US State Funds Research into Links Between Fracking and Cancer – Implications for the UK?

Hydraulic fracturing, otherwise known as ‘fracking’, usually refers to an ‘unconventional’ process through which water, chemicals and sand are pumped at high pressure underground [a well drilled to the depth of 1-3 kilometres (km)[i]] to extract oil and gas, stored within porous shale rocks.[ii] This is not to be confused with the long-used, common technique of pumping water (without chemical additives) at low pressure into ‘conventional’ wells (or ‘well stimulation’) to increase the amount of oil and natural gas recovered from more permeable, non-shale rock formations (ordinarily at 0.3-1.2 km depth).[iii]

In December of last year, Health Secretary for the state of Pennsylvania, Dr. Rachel Levine, announced that the University of Pittsburgh’s Graduate School of Public Health would receive a $2.5 million contract to conduct 2 studies (expected to last 2-years) on the known or suspected health complications of fracking.[iv]

Redeeming a pledge made by Governor Tom Wolf, in November 2019, to address ‘concern that there is a relationship between hydraulic fracturing and childhood cancers’,[v] the 1st investigation, led by Professor of Epidemiology, Dr. Evelyn Talbott, will take inspiration from a 4-county Report (dated March 2020), published by the Pennsylvania Department of Health, which detected elevated paediatric cancer rates in ‘fracking counties’, over a decade-long monitoring period.

These south-western fracking counties have long-hosted coal, chemical and uranium industries[vi] and over the past 15-years, more than 12,000 wells have been drilled and fracked, with 3,500 wells drilled since 2008.[vii]

Tens of cancer cases have been identified among children and young adults.[viii] These include cases of osteosarcoma, liposarcoma, rhabdomyosarcoma, neuroblastoma, Wilms’ tumour, liver cancer, astrocytoma, leukaemia and rare Ewing sarcoma.[ix]

Interestingly, Ewing sarcoma, which disproportionately affects the bones and surrounding tissues of young males,[x] has no known environmental cause, but Pennsylvanian families aver that the ‘noticeably concentrated geographic segment’ of cases show they are linked to fracking:[xi]

‘At least half of the Ewing sarcoma cases in our communities are centrally located around waste, waste streams and waste facilities and not necessarily wellheads’.[xii]

Even though Ewing sarcoma incidence increased by 41% from 2006 to 2017, versus the incidence between 1995 and 2005,[xiii] the March 2020 Report concluded that this was ‘not statistically significant’. Controversy was sparked when it was revealed that a number of cases were either not taken account of in the report, or were misidentified.[xiv]

The 2nd investigation, led by Research Associate Professor of Biostatistics, Dr. Jeanine Buchanich, will examine prevalence of acute conditions, such as asthma (and other respiratory complications), birth outcomes (e.g. defects), blood disorders and nervous system issues, in relation to fracking.

In the round, the research project has been welcomed by local shale gas industry stakeholders, such as the Marcellus Shale Coalition, the Pennsylvania Independent Oil and Gas Association and the American Petroleum Institute Pennsylvania.[xv] They have collectively called upon state officials to ‘neutrally, fairly and without bias evaluate all potential factors’, but have strongly and repeatedly denied that the air and water pollutants emitted in the course of drilling (vertically and horizontally), fracking, processing and transporting have any negative human health impacts.[xvi]

What is the significance of these US investigations on the UK?

A Background to British Fracking

The UK’s first well to encounter shale gas underground was drilled into the Upper Jurassic Kimmeridge Clay, in 1875, but its significance was not realised at the time.

Around 25-years-ago (1987), researchers at Imperial College applied the US shale gas paradigm to evaluate the UK’s onshore shale gas potential and found considerable potential for shale gas exploitation.

Most of this potential is believed to be tied up in the Carboniferous strata of the Pennine Basin (Lancashire and Yorkshire) and in the Jurassic strata of the Weald (Sussex, Hampshire and Dorset).

