Re: IICRC S520

[Guest guest]

Hi Stuart:

I certainly enjoyed meeting you and sharing dinner in Orlando. As I

recall, you'd been performing microbial remediation work for roughly

a year at that time -- is that about right?

You and I would probably agree that for some situations, an honest

and competent contractor can handle the entire process. Even in

cases where the owner could clean things up themselves, that

contractor would say so, and they would offer an appropriate level

of guidance to the owner. Unfortunately, the state rules I

mentioned were created because a number of bad apples spoiled the

situation. This has nothing to do with whether or not you

personally conduct your affairs in an ethical manner.

And I realized that my stated opinion in this matter wouldn't be

popular among remediation contractors. I'm not exactly sure where

those three states draw the line between what constitutes " mold

assessment " as opposed to " mold remediation " because I don't do work

there. I'm pretty sure, however, that they're consistent with the

arrangement I describe immediately below.

My opinion in this matter remains steadfast, but again, not because

I think you're a bad person. I believe that every inquiry from a

property owner should first be directed to a consultant, not a

contractor. And if a contractor receives the initial inquiry, the

caller should be referred to a qualified consultant without

hesitation.

Of course, that consultant needs to be honest and competent, too.

But let's face it, the financial temptation that may lead some down

the path of misconduct either doesn't exist, or isn't nearly as

strong, for the consultant. After all, our part in the overall

effort is rarely 10% of the total cost to the owner.

This perspective is entirely consistent with the message I presented

in my segment of the ASHRAE satellite/web broadcast entitled " Mold

in the Building Environment " (viewed by more than 20,000

participants) in April of last year. I received no disagreement

from you or any other remediation contractor at that time. I urge

you to revisit and listen carefully to that portion of the

broadcast, and see if you don't agree

(http://www.ashrae.org/publications/detail/15205).

I've had, and continue to have, the great pleasure of working with

some fine remediation contractors. And some of them are qualified

to do the consultant's job in some cases.

Finally, calling in a consultant only for verification of your work

is simply poor practice. How can I do a proper job of verifying

that the remediation was complete/adequate if I never saw

the " before picture " ? How can I make comments on your provisions

for, and execution of, containment, filtration and/or

depressurization if I never set foot on site until the work is

complete? How do I know if enough -- or more commonly, too much --

work was done? And finally, how can you expect me to assume (a

portion of) the liability for the overall effort without being

involved throughout? I'd have to charge a pretty steep fee to cover

assumption of that risk.

I try very hard to understand and appreciate the perspective of the

remediation contractor, and I treat them with all due respect. If

you would please, I'd ask you to do the same.

With kind regards,

Wane

<><><><><><><><><><><>

Wane A. Baker, P.E., CIH

Division Manager, Indoor Air Quality

MICHAELS ENGINEERING

" Real Professionals. Real Solutions "

La Crosse, St. , Milwaukee

Phone , ext. 484

Cell

Fax

mailto:wab@...

On the web at: http://www.michaelsengineering.com

" To love what you do and feel that it matters - how could anything

be more fun? "

- Graham

>

> -------------------------------------------------------------------

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

> and as you probably know, it is ILLEGAL in three states for the

same

> firm to perform the assessment work (consultant' s job) and the

> remediation work (contractor' s job) on the same project. because

of

> the underlying conflict of interest, this just makes sense! those

> who continue to sell themselves as a turn-key operation (including

> assessment, remediation AND post-remediation verification) are,

IMO,

> the bane of this industry.

> -------------------------------------------------------------------

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

>

> Wane,

>

> I agree with you as far as post remediation verification goes

but do you really think that ALL mold jobs require a seperate

consultant to do an assesment? Do my clients with mold in their

crawlspace need to call a consultant to tell them that they have

mold because its 75% rh in July in NC and their AC ducts have

condensation? Surely the whole " remediator cant asses " situation

cant be a blanket statement?

> And to say that if I give an " assesment " Im unethical because Im

only a CMR but Im ethical if I only do remediation is, quite

frankly, insulting. Im either an ethical person or Im not. And you

can only tell that but the quality of the work I do and service I

provide, not what I do. Using that standard would mean that Im not

qualified to run the research lab that I do because I dont have a

PhD. Or a Ms. Or even a BSc. I have a GIBiol... And yet the people

who hired me to run their lab are more than satisfied with the

results Im producing, the progress Im making and the value Im adding

to their product. Its my experience that counts. And I will readily

agree that you and many others here are way more experienced than I

am and I will bow to your superior knowledge. But Im perfectly

qualified to figure out a lot of things moldy. And if I cant, then

I'll call in someone who can. The team approach is just fine by me.

