Running head: 9/11 LESSONS LEARNED

The Terrorist Attack on the World Trade Center 9/11/2001: Lessons Learned Gary Couture Columbia Southern University MOS 6301-08C-2 7/19/11 Professor Meng-da Hsieh

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Case Study 2: The Terrorist Attack on the World Trade Center 9/11/2001: Lessons Learned

Introduction
The intent of this paper is to address the following questions in regard to the events and conditions resulting from the terrorist attacks on the twin towers of the World Trade Center: 1. Recommended industrial hygiene role as member of a Recovery Response Team. 2. Major potential health hazards present at the 9/11 site 3. Occupational Medical Surveillance of Recovery Workers. 4. Industrial Hygiene Sampling Plan to characterize exposure levels. Address both specific direct reading instruments and air sampling requiring laboratory analysis. 5. Personal protective equipment requirements with established action levels for upgrade of protection or evacuation. 6. Work practice and administrative controls. It is the authors intent to address these questions as lessons learned in hindsight, with the data currently available, rather than simulating a scenario of being present during the actual event.

Recommended IH role as a member of a Recovery Response Team

An industrial hygienist assigned as a member of a Recovery Response Team would be tasked with monitoring the environment in which the team is laboring to determine the level of hazardous substances to which the team may be exposed to. This would include primarily airborne hazards, but also blood borne, waterborne hazards from human remains and other sources, and sedimentary dust and particulates on the surfaces of the physical structures, walking /working area and rubble piles. He or she would also need to be observant of the other team members and monitor for visual or audible signs of exposure to any contaminant that presents

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symptoms of exposure, as well as conditions such as heat stress, dehydration, exhaustion and even psychological stress. The IH could also serve as a competent person to monitor for proper PPE usage among team members, but this would be reliant upon the other members of the team acknowledging and respecting the authority on the IH, and their compliance with his or her directions. During a conference sponsored by NIOSH in December 2001, veteran participants of the 9/11 WTC recovery efforts noted, the lack of a clear command structure at the World Trade Center thwarted efforts to enforce PPE use and risk-reduction behaviors (Jackson, et al, 2002, p. 45). As to the qualifications of the assigned IH, at a minimum, certification as a CIH (certified industrial hygienist) would be required. Bruce Lippy was the head of a team of health and safety specialists sent from the International Union of Operating Engineers [IUOE] to monitor the exposure of the heavy equipment operators tasked with removing the rubble of the collapsed buildings. Mr. Lippy has earned both the CIH and the CSP (certified safety professional) certifications and appeared eminently qualified to perform his duties ().

Major potential hazards present at the 9/11 site

The scope and scale of the hazards present at the site of the terrorist attack on the twin towers of the World Trade Center was unprecedented in terms of mass quantities, varieties, and complexities. Many of the hazardous compounds had never been encountered or anticipated in such large volumes, and for some there were no established limits of safe exposure. One hazardous substance of prime concern to the Environmental Protection Agency [EPA] was asbestos. Estimates of the amounts of asbestos used as spray-on fire proofing in the early stages of the WTC construction range from 400 to 2000 tons (Newman, 2007 and Lyman, 2003). The incredible force of the collapsing towers pulverized the asbestos, concrete, glass and other building materials to the point of powder and fine dust which became airborne in huge clouds of dust until it gradually settled on the ground and other horizontal surfaces both outdoors as well as

