"2 + 2 = 0" – How Public Health England whitewashed the potential health effects of shale gas on public health
Public Health England's report, Review of the Potential Public Health Impacts of Exposures to Chemical and Radioactive Pollutants as a Result of Shale Gas Extraction – draft for comment
Published in 'The Ecologist', 6th May 2014, under the title, "Shale gas and public health – the whitewash exposed"
Note: This article is a review of my recent, 95 page critical review of PHE's report; a longer and more extensively referenced summary of that report is available in the ecolonomics journal.
Last October, Public Health England (PHE) released their "draft" report on the health impacts of shale gas. They looked at all the evidence on the likely effects of shale gas extraction on public health – evidence of hazardous environmental impacts, gender-bending chemicals disrupting our metabolism, and of toxic and radioactive contamination of the air, soil and water – and concluded that –
Public Health England anticipates a low risk to public health from direct releases of chemicals and radioactive material if shale gas extraction is properly operated and regulated.
The difficulty for PHE is that there is no rational way in which this conclusion could be drawn from the evidence they reviewed in their report. As stated in an editorial in the British Medical Journal last month –
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 the literature.
If you want to understand how this conclusion was reached, you have to look at how Public Health England used a selective method, and even more selective quoting. For example, in the text of their report they didn't specifically quote:
- The AEA Technology study for the European Commission, that PHE cited six times, which said "The study identified a number of issues as presenting a high risk for people and the environment."; or
- The Chief Medical Officer of New Brunswick's study, cited four times, which said, "Some of the key findings include a …lack of information needed to assess toxicity risks; lack of accurate exposure and health data; lack of standard methods for preventing and mitigating social impacts; lack of health status studies before and during gas development; and a lack of systematic health impact assessments."; or
- A Colorado School of Public Health study, cited three times, which said, "The Human Health Risk Assessment used information from a variety of sources to conclude that natural gas processes release chemicals that are known to impact health; chemicals emitted into the air from natural gas processes are more likely to impact health than chemicals released into the water or the soil"; and
- A US Environmental Protection Agency report which was cited six times, even though it said, "At this time, the EPA has not made any judgement about the extent of exposure to these chemicals when used in hydraulic fracturing…";
- PHE didn't even bother to include the United Nations study which stated, "Hydrologic fracking may result in unavoidable environmental impacts even if unconventional gas is extracted properly, and more so if done inadequately."
To produce their review, the Public Health England staff gathered all the evidence they could find on the health implications of shale gas, available up until the end of December 2012. The draft report would not be produced until nearly a year later, so why select such an early cut-off? Practically speaking, it excludes a lot of recent – and for the most part highly critical – research on the health impacts of shale gas.
The way PHE went about their review, it almost appears that they were trying to avoid considering any recent research on the issue of unconventional oil and gas. For example, if we look at one of the leading databases of peer-reviewed research on public health – Pubmed – and search for papers containing the term "shale gas":
- In 2010 there were 0 results;
- In 2011 there were 10 results;
- In 2012, the year of PHE's cut-off, there were 15;
- In 2013, the year after the cut-off, there were 52; and
- Just in the first four months of 2014 there have been 39 – more than 2011 and 2012 put together.
To be fair, PHE did consider a number of papers from 2013. They listed their 'sources' for the review in chapter 12, most of which were from 2011/12 and before. Then, in chapter 13, they listed a whole load of papers, mostly from 2013, which, according to the introductory paragraph, "have been reviewed and are not considered to affect the conclusions of the draft report."
A few days after PHE launched their "draft for comment" report I spent a long train journey picking over the document. Call me naive, but if a report says "draft for comment" on its front cover, then I expect that its authors are inviting "comments on the draft". In the event PHE specifically excluded the receipt of comments on what they had written.
Instead PHE sought "the submission of additional relevant articles from the scientific literature for consideration if these have not been considered in the report or identified below". And by "below" they meant the list of fifty "rejected" papers in chapter 13, which included some of the latest research highly critical of the environmental impacts of unconventional oil and gas development.
