States Approve Chlorine Dioxide Mold Treatment; Endorsements Issued While IAQ Industry Expresses Uncertainty

Senate Defeats Asbestos Bill with Procedural Move

More than a Sheet of Paper

Understanding Issues of Heat Drying Wet Buildings

Déjà Vu All Over Again: EPA and Lead-based Paint

VOICES

“Children are growing up with difficulty assimilating, with difficulty concentrating, experiencing problems with their memory. Are we going to have a population growing up with far a reduced potential of what they can achieve academically?”

— Ritchie Shoemaker, M.D., of Pocomoke City, Md., in a Feb. 23 interview about his observations of New Orleans residents; see related story on page 7

Word on the Street 

CAPITOL HILL’S FALSE ALARM
The nation’s capital was abuzz with talk of homeland security last month. In addition to the city hosting a three-day conference and expo relating to issues including building security, responders evacuated the Russell Senate Office Building Feb. 8 after a suspected nerve agent was detected in the evening. Senators, congressional staffers and visitors were ushered into a garage, according to reports; the unwitting people, approximately 200 in all, were cleared to leave after about three hours, once tests in the Russell Senate Office Building proved negative. A Washington Post opinion piece published Feb. 12 hailed the emergency evacuation as “encouraging.” “Despite the extraordinary wastefulness of much of the nation’s homeland security spending,” it said, “the Capitol police force, at least, has managed to prepare for one of the likelier of the small-scale terror scenarios.”

Within the week, the Critical Infrastructure Resilience conference and Infrastructure Security for the Built Environment exposition were held at the Washington Convention Center. Dr. Jim Woods, executive director of the Building Diagnostics Research Institute, led a 90-minute session on policy and planning, called “Resiliency Initiatives and Standards: Health, Safety, Security, Economics.” Many of the same messages and technologies familiar to IAQ professionals overlap into the related fields of infrastructure protection and resiliency, said Woods, who is a member of this newspaper’s Editorial Advisory Board, told IE Connections. Woods said one of the highlights of the conference was a 90-minute session on Feb. 17 called “Public Health and Safety: Multihazard Exposures and Effects.” Panelists representing the U.S. Department of Veterans Affairs, Dartmouth Medical School, Johns Hopkins Bloomberg School of Public Health, and the Biosecurity Center at the University of Pittsburgh Medical Center were able to move shift the issue of infrastructure protection beyond single-hazard activities, i.e., terrorism, to multihazard response, which is more intense. The Infrastructure Security Partnership was expected to publish on its Web site summaries from the four track chairs in the coming weeks, Woods told IE Connections on Feb. 23.

‘A COUP FOR PRO-LAB’
Dr. John D. Shane is switching labs. The former McCrone Research Institute scientist is moving from the Chicago area, where Environmental Microbiology Laboratory Inc. hired him last spring as regional manager for the Midwest. A spokesperson for EMLab, Kristina Villanueva, said Shane’s 11-month stint ended Feb. 7 and that Ann Atkinson, regional manager for the Northeast, was assuming Shane’s Midwest responsibilities.

“Prior to his departure from EMLab, Dr. John Shane was being groomed to be an instructor” for the company’s Mold University seminar series, according to information Villanueva provided IE Connections. Faculty for this program currently consists of David F. Gallup, who is founder and primary instructor, and also Dr. Payam Fallah Moghadam and Dr. Harriet Burge.

After a 1,400-mile move, Shane is to resurface at the headquarters office of Pro-Lab in Weston, Fla., where he will work as vice president of laboratory services. In a telephone interview Feb. 10, Pro-Lab CEO James McDonald described the acquisition of Shane as “a tremendous coup for Pro-Lab. ... It’s like getting Michael Jordan to play for my basketball industry.” McDonald said adding the Ph.D. mycologist to his staff will “add tremendous value and credit to who Pro-Lab is.”

McDonald said Shane has trained many analysts around the country. Asked if Pro-Lab would be putting Shane to use as an instructor, McDonald said, “He will be doing training, but we don’t know if it will specifically be to train analysts.” That decision is still to come, he said. The lab currently offers an eight-hour mold certification class.

ASCR TREASURER RESIGNS FROM POST
James L. Pearson submitted his resignation Feb. 21 as the treasurer and a board member of the Association of Specialists in Cleaning and Restoration, the organization told IE Connections last month. “Pearson’s resignation was not unexpected as he had, on several prior occasions during 2005, discussed the possibility of his stepping aside,” ASCR said in a statement dated Feb. 24. “Jim Pearson has been actively involved with ASCR for many years, marking a record of involvement that is second-to-none. During his involvement with ASCR, Jim attended numerous industry functions, served on industry committees such as S520, and stepped forward to volunteer for additional service within ASCR where he chaired the convention committee, served as the vice chairman of the Environmental Council, and served in elected roles as director, secretary and as treasurer of ASCR and the ASCR Foundation.” ASCR said new board members would be selected at its annual meeting, to be held March 14–17 in Savannah, Ga., “to fill a number of vacancies created by members rotating off of the board.” ASCR’s statement also recognized the “countless hours” contributed by board members and other volunteers who must juggle their everyday business operations with participation. Pearson did not return a phone call seeking comment.
   