As long as the job gets done properly and the client is

> satisfied.

>

> Stuart McCallum

[Guest guest]

Note: forwarded message attached.

Get your own web address for just $1.99/1st yr. We'll help. Yahoo! Small Business.

Dear Mr. Baker ( & Dr. Tang): I thoroughly enjoyed your "soapbox"! IMHO, we need more of these conversations on this post and within our Industry. Perhaps, it's due to all my studies in Political Science and Philosophy (though, I admit, I failed miserably in Underwater Basket Weaving) that I see the need to step up and join you on the "Soapbox" and contribute some of my own thoughts and observations. (And why I know my place is on the remediation side of the street!). Gentlemen of your stature and those who post regularly on this board are by far and away the most qualified to assess IEQ problems and offer the necessary guidance and recommendations that will address these issues and provide the corresponding solutions. However, many homeowners can't or won't pay the fees your truly qualifed firms require. I also know

of Consultants who won't do work in the residential field due to their aversion of checks made of rubber and the subsequent chase for their money. Thus, a vacuum was created, especially in the residential market, and to fill the (redhot) demand, many less qualifed firms and individuals, along with correpsonding training programs and companies (which are often affiliated with labs and/or contractors), jumped into the marketplace so as to fill this void. As a result, we now have the situation you describe as "the bane of our industry", in which I concur. (I'm curious though: Besides Louisiana and Texas, which is the third State that has outlawed this practice? I know Florida was moving in that direction, but the Bill never made it out of it's sponsoring Committee this year). We need, as an Industry, to continue to educate our lawmakers and

push for sensible legislation. However, as an Industry, we also need to get behind S-520, even with some of it's ambiguities, (remember, it's still a living document) and encourage it's adoption and practice by everyone concerned about IEQ, including the separation of duties and responsibilities of the Consultant and the Remediation Contractor, and where and when to draw that line. This is a debate that needs to be brought up loud and clear until our lawmakers notice and take the appropriate actions. On the flip side of the equation, though, I would encourage you to read Mr. Bos, CR, CMR thought provoking three part article "The Secret to our Mold Remediation Success" published in ASCR's Cleaning and Restoration magazine, June, July & Aug., 2006. He seems to be following a strict quality control post remediation verfication standard developed by Mr. Pinto, PH.D., CMP, Mike

and Sara Eager, which in itself was published in an article entitled "Mold Clean-Up Projects" in the Nov. 2004 issue of ASSE's Professional Safety. Perhaps this clearance criteria would be a good starting point for the definition of "Returned to Condition 1", though that's a subject better left for you truly qualified IEP's to work out. In either event, I believe the time for this debate is long overdue and as a result of our silence many a consumer has suffered the consequences. If our Industry is to move forward in terms of both respectablity and significance in the American and Global Marketplace, then we need to establish, maintain and enforce ethical guidelines that will encourage the current crop of Snake Oil salesman to either get in line or find another occupation. (By the way, there is another type of snake out there

negatively impacting our Industry, even more insiduous and dangerous then those you refer to as the "Bane", a snake who I refer to as the "Charlatan", but their description and practices I will keep to myself at the moment, though they know who they are). I stand down, for now... Pete Carkhuff, ASCS, WRT "Wane A. Baker, P.E., CIH" wrote: Hi Dr. Tang:you bring up several excellent points, and a couple that I must respectfully amend, regarding this process. (beware: soapbox ahead)1. conditions/density: the density of microbial growth must be determined MACROSCOPICALLY (i.e., visually), but only once we understand what's happening at the microscopic level. that's why our graduate microbiologist continues to study fungal ID as part of his Master's program, and why we bring an Olympus CH-2 scope to the site. 2. there is no way any lab can "make the call" RE: density and extent based on a few samples. it's up to the consultant to combine on-site microscopy (or lab analysis) with thorough field observations in order to make this determination. 3. health concerns/conditions: this is the biggest reason why industrial hygienists migrated into work with wet buildings. let's face it, the term "industrial hygiene" has

