Public Health England have produced a draft report entitled Review of the potential public health impacts of exposures to chemical and radioactive pollutants as a result of the shale gas extraction. This review has received widespread media coverage suggesting that it gives fracking a ‘clean bill of health’. Upon reading the report carefully, however, a rather different story emerges. Below is a response by Dr Carroll O’Dolan on behalf of the Fermanagh Fracking Awareness Network.
Fermanagh Fracking Awareness [FFAN] comment on Public Health England [PHE] review draft published in Oct 2013 entitled ‘Review of the Potential Public Health Impacts on the Exposures to Chemical & Radioactive Pollutants as a Result of Shale Gas Extraction’. Nov 2013
FFAN is a cross-community network of individual Fermanagh residents. We are not affiliated to any political party or other organisation but work with a broad range of groups and individuals who are concerned about the risks associated with unconventional oil and gas extraction using high volume hydraulic fracking [HVHF]. Below is our comment on the PHE draft review [henceforth the PHE review or review] detailed above.
The PHE states, prior to the review, that PHE’s mission ‘is to protect and improve the nation’s health and to address inequalities through working with national and local government, the NHS, industry and the voluntary and community sector.’
The PHE review obviously deals with chemical and radioactive pollutants, as stated in its title. This comment will deal with these issues later, but meanwhile we note that there are some very important issues that seem not to have been properly discussed. The review states that it deliberately avoids such issues as climate change, nuisance issues, [increased] traffic, visual impact and socioeconomic impacts. These impacts all have huge and often negative impacts on public health. The British Medical Journal last month [BMJ 2013; 347:f6060] states that climate change itself is now a direct threat to public health. These negative impacts are not clearly stated in the review. This is a serious error, as the shale gas industry is already using this PHE draft review to imply a blanket ‘all is okay with shale gas extraction using HVHF [High Volume Hydraulic Fracking]’.
In Nov 2013 Tamboran Director [Tony Bazley] presented to the Northern Ireland Energy Forum and stated that ‘the PHE says health impacts are minimal’. This misuse of the PHE review by the shale gas industry was totally predictable, as the review’s executive summary seemed to be deliberately vague on the different aspects of health which it might have been expected to cover. The fact that the PHE did not state clearly that many other aspects of health are impacted by HVHF but not covered by the review was a critical error.
The Precautionary Principle: when an activity or occurrence raises threats of serious or irreversible harm to human health or the environment, precautionary measures should be taken even if some cause and effect relationships are not yet fully established scientifically. These measures can include the decision not to allow certain activities to commence if the risks are deemed too high.
Throughout the PHE review there is sentence after sentence referring potential and actual problems that have occurred with HVHF, mostly due to leaky wells, poor operators and poor regulation. However, the review then states that all will be okay in the UK, as we have different rules. The PHE’s disregard for the basic medical and scientific maxim of the precautionary principle is unsettling. ‘First, do no harm’ should always be our motto, but there is a constant acceptance in the review that shale gas extraction will happen, despite the well documented cases that the review itself mentions.
The substantial admission at the end of every section detailing ‘Gaps in Knowledge’ shows that the precautionary principle is not being applied. The PHE review’s summary that potential risks to Public Health are ‘low’ is clearly not substantiated by its own review of the limited evidence.
Quote from executive summary ‘However surface spills of fracking fluids or waste water may affect groundwater; and emissions to air also have a potential impact on health. Where potential risks have been identified in the literature, the reported problems are typically a result of operational failure and a poor regulatory environment’.
This PHE review does not discuss scenarios where:
a) HVHF does not take place as the health impacts are too unknown and too unmanageable
b) HVHF may have to be stopped if any of the monitoring reveals serious pollution and human ill health
c) long-term ‘life cycle analysis’ may uncover other issues regarding HVHF and our public health apart from chemical and radioactive pollutants.
Page 1) Not all HVHF is ‘deep’ [ie. 2,000 – 3,000m] below the surface. In Fermanagh it is aimed at the 700 – 1,200 m level. The company involved [Tamboran] have stated that they wish to do HVHF as shallow as 500m below the surface. Thus many of the supposedly protective factors of deep fracking stated in the PHE review are null and void in the Fermanagh context.
Page 2) ‘Flowback water’ can be assumed to average 50% of injected fracking fluid. Even a conservative estimate will put that at an average of 10, 000,000 litres [2.1 million gallons] of polluted water per well. With a minimum of eight wells per pad in UK mainland and 24 wells per pad in Fermanagh this is a huge problem that the industry has not solved, with at hundreds of millions of litres of contaminated water per pad and a pad every two km. Quote: ‘A significant proportion of the fracking fluid pumped into the borehole is lost below ground’. We can assume that which is ‘lost’ is 100% minus the flowback water (ie. the other 50%) which we now know is at least 10,000,000 litres per well. Evidence from Duke University in the USA now suggests that this ‘lost fluid’ is not gone forever but gradually migrates its way upwards to re-enter the hydrology cycle closer to the surface.
