Kabwe, the capital of Zambia’s Central Province, is one of the most lead-polluted places in the world because of contamination from a former industrial lead and zinc mine and smelter. Lead is a heavy metal that is highly toxic to humans when ingested or inhaled, particularly to children and women during pregnancy. The mine, which was established during the British colonial period and officially closed in 1994, has never been cleaned up. Decades of mining and smelting operations have resulted in an estimated 6.4 million tons of lead-bearing waste piles.

Up to now, lead dust from the former mine’s large, uncovered waste dumps blows across nearby residential areas and contaminates homes, yards, schools, and roads, exposing up to 200,000 people. Medical researchers estimate that over 95 percent of children living near the former mine have elevated lead levels in their blood, and that about half of these children urgently require medical treatment. The United Nations has described Kabwe as a “sacrifice zone”—an area where communities suffer from extreme exposure to pollution and toxic substances.

Lead waste in Kabwe also presents a business opportunity: Numerous businesses are mining, trading, and processing lead waste at the former mine and its surroundings. Since mid-2023 and throughout 2024, businesses and individuals have removed large amounts of lead waste from the area and transported it to different locations in Kabwe, apparently for processing. Piles of dark, sandy material, several meters high, have started to appear by roadsides and outside processing plants. The piles are unfenced, and there are no signs warning that it is lead waste. Mining, removal, and transport of the waste has generated more lead dust and spread it to other parts of Kabwe, resulting in huge additional health risks for people who have already been exposed to toxic lead for decades. The government has failed to stop these highly dangerous activities and to protect people’s right to a healthy environment.

Globally, zinc and lead are highly sought-after metals, including for phasing out fossil fuels and transitioning to renewable energy. Zinc is a key metal in wind turbines and is also needed for solar and hydro power. Lead is used in solar energy, as well as in batteries and hydropower. Vanadium, another metal previously mined in Kabwe and still present in the mine waste, is used in batteries. The Zambian government has designated zinc and lead in Kabwe as “critical minerals” needed for the global energy transition.

This report documents the harmful mining, removal, and processing of lead-contaminated waste at and near the former Kabwe mine, and the impact this has on the rights to health and to a healthy environment, particularly as it affects the rights of children. Its findings are based primarily on research interviews, conducted between March 2022 and November 2024, with miners and community members in Kabwe, as well as government officials, experts, civil society groups, donor agencies, companies, and other key stakeholders in Kabwe and in Zambia’s capital, Lusaka. Human Rights Watch also conducted remote research interviews, open-source research, geospatial analysis, and reviews of government, non-governmental, and expert documents, as well as responses to Human Rights Watch letters from the government and companies.

One company, Enviro Processing Limited (EPL), has a mining license for the largest part of the former Kabwe mine area, colloquially called the “Black Mountain.” EPL is a subsidiary of the South African company Jubilee Metals Group. Jubilee Metals told Human Rights Watch in a meeting that it has not conducted mining operations on its concession. But Human Rights Watch research found that small-scale miners have mined lead, zinc, and other minerals on the EPL concession for years, despite the immense health risks. Small-scale miners interviewed said that security guards on site have allowed them to enter through an EPL gate on numerous occasions, though the leadership of Jubilee Metals denied this, saying that miners have entered their premises without permission.

Artisanal and small-scale mining also takes place in other locations. One of them, colloquially called “Savage Yard,” is adjacent to the EPL concession; a local politician and businessman, Gary Domingo, allegedly works with a business partner, Marvin Hangoma, who has an artisanal mining license for this area. The other location, a few hundred meters from the Black Mountain, is on the land of the processing and manufacturing company ZALCO. Human Rights Watch’s research suggests ZALCO has allowed local small-scale miners to mine zinc on its premises and then bought their zinc. Businesses buy lead and zinc from small-scale miners at various locations in Kabwe. Miners have told Human Rights Watch they have also sold lead or zinc directly to three Chinese processing companies: Datong Industries, Chengde Mining, and Superdeal Investments; these companies did not respond to these allegations.

In mid-2023, businesses and individuals begun to remove waste from the Black Mountain by truck and transported it to other parts of Kabwe, apparently for processing. Waste piles have been placed in publicly accessible locations in Kabwe without warning or fencing, including outside the premises of Datong Industries, Chengde Mining, Union Star Industry, and other businesses. Satellite imagery analysis conducted by Human Rights Watch reveals the emergence of new waste piles around Kabwe’s former mine from July 2023 onwards. As of January 2024, nine waste piles were visible from satellite. Human Rights Watch received credible information that a local cooperative called Kabwe Kamukuba Small Scale Mining Cooperative Society was involved in the removal of the waste in 2023. According to several sources, the cooperative was connected to political leaders from the ruling party, so-called “cadres,” who may have financially benefitted. Since 2024, several other companies seem to have been involved in the removal of the waste, including Chinese companies. Several sources have alleged that ruling party officials continue to be involved in the waste removal through other companies. Jubilee Metals, EPL’s mother company, has described this as trespassing and theft. The unregulated removal of waste causes additional health risks for communities nearby and further afield.

While businesses may make a profit from the poisonous lead waste, the small-scale miners eking out a living in the waste piles are exposing themselves to huge risks. Small-scale mining—sometimes called “scavenging” in Zambia—is usually done with little or no machinery. Children as young as 7 are doing this work, despite the extreme health risks. Women who work as informal miners in Kabwe often take even younger children with them to work because they lack alternative childcare options.

Kabwe’s lead pollution is very severe. For example, soil contamination in Kabwe reaches 60,000 milligrams of lead per kilogram; contamination above 200 milligrams per kilogram is considered a hazard for residents by the United States Environmental Protection Agency.

Lead is a toxic metal with no safe level of exposure. It is particularly harmful to children and can result in profound and permanent adverse health impacts, including intellectual disability, coma, and death. Lead poisoning can impair cognitive development, resulting in problems with concentration, memory, and learning. During pregnancy, lead exposure can cause miscarriage, stillbirth, as well as premature birth and low birth weight in newborns, which can have lifelong health implications for the baby. Lead, which can be stored in bones, can also be mobilized and transferred to a newborn through breastfeeding, especially if the breastfeeding parent has poor nutrition. Lead exposure can also cause harm later in life, such as an increased risk of kidney damage or cardiovascular disease. The World Health Organization (WHO) lists lead as one of ten chemicals representing a “major public health concern.”

Zambia is a party to core international and regional human rights and labor rights treaties that obligate the government to respect human rights, including the right to health, the right to a healthy environment, children’s rights, and labor rights. The government also has a duty to protect rights by regulating business operations, and companies have a responsibility to ensure their operations do not cause or contribute to human rights abuses.

Under the Environmental Management Act of Zambia, everyone has the right to a clean, safe, and healthy environment. The Environmental Management Act also requires businesses to submit an environmental impact assessment to the Zambia Environmental Management Agency (ZEMA) and await approval before commencing any operations that may impact the environment. Mining and processing activities can only proceed with a valid license, and production can be suspended according to the Mines and Minerals Development Act on the grounds of an “unsafe working environment” or “uncontrollable pollution,” among other statutory thresholds. Furthermore, Zambian law stipulates that licenses may be revoked or suspended if it would be in the public interest to do so.

It has become evident that in practice the government has not taken adequate action to enforce mining, environmental, and labor regulations and to ensure that people’s rights to health and to a healthy environment are protected in the context of mining, removing, and processing of lead waste in Kabwe. Instead of tackling the toxic waste by conducting a remediation process near the former mine site, the government has facilitated mining and processing of lead-bearing material by issuing further mining and mineral processing licenses for the area at and around the former Kabwe mine.

To Human Rights Watch’s knowledge, the Ministry of Mines and Mineral Development has not exercised its powers to suspend operations or revoke licenses of companies involved in the hazardous mining, removing, and processing of the lead waste in Kabwe, despite the situation seemingly meeting the requirements for such a step under Zambian law. ZEMA has not published environmental impact assessments of these companies, nor has it pointed to examples where it has used its authority to suspend operations of businesses for operating without ZEMA approval or otherwise violating environmental law. The Zambian government has also not exercised its powers to suspend operations of businesses operating without a processing license. Furthermore, the government has neither inspected nor addressed problematic labor conditions despite reports of the worst forms of child labor, in the context of lead waste mining in Kabwe.

While the Zambian government has undertaken some measures to mitigate the harms of lead contamination in Kabwe, it has failed to tackle the source of the contamination and to put forward a comprehensive, sustainable plan for Kabwe. Between 2016 and 2024, with a US$65.6 million World Bank loan, the government took measures to clean up some homes through the Zambia Mining and Environmental Remediation and Improvement Project (ZMERIP). However, the project did not deal with the waste at the former mine—the source of contamination. Without cleaning up the source of contamination, lead dust will continue to pollute the city, erasing whatever progress was made. Government efforts have been undermined by further permitting mining and processing.

The government has recognized the need for a broader cleanup process but has seemingly taken few steps to put words into action. In March 2022, following meetings with civil society organizations, President Hakainde Hichilema instructed the Ministry of Green Economy and Environment to establish a technical committee to “address and lead the process of comprehensive remediation” in Kabwe, but the body was never formally set up by the cabinet and is not functional. In April 2024, President Hichilema announced the creation of an interministerial committee to address the contamination, yet by November 2024, the interministerial committee had also not been officially established. While the Ministry of Green Economy and Environment secured funding for a feasibility study on “green investments” in Kabwe, this does not appear to include an assessment of remediation options for waste from the former mine. Zambia’s National Green Growth Strategy for 2024-2030 includes a plan for the “restoration and management of mine wastelands.” This is a positive development, and the plan should be put into practice in Kabwe.