out-lived its usefulness. IHs are HEALTH & SAFETY professionals, and the "industrial" part of that title needs to be changed. a few folks on this list still don't get it, but health & safety concerns -- and solutions! -- are applicable to ALL settings: industrial, occupational, and residential. 4. costs: "how much...will be spent" is topic for another day's discussion. [bEGIN SOAPBOX]and yes, TRULY QUALIFIED consultants should be coordinating the overall effort by defining the required scope of work, overseeing the activities of the remediation contractor, and providing verification. to be clear, by "truly qualified" I'm talking about someone with the appropriate education, training and experience needed to understand this complex field of study. e.g., an undergrad in political science, philosophy, or underwater basketweaving just doesn't cut the mustard when we're dealing with the

health of children in our schools or in their homes. and as you probably know, it is ILLEGAL in three states for the same firm to perform the assessment work (consultant's job) and the remediation work (contractor's job) on the same project. because of the underlying conflict of interest, this just makes sense! those who continue to sell themselves as a turn-key operation (including assessment, remediation AND post-remediation verification) are, IMO, the bane of this industry. [END SOAPBOX]with my regards, Wane<><><><><><><><><><><> Wane A. Baker, P.E., CIH Division Manager, Indoor Air Quality MICHAELS ENGINEERING"Real Professionals. Real Solutions" Phone , ext. 484 Cell Fax mailto:wabmichaelsengineering On the web at: http://www.michaelsengineering.com "To love what you do and feel that it matters - how could anything be more fun?" - Graham >> I agree that IICRC 520 is written for mold remediator, and we do have to work with all professionals to make it a feasible "standard". Those four (or maybe more) factors shall determine how the remediation job will be performed. > > (1) Conditions/Density:> The only way to determine the 3 conditions (normal fungal ecology, settled spores, actual mold growth) and the mold population density (NOT IICRC S520 terms: high, medium, low, etc.) is to examine the samples under a

microscope. The consultants/contractors can not do it without using a microscope plus years of training. The labs have to make the call on those. > > > (2) Extent:> The assessment of the extent (size/area) of mold growth is done by consulants' building inspection. The labs or the contractors can not do that. There is big difference between a 1-2 square inch (that's all the lab can see) and a 10 square foot of "actual mold growth". > > (3) Individual health conditions> The consultants will have to determine the probable cause (only when necessary and capable) for the compliants and the necessary final acceptable condition according to the occupants' health conditions. A "normal fungal ecology" might be fine for many people, but not for some sensitized individuals. > > (4) Cost> The buliding owner, manager, insurance company, etc. will determine how much

cost will be spent on the remediation. > > IMHO, the consultants should have most of the saying in determining the remediation scope. We just need to have the common language "defined" so the contractors can follow the scope better, or if there is anything discovered during the remediaiton, contractors can communicate with consultants more efficiently. > > Wei Tang> QLAB>

Talk is cheap. Use Yahoo! Messenger to make PC-to-Phone calls. Great rates starting at 1¢/min.

[Guest guest]

----------------------------------------------------------------------------------------------------------------- Hi Stuart: I certainly enjoyed meeting you and sharing dinner in Orlando. As I recall, you'd been performing microbial remediation work for roughly a year at that time -- is that about right?You and I would probably agree that for some situations, an honest and competent contractor can handle the entire process. Even in cases where the owner could clean things up themselves, that contractor would say so, and they would offer an appropriate level of guidance to the owner. Unfortunately, the state rules I mentioned were created because a number of bad apples spoiled the situation. This has nothing to do with whether or not you personally conduct your affairs in an ethical manner. And I realized that my stated opinion in this matter wouldn't be popular among remediation contractors.

I'm not exactly sure where those three states draw the line between what constitutes "mold assessment" as opposed to "mold remediation" because I don't do work there. I'm pretty sure, however, that they're consistent with the arrangement I describe immediately below. My opinion in this matter remains steadfast, but again, not because I think you're a bad person. I believe that every inquiry from a property owner should first be directed to a consultant, not a contractor. And if a contractor receives the initial inquiry, the caller should be referred to a qualified consultant without hesitation. Of course, that consultant needs to be honest and competent, too. But let's face it, the financial temptation that may lead some down the path of misconduct either doesn't exist, or isn't nearly as strong, for the consultant. After all, our part in the overall effort is rarely 10% of the total cost to the owner.

