Regulatory governance of Naturally Occurring Radioactive Materials (NORM) in conventional mining: Benchmarking Tanzania against IAEA radiation protection standards.

Naturally Occurring Radioactive Materials (NORM) generated during conventional mining activities represent a potential source of environmental contamination and radiological exposure to workers, the public, and ecosystems. Although international radiation protection frameworks provide risk-based approaches for managing NORM, implementation in many developing mining jurisdictions remains limited. This study presents the first systematic benchmarking of Tanzania's regulatory and institutional framework governing NORM in conventional mining against the International Atomic Energy Agency (IAEA) graded approach (SSG-60) and International Commission on Radiological Protection (ICRP) recommendations. A structured document analysis and comparative regulatory evaluation were conducted to assess national mining, environmental, and radiation protection legislation and institutional arrangements. The assessment examined legal recognition of NORM, authorization systems, institutional coordination, monitoring requirements, waste management provisions, and regulatory infrastructure. The findings reveal that, despite the existence of radiation protection legislation and recent adoption of exemption thresholds aligned with international standards, Tanzania lacks an integrated governance framework for NORM management. Radiological risk assessment is not routinely incorporated into mining authorization or environmental impact assessment processes, institutional responsibilities remain fragmented, and critical regulatory tools, including a national NORM inventory, technical guidelines, and routine monitoring systems, are absent. The study highlights the need to operationalize the IAEA graded approach through integrated legislation, coordinated institutional oversight, strengthened technical capacity, and improved environmental monitoring. The proposed benchmarking framework provides a practical model for strengthening NORM governance in Tanzania and other resource-dependent economies.