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

until site conditions can be re-evaluated by the Contractor and the Environmental Consultant's CIH.

2.6 SAFETY EQUIPMENT

The following emergency equipment will be located in the CRZ: fire extinguishers, spill control equipment, , and decontamination equipment.

The requirements for PPE on this job may be refined and changed to address the conditions identified when tasks are performed. The Subcontractors will work with the Contractor to ensure the proper PPE is maintained and available on-site at all times, and that personnel are trained to use the PPE and understand the procedures and practices for the safe and effective use of PPE. The Subcontractors will provide the required PPE for their employees.

The PPE requirements presented in this HASP are the minimally acceptable for the specified activity. Subcontractors can make individual decisions to upgrade the equipment requirements for each PPE level to ensure the hazards presented by an activity are controlled and exposure is minimized. Engineering and administrative controls will be identified and implemented for each activity prior to use of PPE.

2.6.1 Respiratory Protection Pro

Respiratory protection is required whenever work is performed inside the building to protect the workers from exposures to contaminants, primarily asbestos, which may be present. Half-face negative pressure air purify respiration particulate filters that are HEPA or P100 shall be required during work preparation activities (i.e. installation of isolation barriers) and PAPR will be used during other Abatement Phase activities, unless Level B is required. Environmental Consultant's CIH or qualified subcontractor IH personnel will evaluate the need for additional protection such as adding organic vapor cartridges based on their respiratory protection programs and chemicals they may be using. The following practices will be conveyed to all employees and enforced by the Contractor and the CSO respect to respiratory equipment for this project:

1. Subcontractors whose personnel wear respiratory protection shall have a written respiratory protection program that meets the requirements of the OSHA Standard (29 CFR 1910.134) and has been developed by a Competent Person as defined by OSHA.

2. Personnel who may need to wear respiratory protection shall be fit-testing, medically qualified and trained, as required by the Standard, to use respiratory protection. The Subcontractor shall identify personnel who may use respiratory protection and documentation of fit-testing, medical qualification and training shall be provided for each person who may need to wear respiratory protection on the job.

3. The Subcontractor shall review with the Contractor CSO the procedures for the handling, storage and maintenance of respiratory protective equipment to be used on-site, including the process for reporting and repairing or replacing defective equipment and the locations where respiratory equipment will be stored.

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NYC-WTC 000134391