World Trade Center asbestos situation memorandum, December 2001

NYC 9/11 Public Portal Document

dusty, you only need to lower them to the ground slowly to avoid exposures. They state that although a HEPA room air purifier is preferable, any type of air purifier could be used, with no specification as to the quantity of air that it can handle. Using a common room air conditioner to recirculate the air is recommended with changing the filter frequently, even though these filters cannot even begin to capture the dangerous ultra-fine asbestos particles.

There are many other problems with the NYC DOH cleanup methods. My concerns over the lenient NYC DOH recommendations for cleaning up asbestos were detailed in my 10/16/01 memorandum to Arts, Crafts, and Theater Safety in NYC. (posted at www.nyenvirolaw.org and soon at www.nycosh.org/linktopics/WTC-catastrophe.html)

Unsubstantiated EPA claim that exposures are only short term, and that short term exposures not dangerous

Governor Whitman and Ms. Callahan of EPA’s Region 2 claimed that there would be no health hazards fi-om only short-term high level exposures to asbestos in their many press releases and speeches, above. However, unless the asbestos is cleaned up according to the methods specified in the CAA regulations, there will in fact be those sustained hazardous long-term exposures over a lifetime for citizens living in lower Manhattan.

Consider this as well: We do not know what the health effects are for inhaling the type of asbestos found from the WTC at high concentrations for a short period of time. Since the ultra­ fine asbestos particles lodge in the lung and are not eliminated, the effects could be the same. The asbestos is highly unusual in that it has been pulverized into ultra-fine particles. See earlier discussion of the HP Enviromnental study.

EPA has determined that even high asbestos exposures of relatively short duration are harmful through its regulatory and advisory system. The EPA recommendations for cleaning up private residences by homeowners require the use of qualified trained contractors (www.epa.gov/iaq/asbestos.html, discussed earlier). In making these recommendations^ EPA would have assumed that the homeowner would not otherwise be constantly engaged in high asbestos exposure home renovations. Even with making this assumption, EPA still found it necessary to prevent exposures during these highly infrequent occasions of home asbestos removal and cleanup, requiring the use of trained qualified professionals.

Failure to acknowledge EPA determination that asbestos below 1% could be hazardous

The EPA has officially stated that asbestos levels LOWER than 1% could present health hazards

“Levels at 1 % or less may be safe. Even higher levels could be considered safe at remote locations where no one com es in contact with the material. The key to determining whether there is a risk is exposure. If there is no exposure pathway i.e., a way for the asbestos to get into your body, such as contact with the material, or people driving over the material so that they breathe in the fibers, there is no

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