Update: Health Impact Assessment is still not the final word on frac sand mining
Jul 06, 2016
This week, Midwest Environmental Advocates shared an updated review of a Health Impact Assessment of Industrial Sand Mining in Western Wisconsin published by the Institute for Wisconsin’s Health, Inc. earlier this year. The nonprofit, nonpartisan environmental law center intends the review to serve as a resource for citizens and decision-makers who need complete and unbiased information to inform their actions.
Since the Institute for Wisconsin’s Health, Inc. released the report in January, citizens and local government officials have contacted MEA with questions about whether the HIA adequately assesses the potential health impacts of the industrial sand mining industry based on existing evidence. MEA’s review of the Health Impact Assessment is especially important in light of the Wisconsin Department of Natural Resources’ release of the long-awaited public draft of the agency’s Industrial Sand Mining Strategic Analysis.
Over the last five years citizens and communities throughout western Wisconsin have experienced negative impacts from the industrial sand mining industry, whether it is dust in or around their homes, polluted water discharges on their lands or in their streams, or destruction of rural landscapes that have both aesthetic and cultural value.
“Since the start of the boom of frac sand mining activities in Wisconsin, local residents living near mining activity have wanted more of a role in protecting their rural communities, their air and their water from the health and environmental impacts of this major industrial activity,” said Kellan McLemore, MEA Staff Attorney. “Local elected officials, especially, want to base their decisions on sound science and unbiased information about the health and environmental impacts of frac sand mining. We believe this report – and the studies on which it is based – is too incomplete for local and state policy makers or agency staff to rely on for decision making.”
MEA is concerned that the Health Impact Assessment of Industrial Sand Mining in Western Wisconsin:
- Does not explicitly acknowledge potential health threats that were not analyzed or impacts where evidence is insufficient to reach a conclusion – the report fails to reach any conclusion about the risk of air quality impacts from fine particulate matter—PM2.5—and water quality impacts from heavy metal leaching. It is common for an HIA to limit its scope to certain impacts, but typically these kinds of studies should explicitly acknowledge the limited scope or impacts that aren’t assessed, or acknowledge when there is insufficient evidence or gaps in data.
- Relies on evidence without adequate discussion of its limitations – The HIA’s analysis of potential health impacts from crystalline silica relies primarily on one industry-funded study conducted at facilities all owned by the same company, EOG Resources. The report has significant limitations, thus, MEA questions the HIA’s reliance on the study and its conclusion that the evidence is “very strong” that potential health impacts from respirable crystalline silica are “unlikely.”
- Minimizes or fails to include relevant evidence – the report excludes data from a peer-reviewed study of community-level PM2.5 ambient air monitoring. This UW-Eau Claire study focuses on fine particles, which are more strongly associated with cardiovascular disease, lung disease and lung cancer than the PM10 particulate values supplied by industrial sand facility operators included in the HIA. While the study also has some limitations, the HIA’s air quality analysis should explicitly state that it does not assess or draw conclusions about the public health impact of PM2.5 emissions from industrial sand facilities.
- Does not evaluate the effectiveness of the regulatory framework – by not including a look at our environmental protection laws or the capacity of our Department of Natural Resources’ to effectively monitor and enforce air and water quality protections, the report provides an incomplete picture of whether the quality of our air and water are truly being protected.
- Does not include balanced stakeholder involvement or public input – by not providing an opportunity for public comment IWH excluded additional, relevant information, which could have been provided by citizens, environmental and public health organizations that have been working on this issue for years, and likely would have resulted in a more balanced and useful report.
“The Health Impact Assessment was essentially a literature review of handpicked, existing studies. It provides an incomplete picture of sand mining’s repercussions and leaves unanswered questions about the public health risks from small particle air pollutants, known from decades of research on workplace exposure to cause serious health impacts including lung cancer.” said Kimberlee Wright, MEA Executive Director. “How many more reports do we need that point to the need for more data rather than conduct credible research needed to protect families from irreversible impacts that could result from the dust that continually coats the inside of many homes?”
January, 2016 - Health Impact Assessment published by the Institute for Wisconsin's Health, Inc.
