Street
level conditions in Lower Manhattan
after collapse.
Source: wtcphotos by
flagsoncars.com
Related
LA Times & NY Times articles
Executive Summary
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Chapter 2 EPA Statements About Air Quality Not Adequately Qualified
[Complete Evaluation Report at EPA website 3.39MB PDF file]
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Street
level conditions in Lower Manhattan
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The September 11, 2001, terrorist attack on the World Trade Center in New York City and the environmental aftermath were unprecedented. Airborne dust from the collapse of the towers blanketed Lower Manhattan and was blown or dispersed into many of the surrounding office buildings, schools, and residences. This complex mixture of building debris and combustion by-products contained such ingredients as asbestos, lead, glass fibers, and concrete dust. Responding to this crisis required organizations from all levels of government to coordinate their response efforts and to make critical public health and safety decisions quickly, and without all of the data that decision-makers would normally desire.
Unfortunately, this country may experience more terrorist attacks, and a response to such a tragedy could be needed again. Accordingly, we initiated this evaluation, in consultation with the Environmental Protection Agency (EPA) Deputy Administrator, to evaluate EPA’s response to September 11. During our evaluation, we sought to answer six specific questions that address how EPA responded and how it could better respond in the future. Those questions, along with summaries of what we found and recommendations for each, follow.
1. Did the available monitoring data and analyses of that data support EPA’s major public communications regarding air quality and associated health risks resulting from the collapse of the World Trade Center (WTC) towers?
EPA’s early public statements following the collapse of the WTC towers reassured the public regarding the safety of the air outside the Ground Zero area. However, when EPA made a September 18 announcement that the air was “safe” to breathe, it did not have sufficient data and analyses to make such a blanket statement. At that time, air monitoring data was lacking for several pollutants of concern, including particulate matter and polychlorinated biphenyls (PCBs). Furthermore, The White House Council on Environmental Quality influenced, through the collaboration process, the information that EPA communicated to the public through its early press releases when it convinced EPA to add reassuring statements and delete cautionary ones. An EPA draft risk evaluation completed over a year after the attacks concluded that, after the first few days, ambient air levels were unlikely to cause short-term or long-term health effects to the general population. However, because of numerous uncertainties – including the extent of the public’s exposure and a lack of health-based benchmarks – a definitive answer to whether the air was safe to breathe may not be settled for years to come. Details regarding the handling of indoor contamination are discussed in relation to Objective 2 below.
EPA has initiated actions to strengthen its risk communication procedures for emergency situations, including the development of a draft Plan for Incident Communication. We recommend that the EPA Administrator continue these efforts and develop procedures for emergency risk communication to ensure that public pronouncements regarding health risks and environmental quality are adequately supported with available data and analysis and are appropriately qualified.
2. Were EPA actions and decisions in regard to evaluating, mitigating, and controlling risks to human health from exposure to indoor air pollutants in the WTC area consistent with applicable statutes, regulations, policies, guidance, and practice?
EPA’s actions to evaluate, mitigate, and control risks to human health from exposure to indoor air pollutants in the WTC area were consistent with applicable statutes and regulations. These statutes and regulations do not obligate EPA to respond to a given emergency, allowing for local agencies to lead a response, and New York City in fact exercised a lead role regarding indoor air. Nonetheless, we believe EPA could have taken a more proactive approach regarding indoor air cleanup. After the City was criticized for its response, EPA began to assume a lead role in February 2002. Prior to initiation of the EPA-led cleanup, many WTC area residents had returned to their homes, and a study indicated most of them had not followed recommended cleaning practices. The full extent of public exposure to indoor contaminants resulting from the WTC collapse is unknown.
We recommend that the EPA Administrator coordinate with other Federal, State, and local agencies to develop protocols for determining how indoor environmental concerns will be handled in large-scale disasters. We also recommend that EPA work with the Department of Homeland Security and other Federal agencies to develop and publish oversight criteria, including State and local agency reporting requirements, for handling indoor air contamination.
3. Were asbestos demolition and renovation work practice standards followed during WTC cleanup and recovery operations and, if not, why not?
