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I have just returned from the LV Conference titled "Advanced Perspectives

on Mold Remediation." It was useful to me because I was able to get more

information on mold exposure standards from other countries to update my

book. More importantly

There appeared to be significant controversy about whether there is a "need"

to do clearance air testing.

ALL of the "expert" speakers were all saying that clearance air testing is

"not necessary" . However, they admitted to do clearance air testing for

"perception" and "legal" reasons.

The perception requirement is because the public wants to see air results

showing no significant contamination.

The legal reason is because if you don't do at least some air testing -if

the case becomes a legal issue - you will look like an idiot on the witness

stand.

Sounded like double speak to me.

The "experts" were promoting a DUST clearance level of 100mg/m3. Similar

to the National duct cleaning associations cleanliness number. They did not

discuss exactly how one would measure this dust level on a statistical sampling

basis.

ALL of the experts admitted they do air testing. It seems that the reason,

they were saying it was unecessary was because the "number" of samples necessary

to show statistical significance was too high to make sampling meaningful.

Wouldn't their "statistical" limitations apply to the number of dust level

samples also?

I strongly disagree with their anti air sampling statements, based on 30

years experience in the drug and pharmaceutical aseptic fill, clean room

experience.

A number of us other " experts" are planning on forming a committee to develop

a consensus standard on clearance of mold remediation projects - that includes

the need for air testing and the science behind it. I won't go into details

at this time.

What is the opinion of the members of this forum for the need for clearance

air testing AS PART OF THE Clearance process?

BOB

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BOB,

I'm not so sure that ALL of the speakers were saying that air sampling for post-remediation clearance was not necessary. I think most of them were biting their tongues and deferring to just a few. I would be willing to bet that those few would do testing themselves every time if they were asked to clear a remediation project.

In my discussions with many of the attendees, it was obvious that everyone is doing something different when it comes to clearance testing and interpretation of the results.

Just to keep it short, my opinion is that when documentation of acceptable performance of a remediation procedure is necessary, testing is necessary. My preference is to use an aggressive or semi-aggressive air sampling method(s) to suspend settled spores so that the air sampling is reasonably representative of as much SURFACE AREA as possible in the remediation work area.

I don't like surface sampling at all for clearance. It ALWAYS places the IEP in the position of testing a surface that is either more or less likely to have been cleaned. S/He is consciously or subconsciously trying to pass or fail the job. The IEP should not be in this position. The testing must be objective. I can go into a typical remediated work area and find one square inch somewhere that will fail. If I go in after someone else did surface clearance testing and "passed" the job, does that mean the first IEP was negligent for not finding that one square inch that I did?

The only surface sampling I would consider doing is if the contractors removed the negative air machines and/or scrubbers and "let everything settle". This is the time to do surface sampling. Air sampling after everything has settled seems to me like the wrong thing to do, even though it is commonly being done.

I could go on and on and on. By the way, it isn't post-remediation assessment or clearance or verification testing any more. Evidently, the term of art preferred at the symposium is now "close out".

I share your frustration and agree with you that there was a lot of avoidance of controversy and "double speak" at the symposium. I was not as disappointed as many of the attendees, however, because I have come to expect nothing else. I spoke to some who attended the verification track who actually thought they would learn about ways to do clearance testing. All I heard was one infomercial about one type of surface sampling being the only valid method.

As long as the "ultimate criterion" is the ability of the occupants to return to the remediated environment without health complaints, no matter what you do to document that the cleaning was effective, someone can just SAY they have a problem upon re-occupancy and that trumps all your testing anyway.

Other than "the usual politics and controversy", I thought it was a great conference. I would certainly want to attend the next one of its kind. I just wish that we weren't forced to choose between so many concurrent sessions.

Steve Temes

I have just returned from the LV Conference titled "Advanced Perspectives on Mold Remediation." It was useful to me because I was able to get more information on mold exposure standards from other countries to update my book. More importantly

There appeared to be significant controversy about whether there is a "need" to do clearance air testing.

ALL of the "expert" speakers were all saying that clearance air testing is "not necessary" . However, they admitted to do clearance air testing for "perception" and "legal" reasons.

The perception requirement is because the public wants to see air results showing no significant contamination.

The legal reason is because if you don't do at least some air testing -if the case becomes a legal issue - you will look like an idiot on the witness stand.

Sounded like double speak to me.

The "experts" were promoting a DUST clearance level of 100mg/m3. Similar to the National duct cleaning associations cleanliness number. They did not discuss exactly how one would measure this dust level on a statistical sampling basis.

ALL of the experts admitted they do air testing. It seems that the reason, they were saying it was unecessary was because the "number" of samples necessary to show statistical significance was too high to make sampling meaningful. Wouldn't their "statistical" limitations apply to the number of dust level samples also?

I strongly disagree with their anti air sampling statements, based on 30 years experience in the drug and pharmaceutical aseptic fill, clean room experience.

A number of us other " experts" are planning on forming a committee to develop a consensus standard on clearance of mold remediation projects - that includes the need for air testing and the science behind it. I won't go into details at this time.

What is the opinion of the members of this forum for the need for clearance air testing AS PART OF THE Clearance process?

BOB

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Steve,

Thank you for your reply and insight. As some of the members suggested,

we need to put together our own standard practices for clearance. All

of the points you made are excellent and should be considered by anyone

evaluating the completion of a mold project.

Yes, the new word they were suggesting is " close out " . I am not sure

that everyone agrees with this new term.

Let me know if you are interested in being involved with this committee.

Bob

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Regarding the posting below on clearance testing. I agree there was much

discussion at the Univ of Tulsa/Brigham Young Mold Symposium meeting in Las

Vegas on the subject of " close-out " sampling after remediation. In general there

are many caveats of the discussion that ensued that went into the deliberation

over the need for air sampling. It would be impossible to present all of the

discussion here. In no way did the Steering Committee summarily dismiss the use

of sampling after remediation. However, due to the costs involved, # of samples

needed for statistical certainty and the inherent problems with sampling to

discern whther or not an area has been properly remediated, there was a general

interest in consideration of a " cleaning type spec " as opposed to sampling

alone. The amount of dust per area could be used as a measure of cleaning

effectiveness, and could be collected inexpensively (filter cassettes) and

determined by gravimetric analysis. Phil Morey presented information which

indicates from his work that this direction may be equally or more effective in

determining close out acceptability. In the future more research and field work

will be done to test this hypothesis and provide comparisons between these types

of measurements.

Until then the discussion was useful to stimulate thought and perhaps more input

on this subject.

Thank you for the comments on the Symposium overall.

J Shaughnessy, PhD

Program Mgr IAQ Research

University of Tulsa

Date: Sat, 13 Nov 2004 08:25:44 -0600

Subject: Re: Clearance testing

I have just returned from the LV Conference titled " Advanced

Perspectives on Mold Remediation. " It was useful to me because I was

able to get more information on mold exposure standards from other

countries to update my book. More importantly

There appeared to be significant controversy about whether there is a

" need " to do clearance air testing.

ALL of the " expert " speakers were all saying that clearance air testing

is " not necessary " . However, they admitted to do clearance air testing

for " perception " and " legal " reasons.

The perception requirement is because the public wants to see air

results showing no significant contamination.

The legal reason is because if you don't do at least some air testing

-if the case becomes a legal issue - you will look like an idiot on the

witness stand.

Sounded like double speak to me.

The " experts " were promoting a DUST clearance level of 100mg/m3.

Similar to the National duct cleaning associations cleanliness number.

They did not discuss exactly how one would measure this dust level on a

statistical sampling basis.

ALL of the experts admitted they do air testing. It seems that the

reason, they were saying it was unecessary was because the " number " of

samples necessary to show statistical significance was too high to make

sampling meaningful. Wouldn't their " statistical " limitations apply to

the number of dust level samples also?

