Unraveling The Training And Certification Tangle  

Contractors Toolbox - Remediation Using Dry Ice Blasting  

Word on the Street

• Voices: "Fruit flies are efficient 'scouts' that can detect the indoor air pollution sensitively. Maybe we can develop new products to monitor the indoor air quality by imitating their physiological mechanism."
  -Li Shuguang, dean of the pre-clinical medicine institute of Shanghai's Tongji University, on new research aimed at studying the impact of indoor pollution on humans
      
• Suit Extinguished: The U.S. Environmental Protection Agency's 1992 determination to apply its toughest risk assessment rating to environmental tobacco smoke has recently been upheld by a federal circuit court. Despite a decade of litigation from the tobacco industry, which in 2000 persuaded a district court in North Carolina that the EPA had moved improperly, it is likely now that the industry will not pursue further action against the agency. The risk assessment placed on environmental tobacco smoke classifies it as a Class A carcinogen, or a known human carcinogen. The EPA reports that it is pleased that its risk assessment will stand and that it should know this month whether the tobacco industry will appeal the federal circuit court's decision.
    
• New Mold Trainer: DeLisle Associates Ltd. of Kalamazoo, Michigan has been approved by the Indoor Air Quality Association as a Course Provider for the Certified Mold Remediator (CMR) training and certification program. Their first CMR course will be held April 7-9 in Kalamazoo. For more information, call DeLisle Associates at (269) 373-4500, or IAQA at (301) 231-8388, ext 14.
    
• Better Air In China: China's first regulation setting required standards for indoor air quality take effect this month. The regulation establishes a ceiling for 13 chemical pollutants including formaldehyde, benzene, ammonia and several harmful particulate matters. Official statistics show that as many as 111,000 Chinese die of indoor pollution annually. The number of patients suffering from excessive exposure to harmful chemicals in their newly-decorated homes reached 4.3 million last year, while annual economic losses resulting from indoor pollution exceeded 10.7 billion U.S. dollars. China has already enacted legislation regulating indoor environmental pollution and restricting the use of harmful chemicals used in building materials for indoor decoration.
        
  
• Spengler Honored: John D. Spengler of Harvard University's School of Public Health has been named a co-recipient of the ninth annual Heinz Award for the Environment. Together with 1995 Nobel Prize-winner Mario J. Molina of the Massachusetts Institute of Technology, he is being recognized for his groundbreaking contributions toward understanding the impact of air pollution on human health. The two, who join four other Heinz Award recipients, will share the $250,000 award.
    
  Spengler has played a pivotal role in raising public consciousness over health-related issues of indoor air quality. His initial work studying the exposures of commuters in Boston to air pollution led to his participation in the groundbreaking Six Cities Studies, which explored the environmental risks associated with sulfur dioxide and particle emissions from coal-burning power plants. The studies found a lethal relationship between particulate matter and cardiovascular mortality.
    
  Ultimately, Spengler and his colleagues found that indoor air pollution, such as cigarette smoke, nitrogen dioxide, and molds, had a tremendous impact on overall health. These findings contributed to outdoor air quality standards, and to the re-thinking about the sources of air pollution inside homes, schools, offices and vehicles.
    
  "The foundation behind my work has always been simple - creating a cleaner environment starts with cleaner air to breathe," Spengler said. "To be honored by the Heinz Family Foundation, which has itself been a staunch supporter of efforts to improve environmental health, truly affirms that indoor air pollution is a serious issue affecting all of us."
    
• Dust/Mold Connection: In a new issue of the journal Allergy, Columbia University researchers have found that dust and air samples could both be important in determining fungal exposure in the homes of allergic patients.
  Data collected by investigators from Columbia University and Harvard University did not indicate a strong overall relationship between culturable fungi in dust and indoor air. The researchers, therefore, say that the results of the two types of sampling likely represent different types of fungal exposures to residents.
  "It may be essential to collect both air and dust samples, as well as information on housing characteristics, as indicators for fungal exposure," the researchers said. They added that the type of housing and presence of carpeting were often predictive for dust fungi. Outdoor fungal levels often predicted indoor air fungal levels.
    
• Feds Go Green: The Ashkin Group, a Bloomington, Ind.-based consulting firm and national experts on green cleaning, recently nabbed a contract with EPA's Environmentally Preferable Purchasing (EPP) Team to develop a specific strategy to increase the purchase of environmentally preferable - or "green" - cleaning products and services for federal agencies. The project will be led by Stephen Ashkin, principal of The Ashkin Group, who has more than 20 years of experience in the cleaning chemical industry and chaired the task force that wrote the national cleaning standard, ASTM E-1971-98.

Mold Legislation
The media in Texas at the end of December would have you believe that mold insurance would be the hottest topic of the state's 2003 legislative session. Mold wreaked its havoc in Texas over the past few years, causing insurance carriers to double their rates in a matter of months in order to avoid further fiscal losses.

There's bad news for Texas policyholders, who currently pay more for their insurance premiums than anywhere else in the country: Keep holding your breath. Any legislative solution to this epidemic has yet to come.

