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Health and Environmental Licensing: Analysis of an Environmental Impact Study on Oil Wells in Northeast Brazil

Saúde e Licenciamento Ambiental: análise de um Estudo de Impactos Ambientais de Poços de Petróleo no Nordeste do Brasil

José Marcos Silva
Universidade Federal de Pernambuco – Centro Acadêmico de Vitória de Santo Antão.
https://orcid.org/0000-0002-6913-8302.

Solange Laurentino dos Santos
Universidade Federal de Pernambuco – Centro de Ciências Médicas.
https://orcid.org/0000-0002-6405-3959.

Ana Marília Correia Cavalcanti
Fundação Oswaldo Cruz - Instituto Aggeu Magalhães.
https://orcid.org/0009-0006-9353-423X.

Mariana Olivia dos Santos
Fundação Oswaldo Cruz - Instituto Aggeu Magalhães.
https://orcid.org/0000-0002-2129-2335.

Lia Giraldo da Silva Augusto
Fundação Oswaldo Cruz - Instituto Aggeu Magalhães.
https://orcid.org/0000-0002-9322-6863.


ABSTRACT
The interrelation between health and the environment lies at the core of the environmental licensing process. Economic development impacts human health, as seen in the oil industry, known for pollution, illness, chemical spill accidents, and their implications for public health. This article presents the findings of research that analyzed the inclusion of human health in an Environmental Impact Study (EIS) for oil well drilling in northeastern Brazil. Using a method that applied a matrix of health and environmental indicators categorized, systematized, and critically assessed, it found a lack of basic indicators for protecting, preventing, and mitigating health-related damages. The study concludes with an urgent call to include health monitoring in environmental licensing for areas subject to risks associated with the oil production chain. The method highlights the absence of public health considerations in the EIS and reaffirms the principles of Brazil\'s Unified Health System (SUS).

Keywords: public health; collective health; health and environment; oil; offshore drilling.

RESUMO
A inter-relação saúde e ambiente está no centro do processo de licenciamento ambiental. O desenvolvimento econômico gera impactos sobre a saúde humana, como os da indústria do petróleo que é conhecida por poluição, adoecimento, acidentes químicos de derrames, com implicações para a saúde coletiva. Este artigo apresenta os resultados de uma pesquisa que analisou a inserção da saúde humana em um Estudo de Impacto Ambiental de perfuração de poços no nordeste do Brasil. A partir de um método em que se aplicou uma matriz de indicadores de saúde e meio ambiente, com categorização, sistematização e crítica, em que verificou a ausência de indicadores básicos para a proteção, prevenção e mitigação de danos à saúde. Conclui-se a urgência de incluir no licenciamento ambiental o monitoramento da saúde nos territórios submetidos às situações de riscos relacionados a cadeia produtiva do petróleo. Destaca-se que o método contribui para explicitação de ausências de cuidados para a saúde coletiva no EIA para reafirmar os princípios do Sistema Único de Saúde.

Palavras-chave: saúde coletiva; saúde pública; saúde e ambiente; petróleo; perfuração marítima.

