Title Page Previous Contents | Part 4. Lessons Learned

Part 4.
Lessons Learned




sk environmental health experts and local health officials about how they performed on September 11, and you’re likely to get the same response: People responded admirably, especially given the unexpected and unprecedented nature of the attack.

Sept 15, 2001 - The sun streams through the dust over the WTC wreckage.
Photo: Andrea Booher/FEMA News Photo


Former EPA administrator Christie Whitman testified proudly in Senate hearings that “EPA accomplished a remarkable achievement to three national [terrorist] incidents during the same time period,” referring to the response at the World Trade Center, the Pentagon and the anthrax-contaminated buildings at various locations.


 “It’s so easy to be critical in hindsight when everybody was out there and their brother and they were really working hard,” says Jessica Leighton, assistant commissioner for environmental disease prevention at the New York City Department of Health.


“At Ground Zero, heroism was in ample supply” among the safety experts who traveled down to rescue the “brave band of rescuers.”


“What we did at the Pentagon was the way it should be; there was a real success here at the Pentagon and we want everyone to know,” says Mark Penn, head of OEM for Arlington County, VA.


The highest praise goes to those who supplemented the government’s efforts.


“At Ground Zero, heroism was in ample supply” among those like Bruce Lippy and Don Carson for the International Union of Operating Engineers, wrote Rep. Nick Rahall (D-W.Va.) of the safety experts who traveled down to rescue the “brave band of rescuers in New York City are endangered by asbestos, dust, and noxious vapors.” According to Rahall, “They are American



When asked what, in hindsight, they might have done differently, however, many officials and experts have a long list of suggestions.


It’s clear that there have been many more ramifications in New York than in Washington, so in many ways, one can’t compare the situation in New York and Washington, D.C. because the nature and scale of their crises were so different. Nevertheless there are some points on which they may be compared. In both cases, there were a lot number of surviving victims needing medical care, but in both cases, there were plenty of physical damage, infrastructure disruptions and environmental hazards needing attention, from hazardous materials monitoring to decontamination.


But critics of those charged with enforcing occupational safety and health standards in New York don’t mince their words: “First responders, and many unequipped workers like those in construction went in to do heroes’ work and became martyrs instead,” says Joel Shufro, executive director of The New York Committee for Occupational Safety and Health (NYCOSH), a coalition of unions and health professionals.


“Where we see a real need is to understand incident command, chain of command, so that all the things like protecting disaster responders, can get done,” says Joseph (Chip) Hughes of NIEHS’ Worker Education and Training Program (WETP).


Almost all those polled agree one of the biggest areas to improve is risk communication, how public officials communicate hazards to the public. New York City Health Department’s Kelly McKinney admits that the real lesson for his department was for officials to communicate what they know “every day and all day long.” He adds, “If it is a hazard, be clear about what you know and don’t know – and where the uncertainty lies.”


“The public is a little bit smarter and could have understood more complexity.”



“EPA came out way too early about the safety of the site,” says Alison Geyh of Johns Hopkins. “The public is a little bit smarter and could have understood more complexity.”


Paul Lioy criticizes the agencies for letting people come back to Lower Manhattan prematurely. “People came back but they never should not have been allowed to be back,” says Lioy, “No one should have been back at work. Children should definitely have not been back in school.” This was a chaotic time, but there was no basis, he says, for the city and federal government to state that the environment was safe to reinhabit.

Environmental health professionals feel they made a positive difference in many areas. “We were very lucky to have be prepared with incident command, urban search and rescue, medical and occupational response, and quick federal response in ruling out a bio-terrorist attack,” says Arlington County’s Mark Penn.

Despite the problems in pinpointing air pollutants at Ground Zero, there were many words of praise for those who worked hard to get data under pressure and to be responsive to the needs of agencies. Bruce Lippy praises Leighton of DOH because “She did a really nice job of getting hundreds of air samples and reviewing them.

“Agencies without having a plan did a terrific job,” says Alison Geyh. “Three times a week people on the AQ issue spent an hour on the phone making sure everyone was aware of what they were doing; “It was a huge time commitment on the part of Region II EPA, NY State Department of Environmental Conservation, NYC DOH and others. Kelly McKinney did a fantastic job, running on overdrive and fumes. He was good at keeping things on track.”