At press time, the Texas Legislature has considered five separate bills dealing with indoor air quality issues. One bill introduced in both the State Senate and House of Representatives relates to IAQ in public school buildings. Another bill in both houses deals with mold testing in state buildings. One House bill concerns the development and implementation of IAQ programs in school districts. Two separate bills, one in the House and the other in the

Senate, outline different plans to regulate mold remediation.
Senate Bill No. 242 and its matching House Bill No. 473 are on IAQ assessments in schools. They would amend Chapter 385 of the Health and Safety Code to require schools to take an IAQ assessment before the 2005-2006 school year and every four years after that. House Bill No. 22 would amend Chapter 38 of the Education Code to require school districts to implement IAQ programs, complete with a coordinator and support staff who would determine standards, an operation plan and a budget.

None of these state mold bills have to do with insurance. It seems the Texas Legislature has thus far stopped short of dealing with the hot button issue of last year's elections and, incidentally, ranked No. 6 in the Austin Chronicle's "Top 10 News Stories."

Still, the State Senate has made some headway in presenting a thorough plan for the regulation of mold remediation and assessment. If adopted, this could save homeowners and building engineers the headache of fly-by-night remediation companies that do not know the first thing about remediation.

Mold Licensing Act
Weighing in at 30 pages, Senate Bill 129 has many facets attached to it. Known as the Texas Mold Remediation Licensing Act, it would add Chapter 1958 to the Occupations Code, to grant one-year licenses to mold remediators, assessors, analyzers and training providers. The bill also establishes civil, administrative and criminal penalties for operating without a license.

The bill names the Texas Board of Health responsible for establishing criteria for training necessary for licensing the companies and individuals practicing mold remediation, assessment and analysis. However, the training required for licensing would be exempted for the American Board of Industrial Hygiene's active certified industrial hygienists. The Consumer Specialty Products Association said it opposes this exemption and is actively working to amend the bill.

Under the bill, fees for applications and licenses would be set by the Texas Board of Health. The bill specifies that license fees may not exceed $600 for mold analysis, assessment or remediation companies or for mold training providers, $500 for mold assessment consultants or remediation contractors, and $300 for mold assessment technicians or mold remediation supervisors. The bill does not suggest an application fee. Licenses would be good for one year, after which time they would need to be renewed for an additional fee, again not specified. Those renewing expired licenses would be assessed a fee double the normal renewal fee.

Those holding mold-related licenses in other states must apply for a license in Texas before they can practice mold-related activities in Texas, according to the bill. Provisional licenses will be granted to those qualifying only if they have passed a recognized examination and are sponsored by a Texas license holder. (The Department of Health reserves the option to waive the sponsorship requirement as it sees fit.)

The Board of Health would adopt an examination that applicants are required to pass before they receive their applicable licenses. In addition, licensees must attend 15 hours of continuing education each year. These courses would be given by state-licensed mold training providers.

Several pages of the bill delve into some on-the-job responsibilities and standard operating procedures, as well as things to avoid. The Board of Health would be allowed to adopt rules to enforce a section of the bill prohibiting "advertising or competitive bidding … that contains false or misleading statements or that results in deceptive practices."

Under the bill, mold-related activities in a public building cannot legally begin - except in emergencies - until 10 days after the Department of Health has been notified in writing. The Board of Health would impose a notification fee, the amount of which is not suggested in the legislation.

Anyone found to be in violation of or threatening to be in violation of any of the act's provisions would be subject to a civil suit from the appropriate district, county or city. The maximum civil penalty would be set at $10,000 a day for each violation.

The state commissioner of public health would bear the right to assess administrative penalties to those violating any part of the act or rules adopted by the board, only after they have been given the opportunity for a hearing. Administrative penalties would not exceed $10,000 for each violation. Judicial review is available to those assessed administrative penalties, but they must either post bond or place the amount in an escrow account.

Violations would be considered misdemeanor offenses if convicted, and criminal punishments for first offenders would include maximum six months of jail time, maximum $20,000 in fines, or both. For subsequent offenses, the maximum fine would be $25,000, and the maximum jail sentence would be two years.

Senate Bill No. 129 does not currently have a counterpart in the Texas House of Representatives.

 On the other hand, House Bill No. 329 and Senate Bill No. 243 present a much more ambiguous procedure of mold assessment and remediation regulation. The identical bills leave many aspects of the licenses up to the state's health commissioner, board and department. Most of the language centers on penalties, which are generally less lofty compared to those recommended by Senate Bill No. 129.

State Bills Nationally
Overall, IAQ-related legislation has made a splash all over the country. In Connecticut, nine separate bills have been introduced, all dealing with school IAQ programs or inspections. Two of these bills introduced in January would provide grants to fund IAQ improvement projects in school buildings. Another Connecticut Senate bill would allow the state school construction program to reimburse schools for the cost of fixing air quality problems.

New Mexico's legislature has schools covered in one Senate bill that would require all schools to inspect their HVAC systems and test for radon and other chemical compounds affecting air quality every three years. In Rhode Island, a Senate bill calls for yearly IAQ inspections in all school buildings.

The New Mexico House of Representatives is considering a bill on IAQ programs in public buildings that would require both state and local boards to prescribe ambient air quality standards for air contaminants. This bill, No. 371, was passed Feb. 17 by the House committee on energy and natural resources and was sent to the judicial committee.
New Mexico and Texas are not alone when it comes to proposed legislation on IAQ programs in public buildings. They are currently joined in their efforts by six other states: Indiana, Massachusetts, Maryland, New York, Oregon and Washington.