That creates a problem for PHE. As a signatory to the United Nations Economic Commission for Europe's Aarhus Convention, the UK Government –
…shall endeavour to ensure that officials and authorities assist and provide guidance to the public in seeking access to information, in facilitating participation in decision-making and in seeking access to justice in environmental matters.
By failing to consult the public on the substance of the report, Public Health England, on behalf of the Department of Health, have arguably violated the public's rights under the Aarhus Convention. As a result, by infringing our civil rights, PHE have left all Government decisions on the public health and shale gas open to legal challenge.
However, that's possibly the least of their worries! It's their impartiality which is open to question.
In order to demonstrate their claim that the risks are low if, "shale gas extraction is properly operated and regulated", they have to show – as they outlined in their report – that the process over here will not be plagued by the same politically-motivated regulatory failings seen in the USA, Canada or Australia. Yet again, there is no proof of this.
It's just the opposite in fact. And I don't just mean Lord Browne doing his "Superman act" when he walks into a broom cupboard at the Cabinet Office as a Government minister, to emerge moments later at the Chairman of Cuadrilla. We should also consider:
In January 2014, in response to a Greenpeace freedom of information request, the Department of Energy and Climate Change released a wad of emails between DECC officials and UK gas companies. One of those emails was from Centrica to the Office for Unconventional Oil and Gas, and stated –
Our polling shows that academics are the most trusted sources of information to the public so we are looking at ways to work with the academic community to present the scientific facts around shale.
What are these "scientific facts"?
Unfortunately I don't have the space here to talk about the recent studies on birth defects, flaws in air pollution monitoring and how that underestimates impacts on health, the evidence for the importance of climate change as a public health issue, the emission of neurotoxins and hazardous solvents, previously unknown fugitive emissions of methane and toxic gases, or the pollution of rivers in the USA with shale gas effluent, which makes their sediments eight times more radioactive than the regulatory guidelines for beta radiation (read the summary of my recent report to discover more).
Certainly, you're not going to here these "facts" from the Government, or the industry – nor the public body whom our taxes pay to assess these impacts, Public Health England. Instead, I'll leave you with the decision of the House of Lords judgement on what constitutes "bias in public office" –
The question is whether the fair-minded and informed observer, having considered the facts, would conclude that there was a real possibility that the tribunal was biased.
As someone who has spent a lot of time looking at unconventional gas for the last five years, arguably much of the Government's current work is factually biased. And Public Health England's report, if you read the studies on which is was based, and then reads its conclusions, is also biased. PHE's report, which arguably has infringed our civil rights and their own codes of practice, amounts to scientific misconduct – and as such it does not function to protect our public health and well-being.
- Review of the Potential Public Health Impacts of Exposures to Chemical and Radioactive Pollutants as a Result of Shale Gas Extraction, A. Kibble et. al, Centre for Radiation, Chemical and Environmental Hazards, Public Health England, October 2013 – http://www.fraw.org.uk/files/extreme/phe_2013.pdf
- Human health risk assessment of air emissions from development of unconventional natural gas resources, Lisa M. McKenzie, et. al., Science of The Total Environment, vol.1 pp.79-87, March 2012 – http://www.fraw.org.uk/files/extreme/mckenzie_2012.pdf
