CRI Hosts Dialogue On Carpet, IAQ And The Effects In School Buildings

An influential group of IAQ leaders, school officials, health professionals and government representatives attended the "Forum on Indoor Air Quality" organized by the Carpet and Rug Institute (CRI) last month at the Ronald Reagan International Trade Center in Washington, D.C.

The forum had heavy emphasis on indoor air quality and the increasing rates of asthma and allergies in children. School buildings were a main topic of conversation in what was billed by CRI as, "a substantive dialogue about indoor air quality and carpet."

The event began with a welcome by Werner Braun, president of CRI. Braun explained that CRI began addressing IAQ in 1990, when it participated in the Indoor Air Quality Interdisciplinary Forum organized by EPA. At that time, CRI's main indoor environmental focus was on VOC reduction. Standards for VOC levels were created that addressed carpets, adhesives and padding. "VOC level standards have been reduced twice, and a third decrease is coming soon," Braun said.

With the VOC issue behind them, Braun pointed out that mold is the largest IAQ concern for CRI today. "We are committed to finding out carpet's role in the mold problem and correcting it," he said. He added that as with the VOC issue, research and education were keys to tackling the mold issue.

Next the forum attendees heard from four guest speakers organized by CRI. They included: Dr. Alan Hedge, an expert on indoor environments from Cornell University; Dr. Scott Schroeder from the Pediatric Pulmonology Department of the Montefiore Medical Center; Dr. Michael Berry, a researcher and consultant on cleaning and IAQ from the University of North Carolina; and, Mr. Jude Anders, manger of product marketing for Johnson Controls.

Dr. Hedge shared statistics gleaned from research by an engineering society on America's schools. According to the study, the average age of a school in the U.S. is 40 years, and 75 percent of schools need repairs. Of those needing repair, the average school needs $2 million in work.

Aging structures, poor construction, and inadequate maintenance all contribute to the IAQ problem, according to Hedge. He characterized the HVAC system as among the biggest problems associated with poor IAQ, due its ability to serve as both a source and a pathway for contaminants. Add to that high occupancy, diverse activities, and a myriad of pollutant sources, and Hedge says it's no wonder that today's schools are notoriously unhealthy indoor environments.

With respect to floor coverings, Hedge said they could be pollutant sources, sinks and safes. A source is something that emits contaminants. A sink is a reservoir for pollutants, and a safe traps contaminants.

Carpeting may emit 160 different VOCs, but are measured at trace levels. Hedge's research shows that VOC levels from carpets are much lower than those of paint, floor adhesives, wall coverings and other indoor materials. Further, the VOC emissions from new carpet decay rapidly to trace levels after 148 hours. As a further defense of carpets, Hedge reported that EPA studies and other research in the 1990s failed to show adverse effects on animals from new carpet VOC exposure.

According to Hedge, toxins found in carpet never come from carpet, but rather originate from other sources. Often these contaminants get down to the padding level and aren't removed by vacuuming or other normal cleaning activities. In this instance carpeting acts as a safe, trapping contaminants and removing them from circulation within the environment. Hedge said that most contaminants associated carpet are those re-circulated by vacuums with inferior filtration.

With respect to the mold issue, Hedge's research on fungal growth and floor coverings shows that microbes grow far more readily on a smooth covering than carpeting. He cited research by AQS that demonstrates replacing floor coverings does not usually affect indoor airborne biological concentrations.

After Hedge's presentation, which was fairly passionate in its defense of carpet, a doctor representing the American College of Allergy, Asthma and Immunology posed a few questions. "You characterize the VOC problem as insignificant, but what about VOC exposure to sensitive individuals and children? Studies of carpet say allergic or asthmatic symptoms do occur," said the ACAAI representative. Hedge acknowledged the validity of the comment, but responded that the problems being described are not caused by carpet, but rather by the installation process and the use of glue and adhesives. Hedge said that regardless of how safe a particular brand of carpet might be, improper installation could lead to legitimate health issues.

The doctor speaking for ACAAI also challenged Hedge on the mold issue. "You cannot deny that carpet is a major reservoir of mold, dust mites and allergens," he said. But Hedge held firm with his position that mold growth is not a problem in carpet. He said that when mold growth does occur, it is always a function of moisture intrusion. "Clean, dry carpet does not support mold growth," he said.

