California Gets Mold Bill Changes From Industry Pros

While environmental contractors and consultants are attending mold remediation training and certification courses in droves, it may all be for naught in California if the current version of the legislation is finalized as currently amended.

Several amendments were recently made to California Senate Bill 732, the "Toxic Mold Protection Act of 2001," which would eliminate the need for professional microbial sampling or remediation services. The legislation itself would require the state Department of Health Services (DHS) to develop standards for the identification and remediation of molds, and includes a written disclosure notice for mold in the sale or rental of residential, commercial or industrial property.

To voice his opposition to the new amendments, Edward Cross, an indoor environmental attorney in Santa Ana, Calif., spearheaded late last month the "SB 732 Strategy Team," who put together an urgent memorandum to Senators Deborah Ortiz and Sheila Kueh, Assemblywoman Rebecca Cohn, Assemblymen Alan Lowenthal and Simon Salinas, and Ana Matosantos, a staff representative for the Senate Health & Human Services. IE Connections participated in the rewriting of the memorandum, and is listed among the 55 members of the SB 732 Strategy Team.

In a letter written to the Sacramento Bee newspaper last month, IE Connections Publisher Susan Valenti took an official stand against the "no pros" amendments, saying, "Sen. Deborah Ortiz is sacrificing the health of California residents with consumer-protection legislation that caters to big-money special interests."

The amendments in questions occurred on July 5:

They are:

• 26131(a)(7) (...mold Remediation Standards shall not require...a specially qualified professional to conduct the mold remediation); and
• 26140(c) (...landlord shall not be required to conduct air tests of units or buildings to determine whether the presence of molds exceeds the PEL's).

Another revision made on July 18, 26105(d) now states that "A certified industrial hygienist is qualified to conduct a mold assessment," was not included on the SB 732 Strategy Team memorandum, but Cross opposed it in a separate e-mail to Matosantos.

In an e-mail sent to Cross and copied to SB 732 Strategy Team members, Matosantos said that "Sen. Ortiz is aware of the concerns voiced by other parties and yourself regarding language in SB 732 about testing and who can conduct mold remediations. The Senator has been working with the Department of Health Services, Alex Robertson, tenant rights groups, industrial hygienists and many affected industries to address concerns about the language regarding requirements to conduct testing, the use of professionals to conduct remediation and several other issues identified."

She added that Sen. Ortiz would consider any specific language that the Strategy Team would recommend and will share with any new amendments that are developed. The memorandum provided new language for both July 5th revisions to balance fiscal concerns with consumer protection.

SB 732 is currently in the California legislature's Appropriations Committee. Matosantos said the any changes made to these provisions would be reflected August 20th at the earliest.

The American Industrial Hygiene Association (AIHA) has broken their silence on the issue of microbial growth and recently released, Report of Microbial Growth Task Force. The 63-page document represents work since 1997 that, according to task force chair Donald Weekes, contains "what's going on in the industry" regarding mold.

The document contains a "majority opinion" held by 12 industry experts, and also a "minority opinion" by Coreen Robbins. Focusing on the minority report, Edward Light of Pathway Diagnostics told AIHA IEQ Committee members at their June meeting that he agreed that there is a misapplication of sampling in today's mold projects, and more assessment of health complaints must be done. He urged the IEQ committee that guidance on microbial assessment was needed and it should be prepared by AIHA. Besides commenting on the intentions of the document and the peer-review process, Robbins points out that AIHA should be "taking a leadership role in the development of [mold] policy, emphasizing science-based risk assessment." She also addresses the issues not featured, including: interim control measures for mold, who is qualified to perform mold remediation, and health effects from mold exposure.

The majority opinion is the closest thing the industry may ever have to a blueprint for future microbial growth standards. Task force members reviewed current guidelines, identified information gaps, and provided discussion and recommendations on the current guidance as well as to try to fill in the information gaps with expert opinion.

