Lab report transmittal cover sheet from Milcott Associates, Oct 2001

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Emilcolt Asjociaici, Inc, PrcHmlnnry Report - HAS Emlualion NYPD * Fresh Xnis Ijindfill Pages

frequently changing personnel the current site conditions and the work and hygiene procedures that arc necessary to protect their health and safety.

2) The written HASP should include how the following issues arc being managed. These items arc based on required elements of toe OSHA Asbestos and Respiratory Protection Standards.

a) Exposure Monitoring - Currently only area monitoring around toe perimeter of the NYPD work area is conducted by EPA. FBI is conducting personal monitoring weekly. Procedures for personal exposure monitoring of NYPD ' personnel should be implemented as pan of an Exposure Assessment Plan to document actual NYPD exposures and verify that appropriate work procedures are being employed. It is anticipated that individual exposures will vary according to factors which include the job being performed, weather conditions (wind and rain), the source of toe debris (lower floors of toe WTC are noted to contain more asbestos than the higher floors), etc. In addition to asbestos, provision for monitoring of other potential site contaminates should be evaluated during HASP preparation.

b) Task Hazard Assessment - Comprehensive evaluation of all the tasks being conducted by the NYPD and a detailed listing of potential hazards and means and methods to control those hazards.

c) Site Control - Access to toe debris fields where raking is taking place should be limited to personnel wearing the proper protective oqnipmeni and rf^piratopt- Waming signs should be posted at entrances to each area.

d) Use of Respiratory Protection - The following elements are necessary in order to ensure the efTecUvencss of the respirators that are being used: i) Selection - Respirators used in the debris fields should be limited to tight* filling half-face or full-face respirators. The use of filtcring-fiiccpicces (dust masks) of any type should he nmhibt^ unless it is shown that asbestos levels to that person in that Job arc consistently below the OSHA PEL. ii) Training - The training which was observed included instructions on how to put on toe respirator and how to perform a positive and negative pressure "Ct- chcck". Typical respirator training also includes why a respirator is necessary; how improper fit, use, or maintenance can compromise toe protective effect; capabiliiies and limiiations; maintenance and storage procedures; and how to inspect the respirator. Additional training is necessary. iii) Fit-Testing • Instruction was provided on how to perfonn a positive/negative pressure "Fit-Check". Fit-testing, procedures which evaluate if a person has an effective seal between toe respirator and tocir face, was not conducted. Qualitative fit-testing tests an individuals ability to smell, taste, or otherwise

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