Guest guest Posted January 29, 2011 Report Share Posted January 29, 2011 Wei: On 02-09-2010 I sent 2 requests to EPA (names withheld here but they were the listed contacts for each aspect): 1. " I'm looking for the full report on ERMI for the 1,096 homes as indicate in the article: Vesper, Development of an Environmental Relative Moldiness Index for US Homes, J Occup Environ Med, 49, 8, 829 - 833, 2007 I'm also looking for the data on the 13 species subgroup being referred to as ARMI. Where might I acquire this? " And 2. " I am interesting in finding out about the panel for: Environmental relative moldiness index (ERMI) Applications See: http://yosemite.epa.gov/sab/SABPRODUCT.NSF/36a1ca3f683ae57a85256ce9006a32d0/ 404812d3408f7fc2852574f10045e2f1!OpenDocument " Neither was responded to. So much for transparency and Freedom Of Information Act (FOIA). I think I'll retry with a cc to my senators. Tony ....................................................................... " Tony " Havics, CHMM, CIH, PE pH2, LLC 5250 E US 36, Suite 830 Avon IN 46123 www.ph2llc.com off fax cell 90% of Risk Management is knowing where to place the decimal point...any consultant can give you the other 10%(SM) This message is from pH2. This message and any attachments may contain legally privileged or confidential information, and are intended only for the individual or entity identified above as the addressee. If you are not the addressee, or if this message has been addressed to you in error, you are not authorized to read, copy, or distribute this message and any attachments, and we ask that you please delete this message and attachments (including all copies) and notify the sender by return e-mail or by phone at . Delivery of this message and any attachments to any person other than the intended recipient(s) is not intended in any way to waive confidentiality or a privilege. All personal messages express views only of the sender, which are not to be attributed to pH2 and may not be copied or distributed without this statement. Quote Link to comment Share on other sites More sharing options...
Guest guest Posted January 31, 2011 Report Share Posted January 31, 2011 Am I the only one who laughed out loud when I saw that the ERMI health risk assessment calculation involved the division of the amount of some types of mold by the amount of other types of mold? Now, that's funny! Get it? 1. Yes. A good spin document must be about 90% true in order to be a good spin document. 2. (I have a minor in accounting. Like principles of simple math a lot.) How did they justify the logic for using this numerator/denominator equation to reach the conclusions stated? 3. Example of a spin in simple math based on a legitimate hypothesis with a leap to a false conclusion: 5 x 5 = 25; therefore all numbers multiplied by themselves = 25. 4. Where are the false and illogical statements along the way in the hypothesis = conclusion; not founded on principles of math or science? Is there only one or several? 5. Is it kind of like that? Sharon Quote Link to comment Share on other sites More sharing options...
Guest guest Posted January 31, 2011 Report Share Posted January 31, 2011 and All, Whenever I see a paper that professes to establish something that I know is not true, I take that paper and go down thru it word for word, line for line, reference by reference - until I can find the EXACT spin words in the document. They are always snuck in there somewhere. Once you can cite the exact spin words, it makes it easier to articulate the problem. Can we put the ERMI paper on this board and do that together? Sharon,One more thing, (or two or three): the limited species that are used as the comparison data are also an issue. If you can only ID 32(?) species, what does one say/conclude about presence/lack of the other 249,962 species that "might" exist in that environment? (my assumption is there are a finite yet very large set of fungal species likely to arise at any given time in a building, with some estimates hovering around 250k.)And...how can one create a baseline of "normal ecology" when there is no, repeat "no", consensus on what is acceptable as normal (not acceptable as safe, merely 'normal'). Other than zero tolerance, since after all we are speaking of a man-made indoor environment, what are fungi doing there anywhere?. So, the test homes group is suspect, the limited calibration set is suspect, the comparison model and calculation is suspect.With regard to "inference" from the results:I would use the raw data (PCR only, not ERMI score) sparingly and with suspicion only if I was merely using it as a "reference for relativity" to the conditions. But if that was the case, why not use either the visual assessment (obviously something is amiss if we are sampling), or a set of screening samples (sporetraps). Regardless of variability and error issues (e.g., interlab microscopy variability, sampler error, collection efficiency, time, location, wind, ventilation, time of day, humidity, temp, etc.) even a small set of sporetraps (i.e., 1,2,3, or so) will lead you to the same conclusions you get from the very costly PCR set.>> Okay. I think I have the general concept as it applies to this issue:> > MSQPCR good data. ERMI not good data to determine health risk from WDB.> > Much like:> Mechanistic research good data. TLV not good data to determine health > risk from WDB> > Is that about right? > > Sharon> > > > > > When the raw MSQPCR data, and not the ERMI score> Sharon Noonan Kramer Quote Link to comment Share on other sites More sharing options...