The Zambian government should suspend hazardous mining, removal, and processing of lead-bearing waste in Kabwe, in accordance with Zambian law. It should suspend businesses operating without a valid mining or processing license or without a ZEMA approval letter; businesses violating the terms of their ZEMA approval; and businesses operating in an unsafe working environment or causing uncontrollable pollution.

To ensure that children and future generations can realize their rights to health and to a healthy environment, the Zambian government should develop and implement a comprehensive remediation program for the former lead mine and its waste in Kabwe. It should do so in close consultation with the affected community, civil society, and experts. The technical solution for remediation should be based on consultations with Zambian and international experts, including engineers who led the remediation of a similar lead and zinc mine and smelter in the United States, to assess the best option for Kabwe’s residents. A technical remediation proposal should also estimate the cost of remediation.

Comprehensive remediation is complex and expensive. Yet, the cost of inaction is much higher—for the rights and health of people in Kabwe, as well as for its economy. To fund this effort, the Zambian government should seek technical and financial support for remediation from companies responsible for the pollution, in line with the “polluter pays” principle, as well as from donor agencies and governments. Comprehensive remediation of the Kabwe mine waste is the only way to realize children’s right to a healthy environment, now and in the future.

To the Government of Zambia

• Develop and implement a comprehensive remediation program for Kabwe’s lead waste, in line with the National Green Growth Strategy:
  • Consult international and domestic mine remediation experts on the method best designed to comprehensively remediate Kabwe’s lead waste to meet international standards.
  • Consult affected Kabwe residents, including women, youth, children, persons with disabilities, and miners; Zambian and international civil society groups; UN experts; and other relevant stakeholders.
  • Ensure the participation of all relevant government ministries and agencies, as well as Kabwe Municipal Council.
  • Draw up a technical proposal for Kabwe lead waste remediation, based on the best available science and stakeholder consultations, including a detailed analysis and explanation of the best technique to contain the source of the contamination.
  • Seek support for remediation from donor agencies and governments, as well as from companies responsible for the pollution, in line with the “polluter pays” principle.
  • Implement the remediation program including:
• Providing as a priority, access to lead testing and treatment for all affected residents, with a focus on testing and treating children and women of reproductive age;
• A detailed assessment of health and environmental harms done;
• Remediation of the former mine area, based on the best method to contain the source of contamination;
• Remediation of all residential areas, including homes and schools;
• Remediation of other contaminated areas, including locations of processing facilities and waste piles;
• Paving of dirt roads around the mine site;
• A program for ongoing biomonitoring of blood lead levels of affected residents, including an age-disaggregated database to track cases of lead poisoning and lead-related deaths;
• A program to end child labor in mining, including access to quality and inclusive education, as well as social and medical support for former child laborers;
• Alternative income-generating activities for former miners;
• Comprehensive awareness-raising around the health impacts of lead as well as the remediation program, including in Bemba and other relevant local languages;
• A governance structure that includes consulting with residents and civil society groups regarding the design and implementation of the remediation program;
• Appropriate compensation for those affected by lead poisoning.

To the Ministry of Mines and Mineral Development

• Exercise powers to suspend operations of the mining and processing businesses responsible for hazardous mining, removal, and processing of lead-bearing waste in Kabwe following article 36 of the Mines and Minerals Development Act; exercise powers to suspend or revoke their licenses in accordance with article 72; and ensure that all regulatory measures are enforced.
• Seek court orders to suspend businesses responsible for hazardous mining, removal, and processing of lead-bearing waste in Kabwe that operate without a license; initiate administrative and/or legal proceedings as appropriate against such businesses; and ensure all measures are enforced.
• Publish beneficial ownership information of all businesses listed in the Zambia Mining Cadastre by linking to beneficial ownership information contained in the Patents and Companies Registration Agency (PACRA).

To the Zambia Environmental Management Agency (ZEMA)

• Exercise powers to suspend operations and initiate legal proceedings as appropriate against businesses that are responsible for hazardous mining, removal, and processing of lead-bearing waste in Kabwe without a valid ZEMA approval letter, or that are violating other provisions of the Environmental Management Act.
• Publish all environmental impact assessments and approval letters on the ZEMA website.

To the Ministry of Green Economy and Environment

• Promptly establish the interministerial committee announced by the president in April 2024 to provide political leadership for the remediation of Kabwe’s lead waste.
• Include civil society representatives in the committee as announced by the president, and publish the names of the committee members, the committee mandate, terms of reference, timeline, its quarterly updates, and final report.
• Publish detailed information on the ministry’s project on green urban development in Kabwe, ensure participation of Kabwe residents and Zambian civil society, and link the project to the comprehensive remediation program outlined above.

To the Anti-Corruption Commission

• Investigate allegations that government officials and officials of the ruling political party, United Party for National Development (UPND), have benefited from hazardous mining, removal, and processing of lead-bearing waste in Kabwe, including through involvement with the Kabwe Kamukuba cooperative.

To the World Bank

• Provide financial and technical support for the development and implementation of a comprehensive remediation program of Kabwe’s lead waste and provide public updates on expenditures.
• Ensure participation of Kabwe residents and Zambian civil society in the World Bank-funded project on green urban development in Kabwe and link the project to the comprehensive remediation program outlined above.

To Zambia’s international donors

• Provide financial and technical support for the development and implementation of a comprehensive remediation program for Kabwe’s lead waste.

To Anglo American South Africa

• Provide financial support for a comprehensive remediation program for Kabwe’s lead waste.

To the UN Committee on the Rights of the Child, and to UN experts on toxics, health, environment, and disability

• Urge the Zambian government to implement the recommendation by the UN Committee on the Rights of the Child to develop and implement a comprehensive program of remediation in Kabwe.
• Request to visit and report publicly on human rights concerns relating to lead contamination in Kabwe.

To companies mining, removing, and processing lead waste in Kabwe

• Immediately stop mining, removing, and transporting lead waste in Kabwe due to the significant health risks associated with these activities.
• Publicly disclose human rights risks—including environmental health risks—identified in the company’s operations in Kabwe, and the steps taken to mitigate or prevent negative impacts.
• Publicly disclose baseline and emissions data on air emissions from the company’s operations in Kabwe, including lead emissions.
• Provide financial support for a comprehensive remediation program for Kabwe’s lead waste.

This report is based on research conducted in Kabwe and Lusaka in Zambia and remotely from March 2022 to November 2024. The research included four field visits to Kabwe in March 2022, March 2023, August 2023, and March 2024. It is also based on open source and geospatial analysis conducted between March 2022 and November 2024, analysis of audiovisual material received from contacts, and data from government websites.

In Kabwe, Human Rights Watch conducted interviews with 29 miners—15 men, 13 women, and a 15-year-old girl. Some of these interviews were conducted jointly with Environment Africa, a nongovernmental organization (NGO). Human Rights Watch also interviewed five local residents and three staff members of Kabwe-based civil society groups and held discussions with a group of young environmental activists—several under the age of 18—and a group of former ward development committee members. Interviews were conducted in English or, with the help of an interpreter, in Bemba. We have used pseudonyms for interviewees to protect their privacy. Human Rights Watch informed all interviewees of the purpose of the interview, its voluntary nature, and the way information gathered would be used. All interviewees provided informed consent to participate, and no compensation was provided for any interviews.

Human Rights Watch also conducted interviews with government officials in Lusaka. These included officials from the Ministry of Mines and Minerals Development, the Ministry of Green Economy and Environment, the Presidency, and the Zambia Human Rights Commission, as well as the member of parliament for Kabwe Central. We also met with representatives of the World Bank, the German embassy, and the United Nations. These meetings included members of a civil society coalition, the Alliance for A Lead-Free Kabwe.

Human Rights Watch wrote to the minister of mines and minerals development, the minister of green economy and environment, the director-general of the Zambia Environmental Management Agency (ZEMA), and 16 companies conducting mining or processing operations in Kabwe, informing them of our plan to publish a report and requesting written information and meetings.[1] In August 2024, the Ministry of Green Economy and Environment sent a written response to Human Rights Watch’s questions. In September 2024, the mining company Jubilee Metals held a conference call with Human Rights Watch to discuss the questions in our letter. This engagement included Jubilee Metals’ comments in writing on a map of the area around EPL, a subsidiary of Jubilee Metals, sent by Human Rights Watch. Two other businessmen contacted by Human Rights Watch spoke to us by phone, and one of them sent WhatsApp messages in response to some of the questions. The other institutions and companies contacted did not respond.

Human Rights Watch also conducted in-person and remote interviews with international experts, Zambian and non-Zambian academics, UN officials, and civil society representatives. These included participants at a 2023 roundtable meeting in Lusaka entitled “Towards a Lasting Solution for Kabwe Lead Contamination.”Human Rights Watch also reviewed a wide range of written sources and data, including expert reports, documentation by the government and the World Bank, satellite images, maps, and open-source information.