I strongly disagree with their anti air sampling statements, based on 30

years experience in the drug and pharmaceutical aseptic fill, clean room

experience.

A number of us other " experts " are planning on forming a committee to

develop a consensus standard on clearance of mold remediation projects -

that includes the need for air testing and the science behind it. I

won't go into details at this time.

What is the opinion of the members of this forum for the need for

clearance air testing AS PART OF THE Clearance process?

BOB

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The S520 standard calls for a return to Condition 1 status after remediation. How does a gravimetric test method enable an IEP to determine whether fungal contamination is "normal" or "background"? For that matter, how does one determine Condition 1 status based on mold testing?

Some clearance specs I have seen consider the presence of one spore of Stachy to constitute failure. Someone do the math -- how many spores could there be in one mg of dust?

The "cleaning spec" approach won't work for mold remediation if you are going to follow S520 guidelines. Besides, the "white glove test" should be adequate to determine whether there is too much dust on surfaces, and it's quicker and cheaper.

Someone should be thinking about these things before introducing new terms and concepts. I don't have a problem with keeping it simple, but let's keep it consistent.

There is too much paradigm shifting going on without using the clutch. I hear gears grinding. Texas, here we come.

Steve Temes

there was a general interest in consideration of a "cleaning type spec" as opposed to sampling alone. The amount of dust per area could be used as a measure of cleaning effectiveness, and could be collected inexpensively (filter cassettes) and determined by gravimetric analysis. Phil Morey presented information which indicates from his work that this direction may be equally or more effective in determining close out acceptability.

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Hello, Steve:

I have to say that I am on the other side of the camp by thinking

that surface sampling is superior to air sampling for clearance

purposes.

Here are just three reasons I prefer surface sampling for post-

remediation verification:

1. Oftentimes we have found that semi-porous materials, such as wood,

can appear clean and be free of dust (in other words, most of the

spores are removed and the air samples would be acceptable), but

hyphae have been left behind from lack of adaquate scrubbing/sanding.

2. If spot A,B, and C fail a visual or sampling, just A,B, and C need

to be cleaned. If air sampling fails, where does the remediator

start and end??? In this case, surface sampling can give very

straight forward instructions to the remediator.

3. And the biggie: statistical variability with air sampling. I

don't want to be the one who says the job is done when really I just

wasn't allotted enough funds to take the proper amount of samples.

Now I'm not 100% against bioaerosol sampling, we do it all time.

However, given the choice (yes, sometimes the client requires air

samples) I'd choose a good visual assessment and surface sampling

every time.

Cassidy L. Kuchenbecker

> BOB,

>

> I'm not so sure that ALL of the speakers were saying that air

sampling for

> post-remediation clearance was not necessary. I think most of them

were biting

> their tongues and deferring to just a few. I would be willing to

bet that

> those few would do testing themselves every time if they were asked

to clear a

> remediation project.

>

> In my discussions with many of the attendees, it was obvious that

everyone is

> doing something different when it comes to clearance testing and

> interpretation of the results.

>

> Just to keep it short, my opinion is that when documentation of

acceptable

> performance of a remediation procedure is necessary, testing is

necessary. My

> preference is to use an aggressive or semi-aggressive air sampling

method(s) to

> suspend settled spores so that the air sampling is reasonably

representative

> of as much SURFACE AREA as possible in the remediation work area.

>

> I don't like surface sampling at all for clearance. It ALWAYS

places the IEP

> in the position of testing a surface that is either more or less

likely to

> have been cleaned. S/He is consciously or subconsciously trying to

pass or fail

> the job. The IEP should not be in this position. The testing must

be

> objective. I can go into a typical remediated work area and find

one square inch

> somewhere that will fail. If I go in after someone else did

surface clearance

> testing and " passed " the job, does that mean the first IEP was

negligent for

> not finding that one square inch that I did?

>

> The only surface sampling I would consider doing is if the

contractors

> removed the negative air machines and/or scrubbers and " let

everything settle " .

> This is the time to do surface sampling. Air sampling after

everything has

> settled seems to me like the wrong thing to do, even though it is

commonly being

> done.

>

> I could go on and on and on. By the way, it isn't post-remediation

> assessment or clearance or verification testing any more.

Evidently, the term of art

> preferred at the symposium is now " close out " .

>

> I share your frustration and agree with you that there was a lot of

avoidance

> of controversy and " double speak " at the symposium. I was not as

> disappointed as many of the attendees, however, because I have come

to expect nothing

> else. I spoke to some who attended the verification track who

actually thought

> they would learn about ways to do clearance testing. All I heard

was one

> infomercial about one type of surface sampling being the only valid

method.

>

> As long as the " ultimate criterion " is the ability of the occupants

to return

> to the remediated environment without health complaints, no matter

what you

> do to document that the cleaning was effective, someone can just

SAY they have

> a problem upon re-occupancy and that trumps all your testing anyway.

>

> Other than " the usual politics and controversy " , I thought it was a

great

> conference. I would certainly want to attend the next one of its

kind. I just

> wish that we weren't forced to choose between so many concurrent

sessions.

>

> Steve Temes

>

>

> In a message dated 11/13/2004 10:54:26 AM Eastern Standard Time,

> BobB@s... writes:

> > I have just returned from the LV Conference titled " Advanced

Perspectives

> > on Mold Remediation. " It was useful to me because I was able to

get more

> > information on mold exposure standards from other countries to

update my book.

> > More importantly

> >

> >

> > There appeared to be significant controversy about whether there

is a " need "

> > to do clearance air testing.

> >

> >

> > ALL of the " expert " speakers were all saying that clearance air

testing is

> > " not necessary " . However, they admitted to do clearance air

testing for

> > " perception " and " legal " reasons.

> >

> > The perception requirement is because the public wants to see

air results

> > showing no significant contamination.

> >

> > The legal reason is because if you don't do at least some air

testing -if

> > the case becomes a legal issue - you will look like an idiot on

the witness

> > stand.

> > Sounded like double speak to me.

> >

> > The " experts " were promoting a DUST clearance level of

100mg/m3. Similar

> > to the National duct cleaning associations cleanliness number.

They did not

> > discuss exactly how one would measure this dust level on a

statistical sampling

> > basis.

> >

> > ALL of the experts admitted they do air testing. It seems that

the reason,

> > they were saying it was unecessary was because the " number " of

samples

> > necessary to show statistical significance was too high to make

sampling

> > meaningful. Wouldn't their " statistical " limitations apply to the

number of dust level

> > samples also?

> >

> > I strongly disagree with their anti air sampling statements,

based on 30

> > years experience in the drug and pharmaceutical aseptic fill,

clean room

> > experience.

> >

> > A number of us other " experts " are planning on forming a

committee to

> > develop a consensus standard on clearance of mold remediation

projects - that

> > includes the need for air testing and the science behind it. I

won't go into

> > details at this time.

> >

> >

> > What is the opinion of the members of this forum for the need for

clearance

> > air testing AS PART OF THE Clearance process?

> >

> >

> > BOB

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Cassidy,

I like your comments on clearance testing. However, I view clearance

from 2 questions or issues.

1. Did the remediation firm do an adequate cleaning job. ?

This can be answered with surface sampling

This can NOT be answered by air sampling.

2. Are the mold spore levels in the building AND the remediated area

acceptable?

This can NOT be answered by air sampling.

This can be answered by air sampling with statistical limitations.

Really, there are two goals in a remediation project.

1. Removing mold growth

2. Removing excess mold spores in the air as a result of the mold that

was removed.

Two goals - two tests.

BOTH testing methods have statistical limitation. Those of air testing

are well researched. Those of surface testing are not.

Again two questions -2 answers.