States Approve Chlorine Dioxide Mold Treatment
Endorsements Issued While IAQ Industry Expresses Uncertainty

By Steve Sauer

Chlorine dioxide was used in 2001 to decontaminate the Hart Senate Office Building in Washington, D.C., after the discovery of a letter containing anthrax addressed to Tom Daschle, who was then the Senate majority leader. The chemical compound also helped to decontaminate mail processing and other commercial buildings in D.C., New Jersey and Florida after the discoveries of anthrax there.

In recent months, chlorine dioxide users have shifted its focus from bioterrorism response to fumigating mold.

A CNN report aired in November depicted one New Orleans home whose outside was spared from the destruction of Hurricane Katrina. However, the conditions of the home inside were much worse than its barely impacted outward appearance let on. Its walls were riddled with mold. CNN correspondent Rusty Dornan detailed the application of chlorine dioxide gas as a solution that “costs about $8 a square foot” to implement.

By all accounts, many homes and businesses throughout the Gulf Coast are currently undergoing this treatment, under which chlorine dioxide gas is pumped into commercial or residential buildings that are affected by mold. The buildings are encased in tents that prevent the gas from escaping – a process previously seen in fumigation techniques targeted at killing termites. In sometimes as little as half a day, release of the gas is stopped, and occupants are said to be able to get on with their lives in a matter of only a few days. Walls and building contents that were previously spattered with black mold, are given a fresher, brighter tint, according to people who have had the procedure done in their businesses.

For the company marketing this chlorine dioxide treatment in the Gulf Coast states, the Albany, N.Y.-based Sabre Technical Services LLC, one principal selling point is that excessive costs of gutting the building of its contents have been avoided.

Various reports by local media in New Orleans and Florida since November have contributed to a growing perception among the public that “tenting” with chlorine dioxide is a cheaper and much faster alternative to traditional removal methods. Sabre’s Web site offers a two-page brochure on mold fumigation stating that the technique “limits the need for traditional ‘rip and replace’ mold remediation.” The brochure includes several dramatic before-and-after photos from completed commercial jobs.

Sabre also says its patented decontamination process using chlorine dioxide “leaves no residual toxicity” from mold. Mark Minier, a Sabre spokesperson, told IE Connections in a Feb. 20 phone interview that workers use HEPA or wet/dry vacuums in order to capture anything potentially injurious left over after fumigation, before the occupants of the building are allowed to re-enter.

“We haven’t done a whole lot of studies on the remaining allergenicity of the molds because it’s incredibly expensive,” said Minier. Based on his experience with Sabre’s fieldwork, however, he said he believes the chlorine dioxide and vacuum removal to be effective.

The problem, some in the mold remediation industry offer, is that only horizontal surfaces can be vacuumed, which leaves behind vertical surfaces and anything contained inside walls.

Not so, said Minier. “Since it’s a gas, it’ll penetrate through the Sheetrock and go into the wood, the whole way through.” Any mold that was in the wall cavities, he said, is dead.

Dead, maybe – but completely innocuous? Some followers of mycotoxin research dispute any claim that the fumigation of mold renders all toxins harmless. While chlorine dioxide gas proved effective in destroying some fungal spores in a study accepted last March by Environmental Microbiology Journal, its authors also noted that the mold Stachybotrys chartarum “still remains toxic.” In addition, a member of the committee behind the 2003 “Standard and Reference Guide for Professional Mold Remediation” last month reaffirmed the committee’s opposition to the application of chemicals that kill mold.

While research may not have disputably proven the usefulness of chlorine dioxide in protecting building occupants against the health problems associated with indoor molds, and while the industry holds its breath to pass judgment, three states and the federal government have already approved mold fumigation. The EPA in 1988 registered chlorine dioxide gas as a sterilant, which is a type of antimicrobial that eliminates organisms including fungi. Louisiana approved the chemical for fungicidal use in October 2005, and both Texas and Mississippi followed suit last month, EPA press officer Enesta Jones said.

Officials with the Mississippi Department of Agriculture and Commerce also said the use of chlorine dioxide for sterilizing emergency transport vehicles for medical patients is approved in their state.

Allen Spelce, a spokesperson for the Texas Department of Agriculture, confirmed that the state had issued a 24(c) registration allowing the use of chlorine dioxide on mold. This type of registration is for “special local needs,” Spelce said in a Feb. 22 phone conversation.

Dr. Quade Stahl, who is the chief of the department’s Indoor Air Quality Branch, said he had not seen research proving one way or the other that chlorine dioxide leaves allergenic materials in walls, although he said that is not part of the state’s determination in deciding whether or not to approve mold fumigation. “We don’t decide whether that’s the case,” said Stahl. “That’s for the consultant to decide.”

He added that the Texas Mold Rules “do not prevent using antimicrobials if a mold assessment contractor wants to use them. ... It must be EPA-registered and approved for that purpose, according to the rule.” The use of chlorine dioxide to kill mold, he reiterated, fits both of those requirements.

Also last month, the Texas Department of State Health Services prepared to respond to a regulatory complaint alleging that Sabre violated state law on Feb. 2 and 3 when, according to the complaint, Sabre employees “fogged” a 16,000-square-foot home in the Houston area. The complaint, filed Feb. 6 with the department’s Policy/Standards/Quality Assurance Group, alleged that the employees were not licensed within the state to perform mold remediation, and that the mold remediation protocol Sabre used for the project was not developed by a state-licensed mold assessment consultant.

