Deficit Feared as Result of Florida Mold Licensing

Standards, Certification among ASHRAE Activities

Publisher's Perspective: Shades of Green

Should I Sample of Allergens or for Mold?

Chicken Little's Contaminant du Jour...

Safety First: Surprises May Lurk in Crawlspaces
 

Voices / Word on the street
 

Voices

“Building occupants may be told that because they don’t have ‘toxic mold,’ their illnesses are imaginary and they should just go back to work – when in reality, IAQ problems may exist causing occupants to suffer allergy and irritation symptoms while in the workplace.”

— J. David Krause, Ph.D., in the editorial featured on page 26

Word on the Street

COMMENTS ON MOISTURE MANAGEMENT
A standard drafted by the Greenguard Environmental Institute, of Marietta, Ga., is available for public review and comment through June 4. BSR/GEI “Moisture Management in Buildings” applies to new construction, providing protocols for mold prevention as well as operations and post-occupancy maintenance. Copies of the draft standard, which is to be submitted for approval of the American National Standards Institute, can be obtained through Greenguard’s Ethleen Howell by e-mail at ehowell@greenguard.org.

HARTMAN ELECTED TO IAQA BOARD
Larry Hartman, CIEC, was elected to the Board of Directors of the Indoor Air Quality Association last month. His election came after David Bell, Ph.D., resigned from the IAQA Board after departing his position at Environmental Microbiology Laboratory late last year to pursue a career in the water quality industry.

Since 2001, Hartman has served as vice president and facilities environmental services manager, for WaMu, formerly Washington Mutual Bank. He joins one other facilities management professional serving on the IAQA board, Michael Casanova, indoor air quality manager for Lee County Facilities Management in Florida.

Hartman has environmental responsibility for all WaMu corporate facilities, including more than 3,000 throughout the United States. In the two decades prior to his WaMu position, Hartman worked in operations for asbestos contracting firms, where he oversaw more than 10 million square feel of abatement projects. Hartman has also been involved in mold remediation projects since 1987.

While members of the IAQA board are normally elected by the membership, IAQA’s bylaws allow the organization’s Board to elect a member to serve the remainder of the term of a director who resigns. Hartman’s term on the Board expires in October 2008.

“We are thrilled by the addition of Larry Hartman to the IAQA Board of Directors,” said Robert G. Baker, IAQA president. “Larry not only brings a wealth of knowledge and experience to the board, but he also helps broaden representation of those responsible for the management and operations of buildings on the IAQA Board.”

FEDS MAY TACKLE ‘SNAKE OIL’ FILTER TECHNOLOGIES
John Wimer of the National Center for Energy Management and Building Technologies is to lead a presentation on reduced energy use through reduced indoor contamination in residential buildings during the June 6 meeting of the Federal Interagency Committee on Indoor Air Quality. That day’s meeting is to kick off with a preliminary discussion that the committee’s executive secretary said may be focused on “‘non-traditional’ filtration and air cleaning technologies that people are hearing a lot about but don’t know how well they work, including UVGI, PCO, electrostatic, gaseous air cleaning in general, plus a few other items that might belong in the ‘snake oil’ category.” The CIAQ, which currently meets three times a year, had first discussed the idea of having a meeting focused on filtration during a meeting last July. For more information on the meeting, visit the committee’s Web page at www.epa.gov/iaq/ciaq or call Executive Secretary Philip Jalbert at (202) 343-9431.

ODD PLACES TO PROTECT HEALTH
The discovery of mold in a basement ceiling at a health department building serving Greene County, Tenn., was to be removed for an expected sum of nearly $50,000, Tri-Cities News Channel 11 reported last month. The building had been undergoing renovations when the discovery was made, the station’s Melinda Perkins said in a report posted online April 13.

That story did not involve any occupant health complaints from within the health department, contrasting with a similar tale out of the Las Vegas Sun that hit the Internet March 26. It included, on one side, Dan Pauluk, 57, a public health inspector who claimed that “toxic mold” at his office was killing him. On the other side was the public health agency that employed Pauluk and was now appealing a decision that awarded him a portion of his salary and reimbursed him for medical bills. According to the story, the latest of six environmental studies at Pauluk’s office said there was no mold anymore, and the health agency admitted mold used to be in some ceiling tiles.

A news item released March 26 by the NBC affiliate in San Diego revealed that an HVAC system at a naval medical center was being rebuilt after several mold species were discovered there. The station quoted Capt. David Tam, deputy commander at the facility, as saying a comparison of indoor to outdoor mold levels proved the place was still “a safe environment for patients.”

