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By William A. Riggs

Salt, a non-metallic mineral whose use dates back to earliest history of mankind, and whose uses cover the widest range for any mineral raw material, is generally of widespread occurrence in commercially recoverable quantities in the oceans, in certain sedimentary rocks, in certain lakes, and in certain underground waters. Passing over geological detail, it may be said that, generally, all of the salt in the world has, at least once in geological history, been in solution in the oceans. The total salt content of today's oceans, said to equal 4.5 million cubic miles of rock salt, dwarfs the tremendous volume of salt in the sedimentary rocks. In 1958, United States production of salt was about 22 million net tons and world production about 82 million. About 3 percent of United States production is table salt, with chemical, municipal, industrial and agricultural uses taking the remainder. Mississippi River. Figure 1 has been expanded sufficiently to show also those salt occurrences and producing points which might economically ship salt into these states. Although widespread in occurrence, salt deposits and possible production areas generally show very sharp local boundaries. Salt-for non-table use is susceptible to ?place value?, a common problem in low valued raw materials, where transportation costs often exceed the value of the material f.o.b. the production point. Generally only large capacity mechanized salt producing operations can compete in United States markets, as contrasted to the many small local salt evaporators in less industrialized Mexico.

Jan 1, 1962

"A long-term mine production schedule optimization based on stochastic integer programming is presented that manages the risk due to geological variability and uncertainty while jointly considering mine profitability, truck fleet requirements and waste management. The evolution of the pit is controlled so that space within the mined-out pit is continuously provided to allow for tailings and waste rock to be replaced, thus minimizing the project’s environmental footprint. The method is applied at a taconite iron ore deposit and has a project net present value that is 16.9 percent higher than that of a conventional schedule and has a higher chance of meeting production forecasts. The stochastic schedule reduces equipment requirements by delaying waste mining and by mining selectively in order to meet plant ore feed requirements without stockpiling material, resulting in 23.7 and 26.2 percent lower mining capital and operating costs, respectively. IntroductionThe LabMag iron ore deposit is part of the Millennium Iron Range, a 210-km (130-mile) belt of taconite in northern Quebec and Labrador, Canada. LabMag has significant economic potential. It contains more than 3.3 Gt (3.6 billion st) of proven reserves at an average total iron content of 29.8 percent and is very low in impurities. However, on a project basis of 23 Mt/a (25 million stpy) of product, the required capital expenditure is estimated at more than $5 billion (SNC-Lavalin, 2014), which necessitates careful evaluation of all sources of risk. Resource estimation is one of the main sources of risk in a mining project as knowledge of the orebody is primarily based on drilling, which is often sparse because it is expensive. If the expected ore tonnages and qualities are not obtained when mining, the project cash flows are directly affected. The expected quantities and qualities of ore and waste are defined by the mine production schedule, which specifies the sequence of extraction and is dependent on the resource estimation. The goal of mine production scheduling is thus to maximize the expected profit, while also meeting all production targets and constraints, by creating an extraction schedule that is robust in the face of geological risk and has the highest chance possible of actually being realized."

Jan 10, 2017

By T. R. Ellis

"In August 2013, the Appraisal Practices Board of the U.S. Appraisal Foundation issued its “APB Valuation Advisory #4 - Identifying Comparable Properties,” which contains analysis and examples that may suggest a broader meaning of the term “comparable properties” than is current convention in real property value appraisal in the United States and internationally. The advisory is directed at the appraisal of real property of all kinds, including interests in mineral properties, as indicated by the inclusion of two mineral property appraisal papers in the appendix that lists suggestions for further reading.This paper firstly reviews as background the historical meaning of a comparable property, with its perceived constraints, against real-world examples of transacted mineral properties that are adjusted to subject properties to provide market value indications. The advisory’s findings are then examined and evaluated as to whether they may influence and benefit the work of mineral property appraisers, particularly in situations where their sales comparison analyses may be challenged. The conclusion is that the combination of constraints that the advisory’s findings specify for use of the term “comparable” will for mineral properties be met infrequently or rarely. As a result, mineral property appraisers are advised to avoid using the terms comparable or “comp” when referring to transactions of mineral properties that they analyze to derive data for appraising the value of their subject mineral properties. IntroductionA mineral property appraiser rarely finds a sale of a mineral property that meets the literal meaning of the term “comparable sale,” by being directly comparable to the subject property of the appraisal in all factors of significance in the determination of the value of the property interest being appraised. Real estate appraisers have long used a more liberal interpretation of the meaning of comparable sale and its commonly used abbreviation, “comp.” Real estate appraisers compare sales to their subject property on the basis of price per hectare or acre of land and price per square meter or square foot of building floor area. Adjustments totaling to within the range of +30 to -30 percent from the sale property to the subject, before factoring in the property area, have generally been viewed as appropriate for the sale to be considered a comparable sale."