Stahl told IE Connections that as of Feb. 24, the complaint was still being investigated before the department would issue a formal response.

Texas and Louisiana are currently the only states that issue licenses for mold remediation contractors. Texas also issues licenses to mold remediation companies, mold analysis labs, and mold assessment technicians, consultants and companies.

In September, an emergency declaration by the commissioner of Louisiana’s Department of Agriculture and Forestry clarifying that mold is to be classified as a pest began to allow licensed applicators of pesticides to treat mold. The department also threatened to take action against mold remediators who used pesticides without being licensed to do so.

Perspectives from the IAQ Industry

An article in the February issue of ICS Cleaning Specialist magazine describes the limitations of using chlorine dioxide gas to treat mold problems. Its author, Jim Holland, specifically takes issue with the “potential allergic and toxic reactions that remain” after antimicrobials such as chlorine dioxide are used to kill mold without physically removing it.

The article states that the U.S. Environmental Protection Agency has classified chlorine dioxide – in both gas and liquid forms – as a registered antimicrobial pesticide since the 1980s. Those using the chemical for antimicrobial purposes are bound to state laws regarding licensure for pesticide applications, except in times of crisis when the EPA issues exemptions that would loosen restrictions on the sale, distribution and use of liquid and gaseous chlorine dioxide against anthrax.

Holland emphasizes that “worker exposure and cleanup issues” associated with the application of chlorine dioxide are more complicated than with the application of a liquid biocide, a sentiment echoed last month by Patrick Walsh, the IAQ manager with the Northeast location of Environmental Compliance & Control in Denville, N.J.

“Personnel setting up and handling ClO₂ should protect themselves with Level A personal protective equipment to prevent injury,” Walsh told IE Connections in an e-mail dated Feb. 21.

Walsh said he was working for another company five years ago when he last used chlorine dioxide to fumigate mold, and that his supervisor at the time was once hospitalized with swelled lung tissues after accidentally inhaling the gas.

“ClO₂ is highly oxidizing, more so even than ozone. It has seen large scale use for bleaching wood pulp during paper production, and I have personally noted new corrosion spots on certain steel items upon completion of the treatment,” said Walsh.

While he attests to the “exceptional efficacy” of chlorine dioxide as an antifungal fumigant, “the drawbacks of its use far outweigh the benefits,” said Walsh.

He also noted that the explosive limit of chlorine dioxide gas is another concern for those using it. According to the material safety data sheet available from Sabre’s Web site, “Chlorine dioxide gas is explosive at concentration of 10% in air or greater.”

Technical Environmental Services Inc., an environmental health and safety firm located in Marrero, La., just south of New Orleans and the Mississippi River, performed post-remediation verification on three commercial sites where chlorine dioxide was used, said company President Danny Joyce.

“In each case, the smell of chlorine or a chlorine compound was so strong that we had to bathe to get it [out] of our hair – and this was three weeks after fumigation,” Joyce wrote in an e-mail dated Feb. 20. “Although all of the areas ‘looked’ good, they did not clear with air monitoring. Tape lifts and spore traps showed high to very high total spore counts. Viable samples produced nothing of significance. There was also evidence of significant oxidation and corrosion throughout the structure.”

Joyce said he believes the chlorine dioxide remediators failed to complete their mission. “In each of these cases (to the best of our knowledge), the company did not do any HEPA vacuuming or wipe downs and used no air filtration,” he said.

Holland, a member of IICRC’s S520 Mold Remediation Standard Committee, concludes in his article: “Even if it were successful in killing molds and their spores, there is still the problem of the potential allergic and toxic reactions that remain. The S520 recommends physical removal rather than the use of biocides.”

Supporting his argument, Holland quotes a relevant statement from the “Reference Guide” portion of the S520, which was released December 2003. “Killing microorganisms usually does not destroy their antigenic or toxigenic properties,” says the S520 excerpt, which goes on to cite comments from the ACGIH’s “Bioaerosols: Assessment and Control.” This source concludes “complete removal of contaminated materials” is necessary for effective mold remediation, rather than “the application of biocides.”

In a phone interview with IE Connections on Feb. 20, Holland added that mold could still be present “inside wall cavities or interstitial areas” of buildings where fumigation has taken place, even after HEPA vacuuming. What remains inside wall cavities could be released, creating potential health problems for building occupants if the remnants are toxigenic in nature.

Chlorine Dioxide for Anthrax Decontamination

Sabre is a wholly owned subsidiary of Bio One Solutions LLC, a joint venture with Giuliani Partners LLC. Former New York City mayor Rudolph Giuliani founded the company in 2002 and is currently its chairman and CEO. Last April, Bio One completed decontaminating the building in Boca Raton, Fla., that is recognized as the site of the first anthrax attack in the United States. At the time of the October 2001 attack, the building was occupied by American Media Inc., publishers of the National Enquirer. When the cleanup was being completed last year, Giuliani appeared on “NBC Nightly News” and said Bio One would relocate its headquarters in the Boca Raton building “as a symbol that you can deal with these attacks.”

The EPA lists chlorine dioxide among other chemicals used in federal anthrax decontamination efforts, such as diazinon, ethylene oxide, methyl bromide and hydrogen peroxide.