Mold programs and remediation are currently being addressed in five states: Illinois, Michigan, New York, Texas, and Indiana. Identical measures in both chambers of the New York State Legislature call for a task force to determine whether setting permissible exposure limits for mold is even feasible.

Virginia's bill to determine exposure limits in occupational buildings died in the Senate on Feb. 21, less than three weeks after being passed by the Committee on Commerce and Labor.

An Indiana House bill directing the state health department to recommend toxic mold exposure limits to the legislative council has been referred to the Committee on Public Health. This action took place Jan. 23, and at press time, the bill has not moved since.

The Indoor Air Quality Association has begun a program to track state IAQ legislation. A matrix showing each state's proposals, a summary of the provisions, and the status, is maintained in the "members only" section of the IAQA website (www.iaqa.org). From the matrix, IAQA members can directly link online versions of each piece of pending legislation.

As a service to the indoor environmental industry, IAQA will provide a summary of pending state IAQ legislation at least quarterly in Indoor Environment Connections. The information supplied below is accurate as of March 3, 2003.

Mold Programs and Remediation

Illinois - HJR 12
Summary: HJR 12, is a resolution that creates a Joint Task Force on Mold in Indoor Environments, for the purpose of examining the mold issue in Illinois and making recommendations to the Illinois General Assembly pertaining to the regulation of mold in indoor environments in Illinois.
Status: Feb. 4 - Introduced; Feb. 11 - Referred to the Environment and Energy Committee

Indiana - HB 1856
Summary: IN HB 1856 directs the state department of health to make recommendations to the legislative council regarding toxic mold exposure limits. It also creates an 11 member task force to participate in the development of the recommendations.
Status: Jan. 23 - Introduced and referred to the Committee on Public Health

Michigan - SB 185 & HB 4094
Summary: MI SB 185 and HB 4094 would require the department of community health to convene a task force to develop permissible mold exposure limits for indoor environments.
Status: Feb. 13 - Introduced and referred to the Committee on Health Policy

New York - SB 896 & AB 4387
Summary: NY SB 896 and AB 4387 would require the department of health to convene a task force to help consider the feasibility of adopting permissible mold exposure limits for indoor environments.
Status: Jan. 23 - Introduced and referred to the Health Committee

Texas -- HB 329 & SB 243
Summary: TX HB 329 would establish a licensing system for mold assessors and remediators. Licensing requirements could include a test and continuing education requirements for license holders.
Status: Feb. 6 - Introduced and referred to the Licensing & Admin. Procedures Committee

Texas - SB 129
Summary: TX SB 129 establishes the requirements for issuing a mold remediation license program. This bill also establishes testing, fees, and other elements that must be approved and accomplished prior to the issuing a mold remediation license. This bill also exempts "certified industrial hygienists" from the licensing requirements.
Status: Jan. 29 - Introduced and referred to the Business and Commerce Committee; Feb. 27 & 25 - Public Hearing Scheduled

Public Building IAQ Programs

Indiana - HB 1704
Summary: IN HB 1704 would permit the state department of health to conduct indoor air quality inspections in all public buildings and institutions that are occupied by an agency of state or local government
Status: Jan. 21 - Introduced; Feb. 3 - Passed by the Public Health Committee; Feb. 13 - Passed by the House (97-0) and referred to the Senate; Feb. 24 - Referred to the Senate Committee on Health and Provider Services

Massachusetts - SB 1733
Summary: MA SB 1733 would establish a "Green" Building Income Tax Credit/Incentive Program. One element to qualify for such a tax credit would be to meet certain indoor air quality requirements established by the division of energy resources. Some of these requirements would include smoking restrictions, specific ventilation specifications, fresh air intake requirements, and other building requirements. This bill would also require inspections by a licensed professional engineer, or industrial hygienist for IAQ to qualify for the tax credit.
Status: Jan. 1 - Introduced and referred to the Committee on Taxation

Maryland - SB 592
Summary: MD 592 would establish the Office of Indoor Air Quality (IAQ) in the Department of the Environment. The office's responsibility would be to enforce IAQ regulations. This bill also creates the IAQ Advisory Council which would work with the IAQ office to monitor regulatory compliance in public and private office buildings with more than 2,500 square feet of floor space.
Status: Feb. 5 - Introduced; Feb. 7 - Referred to the Education Health and Environmental Affairs Committee; Mar. 4 - Hearing Scheduled (1:00 pm)

New Mexico - HB 371
Summary: NM HB 371 would require the environmental improvement board and local boards to prescribe ambient air quality standards for air contaminants.
Status: Jan. 28 - Introduced; Feb. 17 - Passed by the Energy and Natural Resources Committee and sent to the Judicial Committee.

New York - AB 4520
Summary: NY AB 4520 would require that, prior to approval, hospital construction plans must include proper ventilation design to allow maximize healthful indoor air quality.
Status: Feb. 19 - Introduced and referred to the Health Committee.