Human Rights Watch sourced and reviewed data from the Zambia Mining Cadastre Map Portal (the “Zambia Mining Cadastre”), developed by the Ministry of Mines and Minerals Development and Spatial Dimension, in order to map out spatial information regarding licenses for exploration, mining, and processing within the Kabwe area and surroundings.[2] Data from the Zambia Mining Cadastre Map Portal was accessed by Human Rights Watch on November 15, 2024; therefore, all references to licenses and status refer to that specific date.[3] While the website of the Zambia Mining Cadastre states that its information is updated in real time, it also mentions that the Ministry of Mines and Minerals Development is currently undertaking a “validation exercise of all tenements in the Zambian mining sector.”[4]Previously, the Zambia Mining Cadastre had suffered from irregularities and, in 2022, underwent an audit.[5] As one of the steps to counter potential for outdated or inaccurate information from the Zambia Mining Cadastre, Human Rights Watch sent letters to cadastre-registered companies to obtain status reports on their operations and measures to reduce human rights impacts.[6]

Human Rights Watch used archive high resolution satellite imagery to analyze different ongoing mining activities in and around the former mine of Kabwe, including the emergence of waste piles since mid-2023 in areas near Kabwe and a few kilometers from it. Human Rights Watch also received and verified videos and photographs taken in August 2024 by a local resident. This enabled Human Rights Watch to corroborate satellite imagery analysis that showed the mining activities around the former mine of Kabwe as of August 2024.[7]

Human Rights Watch submitted requests to the government’s Patents and Companies Registration Agency (PACRA) for information on companies, including beneficial ownership information.[8] The information obtained through PACRA comes with certain limitations as it relies on self-reported data from companies and compliance remains low; however, it allowed for the confirmation of company information such as registered addresses or stakeholder information.

This report builds on an earlier report by Human Rights Watch on the lead contamination in Kabwe.[9] The report documented the impacts of lead contamination on children’s rights—namely violations of children’s rights to health, education, and play, as well as child labor—and the government’s response to the lead contamination. It is based on interviews with parents, guardians, children, young adults, teachers, and miners, as well as other sources.

Most companies referenced in the report are limited companies under the law and carry the term “limited” at the end of their company name. For simplicity, we have only listed the “limited” status on the first mention of each company.

The Kabwe Mine and the Search for Accountability

The Kabwe mine began operating in 1904 during the British colonial period, following the discovery of lead, zinc, and vanadium.[10] The mine was set up by a British colonial company, the Rhodesia Broken Hill Development Company, and from 1915 included a smelter, a factory that heats the ore to extract the metal. From 1925, the mining company Anglo American Corporation (now Anglo American plc) became a minority shareholder; according to the company itself, it performed various management and technical services until 1974.[11] In 1964 Zambia declared its independence, and the mine was nationalized in 1971 and closed in 1994.[12] At the time of closure, the mine was owned by Zambia Consolidated Copper Mines Limited (ZCCM).[13]

Early in its operation, mine workers complained of ill-health. In the 1930s, doctors diagnosed smelter workers with lead poisoning.[14] A medical investigation by the colonial authorities in 1944 concluded that there was a high risk of lead poisoning.[15] According to former miners, a common company practice was to move workers with lead poisoning to other areas of work.[16] In 1975, a British medical expert documented severe lead poisoning in children in Kabwe, following the deaths of several children from lead poisoning.[17]

Decades of mining and smelting operations have resulted in an estimated 6.4 million tons of lead-bearing waste piles. These include about 3 million tons of tailings (waste from the mining process), 2.5 million tons of slag (waste from the smelter), and other waste material.[18] After the mine’s closure in 1994, neither the companies involved in mining and smelting nor the government properly cleaned up its toxic waste. The limited efforts that were undertaken by Zambia Consolidated Copper Mines (ZCCM), a government-owned company that had retained liability, were found to be ineffective.[19] As a result, lead dust from the large, uncovered waste dumps blows across nearby residential areas, causing the severe contamination seen today.[20]

In 2020, lawyers from South Africa and the United Kingdom filed a class action lawsuit in a South African court on behalf of affected children and women of childbearing age in Kabwe. The lawsuit seeks compensation, a lead-screening system for children and pregnant women, and remediation of the area.[21] The lawsuit contends that between 1925 and 1974, Anglo American “played a key role in controlling, managing, supervising and advising on technical, medical and safety aspects of the operations of the [m]ine.”[22] Anglo American argues that it did not own or operate the mine, but only provided technical advice and was involved “via an indirect minority shareholding (of ±10%).”[23] In December 2023, the South African High Court dismissed the claimants’ application to certify the class action, describing it as an “unmanageable claim that would set a grave precedent.”[24] In April 2024, lawyers for the claimants won permission to appeal this decision.[25] At this stage, it is unknown whether this case will proceed to a hearing on its merits.

The case has been welcomed by many Kabwe residents, who see it as a way of addressing past harms.[26] If the case results in a settlement or a judgment for the claimants, it could contribute resources to clean up at least some affected areas in Kabwe, depending on the relief agreed upon or the order that is granted.[27]

Health Impacts of Lead on Children and Adults

Lead is a toxic metal with no safe level of exposure. It is particularly harmful to children and women during pregnancy. The World Health Organization (WHO) lists lead as one of ten chemicals representing a “major public health concern.”[28] 

Lead can cause profound and permanent harm in children, particularly to the development of the brain and nervous system.This can result in learning difficulties, memory loss, developmental delays, reduced attention span, anemia, and many other irreversible adverse health effects. Higher exposure can also result in intellectual disability, coma, and death.[29] Younger children’s bodies absorb up to four to five times the amount of lead that adults absorb when they are exposed to lead. The effects of lead are far greater for children than for adults, as children’s brains and bodies are rapidly developing in early childhood.[30] In addition, young children ingest more lead dust because they play on the ground and often put their hands into their mouths.[31]

Exposure of pregnant women to elevated levels of lead can cause miscarriage, stillbirth, premature birth, and low birth weight in newborns. Utero exposure to lead is also associated with impaired neurodevelopment in children.[32] Lead from earlier exposures can be stored in women’s bones but released into the bloodstream during pregnancy and breastfeeding because of the fetus or baby’s nutritional demand for calcium. Iron-deficiency, a common problem in lower-income countries, increases lead absorption. Lead is also associated with maternal hypertension, a dangerous and sometimes deadly condition for pregnant people.[33]

Lead also causes long-term harm in adults (including those exposed as children), such as increased risk of kidney damage, high blood pressure, cardiovascular disease, and, from these, early death.[34]

It is estimated that about 815 million children globally—about one in three children—have elevated blood lead levels.[35] Children from impoverished households are at greatest risk of lead poisoning because they often live in areas where exposure is higher, and because undernourishment increases the amount of ingested lead the body absorbs.[36] A World Bank study found that the global economic cost of lead exposure was about US$6 trillion in 2019, ranking lead exposure as an environmental risk factor on par with ambient and household air pollution combined.[37]

Chelation therapy is the main treatment for lead poisoning; it causes the lead to be successively released in urine. Chelation therapy is advised in cases of severe lead poisoning, defined as 45 micrograms per deciliter (μg/dL) and greater in children up to age ten.[38] However, chelation therapy cannot reverse damage already done by the negative health effects of lead poisoning. 

Since iron deficiency increases the body’s absorption of lead, nutritional supplementation is given to prevent lead from doing as much damage, particularly during pregnancy, breastfeeding, and childhood.[39]

Because damage caused by lead cannot be reversed, prevention is considered the only real solution. This approach is being strongly pursued by the WHO, the UN Children’s Fund (UNICEF), and a US government initiative to reduce lead exposure globally.[40] 

Lead Exposure in Kabwe

Kabwe is considered one of the most lead-polluted places in the world.[41] A 2020 study estimated that between 170,400 and 202,500 people are exposed to lead in Kabwe, particularly in the residential areas of Chowa, Railways, Waya, Luangwa, Katondo, Mutwe Wansofu, Kasanda, Makululu, and Makandanyama.[42] People are mostly exposed to lead through the inhalation and ingestion of lead-contaminated soil and dust.[43]

Kabwe’s lead pollution is very severe both when measured by lead content in residents’ blood lead levels and in the soil. For example, the average level of lead in blood in residents of Kasanda, a neighborhood near the former mine, is 60.2 µg/dl, according to a 2022 medical study.[44] The WHO states that, in case of a blood lead concentration of 5 µg/dL or more, the source of lead exposure should be identified and appropriate action taken to reduce and terminate the exposure.[45] Soil contamination in Kabwe reaches 60,000 milligrams of lead per kilogram (mg/kg) of soil; contamination above 200 mg/kg is considered a hazard for residents.[46] Over 95 percent of children living near the former mine in Kabwe have elevated lead levels in their blood, and about half of these children urgently require chelation therapy.[47]

Lead disproportionately impacts the poor in Kabwe. Its dust is a particular hazard for children in informal settlements such as Makululu where there are few paved roads. In turn, lead exposure can also deepen poverty due to the cost of illness and its impact on cognitive development. A study conducted in Kabwe found that even a 1-percent increase in adult blood lead levels increases the probability of being below the poverty line.[48] Researchers also found that without remediation, generations born in Kabwe between 2025 and 2049 would incur a social cost of US$224 to $593 million in their lifetime, due to ill-health and cognitive impairments.[49]

Zambia’s Mining Sector and the Global Demand for Lead and Zinc

Zambia’s economy is heavily reliant on the mining sector. Copper alone accounted for about 72 percent of total export earnings in 2022, and the government is seeking to boost copper production further to up to three million tons per year.[50] In addition to copper, lead, zinc, and vanadium, there is mining for cobalt, gold, iron, manganese, nickel, and tin, and Zambia has deposits of lithium and graphite.[51] 