In a document obtained at Sabre’s Web site, Gilbert Gordon, a professor emeritus with the Department of Chemistry and Biochemistry at Miami University of Ohio, reports positively on the use of chlorine dioxide in decontaminating the Hart Senate Office Building.

“The important point to note is that the chemistry of chlorine dioxide, the way in which chlorine dioxide is generated, the methodology for the delivery of chlorine dioxide (via the gas stripping) and the measurement of chlorine dioxide and potential other products or by-products are the result of a very well understood and predictable chemistry,” writes Gordon.

“At the end of the decontamination process and after the chlorine dioxide generators have been turned off, all of the chlorine dioxide is gone. It is not being masked. It is not being hidden. It has reacted. It has done its job and it is gone,” Gordon continues. “Chlorine dioxide has its own characteristic chemical properties and the decontamination process was designed to take advantage of this chemistry.”

The information supporting the use of chlorine dioxide to decontaminate areas impacted by anthrax does not necessarily mean the same is true for mold. Anthrax is spread by physical contact and also carried in the air; unlike mold, its reach cannot spread within damp wall cavities.

In addition, the mere application of chlorine dioxide fails to address the moisture intrusion problem that led to the mold growth in the first place. “All [chlorine dioxide] does is kill the mold that’s existing,” Mark Minier of Sabre told IE Connections. “People have to be ready to have their house prepared.”

For example, he said, if water entered a house through a leaky roof, that problem should be addressed before the mold is fumigated. “We’re not a construction firm, but we let people know, ‘You guys have gotta fix it, or the mold will back.’”
 

Senate Defeats Asbestos Bill with Procedural Move
By Steve Sauer

A bill that would have purged asbestos litigation from the courts and created a $140 billion trust fund for victims narrowly escaped Senate passage on Feb. 14, falling just two votes short of approval. Senate Majority Leader Bill Frist (R-Tenn.) first voted in favor of the bill and then switched to “nay” in a procedural move that would allow him to bring the measure up on the Senate floor again. He filed his 11th-hour switch upon learning that a senator from Hawaii who was in favor of the bill’s passage was not present for the vote, meaning the bill would have been defeated by just one vote, according to the Washington Post. An editorial in the newspaper on Feb. 23 said Frist had not yet rescheduled the vote and called on him to do so.

State Updates

IE Connections presents another monthly update of bills on the state level that affect the IAQ industry.

Florida

·         Senate Bill 1046, which proposes a method to regulate mold remediation and assessment without issuing licenses, left the Regulated Industries Committee with a favorable report on Feb. 7 and was referred to the Commerce and Consumer Services Committee the following day, according to information provided by the lobbying firm for the Indoor Air Quality Association. The Florida Coalition on Healthy Indoor Environments is actively lobbying for the bill with some amendments regarding insurance requirements and grandfathering, as well as the addition of a clause that would call for mold remediators and assessors to be certified by an accredited body.

The Senate legislation is sponsored by Sen. Michael S. “Mike” Bennett (R), (941) 727-6349.

Its companion bill in the House is House Bill 161, sponsored by Rep. Carl J. Domino (R), (561) 625-5176.

Illinois

·         House Bill 4364 and Senate Bill 2198 constitute the Mold Remediation Registration Act, which calls on the Department of Public Health “to adopt rules, under the Illinois Administrative Procedure Act, to implement and administer ... a program establishing procedures for parties that provide mold remediation services to register with the State and provide evidence of financial responsibility.” One provision requires mold laboratories to be certified under the American Industrial Hygiene Association’s Environmental Microbiology Laboratory Accreditation Program. The bill, if passed, would take effect July 1.

The House legislation is sponsored by:

·         Rep. Thomas Holbrook (D), (217) 782-0104; and

·         Rep. Linda Chapa LaVia (D), (217) 558-1002.

The Senate legislation is sponsored by Sen. Kirk W. Dillard (R), (217) 782-8148.

Louisiana

·         House Bill 97 was passed in both the House and Senate last month during an extraordinary session. The legislation requires insurers to indicate clearly, in at least 14-point bold print on homeowners insurance policies, whether or not the insured has coverage for flooding or mold and whether an increased deductible is required for hurricane damage. The legislation was sent to Gov. Kathleen Blanco (D) on Feb. 17. The governor had not announced a decision by press time.

The House legislation is sponsored by Rep. Karen R. Carter (D), larep093@legis.state.la.us, (504) 568-8346.

Maine

·         Legislative Document No. 1971 / House Paper 1381 was written to require the state’s Department of Environmental Protection to establish written standards for mold cleanup. At a Feb. 16 hearing on the bill, the Natural Resources Committee amended the legislation to study the potential for developing mold cleanup standards, and the Indoor Air Quality Association testified and asked to be included in any study that takes place on the issue, according to its lobbying firm.

The legislation is sponsored by Rep. Margaret M. Craven (D), RepMargaret.Craven@legislature.maine.gov, (207) 783-7210.

Tennessee

·         Senate Bill 3618, the New Home Warranty Act, provides “clear, concise and mandatory warranties for the purchasers and occupants of new homes in the state and by providing for the use of homeowners’ insurance as additional protection for the public against defects in the construction of new homes.” The warranty would exclude mold and a number of other items “unless the parties otherwise agree in writing.” The legislation was introduced Feb. 16.