BOB

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I have to wonder if much of the remediation " clearance " is " over-kill " . The

IICRC concept of " normal fungal ecology " speaks volumes - although difficult

to actually define. I guarantee surface sampling could find hyphae (and

visible growth) on the lumber going into my new home (despite my repeated

objections). And just think about the percentage of building stock that has

had some degree of water leakage or intrusion resulting in " some " mold

growth over the years. Take all of these buildings that are occupied without

problem until some major event prompts a mold remediation. Is the

remediation contractor then expected to achieve " clearance " that exceeds

" normal " ?

Curtis Redington, RS

Environmental Quality Specialist

City of Wichita Dept. of Environmental Health

Re: Clearance testing

Hello, Steve:

I have to say that I am on the other side of the camp by thinking

that surface sampling is superior to air sampling for clearance

purposes.

Here are just three reasons I prefer surface sampling for post-

remediation verification:

1. Oftentimes we have found that semi-porous materials, such as wood,

can appear clean and be free of dust (in other words, most of the

spores are removed and the air samples would be acceptable), but

hyphae have been left behind from lack of adaquate scrubbing/sanding.

2. If spot A,B, and C fail a visual or sampling, just A,B, and C need

to be cleaned. If air sampling fails, where does the remediator

start and end??? In this case, surface sampling can give very

straight forward instructions to the remediator.

3. And the biggie: statistical variability with air sampling. I

don't want to be the one who says the job is done when really I just

wasn't allotted enough funds to take the proper amount of samples.

Now I'm not 100% against bioaerosol sampling, we do it all time.

However, given the choice (yes, sometimes the client requires air

samples) I'd choose a good visual assessment and surface sampling

every time.

Cassidy L. Kuchenbecker

> BOB,

>

> I'm not so sure that ALL of the speakers were saying that air

sampling for

> post-remediation clearance was not necessary. I think most of them

were biting

> their tongues and deferring to just a few. I would be willing to

bet that

> those few would do testing themselves every time if they were asked

to clear a

> remediation project.

>

> In my discussions with many of the attendees, it was obvious that

everyone is

> doing something different when it comes to clearance testing and

> interpretation of the results.

>

> Just to keep it short, my opinion is that when documentation of

acceptable

> performance of a remediation procedure is necessary, testing is

necessary. My

> preference is to use an aggressive or semi-aggressive air sampling

method(s) to

> suspend settled spores so that the air sampling is reasonably

representative

> of as much SURFACE AREA as possible in the remediation work area.

>

> I don't like surface sampling at all for clearance. It ALWAYS

places the IEP

> in the position of testing a surface that is either more or less

likely to

> have been cleaned. S/He is consciously or subconsciously trying to

pass or fail

> the job. The IEP should not be in this position. The testing must

be

> objective. I can go into a typical remediated work area and find

one square inch

> somewhere that will fail. If I go in after someone else did

surface clearance

> testing and " passed " the job, does that mean the first IEP was

negligent for

> not finding that one square inch that I did?

>

> The only surface sampling I would consider doing is if the

contractors

> removed the negative air machines and/or scrubbers and " let

everything settle " .

> This is the time to do surface sampling. Air sampling after

everything has

> settled seems to me like the wrong thing to do, even though it is

commonly being

> done.

>

> I could go on and on and on. By the way, it isn't post-remediation

> assessment or clearance or verification testing any more.

Evidently, the term of art

> preferred at the symposium is now " close out " .

>

> I share your frustration and agree with you that there was a lot of

avoidance

> of controversy and " double speak " at the symposium. I was not as

> disappointed as many of the attendees, however, because I have come

to expect nothing

> else. I spoke to some who attended the verification track who

actually thought

> they would learn about ways to do clearance testing. All I heard

was one

> infomercial about one type of surface sampling being the only valid

method.

>

> As long as the " ultimate criterion " is the ability of the occupants

to return

> to the remediated environment without health complaints, no matter

what you

> do to document that the cleaning was effective, someone can just

SAY they have

> a problem upon re-occupancy and that trumps all your testing anyway.

>

> Other than " the usual politics and controversy " , I thought it was a

great

> conference. I would certainly want to attend the next one of its

kind. I just

> wish that we weren't forced to choose between so many concurrent

sessions.

>

> Steve Temes

>

>

> In a message dated 11/13/2004 10:54:26 AM Eastern Standard Time,

> BobB@s... writes:

> > I have just returned from the LV Conference titled " Advanced

Perspectives

> > on Mold Remediation. " It was useful to me because I was able to

get more

> > information on mold exposure standards from other countries to

update my book.

> > More importantly

> >

> >

> > There appeared to be significant controversy about whether there

is a " need "

> > to do clearance air testing.

> >

> >

> > ALL of the " expert " speakers were all saying that clearance air

testing is

> > " not necessary " . However, they admitted to do clearance air

testing for

> > " perception " and " legal " reasons.

> >

> > The perception requirement is because the public wants to see

air results

> > showing no significant contamination.

> >

> > The legal reason is because if you don't do at least some air

testing -if

> > the case becomes a legal issue - you will look like an idiot on

the witness

> > stand.

> > Sounded like double speak to me.

> >

> > The " experts " were promoting a DUST clearance level of

100mg/m3. Similar

> > to the National duct cleaning associations cleanliness number.

They did not

> > discuss exactly how one would measure this dust level on a

statistical sampling

> > basis.

> >

> > ALL of the experts admitted they do air testing. It seems that

the reason,

> > they were saying it was unecessary was because the " number " of

samples

> > necessary to show statistical significance was too high to make

sampling

> > meaningful. Wouldn't their " statistical " limitations apply to the

number of dust level

> > samples also?

> >

> > I strongly disagree with their anti air sampling statements,

based on 30

> > years experience in the drug and pharmaceutical aseptic fill,

clean room

> > experience.

> >

> > A number of us other " experts " are planning on forming a

committee to

> > develop a consensus standard on clearance of mold remediation

projects - that

> > includes the need for air testing and the science behind it. I

won't go into

> > details at this time.

> >

> >

> > What is the opinion of the members of this forum for the need for

clearance

> > air testing AS PART OF THE Clearance process?

> >

> >

> > BOB

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Assuming that each Stachy spore consists of water and

is an oblong box 3 x 3 x 12 um, each spore weighs roughly 1.08E-7 mg, meaning

that you could fit nearly 10 million Stachy spores in a milligram.

That said,

I agree with Steve in that there has to be a line between scientific accuracy

and project cost. It simply isn’t

possible on most projects to spec out the most precise analysis for

anything. For instance, I’m not necessarily

going to speciate every organism I find on a project—it costs WAY too much and

requires too much time. Sometimes

analysis to the genus level is adequate for my purposes and those of my

clients, because it has a good balance of precision, speed, and cost.

I’ve seen

the “zero tolerance” for Stachy before and I think it’s ludicrous. First, many of the problems attributed

to Stachy exposure have been disproven.

Second, a single spore is often below the detection limit and is within

experimental error for most samplers.

Third, you cannot selectively clean for a specific mold. It’s just not possible given the

current level of technology available.

It might be one thing if Stachy was rare, which is isn’t, or if it had a

huge spore that was easily filtered out during air scrubbing (a la Peronospora), which it doesn’t. Its aerodynamic diameter is the same as

that of Asp/Pen! I treat it

similarly to other fungi in most cases.

Otherwise, one logical terminus is:

“Ma’am,

your basement is cleared.”

“There’s

no more mold down there?”

“Well, the

Stachy’s all gone.”

“Oh, that’s

good. What about the half million

Asp/Pen spores still floating around down there?”

“Uh, the

Stachy’s gone.”

“And?”

“And we’re

done. Bye!”

(Homeowner

calls lawyer.)

I think a

lot of the basis for “zero tolerance” comes from some firms milking jobs. Happens a lot in the Northeast, I’ve

found.