Zambia hosts a significant number of large-scale industrial mines but also has a small-scale mining sector, where mining is often conducted with little or no machinery.[52] This includes informal small-scale mining, sometimes called “scavenging.” In recent years, Chinese businesses have invested in small-scale mining in Zambia (and elsewhere in Africa) by partnering with and buying from local miners or license holders. Chinese investment has mechanized some small-scale mining, bringing it closer to mid-scale mining operations.[53]

Minerals extracted from the waste at the former Kabwe mine are in high demand in today’s global economy, including for the world’s urgently needed phase-out of fossil fuels and transition to renewable energy. Zinc is a key metal used in the construction of wind turbines and is also needed for solar and hydro power.[54] The demand for zinc for wind energy production is expected to rise by about 80 percent by 2050 in a scenario that seeks to limit global temperature increases to 2 percent above pre-industrial levels.[55] Global demand for lead may also rise, due to its use in certain types of solar energy panels as well as in some types of solar and hydropower production, and—to a lesser extent—in lead-acid batteries.[56] Vanadium, which was mined in Kabwe during the colonial period and is still present in the waste, is used in some types of batteries.[57]

The Zambian government is seeking to expand the production of minerals to support the global energy transition. In September 2023, the Zambian government declared numerous minerals as “strategic minerals essential in accelerating Zambia’s development.”[58] In August 2024, the government launched a Critical Minerals Strategy designed to leverage the country’s mineral wealth in the context of the energy transition; it includes lead and zinc in Kabwe on its map of “critical mineral locations.”[59] The government has signed partnership agreements with the United States and with the European Union for the extraction of minerals for the energy transition.[60]

International Law

Zambia is a party to core international and regional human rights treaties, including treaties relating to the right to health, child rights, and labor rights. International norms on business and human rights also apply in Zambia.

The right to the highest attainable standard of health is guaranteed by the International Covenant on Economic, Social and Cultural Rights (ICESCR)[61] and the African Charter on Human and Peoples’ Rights.[62] The ICESCR obligates governments to take the steps necessary for the healthy development of the child, as well as for the prevention and treatment of occupational diseases.[63] It also recognizes the right to safe and healthy working conditions.[64]

Under the Convention on the Rights of the Child (CRC), children’s right to health, including environmental health, is guaranteed.[65] The CRC also provides that children have a right to be protected from economic exploitation and from hazardous work, and the rights to education and to play.[66] The UN Committee on the Rights of the Child, which monitors state compliance with the CRC, spelled out government obligations relating to child rights and the environment in its General Comment No. 26. To realize children’s right to a clean, healthy, and sustainable environment, it said that “[s]tates should immediately… regulate and eliminate, as appropriate, the production, sale, use and release of toxic substances that have disproportionate adverse health effects on children, in particular those substances that are developmental neurotoxins.”[67]

The Convention on the Elimination of All Forms of Discrimination against Women (CEDAW) obligates governments to ensure “appropriate services in connection with pregnancy” as well as adequate nutrition during pregnancy and lactation.[68]

Those who acquire disabilities because of lead poisoning are protected under the Convention on the Rights of Persons with Disabilities (CRPD), which Zambia ratified in 2010.[69] The Committee on the Rights of Persons with Disabilities has urged Zambia to take legislative and policy measures to recognize and provide support to children with disabilities and their families, to ensure inclusion of children with disabilities in all areas of life.[70]

Zambia is a party to the International Labour Organization Minimum Age Convention and to the Worst Forms of Child Labour Convention.[71] The latter prohibits the worst forms of child labor (also known as hazardous work), including “work which, by its nature or the circumstances in which it is carried out, is likely to harm the health, safety or morals of children.”[72]

The United Nations has recognized the right to a healthy environment, which is also recognized by article 24 of the African Charter on Human and Peoples’ Rights. In August 2022, the UN General Assembly adopted a resolution declaring access to a clean, healthy, and sustainable environment a universal human right.[73]

Governments have a duty to protect human rights in the context of business activity, according to the UN Guiding Principles on Business and Human Rights.[74] While governments have the primary responsibility to respect, protect, and fulfill human rights under international law, businesses and other private entities have the responsibility to respect human rights.[75]

Zambian Law

Under the Environmental Management Act of 2011, everyone in Zambia has the right to a “clean, safe and healthy environment.”[76] Any person undertaking a project or activity with an impact on the environment must get approval for an environmental impact assessment from the Zambia Environmental Management Agency (ZEMA) before commencing, and submit annual reports to ZEMA describing the extent to which the project conforms with the environmental impact assessment.[77] A person who willfully fails to undertake an environmental impact assessment commits an offense.[78]

The Mines and Minerals Development Act of 2015 prohibits exploration, mining, or mineral processing without a license or without environmental impact assessment.[79] The act distinguishes between licenses for exploration, mining (artisanal mining, small-scale mining, and large-scale mining), and mineral processing. It stipulates that the government can direct the holder of a mining or processing license to suspend or curtail production or close a mine because of “an unsafe working environment” and “uncontrollable pollution,” and it can revoke a license when this is in the public interest, or the holder of the license has violated the Mines and Minerals Development Act.[80]

The Children’s Code Act enshrines children’s right to health and health care, as well as protection from “any work that is hazardous or likely to interfere with the child’s education, physical or mental health, spiritual, moral, emotional or social development.”[81] The Employment Code prohibits the employment of children in the worst forms of labor.[82]

Small-scale mining of lead-contaminated waste has been taking place for years at and around the site of the former industrial Kabwe mine. While some small-scale operations are legal and formalized, others are part of the informal sector. Mining disturbs the soil and creates lead dust, bringing health risks to workers and to the wider community.[83]

There are several locations where people mine or have mined for lead, zinc, or other material (see map below). The largest area is colloquially called the “Black Mountain” and is part of the concession of Enviro Processing Limited (EPL), a subsidiary of Jubilee Metals Group, a South African company that specializes in the re-processing of mine waste.[84] The name Black Mountain refers to the core area of the former mine marked by its dark waste piles. Another location nearby is colloquially called the “Savage Yard” (sometimes also called “Salvage Yard”). According to several miners and residents, this area is managed by Gary Domingo, a Zambian businessman and politician, and allegedly a business partner of Marvin Hangoma, who has an artisanal mining license there. Mining also takes place on the premises of the ZALCO, a few hundred meters away from the Black Mountain.

Jubilee Metals also operates another subsidiary in Kabwe, a refinery called Sable Zinc Kabwe Limited. According to data from the Zambia Mining Cadastre, Sable Zinc has a processing mining license for zinc, copper, lead, and cobalt.[85] However, Jubilee Metals has advised that Sable Zinc does not process zinc or lead-bearing material from Kabwe, unlike the name suggests, but processes copper from Zambia’s Copperbelt region.[86]During the research for this report, it was observed that Kabwe residents sometimes use the names of EPL and Sable Zinc interchangeably. 

Based on interviews with local miners and residents, data from the Zambia Mining Cadastre, as well as information provided by EPL, Human Rights Watch gathered the names of the following businesses involved in the mining of lead waste[87]:

• Enviro Processing Limited (EPL; license number 7081-HQ-SML)

• Gary Domingo and Marvin Hangoma (Hangoma has license number 37318-HQ-AMR)

• ZALCO (not in Zambia Mining Cadastre)

The Zambia Mining Cadastre also shows other mining businesses near the former mine and lists lead as one of the commodities they are mining. These are Central Youth Multi-Purpose Cooperative Society Limited,[88] Musonda Kasani,[89] and Leopard Exploration and Mining Limited[90]; all three are listed as “active”, but Leopard Exploration and Mining is additionally classified as “non-compliant.”[91] Despite our efforts to engage with these entities through written correspondence, Human Rights Watch was unable to confirm whether these have been involved in the mining of lead waste.

Most small-scale miners dig Kabwe’s waste material for lead and zinc.[92] Some miners also mine dolomite, a rock which is used locally in construction.[93] Waste material in Kabwe also contains the metal vanadium, though there is no public information on whether vanadium is being mined.[94] Mining work typically consists of digging, sometimes in deep pits; separating lead-and zinc-bearing material; crushing rocks; and filling and carrying sacks with dug-up material. However, not all material gets crushed at the mine site; miners frequently just fill sacks with dug-up material and sell it to traders for further processing.[95]  

Men, women, and children work in mining.[96] Miners sometimes work in groups and sell the ore together, and in other cases work by themselves.[97] They use chisels, hammers, shovels, and picks. Miners divide up tasks into work above ground and work digging deep pits. They are paid per kilogram or ton of material mined.[98]  

Mining on the Concession of Enviro Processing Limited (EPL)

EPL holds a small-scale mining license over most of the former mine, including the area containing the former mine’s waste, the Black Mountain.[99]

When acquiring EPL, Jubilee Metals stated that it intended to reprocess lead, zinc, and vanadium from the Kabwe mine waste.[100] Jubilee Metals representatives have subsequently informed Human Rights Watch that the company did not go ahead with these plans and is not mining or reprocessing any lead waste currently, nor has it done so in the past.[101]

Jubilee Metals has expressed that it does not allow miners to access the Black Mountain, its concession, that any mining there is illegal, and that it considers this to be trespassing.[102] In its initial 2022 letter of response to Human Rights Watch, the company emphasized that the area under license had been fenced off and electrified “to discourage any access to the area to attempt to re-mine or re-process” the waste.[103]

Human Rights Watch found, however, that the company has, on multiple occasions, allowed miners to enter the Black Mountain. People interviewed for this report said security guards allowed miners to dig on the EPL concession from at least 2022 until at least March 2024.

