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Shell in the rest of the world
Neglect of human rights
NIGERIA: Shells operations in the Niger Delta in south-east Nigeria are the best documented case of the environmental and human impact of oil exploitation. Nigeria is by no means unique; the abuses of the Delta repeat themselves wherever oil and gas are extracted around the world.
Shell has extracted oil from the Niger Delta since 1958. Shell operates a joint-venture also consisting of Nigerian National Petroleum Corporation, Elf and Agip[71]. That means Shell has the operational and thus legal responsibility for the damages that the consortium causes. Shell is by far the largest foreign oil company in Nigeria, accounting for 50% of Nigeria's oil production[72]. Nigeria generates roughly 12% of Shell's oil production world-wide[73].
Nigeria is a military dictatorship heavily dependent on oil. By the early 1990s, oil production accounted for 90% of the country's foreign exchange receipts[74]. The laws under which Shell operates are unjust and brutally repressive: military decrees have removed people's fundamental human rights to land and resources, and to freedom of speech and assembly.
Shell is thus given free rein to extract as much oil as it can. High-pressure pipelines have been laid above ground through villages and farmlands without consent. There have been 190 spills per year since 1989, involving on average 319,200 US gallons of oil[75]. Rivers, lakes and ponds are polluted with oil, and much of the land is now impossible to farm. Canals, or 'slots', have permanently damaged fragile ecosystems and led to polluted drinking water and deaths from cholera. Gas flaring and the construction of flow stations near communities have led to severe respiratory and other health problems, and contribute massively to climate change. Exploratory and other work has devastated more rainforest, mangrove and wetland habitat, threatening the biodiversity of the extremely sensitive ecology of the Niger Delta.
Up to 76% of the gas from Nigerian oil wells is flared (burned off), as compared with 0.6% in the US and 4.3% in the UK[76]. Flaring often occurs very close to communities, which causes severe respiratory and other health problems, as well as the disruption of all-night lighting and roaring flames (which also impacts on wildlife). It is a major cause of both acid rain and greenhouse emissions. Most gas flares of Shell in Nigeria are horizontal, which is even more damaging, as the fumes go straight into the soil[77].
Shell promised in 1996 to cut out all unnecessary gas flaring by the year 2008. This target is used as a justification for Shells investment in a Liquefied Natural Gas (LNG) project, to start using gas in 1999. However, the LNG project will use only just over 300m cf/d of the 2000m cf/d flared in Nigeria at the moment[78].
Meanwhile, peaceful protests at oil installations have been brutally crushed by the regime's Mobile Police Force whose presence Shell has repeatedly requested. Much of the Delta is now militarised. Killings, beatings, rapes, large-scale looting, arbitrary arrests and torture are commonplace. In Ogoni alone industrial and military activity have resulted in 2000 deaths and over 100,000 internal refugees. Many protestors against Shell have been detained without trial in appalling conditions.
The Rivers State Internal Security Task Force has been used to maintain militarisation of Rivers State since April 1994. In May 1994, the then leader of the task force Major Okuntimo wrote in a leaked internal memo: "Shell operations [are] still impossible unless ruthless military operations are undertaken for smooth economic activities to commence." He called for "pressure on oil companies for prompt regular inputs as discussed"[79]. There was international outcry when Ken Saro-Wiwa and eight other Ogoni were executed; now a further 20 await the same fate, although it is thought more likely that they will be held in prison until they die (due to poor sanitation and lack of medical care) rather than attract the bad publicity of executions again.
Forced last year to admit having imported weapons and paying the military in Ogoniland, the company has in fact financed military operations throughout the region, and supplied vehicles, boats and a helicopter to transport soldiers who have raided villages. Top officials from Shell even offered to use their influence to help free Ken Saro-Wiwa - if international protests against the company were called off. And according to the World Council of Churches, key witnesses for the prosecution at Saro-Wiwas trial have now signed sworn affidavits admitting that they were bribed by Shell to testify[80].
Shells response to all this has been to concentrate on its public relations. It has made countless promises about how it will improve its environmental performance (promises which earn it points in the publics eye) and not bothered to live up to them. It has also tried to be seen to be helping the communities with schools, hospitals etc, but in reality in many cases it has essentially just done the paintwork on an almost completed job, and taken the credit for it[81]. Often the most desperately needed facilities are ignored by the company.
In June 1997, when Shell refused to pay compensation for a 1982 oil spill, although ordered to by a court, the four affected Ijaw communities gave Shell an ultimatum to leave the oil producing area by July 8, or be forced out. Hours before the deadline expired, the leader of the community was arrested by the State Security Service (SSS). "Worried that the said payments will encourage other legitimate compensation demands, Shell has alerted the security forces and this morning Mr Matthew Eregbene has been whisked away," said a spokesman for the Niger Delta Oil-Producing Communities Development Organisation. Shell allegedly later tried to bribe the community leaders, and pressurised them through locals which had contracts with the company[82].
For more information on Shell and Nigeria, contact Delta: 0116 255 3223.
PERU: Shell signed a 40-year, $2.7 bn contract in 1997 to exploit the vast Camisea gas field, which will be one of the largest gas operations in South America. The land is home to Nahua and Kugapakori Indians, semi-nomadic hunter-gatherers whose well-being is inseparable from the well-being of the rainforest; it is their source of food, shelter, and the focus of their spiritual life. But Shell's plans to drill on the reserve will do worse than just compromise their traditional way of life. Both groups are previously uncontacted, making them extremely vulnerable to Western diseases. When Shell conducted preliminary exploration of the region in the mid-'80s, opening the rainforest to outsiders, the Nahua were exposed to a whooping cough and influenza epidemic that killed off an estimated 50% of the population[83].
Survival International maintains that over 15,000 Indians are at risk or have been affected[84]. The World Wide Fund for Nature is reported to be concerned that local people would be "severely affected" by any developments[85]. "Consultation" procedures have been rushed through, often without a lawyer or even a translator for the local people.
Local demonstrations against Shell have met with violence from the police. In September 1984, 40 Indians were reported killed by Shell's helicopters[86]. Over 70% of the workforce are non-local, leading to tensions and migration problems.
Scientists recently recorded the highest number of animal, bird, insect, and plant populations found anywhere on the planet in this area. Shell has promised to operate to the highest possible environmental and social standards; however reports are already in of erosion, river pollution and disruption to local hunting and fishing patterns. Dozens of Machiguenga communities are located alongside the rivers inside Shell's area of operation, each one facing the likelihood that drilling waste will contaminate its water supply.
For more information, contact Project Underground, 1847 Berkeley Way, Berkeley CA, 94703.
