RE: Re: IEPs

[Guest guest]

For the purpose of educating the remediation contractor, we agreed on the definition of what an IEP entails, but the S520 Mold Standard’s committee never intended telling IEPs how to do their work.

,

I understand the intent and agree. I have no (major) problem with the document for use by contractors. In fact, I like it very much for contractors.

I'm saying that by S520 defining an IEP as someone who can recognize Condition 1, and then defining Condition 1, the document is, de facto, telling an IEP how to do his/her job. I was doing this kind of work before there ever was an "IEP" or a "Condition 1". Now I am one and have to use the term? It is telling me how to do my job. It used to be called "professional judgment". At least we all knew what that meant. We don't know what Condition 1 means, so we'll all just fake it? It's still professional judgment. Why use a term that only confuses everyone and makes people like me feel like I have to declare a situation "Condition 1" and pretend that the term means something? I won't use the term and won't reference the document and will consider S520 to be just good advice for remediators.

My issue isn't with the remediation guidelines, it's simply about the definition of Condition 1 being BOGUS (it defines a concept, not a condition) and that I'm supposed to use the term. If I don't know what it means, I won't. It was a term of convenience when preparing the document. It isn't convenient for me in my practice because it isn't defensible.

Steve Temes

[Guest guest]

Steve and ,

As a taskforce member involving the IEP discussion some years ago, it was not our intention to define for

the IEP industry how they should do their work. For the purpose of educating

the remediation contractor, we agreed on the definition of what an IEP entails,

but the S520 Mold Standard’s committee never intended telling IEPs how to

do their work.

As referenced in the

Standard, the IICRC focus is on remediation contractors and “their”

standards of care. Including advising remediation contractor when an IEP should

be involved with a mold project and what circumstances do they typically find

them self with.

I believe the authority

to write a standard for IEPs is not in the interest of IICRC.

Moffett

From: iequality

[mailto:iequality ] On Behalf

Of AirwaysEnv@...

Sent: Monday, December 11, 2006

3:21 PM

To: iequality

Subject: Re: Re:

Particle Counting for Mold

,

You were either responding to someone else's post or are just missing my point

entirely. For the record, I think the S520 is a great guidance document

for remediation contractors, especially with regard to " coaching

them " on how to minimize their liability exposure. I never said

anything to the contrary.

My very narrow focus was on IEPs and identifying Condition 1. There is a

problem with the IICRC defining (and copywriting) terms that others are

supposed to use and then saying it isn't their job to work out the

details. They created the terms, defined them, and now are leaving the

job of interpreting the inadequate definitions to others.

I do realize that this is a difficult position for IICRC to be in. There

is agreement that there needs to be a line between the contractor and

IEP. The trouble is that sometimes it is a broad, fuzzy gray line that

moves around with the type of project. I'm a real world guy and I get it.

IICRC has started something it can't finish with the definitions of IEP and

Condition 1. Very significant consequences will stem from how these terms

are defined (or not) in S520. If I don't agree with it, I will not use it

or refer to it. If others do the same, the document will lose its

significance and place in the practice of mold remediation. It will still

be good advice for contractors, but that's about all.

You seem to speak with authority on the subject of (toxic) mold but rarely say

anything that leads me to believe that you are not just an entrepreneur with a

PhD which you use to generate business. You have a right to do so in this

country and you certainly aren't alone. On this listserv, that PhD isn't

enough to establish credibility. Please don't confuse your opinions with

facts or your sales pitches with science. Any real facts and science you

would like to bring, and your opinions stated as such, are very welcome.

Steve Temes

In a message dated 12/11/2006 4:22:12 PM Eastern Standard Time, garyrosen72652

writes:

S520 is a set of guidelines for mold remediation

" technicians " . Most AMRT certificate holders were doing water

restoration type of work and they become AMRT certified to make some more money

and branch into mold remediation work.

The S520 guidelines are well suited for their intended audience. Mold

remediation is not rocket science.

By following S520 an AMRT can do a good job cleaning up the mold except for

complex jobs that would need the help of a consultant. Even consumers can

do a good job cleaning up mold using the EPA Mold, Moisture and Your Home

guidelines.

I don't see where all these discussions are going that try to imply that a

technician can't do a good job cleaning up your typical mold problem using S520.

Rosen

Re: Re: Particle Counting for Mold

,

I have had very enjoyable and thought-provoking discussions with Bob s on

the subject. BTW, he cited studies about " normal fungal

ecology " whereas you just said, " In

Canada where there are basements and very tight buildings Normal

means there is some indoor mold growth. Normal

in Florida in

an air conditioned house is no mold growth. But in an older non-air conditioned

house Normal

will be mold growth. " This is merely your unsubstantiated

opinion or assumption.

S520 says that an IEP must be able to identify Condition 1.

