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Accredited IAQ Council Ushers in ‘End of an Era’
By Steve Sauer
All eight
certification programs currently offered by the American Indoor Air
Quality Council now bear the third-party accreditation the group has
been seeking for months.
A
long-anticipated announcement in February states that the Council of
Engineering and Scientific Specialty Boards awarded its
accreditation to six additional IAQ Council programs to the existing
two.
The
certification body, which is run out of Phoenix, Ariz., by Executive
Director Charlie Wiles, hailed its achievement last month in an
e-mail distributed inside the IAQ industry. “With Council
certifications earning prestigious CESB accreditation, the era of
the 3-day wonder is coming to an end,” the e-mail states.
CESB, which is
based in Annapolis, Md., is a third-party accrediting organization
that requires certifying bodies to “have developed a detailed
document specifying the ‘body of knowledge’ or ‘minimum level of
skills and knowledge’ required by a practitioner in the specialty
area.” CESB accreditation is also dependent on factors including a
certifying body’s independence and integrity in its operations.
The IAQ Council,
under its own rules, offers certification only to applicants who
demonstrate requisite experience, education or both. Levels and
subjects of academic degrees are necessary in some cases, while
documented experience alone can qualify applicants. Particular
qualifications vary from one Council certification program to
another.
Within the past
two years, the IAQ Council made changes to its certification
programs that were necessary in order to comply with the CESB
guidelines for engineering-related certification programs.
The CESB’s
accreditations in 2006 of the Council-certified Indoor Environmental
Consultant and Council-certified Microbial Consultant programs were
the first such accreditations in the IAQ industry. Until then,
limits on who could qualify for an industry certification and pass
an exam were little, if any, throughout the industry. Many
certification programs currently offered elsewhere in the IAQ
industry lack any prerequisites necessary for those qualifying to
take exams.
The IAQ
Council’s six newly accredited certification programs join the CIEC
and CMC in that status, which is also shared by the Certified
Industrial Hygienist program offered by the American Board of
Industrial Hygiene, the Certified Hazardous Materials Manager
program offered by the Institute of Hazardous Materials Management,
and others.
The IAQ
Council’s accredited certifications are in the fields of
environmental and microbial investigation and consulting, structural
mold inspection, IAQ program administration, microbial remediation
and the supervision of microbial remediation.
A ninth IAQ
Council certification program, one that would be offered to
microbial insurance claims adjusters, is currently undergoing
revisions to be submitted for accreditation later this year.
“The IAQ Council
has set a standard for the industry that consumers may now use to
examine the credibility of any IAQ certification program,” states
the IAQ Council. “Many certifying organizations will now have to
change to meet this standard, or face unfavorable comparisons with
those who do. Either way, the industry as a whole will benefit.”
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Maine Resists Issuing Mold Licenses, New Guidance
State Finds Credible
Information, Certifications Already Exist
By Steve Sauer
Mold
certifications, guidance and cleanup standards promulgated within
the indoor air quality industry are sufficient to protect the
residents of Maine, according to findings reported in late January
by a task force convened by the state legislature. A 71-page report
by the “Mold in Maine Buildings” task force covers the recent
history of mold as a public policy issue and summarizes positions of
the scientific community on mold’s health effects.
The task force
reports the shortcomings of efforts in Texas and Louisiana to
license mold remediators and assessors. In Texas, it says, the
licensing program “was expected to be self-supporting through
license fees” but that “the number of licensees is fewer than
anticipated and the program is a financial burden to the state.” One
failure of Louisiana’s program, it says, is that it “allows
individuals who had received training and certification from a
reputable non-profit organization to be waived from regulatory
requirements in the areas of training and testing.”
“Significant
financial resources are required to develop a state-run program, and
the work would be redundant of much that is already offered by
independent third-party professional organizations,” the task force
reported. “States considering a regulatory structure to protect
consumers from fraudulent practice by assessment and remediation
contractors can rely on certifications managed by reputable
organizations that undertake the training, testing, and
accreditation of the professional community.”
Its position on
existing standards and guidance relevant to mold was similar. It
listed nationally recognized documents that deal with worker
protection, mold remediation and assessment, ventilation and related
topics. In addition, the task force discredited the notion that a
state could produce better results.
Pointing toward
existing standards that bear the accreditation of the American
National Standards Institute, the task force presented as evidence
the ASTM assessment standard, the IICRC standard for water damage
restoration, and the two ASHRAE ventilation standards.
“Task force
discussions reflected that ANSI-approved standards are preferred for
use in Maine, as the ANSI accreditation process provides
verification that the standards and guidelines represent true
consensus on best practices for the industry,” the report states.
It also listed a
number of guidance documents and standards that, while not
ANSI-accredited, are seen as authoritative. Such documents cited in
the task force’s report were developed by IESO, ASHRAE, ACCA, ASSE,
NADCA and IICRC.
“For assessment,
remediation and worker protection topics for which no
ANSI-accredited standard exist or are under development (assessment
in residential buildings),” the report points to state and federal
guidelines it considers “the most up-to-date references that may be
utilized.” Such references are available on the federal level from
the U.S. Environmental Protection Agency and Occupational Safety and
Health Administration, and on the state level from New York and
Connecticut, the task force reported.
The report bears
a significant impression left by the Maine Indoor Air Quality
Council, a non-profit group established in 1998. Its executive
director, Christine Crocker, was one of 18 main participants on the
task force.
Included in the
report are the minutes of task force meetings held during the last
three months of 2006, a table of existing standards, and a
reprinting of the Maine Indoor Air Quality Council’s mold exposure
policy statement.
The task force
said it believes that the policy statement, adopted in November
2003, “is still an accurate reflection of what we know about the
effect of mold on human health.”
The policy
statement says, in part, “Additional health research is needed to
better characterize the nature and scope of the health effects
caused by indoor exposure to certain, specific molds. Particular
attention should be given to the possible role of mold in producing
serious, short-term or long-term effects on respiratory, immune, and
nervous systems.
“Since the
research to characterize the effect of mold on human health is not
fully developed, it is prudent to take precautionary measures, where
practical, to prevent the growth of mold in the indoor environment.”
Most task force
participants represented various state government agencies or IAQ-,
building- or health-related organizations or companies located in
Maine. Participants also included Maine attorneys, the state
congressperson whose law convened the task force, and the executive
director of the Indoor Air Quality Association (Glenn Fellman, who
is also the publisher of IE Connections, was the task force’s
only participant who resides outside Maine). Five additional
individuals are listed as providing review or research for the task
force.
Two contacts
listed on the report’s cover work for the Department of Health and
Human Service and the Department of Environmental Protection.
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WORD ON THE STREET
Voices
“She’s complaining. I
say, ‘Ok, I’ll do something with a ventilation system.’ ... But it’s not
a sandwich, I cannot make it right away.”
— Tae Hyun Shin, the
owner of a Subway restaurant in Manhattan, quoted by United Press
International in a report last month on his response to a neighbor who
had complained that smells from his kitchen permeate her condominium;
UPI included the story in its “Quirks in the News” column on Feb. 12
after the condominium board took legal action against him
Word on the
Street
HOME INSPECTION
FRANCHISE SOLD
A
lucrative franchise in the home inspection world has been bought out by
a company looking to combine that industry with the IAQ industry. The
acquisition of Allstate Home Inspection & Household Environmental
Testing by Environmental Service Professionals Inc. was completed in
February. Environmental Service Professionals, or ESP, announced plans
to acquire “several complementary service companies” as part of a
strategy it calls “growth through acquisition.” Ed Torres, ESP’s
chairman and CEO, said in a statement that a certification program it
offers, the Certified Environmental Home Inspector, is going about
helping to combine the worlds of IAQ and home inspection. Allstate’s
president, Francis X. “Rich” Finigan, said the franchise has been around
for a dozen years, coupling building inspections “with a wide variety of
environmental testing services.” Finigan currently serves as treasurer
of the Indoor Environmental Standards Organization.