The document covers 11 questions selected by the task force:

1. When should microbial found in occupied buildings be remediated?
2. What amount(s) of mold should indicate what degrees of remediation?
3. What remediation methods should be used?
4. Should biocides be used in remediation?
5. Under what circumstances should buildings be evacuated and work areas isolated?
6. How should remediation work areas be isolated?
7. How should water-damaged content items be treated?
8. What quality assurance principles should be followed to ensure that mold remediation is successful?
9. What PPE are recommended during bioremediation?
10. Is personal air sampling appropriate to determine worker exposure during mold remediation
11. What medical evaluation is recommended for remediators?

As an example to the type of information found in the report, IE Connections provides you with the task force response to question two on what amount of mold corresponds to the degree of remediation. The task force states:

"The question of whether density and extent of fungal growth should be factors in indicating the need for remediation has not been answered. However, the Task Force did agree that density and extent of growth determine the degree of remediation and the containment procedures during remediation.

"The question of whether material (e.g., the inside of a wall) contaminated with fungal propagates should be an indicator for remediation has not been answered."

The report is SN 458-EQ-01. The price for AIHA members is $12 and the non-member price is $15. You can call AIHA Customer Services at (703) 849-8888 to place your order.

Flooring Specifications Can Improve School IAQ
By Tom Ellis

Achieving good indoor air quality in America's schools is one of the most pressing issues facing school facility administrators today. According to the Environmental Protection Agency (EPA), poor indoor air quality (IAQ) ranks as one of the top five public health hazards in the U.S., and poor IAQ plagues over half of all U.S. schools.

Since flooring is not only a large financial investment for schools, but also plays a critical role in maintaining good IAQ, it is vital to implement the right choice. But as one indoor air quality professional noted, "there is a big gap between making IAQ flooring recommendations to school buying teams and getting recommendations implemented. Sometimes it just doesn't happen."

Why? As many IAQ professionals are discovering, to successfully implement IAQ recommendations, professionals need to translate recommendations into flooring specifications. Writing detailed specifications makes it easy for everyone to agree on the solution to IAQ. This, in turn, benefits the school district in lower maintenance costs, lower life-cycle costs, as well as an improved learning environment.

A Brief History

As most IAQ professionals agree, major indoor air quality concerns are:

1. Mold/mildew growth
2. Dust and air-born allergens
3. Volatile organic compounds (VOCs) from installation glues and cleaning supplies.

The proper floor covering can contribute to improved IAQ. The degree to which these indoor air quality problems can be controlled depends on the type of flooring specified. Three main types of flooring today are: vinyl composition tile (VCT), conventional carpeting (broadloom) and vinyl cushion tufted textile (VCTT).

Historically, VCT hard-surface flooring was frequently specified because of its lower initial cost. However, as educators learned more about the importance of the physical environment on the learning process, the use of VCT was questioned.

This hard-surface flooring escalates noise and creates glare from overhead lights and natural day lighting. In addition, concerns over the volatile organic compounds emitted from VCT cleaning products (for washing, stripping and waxing) have caused facility administrators to look for alternatives.

Conventional carpet (known as broadloom), by contrast, offered ergonomic comfort, noise and light control that VCT could not. However, conventional carpet-originally intended for home and light commercial use - frequently wore out in only a few years.

Although conventional carpet did not require high VOC-based cleaning supplies, the carpet developed mold and mildew because of its water-soluble "flow through" backing.

As a result, IAQ professionals have turned to a new hybrid flooring called vinyl cushion tufted textile or VCTT. This flooring provides the benefits required in a learning environment and a backing with the durability and water-impermeability required to improve IAQ.

First developed in the late 1960s, VCTT didn't attract much notice. IAQ was not a major concern, nor was the physical environment considered important in the learning process. However, VCTT technology has continued to evolve with advances in construction called "link engineering", and the VCTT category is gaining recognition for its ability to counteract poor IAQ. A "link-engineered construction" means that the parts - backing, surface nylon yarn with low and dense nylon construction and dry installation adhesive - are interlocked to provide a complete package for IAQ protection. Link Engineered VCTT offers an alternative to broadloom carpet and VCT.

Mold And Mildew

Floor backing is the primary defense against mold, mildew and fungal growth. In fact, the backing determines more than 90 percent of the flooring's overall performance.