Public health officials say that public health system worked well under such high pressure.” The bottom lines was that 100,000 medical charts were surveilled and that went on through November,” Ron Burger of CDC. And scholars agree.

Amazingly, New York City was able to “weather this episode” despite the fact the state’s disaster plan had not been updated since the early 1990s, and, according to New York State Assemblymember from Manhattan Richard Gottfried, the plan “did not function” during the crisis, David Rosner and Gerald Markowitz point out, in their report on September 11th.

The episode reveals the enormous resources available in New York, and that the institutions themselves were able to implement emergency protocols quickly and efficiently, despite the chaos of the moment and the lack of clarity as to the true extent or nature of the disaster,” they wrote. (1)

Where did safety succeed best?

·         EPA and city sanitation got much of the dust off the streets in the first days of the crisis, says Captain Terrance Revella of the New York State Department of Environmental Conservation. That greatly reduced the city populations’ exposures to the dust.

·         Although the city, specifically those designated agencies such as the Department of Design and Construction, can be faulted for failing to enforce worker protections, there were no fatalities at the site.

·         The Coast Guard’s able evacuation of people from Lower Manhattan spared people’s health as well as their lives.

EPA monitored the air for pollutants.
Photo: EPA

At the Pentagon, officials credit the benefit of emergency planning drills; good coordination among agencies. In fact, today some community fire departments are trying to emulate the skills carried out at the Pentagon. Framington, Massachusetts, for example, is putting together an ‘incident command system’ that will create one system of response to be used by everyone--what Homeland Security Director Tom Ridge has been calling for since last year. “ It's important for local communities to have solid plans because local departments are always the first on the scene,” said one official there.

Despite the many successes, however, by the agencies’ own estimations, they were stressed beyond their limits.

EPA feels its responders were able to carry out their mission to protect human health and the environment. “Their response, though successful, was hampered by the unprecedented demand on Agency’s emergency response resources and by limitations posed by EPA’s still developing capacity to respond to terrorist events.”

Having so many air samples to run from so many agencies at one time stressed EPA to its limit. According to EPA, it was seriously tested by having to coordinate air samples being run by 13 different agencies, had to reconcile numerous different sampling protocols. It didn’t have enough facilities and equipment to quickly analyze samples given the volume of data; “The volume of samples requiring quick laboratory analysis greatly exceeded the Regions’ capabilities” and they couldn’t get access to other national labs. (2)

Others would be far less charitable in their assessments.  “The heroes were the police and firefighters who got people out of the buildings,” says Mt. Sinai’s Philip Landrigan.

If a terrorist incident without chemical, nuclear or bioterrorism could so strain the system, what would happen in the event of a highly environmentally hazardous event? EPA says: in its leaked report, “EPA’s mission was to protect front-line responders from dust and contaminants released when commercial aircraft were deliberately crashed. Although the Attacks did not contain weapons of mass destruction (WMD), the results were a series of disasters on a scale greater than EPA had ever encountered during emergency response.” (2)

Since there’s like to be some sort of environmental contamination in future attacks, local agencies need to be prepared to deal with the kinds of issues to surfaced in New York – indoor contamination and removal, assessment of risks to vulnerable populations.

And, experts point out, all sorts of future environmental disasters, from earthquakes in urban areas, to tornadoes, fires and hurricanes, could involve a complex building collapse.

Critics also some major policy failures: No agency enforced proper respiratory protection for workers; no agency took charge of the environmental health piece of the 9/11; and no agency focused on indoor cleanup, and, in fact, according to critics like Congressman Jerrold Nadler, tried to evade it.

If EPA has authority under the National Contingency Plan to control the release of hazardous substances it should be ready to address complex building fires in the future.

Some blame the insufficient awareness of the risks and hazards on political factors like the rush for normalcy and to get financial district back running; lack of good sampling in the first days due to factors beyond their control, like no electricity and not being prepared, and the anthrax crisis coming on its heels; too much focus on asbestos to the exclusion of other toxicants; and too much focus on physical hazards of cleanup and not enough on environmental health.

September 11th, of course, has made the idea of unthinkable environmental disasters involving hazardous chemicals or nuclear byproducts far more imaginable but that has done little to slow their commercial production or encourage their being more strictly regulated. Certainly, the focus on terrorism has permanently changed the terms of the environmental debate in some respects: After 9/11 politicians began to view environmental hazards as security threats too.