This perspective is entirely consistent with the message I presented in my segment of the ASHRAE satellite/web broadcast entitled "Mold in the Building Environment" (viewed by more than 20,000 participants) in April of last year. I received no disagreement from you or any other remediation contractor at that time. I urge you to revisit and listen carefully to that portion of the broadcast, and see if you don't agree (http://www.ashrae. org/publications /detail/15205). I've had, and continue to have, the great pleasure of working with some fine remediation contractors. And some of them are qualified to do the consultant's job in some cases. Finally, calling in a consultant only for verification of your work is simply poor practice. How can I do a proper job of verifying that the remediation

was complete/adequate if I never saw the "before picture"? How can I make comments on your provisions for, and execution of, containment, filtration and/or depressurization if I never set foot on site until the work is complete? How do I know if enough -- or more commonly, too much -- work was done? And finally, how can you expect me to assume (a portion of) the liability for the overall effort without being involved throughout? I'd have to charge a pretty steep fee to cover assumption of that risk. I try very hard to understand and appreciate the perspective of the remediation contractor, and I treat them with all due respect. If you would please, I'd ask you to do the same. With kind regards, Wane <><><><><><> <><><><>< > Wane A. Baker, P.E., CIH Division Manager, Indoor Air Quality MICHAELS ENGINEERING"Real

Professionals. Real Solutions" La Crosse, St. , MilwaukeePhone , ext. 484 Cell Fax ---------------------------------------------------------------------------------------------------------------- Wane, I do have the utmost respect for all experienced, knowledgable and well qualified people in all professions. Im guessing that you saw my "bow to your superior knowledge" remark as sarcasm. It was in fact a sincere comment. I've spent too many years in science working with incredibly smart people to think that I know it all. I am all too aware of my own limitations. But the flip side of that is that I am also confident in my own abilities. And if I get a call that I can help with then Im not going to turn them away just because Im not a "consultant" (unless legally restricted of course). My experience and knowledge

may be different but its just as valid. In the lab I design, perform and interpret my own experiments. But if the experiment I require/design requires techniques and experience I dont have then I'll find it elsewhere. I'm not going to avoid doing the experiment just because of that. If I did that then Id never need to learn anything new. I know I can learn a lot from you and hope I might get a chance to do so again in Nashville. But Im also sure you could learn something from me. Thats the way life works. All I can tell you is that Im an honest and ethical person with no desire to sell myself with false claims. If I wanted to make money illegally or unethically then I wouldnt do it by mold removal... *grin* I guess we'll need to agree to disagree on this. As for your comments on verification - full verification (oversight) would require that someone observes every single aspect of a job to ensure compliance and to observe the quality and details of

the work in progress. Thats unrealistic. The more realistic answer is auditing. After all, thats the way the FDA makes sure that manufacturers comply with quality regs. Its an established method of process investigation. Complete oversight would suggest a lack of trust or confidence in the contractor. But if detailed records are kept by a responsible and ethical contractor then it should be a relatively simple job to investigate the quality and effectiveness of the work performed. On an additional note - if there are any IAQ professionals and HVAC professionals on here who work in the NC Triangle area I would appreciate hearing from you. So I have some names to recommend for those peopleI cant help. Stuart McCallum

[Guest guest]

Wane,

The restaraunt was the " Clambake " at the yachtclub hotel on Disney's

property in Orlando. This is not a place for a weak appettite.

I have a middle of the road way to address Stuart's question and

your concerns. The state of Virginia has a conflict of interest

form for all parties to sign for asbestos or lead abatement work:

http://www.state.va.us/dpor/forms/asb/33adis.pdf

This is the first step for these situations where the contractor can

write a scope of work based on investigation to whatever extent. I

am not saying complex situations should be done this way - just

simple situations.

The next important thing to address is liability. If the contractor

does not have adequate professional (errors & omissions) insurance,

thney absolutely must have a consultant direct them.

I do not think there are enough qualified consultants for all the

residential jobs on the eastern seaboard. Most consultants will not

touch a residential job with a ten foot pole. I think residential

is more complex as far as the way they are typically built versus a

highrise with concrete and steel. The dilemna is the sheer

numbers. Contractors have got to get more education and prove it in

a closed book exam like the CMRS offered by AMIAQ. I have taken the

CMC test. I do not know what the CMRS test is like yet.

I am a firm believer that contracts should spell everything

including post testing goals and independent testing by someone with

no finacial interest or subcontracting. Even test methods should be

addressed in the contract. I will not allow tape lift samples when

I perform remediation. Surface samples must be taken over a square

foot or more by swab or vacuum methods. I apply the same reasoning

to any surface sampling that is meant to be qualitative.