ESP
recently sought to purchase MoldTech Software, and a division of ESP in
January bought National Professional Services Inc., a developer of
training programs and technology-based solutions for the IAQ industry.
ESP is evidently not finished with its “expansion by acquisition”
strategy. Its Feb. 5 news release added that ESP “is in various stages
of discussion with several companies that are a good operational and
economic fit. The current acquisition candidates include some that will
be free standing subsidiaries and others that will be absorbed into
existing operations, if they are acquired.”
SMACNA REVIEWS IAQ GUIDELINES
Now
available for a limited time is a newly updated draft of “IAQ Guidelines
for Occupied Buildings Under Construction.” The document, first
available in 1995 from the Sheet Metal and Air Conditioning Contractors’
National Association, is being revised under a process to be approved by
the American National Standards Institute. Stakeholders wishing to
participate in the public review of this SMACNA document have until
March 31 to contact SMACNA staff liaison Peyton Collie by e-mail at
pcollie@smacna.org.
SPOTLIGHT ON VETERANS’ HOSPITAL BRINGS IEQ TO FRONT PAGE IN WASHINGTON
A series
of articles appearing on the front pages of the Washington Post
throughout February exposed a number of problems at the army’s top
medical facility, with poor indoor environmental conditions among the
“signs of neglect” detailed. Over the course of four months, two Post
reporters conducted numerous interviews with residents of the Walter
Reed Army Medical Center, where many veterans of the wars in Iraq and
Afghanistan are treated. The initial articles focused on conditions like
“mouse droppings, belly-up cockroaches, stained carpets, cheap
mattresses” in a former hotel where the odor was described as smelling
“like greasy carry-out.” Subsequent articles throughout the month dealt
with the military’s response to the articles. One piece by Post
columnist Dana Milbank details the response: “The Army mobilized.
Painters were deployed to cover the offending wall with a fresh coat of
white semigloss. And television crews were invited in to inspect the
result.” Army Lt. Gen. Kevin Kiley, second in command at the facility,
accused the Post of “one-sided representation,” according to Milbank’s
column.
BUILDING SCIENCE ‘ON THE ROAD AGAIN’
A second
national lecture tour of building science experts Joe Lstiburek and John
Straube is scheduled to begin again in May. Between October and December
of last year, the duo brought their two-day seminars to seven cities.
Some of the same cities are gearing up to host them again this year as
“Building Science Fundamentals 2007” intends to cover 10 cities by late
November, including two in Canada. The two-day agenda has been revamped
to include new topics close to the hearts of their authors, including
Lstiburek’s take on energy issues published in this issue of IE
Connections (see page 19). The schedule is set to include
Boston (May 29–30), San Francisco (June 19–20), Los Angeles (June
26–27), Toronto (July 10–11) and Philadelphia (July 17–18). September
dates are set for Houston, with October dates in Chicago and Seattle,
and November dates in Orlando and Vancouver. For more information or to
register for a seminar, visit www.buildingscienceseminars.com or contact
Christine Cronin by phone at (617) 800-2633.
‘MY
FEMA TRAILER IS KILLING ME’
It
sounds like it could be the title of a new book from Jeffrey C. May, but
the above remark is actually something Sierra Club volunteer Becky
Gillette recalls being told in Mississippi.
In an
article by Wayne Martin of AllerAir Industries in Montreal, IE
Connections revealed last June that trailers provided by the Federal
Emergency Management Agency to Hurricane Katrina victims were shown to
have high levels of formaldehyde, probably caused by low air turnover.
The topic has certainly hit the mainstream media, with Gillette
interviewing for an in-depth article appearing in the Feb. 26 issue of
The Nation and reprinted by the Biloxi (Miss.) Sun Herald among other
news outlets and Web sites.
In an
initial Sierra Club test cited by media accounts, formaldehyde levels in
94 percent of a test sample of trailers exceeded federal occupational
limits. In a second test sample almost double the size of the first,
formaldehyde levels exceeded the limit in 83 percent of the trailers.
Gillette told the Memphis
Commercial Appeal that FEMA is selling “these trailers that they know
are dangerous and pawning them off on unsuspecting people.”
THE GAUNTLET HAS
BEEN THROWN
Building community
leaders take partial blame for greenhouse gases they believe cause
global warming, and their “2030 Challenge” contains plans intended to
reverse the trend. It calls for a step-by-step increase in the fossil
fuel reduction standard for new buildings so that new buildings will be
carbon-neutral by 2030. The challenge also impacts existing buildings,
and the newly formed Green Mechanical Council furthers the challenge to
the mechanical system industry, which chairman Dan Chiles says “can
significantly contribute to meeting the carbon reduction challenge
sooner and more effectively than any other industry. We have the
designers, installers and service technicians in position now – today –
to effect real and significant reduction of carbon fuels and greenhouse
gases.” |
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ASCR Renamed ‘Restoration Industry Association’
Strategic Name Change Part of
Reinventing Process, Says Manger
By Steve Sauer
One of the main
components of the reinventing process the Association of Specialists in
Cleaning and Restoration adopted over a year ago has now come to
fruition. It is a strategic move that focuses sharply on refining the
association’s image, identity and role.
Now touting a
pristine and perhaps clearer name than ever before, the newly christened
Restoration Industry Association is expected to enhance understanding
among both the general public and elected officials about who the
association’s constituents are. RIA would also seek to be better
informed and suited to protect the business interests of those companies
making up its membership.
RIA is a fresh brand
with a slick logo, unveiled publicly on both www.ascr.org and a new Web
site, www.restorationindustry.org, on the afternoon of Feb. 16 – all
while the association’s executive director, Don Manger, briefed a
listening audience on the Internet’s “IAQ Radio” and said the name
change was taking immediate effect. IE Connections confirmed his
claim with a phone call placed during the announcement to the
switchboard operator at the association’s headquarters office in
Columbia, Md.
Manger explained
that the association’s new moniker fits in with the reinventing process
underway since September 2005, when he commenced his tenure as ASCR’s
executive director. “The process began more than a year ago, so the name
change is just one of many steps,” he said during his Web-accessible
interview with co-hosts Joe Hughes and Cliff Zlotnik, who is a past
president of ASCR.
Manger is more than
just the appointed spokesperson for the metamorphosis but also a
catalyst for its implementation. An experienced professional in
transforming associations, the gray-haired and bright-eyed executive in
fact plays a crucial role in carrying out the desires for improvement
expressed by members of ASCR’s Board of Directors when he came aboard.
“You know, when the
board hired me in 2005, they asked for far-reaching organizational
change and told me that they had been dissatisfied with ASCR’s
performance for a number of years,” said Manger. He said he kicked off
his transformation method, first, by getting to know the staff and
volunteers and, later, by helping the association’s planners to identify
factors that hindered the kind of success board members were struggling
to achieve.
“One of the most
valuable aspects of the planning report was the planners’ consensus
regarding our own internal cultural barriers that have kept us from
succeeding in the past,” said Manger. “This understanding of what has
held us back well could be the most valuable aspect of the entire plan.”
A rare insight into
what those factors may have been came when Manger admitted there has
been some staff turnover within ASCR’s ranks. “Yes,
we lost a few good people,” he told the listening audience. “The changes
associated with making a quantum leap in performance can be painful.
Although some of the staff have moved on, we recruited successful,
experienced association professionals who are dedicated to the success
of RIA and our shared vision of the industry.”