SOMETHING’S COMING
The chance that a Category 3 or higher hurricane will reach the U.S. coastline by December is higher for this storm season than in years past, predict forecasters with Colorado State University’s Tropical Meteorology Projects. The researchers, William Gray and Phil Klotzbach, warn that the hurricane season beginning June 1 could result in five anticipated tropical storms reaching magnitudes of at least a Category 3 hurricane. Their April 3 report finds a 74 percent probability of one such major storm hitting a U.S. coastline this year, compared to an average of 52 percent for each season over the last century. The landfall risks of major hurricanes are above average in many coastal areas, including the U.S. East Coast including the Florida peninsula, the Gulf Coast from the Florida panhandle westward, and in the Caribbean, the researchers say. Their updated seasonal report is anticipated – online at typhoon.atmos.colostate.edu/forecasts – on the eve of the hurricane season.

BACK FROM THE DRAWING BOARD
A proposed standard setting requirements for inspection and maintenance of HVAC systems was open for a second round of public comment between March 16 and April 30. ASHRAE/ACCA Standard 180P, “Standard Practice for Inspection and Maintenance of Commercial Building HVAC Systems,” is to establish minimum HVAC inspection and maintenance requirements that aid a system’s ability to achieve acceptable thermal comfort, energy efficiency and indoor air quality in commercial buildings. Baker, who chairs the committee drafting the standard, said comments received last autumn during an earlier public review of the document “helped us to clarify and reword some areas to avoid confusion.” The standard is being developed by the American Society of Heating, Refrigerating and Air-Conditioning Engineers and the Air Conditioning Contractors of America.

 

Deficit Feared as Result of State’s Mold Licensing

Proposals Appear Destined for Floor Votes in Both Houses
By Steve Sauer

An amended version of legislation intended to license mold professionals passed two Florida Senate committees in April despite concern that the regulation would result in a deficit for a state already under a financial spending crunch to minimize budget deficits.

Senate Bill 2234 establishes education and experience requirements for an applicant seeking a license in mold remediation or assessment. The bill provides for the funding of state programs in licensing mold remediators and assessors, as well as home inspectors.

The Florida Department of Business and Professional Regulation has “indicated that the fees as estimated would not be adequate to support the cost of regulation,” according to analysis filed last month by staff of the Senate Criminal Justice Committee. The state is expected to lose $17,954 every two years after an initial gain, according to department estimates cited in the analysis.

The committee’s eight members voted unanimously to report favorably on Senate Bill 2234 on April 17. The committee including both mold regulation supporters in the state Senate: Stephen R. Wise, the bill’s sponsor, and Mike Bennett, who himself had sponsored legislation to regulate the mold industry in 2007 for a fourth year in a row.

While state lawmakers determine the fate of the mold legislation, some in the House are also attempting to fend off a budget deficit by trimming annual spending by as much as $1 billion, states a Bloomberg report in March. That report also quoted an analyst who said the state may face the first drop in general fund revenues since 1975.

Compounding staff concerns with Wise’s Senate bill on mold licensing is the fact that while the legislation charges licensing fees for those taking examinations, it does not authorize the department to assess licensing fees for those taking advantage of a grandfathering clause.

Under the bill’s grandfathering clause, applicants may forego having to take state exams through July 2008 if they meet certain requirements in education and experience. An applicant is qualified by having a two-year degree in a field of science and at least one year of field experience. Under the bill, an applicant could otherwise qualify for a licensure exam simply by having a high school diploma or equivalent and at least four years of field experience related to the job.
The committee staff analysis questions the purpose of the grandfathering clause. “The intent of this provision is not clear,” it said.

A grandfathering clause was first added to a proposed mold bill in Florida during last year’s legislative session, after a 2005 veto by Jeb Bush, then governor of Florida, said that not having such a clause would put some “responsible and experienced mold assessors and remediators ... out of business” if they could not meet training and experience requirements before the bill would take effect.

Last year, a House bill that would have regulated mold without creating a state licensing program unanimously passed the House floor but stalled in the Senate due to a lack of supporters, including Bennett.

Missing from the equation this year, in contrast with 2005 and 2006, is lobbying participation from an organization known as the Florida Coalition for Healthy Indoor Environments. It combined the lobbying efforts of several companies and organizations in the mold industry, including the National Air Duct Cleaners Association, the Indoor Air Quality Association, and the Institute of Inspection, Cleaning and Restoration Certification, among others.

Some coalition members have been lobbying, either directly or indirectly, to shape the mold legislation. The American Industrial Hygiene Association, which was not a member of the coalition, sent a letter to Bennett in January saying, among other things, that certified industrial hygienists, certified safety professionals and “other individuals who have undergone considerable training and education ... who may also meet the minimum qualifications to be considered qualified and capable to control mold.”