There are currently no official reserve estimates for shale gas.[xvii] In 2010, the British Geological Survey (BGS) indicated that recoverable resources across the UK were in the region of 0.15 trillion cubic metres (tcm).[xviii] It went on to re-assess, in 2013, that England’s Bowland Shale Formation layer alone contained between 23-65 tcm, of which 1.8-13 tcm was recoverable, if a North American recovery factor of 8-20% was applied.[xix]

However, in 2019, the independent ReFINE partnership, jointly led by Durham and Newcastle Universities, concluded that the assumed shale gas yield from shale rock was based upon a miscalculation. Whilst the total volume of shale rock was reasonably clear, lab sample testing revealed that the volume of gas within it was not (80% less than expected).[xx]

Up until recently, though, it was prophesised that shale gas could revolutionise the UK energy industry [replacing up to 60% of its imported natural gas supply (mostly from Qatar, Norway, Algeria and Russia[xxi]) as offshore deposits in the North Sea dwindle[xxii]] and create a ‘bridge to a zero carbon future’. Prime Minister, Boris Johnson, previously referred to fracking as ‘glorious news for humanity’ and urged the UK to ‘leave no stone unturned, or unfracked’.[xxiii]

5.PNG

[Source: Geograph – KA (19 August, 2011): ‘Shale Gas Exploration [Becconsall, Banks, UK]]

The 1st well dug purposively for high-volume shale gas extraction in UK was operational in 2010. A license for the Preese Hall site (part of the Bowland Shale, in Lancashire) was obtained by Cuadrilla, in 2008, in the 13th round of onshore licensing.[xxiv]

In 2016, The Cabinet Office projected that up to 20 operational shale gas wells would have been fracked by mid-2020, but a National Audit Office Report later divulged that only 3 wells had been drilled (as at 23 October 2019).[xxv] Aside from the Preese Hall well, 2 wells were also dug at nearby Preston New Road.[xxvi]

The main reason for the distinct lack of high-volume fracking activity was due to numerous seismic events, with the first mini tremors occurring at Preese Hall, in 2011.[xxvii] A ‘traffic light system’ was swiftly implemented so that any events over 0.5 on the Richter scale resulted in an immediate suspension of fracking processes.[xxviii] The largest registered event to-date was a magnitude 2.9 earthquake, on 26 August 2019, at Preston New Road.[xxix]

6.png

Since the Infrastructure Act 2015 was passed, energy corporations intending to carry out hydraulic fracturing exploration activities have had to acquire ‘Hydraulic Fracturing Consents’, which ensure that the necessary environmental and health and safety permits have been obtained.

However, on 2 November 2019, the then Business and Energy Secretary, Andrea Leadsom MP, announced a moratorium on issuing new Consents in England, with immediate effect[xxx] - this followed earlier moratoria in Scotland (in 2015, 2017 and 2019)[xxxi] and Wales (in 2015 and 2018), while Northern Ireland imposes a ‘presumption against’.[xxxii]

The UK Government’s decision to pause its support for fracking in England was based on a scientific Report, published by the Oil and Gas Authority (OGA) regulator, which determined that it was not possible, with the available technology, to accurately predict the probability or magnitude of fracking-associated earthquakes.

For the de facto ban to be lifted and works to resume, the OGA’s analysis called for new studies providing clear and compelling evidence that the practice can be carried out safely, sustainably and with minimal disturbance to those living and working nearby.

In the interim, Cuadrilla has relinquished consent to inject hydraulic fracturing fluid, incinerate gases and manage drilling waste at its Preston New Road site, but retains permission to manage waste caused by decommissioning wells, dispose of non-hazardous waste and drain surface water.[xxxiii] Whilst some consider fracking to be ‘finished’ in Lancashire, the operator is optimistic that it will ‘apply for the relevant licences at this [Preston New Road] or other sites as and when the moratorium is lifted’.[xxxiv]

Were Public Health Concerns Voiced Alongside Seismicity Concerns When the Ban Was Imposed?

In 2014, Public Health England published a Report, which acknowledged potential health risks of fracking in extant medical literature (based on foreign exposures), but arrived at the conclusion that these risks were ‘typically the result of operational failure and a poor regulatory environment’, which could have been ameliorated with ‘good on-site management and appropriate regulation of all aspects including exploratory drilling, gas capture, use and storage of hydraulic fracturing fluid, and post-operations decommissioning are essential to minimise the risk to the environment and public health’.