Manger also
emphasized that RIA would be attempting to represent an industry that
has, to this point, not been satisfactorily united or unified. “One of
the things that I think is most important for the immediate future is to
articulate our aspirations – a vision, if you will, for the industry and
how RIA can serve the industry,” he said.
One reason cited for
launching better communication is to attract new members, an area where
he believes vast improvement is drastically needed. “That ASCR should
have barely twelve hundred members after 61 years is unfortunate,” he
said. “I believe that the Restoration Industry Association should strive
to triple that number over the next five years.”
A jolt in membership
would present the association with “two things,” according to Manger,
identifying them as “greater influence of and for the industry, and
increased financial resources to serve the entire industry.”
Having the attribute
of greater influence would be a shot in the arm toward accomplishing the
legislative goals of the restoration industry. Manger said that ASCR
invested more than $14,000 last year into lobbying efforts nationwide.
The primary instance of that was to ensure the passage of a bill in
Colorado then perceived as having benefits for the restoration industry.
Although the state’s legislature passed that bill, a governor’s veto
prevented it from becoming law.
A national
Restoration Industry Association more encompassing of its members would
theoretically be able to exert greater influence over lawmakers across
the country, said Manger, who offered that the new name has been shown
to be more representative of its constituency, and therefore easier to
understand, compared to its cumbersome predecessor.
“Since
November, when the board voted on the name change, we’ve had a number of
encounters that prove RIA is a better name in the public’s mind than was
ASCR,” Manger explained. “Specifically, when we used to introduce
ourselves to potential service providers as ‘A-S-C-R’ – or ‘Ass-car,’ an
acronym that I’ve never particularly enjoyed – we usually had to go
through two or three rounds of explanation before the other party
understood which industry or industries we were talking about.
“But once we
started introducing ourselves as being with the Restoration Industry
Association, we found that understanding came almost immediately on the
first mention of the association’s name, and there was never a problem
with the people we were explaining ourselves to understanding that
cleaning was a part of it.”
In terms of
assembling a more substantial financial force for achieving goals in
regulation and legislation, the association has already instituted what
it now calls the Industry Defense Fund. Formerly dubbed the 1006 Fund
after the number assigned to the Colorado House bill ASCR supported last
year, the fund was set up “to support pro-restoration legislation.”
Manger said that the
money ASCR spent in 2006 on lobbying was miniscule compared to what it
ought to be. “The effort will require several times that amount in order
to wage a credible fight,” he said.
The Industry Defense
Fund has accepted donations from ASCR members, and Manger has acted as
the sole point of contact. Soon to be lending his hand to efforts in
increasing awareness of the fund, Manger said, is longtime association
member G. Pete Consigli, a member of the IE Connections Editorial
Advisory Board. He joins the ranks of fellow technical advisers retained
by RIA: Martin L. King and Dr. Steve Spivak.
As far as what kind
of efforts the Industry Defense Fund was established to support, Manger
said, “In the representation area, we intend to pursue legislation and
regulations that preserve competition and professionalism in the
industry.”
In particular, he
elucidated on the state of affairs between restorers and property and
casualty insurers. “P&C insurers have shown a disturbing trend to
improve their bottom line by treating restoration work as a commodity
rather than a skilled service,” he said. “There is no one-size-fits-all
restoration job, and to treat these jobs as such does not serve either
the consumer or the contractor performing the work, or the retailers who
supply the project.
“We’ve seen many
cases that when an important client of an insurance company has a
catastrophe in his home that the insurer will leave all discretion to
the restoration contractor. However, when the policyholder is just an
ordinary homeowner with no other business or political influence over
the insurer, many will see fit to restrict the scope of work, set limits
on amounts to be reimbursed, restrict the list of available contractors
to a select few, or to just one company,” he continued.
“There’s not a
single P&C insurance executive who, in the event of a fire or a flood in
his own home, would tolerate a restoration under these terms. So, if RIA
does not speak up for the consumer from its unique vantage point as
restoration practitioners, then who will?
“As an aside, I just
want to mention that RIA is not against the property and casualty
insurance industry. We are against the shortsighted policies that many
are using to control their claims payouts. What some insurers are doing
in the professional restoration arena is similar to the attacks on them
by activist attorneys general, as in Mississippi that just caused State
Farm to withdraw from the market, leaving Mississippians with about half
the insurers this year as they had last.”
The initials “RIA”
stand not only for “Restoration Industry Association” but also,
conveniently, for “representation, information and action” – three goals
the revamped trade organization says it plans to undertake more
profoundly.
Asked during his
“IAQ Radio” appearance about how RIA fits in an industry alongside the
Institute of Inspection, Cleaning and Restoration Certification, Manger
said he believed the two would continue to reside symbiotically with an
understanding of their roles.
“IICRC
has done a fine job of advancing the vision of its founder, Ed York, to
develop a training standards and distribution system that helps to get
training down to the technician level,” said Manger. “In fact, I’d
venture to say that the majority of RIA’s members utilize IICRC
certifications and IICRC-approved trainers. And with any organization’s
success comes a certain role confusion, and some practitioners think
that by paying certification service fees to IICRC they are paying a
membership dues that gets [sic] them a vote in the organization, which
they are not.”
He continued, “I
can’t speak for IICRC or for any of the other organizations serving the
industry, but I can tell you what my personal philosophy is. I encourage
industry participants to belong to as many trade associations as they
can economically justify. No organization can do everything, but every
organization can perform its specialty to a high-quality standard, an
ethical practice standard, thereby giving the industry’s members some
meaningful options in where they invest their available money and time.”
At the same time,
RIA indicates that it will seek “to improve the quality of training and
to move the testing out of the training sessions,” according to a list
of talking points generated prior to Manger’s spot on “IAQ Radio” and
shared afterward with IE Connections.
This RIA document,
which closely follows Manger’s interview, references the third-party
accreditation the American IAQ Council has attained for nearly all of
its certification programs.
“The industry is
maturing and outgrowing the era when we could create our own terminology
in the area of third-party certifications,” Manger’s talking points
state. “I believe that the industry will see more moves towards
certification programs that meet the requirements of competency
assurance organizations like NOCA [National Organization for Competency
Assurance] and CESB [Council of Engineering and Scientific Specialty
Boards].”
Manger said RIA is
on its way to making its advanced-level designations – including
Certified Restorer, Water Loss Specialist and Certified Mold
Professional – available outside its membership.
“While our advanced
credentials are known and respected by industry insiders, we need to
open them to a broader audience so that more practitioners can benefit
from them as well as the consumers whom they serve,” he said, adding
that this would be “one means of helping to raise the level of
professionalism of the entire industry.”
Other results of
ASCR’s reinvention are a newfound emphasis on promoting best practices
for all types of restoration. Manger announced that RIA intends to
publish a best-practices guide for specialty rug cleaning this year. In
addition, he said RIA’s Restoration Council agreed in January to adopt
industry business standards similar to those that apply to architects
and construction contractors – a plan Manger said “could be one of the
most ambitious objectives ever undertaken by the association.”
In the process of
reinventing the association, Manger said he would exercise caution not
to alienate any of its current constituents. Asked whether the name
change may result in rug and carpet cleaners dropping their memberships,
the executive director said, “I don’t think it’s likely, and I certainly
hope that doesn’t happen. After all, the association’s ASCR name was
adopted for the members of the association to reflect how they saw
themselves. The ASCR name was built around the terms ‘cleaning and
restoration’ for a number of years, and the ‘cleaning’ term in the
association’s name was never limited to rugs, carpets and textiles but
included cleaning of buildings and mechanical systems.
“Additionally,” he
continued, “in the public mind, ‘cleaning’ is not a term that engenders
understanding, or even respect, and it’s highly subjective: What is
clean to me may not meet your definition of clean. In considering
whether we should change the association’s name, we examined how the
public – our members’ customers – would view the association’s name.”