May 1, 2016

By K. Terhaar

The objective was to determine operating protocols for a lead and silver column flotation cleaner, being considered for installation at Sunshine Mining & Refining Co.'s Kellogg mill in Northern Idaho. In this column, tetrahedrite and galena were floated, and pyrite and other gangue minerals, including siderite and silica, were depressed. The procedure was to develop a dynamic simulation using a linear transfer function approach. The transfer function related cause and effect variables such as the influence of collector and depressant dosages on recovery and grades. Bench-scale flotation tests followed by pilot column testing provided the data used to develop a linear transfer function. The transfer function was derived using a spreadsheet. This model was applied to simulate how the flotation column could be made to respond to disturbances in feed grade. The results were that xanthate, zinc sulfate, and sodium cyanide were found to be suitable controls for grade and recovery. Simulations showed the best sequence of manipulations of these reagents, and these sequences were useful for future operator training. The conclusion was that linear transfer functions were able to simulate lead and silver recovery, develop scenarios for operator training, and provide a foundation for future on-line control.

Jan 1, 1999

By Lena Paar

"Underground construction poses certain challenges for all parties involved because the actual ground conditions are often unpredictable. Highly complex projects like tunnel construction are affected by various uncertainties. To address this complexity, the construction contract has to be flexible enough to be adapted to the actual conditions (e.g. divergent ground conditions, work delays). However, the adaptation of a tunnel construction contract does not guarantee the absence of a margin of interpretation. The perfect construction contract is an illusion because ex ante statements of the actual ground conditions are not feasible. This paper will discuss contractual parameters that must be considered in order to enable an effective adaptation of the contract during excavation. It is therefore necessary to discuss the following topics: decision-making competence, variable remuneration, fair-risk allocation, value engineering and partnering between client and contractor. INTRODUCTION Thinking of tunnel construction processes, engineers’ first (or at least second) association is about ground conditions. When constructing under the surface, the project is directly related to the ground conditions; however, ground conditions are known fairly well in advance. The estimated conditions can be the same or can also differ from the existing ones. A clear view of the conditions is possible only by driving through the section. What Hoek calls “Geological unpredictability which is guaranteed to provide some surprises in even the simplest tunnelling job” is, in addition to contractual issues, one of two critical aspects of modern tunneling (Hoek 1982). Almost no research tries to figure out, what flexibility in this context means and how to approach it in the contracts. Papers dealing with the New Austrian Tunnel Method (NATM) pose some principles to meet the requests for flexibility (cf. Austrian Society for Geomechanics 2011). However, it remains unclear how to create contracts in order to make them “flexible” enough to react to divergent ground conditions."

Jan 1, 2016

By H. Yen, D. E. Walsh, H. K. Lin

"Comminution circuits are widely used in nonferrous and precious metals milling. Steel crushers, grinding mills and grinding media are typically used in comminution circuits. Comminution circuit wear products, in the form of metallic iron (steel) fines, are unavoidably produced and report to undersize products in the classification circuit, i.e., flotation or leach feed, while tramp grinding steel (TGS) reports to classification oversize products and returns to the grinding mill, building up in the circulating load. In laboratory studies, TGS reduced grinding efficiency significantly, the impact being dependent upon the size of the TGS present in the mill. Because iron fines adsorb flotation reagents effectively, iron fines increase reagent consumption and reduce flotation recovery. Iron fines are also capable of reducing gold recovery in cyanidation circuits via a cementation reaction. When using filtered gold solution from the cyanidation circuit of an Alaskan gold mine, the gold concentration in solution was reduced by 0.2 to 2.6% over various reaction periods when iron fines were present in the solution.IntroductionComminution circuits are widely used in copper, lead, zinc, nickel, cobalt, molybdenum and precious metal mills. Flotation and leaching processes are usually preceded by comminution (crushing and grinding) circuits in order to liberate valuable minerals for effective separation, concentration or dissolution by the subsequent flotation or leaching processes.Steel crushers, grinding mills and grinding media are typically used in comminution circuits. Comminution circuit wear products, in the form of metallic iron (steel) powder, are unavoidably produced and report to undersize products in the classification circuit (flotation or leach feed), while tramp grinding steel (TGS) reports to oversize productions during classification and returns to the grinding mill, building up in the circulating load. Variables affecting the amount of metallic iron powder and TGS produced in a comminution circuit include ore hardness, grinding mill operating conditions, comminution circuit design and the metallurgy of the steel used for manufacturing crusher liners, mill liners and grinding media. As one example, a comminution circuit product of 80% passing 200 mesh at the Pogo Mine, AK is estimated to contain approximately 2 kg/t of metallic iron. A finer grind will generally produce a comminution circuit product with higher metallic iron fines content."

