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EPA review letter, 133-135 Greenwich Street

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US EPA Region 2 letter dated November 15, 2005, confirming completion of environmental review for abatement plans at 133-135 Greenwich Street.

NYC-WTC_000134132–000134414
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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

• Inspect frequently. Regular safety inspections of the work site, material, equipment, and operations by qualified persons (i.e., Contractor SSM) shall be performed to ensure early detection of unsafe conditions. Safety and health deficiencies shall be corrected as soon as possible, or site activities shall be suspended. All inspections shall be documented and the records retained by the Subcontractor for, at a minimum, the duration of the project. Copies of the inspection reports shall be provided to the Contractor SSM or Contractor Project Manager upon request,

• Educate personnel concerning the requirements of the HASP. The HASP and all site health and safety education shall be provided by each Subcontractor, the Contractor SSM and CSOCSO.

All minor accidents (i.e., small fires, injuries, and near misses) shall be investigated by the Subcontractor Site Manager or Safety Officer and communicated to the Contractor SSM immediately when reported to the Subcontractor. The Contractor should also be contacted as soon as possible. An accident investigation shall include reviewing the accident/incident report, questioning the injured employee(s) as well as other personnel witnessing the occurrence, identifying all contributing acts and conditions, determining underlying reasons for their existence or occurrence, and implementing corrective actions. A report documenting the investigation shall be written and forwarded by the Subcontractor to the Contractor SSM and the Contractor Project Manager. Recommendations for accident prevention shall also be made in the report and communicated to all site personnel during periodic safety briefings and training sessions.

2.13 MEDICAL SURVEILLANCE PLAN

All persons involved in Abatement Phase activities shall be enrolled in an HAZWOPER and/or asbestos medical monitoring program, as appropriate, prior to working on-site. This requirement ensures that personnel are protected from asbestos and other COPCs that have been identified. In the event that air sampling confirms the presence of asbestos levels above the OSHA PEL, then guidance concerning the requirements for annual medical examinations shall be provided by the Contractor SSM.

2.13.1 Respiratory Protection

All personnel having to wear a respirator must have a medical evaluation as required by 29 CFR 1910.134 to determine fitness to use respiratory protective equipment prior to initiation of work activities. Documentation of fit-testing, medical qualification and training shall be provided for each person who may need to wear respiratory protection on the job. Each Subcontractor shall maintain a written Respiratory Protection Program developed by a competent Person as required by 29 CFR 1926.103.

2.13.2 Hearing Conservation

All personnel exposed to noise levels above 85 dBA must have a baseline audiometric evaluation in accordance with 29 CFR 1926.52 and 101. Personnel shall receive awareness training

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