We could not conclusively determine the extent to which required work practices regarding the control of asbestos were followed at the WTC site during demolition and debris removal. Since asbestos is a known human carcinogen, EPA has established stringent work practices to control emissions of asbestos resulting from demolition and renovation projects. We found that a significant requirement to reduce emissions in emergency demolitions – wetting damaged buildings before demolition and keeping the waste material wet after demolition – was followed. However, work practices applicable to the transport of debris from the site were employed inconsistently. The specific impact on air quality of any variance from EPA’s asbestos emergency work practices is unknown.
We recommend that the EPA Administrator develop specific procedures for ensuring that Federal, State, and local responders follow the appropriate NESHAP work practices for catastrophic emergency situations involving asbestos.
4. To what extent were EPA and government communications regarding air quality and associated health risks: (a) received by the public; (b) understood by the public; and (c) effective in getting people to take the desired actions to reduce their potential health risks?
After the WTC terrorist attack, people received information from many different sources, and many factors – in addition to government communications – could have influenced their actions. Information is a critical component in helping the public minimize their exposure to potential health hazards. However, evidence gathered through government hearings, news polls, health studies, and our interviews indicated that the public did not receive sufficient air quality information and wanted more information on associated health risks. Also, evidence indicated that government communications were not consistently effective in persuading the public to take recommended precautions. Because of these concerns, the OIG conducted a survey of New York City residents regarding government communications. These results will be reported separately.
EPA has initiated several actions to improve its risk communications procedures during emergencies. Further, EPA is working with the Federal Emergency Management Agency to clarify roles and responsibilities for ensuring worker safety during an emergency response. We recommend that EPA continue to coordinate efforts to establish clear Federal roles.
5. What additional actions, if any, should EPA take to improve its response and recovery efforts in the WTC area related to ambient and indoor air quality?
The majority of officials contacted indicated EPA did not need to take additional actions to address outdoor ambient air quality concerns. However, concerns were expressed regarding indoor contamination, and several more measures can be taken to ensure that indoor cleanup effectively minimizes health risk exposure. We recommend that EPA implement a testing program to ensure the indoor cleanup effectively reduced health risks from all pollutants of concern, and implement a verification program to determine whether previously cleaned residences have been recontaminated.
6. Should EPA revise its preparation and contingency planning for dealing with air pollution resulting from environmental catastrophes?
The events of September 11 had national security ramifications not previously experienced, and many persons interviewed spoke highly of the response of EPA and its employees. Still, we, as well as EPA and others, have identified lessons learned from the response that can improve EPA’s preparedness for future disasters. An overriding lesson learned was that EPA needs to be prepared to assert its opinion and judgment on matters that impact human health and the environment. Although many organizations were involved in addressing air quality concerns resulting from the WTC collapse, subsequent events have demonstrated that, ultimately, the public, Congress, and others expect EPA to monitor and resolve environmental issues. This is the case even when EPA may not have the overall responsibility to resolve these issues or the necessary resources to address them.
EPA has initiated many actions as a result of its own internal lessons learned exercises. Based on our review, we our making a number of recommendations to improve EPA’s emergency response capabilities in three areas: (1) contingency planning, (2) risk assessment and characterization, and (3) risk communication.
Agency and New York City Comments and OIG Evaluation
In her August 8, 2003 response to the draft report, the EPA Acting Administrator stated that she was proud of the men and women of EPA and that the Agency’s response was extraordinary. Although she generally agreed with the recommendations of our draft report (with the exception of Chapter 6), she responded that our report lacked sufficient acknowledgment of EPA’s efforts in several areas. For example, she noted that our report focused too heavily on the Agency’s press releases and did not sufficiently consider the Agency’s other forms of communication or the Agency’s “lessons learned” efforts. She provided several specific comments outlining the Agency’s disagreement with some of the report’s findings and conclusions. A detailed summary of the Agency response and our evaluation is included at the end of each chapter. The Agency’s complete response and our evaluation of that response are included as Appendices Q and R, respectively.
New York City officials responded to excerpts from the draft report and provided us with specific comments and clarifications which we incorporated into the final report, as appropriate. New York City’s response is attached as Appendix S and our evaluation of that response is attached as Appendix T.