TIMOR GAP / INDONESIA: East Timor was violently invaded by Indonesia in December 1975. Over 200,000 people, approximately one third of the population have been killed as a result of the armed occupation, which continues to this day in defiance of UN resolutions and international law. Torture and brutal repression are widespread. To the south of East Timor is the Timor Gap, which contains up to 5 billion barrels of oil and 50,000 billion cubic feet of gas, and is among the 25 largest oilfields in the world. In December 1989, the Australian and Indonesian Governments signed the Timor Gap Treaty, to divide the Timor Gap between them. The East Timorese were not consulted. The Treaty is widely regarded as unlawful under international law in that it infringes the right of the people of East Timor to self-determination, to territorial integrity and to permanent sovereignty over their natural wealth and resources. Portugal challenged the Treaty in the International Court of Justice, but because Indonesia does not recognise its jurisdiction, the Court decided that it could not rule on the substantive legal issues.
Since 1991 11 licences have been granted in the Indonesian/Australian shared central (and largest) zone, of which Shell, the largest investor in the Timor Gap, has acquired interests in five. Shell also has one block in the Australian zone.
For more information, contact Tapol, 8 Hop Gdns, London WC2N 4EH. 0171 497 5313.
COLOMBIA: Shell has a 25% interest in the Cano Limon fields, which produce one third of Colombia's total oil production. However these fields are expected only to last until about 2007, so Shell has been exploring for new sites. The company, in joint venture with Occidental and Ecopetrol (the state-owned company), has been granted licenses to explore and exploit Samore, an area in the Andes which includes both the traditional lands and the much smaller designated reserve of the U'wa people. The U'wa live in and from the forest, and want neither compensation nor development; they simply want to continue their peaceful lifestyle. They have threatened a ritual mass suicide if Shell and Oxy start drilling on their land, which could happen any time[87].
CHAD: in mid 1997, Shell, Exxon and Elf announced plans to develop three oil fields in southern Chad, to come onstream in 2000. The oil will be transported to the Cameroonian port of Kribi along a 1,000-mile pipeline which is to be funded by the World Bank. The Bank's involvement provides insurance against political risk and is expected to attract private sector funding. However, the area is quite politically unstable, and as happens around the world, the introduction of oil, infrastructure, money and financial dependency will almost certainly aggravate existing tensions. The fields are to be in the area which is central to the rebellion against the northern government; the present fragile truce would be unlikely to survive the north's controlling the huge oil wealth of the south.
Land in the most fertile part of Chad will be lost to the 300 wells plus pumping stations and roads. Many people will be displaced to make room for the oil infrastructure. Some stretches of the pipeline will run through undisturbed rainforest inhabited by indigenous people. The pipeline also brings risks of leaks into groundwater and rivers. And where the pipeline reaches the port lies between two nature reserves.
The Chadian government has been accused by Amnesty International of torture and extra-judicial killings[88].
SOUTH AFRICA: In the late eighties during the Apartheid era, when 1% of Shell's profits came from South Africa[89], with investments of $400m in the country[90], Shell received much criticism for its breaking of international sanctions, as well as providing fuel to the South African army and police[91].
Access to oil for the South African economy was crucial, as the country has no oil reserves of its own. Therefore oil was considered a powerful tool for a South African boycott to end apartheid. The United Nations and OPEC, amongst others, called for a boycott of oil supplies. However Shell continued to import oil to South Africa[92], and in the eighties was its largest supplier of energy, including supplies to the South African Military[93]. In 1984, Shell was reported to have received incentives' worth $400 million from the South African Government to break the oil embargo, although the company denied the claim[94].
In 1988 in the face of mounting evidence collated by anti-apartheid campaigners, Shell had to publicly admit that it was importing South African coal to the European market on a large scale. At the time coal was South Africa's second most valuable export after gold.
In 1988, Shell sued the Dutch city of Hilversum, after the town refused to consider Shell for municipal oil supplies due to Shell's South African activities[95].
Shell has also broken other boycotts in Southern Africa. For example, Shell, along with BP, Caltex, and Mobil, sold oil through bogus intermediary companies to what was then Southern Rhodesia (now Zimbabwe), which at the time was under a UN boycott, in the mid-1970's. In the late eighties, against United Nations decrees, Shell was also operating, and supplying the South African military in Namibia[96].
In the late eighties documents came to light showing that Shell had hired Pagan International, a PR firm in the US, to run an anti-boycott campaign. Codenamed the Neptune Strategy' it involved recruiting well-known public figures to promote Shell's position, to investigate the personal characteristics' of key boycott supporters and to infiltrate boycott meetings[97].
BURMA: From 1989 to 1993, Shell explored for oil and gas in Burma (Myanmar), giving the military junta, the State Law and Order Restoration Council (SLORC) both badly needed foreign currency and an undeserved endorsement of legitimacy. Shell left Burma for commercial reasons, not because of the Government's appalling human rights record. As one Shell official stated: "We have decided to relinquish it [the concession] purely due to disappointing results"[98]. Shell worked in Burma despite its knowledge that "The country is a source of potential regional instability ...The junta refused to honour the election results which elected Aung San Suu Kyi ... Once one of the more prosperous countries in that part of the world, it is now one of the poorest in the region. The State Law and Order Restoration Council (SLORC) allegedly spends 60 per cent of state revenue on military expenditure"[99].
BRAZIL: Shell has been involved in Brazil for 80 years (currently just offshore). When Brazil proposed constitutional changes in July 1988 which included a nationalisation of mineral rights, tighter controls on joint ventures and prohibition of risk contracts, plus reduction of the working week from 48 to 44 hours, extension of the right to strike, increase in social security benefits and the granting of a week's paternity leave, Shell joined with 16 other transnational corporations with Brazilian interests who agreed to spend $2 million on advertising and lobbying against the bill[100].
OTHER: In 1991, a former executive was awarded $5.3 million in damages for being sacked "solely because he was a sexually active homosexual"[101].
In August 1992, Shell announced that it was introducing drug and alcohol tests for its staff[102].
Double standards
While Shell tells the public that it applies common standards of business ethics worldwide, in reality its view contradicts that. "The need to safeguard the environment is universal, but the same action is not necessary or appropriate in every location. Ecological, technical, economic and other circumstances vary, so solutions and what may feasibly be achieved in a given time will also vary. This approach is consistent with Principle 11 of the Rio Declaration from the Earth Summit in June 1992, which states: '... Standards applied by some countries may be inappropriate and of unwarranted economic and social cost to other countries in particular developing countries.' "[103]. In other words, in the developing world, where Shell can get away with it, it will adopt lower (and cheaper) standards.