A. Walsh MS, CIE

-----Original

Message-----

The

S520 standard calls for a return to Condition 1 status after remediation.

How does a gravimetric test method enable an IEP to determine whether fungal

contamination is " normal " or " background " ? For that

matter, how does one determine Condition 1 status based on mold testing?

Some clearance specs I have seen consider the presence of one spore of Stachy

to constitute failure. Someone do the math -- how many spores could there

be in one mg of dust?

The " cleaning spec " approach won't work for mold remediation if you

are going to follow S520 guidelines. Besides, the " white glove test "

should be adequate to determine whether there is too much dust on surfaces, and

it's quicker and cheaper.

Someone should be thinking about these things before introducing new terms and

concepts. I don't have a problem with keeping it simple, but let's keep

it consistent.

There is too much paradigm shifting going on without using the clutch. I

hear gears grinding. Texas, here we come.

Steve Temes

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Bob,

One justification COULD be that individual occupants have become sensitized to the specific components of the accumulated dust in that specific environment. This is why I believe that when occupants are hypersensitive, thorough removal of dust that occupants might be exposed to is required before re-occupancy. After surface dust containing antigenic material has been removed, then let conditions return to normal (Condition 1). The stuff that is causing negative health effects should be completely removed. If there is recent growth and no one has any health issues, the old accumulated settled dust may not be a problem at all. This is where professional judgment becomes important. The contaminant levels may be normal, but now the people aren't.

Steve Temes

Clearly, if dust and mold spores

are normally present inside of building components- then what is the

justification for "aspectic" removal of normal levels?

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Curtis,

We have dealt with a number of mold remediation project in large older

home. Many times home owners use water damage as a reason for general

renovation. During such activities, we find large amounts of " normal "

dust inside of wall cavitiest that has been deposited over the years.

Certainly, this " normal " dust- that has lots of mold spores in it- is

normal for the building and its age.

Further, air testing before the renovation project has shown normal mold

levels. Certainly, such dust in wall is not a hazard.

However, we have also seen remediation projects that have gone to the

extreme in cleaning dust from plumbing pipes and electrical conduit.

The perspective of such normal conditions is why clearance testing using

surface sampling troubles me.

It is not health or exposure based. Clearly, if dust and mold spores

are normally present inside of building components- then what is the

justification for " aspectic " removal of normal levels?

BOB

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Pat,

I have seen the same " milking " of projects by many consultants. The

latest one the consultant ran up a $68,000 because of an odor problem in

gym. He even tested for mercury and asbestos. What a scam.

RE: Stachy,

Burge and ACOEM did some calcuations on worst case exposure to Stachy

spores. Conclusion: daily exposure and inhalation of thousands of

spore is necessary before any chance of any toxicity.

Needless to say, Stachy appears to be overated as a mold problem.

BOB

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Bob,

The ACOEM article linked below contains the information you alluded to about Stachybotrys exposure. I thought I would pass this on for others who might be interested.

http://www.acoem.org/guidelines/pdf/Mold-10-27-02.pdf

Phil S.

Re: Re: Clearance testing

Pat,I have seen the same "milking" of projects by many consultants. The latest one the consultant ran up a $68,000 because of an odor problem in gym. He even tested for mercury and asbestos. What a scam.RE: Stachy, Burge and ACOEM did some calcuations on worst case exposure to Stachy spores. Conclusion: daily exposure and inhalation of thousands of spore is necessary before any chance of any toxicity.Needless to say, Stachy appears to be overated as a mold problem.BOBFAIR USE NOTICE:This site contains copyrighted material the use of which has not always been specifically authorized by the copyright owner. We are making such material available in our efforts to advance understanding of environmental, political, human rights, economic, democracy, scientific, and social justice issues, etc. We believe this constitutes a 'fair use' of any such copyrighted material as provided for in section 107 of the US Copyright Law. In accordance with Title 17 U.S.C. Section 107, the material on this site is distributed without profit to those who have expressed a prior interest in receiving the included information for research and educational purposes. For more information go to: http://www.law.cornell.edu/uscode/17/107.shtml. If you wish to use copyrighted material from this site for purposes of your own that go beyond 'fair use', you must obtain permission from the copyright owner.

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Being a laboratory person, I would like to know how

surface sampling is conducted for clearance purposes.

A major advantage of surface sampling is that it

targets the source. But how is it conducted to ensure

that the samples taken are a true representative of

the remediated surface? Also, are samples taken from

the same spots before and after remediation and how

are the results compared?

Kung'u, PhD.

Mold & Bacteria Consulting Laboratories (MBL) Inc.

1020 Brevik Place, Unit 1A

Mississauga, ON L4W 4N7

Canada

Tel:

Email: jkungu@...

http://www.moldbacteria.com

--- Cassidy Kuchenbecker

wrote:

>

>

>

> Hello, Steve:

>

> I have to say that I am on the other side of the

> camp by thinking

> that surface sampling is superior to air sampling

> for clearance

> purposes.

>

> Here are just three reasons I prefer surface

> sampling for post-

> remediation verification:

>

> 1. Oftentimes we have found that semi-porous

> materials, such as wood,

> can appear clean and be free of dust (in other

> words, most of the

> spores are removed and the air samples would be

> acceptable), but

> hyphae have been left behind from lack of adaquate

> scrubbing/sanding.

>

> 2. If spot A,B, and C fail a visual or sampling,

> just A,B, and C need

> to be cleaned. If air sampling fails, where does

> the remediator

> start and end??? In this case, surface sampling can

> give very

> straight forward instructions to the remediator.

>

> 3. And the biggie: statistical variability with air

> sampling. I

> don't want to be the one who says the job is done

> when really I just

> wasn't allotted enough funds to take the proper

> amount of samples.

>

> Now I'm not 100% against bioaerosol sampling, we do

> it all time.

> However, given the choice (yes, sometimes the client

> requires air

> samples) I'd choose a good visual assessment and

> surface sampling

> every time.

>

> Cassidy L. Kuchenbecker

>

>

>

> > BOB,

> >

> > I'm not so sure that ALL of the speakers were

> saying that air

> sampling for

> > post-remediation clearance was not necessary. I

> think most of them

> were biting

> > their tongues and deferring to just a few. I

> would be willing to

> bet that

> > those few would do testing themselves every time

> if they were asked

> to clear a

> > remediation project.

> >

> > In my discussions with many of the attendees, it

> was obvious that

> everyone is

> > doing something different when it comes to

> clearance testing and

> > interpretation of the results.

> >

> > Just to keep it short, my opinion is that when

> documentation of

> acceptable

> > performance of a remediation procedure is

> necessary, testing is

> necessary. My

> > preference is to use an aggressive or

> semi-aggressive air sampling

> method(s) to

> > suspend settled spores so that the air sampling is

> reasonably

> representative

> > of as much SURFACE AREA as possible in the

> remediation work area.

> >

> > I don't like surface sampling at all for

> clearance. It ALWAYS

> places the IEP

> > in the position of testing a surface that is

> either more or less

> likely to

> > have been cleaned. S/He is consciously or

> subconsciously trying to

> pass or fail

> > the job. The IEP should not be in this position.

> The testing must

> be

> > objective. I can go into a typical remediated

> work area and find

> one square inch

> > somewhere that will fail. If I go in after

> someone else did

> surface clearance

> > testing and " passed " the job, does that mean the

> first IEP was

> negligent for

> > not finding that one square inch that I did?

> >

> > The only surface sampling I would consider doing

> is if the

> contractors

> > removed the negative air machines and/or scrubbers

> and " let

> everything settle " .

> > This is the time to do surface sampling. Air

> sampling after

> everything has

> > settled seems to me like the wrong thing to do,

> even though it is

> commonly being

> > done.

> >

> > I could go on and on and on. By the way, it isn't

> post-remediation

> > assessment or clearance or verification testing

> any more.

