The Case for a Comprehensive Health Impact Assessment
A thorough investigation of fracking’s impact on human health is desperately needed—and we applaud the Cuomo administration for acknowledging this need. Four years of study and four thousand sGEIS pages have still not answered the three most fundamental questions about hydraulic fracturing in New York State: Will fracking sicken and kill more New Yorkers than it employs? Will the sick and dying have any recourse—other than fleeing their homes and jobs—to protect themselves? And what is the economic cost of that morbidity and mortality?
Case studies and individual reports from other states provide credible evidence of public health risks in communities located near drilling and fracking operations. Although these risks have been acknowledged, no comprehensive assessment has yet been conducted. How many illnesses and deaths are we willing to ignore? Many of the areas currently being drilled are not as densely settled as New York, which is the nation’s third most populous state. Small increases in mortality and disease rates in a state with 19.5 million inhabitants would have much more wide-spread consequences and carry much bigger costs than equivalent effects in, for example, western Wyoming or eastern Utah. Must we see these consequences played out before we take action?
Concerned Health Professionals of NY is convinced that a thorough, well-designed health study, conducted in good faith and inclusive of long-term, cumulative impacts, will reveal many problems. They will be expensive problems, and not all of them will be capable of mitigation through technological fixes. This is an easy prediction to make. Shale gas extraction via horizontal hydraulic fracking is an inherently dangerous activity. Fracking turns solid bedrock into broken shards whose cracks become potential pathways for contamination, some of it radioactive. Broken shale is not reparable by any known technology. Fracking relies upon and releases from the earth large amounts of greenhouse gases and inherently toxic chemicals, including known carcinogens, while also industrializing the natural and built environments of human communities.
Risks to public health from fracking arise from every stage of the gas extraction process—from the clearing of land for well pads to the disposal of toxic wastewater to the radon accompanying the gas that travels through pipelines to people’s homes—and may affect not only disease rates but also the fundamental conditions for human health. For example, with the onset of drilling and fracking operations, a community may experience dramatic increases in noise pollution, light at night, crime, and truck traffic, along with decreases in the availability of locally grown food, affordable housing, and recreational green space for exercise. All of these changes have health consequences. Traffic-related noise pollution alone, for example, demonstrably raises the risk of heart attack and high blood pressure and cognitive deficits in children. Those who are harmed by these activities are rarely those who have chosen to pursue them and who have received any benefit.
The execution of a well-designed, expansive study does not mean simply reviewing the published literature that already exists and zeroing out uncertainties as “no effect” defaults. It means aggressively seeking out an array of data sources and bringing a multi-disciplinary approach to their analysis.
Happily, a comprehensive Health Impact Assessment (HIA) is designed to do just that.
Four hallmark features of a comprehensive HIA make it suited to our current situation in New York: First, its sole purpose is to identify the effects of a proposed activity—in this case, fracking—on the health of a given population and to describe the distribution of those effects within the population. Second, a comprehensive Health Impact Assessment is prospective: it is done in advance of any decision to approve or prohibit the proposed activity. Third, a comprehensive health impact assessment is wide-ranging: it must give special consideration to vulnerable sub-populations (for example, pregnant women, infants, children, and the elderly), and it must analyze not only the causes of illness but also the conditions that affect health. (As identified by the National Academies of Science, these conditions include personal behaviors as well as social and economic factors, the built environment, and the physical environment.) Fourth, a comprehensive Health Impact Assessment is participatory: throughout the process, it includes elements of public participation in the form of hearings, public reviews, meetings, and stakeholder consultations. Concerns suggested by members of potentially affected communities are included in the scope of the study.
In essence, a comprehensive HIA is a formal set of protocols to be used to forecast, and thus avoid, harm. Its protocols were developed by the U.S. Centers for Disease Control and theWorld Health Organization (among others), and they are sanctioned by the National Research Council. A comprehensive HIA is the accepted approach for understanding the health effects of a proposed activity.
The operative word here is comprehensive. This adjective has specific meaning in the world of HIAs. There are several types of HIAs—including the “desktop HIA”—which is little more than a review of the available literature and that requires only a few weeks to complete. Only a comprehensive HIA requires public participation and a quantitative analysis. Quantitative analysis is the difference between saying “lowered air quality may increase slightly the risk of pediatric asthma” and saying “increasing truck traffic on rural roadways by __ percent will increase the background level of ozone in neighboring communities by __ percent and is thus predicted to increase the rate of asthma in New York’s rural children by __ percent, leading to __ number of additional children diagnosed with asthma before age five and __ additional pediatric emergency room visits per year.”
Concerned Health Professionals of NY supports the call for a comprehensive HIA, as strictly defined by our national and international health agencies. A comprehensive HIA is the only tool of public health inquiry into the effects of fracking that we will accept. Concerned Health Professionals of NY will interpret any ad-hoc approach or claim of HIA equivalency as a sign of political expediency and a compromised process. Given the large-scale land use decisions being entertained and the enormous health, economic and environmental implications of our choices, why would we consider using anything but the best possible tool to protect our communities?
We further request that this comprehensive HIA include a formal risk assessment and an economic analysis of the identified health effects. These elements are sometimes included in a comprehensive HIA but are not mandated. We want them—and New Yorkers deserve them—in this HIA.
It is important to note that the goal of any Health Impact Assessment is not to determine whether a project is approved. By definition, an HIA must precede the rollout of a proposed activity, but its results are not necessarily determinative of the decision to roll it out or not. Hence, whatever the findings of a comprehensive HIA, the decision to permit or prohibit fracking in New York State continues to rest with Governor Cuomo.
