OSHA letter on asbestos monitoring data for contractors, Jun 2002

NYC 9/11 Public Portal Document U.S. Department of Labor Occupational Safety and Health Administrat t/ 201 Varick Street ’ New York, New York 10014 w Tel: (212) 337-2378 / Fax:(212) 337-2371 / OSHA Website Address: http://www.osha^

June 14, 2002

Kathleen C. Callahan U.S. Environmental Protection Agency Deputy Regional Administrator 290 Broadway New York, NY

Dear Ms. Callahan:

This is in response to your latest electronic request addressed to David J. Ippolito, in which you sought a written description of OSHA's asbestos monitoring data for the assessment and selection of personal protective equipment for use by contractors who will be included in your residential clean-up program.

29 CFR 1926.1101 presumes worker exposure to asbestos in the construction workplace for specific work operations until this presumption is rebutted by air monitoring or until the employer has obtained a Negative Exposure Assessment as defined in this standard. As you know, OSH.A activities3t the WTC site have included assisting the New York City Department of Design and Construction and the New York City Fire Department (co-incident commanders) in characterizing exposures to many contaminants, including asbestos.

Results from that sampling activity indicate that worker exposures to airborne asbestos have been, and continue to be, ver>' low relative to the applicable limits. As of June 10, OSHA has taken 1,398 airborne asbestos samples (both personal and area) on and around the WTC site. Those samples were analyzed by Phase Contrast Microscopy (PCM) for total fiber counts, which counts all fibers as defined in the OSHA standard, not just asbestos fibers. Of the 1,398 samples taken, only 157 revealed exposure in excess of OSHA’s applicable Permissible Exposure Limit (PEL) of 0.1 fiber per cubic centimeter. However, when discriminating counting techniques and'or Transmission Electron Microscopy (TEM) analysis was performed on these samples, the asbestos fiber count was always less than half of OSHA’s PEL.

In addition, OSHA’s Manhattan Area Office has initiated an enforcement local emphasis program (LEP) to monitor cleanup activities in damaged buildings surrounding the WTC site, which we believe represent the heaviest of the settled dust accumulations. The boundaries of this LEP are: Chambers to the North, Broadway to the East, Rector to the South and Hudson River to the West. The air and bulk samples collected during those monitoring inspections contain no detectable levels of asbestos. In summary, as of June 11,2002, twenty-five bulk samples of settled dust and debris taken from six of these surrounding buildings as part of this LEP/building debris removal all were found to be non-detected for asbestos. Twenty-five air samples, the majority being personal samples, taken in these same buildings to assess exposure on workers

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