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inside office spaces and residences throughout lower Manhattan(). One of the problems with monitoring for asbestos exposure at the site was the difference in standards between OSHA and EPA. According to Lippy (2002), the OSHA standard for asbestos exposure is not applicable to ambient outdoor air quality. He states that OSHAs standard is based upon the limit of resolution for the optical microscopes used in testing samples, which is 5.0 m in length and 0.25 m in width. EPA specifies the use of transmission electron microscopes [TEM], which are capable of observing much finer fibers. Libby reported that 95% of the fibers observed using TEM on eleven samples taken inside buildings near the WTC were below OSHAs defined size limits(). There were other hazardous substances known by the EPA to be present in the twin towers prior to the attack and subsequent destruction of the buildings. In accordance with the Emergency Planning and Community Right to Know Act, the United States Customs Service reported to be housing in their offices, located in 6 World Trade Center: barium, lead, chloroform, chlordane, carbon tetrachloride, cadmium, chromium, mercury, hydrogen sulfide, arsenic and other toxic raw materials. The Port Authority of New York and New Jersey, housed in 1 World Trade Center, submitted a similar list, including: mercury, tetrachloroethylene, PCBs, arsenic, ethane, and other toxic raw materials(). In addition to these materials listed in the databases of the government, the vast quantities of building materials, plus the contents of the thousands of offices housed within the two towers had to be accounted for. An estimated 424,000 tons of concrete, gypsum, sheet rock, fiberglass and glass went into the constructing of the buildings. Reported estimates of the number of personal computers in the building range from 10,000 to 50,000, plus mainframe computers and servers (Newman, 2007 and Lyman, 2003). Each PC contains more than four pounds of lead. This means that anywhere from 40,000 to 200,000 pounds of lead was released into the air when the two buildings collapsed and burned. The Port Authority of New York estimated that there were at least 500,000 fluorescent light

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bulbs in the two buildings. Each fluorescent bulb contains between three to 21 milligrams of mercury, which resulted in the release of between three to 23 pounds of mercury being released into the atmosphere() In a report of test results obtained from samples of settled dust and smoke that were collected on 16 and 17 September, 2001, Lioy, et al, (2002) stated the following: In the inorganic analyses, we identified metals, radionuclides, ionic species, asbestos, and inorganic species. In the organic analyses, we identified polycyclic aromatic hydrocarbons (PAHs), polychlorinated biphenyls, polychlorinated dibenzodioxins, polychlorinated dibenzofurans, pesticides, phthalate esters, brominated diphenyl ethers, and other hydrocarbons. Each sample had a basic pH. Asbestos levels ranged from 0.8% to 3.0% of the mass, the PAHs were > 0.1% of the mass, and lead ranged from 101 to 625 g/g. The content and distribution of material was indicative of a complex mixture of building debris and combustion products in the resulting plume. These three samples were composed primarily of construction materials, soot, paint (leaded and unleaded), and glass fibers (mineral wool and fiberglass). Levels of hydrocarbons indicated unburned or partially burned jet fuel, plastic, cellulose, and other materials that were ignited by the fire. In morphologic analyses we found that a majority of the mass was fibrous and composed of many types of fibers (e.g., mineral wool, fiberglass, asbestos, wood, paper, and cotton) ( 2002, Abstract). Newman (2007) testified that workers and residents returning to the site a full week after the collapse of the WTC were potentially exposed levels of dioxin in the ambient atmosphere nearly six times the highest dioxin concentrations ever recorded in the U.S. (p. 6). Another hazardous airborne contaminant was benzene. OSHAs permissible exposure limit [PEL] for benzene, over an eight hour time-weighted average, is 1,000 parts per billion

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[ppb] and the short term exposure limit [STEL] for a 15 minute exposure is 5,000 ppb. In 57 of 96 air samples taken at or around ground zero, levels of between five to 86,000 ppb were detected. In one sample of the smoke plume taken on November 8, a level of 180,000 ppb was detected, and another taken on January 7, 2002 still showed levels of benzene at 5,300 ppb (). Simply measuring the particulate matter in the atmosphere indicated extremely hazardous levels as compared to OSHAs standards. OSHAs limit for particulates (not including hazardous contaminants such as silica, asbestos or heavy metals) is 10 micrograms per cubic centimeter. Some early readings detected exposure levels as high as 1,600 to 1,800 micrograms per cubic centimeter (). So far, the discussion of this section has been restricted to respiratory hazards present at the site. These hazards were very real and prevalent throughout the site, resulting in a reported 1,000 injuries in the first nine weeks of the recovery efforts (Jackson, et al, 2002). However, there were a great number of other hazardous conditions to which the recovery workers were exposed to. Because of the high amount of particulate matter in the air and settling on all surfaces, eye injuries were common, even with the use of traditional safety glasses, which did not seal and protect the eyes from the fine dust particles. Within the first week, 346 eye injuries of various types were treated by on-site medical personnel. After 10 weeks, the number of treated eye injuries had exceeded a staggering 1,000 cases (Jackson, et al, 2002). The physical hazards of the site took a toll as well. Libby (2002) reports that while there were no fatalities related to the recovery effort, there were 30 reported near-misses that could have resulted in fatalities. He also listed 7,160 visits to the medical tents established on-site or to local emergency rooms, including 342 lacerations and 30 fractures (). The extreme heat of the fires which continued to burn within the rubble pile for months also constituted a hazardous condition, particularly to firefighters in their bulky and heavy turn-out gear. This gear is designed to be worn for short