Introduction

In Brazil, there is a growing scenario of oil and gas production in marine environments and an increasing No of companies of various nationalities and sizes. This underscores the importance of discussing the implementation of sustainable environmental regulation in the offshore oil and gas production chain1, 2.
According to Petrobras3, there is an expectation for oil exploration in the Sergipe-Alagoas Basin, which is considered a robust project within the oil sector. This basin is located in northeastern Brazil, between the states of Sergipe and Alagoas, near tourist-oriented municipalities such as the beaches of Maragogi in Alagoas and Ipojuca in Pernambuco.
The severity of the issue lies in the introduction of risk scenarios for oil spills and disasters, such as the Deepwater Horizon oil platform incident in 2010 in the United States, which, according to Santos3, released approximately 626,000 tons of crude oil at a depth of about 1,500 meters below the sea surface. This incident halted commercial fishing in Louisiana, resulting in an estimated 11% reduction in fishers’ income, 23% in trade, and a 28% drop in employment across sectors associated with the industry. Recently, Brazil faced the largest oil disaster in its history with the 2019 spill on the northeast coast. Over 5,000 tons of crude oil were spilled, contaminating 4,000 km of coastline, 1,009 beaches across 11 Brazilian states, and 55 conservation units. The social, economic, and environmental impacts remain insufficiently measured and may last decades4.
With the implementation of oil well exploration and ship navigation routes transporting oil in the northeastern region, scenarios of danger need to be thoroughly analyzed. Health issues are essential for repositioning environmental regulation in alignment with the Unified Health System (SUS), appreciating evidence of the ecosystem harm caused by pollution to adequately weigh the impacts of decisions with independence and scientific rigor.1, 5, 6.
The implementation of a project entails analyzing risk situations that allow for a broad-spectrum assessment of environmental impacts and the integration of comprehensive data on the effects. For this reason, the absence of health indicators has been studied.8, 9,10, 11, 12.
It is crucial to analyze the absence of health considerations in the EIS and RIMA (Environmental Impact Report) evaluations for oil exploration territories, highlighting the health impacts for proper inclusion in the environmental impact assessment processes of production activities hazardous to human life. Brazilian legislation has established environmental regulation through governmental bodies with provisions for SUS13 participation. For this reason, the inclusion of health indicators in environmental impact assessments has been studied8, 11, 12.
O Estudo de Impactos Ambiental (EIA) é um instrumento do licenciamento ambiental para a concessão ou negação de licença de implantação do empreendimento13, 14; é um documento que compõe um rol de procedimentos para regulação ambiental da Administração Pública, no atinente aos mecanismos de controle da sustentabilidade1.
The Environmental Impact Study (EIS) is an environmental licensing instrument used to grant or deny a project’s implementation license13, 14. It is a document that forms part of a set of procedures for environmental regulation by public administration, related to sustainability control mechanisms1.
The EIS should reflect a detailed data collection process with scientific language. Therefore, it may not be easily understood by the general public, making it essential to produce a document in more accessible language for civil society—the RIMA (Environmental Impact Report), a social communication tool between public authorities and the population11, 12.
The environmental licensing process involving the oil production chain must analyze human health impacts due to potential environmental contamination (air, water, soil), changes in the epidemiological landscape caused by diseases such as cancer, leukemia, and poisoning8, 10, 12.
The analysis of the health-environment-oil production interrelation is of interest for discussing issues related to environmental, health, and occupational impacts due to chemical substances. A National Plan for Health and Environment in Sustainable Development proposes including health topics in EIS, overcoming omissions by consultancy firms that insist on preparing EIS without considering population health11, 16.
In this sense, it is important to analyze the quality of EIS content, paying attention to the identification of health councils, health surveillance systems, and Workers’ Health Reference Centers in identifying risk situations. This perspective reveals the importance of studying proportional environmental regulation mechanisms in light of the contemporary unsustainable global development model that increases risk situations, exacerbates the climate crisis, and environmental contamination, surpassing the planet’s resilience limits.1.
As Moreira and Wedy17 (p. 117), “the State\'s commitment to the fundamental right to a balanced environment and the principle of sustainable development underpins the structuring, by the Public Authority, of an appropriate environmental regulation to address the increasingly complex, challenging, and global issues emerging in contemporary risk society.”
Thus, the EIS should guide the sustainable and transparent management of natural resources, grounded in the Social-Environmental State of Law as a driver of sustainable development and a platform for the Sustainable Development Goals18, ensuring a rights-based approach, environmental protection, and health promotion for universal access to ecological balance, protection of vulnerable populations in current and future generations, and safeguarding the intrinsic dignity of life1.
Inadequate licensing can lead to conflicts over natural resources and environmental crimes that exacerbate local problems, increasing the risks of violent conflicts when natural resource exploitation causes environmental harm, livelihood loss, or unequal distribution of costs and benefits, as argued by Sunstein19.
It is within this analytical field that this article engages with collective health and chemical issues, critically examining EIS-RIMA, aligning with the Environmental Rule of Law, which establishes environmental rule of law as fundamental to sustainable development, interlinking environmental sustainability and fundamental rights, and opposing arbitrary, discretionary, subjective, and unpredictable licensing17.
Therefore, this article presents research findings that analyzed the EIS/RIMA for Offshore Drilling Activities in the Sergipe/Alagoas Basin, to be conducted by ExxonMobil, considering the health, labor, and environmental interrelations and the potential health effects on fishing communities and their surroundings.