When gas rises to the surface once shale rock is fracked, it is posited that some of the used fracturing fluid ‘flows back’ as waste product (15–80% of the volume injected). This contains natural gas (predominantly methane), salts, metals, and naturally occurring radioactive materials (NORM).[xxxv] Thus, to prevent ground/water/air pollution [albeit this should theoretically be prevented by impermeable rock layers above shale[xxxvi] – see the Final Report of the Royal Society and the Royal Academy of Engineering (2012)], wells have been designed and constructed to:

  • Have 3 layers of pipe casing (versus 2 in the US), made of concrete and steel;
  • Have a thick barrier between gas escaping up pipe and ground water (more so than in the US;
  • Collect drilling fluids in closed steel tanks rather than in lined earthen pits (as is common practice in the US); and
  • Use chemical and fluid-proof well pads.

N.B. Unlike in the US, where the majority of water supplies are privatised, the bulk of the UK’s domestic water supply is mains water, subjected to high pollutant-removal standards by legislation. This further reduces the risk of adverse human health complications.

On-site, industry abides by best practice guidelines (including adherence to the Provision and Use of Work Equipment Regulations (PUWER) 1998), developed by the Health and Safety Executive (HSE) and the Environment Agency (EA).[xxxvii] These are published by the United Kingdom Onshore Operators Group (UKOOG), as the representative body for UK onshore oil and gas companies, and are currently in their 4th iteration.

Other regulatory/advisory bodies that ensure effective health and safety precautions are evaluated/followed, include the Department for Business Energy and Industrial Strategy (BEIS), Local Council Planning Authorities and the Minerals Planning Authority (MPA).

Despite the fact that mini tremors were the ultimate cause of the UK Government’s fracking moratorium, concerns have consistently been raised by environmental charities and activists over associated complications affecting human health (consistent with recent accusations made in the US).

In 2016, the Advertising Standards Authority (ASA) ruled that Friends of the Earth (FoE) had directed ‘misleading statements’ to the public in a fundraising flyer, which claimed that 25% of chemicals used in the fracking process cause cancer; that fracking can contaminate water supplies (leakage into aquifiers[xxxviii]); and that asthma rates are 3-times higher than average near fracking sites.

A 14-month investigation into the FoE campaign was prompted by complaints from Cuadrilla that the leaflet was ‘wholly inaccurate’.[xxxix]

In a draft report, leaked to The Times, the regulator stated that the charity had failed to substantiate its allegations about the dangers.[xl]

The case was ‘informally resolved’ on the proviso that the green group agreed not to repeat these claims, or synonymous claims.[xli] Some individuals still, however, publicly deny that FoE ever made false claims.[xlii]

Legitimacy of Explicit Claims that UK Fracking Causes Cancer?               

In 2015, the CHEM Trust published a Report and a Briefing, ultimately calling for a suspension on fracking across Europe, on the premise that it posed a ‘significant’ risk to human health.[xliii] An identical intervention was then sought by Medact, via a 2016 Report.

CHEM Trust warned of 38 fracking chemicals in fracking fluid that were ‘acutely toxic for humans’ and a further 20 that are mutagenic, or known or possible carcinogens. The Trust expressed ‘particular concern’ about the use of hormone (or endocrine) disrupting chemicals tied to hormonally-driven breast, prostate and testicular cancers and coronary heart disease. Specifically referring to worker health, it cited risk of sperm count reduction, altered menstrual cycles and impaired fertility.

However, whilst around 700 chemicals (including known and possible carcinogens) are routinely involved in fracking operations in the US (including benzene, and formaldehyde)[xliv] and are not always disclosed, UK fracking is more stringently regulated and always disclosed. What is more, concentrations of chemical additives in US fracking fluid make up 2% of the overall mixture, compared to 0.25% in the UK.[xlv]

For instance, the fracking fluid injected into the Preese Hall No.1 well comprised of 6 constituent ingredients in the following concentrations:

  • Fresh water (to carry sand and open fractures) – 97.93%.
  • Crystalline silica-based sand (to prop open fractures, i.e. a ‘proppant’) – 2.023%
    • Congleton sand – 0.473%
    • Chelford sand – 1.55%
  • A friction reducer made of polyacrylamide emulsion in hydrocarbon oil (to reduce pressure required to pump down pipe) – 0.043%.
  • A ‘chem tracer’ (to identify ‘frac water’ in flowback) – 0.00005%.
    • Water – 0.000045%
    • Sodium salt 0.000005%.[xlvi]

