EPA response letter with respirator policy revisions, August 2003

NYC 9/11 Public Portal Document

noted that- that workers conducting the-WTC debris sorting and inspection process conducted at the Fresh Kills landfill^ was being handled as a hazardous waste operation with workers wearing wore half-face respirators, hard hats, eye protection, and Tyvek suits. [WTC debris at the Fresh Kills landfill, and at Ground Zero, did not call for a hazardous waste response under OSHA standards. nor was it handled as such.1 The author opined that Rrespiratory protection compliance by workers at Fresh Kills was approximately 90 percent as opposed to 30-50 percent compliance at the WTC site. The author observed that:

“... debris is pulled by workers from the smoking, twisted wreckage of the World Trade Centers and then wetted and hauled to a site where the debris is carejully sorted by workers wearing more protective clothing, much more consistently.’ ’

In other words, the workers at the less hazardous site were more protected-4han the workers at the more hazardous site. The author’s perception was that PPE use was more prevalent at the Fresh Kills landfill than at the WTC site. IThe report as written is again misleading in describing the debris as hazardous, and mischaracterizes the Fresh Kills landfill operation, which presented its own unique, multi-faceted challenges, as “less hazardous”! Moreover, the workers at the landfill were officially informed that not wearing respirators would result in disciplinary action. OIG investigators from our New York office who participated in the recovery operations confirmed the report’s conclusions about the difference in respiratory use between the WTC and landfill sites.

Respirator Use

As demonstrated by a fact sheet prepared on September 11,2001, EPA' s emergency response officials immediately recognized the need for and recommended the use of air purifying respirators^ at Ground Zero (see Appendix S). EPA officials told us this fact sheet was provided to a FEMA official, but was not issued. We contacted a FEMA representative who told us that the flyer was not issued because it was decided that New York City should handle worker protection issues.

3 NIOSH recommended the use of half-face negative pressure respirators with P-100, organic vapor/acid gas (P-IOO/OV/AG) cartridges. Respirators must be properly fitted in order to provide adequate protection against airborne hazards.

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