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Comments recommending removal of respirator sections from EPA report

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Document arguing that respirator safety issues fall under OSHA jurisdiction and should be removed from the EPA review.

NYC-WTC_000153382–000153393
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NYC 9/11 Public Portal Document

[ We strongly recommend that the respirator sections be completely taken out of this report. Work place safety and personal protective equipment are matters within the iurisdiction of the Occupational Safety and Health Administration (OSHA). These matters are, therefore, inappropriate for assessment by EPA-OTG. Further, much of the material concerning respirators appears to be based on two reports that are inaccurate, incomplete and insufficiently researched. !

Respirator Use at Ground Zero Laoking I A widely publicized aspect of the WTC response was the laek 'Of-respiratef-use less than 100% compliance with requirements to use respirators by rescue and construction crews. It was beyond the scope of this review to determine the extent that respirators were net-Hsed- of noncompliance with respirator requirements and why this occurred. However, we reviewed EPA' s efforts to provide respirators, reviewed accounts of respirator use in various articles and reports, and inquired about respirator use and availability during our interviews with EPA, other Federal agencies, New York City, and non-governmental officials. Our limited work in this area indicated that respirators were generallv-widely available but were neTwoni" provisions of the Site requirements for using respirators were not fully complied with for a number of reasons. A significant factor was the desire to save lives without regard for personal safety in the immediate aftermath of the disaster. Other reasons appeared to include the respirators' interference, due to the state of the technology, with the ability of emergency workers to communicate, lack of training [not true, fit-checking and orientation began as early as 9/12/011, lack of enforcement of safety measures at the she [totally false; the City, together with OSHA and the four contractors, undertook an aggressive effort to enforce the use of all personal protective equipment (PPE), especially respirators. These efforts were extensively documented throughout the recovery and cleim-up efforts!, and conflicting messages about the air quality at Ground Zero.

DRAFT EXCERPTS - FOR REVIEW & DISCUSSION PURPOSES ONLY

DRAFT EXCERPTS - FOR REVIEW & DISCUSSION PURPOSES ONLY

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NYC-WTC_000153382

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NYC-WTC_000153382Source: NYC Law Department, mirrored locally

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