Key Elements of a Health Impact Assessment of Hydraulic Fracking in New York State
Concerned Health Professionals of NY considers the following elements to be critical, requisite factors for any comprehensive Health Impact Assessment:
1) The SGEIS cannot be finalized until the HIA is finalized.
2) The HIA must be participatory. The public, especially members of targeted communities, must be engaged at every stage of the HIA, including the scoping process.
3) The HIA must be quantitative. In particular, it must apply quantitative techniques to estimate increases in traffic fatalities and injuries, as well as the health effects from noise pollution (linked to cognitive deficits in children; heart attack and increased blood pressure in adults) and air pollution from drill rigs, trucks, condensers, compressors, and flare stacks (linked to heart attack, stroke, cancer, and diabetes among adults; asthma among children; and preterm birth, and reduced birth size among infants.) Protocols for estimating morbidities and mortalities for all these parameters exist.
4) The HIA must consider health risks from cumulative impacts and across the entire life cycle of shale gas extraction and transport. This includes radon exposure from pipelines and in homes and apartments at the point of combustion. This also includes air emissions and noise pollution from condensers and compressor stations. This also includes exposure to radium in fracking wastewater.
5) The HIA must examine the public health consequences of fracking’s socio-economic impacts. These include projected changes in rates of crime, drunk driving, drug arrests, sexual assault, incidence of teenage pregnancy, and sexually transmitted disease. These include loss of rental housing for low-income families. The HIA must include sociological datafrom other states where fracking is already occurring and where an influx of out-of-state money and workers have introduced severe disruptions to social support systems.
6) The HIA must examine the public health consequences of altered land use patterns and land disturbance. Loss of farmland decreases access to fresh, local food. Loss of such access is, in turn, linked to obesity. Land disturbance increases sedimentation of surface streams, which, when subsequently chlorinated for drinking water, increases the burden of exposure to disinfection byproducts. These byproducts include trihalomethanes, exposure to which is linked to colon and bladder cancers.
7) The HIA must focus closely on infants, children, and pregnant women as vulnerable subpopulations. Fracking chemicals and fracking-related air pollutants include numerous reproductive and developmental toxicants. These substances, which have no known safe thresholds of exposure, can, when exposure occurs during prenatal or early life, abort pregnancies or sabotage pathways of child development. Consequences may be life-long.Emerging evidence from Pennsylvania indicates that, for mothers residing close to gas wells, drilling and fracking operations are associated with low birthweight infants and lower scores on tests of newborn responsiveness
8) The HIA must examine occupational health risks to workers. These include, but are not limited to, head injuries, traffic accidents, blunt trauma, silica dust exposure, and chemical exposures. Oil and gas industry workers have an on-the-job fatality rate seven times that of other industries; silica dust exposure is definitively linked to silicosis and lung cancer. With jobs creation as a central argument for the approval of fracking in New York, we need to understand the health and disability risks that come with these jobs. Can these risks be confined to drilling sites?
9) The HIA investigators must aggressively seek out health data from other states and consult with independent experts from multiple disciplines. Medical gag orders and non-disclosure agreements in states such as Pennsylvania must not prevent the gathering of this data, even if subpoenas are required to obtain it.
10) The HIA must examine failure rates of well casings over time. Important questions have been raised within and without the shale gas extraction industry about the ability of cement to withstand the repeated explosions and intense pressures of fracking. Other important questions have been raised about the lifespan of well casings. Cement and steel are not immortal. At what point does their degradation result in gas leaks? These questions must be addressed by the HIA. If well casings do not provide a permanent, unbreachable seal between drinking water aquifers and the volatile hydrocarbons trapped in shale bedrock and mobilized during fracking operations, then irreparable problems may be created now or in the near and distant future.
11) The HIA must assess reports of groundwater contamination in other states where fracking is ongoing. These reports continue to grow in number, and, in some cases,chemical fingerprinting has linked this contamination to gas fracking. Recent confirmation by the U.S. Geological Survey of fracking-related hydrocarbons in groundwater wells in Pavillion, Wyoming underscore the urgency of this issue.
12) The HIA must assess the total health-related economic costs of fracking. It is possible and necessary to put a price tag on the medical costs of increased disease rates and injuries from fracking. All quantifiable health effects should be monetized using an economic disbenefit analysis, as has already been done for coal. Many hidden costs of fracking have been calculated in other states, and these must also be projected for New York State. For example, public health costs attributable to air pollution from gas drilling operations in Arkansas’ Fayetteville Shale (a rural area, with low population density) carried an estimated price tag of more than $10 million for 2008 alone.
13) The HIA must consider the potential health impacts of fracking to future generations. These may occur as the result of latent effects (for example, aquifer contamination from corroded and crumbling well casings), loss of biodiversity and degraded natural habitat, or from an economic bust that will likely follow the inevitable depletion of the gas reserves so extracted. Some consequences, such as contamination of water resources, may be irreparable, leaving affected areas essentially uninhabitable. The rights of future New Yorkers are not subservient to those living today. In this, we agree with legal scholar Edith Brown Weiss who asserts, “We have a right to use and enjoy the system but no right to destroy its robustness and integrity for those who come after us.”
14) Where uncertainties and gaps in data exist, the HIA must apply the Precautionary Principle. As expressed by the 1998 Wingspread Consensus Statement on the Precautionary Principle: “When an activity raises threats of harm to human health or the environment, precautionary measures should be taken even if some cause and effect relationships are not fully established scientifically. In this context the proponent of an activity, rather than the public, should bear the burden of proof. The process of applying the Precautionary Principle must be open, informed and democratic and must include potentially affected parties. It must also involve an examination of the full range of alternatives, including no action.” Even a small risk of irreparable harm should not be imposed on unwilling members of a community, no matter how close or distant from fracking sites.