Journal of Exposure Science and Environmental Epidemiology (2010) 20, 491–492

r 2010 Nature America, Inc. All rights reserved 1559-0631/10

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LETTER TO THE EDITOR

Response to the comment by Henry Kahn and Dennis Santella on a
summary of the development of a signature for detection of residual dust
from the collapse of the World Trade Center buildings

GREGORY P. MEEKERa, PAUL J. LIOYb,c, MORTON LIPPMANNd AND HEATHER A. LOWERSa

a
US Geological Survey, MS973, Denver, Colorado, USA
b
Environmental and Occupational Health Sciences Institute of New Jersey, UMDNJ-Robert Wood Johnson Medical School and Rutgers University,
New Brunswick, New Jersey, USA
c
Department of Environmental and Community Medicine, UMDNJ-Robert Wood Johnson Medical School, New Brunswick, New Jersey, USA
d
Nelson Institute of Environmental Medicine, New York University, Tuxedo, New York, USA
E-mail: plioy@eohsi.rutgers.edu

Journal of Exposure Science and Environmental Epidemiology (2010) 20, 491–492; doi:10.1038/jes.2010.45

We believe that the comments by Henry Kahn and Dennis
Santella (K&S) are flawed because they assume a use for the
signature method that was never intended. Further, the K&S
comments neglect to provide an adequate history of the
process that led to the development of the WTC dust
signature.
Our responses to K&S are from the perspective of the
Signature Sub-Group of the World Trade Center Expert
Technical Review Panel (WTCETRP). The WTCETRP
(http://www.epa.gov/wtc/panel/) was convened to address
outstanding public health issues, potential residual environ-
mental contamination from WTC dust, and the geographic
extent of the dust plume generated by the 9/11/2001 tragedy.
(http://www.epa.gov/wtc/panel/pdfs/Clint-Lieb-ltr.pdf)
We thank K&S for alerting us to two misstatements in our
paper that we hereby correct. The statement ‘‘The 5% and
10% USGS samples are clearly distinguishable from the
remaining samples in all cases’’ should read ‘‘The 5% and
10% USGS samples are clearly distinguishable from the
remaining samples in most cases.’’ Also, the last sentence of
the caption for Figure 3 should read ‘‘All labs that passed
EPA’s quality assurance test (Rosati et al., 2008) could
distinguish background material from the 5 and 10% USGS-
spiked material.’’ We note, however, that these corrections do
not affect any of our conclusions. Additional issues raised by
K&S are addressed below.
First, we categorically challenge any arguments, conclu-
sions, or statistical analyses based on the incorrect assump-
tion that the four Albany samples represent a legitimate
spiking material, that is, representative of undiluted WTC
dust as generated on 9/11. The results from analyses of the
four Albany samples continue to be incorrectly used to argue
that slag wool could not be reliably detected above
background.
Second, the error bars in Figure 3 of our paper were
derived strictly from actual fiber counts as described in ISO
14966. The fiber count uncertainty is independent of how the
particles got onto the substrate, and the units employed to
express fiber concentration, for example, fibers/liter of air, or
fibers/milligram of liquid.
Third, the K&S notion of a ‘‘convenience’’ background
appeared only in their comments. EPA collected the
representative background samples used in the signature
study. We are somewhat baffled by what background seems
now to mean to K&S.
The issues that we address below are extremely important,
but beyond the scope of our paper. We appreciate the
opportunity given to respond to these issues now being raised
by K&S.
From the perspective of the Signature Sub-Group, the slag
wool dust signature was developed for use in conjunction
with existing validated methods for the analysis of con-
taminants of potential concern (COPCs), including asbestos,
lead, glass fibers, and PAHs (EPA (2005a), and subsequent
discussions by the WTCETRP on 12 July and 13 December
2005). The phase I study was intended to analyze samples
from buildings impacted by the building collapse dust cloud
in areas near the WTC site, and farther away where less
impacted. Data collected from the phase I study would then
be analyzed to determine the strength of correlations between
COPC and the slag wool signature. The slag wool signature
was never intended to be the sole indicator of WTC dust

contamination. In addition, the WTCETRP fully recognized
that there would be some false positives. The purpose of the
signature study, from the perspective of the Signature Sub-
Group, was to (1) determine whether qualified laboratories
could identify slag wool in ‘‘background’’ samples spiked
with various levels of WTC dust; and (2) determine whether
the average background of slag wool in samples unaffected
by the WTC dust cloud would be at levels where the false-
positive rate would be acceptable. Based on the results of the
signature study we believe that both of these criteria were
successfully met (see p. 21, EPA, 2005b). It should be noted
that the goal was to determine the presence of slag wool,
which in undiluted WTC dust could be upwards of 20–50%
of the total mass (Meeker et al., 2005a), before approving an
initial or secondary clean-up of COPCs that are generally
found at trace levels in undiluted WTC dust (Lioy et al,
2002; Meeker et al., 2005b).
The sole reason given by EPA for not proceeding with the
phase I sampling and analysis plan was the lack of full
endorsement by the peer review report on the signature study
(Oppelt, 2005; EPA, 2005c). The Signature Sub-Group
provided comments in response to the signature study peer
review report (Meeker and Lippmann, 2005), which K&S
neglect to mention. These Signature Sub-Group comments
address most of the issues raised by the peer review committee.
These comments also contain a document from the Chair of the
Signature Sub-Group (Comments on Draft Charge Questions
from Greg Meeker, July 2005) discussing problems with the
charge questions provided to the peer review committee by EPA
(Charge Questions, August 2005). To the best of our knowl-
edge, Meeker’s comments were, for the most part, ignored by
the EPA. We maintain that many, if not most, of the issues
raised in the signature study peer review report had already been
addressed by the Signature Sub-Group, by EPA, and by the
WTCETRP prior to the signature study peer review. We also
believe that the signature study peer review was conducted
without the context and background information necessary to
properly evaluate the signature study.
492
Letter to the Editor
During the final meeting of the WTCETRP on 13
December 2005, the WTCETRP clearly expressed its dismay
with the decision by EPA to not proceed with the modified
phase I study using the WTC signature (http://www.epa.
gov/wtc/panel/meetings-20051213.html). Therefore, we
encourage all interested readers to pull up the entire record
to get the full story.
The lessons learned that we refer to in our paper, from the
21 months for which the WTCETRP was active, are not that
slag wool should be used as an indicator of contamination in
some future catastrophe, as suggested by K&S. Rather they
are the lessons of a flawed process that must be understood in
its entirety by researchers and the community, so that a
similar situation does not occur again.
Conflict of interest
The authors declare no conflict of interest.
References
EPA. 2005a: http://www.epa.gov/wtc/panel/pdfs/Final_Report_August_17_2005.pdf.
EPA. 2005b: http://www.epa.gov/wtc/panel/pdfs/sampling_plan_06300505.pdf.
EPA. 2005c: http://www.epa.gov/wtc/panel/pdfs/WTC_peer_review_report.pdf.
Lioy P.J., Weisel C.P., Millette J.R., Eisenreich S., Vallero D., and Offenberg J.,
et al. Characterization of the dust/smoke aerosol that settled east of the World
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Journal of Exposure Science and Environmental Epidemiology (2010) 20(6)