EPA’s early statements reassured the public regarding the safety of the air outside the Ground Zero perimeter area. However, when EPA made a September 18 announcement that the air was “safe” to breathe, the Agency did not have sufficient data and analyses to make the statement. The White House Council on Environmental Quality (CEQ) influenced, through the collaboration process, the information that EPA communicated to the public through its early press releases when it convinced EPA to add reassuring statements and delete cautionary ones. Conclusions from an EPA draft risk evaluation completed over a year after the attacks have tended to support EPA’s statements about long-term health effects when all necessary qualifications are considered. However, EPA’s statements about air quality did not contain these qualifications. (Details on indoor air are in Chapter 3.)
Communicating Information to the Public Critical
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Seven Cardinal Rules of Risk Communication
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Communicating the potential health risks resulting from an environmental hazard is a key mechanism for warning the public to mitigate potential exposures and take other precautions to avoid unnecessary health risks. However, an emergency situation often presents significant challenges.
EPA has many years of experience in communicating environmental risks to the public, especially through its Superfund program. The Agency has issued numerous guidance documents on how to effectively communicate risks to the public, including EPA’s “Seven Cardinal Rules of Risk Communication” (see box). EPA and the New York City Department of Health were significantly involved in communicating information on the air quality in Lower Manhattan after the WTC disaster.
What EPA Said in Its Major Public Communications
EPA used various methods to inform the public after September 11, including attending public forums; having interviews with newspaper, television, and radio reporters; and posting information on its public web site. Our analysis focused primarily on the information provided through press releases since the Agency develops its position through a deliberative process that represents the Agency’s official position.
EPA issued five press releases within 10 days after September 11, 2001, four more through the end of December, and another four through the end of May 2002. EPA’s WTC press releases from September through December 2001 reassured the public about air quality. Although EPA’s press releases generally recommended that rescue and cleanup workers take precautions to reduce their exposure to pollutants, EPA’s basic overriding message was that the public did not need to be concerned about airborne contaminants caused by the WTC collapse. This reassurance appeared to apply to both indoor and outdoor air. For example, EPA Region 2 officials told us that the September 18 statement made by the EPA Administrator (see Appendix C) that the air was “safe” to breathe only applied to:
However, except for the second point, the statements issued by EPA in press releases throughout 2001 generally did not contain the above qualifications. For the general public, EPA’s overriding message was that there was no significant threat to human health.
Key air quality related statements from EPA press releases issued during 2001 following the WTC collapse are in Table 2-1. The full text of each of these press releases are available at our web site.2
Table 2-1: Key Air Quality Statements from 2001 Press Releases
Date Key Statement
09-13-01 “Monitoring and sampling conducted on Tuesday and Wednesday have been very reassuring about potential exposure of rescue crews and the public to environmental contaminants. . . . EPA and OSHA will work closely with rescue and cleanup crews to minimize their potential exposure, but the general public should be very reassured by initial sampling.”
09-16-01 “Our tests show that it is safe for New Yorkers to go back to work in New York’s financial district” (quoting Assistant Secretary of Labor for OSHA). “The Agency is recommending that businesses in the area planning to reopen next week take precautions including cleaning air conditioning filters and using vacuums with appropriate filters to collect dust.”
09-18-01 “I am glad to reassure the people of New York and Washington, D.C. that their air is safe to breath [sic] . . . ” (quoting EPA Administrator).
09-21-01 “NYC Monitoring Efforts Continue to Show Safe Drinking Water & Air” (press release heading).
10-03-01 “Data Confirms No Significant Public Health Risks; Rescue Crews and Nearby Residents Should Take Appropriate Precautions. . . ” (press release sub-heading).
10-30-01 “While we have fortunately not found levels of contaminants that pose a significant health risk to the general public, our efforts to monitor the area and keep the public informed of our findings have not waned. “
Agency officials stressed that press releases were only one of many forms of communication used to provide air quality information to the public, and that public forums and media interviews were also important. Further, EPA provided public access to its monitoring data through its public web site, which included interactive maps that could be used to identify monitoring results. In regard to the monitoring data, we found no evidence that EPA attempted to conceal data results from the public.