EPL’s concession is fenced and has two gates; the main one (commonly called the Motwu Wansofu gate) has a large “EPL” sign and is guarded by security personnel. The second has no sign and is not continuously guarded. According to Jubilee Metals, the two gates are not official entrances; the only official entrance is that to the Sable Zinc refinery.[104] Miners interviewed in 2022 and 2024 said they have been allowed into the fenced area by security guards at the Motwu Wansofu main gate and were able to mine there on a regular basis. In 2022, miners explained that women were not allowed into the area, which women miners complained about.[105] As of March 2024, male and female miners told Human Rights Watch that the guards allowed them into the concession when the gate was open, between 7 a.m. and 5 p.m.[106] Miners described “supervisors” coming to check on them at the Black Mountain and getting a cut of their earnings. They said the supervisors may be influential external actors whom they described as “cadres” linked to Zambia’s ruling political party—the United Party for National Development (UPND).[107]

Sally C., a women miner from Makululu, described access to EPL’s fenced area at the Black Mountain in March 2024:

There is only one gate through which miners can enter the Black Mountain, the Mutwe Wansofu [main] gate. There are guards there continuously. But as a miner you can just come and start working.[108]   

When Human Rights Watch representatives visited Kabwe in March 2022 and August 2023, they observed groups of people mining inside the EPL concession near the main gate. A September 2022 assessment by a Zambian researcher also found “a hive of activities with various small-scale miners manually digging up and selling minerals” within the EPL concession.[109] In October 2024, a local observer said there was mining activity at the Black Mountain, though at a lesser scale than previously observed.[110]

During 2023, the Kabwe Kamukuba cooperative mined and removed waste in large quantities from the EPL concession.[111] According to a news report, this activity was based on an agreement between the cooperative and Sable Zinc.[112] A source in Kabwe told Human Rights Watch that the cooperative was closely connected with political leaders from the ruling party, so-called “cadres,” and alleged that these political leaders have financially benefitted from Kamukuba’s operations; an open letter on the Facebook page of the Patriotic Front, the main opposition party, makes similar allegations.[113]

Human Rights Watch was not able to verify if Sable Zinc or EPL had a financial agreement with the Kabwe Kamukuba cooperative relating to the removal of waste from the EPL concession. Two local sources have alleged that Sable Zinc was actively involved in the removal of waste by the Kabwe Kamukuba cooperative[114]; the open letter by the Patriotic Front says that Sable Zinc was forced into such an agreement.[115]

However, during the meeting with Human Rights Watch, Jubilee Metals representatives said that they have not sold the tailings to anyone and expressed concern about the removal of waste piles from the EPL concession. They described this as theft by Chinese companies and illegal actors or “cadres” that are politically connected and supported.[116] Jubilee Metals representatives said that they had at the time appealed to various political authorities to address the problem.[117]

In September 2023, the minister of green economy and environment, Collins Nzovu, inspected the site and found that the cooperative did not comply with regulations.[118] He instructed the company to get its papers in order and reportedly suspended its operations.

It remains unclear if the Kabwe Kamukuba cooperative stopped operations after the minister’s visit. In any case, large-scale removal of waste from the EPL concession continued according to the various sources of information presented above.

Miners claim that EPL has also conducted its own mining operations. Jubilee Metals denied this in an interview with Human Rights Watch.[119] According to miners interviewed, the area inside the EPL concession is divided into two parts—one where they are allowed to mine, and one that is restricted, only for EPL and its sister company Sable Zinc to mine.[120] Human Rights Watch was not able to independently corroborate either the miners’ allegations or the company’s denial.

Satellite imagery analysis by Human Rights Watch confirms that lead waste was removed from the Black Mountain near the EPL entrance between 2023 and 2024 (see section below “Removal and Processing of Lead Waste”). While a large tailings dump is still visible on satellite imagery collected at the end of April 2023, a comparative image collected in June 2024 shows a clear reduction of this tailings dump. 

Human Rights Watch also verified a video recorded at the end of November 2024 that was sent directly to our researchers. The video captures ongoing mining operations within the EPL concession, near the second entrance to the Black Mountain. Several dump trucks and workers can be seen near the open entrance. Satellite imagery from December 4, 2024, shows several excavators within the EPL concession, near the second entrance, as well as multiple dump trucks along the road separating the EPL concession from the “Savage Yard.” Additionally, more dump trucks and excavators were visible within the Savage Yard area. Human Rights Watch was unable to confirm whether the material extracted from the Black Mountain at the end of November was transported to the Savage Yard area. 

In summary, evidence collected during the research period indicates that highly hazardous and illegal mining activities have taken place on the Black Mountain—the EPL concession—for several years and as recently as August 2024. While EPL has taken legal action against illegal mining activities and the removal of waste from May 2023 onwards, it is alleged that security guards located at the Black Mountain main gate have continued to allow miners to enter at different moments in time between March 2022 and March 2024, according to miners and local observers.

Mining at the “Savage Yard”

Adjacent to the EPL concession is a mining area known as the “Savage Yard.” The entrance is not fenced, so miners can simply walk in. There is no sign indicating who owns or controls the land. Several miners interviewed by Human Rights Watch said they often switched between working at the Black Mountain and the Savage Yard.[121]

Businessman and political leader Gary Domingo has control over mining-related activities at the Savage Yard. He responded to Human Rights Watch’s letter by sending information via WhatsApp and agreed to a videoconference call. He described the operations at Savage Yard as joint activity with his business partner Marvin Hangoma, whose artisanal mining license was granted on August 30, 2024.[122] Mr. Domingo explained further that the “official takeover” of the area was in December 2023, and that he provides pumps and machinery to miners and buys mined material from them; the miners are not formally employed.[123] He added that an environmental impact assessment had been submitted to ZEMA, and that ZEMA had not yet responded, implying that the company has not received a ZEMA approval letter.[124] In his response to Human Rights Watch, Domingo repeatedly asserted his commitment to ensure environmentally sound mining.[125]

According to Domingo, miners dig for zinc at the Savage Yard. However, miners told Human Rights Watch that Domingo’s company buys not only zinc, but also lead and copper slag. The miners said that Domingo controls the middlemen at the Savage Yard, where he has an office and is regularly present.[126] Domingo disputes controlling middlemen. Domingo was the district chairperson of the ruling United Party for National Development (UPND) in 2022 and ran for mayor during the 2021 elections.[127] While he did not win the election, several residents of Kabwe described him as an influential “cadre” who has control over trade networks and mining operations.[128]

Photos and videos recorded on August 27 and 29, 2024, shared by a local observer and verified by Human Rights Watch, corroborated reports of mining activities at Savage Yard, even prior to the license being granted.

Mining on the Land of ZALCO

ZALCO is a Zambian manufacturing and processing company producing cables and other metal equipment, registered in Lusaka with a branch in Kabwe.[129] It built a processing and manufacturing plant in Kabwe in 2012.[130]

In response to a letter sent by Human Rights Watch, the former director of ZALCO, Hussein Safieddine, wrote a message stating that ZALCO did not exist anymore and stopped operations a few years ago.[131]

The Zambian Patents and Companies Registration Agency (PACRA) lists ZALCO as a registered company and mentions Hussein Safieddine as one of the individuals representing it, though it states that its certificate expired on February 28, 2021.[132] The Zambia Mining Cadastre does not list the company as having a mining or processing license.[133] In December 2024, a local source told Human Rights Watch that ZALCO was still operational.[134]

According to residents and miners, ZALCO has previously allowed local residents to enter ZALCO premises to mine zinc. A female miner interviewed in 2022, Regina M., said that she worked at ZALCO as part of a group of six women. She explained that each woman had a different task: digging up material with a shovel; breaking the material up; placing it on large sieves for sieving; washing it in water; carrying it to the packing area; and packing it into bags.[135] According to Regina M., the women produced at least 15 bags of zinc ore a day.[136]

In March 2024, miners told Human Rights Watch that ZALCO allowed them to enter and dig for zinc: “ZALCO is a private property, it has its own gate. You register at the gate…. [People do] re-mining of zinc there. They dig it out, then wash it, then put it into sacks.”[137]

The miners interviewed said that they sold their material to ZALCO, and that ZALCO traded the material with foreign traders.[138] One miner complained that at times the premises at ZALCO were overcrowded and people took over each other’s mine sites, prompting him to stop working there in late 2023.[139]

Miners also said that ZALCO did not warn the workers about the health risks of mining material containing lead. One miner commented that “they [ZALCO] don’t care about health.”[140]

Human Rights Watch geolocated two videos, published by a Kabwe-based civil society group, Siyaliswa Shelter of Hope, that livestreamed a government delegation’s visit to ZALCO premises in Kabwe on January 16, 2023. In the videos, Credo Nanjuwa, then central province minister, is seen accompanied by a group that includes individuals taking photos of the area, as well as officials in uniform. According to the caption of the post, the delegation was on a “fact finding mission to establish allegations of illegal mining.”[141] The caption also notes that ZALCO “stands closed” and has been “found engaging in illegal mining of zinc” in tunnels that were at risk of collapse.[142] In one video, Nanjuwa states that he doesn’t have the authority to close the mining area, and the next step is to give detailed reports to the relevant ministries for better action.[143]

