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 Report No. 2003-P-00012 ii
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,
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.
Full report: http://www.epa.gov/oigearth/ereading_room/WTC_report_20030821.pdf