The legislation is sponsored by Sen. Steve Southerland, sen.steve.southerland@legislature.state.tn.us, (615) 741-3851.
     

In this issue, you’ll see a lot of repeated themes overlapping from one article to another, such as Dr. Harriet Burge and Carl Grimes both stating the fact of logic that one cannot prove a negative. Emphasis on proactive versus reactive measures is included in both Steve Sauer’s front-page story on hotels and in Doug Kladder’s “Radon Corner.” Patrick Moffett’s article on the heat-drying process and news articles on ThermaPure’s structural pasteurization process and the use of chlorine dioxide to kill mold underscore the point that it is natural for an industry to be skeptical of new technologies and processes until it can fully grasp and assess their advantages and shortcomings.

Something readers could infer from a news article on the American Indoor Air Quality Council is stated outright in Grimes’ “Breaking the Mold” column. Think of it as reinforcement, rather than redundancy, that this idea bears repeating here. It is the idea that any certification generated by an industry entity is worth little more than the piece of paper on which it is printed, unless there is something else making it more meaningful. That “something else” is accreditation by an independent third-party organization that demands adherence to strict standards and procedures in the awarding of certification designations.

Before 2006, there were only two certification bodies with ties to the IAQ industry that could boast of being accredited by an independent third party. The Construction and Engineering Specialty Board accredits the American Board of Industrial Hygiene’s Certified Industrial Hygienist credential and Occupational Health and Safety Technologist certification, and CESB also accredits the Board of Certified Safety Professionals’ Certified Safety Professional designation.

While CESB accreditation is much of what makes the CIH and CSP credentials more than just printed sheets of paper, the testing and qualifications for these programs are not directly on the assessment or control of contaminants in non-industrial buildings.

The announcement by AmIAQ last month that CESB accredited its Council-certified Indoor Environmental Consultant designation marks a milestone for the IAQ industry. For the first time ever, there is an IAQ certification that stands head-and-shoulders above all the others. It’s the only IAQ-specific certification to be CESB accredited. Furthermore, like ABIH and BCSP for industrial environments, AmIAQ is the only independent certification body for the non-industrial arena that does not offer membership or require taking their own training courses to obtain certification.

What’s even more encouraging is that AmIAQ is operating all of its Council-certification programs in compliance with CESB rules. CESB reviews accreditation applications annually, and AmIAQ has gone on record to say it will be applying to have several more of it designations accredited. In the meantime, knowing these programs are conducted by a CESB member with at least one CESB-accredited program gives assurance that the programs to be accredited in the future are being conducted in a manner above reproach today.

The same skepticism that should greet the introductions of new technologies and processes for IAQ investigation or mitigation should also naturally apply to the introduction of a new certification system for the industry. In keeping with efforts to enhance the status of its certifications, AmIAQ is challenging itself to operate in a fashion previously unseen in the indoor air quality industry. This even extends to AmIAQ’s governance, which will see the transition of its board of directors to a fully democratically elected body by the end of 2008.

IAQ practitioners should compare new technology to practiced methods and determine which is more effective for the customer. Likewise, it’s time to compare new ways of certifying IAQ consultants and contractors to those of the past and determine which provide the public with assurance of a greater quality.

The methods used to clean and sanitize wet building materials go back to Leviticus and pre-Roman times. In those days, they adopted surface-washing techniques of using soda ash and air-drying, followed by the use of perfume candles.

In today’s world of water-damage remediation where building drying is required, the use of air movement and refrigerant dehumidification is the most common building-drying process. Over the past five years, the industry has shifted from applying traditional drying methods to incorporating faster and more efficient building drying though the aid of heat.

The physics and principles behind heat-drying wet buildings follow the same physics principles upon which we rely on a daily basis to dry other materials. For example, we dry wet fabrics in a clothes dryer, where wet clothing is aerated and heat-dried with the force of positive air pressure to control the clothes drying process. Heated air pressure pushes out moisture vapor, allowing smaller, dryer warm-air molecules to displace the larger, wet moisture molecules. Other examples of a fast but controlled heat-drying process are home hair dryers and hand dryers commonly found in public bathrooms; both of these drying methods provide fast and efficient drying.

Heat-drying allows curing processes to occur during manufacturing; it stops microbial growth in food processing and cooking, and in hospital, bioengineering and pharmaceutical applications; and it provides a sanitizing effect when drying wet buildings.

Wet building materials are generally cooler than the air that is attempting to dry them, and in the first four hours of building drying after the installation of conventional refrigerant dehumidification equipment, the enthalpy-drying curve of the indoor air does not dramatically change whereas the enthalpy-drying curve for heat drying is almost immediate.

Taking this comparison up to a human level, getting out of a swimming pool and standing in the shade produces a cooling effect. This may be desirable in Las Vegas on a hot summer day where the hot sun produces low relative humidity conditions. However, in springtime when there is colder swimming pool water and air temperature and higher relative humidity, the drying effects are reduced, when standing in warm sunlight immediately warms and helps dry the skin. What can we extrapolate from this example? Standing in the summer sun warms and dries the skin faster than standing in a cooler, shaded area. Adding warmed air along with air movement can further increase the skin drying process. This process again is similar to a hair dryer or hand-sanitizing dryer in a bathroom.