For example, conventional broadloom carpet is made with water-absorbent, "flow through" latex backing. Regular cleaning and the humidity of school buildings - which exceeds 70 percent in many schools - can actively promote bacterial growth.

In comparison, only vinyl cushion tufted textile (VCTT) provides a wall-to-wall barrier against contaminants and moisture seeping through backing and fungal growth. In fact, the backing determines more than 90 percent of the flooring's overall performance.

For example, conventional broadloom carpet is made with water-absorbent, "flow through" latex backing. Regular cleaning and the humidity of school buildings - which exceeds 70 percent in many schools - can actively promote bacterial growth.

In comparison, only vinyl cushion tufted textile (VCTT) provides a wall-to-wall barrier against contaminants and moisture seeping through backing and seams - and does so without requiring an annual treatment. This is because VCTT seams are fused together at the time of installation or repairs. This backing system allows standing water to dry within 4-6 hours compared to over 10 hours with conventional broadloom.

By comparison, VCT requires constant maintenance with 5-7 layers of wax to provide water impermeability. Without constant maintenance, mold, mildew and fungus builds-up on VCT, as evident by the black lines between tiles.

Water impermeable backing:

To specify a water impermeable backing, IAQ professionals should consider the following:

• A closed cell vinyl cushion backing, which means that individual vinyl cushion cells are completely enclosed to provide an inherent barrier to contaminants and moisture penetration. All seams should be welded permanently at installation and when repaired.
• The closed cell vinyl cushion backing should be permanently fused to the tufted surface blanket. This attachment creates a permanent impermeable unit.

Moisture Penetration Tests: 

To ensure that flooring is moisture impermeable, specifications should call for three tests:

• The Moisture Penetration by Impact test requires the backing to withstand at least 10,000 impacts without moisture seepage.
• The Moisture Penetration by Impact test also evaluates the integrity of flooring seams, which must be able to withstand 10,000 impacts without any moisture seepage at the seam. Test one and two simulate the abuse floor coverings receive over their 20+ year life in corridors and high traffic areas.
• The Phillips Chair Caster test, insures that the backing will withstand at least 50,000 cycles of chair rolls at the seam without breaking down. This is the most brutal and punishing type of flooring test but is necessary to evaluate product integrity at thresholds, pivot points and funnel areas of a building where most products fail prematurely due to heavy traffic.

Moisture penetration case examples: While the tests listed above are excellent indicators of moisture impermeability, specifications should also request references from current installations. For example: Adlai Stevenson High School in Lincolnshire, Ill., in 1999 was flooded with thousands of gallons of water. While other area schools had to replace their flooring, the VCTT floor covering at Adlai Stevenson was cleaned with hot water extraction and remains in good form today. In another example, Roy Lee Walker Elementary School in McKinney, Texas, only a few days before its opening last fall, experienced a broken water pipe that flooded one of the main corridors. The standing water was removed and the VCTT cleaned with hot water extraction. The school opened on time and the flooring has continued to prevent the growth of any mold, mildew or fungus.

Dust And Airborne Allergen Control

More children are being diagnosed with asthma than ever before, according to the Centers for Disease Control and Prevention, that notes a 100 percent increase from 1980 to 1995. Asthma gets worse when IAQ is poor. Research shows that dust and particles (which aggravates asthma) are present regardless of the kind of floor covering installed. However, these allergens fall quickly to the floor and with normal school traffic on VCT and other hard-surface floors, allergens are reintroduced into the breathing zone.

VCTT flooring traps allergens within the surface fibers where they stay out of the breathing zone until they are easily removed by vacuuming or hot water extraction. Here, the surface yarn system makes the difference. While all soft-surface flooring yarns can hold allergens temporarily, unlike conventional carpet, the VCTT yarn construction is extremely low and dense to reduce the buildup of contaminants and keep them near the surface for easy removal. The impermeable backing also forces moisture to stay at the surface for easy extraction.