Production of dangerous toxic chemicals
"Drins": Since the 1950s Shell has been the sole producer of the three "drin" pesticides aldrin, dieldrin, and endrin[104] which are toxic chlorinated solvents sold as sister products to DDT[105]. Despite repeated warnings over their continued use as early as the fifties and continuing through the sixties and seventies, Shell only stopped production of endrin in 1982, of dieldrin in 1987, and aldrin in 1990, and only ceased sales of the three in December 1991[106]. The "drins" are on the Red List' of dangerous chemicals in the UK [107], and the EC Black List' of dangerous substances[108]. Endrin and aldrin are classified as highly hazardous' by the World Health Organisation; and the World Wide Fund For Nature has classified "drins" as extremely hazardous[109].
The chemicals are extremely environmentally persistent110 and bioaccumulate up the food chain. They have caused numerous poisonings of workers and consumers, some involving mass fatalities ... The drins have also been linked to chronic health problems: the US Environmental Protection Agency classifies aldrin and dieldrin as probable human carcinogens, all of the drins have been associated with birth defects in test animals; other long-term health effects linked to one or more of the drins include liver damage and delayed neurotoxicity[111].
In 1990, aldrin was found to have caused widespread contamination in the Newlyn catchment area of Cornwall in the UK, having been used by potato and daffodil growers[112]. Shell refused to accept liability because the chemical had been approved by the UK Ministry of Agriculture Fisheries and Food. A report undertaken by the National Rivers Authority, concluded that detailed research had not been undertaken by the company before marketing the product[113].
Aldrin has been banned from the European Community[114]. Despite the severe health consequences, in 1990, having stopped production, Shell was still selling its remaining stocks of "drins" to developing countries, and to Spain and Australia[115]. Shell Netherlands is still reported to have an agreement with the Malaysian Government to supply the country with aldrin and dieldrin until the Malaysian government decides to the contrary[116].
DBCP: DBCP or 1,2-Dibromo-3-Chloropropane, is a highly persistent toxic pesticide. It is classified by the World Health Organisation, as extremely hazardous'[117]. It causes sterility in humans and is mutagenic and carcinogenic in animals[118].
Shell, along with chemical company Dow, discovered and developed DBCP in the 1950s. The companies deliberately minimised the impacts found in their animal studies. Although Government officials requested further information on its toxicity, they succumbed to pressure by Dow and Shell for speedy regulatory approval. In 1964 Dow and Shell were granted licences for marketing DBCP. The label and public information on the product concealed its actual hazards. It omitted recommendations for users to wear safety equipment, and the pesticide was not described as toxic.
The EPA banned DBCP production in the USA in 1977, due to concerns over oncogenicity, mutagenicity, reproductive effects and groundwater contamination. Shell and Dow continued to ship the poisonous pesticides to Standard Fruit in Costa Rica after the US ban[119]; as a result between 1,000 and 2,000 Costa Rican plantation workers are sterile[120]. An executive who helped develop DBCP for Shell said "Anyway from what I hear, they could use a little birth control down there."[121] Furthermore, even though DBCP is a known carcinogen, Shell and Dow did not take adequate steps to warn the workers about the hazards or consequences of the product, and didn't provide workers with information which would have minimized the risks of exposure[122]
In February 1992, the leader of the Honduras National Workers Federation, Mario Quintanilla claimed that chlorinated pesticides made by Shell and Dow had killed 14 workers[123].
DBCP has subsequently been banned from the majority of other countries[124]. A study carried out by the Californian Health Service Department has linked DBCP with deaths from stomach cancer[125].
In 1989 Shell, Dow and Occidental Petroleum, were sued by the City of Fresno in California for unhealthy levels of DBCP found in 80 of the city's 200 wells. Shell is reported to have withheld information on the dangers of the pesticide[126].
Ground and water pollution
PRODUCTION FACILITIES: In 1992 Shell gained approval to dispose of low level radioactive waste into an injection well. This was the first time a well would have been used for radioactive material disposal. Brine from oil operations is sometimes more radioactive than that legally allowed to be discharged by nuclear power stations[127].
TANKERS: In response to post Exxon Valdez oil spill laws in the US, which impose unlimited liability on tanker owners and operators in the case of a spill, Shell stopped its tankers docking at US ports, except for the offshore port at Louisiana[128]. The company also announced in 1990 that it would now only charter tankers which had insurance cover of $700m against an environmental disaster, whereas the old premium limit was $400m[129]. In a move to further reduce its environmental liability, Shell has since cut the number of large oil carriers within its fleet from 114 to around 30 (to rely more on contract shippers)[130].In February 1992, a barge owned by the Sargeant Transportation Company carrying 20,000 barrels of asphalt and 5,000 of oil, sunk off the coast of Yucatan, causing a spill 13 km by 24 km. Shell was the owner of some of the cargo[131]. A local fishing cooperative spokesperson commented that the spill threatened the Yucatan's delicate ecology and that 90% of the fishing industry could be affected[132].
In 1989, Hess Oil, a subsidiary of Shell, spilt oil in Bannes Bay, on the Island of St. Lucia, which took over two weeks to clean-up. Environmentalists criticised Shell for: no spill clean-up equipment being on the island (it had to be imported from Barbados), for not carrying out assessments of the short term or long term damage of the spill, and for giving no public reassurances that measures were being implemented to ensure that the accident would not happen again[133].PIPELINES: Shell's largest spill was in December 1988, when 860,000 gallons of crude oil spilled in to the Gasconade, Mississippi, Vienna and Missouri rivers after a pipeline ruptured[134]. At the time the spill was the worst inland oil spill in US history[135]. The local Attorney General commented that: "The situation at Shell is intolerable"[136]. A sentiment shared by many people around the world.
REFINERIES AND CHEMICALS PLANTS: In April 1988, 440,000 gallons of crude oil was discharged into San Francisco Bay from the Martinez Refinery, after the drainpipe of a 12 million gallon storage tank ruptured and storm safety valves had been left open[137]. Just 19 months previously, 48,000 gallons of toxic wastewater had been spilt from the same refinery, after which Shell officials had been found negligent, and had promised to undertake preventative measures to make sure another spill did not occur[138].