The removal, transport, and processing of lead-bearing material brings severe health risks for people already exposed to toxic lead for decades: During the removal and transport of lead waste in Kabwe, lead dust is spread to residential areas along transportation routes and near places where the waste is offloaded and stored. The number of people exposed to lead in Kabwe—estimated between 170,400 and 202,500 people in 2020—may have risen as a result.[144] In addition, the processing of lead-bearing material carries health risks from lead and other toxic emissions through smokestacks.[145]

Businesses Trading and Processing Toxic Waste

Through interviews with miners and residents as well as open-source research, Human Rights Watch has gathered names of businesses involved in processing minerals in Kabwe, listed below.[146] Human Rights Watch does not have conclusive information that all companies named have processed lead waste. However, 6 of the 10 companies are listed in the Zambia Mining Cadastre as processing lead, zinc, or both of these minerals in Kabwe, which requires mining in lead-bearing material[147]:

• Chengde Mining (license number 34486-HQ-MPL)

• Chiman Manufacturing (not listed in the Zambia Mining Cadastre)

• Dashun Industry Company (license number 27408-HQ-MPL)

• Datong Industries (not listed in the Zambia Mining Cadastre)

• Ferro Alloys Corporation (license number 29021-HQ-MPL)

• Finesteel Manufacturing (not listed in the Zambia Mining Cadastre)

• San He (Zambia) (license number 35119-HQ-MPL)

• Superdeal Investments (license number 30841-HQ-MPL)

• Union Star Industry (license number 25646-HQ-MPL)

• ZALCO (not listed in the Zambia Mining Cadastre)

The Zambia Mining Cadastre includes further details on the registered companies listed here, including the status of their application for a license, the commodity to be processed, and the area where processing would take place.[148] Whereas Chengde Mining, Ferro Alloys Corporation, Dashun Industry Company, Superdeal Investments, and Union Star Industry are listed as “active,” the other companies have different statuses, indicating that their license applications are in process, deferred, or otherwise not yet granted.[149]

While most companies are located in the area around the former Kabwe mine, Chengde Mining and Union Star Industry are located several kilometers away.

Miners have told Human Rights Watch that traders buy lead-bearing material from them at multiple locations in Kabwe and sell it to Kabwe-based companies for processing—to recover zinc, lead, or other metals—or for export. In some cases, miners agree beforehand who they will sell to, and are then obligated to sell to that particular trader.[150]

Several local observers said that more businesses have become involved in trading and processing in recent years. Already in 2022, one miner said the situation in the last few years had “escalated.”[151]

Waste Piles from the Black Mountain Concession Spread around Kabwe

Local sources said that significant amounts of waste material from the Black Mountain have been removed by truck since 2023. Miners working at the Black Mountain described Datong Industries and Superdeal Investments coming with trucks to the Black Mountain, adding that “the cadres take the material out and then sell to Datong Industries and others.”[152] Jubilee Metals described this activity as theft, and also called the actors involved “cadres” that are “politically connected and supported.”[153] According to Jubilee Metals, Chinese businesses entered the concession from May 2023 to remove the material.[154] A local resident commented that, due to this activity, the Black Mountain is much smaller now.[155]

In June 2024, the mayor of Kabwe expressed concern[156] about the contamination, and specifically the removal of waste piles from the Black Mountain, but, to the extent that Human Rights Watch is aware, it does not appear that the government has taken any action to address the health risks or to hold any actors accountable for this activity where it is found to be unlawful.

During this same period, large piles of the waste have appeared in several locations in Kabwe, including outside the premises of Chengde Mining and Union Star Industry, as well as at one location near both Ferro Alloys Corporation and Datong Industries. The waste piles are unfenced and there are no signs warning that it is lead waste.[157]

Human Rights Watch analyzed satellite imagery that confirms the emergence of nine new waste piles in several locations across Kabwe since July 2023. The first waste pile became visible in July 2023 within the EPL concession. Between October 2023 and January 2024, four waste piles emerged outside the EPL concession on the right side of Mine Road, a road that passes near the premises of Datong Industries and Ferro Alloys Corporation. In addition, three waste piles emerged several kilometers further away—two near the processing company Chengde Mining, located four kilometers southeast of the former Kabwe mine, and one next to the premises of Union Star Industry, eight kilometers north of the mine. Other waste piles have appeared in other parts of the city, close to residential areas such as Waya and Mutwe Wansofu, including one less than 300 meters from residential homes (see map and satellite imagery below).

During a field visit in March 2024, Human Rights Watch identified a waste pile near the area fenced off by EPL and a second one immediately outside premises belonging to the processing company Union Star Industry in the Mukobeko area of Kabwe. Both these waste piles are visible on satellite imagery. Residents of Kabwe reported waste piles outside Ferro Alloys Corporation (see map below) and Datong Industries.[158]Human Rights Watch also verified photographs and videos, collected in August 2024, showing some of the waste piles that are also visible on satellite imagery.

As of November 19, 2024, all of those nine waste piles were still visible on satellite imagery. Although it has not been confirmed at this stage, the correlation between waste removal from the Black Mountain and the ongoing appearance of waste piles in other locations indicates that the Black Mountain may be the source of this unfenced and unsigned waste.

Hazardous Child Labor

Miners told Human Rights Watch that children were working at the Black Mountain and at the Savage Yard to help increase their families’ income. Human Rights Watch also interviewed parents whose children were mining, as well as a 15-year-old girl working as a miner.

Although child labor violates Zambian and international law, the practice is common due to poverty, sudden illness of a caregiver, or job loss of a primary wage earner. Other reasons for child labor include the lack of enforcement of child labor laws, inadequate social protection, a lack of decent work opportunities, and limited access to quality schooling.[159] It is estimated that about 23 percent of children in Zambia are involved in child labor.[160] Child labor often traps children in poverty as they are unable to get a good education and then a better-paying job.

Several women miners told Human Rights Watch that they took children to the mine with them to help with the work. In addition, older children between the ages of 15 and 17 sometimes mine on their own.

Sally C., a 36-year-old mother of four from Makululu neighborhood, said she takes two of her sons, Peter, 9, and Fred, 13, with her to the Black Mountain or the Savage Yard when they are not in school.[161] Peter gathers the rocks while Fred crushes them. Peter was found to have high blood lead levels in 2022 and was given medicine and a nutritional supplement in the form of powder for his porridge, to reduce the lead in his blood. Sally C. said, “I’m not happy with taking my children to the mine. But there is no other work to do…. I cannot leave them at home because we need the money.”[162]

Kathleen N., a 15-year-old girl from Makululu, said that she works by herself for about four hours a day. She started working in grade 6, when she was about 12 years old. Her job has been to crush dolomite rocks with a hammer and, occasionally, to dig for zinc with a shovel. When asked about the physical impact of the work, Kathleen described fatigue in her whole body and injuries when using the hammer.[163] 

Kennedy S., 15, had previously worked with his parents at the Black Mountain after school and during weekends. He dug underground while his mother, Grace S., separated the ore into zinc- and lead-bearing material. But, according to Grace S., “the lead started affecting him…. He has a memory issue.” The parents then decided not to take Kennedy with them to work at the mine.[164] She said:

We are constantly living in fear because it is not a safe area…. Even though there are problems with lead and we are aware [of them], there is nothing we can do about it. We just have to cope with it. It is the only way I can sustain my children…. I would love a different job, at the market, selling tomatoes, or even second-hand clothes.[165]

Clarissa M. said she takes her 7-year-old daughter Betty to work with her and her husband at the Black Mountain after school and on the weekend. Betty’s job is to help fill sacks with mined material.[166] In April 2023, Betty was diagnosed with very high blood lead levels during lead testing at school. She was given an injection—most likely chelation medicine—as well as soy porridge, likely enriched with a nutritional supplement to reduce lead absorption. According to her mother, Betty was tested a second time, and her lead levels were lower. Clarissa M. said she still takes Betty and her 13-year-old sibling to the mine with her to work: “I feel bad about [taking the children to work at the mine] but there is nothing I can do about it.”[167]

Most of the work performed by children in the mining sector is considered hazardous according to the International Labour Organization.[168] In Zambia, child labor has been documented in multiple types of mining operations, including gemstones, manganese, and copper.[169] Human Rights Watch previously documented the use of child labor at the Black Mountain and the Savage Yard in Kabwe in 2019.[170]

Lead Exposure of Children and Adults in the Community

Adult workers as well as children and adults in the wider community are exposed to lead from ongoing mining. Infants and young children are also exposed to lead when mothers bring them with them to work at the mine, due to the absence of childcare.

Adult miners—including women of reproductive age—said that they are generally aware that lead is harmful but feel that they have no choice but to do the work.[171] A few said they lack information on the health impacts of lead.[172] Several workers said they change their clothes before returning home to protect their families.[173] Some workers said they try to drink milk to protect themselves against lead, or that they would like to buy milk for that purpose but cannot afford it. Foods that are higher in calcium, iron, and vitamin C can indeed help reduce the body’s absorption of lead.[174] However, these limited steps are not sufficient to address the enormous health risks lead poses to workers and their communities, especially given the very high level of lead exposure in Kabwe.[175]

Ruth M., a 34-year-old single mother from Makululu, said that she always takes her 3-year-old son Steven with her to the mine. While she works, the boy crawls in the dust and puts dust into his mouth.[176] Medical staff at the local hospital have told her that Steven had elevated levels of lead in his blood. Ruth M. was given medicine for Steven—most likely chelation treatment—and medical staff told her not to go to work in the mine. But she says she has to work because she needs the money: “I would like to get out of mining. I’d be rather at the marketplace, selling things…. Mining is all about suffering, the work is difficult.”[177]

More broadly, communities living downwind from the mining areas are more exposed to lead because the mining process stirs up and spreads lead-contaminated dust across nearby areas. In this way, current mining adds to the already existing legacy of severe lead contamination caused by mining and smelting during most of the 20th century.[178]

Mining Accidents 

When Human Rights Watch asked miners in Kabwe about challenges in their work, several mentioned the risk of accident first. They described accidents they survived or witnessed, or cases in which friends or family members suffered accidents.