Method
The research was conducted in four stages, analyzing explicit and implicit content in messages, texts, data, and information20. It used the EIS/RIMA analysis model developed by Silva, Gurgel, and Augusto10, incorporating necessary adaptations:
Stage 1 – Theoretical Framework Review: this stage involved reviewing conceptual, historical, legal, and institutional issues related to public/collective health. Scientific, institutional, governmental publications, and legislation on the topic were analyzed. Searches targeted the following databases: Lilacs: Latin American and Caribbean Health Sciences Literature (http://www.bireme.br/bvs); PubMed-MEDLINE: U.S. National Library of Medicine (http://www.pubmed.com.br); SciELO: Scientific Electronic Library Online (http://www.scielo.org).
Stage 2 – Study Scope Definition: the study focused on the EIS/EIR for offshore oil well drilling activities in the Sergipe-Alagoas Basin, under the responsibility of ExxonMobil. This public-access document can be found at link http://licenciamento.ibama.gov.br/Petroleo/Perfuracao/Perfuracao%20-%20Bacia%20de%20SEAL%20-%20%20Blocos%20SEAL-M-351-428-430-501-M-503-573%20-%20ExxonMobil/.
The study selected the socioeconomic impacts section of the EIS, accessible at link http://licenciamento.ibama.gov.br/Petroleo/Perfuracao/Perfuracao%20-%20Bacia%20de%20SEAL%20-%20%20Blocos%20SEAL-M-351-428-430-501-M-503-573%20-%20ExxonMobil/EIA_SEAL_Diag_SE_Rev01.pdf.
Stage 3 – Indicator Matrix Development: based on the theoretical framework established in Stage 1, an indicator matrix was developed to analyze the inclusion of public/collective health topics in the EIS/EIR for offshore oil well drilling activities in the basin under study. Operational categories were defined to find unity in diversity and generate explanations and generalizations20. These analytical categories guided knowledge extraction from the EIS/RIMA.
The analytical categories were based on EIS sections: presentation, environmental diagnosis, impact analysis, mitigation and compensatory measures, and monitoring plans. Indicators and aspects of public/collective health were organized into operational categories8, 9.
Stage 4 – Systematization and Analysis: this stage included gathering concepts based on the operational categories in the matrix analysis. Stage 1 results facilitated the description of operational categories forming the matrix. For each health aspect identified in the EIS/EIR, a score of (-) or (+) was assigned based on whether it was absent or present for public/collective health characteristics. The analysis involved thematic content analysis, a research technique for objective, systematic, and quantitative communication description20.
A summary map was created to describe operational categories for data analysis consistency, considering the technical, scientific, and legal knowledge supporting health inclusion, as proposed by Silva et al11.
Predefined Categories: the minimum elements constituting EIS parts were considered: a) Health inclusion analysis in the presentation; b) Health inclusion analysis in the environmental diagnosis; c) Health inclusion analysis in impact analysis; d) Health inclusion analysis in mitigation and compensatory measures, plans, and programs; e) Health inclusion analysis in monitoring emergency plans.
These categories align with the requirements of EIS/EIR as defined by CONAMA Resolutions No. 001/1981 and No. 237/1997, which serve as the legal foundation for environmental licensing in Brazil13.
The project’s significance lies in its status as the first offshore oil exploration initiative in northeastern Brazil—a region known for tourism and traditional fishing communities11, 12.