Wise’s Senate bill bears an effective date of Oct. 1. The Criminal Justice Committee staff analysis expressed a doubt that this deadline allows “sufficient time to effectively implement” its licensing programs for mold remediators and assessors and for home inspectors.

The bill had previously sought to regulate another category of professionals – those who analyze a buildings’ resistance to gale-force winds. All provisions relating to wind-mitigation assessors have disappeared.

One route for an individual to qualify for a mold license under the House bill is by having a two-year degree in a field of science and at least one year of field experience. At least a year of experience in microbial sampling or investigating counts for assessors, and at least a year of field experience counts for remediators.
Applicants could otherwise qualify for a licensure exam simply by having a high school diploma or equivalent and at least four years of field experience related to the job.

A projection by the Florida Association of Building Inspectors that there may be 215 mold inspection applicants in Florida is cited in the Senate Criminal Justice Committee’s analysis. It says the estimate is based on the number of applications received in Texas, where a licensing program for mold professionals took effect in 2004.

In Texas, there were 284 licensed mold-remediation contractors, 421 mold-assessment consultants and 95 mold-assessment technicians, according to state records compiled in January 2007.

Under Wise’s Senate bill, the Florida Department of Business and Professional Regulation lacks the ability to increase or decrease licensing fees. This created another point of concern within the committee staff analysis, which said would jeopardize the department’s ability “to increase or decrease fees by rule to maintain the financial integrity of the account.”

Earlier in the month, another Senate committee amended the bill to purge its originally submitted language in favor of wording nearly matching a House bill introduced in March by Rep. Carl Domino.

“Currently there are no practice requirements, minimum standards or prohibitions to be a home inspector, mold assessor or mold remediator,” Domino said in a comment published within an official analysis of the bill. He said this lack of regulation leaves homeowners with “no assurances who they hire are competent or trustworthy” and that “many Floridians have been harmed financially when they have hired untrained or unscrupulous persons.”

Domino, in a letter addressing attendees of an Indoor Air Quality Association chapter workshop in February, said he supports the inclusion of mold-industry certifications that are independent and third-party-accredited “as requirements for individuals performing indoor air quality services in Florida.”

However, the lawmaker’s House Bill 1399 does not mention industry certifications. Instead, the requirements for an applicant’s education and experience it establishes are arbitrary.

One route for an individual to qualify for a license under the House bill is by having a two-year degree in a field of science and at least one year of field experience. At least a year of experience in microbial sampling or investigating counts for assessors, and at least a year of field experience counts for remediators.
Applicants could otherwise qualify for a licensure exam simply by having a high school diploma or equivalent and at least four years of field experience related to the job.

These provisions were added to Wise’s Senate Bill 2234 by way of an amendment on April 8, when it was approved unanimously by the eight members of the Senate Committee on Regulated Industries, of which Wise is a committee member.

This substitution withdrew earlier language that included definitions of the levels of contamination set by the IICRC S520 mold remediation standard published in 2003, and generic uses of the phrase “indoor environmental professional,” which IICRC has trademarked.

The House Committee on Business Regulation unanimously approved Domino’s bill during a March 29 hearing. Committee members, who had approved a similar measure by Domino in the previous legislative session, were able to bypass hearing public comments in favor of the bill by indicating they would report favorably on it.

The House bill was also referred to the Jobs and Entrepreneurship Council, which approved it unanimously on April 12. It was also referred to the Policy and Budget Council, which was not known to have scheduled a hearing for the bill by press time.
Earlier estimates of the House bill’s financial impact had painted an even bleaker picture of licensing’s consequences, saying the program’s annual operational estimates of $730,132 would not be supported. This was, in part, due to an assumption that regulation would require as many as eight full-time staff positions, and because those estimates also incorporated the since-withdrawn proposed licensing of wind-mitigation assessors.

Legislation passed by both houses advance to Gov. Charlie Crist, a Republican, for his approval. Crist, who began his term as governor in January, is a former state senator who served as state attorney general while Bush was governor.
 

Standards, Certification among ASHRAE Activities
Compiled from news releases at www.ashrae.org

A busy month that included a long-anticipated satellite broadcast on indoor environmental design also saw the release of several proposed changes to a ventilation standard and the publication of a load-calculation standard, all part of a bustling period. Those activities by the American Society of Heating, Refrigerating and Air-Conditioning Engineers took place as the organization readies to début its first certification program next month.

Five draft addenda to ASHRAE Standard 62.1, “Ventilation for Acceptable Indoor Air Quality,” were released for public comment through April 30. The standard sets minimum ventilation rates and other requirements for commercial and institutional buildings.