Another presentation that drew a lot of attention and fostered good debate was Dr. Michael Berry's talk, titled "Managing School Environments." He boiled it all down to "dry and clean," adding that most IAQ problems would disappear if building construction and operation prevented moisture intrusion and if janitorial activities were more effective.

The first step toward correcting unhealthy school environments is understanding school building dynamics. "There needs to be widespread awareness of how the school building functions," Berry said. "The lack of awareness is creating poor environmental conditions. A training process should start to inform students, faculty and general personnel." As proof of the lack of understanding, Berry showed a slide presentation documenting faulty building construction and maintenance practices in some of North Carolina's most prestigious high schools.

According to Berry, preventing moisture intrusion is paramount. "Moisture in schools is the main cause of structural damage and health risks," he said. Simply constructing schools without flat roofs would alleviate a significant portion of the problem.

Other key elements to maintaining a healthy school environment include repairing mechanical and ventilation systems, establishing a structured mold remediation program, and building a cleaning effectiveness program for janitorial personnel with state-of-the-art equipment and training.

After the four panelists spoke, the floor was opened for an hour of general discussion. While only a few participants joined the discussion, some interesting points did come out. Glenn Fellman, executive director of the Indoor Air Quality Association, noted that while the group assembled for the forum included most of the major players in the IAQ and health arena, one major group was conspicuously absent - the cleaners and restorers.

"We've heard over and over again today about how important cleaning and maintenance are to a healthy school environment, but why aren't the cleaners and facility managers here today?" Fellman asked.

Werner Braun agreed with Fellman's statement, but said CRI recognizes the important role that cleaners play in IAQ. He told the forum about training and education programs that CRI is conducting in cooperation with the Institute of Inspection, Cleaning and Restoration Certification (IICRC).

If it were up to Charlie Norwood, congressional representative to the 10th District in Georgia, he'd strip the "government" right out of the American Conference of Governmental Industrial Hygienists. In a strongly worded letter to U.S. Secretary of Labor Elaine Chao written on May 23, Norwood urges the Department of Labor (DOL) to take nine separate actions designed to limit the ability of government employees to take part in ACGIH activities.
Norwood's letter comes on the heels of a failed lawsuit by the Refractory Ceramic Fibres Coalition (RCFC) against ACGIH. The manufacturers sought a temporary restraining order that would have barred ACGIH from publishing a TLV of 0.2f/cc for refractory ceramic fibres (RCF). RCFC's complaint argued that ACGIH acted as a quasi government agency and that its TLVs were standards set without proper procedure.

The court ruled in favor of ACGIH. The court said it did not appear the ACGIH was a quasi government agency or that the TLVs were standards. The court believed ACGIH had the right to publish the RCF TLV and refused to grant the temporary restraining order requested by RCFC.

One of the three RCF manufacturers who constitute the membership of RCFC is Thermal Ceramics Inc. of Augusta, Ga. No mention of the RCFC vs. ACGIH case was mentioned in Norwood's letter, however, ACGIH speculates, "since this letter came from a Congressman in the same state as some of the plaintiffs in our lawsuits and since that Congressman has never contacted ACGIH directly, we can only assume that the letter was written at the behest of some of these plaintiffs."

Among Norwood's allegations are that ACGIH's TLVs lack scientific basis; that ACGIH is not a private group; that DOL controls or directs ACGIH; that ACGIH acts in secret without public input; and that ACGIH is a Federal Advisory Committee. To combat these problems, Norwood asks DOL to take the following actions:

• "Revoke the TLV incorporation by reference in the 'interim' MSHA HazCom Rule.
• "Propose to revoke the OSHA HazCom Rule ACGIH incorporation by reference.
• "Prohibit Department expenditures to support participation in any ACGIH activities by Department employees.
• "Prohibit DOL direct or indirect employees from serving on the ACGIH Board of TLV committees.
• "Prohibit enforcement based on ACGIH TLVs, either under OSHA General Duty Clause or any other ASHA or MSHA standard.
• "Act to prevent indirect support of ACGIH through the unnecessary or excessive purchase of ACGIH TLV books.
• "Prohibit the use of state grant funds to sponsor ACGIH activities, memberships or the purchase of TLV books.
• "Prohibit the indirect support of employee travel to ACGIH meetings through the scheduling of concurrent Department meetings; and,
• "Require Department employees engaged in ACGIH or activities to conduct such activities on personal time, rather than Department time, and without the use of Department equipment, telephones or facilities."