Over 150 acres of wetland were affected by the 1988 spill, with 11 miles of shoreline polluted along the estuary at Martinez and Benicia in the Carquinez Strait[139]. The spill was said to have devastated a wildlife sanctuary[140], killing at least 350 birds, 50 reptiles and 40 mammals, with another 400 birds treated[141]. The area affected was extremely important to migrating salmon and bass[142]. The local party boat fishing business was also put out of business[143]. Shell's local refinery manager admitted that the company had violated a federally mandated spill response plan, Shell's own policies and standard industry practice[144]. 16 federal, state and local agencies filed suit against the company. In November 1989 Shell Oil Company agreed to pay $19.75m in damages for the spill, in an out of court settlement. At the time the settlement was the largest ever civil penalty in the US for an oil spill[145]. It was reported that between the end of 1989 and the end of 1991, Shell held 67 violations of federal air quality regulations at its Martinez refinery. Figures released in a 1991 "toxic hot spots" report, showed a high chance of contracting cancer around the Shell facility (20 in a million, over a 70 year life span)[146], although Shell denies this[147].
In September 1989 the Illinois state filed a $1.2m suit against Shell for 8 recent environmental mishaps at its St Louis refinery[148]. However by February 1990, the suit had to be updated to include a further nine accidents that had occurred at the refinery in the preceding four months, including the discharge of 204,000 gallons of gasoline into water supplies[149].
In 1989, Shell was also prosecuted under the Clean Water Act by the Natural Resources Defense Council for illegally discharging chemicals such as ammonia, grease, phenols, and hydrocarbons into the Mississippi River. Shell agreed to pay $380,000 in an out-of-court settlement, and $50 million in improving the refinery[150]. In February 1992, Shell, which had already spent $14 million on the clean-up, agreed to pay $8.4m to the US Federal and Missouri State Governments[151].
In June 1990, the environmental group Stichting Reinwater published a report indicating that four companies were responsible for strikingly high concentrations of toxic dioxins in the river Rhine. The effluent from one of the companies concerned, Shell Netherland Chemie of Rotterdam, was found to contain dioxin levels ten times higher than waters in the basin into which the effluent was discharged, despite the fact the company had no licence to emit dioxins[152].
A Shell gas processing plant on the St Clair River in Canada leaked 600 kilograms of benzene and 400 of toluene, causing two municipal drinking plants to be closed in January 1992[153].
Shell refinery in the Philippines has been criticised for causing water pollution. Shell management have been labelled as uncooperative. In 1991, the local Shell refinery manager reportedly said that the Shell facility did not cause any pollution, despite the fact that the refinery had recently failed a waste water effluent quality test[154].
Shell operated a refinery on the island of Curacao, part of the Dutch Antilles, off Venezuela, from 1918-1985. It eventually pulled out because of environmental legislation that it simply could not meet, and sold the refinery for the (now independent) Curacao government for the token price of one guilder. The sale was made on the condition that the government would never claim damages or clean-up costs from Shell, and Curacao is now left with vast air, sea and land pollution that it simply cannot afford to clean up[155].
ROCKY MOUNTAIN ARSENAL: From 1952-1982, Shell Oil manufactured 34 pesticides and herbicides on the US Army Rocky Mountain Arsenal site near Denver, USA. The site has been described as the most contaminated site on the planet[156]. Shell received profits of betwwen $12 million and $24 million a year from the plant[157].
In 1960, after criticism from a game warden from the Colorado Department of Fish and Game[158], Shell responded by stating that: "That's just the cost of doing business if we are killing a few birds out there ... As far as we are concerned, this situation is alright and we have no plans to change the operations"[159].
In fact, Shell was concealing the true extent of the wildlife damage. During the 1950s, it had a policy to collect all duck and animal carcasses in order to hide them before scheduled visits by inspectors[160].
In 1983, Shell was ordered by the Justice Department to pay for the clean up of the site, then estimated at around $1.8 bn[161], after it had been sued by the State of Colorado and the EPA. Despite the fact that the company had known it had been contaminating the environment for years, in October 1983, Shell subsequently tried (unsuccessfully) to sue its 270 insurers for its share of the clean up costs, on the grounds that the company did not know it was polluting the environment[162]. In retaliation, the insurers claimed that Shell was no more covered than a home-owner who set fire to his own home[163]. The Travellers Insurance Company has subsequently filed a counter suit against the oil company, claiming that Shell not only intentionally polluted the environment, but also misled the insurance company over the extent of pollution[164].
Residents living near the arsenal complain of repeated miscarriages, chronic nausea, unexplained diarrhoeas, dizziness, mysterious deaths of their pets[165].
STORAGE FACILITIES: In 1987, the State of Connecticut filed suit against Shell for failing to report an underground leaking storage tank as well as failing to clear up the pollution. As a result, 9,600 gallons escaped over the course of a year[166].
SERVICE STATIONS: In 1991, Shell Oil was fined $55,909 for allowing contaminated fluids to leak from its service stations[167].
Air pollution
In 1988, Shell Oil Co was fined $66,900 for illegally discharging excessive levels of sulphur dioxide from its Wilmington refinery in Carson, California[168]. In November 1990, a toxic cloud of hydrogen sulphide escaped from the refinery, and a large number of residents suffered breathing problems, headaches, eye irritation, and further problems169. Although Shell informed the local Government of the leak it did not notify the local school, where people experienced health impacts from the cloud[170].
Shell's Wood River refinery near St Louis in Illinois was charged with releasing unacceptable levels of sulphur dioxide, hydrogen sulphide, benzene, nickel, vanadium and other metallic dusts in various air pollution violations from 1987 to 1989[171]. In one incident in August 1990, 64 tons of particulate matter containing aluminium, vanadium nickel and other metals were deposited on nearby homes[172]. In May 1991, Shell agreed to pay $550,000 in penalties for all the recent pollution offenses at the refinery[173].
In 1989, it was estimated that the following Shell operations posed a high cancer risk to the surrounding populations: Carson refinery in Los Angeles - a lifetime cancer risk from chromium of between one in 100 and one in 1,000; Geismar Chemical plant in Louisiana - a lifetime cancer risk from ethylene oxide of between one in 10 and one in 100; Deer Park chemical plant in Texas - a lifetime cancer risk from butadiene of between one in 10 and one in 100, and from ethylene dichloride of between one in 100 and one in 1,000[174].
Shell Refining (Australia) was fined $25,000 for consistently violating air pollution limits from its Clyde refinery near Sydney. The company had apparently done nothing to prevent or minimise black smoke which poured from a furnace for 7 hours. Some of the pollutants in the emissions were known to be either toxic or carcinogenic. Since 1974, the company has been prosecuted an additional 26 times for air pollution violations[175].
Shell's refinery (67.6% owned) operations in the Philippines have been criticised for allegedly causing air pollution problems in the country. Anecdotal evidence shows that: there has been persistent air pollution since the refinery opened in 1965; respiratory problems, headaches, and nausea have been experienced by people in Libjo, Malitam, and Tabangao; local vegetation shows signs of acidic damage; and Shell has allegedly not implemented any measures which have reduced the pollution[176].