I know I put myself in harm's way legally but, I'm insured to the

hilt and I document. Customers can call anyone else to verify.

This is the only way to get the cost down for the average

homeowner. We can not let unscrupulous people ruin it for

everyone. If they can't get the insurance, they should not get the

job. I market my professional insurance and the fact the others

have no insurance or the wrong coverage. My customer get a

certificate of insurance from me and that keeps me honest.

The only way to clean the industy is to license at the state level

those that have the proper certifications and disclose any conflicts

of interest in writing. The Washington DC area probably has more

industrial hygienist (CIH & IH), PEs, MPHs and other consultants

compared to anywhere else in America. If we don't have enough to go

around, imagine the problem anywhere in America especially after

flooding. I suppose there are always some small town to rural areas

in the west or deep south that have the numbers due to low

population density.

Does this help any?

Regards,

Greg Weatherman

aerobioLogical Solutions Inc.

Arlington VA 22202

gw@...

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

>

> -------------------------------------------------------------------

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

> Hi Stuart:

>

> I certainly enjoyed meeting you and sharing dinner in Orlando. As

I

> recall, you'd been performing microbial remediation work for

roughly

> a year at that time -- is that about right?

>

> You and I would probably agree that for some situations, an honest

> and competent contractor can handle the entire process. Even in

> cases where the owner could clean things up themselves, that

> contractor would say so, and they would offer an appropriate level

> of guidance to the owner. Unfortunately, the state rules I

> mentioned were created because a number of bad apples spoiled the

> situation. This has nothing to do with whether or not you

> personally conduct your affairs in an ethical manner.

>

> And I realized that my stated opinion in this matter wouldn't be

> popular among remediation contractors. I'm not exactly sure where

> those three states draw the line between what constitutes " mold

> assessment " as opposed to " mold remediation " because I don't do

work

> there. I'm pretty sure, however, that they're consistent with the

> arrangement I describe immediately below.

>

> My opinion in this matter remains steadfast, but again, not

because

> I think you're a bad person. I believe that every inquiry from a

> property owner should first be directed to a consultant, not a

> contractor. And if a contractor receives the initial inquiry, the

> caller should be referred to a qualified consultant without

> hesitation.

>

> Of course, that consultant needs to be honest and competent, too.

> But let's face it, the financial temptation that may lead some

down

> the path of misconduct either doesn't exist, or isn't nearly as

> strong, for the consultant. After all, our part in the overall

> effort is rarely 10% of the total cost to the owner.

>

> This perspective is entirely consistent with the message I

presented

> in my segment of the ASHRAE satellite/web broadcast entitled " Mold

> in the Building Environment " (viewed by more than 20,000

> participants) in April of last year. I received no disagreement

> from you or any other remediation contractor at that time. I urge

> you to revisit and listen carefully to that portion of the

> broadcast, and see if you don't agree

> (http://www.ashrae. org/publications /detail/15205).

>

> I've had, and continue to have, the great pleasure of working with

> some fine remediation contractors. And some of them are qualified

> to do the consultant's job in some cases.

>

> Finally, calling in a consultant only for verification of your

work

> is simply poor practice. How can I do a proper job of verifying

> that the remediation was complete/adequate if I never saw

> the " before picture " ? How can I make comments on your provisions

> for, and execution of, containment, filtration and/or

> depressurization if I never set foot on site until the work is

> complete? How do I know if enough -- or more commonly, too much --

> work was done? And finally, how can you expect me to assume (a

> portion of) the liability for the overall effort without being

> involved throughout? I'd have to charge a pretty steep fee to

cover

> assumption of that risk.

>

> I try very hard to understand and appreciate the perspective of

the

> remediation contractor, and I treat them with all due respect. If

> you would please, I'd ask you to do the same.

>

> With kind regards,

>

> Wane

>

> <><><><><><> <><><><>< >

> Wane A. Baker, P.E., CIH

> Division Manager, Indoor Air Quality

> MICHAELS ENGINEERING

> " Real Professionals. Real Solutions "

> La Crosse, St. , Milwaukee

>

> Phone , ext. 484

> Cell

> Fax

> -----------------------------------------------------------------

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

>

> Wane,

>

> I do have the utmost respect for all experienced, knowledgable

and well qualified people in all professions.

