Action | Expanding disclosure of ingredients used in well stimulation & completion & reviewing best practices |
Stage | NOIRA |
Comment Period | Ended on 2/12/2014 |
Full disclosure should be mandatory as a matter of principle for all chemical substances deposited in the environment where they do not occur naturally or in quantities substantially exceeding their natural occurrences (hereinafter referred to collectively as foreign substances). The environmental effects and health consequences of exposure to industrial chemicals are generally not well understood, especially when multiple substances interact in inherently complex environments.
There are at least two reasons why mandatory full disclosure should be regarded as a principle:
1. People have an unalienable right to know what foreign substances they are being exposed to.
Because of the current lack of disclosure, knowledge of the impact of foreign substances is greatly limited. Many people who have an interest in knowing the impact of these substances have no practical means of determining where they should investigate or what they should be looking for. It is not adequate for people to have to wait until symptoms become manifest before they have even an inkling that something might be wrong. By the time the symptoms become manifest, the problem foreign substance may be widely dispersed and expensive to remove, if it is possible at all to do so.
It is not enough to insist that if the users of foreign substances follow all the correct procedures, there will not be a problem. First, people don't always do what they are supposed to do, because of ignorance or willful neglect. Second, it is assumed that the procedures are adequate to address all circumstances in which the foreign substance is used. However, nature usually turns out to be more complex than people imagine, and circumstances occur that were not anticipated by the people devising the procedures. The consequence is that foreign substance end up in places where no one thought they would.
It is a teaching of the Baha'i Faith that people and the environment both have an intrinsic value that cannot be reduced to economic terms. Economics is only one factor of many.
The argument that it is too costly for businesses to comply with disclosure requirements comes from a too limited perspective. We need to consider not only the cost of compliance to businesses, but also the costs to society when foreign substances end up in places they are not supposed to be. Many businesses are quite happy to externalize these latter kinds of costs rather than take responsibility for avoiding problems and for cleaning up the messes when problems occur.
The claim that proprietary interests justify not disclosing the use of particular foreign substances violates people's unalienable right to know what foreign substances they are being exposed to. Otherwise, we would have to say that narrow economic interests trump every other value that is an intrinsic part of human spirituality.
Adopting the principle of mandatory full disclosure of the use of all foreign substances safeguards both the dignity and the civil rights of all people, and provides a means for verifying that we are responsible in our use of the environment. The welfare of businesses is dependent on, not opposed to, the welfare of the general population.