Air Today . . . Gone Tomorrow Article

New York Environmental Law & Justice Project, October 25, 2001 

    In response to a Freedom of Information request, we obtained EPA's test data on samples of the air, dust, and water run off taken between September 16 and October 16 from the World Trade Center area. While we found the data to be incomplete, we have enough information from this EPA sources, from other studies, and from samples we personally had analyzed to comment on some of the contaminants and to make recommendations.
    ASBESTOS DUST.  Dusts containing one percent or more of asbestos must be treated as asbestos under the EPA and OSHA regulations. EPA's test of dust in and around ground zero show asbestos levels ranging from a trace to 5 percent. The lack of uniformity in dust samples means that workers exposed to this dust should always use precautions consistent with asbestos work. Yet the front page of the October 22 New York Times showed workers on the pile either without respirators or with them hanging uselessly around their necks.
    We believe this is in part due to EPA's press releases which have stressed that air sampling in New York and New Jersey showed very low levels of asbestos. EPA did not make it clear that air tests are not relevant to those working at ground zero. These workers and workers cleaning up dust-contaminated buildings will be exposed to much higher levels of dust which are created by the work they do.
    SULFUR DIOXIDE. The EPA data showed that sulfur dioxide gas in the air on a number of days in October when people were moving back into the area were at levels EPA describes in their own Air Quality Indexes as "unhealthy for sensitive groups" (0.22 parts per million), "unhealthy" (0.3 ppm), "very unhealthy" (0.6 ppm), or outright "hazardous" (0.8 ppm or higher). There were many readings in the hazards range including a spectacular 1.8 ppm.
    Sulfur dioxide is highly irritating and sensitizing. Under EPA's own guidelines, levels of sulfur dioxide as high as these trigger public announcements warning asthamatics and people with heart problems to stay indoors. Yet we did not hear the EPA or the media warning people working or living in the areas near where these readings were obtained about this dangerous gas.
    Benzene & Organic Chemicals. Toxic organic chemicals including benzene contribute to the distinctive odor of the smoke. EPA tests of the air at ground zero and of the smoke plume showed the presence of benzene and about 16 other organic chemicals. Benzene was found in amounts over the occupational (OSHA) limit of 1 ppm on several days.
    Although concentrations of chemicals at a distance from the plume are expected to be much lower, people should have been told that the odor of the smoke is from these highly toxic chemicals. The EPA should explain that while the amounts of these toxic chemicals were usually measured at levels below OSHA standards, these standards are set for the eight-hour work day. People who work longer than eight hours on the pile or who live near ground zero are exposed for much longer periods. And those individuals who both live and work in the area are exposed continuously.
    More importantly, the OSHA standards are set to protect healthy adults. They are not intended for protection of children or people with certain health problems. The EPA should have provided this information in order to help individuals who live and/or work in areas where the odors are strong to make informed decisions about the risks to themselves and their children.
    PCBs & DIOXINS. EPA's data on PCBs and dioxins appear to contain errors or omissions. For example, there were days on which PCBs were not found in the air and water while, on the same day, very high levels of some PCBs were found in run-off water from the area. This is not consistent with other studies of PCB-contaminated sites. We need additional data before commenting.
    FIBER GLASS.  The EPA did not test for fiberglass at all. Yet the dust samples we took ranged from 10 to 75 percent fiber glass. These tiny needle-like particles are probably causing much of the reported irritation of the eyes and respiratory tract. People who are allergic to formaldehyde are likely to have additional symptoms because the fibers are usually coated with a thin layer of formaldehyde-containing resin. In addition, the National Toxicology Program lists respirable size glass fibers as "reasonably anticipated" to cause cancer.
    Clearly, the presence of fiber glass in the dust must be considered when EPA issues advice.

    Workers at ground zero should assume that asbestos is present in the dust and protect themselves appropriately.
    The dust in building and apartments should be analyzed before cleaning is initiated.\
    All work in buildings or areas contaminated with dusts containing one percent or more of asbestos should be done by certified asbestos abatement contractors.
    Householders should only attempt to clean up very small amounts of dusts that are not contaminated with either asbestos or large amounts of fiberglass.
    Respirators, including toxic dust masks, should not be recommended for use by the public unless exposure is expected to be below a level of concern or unless the individual is medically certified, fit tests, and trained for respirator use.
    HEPA vacuum cleaners and/or wet cleaning methods should be used. Even asbestos-free dusts are expected to contain enough other contaminants to warrant using these methods.
    All heating and air-conditioning systems in operation during or after September 11 should be inspected. An environmental consultant determine appropriate methods for remediation.
    All furnishings that can not be cleaned effectively such as wall-to-wall carpet and upholstered furniture should be removed.
    To ensure the dust is completely abated, offices and dwellings should be test again after they have been occupied for a few days. Serious long term health effects can be expected if small amounts of asbestos and fiber glass remain in offices and homes.

    Our criticism are intended to be constructive. Should another emergency arise, we hope that rapid and full access to data will be provided without having to file Freedom of Information requests. Withholding data encourages people to take needless risks. In the end, the information will be released and the people's trust in official sources will be compromised.
    The EPA, local health officials, and the media apparently think they are preventing panic by withholding data. Instead, our experience, based on answering over one hundred inquiries from the public, is that New Yorkers are just as courageous in dealing with air quality issues as they have been in dealing with the disaster.


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