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durations of less than one hour while putting out typical fires. Instead these firefighters were working for entire work shifts and beyond, and the heat stress was a tremendous tax on their stamina. It was reported that the ground was so hot that it would literally melt the soles of work boots. Workers toiling in the hotter areas clearing debris would go through a pair of boots every day. Fortunately, companies donated new work boots and other PPE as a form of support for the countless workers on-site (Jackson, et al, 2002). Another very real hazard presented to the workers was stress, both of the physiological and psychological varieties. In the panels of trades reported on by Jackson, et al (2002), one panelist stated, Many of these workers had never seen a dead person not in an automobile accident, not even in a funeral home (Vol. 1, p. 16). Over 100 cases of psychological stress were treated during the first nine weeks of recovery efforts, and it was the consensus of the panel members that many, many more cases went unreported and untreated (Jackson, et al, 2002). Another concern was hazards that were distinct possibilities but fortunately were unfounded in this case. Since this was a terrorist attack, there were fears that a dirty bomb or even biological agents had been incorporated into the attack. Richard Borri, a senior scientist with the New York Department of Health [DOH] Radiological Health office was dispatched to the scene. He arrived just as the south tower collapsed. If one of the hijackers had managed to smuggle a suitcase of radioactive materials onto the plane, the resulting contamination could have resulted in hundreds, perhaps even thousands of deaths from radiation poisoning and cancer and made the site uninhabitable for years. Borri used a portable liquid scintillation counter to scan for radioactive contamination, and fortunately found none. Borri was perhaps uniquely qualified for this assignment. The test device he had in his possession was one of only a few like it in the country, and is far more sensitive to a wider array of radioactive sources than its more

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prevalent and older relative, the Geiger counter (). Tests for biological agents, other than those associated with the decaying human remains, were found to be negative as well().

Occupational Medical Surveillance of Recovery Workers

The attack was so unanticipated and unplanned for, that when it happened, it initially caught all but the traditional emergency first responders off-guard and unsure how to proceed. Medical surveillance of those first responders did not occur until much later, often not until symptoms of respiratory problems began presenting themselves. News media reports in late December, 2001 indicated that as many as 500 NYFD members were on medical leave due to respiratory-related ailments. In January, 2002, the Uniformed Firefighters Association reported that an estimated 3,000 of its 9,000 members were suffering from what became known as the World Trade Center cough (Jackson, et al, 2002). Within days, once the rescue efforts ended and the recovery phase began, medical treatment and surveillance efforts began (). In a policy statement made available on the Internet, the American Public Health Association [APHA] stated: Important disaster response lessons can be taken from the experience of the post-9/11 period when thousands of workers and residents, young and old, were unnecessarily exposed to toxic substances after being assured by EPA that the air was safe to breathe. At the same time workers were left unprotected by OSHA when it declined to enforce its respiratory protection standard and other regulations. Research and surveillance activities have found serious health conditions as a result of these exposures (APHA, 2006). It is important that medical surveillance continues for recovery workers of the WTC disaster as well as other natural and man-made disasters such as hurricane Katrina and the BP oil spill in the Gulf. In response to the immense number of individuals exposed to airborne contaminants in the wake of the attack on the WTC, a World Trade Center Health Registry has

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been established. This registry includes survivors of the collapsed towers and other buildings, rescue, recovery and clean-up workers, and the students and staff members of schools in the downtown Manhattan area. There are currently over 71,000 registrants ().