Damage to nature sites
ALASKA: Shell began drilling in the Chukchi Sea in 1988. A year later, Inuit and environmentalists asked a federal judge to halt operations, as the previous year's drilling had displaced up to 5 per cent of the walrus herd. After Shell admitted that its operations had actually killed a walrus, the company applied for an exception to the Federal Marine Mammal Act by petitioning the National Marine Fisheries Service (NMFS), that would allow it to accidentally kill or harm arctic pinniped species, bowhead and gray whales without being prosecute[177]. This was granted, despite the agency's statutory responsibility to place the interests of marine mammals above those of industry. Furthermore, even Shell admitted that the full impact of its operations on marine mammals could not accurately be predicted[178]. In 1990 Shell further filed a petition to the US Fish and Wildlife Service to allow "incidental take" of polar bears and walrus[179]. Shell has since disposed of its Alaskan oil and gas production properties.
CANADA: Shell, along with Exxon and Gulf, has a concession to extract natural gas from the Mackenzie Delta in the Canadian Arctic, with a pipeline along the Yukon's North Slope. The project has been strongly opposed by environmentalists and native indians, as disruptive to the local caribou herd, and as inflicting unrecoverable environmental damage[180]. The concession area is on Inuvialuit Indian land[181]. Gas is unlikely to flow until the year 2000, or early next century[182]. Shell is also exploring for oil in the region.
Round the world, Shell has developed richly biodiverse forests for oil exploitation, often despite criticism from environmentalists: in Sumatra (Indonesia)[183] and Thailand[184], in Gabon[185], Madagascar[186] and Zaire[187], in Guatemala[188], Peru[189] and Venezuela[190].
It has also developed oil and gas production in nature reserves, such as off Sakhalin Island in eastern Russia[191], in the Everglades in Florida[192] and in the German / Dutch Waddensea[193].
Health and safety issues
The negligence and cost-cutting that led to many of the accidents listed above under UK health and safety are repeated around the world, particularly in developing countries where the company can get away with lower standards. These are not listed here; however below are just two examples from the USA:
In the period 1977 to the end of 1990, Shell was issued with 100 OSHA citations[194]. In the following two and a half years, between 1991 and Mid 1993, Shell was issued with a further 153 citations by OSHA of which 46 were "serious" and one was "wilful"[195].
Amongst the top USA underground coal producers in 1989, Shell's safety record was the fifth worst[196].
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References and notes
1. Financial Times International Yearbooks, Oil and Gas 1993, Longman, Harlow, p227
2. Fortune, 1993, The Fortune 500, 26 July, p55
3. It is the sixth largest in the world by turnover, after Exxon and four state-owned companies. However in many cases, while a state company will have the greatest share in a joint venture, it will be operated by a western company with the technology etc. Thus Shell controls far more oil than that which it owns, so Shell is bigger than this figure suggests.
4. Royal Dutch / Shell, 1992, The Shell Review, July, pp17-18
5. Royal Dutch / Shell Group of Companies, 1992, Financial and Operational Information 1987 - 1991, London, Netherlands, New York, pp27-28
6. Fortune, 1995, Fortune 500
7. op. cit. 5
8. op. cit. 1
9. Shell Internationale Petroleum Maatschappij BV, 1992, A Matter of Commitment - Health, Safety and Environmental Management in Shell Exploration and Production Companies, The Hague, pp6&32-33
10. op. cit. 1, pp27&29
11. Abrahams P, 1992, 'High Time for Plastic Surgery', Financial Times, 20 August
12. Heinz Rothermund, speaking at the 1997 Celebrity Lecture for the Institute of Petroleum at Strathclyde University, 20th May 1997
13. Spinks P, 1992, 'Industrial Giants Poised to Quit the Netherlands', New Scientist, Vol 133, No 1808, 15 February, p17
14. Collins J, 1990, 'Global Environment Energy Industry's Biggest Challenge', Chairman and Chief Executive Designate of Shell UK Limited, Press Release, Shell UK House, 28 June
15. The Times, 1989, 'Shell to Raise Offshore Gas Platform to Offset Anticipated Rise in Sea Level', 7 September, pp3; Reuter News Service, 1990, 'North Sea Platform Raised to Offset Global Warming', Oslo, 1 February
16. EIRIS, 1991, The Shell Transport and Trading Company Factsheet, London, p7
17. Oil Spill Intelligence Report, 1992, Custom Oil Spill Data - Shell's Ten Year Spill Record, Cutter Information Corporation, Arlington
18. op. cit. 9, pp31&36
19. Van Wachem L C, 1992, 'The Three-Cornered Challenge - Energy, Environment and Population', The Cadman Memorial Lecture, London, 14 September
20. ENDS, 1990, 'Eastern Electricity Wins Green Con Award', Ends Report 191, p24
21. Garrett A, 1991, 'Sponsorship - Business Buys its Way to a Greener Image', Independent on Sunday, 10 November, p26
22. Financial Times, 1990, 'Shell Fined £1M for Mersey Oil Leak', 24 February, p4
23. Megalli M & Friedman A, 1991, Masks of Deception: Corporate Front Groups in America, Essential Information, December, p184
24. BNA Environment Daily, 1991, Title Unknown, 13 February
25. CEP, 1991, Shell - A Report on the Company's Environmental Policies and Practices, Corporate Environmental Data Clearinghouse, Council on Economic Priorities, New York, p7
26. op. cit. 1
27. Independent, 1992, 'Ethics Survey Names Big Polluters of Rivers', 22 March, p22
28. ENDS, 1992, 'Ethical Investors Weed Out Water Polluters', Ends Report 205, February, p9
29. ENDS, 1993, 'Shell Takes High Ground Over Petrol Station Pollution', ENDS Report 213, April, pp4-5
30. The Guardian, 1989, Title Unknown, 4 April
31. Daily Telegraph, 1989, 'Shell Facing Legal Action Over 150-Ton Oil Spillage', 26 September, p2
32. Lloyds List, 1990, 'Shell Oil Pumped Into Mersey To Save Pipeline' Causes Environmental Pollution', 23 February, pp2; Independent, 1990, 'Shell Pumped Oil into the River to Save Pipeline'', 23 February, p2
33. Independent, 1990, 'Shell UK Close to Causing an Environmental Disaster', 23 February, p2
34. Dunn A, 1990, 'Shell Pleads Guilty to Mersey Oil Spill', The Guardian, 23 February, pp3
35. Brown P, 1990, 'Shell Could Not Find Pipe Corrosion, Says Department of Energy Report', Guardian, 5 December, p2
36. Sherwell P, 1989, 'Shell Could Face Legal Action Over Mersey Oil Spill', Daily Telegraph, p4; Independent, 1989, 'Shell Accused of Delaying Oil Spill Clean-up', 23 August, p1
37. op. cit. 22
38. Palmer R, 1990, 'Shell to Face Court Again for Pollution', Sunday Times, 21 October, p3
39. op. cit. 16, p11; EIRIS makes it clear it is the product and not the company that was investigated by the HSE
40. Mackerron C B, 1993, Business in the Rainforests: Corporations, Deforestation and Sustainability, Investor Responsibility Research Centre, Washington, p122
41. Hamilton Fazey I & Hargreaves D, 1991, 'Shell to Seek Oil Off North East Coast', Financial Times, 22 August, p9
42. McIlroy A J, 1990, 'RSPB Returns £2,000 Gift From Shell', Daily Telegraph, 10 July, p6
43. Clover C, 1990, 'Shell To Build on Rare Wader's Only Nesting Site', Sunday Telegraph, 21 January, p5
44. ibid.
