Former state health employees forced silent on fracking

It has been reported by news outlet NPR that former Pennsylvania State Health employees were instructed to ignore enquiries from the public in relation to the negative health effects related to unconventional shale gas development.

GAGGED

Staff were instructed, that in the event of a member of the public calling in regards to a shale gas related ailment, the enquiry was to be forwarded to a supervisor who would handle the case from there on in. However, many members of the public would phone bad, annoyed that they had received no follow up.

There is also evidence to suggest that the problem occurs in other states outside of Pennsylvania.

NPR reports:

npr

Two retirees from the Pennsylvania Department of Health say its employees were silenced on the issue of Marcellus Shale drilling.

One veteran employee says she was instructed not to return phone calls from residents who expressed health concerns about natural gas development.

“We were absolutely not allowed to talk to them,” said Tammi Stuck, who worked as a community health nurse in Fayette County for nearly 36 years.

Another retired employee, Marshall P. Deasy III, confirmed that.

Deasy, a former program specialist with the Bureau of Epidemiology, said the department also began requiring field staff to get permission to attend any meetings outside the department. This happened, he said, after an agency consultant made comments about drilling at a community meeting.

In the more than 20 years he worked for the department, Deasy said, “community health wasn’t told to be silent on any other topic that I can think of.”

Companies have drilled more than 6,000 wells into Pennsylvania’s Marcellus Shale over the last six years, making it the fastest-growing state for natural gas production in America.

Amid the record-breaking development, public health advocates have expressed concern that Pennsylvania has not funded research to examine the potential health impacts of the shale boom.

Doctors have said that some people who live near natural gas development sites – including well pads and compressor stations – have suffered from skin rashes, nausea, nosebleeds and other ailments.

To read the investigative report in full, click here.

Texas: $3 million fracking lawsuit upheld

Previously, we had reported upon the landmark 2014 fracking lawsuit in Texas, whereby the Parr family were awarded $3 million damages against Aruba Energy, for environmental pollution of the air, water and soils from Unconventional Gas Exploration and Extraction activities (UGEE) that proved to have detrimental impacts on the quality of the family’s health.

Parr

Since then, Aruba Energy appealed the decision. The appeal was rejected on June 19th 2014 by Judge Mark Greenberg, thereby upholding the law in favour of the Parr family.

In the original lawsuit filed, the Parr family had complained of nuisance problems that were caused by unconventional shale gas extraction operations including but not limited to: open sores around he eyes, nose and rest of body, permanent scarring, chronic nose bleeds, migranes, drowsiness, irregular heart beat, depression, ataxia, abdominal pains, arrhythmia, and anisocoria.

The Parr family is not the first family to bring an energy company to court over damages caused by unconventional shale gas extraction, however they are the first family to succeed in acquiring damages from an energy company in front of a court of law.

Councilman Brad Koplinski chastises fracking effects on pennsylvania communities

In Pennsylvania, USA, Harrisburg City Councilman Brad Koplinski provided a press release highlighting the environmental, economic and social liabilities experienced in Pennsylvania at the hands of unconventional shale gas extraction.

Koplinski, running for candidacy for Lieutenant Governor, not only asked for tighter regulations on the process, and a closing of the ‘Halliburton Loophole’, but also underlined the need for better protection for landowners who live nearby unconventional shale gas operating plants, wether they signed land agreements with energy companies or not.

Brad Koplinski. Source: politicspa.com
Brad Koplinski. (image source: politicspa.com)

Providing the polite, yet damning press release in front of the Chapin Dehydration Station which faces a 29 litigant lawsuit, Koplinski stated that ‘nuisance’ was too light a word for the local situation which has reduced the quality of human life for local home owners, referring to the high number of detrimental effects an ‘aberration’.

He also lamented on the fact that the shale gas extraction industry makes promises and “say things that are half truths are best most of the time. That certain chemicals won’t be put into the atmosphere, that certain practices won’t be put into place, and yet they are. Through legal contracts and other regulations that they can skirt around, we’ve seen the damages that they cause, and not just here, but throughout the commonwealth.”

