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AITC Center for Health Impact Assessment

HIA News & Updates:

  • Completed HIAs
  • AITC Publications on HIA
  • AITC HIA training documents
  • Testimony and comment letters on Health Impacts of Resource Development

In partnership with Aaron Wernham, MD, MS, a fellow with the Columbia University Institute on Medicine as a Profession, the AI-TC is beginning a new initiative aimed at addressing the public health impacts of industrial development on Alaska Native communities. Through this initiative, AI-TC is available for limited consultations with any Tribe facing a regional industrial development proposal. Our initial work targets North Slope oil and gas development, but we are beginning to expand the initiative to help Tribes address their concerns about mining proposals as well. The goals of our project are:

  • Ensuring that the health impacts of oil and gas development on Alaska Native communities are adequately addressed in the planning, permitting, and regulation of industrial development
  • Giving communities a stronger voice in industrial permitting and regulatory decisions
  • Protecting Alaska Native health, lands, and culture
  • Building local capacity for Health Impact Assessment in Alaska Native communities facing industrial development proposals.

Alaska Native communities are facing an unprecedented number of new proposals for oil and gas development, mining, and logging. Large-scale industrial development is associated with a wide range of social, cultural, economic, and environmental impacts, with profound implications for physical, emotional, and spiritual well-being in Native communities. Yet the permitting process for these projects does not generally include a systematic evaluation of the impacts on human health.

A 2003 National Academy of Science review of the cumulative impacts of North Slope development concluded that there has not been adequate attention to human health in the North Slope regulatory process[1]. North Slope residents have testified to a wide range of health impacts which many believe are related in part to local development. Examples of community concerns include:

  • Cancer and thyroid problems from contamination of subsistence resources.
  • Asthma and respiratory problems because of gas flaring.
  • Social and psychological problems such as increases in alcohol and drug abuse, domestic violence, depression, anxiety, and suicide because of increased stress, cultural change, and impacts to subsistence resources.
  • Increases in diabetes, strokes, and cardiovascular diseases because of greater reliance on store-bought foods as subsistence resources become scarce.
  • Changing patterns of infectious disease because of the influx of outside workers into previously isolated villages.

Yet none of these concerns have been evaluated in depth in the EIS process for permitting new developments.

The National Environmental Policy Act and Human Health
The National Environmental Policy Act of 1969 (NEPA) created the Environmental Impact Statement (EIS) process, through which large industrial development proposals are regulated. Environmental Impact Statements are a way of evaluating the potential effects of a proposed project, and disclosing them to the public and political decision-makers. The EIS forms the basis of the government’s decision regarding whether or not to allow a proposed development: regulators review the impacts identified in the EIS, and determine whether to issue a permit based on a consideration of the relative risks and benefits.

A typical EIS contains up to 3,000 pages of detailed information addressing every aspect of the potential effects on the ecosystem, individual animal species, and air quality and water quality. Surprisingly, however, EIS do not include a comprehensive analysis of potential public heath effects, aside from occasional brief discussions of contaminant-related concerns. Several surveys of EISs in the US have documented this problem. The lack of health information in EISs means that regulators are not clearly considering the potential impacts on local communities in making permitting decisions.

Yet NEPA itself, and the regulations governing it implementation, clearly define human health as one of the fundamental concerns that federal agencies should address in an EIS. Based on our [link to below] AI-TC has successfully argued this point with the Bureau of Land Management and the Minerals Management Service, both of which have now agreed to include a [link to below] in future EIS for North Slope development. We believe that the same laws apply to any NEPA-based permitting activity, whether it applies to oil and gas, mining, logging, or similar activities. Tribes can use these laws to protect the health and well-being of their communities.

The Legal Requirement to Address Health in an EIS
NEPA’s initial statement of intent includes promoting efforts which will “stimulate the health and welfare of man.” With 5 subsequent references to health, NEPA defines the preservation, protection, and stimulation of health among its primary objectives. Among the goals discussed in NEPA are:

  • To “ensure for all Americans safe, healthful, aesthetically and culturally pleasing surroundings.”
  • To “attain the widest range of beneficial uses of the environment without degradation, risk to health and safety.”
  • To “prevent or reduce adverse effects that endanger the health and well-being of man.”

40 C.F.R. Section 1500, established the guidelines for the EIS process as mandated by NEPA. Often quoted as requiring evaluation of the “human environment” (40. C.F.R. §1500.2) actually establishes far more specific requirements regarding health. Specifically, it defines the “effects” of a NEPA action to include:

  • Ecological (such as the effects on natural resources and on the components, structures, and functioning of affected ecosystems), aesthetic, historic, cultural, economic, social, or health, whether direct, indirect, or cumulative” (emphasis added). (40 C.F.R. § 1508.8)
    40 C.F.R. furthermore directs agencies to consider “the degree to which the proposed action affects public health or safety” when evaluating the “intensity” of an impact (40 C.F.R. § 1508.27).

  • Executive Order 12898 on environmental justice directs federal agencies to consider the health effects of their actions with regard to Native American communities, stating:
    Each Federal agency shall make achieving environmental justice part of its mission by identifying and addressing, as appropriate, disproportionately high and adverse human health or environmental effects of its programs, policies, and activities on minority populations and low-income populations in the United States.

