Re: UK has no mold problem [1 Attachment]

[Guest guest]

Jeff, Great idea to author this paper. Here are my comments. "can mean different results may be gathered in the same place even second later. The accuracy of sampling can greatly be increased by more sampling due to the episodic nature of contamination levels in a dynamic environment,"I have tried for over 15 years now to find any research that substantiate the mold spore levels are highly variable in a controlled HVAC environment-even with mold growth. Every paper that I (and others have cited) deals with a buildings that has open windows. In my own experience of testing controlled environments over a 45 day period- this variability simply did not exist. There is no research that shows mold spore levels are highly variable in a building with the windows closed.

Sampling not necessary for clearance

I would add to this section that clearance sampling can and does detect in most cases - the existence of other mold growth - that was not part of the remediated area. This is especially true of older structures where numerous water leaks have occurred over time. In all buildings, it is not a question of whether they have any water leaks, it is only a question of when they will or are occurring. No building is perfectly sealed and all buildings eventually develop water leaks during their lifetime. High exposure from spore release can occur within 7 days of a water loss event and within one day of moist conditions.Decontamination. You only cite NYC and US EPA. There are decontamination guidelines and standard from at least 15 organizations. (This list is from the TOC from our book on PRV.) I would add all of these. CHAPTER 2. POST-REMEDIATION VERIFICATION STANDARDS FOR MOLD & BACTERIA 8Trade AssociationsA. Institute for Inspection, Cleaning and Restoration Certification (IICRC) S500 (2006) 8B. Institute for Inspection, Cleaning and Restoration Certification (IICRC) S520 (2003) 9C. American Industrial Hygiene Association (AIHA) 2004 Document 10D. American Conference of Governmental Industrial Hygienists (ACGIH) 1999 Document 11E. National Air Duct Cleaners Association (NADCA) ACR 2001, 2006 12F. Association for the Prevention and Study of Contamination (ASPEC) 2004 13G. Institute for Research on Occupational Health and Safety (IRRST) 2004 13H. International Society of Indoor Air Quality and Climate Guidelines (ISIAQ) (1996) 14Governmental BodiesI. Federal Environmental Protection Agency (USEPA) 2001 Guideline 14J. England - Ministry of Defense 2004- Requirements for air-conditioning and ventilation 15K. New York City Department of Health (NYCDOH) 2002 Document 16L. Texas Department of Health (TDH) 2004 Regulation 17M. Occupational Safety and Health Administration (OSHA) 2003 Document 18N. University of Minnesota Bulk Analysis of Interior Ventilation Duct Insulation 19O. USACE / NAVFAC / AFCESA / NASA-Unified Facilities Guide Specifications 19"that any amount of HEPA sandwich cleaning cannot remove the substances which cause allergenic, toxic or irritant effects"HEPA sandwich needs to be explained. You may also want to quote the studies of the lack of effectiveness of this method in removing Anthrax spores. The HHSRS requires a threat assessment of environmental conditions and specifically mould hazards covering current and conditions possible changes in the threat or potential of mould for up to 12 months following inspection.German also requires such risk assessments.

The toxic dose level has not been established and can vary in individuals and effects of exposure can be from acute or chronic exposure, making measurement of exposure response immeasurable.

Similar variability is also seen with some chemical exposures. Men vs. women, young workers vs. older workers. See Calabrese.

The level of dose required to adverse health effects in humans has not been determined.

This is too broad of a statement. There are large scale studies done in Germany, Canada, Minnesota, , and others, that have shown that when mold spore levels exceed 75-100,000 cfu/g of dust there is an increased incidence of respiratory health problems. Further, the Netherlands and Poland considers 10,000 cfu/m3 as a threat to health. The Czech republic states that >2,000 cfu/m3 is related to increased health complaints.Remember that these are levels at which increased acute health effects are measurable. What this means is that sub acute health effect are occurring at lower levels. Hence, Finland, Germany, Singapore, Brazil, Czech, Portugal, WHO, Canda, ACGIH (proposed), NIOSH (proposed) and others all applied a safety factor and recommend exposure levels not exceed 200-500 cfu/m3.

The genetic predisposition of those exposed is unknown

I would discuss the issue of at risk immuno-compromise individuals. Include the definition of this population group. I would also included that over 20,000 IMC people die each year from mold infections. I would label the rebuttal section as Myths or Disinformation"studies show that outdoor mold is more likely to cause problems for asthmatics than mold found indoors" Wow! Where is any reference to support this statement? There is no difference between a "outside" clado spore and an "inside" clado spore. With no currently available levels of permitted exposure even to individual toxic compounds,There are endo toxin standards. Bob

Following a recent presentation on mold in the UK, the general consensus amongst people who attended and spread the word about what they did or thought they heard, that mold wasn’t a measurable health hazard, I have written a response to their opinions and more importantly a Hopkins paper cited which states the mold fears don’t hold up to scrutiny.I would appreciate any comments on this draft document either on line or privatelyThanks in advance Jeff Charltontech@...

[Guest guest]

Jeff,

I have briefly read your PAPER and understand the reason for your concerns of misinformation infiltrating the UK and being used to downplay the seriousness of potential physical and financial loss caused by water damaged buildings.

Since I was not present for Mr. Connell's presentation, the comments I have below are based solely on what you write of the matter.

