Hazard or Artifact?
How OEHS Informs Collection Management of World Trade Center Dust at the 9/11 Memorial & Museum
BY LISA CONTE, KERITH KOSS SCHRAGER, AND ADRIENNE GENDRON
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This year, the world commemorates two solemn milestones: the twentieth anniversary of the Sept. 11 terrorist attacks, and the one-year mark of the COVID-19 pandemic. On 9/11, 2,977 people were murdered, thousands more were injured, and since then even more victims have fallen sick or died from 9/11-related diseases. Deaths from COVID-19 are staggering and now number more than half a million people in the United States. How we remember these and other monumental events is intimately tied to the cultural resources that are collected and preserved by museums.
Since Sept. 11, it has become increasingly common for museums to collect material evidence of a culturally significant event in real time to ensure its story can be meaningfully and accurately conveyed. When artifacts are collected amid emergency scenarios, they may harbor hazardous materials. For example, the collapse of the World Trade Center (WTC) twin towers and WTC-7 blanketed lower Manhattan with toxic debris. The pervasive accumulation of dust on both people and things became one of the most indelible images of that day and continues to be intimately associated with evocations of the event. Images of the dust were ubiquitous, and the dust itself and objects covered in it were saved as relics, which would later take on an added significance as people began to understand that it could contain human remains. Generally, the care of this material falls under the purview of museum collection care workers who include, among others, curators (who manage the acquisition and display of collection objects) and conservators (who are responsible for their physical care and preservation).
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Like the personal protective equipment being collected today that will one day document the COVID-19 pandemic—the Smithsonian just collected the scrubs of the nurse who was the first person in the U.S. to receive a COVID-19 vaccine—a dust mask was ostensibly the first artifact acquired by a museum after 9/11. As recounted by Dr. Jan Seidler Ramirez in the New-York Journal of American History, the mask was deposited with the New York Historical Society on the day itself by someone who had worn it to escape the dust cloud. In that moment, as the mask and the WTC dust took on historical significance, the Society, perhaps unwittingly, took on a health and safety liability.
An object’s memorial value can depend in large part on the visible debris, which is powerful evidence of the traumatic event. Preserving dust is not a typical museum function, but for this collection, it is often an essential aspect of maintaining an object’s cultural resonance. The dust, however, presents potential health and safety risks to museum personnel. The competing interests of preservation versus hazard removal are frequently encountered at the 9/11 Memorial & Museum. WTC dust contains hazardous elements such as asbestos and lead, for which abatement is the industry standard. But for museum artifacts, removing these agents through sampling and decontamination may constitute an erasure of key historical information.
Indeed, words like “contamination” and “hazardous” seem inadequate in this context, because their negative connotations fail to acknowledge that an object’s memorial value can depend in large part on the visible hazards and contaminants. Narrative value aside, at the 9/11 Memorial & Museum, perceptible dust is considered potential evidence of human remains and thus triggers examination by the New York City Office of the Chief Medical Examiner, though, so far, none have been identified.
Because museum staff working with these artifacts can be exposed to potential hazards, health and safety protocols must be carefully considered and integrated into institutional policy. Personnel are tasked with navigating the preservation of these contaminants while simultaneously ensuring the safety of staff, researchers, and visitors. Collection policies at the 9/11 Memorial & Museum contain a detailed risk management plan, including safe storage and labeling, the display of artifacts in vitrines or enclosures as needed, local exhaust ventilation, reliance on respirators and gloves, and training. The policies demonstrate how museum staff in collaboration with occupational and environmental health and safety professionals can successfully negotiate these concerns. These decision-making processes can be applied to other collections with 9/11 artifacts and, more generally, to other collections with hazardous components.
Swipe left to view a slideshow of additional images from the 9/11 Memorial & Museum collection.
HAZARDS OF WTC DUST ON MUSEUM COLLECTIONS
Interviews conducted by the authors in 2020 with various stakeholders who recounted their experiences with WTC dust and subsequent museum collections practices demonstrated that the health and safety implications of dust exposure in September 2001 and the months that followed were not universally appreciated. While many OEHS professionals recognized the dangers immediately, members of the public were collecting dust and dust-covered objects as mementos, only later registering concern and then outrage as the risks of exposure became clearer. First responders’ reaction to the dust's potential health impacts was mixed and complicated by the urgency to find survivors. Later, collection staff, eager to retrieve artifacts before they were lost, also did not completely comprehend the hazard.
