The South African mining industry has drawn up a confidential policy document which some labor experts say amounts to a "declaration of war" against the country's growing black trade union movement.

Drafted by the industry's controlling body, the Chamber of Mines, the document states that certain unions will not be recognized "under any circumstances" and "irrespective of the consequences." It admits that a "traumatic time may be ahead" because of this stance.

Certain other types of union will be eligible for recognition by the industry, but the conditions laid down are so stringent that some observers believe it will be impossible for the unions to meet them.

The policy document -- which the industry claims is not final -- runs diametrically counter to the conciliatory moves that the manufacturing sector is making towards black unions.

The mines belonging to the chamberr employ nearly half a million black workers. White workers in the industry are represented by 11 different trade unions, a few of whom have recently opened their ranks to black and Colored (mixed race) workers.

The chamber states thay any black union seeking recognition in the industry must first be thoroughly investigated to enusre that it is "nonsubversive." If it fails to meet this test or fails to meet the offical registration criteria laid down by the government, the union must be denied all access to the industry's black employes. The chamber futher states that an "unregisterable" union must be refused recognition and negotiating rights not only at industry level but also by the individual managements on the 50 or more mines grouped within the chamber.

The chamber says: "The representatives of new unions must learn that industrial relations are subject to certain rules and that they can only succeed in improving the lot of their members if the game is played according to these rules."

Several of South Africa's major black trade unions have refused to apply to the government for registeration on the grounds that it involves unacceptable control by the sate. Last year employers outside the mining industry at first also refused to have any dealings with such unions. They have recently changed their stand, however, because it has become clear that some of these unions have strong worker support.

But the Chamber of Mines' document appears to ignore this. The implication of its tough policy is that black unions which are not registered or are otherwise unacceptable to the industry will be locked out of the mines altogether.

The chamber says it is prepared to deal only with unions that can prove they are committed registration. They may be granted the right to have the members' dues deducted from their pay. But the chamber says that such unions will also have to prove that they have 30 percent membership throughout the industry among the class of workers they seek to represent. Since the workers are spread over dozens of mines sometimes hundreds of miles apart, labor ovservers suspect that it will be extremely difficult for black unions, whose resources are limited, to meet this overall 30 percent criterion.

Other conditions laid are likely to have the effect that if black miners wish to be unionized, they will have to seek membership of white trade unions which are already recognized. But some of the white unions concerned in the country -- the leader of one has publicly compared blacks to baboons -- and are most unlikely to open their ranks to blacks. In any event, many black workers in South Africa perfer to form their own unions rather than unions in the control of whites.

The Chamber of Mines represents South Africa's seven major mining houses. Six of the seven are known to be totally opposed to black unions on the mines anyway. The exception is Harry Oppenheimer's Anglo-American Corp. But the chamber document, by centralizing policy towards black miners, is obviously designed to ensure uniformity throughout the inudstry and prevent Oppenheimer's group from implementing the more flexible policies it sometimes claims to expouse.

Oppenheimer's group is not legally bound to follow the chamber's dictates. In practice, however, Anglo-American does conform with the rest of the industry.

One leading labor commentator said today, "The chamber has not so much drawn up an industrial relations policy as issued a declaration of war. The criteria as they stand are a recipe for disaster in South Africa's most important and most sensitive industry."