Oregon - SB 412 & HB 2708
Summary: OR SB 412 and HB 2708 would require that the Department of Human Services adopt standards for certain indoor air pollutants including, Particulate matter, Aldehydes, Radon, Carbon Monoxide, Carbon Dioxide, Ozone, and Water Vapor.
Status: Feb. 12 - Introduced; Feb. 17 - Referred to Business and Labor Committee

Texas - SB 599 & HB 1111
Summary: TX SB 599 and HB 1111 would require the Department of Health to conduct necessary investigation and testing of indoor air quality in state buildings, upon the request of the entity in charge control of the state building.
Status: Feb. 25 - Introduced and referred to the State Affairs Committee

Virginia - SB 908
Summary: VA SB 908 would require the Safety and Health Codes Board to develop regulations that determine a permissible exposure to mold for occupational buildings. These regulations would establish the proper remediation of mold in occupational buildings.
Status: Jan. 8 - Introduced; Feb. 3 - Passed by the Committee on Commerce and Labor; Feb. 4 - In the Senate; Feb. 21 - Died in Senate

Washington - SB 5798
Summary: WA SB 5798 would require landlords to provide to tenants at the time of lease information about the health hazards associated with exposure to mold. This information must detail how tenants can control mold growth in their dwelling units.
Status: Feb. 12 - Introduced and referred to Financial Services, Insurance & Housing Committee

School IAQ Programs/Inspections

Connecticut - HB 6426
Summary: CT HB 6426 would require biennial indoor air quality inspections for all school buildings. These inspections would evaluate the level of radon, bioaerosols, chemical compounds of concern to indoor air quality, volatile organic compounds, pesticide usages, the degree of pest infestation, and others. The bill would also require that all new school building projects meet complete indoor air quality inspections prior to approval.
Status: Feb. 11 - Introduced and referred to the Joint Committee on Education; Feb. 21 - Hearing held

Connecticut - HB 5636
Summary: CT HB 5636 would require the Commissioner of Public Health to annually conduct environmental health training workshops for certain school employees. This training would include a program based on the state's Indoor Air Quality Tools for Schools publications.
Status: Jan. 22 - Introduced; Feb. 5 - Referred to the House and Senate Committees on Education.

Connecticut - SB 59
Summary: CT SB 59 would provide funding through a public school building project grant program to improve indoor air quality in schools. Grants for school building projects to improve IAQ must include information in relation to environmental conditions within the school.
Status: Jan. 15 - Introduced and referred to the Joint Committee on Education

Connecticut - SB 732 CT
Summary: SB 732 would provide grant funding for school building projects to improve indoor environmental quality in schools.
Status: Jan. 27 - Introduced and referred to the Joint Committee on the Environment.

Connecticut - SB 10
Summary: CT SB 10 would require that indoor air quality standards be established for public schools.
Status: Jan. 8 - Introduced and referred to the Joint Committee on Environment

Connecticut - SB 173
Summary: CT SB 173 would allow the cost of fixing mold and other air quality problems to be eligible for reimbursement from the state school construction program.
Status: Jan. 21 - Introduced and referred to the Joint Committee on Education.

Connecticut - SB 174
Summary: CT SB 174 would amend statute to provide guidance to school districts for the improvement of air quality within school buildings. (No specific amendments are available at this time)
Status: Jan. 21 - Introduced and referred to the Joint Committee on Education.

Connecticut - HB 5148 & HB 5740
Summary: CT HB 5148 and HB 5740 would establish standards for school building project plans to include remediation to effect indoor air quality (IAQ). This bill would also require biennial IAQ inspections for school buildings.
Status: Jan. 16 - Introduced and referred to the Joint Committee on Education

Connecticut - HB 6503
Summary: CT HB 6503 would require that school building projects incorporate indoor air quality (IAQ) standards in building design. It also creates IAQ committees in each school to increase staff awareness of IAQ issues.
Status: Feb. 26 - Introduced and referred to the Joint Committee on Environment

Iowa - SF 136 IA
Summary: SF 136 specifies how educational facilities can implement energy conservation measures. This bill recommends indoor air quality systems which avoid the utilization of polluting chemicals as a way to promote healthier classrooms that incorporate environmental sustainability.
Status: Feb. 13 - Introduced and referred to the Education Committee.

Illinois - HB 2297 & SB 1191
Summary: IL HB 22297 and SB 1191 would require each school district to prepare an indoor air quality management plan. These plans would be required to plan for many elements, including preventative maintenance, microbial management policy, building systems evaluation, and may others.
Status: Feb. 21 - Introduced and referred to the Elementary and Secondary Education Committee

Missouri - SB 115
Summary: MO SB 115 would allow the department of health and senior services to investigate complaints regarding indoor air quality in schools made by public employees.
Status: Jan. 8 - Introduced; Jan. 23 - Referred to the Aging, Families, Mental, and Public Health Committee.