45. Kemp M, 1992, 'Pull Your Socks Up! Shell Told to Show They Care', Daily Mail, 20 May, p13
46. Taylor R, 1993, 'Shell to Derecognise Unions at Refinery', Financial Times, 27 May
47. Petroleum Review, 1993, 'Union Protest Over Derecognition at Shell Haven', September, p394
48. Transport and General Workers Union, 1993, STOP - Think Before You Buy Shell - Shell Attacks Workers Rights, London
49. Aberdeen Press and Journal, 1990, Title Unknown, 1 November
50. Cresswell J, 1991, 'Shell Staff Fear Cuts Will Hit Platform Safety', Aberdeen Press and Journal, 9 July, p1
51 . Cresswell J, 1992, 'Shell Crews Condemn Shift-Change Blunder'', Aberdeen Press and Journal, 29 April, p1
52. Gibb B, 1992, 'Concern over Shell Expro Shift Plans - Platform Staff Claim Safety will be Compromised', Lloyds List, 2 May, p3
53. Grant K, 1992, 'Employees Walk Out', Aberdeen Press and Journal, 9 September, p1
54. Glasgow Herald, 1989, 'Shell Criticised for Brent Field Gas Leak', 6 January, p4
55. The Times, 1989, 'Oilman Killed as Fitting Blows Out', 17 April, p5
56. op. cit. 25, p30
57. Lloyds List, 1990, 'Six Injured As Explosion Hits Shell's Stanlow Refinery', 21 March, p3
58. Chemistry and Industry, 1992, Plant Safety - Shell Fined Following Averted Plant Blast, 28 March, p904
59. Daily Telegraph, 1991, 'Gas Alert Costs Shell £100,000', 3 December, p7
60. Lloyds List, 1990, 'Damaged Shell Tanker "Rapana" Reaches Firth of Forth', Scotland, 28 June, p3
61. Associated Press, 1991, 'Explosions Rock North Sea Rig', 7 August
62. Beaumont M & Cresswell J, 1991, '1,500 Faults on Oil Platform', Aberdeen Press and Journal, 15 August, p9; Cambell C, 1991, 'Platform Safety Faults Stir Concern', Aberdeen Press and Journal, 16 August, p1
63. Forsyth I, 1991, '36 Men Taken Off Rig in Gas Scare', Aberdeen Press and Journal, 12 August, pp1
64. Hargreaves D, 1992, 'Oil Crews Meet Shell for Safety Talks', Financial Times, 17 March
65. Nickson E W, 1993, Environmental Questionnaire, Response to Andrew Rowell, Shell International Petroleum Company, 13 September
66. Walker G, 1992, 'Shell Silent on 'Copter Story', Aberdeen Press and Journal, 23 March, pp2
67. Cresswell J, 1993, 'Shell Accused of Safety Blunder', Aberdeen Press and Journal, 30 September, pp15
68. op. cit. 16, pp3-4
69. Times, 1992, 'Shell Fined', 15 May, pp5
70. Lloyds List, 1991, 'Refinery Alert', 8 January, pp1
71. Shell UK, Shell in Nigeria - update, London, 3 January 1996
72. For instance, in the first quarter of 1996 the SPDC venture accounted for over 46% of Nigeria's oil production, in Petroleum Argus, 19 August 1996
73. 'Shell' Transport and Trading Company, p.l.c., The Annual Report 1995, London, 1996
74. Sarah Ahmad Khan, Nigeria: The Political Economy of Oil, Oxford, 1994, p.183
75. J.P.van Dessel, former head of environmental studies of Shell in Nigeria, had resigned in protest at the company's environmental record. His insights on Shell's environmental record were described in J.P.van Dessel, Internal Position Paper: The environmental situation in the Niger Delta, February 1995
76. In Andrew Rowell, Green Backlash: Global Subversion of the Environmental Movement, London, 1996
77. op. cit. 75
78. report by Environmental Rights Action, St Andrews, 3 March 1997
79. The memo written by the then Chairman of the Rivers State Internal Security, Major Paul Okuntimo, to the then Military Administrator of Rivers State, Lt.Col.Dauda Komo, has been reproduced in Ogoni: The Struggle Continues, World Council of Churches, Geneva, December 1996
80. Robinson et al, 1996, 'Ogoni, The Struggle Continues', World Council of Churches
81. op cit 78. For example, Shell promised that by the end of 1996, all flowlines over 15 years old would be replaced. Environmental Rights Action carried out an extensive survey in February 1997, which found many to be up to 25 years old. ERA obtained a copy of a confidential report for the Niger Delta Environmental Survey, the survey commissioned by Shell Nigeria in February 1995. This report said: "At Umuechem there is a Shell sign post of complete projects as follows: a)Construction of garri factory b) Construction of market c) Construction of town hall d) Umuechem Eqwi road to commence after rain. Upon enquiries in the community, it was discovered that the town hall and market are community self help projects that were at the verge of completion. Shell only took them over at the stage of painting and other finishing touches. The garri factory, the community further observed, is not functional except the cassava grating apect that is common in all the communities." Note that the NDES is considered to be a public relations ploy, being announced after extensive community protests against Shell in 1993-1994 and international campaigns. A member of the steering committee, the respected economist Prof. Claude Ake, resigned in November 1995
82. Chaos in Warri, Delta newsletter No 3, October 1997
83. Rainforest Action Network, 1997
84. Survival International, 1992, 'Survival International's Top Ten List', London, 17 September
85. op. cit. 40., p123
86. Didde R, Duivenvoorden, Duyvendak W, 1989, 'Als Het Tij Keert: Shell en Nederland', Macht en Verbeelding, Amsterdam
87. Vidal J, 1997, 'Cliffhanger', Guardian, 20 September
88. IPS, 1997, London, 15 May
89. The Economist, 1989, 'South Africa - Going Home', 6 May, p104
90. Mokhiber R & Falloon E V, 1988, 'The 10 Worst Corporations of 1988', Multinational Monitor, December, p19
91. ibid.