1. The gist or sting of what Mr. Connell is selling is that if one is unable to establish dose before adverse health effects occur from an exposure, then it can be scientifically concluded the exposure is not a health risk worth taking precaution when performing risk management/addressing/rectifying the exposure.

2. According to the National Academy of Sciences, Reference Manual On Scientific EVIDENCE Third Edition, this form of risk assessment/risk management would not hold up in a court of law in the United States.

3. Nor would the author of the concept being shared in the UK be qualified to testify to such form of risk assessment/risk management. As I understand it, he has no formal education in toxicology, epidemiology, immunology, risk assessment, or industrial hygiene. As I understand it, he has no degree in any form of higher education.

4. According to what you write, Mr. Connell has held out a brief review by an undisclosed author from s Hopkins University, 2008, as a valid science paper to support his position.

"The research cited in this article was: Bush RK, Portnoy JM, Saxon A, Terr AI, Wood RA.The medical effects of mold exposure. J Allergy Clin Immunol. 2006 Feb;117(2):326-33. Review. Erratum in: J Allergy Clin Immunol. 2006 Jun;117(6):1373.PMID: 16514772 [PubMed - indexed for MEDLINE]Posted in Lung Disorders on May 22, 2008"

5. It's interesting that the above paper "9 Common Mold Myths" has a html address that would indicate this was being promoted by s Hopkins in 2012. http://www.johnshopkinshealthalerts.com/reports/lung_disorders/2012-1.html

6. The "9 Common Mold Myths" is citing to the AAAAI Mold Position Statement of 2006. This paper, too, is rarely cited in courts of law in the US. The reason being, it is the kiss of death for the defense to bring up this paper and its form of risk assessment, i.e., must establish dose before an exposure is a concern.

7. This paper was quite an embarrassment for AAAAI. One of the listed authors, Dr. Jay Portnoy, did not even know his name was on the paper until I told him.

8. Once publicly questioned by the Center for Science in the Public Interest of how that paper came to be, for what purpose and who authored it; AAAAI changed their required journal author DISCLOSURES to include income generated from expert witnessing fees.

9. Dr. Leung, editor of the AAAAI's journal, graciously published several PAPERS by physicians and scientists dispelling the myths of the "myth busters". (huge pdf, takes a minute to open).

10. Mr. Connell's risk assessment, must establish dose, is passe. It has been exposed several times over as simply being an unscientific concept that was marketed into policy and the courts in the early 2000's by the medical proponents of the affiliates of the US CHAMBER OF COMMERCE.

11. Your conclusion is good:

"The reality is that these toxins and allergens are difficult to measure and impossible to assess individual exposure and differing personal sensitivity.With no currently available levels of permitted exposure even to individual toxic compounds, the toxic soup found in water damaged buildings may be impossible to assess. This of course does not mean a hazard is not identifiable, but it does mean it may be difficult to quantify in terms of personal risk. Absence of evidence is not evidence of absence and while science may not be available to quantify risks, legislation can. Where a possible hazard exists, all reasonable care should be used to limit that risk. Where a known but unquantifiable hazard exists it should be assumed to be a high risk unless controlled, reduced or eliminated."

12. In my humble opinion, I think you need to state it more clearly at the outset of the paper and tie it to the fact that Mr. Connell is trying to sell US thrown out GARBAGE SCIENCE to the UK.

13. I also think you need to let it be known that IF they follow this in the UK when performing remediations, that all they are doing is setting themselves up for litigation, where those who promote this erred form of risk assessment/risk management & garbage science are then hired as "experts" to defend them.

14. If I was going to write a paper that challenged the scientific validity and advice of this presentation (as I understand what occurred according to your interpretation); I would hit hardest on the unscientific, dose response non-sense causing flawed risk assessment - while leaving those who follow it vulnerable to liability. What Mr. Connell is promoting is not current accepted science in US policy or US courtrooms. I would also hit hard on the lack of credentials/lack of professional DEMEANOR of the speaker when challenged in a public forum.

15. Also, regardless of Mr. Connell's interesting interpretation of science/professional risk management; I take issue with in your paper regarding when and why it is necessary to do sampling and what kind to do, when doing risk assessment. You are leaving out the very important protection from risk for remediators from possible litigation if they don't have numbers to support the job they did was successful.

16. You first have to establish what risk your are trying to assess/protect against before you determine if you should test or not; or what kind of testing to do. Potential financial liability can be just as great of life changing risk to the remediator as the contaminants can be for the occupants of the water damaged buildings. Pre and post remediation air sampling can help to protect remediators from be accused of doing a poor job - or help them to know when they did do a poor job in need of correcting.

17. Lastly, if I were you, I would contact the University of Manchester, Dr. Denning. They are doing world class research on illnesses caused by aspergillus. I am sure they would be quite interested in knowing what garbage is being shipped across the pond.

So that's my two cents. Hope it helps.

Sharon Kramer

Following a recent presentation on mold in the UK, the general consensus amongst people who attended and spread the word about what they did or thought they heard, that mold wasn’t a measurable health hazard, I have written a response to their opinions and more importantly a Hopkins paper cited which states the mold fears don’t hold up to scrutiny.

I would appreciate any comments on this draft document either on line or privately

Thanks in advance

Jeff Charlton

tech@...