OSHA Crane Inspection Report and Analysis Oct 2001

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The general definition of a "competent person" is presented at 29 CFR 1926.32®. According to the standards a "competent person" is, "one toho is capable ofi'entifyin^ existing and predictable hazards in the surroundings or working cmdiiims which ere unsanitanf, hazardous, or dangerous hi employees, and who has authorization to take prompt correctim measures io eliminaie Ihemf' Paragraph 1926.1101(b) further defines a "competent person" as, ''in addition io the definition in 29 CKR 1926.32^, cm who is capable ofidentifying existing asbestos hazards in the Toorkplace and selecting the appropriate control strategy^ asbestos exposure, who has the'authority to take prompt carrsctws measures io sliminate them, as specified in 29 CFR 1925.32^" The Construction. Asbestos standard further incorporates the provisions of 29 CFR 1926.20(b)(2) which, requires frequent and regular inspections of job sites, materials, and equipment to be made by the competent . I person. These requirements are geared toward ensuring maximum safety and health I for employees on worksites where asbestos is present •

Step 3: HEPA filters must be evaluated. Reply: The National institute for Occupational Safety and Health (NIOSH) is the Federal agency assigned the xesponsibfli^’ for approving respirators and filters. AU respirators and filters required by OSHA standards must be NIOSH certified, OSHA's Respiratory Protection Standard, 29 CFR 191D.134, governs the worlqjlace use of respirators. A NIOSH-certified HERA filter is, "afilter that is at kast 99.97% efficient in removing mono-disperse partides of 0.3 nticrometers in diameter.'' Equivalent particulate filters certified by NIOSH are the NlOO, RlOO, arid PlOO filters.

I The 03 micrometers (microns - um) diameter particle used in the certification testing of i the HERA (and 100-series) respirator filters is approximately the most penetrating for I ! particulate filters. Although it seems contrary to expectation, smaller particles do not penetrate as readily as 0-3 gm particles. That is to say, these filters eliminate other i particle sizes at least as w^ as the certified efficiency value of 99.97%, i « Step 4: The rejnaining debris must be taken out properly. Reply: Asbestos-containing waste must be presumed to be intermixed with the remaining debris at the World Trade Center site bemuse materials containing asbestos ‘ I I were used in the constriction of the Twin Towers, Therefore, in accordance with 1926.1101(g)(1)(ii), wet methods must and are being used to control employee asbestos exposures while removing the remaining Twin Towers debris except where employers

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