NO CLEAN BILL OF HEALTH FOR CSG A Critique of the Queensland Department of Health’s Report on the Health Impacts of CSG Activities on the Tara Community

NO CLEAN BILL OF HEALTH FOR CSG A Critique of the Queensland Department of Health’s Report on the Health Impacts of CSG Activities on the Tara Community by National Toxics Network, April 2013

The Queensland Government’s Health Report, ‘Coal seam gas in the Tara region: Summary risk assessment of health complaints and environmental monitoring data, March 2013’, [Health Report] and the reports on which it is based, do not provide a comprehensive investigation of the potential impacts of coal seam gas (CSG) activities on the residents of Tara. The Health Report should not be used by government or industry to claim ‘a clean bill of health’ for the CSG industry in Tara, or any other CSG field for that matter. The Health Report concludes overall that it was unable to determine whether any of the health effects reported by the community are linked to exposure to CSG activities. This is not an unsurprising finding and one that’s very common in cases of chemical exposures and health impacts, especially when no baseline health data has been gathered.

The Health Report does however provide some evidence that might associate some of the residents’ symptoms to exposures to airborne contaminants arising from CSG activities. While industry’s sampling on which the Health Report relies was very limited, both in scope and time, a wide range of volatile organic compounds (VOCs) were still detected in the air around residents’ homes in Tara. The Health Report concludes there was no evidence of contamination of concern, yet for many of the chemicals, the level of detection used by the laboratories was set above the level set for the protection of health used in the report. However, benzene, a confirmed human carcinogen1, was detected at levels above the health criteria, yet these results were dismissed with the claim that ‘benzene was not a compound that is found in CSG and therefore cannot be attributed to CSG activities’. This statement contradicts the Queensland’s Department of Environment and Heritage Protection website2 which states that “BTEX compounds (benzene, toluene, ethylbenzene, xylene) are found naturally in crude oil, coal and gas deposits and therefore they can be naturally present at low concentrations in groundwater near these deposits”. There was no assessment of aggregate or combined exposure, in particular for the children of Tara who are at greatest risk from exposures.

Of the 11 families and 56 people reporting health symptoms, (headache, rashes, sore eyes, nausea, nosebleeds), only 15 were seen in person by the Government appointed doctor. The detection of dangerous air toxics around resident’s homes combined with the ongoing reporting of adverse health symptoms should be treated seriously and a scientifically valid investigation should be undertaken which ensures independence and is based on a rigorous monitoring program which is broad-spectrum, high periodicity and long-term. 

The Health Report released by the Queensland government is not a comprehensive health study. The investigation of the residents’ health complaints was limited to an analysis of reports of symptoms and a questionnaire with little clinical follow-up. The Health Report’s findings are based on information for 56 people from 11 families living in the region. However there was only direct participation by 15 people in person and two by telephone. Two other individuals who registered complaints with13 HEALTH were excluded from the analysis as they were not residents of the region. …

It should also be noted that the appointed Government doctor’s association with the coal companies could also have been an influencing factor. Dr Adam is retained consultant by Anglo Coal and Curragh Qld Mining. …

Queensland Gas Company Environmental Health Assessment Report Tara Complaint Investigation Report, January 2013 Final REF: 0181432R01 (known as the ERM Report)

Much of the environmental sampling and assessment on which the Health Report was based was undertaken on behalf of the Queensland Gas Company. The ERM report notes that twelve CSG wells are located between 0.6 km and 17 km from the residents’ lots, and these are used for the extraction of CSG and water from the Walloon coal seam. However, the ERM report claims there can be no linkages between CSG production and the residents’ lots. The ERM report states there have been no surface releases of CSG production water to surface water despite evidence of CSG water being sprayed on roads as dust suppression with inevitable runoff in Queensland’s heavy rains. The ERM report states that the Queensland Government’s gas monitoring study found no gas leaks and ambient air samples collected downwind from an operating well (Codie #6) showed no presence of coal seam gas components.

The ERM report does not consider the findings of research by the Southern Cross University (SCU),4  which used atmospheric radon (222Rn) and carbon dioxide (CO2) concentrations to measure fugitive emissions in the CSG fields of the Tara region,
Queensland. The SCU study measured a 3 fold increase in maximum 222Rn concentration inside the gas field compared to outside, suggesting enhanced diffuse soil gas exchange processes, helping gases to seep through the soil to be released to the atmosphere. The presence of these gases also suggests the release of other gaseous substances, such as VOCs.

In a related study carried out by the Queensland Department of Natural Resources 
and Mines, toluene and methane were detected in a resident’s private water bore.6

The Health Report criticised the ERM report for summarising the results for dissolved metals, rather than total metals, the latter being more relevant to human health and generally more conservative. It also criticised the ERM report for not testing soil for arsenic, beryllium, cadmium, chromium (III), chromium (VI), cobalt, lead, inorganic mercury and nickel; i.e., metals that are of ‘more relevance to public health considerations of soil contamination’. … Benzene is a confirmed human carcinogen. The dismissal of benzene exceedances is unexplainable when other BTEX chemicals such as toluene, a neurotoxin, were found in the air around a number of Tara homes and in the air above a resident’s water bore. The level of toluene above the bore was measured at 0.33ppm but was dismissed as below levels of concern8, yet this is well above the ‘Chronic Reference Exposure Limits’ used for long term exposure by California, Massachusetts, Michigan states in the USA.9 … Although the levels are dismissed as low, living organisms can be affected significantly by bioactive chemicals at levels well below those detectable by chemical 8 or physical methods, particularly if there is chronic exposure.15 In such cases the biological responses of those exposed are the best evidence that a problem exists, not limited chemical tests – and the tests appear to be remarkably limited. …

There are certainly not enough data to carry out the simplest statistical analysis, or to
draw any meaningful conclusion. The absence of chemically detectable levels is not
proof that dangerous materials are not present at biologically active levels. [Emphasis added]

Contact: Dr Mariann Lloyd-Smith PhD (Law)
Senior Advisor, National Toxics Network Inc.
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