metal accounting.  

Today, AMIRA P754 is considered as a widely accepted global standard for metal accounting in mineral processing facilities (Morrison and Gaylard, 2011). Here are ten reasons why plants who are still using Excel cannot comply:

1. Governance compliance requirements have evolved 

As earlier referenced, in 2005 when the AMIRA P754 guidelines were first released, Excel was a relatively suitable solution for the requirements of metal accounting at that time. Over the years, the scope of mineral processing plant reporting, including evolving ESG disclosure and compliance requirements, has meant that Excel is no longer capable of meeting the more complex requirements.

2. Lack of consistency and transparency to source data

One of the biggest risks in any organisation is that compliance reporting or data will be manually manipulated, either intentionally, or in error. It’s why AMIRA P754 principle #2 stipulates that a compliant metal accounting system 'must be consistent and transparent, and the source of all input data to the system must be clear and understood by all users of the system' (Amira, 2007).

In a typical mineral processing plant that uses Excel for metal accounting, there is simply no way of knowing that the data you are submitting as compliant to governance standards reflects plant source data with any degree of accuracy. In fact, when using Excel, data and formulas can be modified without a trace.

3. Limited analytical scope 

The volume of data within a typical minerals processing plant is enormous, complex, multi-faceted and ever-growing. Emerging requirements to analyse often billions of rows of production data from increasingly complex plant instrumentation, extends well beyond the abilities of an Excel spreadsheet.   

Although Excel can certainly be configured to include calculations, it is not capable of storing enough source data to complete detailed verification. It is also incapable of generating sufficient cross-check data without any user intervention and, in fact, relies on user discretion, which is a more significant issue.  

4. Inaccuracy and lack of error control

Another major problem with Excel as a metal accounting platform is that it lacks in-built error control. There is no debugging capability, and no way of instantly knowing if and where an error has occurred. This is non-compliant with AMIRA P754 principle 1, requiring accuracy (Amira, 2007). If the wrong figure is accidentally entered into a particular cell, or there is an unknown issue with a formula calculation, it can render the analysis or reporting completely incorrect, which can have very far-reaching consequences for the operation.

5. Limited re-use and scalability

In metallurgical facilities, reporting is ongoing and frequent. Regular and ad-hoc reports need to be quickly and constantly provided on all aspects of a plant’s operations. However, when using Excel, there’s very limited re-use of data, or ability to scale the spreadsheets based on growth or changes in the plant’s facilities. Excel doesn’t store formulas in a central location, which limits its scalability. Excessive cutting and pasting also opens up considerable room for error and distracts skilled metallurgists from the main focus of their job.

6. Lack of automation

When a plant is using Excel spreadsheets for its metal accounting platform, it is typically reliant upon a small group of people – or even one operator – who understands the formulas within the spreadsheets and how they can be used and interpreted. The more complex the spreadsheets, the greater likelihood that they will be maintained by a single, dedicated specialist. If this person is away, or leaves the business, the overall metal accounting function can be seriously impacted. This directly contravenes AMIRA P754 principle #3 . 

7. No machine learning or artificial intelligence generated insight 

A major disadvantage of relying on Excel for metal accounting is that, unlike advanced digital twin solutions which utilise machine learning and artificial intelligence, they cannot provide a plant’s management team with any automated insights. Nor can they drive automated improvements. The level of insight that an Excel spreadsheet can offer is very one-dimensional and relies upon the interpretive power of those managing the spreadsheets or reviewing reports. While an Excel spreadsheet may be a sufficient way of managing and interpreting a small pool of data, its capacity to analyse and provide insights for large datasets, and ongoing analysis, is very limited.

8. Auditability 

AMIRA P754 principles #3 and #4 both require a clear audit trail to be available. They also require that the metal accounting system must be subject to internal and external audits. We have demonstrated the inability of Excel to produce data traceable to source systems. This has the associated effect of being equally unavailable to be easily audited, resulting in non-compliance to these AMIRA P754 principles. 

9. Lack of 'what if' planning

The AMIRA P754 principles exist to drive continual improvement in the metal accounting discipline. While Excel does support 'what if' planning to an extent, it doesn’t allow the author to compare multiple scenarios at the one time. Each individual scenario will often require its own spreadsheet. This limits the extent to which plants can use data to achieve continual and ongoing improvement.

10. Excel as a relational database  

To obtain a robust and detailed understanding of a mineral processing plant, and comply with AMIRA P754 principle #2, plant analysts need to collect and analyse data from right across the plant, from a number of data sources, and of several data types and formats.  

While Excel can integrate with some external databases and tools, its ability to capture, merge and relate huge amounts of data from various unrelated sources is very limited.  

The formulas within Excel are also very non-portable and proprietary, which means it’s very difficult, if not impossible, to use Excel as a data source in itself. 

How Metallurgical Intelligence® offers a proven shortcut to AMIRA P754 compliance 

The Metallurgical Intelligence® suite of software has been specifically designed to provide mineral processing plant management a solution to exceed AMIRA P754 guidelines. The unique combination of regulatory compliance and performance improvement opportunities offered by Metallurgical Intelligence® have resulted in rapid and increasing adoption by 23 mineral processing plants globally.

Want to find out more? Take a look at this example of non-compliance and how Metallurgical Systems helped


Amira, 2007. Amira P754: Metal Accounting Code of Practice and Guidelines

Morrison R D and Gaylard P G, 2011. Applying the AMIRA P754 code of practice for metal accounting [online]. Available from: 

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