The American Public Health Association,
Whereas the destruction of the World Trade Center (WTC) and Pentagon on 9/11/2001 has caused APHA to re-examine and extend prior policy relating to the public health management of disasters to include incidents involving intentional use of explosives and other chemical, biological, or nuclear terrorist events.
Whereas the clean-up workers and first-responders to the events of September 11, 2001, suffered acute and chronic health problems as well as injuries including over 9000 injuries and illnesses have been reported onsite in the first 4 months of emergency response and subsequent demolition and clean-up activities in New York City. Over one quarter of the 6,500 firefighters who worked at ground zero after the terrorist attack on the World Trade Center reported respiratory ailments, including many with a condition called “WTC cough,” a condition identified in people who have developed a persistent cough and other respiratory symptoms related to working at or near the WTC site, and several hundred are exhibiting serious symptoms that may allow them to retire on a disability pension. Asbestos was a significant hazard to the workers involved in cleanup of the WTC site as it was used as fireproofing in construction of the north tower up to about the 40th floor, and elevator shafts.
Whereas prior APHA policy statements have emphasized the importance of effective enforcement of the Occupational Safety and Health Act of 1970 and the importance of union involvement in health and safety5 as well as the prevention of job-related stress.
Whereas prior APHA policy statements have called for the Environmental Protection Agency to reduce the impact of hazardous air pollutants on communities;
Whereas the Federal Emergency Management Agency (FEMA), the Federal Response Plan (FRP) establishes a process and structure for the systematic, coordinated, and effective delivery of Federal assistance to address the consequences of any major disaster or emergency declared under the Robert T. Stafford Disaster Relief and Emergency Assistance Act, as amended. This plan provides that the role of the Occupational Safety and Health Administration (OSHA) is limited to that of providing technical assistance and consultation to the incident command structure during the usually brief time period while search and rescue is being conducted.
Whereas the WTC disaster site cleanup was conducted as a search and rescue operation using the approach of progressively upgrading worker protection after the fact of documented exposures. Although OSHA noted over 40 violations of health and safety laws daily during the cleanup phase of the disaster, inspectors were never allowed to enforce OSHA regulations at the site since the activities continued to be categorized as “search and rescue” for months after the last living survivor was found (less than 24 hours after the event). This is despite the fact that nothing in the Federal OSHA Act provides for suspension of the enforcement provisions of the law for prolonged periods of time for sites such as the WTC site that have become effectively a large demolition and construction site.
Whereas the OSHA Hazardous Waste Operations and Emergency Response Standard is a proactive standard intended to insure safer worksites based on knowledge of the nature of activities to be conducted, an inventory of hazardous materials known to be present at the site, providing for comprehensive training of workers, medical surveillance, exposure monitoring and worker protection levels that are adjusted based on site monitoring data.
Whereas search and rescue as well as cleanup workers were on site for shifts as long as 20 hours per day, six or seven days per week in the initial phases of the operation, resulting in prolonged exposure to physically and emotionally stressful and hazardous working conditions;
Whereas the various types and trades of construction workers will be better protected in their particular work on cleanup of disaster sites in the future if other trades are cross-trained and jointly trained. For example laborers may be attaching cables to wreckage from a crane operated by an operating engineer.
Whereas immigrant day laborers performed thousands of hours of work removing debris and dust from lower Manhattan offices and apartments since the September 11, 2001 attacks, many without adequate training or protective equipment, and most without health insurance coverage.
Whereas the fire and collapse of the WTC buildings resulted in the release of fine particulate matter (PM), asbestos fibers, lead and silica-containing dusts as well as various gaseous products of combustion of products containing, among other compounds, polyvinyl chloride from furnishings that are known to aggravate symptoms among those workers and community residents with underlying health conditions such as asthma or other pulmonary diseases;
Recognizing that these events point to the need for much greater attention to worker health and safety and community environmental health in situations of attacks involving explosives, fires or the use of chemical, radiological or biological weapons.
Therefore, be it resolved that APHA recommends that:
- Federal legislation be aimed at improved public health response to acts of mass destruction, especially in the case of bio/chemical hazards, and such legislation should provide for Occupational health surveillance and worker training. These efforts should be adequately supported, funded and directed by public health agencies.
