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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

Reports on Lack of Respirator Use

[This section should be completely deleted, because while it purports to represent a total picture of site operations, it in fact presents a ven.' narrow and skewed snapshot by the author, who was at the site for a very limited number of hours, and who misidentified a key City agency - the Department of Design and Construction - and its role in the rescue and recovery efforts.] An October 2001 report' by the National Institute of Environmental Health Sciences discussed worker safety issues at the WTC site for the period up to October 5, 2001. The report's observations generally focused on construction workers at the site and not Fire Department rescue team or Federal disaster assistance personnel. According to the report:

Respiratory -proteeti-on- was rare with 'the exception of heavy ■ equipment operators. Further, workers were observed in the smoke plume emanating froffl-the-pile without'iiard hats, eve wear, or respiratersr [This should not be presented as the norm. There were thousands of rescue and clean-up workers on the Site and a DDC official monitoring safety at the site personally observed many who did weai‘ respirators diligently. There are thousands of photographs and hours of video that indicate the use of respiratory equipment and hard hats. Respirator use was tracked and enforced throughout the response to the disaster.

Workers-did-not-deeen IdecontamtnateT-afi^^^ IThis implies a hazardous waste operation, and this rescue, recovery and clean-up operation was not such an event.] The hand/face and boot wash stations did not appear to be used by most of the workers.

During the September 22-26, 2001, period, an increase in worker protection was observed, notably respiratory protection. Vehicles leaving the site began to be hosed down.

1 “Worker Education and Training Program (WETP) Response to the World Trade Center Disaster: Initial WETP Grantee Response and Preliminary Assessment of Training Needs," Donald Elisburg, John Moran, National Institute of Environmental Health Sciences WETP, National Clearinghouse for Worker Safety and Health Training, October 6, 2001.

2

NYC-WTC_000153383

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NYC-WTC_000153383Source: NYC Law Department, mirrored locally

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