Law Department notice on WTC document preservation, Oct 2001

NYC 9/11 Public Portal Document

Recommendations

We recommend that the EPA Administrator coordinate with the Department of Homeland Security, FEMA, other appropriate Federal agencies, and those State and local governments having jurisdiction over potential terrorist targets to:

3-1. Develop protocols for determining how indoor environmental concerns will be handled in large-scale disasters, to include addressing:

• The agency or agencies responsible for testing and/or overseeing testing of indoor spaces; • Sampling methods to be used in analyzing indoor contamination; • Benchmarks to be used in assessing whether the indoor contamination poses a threat; • Under what circumstances government-assisted cleanups are warranted; • How these cleanups will be funded; and • The agency or agencies responsible for communicating testing results and appropriate cleaning instructions.

3-2. Develop and publish oversight criteria and State and local agency reporting requirements for those agencies involved in cleaning up buildings and other sites contaminated by pollutants resulting from terrorist attacks or other disasters.

Additional recommendations related to responding to indoor environmental concerns are in Chapters 6 and 7.

Agency and New York City Comments and OIG Evaluation The Agency disagreed that unprotected workers and residents may have experienced unnecessary exposures to asbestos or other pollutants as a result of the delay in providing a government-organized and monitored cleanup, because (1) their recommended cleaning instructions (use of wet mops and HEPA vacuums) were proven effective in EPA studies, and (2) the Agency recommended professional cleaning when residents encountered more than minimal dust. The Agency generally agreed with the recommendations.

EPA’s study of cleaning effectiveness concluded that 1 to 3 cleanings were needed to achieve the health-related benchmarks and did not address the exposure experienced by an unprotected person who may be performing these recommended cleaning procedures. Also, a NYCDOH study conducted in October 2001 concluded that the majority of households polled did not follow the recommended procedures of wet mopping and HEPA vacuuming. Also, a study of immigrant workers used to clean indoor spaces in Lower Manhattan around

30 Report No. 2003-P-00012

NYC-WTC_000145550