Manger pointed out
that defining the word “restoration” embodies the ability “to return
something to a previous state or condition” and that cleaning is an
inherent function of the word’s definition.
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Publisher’s Perspective (March 2007)
Do We Need a Standard For Fixing Leaks?
Given recent
events, there appears a need to develop a restoration industry
standard for fixing leaks – not the kind that causes water damage or
leads to microbial contamination but the kind that results in
newspapers reporting on sensitive, “insider” information.
About a half
dozen people say they were accused, or accused by implication, of
leaking confidential information from the IICRC’s S520 Committee to
IE Connections. IICRC representatives have allegedly made
direct and veiled accusations both verbally and in writing. IICRC
takes confidentiality very seriously, requiring strict
non-disclosure agreements of its volunteers.
The latest
incident occurred when a letter distributed to S520 Committee
members regarding an internal issue of a highly sensitive nature was
forwarded to this newspaper’s editor, Steve Sauer. None of the three
individuals who forwarded him the letter serves on the S520
Committee, and whether all three received the letter from the same
source was not divulged. Like a good reporter, Steve queried IICRC
on the authenticity of the letter.
In response,
IICRC representatives launched what is described to me as a “witch
hunt” to find the culprit who leaked the letter. Knowing the IICRC
folks as well as I do, I suspect “witch hunt” is an exaggeration.
Nonetheless, Steve was contacted by phone after his inquiry about
the letter’s authenticity. The call’s purpose was neither to confirm
nor deny authenticity; Steve was asked to reveal who sent him the
letter, which of course is something a good journalist doesn’t do.
Steve politely denied the request but disclosed that he had received
the letter from three separate individuals.
There are
legitimate reasons a standards development committee should keep
draft documents under wraps. However, an ANSI-accredited standards
developer must also work within a fairly transparent environment
where secrets may be perceived as hush-hush backroom conversation
and insider politicking.
The month after
S520 was released for public comment, I was corresponding with the
American Industrial Hygiene Association’s executive director, who
shared AIHA’s S520 comments with me by e-mail. I asked if I could
share the comments with others and was told yes, both because I am
an AIHA member and because AIHA doesn’t consider its comments on
peer review documents confidential. I forwarded the comments to
several colleagues including Steve, who printed some of AIHA’s
commentary the following month.
Once it
appeared, I learned that an attorney representing IICRC wrote three
people a letter in which he mentioned that AIHA told IICRC that they
had not released their comments to the press. This was followed by a
reminder of committee member confidentiality requirements.
When I learned
about IICRC’s allegation of a leak to us, I called AIHA’s staffer
who drafted their comments. He told me that he was asked if AIHA
sent its comments to the media, to which he replied no – but to
which he also added that AIHA doesn’t view their comments as
confidential and would in fact release them if requested. This
particular staffer simply wasn’t aware of my previous e-mail
exchange with the AIHA executive director.
In “Gulliver’s
Travels,” Jonathan Swift writes satirically about two warring
nations whose ideological divide is over which end of the egg to
break when eating a hard-boiled egg. Had we a Swift in our industry,
he would compose a satire on the folly of chasing down informants
who report to the press on the happenings inside the S520 Committee,
and he wouldn’t lose sight of the irony that all of this energy and
time is being spent on what are really inconsequential leaks of
information in the big picture of consensus-based standards
development.
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Ask Dr. Burge: When Should I Use Cultural
Sampling in Mold Investigations?
Dr.
Harriet Burge
Director of Aerobiology
Environmental Microbiology Laboratory Inc.
San Bruno, Calif.
With the rising
use of spore trapping, this question is cropping up with increasing
frequency. Spore trapping is straightforward, the equipment is
easily handled, and analysis can be as fast as you want. Cultural
sampling, on the other hand, requires sterile agar surfaces that
need special handling. Analysis is straightforward (although
expensive if species identifications are necessary), but the time it
takes depends entirely on how fast the fungi grow. So, given this
comparison, why would you ever want to use cultural sampling?
As I have
emphasized many times, all investigations should be
hypothesis-driven. So, the answer is that cultural sampling should
be used whenever testing your hypothesis requires such sampling.
There are a number of hypotheses that relate to hospitals for which
cultural sampling is essential. In residential or office building
investigations, the information gained by culturable sampling is
usually not worth the added cost in residential or office building
investigations.
But there are a
few exceptions. For example, let’s consider a situation where a good
visual inspection has not revealed any obvious fungal growth.
However, the occupants are convinced there is a mold problem and
insist on some kind of sampling. So, we develop hypotheses for the
next step in the investigation:
1. Fungal
reservoirs are not present in the building.
2. Fungal
reservoirs are present in the building.
These are the
two major hypotheses being tested. If the first is true, then a good
spore trapping protocol is likely to adequately support the
hypothesis. Remember that documenting the negative case can never be
proven with one or two samples. If the second hypothesis is true,
then not only do you have to document that growth is or was present,
but you also may want to gain some
information on its potential source.
Before
beginning, then, we need to develop a new set of hypotheses to test
in the event that the second hypothesis is true:
A.
The aerosol is residual from an outdoor event that occurred
prior to the sampling event (e.g., wood chips were spread on the
garden).
B.
The aerosol is residual from a transient indoor event (e.g.,
the occupants discarded a moldy bagel just before sampling began).
C.
There is a hidden source for spores somewhere in the
building.
We now need to
develop a sampling strategy that will support testing of all of
these hypotheses. First, you may be able to test these hypotheses
without additional sampling.
Questions about outdoor events, or referral to an outdoor data base
that would give you the probability of an outdoor event sufficient
to cause such high residual levels, may
work for hypothesis A. Questioning or searching the trash
might adequately test hypothesis B. You could do a more in-depth
search for hidden growth to test hypothesis C.
If none of these
approaches proves successful, we are going to have to rely on air
sampling data. The spore trapping that was used to differentiate
between the first two hypotheses will give you some information.
Spore trapping will certainly tell you whether or not an aerosol is
present and provide some information on the spore types present.
This may be enough. For example, perhaps all the spores are
basidiospores of the type produced by Coprinus. Then, you can
go outdoors and look for the clump of inky caps that is decaying the
old stump near the house (and producing the moldy odors that concern
the occupant). However, what if the spores are all Penicillium/Aspergillus
types? In this case, we have not distinguished among our three
hypotheses.
It is at this
point that cultural sampling may be useful. Disturbing compost and
tossing out moldy bagels are likely to produce aerosols of different
species of Aspergillus and Penicillium. For example,
A. fumigatus is common in compost but not likely to be
abundant on moldy food or growing in other indoor reservoirs. On the
other hand, Penicillium spp. are very common on molding food,
and both Penicillium and other Aspergillus spp. are
common in damp building materials. Cultural sampling will readily
distinguish these different fungi.
Where should the
samples be collected? Outdoor samples need to be collected both near
and away from the wood chips. A sufficient number of indoor samples
need to be collected so that if no aerosols are found, you have
sufficient data to support the negative case, i.e., in case the
aerosol is no longer present. I would suggest five samples, all of
which need not be analyzed. If the first shows no aerosol, then
analyze the second, and so forth, until you have analyzed all five
or encountered a suspicious aerosol. I would also collect bulk
samples of wood chips and any possible other sources, such as moldy
bagels in the garbage.
Let’s assume
that the spore trap data used to test hypotheses 1 and 2 revealed
10,000 Pen/Asp spores per cubic meter of air indoors.