Jan 1, 2015

By Michael Gauna

A high seam geologic condition exists at Jim Walter Resources No.4 mine which requires immediate rib support after a continuous miner cuts a place, High seam mining heights are typically 2.4 to 2.6 m (8 to 9 it) and a thick rock layer is present in the upper portion of the coal rib side. The 610 m (2000 ft) mining depth at No. 4 mine induces horizontal rib line movement after excavating an entry. Horizontal rib movement greater than 30.5 cm (12 in) have been noted. When lateral movement occurs in the high seam areas, the thick rock layer, and the coal above the rock layer, become fractured and tend to roll into the entry. If not adequately supported, large rib rolls develop in the place being bolted as well as in previously mined areas which endanger men and equipment. To control this situation rib support must be installed in the roof bolting operation as the bolting crew works towards the face. A rib control system has been developed for this high seam mining condition utilizing a mechanical anchor bolt placed at an angle in the rib and installed with a modified Fletcher DDFI- 15 bolting machine. Over 120 km (75 mi) of entry have been supported with angle rib bolts. These angle bolts constitute 43 to 60% of the total roof and rib bolt footage in the high seam port- ions of No.4 mine. The angle rib bolting system has proven safer, more effective, and more efficient than the earlier support method employing bolts installed horizontally into the rib. No rib roll accidents have occurred since the angle drill bolting machines were placed in service in 1981. By securing the broken rib material with an angle bolt anchored above the coal pillar, a more effective means of rib control is achieved. Angle rib bolting does not interfere with continuous miner productivity. In addition, bolting crews are now reduced from three to two people and the total drilling supply costs are approximately 60% the previous cost, when compared to the previous support method using horizontal rib bolts.

Jan 1, 1983

By R. Y. Wan

Acid ferric sulfate solution has been used for heap and dump leaching of low-grade chalcopyrite ores and is being considered as a possible lixiviant for the hydrometallurgical processing of copper sulfide concentrates. For many years, researchers have attempted to explain the leaching behavior of chalcopyrite, since the reaction rate kinetics are extremely slow and seem to be significantly influenced by the nature of the reaction product. A summary of conclusions drawn from reported literature on chalcopyrite leaching is found in the paper by Munoz, Miller, and Wadsworth(1) and more recently by Dutrizac.(2) Lowe(3) and Jones and Peters (4) attributed rate control to a surface reaction. Linge,(5) Dutrizac,(6) Bauer,(7) and researchers at the University of Utah(1,8) reported that the reaction rate is limited by transport in the chalcopyrite lattice or through the elemental sulfur reaction product layer. Munoz et al.(1) presented a model, derived from the Wagner theory of oxidation, which is based on the formation of a protective sulfur layer with rate control by electron transport through the insulating sulfur layer. By utilizing Wagner's parabolic oxidation relationships, (9) the following equation was obtained: [ ] where a is the fraction of CuFeS2 reacted at time t, pB is the molar density of CuFeS2, do is the initial diameter of the particle, e is the electronic charge, s is the total electrical conductivity of the sulfur layer, and ?G is the Gibbs free energy for the reaction:

Jan 1, 1984

By Brendan Howard

Rio Tinto has a large globally distributed technical workforce and needs to ensure these employees have the requisite skills to not only manage technical risk and enable safe efficient production, but also ensure they are keeping pace with a fast-changing technological landscape. Traditional approaches to learning struggle for scale and an inability to respond to the extreme diversity of capability development needs. In response, Rio Tinto has successfully introduced innovative approaches to learning and employee engagement via leveraging the power of globally distributed networks for peer-to-peer knowledge transfer and providing mechanisms to recognise, reward and retain the individual technical contributors.