> Evidently, the term of art

> > preferred at the symposium is now " close out " .

> >

> > I share your frustration and agree with you that

> there was a lot of

> avoidance

> > of controversy and " double speak " at the

> symposium. I was not as

> > disappointed as many of the attendees, however,

> because I have come

> to expect nothing

> > else. I spoke to some who attended the

> verification track who

> actually thought

> > they would learn about ways to do clearance

> testing. All I heard

> was one

> > infomercial about one type of surface sampling

> being the only valid

> method.

> >

> > As long as the " ultimate criterion " is the ability

> of the occupants

> to return

> > to the remediated environment without health

> complaints, no matter

> what you

> > do to document that the cleaning was effective,

> someone can just

> SAY they have

> > a problem upon re-occupancy and that trumps all

> your testing anyway.

> >

> > Other than " the usual politics and controversy " , I

> thought it was a

> great

> > conference. I would certainly want to attend the

> next one of its

> kind. I just

> > wish that we weren't forced to choose between so

> many concurrent

> sessions.

> >

> > Steve Temes

> >

> >

> > In a message dated 11/13/2004 10:54:26 AM Eastern

> Standard Time,

> > BobB@s... writes:

> > > I have just returned from the LV Conference

> titled " Advanced

> Perspectives

> > > on Mold Remediation. " It was useful to me

> because I was able to

> get more

> > > information on mold exposure standards from

> other countries to

> update my book.

> > > More importantly

> > >

> > >

> > > There appeared to be significant controversy

> about whether there

> is a " need "

> > > to do clearance air testing.

> > >

> > >

> > > ALL of the " expert " speakers were all saying

> that clearance air

> testing is

>

=== message truncated ===

______________________________________________________________________

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Bob,

I hope you can keep us up to date regarding the committee to explore

consensus on clearance criteria.

While I was in attendance at the IICRC session, opinions regarding

clearance criteria abounded during the whole sysmposium. I have had

the experience to be on both sides of the fence, remediation

contractor and IEP. My experience has been that of the old

adage, " there is more than one way to skin a cat. " Absent more

research on the subject, I believe there were many valid opinons of

how to conduct and set criteria for post-project clearance.

My experience has always been to establish the clearance criteria

before remediation is started, with all parties involved. In

general, " you don't move the goal-line once the game begins. " I have

found that reasonable minds will come together in establishing the

criteria.

A remediation scope of work should be site specific, perhaps the same

should be true of establishing the clearance criteria. Then make

sure you have many tools in your tool belt!

Shapiro

> I have just returned from the LV Conference titled " Advanced

> Perspectives on Mold Remediation. " It was useful to me because I

was

> able to get more information on mold exposure standards from other

> countries to update my book. More importantly

>

>

> There appeared to be significant controversy about whether there is

a

> " need " to do clearance air testing.

>

>

> ALL of the " expert " speakers were all saying that clearance air

testing

> is " not necessary " . However, they admitted to do clearance air

testing

> for " perception " and " legal " reasons.

>

> The perception requirement is because the public wants to see air

> results showing no significant contamination.

>

> The legal reason is because if you don't do at least some air

testing

> -if the case becomes a legal issue - you will look like an idiot on

the

> witness stand.

> Sounded like double speak to me.

>

> The " experts " were promoting a DUST clearance level of 100mg/m3.

> Similar to the National duct cleaning associations cleanliness

number.

> They did not discuss exactly how one would measure this dust level

on a

> statistical sampling basis.

>

> ALL of the experts admitted they do air testing. It seems that the

> reason, they were saying it was unecessary was because the " number "

of

> samples necessary to show statistical significance was too high to

make

> sampling meaningful. Wouldn't their " statistical " limitations apply

to

> the number of dust level samples also?

>

> I strongly disagree with their anti air sampling statements, based

on 30

> years experience in the drug and pharmaceutical aseptic fill, clean

room

> experience.

>

> A number of us other " experts " are planning on forming a

committee to

> develop a consensus standard on clearance of mold remediation

projects -

> that includes the need for air testing and the science behind it.

I

> won't go into details at this time.

>

>

> What is the opinion of the members of this forum for the need for

> clearance air testing AS PART OF THE Clearance process?

>

>

> BOB

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Randy,

Your statements and experience reflect what I have seen over the years.

If there is a mould amplification problem in a building, it will show

up in the air data -either in total numbers or unusual genera

distributions.

Some time in the next few years, I am going to put together some

statistical data on this from over 2,000 samples.

Unfortunately, My research time is limited

BOB

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Hello;

I couldn't resist to mention if the surfaces have mould then there would be

spores in the air. If mould is suspected we check for the air-born spores

to confirm and then look for the source. The source is then remediate, we

then can check the air if any more spores can be found. We would then look

at the cause of the mould and recommend methods for avoidance.

Sincerely;

Randy,

Ontario Building Solutions

Solving Indoor Air Quality (IAQ) Issues

www.buildingoperation.com <http://www.buildingoperation.com>

info@...

Re: Re: Clearance testing

Being a laboratory person, I would like to know how

surface sampling is conducted for clearance purposes.

A major advantage of surface sampling is that it

targets the source. But how is it conducted to ensure

that the samples taken are a true representative of

the remediated surface? Also, are samples taken from

the same spots before and after remediation and how

are the results compared?

Kung'u, PhD.

Mold & Bacteria Consulting Laboratories (MBL) Inc.

1020 Brevik Place, Unit 1A

Mississauga, ON L4W 4N7

Canada

Tel:

Email: jkungu@...

http://www.moldbacteria.com

--- Cassidy Kuchenbecker

wrote:

>

>

>

> Hello, Steve:

>

> I have to say that I am on the other side of the

> camp by thinking

> that surface sampling is superior to air sampling

> for clearance

> purposes.

>

> Here are just three reasons I prefer surface

> sampling for post-

> remediation verification:

>

> 1. Oftentimes we have found that semi-porous

> materials, such as wood,

> can appear clean and be free of dust (in other

> words, most of the

> spores are removed and the air samples would be

> acceptable), but

> hyphae have been left behind from lack of adaquate

> scrubbing/sanding.

>

> 2. If spot A,B, and C fail a visual or sampling,

> just A,B, and C need

> to be cleaned. If air sampling fails, where does

> the remediator

> start and end??? In this case, surface sampling can

> give very

> straight forward instructions to the remediator.

>

> 3. And the biggie: statistical variability with air

> sampling. I

> don't want to be the one who says the job is done

> when really I just

> wasn't allotted enough funds to take the proper

> amount of samples.

>

> Now I'm not 100% against bioaerosol sampling, we do

> it all time.

> However, given the choice (yes, sometimes the client

> requires air

> samples) I'd choose a good visual assessment and

> surface sampling

> every time.

>

> Cassidy L. Kuchenbecker

>

>

>

> > BOB,

> >

> > I'm not so sure that ALL of the speakers were

> saying that air

> sampling for

> > post-remediation clearance was not necessary. I

> think most of them

> were biting

> > their tongues and deferring to just a few. I

> would be willing to

> bet that

> > those few would do testing themselves every time

> if they were asked

> to clear a

> > remediation project.

> >

> > In my discussions with many of the attendees, it

> was obvious that

> everyone is

> > doing something different when it comes to

> clearance testing and

> > interpretation of the results.

> >

> > Just to keep it short, my opinion is that when

> documentation of

> acceptable

> > performance of a remediation procedure is

> necessary, testing is

> necessary. My

> > preference is to use an aggressive or

> semi-aggressive air sampling

> method(s) to

> > suspend settled spores so that the air sampling is

> reasonably

> representative

> > of as much SURFACE AREA as possible in the

> remediation work area.