This particular solution was classified as ‘non-hazardous’ (to groundwater) by the EA.[xlvii]

Aside from polyacrylamide lubricant, alternative chemical additives permitted (but not used) for fracking fluid in Lancashire included dilute hydrochloric acid and glutaraldehyde.[xlviii]

Elsewhere, in Balcombe (Sussex), Cuadrilla uses oxirane (ethylene oxide) at an oil and gas exploration site where limestone is naturally fractured using a technique called acidisation, through which acid is injected at low pressure into boreholes to widen fractures in the rock.[xlix] These works are exempt from the moratorium currently in place in England and are therefore still ongoing.[l]

Oxirane is classified as a known carcinogen by the International Agency for Research on Cancer (IARC), linked with white blood cell cancer types (non-Hodgkin lymphoma, myeloma, lymphocytic leukaemia, etc.)[li] and breast cancer in females.[lii]

Besides the risk of potential explosions and exposure to hydrocarbons and biocides, the UK Trades Union Congress (TUC) expressed, as part of its own Briefing on fracking worker safety, that respirable crystalline silica (RCS) in the sand element of fracking fluid creates a substantial lung cancer and silicosis threat.

What is more, lead and arsenic (heavy metals found in flowback) are correlated with fertility problems and miscarriage/stillbirth.

Conclusions

The University of Pittsburgh’s double-barrelled study is now firmly on our radar. Of course, any observations that we have made in this article equally apply to coal bed methane extraction, which also relies on ‘unconventional’ hydraulic fracturing methods, albeit with lesser quantities of chemical-containing fracturing fluid (coal seams are less difficult to fracture than shale).

 

[i] Sabrina Weiss, ‘What is fracking? Your need-to-know guide to fracking in the UK’ (26 September 2019 WIRED) <https://www.wired.co.uk/article/what-is-fracking> accessed 19 February 2021.

[ii] ‘Fracking’ (Greenpeace) <https://www.greenpeace.org.uk/challenges/fracking/> accessed 19 February 2021.

[iii] ‘MYTH #3 “Fracking has been going on for decades.”’ (Frack Free Nottinghamshire) <http://frackfreenotts.org.uk/fracking-myths/myth-3-decades/> accessed 22 March 2021.

[iv] April Hutcheson, ‘Wolf Administration Awards $2.5 Million Contract To University Of Pittsburgh To Research Health Effects Of Hydraulic Fracturing In Pennsylvania’ (12 December 2020 Pennsylvania Government) <https://www.media.pa.gov/Pages/Health-Details.aspx?newsid=1215> accessed 24 February 2021.

Chrissy Suttles, ‘Pitt to study potential health effects of fracking’ (23 December 2020 EU Times) <https://eu.timesonline.com/story/news/2020/12/23/pitt-study-potential-health-effects-fracking/4011787001/> accessed 24 February 2021.

[v] ‘Pennsylvania to fund studies into fracking health impact’ (22 November 2019 Pittsburgh Post-Gazette)  

[vi] ‘Pennsylvania To Spend $3M To Study Possible Link Between Fracking And Spike In Childhood Cancer’ (22 November 2019 CBS Local) <https://pittsburgh.cbslocal.com/2019/11/22/pennsylvania-research-funding-fracking-health-impacts-cancer/> accessed 24 February 2021.

[vii] Don Hopey, ‘Pitt to lead shale gas health study looking at possible ties to childhood cancers’ (22 December 2020 Pittsburgh Post-Gazette) <https://www.post-gazette.com/news/environment/2020/12/22/university-of-pittsburgh-Pennsylvania-DOH-lead-shale-gas-health-study-fracking-childhood-cancers/stories/202012220132> accessed 24 February 2021.

[viii] David Templeton and Don Hopey, ‘Risk and exposure in the gas lands’ (14 May 2019 Pittsburgh Post-Gazette) <https://newsinteractive.post-gazette.com/childhood-cancer-pittsburgh-pennsylvania-canon-mcmillan-pollution/> accessed 24 February 2021.