Data Available at the Time Did Not Fully Support EPA Press Releases
Information and the analyses of available data did not fully support the statement made in the September 18, 2001, release, which quoted the EPA Administrator as saying the air was “safe” to breathe. Four factors in particular posed limitations on the conclusions that could be made at that time about air quality:
EPA did not have monitoring data to support reassurances made in press releases up to September 18 because it lacked monitoring data for several contaminants, particularly PCBs, particulate matter, dioxin, and PAHs.
According to a draft evaluation entitled Exposure and Human Health Evaluation of Airborne Pollution from the World Trade Center Disaster, by EPA’s Office of Research and Development, that Office was not able to make health risk evaluations for exposures in the first couple of days because of the lack of monitoring data. For several pollutants of concern, sampling did not begin until September 16, and in many cases the results were not known until after the September 18 press release was issued. EPA was not able to obtain samples and monitor air due to difficulties in access and security, power supply sources, equipment availability, and analytical capacity. As a result, data available before September 18 for making conclusions about air quality for pollutants other than asbestos was limited.
Table 2-2 shows when air monitoring began and when the data results first became available for each pollutant of concern.
Table 2-2: Outdoor Sampling Timeline for Pollutants of Concern
Pollutant Sampling Source Sampling Started Results Available[1] Lead Dust September 11 September 12 Asbestos Bulk Dust September 11 September 12 Ambient Air September 12 September 13 Benzene [2] Air Grab Samples September 16 September 17 Mercury Ambient Air September 16 September 18 Dust September 16 September 20 Lead Ambient Air September 16 September 20 [3] PAHs Ambient Air September 16 September 20 Cadmium Chromium Manganese PAHs Dust September 16 September 22 Dioxin Dust September 16 September 24 [4] Ambient Air September 16 September 28 PCBs Ambient Air September 16 September 28 PM2.5 Ambient Air September 21 October 4 PM10 [5] TSP [5] Ambient Air No Monitoring No Monitoring Notes: [1] = Based on Daily Summaries of monitoring results prepared by Region 2 staff in Edison, New Jersey, which were used to brief management on data results. [2] = EPA sampled for additional VOCs on this date as well. [3] = EPA’s Health Risk Evaluation reported lead results were known on September 18. [4] = EPA’s Health Risk Evaluation reported dioxin results were known on September 23. [5] = “PM” stands for “Particulate Matter.” PM2.5 represents “fine” particulate matter less than or equal to 2.5 micrometers in diameter. PM10 refers to particulate matter less than or equal to 10 micrometers, with the fraction between 2.5 and 10 micrometers known as “coarse.” “TSP” stands for “Total Suspended Particulates,” and includes all sizes of particles.
Health-based benchmarks for short-term and acute exposures did not exist for pollutants of concern resulting from the collapse of the WTC. For asbestos, EPA used benchmarks originally designed for other purposes to assess potential health risks from breathing the air following the WTC collapse. Because health-based benchmarks for short-term exposures did not exist for most of the other pollutants, EPA revised benchmarks for lifetime (30-year) exposures to develop screening levels for short-term (1-year) exposures. Further, health-based benchmarks did not exist for assessing the risk to human health from exposure to the combination of air pollutants that were emitted.
EPA did not have health-based benchmarks for airborne asbestos nor for asbestos in bulk dust. Consequently, EPA used criteria from two programs originally developed for other purposes.
Guidelines were not available to assess the impact of acute (up to 8 hours) exposures. People caught in the initial debris and dust cloud on September 11 were potentially exposed to high levels of various pollutants for a short duration. EPA has been funding a program to develop Acute Exposure Guideline Levels (AEGLs), but none of these levels had been finalized at the time of the WTC disaster. The program had developed several draft AEGL’s but these draft AEGLs were not applicable to the pollutants of concern at the WTC site.