Miners can get hurt when the ground collapses above them and buries them underneath. This happens frequently when it has just rained and the ground is unstable.[179] Clarissa M., who works with her husband and daughter at the Black Mountain, said:

I have witnessed a lot of accidents. My husband was in an incident in March last year [2023]. There were about seven [miners] who were injured. The earth caved in, it buried some up to their legs, others up to their neck…. Nobody was killed. My husband had a broken leg.[180] 

Miners said that in March 2024, men were buried under earth that collapsed at the Savage Yard mining area. One had a deep cut in the abdomen, and another had cuts in the arms. Victims of the accident had to be hospitalized.[181]

Miners mentioned two fatal mine collapses, in 2021 and 2022, in which one person died.[182] Thirty-six-year-old Kevin L. described what happened during the second incident, as he was mining in October 2022 at the Black Mountain:

The ground collapsed. It covered me and a friend. I got pains in the abdomen and had to go to hospital. I was in hospital for a week. Even up to now, when I lift something, I can feel pain…. My friend died. His name was Geoffrey Waya.[183]

Miners also spoke of other types of accidents, in some cases involving child laborers. Kathleen N., 15, injured herself when using a hammer.[184] Patricia M., 22, injured her arm when a sack of rocks that she was carrying ripped.[185] Others described injuries from falling rocks and falling sacks of ore, as well as injuries while crushing ore.[186]

Lack of Employment Alternatives

Most miners—men and women—said they would prefer to do other work but did not feel this was possible in their current circumstances. They expressed hope that the government would support apprenticeships and the creation of small businesses such as tailoring, selling vegetables, selling second-hand clothes, making oil, or bricklaying.[187] Many of these options require small outlays of capital that miners do not have. A few miners also suggested setting up a mining cooperative to work legally and professionally in mining.[188]

The Zambian government has conducted a livelihood project to support local income generation in Kabwe among women and youths, as part of the Zambia Mining and Environmental Remediation and Improvement Project, which ended in June 2024. Under this activity, residents of lead-affected townships could jointly submit proposals for the creation of cooperatives for income generation. The project helped establish 57 livelihood projects in the areas of fishing, farming, and other economic activities, reaching 3,409 beneficiaries by January 2024.[189] However, the project did not specifically target mining communities, even though transitioning miners into different jobs would have been beneficial to them and the wider community. Some miners criticized the World Bank for not approaching them.[190] Poor residents of Kabwe, including women and children, continue to work in mining. 
 

Many children and young adults in Kabwe are deeply concerned about the situation and are pushing for change. The Kabwe Youth Network conducts awareness-raising activities in the community, speaks publicly on behalf of affected children, and engages with the government.

One member, 18-year-old George Kande, described his concerns regarding the recent removal and distribution of lead waste across Kabwe:

The waste piles across Kabwe are very concerning. Number one, because children tend to play around them or on top of them. Also, those mountains of waste are taken to other places in Kabwe, they are not sealed off from the public and this makes those areas toxic, too…. Most children are not aware of the lead pollution. I feel very upset about the situation.[191]

Natalie Chilikwela, an 18-year-old youth group member, made a passionate plea at a roundtable with government officials, civil society groups, and donors in March 2023:

We are done talking…. We now want to see action. We have so many children back home who are affected. I personally know of a young boy who has not been allowed to go to school until his lead levels drop back. And that, if you ask me, calls for immediate action.[192]

Youth activists have highlighted the role of the government, saying in a video: “As the duty bearers are running out of excuses, we are running out of time.”[193] The activists have been calling for treatment for children suffering lead poisoning, and for a proper cleanup of the mine. Mwelwa Lungu, another youth group member, said, “It is important for the government to come up with a comprehensive remediation program, one that actually addresses the source of the contamination.”[194]
 

Failure to Regulate Mining and Processing Companies

Based on Human Rights Watch’s research, it is evident that the Zambian government has not taken adequate action to prevent unregulated methods of mining and processing of lead-bearing material known to carry significant risks for human health. The lack of enforcement of mining, environmental, and labor regulations has exposed Kabwe residents—particularly children—to severe environmental health risks and has undermined the government’s own efforts, designed to mitigate the harm of the toxic pollution. As a result, the right of Kabwe residents to a healthy environment has been violated.

The Zambian Ministry of Mines and Minerals Development has issued several mining and mineral processing licenses for companies that are processing lead-bearing waste, or that may do so in the future. According to the Zambian Mining Cadastre Portal, as of November 15, 2024, five businesses were “active”: Central Youth Multi-Purpose Cooperative Society (artisanal mining right), EPL (small-scale mining license), Leopard Exploration and Mining (large-scale mining license), Musonda Kasani (artisanal mining right) and Marvin Hangoma (artisanal mining right).[195] The Ministry of Mines and Minerals Development also issued five mineral processing licenses—namely to Chengde Mining, Ferro Alloys Corporation, Superdeal Investments, Dashun Industry Company, and Union Star Industry. In addition, three companies had pending applications for mineral processing licenses: Dashun Industry Company, and San He (Zambia).[196]

Based on information available to Human Rights Watch, the Ministry of Mines and Minerals Development has not revoked the licenses or suspended operations of mining or processing companies that are responsible for an “unsafe working environment” or that are causing “uncontrollable pollution” under the Mines and Minerals Development Act. ZEMA has also not published environmental impact assessments of these companies, even though it has a webpage for the publication of environmental impact assessments.[197] At the time of publication, ZEMA had not responded to Human Rights Watch’s letter dated June 19, 2024, asking for those assessments. According to media reports, in September 2023, ZEMA suspended operations of one processing factory in Kabwe, Ferro Alloys Corporation, due to environmental concerns.[198] Human Rights Watch was unable to establish whether operations are still suspended or have been reinstated. According to the Zambian Mining Cadastre Portal, as of November 15, 2024, Ferro Alloys Corporation holds an “active” mineral processing license and is “pending renewal”; the license granted on December 17, 2009 indicates December 16, 2024 as expiration date.[199]

The Ministry of Labour and Social Security, the primary agency responsible for labor law enforcement, does not conduct labor inspections in the informal sector at all, even though it has a mandate to do so, nor does it conduct inspections for violations of child labor laws.[200]

As a result, labor regulations have been ineffective, despite what appear to be widespread infringements of the law, including prohibition of the worst forms of child labor in the context of lead waste mining in Kabwe. Furthermore, it appears that the government has neither investigated nor acted upon the removal of waste from the Black Mountain and the emergence of open waste piles across Kabwe since mid-2023.

Companies with Mining or Mineral Processing Licenses

Jubilee Metals (EPL and Sable Zinc)

The Zambian government, to Human Rights Watch’s knowledge, has not investigated mining activities inside the EPL concession, nor suspended the company’s operations or revoked its license under the Mines and Minerals Development Act. The provincial authorities appear to have consented to a small-scale mining cooperative entering into an agreement with EPL and Sable Zinc for the mining of tailings. For reasons unrelated to environmental concerns, this initiative did not go ahead; had it done so, it could have brought serious risks of further health contamination.

The government has not published an environmental impact assessment for EPL. The company previously operated on the basis of a 2016 environmental impact assessment that omitted some of the current business activities and did not demonstrate how people’s health would be protected.[201] In 2019, the government sent Human Rights Watch a letter stating that ZEMA “will ensure EPL prepares a full Environmental and Social Impact Assessment.”[202] In 2022, EPL told Human Rights Watch that it now has an “improved” environmental impact assessment.[203] However, at the time of publication, neither ZEMA nor Jubilee Metals had responded to Human Rights Watch’s request for the current environmental impact assessment and approval letter.[204]

Chengde Mining

The government granted a mineral processing license to Chengde Mining on October 5, 2023. ZEMA has not published an environmental impact assessment or its approval letter for Chengde Mining.[205] To Human Rights Watch’s knowledge, the government has not investigated Chengde Mining’s activities inside the EPL concession, nor suspended the company’s operations or revoked its license under the Mines and Minerals Development Act. At the time of publication, neither ZEMA nor Chengde Mining had responded to Human Rights Watch’s request for the current environmental impact assessment and approval letter.[206]

Superdeal Investments and Union Star Industry

The government granted mineral processing licenses to Superdeal Investments and Union Star Industry on October 12, 2023 and on December 24, 2019 respectively, without publishing environmental impact assessments for these companies.[207] Based on available information, the exact status of the their environmental impact assessments and approval letters is unclear. In April 2023, a Union Star representative indicated that they had submitted an environmental impact assessment but had not received a response.[208] At the time of publication, neither ZEMA nor these companies had responded to Human Rights Watch’s request for the current environmental impact assessment and approval letter.[209]

Companies without Mining or Mineral Processing Licenses

ZALCO

Based on the information available to Human Rights Watch, the government has not taken adequate action to ensure that ZALCO is operating within current regulations, despite a previous intervention by competent authorities to close down the operation. The company appears to have allowed workers to conduct hazardous mining work on its premises but has no mining or mineral processing license, nor is there a published environmental impact assessment.[210] The former director of ZALCO responded to Human Rights Watch’s request for information by stating that the company does not exist anymore. At the time of publication, ZEMA had not responded to Human Rights Watch’s request for the current environmental impact assessment and approval letter.[211]

