Public Health England recently published a DRAFT report, Review of the Potential Public Health Impacts of Exposures to Chemical and Radioactive Pollutants as a Result of Shale Gas Extraction. As there is no commercial shale gas extraction in the UK, the draft report looks at information from countries where it is taking place and concludes that the risk is low. You can download the report here.
A number of community groups Residents Action on Fylde Fracking (RAFF); Ribble Estuary Against Fracking (REAF); Frack Free Greater Manchester; Central Lancashire Friends of the Earth; and South Lakes Action on Climate Change have published a joint response:
Review of the Potential Public Health Impacts of Exposures to Chemical and Radioactive Pollutants as a Result of Shale Gas Extraction, Public Health England
– A response from community groups in North West England
The report claims that ‘a range of stakeholders’ (p.4) have been consulted as part of the review. However it is clear that arguably the most significant stakeholders in any consideration of the human health impacts of shale gas extraction – directly affected communities – have been excluded from the process. No effort appears to have been made to seek views of residents living near to unconventional gas sites, nor has any evidence been sought into health effects of any drilled or fractured wells including those drilled and fracked in Lancashire.
We are alarmed that the report only considers shale gas and not coal bed methane, which poses different yet as serious risks to health. We are also concerned that there has been no consideration of occupational health risks, and although we find the job creation claims of the industry highly questionable, if they were to be taken at face value then there would be a large workforce at risk.
We are extremely concerned at the conclusions reached in this report that health impacts are ‘low risk’ despite the authors conceding there is a lack of data. We ask, given the serious nature of potential impacts on the environment and health and the lack of data, why a precautionary approach is not recommended?
The approach of UK government agencies is in stark contrast to their European counterparts – for example Germany’s Environment Agency has reviewed similar evidence and concluded that due to lack of data the precautionary principle should be adhered to and a moratorium is in place.
Furthermore, the PHE report cites the European Commission report conclusion that ‘the potential risks to human health and the environment from releases to air across all phases of development was high’ (p.8). We ask why has Public Health England, when looking at similar evidence, come to such a different conclusion to the European Commission?
We would also like to highlight numerous passages in the report which together leave us baffled as to why the authors have come to the conclusion that there is ‘low risk’ to public health:
- ‘the available evidence indicates that a large number of VOCs can be emitted… and that these emissions can impact on local air quality’ (p.12)
- ‘the cumulative impact of a number of well pads may be locally and regionally quite significant’ (p.12) – incidentally we note that a report from the Institute of Directors commissioned by Cuadrilla refers to 4000 wells in Lancashire alone.
- ‘radon de-gassing from the flowback water … may lead to elevated radon levels in the proximity of the wellhead’ (p.16)
- ‘flowback water which may be produced in significant quantities, and (depending on the geology) contain significant levels of NORM’ (p.21)
- ‘disposal of flowback waste during shale gas extraction processes may also present potential public health risks’ (p.21)
- ’reviewed 43 incidents of environmental pollution related to natural gas operations (including shale) and found that almost 50% were related to the contamination of groundwater as a result of drilling operations’ (p.23)
- ‘contamination of Ohio river tributaries with barium, strontium and bromide has been reported… following discharge of flowback water after processing at water treatment works’ (p.23)
- ‘the exact composition of fracking fluids proposed for use in the UK is unclear’ (p.27)
- ‘Colborn et al reviewed the toxicity of 353 chemicals … and found that 75% of the chemicals reported could affect dermal, ocular, respiratory and gastrointestinal systems… 40-50 of the chemicals could affect the nervous or immune systems… 37% of the chemicals could affect the nervous or immune systems… 25% were potential carcinogens or mutagens’ (p.29)
We strongly reject the Public Health England assertion that ‘in the UK strict regulatory requirements governing onshore oil and gas exploration already exist and shale gas extraction will be regulated within this framework’ (p.5) and point out that there are no industry-specific regulations, the system relies on a large degree of self-monitoring, the regulatory and monitoring process has so far proved highly inadequate (see comments on Cuadrilla in Lancashire below) and the regulatory bodies are facing major cuts to budget and workforce.