In general, EPA did not have benchmarks to evaluate short-term exposures such as those experienced from the WTC collapse. For the WTC situation, EPA adjusted the Superfund 30-year exposure benchmarks to 1-year (short-term) exposure benchmarks. (See Appendix D for a list of benchmarks used by EPA in assessing WTC ambient data.) Since this was done very quickly during an emergency situation, these benchmarks were not subjected to peer review.
In addition to not knowing the health impacts of certain individual pollutants, information was not available on the cumulative or synergistic impacts of being exposed to several pollutants at once. For example, one medical expert suggested there may be a synergistic effect between PAHs and asbestos, since PAHs resemble cigarette tar. Studies have shown the lung cancer risk from exposure to asbestos is increased exponentially for cigarette smokers. In addition, this expert noted that the combination of high pH and the small shards of glass found in WTC dust could have had a synergistic impact on the acute respiratory symptoms that many people experienced.
There were limitations with all three methods used to analyze asbestos concentrations in the ambient air and bulk dust in Lower Manhattan. These limitations, which were not noted in EPA’s press releases, restricted EPA’s ability to make definitive assessments about the health risks posed by asbestos. However, even with these limitations, sufficient data existed to identify the presence of asbestos in the dust and ambient air, and to warrant that persons working around the dust take necessary precautions to not inhale the dust. The three methods used and their limitations follow:
According to EPA, essentially all outdoor areas at the WTC site were vacuumed, and the detection methods did not impact the action actually taken to remove the dust from outdoor areas. See Appendix E for a summary of EPA’s outdoor air asbestos sampling results.
Some Asbestos Readings Exceeded Levels of Concern
Over 25 percent of the bulk dust samples that EPA had collected and analyzed by September 18 showed the presence of asbestos above the 1 percent threshold used by EPA to indicate significant risk. In addition, New York City used the 1 percent threshold to determine whether the removal of indoor dust was subject to its Asbestos Control Program regulation. The level of asbestos in dust was a concern because of the potential for the dust to be disturbed and become airborne, and thus inhaled. As noted above, this level is not a health-based standard and dust that contains less than 1 percent could pose a health risk. See Appendix F for results of EPA outdoor asbestos bulk testing.
EPA and the New York City Department of Environmental Protection (NYCDEP) conducted extensive ambient air monitoring for asbestos around Ground Zero and Lower Manhattan after September 11. This sampling was conducted at up to 60 sites and a total of almost 10,000 samples were analyzed using TEM. During the month of September 2001, EPA and New York City monitoring recorded 30 exceedences of the AHERA standard of 70 s/mm2. However, after September 2001 the number of AHERA exceedences decreased significantly. For the period October 2001 through May 2002, seven exceedences of the AHERA standard were recorded, as shown in Table 2-3.
Table 2-3. Ambient Asbestos Readings in Lower Manhattan In Excess of 70 s/mm2
Reading Date (s/mm2) Location 1 10/09/01 104.99 Chambers Street 11/28/01 124.44 North Side of Stuyvesant High School 12/27/01 204.44 Albany and Greenwich 01/14/02 72.00 Pier 6 bus sign 02/05/02 88.00 Liberty and Trinity 02/11/02 213.33 Church and Dey 05/25/02 336.00 West Street (near Stuyvesant H.S.) 1 Excludes four exceedences at worker wash tent.
Council on Environmental Quality Influenced EPA Press Releases
Coordination and collaboration impacted the completeness of the information and the substance of the message EPA communicated to the public through its press releases. As a result of the White House CEQ’s influence, guidance for cleaning indoor spaces and information about the potential health effects from WTC debris were not included in EPA’s issued press releases. In addition, based on CEQ’s influence, reassuring information was added to at least one press release and cautionary information was deleted from EPA’s draft version of that press release.
EPA officials told us that EPA’s WTC press releases issued during the weeks following September 11 were discussed in conference calls that included EPA officials, OSHA, and CEQ. Accordingly, the content of an EPA press release issued during this period could come from several different sources.
Few written records were available on the process used to prepare WTC press releases. We found draft versions for two of the press releases. However, the White House’s role in EPA’s public communications about WTC environmental conditions was described in a September 12, 2001, e-mail from the EPA Deputy Administrator’s Chief of Staff to senior EPA officials:
All statements to the media should be cleared through the NSC [National Security Council] before they are released.