Nebraska - LB 246
Summary: NE LB 246 would allow school districts to levy property taxes to support expenditures to correct safety code violations for indoor air quality, or for mold abatement and prevention.
Status: Jan. 13 - Introduced; Jan. 14 - Referred to the Education Committee; Mar. 10 - Hearing scheduled

New Hampshire - SB 167 & HB 267
Summary: NH SB 167 and HB 267 would require the state department of health and human services monitor and report on the health status of public school buildings. It would also require that the department investigate any complaint in relation to the sanitary and environmental conditions of any school building.
Status: Jan. 30 - Introduced; Feb. 7 - Referred to the Environment Committee; Mar. 12 - Hearing Scheduled

New Mexico - SB 489
Summary: NM SB 489 would allow the state board to adopt rules to protect indoor air quality (IAQ) in public schools. This bill would also require three-year testing of all schools for radon and other chemical compounds affecting air quality, as well as inspections an testing of heating, ventilation, and air conditioning systems. This bill would require that said testing measures for heating, ventilation, and air conditioning be in compliance with certain national standards. This bill would additionally create an indoor air quality in schools advisory committee to assist the state board in adopting IAQ rules for schools.
Status: Feb. 6 - Introduced; Feb. 17 - Referred to the Senate Conservation Committee

New York - AB 3752
Summary: NY AB 3752 would require that all new school building projects or school remodeling be evaluated for quality air conditioning systems design. The bill states that this would be done in order to protect children form exposure to chemicals and other environmental hazards. This bill also requires that the departments of health and environmental conservation to report to the education department and school districts information on environmental hazards relevant to school buildings.
Status: Feb. 10 - Introduced and referred to the Education Committee

Rhode Island - SB 440
Summary: RI SB 440 would require that state department of health establish a yearly school indoor air quality (IAQ) inspection program for all school buildings. This bill would also require that the department set IAQ standards for the level of radon, bioaerosols, chemical compounds of concern to indoor air quality, volatile organic compounds, pesticide usage, the degree of pest infestation, the removal of hazardous substances, ventilation systems, plumbing, and building structure. Violations of these minimum standards by a school must be remedied within sixty days.
Status: Feb. 13 - Introduced and referred to Senate Health and Human Services

Texas - SB 242 & HB 473
Summary: TX SB 242 and HB 473 require the Texas Board of Health to adopt rules to establish mandatory guidelines for indoor air quality (IAQ) for public school building projects. The bill would also require each school district asses the IAQ of each public school, by Sept. 5, 2005 and every four years thereafter. These assessments must evaluate the adequacy of ventilation and the presence of carbon monoxide, volatile organic compounds, formaldehyde, particulate matter, carbon dioxide, and molds.
Status: Jan. 22 - Introduced; Feb. 5 - Referred to the Education Committee

Texas - HB 22
Summary: TX HB 22 would require each school district develop and implement an indoor air quality program for each school. These in pertinent part, these programs must include annual inspections, development of standards and goals, standard maintenance operations, and staff training.
Status: Jan. 30 - Introduced and referred to the Public Education Committee
   

In 1988, Congress passed the Indoor Radon Abatement Act establishing a goal of reducing radon to levels deemed safe. As a result, the U.S. Environmental Protection Agency created a recommended radon guideline of four picocuries per liter of indoor air.

Based on the latest science available, 60 citizens in the United States will die today from radon-induced lung cancer. Tomorrow, 60 more people will die. Each year, 22,000 deaths occur because of this odorless, tasteless, silent gas. Current scientific research indicates that even low levels of radon exposure may contribute to significant cellular damage of lung tissue.

In 2003, the question is no longer whether radon kills or whether radon causes lung cancer but how long policymakers and regulators are going to ignore the fact that radon is killing Americans in the very homes where we believe our families are safe.

Radon, a Class A carcinogen, is a form of radioactivity that routinely kills day after day - yet radon remains an "un-mandated" program within the EPA.

Fourteen years after Congress acted, America's national radon program seems impotent. Recommended action levels and measurement and mitigation standards, developed at significant cost to taxpayers, and once actively promoted by the EPA, are seemingly ignored by the U.S. Department of Housing and Urban Development, a key federal agency responsible for the nation's housing and many state lawmakers. Our nation lacks leadership and a coherent national radon policy, and, to date, efforts to resolve radon are proving unproductive.

Last year, based on supplies sold, 75,000 homes were successfully mitigated in the United States. Unfortunately, this remediation rate is completely inadequate to address the current level of risk and exposure.

Ten million homes in the United States have levels of radon that exceed the radon safety standard. Meanwhile, the national building rate results in new homes at risk being constructed at twice the rate of mitigation. Therefore, each year the nation builds an additional 75,000 at-risk homes, and these homes bring an estimated 250,000 additional citizens into the risk pool of those who inhale radioactive byproducts on a daily basis. At this rate, within 12 years, 11 million homes will exceed the safety standard, thus exposing 38 million Americans to unacceptable doses of radon. In those same 12 years, over a quarter million people will die from radon-induced lung cancer. We have not even begun to estimate the risk or the mortality rate due to radon exposure found in schools, institutions and places of work.

Current EPA Administrator Christine Whitman has the tools to achieve this mission and the ability to provide the leadership to make up for the lack of progress by previous administrations, for the solution rests on current law and an existing system of free enterprise and privatized certification programs for radon professionals. The solution does not rely on funding or new programs; our government simply needs to enforce current laws under the National Environmental Policy Act.

The act requires interagency compliance with EPA policies and programs. In this light, every federally guaranteed mortgage administered by HUD - or any other federal agency - should require a radon test and mitigation (if the test is positive) during the sale or transfer of property. This would include the Federal Housing Association, Ginnie Mae and Fannie Mae loan instruments. Since the military and other departments have already complied with the act, there should be no argument from HUD.