In the museum community, these perspectives began to coalesce by December 2001, as the American Institute for Conservation presented its membership with guidelines, crafted by a team of industrial hygienists and conservators, that detailed the specific risks associated with the dust and recommendations for safe work practices.
Managing health and safety concerns became a priority as the 9/11 Memorial & Museum evolved from initial artifact collection efforts. Protocols for working with artifacts with WTC provenance were based on a 2003 assessment by EPA, the New York City Department of Health and Mental Hygiene, the Agency for Toxic Substances and Disease Registry, the New York State Department of Health, and OSHA that outlined contaminants of potential concern (COPC) in WTC dust. This publication set health-based benchmarks for those contaminants in support of ongoing residential cleanup efforts in Lower Manhattan. A consulting industrial hygiene company provided the Museum with specific advice for the handling, exhibition, and storage of artifacts to help protect Museum personnel, consultants, subcontractors, and the public who might come in contact with potentially contaminated artifacts in a museum setting.
The initial plan for testing and working with COPC-status artifacts at the 9/11 Memorial & Museum was completed in 2012. Its guidelines incorporated expert counsel from Dr. Paul Lioy, from the Robert Wood Johnson School of Medicine at Rutgers University, and Dr. Lung-Chi Chen, from the School of Medicine at New York University. Dr. Lioy and Dr. Chen determined that testing for man-made vitreous fibers (MMVF), asbestos, and lead would be an effective means of verifying the presence or absence of WTC dust on the artifacts, distinguishing it from other particulate contaminants such as general museum or construction dust. This characteristic fingerprint was based upon their analysis of WTC dust, which indicated that MMVF was one of the most prevalent materials, as noted in a 2009 paper published in Journal of Exposure Science and Environmental Epidemiology. Asbestos and lead had been found at detectable concentrations in WTC dust samples and at the time were targeted as posing the greatest potential health risk.
This informed the development of the Museum’s operations and maintenance (O&M) plan outlining protocols for handling, storage, and exhibition, as well as prioritizing risk management for both museum workers and the public. It serves to bolster public trust, particularly among stakeholder groups. The plan covers everything from object handling to air sampling, exposure assessment, respirator fit testing, and employee health monitoring. Yearly evaluation and revision ensures the plan’s conformity with changing regulations, state-of-the-art procedures, and conditions in the museum and its storage locations. However, certain aspects of the plan derive from industrial processes and therefore do not comport with museum best practices. For example, aqueous sampling techniques can be harmful to some artifacts; other methods require large surface areas and therefore are not amenable for use with small objects.
All objects recovered from ground zero are considered potentially hazardous and require special handling procedures until they are cleared by wipe sampling and analysis. As outlined in the O&M plan, objects considered to be contaminated have levels of asbestos greater than one percent, MMVF greater than 52 structures per cubic centimeter (str/cm2), or lead greater than100 μg/ft2. Current testing protocols provide information about the concentrations of contaminants present, which can vary significantly from object to object. To date, over 750 of the 3,500 recovered artifacts have been tested.
Since implementation of the policy, there have been no occupational exposures exceeding levels of concern via air sampling conducted during handling of contaminated artifacts. The following criteria have been established for personal monitoring: asbestos, 0.1 fibers per cubic centimeter (f/cc, OSHA PEL); MMVF, 1 f/cc (ACGIH TLV for synthetic vitreous fibers); lead, 50 μg/m3 (OSHA PEL); and silica, 50 μg/m3 (OSHA PEL). The O&M plan also notes the ACGIH TLV for each of these contaminants.
Readers interested in learning more about collection-based hazards are encouraged to read two earlier Synergist articles: “IH in a Museum, Part 2” from May 2016; and “Hidden Hazards: Health and Safety in Museums and Art Galleries,” originally published in July 2003 and updated for inclusion in the digital version of the May 2016 issue.
WORKING WITH HAZARDOUS COLLECTIONS
Approaches to working with hazards are not uniform across museums. Following hazard identification, collection staff face several issues when considering handling or removing hazardous materials:
- Proper training and testing required for hazard identification is not always available for museum staff; health and safety training is generally not standardized in conservation or museum studies programs. Many staff are initiated into health and safety decisions without adequate experience or preparation as novel situations arise.