Feb 1, 2024

By Martin Langenderfer, Catherine Johnson, Alexander Douglas

Mine haul roads degrade rapidly due to extreme loads on suboptimal construction materials. Unmanned aerial vehicles (UAV) are suited to quantify large-area road-network conditions, such as surface roughness, defects and grade to optimize remediation of poor conditions and reduce overall costs. Mine haul roads present unique challenges, such as material type and edge characteristics, to automatic road detection that often fails, requiring manual road input. This research work proposes a new method using the road center determined by the principal curve of a haul truck’s path. Analysis grids were created from this center line. A dense point cloud from UAV photogrammetry was generated and multiple linear regression analysis was conducted on each individual grid. The root-mean-square error in each grid indicates the surface roughness, and the change of slope between grids indicates the road grade inconsistencies. This method was applied to 26 road sections, and the results were validated by images taken from the truck operator’s vantage point. Critical defects were identified including excessive pothole formation, corrugation, depressions retaining water, and narrowing of travel lane. The results demonstrate this is a valid method of road identification and quantification of road defects at a mine site.

Apr 1, 2024

By Yasutaka Izumi, Tuneyoshi Funasaki, Keizou Miki, Makoto Kanai

INTRODUCTION The Tokyo metropolitan region, inclusive of the three neighboring prefectures (Kanagawa, Chiba and Saitama), has the highest concentration of population and industry in Japan; with an area of 13,500 km2 or only 3.6 percent of the national land, but a population of 31.8 million or 26 percent of the national total, and a Gross Regional Product (GRP) of146 trillion yen (US$1.33 trillion) or 36 percent of the overall GDP of Japan as of 1990. Tokyo Bay, embraced by the metropolitan region as shown in Figure 1 (a), (b), is open to the Pacific Ocean as a marine gateway and is ringed by large cities and coastal industrial zones together with port facilities, all constituting a concentration of prime importance for socio-economic activities. The Trans-Tokyo Bay Highway (TTB highway), which crosses Tokyo Bay and provides a direct transportation link between the west and east sides of the bay, has long been a sort of “dream-come-true” project in Japan. As shown in Figure 2, linked to the Tokyo Bay Shore Highway, Metropolitan Inter-city Expressway, Tokyo Outer Ring Road, Tateyama Express-way, and others, it will play an important role as an integral part of the regional highway network to help promote spatial redistribution and multi polarization of urban functions, thus strengthening cooperation between cities and restructuring the metropolitan region. The TTB Highway is a project of 15.1 km in length designed as a toll highway to cross the bay by tunnel and bridge, and will require ten years to complete at a total cost of more than 1,438 billion yen (US$13.077 billion). Following more than 20 years of feasibility and environmental assessment studies, construction of this giant offshore highway project commenced in May 1989 as the first large-scale highway project with private-sector participation under the prevailing Road Law in Japan, and is now steadily proceeding toward the goal of completion in fiscal1997. This report outlines the entire TTB Highway project, including the waterproofing measures against high water pressure and the rapid construction method applied in the construction of shield tunnel sections.

Jan 1, 1997

By William H. Mount

Since the late 19405, St. Joe has operated rubber-tired, trackless mining equipment underground in its Southeast Missouri Lead Belt operations. At first, the trackless equipment was operated in conjunction with rail haulage equipment in the room-and-pillar operations, but was to later replace rail haulage completely. The first pieces of equipment to travel on pneumatic rubber tires were short-haul shuttle cars of 12-ton capacity hauling rock from the heading to the mainline railroad. Early-model drill jumbos were the next pieces of production equipment to be carried on rubber, along with mobile slusher ramps. Mobile diesel equipment, in the form of conventional rear-dump trucks, made its appearance underground in the early 1950s, introducing the era of relatively high-speed mobile equipment as compared to the electrically powered shuttle cars. Haulage distances for rubber-tired vehicles were no longer dictated by trolley lines and trailing cables and tires were subjected to increasingly severe applications. St. Joe's first completely trackless mine, the Hayden Creek Mine, was opened in 1952, employing rubber-tired drill jumbos, electric shuttle cars, and for the first time, an articulated diesel truck consisting of the tractor unit of a conventional earthmoving scraper and a rear-dump rock wagon. Those machines rolled on the first true earthmover tires to be used underground by St. Joe. The articulated truck concept proved to be very successful, and constitutes an In- creasing portion of the underground haulage today.