Outdoor concentration of Pen/Asp spores was 10,000
spores/m3 near the wood chips, 2,000 spores/m3
of air away from the chips. Based on these data, analysis of the
cultural sampling is necessary to test hypotheses A, B, and C. For
hypothesis A, one would expect that the species present indoors are
the same as those outside near the newly spread wood chips and those
in the wood chip bulk samples. If this is true, then you have good
evidence that wood chip aerosols are responsible for the indoor
aerosol. Similarly, for hypothesis B, you would expect that the
indoor aerosol would be different from that outdoors and that the
indoor aerosol would match the hypothesized “indoor event” source of
spores, e.g., the bagel mold. If no such match occurs, then you are
left with an unidentified source and evidence to support destructive
testing to find hidden mold.
If you can
sample on more than one occasion, then you can do a spore trap
survey to test hypotheses 1 and 2, and then develop new hypotheses
based on these initial results. This is probably the most efficient
approach providing the building occupants will allow more than one
visit. If multiple visits are not feasible, you could collect all
the samples needed to test all the hypotheses, and check the spore
trap results quickly. If no aerosols are found on the spore traps,
then you can abort the analysis of the remaining samples.
This is only one
of many possible hypotheses that are best tested using cultural
sampling. Documenting exposure to opportunistic pathogens often
requires cultural sampling, as does clearance sampling to document
the absence of viable spores (There will always be a few dead spores
around following remediation).
Dr. Harriet
Burge is director of aerobiology at Environmental Microbiology
Laboratory Inc. and associate professor and director of the
microbiology laboratory at the Harvard School of Public Health.
Widely considered the leading expert in IAQ, Burge pioneered the
field more than 30 years ago. She has served as a member of three
National Academy of Sciences committees for IAQ, including as vice
chair of the Committee on the Health Effects of Indoor Allergens.
To submit a
question to Dr. Burge, write to her by e-mail at askdrburge@emlab.com.
All questions posed to Burge will receive a reply, although space
limitations prevent us from publishing them all. By submitting a
question, you agree to have your question and its answer published
in a future edition of IE
Connections.
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Energy Security: How to
Defeat al Qaeda with Insulation
Joseph Lstiburek, Ph.D., P.E.
Principal
Building Science Corp.
Westford, Mass.
Energy security is pretty easy to get a handle on. The
American people are eventually going to figure out that it does not
make sense to send a trillion dollars a year to the Middle East to
people who want to exterminate them – people who turn that money
around and foment hate and terrorism across the planet.
So, how do we keep the money here? Easy. Don’t
buy their oil. We don’t need it anyway. We have plenty of energy
right here in good, old North America. The problem is that it is not
cheap energy, and it is not clean energy. We can make it clean, and
we will, but it will be even more expensive. And actually, that is
good because we won’t waste it when it is expensive.
To be perfectly clear, we don’t have an energy
crisis; we have a cheap oil crisis. We are running out of light,
sweet Arabian crude. And the sooner we run out of it, the better.
Once it is gone, there won’t be much to fight over. That’s why I
drive two SUVs, and each one has a bumper sticker that says: “Drive
an SUV for World Peace.” As soon as the price of oil gets high
enough, we will change over to another energy source. In fact, the
Saudis know this and are pumping oil like crazy to keep the price
down. With oil prices too high, the Saudis know that good,
old-fashioned American technology will make them irrelevant. The
Saudis are the neighborhood drug dealer keeping the American people
hooked on Arabian crack. They know if the price goes up too much,
American junkies will go to a different drug. I’ve got a news flash
here, folks; it’s already too late for the Arab pushers. Let me tell
you how it will play out and what it means.
The first thing you have to understand is that
energy security is first and foremost a car-truck-transportation
problem that, as it gets solved, will change the rest of the
American economy – for the better, I might add. In fact, we have
already solved the transportation problem although most folks don’t
appreciate it. The good news is that the government didn’t do it and
couldn’t do it. The bad news is that government might yet still
screw it up. I am hoping for government gridlock and weak
leadership. What are the odds of that? I want the marketplace and
innovation to sort it out. The only thing we need from government is
a modicum of environmental protection so we don’t pee in our
collective planetary bed while this gets sorted out. I think we can
count on that; the environmental loonies are good for at least one
good thing.
The second thing you have to understand is that
anything General Motors or Ford picks as a winning technology is a
loser. General Motors and Ford picked hydrogen. Dumb. Toyota picked
the hybrid. Guess who won?
So, what is this solution to energy security?
The plug-in hybrid vehicle. That’s it? Yes, that’s it. Not fusion?
No. Not solar? No. Not the flux capacitor? No. OK, so explain it,
Dr. Joe – especially the part about why I should care. Read on,
Macduff.
A hybrid vehicle is nothing more than an
electric vehicle with gasoline as the energy source for the
electricity. When we add a big enough battery, we can plug it in and
run the vehicle using juice we get from the grid rather than juice
we get from the gasoline. As we transition current hybrid vehicles
from nickel hydride to lithium ion battery technology, we are going
to be able to plug in the vehicle and get 50 to 75 miles between
charges. This is a big deal because this is the distance of the
average commute. And we don’t have to worry about running out of
battery power because we still have the gasoline there to take over
when we run the battery down.
It gets even better when we dilute the gasoline
with ethanol – and boy, can we dilute it – up to 85 percent (E85
ethanol is 85 percent ethanol, 25 percent gasoline), and presto! End
of transportation energy problem; hello, energy independence. The
vehicles will have all-electric drive; gasoline/ethanol will be
burned only to run a generator to charge the battery packs.
Will the vehicles get smaller? What, are you on
crack? This is America, the land of the 60 oz Slurpee and the 40 oz
bladder. Small vehicles are a greenie weenie Eurotrash concept.
Europe is a small continent with small countries small people and
small imaginations; their time is past. We are a nation of big-assed
Americans with big-assed cars and trucks. We are going to go for
high performance and size. How do you say 500 brake horsepower in
kilowatts? Do you have any idea what torque you can get with
series-shunt electric drive? We don’t have the tire technology to
take the stress. Electric dragsters will leave the nitro burners in
the dust.
So, what is this transition of the
transportation sector from petroleum to electricity and ethanol
going to do to the rest of the economy? Well, electricity is going
to get expensive – very expensive. And so is natural gas, because we
make electricity from natural gas. Oh, we make electricity from coal
too, but coal is dirty, and we are going to have to make it clean
and that will make it expensive. So, we will have expensive
electricity made from natural gas and from clean coal. What about
nuclear? It will be cheaper to make the electricity out of clean
coal than with nukes. The big problem with nuke is what to do with
the waste. We were going to stick it in Nevada, but too many people
live there now, and the congressional representation is now strong
enough to kill that idea. So where to put it? What’s a big state
with no people and weak congressional representation? I pick
Montana.
With the plug-in hybrid, I bet the cost of
electricity will go to 35 cents per kilowatt and the cost of natural
gas will double. At 35 cents/kilowatt, that translates to 75
cents/gallon gasoline – peanuts, nothing, zip, zilch. Electric
plug-in hybrid vehicles win. The American Dream lives on; we do love
our cars. Now, with winners, there are always losers.
Who loses? Pay attention here; now comes the
fun part. Buildings consume 40 percent of all energy in the U.S.
economy, more energy than the transportation sector, which pushes 30
percent. We cool our buildings with electricity and heat our
buildings with natural gas. Folks, we are going to triple the cost
of air-conditioning, and we are going to double the cost of heating.
The transportation sector is going to compete with the building
sector for the same energy, and the transportation sector is going
to win.
A rational person would say, OK, just make the
buildings smaller, with smaller windows, and smaller appliances. I
remind you, this is America. Twiggy is a European icon. Anna Nicole
is an American icon. Next question. We are not going to get smaller
buildings, but we are going to get ultra efficient buildings. We are
going to double and triple the amount of thermal resistance in the
typical building enclosure. We are going to insulate, and we are
going to insulate big time. We have no choice. So, in order to
defeat al Qaeda, we must insulate.