Unfortunately, for Koplinski and residents of Pennsylvania, the British Medical journal have already drawn attention to the fact that the process of unconventional shale gas extraction, set to arrive in County Fermanagh, cannot be made safe for local communities, regardless of the level of regulation, stating:“To the extent that they are technically and economically feasible, risk reduction technologies that mitigate adverse health outcomes should be deployed. However reviewing the public health aspects of the development of the shale gas industry requires more than merely gesturing to technological improvements that lack empirical data on their effectiveness in the real world. optimism that fail-safe engineering solutions can ensure safe shale gas development may result more from a triumph of marketing than a demonstration of experience.”

To see the press release by Councilman Koplinski in video format, click here.

‘Lancet’ medical journal raises detrimental health implications of fracking

One of the world’s oldest and best known peer-reviewed medical journal, The Lancet, released a paper highlighting the realised risks that unconventional shale gas extraction poses to public human health.

lancet

The Lancet states that despite scientific study of the health effects of fracking being in its infancy, “findings suggest that this form of extraction might increase health risks compared with conventional oil and gas extraction [due to] larger surface footprints of fracking sites; their close proximity to locations where people live, work and play; and the need to transport and store large volumes of materials.”

The article further states that investigation into unconventional shale gas extraction in the USA has shown that, “risks of environmental contamination occur at all stages in the development of shale gas extraction.”

Problems with the structural integrity of the process, which is planned for county Fermanagh include: failure of well cement and casing, surface spills and leakage from above ground storage, gas emissions from gas processing equipment, and the large number of transport vehicles involved with transporting large volumes of chemicals.

The article draws attention and concern to detrimental health effects locally and globally. Locally, environmental contaminants such as volatile organic compounds, tropospheric ozone, diesel particulate matter, benzene, hydrocarbons, endocrine disrupting chemicals and heavy metals.

Source: aljazeera.com
The practice of unconventional shale gas extraction, otherwise known as fracking, has drawn criticism as a result of the negative impacts on human health and the environment. (Image source: aljazeera.com)

Globally, environmental threats to public health is the “contribution of shale gas extraction to green house gas emissions, and thus, climate change.”

In conclusion, the Lancet have recommended the implementation of Health Impact Assessments (HIA) that take into consideration not only public health risks during development of unconventional shale gas extraction, but the legacy left for public health over the long term also.

If you wish to read the peer reviewed article titled, “The health implications of fracking”, click here.

British Medical Journal criticises safety of fracking

The world renowned British Medical Journal(BMJ) has strongly criticised false assurances of safety given by the recent Public Health of England report which opined that whilst unconventional shale gas extraction posed a risk to public human health, it would not pose a health threat to humans on the European side of the Atlantic.

BMJ

The BMJ article, penned by Adam Law (Cornell Medical College), Jake Hays (PSE Health Energy), Seth B Shonkeff (PSE Health Energy) and Madelon Finkel (Cornell Medical College), draw attention to the fact that whilst the PHE Report acknowledges a real risk to public health, as shown by existing scientific research, the claim made by the report that the health risks will not exist for citizens of the UK and Ireland are theoretical at best.

“To the extent that they are technically and economically feasible, risk reduction technologies that mitigate adverse health outcomes should be deployed. However reviewing the public health aspects of the development of the shale gas industry requires more than merely gesturing to technological improvements that lack empirical data on their effectiveness in the real world. The optimism that fail-safe engineering solutions can ensure safe shale gas development may result more from a triumph of marketing than a demonstration of experience.”

oil fracturing drilling rig at dusk
oil fracturing drilling rig at dusk

The BMJ continues: “The [PHE] review appropriately acknowledges differences in geology and regulation between the United States and the United Kingdom. Yet in a leap of faith unsubstantiated by scientific evidence, its authors suggest that many of the environmental and public health problems experienced in the US would probably not apply to the UK. Unfortunately the conclusion that shale gas operations present a low risk to public health is not substantiated by literature.”