Industrial Hygiene Sampling Plan

As part of New York Citys efforts to monitor and improve the ambient air of the city, air sampling monitors have been installed at various locations throughout the city. Unfortunately, not much useful data could be obtained from these monitors for two main reasons: 1) the monitors were only designed to detect and record a narrow range of common contaminants (), and 2) many of the environmental monitors had become fully clogged because of the tremendously high concentration of high-particulate dust (). Lippy and his team from the IUOE began monitoring the exposure of heavy equipment operators on September 17th. He reported the following: All IUOE air samples were collected inside the cabs of heavy equipment operating inside the restricted area at Ground Zero. Sampling media were positioned to approximate the breathing zone of seated operators but not attached directly to the operators. All asbestos samples were collected for analysis by transmission electron microscopy following the EPAs Asbestos Hazard Emergency Response Act (AHERA) protocol found at 40 CFR 763. Sampling for metals, organic vapors, total dust, silica, and lead was conducted following the National Institute of Occupational Safety and Health (NIOSH0 Manual of Analytical Methods. A broad screen for volatile organics was conducted with evacuated cylinders following EPA TO-15 method. All samples were analyzed by American Industrial Hygiene Association Accredited laboratories. Real-time instruments with

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alarms were installed in cabs to monitor agents like carbon monoxide that could pose immediate life-threatening risks () EPAs Office of Emergency Response began monitoring outdoor air for various volatile organic compounds [VOC] on September 15. By September 21, EPA had expanded its monitoring activities to include VOCs typically found in building fires, as well as for Freon. Other agencies and organizations began sampling both the air and settled dust in the perimeter areas, including Johns Hopkins and New York Universitys Institute of Environmental Medicine. OSHA and New York Citys Department of Health began monitoring recovery worker exposure (). One reported problem was the lack of an adequate quantity of reliable, portable quasicontinuous samplers to monitor VOCs. Lioy and Gochfeld (n.d.) attributed this, in part, to the lack of available electricity needed to power the devices. They also stated that the current generation of environmental sampling devices could not handle the high mass concentrations of particulate matter in the air during the early days of the response and recovery period. Their recommendations for a new generation of air sampling devices included: 1) the device must be battery powered since a reliable source of electrical power is unlikely in large-scale disasters, 2) the device must be designed to collect, identify, and quantify a wide range of possible contaminants, especially those not normally monitored by existing agencies for compliance purposes. (They made specific mention of particulates like glass fibers and gaseous organics such as benzene.) 3) The device must be lightweight and easy to handle, enabling the user to rapidly change locations due to changing conditions. 4) The device should provide real-time measurements of an expanded list of substances, above that currently available. Lioy and Gochfeld (n.d.) also recommended the development of new strategies for the rapid collection and testing of re-suspendable dust samples caused by events like the WTC attack. They recounted that at the WTC, initial samples collected by EPA and others were tested

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only for asbestos. It was not until later that tests revealed the presence of many more hazardous agents in the dust, including glass fibers, highly alkaline concrete dust, silica, lead, mercury and other heavy metals (Newman, 2007, and Lioy & Gochfeld, n.d.). These collected samples should be tested following the protocols outlined by Lippy (2002) above.

Personal Protective Equipment Requirements

The firefighters of NYFD of course responded to the initial emergency outfitted in full turn-out gear typical of todays fire departments. While this specifically designed PPE suited the immediate need of fighting fires, it is by no means meant for long-term wear. The helmet is heavy, and after continuous use caused head and neck aches. The wide brim to the rear is designed to prevent water from running down the back of the neck, but became an obstruction and hindrance in moving around in tight, confined spaces of the rubble pile. The face shield protects against the heat of fires and flying debris, but provided no protection to the eyes from the high-particulate dust in the air. The turn-out coat and pants which protect the wearer from the heat and flames of a fire is bulky, uncomfortable for long-term wear, and is difficult to maneuver in. The material of the coat and pants is made of layers, with the outer layer somewhat impervious to water, and the inner layer thermally insulating to ward off heat. Unfortunately, once the inner layer gets wet, either from sweat or the continuous barrage of firefighting water, it compacts and loses its insulating properties and makes the garment heavier. In fact, due to the extreme radiant heat generated by the fires in the rubble, intensified by jet fuel, once the inner layer became wet, firefighters began experiencing steam burns. Likewise, the boots of the ensemble are meant for short-term wear, and many firefighters experienced blisters on their feet after wearing them for more than an hour or two (Jackson, et al, 2002).

