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Shale gas and public health - the whitewash exposed
6th May 2014
Public Health England is guilty of gross scientific misconduct, writes Paul Mobbs, for its apparently deliberate whitewashing of the public health impacts of fracking. But it's all part of a pattern of maladministration that reaches to the heart of government.
PHE's report, which arguably has infringed our civil rights and their own codes of practice, amounts to scientific misconduct.
They looked at all the evidence on the likely effects of shale gas production - usually referred to as 'fracking' - on public health.
After scouring the scientific literature for evidence of hazardous environmental impacts, gender-bending chemicals disrupting our metabolism, and of toxic and radioactive contamination of the air, soil and water, they 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."
Going against the evidence
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."
- 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";
- 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 ... "; and
- 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."
Why such an early cut-off date for evidence gathering?
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.
The 'draft for comment' that excludes comments
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, 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.
Critical science systematically excluded
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."
Government decisions on shale gas and health 'open to challenge'
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 ...
- The Treasury's project to deregulate environmental controls is actively supporting the fast expansion of unconventional oil and gas;
- At the same time the Treasury is forcing cuts to essential environmental services, such as the government's current review of air pollution monitoring ;
- There are high-level political connections  between the unconventional oil and gas operators and the present administration, giving behind-the-scenes access to decision-makers;
- The Environment Agency is being forced to reduce the time taken to issue environmental pollution permits for shale gas to two weeks;
- Local planning authorities have been barred from considering pollution and health issues as part of their planning decisions;
- The Treasury are offering financial inducements, while at the same time cutting budgets, to encourage local authorities to permit shale gas developments in their areas;
- The UK recently blocked new EU environmental assessment regulations  which would have provided evidence on environmental impacts to local decision-makers; and
- There is also an apparent bias in other recent reports on shale gas commissioned by the Government, including - as I argue here - Public Health England's review.
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 write in detail 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.
But you can read the summary of my recent report  to discover more.
Certainly, you're not going to hear 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."
Gross scientific misconduct
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 gross scientific misconduct. As such it undermines the very purpose of PHE's existence - to protect the nation's public health and well-being.
Paul Mobbs is an independent environmental consultant, investigator, author and lecturer. He runs the Free Range Activism website.
- 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.
- Public Health England's draft report on shale gas extraction
BMJ 2014; 348 doi: http://dx.doi.org/10.1136/bmj.g2728, published 17 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
- Owen Paterson held urgent meeting for fracking boss, documents show, Damian Carrington, Guardian On-line, Friday 21st March 2014 - http://www.theguardian.com/environment/2014/mar/21/owen-paterson-urgent-meeting-fracking-cuadrilla-lord-browne
- Air pollution monitoring stations face closure as government looks to cut costs, Rob Edwards, Guardian On-line, Thursday 22nd August 2013 - http://www.theguardian.com/environment/2013/aug/22/air-pollution-monitoring-stations-shut
- "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
- UK defeats European bid for fracking regulations, Damian Carrington, Guardian On-line, Tuesday 14th January 2014 - http://www.theguardian.com/environment/2014/jan/14/uk-defeats-european-bid-fracking-regulations
- 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
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