> >

> > I don't like surface sampling at all for

> clearance. It ALWAYS

> places the IEP

> > in the position of testing a surface that is

> either more or less

> likely to

> > have been cleaned. S/He is consciously or

> subconsciously trying to

> pass or fail

> > the job. The IEP should not be in this position.

> The testing must

> be

> > objective. I can go into a typical remediated

> work area and find

> one square inch

> > somewhere that will fail. If I go in after

> someone else did

> surface clearance

> > testing and " passed " the job, does that mean the

> first IEP was

> negligent for

> > not finding that one square inch that I did?

> >

> > The only surface sampling I would consider doing

> is if the

> contractors

> > removed the negative air machines and/or scrubbers

> and " let

> everything settle " .

> > This is the time to do surface sampling. Air

> sampling after

> everything has

> > settled seems to me like the wrong thing to do,

> even though it is

> commonly being

> > done.

> >

> > I could go on and on and on. By the way, it isn't

> post-remediation

> > assessment or clearance or verification testing

> any more.

> Evidently, the term of art

> > preferred at the symposium is now " close out " .

> >

> > I share your frustration and agree with you that

> there was a lot of

> avoidance

> > of controversy and " double speak " at the

> symposium. I was not as

> > disappointed as many of the attendees, however,

> because I have come

> to expect nothing

> > else. I spoke to some who attended the

> verification track who

> actually thought

> > they would learn about ways to do clearance

> testing. All I heard

> was one

> > infomercial about one type of surface sampling

> being the only valid

> method.

> >

> > As long as the " ultimate criterion " is the ability

> of the occupants

> to return

> > to the remediated environment without health

> complaints, no matter

> what you

> > do to document that the cleaning was effective,

> someone can just

> SAY they have

> > a problem upon re-occupancy and that trumps all

> your testing anyway.

> >

> > Other than " the usual politics and controversy " , I

> thought it was a

> great

> > conference. I would certainly want to attend the

> next one of its

> kind. I just

> > wish that we weren't forced to choose between so

> many concurrent

> sessions.

> >

> > Steve Temes

> >

> >

> > In a message dated 11/13/2004 10:54:26 AM Eastern

> Standard Time,

> > BobB@s... writes:

> > > I have just returned from the LV Conference

> titled " Advanced

> Perspectives

> > > on Mold Remediation. " It was useful to me

> because I was able to

> get more

> > > information on mold exposure standards from

> other countries to

> update my book.

> > > More importantly

> > >

> > >

> > > There appeared to be significant controversy

> about whether there

> is a " need "

> > > to do clearance air testing.

> > >

> > >

> > > ALL of the " expert " speakers were all saying

> that clearance air

> testing is

>

=== message truncated ===

______________________________________________________________________

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specifically authorized by the copyright owner. We are making such material

available in our efforts to advance understanding of environmental,

political, human rights, economic, democracy, scientific, and social justice

issues, etc. We believe this constitutes a 'fair use' of any such

copyrighted material as provided for in section 107 of the US Copyright Law.

In accordance with Title 17 U.S.C. Section 107, the material on this site is

distributed without profit to those who have expressed a prior interest in

receiving the included information for research and educational purposes.

For more information go to: http://www.law.cornell.edu/uscode/17/107.shtml.

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Stevan,

My sympathies.

Does the Texas training program (assuming there is one) and exam for licensing offer guidance on, or require specific knowledge of, clearance criteria?

I remember the various iterations of clearance criteria in the proposed/revised legislation. Did the TX DOH finally give up on dictating to professionals how to approve a remediation procedure altogether?

Will one set of clearance criteria be just as good as another for regulatory enforcement purposes (i.e., one spore of Stachy in air vs. 100 mg surface dust)?

Steve Temes

Overcome by events, as they say.

Stevan

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, et al:

Your third and fourth paragraphs hit home here in Texas. Note that the new Mold Assessment Licensing regulations state:

295.312(B)(6) prepare a mold remediation protocol, including the evaluation and selection of appropriate methods, personal protective equipment (PPE), engineering controls, project layout, post-remediation clearance evaluation methods and criteria, and preparation of plans and specifications;

295.320©(10) writing mold management plans and mold remediation protocols, including format and contents (including structural components, HVAC systems, and building contents), defining affected areas (including floor plans), identifying and repairing moisture sources and their causes, developing a scope of work analysis, specifying containment and air filtration strategies, determining post-remediation assessment criteria, and clearance criteria; and

295.320©(11) post-remediation clearance testing and procedures, including review of mold remediation plans, visual inspections, sampling strategies, and quality assurance; and

Under these regulations, which take effect January 1, 2004, the Mold Assessment Consultant will provide post-remediation clearance testing/inspection criteria in the report of the initial evaluation.

Overcome by events, as they say.

Stevan

Stevan W. Pierce, CIH, CSP

Senior Project Manager/Senior Scientist

ATC Associates Inc.

1860 Crown Drive, Suite 1406

Farmers Branch, Texas 75234

Voice--; Fax--; Cell--

stevan.pierce@...

-----Original Message-----From: Shapiro Sent: Tuesday, November 16, 2004 5:30 PMTo: iequality Subject: Re: Clearance testingBob,I hope you can keep us up to date regarding the committee to explore consensus on clearance criteria.While I was in attendance at the IICRC session, opinions regarding clearance criteria abounded during the whole sysmposium. I have had the experience to be on both sides of the fence, remediation contractor and IEP. My experience has been that of the old adage, "there is more than one way to skin a cat." Absent more research on the subject, I believe there were many valid opinons of how to conduct and set criteria for post-project clearance. My experience has always been to establish the clearance criteria before remediation is started, with all parties involved. In general, "you don't move the goal-line once the game begins." I have found that reasonable minds will come together in establishing the criteria.A remediation scope of work should be site specific, perhaps the same should be true of establishing the clearance criteria. Then make sure you have many tools in your tool belt! Shapiro> I have just returned from the LV Conference titled "Advanced > Perspectives on Mold Remediation." It was useful to me because I was > able to get more information on mold exposure standards from other > countries to update my book. More importantly> > > There appeared to be significant controversy about whether there is a > "need" to do clearance air testing. > > > ALL of the "expert" speakers were all saying that clearance air testing > is "not necessary" . However, they admitted to do clearance air testing > for "perception" and "legal" reasons. > > The perception requirement is because the public wants to see air > results showing no significant contamination.> > The legal reason is because if you don't do at least some air testing > -if the case becomes a legal issue - you will look like an idiot on the > witness stand.> Sounded like double speak to me.> > The "experts" were promoting a DUST clearance level of 100mg/m3. > Similar to the National duct cleaning associations cleanliness number. > They did not discuss exactly how one would measure this dust level on a > statistical sampling basis. > > ALL of the experts admitted they do air testing. It seems that the > reason, they were saying it was unecessary was because the "number" of > samples necessary to show statistical significance was too high to make > sampling meaningful. Wouldn't their "statistical" limitations apply to > the number of dust level samples also?> > I strongly disagree with their anti air sampling statements, based on 30 > years experience in the drug and pharmaceutical aseptic fill, clean room > experience.> > A number of us other " experts" are planning on forming a committee to > develop a consensus standard on clearance of mold remediation projects - > that includes the need for air testing and the science behind it. I > won't go into details at this time. > > > What is the opinion of the members of this forum for the need for > clearance air testing AS PART OF THE Clearance process?> > > BOBFAIR USE NOTICE:This site contains copyrighted material the use of which has not always been specifically authorized by the copyright owner. We are making such material available in our efforts to advance understanding of environmental, political, human rights, economic, democracy, scientific, and social justice issues, etc. We believe this constitutes a 'fair use' of any such copyrighted material as provided for in section 107 of the US Copyright Law. In accordance with Title 17 U.S.C. Section 107, the material on this site is distributed without profit to those who have expressed a prior interest in receiving the included information for research and educational purposes. For more information go to: http://www.law.cornell.edu/uscode/17/107.shtml. If you wish to use copyrighted material from this site for purposes of your own that go beyond 'fair use', you must obtain permission from the copyright owner.