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Urban Search and Rescue [SAR] team members who reported to the scene mostly wore battle dress uniforms [BDU] like military fatigues. These uniforms had the benefit of being lighter weight and more flexible, but did not provide any thermal protection and were more easily torn. One panelist on the NIOSH conference noted that two of his co-workers received minor cuts through their BDUs and did not get them properly treated. Both developed serious infections that required hospitalization (Jackson, et al, 2002). Biohazard garments, such as Tyvek coveralls also presented problems under the intense conditions of WTC. The suits tended to tear, particularly in the area of the joints. There is also a shelf-life issue; once a package is opened, the suit service life is only 60 90 days. Many users reported a significantly better leak-resistance in suits with heat-sealed seams vs. sewn seams (Jackson, et al, 2002). Problems with the soles of the work boots melting was already mentioned above in the discussion of heat as a hazardous exposure. Additional problems were noted with boots with steel shanks in the arch and toes; mostly blistering from long-term wear. It was also noted that firefighter boots tended to leak through the seams when worn in hot water (Jackson, et al, 2002). The firefighters structural gloves reportedly worked well until they got soaked; then they tended to harden, making manual dexterity even more challenging. Construction trade leather or Kevlar reinforced gloves provided good hand protection from abrasion and puncture, but provided no protection from biological or chemical hazards. Leather gloves actually absorbed and retained the water-soluble contaminants. Biohazard protective glove liners worn inside the construction-grade gloves was a viable solution, but reportedly was seldom used (Jackson, et al, 2002).

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As was also mentioned above, safety glasses were plentiful and provide good protection from trauma from flying debris or liquid splashes, but did not provide adequate protection from eye irritation due to particulate matter in the air. Safety goggles were also available, and provided much better dust protection than the glasses, but many, particularly law enforcement personnel, reported that they were uncomfortable, interfered with peripheral vision, and had a tendency to fog up, even the anti-fog variety issued by the U.S. Government Services Administration. They also tended to not fit well when worn in conjunction with half-face respirators. Scratched lenses also became a prevalent problem due to inadequate facilities to properly clean them (Jackson, et al, 2002). Hearing protection, in the form of disposable ear plugs, was plentiful on site. Workers, particularly those of the construction trade, tended to be familiar with the ear plugs and used them when needed. One reported problem was the challenge of determining the proper level of hearing protection needed (Jackson, et al, 2002). Head protection seemed to be universally appropriate, with the typical construction-type hard hat worn by all but the firefighters (Jackson, et al, 2002). Respiratory protection was, of course, the biggest concern, and the most problematic. The firefighters predominantly used the self-contained breathing apparatus [SCBA] which, like the rest of their turn-out ensemble, is designed for short-term use. Most of the air bottles used contain approximately 30 minutes of air. Maintaining a sufficient quantity of charged spare bottles became problematic as the fires raged on for days and even months. In situations where fire-related gasses were not present, many firefighters opted for air purifying respirators [APR] or even the paper disposable-type respirators. It was suggested that powered air-purifying respirators [PAPR] would have provided better protection and prevented the face piece from

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fogging up, but the higher cost made them cost-prohibitive, particularly in mass quantities (Jackson, et al, 2002). The problems apparently did not stem from a lack of respirators. The IUOE team lead by Bruce Lippy reportedly issued 11,000 respirators (). OSHA distributed a staggering 130,000 and EPA gave out 22,000(). The main problem with the respirators was the indiscriminant way they were handed out. Fit-testing and training was non-existent. According to Lippy (2002) the first respirators were given out on September 19. Fit tests werent required until nearly a month later, October 17, and the first formal training wasnt given until November 29. Cartridges and respirator bodies often were not compatible because they were made by different manufacturers(). Many of the recovery workers were resistant, and some outright refused, to wear the respirators. Their reasons were varied, but included the fact that they were uncomfortable, made breathing more labored, and made communication nearly impossible (Lyman, 2003, Lippy, 2002 and Jackson, et al, 2002). Had OSHA been performing their normal enforcement role, the standards for medical evaluation, fit testing, and training would have been mandated and enforced upon every worker. However, OSHA was serving only in a consulting capacity because the New York fire department, and then later the Department of Design and Construction was over-all in command of the site, and this left OSHA without jurisdiction (Lyman, 2003 and Newman, 2007). Lippy (2002) made the following recommendation regarding appropriate respiratory protection, based on IUOE sampling and testing, half-face respirators with cartridges protective against fine particles, organic vapors, and acid gas (P-100/OV/AG) were adequately protective if conscientiously worn. (emphasis in original). Kelly McKinney, of the NYDOH, concurred with Lippys assessment, stating, Everyone who works on the pile needs to wear P100 dual-cartridge half-face respirators with combined Organic Vapor/ Acid Gas (OV/AG) filter cartridges.().