“Furthermore, the [PHE] report incorrectly assumes that many of the reported problems experienced in the US are the result of a poor regulatory environment. This position ignores many of the inherent risks of the industry that no amount of regulation can sufficiently remedy, such as well casing, cement failures, and accidental spillage of waste water. There is no reason to believe that these problems would be different in the UK, and the report provides little evidence to the contrary, despite repeated assertions that regulations will ensure safe development of shale gas extraction.”

The BMJ also draws attention to the fact that unconventional shale gas extraction, on this side of the atlantic, will be taking place in more densely populated areas, than usually seen in the US.

In conclusion the BMJ state that: “Rigorous, quantitative epidemiological research, is needed to assess the risks to public health, and data are just starting to emerge.”

To read the BMJ article in full, click here.

Aerial study reveals methane and benzene emissions higher than expected

A new study of the oil and gas fields of Colorado, conducted by scientists from National Oceanic and Atmospheric Administration (NOAA) and the Cooperative Institute for Research in Environmental Sciences (CIRES), has revealed that methane and benzene emissions are respectively as much as three and seven times higher than Colorado state inventory.

Published on the 7th of May 2014, the aerial study recorded methane and non-methane hydrocarbon emissions over the densely pack oil and gas fields of the Denver-Julesburg Basin, over a two day period covering the 29th and 31st May 2013.

Comparing Colorado state inventory data with observational data, the report found that methane concentrations in the air were three times higher than state inventory, with oil and gas operations in the basin emitting around 19.3 metric tonnes of methane emissions every hour, which the authors calculate as a leak rate of 4.1 percent (± 1.5) of total gas produced.

Colorado State. Source: usgs.gov
Colorado State. (image source: usgs.gov)

Benzene, a volatile organic compound (VOC) harmful to humans, was seven times higher than state inventory, emitting around 173 ± 64 kg/hr.

The study reinforces concerns that fugitive emissions of methane and other non-methane hydrocarbons are running unabated, with gas operators and policy makers unable to halt fugitive emissions of gases harmful to human health.

“These discrepancies are substantial,” said lead author Gabrielle Petron, an atmospheric scientist with NOAA’s Cooperative Institute for Research in Environmental Sciences at the University of Colorado Boulder. “Emission estimates or ‘inventories’ are the primary tool that policy makers and regulators use to evaluate air quality and climate impacts of various sources, including oil and gas sources. If they’re off, it’s important to know.”

To read a copy of the peer-reviewed paper, click here.

Landmark $3million fracking law suit, Texas

A family from Wise county, Texas, were awarded $3 million in their legal battle against Aruba Energy for environmental pollution of the air, water and soils from Unconventional Gas Exploration and Extraction activities (UGEE) that proved to have detrimental impacts on the quality of the family’s health.

Mason and cattle rancher by trade, Bob Parr built his home on his 40-acre estate in 2001. In 2007 his then wife to be Lisa Parr moved in with her daughter and the couple married in 2008. Until this point, the family of three experienced no unusual health effects from their local environment.

After 2008 however, significant gas drilling operations took place around Parr’s 40 acre estate. Soon after, the family began experiencing health effects such as rashes, nausea, vomiting, bleeding noses, as well as environmental damage to their estate and livestock.

It was around 2010 when the Parr family seen an environmental health specialist, who found unusually high traces of specific natural gas related chemicals in their systems, including ethylbenzene and m,p-Xylene.

“We can’t drink our well water,” said Parr in 2011. “We can’t breathe the air without getting sick.”
Parr

The Parr’s filed their lawsuit on 17th september 2013. Item 16 states that as a result of UGEE operations the family suffered environmental contamination of air, water and soils as a result of sudden and continual chemical releases, spills, emissions and discharges of hazardous chemicals which lead to ailments including but not limited to unreasonable fear, impairment and exacerbation of physical health, nausea, loss of peace of mind, damage to livestock, and inability to enjoy their own environment.

Item 18 states that the environmental pollution facilitated by Aruba was as a result of operations related to UGEE including, but not limited to: Vehicles and engines, construction and trucking activity, pits, condensate tanks, dehydrators, flaring, venting, fugitive emissions and the hydraulic fracturing process, also known as fracking.