Proposed addendum 62.1c would add air-cleaning requirements to section 6 of the standard. If approved, systems in non-attainment areas for particulate matter with diameter 2.5 microns (PM2.5) would need to use intake air filters with minimum efficiency reporting value (MERV) 11.

The use of better filtration would improve indoor air quality, said Dennis Stanke, who chairs the 62.1 Committee.

In addition, systems in areas designated by the U.S. Environmental Protection Agency as “serious,” “severe,” or “extreme” non-attainment areas for ozone would require ozone air cleaners with at least 40 percent efficiency. “The standard has required 40 percent efficient ozone air cleaning for some of these high-ozone areas since 2004, but designers have had difficulty determining when this requirement applies,” said Stanke. “If more designers understood which geographical areas require ozone air cleaning and used 40 percent ozone air cleaners in those areas, indoor air quality would be improved for many people.”

Also released for public comment was addendum 62.1i, which would change minimum outdoor airflow requirements for zones with environmental tobacco smoke as described in section 6.2.9. “This issue attracted significant interest during its first public review period, resulting in many comments,” said Stanke.

Based on public input, the current addendum was revised and now requires that ETS be supplied with more outdoor air than areas with the same occupancy category but without ETS (i.e. ETS-free areas). The outdoor airflow rate would be determined using “engineered methods with the approval of the authority having jurisdiction.”

“Some committee members feel that including a requirement for increased outdoor air flow would imply that dilution ventilation can be used to achieve acceptable IAQ in the presence of ETS, and that the ‘engineered methods’ requirement places an undue burden on local authorities,” said Stanke. “The majority, however, feels that removing all reference to outdoor airflow in ETS would mean that any outdoor airflow rate – even a rate below that required for ETS-free areas – would comply with the standard, and that local code authorities must always approve engineered solutions. We’ll see what the public thinks based on this second public review.”

Other 62.1 addenda that were under review:

• Addendum 62.1a – addresses compliance issues that may result from unclear wording or phrasing in section 5
   

• Addendum 62.1b – clarifies informative language in appendices C, D and F
   

• Addendum 62.1d – adds kitchens, banks and their lobbies, break rooms, sorting, packing, light assembly, general manufacturing and storage rooms (dry) as occupancy categories in Table 6-1

One new change to Standard 62.2, “Ventilation and Acceptable IAQ in Low-Rise Residential Buildings,” was published. Addendum 62.2h, according to its foreword, “modifies the requirements for the selection of air-moving equipment in Section 7.1 of ASHRAE Standard 62.2-2004.”

The addendum’s first public review resulted in one comment during a 30-day period between March and April 2006, an ASHRAE spokesperson said. It was approved for publication by the American National Standards Institute on March 27.

In October 2002, ASHRAE said 62.2h describes an “IAQ procedure [that] is a performance-based design approach in which a building and its ventilation system are designed to limit concentration of contaminants at certain levels.”

ASHRAE’s latest free broadcast and Webcast, “Indoor Environmental Design: Practical Solutions to Everyday Problems,” took place April 18, including individual presentations called “Ventilation Systems: Avoiding Common Mistakes by Using Three Keys for Sustainable Design”; “Ventilation Air: First, Do No Harm”; “Noise, IAQ and Thermal Comfort – Can You Have It All?”; and “Behind the Access Door – Advances in Affordable Filtration for IAQ.”

Four ASHRAE certification programs are in development for launches over the next year and a half. An exam for the first, the Healthcare Facility Design Professional, is to be administered June 28 in Long Beach, Calif., immediately following ASHRAE’s Annual Meeting. Eligibility requirements for the certification range from a licensed professional engineer with two years’ experience in healthcare HVAC&R design to a high school diploma or equivalent and a minimum of 10 years’ experience in HVAC&R design with at least seven specialized in healthcare HVAC&R design.

The organization on April 13 announced a call for members wishing to participate in a newly announced committee to write a standard called “Energy Efficient Design of Low-Rise Residential Buildings.” The standard will apply to new residential dwelling units ¬¬– including single-family houses, multifamily structures of three stories or fewer above grade, and modular houses – and their systems. The standard will not apply to new portions of residential dwelling units and their systems, new systems and equipment in existing dwelling units, or “transient” housing such as hotels, nursing homes or jails.
 