> Im guessing that you saw my " bow to your superior knowledge "

remark as sarcasm. It was in fact a sincere comment. I've spent too

many years in science working with incredibly smart people to think

that I know it all. I am all too aware of my own limitations. But

the flip side of that is that I am also confident in my own

abilities. And if I get a call that I can help with then Im not

going to turn them away just because Im not a " consultant " (unless

legally restricted of course). My experience and knowledge may be

different but its just as valid. In the lab I design, perform and

interpret my own experiments. But if the experiment I require/design

requires techniques and experience I dont have then I'll find it

elsewhere. I'm not going to avoid doing the experiment just because

of that. If I did that then Id never need to learn anything new. I

know I can learn a lot from you and hope I might get a chance to do

so again in Nashville. But Im also sure you could learn

> something from me. Thats the way life works. All I can tell you

is that Im an honest and ethical person with no desire to sell

myself with false claims. If I wanted to make money illegally or

unethically then I wouldnt do it by mold removal... *grin* I guess

we'll need to agree to disagree on this.

> As for your comments on verification - full verification

(oversight) would require that someone observes every single aspect

of a job to ensure compliance and to observe the quality and details

of the work in progress. Thats unrealistic. The more realistic

answer is auditing. After all, thats the way the FDA makes sure that

manufacturers comply with quality regs. Its an established method of

process investigation. Complete oversight would suggest a lack of

trust or confidence in the contractor. But if detailed records are

kept by a responsible and ethical contractor then it should be a

relatively simple job to investigate the quality and effectiveness

of the work performed.

>

> On an additional note - if there are any IAQ professionals and

HVAC professionals on here who work in the NC Triangle area I would

appreciate hearing from you. So I have some names to recommend for

those peopleI cant help.

>

> Stuart McCallum

>

[Guest guest]

Greg,

You stated in your post, " I will not allow tape lift samples when I

perform remediation. Surface samples must be taken over a square foot

or more by swab or vacuum methods. I apply the same reasoning to any

surface sampling that is meant to be qualitative. "

Could you elaborate a little more on your reasons for not allowing tape

lifts and why you prefer swab/vacuum methods.

[Guest guest]

Bob/Ma.

The carrier decides how much they will spend in our state in almost all cases without our input unless an attorney is involved.

The carrier has negotiated rates with affiliate companies that will do the job for whatever the insurance company decides to pay.

The carrier almost always recommends non-licensed, non-insured and non-certified firms to do the work in order to keep their cost down. This is not the case in some other states like CA but it is the case here.

The only way to compete in this state is to provide turn key services including construction for which there is limited competition due to the licensing, financial worth and insurance requirements for construction work ... none of which are required for testing or remediation.

Rosen

www.Mold-Books.com

IICRC S520

Pete:You stated: “ The reason for my suggestion is simple; it (IICRC S520) is the current Industry Standard of Care...” Well, yes and no. IICRC S520 may be the current Standard of Care only because it is the most recent mold guideline to be published. In the past 5 years, I have seen over 20 reference/guidance documents pertaining to mold assessment and/or remediation published. Each one claiming to be the Standard of Care, or Best Industry Practice. Your statement, and the plethora of mold documents exemplify the confusing, miss-guided, shot-gun effect of the mold industry.... ..it is a free-for-all. As to your statement that one has to be able to defend their actions “as they relate to this (IICRC S520) document,”... ..well, time

will tell won’t it! The ink has not dried on S520 sufficiently to have any effect in current litigation. Moreover, it will be confusing as hell for any jury to wade through all the competing documents and compelling arguments by attorneys, and try to make an informed decision regarding just who best represents a Standard of Care. This represents a real and significant problem of the mold industry.... excluding the EPA and OSHA, how does an attorney sort the hierarchy of anarchy between competing organizations, all trying to represent the state of the art, e.g., AIHA, ASTM, ANSI, BOMA, IICRC, NIBS, ASHRAE, etc., etc. The lack of consensus and over-whelming zeal of one-upmanship, is counter productive, because it dilutes and confuses everyone’s message. It bodes an ill-wind for the mold industry in general.IMHO...IICRC S520 only represents a Standard of Care until the next organization’ s mold guidance document is published.