Building Heat-drying Systems

Seldom are wet buildings constructed exactly like each other, and seldom do two wet buildings experience the same amount of water damage and wetness. This means the professional water-damage restorer should have a variety of expertise and equipment to manage different types of water damage situations. Refrigerant and desiccant drying are two types of drying systems incorporated in drying wet buildings. Both of these systems produce varying degrees of heat in the form of enthalpy and entropy during their drying process. The process of purposely adding heat to the wet building-drying phase is a natural progression in drying a building faster and more thoroughly.

Heat-drying wet buildings offers the same benefits as a clothes dryer, and in some wet building situations, heat-drying may be the preferred structural drying process. In heat drying, proper equipment and technically trained technicians should be able to contain and eliminate water damage before secondary damage occurs, including stopping microbial growth in its path.

Benefits of heat-drying wet buildings are of course on a case-by-case basis. However, in my study of managing wet buildings including the drying of homes, apartments, banks, churches, schools and administrative offices, the use of heated air during the building-drying process did not just provide a cost and time saving benefit to the customer; the drying process was more thorough and reduced business-loss interruption. By reducing the drying time, there are side benefits that lessen the liability the building-drying contractor may face:

·         It provides a faster and more efficient drying process to carpet, drywall, acoustic ceilings and insulation.

·         It provides a more thorough and complete drying process through which building materials are restorable.

·         It reduces business-loss interruption so tenants can reoccupy the building faster.

·         It decreases the drying time of large open-air spaces and vaulted ceilings.

·         It reduces secondary damage where building swelling and hardwood floors are not disposed.

·         It stops potentially harmful microbial growth that amplifies in the presence of moisture.

·         It increases building wellness because thorough heat drying procedures are able to benefit the wet building immediately.

·         It returns the building to its pre-loss moisture equilibrium at a faster rate.

Challenges

The heat-drying industry faces challenges in education and certification:

·         understanding what heat is and how to use it;

·         understanding the difference between various heat-drying equipment manufacturers;

·         knowing how to displace heated moisture vapor out of the building properly;

·         understanding how controlled air-pressure movement benefits the building-drying process and how uncontrolled air pressure can cause damage and mold growth;

·         monitoring, including air, surface and penetrating meters, data loggers and thermal imaging.

·         understanding that a moisture meter alone is only one tool and that the calibration and accuracy of many moisture meters vary considerably to a point that the data is inaccurate;

·         knowing when to increase or decrease heat mass and drying times; and

·         knowing when the building is dry and how this practice should be documented.

Marketing

The restorative drying industry faced many challenges when air movers and dehumidifiers evolved to become a standard piece of equipment in most every drying job. The insurance adjusters balked on the need to have dehumidifiers on every job, as you may remember. Today, the heat-drying industry faces similar challenges from correcting misinformation, poor equipment use and sloppy training, to job pricing that is all over the board.

Closing Opinions

There is no question in my mind that surface extraction, heated air and air movement (a mass force of air producing a capillary break at the wet surface with warmed air) is capable of drying wet building materials faster than most forms of refrigerant and some desiccant drying methods.

I challenge the refrigerant restorative drying industry and a technically astute team of heat-drying professionals to provide side-by-side tests similar to those I have completed to document how wet building materials dry faster in a controlled heat-dried environment than with refrigerant drying.

All of this said, selling heat drying equipment to refrigerant water-damage remediation contractors with no training or experience in heat-drying is disgraceful. For example, I observed heat-drying jobs from Hurricane Katrina and Rita cleanup that at some point may be challenged in court, where it may be shown that the drying contractor did not produce the desired drying results for one of the following reasons:

·         marketing on what their heat drying equipment could do was exaggerated – over-promised and oversold;

·         improper drying procedures to the extent that the contractor could not dry the building in a week, let alone several days;

·         there was no technician training and certification, and no product support by the dealer; or

·         poor monitoring practices allowed the contractor to have a false sense of security that the heat drying process they applied was adequate.

In other words, this particular drying situation more than likely increased the presence of mold growth and building damage. And yes, this may have been true no matter what type of drying process the contractor provided because these contractors had poor management and technical training skills.

On a personal note, all of us in the building-drying industry are in business to help customers resolve their building-drying problems. Heat-drying is an excellent drying process as long as it is properly applied. Some contractors using various types of heat-drying systems are currently creating problems for the general building-drying industry because they are untrained and inexperienced in heat-drying. These contractors cannot have achieved the desired drying effects (such as uniformly drying a wet building).

Unfortunately, the actions of a few are causing some contractors who are interested in learning more about heat drying to shy away from it. I believe that only through a coordinated industry training and certification program will we be able to go beyond talking about the negatives of heat drying and focus on the positive practices and benefits of drying buildings.

I believe that only through a coordinated industry training and certification effort will we be able to go beyond talking about the negatives of heat drying and focus on the positive benefits.

Patrick J. Moffett has 30 years’ experience, certifications and licenses involving general contracting, hazardous waste, biological remediation and building science. He is the author of several books on the market, the latest of which is called “The Physics and Principles of Heat Drying Wet Buildings.” Others include “Managing Microbial Problems in Buildings: A Teaching Glossary” and “Standard Operating Procedures for Cleaning, Remediation and Building Drying Contractors.” Moffett can be reached by e-mail at patmoffett@att.net or by phone at (714) 379-1096.   
    