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Bob,

I share your exasperation. I have been to similar conferences with

mostly the same speakers and I think they should all agree to shut-

up until they can learn to be clear and say something meaningful

that can be universally measured with respect to post testing. The

IICRC S520 is worthless because there is no real definition to the

term " fungal ecology " and the problems with negative air pressure.

Only consultants who have run both viable and nonviable air samples

can anwer this question about normal fungal ecology or the " rank

order " by genus or species. Inventing another term just confuses

the confounded who are just trying to learn the right keywords to

market their suspect services.

Let me set y'all on your way. I only agree to air samples since

they are " qualitative " and surface samples are " quantitaive " . The

threat for mold is from inhalation just as the threat from asbestos

is from inhalation. Post testing for asbestos abatement is by air

sampling. Lead testing is done by a wipe method because lead is too

heavy to become airborne for too long.

Anthrax testing was done by surface testing because they were

concerned air pumps would stir the surfaces and spread the

contamination further (according to a CDC or EPA Researcher at a

Washington U grand rounds presentation).

Try this wording that keeps outdoor mold in mind. The terms come

from Aerobiology Laboratory Associates in Reston VA. Other labs may

use slightly different terms:

***********************************************************

The person performing post testing should have a certification for

microbial investigations from an industry recognized organization

such as the American Indoor Air Quality Council, Indoor Air Quality

Association or Indoor Environment Standards Organization. A

certification such as PE, architect or CIH will also be accepted.

This person must use an independent lab to analyze the samples.

The lab must be accredited for environmental microbiology and have

EMPAT scores for at least 2 years or more above 80 percent for

fungi. Considerations may be given for labs with personnel who are

certified through the Pan American Aerobiology Association or have a

PhD microbiologist/mycologist personally view the sample.

The air pump used for air sampling must be clean and calibrated with

a NIST traceable primary calibrator at the end of the tubing where

the factory sealed spore trap cassette will be placed. The air pump

must be calibrated according to the specifications given by the

manufacturer of the factory sealed spore trap cassette. The tubing

for the air pump must be left with the firm performing remediation

for quality control purposes.

Post testing levels for nonviable air samples are no greater than

500 spore/m3 total after basidiospores, ascospores, rusts, smuts,

Myxomycetes, Periconia,clear, clear brown, unknown and hyphal

fragments are removed from the total. Also, there can be no more

than the lowest detection level for Stachybotrys,Memnoniella,

Myrothecium or Chaetomium for the factory sealed, nonviable

cassette being used.

There should not be more than 200 spore ct/m3 of

Penicillium/Aspergillus group unless there are matching

concentrations outside the structure and building leakiness is shown

by the presence of basidiospores, ascospores, rusts, smuts,

Myxomycetes, Periconia, clear or clear brown.

In the event of rain showers within two days of the day of post

testing or during post testing, an outdoor sample can not be taken

since the Penicillium/Aspergillus group count may be artificially

low. In this situation, comparisons for Penicillium/Aspergillus

group counts for indoor and outdoor samples can be decided by taking

outdoor samples on the first day with 3 days of dry weather or by

getting local results from an AIHA EMLAP certified lab for the

specific whatever metropolitan area.

Post testing levels for viable air samples are no greater than 500

cfu/m3 with no more than 200 cfu/m3 of Aspergillus or Penicillium.

Also, there can be no Stachybotrys, Memnoniella, Myrothecium or

Chaetomium present. The viable test is only necessary if there is an

argument about cross-contamination or to verify the outdoor air is

affecting the indoor air to a degree that is not controllable.

In the event of rain showers within two days of the day of post

testing or during post testing, an outdoor sample can not be taken

since the Penicillium and Aspergillus counts may be artificially

low. In this situation, comparisons for Penicillium and Aspergillus

counts for indoor and outdoor samples can be decided by taking

outdoor samples on the first day with 3 days of dry weather or

by getting local results from an AIHA EMLAP certified lab for the

specific Whatever metropolitan area.

In the event building leakiness is shown (by the presence of

basidiospores, ascospores, rusts, smuts, Myxomycetes, Periconia,

clear or clear brown) the rank order of mold in the house should

approximately mirror the rank order of mold in outdoor samples to be

taken at a minimum of 20 feet from the building. The concentrations

in the house should be lower than the concentrations outside

the house.

Two nonviable air samples will be taken outside. The outdoor samples

must be taken facing the wind. Six or more nonviable air samples

will be taken inside the house. Samples will not be taken if visible

dust is detected. It is suggested that the remediation contractor is

responsible for any subsequent post testing if the first post

testing fails to meet agreed goals within reason.

*********************************************************

Notice I have not put a demand for a certificate of insurance for

professional (Errors & Omissions) insurance. That may come later or

if the project warrants the protection.

Other peculiar conditions come from catching a consultant redhanded

with a contaminated pump. This guy works for a large firm who has

something to do with the US Capitol visitor center under

construction. It just goes to show you can't trust anybody farther

than you can watch and verify. It cost me a few thousand to prove

it to the homeowner. It will cost me a few thousand to sue and

recover the lost time and money. I will look forward to the day when

they have to answer for actions.

Regards,

Greg Weatherman

aerobioLogical Solutions Inc.

************************************************************

>

> Steve,

>

> Thank you for your reply and insight. As some of the members

suggested,

> we need to put together our own standard practices for clearance.

All

> of the points you made are excellent and should be considered by

anyone

> evaluating the completion of a mold project.

>

> Yes, the new word they were suggesting is " close out " . I am not

sure

> that everyone agrees with this new term.

>

> Let me know if you are interested in being involved with this

committee.

>

> Bob

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Steve:

Sympathies are certainly in order. I took the State test several weeks ago and passed it (Ibetter lucky than good) somehow.

The training program is in arrears right now, not licensed training providers have been licensed to my knowledge. When licensed however, they will have to provide "something" on post-remediation clearance. They did give up on the specific post-remediation clearance criteria of no more than 30 cts/square inch for surface samples. Yes, I suppose that one set of clearance criteria will be as good as another but it does have to be specific to project being surveyed.

We are all waiting to see how the Texas Department of State Health Services enforces the new regulations.

Stevan

-----Original Message-----From: AirwaysEnv@... Sent: Wednesday, November 17, 2004 11:49 AMTo: iequality Subject: Re: Re: Clearance testingStevan,My sympathies.Does the Texas training program (assuming there is one) and exam for licensing offer guidance on, or require specific knowledge of, clearance criteria?I remember the various iterations of clearance criteria in the proposed/revised legislation. Did the TX DOH finally give up on dictating to professionals how to approve a remediation procedure altogether?Will one set of clearance criteria be just as good as another for regulatory enforcement purposes (i.e., one spore of Stachy in air vs. 100 mg surface dust)?Steve Temes

Overcome by events, as they say.StevanFAIR USE NOTICE:This site contains copyrighted material the use of which has not always been specifically authorized by the copyright owner. We are making such material available in our efforts to advance understanding of environmental, political, human rights, economic, democracy, scientific, and social justice issues, etc. We believe this constitutes a 'fair use' of any such copyrighted material as provided for in section 107 of the US Copyright Law. In accordance with Title 17 U.S.C. Section 107, the material on this site is distributed without profit to those who have expressed a prior interest in receiving the included information for research and educational purposes. For more information go to: http://www.law.cornell.edu/uscode/17/107.shtml. If you wish to use copyrighted material from this site for purposes of your own that go beyond 'fair use', you must obtain permission from the copyright owner.