The CEQ guidelines on implementing E.O. 12898 strongly suggest that to accomplish the goal of ensuring environmental justice, federal agencies must include relevant public health data in their analyses, and should consider consulting with local public health agencies.
Finally, the issue of health must be addressed because it has been raised in a substantive manner by numerous residents in testimony, and by the National Research Council in its congressionally-commissioned report on cumulative effects of North Slope development:
Human-health effects, including physical, psychological, cultural, spiritual, and social, have not been adequately addressed or studied. (National Research Council, 2003)

The report concludes with a strong recommendation that all aspects of human health be better addressed both through research and through planning efforts. Although this recommendation was made prior to the NEPA process for the Northeast NPR-A Amended EIS, the Amended FEIS still did not address human health in a systematic or comprehensive way.

Health Impact Assessment – a brief introduction
Health impact assessment (HIA) is a method for assessing the potential impacts of a proposed project on human health. It is similar to the EIS process, relying on available scientific data, public testimony, and modeling to predict potential impacts. HIA looks at health broadly – including social, emotional, and cultural impacts as well as physical. According to the World Health Organization, HIA is based on 4 principles[2].

  1. Democracy – allowing people to participate in the development and implementation of policies, programmes or projects that may impact on their lives
  2. Equity – HIA assesses the distribution of impacts from a proposal on the whole population, with a particular reference to how the proposal will affect vulnerable people (in terms of age, gender, ethnic background and socio-economic status)
  3. Sustainable development – that both short and long term impacts are considered, along with the obvious, and less obvious impacts
  4. Ethical use of evidence – the best available quantitative and qualitative evidence must be identified and used in the assessment. A wide variety of evidence should be collected using the best possible methods

There are 5 stages involved in completing an EIS:

  1. Screening: determine if the proposed development is large enough to require HIA
  2. Scoping: public meetings and literature review to determine the potential health concerns to be analyzed
  3. Assessment/Analysis: using existing data, model the potential health effects; develop mitigation measures
  4. Reporting and Evaluation: write the HIA, and present it for public review
  5. Monitoring and reassessment: throughout the course of the development, monitor health effects, and make modifications to the development plans as necessary

HIA has been used extensively outside the U.S. The World Bank now requires it for large development loans. It has been utilized it for large oil and gas projects such as the Chad-Nigeria pipeline. Canada regularly incorporates it into environmental impact assessments. The World Health Organization has recognized its value for protecting human health and encouraging responsible development, and also strongly advocates its use in evaluating any large industrial project. Many large corporations require HIA as part of a code of corporate responsibility. Shell Oil, for example, recently completed an HIA for the Sakhalin 2 development program in Russia. The U.S. Centers for Disease control has expressed interest and support for HIA. Yet to date the use of HIA in the U.S. is still uncommon.

Until our recent work on the North Slope, an HIA had never been included formally in a U.S. EIS. In view of the wide-spread use of HIA outside of the U.S., the AI-TC believes there is no justification to apply a less protective standard for development that impacts Tribes in the U.S.

HIA Links:
1. World Health Organization Health Impact Assessment Webpage: http://www.who.int/hia/about/why/en/index.html

2. U.S. Centers for Disease Control Health Impact Assessment Webpage: http://www.cdc.gov/healthyplaces/hia.htm

3. UCLA Health Impact Assessment program: http://www.ph.ucla.edu/hs/health-impact/

4. International Association of Oil and Gas Producers Health Impact Assessment Guide: www.ipieca.org/activities/health/downloads/publications/hia.pdf

5. HIA Blog: http://healthimpactassessment.blogspot.com/

6. HIA Gateway: http://www.hiagateway.org.uk/page.aspx?o=hiagateway

Active AI-TC Health Impact Assessment Projects:
The AI-TC, in cooperation with the North Slope Borough, has completed a number of health impact statements as well as comment letters focused on health impacts. We are working with the regulatory agencies to develop health-focused mitigation measures which will become part of the regulatory requirements for developers.

1. Completed Health Impact Assessments:
a. Outer Continental Shelf Oil & Gas Leasing Program, 2007-2012 Final Environmental Impact Statement (expected May 2007)

b. Chukchi Sea Planning Area Oil and Gas Lease Sale 193 and Seismic Surveying Activities in the Chukchi Sea Final Environmental Impact Statement (expected summer, 2007)

c. Northeast NPR-A Supplemental EIS (expected summer, 2007)

2. Comment Letters:
[links to separate files for these letters]
The following excerpts from letters were submitted by the NSB over the last year. The public health sections were contributed by Dr. Aaron Wernham and AI-TC.
a. MMS Beaufort Lease Sale 202 Comments
b. BLM Northeast NPR-A Supplemental EIS

3. Conference Presentations:
[links to separate files for these presentations]
a. Presentation to Minerals Management Service, Department of the Interior, Bureau of Land Management, and EPA, 2006
b. Presentation to NTEC, (expected May 2007)

Health Impacts Database
Under Construction: this page will contain a database of studies that may help Alaska Native communities evaluate the potential impacts of industrial proposals on their communities.

Contacts for AI-TC Health Impact Assessment Program
Aaron Wernham, MD, MS
Alaska Inter-Tribal Council
Fellow, Columbia University Institute on Medicine as a Profession
2050 Cripple Creek Rd.
Fairbanks, AK 99079
Office: (907) 451-4441
aawernham@pol.net

How to start using HIA in your community
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[1] National Research Council (2003) Cumulative Environmental Effects of Oil and Gas Activities on Alaska’s North Slope. Washington, D.C.: the National Academies Press.

[2] World Health Organization (2007) Health Impact Assessment Website. Accessed online on April 16, 2007, at http://www.who.int/hia/about/why/en/index.html