Norwood's letter sent shockwaves through last month's American Industrial Hygiene Conference and Exposition (AIHCE), co-produced by ACGIH and the American Industrial Hygiene Association. But the timing of the letter also allowed ACGIH's 4,200 members and the 10,000 conference participants to rally their troops and plan a defense.

In a June 12 letter to Elaine Chao, ACGIH Chairman Scott Merkle asks DOL to defer "all consideration of Mr. Norwood's requested actions" until she can meet with ACGIH and the society's legal counsel. Meanwhile, ACGIH has posted a sample letter on their website with a plea for industrial hygienists and other professionals serving to protect worker health and safety, to write their congressional representatives in defense of ACGIH and the TLVs.

ACGIH has also taken on the individual allegations made by Norwood. IE Connections has obtained a June 13 letter from ACGIH Executive Director, Dick Strano, in which Norwood's claims are disputed one by one. The following excerpts are made available exclusively to IE Connections readers:

"Mr. Norwood claims that the TLVs are 'highly controversial because of their apparent lack of scientific basis.' In fact, the TLVs are developed by some of our nation's outstanding experts as well as experts from other countries. And each TLV is accompanied by a published list of all the scientific studies used to determine the specific TLV. A library of these Documentations is kept at ACGIH headquarters and is available to anybody, whether or not a member of ACGIH, who wishes to obtain a copy. A copy of a single, typical Documentation can be obtained for between $20 and $50, which represents ACGIH's cost for the documentation.

"It is alleged that ACGIH TLV actions, 'are often based on input, requests and/or participation by Department of Labor employees who serve on the ACGIH Board and/or the ACGIH TLV Committee and Subcommittees.' In fact, DOL employees who serve on the ACGIH Board and its committees act in the same way as DOL employees who may be active in other groups such as the American Bar Association, the American Medical Association, and the American Dental Association. These individuals volunteer their time in the interest of science and the professions they represent. From 1970 until the present time, on average, fewer than 10 percent of the members of the TLV Committee were employees of DOL or any other subdivision thereof. During the same time period, on average, fewer than 12 percent of the members of ACGIH Board were employees of DOL or any other subdivision thereof.

"It is alleged that ACGIH, 'Acts on the TLVs in secret, without criteria to govern the basis for TLVs, without public input, without judicial review and without accountability to the taxpayers.' This is simply untrue. As set forth above, proposed TLVs are put out for public comment for about one year, and sometimes for a longer period, before they are adopted. In addition, the Subcommittees uniformly seek outside input during their processes of investigation and deliberation. Subcommittee proposals are reviewed by both a full Committee and by the Board of Directors in the form of a proposed TLV, and then again in final form. As a private organization, ACGIH's TLV guidelines are not subject to judicial review, and ACGIH is not accountable to taxpayers any more than are other organizations such as the American Medical Association, the American Dental Association, the American Bar Association and innumerable other private groups which promulgate guidelines or recommendations.

"OSHA's ability to use the TLVs has already been considered by the Courts, and the United States Court of Appeals for the 11th Circuit has recognized that the TLVs are certainly something that OSHA can consider in the development of its own standards, although clearly OSHA is required to develop standards based on the requirements of the Occupational Safety and Health Act rather than the criteria of a private organization.

"It is alleged that DOL personnel enlist ACGIH to develop standards. In fact, ACGIH does not develop standards and affirmatively states that its guidelines are not to be used as standards.

"Finally, Mr. Norwood states that ACGIH is operating as a federal advisory committee without complying with the Federal Advisory Committee Act. It is ACGIH's position that it is not a federal advisory committee, and this issue is presently being litigated by both ACGIH and DOL as co-defendants in a matter now pending in the United States District Court in Macon, Georgia."

Whether or not Norwood's letter elicits any action by DOL remains to be seen. In the meantime, however, it has placed additional burden on the already strained resources of ACGIH.

