Law Department notice on WTC document preservation, Oct 2001

NYC 9/11 Public Portal Document

guidelines established for the Superfund program. Based on its experience with the WTC response and the subsequent anthrax contamination responses, EPA has initiated various actions to improve its communication practices.

Better Communication Policies, Procedures, and Guidance Needed

Officials from EPA’s OCEMR and its successor office, the Office of Public Affairs, in Washington, D.C., were not able to provide us with current written policies or procedures for communicating with the public. Although not established as official Agency communication policy, EPA’s Superfund program has issued several guidance documents regarding risk communication. EPA’s risk communication principles and recommended practices are contained in EPA’s Superfund Community Involvement Handbook. This Handbook identifies the “Seven Cardinal Rules of Risk Communication,” presented in Chapter 2. As explained in the following, EPA’s risk communications did not consistently adhere to the principles and guidelines discussed in its Superfund guidance.

Risk Communications Need to Acknowledge Uncertainties

EPA’s Superfund Community Involvement Handbook specifically discusses uncertainties (“Be willing to discuss uncertainties”), and the fourth rule states:

Ifyou do not know an answer or are uncertain, acknowledge it and respond with the answer as soon as possible. Do not hesitate to admit mistakes or disclose risk information. Try to share more information not less; otherwise, people may think you are hiding something.

As detailed previously in this report, EPA’s statement that the air was safe to breathe was not qualified (except for rescue and cleanup personnel at Ground Zero). Further, EPA’s press releases did not discuss any of the uncertainties associated with this statement.

Dr. Peter Sandman, founder of the Environmental Communication Research Program at Rutgers University, provided 26 recommendations for risk communication. These include that one should “acknowledge uncertainty” and urged “never using the word ‘safe’ without qualifying it.”

Procedures Needed to Ensure Consistency in Communications

EPA communications after the WTC catastrophe sometimes gave conflicting information in regard to the same issue or were inconsistent with prior Agency positions. Specifically, information provided orally about cleaning of indoor spaces was not consistent with the messages given in Agency press releases.

64 Report No. 2003-P-00012

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