Guest guest Posted January 31, 2011 Report Share Posted January 31, 2011 Sharon, One more thing, (or two or three): the limited species that are used as the comparison data are also an issue. If you can only ID 32(?) species, what does one say/conclude about presence/lack of the other 249,962 species that " might " exist in that environment? (my assumption is there are a finite yet very large set of fungal species likely to arise at any given time in a building, with some estimates hovering around 250k.) And... how can one create a baseline of " normal ecology " when there is no, repeat " no " , consensus on what is acceptable as normal (not acceptable as safe, merely 'normal'). Other than zero tolerance, since after all we are speaking of a man-made indoor environment, what are fungi doing there anywhere?. So, the test homes group is suspect, the limited calibration set is suspect, the comparison model and calculation is suspect. With regard to " inference " from the results: I would use the raw data (PCR only, not ERMI score) sparingly and with suspicion only if I was merely using it as a " reference for relativity " to the conditions. But if that was the case, why not use either the visual assessment (obviously something is amiss if we are sampling), or a set of screening samples (sporetraps). Regardless of variability and error issues (e.g., interlab microscopy variability, sampler error, collection efficiency, time, location, wind, ventilation, time of day, humidity, temp, etc.) even a small set of sporetraps (i.e., 1,2,3, or so) will lead you to the same conclusions you get from the very costly PCR set. > > Okay. I think I have the general concept as it applies to this issue: > > MSQPCR good data. ERMI not good data to determine health risk from WDB. > > Much like: > Mechanistic research good data. TLV not good data to determine health > risk from WDB > > Is that about right? > > Sharon > > > > In a message dated 1/30/2011 3:19:59 P.M. Pacific Standard Time, > AirwaysEnv@... writes: > > When the raw MSQPCR data, and not the ERMI score > Quote Link to comment Share on other sites More sharing options...
Guest guest Posted January 31, 2011 Report Share Posted January 31, 2011 Hi Tony If you already filed a formal “Freedom of Information Act” Request – then by all means contact your Senator. If not you may want to try the formal process first. Federal Law requires you get a response within 20 days. Of course that response may be “no”, but at least then you know that your request has been rejected and the reason for the rejection. The EPA has an electronic request form for filing. If you fill it out and indicate a willingness to pay $25.00 expenses – you stand a good chance getting your request filled. If not you will at least force them to reply. If the request gets rejected you will then have a valid argument when you approach your Representative. It is possible to request a fee waiver – but then you’ll need to submit additional paperwork justifying the “public good” for getting it free. I will be happy to pitch in half of the $25.00 fee. I would certainly like to see the data. If EPA responds that it their cost is more – post the information here – I suspect there are plenty of us that would be willing to chip in. The EPAs electronic FOI request is at: http://www.epa.gov/foia/requestform.html I too have my doubts regarding ERMI – but have found a number of times where QPCR has been a valuable tool and provided additional important data. As an example – The culture and direct exam results come back looking normal for type and quantities – but the occupants are reporting the building makes them sick after a remediation has been completed. The QPCR comes back showing Chaetomium, Ulocladium or Stachybotrys dominate the sample. Keep us posted – this should be interesting C. Banta, CAIH Quote Link to comment Share on other sites More sharing options...
Guest guest Posted January 31, 2011 Report Share Posted January 31, 2011 4. Where are the false and illogical statements along the way in the hypothesis = conclusion; not founded on principles of math or science? Is there only one or several? The grouping of molds on the basis of health risk is not founded in science. Some of the molds in the denominator are known to be highly allergenic. I recall that the only health risk considered in the field study (I haven't seen the study in a long time and have forgotten the criteria for the selected "sick homes") was childhood asthma. The mathematical equation permits lots of some kinds of mold (denominator molds) to result in a LOWER ERMI rating, as if more of the not-so-bad molds makes the environment more healthful. It is bizarre. Steve Temes Quote Link to comment Share on other sites More sharing options...
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