In addition to the RCFC case, the organization has been forced to defend itself in two additional lawsuits in the last year. The extra expense necessitated the establishment of ACGIH's first legal defense fund. Contributions may be made online through the organization's website. Nearly 200 people and organization have lent financial support - including a fair number of DOL and OSHA employees.

New Test Method Is Valuable Tool For Mold Remediation
By David Krause

PROBLEM: A building owner is faced with a costly mold remediation and their consultant specifies that the remediation contractor demonstrate that the remediation, cleaning and abatement efforts are effective. Traditional analytic methods to detect fungal contamination require laboratory time and will prolong the project. How can we achieve a balance between the client's post remediation specifications and the contractor's time and costs?

SOLUTION: The MycoMeter-test^TM system. This new field test method enables wipe samples to be analyzed on site with results available within an hour. Project management decisions can be made using these stat sample results which indicate the degree of fungal contamination on surfaces. Instant information is available to maintain continuity of the project and to direct the contractor toward meeting remediation specifications by identifying which surfaces have been sufficiently cleaned of fungal contamination and which surfaces require re-cleaning.

Sounds to good to be true? As a practicing IAQ consultant my first thought was "sounds intriguing," but tell me more about the specifics." This tool is exactly what I had been looking for in my practice. I oversee mold remediation of buildings and provide the client with specifications for remediation and clearance testing of remediated surfaces.

The ideal sample collection and analytical methods for post-remediation evaluations should be able to provide immediate results that inform the remediation contractor if the surface meets clearance criteria. The analytical method should be specific to fungi and sensitive to the low levels present after remediation. The method should be capable of detecting all types of viable and non-viable environmental fungi. The sample collection method should be fast and easy without the need of expensive equipment or extensive training. The analytical method should have a low cost per sample and deliver interpretable results.

Developing clearance criteria required consideration of the myriad of sample collection and analysis methods available. My experience in building diagnostics led me to be cautious when interpreting air samples for viable fungi as they are often a misleading indicator of surface contamination. Many times air sample results were acceptable while evidence of contamination was later discovered; massive fungal growth visible throughout the HVAC system, inside wall cavities, or in carpeting. The ability of air samples to indicate the efficacy of surface decontamination is limited. It is recognized that many factors influence spore production and release, including the varying ability of fungi to grow on the culture media used to analyze samples.

Measuring a reduction in air concentrations of viable mold, or total fungi, does not mean that sources of fungi in the building have been substantially mitigated. The best approach to measuring the efficacy of fungal remediation efforts is to sample the surfaces after cleaning and measure the amount of fungal contamination remaining.

In adopting this approach, I turned to the use of adhesive tape lift samples and vacuum collection methods. While this approach brought the clearance sampling closer to answering the direct question of whether or not the surface was relatively free of fungal contamination, it was laborious and required a highly trained microscopist or microbiologist. After samples were collected they had to be shipped to a laboratory where they were analyzed. In addition, it was next to impossible to get the lab to report semi-quantitative results. While these methods provided more information than the less reliable air samples, they were still not meeting the need for a fast method capable of detecting mold contamination.

How The MycoMeter Fits Into Mold Remediation

The MycoMeter-test^TM method quickly delivers sample results that can be used in clearance of indoor environments after mold remediation. The primary role for the MycoMeter-test^TM is to sample surfaces after mold remediation to determine the remediation efficacy. After duct cleaning, coil cleaning, or mold removal from wooden structures and gypsum drywall, the MycoMeter-test^TM can determine the amount of fungal mass remaining.

Tim Hebert, president of Air Purification Specialists Inc. in Pavo, Ga., has been the remediation contractor on several projects where the MycoMeter-test^TM method was used in the clearance sampling protocols. In his own words:

"Our experience with the MycoMeter^TM as the final clearance methodology for HVAC systems and mold remediation projects has been excellent," Hebert said. "This sampling method provides for a thorough on-site analysis of remediated surfaces. One of the benefits is the quick analysis turnaround time during the work shift. This allows for increased quality control and minimizes any time spent on re-cleaning an area. Our goal is to perform the work right the first time. This sampling method documents the diligent efforts of our technicians and provides them with a 'Well done' on the same day the work is performed."

