EPA review letter, 133-135 Greenwich Street

NYC 9/11 Public Portal Document

Part III — Health & Safety Plan 133-135 Greenwich StreetI21-23 Thames Street Airtek Project 05-0701— Rev 3, August 29, 2005

Section 2.8 provides information concerning the management of hazardous chemicals on-site and the site Hazard Communication Program.

2.2.5 Biological Hazards

Biological concerns in the work area are primarily, insects, rodents, and mold/fungi.

2.2.5.1 Insects

The presence of insects shall be addressed by personnel as the insects are encountered. When a stinging or poisonous insect, such as a bee or spider, is identified, personnel should exercise caution to avoid being bitten or stung for example by using tools to move material. In the event that a person is stung or bitten, the incident shall be reported to the Site Manager for the Subcontractor who shall report the incident to the CSO. The Site Manager for the Subcontractor shall initiate actions to manage and address the bite or sting. Personnel who are allergic to insect bites and stings should identify their allergy to their employer.

2.2.5.2 Rodents

In the event that rodents or animal pests are identified or observed on-site, the Subcontractor Manager should report the incident to the Contractor CSO. The Contractor shall be responsible for evaluating the condition and implementing steps to eliminate rodents on the site.

2.2.5.3 Mold/Fungi

The initial building walk-though by Airtek environmental identified mold contaminated building materials/components within the Building. The identification of additional mold/fungi on-site will be made based on visual inspections of building materials. When mold/fungi are identified, the removal of impacted materials shall be addressed concurrently with Asbestos Abatement Activities. Removal and handling measures shall be consistent with the NYC Department of Health and Mental Hygiene "Guidelines on Assessment and Remediation of Fungi in Indoor Environments."

2.3 ENGINEERING CONTROLS

Engineering controls will be used as primary protective mechanisms to protect the safety and health of all employees whenever technically feasible, and prior to the implementation of Administrative Controls and/or personal protective equipment. Each Subcontractor shall be responsible for the provision and implementation of the following:

• Construction/demolition dust suppression materials and equipment to include:

o HEPA-filtered air filtration devices to reduce area dust levels.

o Vacuum cleaners equipped with HEPA filters.

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NYC-WTC 000134387