Notwithstanding the limitations and lack of confidence in the current regulatory system, we note the UN Environment Program’s conclusion that ‘fracking may result in unavoidable environmental impacts even if [gas] is extracted properly’ (UNEP, 2012) and strongly assert that there will be high health risks regardless of regulation due to the nature of the operations and risks involved.
Cuadrilla’s practices so far in Lancashire have given us no confidence in the safety of operations, nor the adequacy of the regulatory system. The only fracking operation so far in the UK at Preese Hall, Weeton, triggered earth tremors that caused deformation of the well casing, increasing the risk of gas, fracking fluid or flowback water leaking from the well. This was not reported by Cuadrilla to the Department for Energy and Climate Change for six months. Another well that was being drilled by Cuadrilla at Anna’s Road near St Annes had to be abandoned after a test instrument got stuck in the well. Cuadrilla also breached its planning conditions at the Becconsall site in West Lancashire, drilling into the wintering bird period, which did not resulted in any enforcement action by the local authority.
Residents in Salford are also alarmed by IGas plans to drill for shale gas (approximately 3000m deep) not coal bed methane (at approximately 1000m) which their permission is for, and the lack of action from the local authority. It is clear that the health implications and environmental considerations of an exploratory shale gas well would not have been taken into account in the planning permission process.
Regarding air pollution, the report says that emissions ‘will need to be put into the context of the existing background level of ambient air pollution’ (p 9) and we would like to ask what PHE’s view of unconventional gas extraction would be in areas that already have high air pollution – would you recommend on public health grounds that development should not take place? What criteria would be used and what are the considerations with regard to our legal obligations to protect public health under the EU Air Quality Directive? For example, residents (and schoolchildren) nearby the Barton Moss site in Salford already suffer from poor air quality from the nearby motorway, other major roads, and an aerodrome (eg 260 days exceeded NO2 levels of > 40μgm-3 in 2012 at a local monitoring site). Do you view this as a suitable site for unconventional gas extraction considering the vulnerability of communities there?
We note that although the report warns that ‘caution is required when extrapolating experiences in other countries to the UK’ (p.iii) it fails to mention the significant difference between the UK and the USA, Australia and Canada where the shale gas industry is more developed – that we have a vastly higher population density, and hence much amplified health risks for neighbouring communities. The report notes a study which found cancer risks are ‘elevated for those residents living within half a mile of the gas wells during well completion’ (p. 10) – what evidence has been collected by PHE or other agencies of the receptors (eg residents, schools) that would be exposed to this heightened risk? Has vulnerability of people to this risk been mapped and if not, why not?
We also note that PHE state ‘comprehensive air quality monitoring in needed… and should be a critical part of any risk assessment’ and as an example point to the coal bed methane application documents and decision process at Barton Moss, Salford, where air quality considerations were absent.
There has also been no monitoring of air quality or health impacts at any of the drill sites including the Preese Hall well in Weeton, Lancashire, which was fracked in 2011. We note that no attempt was made to gather fist-hand evidence for this report. Although no official data exists, members of Residents Action on Fylde Fracking (RAFF) had been made aware of health effects in local residents including breathing difficulties, during and shortly after fracking at Preese Hall – this is via emails RAFF had received from people saying that asthma cases have increased in the area, with one saying their doctor was looking into it, and door-to-door conversations.
Water and soil pollution
On key pollutants, we note the reference to ‘high levels of sodium, chloride, bromide and iron, as well as elevated values of lead, magnesium, zinc, chromium and arsenic’ (p.22) in the flowback water at Preese Hall, Lancashire, and ask what are the health risks from such elevated levels as this appears absent from the PHE commentary? What are the public health risks of transportation of the large volumes of toxic flowback water? Ourunderstanding is that this may involve very large distances due to a lack of authorised waste treatment facilities to deal with the waste.