Unfortunately, HUD has been slow to move forward on the question of radon, and despite serious questions raised in 1991 by the Government Accounting Office about HUD's lack of leadership, it continues to drag its feet.

To alleviate the low cost of measurement and mitigation and to stimulate both environmental and economic activity, Congress should consider passage of tax incentives to drive this environmental solution. States will need to enact supporting laws and regulations to ensure that trained professionals and contractors are certified by either the National Environmental Health Association or the National Radon Safety Board to meet approved education, training and professional standards.

With foresight and leadership, the problem could be addressed within the next two decades. Leadership will save lives. A lack of leadership will mean that 60 people will die from lung cancer, not only today but tomorrow as well, and on and on in a painful progression, until we face up to the deadly evidence that a killer form of radiation exists in many of our nation's homes.

Peter Hendrick is the executive director for American Association of Radon Scientists and Technologists and is also the coordinator for the recently formed American Radon Policy Coalition. He joined AARST in the summer of 2001 with a 25-year background in environmental management and policy issues concerning solid and hazardous wastes. As both a former vice president of government affairs for a Fortune 100 company and as an environmental consultant, he brings to the radon industry years of federal and state experience concerning legislative and regulatory processes. Hendrick can be reached by e-mail at director@aarst.org or by calling (603) 756-9259.

There are two sides to the training and certification coin: (1) the immediate need for professionals working on indoor environmental challenges to have a designation that reflects proven competence and (2) the urgent need for building owners and managers to be able to sort qualified professionals from poseurs. Beginning with what building owners and managers need from the professionals who serve them provides a market-based starting point for assessing the training and certification needs of our industry. With the needs clarified, we can start unraveling the tangled mystery of the existing and proposed training and certification programs.

When it comes to indoor air quality and mold, building owners have a few basic needs. They need their facilities engineers and the professionals and contractors they hire to design, review or oversee their buildings to know how to prevent indoor air and mold problems. When there is a problem, they need a professional to provide competent third-party assessment of the situation and solid advice that will ensure the safety of building occupants, keep the matter out of court or protect them if they are sued. If they have to fix a problem, they need both a professional and a skilled contractor to develop the solution, oversee implementation with competent workers, verify performance and make certain that action is taken to prevent recurrence of the problem.

None of this is happening in a vacuum. Building owners and managers are often sophisticated and savvy employers and purchasers of services and products. Indoor air quality and mold are only a small part of the wide range of issues that is on their plate on a daily basis. They have been constructing and operating buildings much longer than indoor air and mold have been hot topics. There is a long-standing and trusted supply chain for all types of buildings. Now that indoor air and mold are front-burner issues, it will do well to look at that supply chain and what it already offers to see the value in more focused training and certifications.

REGISTRATIONS & CERTIFICATIONS
Building owners and managers have been working with registered architects and professional engineers for decades. Building owners and managers know the value proposition here: If they purchase design services, the registered professional is on the hook to deliver diligent work evidenced by placement of their official stamp on the delivered product. If the registered professionals are negligent or commit errors or omissions, they are liable for the result. These registrations have withstood the tests of time and litigation. As such, an architect's or engineer's registration is an assurance - admittedly not a foolproof one - that the bearer has achieved a certain degree of competence. As building owners face new problems such as indoor air and mold, they have reason to turn to these professionals first to assess and resolve problems. But registration as an architect or engineer does not prequalify a professional to assess or remedy an IAQ or mold problem. Architects and engineers need experience with these non-traditional issues and benefit from certifications that demonstrate that they have the specialized knowledge to serve their clients in these areas.

Certified Industrial Hygienists have entered the indoor air quality marketplace and promoted their certification successfully as a basic requirement. As John Banta reported in the September 2002 issue of IE Connections, some insurance companies require mold assessment reports to be signed by a CIH. The problem here is the same as for engineers. Nothing in the CIH certification process sets forth or tests the skills necessary to deliver the services a building owner needs. An experienced CIH who has specialized in indoor air and mold may be competent in all those skills, but not every CIH has that experience base. Buyer beware.
Registration as an architect, a PE, or a CIH still represents a critical professional credential for building owners. Depending on the context and the scale of the project, it is entirely reasonable for a building owner to demand that someone with these proven credentials sign project documents. However, it is also important for building owners to know the underlying skill sets they are purchasing for an IAQ or mold related issue. For this, they will also need to learn to demand a credential specific to the challenge.

VALUE PROPOSITIONS
A value proposition is a way of connecting the needs of a buyer with the solution set offered by a seller. Linking building owners to the professionals and contractors who serve them, essential value propositions can be reduced to four:

• Provide owners of complex facilities with a certification program for their facilities engineers and the professionals who serve them that gives owners confidence of the policyholder's ability to prevent and resolve IAQ and mold problems in the context of all of the other competing challenges of operations.
• Provide building owners who are concerned about indoor air and mold in their building with a certification program for environmental professionals that gives owners confidence of the policyholder's ability to evaluate the building, direct any needed remediation, and verify that the problem is resolved.
• Provide building owners who have an indoor air or mold problem in their building that requires remediation with a remediation certification program that gives owners confidence that the contractors who do the work have the necessary knowledge and skill.
• Provide building owners who hire contractors to build or service their building and insurance providers with a certification program for contractors that gives owners and insurers confidence that policyholders know enough about mold and indoor air to avoid causing a problem in the construction or service process.