Now, this is both good and bad: good for energy
security but bad for building durability. Insulation reduces energy
flow, and here is a good time to remind everyone that there is no
such thing as a free thermodynamic lunch. As the energy exchange
across building enclosures reduces, drying potentials reduce, and
this means we are in for a world of hurt in the coming years in
terms of corrosion, decay, mold and other moisture-induced
deterioration as we change our building technology to take into
account the new energy cost realities. It gets even worse – or
better, depending on who profits from the problems – when you
consider that over 80 percent of the buildings that will be around
in 2035 are already here and they will have to be insulated as well.
Who knows how to do that? I can tell you who does not: the folks
down at Home Depot and the pretty boys on “This Old House.”
Building science and building diagnostics and
building technology and building rehabilitation are going to boom
because things are going to bust. Can it get even better? Yes. They
can’t outsource the jobs offshore to Bangalore, India. This has to
be fixed by Americans right here in America. The future is not in
plastics, my boy; the future is in construction. Actually, the
future is in fixing construction.
There is more. Remember that trillion dollars?
It doesn’t go abroad anymore; it stays here in the United States. Do
you have any idea what that will do to the balance of payments and
the value of the American dollar and what that will in turn do to
the American economy? We are going to boom like this planet has
never seen before. We are going to have jobs coming out of our ears.
And we are going to need more Americans. And that is good, because
we need young Americans and we are not going to get them by growing
them ourselves. We are going to need immigrants – young,
hard-working ones like my parents and yours. We need them to look
after our old and to pay into Medicare and Social Security. And we
are going to need more houses to put them in. It will be great.
Europe’s population is aging, and so is Japan’s. Ours is not, and we
must not allow it to do so.
Let’s now go back a step and look at the
ethanol part of this a little bit more closely. Where are we going
to get the ethanol? Look around, Grasshopper. The politicians are
meddling. Corn is not the right play for the ethanol source, but
that is where the subsidies are going. It is never smart to trade
food for fuel. The price of corn is going way up. That means beef
prices go up too; the Big Mac price index is in for a ride. There
have already been tortilla riots in Mexico City because of the rise
in corn prices, and they are blaming the American gringo and
corn-based ethanol. Ask me how much I care about the price of your
tortilla, and ask me how much I care about what you think of me,
Pancho Villa, after you flaunt our border laws and suck up to our
enemies. But when the price of my Big Mac goes up right here at
home, now that hurts. Yes, food prices are going to go up
because the politicians are meddling. Cellulositic ethanol is the
answer, but we will get corn ethanol in the short term until this
silliness gets sorted out.
Now, this is not the key point for us in the
construction industry, entertaining as it may be. This ethanol thing
is going to affect us in a big way once the marketplace figures out
that cellulositic ethanol is the right play. One of the dominant
building materials we use is cellulose fiber. It is likely to be a
winner in the future as well. However, it does not make sense for us
to get this cellulose fiber by cutting down 1,000-year-old trees in
the state of Washington. We should be growing and harvesting our
fibers in Iowa and Nebraska and Mississippi and Alabama on
plantations. And we are beginning to do so. The days of 2×10s and
dimensional lumber are over. The rise of engineered wood, oriented
strand board, hardboard, particleboard, fiberboard and laminated
paper composites has arrived. All of these products are cellulose
fiber-based. All will be in competition for the same cellulose
fibers that the transportation sector also covets. Cars will be
competing with buildings for the same energy and raw materials. We
know who will win. The car always wins. That means that the fibers
the building sector will get will be second-rate and expensive. And
none of the engineered wood products are as durable as the real
thing – wood. We will be adding stuff to the fibers to make the
stuff work. I predict the stuff won’t stay in the stuff, and we will
have environmental issues right along with the durability issues.
Damage functions and the Arrhenius1 Equation, here we
come.
We are going to have fun boys and girls. Think
about what lies ahead? Less robust materials in highly insulated
building enclosures with low drying potentials. Stuff is going to
stink, rot, break and otherwise annoy. There are going to be a lot
of mistakes in the next decade as we get all of these things sorted
out. But I wouldn’t trade this for anything else in the world.
Because our country needs us to clean up the mess from the energy
security ethanol hangover we are going to have.
Dr. Joseph Lstiburek2 is a
principal of Building Science Corp. He is internationally recognized
as an authority on moisture-related building problems and indoor air
quality. He can be reached by e-mail at joe@buildingscience.com or
by phone at (978) 589-5100.
_______________________________________________
1. Dead, white, European, Nobel Prize winner, no longer fashionable
to study.
2. Not dead, but
white, of European ancestry, has not won the Nobel Prize, also not
fashionable to study.
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Are We Serious Enough About Radon?
Douglas Kladder
Director
Center for Environmental Research & Technology Inc.
Colorado Springs, Colo.
During January’s
National Radon Action Month, there was a focused effort toward
public awareness about radon. Given the number of news stories and
television responses, I would say it was successful.
However, in
listening to and participating in some of these programs, I heard a
repeated message that just did not sit right. The phrase typically
echoed by the news talent or reporter went something like this: “One
should mitigate a home if it is above four picocuries per liter,
which EPA considers to be a safe level.”
Although it is
correct that the U.S. Environmental Protection Agency recommends
homes be fixed if they have long-term levels in excess of 4.0 pCi/L,
it is totally incorrect to assume that there is no risk below 4.0
pCi/L. However, it is understandable that – with the focus on a
guidance number that is found in so many publications and is part of
many practices – the public could easily draw this incorrect
conclusion. After all, why would a federal agency set a guidance
that wasn’t safe? Let’s examine just how safe 4.0 pCi/L is.
Comparison of EPA
Guidance to Other Contaminant Risks
Seven out of
1,000 people will contract radon-induced lung cancer at a lifetime
exposure at the guidance level of 4.0 pCi/L, according to the EPA’s
“A Citizen’s Guide to Radon.” Whoa, hold the presses! Any
contaminant that is regulated – whether it is for waterborne
contaminants or clean-up efforts – is controlled to a maximum
contaminant level exposure to where one out of 100,000 or 1 million
would be affected. That means the guidance level for radon would
allow for a health risk factor that is 1,000 to 10,000 times
higher than other “regulated” contaminants!
How many lives
are really being saved with a 4.0 pCi/L guidance? Let’s look at this
from another perspective. Recent health advisories from EPA and the
surgeon general indicate that approximately 20,000 lung cancer cases
occur each year in the United States from exposure to radon. The
assumption that many consumers make is that if homes were reduced to
less than 4.0 pCi/L, those 20,000 lung cancer cases would be
averted. However, that is not quite true either.
“Approximately
13,000 of the 20,000 annual radon-related lung cancer deaths occur
below the action level of 4pCi/L, with about 7,000 occurring at
levels above the action level 4pCi/L,” said EPA press officer
Roxanne Smith, in response to questions from IE Connections.
Whoa, hold the
presses once again! What this means is that if all homes that are
above 4.0 pCi/L were mitigated, only one-third of the total annual
deaths would be averted. What about the other two-thirds of the
cases, which amounts to 13,000 deaths per year? I would imagine that
most people would not judge as successful a program that achieves
its goal of reducing exposures to less than established guidelines
but does not save even half of the lives at risk.
Why Such a
High Risk Rate?
So, if we are
serious about radon risk, why is the guidance set at such a high
risk rate? In EPA’s defense, setting a guidance level at a more
common one-in-a-million risk would mean mitigating radon levels to
less than what is found in the ambient air. This would have the
effect, as one EPA staff member related to me, as condemning homes.