92. Wheelwright T, 1991, Oil and World Politics - >From Rockefeller to the Gulf War, Left Book Club, p118
93. Publik Forum, 1989, Seite 9, 8 September
94. op. cit. 90, p19
95. Financial Times, 1988, 9 January, pp2
96. op. cit. 90, p19
97. Labor Notes, 1988, 'Shell's Neptune Strategy' Aims at Countering Anti-Apartheid Boycott', January, pp1&10
98. MacSwan A, 1992, 'Shell is Latest Oil Company to Pull Out of Burma', Rangoon, Reuters News Service, 24 November
99. Shell, No Date, 'Official Shell Statement on Burma', SIPC Media Relations, London
100. Bratz D K, 1988, 'Multinationals Battle Brazilian Constitution', Multinational Monitor, July-August; Royal Dutch/Shell Group of Companies, 1992, Financial and Operational Information 1987-1991, London, Netherlands, New York
101. Daily Telegraph, 1991, 'Homosexual Wins $5.3m Shell Fight', 9 June, p2
102. Harris F, 1992, 'Shell Test Staff for Drugs', Daily Telegraph, 5 August, p4
103. op. cit. 65
104. op. cit. 25, p13
105. Koenig P, 1990, 'Shell to Challenge £50M Clean-Up Bill', Independent on Sunday, 21 October, p3
106. Ibid.; op. cit. 25, p13; Henley S, 1991, 'Dutch Clean-Up Case Against Shell Adjourned', Lloyds List, 17 January, p2
107. Hansard, 1991, Written Answers, Mr Baldry replying to Mr William Ross, 12 December, HMSO, p489
108. ENDS, 1989, 'Revised Guidelines on Black and Grey List Substances in Water', ENDS Report 171, April, p425
109. op. cit. 25, p13
110. Elsworth S, 1990, A Dictionary of the Environment, Paladin, London, pp360-361
111. op. cit. 25, p14; Quoting Global Pesticide Campaigner, 1991, 'Demise of the Drins', January
112. ENDS, 1990, 'Liability for Pesticide Pollution May be tested in Cornwall', ENDS Report 192, March, p7
113. ibid.
114. op. cit. 25, p13
115. op. cit. 105
116. op. cit. 25, p13
117. Thrupp L A, 1989, 'Direct Damage: DBCP Poisoning in Costa Rica', PAN, Dirty Dozen Campaigner, Pesticide Action Network International, May
118. op. cit. 25, p13
119. ibid.
120. op. cit. 117; op. cit. 40, 25 p13
121. op. cit. 25, p13; quoting Mother Jones, 1989, 'Will the Circle be Unbroken?', 24 June and People's Daily World, 1986, 'Costa Rican Workers Sue Dow Chem.', 26 September
122. United Press International, 1993, 'Companies Sued Over Pesticide Exposure', Houston, 19 July
123. Agence France Presse, 1992, 'Honduran Farm Workers Die of Cancer After Using US Made Pesticide', 17 February
124. Arumugam V, 1991, 'An Injury Abolished - Texas Court Holds Multinationals Liable for Harm Abroad', Consumer Interpol Memo, No1/91 (127), March
125. ibid.
126. United Press International, 1989, 'Shell Sued For Polluting Groundwater With Carcinogen Pesticide DBCP', 8 November; op. cit. 25, p16
127. Baton Rouge Morning Advocate, 1990, Title Unknown, 16 November; Nickson E W, 1993, Environmental Questionnaire, Response to Andrew Rowell, Shell International Petroleum Company, 13 September
128. Guest A, 1991, 'Shell To Cut Tanker Fleet by Nearly Half - Oil Major Plans to Realign Transport Policy', Lloyds List, 120 June, p1
129. Financieel Dagblad, 1990, 'Shell Stipulates Higher Insurance Against Oil Spills', Netherlands, 27 February; Lloyds List, 1990, 'Shell International Marine Increases Pollution Cover for Chartered Tankers to $700 Million', 26 February, p1
130. op. cit. 128, p1; Hargreaves D, 1993, 'R Dutch/Shell Planning to Rationalise Shipping Side', Financial Times, 17 May, pp16
131. Oil and Gas Journal, 1992, 'Industry Briefs', 9 March, p43
132. Associated Financial Press, 1992, 'Shell Oil Spill Threatens Yucatan Peninsula', Merida, Mexico, 17 February
133. Bousquet E, 1989, 'Oil Transnational Working on Environmental Image', Castries, Inter Press Service International, 14 November
134. Oil Spill Intelligence Report, 1992, 'Custom Oil Spill Data - Shell's Ten Year Spill Record', Cutter Information Corporation, Arlington; op. cit. 25, p25
135. United Press International, 1989, 'Senator Call For Independent Probe of Oil Spill', Washington, 6 February
136. United Press International, 1990, 'Attorney General: More Environmental Violations At Shell Refinery', Illinois, 9 February
137. Shaper L, 1989, 'Shelling Out After Bay Area Oil Spill', Christian Science Monitor, C/C 10/91, 5 December, pp12,
138. op. cit. 25, pp17-18
139. Maclean P, 1989, 'Shell Oil Pays Record $19.75 Million for Spill, San Francisco', United Press International, 30 November
40. op. cit. 25, p137
141. op. cit. 25, p18
142. United Press International, 1988, 'Regional News', California, 7 May
143. Maclean P, 1989, 'Shell Oil Pays Record $19.75 Million for Spill, San Francisco', United Press International, 30 November
144. United Press International, 1988, 'Shell Oil Acknowledges Violating Environmental Regulations', Martinez, California, 28 April
145. op. cit. 137
146. Kay J, 1992, 'Bay Area Refineries Pay Little for Polluting', San Francisco Examiner, 8 March, ppA1
147. op. cit. 65
148. United Press International, 1990, 'Shell Spill: 672,000 Gallons, 16 Times Greater than Suspected', Illinois, 23 February; United Press International, 1990, 'Attorney General: More Environmental Violations At Shell Refinery', Illinois, 9 February
149. ibid.
