Disclosure of chemical names used in onshore oil and gas

The request was partially successful.

Dear Environment Agency,
I’ve recently looked at the list of chemicals proposed by UKOG in their environmental permit at Broadford Bridge and there is a lot of missing information. It is important that we are aware of the health testing data from the manufacturer of the products used in the oil and gas industry.

Please can you disclose the identities of the chemicals listed below and release toxicological and ecological information; persistence and degradability as well as bioaccumulation potential and mobility in the soil for the following chemicals (listed 1-13)? There are additional questions below. Please can I also receive the CAS numbers for all the chemicals.

1. Protekt 4144
2.Protekt 4200
3. Protekt 4852-
please can you report accute toxicity (oral and inhalation)

6. CFR-8L
7. CONQOR 404 NS
8. CT-17/02WT
9. CT-31/02WT


11. HALAD 300L

12. HR-4L
13. NF-6--

Many thanks for your help with this.

Emily Mott
Markwells Wood Watch

Yours faithfully,

Emily Mott

Enquiries, Unit, Environment Agency

5 Attachments

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7 Attachments

Emily Mott

Markwells Wood Watch




Dear Emily


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




Please refer to the [2]Open Government Licence which explains the
permitted use of this information.


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


[3]ssd[Environment Agency request email]


Further information

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

Wycliffe House

Water Lane




Tel: 0303 123 1113

Website: http://ico.org.uk


For more information about how we regulate the onshore oil and gas
industry please visit our [4]information page.

For information on what you can expect from us and our full service
commitment to you, please follow this link





Kind regards



Customers & Engagement | Environmental Planning and Engagement | Solent
and South Downs Area | Environment Agency | Guildbourne House, Chatsworth
Road, Worthing, BN11 1LD

[6][email address]

National Contact Call Centre:  03708 506506
[7][Environment Agency request email]









Relevant exceptions


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

“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



Where EIR Regulation 13 applies, we are not required to carry out a Public
Interest Test.






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