[ix] ‘Pennsylvania to fund studies into fracking health impact’ (22 November 2019 Pittsburgh Post-Gazette) <https://www.post-gazette.com/local/washington/2019/11/22/State-studies-to-determine-health-impacts-of-shale-gas/stories/201911220067> accessed 25 February 2021.

[x] ‘Ewing Sarcoma’ (6 July 2020 NHS) <https://www.nhs.uk/conditions/ewing-sarcoma/> accessed 25 February 2021.

[xi] Goldberg Segalla, ‘Pennsylvania Launches $4 Million Investigation Into Whether Fracking Causes Rare Form of Cancer in Children’ (12 December 2019 Environmental Law Monitor) <https://environmentallawmonitor.com/fracking/pennsylvania-launches-4-million-investigation-into-whether-fracking-causes-rare-form-of-cancer-in-children/> accessed 25 February 2021.

[xii] Rachel McDevitt, ‘State gives $2.5 million to Pitt to study health impacts of fracking’ (23 December 2020 State Impact Pennsylvania) <https://stateimpact.npr.org/pennsylvania/2020/12/23/state-gives-2-5-million-to-pitt-to-study-health-impacts-of-fracking/> accessed 24 February 2021,

[xiii] Kris Maher, ‘After String of Rare Cancer Cases, Pennsylvania Investigates Potential Link to Fracking’ (20 December 2019 Wall Street Journal) <https://www.wsj.com/articles/after-string-of-rare-cancer-cases-pennsylvania-investigates-potential-link-to-fracking-11576837802> accessed 25 February 2021.

[xiv] Reid Frazier, ‘Washington County family members tell state to “fix” their cancer study’ (8 October 2019 State Impact Pennsylvania) <https://stateimpact.npr.org/pennsylvania/2019/10/08/washington-county-family-members-tell-state-to-fix-their-cancer-study/> accessed 24 February 2021.

[xv] Jamison Cocklin, ‘Pennsylvania Selects Partner for $2.5M Study on Link Between Cancer and Hydraulic Fracturing’ (24 December 2020 Natural Gas Intelligence) <https://www.naturalgasintel.com/pennsylvania-selects-partner-for-2-5m-study-on-link-between-cancer-and-hydraulic-fracturing/> accessed 24 February 2021.

[xvi] Michael Rubinkham, ‘Pennsylvania to fund research into fracking health dangers’ (22 November 2019 AP News) <https://apnews.com/article/e7859cfd44f145f18463568a5891e6b6> accessed 24 February 2021.

[xvii] The Parliamentary Office of Science and Technology, ‘UK Shale Gas Potential’ (July 2013 Parliament.UK) <https://www.parliament.uk/globalassets/documents/post/ShaleGas_POSTbox.pdf> accessed 23 February 2021.

[xviii] Department of Energy & Climate Change, ‘The Unconventional Hydrocarbon Resources of Britain’s Onshore Basins – Shale Gas’ (2013 OGA) <https://www.ogauthority.co.uk/media/1693/shalegas_uk.pdf> accessed 2 February 2021.   

[xix] The Parliamentary Office of Science and Technology, ‘UK Shale Gas Potential’ (July 2013 Parliament.co.uk) <https://www.parliament.uk/globalassets/documents/post/ShaleGas_POSTbox.pdf> accessed 20 February 2021.

[xx] Jon Gluyas and Magdalena Kuchler, ‘Fracking in the UK was doomed a decade ago’ (19 November 2019 Durham University) <https://www.dur.ac.uk/research/news/thoughtleadership/?itemno=40332> accessed 18 March 2021.

[xxi] Adam Vaughan, ‘UK government rings death knell for the fracking industry’ (4 November 2019 New Scientist) <https://www.newscientist.com/article/2222172-uk-government-rings-death-knell-for-the-fracking-industry/> accessed 19 February 2021.

[xxii] Simon Jacks, ‘Is the future of fracking now in doubt?’ (22 October 2019 BBC) <https://www.bbc.co.uk/news/business-50147763> accessed 19 February 2021.

[xxiii] Jillian Ambrose, ‘Fracking halted in England in major government U-turn’ (2 November 2019 The Guardian) <https://www.theguardian.com/environment/2019/nov/02/fracking-banned-in-uk-as-government-makes-major-u-turn> accessed 22 February 2021.

