EPA Tightens The Noose On HVAC Antimicrobial Use

The use of sanitizers and disinfectant products in HVAC systems “could lead to significant exposures in indoor environments with potentially unreasonable adverse effects” says the U.S. Environmental Protection Agency (EPA) in a March 14th letter. IE Connections received EPA’s letter a few days before its wide distribution to organizations throughout the IAQ, cleaning and HVAC industries.

EPA explains that although a product may be permitted for use on hard, non-porous surfaces, its directions for use “may not specifically include the use of the product in HVAC&R systems.” EPA has not assessed the potential for such products to affect occupant health when used in HVAC system cleaning, nor has the agency tested product efficacy for that application.

EPA’s concerns over antimicrobial use in HVAC systems even extends to products the agency has registered specifically for that application. “We are concerned that the Agency has not received and reviewed adequate data to fully evaluate risks to building occupants or product efficacy in that use pattern,” says EPA in a stunning admission.

EPA reports that the National Antimicrobial Information Network has received 150 calls regarding the use of antimicrobial products in HVAC systems in the past 18 months. EPA is not specific whether those calls were complaints or information inquires, but given the severity of EPA’s recommendations it is likely the former.

EPA asks industry nonprofits to “advise your members not to apply disinfectant, sanitizer or other antimicrobial products to treat HVAC&R systems if such product does not include specific directions for HVAC&R use.” EPA further advises industry not to use products in “HVAC&R systems that are not registered for that use.” While this might seem to leave an opening for a few products on the market that have HVAC use in the registration to remain on the shelf, the admission by EPA that it hasn’t adequately evaluated exposure and efficacy of such products leaves a glaring contradiction. A firm that has heard the EPA warning and still knowingly applies any antimicrobial product to an HVAC system may be accepting a new level of exposure and liability.

After several meetings last year with manufacturers, EPA was expected to take some action early this year. According to agency officials, there is no EPA-accepted protocol that measures efficacy, chemical exposure, or risk assessment of these antimicrobial products.

Look for full scale coverage of this issue including reaction from government officials, manufacturers, contractors and consumers in next month’s issue of IE Connections.

Burge On The Move Again: Environmental Microbiology Laboratory Inc. (EMLab) and Dr. Harriet Burge recently announced the appointment of Burge to EMLab’s indoor air quality analysis team. She is recognized as one of the world’s foremost authorities in indoor air quality and aerobiology. EMLab is a leading commercial laboratory specializing in the analysis of indoor air and surface samples for fungi, including mold, yeasts and macrofungi, and also bacteria.

Association Shake-Up: The Association of Specialists in Cleaning and Restoration (ASCR) wants to position itself as the "manufacturer" of educational products for the cleaning and restoration industry, with the many state and regional cleaning associations serving as "distributors." According to Cliff Zlotnick, ASCR Past President, the smaller regional groups in the cleaning and restoration industry are failing and need a boost. Last year ASCR dropped out of the Institute of Inspection, Cleaning and Restoration Certification (IICRC), which is a certifying body made up of 18 state and regional trade organizations. It appears that ASCR is positioning itself to usurp IICRC as the overseer of industry education and certification programs.
Meanwhile, everyone is wondering what happened to the relationship between ASCR and the MidAtlantic Environmental Hygiene Resource Center (MEHRC) that was being touted at last year's Healthy Indoor Environments conference. ASCR's decision to hand its mold remediation training program over to WonderMakers Environmental of Michigan was a big surprise, since most in the industry assumed the infinitely qualified MEHRC group would do ASCR's mold education work.

Loss At CFA: After 18 years at the IAQ helm, Mary Ellen Fise resigned from the Consumer Federation of America effective the end of February. She cited her desire to spend more time with her family as the reason. Fise was a staple at many IAQ conferences over the years, and conducted many research projects on consumers and indoor air quality. Indoor air quality issues at CFA will be handled by Betty Leppin (bleppin@consumerfed.org) for interim.

AIHA Beefs Up On Hill: In a never-ending attempt to keep AIHA members updated on government affairs activity in Washington, AIHA Government Affairs recently unveiled a new “Federal Legislative Action Center” within the members-only section of the AIHA web page. The federal action center contains a tremendous amount of information and access, including all federal legislation of interest to AIHA. This includes access to legislation by subject matter, legislative text, current status of the legislation, and AIHA position. Next up: a State Legislative Action Center.

UL Teams With NEHA: The national IAQ standard from Underwriters Laboratories is apparently back in play. A recent news release announced that UL has officially joined forces with the National Environment Health Association to produce the standard and a National IAQ Standards Committee has been named with many familiar faces from the first UL IAQ workgroup.

