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EPA work plan review, 133-135 and 21-23 buildings, August 2005

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EPA Region 2 letter regarding revised environmental work plan submission for two buildings including asbestos, health, and safety assessment components.

NYC-WTC_000134871–000135144
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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 1, August 11, 2005

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."

23 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.

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 during torching or cutting activities.

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.

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NYC-WTC 000135005

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NYC-WTC_000135005Source: NYC Law Department, mirrored locally

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