Comment on “Fracking with Forever Chemicals” by Physicians for Social Responsibility, issued July 2021

The recent publication “Fracking with Forever Chemicals” by the Physicians for Social Responsibility (PSR) has received national press coverage of its claims that the USEPA authorized the unsafe use of a per- and polyfluoroalkyl substances (PFAS) for hydraulic fracturing, that these chemicals are widely used by oil and gas operators in a dangerous manner, and that hydraulic fracturing should therefore be suspended.  Based on our detailed analysis of the FracFocus data used by PSR, GSI has developed a fact-based response to the PSR paper, which can be accessed at here.

We find that the PSR report presents an inaccurate and exaggerated picture of the use of PFAS in hydraulic fracturing and the risks posed to public health and the environment.   Our key findings include:

  1. PFAS fluids have been used in less than 1% of hydraulic fracturing projects nationwide, meaning that over 99% of hydraulic fracturing projects used no such chemicals.
  2. Over 99% of the projects on record that used PFAS were located in Texas, Oklahoma, and New Mexico, where hydraulic fracturing occurs at great depth, nearly all produced water is captured for reinjection into deep brine strata, and impacts by hydraulic fractures on drinking water aquifers have not been observed and are very unlikely to occur.
  3. The FracFocus records show that the limited use of PFAS occurred principally prior to 2017 and current use is nearly non-existent.
  4. None of the PFAS health effects described by PSR have been associated with PFAS use for hydraulic fracturing, nor have any of the PFAS impacts on drinking water systems in the US been tied to hydraulic fracturing operations.
  5. USEPA did not approve the unsafe use of PFAS in hydraulic fracturing fluids. To the contrary, the products in question were never proposed for use in hydraulic fracturing, were never used for hydraulic fracturing, and, consistent with applicable regulations, were subject to USEPA restrictions on their manufacture, import, and use.
  6. Oil and gas drilling and well completion operations incorporate numerous measures to protect groundwater, subject to strict regulations, which PSR has ignored.
  7. Hydraulic fracturing has not caused widespread groundwater impacts, as has been confirmed by numerous studies.
  8. PSR’s recommendations regarding hydraulic fracturing are duplicative of existing regulatory programs and are not based on objective science. 

We hope that this information is helpful to you.  Please contact us with any questions or comments that you may have on this paper or related issues regarding effective environmental management for oil and gas operations.

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