Colorado physicians confronted Hickenlooper on O&G health impacts

Health Effects of Chemicals Associated with Oil & Gas Development [Source: Warning Signs: Toxic Air Pollution Identified at Oil and Gas Development Sites]

Please note: This one slipped under may radar last month. On February 7, seven doctors representing the Colorado Physicians for Social Responsibility Advocacy Group sent a letter to Governor John Hickenlooper expressing their disagreements and concerns with the Colorado Department of Health and the Environment (CDPHE) report that downplays the public health impacts of oil & gas development. Their letter is posted below. To my knowledge, the governor has not yet to responded. 

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Colorado Physicians for Social Responsibility Advocacy Group

February 7, 2018

Dear Governor Hickenlooper,

We are Colorado health professionals concerned about the health of all Coloradans. We wish to register our concern about the stance of the State of Colorado related to the impacts of hydraulic fracturing on public health and environment.

In October 2017, members of our Physicians for Social Responsibility Colorado Working Group met with the CDPHE researchers (research group) who had gathered data and produced the report titled “Potential Public Health Effects from Oil and Gas Operations in Colorado” referred to hereafter as “the report.”

Our members were impressed with the sincere concern of the research group regarding the potential and known negative impacts of hydraulic fracturing on Colorado’s public health and environment and with their efforts to produce the report.

Recommendations and conclusions from the CDPHE are likely the basis upon which the COGCC will decide if requests for permits fulfill the legal condition in Martinez v. COGCC of the protection of public health and the environment. The CDPHE conclusions and recommendations will inform budgetary, policy and regulatory decisions and can influence the outcome of future elections.

Therefore, we need to report to you that we disagree strongly with many of the CDPHE report conclusions and the misleading way these and other research conclusions are presented to the public especially by the director of CDPHE. We are concerned with the under-emphasis on known and potential harms. We believe the role of our public health officials is to adhere to the precautionary principle of do no harm.

At our meeting with CDPHE and in subsequent correspondence with the research group, we presented some of the following concerns:

  • The study conclusion states there is no need for “immediate public health action” and “low risk of harmful effects for residents living near oil and gas operations.” We found these conclusions to be spurious and misleading based on the report itself;
  • The report shows combined elevated exposure risks for neurological, ear/nose/throat and respiratory effects. These were not included as health harms and were effectively written off. We advised this be noted in the Executive Summary;
  • The report under-emphasizes the danger of benzene exposure. The Executive Summary states that levels of benzene … are “well within acceptable range for cancer…effects.” Both the Environmental Protection Agency and the World Health Organization state that, as a carcinogen, there is no safe level of exposure to benzene;
  • The title, “Potential Public Health Effects from Oil and Gas Operations in Colorado,” does not indicate that this report is only related to air emissions;
  • The report does not address all air emissions. Notably missing are climate change effects of methane, measurements of and the health impacts of high ozone levels attributable to fracking, and particulate pollution;
  • The report does not address spills, water contamination, explosions, psychosocial impacts, or worker exposures and risks;
  • Methodology was not adequately explained;
  • Much of the air monitoring data lacks information on location and stage of operations.

Whereas the report gave poor ratings to most of the thirteen epidemiological studies published in peer-reviewed journals, the CDPHE report has neither been peer-reviewed nor published in a peer-reviewed journal. Conclusions from this report and from other CDPHE non-peer-reviewed studies are being used in an official capacity to minimize the perception of health impacts.

We take issue with various statements made by CDPHE director Dr. Larry Wolk. Some examples of errors and misleading statements include but are not limited to:

  • In 2014, CDPHE conducted a study that looked at birth anomalies at two clinics in Glenwood Springs.* The study had a total of twenty-two subjects with seventy percent of those subjects living greater than 15 miles from an active well. None of the published studies found correlations between prenatal harm at distances greater than ten miles and risk increased with the density of wells less than ten miles away. Residents at greater than ten miles were considered to be unexposed. The author correctly concludes that the study found “no one single environmental or genetic or substance-related factor that will explain these rare prenatal outcomes”. Thus this study has no validity and cannot be used to prove there is no health impact from fracking. Dr. Wolk’s public response that the anomalies “are not linked to any common risk factor” and “sadly birth anomalies do occur” is worse than misleading. [*The link to this study has been removed from the CDPHE website.]
  • Dr. Wolk is dismissive of Dr. McKenzie’s published and peer-reviewed study “Childhood Hematologic Cancer and Residential Proximity to Oil and Gas Development” (attached). Energy in Depth quotes Dr. Wolk as saying that the study conclusions are “misleading” and the study does not “prove a connection.” Statistically, there is no such thing as “proof” in this type of study, but rather a probability/likelihood. McKenzie’s analysis of the data shows a statistically significant likelihood that children who developed a specific hematologic cancer were up to four times more likely to have lived within a certain distance/proximity to well sites.
  • Regarding Dr. McKenzie’s study “Birth Outcomes and Maternal Residential Proximity to Natural Gas Development in Rural Colorado” (attached), Dr. Wolk is equally dismissive. He advises people not to become overly concerned. He states that he would tell pregnant women and mothers who live or who at the time of their pregnancy lived in proximity to a gas well to “not to rely on this study as an explanation of why one of their children might have had a birth defect.” McKenzie’s study does not report that birth defects are associated with living near “a” gas well but rather finds statistically significant correlations between an increased likelihood of birth defects and the density and proximity of gas wells. This sensitive population should be of great concern to our health department.
  • An August 2016 article in the Greeley Tribune quotes Dr. Wolk as saying that as long as people aren’t standing on a well and inhaling the fumes, there is no apparent health risk. This is not helpful and patently untrue. It implies permission for housing developments that are being placed closer to the current setback of 500 feet while risk assessments estimate significant increased health risk within 2500 feet of well sites.