Prior to the beginning of a mold remediation, the MycoMeter-test^TM can be used to delineate the surface areas and building systems with fungal contamination. Since the fungal contamination can often extend for several feet beyond the visible colonies, the IAQ consultant can empirically determine the limits of necessary remediation. These sample results can then be used to define the scope of work for the remediation contractor. In this manner, remediation projects can be well defined and a substantial reduction in change orders should result.

Another use for the MycoMeter-test^TM is to determine the efficacy of contractor cleaning efforts by conducting a test clean. Having a remediation contractor perform a test clean before bidding a project enables the contractor to deliver more realistic price estimates and also tells the building owner whether the cleaning methods being applied actually remove fungal contaminants. This approach will prove invaluable on larger projects where the cleanability of materials is in question.

Finally, the MycoMeter-test^TM has a use in the diagnostics of fungal contamination in indoor environments by allowing consultants to make on-site determinations of fungal growth, but cannot be used to test for hidden mold damage. The ability of the MycoMeter-test^TM to demonstrate the presence of active fungal growth on building and HVAC surfaces enables the consultant to advise clients on appropriate actions. No other single test method enables the consultant to determine if mold is actively growing on the surface in question. It must be recognized that high levels of fungal growth from bulk samples is only an indicator of active fungal colonization, not a direct measure of active growth. Once a bulk sample is cultured onto agar media the viable material can grow and produce colonies. Many factors impact the ability of the fungi to grow on the media including the presence of necessary nutrients, environmental conditions and competition with other organisms.

Some Limitations

Readers must recognize the limitations of the MycoMeter-test^TM method as well as its usefulness. The method does not speciate or even identify the types of fungi in the samples. If it is necessary to determine the species of fungi causing building contamination then more traditional methods should be employed. The current trend in mold contamination diagnostics is to treat all molds as potential hazards and remediate growth sources with the same care. This trend is evidenced by the revisions to The New York Department of Health Guidelines on Assessment and Remediation of Fungi in Indoor Environments that no longer focuses on specific fungal species, but has become inclusive of all fungal species.

According to Hebert, "All sampling methodologies should be viewed in light of their strengths and limitations. This methodology should be seriously considered by any consultant or contractor interested in staying at the top of this industry."

Since meeting with the inventors of the MycoMeter-test^TM, I have used it in side-by-side comparisons with adhesive tape lift clearance samples in the oversight of five mold remediations and found that the outcomes were comparable. Since January 2001, in over 95 percent of the samples, I have collected in the course of these mold remediations, the decision to fail or clear a remediated surface would have been the same regardless if the tape-lift or MycoMeter-test^TM method were used.

I am so impressed with the MycoMeter-test^TM performance that I am now working with the inventors to distribute and provide training on the system here in the United States. The purpose of this article is to introduce the availability of this new field test method and to discuss the impact that this analytic method is likely to have.

The Method

The MycoMeter-test^TM was developed by MycoTec ApS of Copenhagen, Denmark, which is not associated with Mycotech Biological Inc. of Jewett, Texas. All sales of test equipment and sample kits are through U.S. distributors though, including this author. The test equipment consists of a specially made fluorometer, sample holding racks, timer, calibrated pipette, and travel case.

The MycoMeter-test^TM method is a patented method based on detection of an enzyme activity present in all molds. Molds produce this enzyme during their growth cycle and the enzyme is present in both spores and hyphae.

In order to collect and analyze each sample, a MycoMeter-test^TM Kit is required in addition to the MycoMeter-test^TM Equipment. The Test Kits are sold in multiples of 20 and consist of:

Sample Collection Materials

• Cotton swabs in sterile, sealed containers
• Self Adhesive Templates with a defined area
• Tubes containing sterile saline Sample Analysis Materials
• Tubes containing enzyme substrate
• Tubes containing solvent
• Cuvettes
• Tubes containing developer
• Pipette tips

Surface samples are collected by washing or rubbing a defined surface area with a moist sterile cotton swab. This method of collection is also described in the ACGIH's Bioaerosols Assessment and Control, Chapter 12, section 2.2.2. The samples are prepared for analysis using a simple extraction procedure and transferred to a cuvette for reading in a device known as a fluorometer. Fluorometers have been used for many years to measure the contaminants in environmental samples including aflatoxins, cyanobacteria and petroleum pollutants.