Q. I’ve been told that people have mold allergies. Shouldn’t I be sampling for the allergens rather than the mold?
A. The answer, as always, is yes and no. First, though, let’s recap the subject of allergens. Allergens are specific chemicals that cause some appropriately exposed people to develop a specific immune response. In genetically susceptible people, allergens cause the body to produce ImmunoGlobulin E, or IgE. Upon re-exposure, this leads to the release of inflammatory chemicals such as histamine that cause the symptoms associated with allergies. Thus, we have a chain of chemicals (molecules) that leads to a response: Allergen --> IgE --> Histamine

Ideally, one could measure histamine to evaluate response, IgE to measure sensitization and to confirm that exposure has occurred at some time in the past, and allergens to determine where exposure has occurred or is occurring. So, the ideal environmental measure is allergen. However, there is no general test for allergens. In order to use allergen as the environmental measure, you have to know exactly which allergen is of interest, and whether or not there are tests available for that allergen. Since virtually all living things produce some chemicals that are allergenic, we are faced with a formidable problem.

In the majority of cases, one of the common allergens will be involved. These are produced by cats, dogs, mice, rats, cockroaches, dust mites, and, of course, the fungi. If you know there are one or more cats, dogs, or other furry pets in a home, there is little use in measuring allergen. It will certainly be there. Better would be to educate the homeowner about the ubiquity of these allergens when the source animal is present. Mice, rats, and cockroaches can also be seen. However, there is some social stigma to their presence in a house, and the occupants may deny their presence. Setting traps is one approach to discovering whether or not these pests are present. However, you can also readily measure allergen concentrations in dust (we’ll get to how to collect the samples in a minute).

Dust mites are tiny, and generally not visible to the naked eye. They are consistently present in bed dust (and generally in floor dust as well) in humid parts of the country. However, they may also be present under apparently dry conditions (remember that while you are in the bed, the climate under the covers is warm and humid). If night time asthma is of concern, dust mites would be a good first guess as an allergen source, and measurement of dust mite allergens is appropriate.

Finally, we come to the fungi. All fungi probably produce allergens, although (unlike the animal and plant allergens) their production is inconsistent, and the kinds and concentrations of allergens produced may vary widely within a single fungal species.

In some cases, allergen can be extracted from dead spores (e.g., Alternaria alternata). In other cases the spore must be living and begin to germinate before the allergens are released (e.g., Aspergillus fumigatus). Another problem lies in the fact that a single allergen may be produced by several different kinds of fungi. In view of these complications is it really useful to measure fungal allergens in investigating situations where the aim is finding sources and conducting remediation? Generally, I would say no. Fungal growth is relatively easy to see visually, and, as always, if you see fungal growth, then you know it exists and further testing is not generally useful. If you can’t see the fungi, then spore trap samples will tell you if there is hidden growth that is releasing spores with their associated allergens.

To evaluate whether or not there are inappropriate concentrations of fungal spores in dust one can use dust culture, direct exam, or, perhaps, the new EPA method that uses a DNA method to look for 36 common fungi. Note that there are no baseline data to allow evaluation of the last type of analysis. We’ll talk about that method in another article. At this point, then, I would not recommend collecting samples for fungal allergen analysis, except under specific, unusual circumstances.

A final word on collecting samples for allergen analysis: You need dust samples for these analyses, and you should collect at least a teaspoon full of dust. You can use filter cassettes, or vacuum cleaners. It is generally not advisable to use dust from the occupant’s vacuum unless you use a new bag. Cockroaches and dust mites both can reproduce within the vacuum bag. For dust mites, the best source for dust is the bed of the person experiencing symptoms. Collect dust from pillows, mattress, and all layers of bedding. For cockroaches, mice, and rats the best source is kitchen dust. Be sure to collect dust from within cabinets as well as on the floor near the cabinets. Pet allergens can be measured in floor or furniture dust.

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.
 

Editorial: Chicken Little’s Contaminant du Jour –
Calling for a Comprehensive Approach to IAQ

J. David Krause, Ph.D.
President
Indoor Air Solutions Inc.
Tallahassee, Fla.

The hyper-focus on mold prevalent throughout much of the indoor air quality industry today has been detrimental to Americans and underlies the skewed perception of the public. Indoor air quality, a component of environmental public health, is where science, politics, and business converge. Specialized certifications for mold assessors, mold consultants, and mold remediators illustrate the blinders that many in the industry have donned.

For many years public health and air quality professionals tried to raise concerns about water damage and mold growth in homes and commercial buildings. Prior to the CDC Cleveland cluster assessment in 1994 (Morbidity and Mortality Weekly Report Vol. 43, pages 881–883), mold damage was often dismissed by building owners and employers as inconsequential or a nuisance.

Despite CDC redacting most of the original report’s assertions in 2000, the media latched onto phrases like “toxic black mold” and Stachybotrys chartarum became a part of every American’s vocabulary (J. David Miller et al. in the journal Medical Mycology, August 2003). Media warnings about the possible hazards from exposure to fungi were presented as TV sound bites with backgrounds of visually disturbing images of mold-damaged homes, classrooms and hospitals. Stories on “toxic mold” found at the neighborhood elementary schools, nursing homes and government buildings proliferated.
After the media ran the stories, public hysteria and outrage manifested into a blossoming of consultation, remediation, litigation and legislative action. Recommendations for further research were all but ignored by federal agencies and legislatures.