Results and Discussion
The scope of the EIS is determined by the licensing authority through the issuance of a reference term that guides the content and studies to be conducted for analyzing environmental impacts.
As per the application for an operational license, the project is registered under the name ExxonMobil Exploração Brasil Ltda, CNPJ: 04.033.958/0001-30, headquartered in the Botafogo neighborhood, Rio de Janeiro – RJ. The blocks are located in the Sergipe-Alagoas Basin along the coasts of Sergipe and Alagoas, at water depths ranging from 1,900 to 3,800 meters. The total area covered by the blocks is approximately 4,531 km². The nearest vertex to the coastline is 50 km from Brejo Grande/SE. Up to 11 exploratory wells are planned, with two guaranteed and nine contingent.
In Table 1, the analysis results of health inclusion in the presentation are shown. The technique used to evaluate environmental impacts in ExxonMobil\'s EIS/EIR relied on secondary data consulted by a team of specialists hired by the company. No professional with training or expertise in health situation analysis or population health diagnosis within the area of influence was identified. The team predominantly consisted of biologists and engineers.
The EIS/EIR preparation process does not appear to have been an integrated effort, as it excluded health professionals such as public health experts, as well as investigators and managers capable of addressing quality-of-life approaches for populations. Public health issues and their interrelation with the environment are poorly evaluated or not evaluated at all. The EIS/EIR presents fragmented data on physical and biological environments, without including health data or potential health impacts, similar to findings by Silva and Augusto9, 11.
The study does not delve into social issues or health impacts on communities and workers, nor does it address the increase in illnesses that exacerbate social inequities. It is essential to note that consultants did not demonstrate compliance with the CONAMA resolutions No. 001/1981 and No. 237/1997, which require public participation as a social and political strategy to address the impacts of the project, corroborating other studies by Silva and Augusto11, 12.
There is no fundamental information on the vulnerabilities of populations in areas of influence, their territories, or the human occupation potentially resulting from the project\'s implementation. The EIS/EIR was prepared using data from previous studies, which is unacceptable given the potential for ecosystem pollution and its reach to human health. The report limits itself to stating that field studies were conducted only in Alagoas in February 2020, relying heavily on secondary data that does not account for the covid-19 pandemic context.
Research in collective health indicates that every infrastructure project in the oil production chain promotes migration and urbanization as people seek jobs and better living conditions, as highlighted by studies from Arruda et al.8 and Silva et al10, 12. Disorganized migration flows generate typical health and environmental issues associated with poverty, such as precarious housing conditions near projects. Even for offshore drilling activities, an influx of people to nearby municipalities is expected, as noted in prior studies11.
It is crucial to consider that oil drilling in the Sergipe/Alagoas Basin impacts the environment, primarily by exposing ecosystems to oil extracted through complex engineering processes that are not closed systems.
Research from the 2000s, such as that by Mariano21, has demonstrated that the composition of oil has polluting and disease-causing potential due to exposure of workers and communities to heavy metals, hydrocarbons, and benzene. Therefore, risks, particularly to fishing, tourism, and seafood consumption, must be analyzed, and mitigation and compensation measures presented according to prospective scenarios—implementation, operation, environmental disaster, recovery, and decommissioning21.
Oil exploration must be understood within its global context and the existence of core-periphery relationships in territories, rooted in forms of domination, intervention, and control over resource use by economic investors2, 13.