Our CDPHE director should refrain from issuing public reassurances based on conclusions of studies that are neither published nor peer-reviewed nor should he be dismissive of published, peer-review research conducted by the Colorado School of Public Health and other well-respected institutions. Such actions on his part reduce the credibility of the agency in many other regards.

These CDPHE conclusions, and others, are further amplified and distorted by industry-based entities such as Energy-in-Depth and Coloradans for Responsible Energy Development. The Energy-in-Depth website, regarding the Glenwood Springs study, states that the CDPHE has “once again debunked the reckless claims of political activists who are trying to scare mothers and fathers.”

Our requests of the Governor and recommendations

We believe there is ample evidence to suspect harm, particularly in relationship to sensitive populations, those living in closer proximity to wells, and those exposed to elevated levels of documented carcinogens like benzene and other neurotoxins.

We join the ranks of the eighteen Colorado lawmakers who questioned the CDPHE report and its findings of “limited evidence of harm.”

We ask that you:

  • Strongly recommend that the CDPHE revise the conclusions of the report to reflect that rather than “limited evidence of harm” there is insufficient information to prove no harm;
  • Recommend and encourage CDPHE to have this report peer-reviewed;
  • Publicly support our recommendation that no further permits be issued until an independent review of studies and adequate monitoring can confirm that no harm exists, particularly for sensitive populations;
  • Actively advocate for funding to increase the number of CDPHE staff to assure that the agency can thoroughly and accurately study and evaluate the potential health and environmental risks associated with fracking including spills, water contamination, explosions, psychosocial impacts, worker exposures, elevated ozone, and methane impacts on climate change.
  • Familiarize yourself with and respond publicly to distortions and misinformation that are being put out by oil and gas interest groups;
  • Discuss with Dr. Wolk the concerns that we have stated in this memo. Ask for his public clarification or retraction about the lack of potential public health harm;
  • Speak out and be a strong advocate for unbiased independent monitoring and reporting (ie., not relying on the oil and gas industry) on air emissions including methane, ozone, and particulates as well on as spills, leaks, noise, and explosions;
  • Advocate for developing additional funding from the oil and gas industry for full support of adequate inspection, monitoring, study and enforcement of all regulations;
  • Recommend that the COGCC provide online summaries of spill data in a format that is uniform and accurate, includes aggregate data, and has standardized reporting forms with standardized units for both spills and toxics recovered;
  • Recommend that all spills be cleaned up, not just those noted to impact water;
  • Recommend that spill data be analyzed to determine common spill sources. Improvements should be implemented in procedure and inspections based on the information as well as new regulations implemented to reduce spills. An example would be to increase inspections of equipment with high spill rates, especially those of battery tanks and their flowlines (as per the attached report by Dr. Joe Ryan).
  • Support mandatory monitoring and inspections for flowback capture of methane and air toxics.
  • Support mandatory evaluation and testing of all flowlines not just those closest to homes or schools to reduce risk of explosions.
  • Support mandatory reporting of all fires and explosions, not only those requiring medical treatment or significant damage to equipment or well sites to determine trends of companies with risky practices and air pollution.

Protection of public health and the environment should come first. Though we appreciate the work of the COGCC and the CDPHE we disagree with many of the practices and conclusions. Monitoring must be ongoing and rigorous, regulations must be effective and enforced, and inspection should be adequately funded. Public statements on health impacts and subsequent decisions should be governed by scientific research and be precise and accurate. If these conditions cannot be met then the oil and gas industry should not be allowed to drill and extract oil and gas in Colorado.

We look forward to meeting with you and/or hearing your response.

Respectfully submitted,

Julie Carpenter, MD, Family Medicine
Ward, Colorado

Lauri Costello, MD, Family Medicine
Durango, Colorado

Barbara Donachy, MPH
Denver, Colorado
barbaradonachy@gmail.com

Larry Moore MD,
Emergency Medicine
Manitou Springs, Colorado
doclmoore@wildernesswise.com

Cindy L Parker MD, MPH, Public Health and General Preventive Medicine
Salida, Colorado

Cecilia Sorensen, MD, Emergency Medicine, Climate Change Fellow
Boulder, Colorado

James Welle, MD, Internal Medicine
Denver, Colorado

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One Comment on “Colorado physicians confronted Hickenlooper on O&G health impacts”

  1. amyhaddenmarsh Says:

    Thanks, Peggy. AHM

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