As the year 2005 was drawing to a close, late on a Friday afternoon as employees were wrapping their new winter coats around themselves for the ride home and business for the year was rapidly being put to rest, a quiet prepublication notice pinged into my mailbox.

Its arrival in my office on the last hour of the last business day of the year almost seemed no accident. Over the years, I’ve learned that any time a government agency doesn’t want to make news, it releases the information over a weekend, preferably a holiday weekend. This being the best weekend of the year to bury something in the holiday, I was curious as to what its author – the U.S. Environmental Protection Agency – was up to.

Clicking the link on the page, I was transported to notice EPA-747-F-06-001, titled “Proposed Rule Establishing Requirements to Protect Children During Renovation, Repair and Painting Activities that Disturb Lead-Based Paint.” Among other things, the notice said the EPA was “proposing some simple but effective work practice standards that can reduce potential exposure to dangerous levels of lead for residents, especially children.”

Are they kidding? I interrupted the last moments of my work year for this?

It’s like déjà vu all over again. I’ve been involved with the lead-based paint industry since 1989, when I went to Georgia Tech for my first lead training course. This was long before Title X or the EPA model accreditation plan was developed. I can remember the excitement in the air during the training sessions and in the clubs after hours. The asbestos boom was in full swing, and lead was going to be the icing on the cake. The Department of Housing and Urban Development was drafting guidelines to be released in April 1990, and soon there would be regulations that would drive the industry. The people attending these classes were going to be the people running this new industry – or so we thought.

The two major issues that we failed to foresee in all of our exuberance were that the emerging lead market was nothing like the asbestos market in either character or ability to finance, and that the political will to remove lead-based paint was much less than it was to remove asbestos.

The first issue deals with the differences in location and economy of lead-based paint and asbestos. Although asbestos can physically be found in residential settings, the vast majority of asbestos materials were used on ships and in industrial, commercial and institutional buildings. The owners of these assets were in a much better financial position to leverage the cost of removal than the average homeowner. Often, the building owners were the taxpayers themselves as schools and governmental institutions raced to rid themselves of the perceived potential liability of owning asbestos containing building materials.

There were also regulatory triggers for asbestos activities under 40 CFR 61 Subpart M, the asbestos NESHAP (National Emissions Standards for Hazardous Air Pollutants). This scenario never developed for lead. Owners of industrial, commercial and institutional buildings were able to simply remove lead hazards without controls because there was no regulatory trigger to stop them. For the most part, when lead was concerned, if there was not a child or a worker with an elevated blood lead level, there was no regulatory scrutiny. The federal government, through the EPA and HUD, contributed to this confusion by excluding remodeling and renovations from oversight in Title X of the Housing and Community Development Act of 1992. The failure of this action has meant that by and large we conduct lead-based paint abatement only through the poisoning of children.

The issue of political will deals with the “who” of lead exposure. Not to downplay the dangers of exposure to asbestos, but the consequences of lead exposure are so much greater. “Lead poisoning, a preventable condition, is one of the most serious environmental health threats to children in the United States,” according to a General Accounting Office Report from 1999, titled “Lead Poisoning Federal Health Care Programs Are not Effectively Reaching Children at Risk.” It continues, “Children in low-income families who live in older housing with deteriorating lead-based paint are at high risk for lead poisoning.”

The reason low-income families are at risk is because they live in dwellings that are in poor repair that contain lead-based paint. Although suburban homes also contain lead-based paint, these homes are generally in much better condition. The simple fact of the matter is that the economic value of these inner-city dwellings was lost generations ago, but the lead-based paint continues to decompose and puts children at risk. The cost to make these dwellings habitable is greater than their resale value; therefore, it does not make financial sense to abate lead.

Federal efforts have had an effect on reducing blood lead levels. Prior to 1970, blood lead poisoning occurred at levels of 60 micrograms per deciliter or greater. At this level, there are overt signs and symptoms. Blood lead concentrations used to define lead toxicity have been reduced over time to 40 μg/dl in 1971, to 30 μg/dl in 1978, and to 25 μg/dl in 1985. In 1991, the CDC determined that children with a blood lead level of 10 μg/dl were at risk of lead toxicity. According to the 1999 GAO report, “[N]ational health surveys that CDC conducts periodically have shown a marked decline in the prevalence of elevated blood lead levels in recent years, attributed primarily to the regulatory ban on lead in gasoline and lead-soldered food cans. ... Average blood lead levels for children aged 1 through 5 declined from 15 μg/dl during 1976 through 1980 to 2.7 μg/dl during 1991 through 1994.” The National Health and Nutrition Examination Survey (NANES 1999) shows an additional decrease to 2.0 μg/dl from 1996 through 1999, according to the Dec. 22, 2000, MMWR Weekly report titled “Blood Lead Levels in Young Children – United States and Selected States 1996–1999.” One should note that the greatest drop in childhood blood lead levels occurred before the promulgation of Title X in 1992 – in other words, before the EPA’s major involvement in the lead-based paint removal industry.