Members include: Dr. Welford Roberts, University Health Sciences, Maryland; Dr. Ginger Gist, Agency for Toxic Substances and Disease, Georgia; Dr. Lawrence Betts, Eastern Virginia Medical School, Virginia; Wayne Morris, Association of Home Appliance Manufacturers, Washington, D.C; Alan Wozniak, Pure Air Control Services, Florida; Dr. Paul Cammer, Business Council on Indoor Air, Washington, D.C; Tom Dickey, National Environmental Health Association, Iowa; John DiFazio Jr., Consumer Specialty Products Association, Washington, D.C; Dr. William Field, University of Iowa, Iowa; N. Mike Gilley, Florida Dept. of Health, Florida; Charles Hart, Ohio University, Ohio; Tom Hart, Linn County Public Health, Iowa; Jack McGurk, Underwriters Laboratories, Calif.

The goals and objectives for the committee is to take UL initial effort to establish the report entitled, “A Process for Developing An Indoor Air Quality Standard.” The report provides UL recommendations for a shared vision, specific goals and objectives, and selected tasks. Finally, there is a recommendation for the process that can followed to develop an IAQ standard.

Mold Policy: The Joint Legislative Program of the National MultiHousing Council (NMHC) and the National Apartment Association (NAA) released their annual public policy agenda. Top on the associations' 2002 agenda is mold.

According to their joint statement, NMHC/NAA will continue to work both at the state and federal level to advance a legislative agenda on mold, which is reasonable and based on sound science. “While the public has become increasingly concerned about mold growth in commercial and residential properties, there are no existing federal statutes regarding mold and indoor air quality,” the statement says. “The U.S. Environmental Protection Agency itself has indicated there is insufficient scientific/medical data to establish guidelines for which molds cause disease and at what levels. NMHC/NAA will oppose the development of any mold exposure guidelines without a scientific basis for such standards.”

Clearing The Air in DC, NYC: Abatement Technologies Inc. of Duluth, Ga., has reported a significant increase in the demand for its IAQ remediation products in the areas near Ground Zero in New York City, and in Washington, D.C. A leader in the indoor air quality business since 1985, the company’s products are used by more than 5,000 HVAC, environmental abatement and mechanical contractors, and by more than 1,000 hospitals in North America alone, and in more than 50 countries world wide, according to David Shagott, Abatement Technologies’ president.

New CIE Trainer: The Chelsea Group Ltd. applied last month to become a Course Provider for the nonprofit Indoor Air Quality Association (IAQA). Once approved, Chelsea Group intends to begin teaching IAQA's Certified Indoor Environmentalist (CIE) course. IAQA officials say their approval is likely by next month, and their first courses on behalf of IAQA could be scheduled for the summer. Chelsea Group's instructor team is likely to include Barney Burroughs, Ed Cross, David Munn and others.

Radon Corner - NEHA Fine Tunes Proficiency Program

In an announcement last month, Larry Marcum, program manager for the National Environmental Health Association that operates the National Radon Proficiency Program, indicated that the program would be making improvements in the way people become certified as radon professionals.

Marcum cited concerns that individuals were attending educational programs and utilizing course attendance certificates as indications of their proficiency without having passed an exam or agreeing to follow protocols as is required of a person becoming certified.

After a considerable review of the radon credential that is a legacy of EPA’s former program and other environmental health credentials, the NEHA-NRPP program (as represented by the “Blueprint” presented at the National Radon Meeting in October 2001), needed refinement to bring its radon credential more in line with other successful credentialing programs. According to Marcum, the refinements are designed to “raise the bar” above the EPA program by improving educational programs and expanding the types of credentials available to radon professionals.

The largest change in the document was a commitment by NEHA to work with scientists, educators and state regulators in developing consistent classroom educational materials that will allow for a consistent delivery of entry level course material while integrating local state regulations and practices. Furthermore, the approach will include a mechanism to qualify and approve trainers (new and existing course providers) and a means to evaluate performance for maintenance of their “approved status.”

In essence, NEHA NRPP will facilitate the development of new curriculum in concert with existing reference materials efforts currently underway such, as the one by the University of Minnesota. It will make this curriculum available to trainers who are certified environmental trainers (NETA or equivalent) and grant them “approved status.” NEHA also intends to aggressively market the services of NEHA approved trainers. Furthermore, students planning to attend a NEHA approved training program will be required to sit for and pass an exam. A person passing the entrance exam will be issued a temporary certification, (provided they agree to follow protocols and industry accepted codes of ethics). That is, people will not be issued pass/fail letters as has been the case in the past, but rather a certification that they can use to demonstrate to states that they have not only received the training, but also demonstrated their knowledge by passing the exam and have agreed to follow protocols. The temporary certification will also allow students time to determine the devices they will be using before obtaining the full certification.

This approach will also provide a more complete and consistent service for individuals wanting to enter the radon field, through the NEHA approved training providers.

The revised Blueprint also reinforced the plan for adding new credentials in the areas of radon-in-water, large building surveys and mitigation, as well radon resistant new construction. For more information and the entire text of the announcement go to www.radongas.org.

Doug Kladder is program manager for the National Environmental Health Association’s National Radon Proficiency Program. You can reach him by calling (719) 477-1714 or by e-mail at dkladder@neha.org.