150. op. cit. 25, p25
151. Oil and Gas Journal, 1992, 'Industry Briefs', 17 February, pp42; United States Environmental Protection Agency, 1993, Enforcement Accomplishments Report, FY 1992, Office of Enforcement LE-133, April, pp3-105
152. Financieel Dagblad, 1990, 'Survey Reveals High Dioxin Levels in Rhine', The Netherlands, 8 June
153. Vancouver Sun, 1992, Title Unknown, 24 January
154. Mincher P, 1991, Batangas Bay - The Effect of Industrial Development on the Ecology, Fisheries and Coastal Communities, PO Box 10251, Quezon City, Philippines
154. 'The World of Shell,' Tegantai, Oilwatch, 1997
155. Raphael A, 1993, 'Trillion-Dollar Time Bomb', The Observer, 6 June, pp49
156. ibid.
157. ibid.
158. ibid.
159. ibid.
160. ibid.
161. Associated Press, 1988, 'Jury decides Against Shell in $2 Billion Arsenal Cleanup, San Bruno', San Bruno, 20 December
162. op. cit. 25, p20
163. op. cit. 161
164. op. cit. 25, p20
165. ibid.
166. United Press International, 1987, 'Leak Suit, Connecticut Regional News', 23 September
167. BNA Environment Daily, 1991, Title Unknown, 19 July
168. United Press International, 1988, 'Shell Fined $66,900 for Illegally Discharging Pollutant', Los Angeles, 16 August
169. Hatch G, 1990, 'Shell Refinery Incident Spurs Effort to Warn Schools of Emissions', Los Angeles Times, 7 December
170. Associated Financial Press, 1992, 'Shell Oil Spill Threatens Yucatan Peninsula', Merida, Mexico, 17 February
171. United Press International, 1990, 'Attorney General: More Environmental Violations At Shell Refinery', Illinois, 9 February; United Press International, 1989, 'Shell Sued Over Refinery Emissions', Illinois, 15 September
172. Ayers D, 1990, 'EPA: No Contamination from Wood River Refinery Release', United Press International, 24 January
173. Associated Press, 1991, Title Unknown, 22 May
174. United Press International, 1989, Title Unknown, 8 June
175. The Age, 1990, 'Shell Oil Refinery's Smoke Leads to $25,000 Fine', Melbourne, Australia, 14 February, pp4
176. op. cit. 154
177. Reuter News Service, 1990, 'Eskimos, Environmentalists Seek Halt to Shell', Anchorage, 11 July
178. Miller P A, Smith D & Miller P K, 1993, Oil in Arctic Water: The Untold Story of Offshore Drilling in Alaska, Greenpeace, January, p37
179. Shell Western Exploration and Production (SWEPI), 1990, Petition For Promulgation of Regulations Pursuant to Section 101 (a) (5) of the Marine Mammal Protection Act, March
180. Fagan D, 1989, 'Foothills Presses NEB to Oppose Yukon North Slope Pipeline', Globe and Mail, Toronto, c/c, 1/92, 21 April; Calgary Herald, 1991, Title Unknown, 15 March
181. Oil and Gas Journal, 1991, 'International Briefs', 16 December, p36
182. 9' 9* Gas Journal, 1992, 3 September, p25
183. op. cit. 25, p29
184. 184. op. cit. 40, p123
185. Harrison M, 1988, New Guenon From Gabon, Oryx 22, Fauna and Flora Preservation Society
86. op. cit. 40, p123
187. op. cit. 40, p123
188. This Week in Central America, 1992, 'Shell Oil Announces that it Will Drill in Lake', Vol XV, No16, 27 April, pp27; op. cit. 40, pp122-123
189. Bowen S, 1993, 'The Oilman's Land of Opportunity', Financial Times, 28 January, pp34; Survival International, 1992, 'Survival International's Top Ten List', London, 17 September; Didde R, Duivenvoorden, Duyvendak W, 1989, 'Als Het Tij Keert: Shell en Nederland', Macht en Verbeelding, Amsterdam; Moody R, 1992, The Gulliver File - Mines, People and Land: A Global Battleground, Minewatch, London, p708
189. Regenstreif G, 1992, 'Venezuela Natgas Project Partners Agree On Details', Reuter Newswire, Reutla, 21 May; Mirabel F, Lander E, Sharpe C, 1992, The Christopher Columbus' Natural Gas Project: Its Implications for the Paria Peninsula, Venezuela, Universidad Central de Venezuela, Provita, May; World Oil, 1993, 48th Annual International Outlook, Vol 214, No 8, pp50
190. Royal Dutch Petroleum Company, 1993, Annual Report 1992, pp6; Oil and Gas Journal, 1993, OGJ Newsletter, 4 October
191. Oil and Gas Journal, 1993, OGJ Newsletter, 4 October; op. cit. 25, pp20
192. Bureau of Land Management, Bureau of Indian Affairs, Dames & Moore, 1993, Draft Environmental Impact Statement, Shell Western E&P Inc. Miccosukee 3-1 Exploratory Well, Broward County, Florida; US Department of Interior, Bureau of Land Management, Jackson District Office, Jackson, Mississippi; US Department of Interior, Bureau of Indian Affairs, Eastern Area Office, Arlington, Virginia; Dames & Moore, Boca Raton, Florida, 8 March; op. cit. 65; World Oil, 1992, 'Shell Everglades Well Hits Snag', June, pp9; Osber, 1993, Oil Spill Bulletin and Environmental Review, Alba International, April, pp20
193. Greenpeace Press Release, 1992, 'Greenpeace Against Drilling Attempts in the Waddensea, Hamburg', 26 February; Reuter News Service, 1992, 'Greenpeace Occupied Gas Rig Off Dutch-German Coast', Netherlands, 14 August; Petroleum Economist, 1992, 'Estuary Drilling By Shell/Exxon Attracts Protestors', 30 April, pp30; Greenpeace, 1993, 'No Drilling in Waddensea: A Clean Energy Future', Press Release, Amsterdam, 20 October
194. Corporate Crime Reporter, 1991, 'Number of Federal OSHA Citations (1977 Through 1990)', 9 December, pp20; quoting an Essential Information SurveyOil and Gas Journal, 1993, OGJ Newsletter, 4 October; op. cit. 25, pp20
195. Katalinas J A, 1993, Federal and 18 (B) State Inspections of Specified Oil Companies, Office of Management Data Systems, Occupational Safety and Health Administration, US Department of Labour, Washington, 20 August; Record is between January 1991 and July 1993
196. op. cit. 25, p13-14
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