No one wants to do that. However, in selecting a guidance number
upon which many real-estate transaction contingencies are based,
there is a perception that buying a home having a level below the
4.0 pCi/L guidance level would provide a safe living environment,
which is obviously not correct.
Also, as the
“Citizen’s Guide” indicates, “Radon levels can be reduced in most
homes to 2 pCi/L or below.” At least for those cases where
mitigation is employed, substantial health risk reductions are being
achieved. But what about the homes that have test results of 3.9 pCi/L
and the buyer thinks everything is just fine and dandy, yet their
risk is in the neighborhood of one in a 100 if they do not smoke and
about 10 times higher if they do?
It has also been
related to me, since the use of short-term tests at the time of
resale is assumed to overestimate the long-term exposure, homes are
being mitigated where the long-term exposures are less than 4.0 pCi/L
and, therefore, some of the homes with moderate radon exposures are
being addressed beneficially. That could very well be true, assuming
the short-term tests are being conducted correctly and that they
truly provide an indication of the highest radon potential of the
home. However, there have been a number of studies that indicate
short-term radon tests on a given home, depending upon the time of
the year the home is tested, can have results varying twofold or
even threefold. This certainly suggests that there can be a number
of false negatives in homes where mitigation would have been prudent
but did not occur. So even with a generous 4 pCi/L guidance, the
high reliance on short-term testing versus long-term testing may be
causing even more of those avoidable lung cancer cases to be missed.
Several in this
field have suggested that even if the short-term test result is less
than 4 pCi/L, a long-term test would be highly advisable.
How Serious
Are We About Radon Control Systems for New Homes?
The EPA and
other organizations recommend the installation of a passive system
during the construction of a new home in high-risk areas and that,
after occupation, a test be conducted. If elevated (presumably above
4 pCi/L), a fan should be installed to reduce the indoor radon
levels further, according to recommendations within the appendix of
the 2006 International Residential Code.
Again, a
homeowner’s perception of a system installed during construction is
that it should prescriptively reduce levels to less than the surgeon
general’s recommendation of 4.0 pCi/L on a long-term basis;
unfortunately, that is not the case.
Smith, the EPA
press officer, indicated, “A passive system can be expected to
reduce the radon level by about 50 percent if installed correctly.”
Whoa, stop those presses yet again! If the home would have had a
radon level of, say, 12 pCi/L (without the passive radon system),
then the installation of the system in accordance with code would
reduce it to 6 pCi/L with a risk factor that is more than a risk of
one in 100!
Compound this
with the fact that passive systems are recommended only for Zone 1
areas, where the radon potentials are high enough to where a
short-term test would likely be above 4.0 pCi/L. What about the
folks in lower zone designations where significant risks are still
present, yet with the unintended perception of the zone maps being
that one need to be concerned only about new homes in high-risk
areas? If one takes the health studies stating risks at exposures
less than 4.0 pCi/L seriously, does this make sense?
Does Budget
Reflect Priorities?
It has been said
that radon presents the largest environmental health risk in the
United States with respect to mortality, at an annual rate of 20,000
lung cancer cases per year. Accepting this staggering statistic, one
would expect that federal budgets would reflect this as a priority.
However, in reviewing the president’s proposed EPA budget for fiscal
year 2007, we see that the sum of the budget items for state radon
grants and the EPA radon program administration is 0.2 percent of
the entire EPA budget. That is less than 1 percent for a contaminant
that causes 20,000 lung cancer cases each year and is supposed to be
the single largest environmental health threat!
Granted, radon
is not a regulated program and often does not get the financial
priorities of regulated and compliance related programs, and there
are certainly financial pressures on EPA and other branches of the
government. But on the other hand, it is easy to understand consumer
perception of low risk associated with radon when the radon program
represents such a miniscule portion of the EPA budget.
The purpose of
this column was not to bash EPA, as the 4.0 pCi/L guidance is lower
than many those of other nations in the free world, and a lot of
progress has been made over the last 20 years. However, many of
those advances were made subject to the support or limitations of
technology that were available at the time guidances and approaches
were adopted.
Times have
indeed changed. Technologies have improved. Consumers want and
expect safer indoor environments than they did 20 years ago. It may
be time to reassess some of the approaches and priorities that we
are assigning to this issue. EPA does not dictate budget but rather
must rely upon the will of Congress, and that takes support from the
constituencies of our representatives. Certainly, progress has been
made, but we also need to reassess our approaches in light of
current times and most certainly as a function of some of the
unintended consequences and false assumptions that are being made.
As always, who
says there is nothing new in radon?
Douglas Kladder is director of the Center for Environmental Research
and Technology Inc. He can be reached by e-mail at dougkladdr@aol.com
or by phone at (719) 477-1714.
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The King is Dead? Long Live the King, Asbestos!
Jeff
Mlekush
Operations Manager
QuanTEM Laboratories, LLC
Oklahoma City, Okla.
Do you remember, back
in the cobwebs of your memory, when you could read a trade
publication and not even see an article about mold? Do you remember
back when asbestos was king.
Most articles
about environmental issues in the media lately have been geared
toward mold. This article may prove to be a breath of fresh air –
pun intended.
Indoor
environmentalists should be concerned with potential sources of
problems other than mold: formaldehyde, lead containing paints and
varnishes, animal dander, insect skeletons, excrement,
asbestos-containing materials and so forth. So, I will turn the
focus away from mold for a bit and talk about something else.
The mold
professionals out there should keep in mind that the fixing of a
moisture problem and the associated remediation of the moldy
materials may involve breaking, abrading or otherwise damaging
materials that contain asbestos or lead. In our litigious society,
the issues of lead-containing and asbestos-containing materials are
still hot topics and should be addressed in addition to any primary
mold issues. The suspect materials should be addressed in an
inspection report. Sample the materials yourself, get the materials
sampled by another appropriately certified party, or include a
disclaimer in your mold report and recommend the materials be
sampled by a properly certified and licensed inspector prior to
being disturbed during mold remedial activities. Also, if you do the
sampling yourself, make sure that you have the proper lead or
asbestos certifications and/or licenses in your state to avoid any
encounters with your local environmental regulatory agency.
As a reminder,
prior to 1978, lead was commonly added to paints, varnishes, ceramic
tile and ceramic tile glazes. Even today, some imported ceramic
tiles and glazing contain lead. Asbestos was, at one time or
another, put in just about every building material produced. A long
list of materials has been found to contain asbestos, including
gypsum wallboard, joint compound, texture (surfacing) materials,
plasters, vinyl floor tiles, sheet flooring, tile adhesives, grouts,
caulks, pipe wrap, block pipe insulation, sink insulation coatings,
heat shields in light fixtures, vermiculite attic and wall
insulations, acoustic ceiling tiles, lightweight acoustical ceiling
textures, cement sheeting (transite), roofing (shingle, rolled, tar
paper, built-up), roofing tars, penetration sealants, aluminized
paints, stuccos, and wire insulation.
Asbestos
The asbestos
process has been defined for over 20 years now and involves the
phases of inspection and sampling, abatement, and clearance. During
the inspection and sampling phase, each suspect material is
identified, sampled and analyzed, utilizing a bulk analysis
technique such as polarized light microscopy or transmission
electron microscopy, otherwise known respectively as PLM and TEM.
During abatement and clearance, air samples are collected. Air
sampling is used during abatement to determine asbestos
concentrations for worker exposure purposes and to ensure that
asbestos fibers are not being released into areas outside the
containment area.
Now, the U.S.
Environmental Protection Agency requires air sampling after
abatement (clearance, in other words) to ensure that the air within
the containment is not contaminated with residual asbestos and that
the containment can be removed and remaining remodeling, demolition
or re-occupancy can occur. Air sampling should be adequate to
identify any airborne asbestos hazard. But is air sampling enough to
characterize asbestos health hazards within the containment? What if
the asbestos particles are not airborne at the time of sampling?