- FEMA revise the regulations in the Federal code such that OSHA would, within 24 hours of the onset of the operations phase of a disaster response, be responsible for effective enforcement of the relevant health and safety standards, not limited simply to technical assistance and consultation to the Disaster Safety Officer as provided under the current plan. Thus, for example, once a disaster site is secured following the immediate rescue phase of operations, the provisions of the OSHA Hazardous Waste Operations and Emergency Response Standard would be enforced for all subsequent demolition and cleanup activities.
- The State and Local Health Departments, Environmental Protection Agency (EPA), National Institute for Environmental Health Sciences (NIEHS), Centers for Disease Control (CDC) and Agency for Toxic Substances and Disease Registries (ATSDR) collaborate on implementing an environmental health tracking system for those already affected and potentially affected by the World Trade Center attack.
- The EPA and the Department of Housing and Urban Development (HUD) develop protocols and funding for training, personal protective equipment, and medical monitoring of day laborers and other workers cleaning up the neighborhood buildings in lower Manhattan.
- The Department of Labor develop regulations to reduce the number of hours worked by cleanup workers to a maximum of one 8 hour shift per day to minimize risk of prolonged exposure to chemical, ergonomic and safety hazards, as well as stressful working conditions common in disaster situations. Additional trained workers and a mutual aid system should be developed to insure that sufficient numbers of trained operating engineers, laborers, carpenters and iron workers, as well as other key construction trades and health and safety personnel are able to be mobilized to support the cleanup activity.
- The appropriate Federal Agencies provide resources for health care and hospital worker training to support health care needs for cleanup workers and develop guidelines for health practitioners to improve the timely recognition and appropriate referral and treatment of patients from communities that have been affected by such incidents.
- NIEHS provide protocols for cross training of potential clean-up workers across the US in advance of any future similar disaster.
- FEMA develop and fund integrated training for Urban Search and Rescue Teams with training for clean-up workers for potential disaster response. So far the training has been limited to teams in state and local governments. It is clear from the events of 9/11 that a much larger audience of emergency response and hazardous materials workers needs occupational health and safety training specific to this area.
- Specific training for cleanup workers to better enable them to respond specifically to events involving bio/chemical weapons of mass destruction should be provided on a regional basis to provide a cadre of workers available in case of an emergency at various places throughout the country.
- Appropriate Federal Agencies, academic and professional associations provide training and resources to deal with the psychological and mental health risks and consequences of terrorism and other disasters.
- Medical surveillance systems be modified to account for all workers involved in emergency repsonse and cleanup.
- Worker health and safety considerations should be addressed in all federal, state, and local emergency response plans.
References
- Elisberg D, Moran J. Response to the World Trade Center disaster: Initial Worker Education and Training Program (WETP) Grantee Response and Preliminary Assessment of Training Needs. National Clearinghouse for Worker Safety and Health Training, 1301 Connecticut Ave., NW, Suite 310, Washington, DC 20036, http://www.wetp.org/
- Landesman LY. Epilogue. In: APHA, Public Health Management of Disasters: The Practical Guide. APHA 2001.
- New York City Department of Health Responds to the World Trade Center Disaster Environmental Health Questions Following The World Trade Center Disaster http://www.nyc.gov/html/doh/html/alerts/wtc12.html
- Kelly T. At Least a Quarter of Ground Zero Firefighters Ill. New York Times, Dec. 21, 2001 (http://www.nytimes.com/2001/12/21/nyregion/21FIRE.html)
- Reitze WB, Nicholson WJ, Holaday DA, Selikoff IJ. Application of sprayed inorganic fiber containing asbestos: occupational health hazards. Am Ind Hyg Assoc J 1972;33:178-191.
- APHA Position Paper 7523(PP): Regulation of Occupational Health and Safety Standards.
- APHA Policy Statement 8509: Occupational Disease Prevention: Increase Worker and Union Rights
- APHA Policy Statement 200018: Public Health Impacts of Job Stress.
- APHA Policy Statement 8511: Hazardous Air Pollutants.
- http://www.fema.gov/r-n-r/frp/frpintro.htm
- 42 U.S.C. 5121, et seq.
- The “Hazwoper” Standard, 29 CFR 1910.120
- WTC day laborers to get toxin tests. Associated Press, January 11, 2002. http://www.phillyburbs.com/terror/news/0114toxintests.htm
- FRP Occupational Saftey and Health Annex http://www.fema.gov.r-n-r/frp/frposh.htm.
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