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Action levels for upgrade of protection levels would be based upon sampling results, and would probably be task-specific, as experience at the WTC. Lippy (2002) reported that selection of respirator type and cartridges did not change after the first week and the only reported overexposures dealt with specific tasks such as silica exposure while drilling into a concrete wall. It must be noted, however, that Lippys sampling, as stated above, was predominantly restricted to heavy equipment operators working inside enclosed cabs.

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Work Practice and Administrative Controls

The terrorist attack on the World Trade Center twin towers on September 11, 2001 was as unique and unprecedented as it was horrible. Never before had a disaster of this type and magnitude been experienced in this or any other country. While it is true that natural disasters and acts of war had wreaked greater havoc throughout the world, this despicable act brought about conditions that no one had ever before conceived, much less prepared for. Along with the shock, horror, sorrow, and rage, came confusion, uncertainty, and a hesitancy among certain governmental agencies as to how to proceed and who should act. There were many conflicting priorities, needs, and courses of action demanding attention, each with its own set of responders, all of whom truly believed that their role was the most critical and took precedent over any other consideration. Because this was a multi-building fire and rescue operation, the New York Fire Department [NYFD] naturally was first on the scene, with firefighters and emergency medical technicians responding and charging into the burning building as employees were scrambling to evacuate. Because of the intense heat generated by 180,000 gallons of aviation fuel consuming everything combustible trapped in the immense pile of rubble, NYFD, augmented by firefighters from all over the country, continued to battle the blaze for months(). The fires were finally reported to be fully extinguished on December 19, 2001 (Jackson, et al, 2002). It soon became obvious that this was an act of terrorism, making the sixteen acre site a very large crime scene, with multiple law enforcement agencies proclaiming jurisdiction and trying to establish and maintain control of the scene to preserve evidence (Jackson, et al, 2002).

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New York state is known as a home-rule state, meaning that the state retains responsibility for responding to disasters within its borders, and in fact, pushes that responsibility to the lowest level of governmental authority, in this case the city of New York and its agencies(). Mayor Rudi Giuliani initially assumed control responsibility for the disaster, appealing to the state government for additional support once the scale and scope of the emergency became evident. Governor George Pataki quickly declared a state of emergency and provided the requested support, with Mayor Giuliani retaining over-all control. President Bush then declared the site a federal disaster area, activating the Federal Emergency Management Administration [FEMA]. The Federal Response Plan [FRP], which is the governing document under which FEMA operates, designates FEMA as the lead agency for consequence management, with another 28 federal agencies as well as the American Red Cross in various support roles (). Presidential Decision Directive [PDD] #62 specifically names the Environmental Protection Agency [EPA] as the lead agency for responding to the release of hazardous materials resulting from a terrorist act on US soil(). The National Contingency Plan [NCP], the National Response Plan [NRP] Emergency Support Function #10, and the Oil and Hazardous Materials Response Annex all give exclusive jurisdiction to the EPA as both the primary agency and emergency support function coordinator for any actual or potential uncontrolled release of hazardous materials (). The end result of all these conflicting directives, policies, charters and agency functions was a great deal of confusion as to who was in control. It eventually became apparent that the answer was that no one was truly in over-all control.