Tab.1

The core-periphery division, which creates local socio-environmental problems, is based on systematic disregard for nature and the legitimate interests of local inhabitants—pushing them to political, economic, and geographical peripheries. There is a tendency to appropriate territories for projects, particularly by devaluing the autonomy of local societies, necessitating environmental regulation and sustainability actions, as advocated by Freitas and Moreira1.
The oil production chain is complex and involves various stages: exploration, drilling, extraction, refining, transformation into multiple high-value derivatives with significant commercial interest, and distribution of energy and non-energy products, such as diesel, gasoline, Liquefied Petroleum Gas, kerosene, asphalt, and green coke9.
This is an energy-intensive production chain that, in Brazil, in addition to consuming vast amounts of water, causes severe contamination of water, air, soil, and the food chain9. Consequently, it produces environmental and public health damage, often with the tacit approval of governments and institutions legally tasked with protecting the environment and public well-being. Although health, development, and environmental challenges are interconnected, evidence remains fragmented across sectors due to methodological and conceptual differences in research and practice, as highlighted by Tallis et al6.
In Table 2, the results of health inclusion analysis in the environmental diagnosis of the EIS/EIR for Offshore Drilling Activities in the Sergipe/Alagoas Basin are presented. It was observed that there was no public participation, no consideration of risk scenarios, no inventory of inherent chemical substances, no identification of potential health risks, no quantification or characterization of exposed populations, no health services, nor a situational health diagnosis in the areas of influence.
The inventory of pollution sources is an essential parameter and a starting point for any environmental study/project22. Oil poses significant environmental and public health risks due to emissions of polycyclic aromatic hydrocarbons, heavy metals, nitrogen oxides, sulfur oxides, carbon monoxide, non-methane hydrocarbons, hydrogen sulfide, and other gases. Without such an inventory, the EIS/EIR lacks technical validity, as per the Environmental Company of the State of São Paulo (CETESB)22 and Mariano21.
Environmental licensing aims to prevent and, when necessary, compensate for the pollution produced. As such, studies on air, soil, and water quality related to the drilling, transportation, and onshore support processes should be included, along with robust cost-benefit analyses, as proposed by Sunstein.19.
In oil and gas drilling processes, scenarios of potential impact from oil spills due to blowouts—loss of well control—are anticipated. Prospective scenarios should consider the following impacts: changes in water quality, air quality, sediment quality, coastal ecosystem alterations, changes in planktonic, benthic, and nektonic communities, impacts on fishing resources and activities, changes in tourism activities, and pressure on infrastructure for solid waste disposal7.

Table 2

The consultants identified the project\'s area of influence as 63 coastal municipalities across five Brazilian states. However, the population data used in the EIS/EIR came from a 2019 study, which diverges from the reality of the recent 2019 oil spill disaster that affected over 1,000 localities in 130 municipalities along Brazil\'s northeastern coast22.
While recognizing the importance of environmental diagnosis for decision-making, the EIS/EIR evades the implications and impacts on public health, especially for fishing communities and coastal workers. Thus, crucial information obliging the project developer to address damages caused by chemical exposure is omitted, as pointed out in prior studies by Silva and Augusto9 and Silva et al11.
In Table 3 are the results of the analysis of health inclusion in the impact assessment. The dosage of all metabolites produced by the body in cases of exposure to chemical agents present in petroleum was not considered. The applicability of molecular-level markers that establish a causal link between exposure and health effects on workers and the population is important, as demonstrated by Augusto23, 24.
There is no consideration of the health damages and harms, despite the literature inferring environmental risks and health risks for workers related to the oil industry, with the potential to produce changes in the population\'s morbidity and mortality profile due to the implementation of this type of enterprise10, 11.
The EIS/EIR does not address health issues, the environmental parameters significantly impacting human health, the assessment of health impacts on morbidity and mortality, nor does it include the calculation of exposure for affected populations or the analysis of significant health risks. It did not present an evaluation of significant impacts on health, work, and the environment.6, 8, 12.