Jan 1, 1975

By B. N. Thompson

The main industrial minerals produced are non-metallic - clay, dolomite, limestone, pumice, salt, serpentine, and silica sand. The other minerals, some with minor production, include diatomite, feldspar, magnesite, sulphur, asbestos, and perlite. Energy and metallic minerals and aggregate are excluded from this account. These industrial minerals occur in a wide range of rock types and geological ages. For example clays are known from the weathering products of Cretaceous rhyolite and leaching of Eocene coal measures; from Quaternary weathering of contemporary loess and shallow marine sediments, and of greywacke of Triassic-Jurassic age; and from the hydrothermal alteration of Late Cenozoic acidic volcanic rocks.

Jan 1, 1982

By Thornton L. Neathery

The low-grade talc deposits in Tallapoosa County, Alabama, are associated with a mafic-ultramafic rock complex that is part of a widely distributed schist and gneiss group. These rocks form a synform structure overlying Inner Piedmont lithology. Paragenetic sequence of the Tallapoosa talc is interpreted as enstatite-anthophyllitetalc. Talc occurs as massive boulders formed by the alteration of enstatite-anthophyllite and as finely disseminated discrete particles in the enclosing saprolite matrix. Weathered rock reaches depths as great as 60 feet. The quality and quantity of the talc, however, are variable. Mineral analyses of the talc-bearing samples, by petrographic grain count, indicate a talc content of 16 to 26 percent. Most of the talc occurs as plates or scales that are moderately stained with limonite. Fibrous talc also occurs in the deposits and is often mistaken for anthophyllite asbestos which is intimately associated with the talc. The size, shape, and occurrence of the talc deposits precludes any method of min¬ing other than open-cut. A small-scale mining operation began in the district in 1969. Potential capacity of the operation is 5, 000 tons per year. Inferred reserves, based on field investigations, are placed at approximately 8 million tons. Approved for publication by the State Geologist, Geological Survey of Alabama.

Jan 1, 1970

By D. J. Bryden, J. W. Oberholzer

In response to the need for enhanced precautionary measures to safeguard mine workers in collieries from the consequences of methane ignitions in a heading, the coal mining industry has ex- pressed the desire for the development and testing of active on board suppression systems. As overseas systems cannot be used directly in the bord and pillar geometry it is necessary to adapt overseas and local technology to suit local mining conditions, as well as to test such developed systems for their compliance with the expressed needs. As the systems have to be tested in a specific roadway configuration, a facility was developed to enable the testing in South Africa. A surface test facility has been established which can be used to develop and test suppression systems on continuous miners and roadheaders. This facility consists of a tunnel wherein compliance tests can be conducted in simulated underground conditions. A number of methane explosion tests have been conducted in the test facility. The explosions conducted varied in CH,/air concentration (7,5 to 9 percent) and volume (26 to 88 m3). At lower concentrations there was a marked reduction in explosion strength and flame speed. Tests carried out with the Explostop system successfully suppressed the propagation of methane ignitions in both scenarios tested.

Jan 1, 1997

By Craig J. Nelsen, J. Leroy Schutz

The Carache Canyon Prospect consists of a hypabyssal breccia pipe which intrudes a gently dipping sequence of Cretaceous Mancos Formation and Mesa Verde Group shales and sandstones. This sedimentary sequence is intruded by a number of Oligocene (34-30 Ma) calc- alkaline sills. The formation of the breccia pipe and its subsequent gold mineralization is related to the emplacement of an alkaline intrusive complex dated between 30-26 Ma. An exceptionally large block within the pipe provides compelling evidence that brecciated sills and sedimentary rocks form a relict stratigraphy that collapsed 400-800 ft (120-240 m) below their counterparts outside the pipe without substantial changes in stratigraphic position. Native gold and sulfide mineralization within and around the pipe occurs in fractures that are primarily controlled by competency differences between sills and sedimentary rocks and secondarily controlled by ductility contrasts between the relatively brittle Mancos Formation hornfels and the more ductile Menefee Group shales. The resulting pattern of gold mineralization is a series of stacked, tabular, mineralized sills and sandstone separated by barren shale in an annular region along the southwest margin of the pipe. A series of near-vertical, subparallel, sill and sandstone breccias separated by barren or weakly mineralized shale breccia occur within shallow levels of the pipe.