[xxiv] Selley RC, UK shale gas: The story so far. Marine and Petroleum Geology. Vol 31 (Pages 100-109). March 2012. <https://www.sciencedirect.com/science/article/abs/pii/S0264817211002030> accessed 23 February 2021.

[xxv] ‘Fracking process making slow progress, report finds’ (23 October 2019 Shropshire Star) <https://www.shropshirestar.com/news/uk-news/2019/10/22/fracking-process-making-slow-progress-report-finds/> accessed 19 February 2021.

[xxvi] ‘Preston New Road fracking: Cuadrilla bring equipment to wells’ (24 September 2018 BBC) <https://www.bbc.co.uk/news/uk-england-lancashire-45627556> accessed 23 February 2021.

[xxvii] ‘Fracking tests near Blackpool “likely cause” of tremors’ (2 November 2011 BBC) <https://www.bbc.co.uk/news/uk-england-lancashire-15550458> accessed 23 February 2021.

[xxviii] Department for Business, Energy & Industrial Strategy, ‘Traffic light monitoring system (shale gas and fracking)’ (9 September 2013 GOV.UK) <https://www.gov.uk/government/publications/traffic-light-monitoring-system-shale-gas-and-fracking> accessed 19 March 2021.

[xxix] ‘Lancashire fracking: Second tremor in a day recorded at fracking site’ (27 August 2019 BBC) <https://www.bbc.co.uk/news/uk-england-lancashire-49480142> accessed 19 February 2021.

[xxx] Department for Business, Energy & Industrial Strategy, Oil and Gas Authority, The Rt Hon Kwasi Kwarteng MP, and The Rt Hon Andrea Leadsom MP, ‘Government ends support for fracking’ (2 November 2019 GOV.UK) <https://www.gov.uk/government/news/government-ends-support-for-fracking> accessed 19 February 2021.

[xxxi] Kevin Keane, ‘Scottish government fracking “ban” to continue indefinitely’ (2 October 2019 BBC) <https://www.bbc.co.uk/news/uk-scotland-49910646> accessed 19 February 2021.

[xxxii] Steffan Messenger, ‘Fracking plans face cold shoulder under new Wales policy’ (3 July 2018 BBC) <https://www.bbc.co.uk/news/uk-wales-44696285> accessed 19 February 2019.

Sarah Priestley, ‘Shale gas and fracking: BRIEFING PAPER Number CBP 6073, 31 March 2020’ (House of Commons) <https://researchbriefings.files.parliament.uk/documents/SN06073/SN06073.pdf> accessed 19 March 2021.

[xxxiii] ‘Cuadrilla partly surrenders Lancashire fracking licence’ (10 December 2020 BBC) <https://www.bbc.co.uk/news/uk-england-lancashire-55267000> accessed 19 February 2021.

The Environment Agency, ‘Permitting decisions- Surrender’ (GOV.UK) <https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/942406/Decision_Document_AB3101MW-S007.pdf> accessed 19 February 2021.

[xxxiv] ‘Cuadrilla “will seek fresh fracking licences” for Lancashire’ (11 December 2020 BBC) <https://www.bbc.co.uk/news/uk-england-lancashire-55275057> accessed 22 March 2021.

[xxxv] ‘Guidance Note: Regulation of exploratory shale gas operations’ (November 2012 Environment Agency) <http://www.groundwateruk.org/downloads/EA_ShaleGasRegulation.pdf> accessed 19 March 2021.

[xxxvi] ‘Facts about fracking’ (2017 Environment Agency) <https://consult.environment-agency.gov.uk/onshore-oil-and-gas/onshore-oil-and-gas-regulation-information-page/user_uploads/2017-ea-water-factsheet.pdf> accessed 19 March 2020.

[xxxvii] Department of Energy & Climate Change, ‘Onshore oil and gas exploration in the UK: regulation and best practice’ (December 2015 GOV.UK) <https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/503067/Onshore_UK_oil_and_gas_exploration_England_Dec15.pdf> accessed 19 March 2021.

[xxxviii] Department for Business, Energy & Industrial Strategy,‘Fracking for shale gas in England’ (October 2019 NAO) <https://www.nao.org.uk/wp-content/uploads/2019/07/Fracking-for-shale-gas-in-England.pdf> accessed 19 March 2021.