The contaminant du jour has been mold for the last eight years to a decade, depending on your perspective. “Toxic mold” seems to be running a course similar to that of a pop song or hairstyle: the familiar stages of novelty, popularity, and finally overplay. If a public health hazard is sensationalized and treated as a fad or fashion, the public may lose confidence in public health authorities.

Implications for the Practice of IAQ Consulting
So, how does chasing mold hurt anyone? By hyper-focusing on a single, fashionable contaminant, even if it does photograph nicely, consultants run the risk of finding mold but missing the other pollutant sources that may actually be causing the complaints or illness. Public health agencies and professional organizations can lose credibility when so much effort has been spent on educating the public about mold, with an absence of consensus on standard test methods, or interpretation of results. Building occupants may be told that because they don’t have “toxic mold,” their illnesses are imaginary and they should just go back to work – when in reality, IAQ problems may exist causing occupants to suffer allergy and irritation symptoms while in the workplace.

Guidance from Government Agencies
In response to the media’s focus, the public’s inquiries, and requests from professionals, several guidance documents on mold in buildings have been published that advocate a comprehensive, balanced approach. The US EPA began publishing many useful guidance documents in the early 1990s, exemplified by the “Building Air Quality Guide: A Guide for Building Owners and Facility Managers” (1991).
This and numerous other documents are available online at the EPA Web site. A comprehensive discussion of their research needs was published in the March 2005 “Program Needs for Indoor Environments Research.” A review of this publication should convey to most professionals and laypersons the vast amount of information we don’t have, or we are severely lacking in depth.

The report acknowledges, “The ability to understand the relationship between mold exposure and health is a foundational issue and requires that techniques to reliably and accurately assess mold exposure be developed” (emphasis added).

Without a solid scientific foundation, how can meaningful public health policy be established? If consultants cannot reliably and accurately measure mold exposure, then how can they offer meaningful opinions regarding quantifiable health risks from mold exposure?

As often occurs in public health, general guidance advocating that mold contamination be prevented, avoided and abated has been proffered in the EPA guidelines for the remediation and cleanup of mold and moisture problems in schools and commercial buildings (“Mold Remediation in Schools and Commercial Buildings,” 2001).

Guidance from Professional Associations
Several professional associations, primarily lead by Industrial Hygiene Professionals, have published consensus guidance documents on mold in the workplace and other indoor environments. The 1999 “Bioaerosols: Assessment and Control,” published by the American Conference of Governmental Industrial Hygienists, has been adopted as an authoritative resource for information on mold and other relevant microorganisms.

A 2004 publication by the American Industrial Hygiene Association followed with more specific guidance on the practice of “Assessment, Remediation, and Post-Remediation Verification of Mold in Buildings.” This latest guidance, while diminutive in size (18 pages), actually says more about who, how and why mold should be tested than its voluminous predecessor. It tackles the sensitive issue of competencies that a professional should possess and addresses some of the limitations that current sampling methods have.

Many other guidance documents were not mentioned above, and their omission is not intended to suggest they don’t deserve credit or merit; time and space preclude a comprehensive discussion of their contributions to the practice of indoor air quality and mold assessment. All IAQ and mold consultants should familiarize themselves with all of the relevant guidance documents. The brief discussion of these specific documents was offered to illustrate that guidance has been published by various consensus organizations and governmental public health agencies.

A thorough review reveals that available guidance documents are not in total agreement with one another and that each acknowledges significant gaps in scientific foundation, testing methods, and remediation of mold. Over the past few years, it has appeared that most guidance documents have focused on mold and microbial contaminants, neglecting the broader issue of indoor environmental pollution.
The most well rounded approach to indoor environments has been advocated by the EPA’s Indoor Environments Division. The lack of updates and revisions for guidance documents from the EPA may reflect the shifting priorities of the current administration, but does not reflect the need for continued efforts to improve public health and indoor air quality.

Readers are encouraged to review the EPA’s “Program Needs for Indoor Environments Research,” available at www.epa.gov/iaq/pubs/npier.pdf, to reacquaint themselves with the needs for further research and testing. Despite many of the delicate issues these guidelines attempt to address, they do for the most part answer many important questions.

