OSHA Crane Inspection Report and Analysis Oct 2001

NYC 9/11 Public Portal Document 03/19/02 10:07 FAX

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The general definition of a "competent person" is presented at 29 CFR 1926.32(f). I According to the standard/ a "competent person" is, "one who is capable of identif^g existing and predictt&le hazards in Ute siaroundings ar working condiHans wMch are unsanitiny, hazardous, or dangerous to employees, and who has auOiorization to take prompt I I correctioe measures io eUmiruae them." Paragraph 1926.1101(b) further defines a "competent person" as, "'in addition io &e definition in 29 1926.32(f), one who is capable ! of identifying existing asbestos hazards in the workplace and sekcting the appropriate control strategy far asbestos exposure, who has ihe'authoritij to take prompt ccrrectrae measures io' I elmina.te them, as specified in 29- CPK192632^." The Construction Asbestos standard further incorporates Ae provisions of 29 1926.20(b)(2) which requires frequent and regular inspections of job sites, materials, and equipment to be made by the competent 1 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 S^ety and Health. (NIOSH) is the Federal agency assigned, the responsibility for approving respirators and ^ters. All respirators and filters required by OSHA standards must be NIOSH certified. OSHA's Respiratory ProtEction Standard, 29 CFR 1910.134, governs the workplace use of respirators, A NIOSH-certified HEPA filter is, "afilter that is at least 99.97% efftciertt in remooaig mono-diverse particles ofC.3 micrometers in diameier.'' Equivalent particulate filters certified by NIOSH are the NlOO, KLOO, arid PlOO filters.

The 03 micrometers (microns - gm) diameter particle used in the certification testing of .the HERA (and 100-seri.es) respirator filters is approximately the most penetrating for I : particulate filtera. Although, it .seems contrary to expectation, smaller particles do not i penetrate as readily as 0.3 pm particles. That is to say, these filters eliminate other I particle sizes at least as well as the certified efficiency value of 99.97%. I

Step 4; The remaouing debris must be taken out properly.

: 1i Reply:: Asbestos-containing waste must be presumed to be intemuxed with'the remaining debris at the World Trade Center site because materials containing asbestos : I were used in the construction of the Twin Towers. Therefore, in accordance with ! . 1926-1101(g)(l)(u), 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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