The challenge for the emerging indoor air quality industry is to provide building owners with solution sets that fulfill these value propositions. Carefully selected certifications can supplement professional registrations and documentation of successful projects. The proliferation of certifications you find now serves only to cloud these value propositions and reduce the confidence of buyers in the marketplace. Good specialty certifications are critical to the health of the industry just as they are to building owners.

MEANINGFUL SPECIALTY CERTIFICATIONS
Existing certifications respond to these value propositions, with plenty of room for improvements. Looking at the certifications in light of the value propositions helps to clarify their role and importance, including their value to people seeking certification.
Provide owners of complex facilities with a certification program for their facilities engineers and the professionals who serve them that gives owners confidence of the policyholder's ability to prevent and resolve IAQ and mold problems in the context of all of the other competing challenges of operations.

This value proposition connects to the solution set offered by the Association of Energy Engineers' Certified Indoor Air Quality Professional program. Barney Burroughs and Shirley Hansen initiated this program in 1993 in response to the obvious need to facilities managers to have a certification for themselves and the professionals who serve them. Al Thumann, executive director of AEE, had learned from his 9,000 members that this is a critical value proposition for both building owners and the industry. The program has continued to evolve since 1993 and was relaunched in 2002 with the addition of all new sections on two key issues, mold and protection from acts of terrorism. The CIAQP is specifically geared to a professional level. Many architects, PEs and CIHs have received CIAQP certification. It is a performance-based learning system that requires extensive professional experience and verification of skills through a challenging examination. And it is true to the value proposition: It sets the issues of indoor air and mold in the context of building and running a complex facility with competing priorities.

Provide building owners who are concerned about indoor air and mold in their building with a certification program for environmental professionals that gives owners confidence of the policyholder's ability to evaluate the building, direct any needed remediation, and verify that the problem is resolved.

This value proposition connects to the solution set offered in the Certified Indoor Environmentalist program at the Indoor Air Quality Association. The CIE certification has emerged in the past few years as a leading example of how to build the skills and credentials of a professional specialty, the diagnosis and remediation of indoor air and mold problems. The CIE provides a building owner with evidence of a level of dedication and effort that has been invested by a professional claiming to understand these issues. For those seeking a career in investigating and managing remediation of IAQ and related problems, the CIE offers a valuable credential. The CIE fulfills the value proposition, offering a solution set for those with a specific evaluation or remediation need in the indoor environment.

Provide building owners who have an indoor air or mold problem in their building that requires remediation with a remediation certification program that gives owners confidence that the contractors who do the work have the necessary knowledge and skill.

This value proposition, at least as it relates to mold problems, is fulfilled by the solution set offered by several certifications available today, such as IAQA's Certified Mold Remediator program. Core skills of isolation, demolition, handling of contaminated materials, disinfection of contaminated areas are all expanded and tested through this program. The building owner or, more likely, an engineer or building sciences professional representing them who hires a contractor with a CMR gains a comfort factor in knowing that the remediation team includes workers or supervisors who care enough to have participated in some training and know enough to have passed an examination. For contractors, it is an opportunity to distinguish themselves in a crowded marketplace with many newcomers. The CMR fulfills the value proposition by giving some level of confidence to the building owner of the competence of the people working in his building on solving an important problem.

Provide building owners who hire contractors to build or service their building and insurance providers with a certification program for contractors that gives owners and insurers confidence that policyholders know enough about mold and indoor air to avoid causing a problem in the construction or service process.

This value proposition has emerged only recently as the insurance industry has started to look at their losses related to mold and litigation losses by contractors have mounted. The insurance industry is well along in the process of alerting building owners and contracting and service business owners to the risks associated with IAQ and mold issues. In response to the emergence of this value proposition, IAQA has just introduced the Certified Mold Loss Prevention Specialist program, developed in a joint effort with the Foundation of the Wall and Ceiling Industry. For building owners, contractors who staff jobs with MLP-certified supervisors demonstrate that they are alert to the issue of protecting owners' assets from mold damage. For contractor, the MLP helps by both better positioning them in the marketplace and helping to obtain cost effective coverage from their insurers related to mold. The MLP fulfills the value proposition by giving some level of confidence to the building owner of the competence of the contractor in preventing his building from becoming a problem building and perhaps reducing the cost of insurance to cover mold problems.

UNRAVELING THE TANGLE
There is a substantial effort and investment in training and certification in our nascent industry. Developing a consensus around the value propositions that are important for our future and focusing our energies in those areas will bring the greatest benefit both to our industry and the customers for our products and services. It is time to focus on building the institutional capacity and reputation of high quality certifications to supplement the traditional and respected registrations and certifications that are generally known to and understood by building owners, managers, and facilities engineers. The problem in unraveling the tangle will not be resolved by the addition of new certification programs, but by shepherding an understanding on the part of those who must rely upon them in purchasing services. With value propositions clear in our collective minds, it is time to invest in keeping the training and certification programs untangled in the minds of building owners.

George Benda is chairman and CEO of Chelsea Group Ltd., specializing in helping clients make the indoors a better place to be. Benda serves on the Board of Directors of the Indoor Air Quality Association and is Chairman of the Board for Certification of Indoor Air Quality Professionals at the Association of Energy Engineers. He is an active ASHRAE member and served on the steering committee for ASHRAE IAQ 2001 on mold and humidity issues in buildings. He can be reached by e-mail at gbenda@chelsea-grp.com or by phone at (630) 775-9205.