For An Introduction to Fluorescence Measurements see www.turnerdesigns.com/t2/doc/appnotes/998_0050/0050_c1.html.

The swab samples can be analyzed on site or transported back to a laboratory area for analysis. While it is recommended that samples be analyzed immediately, they can be held at room temperature for several days without significant alterations in fungal enzyme activity as long as the tube is kept sealed. To prevent amplification of fungi on the swab during transport a biostatic additive is present in the wetting agent supplied for the swab.

The amount of enzyme activity present in the sample is determined by the use of a synthetic substrate. When this substrate is cleaved by the enzyme a fluorogenic compound is released. The amount of fluorescence formed is proportional to amount of mold (biomass density) in the sample. Since the sample is always collected from a defined surface area the results are related back to the mass of fungi per surface area.

Interpretation Of Sample Results

The MycoMeter-test^TM is a quantitative method with the results divided into three categories based on the mold biomass density on the surface. 

Category A (MycoMeter Values of 25 or below) indicates the level of deposited mold spores is not above normal background levels. Post-cleaning sample results above Category A are not considered acceptable for clearance criteria. Studies conducted in Danish buildings without mold problems found that surfaces free of visible dust or dirt consistently resulted in MycoMeter Values of 25 or below in all samples collected (n=101 samples). Samples having a MycoMeter Value of 25 or less are not sterile, but indicate that very low levels of mold may be present.

Category B (25 < MycoMeter Value £ 450) indicates the level of mold is above normal background levels. These sample results can indicate an accumulation of spores on a surface or old, dormant, desiccated mold growth. Therefore, if Category B results are encountered during the delineation of a mold problem it is recommended that adhesive tape lift samples be collected to determine if fungal hyphae are present. To determine this range of values samples were collected from a variety of surfaces ranging from slight visible accumulation of dirt and dust to heavy accumulation of debris. About 96 percent of these samples resulted in a MycoMeter Value of less than 450.

Category C (MycoMeter Values >450) indicates the level of mold is high above normal levels due to active growth. Samples with MycoMeter Values above 450 have been determined to be indicative of a high fungal biomass density, and present only when active fungal growth occurs.

Limitations And Costs

The MycoMeter-test^TM method does not determine if a sample contains toxins or toxigenic fungi. Since the method is sensitive to the specific mold enzyme activity, it does not detect the presence of yeasts, bacteria, actinomycetes or other microorganisms. These organisms generally do not produce this enzyme. The only exception is that some bacteria produce this enzyme when growing along with fungi. This situation is only expected to slightly increase the MycoMeter-test^TM response to a sample already heavily contaminated with fungi.

The cost of analyzing each MycoMeter-test^TM is slightly higher than direct microscopic examination of adhesive tape lift samples. If shipping, material, and rush service costs are considered the cost per sample of the MycoMeter-test^TM method is comparable. The value of fast sample results must also be considered when determining if the MycoMeter-test^TM method is best suited for each application.

The cost of the MycoMeter-test^TM Equipment is comparable with other test equipment commonly used in IAQ diagnostics and includes the required training for operation of the equipment.

David Krause is president of Indoor Air Solutions in Tampa, Fla., a indoor air quality consulting firm he founded in 1997. He has specialized in the areas of public health, toxicology and indoor air quality since 1990. From 1990-1994, Krause served as an officer in the U.S. Army, Europe, where he was responsible for environmental and occupational safety for hazardous materials transportation. From 1994-1997, he was the Industrial Hygienist/Indoor Air Quality Programs Coordinator for the Florida Department of Health. He established the Florida Indoor Air Assistance Program, which provided IAQ response services to more than 4,200 clients per year through County Health Departments. Krause has served on numerous committees to determine the impacts of indoor air pollution, including the National Air and Radiation Indicators Project (NARIP) sponsored by EPA and the Florida Report on Indoor Air Quality (HB 251). You can reach him by calling (813) 792-9566 or by e-mail at dkrauseiaq@msn.com.