Law Department notice on WTC document preservation, Oct 2001

NYC 9/11 Public Portal Document

sampling methods were being used with the results being reported in different metrics, which made the results more difficult to interpret. A senior New York City Office of Emergency Management official told us that roles and responsibilities of the Federal, State, and local agencies in responding to a disaster were unclear on September 11,2001, and were still unclear when we met with him during the summer of 2002.

EPA has addressed coordination with other organizations in both its Headquarters and Region 2 lessons learned reports. For example, the Headquarters Report recommended that EPA collaborate with OSHA and the Department of Health and Human Services to clarify the Agency’s role in protecting the health and safety of responders, and that EPA coordinate with Department of Homeland Security to develop a coordination strategy for all responders during national emergencies. Region 2 management and staff recommended that their Region clearly identify scope and boundaries of their work in an emergency; and educate EPA and other Federal and State officials about the scope, boundaries and authorities of the various emergency response plans and systems. We agree with these recommendations. These coordination efforts should also take place in all EPA regions and include FEMA, and should address likely sources of funding for these activities.

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The WTC disaster pointed to the need for better risk assessment and characterization procedures and tools for addressing the types of environmental concerns resulting from large-scale disasters. A significant challenge encountered by EPA and other organizations was how to characterize health risks to the public in the absence of health-based benchmarks. The need for consistent sampling protocols and special monitoring requirements was also demonstrated.

Health-Based Benchmarks Needed

Government entities, such as EPA, OSHA, ATSDR, and NIOSH, have developed guidelines for many of the contaminants found in Lower Manhattan. However, existing health benchmarks were not applicable to exposures experienced by the general public in Lower Manhattan. Many of the benchmarks available at that time to assess the exposure risks for contaminants found in the ambient air were: occupational standards based on an 8-hour-per-day exposure; guidelines based on long-term exposures; or standards, such as those for asbestos, that were not health based. Details on some of these issues are in Chapter 2.

OSHA and NIOSH have developed occupational standards to protect industrial workers from pollutant exposures, but these standards are based on an 8-hour-a- day exposure. In general, these standards were not applicable to characterizing risks for residents who experienced exposures greater than 8 hours a day in indoor

60 Report No. 2003-P-00012

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