At first, the political winds favored regulating toxic chemicals at chemical plants more strongly. Environmentalists in the past used to play down the terror threats of chemicals because industry would complain “Greenpeace was courting attacks by spotlighting potential hazards,” wrote Wall Street Journal reporters Jacob. M. Schlesinger and Thaddeus Herrick. “But soon after the Sept. 11 attacks, the activists made terrorism the new centerpiece of their old crusade. That fall, Rena Steinzor of the Natural Resources Defense Council told Congress: "Human error ... killed several thousand people in Bhopal. What price will we pay for deliberate sabotage at such a facility?" (3)

New York, NY—March 15, 2002

Photo: Larry Lerner/FEMA News Photo

While that logic has won some converts, they write, the new crusade has triggered a chemical industry lobbying campaign to stall any new regulation in the name of terrorism protection. (3) Earlier legislation that would have promoted industries moving toward least-toxic processes has been derailed while new legislation drafted by the White House and Sen. James Inhofe, the new chairman of the Senate Environment and Public Works committee, would remove the EPA from control, giving authority instead to the Department of Homeland Security. “The new version also would give companies more credit for actions taken on their own,” they write. “It would give the government little, if any, authority to promote inherently safer technologies.”

Have we learned anything in the two years’ worth of lessons? Environmental professionals cite a litany of lessons, as well as their recommendations for the future:

(1)   Call a hazard a hazard.


Be ready to protect the public against all environmental risks by giving them ample warning.     “It’s very clear that the government may have gone too far in reassuring people,” says Kenneth Olden of the NIEHS. “People are still suffering. And there well be long-term consequences to the public [from the hazards at the disaster site of the former World Trade Center.]”


Recommendation: Public officials need to be open about risks and hazards to the public, and agencies should not try to downplay those hazards. 


(2)   If it is a health emergency—as well as a disaster--treat it that way. Be clear about what kind of event it is.


Critics say EPA could have done more to protect residents from the pollutants coming off the Ground Zero site, by warning them, or making efforts to restrict them from hazards.


Air pollution expert Thomas Cahill of the University of California at Davis, and Marjorie Clarke, hazardous waste expert at Lehman College fault the agencies for not coming up with a way to keep unprotected populations away while the “pile” was burning like an uncontrolled incinerator.


If EPA has authority under the National Contingency Plan to control the release of hazardous substances it should be ready to address complex building fires in the future.


Define the perimeters of environmental contamination. There should have been systematic testing of dust and debris in different gradients from the epicenter of Ground Zero, to know the level of hazard to the public, suggests Dr. Stephen Levin of Mt. Sinai Hospital. “Instead, the city set an arbitrary line at Canal Street,” says Levin. “But that is a political, not a medical or scientific boundary.”


Recommendations: Data is critical in managing emergencies. Investments should be made in making sure that adequate environmental data is available.


(3) Clear Chain of command to protect health and safety.


The authority for the Ground Zero site changed many times, and it was unclear which agency was in charge of which functions. Occupational health protections suffered, and some environmental health questions fell through the cracks – such as protecting residents from hazardous indoor dust.


Critics suggested that there ought to have been a lead agency for environmental health, to coordinate among the various other agencies. (Lioy; NRDC; Jerrold Nadler’s Ground Zero Task Force)


Had there been such an agency at Ground Zero, this would have made sure respiratory protection was emphasized from day one. “The way it was at Ground Zero, we couldn’t throw workers off the site if they didn’t comply,” says EPA’s Steve Touw.


“There ought to be solid interagency agreements worked out beforehand to insure good coordination,” says Paul Lioy, “and perhaps under the Department of Homeland Security there can be much better pre-planning and coordination.


Recommendations: Need for effective pre-planning, coordination, and (most important) enforcement mechanisms to insure standards are enforced.


(4) Open communication with the public.


“I don't think we understood at the time the magnitude of the risk communication challenges we faced,” says New York City DOH’s Kelly McKinney.


However critics say that the public shouldn’t be kept in the dark about real or potential environmental hazards. Public officials should not make reassuring statements before they have the information.  “EPA came out way too early about the safety of the World Trade Center site,” say critics like scientist Alison Geyh.