What if the asbestos particles are settled out of the air and are
present in settled dust? How would the air sampling technician
identify this problem? Now that everyone is up to speed on the
different asbestos materials and the asbestos process, I would like
to address a specific issue that may be overlooked concerning
asbestos contamination.
Our company has
been involved in several projects where the consultants chose to
collect settled dust samples in addition to clearance air samples.
The interesting thing about these projects was that no asbestos was
detected in the air samples while hundreds of thousands to millions
of asbestos fibers per square centimeter were present in the settled
dust. What does this mean? What conditions could promote this
outcome? Scores of hypotheses could be made if all of us were to sit
down and think back on all the containments we’ve been in and what
we’ve seen in those areas. Let’s discuss two possible causes.
First: Make sure
the containment is clean. Visual inspection of the containment after
detail-cleaning and prior to air sampling needs to be improved. More
thorough investigation of surfaces in the containment is warranted.
The inspector’s visual inspection needs to be comprehensive,
including areas the abatement crew may have overlooked during their
detail-cleaning. I can’t remember how many times I went into
containment and crawled around in hard-to-reach places and found
pockets of asbestos-containing debris lying about. Many of my
colleagues in various areas of the country have found similar
conditions. So, if you have raw asbestos-containing debris lying
around, there are bound to be asbestos fibers in the dust. Make sure
the abatement contractor cleans these areas thoroughly (HEPA-vacuumed
and wet-wiped, not just picking up the bulk pieces); otherwise,
asbestos may still be hiding in the dust.
Second: Is the
air sampling protocol utilized during a clearance sampling event
adequate? The EPA-established protocol is usually the preferred
method for clearance sampling. This method requires aggressive
agitation of the air inside containment; this is usually
accomplished with a leaf blower and box fans. Samples are then
collected in and around the containment. The problem arises when all
the surfaces inside the containment are not blown with the leaf
blower. In some containment areas, blowing every surface may take
hours to accomplish. As a TEM laboratory, our company receives
thousands of these clearance air samples from abatement activities
each year. Over 90 percent of them contain no detectable amounts of
asbestos. This means either that the majority of the containments
are very clean or that asbestos is not becoming airborne during the
sampling event. Given the outcome of the projects mentioned
previously where settled dust samples were collected, I tend to
believe that there may be a hidden contamination problem this
industry is missing.
The methods used
to determine if the asbestos has been removed may not be thorough
enough. The unaided eye cannot see microscopic particles.
Air-sampling devices cannot collect asbestos particles if the
particles are not entrained in the air. So, to improve the
effectiveness of an abatement project, why not collect settled dust
samples to make sure that the entire containment is clean and that
the response action is truly complete?
No
asbestos-containing materials + “clean” dust + “clean” air = clean
containment.
Lead
Let’s look at a
similar scenario with a different contaminant: lead. EPA-mandated
lead clearance has required sampling of settled dust. Why? Because
lead is heavy and settles out of the air quickly, and the hazard is
ingestion of lead-containing dust. No air sampling is mandated for
lead clearance. Yes, I know, most asbestos fibers are much lighter
than lead particles, but some will still settle. The small fibers
will be entrained in the air and drawn into the HEPA filters. The
larger particles will settle out.
Now the fun
begins: sampling settled dust. There just happens to be a method for
determining asbestos contamination on surfaces. The folks over at
ASTM International developed the method over a decade ago. The
specific reference is ASTM D5755 Standard “Standard Test Method for
Microvacuum Sampling and Indirect Analysis of Dust by Transmission
Electron Microscopy for Asbestos Structure Number Concentrations.”
For a copy of the complete method, contact ASTM. A summary of the
method follows.
Collecting dust
samples is straightforward. Materials needed:
·
25 or 37 mm sampling
cassettes containing a mixed-cellulose ester (MCE) filter with pore
size less than or equal to 0.8 microns (standard PCM or TEM sampling
cassettes work great)
·
vacuum sampler capable
of maintaining a minimum flow rate of two liters per minute
·
masking tape or
template for demarcating sample area
·
quarter-inch diameter
tubing for connecting cassette to vacuum sampler and constructing
vacuum nozzle
·
sampling log for
recording data (area sampled, location of sample, etc.)
Constructing the
nozzle:
·
Cut a 1–1.5-inch length
of tubing.
·
Cut one end of the
tubing at a 45-degree angle.
The sampling
technician demarcates an area to sample using a template or masking
tape. ASTM recommends 100 square cm for the sample area, but it can
vary either way depending on the amount of visible dust present.
Cleaner surfaces may require larger sample areas while dirtier
surfaces may require smaller sample areas. Remove the end plug from
the cassette. Place the nozzle on the cassette. Calibrate the vacuum
sampler to draw at least two liters per minute using standard
industrial hygiene practices. Make sure to calibrate the vacuum with
the sample cassette on the tubing. Vacuum the sample area for at
least two minutes by moving the nozzle left to right across the
entire area and then front to back across the entire area. Once the
sample is collected, point the nozzle upward, turn off the vacuum,
remove the nozzle and place it inside the cassette, and replace the
plug in the cassette endcap. Make sure to label the cassette with an
appropriate identifier, fill out a chain of custody, and submit the
sample to the laboratory for analysis. The laboratory will need to
know the exact area vacuumed for the sample, so send that
information with the sample.
As a side note,
the ASTM sampling method described above can be used in other
scenarios. It has been successfully used to collect mold samples
from surfaces, to determine the extent of asbestos contamination
from inadvertent damage to asbestos material, and to collect dust
for forensic particle analysis. The method is not limited to hard
surfaces either. Soft goods such as furniture, carpet, clothing and
so forth have all been successfully sampled using this method.
At the Lab
Once the
laboratory receives the sample, technicians will rinse all of the
dust out of the cassette and prepare the sample for TEM analysis
according to the method. The preparation process can be quite
lengthy depending on the amount of contamination and the number of
dilutions the laboratory must perform to make a suitable mount of
the dust. The analyst will analyze the sample on the TEM at a
magnification of approximately 20,000×. Asbestos structures will be
classified and counted using the same counting criteria as standard
Asbestos Hazard Emergency Response Act air clearance samples.
The laboratory
will provide results in number of asbestos structures per square
centimeter of the area sampled, or S/cm2. The report will
also tell you what type or types of asbestos were identified in the
sample. This qualitative information may be helpful in discovering
the source of the asbestos contamination.
But what do you
do with this data? Local, state and federal government really have
not defined any limits for asbestos in settled dust.
This leads us
into an ethics debate that I am not going to discuss at length.
However, there are a few things we, as professionals in this
industry, need to think about: If the government doesn’t provide us
with an acceptable limit for asbestos in settled dust, do we need to
collect the samples? What will happen to the dust after the
abatement crew has left? Will the dust be disturbed and the asbestos
become airborne? Will other construction trades disturb the
settlements to complete their portion of the project? Will occupants
of the building return and clean up the dust? If we, as ethical
environmental professionals, do not investigate this potential
contamination concern, this means that asbestos may still be present
in dust settlements. Doesn’t this increase our liability?
What do you
think? More importantly, what are you going to do?
Jeff Mlekush
is operations manager for QuanTEM Laboratories LLC, based in
Oklahoma City. He has over 13 years of experience in asbestos, lead,
industrial hygiene and IAQ issues. He supervises a knowledgeable,
experienced group of analysts whose mission is to build strong,
long-lasting partnerships with environmental professionals through
quality analyses and a sincere commitment to customer service. He
can be reached by e-mail at asbestos@quantem.com or by phone at
(800) 822-1650.
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