On February 9, Midwest Environmental Advocates sent a letter to the Institute for Wisconsin’s Health to express concern about a recent report’s short shrift given to air quality concerns from fine particles of dust created in industrial frac sand mining.
The Institute for Wisconsin’s Health, Inc. released a Health Impact Assessment of Industrial Sand Mining in Western Wisconsin that fails to analyze or draw complete conclusions about the health threat of frac sand dust. This is a serious error that calls into question the rest of the assessment.
First, the science is settled that fine particulate matter, or PM2.5, causes serious, life-threatening health problems. Exposure to the fine dust also exacerbates asthma and leads to serious cardiovascular and respiratory illness. This kind of dust is dangerous because it can travel deep into the lungs and cause illness, especially in vulnerable populations like children and the elderly. For more information about health concerns with silica and other fine dust, see our page on Fast Facts on Frac Sand Mining, Silica Dust, Air Quality and Our Health.
We also know that industrial sand mines emit fine particles into the air. Tests at these facilities confirm that these fine particles make of part of the dust that comes from emissions stacks. The Journal of Environmental Health* recently published a study of air quality monitoring near industrial sand mines in Wisconsin that showed elevated levels of fine particles around these facilities. The report did not include the latest academic research.
In spite of these well-recognized facts, the Institute for Wisconsin’s Health’s report was simply a literature review of incomplete studies and a repackaged summary of industry-produced air quality data. In the absence of requirements of air quality monitors at frac sand mines in Wisconsin, the public – and researchers such as the Institute for Wisconsin’s Health – cannot truly assess the comprehensive and cumulative impacts of the dust produced by this industry.
Midwest Environmental Advocates points out numerous errors or omissions in the Health Impact Assessment report, such as:
- The HIA report fails to assess cumulative, localized impacts of industrial sand mines that are concentrated in certain communities, and the data relied on in the HIA does not measure local impacts.
- The HIA report relies on and fails to take a critical look at voluntary, industry-sponsored air quality studies, and limited air quality monitoring for only larger particles, called PM10.
- The HIA report ignores an independent, published, peer-reviewed study of air quality near industrial sand mines, which happens to show that there are elevated levels of fine particles, PM2.5, downwind of these facilitates.
- The HIA report discusses potential health impacts from fine particles, but fails to draw any conclusions or make any recommendations to protect the public from this air quality threat.
This HIA report comes at a critical time as the agency in charge of regulating this industry, the Wisconsin Department of Natural Resources, is conducting a strategic analysis to evaluate the health and environmental impacts of the industrial sand industry. Midwest Environmental Advocates is concerned that the cursory and incomplete air quality analysis in the HIA report will lead to a DNR strategic analysis that also fails to provide a complete picture of the health threats.
Staff attorney Kellan McLemore comments, “The HIA represents a missed opportunity to provide answers to the public about the health and environmental impacts of this industry. People are concerned, and their concerns should not be dismissed until we have more reliable evidence that their health will not be affected by living near these facilities. Voluntary, industry-sponsored studies are not going to provide a complete and accurate picture.”
Midwest Environmental Advocates will continue to work with the DNR as it prepares its strategic analysis to ensure that it considers and takes a close look at all available data. We encourage members of the public to stay engaged as well.
* Journal of Environmental Health issue Nov 2015 Vol. 78 No. 4 pp. 8-12
More discussion on the HIA
On February 14, the Institute for Wisconsin's Health, Inc. sent a letter to Midwest Environmental Advocates in response to our initial concerns and outlined objections and disagreements the Institute had with our criticism of the published report.
On February 19, we issued a response letter to Institute for Wisconsin's Health that (1) reaffirmed our critique of the report, and (2) emphasized the need for assurance by our state Department of Natural Resources that our health is not threatened by the frac sand industry and that this assurance is based on sound science and complete information. Additionally, the response explains how Midwest Environmental Advocates contacted IWHI several times during the course of the project with offers to provide expertise and community connections to those already experiencing health problems related to frac sand mining. Our offers for help – even without the expectation of being formally involved in the Institute’s assessment process – went without response.