At the same time, federal agencies shouldn’t withhold data, as some charge the EPA did under the guise of “national security” in fighting terrorism. The EPA’s OIG report states that the agency never suppressed any data it could have made available to the public. However it is clear that many scientists and nonprofit groups had to file Freedom of Information Act requests to get information because the agency wasn’t forthcoming with its data. “We had trouble getting clearance to put data up on the web and had to clear it through the White House counsel for national security reasons,” says EPA’s Steve Touw. “Yet we had nothing to hide; it was just one or two people in the White House trying to keep it close to the vest.”

Nor should ‘terrorism’ be used as an excuse to hold back information, as it has been in some instances—an issue raised by journalists. For example, the Society of Environmental Journalists, on behalf of its 1200 members, signed a letter to Secretary Tom Ridge at the Department of Homeland Security, along with other organizations also representing scientists, librarians, privacy advocates and others, calling on it to allow public input on procedures for "safeguarding" and sharing a vaguely defined set of information between firefighters, police officers, public health researchers, and federal, state and local governments. In a news release, they wrote, "Under the auspices of fighting terrorism, the Department is poised to write — without guarantees for public input — procedures that could sweep up otherwise publicly available information that has nothing to do with terrorism into a zone of secrecy while subjecting millions of Americans to confidentiality agreements."

Disaster experts, instead, emphasize that officials should enlist the public’s help. They stress that it is important to have the public trust so that it can be depended upon to help in a crisis, by, for example, stopping cell phone use so as not to deter the transmission of emergency information.


Recommendation: “Make data available as soon as possible, with a registry of samples.”


(5) Better training and preparedness


Fire departments are not used to respirators needed for hazardous events unless they’ve been trained. Some first responders don’t fall into current “environmental health” training and went into the WTC disaster without any sense of the consequences of being exposed, such as tow truck operators, electricians, telephone repair people and others need to be considered. (4)


In responding to the World Trade Center disaster, local hospitals were ready for any casualties and injured victims because they were prepared from the last terrorist attacks. In Arlington County, local emergency responders had experience from an earlier airport disaster. In New York City, by contract, local, state and federal agencies were not prepared to coordinate their efforts because those disaster plans had never been tested before. And, strikingly, the Rand Corporation has found that few localities are prepared for chemical or biological terrorism (5)


Recommendation: Have a broader definition of first responder, says Mark Penn of the Arlington County Office of Emergency Management. 


(6) Better health registries and health tracking. Localities should start developing health data right away, instead of simply relying on samples and monitors.


New York’s 9/11 Environmental Action group complained that the city waited too long—two years—to start its promised Health Registry in New York, months after physicians, researchers and residents clamored for it.


A similar charge is leveled at the national level. “The September 11 attacks have made the gap in our public health knowledge more dangerous than ever,” according to advocates for better disease monitoring. “While Congress is considering how to help the public health system be better prepared in the face of unprecedented health risks—whether from the increasing concerns of disease clusters or the unforeseen threats from chemical and biological terrorism—we must make sure investments are made in the right way and that they part of a long-term commitment.”


While we track more than 50 infectious diseases in this country, the Pew Environmental Health Commission found almost no national monitoring of chronic diseases. (“For instance, more than half of the states have no ongoing tracking and monitoring of asthma, and less than half of the nation's population is covered by birth defects registries. Only nine states report tracking developmental disabilities such as mental retardation and cerebral palsy.”)


Supporters of a Nationwide Health Tracking Network, advocate involving a network of local, state, and federal public health agencies in tracking the trends of priority chronic diseases and relevant environmental factors in all 50 states and Washington, D.C., Puerto Rico, and U.S. territories. This, they say, will help create an early warning system to monitor immediate health crises, such as heavy metal and pesticide poisonings, that can trigger action against hazards. It would also be vital as baseline data in any future terrorist incident.


Recommendation: Start a tracking system as soon as possible after a terrorist attack. (6)


(7) Better preparedness on evacuation plans.


    Even though cities have evacuation plans, they’re not enforced adequately.     


     New York City, for example, didn’t even contemplate any kind of evacuation plan, not having updated its disaster plan in more than 10 years.


 Recommendation: Cities should update evacuation plans and make them enforceable; train fire marshals.


(8) Improve the way buildings are designed and constructed.


Fire fighters and their advocates have long been concerned about building materials because of their tendency to make for unusually toxic fires.