Specifying for long-term performance: The face weight of the yarn, its quality and tufting construction are critical. Type 6,6 nylon is the most advanced yarn system available today. It will provide 20-plus years of performance without crushing or breaking down when linked engineered to a water impermeable cushion backing.

Nylon type 6,6 performs best in a low pile height with a dense tufted construction (equal to or greater than 100 stitches per inch). Unfortunately, popular opinion has incorrectly associated high face weights (amount of yarn used) with better performance. In reality, as pile height increases, maintenance costs increase and product performance decreases. For example, yarn face weights of 20ozs.on VCTT provided 47 percent better soil removal than 26-oz. yarns on latex backings. The higher contamination removals translated into lower biological counts, as well as improved IAQ and maintenance control. Specifications should require face weights to be equal to or less than 20 ounces.

Eliminating VOCs

As most IAQ professionals know, schools are under increasing pressure to eliminate VOCs, particularly those from cleaning supplies and installation adhesives. VCT floors, which require stripping and waxing for warranty coverage, are particularly prone to VOC off gassing. In fact, the EPA recommends that when VCT floors are stripped and finished, buildings should remain unoccupied for at least 48 hours to allow sufficient time for off gassing.

By contrast, both conventional carpet and VCTT can be cleaned with hot water extraction - not only eliminating harsh chemicals, but also eliminating allergens, fungi and bacteria up to 99 percent, as measured in post-cleaning tests. However, because conventional carpeting has a "flow through" backing, it can require more than 10 hours to dry, leaving it prone to mold, mildew and fungal growth.

VOCs are also created with wet glues used to install VCT and conventional carpets. VCTT, on the other hand, can be installed without wet glues by using a " peel and stick" dry adhesive. Installation is fast; there is no off gassing from adhesive curing and no smell. Installation can occur while the building is occupied.

To reduce VOC emissions during installation and repairs, always specify a factory-applied microencapsulated tackifier for the backing. In addition, consult the state of Washington's IAQ protocol, which is among the nation's most stringent for IAQ standards. Incidentally, VCTT is the only floor covering to meet the protocol immediately upon installation. VCTT also measures 20 times less than the Carpet and Rug Institute's "green label" standards for off gassing by floor coverings with adhesives.

Further, IAQ professionals should always review the maintenance equipment and chemicals recommended by the flooring manufacture prior to recommending flooring systems.

Warranties To Protect Your Investment

Since most school's budgets are strained, the lower the maintenance costs the better. Floorings should be warranted for a high level of performance and appearance retention for a minimum of 20 years. In addition, all warranties should be non-prorated. As the term implies, non-prorated means that even if the flooring fails to meet any of these expectations, up to and including the last day of the 20-warranty, the entire floor covering is replaced free of charge. This is critical since many manufacturers only give pro-rated or limited warranties on their products. Unfortunately, VCT only carries a 5-year warranty. In the case of conventional carpet, most warranties are for 10 years and do not cover the issues most relevant to product failure. VCTT products are warranted for 20-years non-prorated and protect against zippering, de-lamination (backing pulls away from surface), edge ravel, excessive surface wear and loss of backing resiliency. VCTT products have proven to contribute to improved IAQ without failure even after 30 years.

Providing Client Value

Experienced IAQ professionals know that the IAQ plan should include life cycle costing. For example, the cost of maintaining flooring in a 90,000 square foot school over 20 years can vary substantially. While VCT has a perceived lower cost, on average, VCT - under normal maintenance conditions - costs about $94,500/year to maintain. A VCTT floor may have an initial higher installed cost, yet it costs less than $35,000/year to maintain. When considering this life cycle cost variance, one school official noted, "We are too poor to buy cheap."

Conclusion

IAQ professionals are facing a challenging and exciting future. School flooring decisions are not only one of the larger investments for new and rehab projects, but are also one of the most important for their IAQ impact. By learning how to develop workable flooring specifications, IAQ professionals are ensuring that they will become not only valued members of school planning teams, but will also profoundly impact the total learning environment quality for decades to come.

Tom Ellis is product manager for Collins & Aikman in Dalton, Ga. You can reach him by calling (800) 241-4902 or by e-mail at tellis@powerbond.com.