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Below is a snippet from the Texas Mold Assessment and Remediation Rules concerning clearance testing. The Texas Department of Health does not go so far as to define the clearance criteria but they do require the consultant to spell out what methods will be used and what criteria will need to be met in order to achieve clearance.

-----------------------------------------------------------

(i) Clearance procedures and criteria. In the remediation protocol for the project, the assessment consultant shall specify:

(1) at least one nationally recognized analytical method for use within each remediated area in order to determine whether the mold contamination identified for the project has been remediated as outlined in the remediation protocol;

(2) the criteria to be used for evaluating analytical results to determine whether the remediation project passes clearance;

(3) that post-remediation assessment shall be conducted while walk-in containment is in place, if walk-in containment is specified for the project; and

(4) the procedures to be used in determining whether the underlying cause of the mold identified for the project has been remediated so that it is reasonably certain that the mold will not return from that same cause.

----------------------------------------------------

The state exam for a Mold Assessor Consultant does have some questions about samplers and sampling techniques but did not go into the subject of clearance testing in any great depth.

Phil S.

Re: Re: Clearance testing

Stevan,My sympathies.Does the Texas training program (assuming there is one) and exam for licensing offer guidance on, or require specific knowledge of, clearance criteria?I remember the various iterations of clearance criteria in the proposed/revised legislation. Did the TX DOH finally give up on dictating to professionals how to approve a remediation procedure altogether?Will one set of clearance criteria be just as good as another for regulatory enforcement purposes (i.e., one spore of Stachy in air vs. 100 mg surface dust)?Steve Temes

Overcome by events, as they say.StevanFAIR USE NOTICE:This site contains copyrighted material the use of which has not always been specifically authorized by the copyright owner. We are making such material available in our efforts to advance understanding of environmental, political, human rights, economic, democracy, scientific, and social justice issues, etc. We believe this constitutes a 'fair use' of any such copyrighted material as provided for in section 107 of the US Copyright Law. In accordance with Title 17 U.S.C. Section 107, the material on this site is distributed without profit to those who have expressed a prior interest in receiving the included information for research and educational purposes. For more information go to: http://www.law.cornell.edu/uscode/17/107.shtml. If you wish to use copyrighted material from this site for purposes of your own that go beyond 'fair use', you must obtain permission from the copyright owner.

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,

Apply the same question(s) to air sampling.

Curtis Redington, RS

Environmental Quality Specialist

City of Wichita Dept. of Environmental Health

Wichita, KS

Re: Re: Clearance testing

Being a laboratory person, I would like to know how

surface sampling is conducted for clearance purposes.

A major advantage of surface sampling is that it

targets the source. But how is it conducted to ensure

that the samples taken are a true representative of

the remediated surface? Also, are samples taken from

the same spots before and after remediation and how

are the results compared?

Kung'u, PhD.

Mold & Bacteria Consulting Laboratories (MBL) Inc.

1020 Brevik Place, Unit 1A

Mississauga, ON L4W 4N7

Canada

Tel:

Email: jkungu@...

http://www.moldbacteria.com

--- Cassidy Kuchenbecker

wrote:

>

>

>

> Hello, Steve:

>

> I have to say that I am on the other side of the

> camp by thinking

> that surface sampling is superior to air sampling

> for clearance

> purposes.

>

> Here are just three reasons I prefer surface

> sampling for post-

> remediation verification:

>

> 1. Oftentimes we have found that semi-porous

> materials, such as wood,

> can appear clean and be free of dust (in other

> words, most of the

> spores are removed and the air samples would be

> acceptable), but

> hyphae have been left behind from lack of adaquate

> scrubbing/sanding.

>

> 2. If spot A,B, and C fail a visual or sampling,

> just A,B, and C need

> to be cleaned. If air sampling fails, where does

> the remediator

> start and end??? In this case, surface sampling can

> give very

> straight forward instructions to the remediator.

>

> 3. And the biggie: statistical variability with air

> sampling. I

> don't want to be the one who says the job is done

> when really I just

> wasn't allotted enough funds to take the proper

> amount of samples.

>

> Now I'm not 100% against bioaerosol sampling, we do

> it all time.

> However, given the choice (yes, sometimes the client

> requires air

> samples) I'd choose a good visual assessment and

> surface sampling

> every time.

>

> Cassidy L. Kuchenbecker

>

>

>

> > BOB,

> >

> > I'm not so sure that ALL of the speakers were

> saying that air

> sampling for

> > post-remediation clearance was not necessary. I

> think most of them

> were biting

> > their tongues and deferring to just a few. I

> would be willing to

> bet that

> > those few would do testing themselves every time

> if they were asked

> to clear a

> > remediation project.

> >

> > In my discussions with many of the attendees, it

> was obvious that

> everyone is

> > doing something different when it comes to

> clearance testing and

> > interpretation of the results.

> >

> > Just to keep it short, my opinion is that when

> documentation of

> acceptable

> > performance of a remediation procedure is

> necessary, testing is

> necessary. My

> > preference is to use an aggressive or

> semi-aggressive air sampling

> method(s) to

> > suspend settled spores so that the air sampling is

> reasonably

> representative

> > of as much SURFACE AREA as possible in the

> remediation work area.

> >

> > I don't like surface sampling at all for

> clearance. It ALWAYS

> places the IEP

> > in the position of testing a surface that is

> either more or less

> likely to

> > have been cleaned. S/He is consciously or

> subconsciously trying to

> pass or fail

> > the job. The IEP should not be in this position.

> The testing must

> be

> > objective. I can go into a typical remediated

> work area and find

> one square inch

> > somewhere that will fail. If I go in after

> someone else did

> surface clearance

> > testing and " passed " the job, does that mean the

> first IEP was

> negligent for

> > not finding that one square inch that I did?

> >

> > The only surface sampling I would consider doing

> is if the

> contractors

> > removed the negative air machines and/or scrubbers

> and " let

> everything settle " .

> > This is the time to do surface sampling. Air

> sampling after

> everything has

> > settled seems to me like the wrong thing to do,

> even though it is

> commonly being

> > done.

> >

> > I could go on and on and on. By the way, it isn't

> post-remediation

> > assessment or clearance or verification testing

> any more.

> Evidently, the term of art

> > preferred at the symposium is now " close out " .

> >

> > I share your frustration and agree with you that

> there was a lot of

> avoidance

> > of controversy and " double speak " at the

> symposium. I was not as

> > disappointed as many of the attendees, however,

> because I have come

> to expect nothing

> > else. I spoke to some who attended the

> verification track who

> actually thought

> > they would learn about ways to do clearance

> testing. All I heard

> was one

> > infomercial about one type of surface sampling

> being the only valid

> method.

> >

> > As long as the " ultimate criterion " is the ability

> of the occupants

> to return

> > to the remediated environment without health

> complaints, no matter

> what you

> > do to document that the cleaning was effective,

> someone can just

> SAY they have

> > a problem upon re-occupancy and that trumps all

> your testing anyway.

> >

> > Other than " the usual politics and controversy " , I

> thought it was a

> great

> > conference. I would certainly want to attend the

> next one of its

> kind. I just

> > wish that we weren't forced to choose between so

> many concurrent

> sessions.

> >

> > Steve Temes

> >

> >

> > In a message dated 11/13/2004 10:54:26 AM Eastern

> Standard Time,

> > BobB@s... writes:

> > > I have just returned from the LV Conference

> titled " Advanced

> Perspectives

> > > on Mold Remediation. " It was useful to me

> because I was able to

> get more

> > > information on mold exposure standards from

> other countries to

> update my book.

> > > More importantly

> > >

> > >

> > > There appeared to be significant controversy

> about whether there

> is a " need "

> > > to do clearance air testing.

> > >

> > >

> > > ALL of the " expert " speakers were all saying

> that clearance air

> testing is

>

=== message truncated ===

______________________________________________________________________

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