According to the EPA Chief of Staff, one particular CEQ official was designated to work with EPA to ensure that clearance was obtained through NSC. The Associate Administrator for the EPA Office of Communications, Education, and Media Relations (OCEMR)3 said that no press release could be issued for a 3- to 4-week period after September 11 without approval from the CEQ contact.
Although EPA’s position has been that WTC area residents should obtain “professional cleaning,”4 EPA’s press releases did not instruct residents to do so. Instead they instructed residents to follow recommended and proper cleaning procedures and referred the public to the New York City Department of Health (NYCDOH) for recommended cleaning procedures. We asked the OCEMR Associate Administrator whether her office had considered advising the public through a press release that they needed to obtain professional cleaning for their indoor spaces. The Associate Administrator stated: “It was in a press release: it was removed by. . . [the CEQ contact].”
OCEMR’s records contained a document, entitled “PM FACT SHEET,” that discussed the health risk to “sensitive populations” from exposure to particulate matter. We asked the Associate Administrator whether she had considered putting any of this information in a press release. She said she had, but the CEQ official discouraged her from doing so. Her recollection was that he told her health effects information should not be included in EPA’s press releases, and that anything dealing with health effects should come from New York because they were on the ground and they were already dealing with it.
The extent of the CEQ official’s influence on EPA’s WTC press releases was most clearly illustrated by the changes that were made to a draft press release dated September 14, 2001, that was issued on September 16, 2001. Every change that was suggested by the CEQ contact was made. The CEQ official’s suggested changes added reassuring statements and deleted cautionary statements.
Details on these various revisions based on the CEQ contact’s input, including comparisons of draft and issued versions, are in Table 2-4, while the actual press release is in Appendix G. It should be noted that our analysis of CEQ’s input was limited because CEQ officials chose not to meet with us. Details on this limitation are in Appendix B.
Table 2-4: Impact of CEQ Instruction on September 16 EPA Press Release
Statement Deleted From the Draft and Not Replaced
The concern raised by these samples would be for the workers at the cleanup site and for those workers who might be returning to their offices on or near Water Street on Monday, September 17, 2001.
Statements Significantly Revised
Draft Press Release Recent samples of dust gathered by OSHA on Water Street show higher levels of asbestos in EPA tests. Issued Press Release The new samples confirm previous reports that ambient air quality meets OSHA standards and consequently is not a cause for public concern. New OSHA data also indicates that indoor air quality in downtown buildings will meet standards. EPA has found variable asbestos levels in bulk debris and dust on the ground, but EPA continue [sic] to believe that there is no significant health risk to the general public in the coming days. Appropriate steps are being taken to clean up this dust and debris. ------------------------------------------------------------------------------- Draft Press Release Seven debris and dust samples taken Thursday, showed levels of asbestos ranging from 2.1 percent to 3.3 percent. EPA views a 1 percent level of asbestos as the definition for asbestos-containing material. Issued Press Release Debris samples collected outside buildings on cars and other surfaces contained small percentages of asbestors, [sic] ranging from 2.1 to 3.3 - slightly above the 1 percent trigger for defining asbestos material. -------------------------------------------------------------------------------
Statements Added to the Issued Press Release Based on CEQ Instructions
CEQ Instructions “Add sentence about OSHA monitors walking the streets yesterday and wearing personal monitors and coming up clean.” Statements Added to Issued Press Release OSHA staff walked through New York’s financial district on September 13th, wearing personal air monitors and collected data on potential asbestos exposure levels. All but two samples contained no asbestos. Two samples contained very low levels of an unknown fiber, which is still being analyzed ------------------------------------------------------------------------------- CEQ Instructions “INSERT HENSHAW quote somewhere around here” Statements Added to Issued Press Release “Our tests show that it is safe for New Yorkers to go back to work in New York’s financial district,” said John L. Henshaw, Assistant Secretary of Labor for OSHA. ------------------------------------------------------------------------------- CEQ Instructions “Add OSHA indoor air sampling data sentence.” Statements Added to Issued Press Release Air Samples taken on Sept. 13th inside buildings in New York’s financial district were negative for asbestos.