Dry ice blasting or cleaning is not a new technology. The process has been around for a number of years in various forms. At first glance, the process looks similar to sand blasting but uses a different aggregate. In truth, dry ice blasting is very different from sand blasting and fills a void where sand blasting is too aggressive to underlying substrates or creates too much residue.

Dry ice cleaning uses frozen carbon dioxide particles as a blasting means. As with sand blasting, the pellets are driven by compressed air through a gun on to the surface to be cleaned. Unlike sand blasting, the dry ice changes from a solid directly into a gas, leaving no residue other than what has been removed. The fact that there is no additional residue has made this method of cleaning valuable in the remediation of hazardous materials where the process adds nothing to the volume of material to be disposed.

The cleaning effect of dry ice is based on three principles: 1) to utilize the thermal effect that the dry ice exercises on the impurities, 2) to utilize the kinetic effect, which the dry ice, by virtue of its speed and its state, physically moves the impurities away from the unit to be cleaned, and 3) the volume extension or sublimation.

• Thermal effect: Dry ice pellets have a temperature of -79 degrees Celsius. The impurities that are hit will be cooled down tremendously then shrink and loosen.
• Kinetic effect: When dry ice pellets leave the nozzle of the blasting pistol, they have kinetic energy. This kinetic force dislodges the surface material. It is the same principle as the sand blasting operations. Although both sandblasting and dry ice blasting use kinetic energy, dry ice pellets are softer and less aggressive than sand aggregates.
• Sublimation effect: When a dry ice pellet strikes a surface, it is immediately transformed from a solid into gas. This process results in the fact that the volume is increased approximately 700 times and causes all loose and brittle units to be torn away from the solid surface where the pellet hits.

In some cases, the thermal effect will be most important (i.e. bitumen, resin, glue). In other cases, the kinetic effect will be most important (i.e. brittle coverings).

As mentioned earlier, dry ice blasting is less aggressive than sand blasting and, as such, is not a replacement to sand blasting but could be used in applications where sand blasting would damage the underlying substrate. Dry ice blasting can be used on processing machinery such as extrusion machines, printing and book binding machines and automobile parts without damage to electrical wiring or other soft material that would be damaged by sand blasting. While dry ice blasting is not new, the value and benefits of dry ice blasting are only now being realized in mold remediation.

There are a growing number of examples where dry ice blasting is a natural fit in mold remediation, predominantly as a labor saving tool. Applications such as carpet adhesive removal, structural wood ablation, duct liner removal and hard surface cleaning lend themselves to the use of dry ice.

In the removal of carpet adhesives and mastics that are impacted by mold, dry ice blasting replaces scrapers, heat guns and chemical applications. With structural wood ablation where the outermost layer of wood is to be removed, dry ice blasting is faster than sanding and is far superior at getting into corners, joints and gaps in the wood. As with sanding, dry ice ablation of laminated beams may impact the structural strength and therefore it is important to consult with the product manufacturers.

Dry ice blasting has recently been used in removing internal insulation from HVAC systems including air handlers, ductwork and other components. In air handlers, the insulation and adhesive can be removed along with loose rust and scale deposits. Ice blasting systems that mount on robotic systems for remediation in duct systems and other remote spaces are now available.
Ice blasting systems come in two basic designs. These designs are single-hose and dual-hose configurations. The dual-hose systems use one hose for compressed air and a second hose for the pellets. The pellets are drawn through the hose to the gun or pistol by the vacuum created by the compressed air, much like a two-hose painting system. The two-hose systems are typically less expensive but lack versatility in nozzle configurations and are less aggressive than single-hose systems.

The single-hose systems combine the pellets and compressed air at the primary unit. The rate at which the pellets are introduced is controlled by a rotary plate or air lock mechanism, which allows the operator to adjust the volume of material and thus the aggressiveness of the cleaning. The single-hose systems typically offer more flexibility in nozzle configurations and levels of aggressiveness. The single-hose design is also adaptable to robotic systems for remote cleaning.

The machines also differ in the form of dry ice that they use. There are block shaver systems and pellet systems. The block shaver system uses solid blocks of dry ice to shave and create the aggregate. The shavings shatter under their own weight into smaller structures that are carried to the gun.

The pellet systems use pre-manufactured carbon dioxide pellets that are commonly available. These pellets range from .04 to .12 inches in diameter and are far more dense than the dry ice shavings, resulting in greater kinetic energy. The pellet system also delivers a highly uniform aggregate to the surface to be cleaned and gives greater consistency in the cleaning process.

Other issues to consider include compressed air needs and the length of the hoses. Some designs limit the hose length to 15 feet while others allow up to 50 feet and more. As with sand blasting, dry ice cleaning is far from quiet and does not lend itself to all applications. However, the technology does offer benefits in a number of mold applications and opens up new markets for those in the field of remediation.

Charles W. Cochrane is president of Cochrane Ventilation Inc. in Wilmington, Mass., and is a past president of National Air Duct Cleaners Association. You can reach him by calling (800) 974-9055 or by email at IAQCVI@aol.com.