- Budgeting to mitigate exposures and ensure safe access to hazardous collections as well as the institutional resources and support required are not usually part of standard museum practice. Most institutions must rely on outside OEHS resources because their own staff members do not possess the relevant expertise.
- Collection access may be restricted when objects are considered hazardous. But contact with objects is necessary for staff to perform the essential work of ensuring preservation, conducting research, or sharing these materials through exhibition and loan.
- Collection caretakers have an ethical responsibility to consider not only the aesthetic appearance, but also the possibility that material changes they might make will alter cultural significance or interpretation. Decision-making about aesthetic alterations should include the voices of stakeholders and community members.
This last point is central to conservation practice. Conservators are extremely cautious about altering original material, even the removal of microscopic samples. Sensationalized examples in the media of amateur restorers trying to repair works of art demonstrate what can happen when misguided intervention loses sight of the original work. Conservators demand better than this through the application of logical, rigorous, and systematic methods when conducting any intervention, especially removal of material.
Museum professionals approach objects in essentially reverse order of the hierarchy of controls. Elimination is the least desirable outcome because the object contains unique information that shouldn’t be altered or discarded. Isolation in the form of vitrines, storage boxes, or limited access may be a suitable alternative. Museum workers tend to lean heavily on personal protective equipment as the first line of defense; use of gloves and a dust mask may be the only health and safety training they receive.
When removal of a hazard will permanently alter the object’s meaning, the decision-making process becomes even more complex. Inherent hazards, such as radioactive components, asbestos liners, and heavy metal-based pigments, result from the object’s manufacturing. In contrast, acquired hazards, which can include mold and pesticide residues, typically are not integral to the object’s meaning and are often removed during conservation treatment without much perseveration. These distinctions, however, are not always straightforward. Integral elements, such as original layers of lead paint on outdoor sculpture, may be removed and replaced with less hazardous alternatives. As in the case of WTC dust, situations where acquired hazards take on a great deal of meaning complicate issues of integrity and safety, and highlight the limitations of pigeonholing hazards into standardized mitigation protocols.
CASE STUDIES FROM THE 9/11 MEMORIAL & MUSEUM
Museums are ethically mandated to make their collections accessible while safeguarding their constituents and facilities. As a result, when possible, many museums choose to reduce the risk rather than eliminate the hazard. At the 9/11 Memorial & Museum this translates into taking different approaches for various types of objects. For example, small artifacts, such as dust-covered business cards and receipts, or the footwear worn by survivors and first responders, can be safely and securely isolated within sealed cases with no conflict between safety and narrative poignancy. However, some artifacts, like the twisted architectural steel from the WTC towers or badly damaged responder vehicles, defy this strategy; their size rules out isolating the hazards. Providing access required close proximity without case enclosures, making elimination of the dust necessary, notwithstanding a curatorial desire to maintain it. Ultimately, the power of these artifacts is their condition rather than the dust that coated them.
Museum professionals approach objects in essentially reverse order of the hierarchy of controls.
In one notable instance, the decision was made to encase and preserve a large-scale work. Chelsea Jeans represents a storefront that was a block from to the WTC. After 9/11, the store’s owner decided to enclose part of it as an intact memorial, preserving the damage caused by the towers’ collapse as well as the dust blanketing everything. The storefront drew countless individuals who came to observe the recovery process and honor those who had lost their lives. When the memorial was permanently installed in the museum in a hermetically sealed exhibition case, it was not cleaned because the presence of dust is integral to its value as an artifact. Today, the exhibit is part of an asbestos management plan. Physical contact is restricted unless additional precautions are taken, such as the use of asbestos-certified personnel with proper engineering controls and work practices.
CREATING EFFECTIVE MANAGEMENT PLANS AND COLLABORATIONS
While not all museums have the same resources, the collection management goals prioritizing health and safety are achievable if proper policies are established. Most significantly, as the 9/11 Memorial & Museum demonstrates, hazardous materials can be safely maintained and exhibited with proper risk management protocols in place. However, the decision-making process may be complicated by stakeholders with different, valuable, and relevant priorities, each of which must be carefully considered.