A wealth of practical information and research findings can be gained by reading the available scientific literature, research reports, and public health guidance documents. With time and effort most well intentioned professionals can divorce themselves from their preconceived notions long enough to learn something new. Given time, the information might become incorporated into their standard operating procedures by consultants and remediators. With leadership from competent professionals these organizations may be able to agree on guiding principles for assessing indoor environments and their impact on health. Until then, this industry will continue to chase the contaminant du jour.

Professional Competencies
In the absence of a strong foundation in science or regulatory mandates, it will be the professional opinion that reigns supreme. Defining what constitutes a professional would be a logical exercise. The most comprehensive discussion of what constitutes a competent professional in relation to mold assessment can be found in Appendix 2 of AIHA’s “Assessment, Remediation, and Post-Remediation Verification of Mold in Buildings.” With a few additional areas of study, the list of competencies this document describes could apply to an indoor environmental consultant.

Various state laws and proposed bills have defined acceptable education, training and experience but frequently do not address competencies. Competencies identify the knowledge, skills, and abilities required to perform the identified task.
Competencies are described in a way that they can be measured. Certification programs often address the knowledge, skills and experience necessary to be certified but may not define the related competencies. Consensus on the competencies that one should possess to design and conduct an indoor environmental assessment would be an indicator that this professional field is maturing.

Consensus on a Paradigm for Assessing Technologies
Technology marches forward, often in the absence of regulation, standards, or scientific foundation. Each technology that promises to improve our ability to detect, measure and identify a contaminant often does so without a milepost to compare its advantage. In the fields of pharmacology, drinking-water safety and radiation, well defined measurement standards exist that have relevance to levels capable of impacting health.

The field of mold assessment is without a health-based dose-response level of detection. Measurement methods vary greatly and may likely overlap with clinically insignificant concentrations. It is not even agreed that measuring mold spores is the right thing to do when assessing a building for mold contamination. Without the foundational understanding of the relationship between health and exposure to mold, we cannot assert that any measurements have predictable relevance to occupant health.

The criticality of reliable and accurate measurement methods to assess occupant exposure has been ignored for too long. A few methods have been relied upon for several decades to measure bioaerosols, and without scientific justification used to diagnose buildings and risks to occupant health in a variety of indoor environments.
While all technologies intended to measure and detect indoor mold sources are not the same, it is conceivable to hold each to a standard validation process capable of assessing their relevance. Specifically, what is a test method’s ability to detect what they claim to, and with what accuracy, bias, specificity, and reliability. A “validation process” applied to existing and future measurement and detection technologies could enable users to choose appropriate investigative tools and diagnostic methods.

Why Do We Assess Indoor Environments?
Rarely is the reason to determine what is normal, typical or healthy. I would venture that most assessments of indoor environments have been due to occupant complaints of illness. In recent years, a slightly greater proportion may have been to avoid or prevent foreseeable problems. A due-diligence assessment as part of a real-estate transaction may be focused on microbial contamination. A post-incident assessment for mold or bacterial contamination after a water intrusion event may occur to verify that drying and cleaning efforts were successful. These assessments are often narrowly focused and exclude many environmental issues that can cause occupant complaints.

The most common driving force for an indoor environmental assessment is an occupant complaint related to illness. When these assessments begin with a narrow focus such as a mold assessment, they run a real risk of missing other factors potentially contributing to occupant illness. Remember, there is no reliable way of measuring occupant exposure to mold and current air sampling methods cannot determine if occupants are at increased risk of adverse health effects. It turns out that most research shows the amount of visible mold growth to be the best predictor of adverse health effects. The unfortunate conclusion is that with all the monitors and sampling tools available to investigators, our eyes still provide the most reliable detection tool. If our eyes are focused on mold and yet are blinded to the multitude of other indoor contaminants – whether biological, chemical or physical – then a distinct probability of missing the root cause exists.

Any person hired to assess indoor environments should be sufficiently trained and experienced to identify a plethora of indoor pollution sources other than the contaminant du jour, mold. When these assessments are performed to identify potential causes of occupant health complaints, it is critical that all blinders be removed.

My favorite example is one where a teenager almost died due to misdiagnosis by medical doctors and environmental assessors. The child was treated for allergies because of mold damage from a roof leak. His bouts of sleepiness and headaches were dismissed as depression and treated with the appropriate pharmaceutical. It was sheer luck that he was eventually taken to an emergency room where they tested him for carbon monoxide poisoning.

It turned out that the roofers repairing the leaky roof had blocked the exhaust flue of the natural gas water heater that resided in the kid’s bedroom, a converted garage. Missing that important clue almost cost this kid his life, even though they found and remedied the mold.

Diffusion of Knowledge
Diffusion of knowledge gained from anecdotal assessment findings and academic research programs, back to building designers, engineers, product manufacturers and academic institutions for professionals is essential. Unless the information gained from building assessments and research programs is translated into knowledge taught in universities and professional training programs, the same mistakes will be repeated.