Page 6) Quote: ‘At present public health professionals in Public Health England and Public Health Wales are routinely asked to comment on environmental permit applications’. In 2012 FFAN wrote to the Minister for Health in Northern Ireland regarding public health professionals’ input into HVHF issues in the province. Minister Poots declined to involve the public health consultants and decided that the Environmental Health Department was enough.
Page 7) The review states that published evidence suggests a wide variety of different sources of air pollutants but then states ‘ However on a site by site basis these emissions are relatively small’. One of the biggest issues in HVHF is the intensity and cumulative impact of dozens of pads with dozens of wells per pad each spaced at approximately 2km apart. The cumulative impact of all these individual emitted pollutants is huge. To use an analogy: smoking one cigarette per week won’t kill you but 40 cigarettes per day, every day, has a 50% chance of killing you.
Page 8) Quote: ‘The European Community concluded that the potential risks to human health and the environment from releases to air across all phases of development was high’.
Question: How can the PHE draft review still say that these emissions are ‘low’ risk as stated in the Executive Summary?
Page 10) The only HIA [Health impact assessment] published in the peer reviewed literature has been the Colorado School of Public Health and that HIA is very clear in demonstrating the many risks that HVHF poses to nearby populations. The PHE review spends one and a half pages trying to discredit the science used in that HIA; at one stage stating that ‘the risk assessment methodology used in this study is not recommended for use in the UK’. If this is the case then surely the PHE should state that we need to await several more HIAs from the USA so that we can get an overview of the average findings of many studies. Nowhere does the PHE review cast such a critical eye on the pro HVHF ‘science’. At no stage does the PHE review question the possibility that UK regulation during a time of austerity, budget cuts and de-regulation could result in poor regulation of HVHF. The summary relies on the belief that the UK will regulate a new Industry with minimal effect on human health, despite the fact that the only HIA carried out states the opposite.
Question: Can the authors of this PHE draft review:
a) name themselves, their qualifications and their current positions in healthcare.
b) state any conflict of interests, if existing, such as financial, academic, family or investment ties with the oil and gas industry.
c) state what systemic reviews they used to base their conclusion of ‘ low risk of harm’ given the many gaps in the knowledge of HVHF and health that the review freely admits exists.
Page 12) Quote: ‘The available evidence suggests that while emissions from individual well pads are low and unlikely to have an impact on local air quality, the cumulative impact of a number of well pads may be locally and regionally quite significant’
Question: How can the PHE review state that the risk to public health is low given the above statement?
Page 13) Radon: Fermanagh has one of the highest radon background levels on Europe therefore the increased risks here are twofold since the review states that ‘deep’ fracking reduces the risk of radon exposure already low level. In Fermanagh we will be exposed to an even higher level of radon from an existing high background level, as the planned HVHF here is very shallow in comparison to most shale gas areas.
Page 14) PHE review again refers to the integrity of the well bore and casings as being an important issue in the prevention of leakage [be it radon, methane or flow back fluid] The report fails to have referenced the readily available evidence that well bores ‘fail’ [ie start leaking] at an average rate of 3%-5% of wells per year [Professor Ingraffea, Cornell University]. This failure rate of wells makes null and void the protection factor quoted throughout the PHE review.
Page 15) Quote: ‘The chance of a fracture extending more than 600 metres is exceptionally low.’ The chance is actually 1% [Durham University] and that one percent is all that is needed to create a conduit to another level or fault that allows the migration of both contaminated frack fluid but also the methane and underground toxins, such as benzene, xylene, ethyl benzene, toluene, volatile organic compounds, arsenic, cadmium, lead and mercury to work their way up to wards the surface. This 600m distance is used by the HVHF industry to imply safety of fracking at 2,000-4,000 metres when there are no aquifers nearby.
In Fermanagh the planned frack zone is 700-1200metres below the surface with the water table above and a regionally important aquifer [Ballyshannon limestone] immediately below the 1200m mark. Thus, this bare minimum safety distance of 600m means that HVHF in Fermanagh could never be safe even using the HVHF industry’s own rules.
Page19) Quote: regarding radioactive waste disposal. ‘it is expected that the waste management process will be optimised through the application of best practice techniques’
Question: Given that the Cuadrilla Company was given an exemption, on the very first HVHF site in Britain, to dump several thousand tons of radioactive waste into the Manchester Ship Canal in 2011 where is the evidence that best practice techniques, if they exist, would either be obeyed or policed for violations?
Page 21) The complicated issue of the management of the flowback water is discussed with the extensive risks involved and the crucial question of how this contaminated water could or could not be treated, recycled or stored. Currently recycling, even in the best USA scenarios, is well under 50% and the Industry accepts that it is not economically viable to recycle the majority of this contaminated water/chemical mix. Indeed recycling simply creates a smaller amount of a more concentrated toxic sludge that still has to be managed somehow.
