EPA review letter, 133-135 Greenwich Street

NYC 9/11 Public Portal Document

Part III — Health & Safety Plan 133-135 Greenwich Street/21-23 Thames Street Airtek Project 05-0701— Rev 3, August 29, 2005

o Fume eductors attached to HEPA filters for all hand-powered tools.

• Removal of all lead-based painted materials (if necessary), and adequate exhaust ventilation provided.

• Barricades, railings or other devices to prevent employee exposure to fall hazards or moving equipment per 29 CFR 1926.

• Other task-specific engineering controls as recommended by OSHA guidelines or as recommended by the Contractor or the CIH.

2.4 ADMINISTRATIVE CONTROLS AND WORK PRACTICES

Each Subcontractor shall utilize administrative controls and work practices as a secondary means of ensuring worker health and safety when engineering controls do not provide sufficient protection or are technically infeasible. Each Subcontractor shall be responsible for the provision and/or implementation of the following:

Ensuring all employees are enrolled in a medical monitoring program as required by OSHA, including medical monitoring for blood lead levels as outlined in Section 2.13 of this HASP.

Ensuring all employees have current fit-test and training certifications.

Implementing work practices that avoid generating dust whenever possible.

Requiring that all employees implement decontamination procedures, including washing hands, face, hair and neck upon leaving the work area and before eating, drinking or smoking.

Removing lead based paint or coatings before cutting, grinding or other activities that would be expected to. disturb the lead-based materials, or complying with the provisions of 29 CFR 1926.62.

Use of the Buddy System will be required for all employees working within the Exclusion Zone, as defined in Section 2.8.1 below, or while performing non-standard tasks as designated by the Subcontractor's Safety Officer.

2.5 PERSONAL PROTECTIVE EQUIPMENT (PPE)

Personal protective equipment will be used to provide adequate personnel protection only after feasible engineering and administrative control options have been exhausted. All personnel engaged in the project work activities will use the appropriate level of protection as required by the activity to be performed and are presented in the "Task Hazard Analysis" presented in Table 2-1.

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NYC-WTC 000134388