- Natural Gas Operations from a Public Health Perspective, Theo Colborn et. al., Human and Ecological Risk Assessment, vol.17 no.5 pp.1039-1056, 20th September 2011 – http://www.fraw.org.uk/files/extreme/colborn_2011.pdf
- Assessment of Effluent Contaminants from Three Facilities Discharging Marcellus Shale Wastewater to Surface Waters in Pennsylvania, Kyle J. Ferrar et. al., 4th March 2013 – http://www.fraw.org.uk/files/extreme/ferrar_michanowicz_2013.pdf
- Public Health England's draft report on shale gas extraction: Mistaking best practices for actual practices, Adam Law et. al., British Medical Journal, vol.348, 17th April 2014 – http://www.bmj.com/content/348/bmj.g2728
- Support to the identification of potential risks for the environment and human health arising from hydrocarbons operations involving hydraulic fracturing in Europe, Mark Broomfield, AEA Technology, 10th August 2012 – http://www.fraw.org.uk/files/extreme/aeat_2012.pdf
- Chief Medical Officer of Health's Recommendations Concerning Shale Gas Development in New Brunswick, Office of the Chief Medical Officer of Health, New Brunswick Department of Health, September 2012 – http://www.fraw.org.uk/files/extreme/new_brunswick_2012.pdf
- Health Impact Assessment for Battlement Mesa, Garfield County Colorado (2nd draft), Roxana Witter et. al., Colorado School of Public Health, University of Colorado Denver, February 2011 – http://www.garfield-county.com/environmental-health/battlement-mesa-health-impact-assessment-draft2.aspx
- Study of the Potential Impacts of Hydraulic Fracturing on Drinking Water Resources ‐ Progress Report, United States Environmental Protection Agency, December 2012 – http://www2.epa.gov/sites/production/files/documents/hf-report20121214.pdf
- Gas fracking: Can we safely squeeze the rocks?, Pascal Peduzzi, Ruth Harding, UNEP, November 2012 – http://www.fraw.org.uk/files/extreme/unep_geas_2012.pdf
- Pubmed – http://www.ncbi.nlm.nih.gov/pubmed
- The Aarhus Convention: An Implementation Guide (Second Edition), United Nations Economic Commission for Europe, April 2013 – http://www.fraw.org.uk/files/ukgov/unece_2013.pdf
- Challenges of Unconventional Shale Gas Development: So What's the Rush, Bernard D. Goldstein, Elizabeth Ferrell Bjerke, Jill Kriesky, Notre Dame Journal Of Law, Ethics & Public Policy, vol.27 no.1, 13th April 2013 – http://www.fraw.org.uk/files/extreme/goldstein_bjerke_2013.pdf
- Air quality in the Industrial Heartland of Alberta, Canada and potential impacts on human health, Isobel J. Simpson et. al., Atmospheric Environment, vol.81 pp.702-709, December 2013 – http://fraw/files/extreme/simpson_2013.pdf
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- Guardian On-line: Owen Paterson held urgent meeting for fracking boss, documents show, Friday 21st March 2014 – http://www.theguardian.com/environment/2014/mar/21/owen-paterson-urgent-meeting-fracking-cuadrilla-lord-browne
- Section 4, Investing in Britain's future, Cm8669, HM Treasury, June 2013 – https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/209279/PU1524_IUK_new_template.pdf
- Guardian On-line: Air pollution monitoring stations face closure as government looks to cut costs, Thursday 22nd August 2013 – http://www.theguardian.com/environment/2013/aug/22/air-pollution-monitoring-stations-shut
- Review of Local Air Quality Management in England, Department for the Environment, Food and Rural Affairs, July 2013 – https://consult.defra.gov.uk/communications/https-consult-defra-gov-uk-laqm_review
- "Behind every picture lies a story" – statistical reality versus PR-hype within the political project of unconventional gas in Britain, Paul Mobbs, Mobbs' Environmental Investigations, 25th July 2013 – http://www.fraw.org.uk/mei/musings/2013/20130725-behind_every_picture_lies_a_story.html
- Guardian On-line: Emails reveal UK helped shale gas industry manage fracking opposition, Friday 17th January 2014 – http://www.theguardian.com/environment/2014/jan/17/emails-uk-shale-gas-fracking-opposition
- Onshore oil and gas exploratory operations: technical guidance – Consultation Draft, Environment Agency, August 2013 – https://consult.environment-agency.gov.uk/file/2582905