Moreover, IICRC significantly reduces the effectiveness of S520 by charging a hefty fee for it, and attempts to glean a profit from it.For what it is worth....On 2/3/07 4:55 AM, "Pete Carkhuff" <cincinnatussc@ yahoo.com> wrote:

Good Day, Mr. Brown: I believe it's time to attempt to set the record straigtht in regards to various quotes attributed to IICRC S520, "Standard and Reference Guide for Professional Mold Remediation" for the simple fact that 1). I like it and don't believe that it should be misquoted and have portions taken out of context 2). it has become the "de facto" Standard Nationally for Professional Mold Remediation (emphasis on the word Professional! ). Though it's not a perfect document, it is a Living Document, subject to change and revision as our knowledge in this field increases. I would suggest that anyone and everyone who is a party in a Mold Remediation project, be they a Consultant or a Contractor (or who train's folks in this field), make the investment and purchase a copy. I believe a revision attempting to achieve ANSI

criteria is scheduled for print shortly. The reason for my suggestion is simple; it is the current Industry Standard of Care, and should you ever find yourself in Court, you had better be able to defend your decisions and actions as they relate to this document. It is a sad commentary on our Industry, though, when I have to keep referring back to "my favorite section", Section 4.2.1, Assessment, as opposed to say, Section 7.3.2, Highly Recommended Documentation or Section 10.2, Source Control, Isolation Barriers and Containments. Section 10, Structural Remediaiton is, at least for a Remediation Contractor, the meat of this document and I personally would prefer it if we could as a Professional IEQ Quality Group discuss the merits and drawbacks on this and other "meatier" sections, and how we can improve upon them. Yet, we are where we are. So, for those who have yet purchase a copy or have yet to see Section 4.2.1,

here goes: 4.2.1 Assessment "When a preliminary determination indicates that mold contamination (as defined in S520) existos or is likely to exist, it is highly recommended that an assessment (as defined in S520) be performed prior to starting remediation. It is highly recomended that an independent IEP with no business affilitation to the remediatior be used for this purpose. In circumstances where an entire building or system is fully involved as a result of Conditon 3 mold contamination or when the scope of work can be determined without sampling or indepedent IEP inspection and assessment, engagement of an IEP for assessment may not be necessary. Furthermore, some loss mitigation services may be initiated before or during assessment of conditions and/or performance of remediation processes. Notwithstanding the foregoing, if health issues are discovered or apparent that seem to be related to the actual or

suspected mold contamination, it is highly recomended that an IEP or other appropriate professional be engaged by the property owner." Now, Mr. Brown, in States such as Texas , where Law and Regulations exist in this domain, I would suggest one replace the words "highly recommended" with the word "must". Some more quotes, if I may. On page "31", we find Section 13, Post Remediation Verification. "Following post-remediation evaluation by the remediator,, including application of internal quality control procedures, verification of a return to Coditon 1 status may need to be determined by sampling and testing, and, if so, it is highly recommended that an independent IEP conduct or oversee that process." Section 15, Indoor Environmental Professional "The role of an IEP is to perform an assessment of the fungal ecology of property, systems and

contents at the job site, create a sampling strategy, sample the indoor environment, interpret laboratory data and determine Conditon 1, 2 and 3 status for the purpose of establishing a scope of work (pre-remediation assessment) and/or when necessary to verify the return to normal fungal ecology" Some more quotes from this section; "S520 provides general guidance or when to engage the sevices of an IEP. It recognizes that limited, surface or trace mold growth may not constitute enough contamination to require the services of an IEP, and that more extensive mold growth or uncertainty with regard to the extent of mold contamination gnerally will require the sevices of an IEP. Deciding if and when an IEP is required on any mold remediation project is subject to the sound professional judgement of the remediator or other materially interested party on a case-by-case basis. Although an IEP is not necessary on

every mold remediaiton project, there also are projects on which an IEP is essential. Deciding upon the amount of mold contamination that necessitates using an IEP is both a science and an art, which must be determined with care." Mr. Brown, I believe the above quotes go a long way in support of your previous post. Nowhere does this document recommend that a Remediator act as his own IEP. In fact, it recognizes the inherent "conflict of interest" in Section 4.2.1 with the sentence, "It is highly recommended that an independent IEP with no business affilitation to the remediator be used for this purpose." I would also like to point out that the IAQA is a Contributing Organziation for the publication of this extraordinary document. The problem is with enforcement. However, I agree that this is the direction that our Industry is going, and must continue to go, either voluntarilly by those

engaged in these services or by Regulation and the Courts. As always, I remain... at your service. Sincerely, Pete H. Carkhuff, ASCS, WRT

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