Concerned Health Professionals of Ireland (CHPI) response to the EPA Unconventional Gas Exploration and Extraction (UGEE) Joint Research Programme Integrated Synthesis Report

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The question was “Can UGEE projects/operations be carried out in the island of Ireland whilst also protecting the environment and human health?” This question has already been answered 900 times[1], by experts. The answer is no.

So why did the Irish Government spend €1 million asking an unqualified group to answer this question again? An unqualified group with a vested interest no less.

The EPA’s Unconventional Gas Exploration and Extraction (UGEE) Joint Research Programme steering group altered the meaning of this question before embarking on the project. CDM Smith defined Health and Health Impacts in such a way as to make both concepts virtually meaningless, they proceeded to neglect the investigation of key risk factors for health. Traffic accidents, occupational injuries, suicide rates, birth defects and crime levels are all shown to increase in fracked communities.  None of these was examined; neither did the UGEE JRP examine the interrelationships between these risk factors.

The key concerns of CHPI are the risks and harms to health from fracking. We know from the Concerned Health Professionals of New York (CHPNY) and the Physicians for Social Responsibility (PSR)[1] that the risks include;

  1. Air pollution
  2. Water contamination
  3. Inherent engineering problems that worsen with time
  4. Radioactive releases
  5. Occupational health and safety hazards
  6. Public Health Effects – Documented indicators variously include increased rates of hospitalization, ambulance calls, emergency room visits, self-reported respiratory and skin problems, motor vehicle fatalities, trauma, drug abuse, infant mortality, congenital heart defects, and low birth weight.
  7. Noise pollution, light pollution and stress
  8. Earthquakes and seismic activity
  9. Abandoned and active oil and natural gas wells (as pathways for gas and fluid migration)
  10. Flood risks
  11. Threats to agriculture and soil quality
  12. Threats from fracking infrastructure
  13. Threats to the climate system
  14. Inaccurate jobs claims, increased crime rates, threats to property value and mortgages and local government burden.

In 2011, when fracking came to the attention of the public and the public representatives, the then Minister for Communications, Energy and Natural Resources – Pat Rabbitte responded to public concern about fracking.

“As Minister, I have to take such concerns seriously. I will see how we can get independent sources that do not have any vested interest in the outcome to examine whether there is a reason for concern in this respect.

Instead of an independent source, the steering group for this study – which included the EPA – commissioned the oil and gas industry, in the guise of CDM Smith to oversee this report, the other companies involved – AMEC Foster Wheeler and Philip Lee Solicitors – have strong connections to the oil and gas industry.

There were a number of problems with this report from the beginning. It took sustained public pressure to get the EPA to consult on the terms of reference. The consultation process was shown to be an exercise in ticking boxes – despite 1250 out of 1350 responses requesting that Public Health be put at the centre of this report – in the final terms of reference, the issue of health was only included as an ‘add-on’.

In its post-consultation terms of reference, the UGEE JRP defines human health in an extremely limited way.

“The wording “human/public health” throughout this document refers specifically and is limited to potential health impacts deriving from impacts on environmental media (e.g. exposure to chemicals, vibration, light, noise, and pollution of environmental media (i.e. soils, air & water). In addition, the wording “protecting human health” refers and is limited to preventing environmental factors from degrading human health.” (page 6)

It also limits its definition of impacts on human health as follows;

 4.2.4. Impacts on Human Health

In the EPA Acts (1992, 2003), environmental pollution is defined as: “The direct or indirect introduction to an environmental medium, as a result of human activity, of substances, heat or noise which may be harmful to human health or the quality of the environment,…”. (ibid)

The request to have a Public Health expert on the steering committee was responded to with the appointment of Andrew Sulley, an Environmental Health Officer with the HSE, whose area of expertise is listed as Environmental Impact Assessment (EIA) and Environmental Licensing. This appointment did not in any way allay the fears of the consultation participants, but it did allow the group to list the Health Service Executive as part of the steering committee.

Since 2013, when this EPA report was commissioned, there have been over 750 peer reviewed studies conducted which show that this industry has significant detrimental effects on environmental, socioeconomic, and public health.

Notwithstanding the mounting peer-reviewed evidence, the Irish government commissioned a study from a consortium with no human health experts aboard, to undertake a study. Again, this in spite of 1,250 public submissions urging the EPA to do so.

This study unsurprisingly concluded “that UGEE projects/operations comprise multiple activities over a period of up to 25 years, which have the potential to impact both human health and the environment” (page ix).

The application of the industry principle of ‘as low a risk as possible’ (ALARP), as opposed to the health sector standard – the precautionary principle, is evident in every line of this report. For example; while the writers admit that UGEE projects/operations can result in the emission of some pollutants that, if present in high enough concentrations, are associated with possible adverse health effects through direct external contact or through inhalation” (page xvi).

This is followed up with “Very few, if any, methodologically rigorous studies have examined the potential cause–effect relationships of UGEE activities and actual health outcomes in hazard analyses, in terms of exposure pathways and the health outcomes related to air emissions” (page xvi). This suggests an orientation towards the acceptance of evidence of harm and away from acceptance of evidence of risk, an ideology that is repugnant to Health Professionals.

A further, more worrying, example of this appears in the summary of the three main impacts which the report admits “cannot be discounted by regulatory control and good practice”

The report states

“Gas emissions have been cited by the public as an issue of concern from a human health viewpoint. During active operations, these can be adequately managed by mitigation measures that address the health and safety of the workforce who would have a much higher level of exposure than the general public”(page xxi).

Firstly, there is no good reason to limit the concern of this health impact to the workforce. When one considers that a worker may be exposed for 8-12 hours a day, but a resident is exposed for 24 hours per day. Most importantly, a child or an elderly person cannot be exposed to the same level as a fit working male adult. Secondly, why choose this risk only – the 4th edition of the Compendium of Risks and Harms of Fracking (2016) tells us

 “Drilling and fracking jobs are among the most dangerous jobs in the nation with a fatality rate that is five times the national average and shows no sign of abating. ….An investigation of occupational exposures found high levels of benzene in the urine of wellpad workers, especially those in close proximity to flowback fluid coming up from wells following fracturing activities. Exposure to silica dust, which is definitively linked to silicosis and lung cancer, was singled out by the National Institute for Occupational Safety and Health as a particular threat to workers in fracking operations where silica sand is used.”

Some space is given to the subject of Health Impact Assessments (HIAs) in this report. HIAs are conducted alongside the developing industry; they are a tool for the mitigation of the effects of an activity or policy. A review of the evidence on the health impacts precludes the need for an HIA, on the basis that the evidence suggests that the industry should not be licenced by a State that wants to protect its citizens.

To conclude, when the 1,250 responses to the EPA consultation on the Terms of Reference of this project, requested that Public Health be put at the centre of this report, what was being asked was that the available evidence on the impacts of fracking on health would be reviewed so that the EPA could advise the Government on whether or not it was safe to introduce fracking in Ireland, thereby answering Minister Rabbitte’s original question. The investigators had a vested interest in the promotion of fracking and even they were forced to admit that there are impacts from fracking that “cannot be discounted by regulatory control and good practice”. There was no public health expert on the team and therefore the precautionary principle was not applied to the investigation. This project failed to take the Minister’s or the public’s concerns into account when they neglected to address the risks and harms of fracking. Fracking should never be allowed in Ireland.

[1] CHPNY & PSR (2016) Compendium of scientific, medical, and media findings demonstrating risks and harms of fracking (unconventional gas and oil extraction) Fourth edition. (Available from http://concernedhealthny.org/compendium/ ) [Accessed 24.11.2106]

 

 

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