[xxxix] ‘Friends of the Earth must not repeat misleading fracking claims’ (4 January 2017 BBC) <https://www.bbc.co.uk/news/uk-england-lancashire-38499811> accessed 24 February 2021.

‘Friends of the Earth accused of “misleading” over fracking’ (19 October 2015 BBC) <https://www.bbc.co.uk/news/uk-england-lancashire-34570974> accessed 24 February 2021.

[xl] ‘Friends of the Earth fracking leaflet “misleading”, ad watchdog says’ (26 September 2016 BBC) <https://www.bbc.co.uk/news/uk-england-lancashire-37473276> accessed 23 February 2021.

[xli] Mark Sweney and Damian Carrington, ‘Friends of the Earth ticked off over claims in anti-fracking leaflet’ (4 January 2017 The Guardian)  <https://www.theguardian.com/environment/2017/jan/04/friends-of-earth-ticked-off-claims-anti-fracking-leaflet> accessed 23 February 2021.

[xlii] Ben Webster, ‘New rebuke for Friends of the Earth over fracking claims’ (6 January 2017 The Times) <https://www.thetimes.co.uk/article/new-rebuke-for-friends-of-the-earth-over-fracking-claims-856h56x5n> accessed 24 February 2021.

[xliii] ‘Fracking poses “significant” risk to humans and should be temporarily banned across EU, says new report’ (22 June 2015 The Independent) <https://www.independent.co.uk/climate-change/news/fracking-poses-significant-risk-to-humans-and-should-be-temporarily-banned-across-eu-says-new-report-10334080.html> accessed 19 March 2020.

[xliv] Natalie Rahhal, ‘Pennsylvania will spend $3 million to study cancer cluster of DOZENS of children and young adults in counties where over 3,500 new fracking wells were dug in the last decade’ (22 November 2019 Daily Mail) <https://www.dailymail.co.uk/health/article-7714967/Pennsylvania-fund-research-fracking-health-impacts.html> accessed 25 February 2021.

[xlv] ‘Unconventional Gas’ (April 2011 Houses of Parliament) <https://www.parliament.uk/globalassets/documents/post/postpn374-unconventional-gas.pdf> accessed 19 March 2021.

[xlvi] ‘Composition of Components in Bowland Shale Hydraulic Fracturing Fluid for Preese Hall-1 Well’ (February 2012 Cuadrilla) <https://web.archive.org/web/20161028025458/http://www.cuadrillaresources.com/wp-content/uploads/2012/02/Chemical-Disclosure-PH-1.jpg> accessed 2 March 2021

[xlvii] Under Schedule 22 of the Environmental Permitting (England and Wales) Regulations 2010 and the EU Groundwater Directive (80/68/EEC).

[xlviii] Peter Hardy, CHAPTER 1: Introduction and Overview: the Role of Shale Gas in Securing Our Energy Future , in Fracking, 2014, pp. 1-45 <https://pubs.rsc.org/en/content/chapterpdf/2014/9781782620556-00001?isbn=978-1-84973-920-7> accessed 2 March 2021.

[xlix] Fiona Harvey and Adam Vaughan, ‘Fracking firm was barred from using chemical, Balcombe meeting told’ (10 October 2013 The Guardian) <https://www.theguardian.com/environment/2013/oct/10/fracking-chemical-balcombe-meeting> accessed 2 March 2021.

[l] ‘UK government’s fracking ‘ban’ has a convenient loophole’ (8 November 2019 The Conversation) <https://theconversation.com/uk-governments-fracking-ban-has-a-convenient-loophole-126475> accessed 25 February 2021.

[li] ‘Frequent Questions: Health Information About Ethylene Oxide’ (US EPA) <https://www.epa.gov/hazardous-air-pollutants-ethylene-oxide/frequent-questions-health-information-about-ethylene-oxide#:~:text=Evidence%20in%20humans%20indicates%20that,of%20breast%20cancer%20in%20females> accessed 19 March 2021.

[lii] ‘Ethylene Oxide’ (BCPP) <https://www.bcpp.org/resource/ethylene-oxide/> accessed 19 March 2021.