But is the construction industry revising how it builds—and how high it builds—especially in likely targets? To make for a safer post 9/11 built environment, construction planners need to investigate safer materials, and designs that facilitate easier evacuation in emergencies.


Recommendation: From an environmental health perspective, designers ought to also look at construction materials for their durability and well as elimination of toxic products and processes.


(9)   Manage an abundance of volunteers—and donations.


Localities need to learn to manage volunteers as they converge upon the scene. Dodie Gill of Arlington County, Va. suggests finding constructive ways to accept people’s donations of time and resources. When it comes to food, “Thank them, and once they’ve left, dispose of it quickly.”


“As in other disasters, New York saw a tremendous influx of resources after the disaster. Some of these resources were needed, while others were a burden on the system.” Notes Tricia Wachtendorf in her presentation, “A changing risk environment: Lessons Learned from the 9/11 World Trade Center Disaster.” (7)


(10) Make way for better partnerships 


Robert Martin, former EPA ombudsman faults the EPA for failing to consult with the New York community on places hardest hit from a public health standpoint.


When it comes to research, the public and research community could benefit in the future if a more formal process were developed to guide the reactive and proactive steps that researchers should take in disaster situations. A national body such as the NIEHS or National Academy of Sciences could play a role in developing an action plan


Recommendation: Consult with the community and empower them to be involved. Set up a process to have a liaison research committee to the community.


(11) New on-scene emergency protocol for measuring potential pollutants.


Sen. Hillary Clinton has suggested that setting health-based air quality standards should be part of the Homeland Security Act. She has called for the passage of the Disaster Area Health and Environmental Monitoring Act of 2003, legislation she cosponsored with Senator George V. Voinovich (R-OH) and which was approved by the Senate Environment and Public Works Committee.


“This legislation would ensure that the health of first responders, workers, residents, school children, and other community members is adequately protected and monitored when exposed to harmful substances and other health risks in a declared disaster area," according to Clinton. (8)


Recommendation: Create a new emergency protocol for environmental health identifying the pollutants to be measured in the aftermath of a disaster and standards for controlling them.


(12) Give environmental health higher priority.


“At 9/11 safety professionals were rotated in and out but we didn’t have the manpower,” says Bruce Lippy of the National Union of Operating Engineers.


Professionals needed more staff and funding, argues CDC’s environmental health expert Ron Burger. “There should be more than 2 or 3 environmental health professionals in a local health department of 20 or 30,” says Burger.


Patrick Meehan at the CDC agrees. “New York City, as well funded as it was, didn’t have enough capability. That speaks to what we can expect from other, much smaller, cities and towns.”


One way to give environmental health greater priority would be to issue advisories to physicians so that they can be aware of illnesses that may arise out of environmental health consequences, suggests Stephen Levin of Mt. Sinai Hospital.


Recommendation: Beef up environmental health funding, staffing, and other public and professional resources.


(13) Be ready to improvise.


 “You can’t plan for every single thing; but when something happens, it’s not time to take a plan out,” says CDC’s Ron Burger. At both Ground Zero and the Pentagon, says disaster scholar Kathleen Tierney, improvisation was as critical as pre-planning in helping handle everything from unsolicited food donations to creating credentialing procedures that balanced effective access to the site against security.


Recommendation: “Plan effectively beforehand,” urges Tierney, but also create an environment where you can “improvise solutions to unforeseen problems that will inevitably develop.”




(1)     Rosner and Markowitz, et al.http://www.milbank.org/reports/911/foreword

(2)     EPA, “Lessons Learned”


(3)     Chemical Manufacturers Elude Crackdown on Toxic Materials: Sen. Corzine Pushed for Rules to Reduce Terror Threats, but Political Wind Shifted,” By Jacob M. Schlesinger and Thaddeus Herrick, Wall Street Journal, 5/21/03


(4)     http://wetp.org/oldchfiles/awardee_mtgs/spring02/WMDreport.pdf


      (5) http://www.rand.org/publications/IP/IP217/IP217/index.html


      (6) http://healthyamericans.org/resources/testimony/hearne030602-oral.php3  


      (7) Wachtendorf, Disaster Research Center, University of Delaware,



     (8)  Proposal for Disaster Area Health and Environmental Monitoring Act of 2003



(9)     Kathleen Tierney, National Academies Press, http://www7.nationalacademies.org/ndr/1Tierney_Presentation.pdf

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