In a museum environment, it is important to think about who will be affected by the removal of a hazardous material. For example, the use of vitrines to isolate a hazard may be visually or conceptually distracting. On the other hand, removing the hazard may allow for a more impactful visitor experience but prompt a difficult ethical discussion. Further, OEHS professionals may not be familiar with the unique exposure scenarios of museum workers. Clear communication between collection workers and the OEHS professionals they enlist to help mitigate risks is crucial for successful problem solving as individual definitions of a successful outcome may be based on different priorities.
Before assuming responsibility for hazardous materials, organizations should also consider how the objects function within their mission. They should discuss with their OEHS collaborators whether the individual object and the requirements for its specific hazard are worth the investment of money, time, and personnel required to accommodate all the protocols needed to manage it.
Removing hazards and maintaining thorough documentation can be the ethical choice, despite the standard museum practice of preserving all original materials; however, careful consideration of cultural significance should dictate whether a material is preserved. Without dust, the Chelsea Jeans memorial loses its essential meaning, but in the case of the FDNY vehicles, their crumpled forms speak more to their history than the dust. Another option is to put the object in storage indefinitely. Many of the personal items from 9/11 may never be displayed, yet the museum serves an important role by housing and protecting these collections for future researchers.
Learning about the perspective of cultural heritage professionals and the unique hazards and handling restrictions of collections allows OEHS professionals to consider cultural heritage objects and their hazards with increased sensitivity and appreciate the value of interpreting their stories correctly. At the same time, effective collaboration encourages cultural heritage workers to better appreciate the roles safety, risk assessment, and hazard management play in all aspects of their work.
Finally, museum professionals in collaboration with their OEHS counterparts need to prioritize sharing these risk management strategies with the community—especially since health and safety education for museum workers remains limited. Setting health and safety standards for proper handling of hazardous collections must be a priority in the museum field. Creating a positive health and safety culture encourages good practices throughout the collections care world and further ensures the continued preservation of the artifacts of our cultural experiences.
LISA CONTE is the head of Conservation at the 9/11 Memorial & Museum in New York City.
KERITH KOSS SCHRAGER is the owner of The Found Object Art Conservation in White Plains, New York, and a consulting conservator for the 9/11 Memorial & Museum. She is an MS student in Environmental Health Sciences at New York University.
ADRIENNE GENDRON, the Suzanne Deal Booth Fellow at the Conservation Center of the New York University Institute of Fine Arts, is pursuing an MS in the Conservation of Historic and Artistic Works and an MA in the History of Art and Archaeology.
Acknowledgement: The authors thank the members of the AIHA Museum and Cultural Heritage Industry Working Group for their assistance in reviewing this article. We are indebted to many colleagues who facilitated and furthered our research, including Dr. Jan Seidler-Ramirez, Amy Weinstein, Amanda Granek, Steve Weintraub, Alan Balicki, Maureen Merrigan, and Bethany Romanowski. A special acknowledgement goes to Kathryn Makos.
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RESOURCES
American Institute for Conservation: “World Trade Center Dust: Safe Work Practices for Conservators, Based on Data Available as of 12-6-01” (December 2001).
EPA: “World Trade Center Background Study Report, Interim Final” (PDF, April 2003).
EPA: “World Trade Center Indoor Environment Assessment: Selecting Contaminants of Potential Concern and Setting Health-Based Benchmarks” (PDF, May 2003).
Journal of Exposure Science and Environmental Epidemiology: “Summary of the Development of a Signature for Detection of Residual Dust from the Collapse of the World Trade Center Buildings” (March 2009).
New-York Journal of American History: “Present Imperfect: The New-York Historical Society’s Collecting Odyssey of 9/11/01” (Spring 2003).
New York State Department of Labor: Asbestos: Part 56 of Title 12 of the Official Compilation of Codes, Rules and Regulations of the State of New York (PDF, March 2007).
Skira Rizzoli: “The Complexities of Displaying World Trade Center Dust” in No Day Shall Erase You: The Story of 9/11 as Told at the National September 11 Memorial Museum (2016).
U.S. Department of Housing and Urban Development: Guidelines for the Evaluation and Control of Lead-Based Paint Hazards in Housing (2012 Edition).