Markwells Wood Watch
Thank you for your email concerning the onshore oil and gas site at Broadford Bridge, which
we received on 15 June 2018. We respond to requests under the Freedom of Information Act 2000 and
Environmental Information Regulations 2004
You requested information relating to the chemicals approved for use at the Broadford
Bridge Well Site operated by Kimmeridge Oil and Gas. The chemicals are listed within the
Waste Management Plans approved under the permit. These include the chemicals you
have listed with the exception of the biocides SAFE-CIDE and the corrosion inhibitor
CONQOR 404 NS.
Please see the attached material safety data sheets for the products listed. These give
information about the composition, toxicity and environmental fate, where it is available. The
sheets include the CAS number for the chemical that make up the products used.
The chemical abstract service (CAS) is a division of the American Chemical Society. Their
services are detailed within their web site at www.cas.org. One of the services includes
maintaining a register of chemical substance information. The reference number within that
register is used globally to identify specific chemicals.
The material safety Data sheets can be accessed via the following sharefile link https://ea.sharefile.com/d-sf4f09b8b0094654b
Please refer to the Open Government Licence which explains the permitted use of this
Please note the link is available for 30 days.
Whilst we are able to provide the information requested, the data sheets include personal
data relating to employees of a third party. This information has been redacted
The Environment Agency is not able to disclose personal data relating to employees of a
third party, this is personal data under the Data Protection Act 2018 (DPA 2018) and to
disclose it would breach the First Data Protection Principle of the DPA 2018.
As a public body we are required under the Freedom of Information Act/ Environmental
Information Regulations to give reasons for this refusal.
You can find the details in the appendix attached
Please send any future correspondence to our team email account at firstname.lastname@example.org
Please get in touch if you have any further queries or contact us within two months if you
would like us to review the information we have sent. We shall review our response to your
request and give you our decision in writing within 40 working days.
If you are still not satisfied following this, you can raise a concern with the Information
Commissioner, who is the statutory regulator for Freedom of Information and the
Environmental Information Regulations. The contact details are:
Information Commissioner’s Office
Tel: 0303 123 1113
For more information about how we regulate the onshore oil and gas industry please visit our information page.
For information on what you can expect from us and our full service commitment to you,
please follow this link https://www.gov.uk/government/publications/environment-agency-customer-service-
Customers & Engagement | Environmental Planning and Engagement | Solent and South
Downs Area | Environment Agency
| Guildbourne House, Chatsworth Road, Worthing,
BN11 1LD email@example.com
National Contact Call Centre: 03708 506506 firstname.lastname@example.org
The exceptions which apply to the withheld information are:
‘To the extent that the information requested includes personal data of which the applicant is
not the data subject, the personal data shall not be disclosed otherwise than in accordance
with Regulation 13.’
EIR Regulation 13 sets out at length the necessary consideration of the requirements of the
Data Protection Act 2018 (DPA 2018).
The Environment Agency is not able to disclose personal information relating to third parties
as this is personal data under the Data Protection Act 2018 (DPA 2018) and to disclose it
would breach the First Data Protection Principle of the DPA 2018.
The information requested is therefore exempt due to Regulation 13(1) of the Environmental
Information Regulations 2004, which explains that:
“To the extent that the information requested includes personal data of which the applicant is
not the data subject, a public authority must not disclose the personal data if—
(a) the first condition is satisfied…”
The ‘first condition’ referred to above is further explained in Regulation 13(2A):
“The first condition is that the disclosure of the information to a member of the public
otherwise than under these Regulations—
(a) would contravene any of the data protection principles…”
It is the view of the Environment Agency that the information requested is personal
information and its disclosure would contravene the first data protection principle of the Data
Protection Act 1998.
The First Data Protection Principle requires that we are fair to individuals when we collect
and use their personal data. In this case it would be unfair to disclose information relating to
an identifiable individual as such individuals have a reasonable expectation that any
information held about them by the Environment Agency would remain confidential.
Where EIR Regulation 13 applies, we are not required to carry out a Public Interest Test.