We were unable to identify any EPA official who claimed ownership of EPA’s WTC press releases issued in September and early October 2001. When we asked the EPA Chief of Staff whether she could claim ownership of EPA’s early WTC press releases, she replied that she was not able to do so “because the ownership was joint ownership between EPA and the White House,” and that “final approval came from the White House.” She also told us that other considerations, such as the desire to reopen Wall Street and national security concerns, were considered when preparing EPA’s early press releases. The OCEMR Associate Administrator said of the September 16 release: “I did not feel like it was my press release.”
September 13 Press Release Also Revised to Eliminate Cautionary Statements
Cautionary statements in a draft version of the September 13, 2001, press release (see Appendix H) were removed and replaced with more reassuring statements. For example, the second clause of the caption to the draft press release, which noted that EPA was testing for environmental hazards, was replaced with a statement reassuring the public about environmental hazards. Further, the press release did not contain a statement in the draft version that EPA considered asbestos hazardous in this situation. We were unable to locate any record that explained why the changes were made, and the OCEMR Associate Administrator did not recall ever having seen the draft. The major differences between the draft and the issued press release are shown in Table 2-5.
Table 2-5: Significant Changes to the September 13 EPA Press Release
Draft Press Release Caption to press release: EPA Initiating Emergency Response Activities, Testing Terrorized Sites For Environmental Hazards Issued Press Release Revised caption to press release: EPA Initiating Emergency Response Activities, Reassures Public About Environmental Hazards ------------------------------------------------------------------------------- Draft Press Release Preliminary results of EPA’s sampling activities indicate no or very low levels of asbestos. However, even at low levels, EPA considers asbestos hazardous in this situation and will continue to monitor and sample for elevated levels of asbestos and work with the appropriate officials to ensure awareness and proper handling, transportation and disposal of potentially contaminated debris or materials. Issued Press Release EPA is greatly relieved to have learned that there appears to be no significant levels of asbestos dust in the air in New York City,” said Administrator Whitman. “We are working closely with rescue crews to ensure that all appropriate precautions are taken. We will continue to monitor closely.” Public health concerns about asbestos contamination are primarily related to long-term exposure. Short-term, low-level exposure of the type that might have been produced by the collapse of the World Trade Center buildings is unlikely to cause significant health effects. EPA and OSHA will work closely with rescue and cleanup crews to minimize their potential exposure, but the general public should be very reassured by initial sampling.
Recent Conclusions About WTC Air Quality
The only formal risk evaluation of the health effects from exposure to the outdoor air in Lower Manhattan following the WTC collapse was performed by EPA’s Office of Research and Development. This evaluation, still in draft form as of July 2003, concluded that, except for the rescue and cleanup workers at Ground Zero who were not wearing respirators, as well as unknown exposures to the public during the first few days, persons in the area were unlikely to suffer adverse heath effects from the outdoor air.
The report also had a caveat for the conclusions drawn in the report relative to human health risks. The draft report stated:
This report should be viewed as the first phase of an ongoing analysis, and the conclusions and findings cited below should not be considered the final EPA judgment. At this point, the available data and analysis are still too preliminary to support reliable quantitative predictions of potential human health risks.
We spoke to a number of experts in the field of environmental monitoring, including physicians, industrial hygienists, and researchers These experts generally agreed that the levels of airborne asbestos detected in the air outside the perimeter of Ground Zero in Lower Manhattan did not present a significant increase in long-term health risk to the public. Appendix I lists the experts we interviewed during this evaluation.
We noted that several health studies pointed to potential problems for firefighters, rescue workers, and other persons working within the confines of Ground Zero who did not wear respirators:
At the time we completed our report, no studies of the health effects of the WTC collapse on the general public had been completed, although we noted studies6 were underway to determine the effects of the WTC collapse on pregnant women and their children. Further, in January 2003, New York City and Federal health officials announced a plan to study residents and employees in Lower Manhattan to identify whether there will be long-term pulmonary effects associated with exposure to WTC dust and air.