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Of all the lessons learned by studying the disaster recovery efforts at the WTC, the area of work practice and administrative controls was perhaps the greatest model of what not to do. Command and control of the overall recovery effort was virtually non-existent as various city, state and federal agencies vied for control. Lyman states, At its peak, there were some 30 different city, state and federal government agencies involved, more focused at the time on evidence collection than environmental health, but still calling for unprecedented coordination. (p. 58). Lyman also quotes an EPA lessons learned report published after the WTC recovery efforts were finished, which stated, Many federal, state and local entities, however, failed to sufficiently recognize and understand EPAs role, mission and capability as part of an emergency response with environmental and human health consequences (p. 34). As was stated above, OSHA was present only in a consultation mode and took no active role in enforcement or administrative control of workers. This left much of the work practice and administrative controls up to the individual organizations and agencies to police their own, much like Lippy did for the equipment operators represented by the IUOE. In his report, he wrote, People calling the shots at the top were simply not focused on safety (Lippy, as quoted by Lyman, 2003, p. 52) Lyman (2003, p. 59) further wrote, The biggest criticism was that the environmental health effort lacked coordination. Among the problems Mt. Sinais Landrigan identified: A disorganized approach to worker health and safety. This, he feels, came about because of unclear lines of authority. Another problem that cropped up was a lack of health-based standards for certain chemicals that made their way into the air and water. These problems, Landrigan warned, must be addressed, and the necessary improvements to the system must be made, if mistakes are not to be repeated in future disasters.

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Lyman (2003, p.66) also quotes Anthony Sutton, from the Westchester County health agency, who said, At Ground Zero, they discounted the environmental hazards, even though this was no ordinary building collapse. As the operation wore on, and time was no longer a factor, people could have stepped back and made it a priority. Before they sent in workers for a protracted amount of time, they should have very early on established baseline pulmonary function tests on workers to detect any obstructions to their lungs. Jackson, et al (2002), in reporting on statements made by participants of the lessons learned conference hosted by NIOSH, wrote, A continuing refrain throughout the conference was the need to rapidly establish a single controlling authority or unified commandHealth and safety officials, as well as specialoperations personnel, lamented the lack of a unified authority and command structure at the World Trade Center site The absence of an overall authority had important implications for responder health and safetyHealth and safety officials said that the lack of a clear command structure at the World Trade Center thwarted efforts to enforce PPE use and risk-reduction behaviorsPanelists reported that the PPE standards and procedures they were supposed to follow varied widely. Some organizations had no standards or procedures at all (Vol. 1, p.45). Because of this lack of centralized command and control, it is difficult to ascertain what work practices or administrative controls were actually put into place or enforced during the recovery efforts at WTC. It is very likely that many workers, volunteers and responders were unnecessarily exposed to excessive amounts of airborne contaminants, as well as physical and psychological stress due to poor work practices and little or no administrative controls to provide

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orderly rotating shifts with time off to physically and emotionally recuperate. Without strict enforcement of respiratory protection standards, workers were left on their own to do what they felt appropriate, often at their own peril. As a result, thousands of recovery workers are now experiencing reduced lung capacity and a diminished quality of life.

References American Public Health Association. (2006). Response to disasters: Protection of rescue and recovery workers, volunteers, and residents responding to disasters . Retrieved March 25, 2011, from APHA: Policy Statement Database: http://www.apha.org/advocacy/policy/policysearch/default.htm?id=1333 Jackson, B., Peterson, D. B., LaTourrette, T., Brahmakulam, I., Houser, A., & Sallenger, J. (2002). Protecting emergency responders: Lessons learned from terrorist attacks. Santa Monica: RAND. Lioy, P. P., & Gochfeld, M. M. (n.d.). Lessons learned on environmental, occupational, and residential exposures from the attack on the WTC. Retrieved March 23, 2011, from Rutgers.edu: http://eohsi.rutgers.edu/wtc/Lessons%20Learned%20Manuscript.pdf Lioy, P P., Weisel, C. P., Millette, J. R., Eisenreich, S., Vallero, D., Offenburg, J., et al. (2002). Characterization of dust/smoke aerosol that settled east of the world trade center (WTC) in lower Manhattan after the collapse of the WTC 11 September 2001. Retrieved March 23, 2011, from Environmental Health Perspectives: http://ehp03.niehs.nih.gov/article/fetchArticle.action? articleURI=info:doi/10.1289/ehp.02110703

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Lippy, B. E. (2002). Safety and health of heavy equipment operators at ground zero. American Journal of Industrial Medicine , 539-542. Lyman, F. (2003). Messages in the dust. Denver: National Environmental Health Association. Newman, D. M. (2007). EPA's response to 9/11 and lessons learned for future emergency preparedness. New York: New York Committee for Occupational Safety and Health. Samet, J. M., Geyh, A. P., & Utell, M. M. (2007). The legacy of the World Trade Center dust. The New England Journal of Medicine , 2233-2236.