- Planning practice guidance for onshore oil and gas, Department for Communities and Local Government, July 2013 – https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/224238/Planning_practice_guidance_for_onshore_oil_and_gas.pdf
- Harnessing the potential of the UK's natural resources: a fiscal regime for shale gas, HM Treasury, December 2013 – https://www.gov.uk/government/consultations/harnessing-the-potential-of-the-uks-natural-resources-a-fiscal-regime-for-shale-gas/harnessing-the-potential-of-the-uks-natural-resources-a-fiscal-regime-for-shale-gas
- Local councils to receive millions in business rates from shale gas developments, Prime Ministers Office, 13th January 2014 – https://www.gov.uk/government/news/local-councils-to-receive-millions-in-business-rates-from-shale-gas-developments
- Guardian On-line: UK defeats European bid for fracking regulations, Tuesday 14th January 2014 – http://www.theguardian.com/environment/2014/jan/14/uk-defeats-european-bid-fracking-regulations
- A critical review of Public Health England's report, "Review of the Potential Public Health Impacts of Exposures to Chemical and Radioactive Pollutants as a Result of Shale Gas Extraction – draft for comment, Paul Mobbs, Mobbs' Environmental Investigations, April 2014 – http://www.fraw.org.uk/mei/archive/phe_shale_gas_and_health_report-critical_analysis.pdf
- Correspondence and meetings between the Office of Unconventional Gas and Oil, UKOOG, Centrica and IGas, DECC, 15th January 2014 – https://www.gov.uk/government/publications/correspondence-and-meetings-between-the-office-of-unconventional-gas-and-oil-ukoog-centrica-and-igas
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- A Human Health Perspective On Climate Change, Environmental Health Perspectives/National Institute of Environmental Health Sciences, US Centers for Disease Control, 2010 – http://www.cdc.gov/climateandhealth/pubs/HHCC_Final_508.pdf
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- Maternal Exposure to Ambient Levels of Benzene and Neural Tube Defects among Offspring: Texas, 1999-2004, Philip J. Lupo et. al., Environmental Health Perspectives, vol.119 no.3 pp.397-402, March 2011 – http://www.fraw.org.uk/files/extreme/lupo_2010.pdf
- Toward a better understanding and quantification of methane emissions from shale gas development, Dana R. Caulton et. al., PNAS (early edition), 14th April 2014 – http://www.fraw.org.uk/files/extreme/caulton_2014.pdf
- Air Impacts of Increased Natural Gas Acquisition, Processing, and Use: A Critical Review, Christopher W. Moore et. al., Science of the Total Environment (undated preprint), March 2014 – http://www.fraw.org.uk/files/extreme/moore_2014.pdf
- Impacts of Shale Gas Wastewater Disposal on Water Quality in Western Pennsylvania, Nathaniel R. Warner et. al., Environmental Science and Technology, vol.47 no.20 pp.11849-11857, 2nd October 2013 – http://www.fraw.org.uk/files/extreme/warner_2013.pdf
- A Critical Review of the Risks to Water Resources from Unconventional Shale Gas Development and Hydraulic Fracturing in the United States, Avner Vengosh et. al., Environmental Science and Technology (preprint), 7th March 2014 – http://www.fraw.org.uk/files/extreme/vengosh_2014.pdf
- Analysis of Reserve Pit Sludge From Unconventional Natural Gas Hydraulic Fracturing and Drilling Operations for the Presence of Technologically Enhanced Naturally Occurring Radioactive Material (TENORM), Alisa L. Rich, Ernest C. Crosby, New Solutions, vol.23 no.1 pp.117-135, March 2013 – http://www.fraw.org.uk/files/extreme/rich_2013.pdf
- Extreme energy and public health: How the Government engineered the denial of the health impacts of unconventional oil and gas, ecolonomics journal no.15, Paul Mobbs, Mobbs' Environmental Investigations, 5th May 2014 – http://www.fraw.org.uk/mei/ecolonomics/2014/ecolonomics_15-extreme_energy_and_public_health.shtml
- Porter v. Magill  UKHL 67 – http://www.publications.parliament.uk/pa/ld200102/ldjudgmt/jd011213/magill-1.htm