Tab.3

Table 4 presents the results of the analysis regarding the inclusion of health in mitigating and compensatory measures, plans, and programs. The EIS/EIR does not identify government plans, programs, and projects at the federal, state, and municipal levels, nor other sectors related to population health in the area of influence of the project. It does not assess the compatibility of government programs; it does not identify government plans and projects related to the health sector and the SUS; it did not present an evaluation of government actions in the area of influence related to the protection of health for different social groups.
It refers to a set of measures and regulations related to safety, environment, and health aspects, as well as technological procedures; it presents an environmental education program for workers without any aspects related to accident prevention and occupational exposure to organic compounds such as benzene, toluene, and xylene. The presented programs lack financial information, and therefore, there are no guarantees that they will be implemented or by which institution, corroborating the findings of Silva et al.11, 12.
There is an absence of analysis of technological and locational alternatives, indicating different scenarios and the need to reduce or minimize impacts with mitigating measures. This absence is common in EIS/EIR of other oil projects, similar to the omissions in the environmental diagnosis, which result in neglecting obligations regarding the impacts12.
The identification of technological and locational alternatives is an essential element of the EIS/EIR and should be subject to regulation by the licensing authority through the terms of reference, requiring those responsible for the EIS/EIR to conduct the necessary analysis and provide the information that supports decision-making12, 13.
A social communication plan and an individual emergency plan were identified, but they are very limited and restricted to the notification of oil spills to environmental agencies and public institutions, without demonstrating what the project\'s responsibility will be in mobilizing society.
Table 4: Analysis of the inclusion of Health in the mitigating, compensatory measures, plans, and programs of the Environmental Impact Study for Offshore Oil Well Drilling in the Sergipe/Alagoas Basin, considering the categories absent (-) or present (+), 2022
Operational Categories Characteristics
Identification of effective mitigating measures to reduce significant health impacts, aiming to reduce exposure and protect groups exposed to risks and those more vulnerable (-)
Identification of health-related measures proposed to control significant health impacts and whether they stem from the health risks potentially inherent to the project (-)
Identification of protection and health promotion actions for the most vulnerable population groups exposed to health risks in the project area (-)
Expanded emergency and accident plans (+)
Identification of effective mitigating measures to reduce significant health impacts, aiming to reduce exposure and protect groups exposed to risks and those more vulnerable
(-)
Identification of health-related measures proposed to control significant health impacts and whether they stem from the health risks potentially inherent to the project
(-)
Source: prepared by the authors based on the EIS/EIR submitted to Ibama.


They do not present the financial resources for an effective expanded risk communication plan for disasters and chemical accidents. There is an evident externalization of responsibilities to the government and society; the benefits of oil exploration go to the project, while the costs of environmental impacts are socialized1, 11, 13.
They should identify effective mitigating measures to reduce significant health impacts, aiming to reduce exposure and protect groups exposed to risks and the most vulnerable. It is necessary to demonstrate financial and technological capacity to mitigate impacts on collective/public health in disaster situations.
This scenario is concerning for the protection and promotion of health among the most vulnerable population groups exposed to health risks. Expanded chemical accident emergency plans should be established, with an indication of their costs and financial guarantees for their implementation with social participation. Environmental agencies and Ibama should carry out their regulatory function to ensure they are not subject to a final goal deviation that leads to inefficiency, corruption, or the supposed generation of employment 18.
These institutions must perform the role of regulator with reasonable scientific independence, inherent to state agents, maintaining the necessary institutional controls to carry out an assessment of sustainability of the impacts, without the chronic indifference towards the aforementioned invisible genocides1.
Regarding the analysis of the inclusion of health in the monitoring and follow-up of plans and impact monitoring (Table 5), the system for monitoring the project\'s actions and activities and the institutional capacity for this monitoring were not defined. There is no definition of health actions and services for monitoring the risks identified in the exposed population, especially the working population.

