Online Program

Regulation of Technologically Enhanced Naturally Occurring Radioactive Materials (TENORM) under State Law: How Effective Is it? What More Needs to Be Done?

Tuesday, November 3, 2015

Elizabeth Glass Geltman, JD, LLM, Environmental & Occupational Health Sciences, CUNY School of Public Health, New York, NY
When materials are removed from the earth during oil and gas drilling, Naturally Occurring Radioactive Materials  (NORM) becomes Technologically Enhanced Naturally Occurring Radioactive Materials (TENORM). Exposure to TENORM can cause health issues associated with radiation. TENORM can be found in most aspects of oil and gas operations, including millions of gallons of produced waters, miles worth of drilling sludge and other wastes that may contain TENORM and are shipped off site. Fracking has increased the amount of TENORM contaminated materials. Not all states regulate TENORM but a growing number do.

We used principles of legal epidemiology following PHLR policy surveillance protocols to examine the relative effectiveness of state TENORM regulation in the oil and gas industry to protect public health and the environment. We began by collecting documents referencing TENORM, NORM, radon or radium using LEXIS and state law databases. We reviewed the laws and regulations of all 50 states against preset codes using LawAtlas WorkBench. Coders crosschecked each other’s work to determine consistency. Our review concluded that there is a growing number of states that are regulating handling, treatment and disposal of TENORM in the oil and gas industry. Many states entering the regulatory field sought to regulate in order to relax regulation on industry.

Learning Areas:

Environmental health sciences
Public health or related laws, regulations, standards, or guidelines
Public health or related public policy

Learning Objectives:
Analyze the different regulation of Technologically Enhanced Naturally Occurring Radioactive Materials (TENORM) by states in the oil and gas industry Evaluate the effectiveness of different state regulatory approaches to TENORM Discuss alternative TENORM regulation Compare regulation of TENORM in the oil and gas industry to medical, industrial and nuclear energy activities

Keyword(s): Law, Environmental Health

Presenting author's disclosure statement:

Qualified on the content I am responsible for because: I am an associate professor and program director of Environmental & Occupational Health Sciences at a major, urban School of Public Health. I am also an attorney and the author of 17 books on environmental and natural resources policy.
Any relevant financial relationships? No

I agree to comply with the American Public Health Association Conflict of Interest and Commercial Support Guidelines, and to disclose to the participants any off-label or experimental uses of a commercial product or service discussed in my presentation.

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