The catch phrase “mold is gold” has certainly proven true for organizations and companies in the mold remediation training and certification field. Thousands of individuals have flocked to mold remediation seminars and schools in the last twelve months. Two IAQ industry non-profit groups are already certifying remediators, and two others are expected to launch similar programs this year.

This article will review the mold remediation training and certification programs offered by the Indoor Air Quality Association (IAQA) and American Indoor Air Quality Council (AmIAQ). IAQA and AmIAQ have both sold-out every mold remediation training class scheduled in the last year. This article will also take a look at the forthcoming programs of the Institute of Inspection, Cleaning and Restoration Certification (IICRC) and the newly formed International Association of Mold Remediation Specialists (IAMRS).

Certified Mold Remediator
IAQA’s Certified Mold Remediator (CMR) program was launched in June 2001. Since its inception, more than 1,600 people have taken IAQA’s challenging, 130 question examination. About 1,200 have passed and were awarded CMR status. You have to score 70 percent or better to pass.

IAQA administers its certification examination at the conclusion of a 3-day training course. Courses are conducted by association-approved Course Providers operating out of California, Texas and Florida. Course Providers frequently take their training programs “on the road,” enabling IAQA to reach audiences around the country. To become a Course Provider, a training firm must pass rigorous pre-qualifications.

In addition to being the largest mold remediation certification effort, IAQA’s CMR program is also widely accepted and specified. Several major insurance companies look for CMR certification in their contractors. The restoration industry’s leading franchises have embraced CMR and advocate it for their franchisees. Hundreds of representatives from Servpro Industries, ServiceMaster, Paul Davis Systems, DUCTBUSTERS, and Blackmon Mooring Steamatic have been tested and awarded the CMR credential.

“For individuals working in the mold remediation field, IAQA CMR certification demonstrates the highest level of expertise. Not only are CMR professionals trained and tested, but they also must meet a 5-year experience requirement to be eligible to take the CMR exam,” said Tom Yacobellis, IAQA president.

Don’t Forget To Add The “S”
The American Indoor Air Quality Council offers a training and certification program for Certified Mold Remediation Supervisors (CMRS). Just as the AmIAQ credential title is close to that of IAQA, the two associations’ training and certification programs have many similarities as well.

AmIAQ requires two years of experience, “in a career relevant to the field of microbial mitigation and/or remediation,” to take the CMRS exam. Candidates must submit two project sheets that describe specific field experience in IAQ-related remediation projects.

The CMRS test consists of 100 multiple-choice questions. It was created by the CMRS Board and a candidate must score 70 percent or better to pass. AmIAQ currently has just over 400 Certified Mold Remediation Supervisors.

As with the IAQA program, AmIAQ’s CMRS training is conducted by association-approved course providers. The two providers based in Phoenix and San Diego limit their class locations to the desert southwest and California. A third course provider takes its classes on the road, with Atlanta, Austin and Syracuse on the 2002 course calendar. A New Jersey-based course provider will hold its first mold remediation class for AmIAQ this spring.

AmIAQ has been successful in attracting attention from insurance companies who use the association’s list of CMRS for project referrals and claims work.

Adding Sewage To The Mix
In February, the Institute of Inspection, Cleaning & Restoration Certification (IICRC) completed development of its Applied Microbial Remediation Technician (AMRT) and Applied Microbial Remediation Specialist (AMRS) certification programs. The next phase before program launch is instructor training.

The IICRC training and certification programs are unique in that they include a component on sewage remediation. Many of IICRC’s traditional supporters come from the professional fire and water restoration industry, where a credentialing effort for sewage disaster work has been needed for some time.

Obtaining AMRT or AMRS certification will be a multi-phase process building on other IICRC certifications. To achieve AMRT certification, a candidate will have to take a four-day IICRC-approved course and pass a written examination. In addition, an AMRT candidate must have IICRC Water Restoration Technician certification. To obtain AMRS certification, all of the requirements of AMRT apply, plus candidates must have a year of field experience; must complete one of several IICRC-approved safety training programs; and must verify field experience in mold remediation equating to at least 10 separate projects or 1,000 hours of work.

IICRC expects the first AMRT and AMRS courses to take place by summer. The pre-requisites are sure to keep program quality very high, but may also limit the number of eligible candidates.

Mold Remediation Only, Please
The International Association Mold Remediation Specialists (IAMRS) was founded late last year by Bob Allen. Allen’s company runs a “mold remediation boot-camp” training program. The association was created as a result of demand from boot-camp students who wanted to see an association entirely dedicated to the field of mold remediation.

Allen told IE Connections that 658 students have been through the boot-camp and have received certificates of completion. There is no pre-requisite to attend the four-day class, and all attendees get the certificate.

IAMRS will launch its Master Mold Remediator (MMR) certification program sometime this year. To achieve certification, a candidate will have to pass a written exam and meet eligibility requirements that include education, training and job experience.
For more information: American Indoor Air Quality Council: www.iaqcouncil.org, Indoor Air Quality Association: www.iaqa.org, International Association Mold Remediation Specialists: www.iamrs.org, Institute of Inspection, Cleaning and Restoration Certification: www.iicrc.org