Datong Industries

Similarly, there is no indication that the government has taken any steps to ensure that Datong Industries is operating within current regulations. Datong Industries operates openly in Kabwe, and evidence suggests that it has purchased material from miners working under hazardous conditions. It lacks a mineral processing license according to the Zambia Mining Cadastre, and there is no publicly available environmental impact assessment.[212] At the time of publication, neither ZEMA nor Datong Industries had responded to Human Rights Watch’s request for the current environmental impact assessment and approval letter.[213]

Ferro Alloys Corporation

The government closed down operations at Ferro Alloys Corporation in September 2023 due to regulatory violations. According to media reports, the government told the facility: “We are stopping operations until you comply in full to all conditions in the decision letter of approval for the operations of Ferro Alloys Processing Plant.”[214] Records show that by November 2024, the company had a mineral processing license with “renewal approved,” which expired on December 16, 2024, according to the Zambia Mining Cadastre.[215] There is no public information on whether the conditions in the previous ZEMA approval letter were met. At the time of publication, neither ZEMA nor Ferro Alloys Corporation had responded to Human Rights Watch’s request for the current environmental impact assessment and approval letter.[216]

Zambia Mining and Environmental Remediation and Improvement Project (ZMERIP)

The Zambian government has undertaken some measures to reduce lead exposure in Kabwe, but so far, the situation on the ground indicates that these have not resulted in a sustainable solution.

From December 2016 to June 2024, the government conducted the Zambia Mining and Environmental Remediation and Improvement Project (ZMERIP) with a World Bank loan. This US$65.6 million project aimed to reduce environmental health risks in critically polluted mining areas in Kabwe and the Copperbelt area.[217] In Kabwe, the project provided lead testing and treatment to children with high blood lead levels; initiated income-generating projects for women and unemployed youth; raised awareness around the risks of lead exposure; and cleaned up a school, some homes, and a canal polluted by the mine.[218]

However, the project had several serious flaws. Most importantly, it did not address the source of contamination—the former mine. Without cleaning up the waste at the former mine, any gains made are quickly reversed. For example, children who have been treated for lead poisoning will continue to be exposed to severe lead pollution, resulting in further adverse health impacts. Residential areas where the soil has been cleaned up are being re-contaminated with lead dust from the former mine.

Other problems with the project have revolved around poor management and delays. The project was approved in 2016, but on-the-ground activities only began in 2019. It was extended by two years, ending in June 2024.[219] According to the World Bank itself, there were also serious issues with “inefficient leadership,” “deficient individual accountability, project administration and contract management” as well as inadequate communication with external stakeholders.[220] It rated the project’s progress towards its objectives as “moderately unsatisfactory” in June 2022; in May 2024, a few weeks before the project’s closure, this rating was “moderately satisfactory.”[221] A previous World Bank program that ran from 2003 to 2011 also had serious shortcomings and did not meet its key objective of reducing children’s blood lead levels.[222]

Government Announcements – Empty Promises?

The government has recognized the need for broader cleanup. In his August 2024 letter to Human Rights Watch, the minister of green economy and environment said that “the lead situation in Kabwe is not completely resolved and more needs to be done.”[223] But so far the government’s pronouncements of concern have not been followed by effective and sustained action.

In March 2022, following meetings with civil society organizations, President Hichilema instructed the Ministry of Green Economy and Environment to establish a technical committee to “address and lead the process of comprehensive remediation” in Kabwe.[224]However, the body was never formally set up by the cabinet and is therefore not functional.

In 2023, the Ministry of Green Economy and Environment announced its intention to make Kabwe a “Green City” in which economic development takes place on top of “buried lead” surfaces.[225] The ministry has since secured World Bank funding for a feasibility study to “aid and direct the implementation of green investments” in Kabwe, but the project does not appear to include remediation of the former mine waste.[226] The ministry’s National Green Growth Strategy for 2024-2030 includes a plan for the “restoration and management of mine wastelands,” mentioning Kabwe as an example.[227] This strategy should be put into practice in Kabwe as soon as possible.

In April 2024, President Hichilema again took up the problems in Kabwe and announced the creation of an interministerial committee to address the contamination.[228] Yet, at the time of publication, the interministerial committee had not been officially established.

Need for Comprehensive Remediation of Kabwe’s Lead Waste

The Zambian government should develop a comprehensive remediation program for Kabwe’s lead waste, in close consultation with the affected community, civil society, and domestic and international experts. The remediation program should include all areas where lead waste is present, including lead waste piles that appear to have been removed from the EPL concession. The government should seek financial support for remediation from donor agencies and governments, as well as companies responsible for the pollution, in line with the “polluter pays” principle.[229] The “polluter pays” principle is the widely accepted practice that those who produce pollution should bear the costs of managing it to prevent further damage to human health or the environment.[230] Kabwe residents, youth activists, community groups, as well as civil society organizations and church leaders have long called for such a remediation process.[231]

In parallel, in accordance with applicable legal provisions, the government should suspend hazardous mining, removal, and processing of lead-bearing waste in Kabwe. In particular, the government should investigate businesses that appear to engage in activities without a valid ZEMA approval letter or that otherwise violate the Environmental Management Act or the Mines and Minerals Development Act. In addition, the government should consider exercising its statutory power to revoke mining and processing licenses of businesses responsible for an “unsafe working environment” and “uncontrollable pollution” under the Mines and Minerals Development Act, and initiate legal proceedings as appropriate against such businesses.

In mine remediation, there are broadly three different techniques to deal with the source of contamination: containment, removal, and stabilization.[232] Containment means that the source of pollution is encapsulated, capped, or otherwise prevented from causing exposure. Removal means that the source of pollution is extracted. Stabilization means that chemical processes are used to immobilize the source of contamination, for example by using plants as a cover to absorb the contaminants.[233]

Human Rights Watch’s research found that, to date, the government does not have a technical proposal for the remediation of the former Kabwe mine and its lead waste. In the immediate future, the government should seek funding for the development of such a technical proposal that includes consultation with international and Zambian experts. Mining and tailings engineers who led the remediation of Bunker Hill, a former lead and zinc mine and smelter in Idaho in the United States, should be invited in these consultations because their experience can help provide lessons for Kabwe. One lesson from Bunker Hill is that remediation programs should include several components to be successful. In Bunker Hill, the source of the industrial pollution was capped (sealed); residential areas were cleaned up; reclaimed land was revegetated; the community received health information, testing, and treatment; and key stakeholders, including local communities, were involved in the remediation process.[234]

The “International Principles and Standards for the Ecological Restoration and Recovery of Mine Sites,” put forward by a group of international environmental scientists in 2022, may also offer useful guidance for the development of a remediation program in Kabwe. While the document lacks guidance for the health component of a remediation program, it defines eight broad principles that should guide any process of mine restoration, including stakeholder engagement; seeking evidence-based decisions founded on science, Indigenous knowledge, and practitioner experience; and seeking the highest level of recovery attainable.[235]

A technical remediation proposal should also estimate cost so that adequate funding can be raised and allocated. Comprehensive remediation is a complex, expensive undertaking. Yet, the cost of inaction is much higher—for the rights and health of people in Kabwe, as well as for its economy. A multidisciplinary team of international scientists estimated that a one-centimeter cement mortar cap for the dumpsite (the Black Mountain area) would cost $35.1 million. The cost of remediation would rise to about $84.7 million if it included a 10-centimeter soil removal and 30-centimeter soil replacement in 95 percent of highly polluted residential areas. For all scenarios assessed, the researchers found that the benefits of remediation exceeded the costs.[236] They found that in the absence of any remediation, Kabwe’s generations born in 2025–2049 would incur a social cost of $224 million to $593 million in their lifetime, caused by the future income loss due to decreased IQ and educational outcomes, as well as mortality from lead poisoning-related illnesses.[237] On a global level, World Bank economists estimate that the global cost of lead exposure was about US$6 trillion in 2019.[238]

Comprehensive remediation of the Kabwe mine waste is the only way to realize children’s right to a healthy environment, now and in the future. 
 

This report was researched and written by Juliane Kippenberg, associate director of the Children’s Rights Division. Carolina Jordá Álvarez, senior geospatial analyst, and Ekin Urgen, senior associate in the Technology, Rights and Investigations Division conducted open source and geospatial research and wrote relevant sections.

The report was reviewed and edited by Zama Neff, director of the Children’s Rights Division; Tom Porteous, deputy program director; James Ross, policy and legal director; Idriss Nassah, senior researcher in the Africa Division; Katharina Rall, senior researcher in the Environment and Human Rights Division; Jim Wormington, senior researcher and advocate in the Economic Justice and Rights Division; Kayum Ahmed, special advisor on health and human rights; Elizabeth Kamundia, director of the Disability Rights Division; Skye Wheeler, senior researcher in the Women’s Rights Division; Maya Wang, associate China director; and Sam Dubberley, director of the Technology, Rights and Investigations Division.

The report was prepared for publication by Joya Fadel, senior associate in the Children’s Rights Division; Travis Carr, publications officer; Ivana Vasic, senior graphic designer; Laura Navarro Soler, information designer; Fitzroy Hepkins, senior administrative manager, and José Martínez, administrative officer.

We would like to thank NGO colleagues, academics, government officials, company representatives, researchers, and experts who provided information for this report.