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

2.9 TRAINING PLAN

All personnel directly involved in the project site activities shall be trained for the tasks they will perform, as required by applicable federal/state/local regulations. Refresher training will be performed at least yearly. In addition, all site personnel shall participate in site-specific training and participation of personnel in training shall be documented, with proof of training maintained on-site. The topics of training required are dependent on the SOW. This training shall be administrated by the Contractor, the Subcontractor, or certified training facilities.

2.9.1 Health and Safety Awareness Training

Each Subcontractor shall be responsible for presenting and discussing the elements of this HASP with their personnel and subcontractors, and ensuring that personnel follow the elements of this HASP when working on-site. Prior to the start of work activities, or whenever a new hazard is introduced into the work area, employees shall be provided with the information indicated below. The Contractor or HASP CIH shall be available to address any questions or assist in the presentation of the HASP information to project employees. Information to be addressed during this training shall include, but not be limited to:

• Hazardous chemicals present at the work site and their associated health risks. • Potential physical hazards associated with the work activities, and proper safety practices. • Proper use of all tools and equipment to complete the scope of work activities. • Requirements of the site Hazard Communication Program, including the labeling of containers. • Site alarm system, emergency response procedures, and location of emergency lay down Area. • Proper PPE to be used during work activities. • Location of the MSDS files. • How to reduce or prevent exposure to hazardous chemicals through the use of procedures, work practices, and personal protective equipment.

2.9.2 Asbestos Training

ACBM was determined to be in several building components per the Airtek Building Asbestos Survey. Building Personnel entering containment shall be trained to identify ACBM and the hazards associated with asbestos in accordance with the OSHA Asbestos Standards (29 CFR 1910.1001 and 29 CFR 1926.1101) and state/local certification requirements. This training provides personnel with a better understanding of asbestos and the steps to be taken to protect themselves and the public. In all areas, required NYSDOL and NYCDEP procedures shall be followed.

2.9.3 HAZWOPER Training

Personnel entering the exclusion or contamination zones for the purpose of performing cleanup abatement activities must have received the required 40 hour training as outlined by 29 CFR

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NYC-WTC 000134397