The recent floods in Colorado [Oct 2013] where many HVHF pads were flooded and the flowback water ponds ended up as ‘run off’ into the nearby water courses highlight that this heavily contaminated water cannot be stored safely. Thus after one single flood the now contaminated streams in part of Colorado pose a public health and environment risk into the future. Effective decontamination treatment is limited by its inability to work and the extra expense for the fracking company.
Question: Given the lack of evidence of the long-term safe management of the thousands of millions of litres of toxic flowback water that exist in every HVHF area in the USA how has the PHE review come to the conclusion that the risk to public health is ‘low’?
Pages 22/23/24) These pages go into detail of both the potential risks and actual water contamination that have resulted in the USA from HVHF. The general public view HVHF in its entirety so in the case of a contaminated river or field they do not draw a distinction between whether it was caused by well failure, surface spills or underground frack migration. Their view is that it was caused by the fracking company and they are correct in that belief. Air, water and soil contamination is common in the USA around HVHF sites. There is no justification given at the end of this section as to how all these problems in the USA would cease to exist on UK HVHF pads. Most of these accidental contaminations are due to human error and that cannot be eliminated.
Question: Why has the precautionary principle not been applied during the PHE assessment of water contamination due to HVHF? An attitude of ‘let’s give the benefit of the doubt’ to the fracking industry regarding the lack of definitive answers is not good public health science.
Page 25) Quote: ‘The likelihood of fracking fluid reaching underground sources of drinking water through fractures is reported to be remote where there is a separating impermeable layer of at least 600metres between the drinking water and the production zone’.
Therefore Fermanagh cannot be fracked based on this minimal safety requirement. Many hydrologists state that the minimum distance should be a thousand metres. Baseline monitoring in advance of HVHF needs to be at least six monthly over at least two years, in all areas of air water and soil in the frack zone so as to ensure that any seasonal/annual variations are taken into account [Polglase: Australian geochemist and hydrogeologist, personal correspondence] . These baseline studies must be carried out by Independent specialists with a ‘firewall’ to avoid any conflicts of interests by the fracking companies who must pay for all this work.
Page 26) Quote: ‘Analytical methods capable of detecting contaminants associated with shale gas extraction and related activities may need to be developed’.
This statement is concerning in the very lax way it is worded, as if there is an option that the companies and government regulators may decide to monitor without appropriate analysis of contamination. These methods must be developed in advance of HVHF, not in tandem with HVHF. This is necessary as the analytical methods are required to seek out HVHF contaminates at the baseline stage and indeed would not expect to find any contamination at that pre-HVHF. Repeat analysis would then prove that any new contamination is likely to be due to HVHF. The HVHF industry has avoided many proven cases of water contamination in the USA by ensuring either a) that no baseline studies were done or b) that only basic studies, that did not specifically test for likely HVHF contaminants in advance, were carried out.
Page 31) Health Impact Assessments [HIA] are not just useful in deciding about HVHF, they are essential but must be given proper time, funding and independence of industry and government meddling. This PHE review itself does not instil confidence in the true impartiality of the PHE in this debate. Let us hope that other health professionals will look at all the areas that need to be protected before stating that fracking is considered ‘low risk’.
Question: Why has the Colorado HIA findings of so many risks with HVHF been translated by this PHE review into ‘low risk’?
Page 32) Risks, actual and potential, to air and water due to HVHF expressed in the PHE review summary are followed by the statement that risks are ‘low if properly run and regulated’. The UK Government is on record as saying they want to cut the red tape to allow fracking to proceed as quickly as possible. This review gives the Government and the HVHF industry the ‘medical approval’ they so badly need so to allow them to proceed without following the precautionary route.
Page 36) The addendum lists references that ‘have been reviewed and are not considered to affect the conclusions of the draft report’. Some of these references are very relevant to Public Health as we try to seek out the initial signs of any problems with this very young industry, HVHF only became commonplace after 2005.
The Bamberger/Oswald report studied multiple sudden deaths, slow deaths, reproductive problems and neurological disease documented in twenty four different incidents, involving hundreds of farm animals, over six States in USA. Animal owners were also affected as animals are believed to have ended up in the human food chain as they were rendered for the poultry trade. Animals often act as sentinels for human disease as their life cycles are shorter than ours. Some of the effects included arsenic poisoning in children and benzene derivatives in adults. Many cases involved cattle exposed to flowback frack fluid, usually via secondary spills due to human error. The report concludes “Without rigorous scientific studies, the gas drilling boom sweeping the world will remain an uncontrolled health experiment on an enormous scale”. [Bamberger & Oswald, 2012. Veterinary Medical Centre, Cornell University, New York]
The Eswessein report discussed silicosis from silica dust [part of fracking sand additive] A long-standing known risk of silica exposure is silicosis, that causes irreversible lung damage. This HVHF risk was only flagged up in 2012 by health and safety physicians in the USA, who are now concerned about this major problem on well pads & downwind areas. [Esswein, 2012]
Question: Why did the PHE review consider that these reports should not affect the review’s conclusion?
Dr Carroll O’Dolan. Member of the Royal College of General Practitioners
and Chairperson of FFAN, November 2013.