The report refers to ‘the risk of stored fracking fluids and flowback water entering nearby surface water bodies or infiltrating into the soil and near-surface ground water’ (p.21) and we would like to highlight the vulnerability of agricultural land and food production. Much unconventional gas extraction would be taking place in or nearby farmland, including the Becconsall site in West Lancashire where some of the most fertile agricultural land in the UK is located.
Planning permission process
The report states that ‘we would expect local public health professionals to play an active role during planning applications’ (p. 6) and would like to point out that public health agencies have not been involved in all shale gas or coal bed methane planning applications so far in Lancashire and Greater Manchester – considering the low number of active sites up to now we find that unacceptable, and also worrying in terms of the capacity of public health agencies to constructively engage when we have the health implications of thousands of wells to deal with.
Similarly we note ‘it would be expected that the presence of private water supplies as well as overlying aquifers to be a material consideration in approving shale gas operations’ (p.25) and would like to highlight the lack of consultation with and consideration of residents with private boreholes in the case of Cuadrilla in Lancashire. A Lancashire landowner whose domestic water supply is from a well source has made the following observation regarding risk to groundwater:
“After the events at the Preese Hall site, I wrote to the Environment Agency over concerns of possible contamination to my private water supply from shale gas activities. They replied in February 2012 informing me that they had assessed the drilling technique (from the surface to the shale) and from that study there is ‘no risk to the ground water’ and no risk of flowback fluid affecting my water supply.
Later the Department of Energy and Climate Change Report (Preese Hall Shale Gas Fracturing Review and Recommendations for Induced Seismic Monitoring, April 2012) on events at the Preese Hall site and the technical failings announced by Cuadrilla at the Anna’s Road site clearly highlights the possibility of the formation of pathways from source to receptor being created by well integrity failures and induced or naturally occurring fault systems along which gas and fluid could migrate.
It is a concern that the EA, as a high profile regulatory body, have not since updated their statement to me regarding these findings and the potential risk to my well”.
Clarifications and corrections
Further, we have some specific clarifications regarding the draft PHE report:
- The report states that ‘Gas exploration techniques, using directional drilling and fracking, are not new and have been used across the oil and gas industry (including in the UK) for decades’ (p.4) – this is misleading. The scale and intensity of high volume hydraulic fracturing for unconventional gas extraction as practiced today is in its infancy and at best the technology is a decade old. The long-term implications are yet to be seen.
- A reference to ‘hydraulic fracturing’ at the Elswick well in Lancashire is made (p.6) which we think could be misleading. Elswick is a conventional gas well, it is not an unconventional hydraulically fractured shale gas well, so is irrelevant to this study.
- Reference to private boreholes (p.24) seems dismissive of potential risks and monitoring and we would like to highlight the large numbers of private boreholes in the UK and ask have PHE considered the number of households near unconventional gas resources whose boreholes could be at risk?
- ‘there are limited data on fracking fluid composition from UK operations’(p.28) – we would like to ask why chemicals used in drilling muds and particularly hazardous chemicals used in coal bed methane operations (see material data safety sheets for hazardous chemicals to be used at Barton Moss) have not been included in this report?
Finally, we would like to express again our strong rejection that the UK has a strong regulatory framework and make clear our lack of confidence, based on experience, in the competence of the planning and regulatory authorities. We also state again our dismay at the conclusion PHE have come to regarding risk to public health, and regard that it has no logical basis given the evidence, and indeed gaps in data, that exist. We are therefore concerned that the conclusions of this report may be politically driven rather than evidence-based.
- This is a joint response from:
- Residents Action on Fylde Fracking
- Ribble Estuary Against Fracking
- Frack Free Greater Manchester
- Central Lancashire Friends of the Earth
- South Lakes Action on Climate Change