The Environmental Health Association of Nova Scotia has submitted a detailed brief to the Nova Scotia Review of Hydraulic Fracturing, outlining concerns about health risks of the unconventional natural gas industry, including fracking.
The brief starts by looking at points of consensus in the evidence, including the need to evaluate the full impacts of the HVHF industry, the fact that large amounts of toxic substances are used or generated, that routes of exposure exist, and that large numbers of people can be affected, including vulnerable populations. The literature also recognizes a need for substantially more study, and that existing information gaps make it difficult to accurately assess the extent of risk, and how risk could be managed.
Emerging evidence, but no definitive answers
Three years ago, when EHANS made a submission proposing that the scope of the in-house review of hydraulic fracturing include heath, we documented a wide range of health concerns that were emerging, and argued that the review needed to consider those issues. At that time, there was little peer-reviewed evidence of health risks, but information showed a pattern of newly developed health problems in states and provinces where shale gas development was taking place.
The emerging information, though “unproven,” gave a reasonable basis for concern that health risks could be serious and widespread, and that there was reason to proceed with caution in allowing HVHF.
In the past three years, human health has become widely recognized as a major issue to be addressed in assessing the impacts of unconventional natural gas development (UGD)including high volume hydraulic fracturing. New peer reviewed articles have measured and evaluated air emissions in gas production areas, potential routes of exposure from water and air and potential health impacts associated with contaminants released through unconventional gas operations. These studies provide ever-increasing evidence of potential for a wide range of risks to health, and health impacts for people living in UGD areas. Our concerns remain, and have been strengthened by the evidence of the past three years. Other health organizations in the US and Canada share these concerns.
Focal points of EHANS submission
Because there now exist a number of excellent summaries of the health issues relating to hydraulic fracturing for unconventional gas, EHANS’ focus in this submission will not be to summarize all the evidence.
Summaries of the evidence and gaps in evidence relating to hydraulic fracturing and public health may be found in articles by Adgate et al (Environmental Science and Technology, 2014), Finkel and Hayes (Public Health), the position paper of the American Public Health Association (2012) and the report issued by Dr. Eilish Cleary, Chief Medical Officer of Health for New Brunswick (2013) among others.
Our approach in this submission is rather to:
- Direct the review’s attention to particular science-based resources that we believe provide excellent overview summaries of potential health risks and impacts as well as studies of specific risks arising from hydraulic fracturing and unconventional natural gas development (UGD)
- Sum up key points of consensus in the literature.
- Highlight key issues and approaches that we believe this review should take into account in reviewing and making recommendations on high volume hydraulic fracturing in order to address protection of public health as well as worker health and safety.
The brief investigates a number of issues including the need to consider the health impacts all aspects of the HVHF industry, including but not limited to fracking, and the need to consider short, medium and long term impacts, as well as cumulative, aggregate and peak impacts.
The brief also highlights ways in which traditional regulatory approaches are not a good fit for this industry at this time, including the fact that best practices cannot be assumed to be health protective, given the considerable gaps in scientific understanding of the issue.
The brief notes a strong consensus in the literature to slow down and prevent harm.
The brief concludes: First, do no harm
We are encouraged that the present government made the election commitment that “Unless we can definitively determine that fracking will not harm our resources, our environment, or the general public in any way, the extraction procedure should be prohibited.”
Bearing in mind the government’s stated intention, and the defined mandate of the review, EHANS urges the panel to adopt the approach set out in the Maryland HIA, and “focus on those exposures and conditions that either would not occur in the absence of, or would be increased as a result of the HVHF industry.” A true understanding of the health impacts, and most other potential impacts of hydraulic fracturing requires adopting a broad perspective.
EHANS’ understanding of the literature is that we are far from being able to definitively determine that hydraulic fracturing can be carried out with lack of harm in the area of public health. Even using the more limited question presently posed by the panel, we are far from being able to definitively determine that this practice can be done safely, if safety is understood as protection against harm from impacts arising from this operation.
For all of these reasons, EHANS urges the panel to recommend a continued moratorium on hydraulic fracturing for UG for a period of at least 10 years, until valid evidence exists as to whether, and how, the full industrial impacts of the hydraulic fracturing process and industry can be carried out safely and without harm to public health, or the environment on which our health relies.
Read the full submission
In brief on YouTube: Health Impacts summary at Speak-out Against Fracking, Tatamagouche, NS
The deadline for public submission of written evidence t the HF Review is April 30. Additional information is available on the HF Review website, http://www.cbu.ca/hfstudy/project-status.