FREEPETEY.COM

Day 19

On September 11, 2007 the United States Government's, Department of Labor, Occupational Safety & Health Administration (OSHA) issued a Request for Information with regard to emergency response and preparedness. OSHA is concerned about the health and safety of emergency responders in general and firefighters in particular. In light of the extraordinary health and safety threats that 130 Liberty Street posed to firefighters both in terms of inspecting and fighting fires, OSHA's interest in firefighter health and safety could not be more timely and appropriate. The deadline for responses is December 10, 2007.  Will FDNY share with OSHA the lessons it has learned from its experience with 130 Liberty Street by the December 10, 2007 deadline? Or, will FDNY continue to refuse to comment claiming pending investigations?  It is important for the greatest fire department in the world to talk to OSHA on the issue of emergency response and preparedness. But will it?

 OSHA in its Request for Information has indicated that its "areas of interest are primarily: personal protective equipment, training and qualifications, medical evaluation and health monitoring, and safety management." 

Let us keep in mind that there were both chemical and biological hazards inside 130 Liberty St.  The chemical hazards were

1. Asbestos,
   
2. silica,
   
3. PAHs,
   
4. dioxins,
   
5. man-made vitreous fibers (MMVF), 
   
6. antimony,
   
7. cadmium,
   
8. nickel,
   
9. lead,
   
10. barium,
    
11. chromium,
    
12. zinc,
    
13. manganese,
    
14. copper, 
    
15. beryllium,
    
16. PCBs,
    
17. mercury,
    
18. copper,
    
19. zinc,
    
20. cristobalite and
    
21. quartz

The biological hazards were

1. Mold;
   
2. rodents;
   
3. insects;
   
4. Legionella.
   

Asbestos was but one of the hazards lurking within 130 Liberty Street.

How does FDNY protect its firefighters from these extraordinary threats to their health and safety?  OSHA would like to know. 

OSHA in its request for information cites to a report that

... recognized the need for national standards on training,qualifications, medical and physical fitness, as well as for emergency response policies and procedures.

It is imperative that FDNY in light of its recent experience with 130 Liberty Street contribute to OSHA's effort to better protect the health and safety of firefighters especially in suggesting "emergency response policies and procedures".

The OSHA request for information explains OSHA's involvement in firefighter health and safety and the reason that it thinks its time to develop a comprehensive national policy 

OSHA addresses the elements of emergency responder health and safety primarily by the following OSHA standards:

The hazardous waste operations and emergency response standard (29 CFR 1910.120);

the personal protective equipment general requirements standard (29 CFR 1910.132);

the respiratory protection standard (29 CFR 1910.134);

the permit-required confined space standard (29 CFR 1910.146);

the fire brigade standard (29 CFR 1910.156); and

the bloodborne pathogens standard (29 CFR 1910.1030).

These standards were designed to address the health and safety needs of employees over a broad cross-section of industries and workplaces. None of these standards was designed as a comprehensive emergency response standard, and as a result, specific hazards are addressed in a piecemeal manner, and important concepts in emergency management are not addressed at all.

 
It is called PESH    The New York State Department of Labor's Public Employee Safety and Health (PESH) Program oversees the workplace protection of public employees at the State and local level. Protection guidelines are determined by standards set by OSHA, ...

New York's PESH plan was initially approved in 1984

Private employees are covered by Federal OSHA

One of the expressed concerns of OSHA in its request for information is

Emergency response and preparedness activities have historically included a range of events from pre-planning for an emergency, to the actual emergency response, and ultimately, to remediation/recovery. 

One of the critical questions OSHA asks in its Request for Information is

Should emergency response organizations establish written standard operating procedures (SOPs) or standard operating guidelines (SOGs) for expected emergency response activities? If so, what types of issues should be addressed in the SOPs or SOGs

OSHA goes on to ask

How should employers [FDNY] plan and prepare for special hazards within their area of operations?

The lessons learned from 130 Liberty Street by the lack of FDNY pre-planning for inspections and pre-planning for fire operations would benefit the nation as well as FDNY.  However, the question remains, Will FDNY help OSHA formulate policy and procedure by contributing or will FDNY continue to remain mute?  We know that it is only a short time - Sept 11, 2007 to December 10, 2007 - for FDNY to prepare its contribution.  We know that years went by - almost 2 and 1/2 - since the 3/22/2005 Draft Siegel Memorandum and on August 18, 2007 FDNY still had not promulgated a plan for either inspections or fighting fires at 130 Liberty St. However, we would hope that FDNY would help OSHA as best it can before December 10, 2007 comes and goes. In order to properly respond to OSHA's request for information, the Big Chief's at Headquarters will probably have to be debriefed to learn why pre-planning failed with regard to 130 Liberty Street.  The big question remains, Does FDNY have the courage to do this? Stay tuned.

(Once again my thanks is extended to Deep Throat for pointing me to this OSHA request for information. Without the courageous help of Deep Throat and other courageous people, I don't know where Captain Peter Bosco would be by now.  Thanks also to the courageous firefighters of FDNY. 130 Liberty Street was "a trap for honest men".  Your help is preventing that trap from snagging Captain Peter Bosco)