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EXHIBIT 16.1

Disclosureof Mine Safety andHealthAdministration(MSHA)Safety Data

PolyMet is committed to the health and safety of its employees
and in providing an incident free workplace. The Company maintains a
comprehensive health and safety program that includes extensive training for all
employees and contractors, site inspections, emergency response preparedness,
crisis communications training, incident investigation, regulatory compliance
training and process auditing.

PolyMets U.S. mining operations are subject to MSHA regulation
under the U.S. Federal Mine Safety and Health Act of 1977 (the Mine Act). MSHA
inspects our mining operations on a regular basis and issues various citations
and orders when it believes a violation has occurred under the Mine Act.
Whenever MSHA issues a citation or order, it also generally proposes a civil
penalty, or fine, related to the alleged violation.

The following disclosures are provided pursuant to Section
1503(a) of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the
Act), which requires certain disclosures by companies required to file
periodic reports under the Securities Exchange Act of 1934 that operate mines
regulated under the Mine Act.

The information in the table below reflects citations and
orders MSHA issued to PolyMet during the year ended January 31, 2016 as
reflected in our records. The data in our system may not match or reconcile with
the data MSHA maintains on its public website. In evaluating this information,
consideration should also be given to factors such as: (i) the number of
citations and orders may vary depending on the size and operation of the mine,
(ii) the number of citations issued may vary from inspector to inspector and
mine to mine, and (iii) citations and orders may be contested and appealed, and
in that process, may be reduced in severity and amount, and may be
dismissed.

|                   |           |               |            |            |                |            |              |            |            | Received  |           |            |           |         
|------------------ | --------- | ------------- | ---------- | ---------- | -------------- | ---------- | ------------ | ---------- | ---------- | --------- | --------- | ---------- | --------- | --------
|                   |           |               |            |            |                |            |              |            | Received   | Notice of |           |            |           |         
|                   |           |               |            |            |                |            |              |            | Notice of  | Potential | Legal     |            |           |         
|                   |           | Section       |            |            |                |            |              | Total      | Pattern of | to Have   | Actions   | Categories |           |         
|                   |           | 104           |            | Section    |                |            | Total dollar | number     | Violations | Pattern   | Pending   | of         | Legal     | Legal   
|                   |           | Significant   |            | 104(d)     |                |            | value of     | of         | Under      | under     | as of     | Pending    | Actions   | Actions 
|                   | Mine or   | and           | Section    | Citations  | Section        | Section    | MSHA         | Mining     | Section    | section   | Last      | Legal      | Initiated | Resolved
|Mine               | Operating | Substantial   | 104(b)     | and        | 110(b)(2)      | 107(a)     | assessments  | Related    | 104(e)     | 104(e)    | Day of    | Actions    | During    | During  
|ID
      number(1) | Name      | Citations (2) | Orders (3) | Orders (4) | Violations (5) | Orders (6) | proposed (7) | Fatalities | yes/no     | yes/no    | Period(8) | (i-vii)(9) | Period    | Period  
|2103658            | POLYMET   | 0             | 0          | 0          | 0              | 0          | $ 0          | 0          | No         | No        | 0         | NA         | 0         | 0       

|1 | MSHA assigns an identification number to each mine or
      operation and may or may not assign separate identification number to
      related facilities. The information provided in this table is presented by
      mine identification number.                                                                                          
|- | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
|2 | Represents the total number of citations issued by MSHA
      for violation of health or safety standards that could significantly and
      substantially contribute to a serious injury if left unabated.                                                                                                                                   
|3 | Represents the total number of orders issued, which
      represents a failure to abate a citation under section 104(a) within the
      period prescribed by MSHA. This results in an order of immediate
      withdrawal from the area of the mine affected by the condition until MSHA
      determines that the violation has been abated.
|4 | Represents the total number of citation and orders issued
      by MSHA for unwarrantable failure to comply with mandatory health or
      safety standards.                                                                                                                                                                                  
|5 | Represents the total number of flagrant violations
      identified.                                                                                                                                                                                                                                                                          
|6 | Represents the total number of imminent danger orders
      issued under section 107(a) of the Mine Act.                                                                                                                                                                                                                                      
|7 | Amounts represent the total dollar value of proposed
      assessments received from MSHA.                                                                                                                                                                                                                                                    
|8 | Pending legal actions before the Federal Mine Safety and
      Health Review Commission (the Commission) as required to be reported by
      Section 1503(a)(3) of the Act.                                                                                                                                                                 
|9 | The following provides additional information regarding
      the types or categories of proceedings that may be brought before the
      commission:.                                                                                                                                                                                        

| | (i)   | Contest Proceedings - may be filed with the Commission by
      an operator to challenge the issuance of a citation or order issued by
      MSHA;                                                                                                                                                        
| | ----- | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
| | (ii)  | Civil Penalty Proceedings - may be filed with the
      Commission by an operator to challenge a civil penalty MSHA has proposed
      for a violation contained in a citation or order;                                                                                                                  
| | (iii) | Discrimination Proceedings - involves a miners
      allegation that he or she has suffered adverse employment action because
      he or she engaged in activity protected under the Mine Act, such as making
      a safety complaint;                                                                 
| | (iv)  | Temporary Reinstatement Proceedings - involves cases in
      which a miner has filed a complaint with MSHA stating that he or she
      suffered discrimination and the miner lost his or her position;                                                                                                  
| | (v)   | Compensation Proceedings - may be filed with the
      Commission by miners entitled to compensation when a mine is closed by
      certain closure orders issued by MSHA. The purpose of the proceeding is to
      determine the amount of compensation if any, due to miners idled by the
      orders;
| | (vi)  | Applications for Temporary Relief - applications for
      temporary relief of any order issued under Section 104; and                                                                                                                                                                                    
| | (vii) | Appeals.                                                                                                                                                                                                                                                                                                  

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