Recent Developments
EPA has initiated actions to strengthen its risk communication procedures for emergency situations. For example, EPA’s Office of Public Affairs has prepared a draft “Plan for Incident Communication” that establishes basic incident procedures and assigns responsibilities and authorities. Further, the Agency intends to use this plan as the basis for more inclusive best-practices emergency communications guidance.
Conclusions
EPA’s early statement that the air was safe to breathe was incomplete in that it lacked necessary qualifications and thus was not supported by the data available at the time. CEQ influenced the final message in EPA’s air quality statements. Competing considerations, such as national security concerns and the desire to reopen Wall Street, also played a role in EPA’s air quality statements. The “safety” of the air in Lower Manhattan after the collapse of the WTC towers is still being debated and studied. However, given the current lack of health-based benchmarks, the lack of research data on synergistic effects, and the lack of reliable information on the extent of the public’s exposure to these pollutants, the answer to whether the outdoor air around WTC was “safe” to breathe may not be settled for years to come.
Recommendation
We recommend that the EPA Administrator:
2-1. Develop procedures for emergency risk communication to ensure that EPA’s public pronouncements regarding health risks and environmental quality are adequately supported with available data and analysis.
Additional recommendations regarding contingency planning, risk characterization and assessment, and risk communication are presented in Chapter 7.
Agency Comments and OIG Evaluation
In her August 8, 2003 response to our draft report, the EPA Acting Administrator stated that the report placed too much emphasis on EPA’s press releases and did not sufficiently acknowledge EPA’s many other communications. She further noted that EPA’s early statement that the air was safe to breathe was made in direct response to the public’s concern about asbestos contamination following the WTC collapse, and that the press release detailed the monitoring that led to the statement and made it clear that further monitoring would take place. The Acting Administrator also pointed out that EPA never withheld data from the public and made its extensive monitoring data available on its interactive web site. With respect to CEQ’s involvement in the preparation of EPA’s press releases, the Acting Administrator stated that the Agency coordinated with CEQ and that this coordination was neither unusual nor unexpected during a catastrophic disaster on the scale of the WTC attacks. Further, she noted that EPA acknowledges that mistakes were made and things could have been done better, and that there are lessons to be learned in the difficult area of risk communication. Improving risk communications is an Agency priority as it implements its “lessons learned.”
In our opinion, Agency press releases are a very important form of communication. As detailed in our draft report, EPA press releases result from a deliberative process that should reflect the Agency’s official position on significant issues. Press releases are made available to essentially all news media and may be quoted or paraphrased in radio, television, and other forms of communication. In our opinion, the Agency could have provided more complete and useful information in the press releases. Further, we reviewed other agency forms of communication including all communication-related documents provided by the Agency. These documents included videotaped interviews, newspaper articles, briefing notes, and other forms of communication. With respect to the Agency’s early statement about the air quality, we fully recognize the extraordinary circumstances that existed at the time the statement was made about the air being safe to breathe. It continues to be our opinion that there was insufficient information to support the statement.
The Agency’s complete written response to our draft report and our detailed evaluation of that response are contained in Appendices Q and R, respectively.
NOTES
2 www.epa.gov/oig
3 EPA’s Office of Communication, Education and Media Relations (OCEMR) issued the press releases. The OCEMR Associate Administrator left the Agency in December 2001 and OCEMR was renamed the Office of Public Affairs in July 2002.
4 In this context, professional cleaning refers to the use of a certified asbestos cleaner trained in the proper use of personal protective equipment and procedures to prevent re-contamination.
5 “Cough and Bronchial Responsiveness in Firefighters at the World Trade Center Site,” David J. Prezant et al, New England Journal of Medicine, Vol. 347, No. 11, September 12, 2002.
6 “Prospective Study of Pregnant Women and Infants Exposed in Utero to WTC Air Pollution,” Columbia University; and “Study of Pregnant Women and Children Near WTC,” Mt. Sinai School of Medicine.
source: http://www.epa.gov/oigearth/ereading_room/WTC_report_20030821.pdf (3.39MB) 23aug03
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