Jan 1, 1990

By Y. Okahara

The chlorination behaviors of pure iron and manganese oxides were investigated by combining a thermogravimetric analysis (TGA) technique with batch-boat roasting followed by leaching. Ferrous and manganeus oxides could be chlorinated readily, but, in the absence of a reductant, the higher oxides of both iron and manganese were difficult to chlorinate. Thermogravimetric analysis curves were drawn to illustrate the complexitites of the reactions, and the possible mechanisms were discussed. Then three manganiferous materials from the Cuyuna Range of Minnesota were treated by a process involving the selective chlorination of manganese followed by leaching. The results were interpreted in the light of the chlorination mechanisms observed on the pure iron and manganese oxides.

Jan 1, 1969

By Whitmell J. Smithwick

Lime is one of the most extensively used chemicals in industry. Other than sulfuric acid, it is used in greater quantities than any other man-made industrial chemical. In 1974 there were 20,368,000 tons of lime used in the United States, which amounts to approximately 190 pounds for each man, woman and child in our nation. Lime also is perhaps the most diversely used of any industrial chemical. It is used in such areas as pharmaceutical, chemical, steel making, glass making, production of copper and aluminum, sugar refining, agriculture, construction, ecological endeavors, potable water treatment and sanitation. Figure I lists the major uses of lime for 1974, which is the latest year for which this data is available. The impact of the use of lime for ecological reasons did not show up to any appreciable extent in 1974, but we expect this to be a significant factor within the next few years. Fortunately, in the United States and also in most of the world, there are many deposits of high quality limestone available for the production of hood quality lime. For this discussion, we will assure that a limestone of a suitable quality and size consist will be available in a storage bin or stockpile near the kiln. Quality requirements for the lime product will be covered. We also will give a brief description of the three most popular types of lime calcining systems, how they function, and expected lime product quality from each of these. Commercial fuels and major accessory equipment will be discussed briefly.

Jan 1, 1976

By Brendan Demich, Joseph McGuire, Emily J. Haas

Near misses recorded and reported by workers can provide awarenessto the potential causes of injury and prompt safety management initiatives. Although most companies require near-miss reporting, it is unclear what the value of these reports are, if any, and how they influence subsequent actions or controls to reduce on-the-job risks. Researchers at the National Institute for Occupational Safety and Health (NIOSH) conducted a case study with an aggregates company in which near-miss reports were analyzed at each of their locations over an entire quarter during the summer of 2018. Within that quarter, workers recorded 249 near misses. Of those, 167 were valid near misses that occurred at work. Researchers coded the reports using a qualitative 5 × 5 risk matrix. Of the 167 near misses, 19% were deemed low risk, 25% moderate risk, 30% high risk, and 26% critical risk. Several patterns in the near-miss incidents were documented, including classification of incidents and common corrective actions referenced (i.e., elimination/substitution, engineering control or redesign, work process/procedures, and personal protective equipment). The analysis provides insight into ways that risk communication and management programs can be improved to reengage workers and their situational awareness on the job.

By J. E. Lees

Advanced remote sensing can be a powerful new information tool to help private and public entities make better environmental and resource management decisions. However, some regulated entities are reluctant to develop or use this tool because of their concerns that it will lead to increased risks and costs of environmental legal liability. They fear that new ways of monitoring the environment will increase liability, undermine existing enforcement agreements, reopen compliance agreements, and generally provide a competitive disadvantage to early adopters by accelerating environmental cleanup costs. Others counter that the increased risks are marginal, and that several advantages outweigh these risks, including the opportunity to more effectively manage environmental operations, target and set priorities, measure and track management and compliance effectiveness, provide more defensible environmental assessments and baseline conditions, make and defend optimal siting decisions, and avoid or resolve environmental disputes. This paper offers strategic advice on ways regulated entities can enjoy the benefits of these powerful new information tools while mitigating down-side legal and compliance risks as much as possible.

Jan 1, 1999