" IEP " and " Condition 1 " are both IICRC constructs defined

very poorly for practical application. When I wrote, " How about IEP-CERTIFIED CONDITION 1? " as a term to replace

" CERTIFIED MOLD FREE " , it was my sense of humor dominating the deeply

cynical and jaded side of my character. I wanted to point out how

nebulous and vague (and funny, to me) the term IEP-Certified Condition 1

actually would be (what/who qualifies as an IEP, and what constitutes Condition

1?). It still beats the crap out of CERTIFIED MOLD FREE.

Let's take a look at Condition 1, " normal fungal ecology " , starting

from Condition 3:

Condition 3 -- colonization of a

substrate, mold amplification

Condition 2 -- airborne or

formerly airborne (settled) contaminants which had disseminated from Condition

3 locations

Condition 1 -- anything else.

Those are your 3 choices. Pick one.

This is how I intend to identify Condition 1.

Post-remediation conditions had better be cleaner than Condition 1 because

after Condition 3 and Condition 2, the place ain't normal, by definition.

Thereafter it contains bioaerosols and microbial stuff that people can be

sensitive, or sensitized, to. You can't go backwards from Condition 3 or

2 until you've cleaned up the place. Once it has been cleaned, then it

can return to Condition 1.

Comments anyone?

Steve Temes

In a message dated 12/10/2006 11:48:38 AM Eastern Standard Time,

garyrosen72652@ yahoo.com writes:

Steve,

Bob s BobB@safety- epa.com has

just provided us some very interesting and useful perspective on Normal. Normal depends on many

factors. In Canada

where there are basements and very tight buildings Normal means there is some indoor mold

growth. Normal in Florida in an air conditioned house is no

mold growth. But in an older non-air conditioned house Normal will be mold growth.

The S520 leaves the definition to the professionals involved in the remediation

which is as it should be. Unfortunately Normal in schools throughout the country is

in many cases unhealthful. I don't think that is what they mean by Normal.

Rosen

[Guest guest]

,

As I remember, my first time dealing with

mold problems in a hospital was 1976. The focus of the investigation became the

ventilation system of an almost 100-year-old building. Traditional lab testing

back then was using settling and Rodac plates and swabs. The result was extensive Pen/Asp growing in

the lining of the ventilation system. I don’t remember Stachybotrys being

an issue in this case.

Moffett

From:

iequality [mailto:iequality ] On Behalf Of erikmoldwarrior

Sent: Tuesday, December 12, 2006

11:58 AM

To: iequality

Subject: Re: IEPs

" Moffett " < wrote:

>

> Steve,

> You and I are in the same boat on this.

> My first involvement with testing for mold in hospitals goes back to

about 1976.

>

, was it the unexpected presence of mold itself that called for

testing, or was it an attempt to determine the cause of some

unexplained effects, and if so.

What kind of effects were being observed?

Did you identify Stachy?

-

[Guest guest]

Steve:

I agree with your perception of S520, and your comments. S520 should have focus as a guidance document for environmental contractors cleaning/remediating the presence of mold in common and typical building materials in residential applications. When the scope of S520 “branched out” to describe conditions of mold presence, it began to morph into an assessment document as well, and it tells us IEP’s what the standard of care is. Not good! From my perspective, I foresee conflict. Moreover, I got a kick on S520’s description of Condition 1, and the definition of fungal ecology....”Normal is normal.” This concept in S520 fails based on circular reasoning. I find this frustrating! While I believe S520 is a good document to provide guidance for the remediation contractor, it tried to be too many things, to too many people, for too many situations. S520 is good for the common and typical residential application, in my opinion, and less so for commercial, industrial, and retail applications. I hope S520 can regain its original focus.

For what it is worth...

--

Geyer, PE, CIH, CSP

President

KERNTEC Industries, Inc.

Bakersfield, California

www.kerntecindustries.com

For the purpose of educating the remediation contractor, we agreed on the definition of what an IEP entails, but the S520 Mold Standard’s committee never intended telling IEPs how to do their work.

,

I understand the intent and agree. I have no (major) problem with the document for use by contractors. In fact, I like it very much for contractors.

I'm saying that by S520 defining an IEP as someone who can recognize Condition 1, and then defining Condition 1, the document is, de facto, telling an IEP how to do his/her job. I was doing this kind of work before there ever was an " IEP " or a " Condition 1 " . Now I am one and have to use the term? It is telling me how to do my job. It used to be called " professional judgment " . At least we all knew what that meant. We don't know what Condition 1 means, so we'll all just fake it? It's still professional judgment. Why use a term that only confuses everyone and makes people like me feel like I have to declare a situation " Condition 1 " and pretend that the term means something? I won't use the term and won't reference the document and will consider S520 to be just good advice for remediators.

My issue isn't with the remediation guidelines, it's simply about the definition of Condition 1 being BOGUS (it defines a concept, not a condition) and that I'm supposed to use the term. If I don't know what it means, I won't. It was a term of convenience when preparing the document. It isn't convenient for me in my practice because it isn't defensible.

Steve Temes