The broad scope of indoor air quality problems and their root causes almost requires practitioners to be highly trained generalists. However, due to our system of educational and professional associations, what we most often have are a series of specialists visiting a building and offering diagnoses based upon their training and experience. This brings to mind the parable of three blind men surrounding an elephant and using their hands to determine what the animal is, with each concluding the creature to be a different animal due to a unique and isolated perspective.

Where Do We Go from Here?
A comprehensive approach should be adopted as the standard of care when investigating indoor air quality and indoor pollution sources. We should all attempt to keep our preconceived notions in check, while still using our experience to guide our assessment. Despite our clients and market forces, professionals should design and conduct their assessments with forethought and avoid the temptation to offer boilerplate investigations.

Indoor environmental consultants have some valuable services and skills to offer in today’s world. Regardless of an individual’s education, training or experience, a well thought-out assessment designed by a competent professional can be invaluable for people in need. New and existing technologies can be evaluated using a validation process, enabling users to choose appropriate investigative tools and diagnostic methods.

Rather than prescriptive methods of assessment, we should establish an acceptable paradigm for planning, assessing and testing indoor environments that meets an agreed-upon standard of care for competent professionals. By adopting as a standard of care a well-rounded, comprehensive approach to assessing indoor environments and associated health complaints we may reduce the tendency to run around like Chicken Little searching for the contaminant du jour.

Dr. J. David Krause, CIAQC and CIEC, is a member of the IE Connections Editorial Advisory Board. The president and founder of Indoor Air Solutions, he has practiced industrial hygiene since 1990 performing environmental health evaluations in a variety of indoor environments. Krause established the Indoor Air Assistance Program for the Florida Department of Health, and he has been involved in several local and national efforts to quantify the impacts of indoor air pollution, including the EPA-sponsored National Air and Radiation Indicators Project. He can be reached by e-mail at dkrause@indoorairsolutionsinc.com or by phone at (850) 561-6422.

I said, “Oh no.”
She said, “What’s the matter?”
I said, “Look.”
She shrieked, “Oh no, snakes!”

In the light from the flashlight, I could see 35 or 40 snakeskins from about 18 inches long to over seven feet long. There were a number of “tubes” burrowed through the attic insulation. We were standing in a nest of snakes! I am so glad it was 12 degrees!

You could have heard her screams in the next county. She was starting to shake, and I was afraid she would lock up from fear, so I said, “Look, lady, me and Indiana Jones don’t do snakes either.”

This had the desired effect of a small laugh.

I said, “This is a civilized attic. It has a walk board. I’ll cover your back. You cover mine. If you see anything move, you scream.”

She gave a timid chuckle and said, “You don’t have to worry about that!”
We hurried through our inspection of the attic. Fortunately, nothing stuck its head out of the fiberglass insulation.

When we got back to the scuttle, there were six people trying to see us. Buyers (husband and wife), sellers (husband and wife), and two real-estate agents. I didn’t have to say a word; the home inspector did the talking.

The sellers arranged for some kind of “critter control” company to suck out the insulation and to gather all the snakes. I was kind of surprised because neither the buyer nor the seller objected to the snakes. I guess it was because they were both attorneys; they must have considered that it was an act of professional courtesy.
After I told this story to a good ol’ boy from western Texas, his laconic reply was, “You don’t have to worry ’til you hear the rattle.” So, I guess it could have been worse.

A new problem we must look for is meth labs. For each pound of meth generated, you get three to four pounds of toxic waste, and this is bad stuff! It used to be that this was a problem in old, abandoned farmhouses way out in the country. No more. Recently, we had the case of an attorney cooking up meth in small batches at his big house on the lake.

I recently attended a class offered by the Ohio Department of Health in conjunction with the Highway Patrol and Drug Enforcement Administration. If a class is offered in your area, go to it. You need the data.

Let’s face it: Indoor environmental consultants and home inspectors have a pretty interesting job. But it can be a dangerous one. For the one-man company, if you are hurt, you don’t work. So this should be important.

Tools, PPE and insurance are important but can do only so much. Common sense, combined with an awareness of the risks faced, lets us handle these risks, if we put safety first.

Frank B. Dean, CIE, is the CEO of The PDF Group LLC in Columbus, Ohio. He is active as an indoor environmental consultant offering assessments, consulting, training and litigation support in a multi-state area. He is also an approved course provider and certified instructor for the Indoor Air Quality Association, delivering the prep course for the American Indoor Air Quality Council’s CRMI designation. Dean can be reached by e-mail at pdfgrp@earthlink.net or by phone at (614) 846-7100.