OSHA Crane Inspection Report and Analysis Oct 2001

NYC 9/11 Public Portal Document

03/19/02 10:07 FAX ®002 02■^19^2002 12:26 E.P.fl. -» 92256923 NO. 637 ceoz -ae-is-u/ -lijfain ^rom-iftYsK suu£Zi tnuuisH t .^ucin +Z1Z‘4'2SI311 r-Z!8 DZ/04 F-5ze

5 ». . I • U.S. Departmord of Labor ‘ Ausisiant toi Octajpaaanal Salary and Heafth WasntfTgron. O.C. 20210 i r

K'lr. Lowell Peterson Meyer, SubzzL English and Klein, P.C. Counselors at Law 1350 Broadway, Suite 501 I I New York, New York, 20013

I Dear Mr, Pfet&fsoxi: i Thank you for your October 16 letter to the Occupational Safety and Health I i Administration. (OSHA). This letter constitutes OSHA's position only on the I i requiremeirfs di^ussed and may not be applicable to any issue not delineated within your original’ correspondence. You presented steps that Local 73 of the Asbestos, Lead, and Hazardous Waste Laborers union thinks are imperative to protect the workers and residents in the area of the World Trade Center from the setfled dust produced by the J collapse of the tevirv towers. The steps the union recommends and our replies are provided below. ! Ste!p 1; All of the dust must be tested for asbestos using the Transnu'-ssion Electron i Microscopy method.

Reply: Bn. that the materials coirtaining asbestos were used in the constnxction of the ‘ Twin Towers, the settled dust from their collapse must be presumed to contain asbestos. Therefore, the use of Transmission Electron Microscopy (TEM) is not necessary In order to establish that the applicable provisions of the Construction Asbestos standard, 29 . CTR 1926.1101 apply during the demolition or salvage of the affected structures. i Step 2: All dust which teste positive must be removed bv licensed contractors 1 using cerHfi^ asbestos handlers. I i 1 Reply As you may know, contractor licensing and asbestos handler certification axe city and state programs. Your concarit, however, is directed toward ensuring the appropriate handling of asbestos hazards, OSHA's requirements, per 29 CFR I T 1926.1101(0) 0.), address the need for a "'competent person"and state that this individual must 'be on the worksite. Tire coropetenT person must have the qualLHcations and authorities for ensuring Worker safety and health as required by Subpart C, General .. Safety and Health Provisions for Construction (29 CFR 1926.20 through 1926.32).

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