On Oct. 28, 1992, President George H.W. Bush signed into law the Housing and Community Act of 1992. This omnibus housing bill included as Title X the Residential Lead-Based Paint Hazard Reduction Act. The Alliance to End Childhood Lead Poisoning called this “unquestionably the most comprehensive and significant lead poisoning prevention legislation in more than two decades.” Title X theoretically altered all aspects of dealing with lead-based paint hazards. The act’s fundamental purpose focused on prevention: finding and fixing lead-based paint hazards before children are poisoned. Two important elements of the act were the requirements for the EPA to look at work practices and to develop the Model Accreditation Program for training workers, supervisors, inspectors and risk assessors. HUD was charged with becoming a model landlord for public property, and OSHA was charged with revisiting its standard on lead in construction.

When the EPA released the MAP on Aug. 9, 1996, one thing became abundantly clear: The agency opted to specifically exclude definitions for renovations and restorations. In fact, the EPA’s definition of abatement specifically excludes “renovation, remodeling, landscaping or other activities when such activities are not designed to permanently eliminate lead paint hazards.” In my opinion, the EPA missed a huge opportunity to address renovations and remodeling activities, the very activities that create the bulk of lead dust and contribute the most to elevate childhood blood lead levels.

The agency has, to its credit, admitted that renovation activities were a huge hole in the intent of the regulation and decided to revisit the issue in the future after studying the issue. In June 1998, the EPA announced the Pre-Renovation Lead Information Rule under their authority in Section 406B of the Toxic Substance Control Act. This rule required that contractors doing renovation work for compensation provide the building occupants with a copy of the lead hazard information pamphlet prior to beginning work. This pamphlet described the hazards of lead-based paint renovation activities. The rule applied to all dwellings constructed prior to 1978, and required contractors to get the signature of the occupant stating that they understand the hazards associated with lead-based paint. If the owner refused to sign, the contractor was required to note that on the form. At long last it looked like the renovation loophole had been closed and renovation and remodeling would come under regulatory scrutiny.

As it turned out, the EPA did a poor job of disseminating information about the requirement of this rule to those that needed the information the most: renovation contractors. There were no regulatory triggers written into the regulations to ensure compliance, so, in spite of the EPA’s efforts, childhood lead poisoning continued to be the de facto trigger for compliance.

So, with all of this in mind, let’s look at the EPA’s new proposed regulations. According to the prepublication notice, “EPA is therefore proposing to revise existing regulations to extend training, certification, and work practice requirements to certain renovation and remodeling projects in target housing. It is not EPA’s intention to merely expand the scope of the current abatement requirements to cover renovation and remodeling activities. Rather, EPA has carefully considered the elements of the existing abatement regulations and revised them as necessary to craft a proposal that is practical for renovation and remodeling businesses and their customers, while taking into account reliability, effectiveness, and safety as directed by TSCA section 402(a).”

How does the EPA intend to do this? They plan to lower childhood blood lead levels by narrowing the applicability of the pre-renovation rule to targeted housing constructed prior to 1960. They also plan to develop a new pre-renovation pamphlet and to require training for supervisors on all projects affected by the rule. Excuse me, but this is a step backwards. First, the current rule applies to all targeted housing. By targeted housing, we mean housing constructed prior to 1978 in which children under the age of six reside. To reduce this requirement places children in post-1960 housing at greater risk than they are under the current rule. Second, creating a new pamphlet will only add to the confusion that abounds in the industry about what action a renovation contractor must take to protect families from the hazards of lead. Lastly, the agency discusses in great detail the adequacy of the available stock of trained individuals under the current MAP. In my opinion, adding a classification, the restoration supervisor accreditation, will be more confusing and costly to businesses, and possibly exclude those already trained under the current MAP from the labor pool by giving contractors the option of using lesser trained individuals to accomplish lead-safe work. Also, without a regulatory trigger to ensure post-renovation evaluations, this new rule will not change the current situation of conducting lead abatement by reacting to elevated blood levels of children. The EPA’s new proposal remains reactive rather than proactive.

At this point, if you are like me, you might be asking why we need this particular change. You might also ask why the EPA ignored the 1999 GAO report that said the problem with the lead-based paint regulations was that states were inconsistent with their enforcement of existing lead-based paint regulations. We do not need more or different rules, we need more enforcement triggers. Making changes to these regulations without due credence to the GAO critique will likely be ineffective.

Here is my take on the situation. First, I have no axe to grind with the EPA. I have many friends and colleagues who work throughout the agency, and I believe they are good people doing what they can to protect the environment and human health. For the most part, the agency has tried to develop reasonable and prudent regulations. I believe this proposed EPA action is consistent with the current administration’s penchant for slowing down or reversing the course of regulations under the guise of more effective enforcement and further study. They have deployed similar strategies with the Clean Air Act and the Clean Water Act.

I encourage anyone with an interest in childhood lead poisoning to obtain a copy of proposed regulations, which were published in the Federal Register on Jan. 9, and to make comments to the EPA before the end of the comment period, April 10. Let’s make the EPA put some teeth in their regulations rather than giving us their same old wine in a brand new bottle.

Mark Doughty is the president of Doughty Environmental Hygiene Associates, an environmental hygiene consulting firm located in Stockbridge, Vermont. He has over 20 years of consulting and laboratory experience which includes being the principal instructor for several EPA model accreditation programs. Doughty can be reached at (802) 746-8909 or by e-mail at deha@bellatlantic.net.