Tab.5

Health indicators for monitoring, a system for monitoring project activities, and the institutional capacity for this monitoring were not defined. There is no methodology for monitoring by the population, from the beginning of the preparation of the EIS/EIR to the implementation phase of the project9, 11, 12, 21.
Information on budget sources for the monitoring plans, social communication, and environmental education plans is absent. It is emphasized that the EIS/EIR contains a mechanism for deferring responsibility for the impacts and risk situations introduced by the project. There are indications that these documents represent more the interests of the project than a commitment to the defense of the environment and public health.
A conflict of interest is revealed when the defense for the approval of the license is anticipated. It is inappropriate for the EIS/EIR consultants to advocate for the feasibility of the project because they have not engaged with local communities nor conducted the necessary environmental diagnosis; they used outdated study results from different contexts as references. Instead of anticipating risks and predicting environmental and health damages, the project was defended without ethics or impartiality11.
It is now important for the specialization and regulatory autonomy of environmental agencies and Ibama not to disregard integrated action with the SUS (Unified Health System) and civil society. The prudent reservation to avoid the complex and redundant overlap of duties should not exempt the combination of expertise from health departments, universities, and research institutes, as sustainable environmental regulation is the way to transform isolated, disconnected, and fragmented regulatory performance1, 11.
It is urgent to consider the inclusion, by the licensing agencies, of health variables in the terms of reference so that they are presented in the EIA-RIMA and, therefore, be required and guide the decision on licensing or refusal of the project\'s implementation authorization, as provided in environmental legislation aimed at protecting life and public health12, 13.
There is sufficient legal framework (laws, resolutions, ordinances) requiring environmental analysis regarding the interdependence between health and the environment in situations such as oil exploration. According to Silva, Gurgel, and Augusto, environmental protection implies the protection of human health. This is stated in the Federal Constitution of 1988 (CF/1988), the National Environmental Policy (Law No. 6.938/1981), and the SDGs11,12,18.
Regarding the different spheres of the tripartite system and the intergovernmental relationship on environmental licensing, Article 23 of the Federal Constitution of 1988 defines the cooperation between the Union, the States, the Federal District, and the Municipalities, with a view to balancing development and well-being12.
Both the National Environmental Policy and Article 23 of the Federal Constitution of 1988 were updated with Complementary Law No. 140, of December 8, 2011, establishing standards for cooperation between federative entities on environmental protection issues. Since 2009, what has effectively been implemented regarding the inclusion of health in EIS is the joint ordinance of the Brazilian Institute of Environment and Renewable Natural Resources, Ordinance No. 259/2009, which mandates the inclusion of worker health issues in the EIS.
Therefore, it is the responsibility of the Unified Health System (SUS) to intervene in the environmental licensing process for health promotion, prevention of harm, and protection of life, overcoming the incipient capacity of licensing agencies to provide society with important information about the impacts, effects, and risk conditions arising from the implementation of polluting projects, due to the mechanism of omitting important data, which is only perceived after the actual implementation of the project10,11, 12.
The implementation of oil well exploration is marked by tension between the interests of governments, entrepreneurs, financial investors, and the interests of traditional peoples, whose rights are often disregarded in decision-making processes. The concealment of foreseeable risks is confirmed through the use of information disconnected from the socio-environmental relations in the territory where oil production processes are implemented9, 11.
Revealing the different interests allows society to participate in the discussion about whether to authorize the licensing or not, in a minimally informed manner, enabling them to take a position on the violation of the rights of more vulnerable social groups. This is not being respected by the way the entire EIA preparation process is carried out, from the issuance of the terms of reference and its scope, what is delivered by the consultancy that prepares the EIA, the public hearings, and the granting of the preliminary license.

Conclusion

The oil industry has processes and products that are harmful to the environment and health. For this reason, including in the EIA the monitoring and health care in the territories of life and work where there are production processes, whether for extraction, refining, or petrochemical transformation, is the basic expectation.
The concealment observed in situations of expected risks and damages can be interpreted as a deliberate and chronic attitude of denying or making invisible the harms and disasters, while convincing society only of the advantages. Negative externalities need to be disclosed, and their consequences made known, as well as the preventive and mitigation measures that must be established based on a technically conducted EIA, aimed at protecting workers, communities, biodiversity, and the entire environment, considering the quality of air, water, and soil.
The design of the research method stands out by making explicit connections for a public health perspective in the environmental licensing process, without aiming to exhaust the possibilities of EIA analysis. Research is needed on other critical aspects in this context, such as housing, leisure, and the quality of environmental compartments.



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