NYC 9/11 Public Portal Document
■
The City of New York
DEPARTMENT OF HEALTH AND MENTAL HYGIENE
Michael R. Bloomberg Thomas R. Frieden, M.D., M.P.H.
Mayor Commissioner
nyc.gov/health
MEMORANDUM
To: Technical Information Staff, NCEA-W (8623D)
US Environmental Protection Agency
Washington DC 20460
From: Kelly R. McKinney PE, Associate Commissioner, Environmental Health
Date: April 7, 2003
Subject: Comments on EPA/600/P-02/002A October 2002
The Department of Health and Mental Hygiene (DOHMH) submits the following comments on
the EPA report “Draft Exposure and Human Health Evaluation of Airborne Pollution from the
World Trade Center Disaster”.
Generally, the report provides a clear characterization of ambient air issues and potential
exposures. It also, however, discusses issues beyond the scope of the document. The report
“relies primarily on the analysis of ambient air samples” but makes assumptions about indoor air
exposures based on ambient air data or on a small number of indoor air samples.
For example, in the absence of data that would describe the relationship between particle
configuration and location of exposure (indoor vs. outdoor), the report states (bottom of page 4);
"indoor exposures.. .probably warrant more concern than outdoor exposures for possible acute
irritative effects or more chronic health effects, not only because of the basic nature of some
constituent particles but also because of other unusual features."
Similarly, the report includes other statements about indoor exposures as on the top of page 33:
"...penetration of substantial quantities of WTC-derived dust into indoor office or residential
spaces likely notably increased the potential for indoor exposures (via ingestion or by inhalation
of re-entrained particles) to high levels of constituent elements and compounds." There is
significant data (including the DOH/ATSDR indoor study and the DEP indoor database
described on page 134) that contradict such a statement.
As always, we look forward to working closely with EPA on behalf of the residents of New York
City.
CITY_21MC100_008941717
NYC-WTC_000208356
OCR can misread numbers and units. Confirm readings against the page image before using them.