NYCity Council Hearing
on Post-9/11 Remediation
of WTC Contamination (revised)
Marjorie J. Clarke, Ph.D, QEP,
CUNY faculty, mclarke@hunter.cuny.edu
I
am Marjorie J. Clarke, Ph.D., Scientist-in-Residence and adjunct assistant
professor in the City University of New York system. I was co-author of a National Academy of
Sciences report on the Health Effects of Waste Incineration and teach a course
on urban environmental health management.
I have written extensively on incineration emissions and their
control:
www.maggieclarkeenvironmental.com
Background
In
addition to being a tragedy of global proportions, as an environmental
disaster, the collapse of the three
Recommendations
The Precautionary
Principle
needs to be applied to disaster response decision-making. The aim should not be either to reassure the
public at all costs or to rush people back into their homes and businesses for
the sake of the stock exchange or similar.
The evacuation zone should extend to where there is no evidence of
environmental impact (e.g., no air pollution odors, no dusts, no immediate
health impacts – e.g. coughing, nosebleeds, etc). For example, the NYC DOH asked citizens who
were forced back into a hazardous situation (their homes and offices) and told
to remediate toxic waste with wet rags.
This actually Caused additional exposure to
hazardous air pollutants of thousands of people, and exposes the City to
lawsuits. And though the Fire Department
was heroic in their rescue attempts, they were ill-equipped, not trained, or
even asked to try to totally extinguish the fires which caused a huge on-going
source of hazardous air pollutants. The
City Council needs to address these problems once and for all, and to codify,
in law, requirements to assure that adequate precautions are taken so that
protection of public health and safety is paramount priority above everything
else in disaster response. This includes
prevention of additional exposures to air and water pollutants. This priority should continue until
sufficient data have been collected and analyzed to make certain that no danger
exists.
Evacuation Drills involving residents and
workers, as well as emergency response personnel. The City may be conducting drills, but if the
average person has no idea of what to do in a disaster, or confidence that
anything has been planned, what’s going to happen? We never practice evacuating part of the city
much less individual buildings or subway stations. In two years of working at WTC 1 – 83rd
floor, we had only one drill, consisting of walking
down to the 77th floor. This
accomplishes nothing. Actual large- and
small-scale evacuation drills need to be practiced. The City Council should provide funds for
such planning and drills.
Resolution: To
recommend that the National Academy of Sciences conduct a risk assessment of
the public health impacts due to the air pollution caused by the 9/11 attacks.
Sharing health
information with the public. The City Council needs to enact laws to ensure that
sharing of correct health info with public (air quality data, air quality
alerts, emergency and evacuation info) occurs
immediately after the start of any environmental emergency. Such an emergency could be a spill,
explosion, collapse, or terrorist incident.
The information should be included on public websites and via the media.
Sharing
health information with physicians and hospitals. To
ensure that guidance is disseminated to all physicians and hospitals in the
area to look for and properly treat those exposed to WTC air. According to Mt Sinai 2/4/02 memo to help
physicians determine whether pulmonary symptoms are related to WTC, some
symptoms from exposure can begin as late as 3 weeks after exposure or cessation
of exposure. If physicians had to be
given guidance on these issues, many of those exposed are likely not to realize
their symptoms are WTC-related. Why
didn't the City, State or Federal government issue
this memo in September? Efforts are not
being made to locate all those who were exposed and to characterize their
exposures and register their symptoms over time.
Use of similar laws. The City Council should
enact a law to require that any existing laws and regulations to prevent and
control emissions from hazardous waste incinerators, ash management facilities,
and other sources of pollution be applied to environmental disasters. For example, WTC ash and debris were not
transported in sealed trucks or moved to barge in sealed facilities, even
though this is required for less toxic incinerator ash.
CUNY Research facility. The City Council should
fund the City University of New York to create a new research center on
Governor’s
Standards Needed for
Different types of exposure
Various governmental agencies have applied occupational
safety exposure levels for specific pollutants to those exposed to WTC
air. But there are several distinct
groups of those exposed, and each group has had distinctly different exposures:
·
Those working on the pile (Variables: the level
of emissions have decreased over time as the fires decreased in extent, degree
of protective respirator/masks used, amount of time spent)
·
Those who were caught in the initial horrendous
dust cloud, covered in dust, running away, breathing intense quantities of dust
deeply into the lungs and ingesting dust particles.
·
Those living in the area (Variables: level of
emissions varies depending on specific location, on weather, and length of time
since 9/11; degree of protective respirator/masks used)
·
Those who cleaned apartments (level of exposure
varying with amount of dust in apartment, method of cleaning, degree of
protective respirator/masks used, amount of time spent in cleaning)
·
Those working in the area - 8 hours a day five
days a week; (Variables: degree of protective respirator/masks used)
·
Those at risk:
Children, Elderly, Compromised Immune systems, those with pulmonary
problems are more likely to suffer more adverse affects than others for all the
above categories.
·
Handlers of disposed debris: shipments to
Most of these groups of exposed cannot be compared with
occupational exposure. Studies of
occupational exposure assume 5 days a week, 8 hours a day exposure to adults
(healthy males?) What about those who
live there, those at risk, those caught in the initial cloud? This requires considerable investigation, and
many new standards need to be created to address these different categories of
exposure.
Research into and
adoption of more protective building codes
(less toxic materials, evacuable buildings,
better fire drill and practice evacuations, better, more well-thought out
announcement systems during emergencies.
It is arguable that many people died in stairwells too small to evacuate
everyone, especially since their capacity was reduced by half due to
firefighters climbing them at the same time.
It is arguable that some died when they heard Port Authority
announcements to go back to their offices.
Could the buildings be built with fewer toxics?
Getting to the Truth
EPA has set the
scientific method on its head by letting policy (as handed down from the White
House) determine conclusions that have enormous implications for New Yorkers’
public health and safety, rather than the data.
EPA’s current propensity to practice junk science has been demonstrated
more than once in the WTC issue. Not
only did EPA conclude that the air was safe before gathering data, they issued
belated reports to the public and media highlighting conclusions several months
prior to beginning a scientific peer review on it (this is reverse of
scientific practice), and they began a faux cleanup program months prior to
having a peer review of the Contaminants of Potential Concern document on which
the cleanup was based. The peer
reviewers have not heartily endorsed everything that EPA had done in its
reports. EPA’s procedures are
backwards. They are a feeble attempt to
cover up poor decision-making methods.
The City Council should be aware of this and not assume that conclusions
announced by EPA under the current administration are based on sound
science. The following are links to my Comments on the EPA/NCEA document: “Exposure and Human Health Evaluation of
Airborne Pollution from the World Trade Center Disaster” http://www.geography.hunter.cuny.edu/~mclarke/EPANCEAcomments-ClarkeRossolSingh.htm,
and http://www.geography.hunter.cuny.edu/~mclarke/FurtherCommentsOnNCEAdocument.htm
Further,
since I and others have heard EPA’s On Scene Coordinators (OSC’s)
say that City officials obfuscated EPA’s initial attempts to assist in
environmental assessments, etc., it is imperative that the City Council
subpoena all the EPA OSC’s to determine exactly what
they were told and by whom. It is
important because if we don’t understand the failures of the last emergency, we
will suffer the same failures for the next one.
Precedents and
Perspective
It was asked, what could be done better in the event of a
disaster, and why? First, it’s important
to look in perspective at the measures the
Conclusion
If the City Council can accomplish, via resolution,
legislation, and appropriation the few recommendations given above, the
citizens of