In the law suit, Item 21 states that the Parr family were under constant environmental abuse by Aruba and its discharge of chemicals, before Item 21 lists experienced health effects in more detail, including but not limited to: open sores around he eyes, nose and rest of body, permanent scarring, chronic nose bleeds, migranes, drowsiness, irregular heart beat, depression, ataxia, abdominal pains, arrhythmia, and anisocoria

Items 29-34 state clearly that Aruba Energy had performed their duties with negligence, which lead to the fact that the Parr family were able to come into contact with the hazardous chemicals.

Item 41 holds Aruba negligent towards the Parr family, before accusing Aruba in Item 44 of recklessness, oppression, fraud, malice and wilfulness to pollute the land with hazardous chemicals. Item 29 to 75 state that the Parr family had suffered gross negligence, negligence, private nuisance and trespass to property. You can read the full legal document here.

After winning their case in court after a three year legal battle, the Parr family attributed some of their success to the fact that they documented their ordeal on a daily basis, documentation that supported their case in front of a jury. The Parr family expect Aruba to appeal the decision.

Chinese villagers concerned over shale gas explosion

The New York Times has reported that local villagers of the Jiaoshizhen have been warned not to discuss a gas fire incident that claimed eight lives to outsiders.

china

One night on April 2013, villagers heard a loud explosion  and found the source to be from a shale gas well in the area, where flames from the gas fire reached 100 meters in height. Within twenty four hours, workers working on the well pad were moved to work in another location.

Chinese Energy giant Sinopec are the first company to open a shale play within the nation of China, and have stated that a controlled explosion took place, with no loss of life.

You can read the NY Times article here.

Los Angeles – Largest U.S. city to approve fracking ban

On 28th of February, the city of Los Angeles placed a moratorium on unconventional shale gas extraction (USGE), making it the largest city in the United States to do so.

The city of L.A. City council voted unanimously to ban the practice within city limits, 10-0. The L.A. ordinance prevents operation of USGE until effective government oversight and regulation is in place at local, state, and federal levels. The motion, brought forward by councilmen Koretz and Bonin will hold in place until verification that USGE does not pollute the ground waters of the city. The council curbed “all activity associated with well stimulation, including, but not limited to, hydraulic fracturing, gravel packing, and acidizing, or any combination thereof, and the use of waste disposal injection wells.”

“Until these radical methods of oil and gas extraction are at the very least covered by the Safe Drinking Water Act, until chemicals are disclosed and problems are honestly reported, until we’re safe from earthquakes, until our atmosphere is safe from methane leaks, we need a fracking moratorium,” said Councilman Koretz.

fracking-calif-map

The moratorium was met with applause. Liz Crosson, executive director of Los Angeles Waterkeeper said, “While state oil and gas regulators drag their feet on enforcing existing rules and taking adequate precaution for the health of our communities, rivers and ocean, L.A. residents suffer from what is already occurring at the nation’s largest urban oil field and in communities throughout the city,”. She further stated, “We don’t know all of the chemicals oil companies are exposing us to when they frack in our neighborhoods, but we know enough to know we don’t want them in our air or in our water.”

There will now be an attempt to introduce a ban on USGE and related activities across the state of California.

***

References

1) Reyes, E. (2014). L.A. City Council takes step toward fracking ban. Available: http://www.latimes.com/science/la-me-0301-fracking-ban-20140301,0,6285538.story#axzz2xCYvuYPq. Last accessed 27/03/2014.

2) Russia Today. (2014). Los Angeles becomes largest US city to prohibit fracking. Available: http://rt.com/usa/los-angeles-fracking-ban-290/. Last accessed 27/03/2014.

3) Sustainable Business. (2014). Los Angeles Bans Fracking. Available: http://www.sustainablebusiness.com/index.cfm/go/news.display/id/25555. Last accessed 27/03/2014.

4) Baker, B. (2014). Los Angeles Passes Fracking Moratorium. Available: http://ecowatch.com/2014/02/28/breaking-los-angeles-passes-fracking-moratorium/. Last accessed 27/04/2014.

Fracking and public health

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.

FFAN

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.

 

SPECIFIC COMMENTS:

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.